`
`Case No. IPR2013-00010
`
`Patent No. 7,516,484
`
`Exhibit 2012
`
`1
`
`ALDERSON REPORTING COMPANY
`
`2
`
`HJU104000
`
`
`
`
`
`3
`
`MARKUP OF H.R. 1249, THE AMERICA INVENTS ACT
`
`4
`
`Thursday, April 14, 2011
`
`5
`
`House of Representatives
`
`6
`
`Committee on the Judiciary
`
`7
`
`Washington, D.C.
`
`
`
`
`
`
`
`8
`
` The committee met, pursuant to call, at 10:35 a.m., in
`
`9
`
`Room 2141, Rayburn Office Building, Hon. Lamar Smith
`
`10
`
`[chairman of the committee] presiding.
`
`11
`
` Present: Representatives Smith, Sensenbrenner, Coble,
`
`12
`
`Gallegly, Goodlatte, Lungren, Chabot, Issa, Pence, Forbes,
`
`13
`
`King, Franks, Gohmert, Jordan, Poe, Chaffetz, Griffin,
`
`14
`
`Marino, Gowdy, Ross, Adams, Quayle, Conyers, Berman, Nadler,
`
`15
`
`Scott, Watt, Lofgren, Jackson Lee, Waters, Cohen, Johnson,
`
`16
`
`Pierluisi, Quigley, Chu, Deutch, Sanchez, and Wasserman
`
`17
`
`Schultz.
`
`
`
`HJU104000 PAGE 2
`
`18
`
` Staff present: Sean McLaughlin, Chief of Staff;
`
`19
`
`Allison Halatei, Deputy Chief of Staff/Parliamentarian;
`
`20
`
`Sarah Kish, Clerk; Perry Apelbaum, Minority Staff Director;
`
`21
`
`and Chrystal Sheppard.
`
`22
`
`
`
`HJU104000 PAGE 66
`
`1318
`
`constructive move. Thank you.
`
`1319
`
`Chairman Smith. I thank the gentleman.
`
`1320
`
`If there are no other members who wish to be heard on
`
`1321
`
`the amendment, all those in favor, say aye.
`
`1322
`
`[Chorus of ayes.]
`
`1323
`
`Chairman Smith. All those opposed, no.
`
`1324
`
`[No response.]
`
`1325
`
`Chairman Smith. In the opinion of the chair, the ayes
`
`1326
`
`have it. The amendment to the amendment is agreed to.
`
`1327
`
`We will now go to the next amendment which is going to
`
`1328
`
`be offered by the gentlewoman from California, Ms. Lofgren.
`
`1329
`
`And she is recognized for that purpose.
`
`1330
`
`Ms. Lofgren. Thank you, Mr. Chairman. I have an
`
`1331
`
`amendment at the desk, Lofgren number 7.
`
`1332
`
`Chairman Smith. The clerk will report the amendment.
`
`1333
`
`Ms. Kish. “Amendment to the amendment offered by Mr.
`
`1334
`
`Smith to H.R. 1249 offered by Ms. Zoe Lofgren of
`
`1335
`
`California.”
`
`1336
`
`Ms. Lofgren. I would ask unanimous consent that the
`
`1337
`
`amendment be considered as read.
`
`1338
`
`Chairman Smith. Without objection the amendment to
`
`1339
`
`the amendment will be considered as read.
`
`
`
`HJU104000 PAGE 67
`
`1340
`
`[The information follows:]
`
`1341
`
`
`
`HJU104000 PAGE 68
`
`1342
`
`Chairman Smith. And the gentlewoman is recognized to
`
`1343
`
`explain her amendment.
`
`1344
`
`Ms. Lofgren. Thank you, Mr. Chairman.
`
`1345
`
`Current law provides no deadline for a party to file a
`
`1346
`
`petition for an IPR even after it is sued for infringement
`
`1347
`
`of the same patent in district court.
`
`1348
`
`The manager's amendment sets a 12-month deadline for a
`
`1349
`
`party to file a petition starting from when the party is
`
`1350
`
`served with the complaint for infringement.
`
`1351
`
`My amendment sets the deadline at 30 days after the
`
`1352
`
`district court enters an order construing the claims of the
`
`1353
`
`patent, known as the Markman hearing.
`
`1354
`
`The inter partes review is a crucial tool in our
`
`1355
`
`patent system. It can provide an effective and less
`
`1356
`
`expensive alternative to litigation by allowing third
`
`1357
`
`parties to request a reexamination of a patent’s validity by
`
`1358
`
`the PTO based on specific types of prior art. The procedure
`
`1359
`
`is, in effect, insurance against patents that should never
`
`1360
`
`have been issued in the first place and which do not
`
`1361
`
`represent genuine innovation. This is particularly
`
`1362
`
`important in the information technology industry. As this
`
`1363
`
`committee is aware, many IT products from servers to
`
`
`
`HJU104000 PAGE 69
`
`1364
`
`software to websites are ensnared in a thicket of
`
`1365
`
`overlapping patents, many of which are broadly written,
`
`1366
`
`highly abstract, and of dubious validity.
`
`1367
`
`Director Kappos is taking admirable steps at the PTO
`
`1368
`
`to improve patent quality and filter out more invalid
`
`1369
`
`applications, but even if he succeeds, we are still left to
`
`1370
`
`deal with all of the bad patents that already exist. That
`
`1371
`
`is why inter partes review is so important as an alternative
`
`1372
`
`to litigation.
`
`1373
`
`Under current law, if someone is sued for patent
`
`1374
`
`infringement, there is no deadline for them to file, as I
`
`1375
`
`mentioned. The manager's amendment changes it to 12 months.
`
`1376
`
`I recognize that some deadline is warranted to address the
`
`1377
`
`worries from patent owners who have worries about undue
`
`1378
`
`delay. However, 12 months is an arbitrary figure and it
`
`1379
`
`does not square with the reality of many complex patent
`
`1380
`
`cases. It is important to understand that defendants often
`
`1381
`
`have no prior knowledge or notice of the patents at issue
`
`1382
`
`before they are sued and, therefore, have no opportunity to
`
`1383
`
`file a petition for inter partes review in advance. Many of
`
`1384
`
`these suits start out with an overwhelming number of patents
`
`1385
`
`and claims at issue. For example, one recent infringement
`
`
`
`HJU104000 PAGE 70
`
`1386
`
`suit involved 31 patents, 1,975 claims, and 65 different
`
`1387
`
`defendants. Many patents and claims fall away as the
`
`1388
`
`litigation progresses.
`
`1389
`
`In a crucial stage of patent litigation, based on what
`
`1390
`
`is known as the Markman hearing, the court will reach
`
`1391
`
`decisions on claim construction, in other words, what the
`
`1392
`
`patents at issue actually mean, to determine at trial
`
`1393
`
`whether they were infringed. Until that decision, the
`
`1394
`
`defendants often don’t have a clear sense of the core issues
`
`1395
`
`in the case or even which specific patents and claims will
`
`1396
`
`be raised at trial. This means that they have little basis
`
`1397
`
`to prepare an effective petition for IPR that can focus on
`
`1398
`
`the genuine issues in litigation. In these instances, 12
`
`1399
`
`months is simply not enough time to do the voluminous work
`
`1400
`
`that is required to file.
`
`1401
`
`My amendment would replace the arbitrary 12-month
`
`1402
`
`figure by tying the deadline to the completion of the
`
`1403
`
`Markman hearing. Under the amendment, a defendant would
`
`1404
`
`have only 30 days to file an inter partes petition after the
`
`1405
`
`court reaches a decision on claim construction. By the time
`
`1406
`
`claim construction happens, we can be confident that the
`
`1407
`
`defendant will have had adequate time and notice of the
`
`
`
`HJU104000 PAGE 71
`
`1408
`
`genuine issues in the case in order to prepare an effective
`
`1409
`
`petition.
`
`1410
`
`I think this is a fair approach for both the patent
`
`1411
`
`owner and those accused of infringement. It preserves the
`
`1412
`
`ability of inter partes while still preventing undue delay,
`
`1413
`
`and while there is no deadline tied to litigation in the
`
`1414
`
`status quo, proponents of strict deadlines really haven’t
`
`1415
`
`given any real world examples that I am aware of of inter
`
`1416
`
`partes challenges that have been unduly delayed or harm that
`
`1417
`
`would occur therefor.
`
`1418
`
`So if there are concerns, they are theoretical, and
`
`1419
`
`regardless of the deadline, defendants have a significant
`
`1420
`
`incentive to file their petitions for IPR as early as
`
`1421
`
`possible. If the defendant waits too long to file, it could
`
`1422
`
`lose at trial and be forced into paying damages for
`
`1423
`
`infringement before the PTO makes a decision to invalidate
`
`1424
`
`the patent.
`
`1425
`
`So I think this amendment is a middle ground and
`
`1426
`
`improves the bill, and I hope that the members will see fit
`
`1427
`
`to approve it.
`
`1428
`
`And I yield back.
`
`1429
`
`Chairman Smith. Thank you, Ms. Lofgren.
`
`
`
`HJU104000 PAGE 72
`
`1430
`
`I will recognize myself in opposition to the
`
`1431
`
`amendment.
`
`1432
`
`This amendment expands the inter partes review program
`
`1433
`
`from 12 months after the filing of a civil action to 30 days
`
`1434
`
`after the Markman hearing. This amendment could create an
`
`1435
`
`open-ended process because there is actually no guarantee
`
`1436
`
`that a Markman hearing will even take place. The inter
`
`1437
`
`partes proceeding in H.R. 1249 has been carefully written to
`
`1438
`
`balance the need to encourage its use while at same time
`
`1439
`
`preventing the serial harassment of patent holders. This
`
`1440
`
`bill represents a delicate balance, and making such a core
`
`1441
`
`change to the deadline may turn the inter partes program
`
`1442
`
`into a tool for litigation gamesmanship rather than a
`
`1443
`
`meaningful and less expensive alternative to litigation.
`
`1444
`
`For those reasons, I oppose the amendment.
`
`1445
`
`Are there other members who wish to be heard on this
`
`1446
`
`amendment?
`
`1447
`
`[No response.]
`
`1448
`
`Chairman Smith. If not, we will vote on it. All
`
`1449
`
`those in -- the gentleman from California, Mr. Berman, is
`
`1450
`
`recognized.
`
`1451
`
`Mr. Berman. Mr. Chairman, the issue you raise -- I
`
`
`
`HJU104000 PAGE 73
`
`1452
`
`rise to suggest an alternative to the amendment, although I
`
`1453
`
`think the amendment is good.
`
`1454
`
`If there is a Markman hearing, that is the logical
`
`1455
`
`time to cut off the ability to stay a court case, 30 days
`
`1456
`
`afterwards. So on the face of it, I think the amendment
`
`1457
`
`makes sense. You raise legitimately what if there is no
`
`1458
`
`Markman hearing. So what if the gentlelady’s amendment said
`
`1459
`
`the Markman hearing or no later than 18 months so that if
`
`1460
`
`there were no Markman hearing, the time set, they could not
`
`1461
`
`go beyond the 18 months? Would that make it then more
`
`1462
`
`attractive to you? It would deal with this issue of no
`
`1463
`
`Markman hearing.
`
`1464
`
`Remember, under existing law -- first of all, the stay
`
`1465
`
`is never mandated. The court gets to decide whether or not
`
`1466
`
`to have a stay. And your bill, I think, is a positive
`
`1467
`
`improvement on the Senate language which was only 6 months,
`
`1468
`
`but conceptually knowing what claims are going to be
`
`1469
`
`litigated makes the most sense in terms of telling the
`
`1470
`
`defendant they no longer can use inter partes reexam as an
`
`1471
`
`effort to stall the litigation. They got to do it within 30
`
`1472
`
`days of the Markman hearing or if they haven’t gotten the
`
`1473
`
`Markman hearing or aren’t going to get a Markman hearing, no
`
`
`
`HJU104000 PAGE 74
`
`1474
`
`later than 18 months.
`
`1475
`
`Chairman Smith. Thank you, Mr. Berman.
`
`1476
`
`Mr. Berman. That is my suggestion.
`
`1477
`
`Chairman Smith. At this point, I am not prepared to
`
`1478
`
`accept that suggestion. If the gentlewoman wants to
`
`1479
`
`withdraw the amendment, we can continue talking, but I
`
`1480
`
`wouldn't want to mislead anybody either.
`
`1481
`
`Ms. Lofgren. If there is an interest in pursuing
`
`1482
`
`this, I would be happy to withdraw to pursue it, but if the
`
`1483
`
`chairman is saying I am really not interested in any changes
`
`1484
`
`in the underlying bill, then I would rather have a vote.
`
`1485
`
`Chairman Smith. As I say, I don't want to mislead the
`
`1486
`
`gentlewoman from California. Right now, I still feel
`
`1487
`
`strongly opposed to the amendment, and I don't know if that
`
`1488
`
`will change or not. It is up to her to take her risk.
`
`1489
`
`If not, we will proceed then. Are there any other
`
`1490
`
`members who wish to speak on this amendment?
`
`1491
`
`[No response.]
`
`1492
`
`Chairman Smith. If not, we will vote. All those in
`
`1493
`
`favor of the amendment will say aye.
`
`1494
`
`[Chorus of ayes.]
`
`1495
`
`Chairman Smith. All those opposed, no.
`
`
`
`HJU104000 PAGE 75
`
`1496
`
`[Chorus of nays.]
`
`1497
`
`Chairman Smith. The noes have it in the opinion of
`
`1498
`
`the chair and the amendment --
`
`1499
`
`Ms. Lofgren. Mr. Chairman, I would like a recorded
`
`1500
`
`vote on that.
`
`1501
`
`Chairman Smith. A recorded vote has been requested,
`
`1502
`
`and the clerk will call the roll.
`
`1503
`
`Ms. Kish. Mr. Smith?
`
`1504
`
`Chairman Smith. No.
`
`1505
`
`Ms. Kish. Mr. Smith votes no.
`
`1506
`
`Mr. Sensenbrenner?
`
`1507
`
`Mr. Sensenbrenner. Aye.
`
`1508
`
`Ms. Kish. Mr. Sensenbrenner votes aye.
`
`1509
`
`Mr. Coble?
`
`1510
`
`[No response.]
`
`1511
`
`Ms. Kish. Mr. Gallegly?
`
`1512
`
`Mr. Gallegly. Aye.
`
`1513
`
`Ms. Kish. Mr. Gallegly votes aye.
`
`1514
`
`Mr. Goodlatte?
`
`1515
`
`Mr. Goodlatte. No.
`
`1516
`
`Ms. Kish. Mr. Goodlatte votes no.
`
`1517
`
`Mr. Lungren?
`
`
`
`HJU104000 PAGE 76
`
`1518
`
`Mr. Lungren. Aye.
`
`1519
`
`Ms. Kish. Mr. Lungren votes aye.
`
`1520
`
`Mr. Chabot?
`
`1521
`
`Mr. Chabot. No.
`
`1522
`
`Ms. Kish. Mr. Chabot votes no.
`
`1523
`
`Mr. Issa?
`
`1524
`
`[No response.]
`
`1525
`
`Ms. Kish. Mr. Pence?
`
`1526
`
`Mr. Pence. No.
`
`1527
`
`Ms. Kish. Mr. Pence votes no.
`
`1528
`
`Mr. Forbes?
`
`1529
`
`Mr. Forbes. No.
`
`1530
`
`Ms. Kish. Mr. Forbes votes no.
`
`1531
`
`Mr. King?
`
`1532
`
`Mr. King. No.
`
`1533
`
`Ms. Kish. Mr. King votes no.
`
`1534
`
`Mr. Franks?
`
`1535
`
`Mr. Franks. No.
`
`1536
`
`Ms. Kish. Mr. Franks votes no.
`
`1537
`
`Mr. Gohmert?
`
`1538
`
`[No response.]
`
`1539
`
`Ms. Kish. Mr. Jordan?
`
`
`
`HJU104000 PAGE 77
`
`1540
`
`[No response.]
`
`1541
`
`Ms. Kish. Mr. Poe?
`
`1542
`
`[No response.]
`
`1543
`
`Ms. Kish. Mr. Chaffetz?
`
`1544
`
`Mr. Chaffetz. No.
`
`1545
`
`Ms. Kish. Mr. Chaffetz votes no.
`
`1546
`
`Mr. Griffin?
`
`1547
`
`Mr. Griffin. No.
`
`1548
`
`Ms. Kish. Mr. Griffin votes no.
`
`1549
`
`Mr. Marino?
`
`1550
`
`Mr. Marino. No.
`
`1551
`
`Ms. Kish. Mr. Marino votes no.
`
`1552
`
`Mr. Gowdy?
`
`1553
`
`Mr. Gowdy. No.
`
`1554
`
`Ms. Kish. Mr. Gowdy votes no.
`
`1555
`
`Mr. Ross?
`
`1556
`
`Mr. Ross. No.
`
`1557
`
`Ms. Kish. Mr. Ross votes no.
`
`1558
`
`Ms. Adams?
`
`1559
`
`[No response.]
`
`1560
`
`Ms. Kish. Mr. Quayle?
`
`1561
`
`Mr. Quayle. No.
`
`
`
`HJU104000 PAGE 78
`
`1562
`
`Ms. Kish. Mr. Quayle votes no.
`
`1563
`
`Mr. Conyers?
`
`1564
`
`Mr. Conyers. Aye.
`
`1565
`
`Ms. Kish. Mr. Conyers votes aye.
`
`1566
`
`Mr. Berman?
`
`1567
`
`Mr. Berman. Aye.
`
`1568
`
`Ms. Kish. Mr. Berman votes aye.
`
`1569
`
`Mr. Nadler?
`
`1570
`
`Mr. Nadler. Aye.
`
`1571
`
`Ms. Kish. Mr. Nadler votes aye.
`
`1572
`
`Mr. Scott?
`
`1573
`
`Mr. Scott. Aye.
`
`1574
`
`Ms. Kish. Mr. Scott votes aye.
`
`1575
`
`Mr. Watt?
`
`1576
`
`Mr. Watt. Aye.
`
`1577
`
`Ms. Kish. Mr. Watt votes aye.
`
`1578
`
`Ms. Lofgren?
`
`1579
`
`Ms. Lofgren. Aye.
`
`1580
`
`Ms. Kish. Ms. Lofgren votes aye.
`
`1581
`
`Ms. Jackson Lee?
`
`1582
`
`[No response.]
`
`1583
`
`Ms. Kish. Ms. Waters?
`
`
`
`HJU104000 PAGE 79
`
`1584
`
`Ms. Waters. Aye.
`
`1585
`
`Ms. Kish. Ms. Waters votes aye.
`
`1586
`
`Mr. Cohen?
`
`1587
`
`Mr. Cohen. Aye.
`
`1588
`
`Ms. Kish. Mr. Cohen votes aye.
`
`1589
`
`Mr. Johnson?
`
`1590
`
`Mr. Johnson. Aye.
`
`1591
`
`Ms. Kish. Mr. Johnson votes aye.
`
`1592
`
`Mr. Pierluisi?
`
`1593
`
`Mr. Pierluisi. No.
`
`1594
`
`Ms. Kish. Mr. Pierluisi votes no.
`
`1595
`
`Mr. Quigley?
`
`1596
`
`[No response.]
`
`1597
`
`Ms. Kish. Ms. Chu?
`
`1598
`
`Ms. Chu. Aye.
`
`1599
`
`Ms. Kish. Ms. Chu votes aye.
`
`1600
`
`Mr. Deutch?
`
`1601
`
`Mr. Deutch. Aye.
`
`1602
`
`Ms. Kish. Mr. Deutch votes aye.
`
`1603
`
`Ms. Sanchez?
`
`1604
`
`[No response.]
`
`1605
`
`Ms. Kish. Ms. Wasserman Schultz?
`
`
`
`HJU104000 PAGE 80
`
`1606
`
`[No response.]
`
`1607
`
`Chairman Smith. The gentleman from California, Mr.
`
`1608
`
`Gallegly?
`
`1609
`
`Mr. Gallegly. How am I recorded?
`
`1610
`
`Ms. Kish. Aye.
`
`1611
`
`Mr. Gallegly. No.
`
`1612
`
`Ms. Kish. Mr. Gallegly votes no.
`
`1613
`
`Chairman Smith. The gentleman from Texas, Mr.
`
`1614
`
`Gohmert?
`
`1615
`
`Mr. Gohmert. No.
`
`1616
`
`Ms. Kish. Mr. Gohmert votes no.
`
`1617
`
`Chairman Smith. The gentleman from California, Mr.
`
`1618
`
`Issa?
`
`1619
`
`Mr. Issa. No.
`
`1620
`
`Ms. Kish. Mr. Issa votes no.
`
`1621
`
`Chairman Smith. Are there other members who wish to
`
`1622
`
`vote or change their vote?
`
`1623
`
`Ms. Jackson Lee. Aye.
`
`1624
`
`Ms. Kish. Ms. Jackson Lee votes aye.
`
`1625
`
`Chairman Smith. The clerk will report.
`
`1626
`
`Ms. Kish. Mr. Chairman, 14 members voted aye; 17
`
`1627
`
`members voted nay.
`
`
`
`HJU104000 PAGE 81
`
`1628
`
`Chairman Smith. In the opinion of the chair, the noes
`
`1629
`
`have it and the amendment to the amendment is not agreed to.
`
`1630
`
`We will now move on to the next amendment, and that
`
`1631
`
`will be offered by the gentleman from Virginia, Mr.
`
`1632
`
`Goodlatte.
`
`1633
`
`Mr. Goodlatte. Thank you, Mr. Chairman. Mr.
`
`1634
`
`Chairman, I have an amendment at the desk, Goodlatte number
`
`1635
`
`8.
`
`1636
`
`Chairman Smith. The clerk will report the amendment.
`
`1637
`
`Ms. Kish. “Amendment to the amendment offered by Mr.
`
`1638
`
`Smith to H.R. 1249 offered by Mr. Goodlatte” --
`
`1639
`
`Chairman Smith. Without objection, the amendment will
`
`1640
`
`be considered as read.
`
`1641
`
`[The information follows:]
`
`1642
`
`
`
`HJU104000 PAGE 89
`
`1786
`
`Chairman Smith. And the gentlewoman from California
`
`1787
`
`is recognized to explain her amendment.
`
`1788
`
`Ms. Chu. Mr. Chair, a longstanding goal of patent
`
`1789
`
`reform has been to improve the U.S. Patent and Trademark
`
`1790
`
`Office’s administrative procedures for challenging poor
`
`1791
`
`quality patents through reexamination. This procedure, if
`
`1792
`
`effective, can be an important tool to avoid costly
`
`1793
`
`litigation and ensure the overall quality of patents by
`
`1794
`
`encouraging the resolution of complex questions of patent
`
`1795
`
`validity by the experts at the PTO instead of lay jurors.
`
`1796
`
`Rather than expanding the availability of the PTO’s
`
`1797
`
`inter partes reexamination, the manager's amendment imposes
`
`1798
`
`new restrictions that makes invoking this procedure more
`
`1799
`
`difficult. Unfortunately, the manager's amendment creates
`
`1800
`
`an unworkable standard for initiating inter partes
`
`1801
`
`reexamination proceedings making it more difficult for
`
`1802
`
`companies to weed out bad patents.
`
`1803
`
`Instead of restricting this important process, my
`
`1804
`
`amendment would keep the current standard of a substantial
`
`1805
`
`new question of patentability. To be clear, this is the
`
`1806
`
`current threshold for entering the inter partes
`
`1807
`
`reexamination process. Since the procedure was first
`
`
`
`HJU104000 PAGE 90
`
`1808
`
`created in 1999, PTO has issued decisions in 221
`
`1809
`
`reexaminations and 90 percent of those resulted in the
`
`1810
`
`invalidation of at least patent claim. Again, 90 percent of
`
`1811
`
`the patents that go through the inter partes process under
`
`1812
`
`the current threshold are found to be defective. Even PTO
`
`1813
`
`Director Kappos testified that the current standard allows
`
`1814
`
`the PTO to weed out meritless petitions.
`
`1815
`
`This is clearly a solution without a problem. I ask
`
`1816
`
`you to support my amendment and reject the unworkable
`
`1817
`
`standard that is in the current manager's amendment.
`
`1818
`
`Chairman Smith. Thank you, Ms. Chu.
`
`1819
`
`I will recognize myself in opposition to the
`
`1820
`
`amendment.
`
`1821
`
`The balance that we have struck in the inter partes by
`
`1822
`
`raising the threshold and extending the deadline to 12
`
`1823
`
`months after the filing of a civil action is a fair deal.
`
`1824
`
`But if we do as this amendment suggests and couple such a
`
`1825
`
`1-year period of time to decide whether or not to even enter
`
`1826
`
`inter partes with a lower threshold, it could create
`
`1827
`
`problems for the PTO and open the program up to litigation
`
`1828
`
`abuse. The lower threshold standard for inter partes really
`
`1829
`
`does not make that much sense for infringing parties. Inter
`
`