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Other patents were temperature-sensor based; Sergi's was pressure- sensor based; and CTR claims to be even quicker in detection. The ISA report notes that none of the previous patents had all these features in combination. The Differential Relay, the Buchholz Relay and the Circuit Breaker are all integers in transformer safety device design that are central to the present dispute.

19. In paragraphs 13 and 16 of the Plaint, CTR says that the fundamental features of its patent are these:

27 of 103 NMS-497-14-CTR-V-SERGI-F02.DOC the material, CTR's Patent cannot possibly provide any reduction in detection time at all. The patent itself is vulnerable, he says.

22. CTR's complete specification40 sets out what, according to it, is the 'prior art', including in Sergi's Indian Patent No.189089. That patent uses a pressure sensor as a means for detection. Other patents are also explained. According to CTR, all these use 'pressure means'. These, CTR claims, come late in time sequence after much damage is done; specifically 'tearing'. None of them, it says, teaches a system or method to detect or prevent tearing without delay, before it occurs. CTR's system is said to operate before the coolant oil's decomposition. Specifically, it claims that its system is 'devoid of pressure sensors, temperature sensors or vapor sensors'.