Case 1:20-cv-00393-LMB-TCB Document 1398-1 Filed 07/20/22 Page 1 of 16 PageID# 34839
`Case 1:20-cv-00393-LMB-TCB Document 1398-1 Filed 07/20/22 Page 1 of 16 PagelD# 34839
`
`EXHIBIT 1
`EXHIBIT 1
`
`

`

`Case 1:20-cv-00393-LMB-TCB Document 1398-1 Filed 07/20/22 Page 2 of 16 PageID# 34840
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`RAI STRATEGIC HOLDINGS, INC. and
`R.J. REYNOLDS VAPOR COMPANY,
`
`
`Plaintiffs and Counterclaim
`Defendants,
`
`v.
`
`
`
`
`ALTRIA CLIENT SERVICES LLC; PHILIP
`MORRIS USA INC.; and PHILIP MORRIS
`PRODUCTS S.A.
`
`Defendants and Counterclaim
`Plaintiffs.
`
`Case No. 1:20-cv-00393-LO-TCB
`
`
`ALTRIA CLIENT SERVICES LLC, PHILIP MORRIS USA, INC., AND
`PHILIP MORRIS PRODUCTS S.A.’S FIRST SET OF INTERROGATORIES
`(NOS. 1-11)
`
`Pursuant to Federal Rules of Civil Procedure 26 and 33, Altria Client Services LLC, Philip
`
`
`
`
`Morris USA Inc., and Philip Morris Products S.A. request that RAI Strategic Holdings, Inc. and
`
`R.J. Reynolds Vapor Company answer each interrogatory set forth below separately and fully, in
`
`writing and under oath, in accordance with the definitions and instructions contained herein, within
`
`thirty (30) days after service of the interrogatories. Altria Client Services LLC, Philip Morris USA
`
`Inc., and Philip Morris Products S.A. request that RAI Strategic Holdings, Inc. and R.J. Reynolds
`
`Vapor Company make any production of documents in connection with answers to these
`
`interrogatories at the office of Latham & Watkins LLP, 555 Eleventh Street NW, Suite 1000,
`
`Washington, DC 20004.
`
`

`

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`DEFINITIONS
`
`As used herein and all further interrogatories, unless specified otherwise, the following
`
`definitions apply:
`
`1.
`
`The terms “You,” “Plaintiffs,” “Counterclaim Defendants,” and “RJR” refer
`
`collectively to RAI Strategic Holdings, Inc. (“RAI”) and R.J. Reynolds Vapor Company
`
`(“RJRV”), their predecessors-in-interest, subsidiaries, joint ventures, affiliates, and other legal
`
`entities that are wholly or partially owned or controlled by RAI, RJRV, and/or R.J. Reynolds
`
`Tobacco Company, either directly or indirectly, and the principals, directors, officers, owners,
`
`members, representatives, employees, agents, consultants, accountants, and attorneys of these
`
`same entities.
`
`2.
`
`The terms “Defendants” and “Counterclaim Plaintiffs” refer collectively to Altria
`
`Client Services LLC (“ACS”), Philip Morris USA Inc. (“PM USA”), and Philip Morris Products
`
`S.A. (“PMP”).
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`References to this “lawsuit,” “case,” or “action” mean the above-captioned action.
`
`The “’265 patent” means U.S. Patent No. 9,814,265.
`
`The “’556 patent” means U.S. Patent No. 10,555,556.
`
`The “’911 patent” means U.S. Patent No. 10,104,911.
`
`The “’545 patent” means U.S. Patent No. 6,803,545.
`
`The “’374 patent” means U.S. Patent No. 10,420,374.
`
`The “Counterclaim Asserted Patent(s)” means the ’265 patent, the ’556 patent, the
`
`’911 patent, the ’545 patent, and the ’374 patent, collectively, any other patent that may be added
`
`to this litigation by Counterclaim Plaintiffs, and the applications that led to the issuance of any of
`
`the foregoing patents.
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`

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`10.
`
`“Counterclaim Asserted Claim(s)” means each asserted claim of each Counterclaim
`
`Asserted Patent.
`
`11.
`
`12.
`
`13.
`
`The “’268 patent” means U.S. Patent No. 9,814,268.
`
`The “’542 patent” means U.S. Patent No. 10,492,542.
`
`The “RJR Asserted Patent(s)” means the ’268 patent, and the ’542 patent
`
`collectively, any other patent that may be added to this litigation by Plaintiffs in amended
`
`pleadings, and the applications that led to any of the foregoing patents.1
`
`14.
`
`“RJR Asserted Claim(s)” mean each claim of each RJR Asserted Patent that
`
`Plaintiffs allege Defendants infringe, either directly or indirectly, literally or by the doctrine of
`
`equivalents.
`
`15.
`
`“Infringe,” “infringing,” “infringed,” or “infringement” means direct infringement,
`
`indirect infringement, contributory infringement, induced infringement, literal infringement and/or
`
`infringement under the doctrine of equivalents.
`
`16.
`
`“Prior Art” is used in these Interrogatories in the same sense that it is used in 35
`
`U.S.C. §§ 102 or 103 and includes without limitation, any patent, publication, physical device,
`
`prototype, knowledge, use, sale, offer for sale, any documents or other items evidencing any of the
`
`foregoing, and/or any other act or event defined in 35 U.S.C. § 102, taken singly or in combination,
`
`and having or occurring at a date such as to be potentially relevant under any subsection of 35
`
`U.S.C. §§ 102 or 103.
`
`
`1 RJR has additionally asserted U.S. Patent Nos. 9,839,238 (“the ’238 patent”); 9,901,123 (“the
`’123 patent”); and 9,930,915 (“the ’915 patent”). These patents have been stayed until the
`determination of the International Trade Commission in In the Matter of Certain Tobacco Heating
`Articles and Components Thereof (Inv. No. 337-TA-1199) becomes final. Once the stay is lifted,
`the term “RJR Asserted Patent(s),” as used in this document, will further encompass the ’238
`patent, ’123 patent, and ’915 patent.
`
`

`

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`17.
`
`“RJR Accused Product(s)” refers to any RJR Product Counterclaim Plaintiffs
`
`contend infringe any Counterclaim Asserted Claim(s), including but not limited to the VUSE
`
`VIBE, VUSE SOLO, VUSE CIRO, and VUSE ALTO devices, as well as Flavor Packs and power
`
`units associated with those products.
`
`18.
`
`“Accused Product(s)” means any of Counterclaim Plaintiffs’ products that
`
`Counterclaim Defendants contend infringe any RJR Asserted Claims, including but not limited to
`
`the IQOS System and associated tobacco sticks identified in ¶¶ 20-33 of the Amended Complaint.
`
`19.
`
`“RJR Covered Product(s)” refers to any Product that Plaintiffs contend practices or
`
`embodies any purported invention described or claimed in the RJR Asserted Patents, including
`
`any Products made by Plaintiffs or third parties.
`
`20.
`
`“Product” means any machine, manufacture, apparatus, device, system, process,
`
`service, method, or instrumentality which is designed to function together electrically,
`
`mechanically, chemically, or otherwise, to achieve a particular function or purpose, including
`
`those offered for sale, sold, imported, or under development.
`
`21.
`
`22.
`
`“Person” or “individual” means any natural person.
`
`“Document” is synonymous in meaning and equal in scope to the usage of the term
`
`“documents or electronically stored information” in Rule 34(a)(l)(A) of the Federal Rules of Civil
`
`Procedure. A draft or non-identical copy is a separate document within the meaning of this term.
`
`By way of illustration, and without limitation, documents include at least the following: originals,
`
`drafts, and all non-identical copies of memoranda, reports, notes, graphs, laboratory notebooks,
`
`correspondence, interoffice communications, letters, diaries, calendars, photographs, motion
`
`pictures, sketches, drawings, promotional material, technical papers, printed publications, patents,
`
`records, reports, and all other writings, as well as all non-paper information storage means such as
`
`

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`sound reproductions, computer inputs and outputs, tape, film and computer memory devices, as
`
`well as tangible things such as models, modules, prototypes, and commercially saleable products.
`
`23.
`
`“Thing” shall mean any tangible item, including without limitation, models,
`
`prototypes and samples of any device or apparatus or product.
`
`24.
`
`The term “Communication” means every manner or method of the disclosure,
`
`transfer, or exchange of information, whether orally, electronically, or by Document, and whether
`
`face to face or by telephone, mail, facsimile, E-mail, video, instant message, internet
`
`Communication, or otherwise.
`
`INSTRUCTIONS
`
`1.
`
`The following shall apply to all Interrogatories:
`
`a.
`
`The singular of any word includes its plural, and vice versa, to bring within
`
`the scope of these Interrogatories any information that might otherwise be
`
`deemed outside their scope;
`
`b.
`
`The terms “and” and “or” shall be construed either conjunctively or
`
`disjunctively, to bring within the scope of these Interrogatories any
`
`information that might otherwise be deemed outside their scope;
`
`c.
`
`The terms “all,” “any,” and “each” shall be construed as encompassing any
`
`and all to bring within the scope of these Interrogatories any information
`
`that might otherwise be deemed outside their scope;
`
`d.
`
`“Including” shall not be used to limit any general category or description
`
`that precedes it and shall mean “including without limitation” so as to be
`
`inclusive; and
`
`e.
`
`The present tense shall be construed to include the past tense and vice versa.
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`

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`2.
`
`Each Interrogatory shall operate and be responded to independently and, unless
`
`otherwise indicated, no Interrogatory limits the scope of any other Interrogatory.
`
`3.
`
`All Interrogatories are to be understood as requesting information in Your
`
`possession, custody, or control, and the request extends to knowledge or information in the
`
`possession of your predecessors-in-interest and/or successors.
`
`4.
`
`In answering the following Interrogatories, You shall furnish all available
`
`information, including information in the possession, custody, or control of any of Your attorneys,
`
`directors, officers, agents, employees, representatives, associates, investigators or division
`
`affiliates, partnerships, parents or subsidiaries, and persons under Your control, who have the best
`
`knowledge, not merely information known to You based on Your own personal knowledge. If
`
`You cannot fully respond to the following Interrogatories after exercising due diligence to secure
`
`the information requested thereby, so state, and specify the portion of each Interrogatories that
`
`cannot be responded to fully and completely. In the latter event, state what efforts were made to
`
`obtain the requested information and the Facts relied upon that support any contention that the
`
`Interrogatories cannot be answered fully and completely, and state what knowledge, information
`
`or belief You have concerning the unanswered portion of any such Interrogatories.
`
`5.
`
`If any information requested is claimed to be privileged or otherwise immune from
`
`discovery, please provide all information falling within the scope of the Interrogatory which is not
`
`privileged, and for each item of information contained in a document or communication to which
`
`a claim of privilege is made, identify such document or communication with sufficient particularity
`
`for purposes of a motion to compel in accordance with Federal Rule of Civil Procedure 26(b)(5).
`
`

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`6.
`
`If any Interrogatory is ambiguous or unclear to You, please contact undersigned
`
`counsel as soon as possible so that the Interrogatory can be clarified to avoid unnecessary delays
`
`in discovery.
`
`7.
`
`Your obligation to respond to these Interrogatories is continuing and Your
`
`responses are to be supplemented to include subsequently acquired information in accordance with
`
`the requirements of Rule 26(e) of the Federal Rules of Civil Procedure.
`
`8.
`
`To the extent You contend that any Interrogatory consists of multiple discrete
`
`subparts, You are to state in Your objections to that Interrogatory Your contention as to the number
`
`of subparts for that Interrogatory and the basis for Your contention.
`
`9.
`
`If You elect to specify and produce business records in answer to any Interrogatory,
`
`the specification shall be in sufficient detail to permit Defendants/Counterclaim Plaintiffs to locate
`
`and identify, as readily as You can enable, the business records from which the answer may be
`
`ascertained.
`
`10.
`
`If in answering any Interrogatory, You seek to invoke the procedures of Rule 33(d)
`
`of the Federal Rules of Civil Procedure, state fully all facts which support your contention that the
`
`burden of ascertaining the answer to the Interrogatory is substantially the same for
`
`Defendants/Counterclaim Plaintiffs as it is for you, and specify those business records from which
`
`You contend Defendants/Counterclaim Plaintiffs may ascertain or derive the answer.
`
`11.
`
`If any objection is made to any Interrogatory herein, the objection shall state with
`
`particularity the basis therefore, and the Interrogatory shall be answered to the extent not objected
`
`to.
`
`

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`12.
`
`If You do not agree with any definition of the terms provided herein, You are
`
`instructed to provide a reasonable, alternative definition for that term, consistent with industry
`
`custom and usage.
`
`13.
`
`Each of the definitions and instructions contained herein shall be fully applicable
`
`to each Interrogatory notwithstanding that a definition or instruction above may, in whole or in
`
`part, be reiterated in a particular Interrogatory and notwithstanding that a particular Interrogatory
`
`may incorporate supplemental instructions or definitions. If, however, You provided any alternate
`
`definitions in accordance with these instructions, indicate whether and how, any answer to any
`
`Interrogatory would differ if You relied on Your alternate definition in responding to that
`
`Interrogatory instead of the definitions provided.
`
`FIRST SET OF INTERROGATORIES
`
`INTERROGATORY NO. 1:
`
`
`
`To the extent that You contend that the RJR Accused Products do not infringe the
`
`Counterclaim Asserted Patents, separately for each RJR Accused Product, provide all factual and
`
`legal bases for Your contention that Your making, using, offering to sell, or selling within the
`
`United States, or importing into the United States such RJR Accused Product does not infringe,
`
`directly or indirectly, any Counterclaim Asserted Claim, including: an identification of the claim
`
`elements that You allege are not included in or performed by each RJR Accused Product; an
`
`explanation in detail as to why each claim element is not met by each RJR Accused Product (either
`
`literally or under the doctrine of equivalents); an identification of any part of Counterclaim
`
`Plaintiffs’ infringement contentions with which You disagree, and a detailed explanation of why
`
`You disagree; an identification of all Documents and other evidence that support Your contention;
`
`

`

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`and an identification of the three (3) Persons most knowledgeable about the factual bases for Your
`
`contentions.
`
`INTERROGATORY NO. 2:
`
`
`
`To the extent that You contend that the Counterclaim Asserted Claims are invalid, provide
`
`on a claim-by-claim basis all factual and legal bases for your contention, including but not limited
`
`to: identifying the specific portion of §§ 101, 102, 103, or 112 that You contend each claim fails
`
`to meet; identifying the Prior Art or event that You assert invalidates the claim; identifying (as in
`
`a claim chart) where each limitation of the claim is found in each item of the Prior Art; and
`
`identifying all Documents that support Your contentions, including but not limited to those related
`
`to public accessibility of the Prior Art.
`
`INTERROGATORY NO. 3:
`
`
`
`
`
`Separately for each of the Counterclaim Asserted Patents, describe in detail Your
`
`awareness or knowledge of the patent and any applications relating to the patent, including the
`
`date You first became aware, how You became aware, the substance of what You knew, and any
`
`actions You took as a result of that knowledge, each Document that supports Your response or to
`
`which You referred in preparing Your response, and identify the three (3) Persons most
`
`knowledgeable about Your awareness or knowledge.
`
`INTERROGATORY NO. 4:
`
`
`
`For each RJR Accused Product, separately for each of the Counterclaim Asserted Patents,
`
`describe in detail all theories and bases under which Counterclaim Defendants contend damages
`
`should be measured, and explain in detail how such damages are computed, including identifying
`
`all Products for which damages should be awarded, whether and to what extent there have been
`
`convoyed sales, the amount of any reasonable royalty that should be awarded, any royalty base
`
`

`

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`and rate which Counterclaim Defendants contend is reasonable, how such amount, base, and rate
`
`are computed, the date(s) on which you contend the hypothetical negotiation would have occurred,
`
`the parties to the hypothetical negotiation, the appropriate time period(s) for which damages should
`
`be assessed, all facts and evidence that support or refute Counterclaim Defendants’ damages
`
`theories and bases, and identify the three (3) Persons most knowledgeable concerning such facts.
`
`Your response should include, but not be limited to, the bases for Your contentions regarding the
`
`factors set forth in Georgia-Pacific Corp. v. U.S. Plywood Corp., 318 F. Supp. 1116, 1120
`
`(S.D.N.Y. 1970).
`
`INTERROGATORY NO. 5:
`
`
`
`
`
`For each RJR Asserted Claim of the RJR Asserted Patents, explain in detail Your
`
`contentions regarding infringement by each Accused Product (including literal infringement,
`
`infringement by the doctrine of equivalents, inducement of infringement and contributory
`
`infringement), and separately for each Accused Product, describe in detail and identify the specific
`
`factual and legal bases that support Your contentions including, but not limited to: identification
`
`of each claim of the RJR Asserted Patents that is allegedly infringed by Defendants and
`
`identification of where each limitation of each asserted claim is found in each Accused Product.
`
`INTERROGATORY NO. 6:
`
`
`
`
`
`For each RJR Asserted Patent that You contend Defendants have willfully infringed,
`
`describe in detail and identify the factual and legal bases for Your contention, and identify all facts,
`
`evidence, and Documents supporting such contention.
`
`INTERROGATORY NO. 7:
`
`
`
`
`
`For each Accused Product and RJR Asserted Claim, describe in detail and identify the
`
`factual and legal bases for Your claim for damages to which You contend You are entitled as a
`
`

`

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`result of Defendants’ alleged infringement, including without limitation, whether Your damages
`
`claims are based on lost profits, a reasonably royalty, or other damages theory, any royalty rate,
`
`royalty base, lost profits, disgorgements, enhanced damages, attorney’s fees, or costs that You
`
`contend are appropriate, Your products that you contend compete with the Accused Products, non-
`
`infringing alternatives, the date You contend the hypothetical negotiation would have commenced
`
`with respect to each RJR Asserted Patent, the time period for which You contend You are entitled
`
`to collect damages from Defendants due to any alleged infringement of each RJR Asserted Patent,
`
`and whether the royalty base is based on the value of the entire product or a portion thereof (if so,
`
`identify the portion); identify all Documents and things supporting, contradicting, or otherwise
`
`relating to Your contentions; and identify the three (3) most knowledgeable Persons concerning
`
`the facts described in Your response and all Persons on which you intend to rely to support Your
`
`contentions.
`
`INTERROGATORY NO. 8:
`
`
`
`
`
`Describe the complete factual and legal basis for Your contention that You are entitled to
`
`any injunctive relief, including any irreparable injury You have allegedly suffered, and why such
`
`injury is irreparable, why remedies available at law, such as monetary damages, are inadequate to
`
`compensate for that injury, why, considering the balance of hardships between You and
`
`Defendants, a remedy in equity is warranted, why the public interest would not be disserved by a
`
`permanent injunction, and identify the three (3) individuals most knowledgeable of the foregoing,
`
`and all Documents and things (by Bates number) You intend to rely on to support Your contention.
`
`INTERROGATORY NO. 9:
`
`
`
`
`
`For each RJR Asserted Claim, describe in detail and identify the facts and circumstances
`
`of the conception and reduction to practice of the purported claimed invention, and any intervening
`
`

`

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`diligence, including, without limitation, the earliest date by which the inventors conceived of the
`
`claimed invention, the earliest date by which the inventors reduced to practice the claimed
`
`invention, where and when such conception, reduction to practice, or diligence occurred, all
`
`Documents that refer or relate to such conception, reduction to practice, or diligence, all Persons
`
`involved in such conception and reduction to practice of the claimed invention, and any intervening
`
`diligence, and their role in such conception, reduction to practice, or diligence, state all factual and
`
`legal bases supporting, contradicting, or otherwise relating to any alleged conception and reduction
`
`to practice; and identify the three (3) most knowledgeable Persons about the facts described in
`
`Your response.
`
`INTERROGATORY NO. 10:
`
`
`
`
`
`Identify and describe Your contentions relating to the purported validity of any RJR
`
`Asserted Claim including identification of Your contentions relating to all secondary
`
`considerations and objective evidence of nonobviousness of the purported inventions claimed in
`
`the RJR Asserted Patents, including, but not limited to, the presence or absence of any commercial
`
`success, long-felt need, commercial acquiescence, expressions of skepticism, copying, teaching
`
`away, successful or failed attempts by others, or simultaneous development; identify all
`
`Documents and things supporting, contradicting, or otherwise relating to Your contentions; and
`
`identify three (3) most knowledgeable Persons about the facts described in Your contentions.
`
`INTERROGATORY NO. 11:
`
`
`
`
`
`Separately, for each RJR Covered Product, identify the claims, and identify and describe
`
`on a limitation-by-limitation basis in chart-form the portions of any Documents or things that You
`
`contend show how each limitation of each identified claim is satisfied by the RJR Covered Product;
`
`identify all Documents and things supporting, contradicting, or otherwise relating to Your
`
`

`

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`contentions; and identify the three (3) most knowledgeable Persons about the facts described in
`
`Your contentions.
`
`
`
`Dated: August 11, 2020
`
`
`
`
`
`
`
`
`
`
`
`/s/ Maximilian A. Grant
`Maximilian A. Grant (VSB No. 91792)
`max.grant@lw.com
`Matthew J. Moore (pro hac vice pending)
`matthew.moore@lw.com
`LATHAM & WATKINS LLP
`555 Eleventh Street, N.W., Ste. 1000
`Washington, DC 20004
`Tel: (202) 637-2200; Fax: (202) 637-2201
`
`Clement J. Naples (pro hac vice pending)
`clement.naples@lw.com
`LATHAM & WATKINS LLP
`885 Third Avenue
`New York, NY 10022-4834
`Tel: (212) 906-1200; Fax: (212) 751-4864
`
`Gregory K. Sobolski (pro hac vice pending)
`Gregory.sobolski@lw.com
`LATHAM & WATKINS LLP
`505 Montgomery Street, Suite 2000
`San Francisco, CA 94111
`Tel: (415) 391-0600; Fax: (415) 395-8095
`
`Brenda L. Danek (pro hac vice pending)
`brenda.danek@lw.com
`LATHAM & WATKINS LLP
`330 North Wabash Avenue, Suite 2800
`Chicago, IL 60611
`Tel: (312) 876-7700; Fax: (312) 993-9767
`
`Counsel for Defendants-Counterclaim
`Plaintiffs Altria Client Services LLC, Philip
`Morris USA Inc., and Philip Morris
`Products S.A.
`
`

`

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`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 11th day of August, 2020, I served the foregoing by hand
`
`delivery and email on the following:
`
`Anthony M. Insogna
`JONES DAY
`4655 Executive Drive, Suite 1500
`San Diego, CA 92121
`Telephone: (858) 314-1200
`Facsimile: (844) 345-3178
`Email: aminsogna@jonesday.com
`
`And by email on the following
`
`Stephanie E. Parker
`JONES DAY
`1420 Peachtree Street, N.E.
`Suite 800
`Atlanta, GA 30309
`Telephone: (404) 521-3939
`Facsimile: (404) 581-8330
`Email: separker@jonesday.com
`
`William E. Devitt
`JONES DAY
`77 West Wacker
`Suite 3500
`Chicago, IL 60601
`Telephone: (312) 269-4240
`Facsimile: (312) 782-8585
`Email: wdevitt@jonesday.com
`
`John J. Normile
`JONES DAY
`250 Vesey Street
`New York, NY 10281
`Telephone: (212) 326-3939
`Facsimile: (212) 755-7306
`Email: jjnormile@jonesday.com
`
`Counsel for Plaintiffs RAI Strategic
`Holdings, Inc. and R.J. Reynolds
`Vapor Company
`Alexis A. Smith
`
`
`JONES DAY
`555 South Flower Street
`Fiftieth Floor
`Los Angeles, CA 90071
`Telephone: (213) 243-2653
`Facsimile: (213) 243-2539
`Email: asmith@jonesday.com
`
`Sanjiv P. Laud
`JONES DAY
`90 South Seventh Street
`Suite 4950
`Minneapolis, Minnesota 55402
`Telephone: (612) 217-8800
`Facsimile: (844) 345-3178
`Email: slaud@jonesday.com
`
`David M. Maiorana (VA Bar No. 42334)
`Ryan B. McCrum
`JONES DAY
`901 Lakeside Ave.
`Cleveland, OH 44114
`Telephone: (216) 586-3939
`Facsimile: (216) 579-0212
`Email: dmaiorana@jonesday.com
`Email: rbmccrum@jonesday.com
`
`
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`

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`/s/ Maximilian A. Grant
`Maximilian A. Grant (VSB No. 91792)
`max.grant@lw.com
`LATHAM & WATKINS LLP
`555 Eleventh Street, N.W., Ste. 1000
`Washington, DC 20004
`Tel: (202) 637-2200; Fax: (202) 637-2201
`
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