Now -- MS. HARDMAN: Counsel, in the petitioner's reply on page nine, there's a statement that a POSITA would understand the portion of the interior of Gravesen's housing shown in its figures to be an alcove and thus a recess.
But since they made this argument in their response in our reply, Dr. Fletcher explained in his supplemental declaration at length why POSITA would have naturally combined that push rod with the Gravesen embodiment.
Patent 10,945,649 B2 acknowledged the fact that Petitioner's POSITA is a college grad with one year of design experience, and they were doing a complete refabrication of the Gravesen combination of figures 1 and 9, which already started off with 10 substitutions or deletions.
The -- like this started with the last point the cylindrical shape and counsel properly said under Phillips we look at the intrinsic record, but patent owner continues to run from its own specification and the 1300 embodiment.
It was saying you have a skilled artisan read Yodfat in one room, walks down the hall and tells their friends, say, hey, this reference uses a circular, centrally located, recessed rotor.