What is the difference between a private sale and a public sale?

In their reply brief, plaintiffs argue for the first time that the issue is not between private sale and "public auction," but between private sale and "public sale," meaning any sale that has been publicly advertised. Plaintiffs argue that the procedure carried out here was a "public sale," and thus the sale violated the court's order for a private sale. However, this is not the argument made in plaintiffs' opening brief, which specified " 'public auction.' " We disregard new points raised for the first time in a reply brief. (Reichardt v. Hoffman (1997) 52 Cal.App.4th 754, 763-766.)