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`Filed on behalf of Clearlamp, LLC
`By:
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`Matthew L. Cutler (mcutler@hdp.com)
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`Bryan K. Wheelock (bwheelock@hdp.com)
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`Douglas A. Robinson (drobinson@hdp.com)
`Harness, Dickey & Pierce, PLC
`7700 Bonhomme Ave., Suite 400
`St. Louis, MO 63105
`Phone: (314) 726-7500
`Fax: (314) 726-7501
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________
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`LKQ CORPORATION
`Petitioner
`
`v.
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`CLEARLAMP, LLC
`Patent Owner
`
`_____________
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`Case IPR2013-00020
`Patent 7,297,364
`_____________
`
`PATENT OWNER’S OPPOSITION
`TO PETITIONER’S MOTION TO EXCLUDE
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`Case IPR2013-00020
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`Table of Contents
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`INTRODUCTION ............................................................................................... 1
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`I.
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` Ex. 2004-Declaration of A. Harvey Bell ............................................................. 2 II.
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`A. Federal Safety Standards and the Relevant Market ......................................... 3
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`B. Ex. 2004—Patent Owner’s Experiments (¶¶54–55) ........................................ 6
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`III.
` Exhibit 2009—Declaration of Irving S. Rappaport ......................................... 9
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`
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` Exhibits 2012–2014—Testing compilations ..................................................10 IV.
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`
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` Exhibit 2016 and 2021—Deposition Testimony of Robert Sandau ..................12 V.
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` Ex. 2017—FMVSS 108 ..................................................................................14 VI.
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` Conclusion ......................................................................................................15 VII.
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`i
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`Case IPR2013-00020
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`I.
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`INTRODUCTION
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`
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`Clearlamp, LLC opposes LKQ Corp.’s Motion to Exclude various portions
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`of Clearlamp’s evidence in this proceeding, and requests that the Board deny the
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`motion in its entirety. As shown below, and contrary to LKQ’s representations, the
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`testimonial and documentary evidence subject to LKQ’s motion is admissible
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`under the Federal Rules of Evidence and the Code of Federal Regulations.
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`Clearlamp’s Response to LKQ’s Petition detailed LKQ’s failure to put forth
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`a prima facie case of obviousness with regard to the challenged claims. In support
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`of its Response, Clearlamp submitted extensive evidence that detailed this failure
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`by LKQ, including the expert declaration of Professor A. Harvey Bell, which fully
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`addressed the prior art, including through certain testing of the prior art method
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`and testing by third parties of the patented method. Clearlamp’s opposition also
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`addressed secondary considerations of non-obviousness, again through both expert
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`testimony (from Mr. Rappaport) and deposition testimony from a former LKQ
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`employee (Mr. Sandau) illustrating LKQ’s efforts to copy the patented process.
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`As a means to fix—post-Petition—its failure to establish a prima facie case
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`of obviousness, LKQ tries several tactics, including improperly attempting to fill
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`its evidentiary holes with deposition testimony from Clearlamp’s experts, while at
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`the same time trying to exclude other expert testimony and supporting evidence of
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`Clearlamp’s. Although LKQ does not move to exclude all of Clearlamp’s
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`1
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`Case IPR2013-00020
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`evidence (including, notably,
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`the declaration
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`testimony of Mr. Dimitris
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`Katsamberis, a clear coat expert), LKQ is still forced to overreach in its efforts to
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`exclude the evidence that is subject to its motion. For example, LKQ argues that
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`Mr. Bell’s description of testing conducted at Clearlamp is inadmissible (Ex. 2004,
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`¶¶54, 55), but then bootstraps that into an argument that ¶¶51–53 of Mr. Bell’s
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`declaration—which are based on the Kuta reference alone—are also somehow
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`inadmissible. LKQ’s overreaching illustrates the desperation embodied in its
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`Motion to Exclude—an attempt to avoid an adverse judgment in this proceeding in
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`view of the holes in its own evidence. In the end, LKQ’s Motion to Exclude must
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`fail, though, because all the evidence it complains of is properly admissible.
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` Ex. 2004-Declaration of A. Harvey Bell
`II.
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`Mr. Bell is a Professor of Engineering Practice and Co-Director of
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`Multidisciplinary Design Program at the University of Michigan. Ex. 2005. He
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`holds a Bachelor of Science degree in Mechanical Engineering from the University
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`of Michigan. Prior to his current position, Professor Bell worked for General
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`Motors for 39 years in a variety of capacities, including Executive Director of
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`Advanced Vehicle Development (North America). There, Mr. Bell was responsible
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`for ensuring that all designs met GM and government safety requirements.
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`Throughout his extensive career at GM, Professor Bell was focused on
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`vehicle safety including headlamps and tail lamps. As a result of his more than 40
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`years’ of experience in the car industry, Professor Bell is familiar with all aspects
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`of all vehicle safety systems, including vehicle lamps, and understands the
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`performance requirements of original equipment vehicle lamps (headlamps and tail
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`lamps), as well as federal vehicle safety requirements. Mr. Bell’s qualifications are
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`further summarized in his curriculum vitae. Ex. 2005. Mr. Bell is experienced and
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`skilled in the relevant field – automotive, field and vehicle safety, including
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`vehicle lamps, and offered cogent, reliable, and relevant testimony comparing the
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`patent-in-suit to the prior art at issue in this proceeding.
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`LKQ seeks to exclude two portions of Mr. Bell’s declaration. First, LKQ
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`argues that ¶¶6, 17, 22, 25–30, 41–43, 56, 58, 75, 77–79, and 87, addressing
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`federal motor vehicle safety standards and the market for refurbished car parts,
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`should be excluded as irrelevant or lacking foundation. Separately, LKQ argues
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`that ¶¶51–55 of Mr. Bell’s declaration, addressing the issue of whether the prior art
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`teaches the claims’ step of removing the old clear coating, should be excluded
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`under 37 C.F.R. 42.65. Both aspects of LKQ’s motion should be denied.
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`A.
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`Federal Safety Standards and the Relevant Market
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`
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`LKQ first argues that ¶¶17, 25, 30, 77, and 871 of Mr. Bell’s declaration,
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`which address federal vehicle safety standards, should be excluded as irrelevant,
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`1 Notably, Paragraph 87 of Mr. Bell’s declaration is a discussion of his review of
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`the infringing LKQ process. Because it infringes the method of the ‘364 patent
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`because, per LKQ, the ‘364 patent “does not mention federal vehicle safety
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`requirements.” Mot. at 1. Although the ‘364 patent does not use those exact
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`words, the patent does discuss returning a lamp to an “original equipment
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`condition,” and, thus, LKQ goes too far in arguing that safety standards are not
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`relevant to the patent. See, e.g., Ex. 1001, 1:8–10 and 4:19–23. Rather, and as
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`testified to by Mr. Bell, original equipment lamps must comply with Federal Motor
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`Vehicle Safety Standards (FMVSS 108). Thus, and as also testified to by Mr. Bell,
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`a person of ordinary skill would understand the ‘364 patent to implicate those
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`standards by teaching that its processes can return a lamp to optical quality that is
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`equivalent to an OEM lamp. See, e.g., ¶ 30 (“In my opinion, the steps set forth in
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`the ‘364 patent describe a methodology that can restore a damaged vehicle lamp to
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`original equipment condition, including such that it meets federal safety
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`requirements.”). Paragraphs 17, 25, 30, 77, and 87 thus explain why a person of
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`ordinary skill would understand that the ‘364 patent is directed to the OEM market.
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`Mr. Bell also explains that the market the ‘364 patent is directed to is
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`different from the market to which LKQ’s prior art is directed. Specifically, by not
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`removing the lamp from the vehicle, the Kuta reference is directed to a different
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`problem, and obtains a different result than the method disclosed and claimed in
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`LKQ’s process tangentially relates to the objection raised by LKQ. Federal safety
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`standards are not, however, specifically discussed in paragraph 87.
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`the ‘364 patent. Regardless, whether the specific descriptions Mr. Bell uses (i.e.,
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`OEM replacement parts market versus consumer retail market) appear verbatim in
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`the patent is not the test for admissibility. Mr. Bell testified that he had reviewed
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`both the patented invention and the prior art, and testified that a person of ordinary
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`skill in the art would understand from those teachings that the ‘364 patent is
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`directed to a different market than the prior art at issue in this proceeding. Further,
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`to substantiate that opinion, Mr. Bell considered the FMVSS 108 standard and tests
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`comparing the teachings of Kuta to the teachings of the ‘364 patent. Regardless of
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`whether LKQ disagrees with Mr. Bell’s opinion, it cannot be said that he does not
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`provide a foundation for his testimony. And, LKQ is notably unable to point to
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`any evidence or expert testimony that counter’s Mr. Bell’s opinions.
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`Further, LKQ’s allegation (at 2) that Mr. Bell has “no experience with
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`polycarbonate headlamps at all” is misleading. Rather, Mr. Bell testified that he
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`personally did not refurbish a polycarbonate lamp. Ex. 2026 at 41:22–42:6. But,
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`Mr. Bell has extensive experience that directly translates to the OEM market,
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`vehicle safety and standards, including with respect to head lamps. Ex. 2005.
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`Moreover, the description of the relevant field in the ‘364 patent, is broad enough
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`to encompass Mr. Bell’s qualifications. In any case, there is no requirement of a
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`perfect match between the expert’s experience and the field of the patent. See SEB
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`S.A. v. Montgomery Ward & Co., 594 F.3d 1360, 1373 (Fed. Cir. 2010).
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`B.
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`Ex. 2004—Patent Owner’s Experiments (¶¶54–55)
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`An issue in this proceeding is whether Kuta teaches the ‘364 patent’s
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`claimed step of removing the clear coating. Mr. Bell testified that the process
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`taught by Kuta would not remove a clear coating from the surface of a lamp. This
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`was supported by Mr. Bell’s analysis of Kuta itself (see Ex. 2004, ¶¶ 51–53), and
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`confirmed by experiments conducted at Mr. Bell’s request (id. at ¶¶ 54–55). LKQ
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`lacks any countervailing evidence, and thus is left to move to exclude Mr. Bell’s
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`testimony on this point. LKQ’s arguments are misplaced.
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`First, LKQ overreaches again by arguing that “Mr. Bell Lacks Any
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`Knowledge About the Experiments.” Mot. at 2 (emphasis in original). Mr. Bell
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`has sufficient knowledge to testify regarding the experiments. Paragraphs 54 and
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`55 of Mr. Bell’s confirm his view that Kuta’s teaching of hand sanding corners of a
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`lens with 1500 grit sandpaper for about 5 minutes would not remove the clear coat.
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`Those paragraphs fully set forth the pertinent experimental conditions important to
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`Mr. Bell, including the grit of sandpaper used, length of time, and sanding method.
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`Those conditions track the ‘364 patent and Kuta, respectively. Further, Mr. Bell
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`provided video links showing the experiment described in ¶55.
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`LKQ argues that ¶¶54 and 55 should be excluded because Mr. Bell testified
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`at his second deposition that he did not know certain details of that testing, such as
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`whether the lamps were new or used, the identity of the person doing the sanding,
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`or exactly what clearing coating was used. Mot. at 2–3. LKQ provides no
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`indication for why these details matter to the opinion expressed by Mr. Bell, much
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`less an explanation for why the experiments must be excluded without it. Indeed,
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`LKQ provides no evidence regarding what the proper conditions should have been.
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`LKQ also complains that Mr. Bell did not know the pressure being applied,
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`and did not conduct the experiments himself. But the pressure applied was
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`sufficient for Mr. Bell, and no countervailing evidence has been presented to refute
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`his opinion. With respect to the fact that Mr. Bell did not physically conduct the
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`experiments, LKQ overlooks the principle that experts are entitled to rely upon
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`information from others in forming their expert opinions. Indeed, FRE 703 states
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`that facts or data underlying an expert’s opinion do not need to be admissible.
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`FRE703. Even if the Board determines that the underlying tests are not admissible,
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`that does not exclude Professor Bell’s testimony. At best, the exclusion of the tests
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`would go to the appropriate weight to be given Professor Bell’s testimony.
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`Second, LKQ’s “Underlying Data” argument is a red herring. LKQ also
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`complains that ¶¶54 and 55 of Mr. Bell’s declaration fail to satisfy § 42.65 because
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`the “underlying data” for the experiments is allegedly not in evidence. Mot. at 3–
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`4. At threshold, it is unclear what “underlying data” LKQ believes should be
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`provided. Paragraph 54 shows a picture that illustrates the difference between a
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`lamp surface sanded for 5 minutes with 1200 grit sandpaper versus a lamp surface
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`sanded with 320 grit sandpaper. The only point is that different sandpaper grits
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`have different effects—and this is fully supported by the experimental conditions
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`and picture set forth in paragraph 54. Paragraph 55 similarly illustrates the
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`different effects of 1500 grit sandpaper versus 320 grit sandpaper, again providing
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`pictures showing the results. Moreover, Mr. Bell’s declaration provides URL links
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`(thus authenticating those links and placing them into evidence).2 That is the
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`information Mr. Bell relied on to form his opinions, and LKQ’s contention that
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`more “underlying data” is needed to evaluate the experiments—or that such data
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`even exists—is unsupported and not a basis for exclusion.
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`Further, LKQ’s bootstrapping argument for exclusion of paragraphs 51–53
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`is inappropriate and should be rejected. LKQ asserts that ¶¶51–53 “rely on the
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`experiments” shown in ¶¶54–55, but in reality the reverse is true: ¶¶54 and 55
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`confirm Mr. Bell’s opinions that are set forth in ¶¶51–53 (see ¶54: “I requested
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`that Clearlamp conduct an experiment to illustrate this point.”). Rather than
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`“relying” on the experiments, Mr. Bell’s opinions in ¶¶51–53 are based on what a
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`person of ordinary skill in the art would understand from the disclosures of Kuta
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`and the ‘364 patent. The admissibility of ¶¶54–55 has no effect on that opinion.
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`2 Clearlamp believes that the links in Mr. Bell’s declaration properly place the
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`videos into evidence. At the very least, LKQ has had fair access to the videos.
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`Clearlamp will provide a DVD containing the videos if the Board wishes.
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` Exhibit 2009—Declaration of Irving S. Rappaport
`III.
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`
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`LKQ seeks to exclude Ex. 2009 in its entirety, yet, only addresses
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`paragraphs 19–50. LKQ contends that Mr. Rappaport’s declaration should be
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`excluded under 37 C.F.R. §42.65(a) and FRE 702/703. Mr. Rappaport
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`appropriately opined on issues of patent validity, based on fifty years of specialized
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`knowledge and experience in intellectual property and business, and on his study
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`of the facts in this case. Id. Any discussion of patent law was included for
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`context, and not legal opinions on patent law. See e.g., Ex. 2009 ¶¶27, 31-32.
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`Mr. Rappaport testified as the underlying grounds of the quality of the
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`examination performed by the Examiner and the Board’s decision to institute the
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`trial. Specifically, Mr. Rappaport discusses the disclosures in the prior art cited by
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`the Examiner and the Board and how those disclosures do not invalidate the patent.
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`Mr. Rappaport does not opine whether the Patent Office’s actions were right or
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`wrong. In fact, Mr. Rappaport does not make any judgment as to the soundness of
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`the decisions. See Ex. 2009, ¶¶18–29.
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`Further, Mr. Rappaport’s opinions concerning secondary considerations of
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`non-obviousness (e.g., Ex. 2009, ¶¶31–49)—such as LKQ’s implementation of the
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`Clearlamp process, and commercial success—are permissibly based on his review
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`of the facts, his extensive experience in the business aspects of patent protection
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`(see Ex. 2010, Rappaport CV), and, regarding infringement, the conclusions of
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`other experts in reaching his opinions (see Ex. 2009, ¶¶25, 45, noting reliance on
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`Mr. Bell’s and Mr. Katsamberis’s opinions). FRE 702(b)-(d); FRE703. Further,
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`Mr. Rappaport’s opinions on the ultimate issue are not a basis for exclusion. FRE
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`704(a). Finally, the data concerning LKQ’s infringing sales (shown in Ex. 2009,
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`¶47) is relevant independently of Mr. Rappaport’s opinions, and should not be
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`excluded for that reason. Because Mr. Rappaport provides relevant and helpful
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`testimony, LKQ’s Motion to Exclude his declaration should be denied.
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` Exhibits 2012–2014—Testing compilations
`IV.
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`LKQ seeks to exclude Exhibits 2012–2014, asserting lack of foundation,
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`authenticity and compliance with Rule 42.65(a) or (b). Exhibits 2012–2013 are the
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`results of testing conducted by original equipment parts companies on headlamps
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`refurbished according to the Clearlamp process. These exhibits illustrate the
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`commercial utility of the claimed invention.
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`LKQ incorrectly contends that “no witness in this proceeding” has been able
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`to explain why exhibit 2012 reflects testing on lamps. In response to LKQ’s prior
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`objections to exhibits 2012, 2013, and 2014, Clearlamp timely submitted the
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`declaration of Michael Asselta to address their objections and attest to the nature of
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`the documents. Ex. 2022. As stated in that declaration, Ex. 2012 “describes
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`separate testing conducting by General Motors, North American Lighting and GE
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`Momentive for America Bumper (an affiliate of Clearlamp), General Motors and
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`Volvo.” Mr. Asselta’s declaration also authenticates exhibit 2013 and 2014.
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`Regarding exhibit 2012, Mr. Asselta testified that exhibit 2012 contains
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`“various tests that have been performed by outside parties.” Ex. 2027 at 30:8–22.
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`Mr. Asselta also testified that pages 5–7 were received from a General Motors
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`engineer and “outline engineering standards from General Motors.” Ex. 2027 at
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`31:16–24; 32:4–17. Mr. Asselta testified as to the coatings used in the testing and
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`provided testimony on how the tests were conducted, who conducted the tests, and
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`the origin of the lamps used in the testing. In response to LKQ’s questioning, Mr.
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`Asselta testified that the lamps used were refurbished according to the ‘364 patent,
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`provided by Clearlamp, and submitted to the companies who did the testing. Ex.
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`2027 at 37:13–25; 38:8–39:9; 39:10–5; 40:9–18; 43:6–21. Further, Mr. Asselta
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`testified that exhibit 2014 contains photographs received from General Motors
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`Engineering. Ex. 2027 at 45:9–14. Mr. Asselta testified that the photographs are
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`“close-ups of Clear headlamp assembly lenses” and are “refinished samples.” Ex.
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`2027 at 45: 46:3. Mr. Asselta testified that “refinished samples” shown in exhibit
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`2014 are comparing “known approved coatings” to “OEM assemblies that have
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`been refurbished using [the ‘364 patent] process.” Ex. 2027 at 46:7–10.
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`LKQ’s other attacks on Exs. 2012–2014 are likewise unavailing. First,
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`while Mr. Asselta admitted he did not perform the refurbishment, he was able to
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`testify about the process that was used. Specifically, he testified that the depicted
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`lamps were refinished by Clearlamp using the ‘364 process. Ex. 2027 at 46:11–15.
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`He further testified that the depicted lamps were tested for General Motors using
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`the GE Momentive Product. Ex. 2027 at 46:22–25.
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`Second, the fact that Mr. Asselta did not know some minor aspects of the
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`documents, for example the meaning of acronyms, is not relevant. Third, Ex. 2012
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`is not “litigation motivated.” The testing results contained in Ex. 2012 all predate
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`litigation with LKQ. Instead, the independent documents were compiled by
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`Counsel as an exhibit group. Clearlamp has proved ample ground demonstrating
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`the relevance, foundation and authenticity of exhibits 2012–2014, and LKQ’s
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`Motion to Exclude them should be denied.
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` Exhibit 2016 and 2021—Deposition Testimony of Robert Sandau
`V.
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`LKQ argues that the deposition testimony of Mr. Sandau should be excluded
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`for three reasons: (1) it was the result of improper coaching; (2) some of the
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`testimony was the result of leading questions; and (3) it is hearsay. Each of these
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`efforts to avoid Mr. Sandau’s testimony must fail.
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`First, LKQ complains about a pre-deposition conversation between
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`Clearlamp’s counsel and Mr. Sandau.3 Ex. 2016, 67:1–3. But, the Trial Practice
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`3 LKQ failed to raise its coaching objection at Mr. Sandau’s deposition. 77 Fed.
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`Reg. 48612 at 48623-24 (Aug. 14, 2012).
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`Guide limits the amount of advice that can be given during a cross-examination
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`portion of a deposition. See 77 Fed. Reg. 48756 at 48772. This prohibition only
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`applies while cross-examination is being conducted, and does not apply to any
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`other time period. Case No. IPR2013-00290, Paper 21 (Nov. 25, 2013). There is
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`no allegation that Clearlamp’s counsel engaged in inappropriate coaching during
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`cross-examination and LKQ fails to cite a single example of coaching that
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`occurred during the deposition. LKQ offers no legal basis for a finding that an
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`interview of a third-party witness, prior to a deposition, is improper coaching that
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`merits the exclusion of any later testimony from that witness. Further, Mr. Sandau
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`confirmed his answers were his own and not provided by Clearlamp’s attorneys.
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`Ex. 2016, 66:12–25; 67:10–19. Thus, Mr. Sandau’s testimony was true, accurate
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`and proper, and, LKQ’s Motion to Exclude should be denied.
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`Second, LKQ argues that the Sandau testimony should be excluded because
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`some of the questions were allegedly leading.4 However, leading questions are
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`authorized on cross-examination. FRE 611(c)(1). Leading questions are also
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`allowed where the witness is “identified with an adverse party.” FRE 611(c)(2).
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`Mr. Sandau is a former operations manager at LKQ (Ex. 2016, 12:4–13:21), and
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`4 Further, LKQ provides justification or legal basis for how these 16 examples are
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`improper and how they require the exclusion of Mr. Sandau’s entire deposition.
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`thus, plainly “identified” with LKQ. Thus, even if any of the questions LKQ
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`complains of were leading, those questions are still allowable under FRE 611.
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`Third, to the extent LKQ attacks Mr. Sandau’s testimony based on hearsay,
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`LKQ has waived those objections because it failed to raise them during the
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`deposition and failed to raise them during its formal objections. 37 C.F.R.
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`§42.53(f)(8) 77 Fed. Reg. 48612 at 48623–24 (Aug. 14, 2012). Because of LKQ’s
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`failure to state its hearsay objection, Clearlamp is no longer in a position to
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`rephrase any questions, resume its questioning to ascertain the basis of the
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`challenged testimony and the exclusion of the testimony would be unfairly
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`prejudicial to Clearlamp. Regardless, Mr. Sandau’s deposition testimony about his
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`prior conversations with Mr. Paperi and Mr. Wagman are admissible under the
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`former testimony exception of FRE 804(b)(1), because there is no mechanism by
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`which Clearlamp can procure Mr. Sandau’s attendance and testimony at the
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`hearing in this matter. Further, Mr. Sandau’s testimony concerning statements by
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`Mr. Wagman go to Mr. Wagman’s intent (state of mind), and thus, are admissible
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`under FRE 803(3).
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` Ex. 2017—FMVSS 108
`VI.
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`Finally, LKQ argues that Federal Motor Vehicle Safety Standard 108 (Ex.
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`2017)—which indisputably covers vehicle lamps—is irrelevant to this proceeding.
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`This is incorrect, because Ex. 2017 meets the FRE 401 standard for relevance. The
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`‘364 patent is directed to methods for refurbishing headlamps. As noted, the ‘364
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`patent’s specification teaches that the invention is directed to a process for
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`returning lamps to OEM-equivalent quality. See Ex. 1001, 1:8–10, 4:19–23. LKQ
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`does not dispute that FMVSS 108 is directed to the requirements—including
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`optical characteristics—of original equipment lamps. FMVSS 108 is thus relevant
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`to the level of quality implicated by the ‘364 patent’s description of its invention.
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`Moreover, Patent Owner’s proposed amended claim 25’ explicitly recites that the
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`method steps “are performed to restore the lamp to its original equipment
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`condition.” See Patent Owner’s Motion to Amend (Paper No. 38) at 3.
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` Conclusion
`VII.
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`For the foregoing reasons, LKQ’s Motion to Exclude should be denied.
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`Dated: December 3, 2013
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`Respectfully submitted by:
`/Matthew L. Cutler /
`MATTHEW L. CUTLER, Reg. No. 43574
`BRYAN K. WHEELOCK, Reg. No. 31441
`DOUGLAS A. ROBINSON, Reg. No. 59703
`Harness, Dickey & Pierce, PLC
`7700 Bonhomme Ave., Suite 400
`St. Louis, MO 63105
`Phone: (314) 726-7500
`Fax: (314) 726-7501
`mcutler@hdp.com
`bwheelock@hdp.com
`drobinson@hdp.com
`
`Attorneys for Patent Owner, Clearlamp,
`LLC
`
`
`
`15
`
`
`
`
`Case IPR2013-00020
`
`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
`
`
`
`It is hereby certified that on this 3rd day of December, 2013, a copy of the
`
`foregoing document was served via Electronic Mail, upon the following:
`
`Alan L. Barry
`Jason Engel
`Benjamin E. Weed
`Viren S. Soni
`K&L Gates LLP
`70 West Madison Street, Suite 3100
`Chicago, Illinois 60602
`Phone: (312) 372-1121
`Fax: (312) 827-8000
`alan.barry@klgates.com
`jason.engel@klgates.com
`benjamin.weed@klgates.com
`viren.soni@klgates.com
`
`Attorneys for Petitioner, LKQ Corporation
`
`
`
`
`/Matthew L. Cutler /
`
`
`
`16
`
`
`
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