throbber
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Applicant:
`
`Darbee et al.
`
`Universal Remote Control, Inc.
`
`Case No.:
`
`IPR2013-00127
`
`v.
`
`Filing Date:
`
`2/23/2001
`
`Patent No.:
`
`6,587,067
`
`Title:
`
`Universal Remote
`Control With Macro
`Command Capabilities
`
`Universal Electronics, Inc.
`
`Trial Paralegal: Andrew Kellog
`
`Attny Doc.: 059489.05US5/IPR
`
`DECLARATION OF PATRICK H. HAYES
`
`I, Patrick H. Hayes, hereby declare as follows:
`
`Background And Qualifications
`
`1.
`
`My name is Patrick H. Hayes. I recently retired from full-time employment
`
`with Patent Owner Universal Electronics, Inc. (“UEI”), but I continue to consult
`
`for them occasionally. I served in various engineering and development capacities
`
`in the electronics industry since 1969, including fourteen years in commercial
`
`computers and networking, eight years in telecommunications, and twenty years in
`
`consumer electronics.
`
`2.
`
`In 1968, I earned a Bachelor of Science degree in the field of Electrical
`
`Engineering from the University of Witwatersrand in Johannesburg, South Africa.
`
`3.
`
`Between the years of 1969 and 1973, I worked for the South African
`
`Railroad Administration, where my responsibilities included the design and
`
`Universal Electronics Exhibit 2006, Page 1
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`

`

`installation of communication networks for purposes such as railroad car control,
`
`oil pipeline telemetry and airline reservation systems.
`
`4.
`
`Between the years of 1973 and 1975 I worked for Computer Sciences
`
`Sigma Ltd. as a software development engineer for networked systems.
`
`5.
`
`Between the years 1975 and 1987 I worked for Computer Automation Inc.
`
`(later SyFA Data Systems) in the capacity of Director of Engineering, overseeing
`
`product development of hardware and software for distributed processing and local
`
`area network systems.
`
`6.
`
`Between the years 1987 and 1992 I worked for Lear Siegler Inc.
`
`Telecommunication Division as Director of Engineering overseeing the hardware
`
`and software development of digital telephony transmission systems.
`
`7.
`
`Between the years of 1992 and 2013, I worked for UEI, a major developer
`
`and manufacturer of universal remote controls, performing at various times as
`
`Director of Software Development, Vice President of Technology Development,
`
`Vice President of Core Technology, and Vice President of Intellectual Property.
`
`8.
`
`I am a named inventor on over sixty granted and pending U.S. patents and
`
`patent applications, the majority of which relate to universal remote control
`
`technology.
`
`9.
`
`I have been retained in this matter by UEI to provide an analysis of U.S.
`
`Patent No. 6,587,067 (the “‘067 patent”) pursuant to the Board’s decision
`
`2
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`instituting an inter partes review of Claims 1-6 of the ‘067 patent, and specifically
`
`to rebut the opinions of Petitioner’s expert, Dr. Alan Herr.
`
`10.
`
`I am being compensated at the rate of $125 per hour for my work. My fee is
`
`not contingent on the outcome of this matter, or on the positions I have taken in
`
`this declaration. I have no financial interest in Petitioner Universal Remote
`
`Control, Inc.
`
`11.
`
`It is my understanding that my former employer UEI owns the ‘067 patent. I
`
`have no financial interest in UEI.
`
`The State Of The Art As Of The Priority Date Of The ‘067 Patent
`
`12.
`
`In his declaration, Dr. Herr opined that, as of the priority date of the ‘067
`
`patent, a person of ordinary skill in the art would have purportedly been aware of
`
`three different methods of configuring a universal remote control, of which I am in
`
`agreement on the following two: (1) “learning” remote controls, which learn how
`
`to operate a particular appliance from the remote control that was sold and
`
`packaged alongside the particular appliance; and (2) “scan and set” remote
`
`controls, which scan through a variety of command codes while the user watches
`
`the particular appliance for an observable effect thereon, at which point the user
`
`instructs the remote to utilize that command code for that appliance.
`
`13. However, I disagree with Dr. Herr that one of ordinary skill in the art was
`
`aware of a third method of configuration, which I will refer to as a direct entry
`
`3
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`method, at that time. In the direct entry method, the universal remote control is
`
`pre-programmed with a large library of command codes that are predisposed to
`
`enable the universal remote control to operate a plurality of different home
`
`appliances sold by different manufacturers. The user directly identifies the remote
`
`control to operate with a particular appliance by entering an identification code—
`
`for example a three- or four-digit number. Each identification code corresponds to
`
`a set of command codes and data in the library stored in the remote control, which
`
`control a particular appliance. Based on my own experience in the industry and
`
`my review of the documents I have considering herein, this particular methodology
`
`was first disclosed to those of ordinary skill in the art through UEI’s filing in 1987
`
`of the ancestor patent application that eventually led to the ‘067 patent.
`
`Summary And Basis Of Opinions
`
`14.
`
`It is my opinion that the prior art of record in this proceeding is insufficient
`
`to anticipate or render obvious the ‘067 patent because each of the prior art
`
`references relied on by Petitioner lacks one or more key elements disclosed and
`
`claimed by the ‘067 patent.
`
`15.
`
`I understand that patent claims are unpatentable as obvious when the
`
`differences between the claimed subject matter and the prior art are such that the
`
`subject matter as a whole would have been obvious at the time the invention was
`
`made to a person having ordinary skill in the art in the relevant field of technology.
`
`4
`
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`It is my understanding that an obviousness analysis involves consideration of the
`
`following factors: (1) the scope and content of the prior art; (2) the differences
`
`between the claimed invention and the prior art; (3) the level of ordinary skill in
`
`the art; and (4) secondary considerations of non-obviousness.
`
`The ‘067 Patent Is Patentable Over Rumbolt In View Of Magnavox
`
`16. U.S. Patent No. 4,774,511 to Rumbolt et al. (“Rumbolt”) discloses a
`
`universal remote control for controlling a plurality of home appliances from
`
`different manufacturers, which are identified to the remote control using a set of
`
`binary DIP (dual in-line package) switches.
`
`17.
`
`PR Newswire (April 9, 1987), “Magnavox Unveils Total Remote Tuning
`
`System and Second Generation Universal Remote Control,” [Press Release], NAP
`
`Consumer Electronics Cop., Retrieved from DIALOG (“Magnavox”) discloses a
`
`universal remote control for controlling a plurality of home appliances from
`
`different manufacturers, whereby the user can program the remote control using a
`
`numeric code provided in the operating manual. “To identify a particular VCR, a
`
`viewer simply presses the REC button on the remote, presses the on/off button on
`
`the VCE (sic) or cable box and enters the appropriate code.” (Magnavox, at 2.)
`
`18. At the outset, it is my opinion that Magnavox is, at best, ambiguous as to
`
`how its remote control is programmed to operate with a particular appliance.
`
`Magnavox states that
`
`5
`
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`The identification process has been simplified. Each VCR and cable brand
`is listed in the front of the operating manual with an assigned number. For
`instance, GE is 01, RCA is 03 and Zenith is 15. To identify a particular
`VCR, a viewer simply presses the REC button on the remote, presses the
`on/off button on the VCE or cable box and enters the appropriate code.
`
`(Magnavox, at 2 (emphasis added).) Simply put, while Magnavox notes elsewhere
`
`in the press release that the remote includes a keyboard, that short and simple
`
`marketing release is devoid of any specifics. In particular, does not describe how
`
`the appropriate code is entered, e.g. via pushbuttons, DIP switches, or rotary
`
`switches labeled with digits 0-9. Such rotary digit switches were well-known in
`
`the art at the time of Magnavox, and were a user-friendly substitute for binary DIP
`
`switches. If retaining the programming of the remote control during battery
`
`replacement was an important consideration of the remote control in Magnavox,
`
`one of ordinary skill in the art who was familiar with the Rumbolt patent may have
`
`preferred such rotary digit switches over pushbuttons to avoid the added cost of
`
`backup batteries and additional software for enabling multi-modal pushbuttons.
`
`19.
`
`Further, the minimal description provided by Magnavox appears to be at
`
`odds with itself. If pressing the “REC” button invokes the setup mode, it is unclear
`
`how a user issues a routine “record” command request to the VCR without
`
`inadvertently switching the remote control to setup mode.
`
`20. Dr. Herr argues that Rumbolt in combination with Magnavox discloses and
`
`renders Claims 1-6 of the ‘067 patent obvious because “one of ordinary skill in the
`
`6
`
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`art would have found it obvious to replace the DIP switches used by Rumbolt with
`
`the pushbutton code entry taught by Magnavox.” (Declaration of Alan J. Herr,
`
`Ph.D (“Herr Decl.”), at ¶28.) Dr. Herr also argues that replacing the DIP switches
`
`of Rumbolt with the pushbuttons of Magnavox could have been implemented
`
`“with obvious modifications to electronic circuitry and programming code,” and
`
`that one of ordinary skill in the art would have been motivated to make such
`
`modifications to “lower the cost of manufacture by removing the need for the DIP
`
`switches.” (Id., at ¶¶ 29-30.) In my opinion, those arguments are fundamentally
`
`flawed.
`
`21. Using the DIP switches of Rumbolt, the remote control’s primary memory
`
`could consist solely of low-cost Read-Only Memory (ROM). In essence, the DIP
`
`switches act as a register to store the user provided identification codes necessary
`
`to identify the particular appliance. By contrast, with the pushbutton approach, it
`
`is necessary to utilize more expensive Random Access Memory (RAM), i.e.
`
`read/write memory, in which a register maintained within the RAM is used for
`
`storing the codes necessary to identify appliances.
`
`22. At the time of the invention of the ‘067 patent, most microprocessors
`
`included a small amount of scratchpad RAM. See Rumbolt, Col. 4, ll. 18-19 and
`
`Fig. 1 (stating: “As illustrated in FIG 1., RAM 44 is internal to microprocessor
`
`10.”) However, the RAM in such devices was volatile, meaning the data would be
`
`7
`
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`lost upon the loss of power, and therefore would have required users to re-program
`
`the remote control every time the batteries were changed. Thus, in the mid 1980s,
`
`one of the key reasons for using DIP switches was to preserve the stored identities
`
`of appliances when the batteries were removed (to allow them to be replaced).
`
`23.
`
`In my opinion, even assuming for the sake of argument that Magnavox did
`
`disclose programming a universal remote via its keypad, one of ordinary skill in
`
`the art would still not have combined Rumbolt with Magnavox because using
`
`keypad buttons to establish a transient value that would have to be re-entered every
`
`time the batteries were replaced would not have been considered an effective
`
`solution. To address that problem, the ‘067 patent discloses a large RAM capable
`
`of storing all of device identification codes, which RAM is directly connected to
`
`both a lithium battery 52 to sustain the contents of RAM memory 54 when AAA
`
`batteries 46 are depleted or removed, together with a backup capacitor with “a
`
`discharge time of about 10 minutes, providing ample time to change (if necessary)
`
`the lithium battery 52 itself, all without losing the instructions and data stored in
`
`the RAM 54.” (‘067 patent, Col. 6, ll. 55-62; see Col. 8, ll. 46-48 (stating: “It is to
`
`be noted that the circuitry 42 has no ROM and all instruction codes and code data
`
`are loaded directly into the RAM 54”).) The additional circuitry necessary to
`
`provide the remote’s RAM with backup power, including the lithium battery itself,
`
`would have been more complex and more costly than a simple DIP switch. Thus,
`
`8
`
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`

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`and contrary to the claims of Petitioner’s expert, combining Rumbolt with
`
`Magnavox would have required a higher cost to manufacture, because removing
`
`the DIP switches inherently requires the use of additional, more expensive
`
`components. However, as the inventors of the ‘067 patent appreciated, this more
`
`expensive device involved a massive benefit—the remote control could also be
`
`upgradeable by allowing new command codes to be added to the library after
`
`manufacture and/or sale. (‘067 patent, Col. 8, ll. 46-49 (noting that storing all
`
`instruction codes and code data in the RAM “allows for infinite upgradability in
`
`the field via the serial ports 1, 2, 3”).)
`
`24.
`
`The greater expense of eliminating Rumbolt’s DIP switches also arises from
`
`the need for additional software. The pushbuttons on a remote control
`
`programmed via a DIP switch, like the one disclosed in Rumbolt, each have a
`
`single, dedicated function, such as controlling volume, power, or sending
`
`numerical values. By contrast, the pushbuttons of the remote control disclosed in
`
`the ‘067 patent are necessarily multi-modal: in one function, they act to program
`
`the remote to particular appliance, while in another, they perform the typical
`
`functions of remote control buttons (e.g. transmitting number commands to a
`
`television). As a result, combining Rumbolt with Magnavox would require a
`
`substantial amount of new software to manage and keep track of the current mode
`
`of operation, because each keystroke must be interpreted in the context of the
`
`9
`
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`remote’s current state, rather than simply as a fixed function. The creation of such
`
`additional software represents yet another cost that one of ordinary skill in the art
`
`would not undertake without the inventive contributions of the ‘067 patent.
`
`25.
`
`Thus, contrary to Dr. Herr’s claims, replacing the DIP switches of Rumbolt
`
`with the alleged push buttons of Magnavox would not involve “obvious
`
`modifications to electronic circuitry and programming code,” and would not
`
`“lower the cost of manufacture by removing the need for the DIP switches.”
`
`Indeed, substantial modifications would have been necessary, including the use of
`
`more expensive memory circuitry and backup batteries, as well as a substantial
`
`amount of new software for handling the multi-functionality of the pushbuttons.
`
`The ‘067 Patent Is Patentable Over Rumbolt In View Of Magnavox and Evans
`
`26. U.S. Patent No. 4,825,200 to Evans et al. (“Evans”) discloses a “learning”
`
`universal remote control for controlling a plurality of home appliances from
`
`different manufacturers, wherein the universal remote must be “taught” the codes
`
`and data necessary to operate a particular appliance by the OEM remote control
`
`that was sold and packaged alongside the particular appliance. While through the
`
`remote of Evans may stores codes and data during the course of its learning, but it
`
`does not disclose a remote control having a “library of codes and data” as that term
`
`is used in the ‘067 patent.
`
`10
`
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`

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`27.
`
`Each of the claims of the ‘067 patent requires a universal remote control
`
`having a “library of codes and data for use in transmitting operating commands to
`
`a plurality of different home appliances of different manufacturers.” In my
`
`opinion, based on the totality of the specification of the ‘067 patent, one of
`
`ordinary skill in the art would have understood the term “library of codes and data”
`
`to refer to a table programmed into the remote control, the table comprising a
`
`variety of command codes corresponding to particular appliances of different
`
`manufacturers.
`
`28.
`
`The ‘067 patent describes one aspect of the invention as
`
`methods for using the remote control device for finding, in a library or table
`of code data for generating infrared codes for operating different electrical
`apparatus manufactured by different manufacturers stored in a RAM of the
`remote control device, the code data for generating infrared coded signals
`for operating a particular apparatus.
`
`(‘067 patent, Col. 1, ll. 52-58.) The “library or table of code data” is clearly
`
`identified as (1) comprising codes for operating different appliances of different
`
`manufacturers; and (2) being stored in the memory of the remote control device.
`
`29.
`
`Fig. 17 of the ‘067 patent is a flow chart that describes the direct entry
`
`method of programming the remote control to operate with a particular appliance.
`
`(‘067 patent, Col. 10, ll. 44-46; Fig. 17.) The eighth step in the process involves
`
`the receipt of an identification code (referred to in the specification as a “blink
`
`code”) via the pushbuttons, and the ninth step comprises looking up the
`
`11
`
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`

`

`identification code in memory (‘067 patent, Col. 10, ll.64-67; Fig. 17.)
`
`Accordingly, the “library of codes and data” required by the claims of the ‘067
`
`patent requires a table of data stored in memory comprising codes identifying
`
`particular appliances.
`
`30. Under that construction of “library of codes and data,” Evans does not
`
`disclose such a library, even after it has learned the codes of a user’s household
`
`appliances. Indeed, the “library of codes and data” disclosed by the ‘067 patent
`
`enables the remote control described by that patent to inherently operate a large
`
`number of appliances directly out of the box simply by setting the remote control
`
`(using identification codes listed in a table in the instruction booklet) to use the
`
`codes and data already stored in memory at the time of manufacture. By contrast,
`
`the Evans remote control must be taught each code and piece of data to operate
`
`each appliance. Even after the Evans remote control has been taught a variety of
`
`appliances, it still does not comprise such a “library of codes and data” because
`
`there is no library of data stored on the remote control that enables it to operate
`
`other appliances without learning from a separate remote control device. Rather,
`
`the Evans remote control can only be matched to a different appliance by teaching
`
`the remote each associated command code separately, whereas the ‘067 patent
`
`discloses a remote control inherently capable of operating a wide variety of devices
`
`using a pre-existing library.
`
`12
`
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`

`

`The ‘067 Patent Is Patentable Over Wozniak In View Of CORE
`
`31. U.S. Patent No. 4,918,439 to Wozniak et al. (“Wozniak”) discloses a remote
`
`control that can be programmed to operate a plurality of home appliances.
`
`(Wozniak, Abstract.)
`
`32. Rob Karr, Robert Retzlaff, Tom Johnson, Chuck Van Dusen and Meg
`
`Beeler, “CORE Reference Manual,” 1987 (“CORE”), is a user reference manual
`
`for a remote control that allegedly embodies the invention disclosed in Wozniak.
`
`33.
`
`The CORE remote control is incapable of having its pushbuttons activated to
`
`directly identify an appliance. Rather, the function of the pushbuttons of the
`
`CORE remote can be switched between various “pages” in its memory
`
`corresponding to physical changes in a journal provided with the remote. Those
`
`pages may be entirely empty. It is also possible for a single page to include
`
`commands for multiple appliances. Still further, it is possible for some of the
`
`commands for a particular appliance to be stored on one “page” and other
`
`commands to be stored on another “page.” Thus, switching between the “pages”
`
`of the CORE remote does not directly identify any particular device. Put simply,
`
`CORE does not disclose any manner by which a user can direct the remote to
`
`match to a particular appliance—for example, Sony TV model ABC-123—via its
`
`pushbuttons.
`
`13
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`34. Moreover, the CORE remote control does not—and cannot— “directly
`
`identify each of the plurality of home appliances of different manufacturers” as
`
`required by each of the claims of the ‘067 patent. It is my understanding that the
`
`United States District Court for the Central District of California has construed
`
`relevant claim language in a Claim Construction Order dated February 1, 2013. In
`
`that Order, Judge Andrew A. Guilford recognized that the “directly identify” claim
`
`term refers to the fact that the codes stored in the remote control of the ‘067 patent
`
`during manufacture and prior to its sale are inherently “device-specific” and that
`
`“the device is directly identified by the entered code.” (Exhibit 2001 at 31.) As a
`
`result, Judge Guilford construed relevant claim language in the ‘067 patent
`
`containing the term “directly identify” to make clear that “pushbuttons are pressed
`
`to enter codes that directly identify each particular home appliance to which the
`
`universal remote control is to be matched.” (Exhibit 2001 at 34.) Thus, the term
`
`“directly identify” as used in the ‘067 patent refers to the fact that the device-
`
`specific codes pre-programmed into the library of the remote control are
`
`predisposed to operate each particular home appliance.
`
`35. By contrast, in the CORE remote control, nothing stored therein directly
`
`identifies the appliance to be controlled. Rather, the function of the pushbuttons of
`
`the CORE remote can be switched between various “pages” in its memory
`
`corresponding to physical pages in a journal provided with the remote. Those
`
`14
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`

`pages may be entirely empty. It is also possible for a single page to include
`
`commands for multiple appliances. Still further, it is possible for some of the
`
`commands for a particular appliance to be stored on one “page” and other
`
`commands to be stored on another “page.” Thus, switching between the “pages”
`
`of the CORE remote does not directly any particular device. Put simply, CORE
`
`does not disclose any manner by which a user can direct the remote to match to a
`
`particular appliance—for example, Sony TV model ABC-123—via its
`
`pushbuttons. For this reason, neither CORE nor Wozniak disclose codes that
`
`directly identify each of a plurality of home appliances of different manufacturers,
`
`and thus those references do not anticipate or render obvious the claims of the ‘067
`
`patent.
`
`Miscellaneous
`
`36.
`
`In signing this declaration, I recognize that the declaration may be filed as
`
`evidence in a contested case before the Patent Trial and Appeal Board of the
`
`United States Patent and Trademark Office. I also recognize that I may be subject
`
`to cross examination in that case and that cross examination will take place within
`
`the United States. If necessary, I will cooperate to the best of my ability to appear
`
`for cross examination within the United States during the time period allotted for
`
`such cross examination to occur.
`
`15
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`

`37. The hst of documents I reviewed in forming the opinions discussed in this
`
`declaration are listed in the attached Appendix A
`
`38.
`
`I reserve the right to supplement the opinions set forth herein to respond to
`
`any arguments that Petitioner raises and to take into account new information if it
`
`becomes available to me.
`
`39.
`
`I declare that all statements made herein of my own knowledge are true, and
`
`that all statements made on information and belief are believed to be true; and
`
`further that these statements were made with the knowledge that willful false
`
`statements and the like are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`40.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Patrick H. Hayes
`
`16
`
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`

`

`Appendix A
`
`List of documents I reviewed in forming the opinions expressed in this declaration.
`
`Paper 6
`
`Paper 12
`
`Paper 13
`
`Petitioner’s Amended Petition for Inter Partes Review under 35
`U.S.C. 311-319 and 37 C.F.R. 2.100 et seq.
`
`Preliminary Response of Patent Owner
`
`Decision Instituting Inter Partes Review, 37 C.F.R. § 42.108
`
`Exhibit 1001
`
`U.S. Patent No. 6,587,067 to Darbee at al.
`
`Exhibit 1002
`
`U.S. Patent No. 4,774,511 to Rumbolt et al.
`
`Exhibit 1003
`
`U.S. Patent No. 4,918,439 to Wozniak et al.
`
`Exhibit 1004
`
`U.S. Patent No. 4,825,200 to Evans et al.
`
`Exhibit 1005
`
`CORE Reference Manual
`
`Exhibit 1006 Magnavox unveils Total Remote Tuning System and second
`generation Universal Remote Control
`
`Exhibit 1010
`
`Declaration of Alan J. Herr, PhD
`
`Exhibit 2001
`
`February 1, 2013, Claim Construction Order, from Universal
`Electronics, Inc. v. Universal Remote Control, Inc., C.D.Cal. Case
`No. SACV 12-00329 AG (JPRx)
`
`Exhibit 2003
`
`U.S. Patent No. 6,587,067 to Darbee at al.
`
`Universal Electronics Exhibit 2006, Page 17
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`
`

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