`
`
`
`PAUL J. ANDRE (State Bar No. 196585)
`pandre@kramerlevin.com
`LISA KOBIALKA (State Bar No. 191404)
`lkobialka@kramerlevin.com
`JAMES HANNAH (State Bar No. 237978)
`jhannah@kramerlevin.com
`KRISTOPHER KASTENS (State Bar No. 254797)
`kkastens@kramerlevin.com
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`
`Attorneys for Plaintiff
`FINJAN, INC.
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF CALIFORNIA
`SAN FRANCISCO DIVISION
`
`
`Case No.: 3:17-cv-05659-WHA
`
`PLAINTIFF FINJAN, INC.’S MOTION
`FOR LEAVE TO SUPPLEMENT ITS
`INFRINGEMENT CONTENTIONS
`
`Date: August 22, 2019
`Time: 8:00 a.m.
`
`Judge: Hon. William H. Alsup
`
`
`
`
`
`
`FINJAN, INC., a Delaware Corporation,
`
`
`
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`
`
`Plaintiff,
`
`v.
`
`
`JUNIPER NETWORKS, INC., a Delaware
`Corporation,
`
`
`
`
`
`
`Defendant.
`
`REDACTED VERSION OF DOCUMENT SOUGHT TO BE SEALED
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`FINJAN’S MOTION FOR LEAVE TO SUPPLEMENT
`INFRINGEMENT CONTENTIONS
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`NOTICE OF MOTION
`TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
`NOTICE IS HEREBY GIVEN that on August 22, 2019 at 8:00 a.m., or as soon thereafter as
`counsel may be heard by the Honorable William Alsup in Courtroom 12, 19th Floor, United States
`District Court, 450 Golden Gate Avenue, San Francisco, CA 94102, Plaintiff Finjan, Inc. (“Finjan”) will
`and hereby does move the court for an order granting Finjan leave to supplement its infringement
`contentions which were provided to Defendant Juniper Networks, Inc. (“Juniper”) on June 25, 2019.
`This motion is based on this Notice of Motion, the following Memorandum of Points and Authorities,
`the Declaration of Kristopher Kastens (“Kastens Decl.”), the proposed order submitted herewith, the
`pleadings and papers on file in this action, any evidence and argument presented to the Court at or
`before the hearing on this motion, and all matters of which the Court may take judicial notice.
`STATEMENT OF ISSUES
`Whether Finjan should be granted leave to supplement its Infringement Contentions for the ’154
`Patent based on the Court’s claim construction.
`MEMORANDUM OF POINTS AND AUTHORITIES
`INTRODUCTION
`The Court should grant Finjan’s leave to supplement its Infringement Contentions for the U.S.
`Patent No. 8,141,154 (the “’154 Patent”) pursuant to Local Patent Rule 3-6, based on the Court’s recent
`construction of the phrase “a content processor” that was different from the construction put forward by
`Finjan. Finjan’s proposed supplemental infringement contentions is attached hereto as Ex. A, where
`Finjan has added only a single paragraph to its contention for each accused product and an update to
`Finjan’s Doctrine of Equivalents (“DOE”) theory to address the new construction of “content processor”
`at issue in the Court’s Claim Construction Order. See Ex. A1 (Appendix E-1) at 10-12, Ex. A (Appendix
`E-2) at 7-9, Ex. A (Appendix E-3) at 9-11. Patent Local Rule 3-6 specifically provides that Finjan has
`good cause for such a supplementation because the Court entered a claim construction “different from
`
`I.
`
`
`1 Unless otherwise noted, all exhibits to this motion are attached to Declaration of Kristopher Kastens,
`filed herewith.
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`that proposed by the party seeking amendment.” Additionally, Finjan has good cause to supplement its
`infringement contentions because Finjan could not have addressed the construction earlier, as the
`construction issued by the Court was not proposed by either party during claim construction in this case,
`but was first adopted by Juniper in its Opposition to its Motion for Summary Judgment. Juniper’s delay
`in arguing this construction establishes that Finjan was not previously on notice that the Court’s
`construction was a possibility, and now has good cause to supplement based on this new construction.
`Finjan has been diligent in seeking the amendment after the Court’s claim construction (Dkt. No.
`459) and notifying the Court and Juniper in Finjan’s response (Dkt. No. 474 at 10-11) to the Court’s
`order to show cause that it would seek leave to amend its infringement contentions after the Court ruled
`on its Order to Show Cause, which would determine if Claim 1 of the ‘154 Patent was still in the case.
`While the Court has not ruled on its Order to Show Cause, Finjan brings this Motion out of the
`abundance of caution to request a supplementation of Finjan’s Infringement Contentions in view of the
`Court’s new construction of the content processor term. Finjan’s supplementation will not prejudice
`Juniper because it only clarifies Finjan’s infringement contentions based on the court’s new claim
`construction. Furthermore, Juniper will not be prejudiced because it has been aware of Finjan’s
`positions since Finjan attached a declaration from Dr. Mitzenmacher, which included the substance of
`the supplement that Finjan requests, establishing that there is no surprise to Juniper of Finjan’s position.
`Dkt. Nos. 469-6, 474. Finally, Finjan’s supplementation will not disrupt the case schedule as there will
`be no additional discovery taken a result of the supplementation, as Juniper has been aware of Finjan’s
`position at least since Finjan’s response to the Court’s order to show cause (Dkt. Nos. 470, 474). As
`such, Finjan should be provided leave to supplement its infringement contentions to address the Court’s
`new claim construction.
`II.
`FACTUAL BACKGROUND
`Pursuant to the Court’s second showdown procedure (Dkt. No. 219), Finjan filed a summary
`judgment of infringement on the ’154 Patent (Dkt. No. 369) on Juniper’s SRX Gateways, Sky ATP,
`and ATP Appliances products. Prior to the summary judgment, Finjan has proposed the term “content
`processor” to be accorded its plain and ordinary meaning, namely a component that processes content
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`downloaded across a network. Dkt. No. 176 (Finjan’s Opening Claim Construction Brief) at 17-18.
`Juniper, on the other hand, has proposed a number of different constructions for “content processor” in
`various different briefings in this Court and also in an IPR petition. However, none of the constructions
`proposed by Juniper required “content processor” to process “modified content.” See Dkt. No. 115 at 4;
`Dkt. No. 182 at 20; Juniper Networks, Inc. v. Finjan, Inc., Case No. IPR2019-00031, Paper 2 (Petition)
`at 14-15 (P.T.A.B. Oct. 3, 2018).
`For the first time, in Juniper’s opposition to Finjan’s summary judgment, Juniper inserted the
`limitation that a content processor must process “modified” content. The Court then adopted a version
`of Juniper’s new claim construction to require the content processor to process modified content, after
`Finjan already put forth its infringement case based on Juniper’s previous claim construction. Dkt. No.
`459 at 11. With its issuance of this claim construction order, the Court simultaneously ordered that
`Finjan show cause for why Juniper’s products still infringe under the Court’s claim construction. See
`Dkt. Nos. 470, 474 (“Resp. Order to Show Cause”). In response to this Order to Show Cause, Finjan
`submitted a declaration of its technical expert, Dr. Mitzenmacher, which included several bases for
`Juniper’s infringement of Claim 1 of the ’154 Patent under this construction. In particular, Finjan
`established that the content processors in the accused products process content that has been modified.
`See, e.g., Dkt. No. 469-6 (Mitzenmacher Decl.) at ¶¶ 36-76. In this same response to the Order to Show
`Cause, Finjan also stated that it would supplement its infringement contentions to account for the
`Court’s claim construction when the Court rules on its order to Show Cause, because if the Court ruled
`against Finjan the issue would be mooted. Dkt. No. 474 at 10-11.
`On June 7th, as the Court had not yet issued an order on its Order to Show Cause, Finjan reached
`out to Juniper about whether it would stipulate to Finjan’s supplementing its infringement contentions
`in response to the Court’s new claim construction Order. Ex. B at 3. In response, Juniper’s counsel
`stated that they would consider stipulating to Finjan serving a supplementation, but that they wanted to
`see the exact proposed supplementation. Id. at 2. Finjan provided Juniper’s counsel with Finjan’s
`supplemental infringement contentions on June 25, which updated Finjan’s infringement contentions to
`address the Court’s claim construction Order. Id.; see also Ex. A (proposed supplemental infringement
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`contentions). Finjan’s proposed supplementations were narrow in nature, and specifically addressed the
`new construction provided by the Court. Ex. A, (Appendix E-1) at 10-12, Ex. A (Appendix E-2) at 7-9,
`Ex. A (Appendix E-3) at 9-11 (the word version of these charts were attached to Ex. B, June 25th
`Attachments to Email to Glucoft). On June 27th, Juniper stated that there was no good cause to amend
`because: (1) Finjan should have known that Juniper would adopt a new construction it had never
`previously adopted because the construction was included in PTAB decision and (2) because Juniper
`believed the supplementation were futile. See Ex. B at 1. Finjan requested a meet and confer on July
`3rd, and the parties have not been able to meet and confer. Id.; Kastens Decl. at ¶ 4. Thus, Finjan is left
`with no choice but to bring this Motion as the close of fact discovery is fast approaching.
`III. ARGUMENT
`Under the Patent Local Rule, a party may amend its Infringement Contentions “by order of the
`Court upon a timely showing of good cause.” Patent L.R. 3-6. “The good cause inquiry is two-fold: (1)
`whether the moving party was diligent in amending its contentions; and (2) whether the non-moving
`party would suffer prejudice if the motion to amend were granted.” 24/7 Customer, Inc., v. Liveperson,
`Inc., No. 3:15-cv-02897-JST-KAW, 2016 WL 6673983, at *2 (N. D. Cal. Nov. 14, 2016) (citation
`omitted). The Patent Local Rules specifically set forward as an example of good cause being a claim
`construction of a term that is “different from that proposed by the party seeking amendment.” Patent
`L.R. 3-6(a).
`1.
`Finjan Has Good Cause to Supplement
` Finjan has good cause to supplement its Infringement Contentions because the claim
`construction adopted by the Court is different from the construction proposed by Finjan during claim
`construction, namely, that a “content processor” must process “modified content.” See Dkt. No. 459 at
`6 (listing Finjan’s construction followed the plain and ordinary meaning of “content processor” and not
`requiring it to process modified content). The Patent Local Rules are clear that good cause is found
`where, as was done here, “a claim construction by the Court [is] different from that proposed by the
`party seeking amendment.” Patent L.R. 3-6(a); see also MyMedicalRecords, Inc. v. Quest Diagnostics,
`Inc., No. 2:13-cv-02538-ODW (SHX), 2014 WL 5810363, at *3 (C.D. Cal. Nov. 6, 2014) (holding that
`
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`it was reasonable to wait to move to amend infringement contentions until
`after claim construction order; noting “[n]either party had any way of predicting how the Court would
`rule on the claim construction dispute before it issued the Claim–Construction Order.”). Especially
`here, the Court did not exactly adopt either exact construction, but adopted a revised version of the
`construction requested by Juniper. In this type of scenario, “Courts generally have granted leave to
`amend following a claim construction order.” Slot Speaker Techs., Inc. v. Apple, Inc., No. 13-cv-
`01161-HSG (DMR), 2017 WL 1278744, at *4 (N.D. Cal. Apr. 6, 2017) (citations omitted).
`Finjan’s proposed supplementations set forth in Exhibit A are also all directly related to the new
`construction adopted by the Court. See Ex. A. Finjan has added a single paragraph of new description,
`as well as updating its theory under the Doctrine of Equivalents. Finjan made no other changes to its
`infringement contentions. An example of the supplementation for Juniper’s SRX Gateway product is
`provided below, and as shown, is directly responsive to the Court’s Order on Claim Construction:
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`Ex. A (Appendix E-1) at 10. The proposed supplementations for the other two accused products, Sky
`ATP and the ATP Appliance, are similar in scope, and are also directly responsive to the Court’s
`construction. Id. (Appendix E-2) at 7-8; id., (Appendix E-3) at 9-11. Similarly, Finjan has
`supplemented its DOE theories to address the new construction that a content processor in the claims
`must process modified content. As such, Finjan has good cause for the scope of the supplementation
`requested, as it directly addresses the Court’s construction.
`2.
`Finjan Has Been Diligent in Supplementing Its Infringement Contentions
`Finjan has been diligent in seeking leave to supplement. Fujifilm Corp. v. Motorola Mobility
`LLC, No. 12-cv-03587-WHO, 2014 WL 491745, at *3 (N.D. Cal. Feb. 5, 2014). Diligence consists of
`two steps: “(1) diligence in discovering the basis for amendment; and (2) diligence in seeking
`amendment once the basis for amendment has been discovered.” Monolithic Power Sys., Inc. v. Silergy
`Corp., No. 14-cv-01745-VC (KAW), 2015 WL 5440674, at *2 (N.D. Cal. Sept. 15, 2015) (citation
`omitted). Finjan has established its diligence in both steps because: (1) it did not learn of the new
`construction until the Court issued its Order and (2) Finjan has diligently sought to supplement its
`infringement contentions, even though the Court has not yet ruled on whether Claim 1 of the ‘154
`Patent will remain in the case.
`First, “[i]n considering the party’s diligence, the critical question is whether the party could have
`discovered the new information earlier had it acted with the requisite diligence.” Radware Ltd. v. F5
`Networks, Inc., No. C-13–02041-RMW, 2014 WL 3728482, at *1 (N.D. Cal. July 28, 2014) (citation
`omitted). Finjan first discovered the basis for supplementation when the Court issued its claim
`construction on May 8, 2019, which modified Juniper’s claim construction first proposed on March 14,
`2019. Finjan could not have anticipated that the Court adopted this modified version of Juniper’s new
`claim construction because Juniper’s new construction was procedurally improper, and was never
`proposed nor briefed as part of the parties’ claim construction briefing occurred last year. In addition,
`neither party proposed this claim construction prior to Finjan’s motion for summary judgment. Finjan
`could not have anticipated that Juniper changed in its claim construction positions this late in the game,
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`as none of Juniper’s constructions in this case, and in front of the PTAB includes a limitation of
`“processing modified content”.
`Moreover, Juniper’s argument that Finjan should have somehow guessed Juniper would request
`this construction because it was in a single IPR decision—even Juniper gave no indication of this
`during claim construction—is without any basis. Even if Finjan could have somehow divined the
`Court’s ultimate construction of the term “content processor,” there is no requirement that a party must
`include every possible claim construction position in its infringement contentions in the alternative,
`even if the construction is not advocated by the party. In fact, this goes against the Patent Local Rules
`specifically stating that there is good cause when a claim construction different from what the moving
`party requested is ordered. As such, even if the Court’s construction was included in a single IPR
`decision, Finjan was not required to use that construction, particularly since Court’s in this district of
`used different constructions of the term.
` Despite of the prejudice that Juniper has inflicted on Finjan by its late change in construction of
`the term “content processor,” Finjan has been diligent in seeking the amendment. Within 3 business
`days after learning the Court’s construction on May 8, 2019, Finjan notified the Court and Juniper in its
`response to the Court’s order to show cause that Finjan intended to supplement its Infringement
`Contentions based on the Court’s new construction and provided the substance of these supplements in
`an expert declaration. Dkt. No. 474 at 10-11; Dkt. No. 469-6 (Mitzenmacher Decl.). At the time when
`Finjan filed the response, there was not a discovery cut-off and many uncertainties with respect to how
`the subsequent trial will be conducted. Thus, Finjan stated that “it will seek to amend its contentions
`based on the Court’s construction of ‘content processor’ when the Court rules on its Order to Show
`Cause,” (Dkt. No. 474 at 10-11) which was proper because the Court’s decision on its Order to Show
`Cause would establish whether Claim 1 of the ‘154 Patent was still in the case and the issue was not
`moot. However, as a case schedule was later set and expert reports will be due soon, Finjan move to
`supplement its infringement contentions out of an abundance of caution, even though the Court has not
`ruled on the Order to Show Cause.
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`3.
`Juniper Will Not be Unduly Prejudiced
`Juniper will not be prejudiced by Finjan’s supplementation, as “[p]rejudice is typically found
`when amending contentions stand to disrupt the case schedule or other court orders,” and no such
`disruption will occur here. Karl Storz Endoscopy-Am. v. Stryker Corp., No. 14-cv-0087-RS (JSC),
`2016 WL 7386136, at *3 (N.D. Cal. Dec. 21, 2016) (citation omitted). Juniper has been well aware of
`Finjan’s positions, as they were disclosed in an expert declaration attached to Finjan’s response to the
`Order to Show Cause on May 13, 2019.
`Finjan’s supplementation will not disrupt the case schedule or the court orders because it only
`clarifies Finjan’s contentions for one patent based on the Court’s new claim construction, and does not
`add any new patent claims or products. See Brandywine Commc’ns Techs., LLC v. AT & T Corp., No.
`C 12-2494 CW, 2014 WL 1569544, at *16 (N.D. Cal. Apr. 18, 2014) (permitting “supplemental
`contentions [that] essentially expand on [plaintiff’s] previous infringement contentions and do not add
`any new patent claims or products”). As no new discoveries are needed, the case schedule will not be
`disrupted. MLC Intellectual Property, LLC v. Micron Tech., Inc., No. 14-cv-03657-SI, 2019 WL
`978766, at *5 (N.D. Cal. Feb. 28, 2019) (finding no prejudice to non-moving party where no new
`theories of liability are added and no additional discovery is needed). Furthermore, even if new
`evidence was required to address Finjan’s supplementation, Juniper has had Finjan’s infringement
`positions at least since Finjan filed its response to the Order to Show Cause, allowing Juniper plenty of
`time to investigate this issue or otherwise seek discovery. Furthermore, as this construction was first
`advocated by Juniper, Juniper had ample time to investigate its infringement under its own construction,
`even if it never actually raised this proposed construction with Finjan.
`Finally, Juniper cannot show it was prejudiced when Finjan seeks to supplement in response to
`Juniper’s own shifting claim construction. See Synchronoss Techs., Inc. v. Dropbox Inc., No. 4:16-cv-
`00119-HSG-KAW, 2018 WL 5619743, at *3-6 (N.D. Cal. Oct. 29, 2018) (no prejudice where non-
`moving party’s own witness disclosed new information, the case schedule would not be interrupted by
`the amendment and expert discovery was still ongoing). Juniper had numerous opportunities to raise
`this construction during claim construction, or when it filed an IPR related to the ’154 Patent, and never
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`did. The lack of any prejudice to Juniper is further coupled to the fact that Finjan’s supplement contains
`the same theories that were previously set forth in the response to the Court’s order to show cause, and
`thus Juniper was already aware of the infringement theories in the supplemental Infringement
`Contentions.
`IV. CONCLUSION
`For the reasons set forth above, Finjan respectfully requests that the Court grant it leave to
`supplement its Infringement Contentions pursuant to Local Patent Rule 3-6.
`
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`Dated: July 11, 2019
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`Respectfully submitted,
`
`
`By: /s/ Kristopher Kastens
`Paul J. Andre (State Bar No. 196585)
`Lisa Kobialka (State Bar No. 191404)
`James Hannah (State Bar No. 237978)
`Kristopher Kastens (State Bar No. 254797)
`KRAMER LEVIN NAFTALIS
`& FRANKEL LLP
`990 Marsh Road
`Menlo Park, CA 94025
`Telephone: (650) 752-1700
`Facsimile: (650) 752-1800
`pandre@kramerlevin.com
`lkobialka@kramerlevin.com
`jhannah@kramerlevin.com
`kkastens@kramerlevin.com
`
`Attorneys for Plaintiff
`FINJAN, INC.
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