Ex Parte Vogtmeier et alDownload PDFPatent Trial and Appeal BoardMay 25, 201612990814 (P.T.A.B. May. 25, 2016) Copy Citation UNITED STA TES p A TENT AND TRADEMARK OFFICE APPLICATION NO. FILING DATE FIRST NAMED INVENTOR 12/990,814 11/03/2010 Gereon Vogtmeier 24737 7590 05/27/2016 PHILIPS INTELLECTUAL PROPERTY & STANDARDS 465 Columbus A venue Suite 340 Valhalla, NY 10595 UNITED STATES DEPARTMENT OF COMMERCE United States Patent and Trademark Office Address: COMMISSIONER FOR PATENTS P.O. Box 1450 Alexandria, Virginia 22313-1450 www .uspto.gov ATTORNEY DOCKET NO. CONFIRMATION NO. 2008P00199WOUS 3515 EXAMINER MIDKIFF, ANASTASIA ART UNIT PAPER NUMBER 2884 NOTIFICATION DATE DELIVERY MODE 05/27/2016 ELECTRONIC Please find below and/or attached an Office communication concerning this application or proceeding. The time period for reply, if any, is set in the attached communication. Notice of the Office communication was sent electronically on above-indicated "Notification Date" to the following e-mail address( es): marianne.fox@philips.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE PA TENT TRIAL AND APPEAL BOARD Exparte GEREON VOGTMEIER, 1 Rainer Pietig, Astrid Lewalter, and Rolf Karl Otto Behling Appeal2014-007448 Application 12/990,814 Technology Center 2800 Before MARK NAGUMO, KAREN M. HASTINGS, and CHRISTOPHER L. OGDEN, Administrative Patent Judges. NAGUMO, Administrative Patent Judge. DECISION ON APPEAL Gereon Vogtmeier, Rainer Pietig, Astrid Lewalter, and Rolf Karl Otto Behling ("Vogtmeier") timely appeal under 35 U.S.C. § 134(a) from the Final Rej ection2 of claims 1, 2, and 5-10. 3 We have jurisdiction. 35 U.S.C. § 6. We affirm-in-part. 1 The real party in interest is identified as Koninklijke Philips Electronics N.V. (Appeal Brief, filed 10 December 2013 ("Br."), 3.) 2 Office action mailed 18 October 2013 ("Final Rejection"; cited as "FR"). An Advisory Action was mailed 21November2013 ("Adv.") Appeal2014-007448 Application 12/990,814 A. Introduction4 OPINION The subject matter on appeal relates to an X-ray scanner system said to have improved heat dissipation characteristics of the anode. The Specification teaches that X-rays are generated by an X-ray tube comprising a cathode and an anode with a high voltage potential, on the order of 40 kV to 160 kV applied between the two, which are held in a vacuum. (Spec. 1, 1. 25, to 2, 1. 3.) The Specification explains that electrons flow from the cathode to the anode, where they impinge "on a small area or focal spot with sufficient energy to generate X-rays." (Id. at 11. 3--4.) The small focal spot is required to obtain high spatial resolution in an imaging system. (Id. at 11. 7-8.) It is also desirable to perform a full CT scan of a moving system, for example, of a human heart, within the time span during the heart cycle when the heart muscle is at rest (less than 100 ms). (Id. at 3, 11. 17- 22.) Thus, high peak power is required for such high-resolution time- resolved imaging. However, the conversion efficiency to X-rays is said to be, at a maximum, only 1-2%, the rest of the power being converted into heat. (Id. at 2, 11. 8-10.) In the words of the '814 Specification, "[e]fficient 3 Copending claims 3 and 4 have been objected to by the Examiner (FR 1, § 8), and remaining copending claims 11-20 have been indicated to be allowable (id. at§ 6); these claims are not before us. 4 Application 12/990,814, X-ray system with efficient anode heat dissipation, filed 3 November 2010, under 35 U.S.C. § 371 as the national stage of PCT/IB09/51814, which was filed 4 May 2009, claiming the benefit of a European application filed 9 May 2008. We refer to the '" 814 Specification," which we cite as "Spec." 2 Appeal2014-007448 Application 12/990,814 heat dissipation thus represents one of the greatest challenges faced in the development of current high power X-ray sources." (Id. at 11. 14-15.) The inventors seek patent protection for an X-ray scanner that addresses these problems by providing an array of X-ray sources that are "spatially distributed" and that can be turned off and on in a programmable sequence. Each source comprises a specified anode and an integrated actuator that moves the anode relative to a stationary electron-beam emitting cathode. Vogtmeier (Br. 3, 11. 20-23) identifies5 the embodiment illustrated in Fig. 7a, reproduced below, as an example of an "array" of X-ray sources. 207 f 700a i .·-"' _,-201b --210b {Fig. 7a shows X-rays 208 from tubes 210 with actuators 206 that move focal spots of electron beams 2026 } 5 V ogtmeier cites the printed publication of the '814 Specification, US201 l/0051895 Al (3 March 2011) ,-i [0060], which in tum refers to Fig 7a. We cite the Specification as filed, which is part of the official record. 3 Appeal2014-007448 Application 12/990,814 As shown, X-ray tubes 210 comprise cathodes 201 and anodes 204. (Spec. 16, 11. 10-14.) Actuators 206a' and 206b' induce translational displacements of the focal spots of the electrons in a direction parallel to the anodes' rotary shafts 209 relative to fixed mounting plate 207. (Id. at 11. 15- 19.) Deflecting means 211 compensate for the translational displacement movement of the anodes (id. at 11. 19-22) by keeping constant the position of the focal spot relative to the location of the detector irradiated by the X-ray beam from the anode (id. at 17, 11. 1--4). Second actuators 206a and 206b allow for a shift of the X-ray tubes along lines of displacement 212a and 212b along the anodes during scanning. (Id. at 11. 27-29.) Sole independent claim 1 is representative of the dispositive issues and reads: An X-ray scanner system comprising an array of spatially distributed, sequentially switchable X-ray sources, said X-ray sources being addressed by a programmable switching sequence with a given switching frequency, wherein each X-ray source comprises an anode with a planar X-radiation emitting surface inclined by an acute angle with respect to a plane normal to the direction of an incoming electron beam impinging on said anode at the position of a focal spot and at least one integrated actuator unit for performing at least one translational and/ or rotational displacement movement 6 Throughout this Opinion, for clarity, labels to elements are presented in bold font, regardless of their presentation in the original document. 4 Appeal2014-007448 Application 12/990,814 of the anode relative to at least one stationary electron beam emitting cathode used for generating said electron beam. (Claims App., Br. 18; some indentation, paragraphing, and emphasis added.) The Examiner maintains the following ground of rejection7 : Claims 1, 2, and 5-10 stand rejected under 35 U.S.C. § 103(a) in view of the combined teachings of Hell8 and Price.9 B. Discussion Findings of fact throughout this Opinion are supported by a preponderance of the evidence of record. V ogtmeier presents arguments for the patentability of claim 1, with which claims 2, 9, and 10 stand or fall. We address the additional arguments for the patentability of claims 5-8 separately. Ia V ogtmeier first urges the Examiner erred harmfully in finding that Price describes an array of spatially distributed X-ray sources, each of which has an anode and an integrated actuator unit. (Br. 6, 1. 21, to 7, 1. 10.) The Examiner holds that "[t]he language of the claims does not require a separate anode for each emitter in order to realize separate sources of x-rays." (Adv. 2, last para.) The Examiner explains that "[a]t each point 7 Examiner's Answer mailed 24 April 2014 ("Ans."). 8 Erich Hell et al., X-ray tube with a low-temperature emitter, U.S. Patent No. 5,703,924 (1997). 9 J. Scott Price et al., X-ray source and method having cathode with curved emission surface, U.S. Patent Application Publication 2003/0198318 Al (2003) (issued as U.S. Patent No. 6,760,407 on 6 July 2004). 5 Appeal2014-007448 Application 12/990,814 on the shared anode that an electron beam from one of the array of emitters strikes, a separate source of x-rays exists (i.e., a separate focal spot creating a separate x-ray beam." (Id.) The Examiner's interpretation, in effect, equates any region of an anode that is struck by electrons resulting in the generation of X-rays to the term "X-ray source." In contrast, Vogtmeier, in effect, urges that the term "X-ray source" refers to the apparatus that produces x-rays, and that each X-ray source is a completely separate device that has its own anode and its own integrated actuator unit. Thus, Vogtmeier argues, "Appellant fails to see, for example, how the focal spots on the Hell/Price 'shared anode' each comprise ' ... at least one integrated actuating unit. ... "' (Br. 7, 11. 16-17.) V ogtmeier argues further, [i]t is also unclear how each "separate" anode, presumably a very thin plate, maintains its structural integrity during operation, independently of any adjacent "separate" anode .... If the incident surface 22 is, instead, many "separate" incident surfaces, it is unclear if the "separate" angles of the surfaces are maintained exactly equal during operation, if not for the fact that the anode 7 is, in reality, an integral, structural whole. (Id. at 8, 11. 1-8; emphasis added.) The language of claim 1 appears in the body of the original Specification at page 4, lines 17-26, and in original claim 1. 10 The only 10 Original claim 1 also includes references to items listed in the Table at pages 20-26 of the Specification; these references were deleted by the preliminary amendment filed 3 November 2010, upon entry to the national stage. 6 Appeal2014-007448 Application 12/990,814 other references to an array of X-ray sources appears in the abstract and at page 1, which reads in most relevant part, [t]he present invention refers to X-ray systems for use in high-resolution imaging applications with an improved power rating and, more particularly, to a variety of system configurations for an X-ray based image acquisition system using an X-ray source of the rotary anode type or, alternatively, an array of spatially distributed X-ray sources fabricated in carbon nanotube (CNT) technology, thus allowing higher sampling rates for an improved temporal resolution of acquired CT images as needed for an exact reconstruction of fast moving objects. (Spec. 1, 11. 6-12; emphasis added.) Notably, in this passage, the array of spatially distributed X-ray sources is described as an alternative to a rotary anode-type X-ray source. This emphasizes the status of the "array" illustrated in Fig. 7a, reproduced supra, as merely one example of an array of X-ray sources. V ogtmeier does not direct our attention, however, to any disclosure in the Specification, or to any disclosure in the prior art of record, that demonstrates that the term "X-ray source" has acquired the exclusive meaning of a device such that an array of X-ray sources would necessarily have physically separate anodes, each with its own separate integrated actuator unit. Nor has V ogtmeier shown error in the Examiner's finding that Price teaches that X-rays may be produced at spatially distinct sites on an X-ray anode. Put another way, Vogtmeier has not demonstrated harmful error in the Examiner's findings (FR 3, 11. 4-9) that Price describes an X-ray source that comprises spatially distributed, addressable positions on an anode that may 7 Appeal2014-007448 Application 12/990,814 be targeted by beams of electrons. In particular, Price teaches that control signals may be sent "to the cathode 79 to separately energize multiple groups of the emitters 84 (which may be overlapping)." (Price, 4 [0042].) 11 Price teaches further that the signals to the cathode 79 may be controlled "so as to cause the focal spot [on the anode] to wobble back and forth between multiple positions." (Price 4 [0044].) Thus, it appears that distinct locations on the anode may be stimulated to emit X-rays. Again, Vogtmeier has not directed our attention to a definition in the record of the term "X-ray source" that excludes the X-ray sources described by Price. Absent a clear definition of the terms "array of ... X-ray sources" or "X-ray source" that requires each X-ray source to have, for example, a separate housing, the express requirements of the X-ray sources required by claim 1 are met by Price. Each source comprises an anode that V ogtmeier has not disputed meets the angular orientation requirements recited in claim 1, and each has an actuator integrated with the anode. In accordance with settled law, and with the instructions of the '814 Specification itself, 12 we shall not read limitations from preferred embodiments into the claims. We are not persuaded of harmful error in the Examiner's interpretations of the terms "X-ray source" or "array of X-ray sources," or the Examiner's findings that Price describes an array of X-ray sources within the scope of those terms, properly understood. 11 The Examiner cites Price [0033]-[0039], and [0042]-[0045] at FR 3. 12 The Specification instructs that "such illustration and description are to be considered illustrative or exemplary and not restrictive." (Spec. 19, 11. 5-6.) 8 Appeal2014-007448 Application 12/990,814 lb Vogtmeier' s second major argument is that modifying Hell in view of Price would change the X-ray tube described by Hell in a way that would not retain the rotationally-symmetric W ehnelt electrode and the W ehnelt voltage Uw. According to Vogtmeier, these features are required to achieve a laminar electron beam profile to create an omni-directional Gaussian-like distribution of X-ray intensities at the focal spot. (Br. 10, 11. 9-14, citing Hell, col. 3, 11. 50-53, and col. 4, 11. 12-16and11. 26--41.) Hell describes an X-ray tube in which a circular electron beam ES is emitted by cathode arrangement 3, as illustrated in Fig. 2, shown below. 29a FIG 2 {Hell Fig. 2 shows an X-ray tube with actuators 26, 27 at cathode 3, focussing electrode 19, aperture 20, and focus spot BF on anode 7} Cathode arrangement 3 comprises circular disk-shaped glow electrode 5 that is attached via ceramic disk 6 to W ehnelt electrode 4. (Hell, col. 2, 11. 49-56.) An electron beam ES emanates from glow 9 Appeal2014-007448 Application 12/990,814 cathode 5 and is focused by focusing electrode 19 through an apertured diaphram 20, held at the anode potential, onto anode 7 at an angle a to the surface normal N of the anode. (Id. at col. 3, 11. 7-21.) The useful X-ray beam ZS, which is said to have a substantially circular focus beneficial for a high imaging quality, is emitted at an angle substantially equal to the angle a and exits out window 23. (Id. at 11. 21-24, and col. 4, 11. 5-11.) Hell teaches that ions as well as X-rays are emitted by the anode, and that diaphram 20, with aperture A, shields the cathode from most of the emitted ions, thereby increasing the useful working life of the cathode. (Hell, col. 2, 11. 5-16.) In particular, Vogtmeier urges that it is "unclear ... how each Price emitter 84 could be configured for emitting a beam of circular cross-section, given the apparently rectangular gaps in the gate film 92." (Br. 9, 11. 15-17, citing Price, Fig. 6.) However, as the Examiner finds (Ans. 8, 1st bullet, last sentence, citing Price [0034]), Price teaches expressly that various beam profiles may be obtained, including circular profiles. Vogtmeier appears to have overlooked Price's teachings that multiple groups of emitters 84 can be controlled separately to form electron beams having various focal spots with various shapes. (Price 4 [0042].) Thus, the reference to Price Fig. 6, showing individual cathode emitters in cross section, is not persuasive as to the beam shape (nor is it clear that the cross-section shows rectangular openings, as the openings could be circular, or any other shape). 10 Appeal2014-007448 Application 12/990,814 Vogtmeier argues next that each emitter 84 would have to have its own respective through-circular opening. (Br. 9, 11. 18-19, citing Hell, col. 2, 1. 27.) Otherwise, according to Vogtmeier, the opening would be non-optimal for another emitter (Br. 10, 11. 3--4), or wider, and therefore less protective of the electron-emitting cathode (id. at ll. 5-8). These arguments are not persuasive because they appear to be based on the misapprehension that individual emiters 84, rather than groups or arrays of individual emitters, are the basis of the electron beams that excite X-rays when they strike the anode. Moreover, these arguments are not supported by probative citations to evidence of record. We decline to credit such arguments. In re Pearson, 494 F .2d 1399, 1405 (CCPA 1974) ("Attorney's argument in a brief cannot take the place of evidence.") Vogtmeier also urges that it is unclear how Hell can achieve an omni-directional Gaussian-like distribution of X-ray intensities in the focal spot. (Br. 10, 11. 9-14.) This argument is not persuasive in view of Price's disclosure in Fig. 9 of Gaussian distribution 114, said to be achievable with the disclosed cathode 79. (Price 4 [0040]; references to Fig. 8 are clear typographical errors.) We are unable to find any basis for Vogtmeier' s presumption (Br. 10, 11. 15-1 7) that the Examiner proposes to eliminate the Hell diaphram. (Cf Ans., para. bridging 8-9, denying such a proposal.) 11 Appeal2014-007448 Application 12/990,814 Vogtmeier argues that the Examiner's proposal to use the carbon nanotube ("CNT") emitter cathodes described by Price is contrary to Hell's requirement that the electron emitter have a low electron affinity compared to tungsten, which is the usual cathode emitter material. (Br. 11, ll. 3-8.) As the Examiner explains, however, the primary purpose behind the low electron affinity requirement is to lower the temperature of the emitter. (Ans. 9-10; cf Hell, col. 2, 11. 29-33, recommending specific materials for low temperature emitters.) Price is directed to cold cathode X-ray sources, so the desired lower temperature aspect is fulfilled by another mechanism. Thus, the proposed substitution does not give rise to a fundamental inconsistency that would change the principle of operation of Hell. Vogtmeier devotes the Reply13 to reiterated arguments regarding the perceived defects of the rejection of claim 1. As these arguments are based on the same assumption regarding the nature of the X-ray source and the resulting "array of ... X-ray sources" we have found erroneous, we find them unpersuasive of harmful error. We affirm the rejection of claim 1. 13 Reply Brief, filed 24 June 2014 ("Reply"). 12 Appeal2014-007448 Application 12/990,814 II Vogmeier presents separate arguments for the patentability of claims 5-8, each of which depends from claim 1, only in the principal Brief. (Br. 12-16.) Claim 5 requires, in addition to a focusing unit for adjusting the electron beam on the anode, that there be "a focusing control unit for adjusting the focusing of the anode's focal spot such that deviations in the focal spot size resulting from the translational and/ or rotational displacement of the anode relative to the at least one stationary electron beam emitting cathode are compensated." (Claims App., Br. 19.) The Examiner finds that focusing unit 19 and 20 described by Hell at column 3, lines 11-20, meets the first focusing unit, and that Hell describes the second requirements at column 3, line 66, to column 4, line 36. (FR, para. bridging 3-4.) The latter passage, however, merely describes the usually desired dimensions of the focal spot and the range of diameters of electron beam ES, and the absence of electric fields that can distort the cross section of the beam due to the presence of apertured diaphram 20, which is held at the anode potential. As Vogtmeier argues (Br. 12-13), the Examiner has not explained how this passage teaches or suggests that deviations in spot size resulting from displacements of the anode relative to the cathode are compensated. We reverse the rejection of claim 5. 13 Appeal2014-007448 Application 12/990,814 Claim 6 requires that "the anode's translational displacement movement goes along a rectilinear displacement line in the direction of the anode's inclination angle." (Claims App., Br. 19.) The Examiner finds, without elaboration in the Final Rejection, that this is described by Hell at column 5, lines 10-67. (FR 4.)14 Vogtmeier argues that Hell describes, at column 5, lines 29-40, that piezoelectric translators 26 and 27 are driven in the same direction, resulting in electron beam ES moving "as can be imagined from Hell, Fig. 2, in a parallel manner with no change in angle." (Br. 13, 11. 18- 20.) For future reference, we call this movement "parallel movement." Vogmeier notes that when the actuators are driven in opposite directions, "the angle of the beam ES changes due to tilting." (Id. at 1. 20; cf Hell, col. 5, 11. 37--40.) For future reference, we call this movement "angular movement." Vogtmeier invites us to compare the disclosures in the '814 Specification, paragraphs [ 181 ], i.e., Spec. 24, 11. 1-2 (definition of rectilinear displacement line 212a15);and [060], the 14 In the Answer, the Examiner explains that there are sufficient adjustment capabilities in the apparatus described by Hell at column 5, lines 10--40, that, "within said range of movements, there exists a combination of movement that would naturally encompass a movement in the direction of the anode inclination, even though this specific movement is not discussed by Hell." (Ans. 12, 11. 8-14.) The Examiner concludes that "the apparatus of Hell is capable of fulfilling the function of the claims as written." (Id. at 11. 14-15.) As Vogtmeier does not address this clarification in the Reply, further argument on this point has been waived. 15 212a: "rectilinear displacement line ('line of mechanical displacement') running in the direction of the inclination angle of anode 204a. '" 14 Appeal2014-007448 Application 12/990,814 description of Fig. 7a at Spec. 16, 1. 10, to 17, 1. 1. 4. Vogtmeier concludes that Hell does not describe or suggest the displacement of the anode required by claim 6. Consideration of Hell, Fig. 2, indicates that as a result of either parallal or angular movement, the displacement of the electron beam due to motion of the cathode induced by the actuators is in the same plane, i.e., the plane defined by the rays ES and ZS. The displacement of the electron beam occurs, by symmetry, in the intersection of the ES:ZS plane with the planar surface of the anode. That line, appears to be, in the words of claim 6, "in the direction of the anode's inclination angle." It is clear that the Examiner has determined, based on Hell's teaching that "[i]t is also possible, however, to allocate the adjustment unit to the rotating anode 7, and thus to effect the desired relative motion [of electron beam ES] by adjusting only the rotating anode 7" (Hell, col. 6, 11. 10-13), that the same directions of motion of electron beam ES relative to the anode surface could be obtained by adjusting the anode. Vogtmeier has not shown error in the Examiner's assumptions and the conclusions that follow. We therefore affirm the rejection of claim 6. Claim 7 requires that the integrated actuator, under its control unit, controls the relative orientation of the anode to the cathode "such that the X-ray beam emitted by the anode leads to the same X-ray beam 15 Appeal2014-007448 Application 12/990,814 direction and thus to the same field of view irrespective of the anode's inclination angle and irrespective of said displacement movement." (Claims App., Br. 19.) The Examiner finds, again without elaboration in the Final Rejection, that these features are described or suggested by Hell at column 5, lines 10-67. (FR 4.) Vogtmeier argues that the two types of movement (i.e., parallel and angular) "would not result in' ... the same X-ray beam direction and thus to the same field of view ... "' as required by claim 7. (Br. 15, 11. 9-10.) In the Answer, the Examiner finds that [ t ]he apparatus of Hell is capable of changing the distance of the cathode to the anode without changing the angle of impact of the cathode beam upon a specific focal spot of the anode by, for example, only changing the distance, via the control unit, between the cathode and anode in a single direction. Consequently, the apparatus of Hell is capable of fulfilling the function of the claims as written. (Ans. 13, 1. 20, to 14, 1. 2.) The weight of the evidence favors Vogtmeier on this point. We find no substantial evidence supporting the more detailed findings set out in the Answer. As with the compensatory adjustments recited in claim 5, we conclude that Vogtmeier has demonstrated harmful error in the rejection of claim 7. Accordingly, we reverse the rejection of claim 7. 16 Appeal2014-007448 Application 12/990,814 Claim 8 requires that "the size of the anodes' s translational and/or rotational displacement movement is in the range of the focal spot size or larger." (Claims App., Br. 19.) Vogtmeier argues that the range of translator movement are "within the adjustment limits of the piezoelectric translators 26 and 27 ," and that there is no disclosure or suggestion that such movements are in the range of the size of the focal spot or larger. (Br. 16, 11. 9-13.) The shift from moving the cathode to moving the anode, Vogtmeier urges, "cannot cure this deficiency in Hell/Price." (Id. at ll. 14-15.) The Examiner (FR 4, 11. 14-16) finds that Hell teaches that translators 26 and 27 together make it possible "to adjust the alignment of the cathode arrangement 3 and the rotating anode 7 relative to one another such that the focal spot BF assumes the position desired" (Hell, col. 5, 11. 40--46). The Examiner finds that this teaches the required magnitude of anode displacement. In the Answer, the Examiner explains that the size of the full 360 degree rotations of the anode "would naturally and easily be greater than the small focal spot (BF) on the anode." (Ans. 14, 11. 15-17.) The Examiner reasons further that "[t]he translational movements of the actuators having a magnitude great enough to cause the changes in beam direction as discussed in Column 5, lines 10-67, which again, would naturally be larger than the small focal spot size." (Id. at 11. 17-19.) 17 Appeal2014-007448 Application 12/990,814 From this discussion, it appears that the Examiner has conflated the rotory motion of a rotary anode with the motion induced by the actuator required by claim 1, which claim 8 further limits. Moreover, the Examiner appears to have conflated the motion of the beam with the motion of the anode. A small change in relative orientation of the cathode relative to the anode can result in a relatively large motion of the electron beam at the anode. The Examiner has not shown, however, that the motion induced by piezoelectric transducers 26 and 27 when attached to the anode would have been expected to result in a motion of the anode of the same size or larger than the spot size of the focused electron beam. We therefore reverse the rejection of claim 8. C. Order It is ORDERED that the rejection of claims 1, 2, 6, 9, and 10 is AFFIRMED. It is FURTHER ORDERED that the rejection of claims 5, 7, and 8 is REVERSED. No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § l.136(a). AFFIRMED-IN-PART 18 Copy with citationCopy as parenthetical citation