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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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`APPLE INC., GOOGLE INC., AND MOTOROLA MOBILITY LLC
`Petitioners
`v.
`
`ARENDI S.A.R.L.
`Patent Owner
`
`
`
`Patent No. 7,917,843
`Issue Date: February 24, 2009
`
`Title: METHOD, SYSTEM AND COMPUTER READABLE MEDIUM FOR
`ADDRESSING HANDLING FROM A COMPUTER PROGRAM
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`_______________
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`Inter Partes Review No. IPR2014-00208
`____________________________________________________________
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`PETITIONERS’ REPLY TO PATENT OWNER’S RESPONSE
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`TABLE OF CONTENTS
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`Page
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`TABLE OF AUTHORITIES .................................................................................. ii
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`PETITIONERS’ EXHIBIT LIST ........................................................................... iii
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`I.
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`INTRODUCTION .......................................................................................... 1
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`II.
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`REPLY TO PATENT OWNER’S ARGUMENTS ........................................ 4
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`A.
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`Pandit Renders The Challenged Claims Obvious ................................ 4
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`1.
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`2.
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`3.
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`4.
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`5.
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`The Retrieved Definition or Other Information (“Second
`Information”) in Pandit Is Related to the Type of “First
`Information” ............................................................................... 6
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`Reliance on the Common Sense and Knowledge of One
`of Ordinary Skill in the Art Is Not Only Appropriate, It Is
`Necessary ................................................................................... 7
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`The Patent Owner Misapplies Federal Circuit Law in
`Arguing that Common Sense Has No Role in the
`Obviousness Analysis .............................................................. 10
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`Searching for Duplicates Is a Simple Method Known to a
`Person of Ordinary Skill in the Art .......................................... 12
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`Searching For Duplicates Need Not Rely on the Use of a
`Name ........................................................................................ 14
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`III. CONCLUSION ............................................................................................. 15
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`CASES
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`TABLE OF AUTHORITIES
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`Docket No. 106842805200
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`Page(s)
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`I/P Engine, Inc. v. AOL Inc.,
`No. 2013-1307, 2014 U.S. App. LEXIS 15667, at *17-18
`(Fed. Cir. Aug. 15, 2014) ..................................................................................................12
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`DyStar Textilfarben GmbH & Co. v. C.H. Patrick Co.,
`464 F.3d 1356 (Fed. Cir. 2006)................................................................................................12
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`Eizo Corp. v. Barco N.V.
`IPR2014-00358, 2014 WL 3704253, at *9, (PTAB July 23, 2014) ....................................3, 11
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`K/S HIMPP v. Hear-Wear Techs., LLC,
`751 F.3d 1362 (Fed. Cir. 2014)..................................................................................................3
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`KSR Int’l Co. v. Teleflex, Inc.,
`550 U.S. 398 (2007) .............................................................................................................8, 12
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`Perfect Web Technologies, Inc. v. InfoUSA, Inc.,
`587 F.3d 1324 (Fed. Cir. 2009)..........................................................................................2, 3, 9
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`SIBIA Neurosciences, Inc. v. Cadus Pharmaceutical Corp.,
`225 F.3d 1349 (Fed. Cir. 2000)................................................................................................10
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`OTHER AUTHORITIES
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`37 C.F.R. § 42.23 ........................................................................................................................1
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`Petitioners’ Exhibit List for Inter Partes Review of U.S. Patent No. 7,496,843
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`Exhibit Description
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`Exhibit #
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`U.S. Patent No. 7,917,843 to Hedloy
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`Declaration of Dr. Daniel A. Menascé
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`Amendment dated January 24, 2008
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`Non Final Office Action dated October 24, 2008
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`Amendment dated December 8, 2010
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`SIGCHI Bulletin (April 1998) at 51-63
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`U.S. Patent No. 5,946,647 to Miller et al.
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`U.S. Patent No. 5,644,735 to Luciw et al.
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`U.S. Patent No. 5,859,636 to Pandit et al.
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`SIGCHI Bulletin (April 1998) at 53-63 (web version)
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`Declaration of Julie S. Turner
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`Declaration of Robert Kent
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`1001
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`1002
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`1003
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`1004
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`1005
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`1006
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`1007
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`1008
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`1009
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`1010
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`1011
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`1012
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`*Petitioners’ Exhibits 1001 - 1012 were previously filed and are listed again here
`based on 37 C.F.R. § 42.63.
`Deposition Transcript of Daniel A. Menascé, Ph.D.
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`1013
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`**Petitioners’ Exhibit 1013 is newly filed.
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`Apple Inc., Google Inc., and Motorola Mobility LLC (collectively,
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`“Petitioners”) provide this Reply under 37 C.F.R. § 42.23 to the August 26, 2014
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`“Patent Owner Response” (Paper No. 17; “Response”). With this Reply and the
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`Petition filed on December 2, 2013 (Paper No. 1), Petitioners request relief through
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`the cancellation of claims 1-2, 8, 14-17, 20-21, 23-24, 30, 36-39, and 42-43 of
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`U.S. Patent No. 7,917,843 (“the '843 patent”; Ex. 1001).
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`I.
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`INTRODUCTION
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`The '843 patent is directed to name and address handling within a document
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`created by a computer program, such as a word processing program. (1:18-26.)
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`The claims are specifically directed to finding information (Second Information)
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`related to the contents of a document (First Information) and performing an action
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`using that information. (3:42-67.) Displaying an address and inserting an address
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`into the document are the only actions disclosed in the '843 patent that use
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`information located by a search.
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`The Board instituted inter partes review based upon Pandit (Ex. 1009). (See
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`Decision (June 11, 2014), Paper No. 8 at 19.) Pandit is directed to recognition of
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`and operation on text data. For example, a document is illustrated in Figs. 1a-1f.
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`Various text items in the document can be selected by the user and analyzed to
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`determine the nature of the text, e.g., whether it is a date, an email address or a
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`phone number. Based upon this determination, various actions relating to the
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`determined type of text can be made available for selection by the user. Pandit
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`provides several examples, including: (1) searching a dictionary for “the meaning
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`of the highlighted word, appropriate synonyms and the singular or plural version of
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`the noun or conjugation of the verb” (Ex. 1009, 3:11-15); and (2) adding
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`information corresponding to a detected phone number to an address book. (Id. at
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`Figs. 1d and 1f; 2:56-63; 3:1-10.) The Institution Decision focused on the second
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`example.
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`In its Response, the Patent Owner seeks to overcome the instituted ground
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`by disputing the disclosures in Pandit, the appropriateness of Petitioners’ reliance
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`on common sense of one of ordinary skill in the art in making the obviousness
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`determination, and the sufficiency of the evidence in the record. The Patent Owner
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`is incorrect on all counts. First, the Patent Owner continues to argue that the
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`“type” of information retrieved from a dictionary search is a definition that does
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`not depend on the “type” of the information searched (i.e., whether the definition is
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`the same regardless of whether a noun or a verb form of a word is searched). This
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`argument ignores the fact that words have different definitions, and Pandit presents
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`different information, depending on whether words are nouns or verbs.
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`The Board’s reliance on common sense as part of the obviousness analysis
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`in instituting review was entirely proper. The Federal Circuit in Perfect Web
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`Technologies, Inc. v. InfoUSA, Inc. held that “while an analysis of obviousness
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`always depends on evidence that supports the required Graham factual findings, it
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`also may include recourse to logic, judgment, and common sense available to the
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`person of ordinary skill that do not necessarily require explication in any reference
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`or expert opinion.” 587 F.3d 1324, 1329 (Fed. Cir. 2009) (emphasis added). In
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`Perfect Web, as here, the reliance on common sense pertains to easily
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`understandable concepts. The Petitioners supported their analysis with testimony
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`from Prof. Menascé.
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`The Patent Owner’s argument that the case law “prohibits the use of
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`‘common sense’ to compensate for a claim limitation that is missing from the prior
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`art” is simply wrong. In the cases cited by the Patent Owner—Hear-Wear and
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`Eizo—the party alleging obviousness failed to submit any reasoning, expert
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`testimony or other evidence to support its assertions. For example, in K/S HIMPP
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`v. Hear-Wear Techs., LLC, the requesters relied on an Examiner’s unsupported
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`statement made during prosecution of the patent that “detachable connections were
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`well known at the time of the alleged invention.” 751 F.3d 1362, 1364 (Fed. Cir.
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`2014) (internal quotation marks and citation omitted). Similarly, in Eizo Corp. v.
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`Barco N.V., the petitioner relied solely on unsupported attorney arguments “that
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`spatial periods below one millimeter and above fifty millimeters are in accordance
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`with human perceptual limitations.” IPR2014-00358, 2014 WL 3704253, at *9
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`(PTAB July 23, 2014).
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`Finally, the Patent Owner’s reliance on Dr. Levy to argue that only names—
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`rather than telephone numbers—should be used to search for duplicates
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`demonstrates its failure to properly address the obviousness analysis. By insisting
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`that names be entered via a “template or similar mechanism” for the user to enter
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`(Response at 25; Ex. 2002, Levy Decl. ¶ 21), Dr. Levy misses the point on Pandit.
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`Pandit discloses performing relevant operations based on the recognition of text in
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`the document and discloses that “names, street addresses, etc.” can also be used for
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`the operations. (Ex. 1009, 2:4-5; 24-31.)
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`II. REPLY TO PATENT OWNER’S ARGUMENTS
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`A.
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`Pandit Renders The Challenged Claims Obvious
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`As discussed above, the claims of the '843 patent are focused specifically on
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`finding information (Second Information) related to the contents of a document
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`(First Information) and performing an action using that information. (3:42-66.)
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`Specifically, the clicking of a user-selectable button (OneButton) in the word
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`processor causes the execution of another program to receive the typed First
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`Information in the document so that it can be used to search a database for a
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`Second Information. (3:35-54.) The only actions disclosed in the '843 patent that
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`use the Second Information located by the search are displaying an address and
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`inserting an address into the document.
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`Pandit is directed to recognition of and operation on text data. FIGs. 1a-1f
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`show that various text items in the document can be selected by the user and
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`analyzed to determine the nature of the text, e.g., whether it is a date, an email
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`address or a phone number. Based upon this determination, various actions
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`relating to the determined type of text can be made available for selection by the
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`user. For example, as shown in Fig. 1f, the determination that a selected text item
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`is a phone number can result in the provision of available actions, including calling
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`the number, adding the number to an address book, or sending a fax to the number.
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`While FIGS. 1a-f show examples of operations based on information such as email
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`address, telephone number, dates, etc., Pandit also discloses that an operation can
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`be based on searching a dictionary for the meaning of a selected word. (Ex. 1009,
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`3:11-15.)
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`To aid the Board in its analysis, the limitation at issue is reproduced in the
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`table below, along with a listing of the First Information and Second Information
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`for both the dictionary and address book examples in Pandit.
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`Excerpt of Claim 1
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`Dictionary Example
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`Address Book Example
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`the operation comprising
`(i) performing a search
`using at least part of the
`first information as a
`search term in order to
`find the second
`information, of a specific
`type or types, associated
`with the search term in an
`information source
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`First Information:
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`First Information:
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`word in a document
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`
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`telephone number, email
`address, or name
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`Second Information:
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`Second Information:
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`definition of the word
`found in a dictionary,
`synonyms, or other
`information regarding the
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`contact information
`relating to the telephone
`number, email address, or
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`external to the document,
`wherein the specific type
`or types of second
`information is dependent
`at least in part on the type
`or types of the first
`information, and
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`1.
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`The Retrieved Definition or Other Information (“Second
`Information”) in Pandit Is Related to the Type of “First
`Information”
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`The Patent Owner rehashes its argument that “the dictionary search aris[ing]
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`in an embodiment in which the classes of information distinguished by the Pandit
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`program are nouns and verbs” is not a “search using at least part of the first
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`information as a search term in order to find the second information … wherein the
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`specific type or types of second information is dependent at least in part on the
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`type or types of the first information” because “the ‘type’ of information retrieved
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`is a definition and does not depend on the ‘type’ or class of information searched.”
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`(Response at 12; Preliminary Response (March 12, 2014), Paper No. 6 at 54-55.)
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`But the information that is retrieved is clearly based on the type of the information
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`searched. Specifically, Pandit “is capable of recognizing nouns or verbs.” (Ex.
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`1009, 3:11-16.) Based upon the recognition of the type of word, Pandit will
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`display different information, such as meaning, synonyms, singular and plural
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`versions of a noun, or conjugation of a verb.
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`It is unclear what the Patent Owner’s argument is relating to the address
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`book example of Pandit. (Response at 13.) To the extent the Patent Owner is
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`arguing that the type of Second Information in the address book example does not
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`depend on the type of First Information, Patent Owner is missing the point. For
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`example, a search for a person’s telephone number (First Information) in a
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`database would bring up address book information (Second Information) relating
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`to that person. The telephone number and address are types of information relating
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`to that person, and in order to bring up the address type of information, the search
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`would depend on the telephone number type of information of that person.
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`2.
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`Reliance on the Common Sense and Knowledge of One of
`Ordinary Skill in the Art Is Not Only Appropriate, It Is
`Necessary
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`The claims require “performing a search using at least part of the first
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`information as a search term in order to find the second information.” In the
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`address book example, Petitioners argue that, in order to avoid multiple entries of
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`the same address, it would have been a matter of common sense to one of ordinary
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`skill in the art that the first step in adding an entry to an address book would be to
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`search the address book to determine if that entry already exists with the entered
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`information, and display any associated information that is located. (Petition
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`(December 2, 2013), Paper No. 1 at 51.) The Board agreed, noting that:
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`Pandit teaches that, from pulled down-menu 20 (Fig. 1f), programs
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`that can be called may include a writeable computer database of
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`telephone and telefax numbers. Ex. 1009, col. 3, ll. 1-3. Dynamically
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`linked libraries may contain subroutines for implementing the
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`invention with respect to telephone and telefax numbers. Id. at col. 4,
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`ll. 20-31. It would be reasonable to presume, as a matter of common
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`sense, that the subroutine would search for duplicate telephone
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`numbers and, upon locating a duplicate entry, both the first
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`information and associated (or second) information, such as the name
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`and/or address associated with the telephone number, would be
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`displayed to the user. A person having a bound paper address book
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`would look first to determine if a potential new contact had been
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`entered previously. A computerized search for duplicate entries
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`would be a search “in order to find the second information, of a
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`specific type or types,” as claimed, in the same sense that the '843
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`patent’s search is in order to find the second information. As shown,
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`for example, in Figure 1 of the '843 patent, a name (first information)
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`can be searched for in a database (12), and more than one possible
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`contact or address (containing second information) may be found to
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`match with the first information (18). The first and the second
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`information are displayed to the user for user action (20). Searching a
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`database for a telephone number in Pandit’s system, and displaying
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`results, would be no different in substance from searching a database
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`for a name, and displaying results, in the disclosed example in the '843
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`patent. “What matters is the objective reach of the claim. If the claim
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`extends to what is obvious, it is invalid under § 103.” KSR Int’l Co. v.
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`Teleflex, Inc., 550 U.S. 398, 419 (2007).
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`(Decision at 17-18, emphasis added.) Undeterred, the Patent Owner now argues
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`that, “[a]s a matter of law, neither ‘common sense’ nor ‘basic knowledge’ can be
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`used to supply a missing claim limitation.” (Response at 14.) However, as
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`discussed below, the Patent Owner’s pronouncement that Hear-Wear “prohibits
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`the use of ‘common sense’ to compensate for a claim limitation that is missing
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`from the prior art” is simply wrong. In fact, it is entirely appropriate—and
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`necessary—and the Federal Circuit stated just that in Perfect Web, 587 F.3d 1324.
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`See, e.g., Response at 15. In Perfect Web, Perfect Web conceded that steps (A)-
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`(C) (of a four-step ((A)-(D)) method claim) were disclosed in prior art references,
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`but argued that common sense would not have taught step (D). Id. at 1327. Like
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`the Patent Owner here, Perfect Web contended “that common sense or knowledge
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`‘must be rooted in evidence and factual findings,’ because they play ‘the same role
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`as the inquiry into whether the prior art contains any teaching, suggestion or
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`motivation (‘TSM’) that would have led a person of ordinary skill to produce the
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`claimed invention.’” Id. at 1327-28. The Federal Circuit rejected that argument,
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`stating that, “while an analysis of obviousness always depends on evidence that
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`supports the required Graham factual findings, it also may include recourse to
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`logic, judgment, and common sense available to the person of ordinary skill that
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`do not necessarily require explication in any reference or expert opinion.” Id. at
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`1329 (emphasis added).
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`Moreover, the Patent Owner’s blanket assertion is fundamentally at odds
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`with the fact that obviousness may be found—as it is here—based upon a single
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`reference. Applying Patent Owner’s reasoning, obviousness could never be found
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`based upon a single reference because differences between the single reference and
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`the claimed invention would have to be supplied by “evidence” with respect to the
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`missing limitation, and could not be provided by the common sense and knowledge
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`of one of ordinary skill in the art. Effectively, obviousness based upon a single
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`reference would be eliminated, and would collapse into anticipation. That is not
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`the law. As stated in SIBIA Neurosciences, Inc. v. Cadus Pharmaceutical Corp.,
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`“a single prior art reference can render a claim obvious.” 225 F.3d 1349, 1356
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`(Fed. Cir. 2000). Moreover, “the motivation to modify a reference can come from
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`the knowledge of those skilled in the art, from the prior art reference itself, or from
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`the nature of the problem to be solved.” Id. Petitioners, and the Board, have relied
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`on the knowledge of those skilled in the art.
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`3.
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`The Patent Owner Misapplies Federal Circuit Law in
`Arguing that Common Sense Has No Role in the
`Obviousness Analysis
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`The Patent Owner reliance on Hear-Wear is misplaced. In Hear-Wear, the
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`majority affirmed the Board’s decision to decline to adopt requester HIMPP’s
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`obviousness contentions because “HIMPP failed to cite any evidence on the record
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`to support its contention that claims 3 and 9 of the '512 patent contained only
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`known prior art limitations.” 751 F.3d 1367 (emphasis added). In its Request for
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`Inter Partes Reexamination of the '512 patent, HIMPP argued that claims 3 and 9
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`of the '512 patent would have been obvious because “detachable connections were
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`known at the time of the alleged invention as concluded by the Examiner during
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`prosecution.” Id. at 1364 (emphasis added) (internal quotation marks omitted)
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`(citing pp. 138-40 of HIMPP’s Request for Inter Partes Reexamination). The
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`Examiner, during prosecution of the '512 reexamination, had found that “providing
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`a plurality of prongs for the electrical connections or for the plugs [(i.e., detachable
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`connections)] is known in the art.” Id. at 1363 (internal quotation marks and
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`citation omitted). The majority noted that HIMPP cannot rely on the Examiner’s
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`“basic knowledge and common sense as a replacement for documentary evidence
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`for core factual findings.” Id. at 1366. The Patent Owner’s assertion that Hear-
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`Wear “prohibits the use of ‘common sense’ to compensate for a claim limitation
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`that is missing from the prior art” is simply an incorrect statement of the law.
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`(Response at 14-16.) Furthermore, unlike the requesters in Hear-Wear, Petitioners
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`here did provide documentary evidence in the record (Exhibit 1002, the expert
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`declaration of Prof. Menascé), and the Board correctly considered Prof. Menascé’s
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`conclusions in its Institution Decision. (Decision at 17.)
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`The Patent Owner’s reliance on the Board’s decision in Eizo is similarly
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`misplaced. (Response at 16.) In Eizo, the Board correctly found that the
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`“Petitioner [has] not provide[d] sufficient evidence to support the argument that
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`spatial periods below one millimeter and above fifty millimeters are in accordance
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`with human perceptual limitations.” (2014 WL 3704253, at *9.) Indeed, the
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`petitioner in Eizo, unlike the Petitioners here, did not submit any expert declaration
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`in support of its petition, and relied solely on attorney argument “that spatial
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`periods below one millimeter and above fifty millimeters are in accordance with
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`human perceptual limitations.” Id.
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`The Federal Circuit just recently reiterated that “the obviousness inquiry ‘not
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`only permits, but requires, consideration of common knowledge and common
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`sense.’” I/P Engine, Inc. v. AOL Inc., No. 2013-1307, 2013-1313, 2014 U.S. App.
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`LEXIS 15667, at *17-18 (Fed. Cir. Aug. 15, 2014), citing DyStar Textilfarben
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`GmbH & Co. v. C.H. Patrick Co., 464 F.3d 1356, 1367 (Fed. Cir. 2006), which
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`was also cited with approval by the Supreme Court in KSR Int’l Co. v. Teleflex
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`Inc., 550 U.S. 398, 421-22 (2007). The court further stated that “the obviousness
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`inquiry must take account of the ‘routine steps’ that a person of ordinary skill in
`
`the art would employ.” 2014 U.S. App. LEXIS 15667, at *19 (citation omitted).
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`This is precisely what the Board did in its Institution Decision.
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`4.
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`Searching for Duplicates Is a Simple Method Known to a
`Person of Ordinary Skill in the Art
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`The Patent Owner’s complaint that Prof. Menascé “merely provide[d]
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`conclusory remarks” that it would be obvious to search for duplicates is not only
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`baseless, it is contradicted by the Patent Owner’s own expert.1 (Response at 17-18;
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`see also Ex. 1002 at ¶ 99.) Searching an address book for duplicates prior to
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`adding an entry is a simple method known to a person of ordinary skill in the art.
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`In fact, even Dr. Levy admitted that searching for duplicate entries was known in
`
`the art. (Levy Decl. ¶ 25 (“Some database programs conduct a search for
`
`duplicates by default, and others do not.”).) Indeed, the concept of avoiding
`
`duplicates in a database is based upon simple logic that would be employed by one
`
`of ordinary skill in the art. Furthermore, as the Board correctly recognized, the
`
`“dynamically linked libraries [in Pandit] may contain subroutines for implementing
`
`the invention with respect to telephone and telefax numbers [and i]t would be
`
`reasonable to presume, as a matter of common sense, that the subroutine would
`
`search for duplicate telephone numbers and, upon locating a duplicate entry, both
`
`the first information and associated (or second) information, such as the name
`
`and/or address associated with the telephone number, would be displayed to the
`
`user.” (Decision at 17.)
`
`
`1 In this case, Prof. Menascé noted that it would be common sense to search for
`
`duplicate entries prior to adding an entry into an address book. Even if he had not,
`
`in a context such as this that involves a simple search for duplicate entries, expert
`
`testimony would not be necessary. See supra Section II.A.2.
`
`
`la-1268066
`
`13
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`
`
`IPR2014-00208
`
`
`5.
`
`Docket No. 106842805200
`
`Searching For Duplicates Need Not Rely on the Use of a
`Name
`
`The Patent Owner argues that Petitioners fail “to meet the claim limitation of
`
`‘using at least part of the first information as a search term’” because the Petition
`
`equates the “first information” with a telephone number rather than a name.
`
`(Response at 28.) The Patent Owner relies on Dr. Levy’s assertion that searching
`
`for duplicates must rely on a name because using a “telephone number would not
`
`be an effective method of identifying duplicate records,” as “many individuals,
`
`such as employees at a company, may have a shared telephone number.” (Levy
`
`Decl. ¶ 27; Response at 26-27.) However, a search of common names (e.g., John
`
`Smith) may also turn up numerous duplicate records. Moreover, the claims do not
`
`require searching using a term that will provide the “most effective method.”
`
`Importantly, by requiring a “template or similar mechanism” to appear in order for
`
`the user to enter a name (Response at 25; Levy Decl. ¶ 21), the Patent Owner
`
`misses the point of Pandit, which is that it “selectively recognizes text [in a
`
`document] and performs relevant operations based on the recognition.” (Ex.
`
`1009, 2:4-5, emphasis added.) Notably, Pandit also discloses that “names, street
`
`addresses, etc.” can be used for the operations. (Id. at 2:24-31.)
`
`
`la-1268066
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`14
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`
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`IPR2014-00208
`
`III. CONCLUSION
`
`Docket No. 106842805200
`
`For the foregoing reasons, as well as those set forth in their Petition,
`
`Petitioners respectfully request cancellation of claims 1-2, 8, 14-17, 20-21, 23-24,
`
`
`By /s/ David L. Fehrman
`David L. Fehrman, Reg. No.: 28,600
`Mehran Arjomand, Reg. No.: 48,231
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, California 90017-3543
`Tel: (213) 892-5200
`
`30, 36-39, and 42-43 of the '843 patent.
`
`
`
`Dated: November 11, 2014
`
`
`
`
`la-1268066
`
`15
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`
`
`IPR2014-00208
`
`
`
`
`
`
`Docket No. 106842805200
`
`Certificate of Service (37 C.F.R. § 42.6(e)(4))
`
`I hereby certify that the attached Petitioners’ Reply to Patent Owner’s
`
`Response was served on the below date on the Patent Owner via email (by
`
`consent) to the following counsel of record for the Patent Owner:
`
`SUNSTEIN KANN MURPHY & TIMBERS LLP
`125 SUMMER STREET
`BOSTON, MA 02110-1618
`
`
`by transmitting the documents to the attorneys’ email addresses at:
`
`RAsher@sunsteinlaw.com,
`BSunstein@sunsteinlaw.com,
`JStickevers@sunsteinlaw.com, and
`DWu@sunsteinlaw.com.
`
`
`
`Dated: November 11, 2014
`
`
`
`
`/s/ David L. Fehrman
` David L. Fehrman
`
`
`
`
`
`
`la-1268066
`
`16
`
`
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