Trials@uspto.gov
`571-272-7822
`
`Paper 37
`Date: April 23, 2024
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MEDIVIS, INC.,
`Petitioner,
`v.
`NOVARAD CORP.,
`Patent Owner.
`
`IPR2023-00042
`Patent 11,004,271 B2
`
`
`
`
`
`
`
`
`
`Before MIRIAM L. QUINN, Acting Vice Chief Administrative Patent Judge,
`MICHAEL R. ZECHER and SCOTT RAEVSKY, Administrative Patent
`Judges.
`RAEVSKY, Administrative Patent Judge.
`
`DECISION
`Denying Petitioner’s Request on Rehearing of
`Final Written Decision
`37 C.F.R. § 42.71(d)
`
`
`
`
`
`
`
`
`571-272-7822
`
`Paper 37
`Date: April 23, 2024
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MEDIVIS, INC.,
`Petitioner,
`v.
`NOVARAD CORP.,
`Patent Owner.
`
`IPR2023-00042
`Patent 11,004,271 B2
`
`
`
`
`
`
`
`
`
`Before MIRIAM L. QUINN, Acting Vice Chief Administrative Patent Judge,
`MICHAEL R. ZECHER and SCOTT RAEVSKY, Administrative Patent
`Judges.
`RAEVSKY, Administrative Patent Judge.
`
`DECISION
`Denying Petitioner’s Request on Rehearing of
`Final Written Decision
`37 C.F.R. § 42.71(d)
`
`
`
`
`
`
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`
`INTRODUCTION
`I.
`We issued a Final Written Decision determining no challenged claims
`unpatentable. Paper 35 (“Decision” or “Dec.”). Petitioner timely filed a
`Request for Rehearing of our Decision. Paper 36 (“Request” or “Req.”).
`For the reasons explained below, we deny Petitioner’s Request.
`
`
`II. LEGAL STANDARD
`The requirements of a request for rehearing are set forth in 37 C.F.R.
`
`§ 42.71(d):
`
`The burden of showing a decision should be modified lies with
`the party challenging the decision. The request must
`specifically identify all matters the party believes the Board
`misapprehended or overlooked, and the place where each
`matter was previously addressed in a motion, an opposition, a
`reply, or a sur-reply.
`Thus, a request for rehearing is not an opportunity to present new arguments
`or evidence or merely to disagree with the panel’s assessment of the
`arguments or weighing of the evidence. With this in mind, we address the
`arguments presented in turn.
`
`
`
`III. ANALYSIS
`The Request challenges our Decision’s finding that Petitioner failed to
`establish public accessibility of the references Chen, 3D Visualization,1 and
`3D Slicer. Req. 1. The Petition challenged claims 1–6 and 11–20 as
`
`
`1 The Request refers to this reference with different name variations: “3D-
`Slicer-Visualization,” “3D Slicer-Visualization,” and “3D Visualization.”
`Req. 1, n.2, 7. For consistency with the Petition, we refer to it solely as “3D
`Visualization.” See Pet. 31, 54–69.
`
`2
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`allegedly being obvious over the combination of Chen, 3D Visualization,
`and 3D Slicer. Pet. 31, 54–69. Because our Decision determined that
`Petitioner did not prove public accessibility of these references, our Decision
`concluded that Petitioner did not prove unpatentability of these claims over
`the combination of these references. Dec. 25–31.2
`In our Decision, we faulted the Petition for not presenting evidence of
`public accessibility. Id. at 26 (citing Pet. 29–30). We also found the
`Reply’s conclusory arguments unavailing. Id. (citing Reply 27–28). For
`example, for the Chen reference, we found the Reply’s reliance on a
`copyright date, statements on the face of Chen, and mere assertion that Chen
`was cited by seven publications as insufficient to establish public
`accessibility. Id. at 27–28. We found Petitioner’s arguments for the public
`accessibility of 3D Visualization and 3D Slicer “similarly terse and
`unpersuasive.” Id. at 29–30. Further, we found Petitioner’s citation to two
`supporting declarations to be improper incorporations by reference and
`therefore not entitled to consideration. Id. at 28–30.
`Petitioner argues that we overlooked or misapprehended arguments
`and evidence addressing public accessibility in both the Petition and Reply.
`Petitioner also alleges that we overlooked certain other documents. We
`address these arguments in turn.
`A. Petition
`Petitioner first argues that the Decision “wrongly found that the
`Petition offers ‘no proof’ that any of these references were publicly
`
`
`2 Petitioner does not request rehearing of our determination that Petitioner
`failed to prove anticipation of claims 1, 5, and 6 by Doo or our
`determination that Petitioner failed to prove obviousness of claims 1–6 and
`11–20 over the combination of Doo and Amira. See Dec. 8–25, 33–34.
`
`3
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`accessible.” Req. 4. For instance, Petitioner argues that pages 29–30 of the
`Petition present evidence recognized by our precedential Hulu decision as
`supporting a printed publication, namely “a copyright date, a publication
`date, and an established publisher of a series of a similar type of references.”
`Id. (citing Hulu, LLC v. Sound View Innovations, LLC, IPR2018-01039,
`Paper 29 at 19–20 (PTAB Dec. 20, 2019) (precedential)). We disagree.
`Petitioner’s argument overstates the evidence submitted with the Petition
`and misapplies our precedential Hulu decision.
`On pages 29–30 of the Petition, Petitioner cites no evidence for public
`accessibility, except the references Chen, 3D Visualization, and 3D Slicer
`themselves. This is insufficient and tantamount to submitting no proof of
`public accessibility. To find public accessibility, we must determine that a
`“document has been disseminated or otherwise made available to the extent
`that persons interested and ordinarily skilled in the subject matter or art[,]
`exercising reasonable diligence, can locate it.” SRI Int’l, Inc. v. Internet Sec.
`Sys., Inc., 511 F.3d 1186, 1194 (Fed. Cir. 2008), quoted in Dec. 26–27.
`Petitioner has insufficiently explained, by a preponderance of the evidence,
`how Chen, 3D Visualization, and 3D Slicer themselves answer the question
`of whether they have been disseminated or otherwise made available to
`those of ordinary skill in the art. Thus, we did not overlook or misapprehend
`any evidence of public accessibility on pages 29–30 of the Petition.
`Petitioner’s argument regarding Hulu is also unpersuasive. There, a
`reference bearing a copyright date, a printing date, and an ISBN date, as well
`as an indication that it was from an established publisher and “well-known
`book series,” supported a finding of a reasonable likelihood that the
`reference was a printed publication. Hulu, Paper 29 at 19–20. In other
`words, Hulu considered whether a petitioner had met its institution burden
`
`4
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`for public accessibility, not whether the petitioner had proven that the
`reference was publicly accessible at the final decision stage. Id. As we
`explained in our decision, however, at the final decision stage, Petitioner
`must establish public accessibility by a preponderance of the evidence. See
`Dec. 26. The Hulu panel itself confirmed in its final decision that a
`petitioner must prove public accessibility at that stage by a preponderance of
`the evidence. Hulu, Paper 66 at 22 (“The standard of proof to institute a trial
`is ‘that there is a reasonable likelihood that the petitioner would prevail’ (35
`U.S.C. § 314(a)) while the standard of proof for a final decision is whether
`the Petitioner has met ‘the burden of proving a proposition of unpatentability
`by a preponderance of the evidence’ (35 U.S.C. § 316(e)).”). Thus, we
`cannot have overlooked or misapprehended our precedential Hulu decision
`because it addresses a lesser required showing of public accessibility at the
`institution stage.
`Petitioner also points to other statements in the Petition that we
`allegedly overlooked. Req. 5–6 (citing Pet. 16–19, 54–55). According to
`Petitioner, these statements reference Dr. Kazanzides’s testimony that 3D
`Slicer was a printed publication. Id. (citing Ex. 1012 ¶¶ 41–43, 106).
`Petitioner contends, for example, that 3D Slicer software was available “by
`2014” and that the website “www.slicer.org” about this software was a
`known source of information. Id. at 5 (citing Pet. 16–17, 54; Ex. 1012 ¶ 41;
`Ex. 1007, slides 6–7). Petitioner further argues that, “[b]ased on his
`knowledge and experience as an expert qualified as a POSA [person of
`ordinary skill in the art], [Dr.] Kazanzides testified that ‘[a] POSA would
`have been familiar with the 3D Slicer application and its ability to load and
`display data for a user.’” Id. (citing Pet. 16–17; Ex. 1012 ¶ 41). Petitioner
`also references Dr. Kazanzides’s testimony regarding example data
`
`5
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`published by Surgical Planning Laboratory, presumably using 3D Slicer
`software. Id. (citing Ex. 1012 ¶¶ 42–43). Finally, Petitioner asserts that Dr.
`Kazanzides testified that by 2016, 3D Slicer software “included published
`documentation of the Main Application Graphical User Interface (GUI).”
`Id. at 6 (citing Pet. 55; Ex. 1012 ¶ 106). Thus, Petitioner concludes, we
`“overlooked or misapprehended [Dr.] Kazanzides’s original testimony cited
`in the Petition as to the public accessibility of non-patent references related
`to 3D Slicer.” Id. at 6.
`We disagree that we overlooked or misapprehended these arguments
`and testimony. Although our Decision does not discuss them, none of these
`arguments or testimony supports a finding of public accessibility.
`Petitioner’s argument boils down to this—3D Slicer software was publicly
`known, so its documentation, the 3D Slicer reference, must also have been
`publicly accessible. This conclusion does not follow. Petitioner needed to
`show that 3D Slicer itself, the reference, was “disseminated or otherwise
`made available.” SRI, 511 F.3d at 1194. At best, Petitioner presented
`evidence that 3D Slicer software may have been available and then asks us
`to infer that the software’s documentation, 3D Slicer, must also have been
`publicly accessible. This leap we cannot make without supporting evidence.
`For example, unlike a recent case where an operating manual for a food
`slicer machine was publicly accessible because evidence showed that it was
`disseminated, Petitioner presents no evidence that 3D Slicer was
`disseminated along with the 3D Slicer software. See Weber, Inc. v. Provisur
`Techs., Inc., 92 F.4th 1059, 1068 (Fed. Cir. 2024) (finding, based on
`employee testimony, that users obtained the operating manual upon purchase
`of the food slicer or upon request, and that this testimony was corroborated
`by additional testimony and documentary evidence).
`
`6
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`Dr. Kazanzides’s testimony on this point insufficiently supports the
`inference Petitioner wants us to draw. Dr. Kazanzides testifies that 3D
`Slicer was publicly accessible by relying on 3D Visualization and Chen. See
`Ex. 1012 ¶¶ 41–43 (citing Ex. 1007, relying on 3D Visualization), 106
`(citing Ex. 1010, relying on Chen). Setting aside that Petitioner did not
`establish the public accessibility of 3D Visualization and Chen, this
`testimony is still deficient. Dr. Kazanzides refers to several slides from 3D
`Visualization, but these slides discuss only 3D Slicer the software, not the
`reference relied upon by Petitioner. E.g., Ex. 1012 ¶¶ 41–43 (citing Ex.
`1007, slides 6–7, 39, 42).
`For example, slide 6 of 3D Visualization is reproduced below:
`
`Ex. 1007, slide 6. This slide explains that “3D Slicer is a freely available
`open-source platform” and includes an image that states, “3D Slicer version
`4.0.” Id. This slide does not support public accessibility because, again, the
`existence of 3D Slicer software does not prove the public accessibility of
`alleged documentation about that software.
`
`
`
`7
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`Dr. Kazanzides’s reliance on Chen to prove public accessibility of 3D
`Slicer is similarly unavailing. Dr. Kazanzides testified that because Chen
`mentions 3D Slicer software, 3D Slicer itself must be prior art:
`In my opinion, Chen expressly suggests combination of
`the systems and methods disclosed therein with the “well-
`known, free and open-sourced package named 3D Slicer
`(http://www.slicer.org/) for visualization and medical image
`computing.” Ex. 1009, Chen, 131/1:29-41. . . . By 2016, the
`3D Slicer software included published documentation of the
`Main Application Graphical User Interface (GUI). See Ex.
`1010 [3D Slicer]. I understand that 3D Slicer is prior art
`because its publication date predates the assumed March 10,
`2017 relevant date.
`Ex. 1012 ¶ 106. Like 3D Visualization, Chen mentions the 3D Slicer
`software and does not refer to 3D Slicer, the reference. Also, Dr.
`Kazanzides’s statement that, “[b]y 2016, the 3D Slicer software included
`published documentation” is not supported by any evidence apart from 3D
`Slicer itself, so this statement is entitled to little weight. 37 C.F.R.
`§ 42.65(a) (“Expert testimony that does not disclose the underlying facts or
`data on which the opinion is based is entitled to little or no weight.”). Thus,
`Dr. Kazanzides’s unsupported conclusion that “3D Slicer is prior art because
`its publication date predates the assumed March 10, 2017 relevant date” is
`also entitled to little weight.
`Accordingly, Petitioner does not persuade us that we overlooked or
`misapprehended arguments or testimony submitted with the Petition
`regarding 3D Slicer.
`Returning to the Chen reference, Petitioner argues that, in light of
`Hulu, we overlooked or misapprehended that certain information on the face
`of Chen (such as a statement that Chen was “[a]vailable online 13 April
`2015”). Req. 6. Petitioner also faults our Decision for ignoring its argument
`
`8
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`that Chen “was published in volume 55 of the JOURNAL OF
`BIOMEDICAL INFORMATICS.” Id. (citing Pet. 29–30). Petitioner
`asserts that our Decision “directly contradicts Hulu’s explanation that ‘the
`indicia on the face of a reference, such as printed dates and stamps, are
`considered part of the totality of the evidence.’” Id. (citing Hulu, Paper 29 at
`17–18). This argument is unpersuasive because Petitioner again conflates
`Hulu’s analysis based on the lower reasonable likelihood standard with
`Petitioner’s burden at the final decision to prove a proposition by a
`preponderance of the evidence. See Hulu, Paper 29 at 18.
`Yet, even if we were to determine that Petitioner had proven Chen’s
`public accessibility based on the indicia on the face of Chen (i.e., printed
`date and established publisher), this still would have been insufficient to
`grant rehearing. 3D Visualization and 3D Slicer do not have similar facial
`indicia and, for reasons we explain herein, are not shown to be publicly
`accessible. Since Petitioner’s challenges based on Chen also rely on 3D
`Visualization and 3D Slicer, the alleged public accessibility of Chen alone is
`insufficient to grant rehearing. See Pet. 31, 54–69 (e.g., relying on 3D
`Visualization to disclose the “confined” limitation of independent claim 1
`(id. at 59) and various limitations of independent claim 11 (id. at 65–68)).
`B. Reply
`Petitioner next argues that we “overlooked or misapprehended most of
`the relevant evidence presented in the Reply.” Req. 7. We first address
`Petitioner’s footnote at the beginning of this argument:
`The Board expressed its willingness to consider uncited
`exhibits, filed without explanation, for [Patent Owner]’s
`benefit. Order, Paper 23 (Dec. 11, 2023), 4 (“At a minimum, we
`are able to assess the qualifications of [Patent Owner’s]
`declarants based on their [uncited] curricula vitae.”)). It would
`
`9
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`be arbitrary and capricious for the Board to not be at least as
`willing to review cited exhibits of similar length for
`[Petitioner]’s benefit.
`Id. at 7, n.7. Here, Petitioner refers obliquely to our Decision’s finding that
`Petitioner’s wholesale citation of two declarations (Exs. 1021, 1028),
`without discussion, constituted improper incorporations by reference. Dec.
`28–30. Petitioner’s footnote does not adequately explain how our decision
`not to permit these improper incorporations by reference somehow
`overlooked or misapprehended anything. Petitioner does not, for instance,
`assert that the Reply’s citation to, yet total absence of any discussion of,
`these declarations was not an improper incorporation by reference. Instead,
`Petitioner conflates its incorporation by reference with our reliance on Patent
`Owner’s curriculum vitae exhibit. But our rules prohibit parties’
`incorporation of arguments by reference, not the Board’s consideration of
`curricula vitae. See 37 C.F.R. § 42.6(a)(3) (“Arguments must not be
`incorporated by reference from one document into another document.”),
`cited in Dec. 28. And Petitioner makes no colorable argument that Patent
`Owner incorporated arguments from the curriculum vitae by reference.
`Petitioner’s related assertions that “the Board overlooked [Dr.]
`Kazanzides’s cited [Reply] testimony” and that we found this testimony
`“somehow unduly burdensome” miss the mark. Req. 7. As we explained in
`our Decision, “incorporation ‘by reference amounts to a self-help increase in
`the length of the . . . brief.’” Dec. 28–29 (quoting DeSilva v. DiLeonardi,
`181 F.3d 865, 866–67 (7th Cir. 1999)). This is not an issue of us finding
`Petitioner’s declaration testimony “somehow unduly burdensome”; it is an
`issue of Petitioner relying on declaration testimony to expand its word count
`beyond the word count limit, to the prejudice of Patent Owner. Our
`
`10
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`reviewing court has explained that “incorporating argument by reference
`‘cannot be used to exceed word count’” because “[i]t is ‘fundamentally
`unfair to allow a party to use incorporation to exceed word count.’”
`Promptu Sys. Corp. v. Comcast Cable Comm’s, LLC, 92 F.4th 1384, 1385
`(Fed. Cir. 2024) (quoting Microsoft Corp. v. DataTern, Inc., 755 F.3d 899,
`910 (Fed. Cir. 2014)).
`Although Petitioner improperly incorporated Dr. Kazanzides’s reply
`declaration by reference, we exercised our discretion to address a portion of
`it in our Decision. Dec. 30–31. We did so because we noted that his
`testimony was “particularly deficient for [the 3D Slicer] reference.” Id. at
`30. Petitioner now asserts that in doing so, we “misapprehended or
`overlooked the logic that application documentation” like 3D Slicer’s “must
`be accessible to potential application users because it serves to help users
`use the application.” Req. 7. But Petitioner’s assertion that “application
`documentation must be accessible to potential application users because it
`serves to help users use the application” is a new argument, not raised in the
`Petition or Reply. Even if Petitioner’s assertion were correct, it falls far
`short of the evidence required to prove that 3D Slicer was actually
`disseminated to interested members of the public. See, e.g., Weber, 92 F.4th
`at 1068. Thus, Petitioner’s argument fails to persuade us that we overlooked
`or misapprehended anything.
`Regarding 3D Visualization, Petitioner asserts that, despite Hulu, our
`Decision found “that the fact that 3D Slicer’s Director of Training had
`presented similar tutorials at 22 conferences to more than 2700 people . . .
`does not support the public accessibility of [3D Visualization].” Id. at 8
`(citing Dec. 29; Ex. 1007, passim; Ex. 1021 ¶¶ 11–23). What Petitioner
`argued in the Reply was merely that 3D Visualization is “a tutorial by 3D
`
`11
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`Slicer’s Director of Training, like previous trainings given at 22 conferences
`to more than 2700 people.” Reply at 27–28 (emphasis added). We
`explained in our Decision that “Petitioner’s assertion that 3D Visualization
`is ‘like previous trainings’ given at conferences does not assert that 3D
`Visualization itself was presented at any conferences before any skilled
`artisans,” and thus, “this bare assertion does not support public
`accessibility.” Dec. 29. Petitioner provides no persuasive reason to disturb
`our finding that Petitioner presented no evidence that 3D Visualization itself
`was presented at any conference before any skilled artisans.
`C. Other Documents
`Finally, Petitioner argues that we overlooked or misapprehended
`certain other documents.
`Petitioner argues that we overlooked the Price Declaration (Ex. 1023),
`which allegedly addresses the public accessibility of 3D Visualization. 3
`Req. 8. Petitioner asserts that we also overlooked Patent Owner’s “adoption
`of the Price Declaration as its own evidence of the state of the art at the
`relevant time.” Id. (citing Sur-reply 20–21). In particular, Petitioner notes
`that Patent Owner filed a copy of the Price Declaration as its own exhibit,
`which we later expunged as duplicative. Id. (citing Ex. 2023). “By adopting
`the Price Declaration as its own evidence of the state of the art, [Patent
`Owner] waived the right to challenge the Price Declaration and added to the
`
`
`3 Petitioner also contends that the Price Declaration addresses the public
`accessibility of Amira (Ex. 1005). Req. 8. Whether Amira is publicly
`accessible is irrelevant because in our Decision, we found (and Petitioner
`does not challenge on rehearing) that Petitioner failed to articulate a
`persuasive rationale to combine Amira with Doo. Dec. 25.
`
`12
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`record evidence of the public accessibility of [3D Visualization],” Petitioner
`asserts. Id. at 9.
`We disagree with Petitioner’s characterization of Patent Owner’s
`citation of Exhibit 1023 and refiling of this exhibit. Patent Owner only
`discusses the Price Declaration in the context of Amira, not 3D
`Visualization. Sur-reply 20–21. Whatever tenuous connection Patent
`Owner’s citation and refiling of the Price Declaration may have had to
`public accessibility of 3D Visualization, Petitioner does not clearly
`illuminate.
`Relatedly, Petitioner argues that it cannot be faulted for not discussing
`the Price Declaration because we denied Petitioner’s request for additional
`briefing after Patent Owner filed its Sur-reply. Req. 9. This argument has
`no merit. Petitioner submitted the Price Declaration with its Reply. See
`Reply v (listing Exhibit 1023 in the Exhibit List). Petitioner’s decision not
`to address the Price Declaration in the Reply means that it is too late to
`address it now. Moreover, in our brief review of this lengthy exhibit
`spanning several hundred pages, we also do not see any discussion of the
`alleged public accessibility of 3D Visualization. So the Price Declaration
`also does not appear to support Petitioner’s rehearing request.
`Petitioner also asserts that we “overlooked undisputed facts in
`[Petitioner’s] Motion to Exclude [Mot.].” Req. 9. In particular, Petitioner
`asserts that Patent Owner’s “expert admitted that multiple research groups
`commonly used 3D Slicer technology before the relevant time.” Id. at 10
`(citing Mot. 6–7 (“[Dr.] Mulumudi agreed that the underlying technology
`was commonly used by multiple research groups before the relevant time
`. . . .”)). In addition to this alleged admission, Petitioner would have us draw
`an “inference that groups commonly using 3D Slicer technology before the
`
`13
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`relevant time must have had some way to understand the 3D Slicer
`technology and to learn how to use it.” Id. We decline to do so for reasons
`we explain above. Further, Petitioner did not make this argument in its
`briefing or at the oral hearing, so it is a new argument that we could not have
`overlooked or misapprehended because it was presented for the first time in
`Petitioner’s rehearing request. It is also unpersuasive because, even if we
`take as true Dr. Mulumudi’s alleged admission that 3D Slicer technology
`was commonly used, it still does not prove that the reference submitted by
`Petitioner as prior art here (e.g., the 3D Slicer reference) was publicly
`accessible.
`
`
`IV. CONCLUSION
`For the forgoing reasons, Petitioner has not shown that we
`misapprehended or overlooked any arguments or evidence presented in the
`Petition, Reply or other documents. Accordingly, we deny the Request for
`Rehearing.
`
`
`V. ORDER
`
`It is, therefore:
`ORDERED that Petitioner’s request for rehearing is denied.
`
`
`
`
`
`
`
`14
`
`
`
`IPR2023-00042
`Patent 11,004,271 B2
`FOR PETITIONER:
`
`Kia L. Freeman
`John Curran
`MCCARTER & ENGLISH, LLP
`kfreeman@mccarter.com
`jcurran@mccarter.com
`
`FOR PATENT OWNER:
`
`Joseph Harmer
`Jed H. Hansen
`THORPE NORTH & WESTERN LLP
`joseph.harmer@tnw.com
`hansen@tnw.com
`
`15
`
`
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