I know that the parties try to bring in some of this for secondary considerations, so my understanding is that Patent Owner is using this deposition that we're looking at for the proposition that the combined device of Westerkull and Choi would not have a flange that's adapted to rest on the bone, and I wanted to get your reaction to that.
In terms of, you know, the specific number, we haven't made some requirement of physically combining a 2 millimeter relieving portion of Choi and just kind of squeezing that into this region, you know, a person of ordinary skill in the art would recognize that there are some dimensional constraints, but in terms of the issue of obviousness, we've focused on the issue of obviousness of combining the teachings of these minute grooves the institution decision referred to, I believe at page 8, incorporating some minute grooves on top of this threaded portion, so as to provide the benefits as described in Choi, and is detailed in the institution.
There's a little bit of a delay, but so Mr. Batts, I apologize for interrupting, but I would like to turn, it's actually a follow-up question that Judge Worth had earlier regarding the circumferential grooves, and if I could direct you to let's look at Choi, Exhibit 1005, the first paragraph in column 9.
So the evidence that Patent Owner is solely relying on recognized that this is taking something that has been done in dental implants and merely applying that to the skull bone anchor or -- and again, some of this can be characterized as intended use even if it's considered a limitation, even if the issue is physical combinability, there's no recognition that the POSA would have been deterred by the fact that there is different
It specifically refers to inserting there into the roots of the main screw threads, and I think it makes sense because these are perhaps larger gaps relative to other perhaps areas like a miniature groove that might have difficulty contacting bone tissue or integrating with bone tissue, so again, this is a feature that there is really in the context of the claim, there's no establishment of the criticality, and we think the references clearly teach and suggest that you vary the surface roughness based on the particular conditions and based on the particular region of the implant that you're concerned with.