Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 1 of 10
`Case 1:19-cv-00859—RTH Document 1-11 Filed 06/11/19 Page 1 of 10
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`EXHIBIT J
`EXHIBIT J
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 2 of 10
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`Claim Chart For U.S. Patent 9,262,384
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`
`
`Claim 66
`A computer program product
`embodied on at least one non-
`transitory computer readable
`medium and configured to cause
`at least one hardware processor
`to operate, the computer
`program product comprising:
`
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`
`
`Infringement Analysis
`Non-limiting preamble. By way of background, the eXtensible Business Reporting Language (XBRL)
`Financial Reporting standard (see http://www.xbrl.org/Specification/xbrl-recommendation-2003-12-
`31+corrected-errata-2012-01-25.htm) specifies a Report generation and formatting facility that uses a
`computer program product embodied on a non-transitory computer readable medium to process a set of
`interrelated eXtensible Markup Language (XML)-formatted files that specify:
`
`(1) how tagged numerical data items to be formatted in an XBRL Financial Report are identified as a Fact (a
`tagged numerical data value that will be reported) related to a Concept (a particular Financial semantic
`meaning for the tagged numerical data value) in the context of the Taxonomy (a list of concepts to be
`included in the Financial Report, and a collection of XML-compliant documents (linkbases) that provide
`additional information that forms part of the concept definitions) for inclusion in a given XBRL Financial
`Report Instance Document (see XBRL “Essentials https://specifications.xbrl.org/xbrl-essentials.html),
`
`(2) how the numerical data items are tagged in the XML-compliant Instance Document file (with a name
`ending in “.xml”), which indicates the content of the Financial Report, to facilitate association of the
`related linkbases:
`
`(a) XML-compliant Schema Definition file (with a name ending in “.xsd”) which contains formatting
`and semantic meaning information,
`(b) XML-compliant Label file (with a name ending in “_lab.xml”) which indicates the label of the
`numeric data value,
`(c) XML-compliant Calculation file (with a name ending in “_cal.xml”) which contains rules that
`determine how to combine information and to determine that the set of XML-compliant
`documents are valid,
`(d) XML-compliant Definition file (with a name ending in “_def.xml”) relates concepts with other
`concepts,
`(e) XML-compliant Presentation file (with a name ending in “_pre.xml”) This linkbase associates
`concepts with other concepts so that the resulting relations can guide the creation of a user
`interface, rendering, or visualization.
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`(3) how each tagged numerical data item is identified and categorized from the information contained in
`the referenced linkbases using the tags,
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`Page 1 of 9
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 3 of 10
`
`Claim Chart For U.S. Patent 9,262,384
`
`
`
`Claim 66
`
`code stored on the at least one
`non-transitory computer
`readable medium and configured
`to cause the at least one
`hardware processor to identify at
`least parts of a plurality of
`
`Infringement Analysis
`
`(4) how each tagged numerical data item is formatted for display,
`
`(5) how each tagged numerical data item is displayed hierarchically in relation to other tagged numerical
`data items,
`
`(6) how an individual tagged numerical data item is combined with other tagged numerical data items to
`yield a “summary” tagged numerical data item based on specified formulas relating to the semantic
`meaning associated with the numerical data item’s tag in accordance with information contained in the
`XBRL Taxonomy file and the associated XBRL Calculation linkbase file, and
`
`(7) how the set of interrelated XBRL files are validated to ensure consistency and completeness of the
`information contained therein.
`
`The XBRL Financial Reporting standard specifies that each of the interrelated files comprising the XBRL
`Financial Report are encoded using the eXtensible Markup Language (XML) syntax such that they may be
`interpreted, manipulated and displayed using standard computer program products such as a World Wide
`Web “browser” (e.g., Microsoft Internet Explorer, Apple Safari, Google Chrome, Mozilla Firefox, etc.) that is
`capable of interpreting the set of interrelated XML-compliant documents containing tagged numerical data
`items and implementing the formatting, computation formulas and rules required to validate and present
`the XBRL encoded Financial Report in human readable form through the use of “a computer program
`product embodied on a non-transitory computer readable medium”
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would entail use of such “a computer program product
`embodied on a non-transitory computer readable medium.”
`
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “a computer program product
`embodied on a non-transitory computer readable medium, comprising:… code stored on the at least one
`non-transitory computer readable medium and configured to cause the at least one hardware processor
`to identify at least parts of a plurality of original documents including a plurality of original values, the
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 4 of 10
`
`Claim Chart For U.S. Patent 9,262,384
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`
`
`Claim 66
`original documents including a
`plurality of original values, the
`plurality of original documents
`including a first document
`including first values and a
`second document including
`second values;
`
`
`code stored on the at least one
`non-transitory computer
`readable medium and configured
`to cause the at least one
`hardware processor to process at
`least a part of the first document
`and at least a part of the second
`document, resulting in at least
`one data structure including at
`least one of the plurality of
`original values of at least one of
`the plurality of original
`documents;
`
`Infringement Analysis
`plurality of original documents including a first document including first values and a second document
`including second values”.
`
`The XBRL Financial Reporting standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. Together, the XML-compliant computer-
`readable Instance Document embodied on a non-transitory computer readable medium and the
`computer-readable linkbase embodied on a non-transitory computer readable medium, referenced using
`the tag associated with each individual data value contained in the instance Document, contain “a
`plurality of original documents including a plurality of original values, including a first document
`including first values and a second document including second values”.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “a computer program product embodied on
`a non-transitory computer readable medium, comprising:… code stored on the at least one non-
`transitory computer readable medium and configured to cause the at least one hardware processor to
`identify at least parts of a plurality of original documents including a plurality of original values, the
`plurality of original documents including a first document including first values and a second document
`including second values” in order to store the XBRL Instance Document and the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “a computer program product
`embodied on a non-transitory computer readable medium, comprising:… code stored on the at least one
`non-transitory computer readable medium and configured to cause the at least one hardware processor
`to process at least a part of the first document and at least a part of the second document, resulting in at
`least one data structure including at least one of the plurality of original values of at least one of the
`plurality of original documents”.
`
`The XBRL Financial Reporting Standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. Together, the XML-compliant computer-
`readable Instance Document embodied on a non-transitory computer readable medium and the
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`Page 3 of 9
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 5 of 10
`
`Claim Chart For U.S. Patent 9,262,384
`
`
`
`Claim 66
`
`
`code stored on the at least one
`non-transitory computer
`readable medium and configured
`to cause the at least one
`hardware processor to identify
`one or more indications for one
`or more of the original values for
`tagging, in connection with at
`least one computer-readable
`Extensible Markup Language
`(XML)-compliant data document,
`using a corresponding one or
`more computer-readable
`semantic tags;
`
`
`Infringement Analysis
`computer-readable linkbases embodied on a non-transitory computer readable medium, referenced using
`the tag associated with each individual data value contained in the instance Document, must be processed
`using “code stored on the at least one non-transitory computer readable medium and configured to
`cause the at least one hardware processor to process at least a part of the first document and at least a
`part of the second document, resulting in at least one data structure including at least one of the
`plurality of original values of at least one of the plurality of original documents” in order to generate the
`required XBRL-compliant Financial Report.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “a computer program product embodied on
`a non-transitory computer readable medium, comprising:… code stored on the at least one non-
`transitory computer readable medium and configured to cause the at least one hardware processor to
`process at least a part of the first document and at least a part of the second document, resulting in at
`least one data structure including at least one of the plurality of original values of at least one of the
`plurality of original documents in order to perform the actions specified in the XBRL Instance Document
`and the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “a computer program product
`embodied on a non-transitory computer readable medium, comprising:… code stored on the at least one
`non-transitory computer readable medium and configured to cause the at least one hardware processor
`to identify one or more indications for one or more of the original values for tagging, in connection with
`at least one computer-readable Extensible Markup Language (XML)-compliant data document, using a
`corresponding one or more computer-readable semantic tags”.
`
`The XBRL Financial Reporting standard uses an XML-compliant Instance Document to describe the contents
`of the Financial Report, and associated linkbases to describe semantic, formatting, calculation and
`validation information. During Mattress Firm’s creation and editing of an XBRL-compliant Financial Report,
`a computer program product embodied on a non-transitory computer readable medium to allow the at
`least one hardware processor to identify one or more indications for one or more of the original values
`for tagging … using a corresponding one or more computer-readable semantic tags from those available
`in the XBRL-compliant linkbases must be provided. Once selected, the corresponding tag is associated with
`the data value in the XBRL-compliant Instance Document.
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 6 of 10
`
`Claim Chart For U.S. Patent 9,262,384
`
`
`
`Claim 66
`
`code stored on the at least one
`non-transitory computer
`readable medium and configured
`to cause the at least one
`hardware processor to associate
`the one or more computer-
`readable semantic tags with the
`one or more original values such
`that the one or more computer-
`readable semantic tags are
`computer-readably associated
`with the one or more original
`values;
`
`
`Infringement Analysis
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting standard by Mattress Firm would require “a computer program product embodied on
`a non-transitory computer readable medium, comprising:… code stored on the at least one non-
`transitory computer readable medium and configured to cause the at least one hardware processor to
`identify one or more indications for one or more of the original values for tagging, in connection with at
`least one computer-readable Extensible Markup Language (XML)-compliant data document, using a
`corresponding one or more computer-readable semantic tags” in order to create and/or edit the XBRL
`Instance Document and the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “a computer program product
`embodied on a non-transitory computer readable medium, comprising:… code stored on the at least one
`non-transitory computer readable medium and configured to cause the at least one hardware processor
`to associate the one or more computer-readable semantic tags with the one or more original values such
`that the one or more computer-readable semantic tags are computer-readably associated with the one
`or more original values”.
`
`The XBRL Financial Reporting standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. During Mattress Firm’s creation and editing
`of an XBRL-compliant Financial Report, code must exist to allow the at least one hardware processor to
`associate the one or more computer-readable semantic tags with the one or more original values from
`those available in the XBRL-compliant linkbases. Once selected, the corresponding tag is associated with
`the data value in the XBRL-compliant Instance Document.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “a computer program product embodied on
`a non-transitory computer readable medium, comprising:… code stored on the at least one non-
`transitory computer readable medium and configured to cause the at least one hardware processor to
`associate the one or more computer-readable semantic tags with the one or more original values such
`that the one or more computer-readable semantic tags are computer-readably associated with the one
`or more original values” in order to create and/or edit the XBRL Instance Document and the associated
`linkbases.
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 7 of 10
`
`Claim Chart For U.S. Patent 9,262,384
`
`
`
`Claim 66
`code stored on the at least one
`non-transitory computer
`readable medium and configured
`to cause the at least one
`hardware processor to generate a
`presentation utilizing at least a
`portion of the at least one data
`structure, the presentation
`capable of including at least a
`portion of the original values
`including the at least one original
`value, where the computer
`program product is configured
`such that, utilizing the at least
`one data structure, a change to
`the at least one original value
`results in a corresponding change
`in a subsequently generated
`presentation;
`
`
`Infringement Analysis
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Presentation would require “a computer program
`product embodied on a non-transitory computer readable medium, comprising:… code stored on the at
`least one non-transitory computer readable medium and configured to cause the at least one hardware
`processor to generate a presentation utilizing at least a portion of the at least one data structure, the
`presentation capable of including at least a portion of the original values including the at least one
`original value, where the computer program product is configured such that, utilizing the at least one
`data structure, a change to the at least one original value results in a corresponding change in a
`subsequently generated presentation”.
`
`The XBRL Financial Reporting standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. During Mattress Firm’s editing of an XBRL-
`compliant Financial Presentation, code must exist to allow change to the at least one original value of the
`at least one original computer-readable Instance Document embodied on a non-transitory computer
`readable medium data value. Once the change to the at least one original value of the at least one
`original computer-readable Instance Document embodied on a non-transitory computer readable
`medium data value has been input by the user, validated and stored in as a revised version of the XBRL-
`compliant computer-readable Instance Document embodied on a non-transitory computer readable
`medium, the “code stored on the at least one non-transitory computer readable medium and configured
`to cause the at least one hardware processor to generate a presentation utilizing at least a portion of the
`at least one data structure, the presentation capable of including at least a portion of the original values
`including the at least one original value, where the computer program product is configured such that,
`utilizing the at least one data structure, a change to the at least one original value results in a
`corresponding change in a subsequently generated presentation” would be executed to generate the
`XBRL-compliant presentation.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “a computer program product embodied on
`a non-transitory computer readable medium, comprising:… code stored on the at least one non-
`transitory computer readable medium and configured to cause the at least one hardware processor to
`generate a presentation utilizing at least a portion of the at least one data structure, the presentation
`
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`Page 6 of 9
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 8 of 10
`
`Claim Chart For U.S. Patent 9,262,384
`
`
`
`Claim 66
`
`code stored on the at least one
`non-transitory computer
`readable medium and configured
`to cause the at least one
`hardware processor to generate a
`report utilizing at least a portion
`of the at least one data structure,
`the report capable of including at
`least a portion of the original
`values including the at least one
`original value, where the
`computer program product is
`configured such that, utilizing the
`at least one data structure, a
`change to the at least one
`original value results in a
`corresponding change in a
`subsequently generated report;
`and
`
`
`Infringement Analysis
`capable of including at least a portion of the original values including the at least one original value,
`where the computer program product is configured such that, utilizing the at least one data structure, a
`change to the at least one original value results in a corresponding change in a subsequently generated
`presentation” to edit and then present the XBRL Instance Document and the associated linkbases.
`
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “a computer program product
`embodied on a non-transitory computer readable medium, comprising:… code stored on the at least one
`non-transitory computer readable medium and configured to cause the at least one hardware processor
`to generate a report utilizing at least a portion of the at least one data structure, the report capable of
`including at least a portion of the original values including the at least one original value, where the
`computer program product is configured such that, utilizing the at least one data structure, a change to
`the at least one original value results in a corresponding change in a subsequently generated report”.
`
`The XBRL Financial Reporting standard uses an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. During Mattress Firm’s editing of an XBRL-
`compliant Financial Report, code must exist to allow change to the at least one original value of the at
`least one original computer-readable Instance Document embodied on a non-transitory computer
`readable medium. Once the change to the at least one original value of the at least one original
`computer-readable Instance Document embodied on a non-transitory computer readable medium has
`been input by the user, validated and stored in as a revised version of the XBRL-compliant computer-
`readable Instance Document embodied on a non-transitory computer readable medium, the “code stored
`on the at least one non-transitory computer readable medium and configured to cause the at least one
`hardware processor to generate a report utilizing at least a portion of the at least one data structure, the
`report capable of including at least a portion of the original values including the at least one original
`value, where the computer program product is configured such that, utilizing the at least one data
`structure, a change to the at least one original value results in a corresponding change in a subsequently
`generated report” would be executed to generate the XBRL-compliant report.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting standard by Mattress Firm would require “a computer program product embodied on
`
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`Page 7 of 9
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 9 of 10
`
`Claim Chart For U.S. Patent 9,262,384
`
`
`
`Claim 66
`
`code stored on the at least one
`non-transitory computer
`readable medium and configured
`to cause the at least one
`hardware processor to generate
`the computer-readable XML-
`compliant data document
`utilizing at least a portion of at
`least one data structure, the at
`least one computer-readable
`XML-compliant data document
`capable of including a plurality of
`line items at least one of which
`involves at least a portion of the
`original values including the at
`least one original value and at
`least some of the one or more
`computer-readable semantic
`tags, where the computer
`program product is configured
`such that, utilizing the at least
`one data structure, a change to
`the at least one original value
`results in a corresponding change
`in a subsequently generated at
`
`Infringement Analysis
`a non-transitory computer readable medium, comprising:… code stored on the at least one non-
`transitory computer readable medium and configured to cause the at least one hardware processor to
`generate a report utilizing at least a portion of the at least one data structure, the report capable of
`including at least a portion of the original values including the at least one original value, where the
`computer program product is configured such that, utilizing the at least one data structure, a change to
`the at least one original value results in a corresponding change in a subsequently generated report” to
`edit and then report the contents of the XBRL Instance Document and the associated linkbases.
`In accordance with the XBRL Financial Reporting standard as described above, Mattress Firm’s creating,
`editing and generating of an XBRL-compliant Financial Report would require “a computer program product
`embodied on a non-transitory computer readable medium, comprising:… code stored on the at least one
`non-transitory computer readable medium and configured to cause the at least one hardware processor
`to generate the computer-readable XML-compliant data document utilizing at least a portion of at least
`one data structure, the at least one computer-readable XML-compliant data document capable of
`including a plurality of line items at least one of which involves at least a portion of the original values
`including the at least one original value and at least some of the one or more computer-readable
`semantic tags, where the computer program product is configured such that, utilizing the at least one
`data structure, a change to the at least one original value results in a corresponding change in a
`subsequently generated at least one computer-readable XML-compliant data document”.
`
`The XBRL Financial Reporting standard specifies an XML-compliant computer-readable Instance Document
`embodied on a non-transitory computer readable medium to describe the contents of the Financial
`Report, and associated linkbases embodied on a non-transitory computer readable medium to describe
`semantic, formatting, calculation and validation information. For Mattress Firm to “output at least one
`computer-readable Extensible Markup Language (XML)-compliant data document” as an XBRL-compliant
`Financial Instance Document and its associated linkbases, code must exist to allow change to the at least
`one original value of the at least one original computer-readable Instance Document embodied on a non-
`transitory computer readable medium data value. Once the change to the at least one original value of
`the at least one original computer-readable Instance Document embodied on a non-transitory computer
`readable medium has been input, validated and stored in as a revised version of the XBRL-compliant
`computer-readable Instance Document embodied on a non-transitory computer readable medium, the
`“code stored on the at least one non-transitory computer readable medium and configured to cause the
`at least one hardware processor to generate the computer-readable XML-compliant data document
`utilizing at least a portion of at least one data structure, the at least one computer-readable XML-
`
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`Case 1:19-cv-00859-RTH Document 1-11 Filed 06/11/19 Page 10 of 10
`
`Claim Chart For U.S. Patent 9,262,384
`
`
`
`Claim 66
`least one computer-readable
`XML-compliant data document.
`
`Infringement Analysis
`compliant data document capable of including a plurality of line items at least one of which involves at
`least a portion of the original values including the at least one original value and at least some of the
`one or more computer-readable semantic tags, where the computer program product is configured such
`that, utilizing the at least one data structure, a change to the at least one original value results in a
`corresponding change in a subsequently generated at least one computer-readable XML-compliant data
`document” would be executed to generate the XBRL-compliant Instance Document and associated
`linkbase Documents in XML-compatible format.
`
`Therefore, any preparation, editing and submission of a Financial Report that complies with the XBRL
`Financial Reporting Standard by Mattress Firm would require “a computer program product embodied on
`a non-transitory computer readable medium, comprising:… code stored on the at least one non-
`transitory computer readable medium and configured to cause the at least one hardware processor to
`generate the computer-readable XML-compliant data document utilizing at least a portion of at least
`one data structure, the at least one computer-readable XML-compliant data document capable of
`including a plurality of line items at least one of which involves at least a portion of the original values
`including the at least one original value and at least some of the one or more computer-readable
`semantic tags, where the computer program product is configured such that, utilizing the at least one
`data structure, a change to the at least one original value results in a corresponding change in a
`subsequently generated at least one computer-readable XML-compliant data document” to edit and then
`output the contents of the XBRL Instance Document and the associated linkbases as computer-readable
`XML-compliant data documents.
`
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`Page 9 of 9
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