Marjac, Absolutely brilliant. You explained things so clearly that anyone who listened should have been able to follow. I don't see how any of the panel members could disagree with your view on timeliness. Sleven,
You easily handled/distinguished the Starr case, rather casually brought up by Judge Dyk, notwithstanding it had not been cited in either brief. Am happy you and I had an opportunity to discuss why the dicta in Starr did not apply a week or so before your argument.
"Thanks for the feedback on Starr. It was not cited in either side's Briefs, but I can see the Court asking about it during oral argument."