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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MICROCHIP TECHNOLOGY, INC.,
`Petitioner
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`v.
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`HD SILICON SOLUTIONS LLC,
`Patent Owner
`
`Case IPR2021-01265
`U.S. Patent No. 7,870,404
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`
`
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`DECLARATION OF SYLVIA HALL-ELLIS, PH.D. IN SUPPORT OF
`PETITIONER’S PETITION FOR INTER PARTES REVIEW
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`I, Sylvia D. Hall-Ellis, Ph.D., declare as follows:
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`I.
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`INTRODUCTION
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`1. My name is Sylvia D. Hall-Ellis. I have been retained as an expert by
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`Microchip Technology Inc. (“the Petitioner”), who I am informed is the Petitioner
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`seeking for the Patent Trial and Appeal Board to institute inter partes review (IPR)
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`proceeding.
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`2.
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`I have written this declaration at the request of the Petitioner to provide
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`my expert opinion regarding the public availability of several publications, identified
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`below. My Declaration sets forth my opinions in detail and provides the basis for
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`my opinions regarding the public availability of these publications.
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`3.
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`I reserve the right to supplement or amend my opinions, and bases for
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`them, in response to any additional evidence, testimony, discovery, argument, and/or
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`other additional information that may be provided to me after the date of this
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`Declaration.
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`4.
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`As of the preparation and signing of this declaration, many libraries
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`across the nation are closed or permit only limited access due to the COVID-19 virus.
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`However, were the libraries open, I would expect to be able to obtain paper copies
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`of at least some of the documents in this declaration. I reserve the right to supplement
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`my declaration when the libraries reopen to provide such information.
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`5.
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`I am being compensated for my time spent working on this matter at
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`1
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`my normal consulting rate of $325 per hour, plus reimbursement for any additional
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`reasonable expenses. My compensation is not in any way tied to the content of this
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`report, the substance of my opinions, or the outcome of this litigation. I have no
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`other interests in this proceeding or with any of the parties.
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`6.
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`All of the materials that I considered and relied upon are discussed
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`explicitly in this declaration.
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`II. QUALIFICATIONS
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`7.
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`I am currently an Adjunct Professor in the School of Information at San
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`José State University in San José, California. I obtained a Master of Library Science
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`from the University of North Texas in 1972 and a Ph.D. in Library Science from the
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`University of Pittsburgh in 1985. Over the last fifty years, I have held various
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`positions in the field of library and information resources. I was first employed as a
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`librarian in 1966 and have been involved in the field of library sciences since,
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`holding numerous positions.
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`8.
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`I am a member of the American Library Association (ALA) and its
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`Association for Library Collections & Technical Services (ALCTS) Division, and I
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`served on the Committee on Cataloging: Resource and Description (which wrote the
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`new cataloging rules) and as the chair of the Committee for Education and Training
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`of Catalogers and the Competencies and Education for a Career in Cataloging
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`Interest Group. I also served as the Chair of the ALCTS Division’s Task Force on
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`2
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`Competencies and Education for a Career in Cataloging. Additionally, I have served
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`as the Chair for the ALA Office of Diversity’s Committee on Diversity, as a member
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`of the REFORMA National Board of Directors, and as a member of the Editorial
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`Board for the ALCTS premier cataloging journal, Library Resources and Technical
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`Services. Currently I serve as a Co-Chair for the Library Research Round Table of
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`the American Library Association.
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`9.
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`I have also given over one hundred presentations in the field, including
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`several on library cataloging systems and Machine-Readable Cataloging (“MARC”)
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`standards. My current research interests include library cataloging systems,
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`metadata, and organization of electronic resources.
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`10. My full curriculum vitae is attached hereto as Exhibit A.
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`III. PRELIMINARIES
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`A.
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`Scope of Declaration and Legal Standards
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`11.
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`I am not an attorney and will not offer opinions on the law. I am,
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`however, rendering my expert opinion on the authenticity of the documents
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`referenced herein and on when and how each of these documents was disseminated
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`or otherwise made available to the extent that persons interested and ordinarily
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`skilled in the subject matter or art, exercising reasonable diligence, could have
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`located the documents before the dates discussed below with respect to the specific
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`documents.
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`3
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`12.
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`I am informed by counsel that a printed publication qualifies as publicly
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`accessible as of the date it was disseminated or otherwise made available such that
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`a person interested in and ordinarily skilled in the relevant subject matter could
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`locate it through the exercise of ordinary diligence.
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`13. While I understand that the determination of public accessibility under
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`the foregoing standard rests on a case-by-case analysis of the facts particular to an
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`individual publication, I also understand that a printed publication is rendered
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`“publicly accessible” if it is cataloged and indexed by a library such that a person
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`interested in the relevant subject matter could locate it (i.e., I understand that
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`cataloging and indexing by a library is sufficient, though there are other ways that a
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`printed publication may qualify as publicly accessible). One manner of sufficient
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`indexing is indexing according to subject matter category. I understand that the
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`cataloging and indexing by a single library of a single instance of a particular printed
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`publication is sufficient, even if the single library is in a foreign country. I
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`understand that, even if access to a library is restricted, a printed publication that has
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`been cataloged and indexed therein is publicly accessible so long as a presumption
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`is raised that the portion of the public concerned with the relevant subject matter
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`would know of the printed publication. I also understand that the cataloging and
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`indexing of information that would guide a person interested in the relevant subject
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`matter to the printed publication, such as the cataloging and indexing of an abstract
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`for the printed publication, is sufficient to render the printed publication publicly
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`accessible.
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`14.
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`I understand that routine business practices, such as general library
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`cataloging and indexing practices, can be used to establish an approximate date on
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`which a printed publication became publicly accessible.
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`B.
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`Persons of Ordinary Skill in the Art
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`15.
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`I am told by counsel that the subject matter of this proceeding generally
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`relates to reducing the power consumed by processors and voltage regulators in a
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`computer system.
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`16.
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`I have been informed by counsel that a “person of ordinary skill in the
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`art at the time of the invention” (POSITA) is a hypothetical person who is presumed
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`to be familiar with the relevant field and its literature at the time of the inventions.
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`This hypothetical person is also a person of ordinary creativity, capable of
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`understanding the scientific principles applicable to the pertinent field.
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`17.
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`I am told by counsel that a POSITA as of October 23, 2000, would have
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`possessed a bachelor’s degree in electrical engineering, computer engineering, or
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`computer science, with two years of experience in computer system development,
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`including experience in developing power/voltage regulation systems for portable
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`devices. A person could also have qualified as a POSITA with some combination
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`of (1) more formal education (such as a master’s of science degree) and less technical
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`5
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`experience or (2) less formal education and more technical or professional
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`experience in the fields listed above. I have been further informed by counsel that a
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`POSITA would have been familiar with and able to understand the information
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`known in the art relating to these fields, including the publications discussed in this
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`declaration. I have been further informed by counsel that a POSITA would have
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`been familiar with and able to understand the information known in the art relating
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`to these fields, including the publication discussed in this declaration.
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`C. Use of Authoritative Databases
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`18.
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`In preparing this report, I used authoritative databases, such as the
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`OCLC bibliographic database and the Library of Congress Online Catalog, to
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`confirm citation details of the publication discussed.
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`19. A researcher may discover material relevant to his or her topic in a
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`variety of ways. One common means of discovery is to search for relevant
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`information in an index of periodical and other publications. Having found relevant
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`material, the researcher will then normally obtain it online, look for it in libraries, or
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`purchase it from the publisher, a bookstore, a document delivery service, or other
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`provider. Sometimes, the date of a document’s public accessibility will involve both
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`indexing and library date information.
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`20.
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`Indexing services use a wide variety of controlled vocabularies to
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`provide subject access and other means of discovering the content of documents.
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`6
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`The formats in which these access terms are presented vary from service to service.
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`21. Online indexing services and digital repositories commonly provide
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`bibliographic information, abstracts, and full-text copies of the indexed publications,
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`along with a list of the documents cited in the indexed publication. These services
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`also often provide lists of publications that cite a given document. A citation of a
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`document is evidence that the document was publicly available and in use by
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`researchers no later than the publication date of the citing document.
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`D.
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`Summary of Opinions
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`22.
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`I am informed by counsel that the priority date for the patent at issue is
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`October 23, 2000. As I will explain below, it is my opinion that the printed
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`publication discussed in my Declaration was publicly accessible more than one year
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`before the October 23, 2000, priority date.
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`IV. LIBRARY CATALOGING PRACTICES
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`A. MARC Records and OCLC
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`23.
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`I am fully familiar with the library cataloging standard known as the
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`MARC standard, which is an industry-wide standard method of storing and
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`organizing library catalog information. MARC was first developed in the 1960’s by
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`the Library of Congress. A MARC-compatible library is one that has a catalog
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`consisting of individual MARC records for works made available at that library.
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`24. Since at least the early 1970s and continuing to the present day, MARC
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`has been the primary communications protocol for the transfer and storage of
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`bibliographic metadata in libraries.1 As explained by the Library of Congress:
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`You could devise your own method of organizing the bibliographic
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`information, but you would be isolating your library, limiting its options, and
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`creating much more work for yourself. Using the MARC standard prevents
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`duplication of work and allows libraries to better share bibliographic
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`resources. Choosing to use MARC enables libraries to acquire cataloging data
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`that is predictable and reliable. If a library were to develop a “home-grown”
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`system that did not use MARC records, it would not be taking advantage of
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`an industry-wide standard whose primary purpose is to foster communication
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`of information.
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`Using the MARC standard also enables libraries to make use of commercially
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`available library automation systems to manage library operations. Many
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`systems are available for libraries of all sizes and are designed to work with
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`the MARC format. Systems are maintained and improved by the vendor so
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`that libraries can benefit from the latest advances in computer technology. The
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`1 A complete history of the development of MARC can be found in MARC: Its
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`History and Implications by Henrietta D. Avram (Washington, DC: Library of
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`Congress, 1975) and available online from the Hathi Trust
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`(https://babel.hathitrust.org/cgi/pt?id=mdp.39015034388556;view=1up;seq=1; last
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`visited July 15, 2021).
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`8
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`MARC standard also allows libraries to replace one system with another with
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`the assurance that their data will still be compatible.
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`Why
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`Is
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`a MARC Record Necessary? LIBRARY OF CONGRESS,
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`http://www.loc.gov/marc/umb/um01to06.html#part2 (last visited July 15, 2021).
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`25. Thus, almost every major library in the world is MARC-compatible.
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`See, e.g., MARC Frequently Asked Questions (FAQ), LIBRARY OF CONGRESS,
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`https://www.loc.gov/marc/faq.html (last visited July 15, 2021) (“MARC is the
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`acronym for MAchine-Readable Cataloging. It defines a data format that emerged
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`from a Library of Congress-led initiative that began nearly fifty years ago. It
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`provides the mechanism by which computers exchange, use, and interpret
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`bibliographic information, and its data elements make up the foundation of most
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`library catalogs used today.”). MARC is the ANSI/NISO Z39.2-1994 standard
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`(reaffirmed in 2016) for Information Interchange Format. The full text of the
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`standard
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`is
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`available
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`from
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`the
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`Library
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`of
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`Congress
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`at
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`http://www.loc.gov/marc/bibliographic/ (last visited July 15, 2021).
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`26. A MARC record comprises several fields, each of which contains
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`specific data about the work. Each field is identified by a standardized, unique,
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`three-digit code corresponding to the type of data that follow. See, e.g.,
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`http://www.loc.gov/marc/umb/um07to10.html
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`(last visited July 15, 2021);
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`http://www.loc.gov/marc/bibliographic/ (last visited July 15, 2021). For example, a
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`work’s title is recorded in field 245, the primary author of the work is recorded in
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`field 100, a work’s International Standard Book Number (“ISBN”) is recorded in
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`field 020, a work’s International Standard Serial Number (“ISSN”) is recorded in
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`field 022, and the publication date is recorded in field 260 under the subfield “c.”
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`Id.2 If a work is a periodical, then its publication frequency is recorded in field 310,
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`and the publication dates (e.g., the first and last publication) are recorded in field
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`362, which is also referred to as the enumeration/chronology field. See
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`http://www.loc.gov/marc/bibliographic/bd3xx.html (last visited July 15, 2021).3
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`2 In some MARC records, field 264 is used rather than field 260 to record
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`publication information. See http://www.loc.gov/marc/bibliographic/bd264.html
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`(last visited July 15, 2021) (“Information in field 264 is similar to information in
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`field 260 (Publication, Distribution, etc. (Imprint)). Field 264 is useful for cases
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`where the content standard or institutional policies make a distinction between
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`functions”).
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`3 Upwards of two-thirds to three-quarters of book sales to libraries come from a
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`jobber or wholesaler for online and print resources. These resellers make it their
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`business to provide books to their customers as fast as possible, often providing
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`turnaround times of only a single day after publication. Libraries purchase a
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`significant portion of the balance of their books directly from publishers
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`themselves, which provide delivery on a similarly expedited schedule. In general,
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`libraries make these purchases throughout the year as the books are published and
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`shelve the books as soon thereafter as possible in order to make the books available
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`10
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`27. The library that initially created the MARC record is reflected in field
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`040 in subfield “a” with that library’s unique library code. See, e.g.,
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`http://www.loc.gov/marc/umb/um07to10.html
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`(last visited July 15, 2021);
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`http://www.loc.gov/marc/bibliographic/ (last visited July 15, 2021). Once a MARC
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`record for a particular work is originally created by one library, other libraries can
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`use that original MARC record to then create their own MARC records for their own
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`copies of the same work. These other libraries may modify or add to the original
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`MARC record as necessary to reflect data specific to their own copies of the work.
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`However, the library that created the original MARC record would still be reflected
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`in these modified MARC records (corresponding to other copies of the same work
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`at other libraries) in field 040, subfield “a”. The modifying library (or libraries) is
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`reflected
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`in
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`field
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`040,
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`subfield
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`“d”.
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`See
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`http://www.loc.gov/marc/bibliographic/bd040.html (last visited July 15, 2021).
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`28.
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`I
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`consulted
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`the
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`Directory
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`of
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`OCLC
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`Libraries
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`(http://www.oclc.org/contacts/libraries.en.html; last visited July 15, 2021) in order
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`to identify the institution that created or modified the MARC record. Moreover,
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`when viewing the MARC record online via Online Computer Library Center’s
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`(“OCLC”) bibliographic database, which I discuss further below, hovering over a
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`to their patrons. Thus, books are generally available at libraries across the country
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`within just a few days of publication.
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`library code in field 040 with the mouse reveals the full name of the library. I also
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`used this method of “mousing over” the library codes in the OCLC database to
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`identify the originating and modifying libraries for the MARC records discussed in
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`this report.
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`29. MARC records also include one or more fields that show information
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`regarding subject matter classification. For example, 6XX fields are termed
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`“Subject Access Fields.” See http://www.loc.gov/marc/bibliographic/bd6xx.html
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`(last visited July 15, 2021). Among these, for example, is the 650 field; this is the
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`“Subject
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`Added
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`Entry
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`–
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`Topical
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`Term”
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`field.
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`See
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`http://www.loc.gov/marc/bibliographic/bd650.html (last visited July 15, 2021). The
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`650 field is a “[s]ubject added entry in which the entry element is a topical term.”
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`Id. These entries “are assigned to a bibliographic record to provide access according
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`to generally accepted thesaurus-building rules (e.g., Library of Congress Subject
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`Headings (LCSH), Medical Subject Headings (MeSH)).” Id.
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`30. Further, MARC records can include call numbers, which themselves
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`contain a classification number. For example, a MARC record may identify a 050
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`field, which
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`is
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`the
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`“Library of Congress Call Number.”
`
` See
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`http://www.loc.gov/marc/bibliographic/bd050.html (last visited July 15, 2021). A
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`defined portion of the Library of Congress Call Number is the classification number,
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`and “source of the classification number is Library of Congress Classification and
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`the LC Classification-Additions and Changes.” Id. Thus, the 050 field may be used
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`to show information regarding subject matter classification.
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`31. Each item in a library has a single classification number. A library
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`selects a classification scheme (e.g., the Library of Congress Classification scheme
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`just described or a similar scheme such as the Dewey Decimal Classification
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`scheme) and uses it consistently. When the Library of Congress assigns the
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`classification number, it appears as part of the 050 field, as discussed above. For
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`MARC records created by libraries other than the Library of Congress (e.g., a
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`university library or a local public library), the classification number may appear in
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`a 09X (e.g., 090) field. See http://www.loc.gov/marc/bibliographic/bd09x.html (last
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`visited July 15, 2021).
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`32. When a MARC-compatible library acquires a work, it creates a MARC
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`record for its copy of the work in its computer catalog system in the ordinary course
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`of its business. This MARC record (for the copy of a work available at the particular
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`library) may be later accessed by researchers in a number of ways. For example,
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`many libraries, including the Library of Congress, make their MARC records
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`available through their website. As an example, the MARC record for the copy of
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`The Unlikely Spy, by Daniel Silva,4 available at the Library of Congress can be
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`4 The Unlikely Spy is a 1996 novel written by Daniel Silva, who happens to be one
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`of my favorite authors.
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`viewed
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`through
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`the
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`Library
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`of
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`Congress
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`website,
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`at
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`https://catalog.loc.gov/vwebv/staffView?searchId=20265&recPointer=1&recCount
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`=25&bibId=2579985 (last visited July 15, 2021). One could, of course, always
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`physically visit the library at which the work is available, and request to see that
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`library’s MARC record for the work. Moreover, members of the Online Computer
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`Library Center (“OCLC”) can access the MARC records of other member
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`institutions through OCLC’s online bibliographic database, as I explain further
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`below.
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`33. The OCLC was created “to establish, maintain and operate a
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`computerized library network and to promote the evolution of library use, of libraries
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`themselves, and of librarianship, and to provide processes and products for the
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`benefit of library users and libraries, including such objectives as increasing
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`availability of library resources to individual library patrons and reducing the rate of
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`rise of library per-unit costs, all for the fundamental public purpose of furthering
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`ease of access to and use of the ever-expanding body of worldwide scientific, literary
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`and educational knowledge and information.”5 Among other services, OCLC and
`
`
`5 Third Article, Amended Articles of Incorporation of OCLC Online Computer
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`Library Center, Incorporated (available at
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`https://www.oclc.org/content/dam/oclc/membership/articles-of-incorporation.pdf;
`
`last visited July 15, 2021).
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`its members are
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`responsible
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`for maintaining
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`the WorldCat database
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`(http://www.worldcat.org/; last visited July 15, 2021), used by independent and
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`institutional libraries throughout the world. All libraries that are members of OCLC
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`are MARC-compatible. See, e.g., https://help.oclc.org/Metadata_Services/OCLC-
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`MARC records/About OCLC-MARC records
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`(last visited July 15, 2021)
`
`(“OCLC-MARC records describes records produced since November 1993.”);
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`https://www.oclc.org/support/services/worldcat/documentation/cataloging/electron
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`icresources.en.html (last visited July 15, 2021) (“Like the two superseded OCLC
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`documents, this revised set of guidelines is intended to assist catalogers in creating
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`records for electronic resources in WorldCat, the OCLC Online Union Catalog.
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`These guidelines pertain to OCLC-MARC tagging (that is, content designation).
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`Cataloging rules and manuals (such as AACR2) govern the content of records. You
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`should implement these guidelines immediately.”).
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`34. When an OCLC member institution acquires a publication, like the
`
`other MARC-compatible libraries discussed above, it creates a MARC record for
`
`this publication in its computer catalog system in the ordinary course of its business.
`
`MARC records created at the Library of Congress are tape-loaded into the OCLC
`
`database through a subscription to MARC Distribution Services daily or weekly.
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`Once the MARC record is created by a cataloger at an OCLC member library or is
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`tape-loaded from the Library of Congress, the MARC record is then made available
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`to any other OCLC members online, and thereby made available to the public.
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`Accordingly, once the MARC record is created by a cataloger at an OCLC member
`
`library or is tape-loaded from the Library of Congress, any publication
`
`corresponding to the MARC record has been cataloged and indexed according to its
`
`subject matter such that a person interested in that subject matter could, with
`
`reasonable diligence, locate and access the publication through any library with
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`access to the OCLC bibliographic database or through the Library of Congress.
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`35. Fields 008, 005, and 955 in MARC Records as Indicators of Public
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`Accessibility. When a MARC-compatible library creates an original MARC record
`
`for a work, the library records the date of creation of that MARC record in field 008,
`
`characters 00 through 05, in the ordinary course of its business.
`
` See
`
`http://www.loc.gov/marc/bibliographic/bd008a.html (last visited July 15, 2021).
`
`For OCLC member institutions that use OCLC software to create original MARC
`
`records, the date of creation in field 008 is automatically supplied by the OCLC
`
`software. The MARC record creation date in field 008 thus reflects the date on
`
`which, or shortly after which, a work was first acquired and cataloged by the library
`
`that created the original MARC record.
`
`36. When other MARC-compatible libraries subsequently acquire their
`
`own copies of the same work, as mentioned, they create MARC records in their own
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`computer catalog systems for their copies in the ordinary course of business.6 They
`
`may use a MARC record previously created for that work (by another MARC-
`
`compatible library) to create their own MARC records for their own copies of that
`
`same work.7 The previously created MARC record used by subsequently-acquiring
`
`libraries to create MARC records for their own copies may be obtained through the
`
`OCLC bibliographic database, as described above. If, when creating a MARC
`
`record to represent its own copy of the work, the subsequently-acquiring library uses
`
`the master MARC record in its original form, the subsequently-acquiring library
`
`cannot reenter data into the 008 field; therefore, the date in the 008 field will continue
`
`to reflect the date the MARC record was initially created by the originating library.
`
`On the other hand, if the subsequently-acquiring library modifies the previously
`
`created MARC record when creating its own MARC record for its own copy of the
`
`work, the subsequently-acquiring library may enter into the 008 field of its own
`
`MARC record the date its own MARC record was created.8 But the library that
`
`
`6 Initial contributions to the bibliographic database for a work are called “master
`
`records.”
`
`7 When a local library uses a master record in OCLC and produces (or downloads)
`
`it to the in-house system, the three-character symbol for the subsequent library is
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`added to the holdings for the work.
`
`8 This practice is not required by, but is nevertheless consistent with, the MARC
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`standard. Many MARC records exist today whose 008 fields indicate when the
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`created the original MARC record used by the subsequently-acquiring library would
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`still be reflected in the MARC record of the subsequently-acquiring library in field
`
`040, subfield “a”. Thus, the work identified by any MARC record possessed by any
`
`MARC-compatible library would have been accessible to the public at least as of the
`
`date shown in the 008 field, or shortly thereafter, either from the library that
`
`possesses the MARC record itself, or from the originating library indicated in field
`
`040, subfield “a”. As discussed, a MARC-compatible library in the ordinary course
`
`of its business creates a MARC record in its own catalog system for a work when it
`
`acquires a copy of that work.
`
`37. Moreover, when a MARC record is created by a library for its own copy
`
`of a work, field 005 is automatically populated with the date that MARC record was
`
`created
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`in
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`year, month,
`
`day
`
`format
`
`(YYYYMMDD).
`
`
`
`See
`
`http://www.loc.gov/marc/bibliographic/bd005.html (last visited July 15, 2021).9
`
`Thereafter, the library’s computer system may automatically update the date in field
`
`005 every time the library updates the MARC record (e.g., to reflect that an item has
`
`
`first original MARC record for a work was created, rather than when a derivative
`
`record was created based on the original MARC record by a subsequently-
`
`acquiring library for its own computer catalog system.
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`9 Some of the newer library catalog systems also include hour, minute, second
`(HHMMSS).
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`been moved to a different shelving location within the library). Id.10 Thus, the work
`
`identified by any MARC record possessed by any MARC-compatible library would
`
`have been accessible to the public at least as of the date shown in the 005 field, or
`
`shortly thereafter, from the library that possesses the MARC record itself. As noted,
`
`because the 005 field may be updated each time the library updates its MARC record,
`
`the work identified by the MARC record may, in fact, have been accessible to the
`
`public from that library much earlier than the date indicated in the 005 field.
`
`38. Moreover, MARC records for copies of works available at the Library
`
`of
`
`Congress
`
`can
`
`have
`
`a
`
`955
`
`field.
`
`
`
`See
`
`http://www.loc.gov/cds/PDFdownloads/dcm/DCM 2007-03.pdf (last visited July
`
`15, 2021). The 955 field in MARC records obtained from the Library of Congress
`
`provides Local Tracking Information, which is a record of internal steps in the
`
`cataloging process followed by the Library of Congress. Id. Entries in the 955 field
`
`for a particular work are generated by Library of Congress staff as the work
`
`progresses through the cataloging process. Id. One of the mandatory fields that
`
`library staff must enter for each step is the date (in the form of “yyyy-mm-dd” or
`
`
`10 Field 005 is visible when viewing a MARC record via an appropriate
`
`computerized interface. But when a MARC record is printed directly to hardcopy
`
`from the OCLC database, the “005” label is not shown. The date in the 005 field
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`instead appears next to the label “Replaced.”
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`“yy-mm-dd”) the step was taken. Id. Thus, the work identified by a MARC record
`
`possessed by the Library of Congress would have been accessible to the public at
`
`least as of the earliest date shown in the 955 field, or shortly thereafter, from the
`
`Library of Congress.
`
`39. Based on my personal experience as a professional librarian using the
`
`MARC and OCLC resources, it has been my experience that both of these resources
`
`were continuously operational and available since at least 1992. Indeed, in the
`
`course of my work, I have extensively used both of these resources over the past 30+
`
`years, and I have consistently found the information contained within these resources
`
`to be complete and reliable. I have never found the date of accessibility as indicated
`
`in fields 008, 005, or 955 to be incorrect. And in only a minute number of cases
`
`have I found any errors at all in these records – none
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