Avaya Inc.Download PDFPatent Trials and Appeals BoardSep 16, 202014752854 - (D) (P.T.A.B. Sep. 16, 2020) Copy Citation UNITED STATES PATENT AND TRADEMARK OFFICE 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 APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO. 14/752,854 06/27/2015 William Meaney 415077-US- NP/AVA125PA 2679 136582 7590 09/16/2020 STEVENS & SHOWALTER, LLP Box AVAYA Inc. 7019 Corporate Way Dayton, OH 45459-4238 EXAMINER MEINECKE DIAZ, SUSANNA M ART UNIT PAPER NUMBER 3683 NOTIFICATION DATE DELIVERY MODE 09/16/2020 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): pair_avaya@firsttofile.com pto@sspatlaw.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ________________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ________________ Ex parte WILLIAM MEANEY, DARA GEARY, ADRIAN RYAN, and EDEL KELLY ________________ Appeal 2020-001260 Application 14/752,854 Technology Center 3600 ________________ Before JUSTIN BUSCH, JASON J. CHUNG, and JOYCE CRAIG, Administrative Patent Judges. CHUNG, Administrative Patent Judge. DECISION ON APPEAL Pursuant to 35 U.S.C. § 134(a), Appellant1 appeals the Final Rejection of claims 1–6, 8–14, and 16–19.2 We have jurisdiction under 35 U.S.C. § 6(b). We AFFIRM. INVENTION The invention relates to providing notifications to resources to manage communication sessions in an enterprise. Spec. ¶ 2. Claim 1 is illustrative of the invention and is reproduced below: 1 We use the word “Appellant” to refer to “applicant” as defined in 37 C.F.R. § 1.42. According to Appellant, Avaya, Inc. is the real party in interest. Appeal Br. 4. 2 Claims 7, 15, and 20–23 are cancelled. Appeal Br. 29–31. Appeal 2020-001260 Application 14/752,854 2 1. A computing system to manage a communication session in an enterprise, the system comprising: a memory device storing executable code; and a processor in communication with the memory device, wherein the executable code, when executed by the processor, causes the processor to: receive a subscription request from an agent of the enterprise, wherein the subscription request comprises subscription criteria indicating parameters of communication sessions which the agent of the enterprise is interested in and a time when the agent of the enterprise is unavailable to manage communication sessions; monitor the communication session to generate a data metric about the communication session based on the parameters of the subscription criteria; analyze the generated data metric to generate a subscription report about the communication session; determine if the agent is unavailable to manage the communication session; determine if the agent is subscribed to real-time notifications; generate the notification for the agent of the enterprise based on the generated subscription report if the agent is unavailable to manage the communication session and if the agent is subscribed to receive real-time notifications; and transmit the generated notification to the agent of the enterprise. Appeal Br. 28 (Claims Appendix) (emphases added). REJECTIONS The Examiner rejects claims 1–6, 8–14, and 16–19 under 35 U.S.C. § 101 as being directed to patent ineligible subject matter. Final Act. 4–5. The Examiner rejects claims 1–6, 8–14, and 16–19 under 35 U.S.C. § 103(a) as being unpatentable over the combination of Dwyer (US Appeal 2020-001260 Application 14/752,854 3 2015/0195406 A1; filed Jan. 8, 2015) and Somasundaram (US 2013/0147623 A1; published June 13, 2013). Final Act. 5–11. ANALYSIS I. Claims 1–6, 8–14, and 16–19 Rejected Under 35 U.S.C. § 101 A. Principles of Law An invention is patent-eligible if it claims a “new and useful process, machine, manufacture, or composition of matter.” 35 U.S.C. § 101. However, the U.S. Supreme Court has long interpreted 35 U.S.C. § 101 to include implicit exceptions: “[l]aws of nature, natural phenomena, and abstract ideas” are not patentable. E.g., Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014). In determining whether a claim falls within an excluded category, we are guided by the Court’s two-part framework, described in Mayo and Alice. Id. at 217–18 (citing Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 75–77 (2012)). In accordance with that framework, we first determine what concept the claim is “directed to.” See Alice, 573 U.S. at 219 (“On their face, the claims before us are drawn to the concept of intermediated settlement, i.e., the use of a third party to mitigate settlement risk.”); see also Bilski v. Kappos, 561 U.S. 593, 611 (2010) (“Claims 1 and 4 in petitioners’ application explain the basic concept of hedging, or protecting against risk.”). Concepts determined to be abstract ideas, and thus patent ineligible, include certain methods of organizing human activity, such as fundamental economic practices (Alice, 573 U.S. at 219–20; Bilski, 561 U.S. at 611); mathematical formulas (Parker v. Flook, 437 U.S. 584, 594–95 (1978)); and Appeal 2020-001260 Application 14/752,854 4 mental processes (Gottschalk v. Benson, 409 U.S. 63, 67 (1972)). Concepts determined to be patent eligible include physical and chemical processes, such as “molding rubber products” (Diamond v. Diehr, 450 U.S. 175, 191 (1981)); “tanning, dyeing, making waterproof cloth, vulcanizing India rubber, smelting ores” (id. at 182 n.7 (quoting Corning v. Burden, 56 U.S. 252, 267–68 (1853))); and manufacturing flour (Benson, 409 U.S. at 69 (citing Cochrane v. Deener, 94 U.S. 780, 785 (1876))). In Diehr, the claim at issue recited a mathematical formula, but the Court held that “a claim drawn to subject matter otherwise statutory does not become nonstatutory simply because it uses a mathematical formula.” Diehr, 450 U.S. at 187; see also id. at 191 (“We view respondents’ claims as nothing more than a process for molding rubber products and not as an attempt to patent a mathematical formula.”). Having said that, the Court also indicated that a claim “seeking patent protection for that formula in the abstract . . . is not accorded the protection of our patent laws, and this principle cannot be circumvented by attempting to limit the use of the formula to a particular technological environment.” Id. (citation omitted) (citing Benson and Flook); see, e.g., id. at 187 (“It is now commonplace that an application of a law of nature or mathematical formula to a known structure or process may well be deserving of patent protection.”). If the claim is “directed to” an abstract idea, we turn to the second step of the Alice and Mayo framework, where “we must examine the elements of the claim to determine whether it contains an ‘inventive concept’ sufficient to ‘transform’ the claimed abstract idea into a patent- eligible application.” Alice, 573 U.S. at 221 (quotation marks omitted). “A claim that recites an abstract idea must include ‘additional features’ to Appeal 2020-001260 Application 14/752,854 5 ensure ‘that the [claim] is more than a drafting effort designed to monopolize the [abstract idea].’” Id. (alterations in original) (quoting Mayo, 566 U.S. at 77). “[M]erely requir[ing] generic computer implementation[] fail[s] to transform that abstract idea into a patent-eligible invention.” Id. B. USPTO Section 101 Guidance In January 2019, the U.S. Patent and Trademark Office (USPTO) published revised guidance on the application of § 101. 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“2019 Revised Guidance”).3 “All USPTO personnel are, as a matter of internal agency management, expected to follow the guidance.” Id. at 51; see also Update at 1. Under the 2019 Revised Guidance and the Update, we first look to whether the claim recites: (1) any judicial exceptions, including certain groupings of abstract ideas (i.e., mathematical concepts, certain methods of organizing human activity such as a fundamental economic practice, or mental processes) (“Step 2A, Prong One”); and (2) additional elements that integrate the judicial exception into a practical application (see MPEP § 2106.05(a)–(c), (e)–(h) (9th ed. Rev. 08.2017, Jan. 2018)) (“Step 2A, Prong Two”).4 3 In response to received public comments, the Office issued further guidance on October 17, 2019, clarifying the 2019 Revised Guidance. USPTO, October 2019 Update: Subject Matter Eligibility (the “Update”) (available at https://www.uspto.gov/sites/default/files/documents/ peg_oct_2019_update.pdf). 4 This evaluation is performed by (a) identifying whether there are any additional elements recited in the claim beyond the judicial exception, and (b) evaluating those additional elements individually and in combination to Appeal 2020-001260 Application 14/752,854 6 2019 Revised Guidance, 84 Fed. Reg. at 52–55. Only if a claim (1) recites a judicial exception and (2) does not integrate that exception into a practical application, do we then look, under Step 2B, to whether the claim: (3) adds a specific limitation beyond the judicial exception that is not “well-understood, routine, conventional” in the field (see MPEP § 2106.05(d)); or (4) simply appends well-understood, routine, conventional activities previously known to the industry, specified at a high level of generality, to the judicial exception. 2019 Revised Guidance, 84 Fed. Reg. at 52–56. C. The Examiner’s Rejection and Appellant’s Arguments The Examiner concludes the present claims recite certain methods of organizing human activity. Final Act. 4. The Examiner concludes the present claims are not integrated into a practical application and there are no limitations recited in the present claims that add significantly more to the abstract idea. Id. (citing Spec. ¶ 102); Ans. 13–14 (citing Spec. ¶ 102; In re TLI Commc’ns LLC Patent Litig., 823 F.3d 607, 610 (Fed. Cir. 2016); OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359 (Fed. Cir. 2015); buySAFE, Inc. v. Google, Inc., 765 F.3d 1350 (Fed. Cir. 2014)). Appellant argues that, although the present claims recite an abstract idea, each element of the present claims does not recite an abstract idea and, therefore, the present claims as a whole are not directed to an abstract idea. determine whether the claim as a whole integrates the exception into a practical application. See 2019 Revised Guidance - Section III(A)(2), 84 Fed. Reg. 54–55. Appeal 2020-001260 Application 14/752,854 7 Appeal Br. 17–18. Appellant argues the present claims are similar to the patent eligible claims of Example 42 of the USPTO 2019 Examples because the present claims include converting the communication session (regardless of a format of the communication session) to a data metric that is used when generating a subscription report. Id. at 18–20. Appellant argues the Examiner does not provide the evidence required by Berkheimer to support a determination that the additional elements are well-understood, routine, or conventional. Id. at 20–22 (citing Berkheimer v. HP Inc., 881 F.3d 1360 (Fed. Cir. 2018)). We disagree with Appellant. D. Step 2A, Prong 1 Patent eligibility under § 101 is a question that we resolve pursuant to the 2019 Revised Guidance. The emphasized portions of claim 1,5 reproduced above (see supra at 2), recite commercial interactions (including business relations).6 Commercial interactions (including business relations) fall within the category of certain methods of organizing human activity (i.e., an abstract idea). See 2019 Revised Guidance, 84 Fed. Reg. at 52 n.14. Appellant also acknowledges the present claims recite an abstract idea. Appeal Br. 17–18. We disagree with Appellant’s argument that the present claims as a whole are not directed to an abstract idea (id.) for the reasons discussed infra §§ I.E. and I.F. We must still determine whether the abstract idea is integrated into a practical application, namely whether the claim applies, relies on, or uses the 5 Appellant does not argue claims 1–6, 8–14, and 16–19 separately with particularity. Appeal Br. 17–22. We, therefore, group these claims together and refer to them as the “present claims.” 6 We determine the “transmit” limitations are extra-solution activity. See also Ans. 13–14 (the Examiner makes the same determination). Appeal 2020-001260 Application 14/752,854 8 abstract idea in a manner that imposes a meaningful limit on the abstract idea, such that the claim is more than a drafting effort designed to monopolize the abstract idea. See 2019 Revised Guidance, 84 Fed. Reg. at 54–55. We therefore (1) identify whether there are any additional recited elements beyond the abstract idea, and (2) evaluate those elements both individually and collectively to determine whether they integrate the exception into a practical application. See id. Accordingly, we proceed to Prong 2. E. Step 2A, Prong 2 Here, the elements in the present claims used to implement the abstract idea are the “memory device,”7 “processor,”8 “enterprise,” “computer,”9 and “database.”10 See 2019 Revised Guidance, 84 Fed. Reg. at 52. The additional elements of the present claims do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea for the following reasons. Appellant does not identify persuasively how the Specification sets forth an improvement in technology. Appeal Br. 9–10 (citing Core Wireless Licensing S.A.R.L v. LG Elecs., Inc., 880 F.3d 1356 (Fed. Cir. 2018). The Update addresses how we consider evidence of improvement that is presented to us. The Update states: 7 This additional element is recited in claim 1 (and its dependent claims) only. See Claims App. 8 This additional element is recited in claim 1 (and its dependent claims) only. See Claims App. 9 This additional element is recited in claims 9 and 16 (and its dependent claims) only. See Claims App. 10 This additional element is recited in claim 16 (and its dependent claims) only. See Claims App. Appeal 2020-001260 Application 14/752,854 9 [T]he evaluation of Prong Two requires the use of the considerations (e.g. improving technology, effecting a particular treatment or prophylaxis, implementing with a particular machine, etc.) identified by the Supreme Court and the Federal Circuit, to ensure that the claim as a whole “integrates [the] judicial exception into a practical application [that] will apply, rely on, or use the judicial exception in a manner that imposes a meaningful limit on the judicial exception, such that the claim is more than a drafting effort designed to monopolize the judicial exception. Update 11 (emphases added). The Update further states: During examination, the examiner should analyze the “improvements” consideration by evaluating the specification and the claims to ensure that a technical explanation of the asserted improvement is present in the specification, and that the claim reflects the asserted improvement. Generally, examiners are not expected to make a qualitative judgment on the merits of the asserted improvement. If the examiner concludes the disclosed invention does not improve technology, the burden shifts to applicant to provide persuasive arguments supported by any necessary evidence to demonstrate that one of ordinary skill in the art would understand that the disclosed invention improves technology. Any such evidence submitted under 37 C.F.R. § 1.132 must establish what the specification would convey to one of ordinary skill in the art and cannot be used to supplement the specification. For example, in response to a rejection under 35 U.S.C. § 101, an applicant could submit a declaration under § 1.132 providing testimony on how one of ordinary skill in the art would interpret the disclosed invention as improving technology and the underlying factual basis for that conclusion. Id. at 13 (emphasis added). We, therefore, focus on any evidence Appellant cites in its briefs, as discussed in the Update. Appellant does not refer us to any paragraphs of the Specification or other evidence of an improvement to a technology or technological field. Appeal Br. 18–20. Appeal 2020-001260 Application 14/752,854 10 Furthermore, the additional elements in the present claims, namely “memory device,” “processor,” “enterprise,” “computer,” and “database,” do not, either individually or in combination, integrate the abstract idea into a practical application. Appellant’s Specification discloses that these elements encompass generic computer components. Spec. ¶¶ 11–13, 31, 38, 53, 100, 102. Merely adding generic computer components to perform abstract ideas does not integrate those ideas into a practical application. See 2019 Revised Guidance, 84 Fed. Reg. at 55 (identifying “merely includ[ing] instructions to implement an abstract idea on a computer” as an example of when an abstract idea has not been integrated into a practical application). We, therefore, conclude that the additional elements, whether considered individually or as an ordered combination, do not integrate the abstract idea into a practical application because the additional elements are generic computer components that do not impose meaningful limits on practicing the abstract idea. We disagree with Appellant’s argument that the present claims are similar to the patent eligible Examples because the present claims include converting the communication session (regardless of a format of the communication session) to a data metric that is used when generating a subscription report. Appeal Br. 18–20. Instead, we conclude that the present claims are directed to improvements to an abstract idea (i.e., certain methods of organizing human activity), rather than to improvements to a technology or technological field. See, e.g., Synopsys, Inc. v. Mentor Graphics Corp., 839 F.3d 1138, 1151 (Fed. Cir. 2016) (“[A] claim for a new abstract idea is still an abstract idea.”). “[U]nder the Mayo/Alice framework, a claim directed to a newly discovered law of nature (or natural phenomenon Appeal 2020-001260 Application 14/752,854 11 or abstract idea) cannot rely on the novelty of that discovery for the inventive concept necessary for patent eligibility . . . .” Genetic Techs. Ltd. v. Merial L.L.C., 818 F.3d 1369, 1376 (Fed. Cir. 2016) (citations omitted). Appellant does not make any other arguments pertaining to Step 2A, Prong 2. Because the present claims recite an abstract idea that is not integrated into a practical application, we proceed to Step 2B. F. Step 2B We disagree with Appellant’s argument that the Examiner fails to provide sufficient evidence to support the finding that the additional elements implementing the abstract idea, whether considered individually or as an ordered combination, are well-understood, routine, and conventional. Appeal Br. 20–22 (citing Berkheimer, 881 F.3d 1360). The Examiner does not make a specific finding that the additional elements implementing the abstract idea are well-understood, routine, and conventional. Final Act. 3. To the extent that Appellant is arguing that the Specification does not support a finding that the additional elements implementing the abstract idea are well-understood, routine, and conventional, we disagree because the Specification indicates that the additional elements (i.e., “memory device,” “processor,” “enterprise,” “computer,” and “database”) are nothing more than generic computer components. Spec. ¶¶ 11–13, 31, 38, 53, 100, 102. Appellant’s Specification indicates these additional elements were well- understood, routine, and conventional components because it describes them at a high level of generality and in a manner that indicates that they are sufficiently well-known. Appellant does not argue that the dependent claims recite any additional features that would transform the abstract idea embodied in Appeal 2020-001260 Application 14/752,854 12 independent claims 1, 9, and 16 into an inventive concept. We, therefore, sustain the Examiner’s rejection of: (1) independent claims 1, 9, and 16; and (2) dependent claims 2–6, 8, 10–14, and 17–19 under § 101. II. Claims 1–6, 8–14, and 16–19 Rejected Under 35 U.S.C. § 103 The Examiner finds Somasundaram teaches sending notifications to a first customer, and the first customer gives a second customer authorization to receive notifications while the first customer is away on vacation, which the Examiner maps to the limitation determine if the agent is unavailable to manage the communication session; determine if the agent is subscribed to real-time notifications; generate the notification for the agent of the enterprise based on the generated subscription report if the agent is unavailable to manage the communication session and if the agent is subscribed to receive real-time notifications; and transmit the generated notification to the agent of the enterprise recited in claim 1 (and similarly recited in claims 9 and 16). Final Act. 6–10 (citing Somasundaram ¶¶ 19, 71, 89); Ans. 14–18 (citing Somasundaram ¶¶ 19, 71, 89). Appellant argues Somasundaram merely teaches when a user is unavailable, the notification is sent to a third party (i.e., a different entity), which is not the same entity as the subscribing entity and is not the unavailable entity. Appeal Br. 26; Reply Br. 3. Appellant argues Somasundaram is not analogous to the claimed invention because (1) Somasundaram is directed to video surveillance systems, whereas the claims are directed to providing notifications to resources and (2) Somasundaram is directed to video surveillance, whereas the claims are directed to providing notifications in an efficient manner so Somasundaram Appeal 2020-001260 Application 14/752,854 13 is not reasonably pertinent to the problem being solved. Reply Br. 4–5. We disagree with Appellant. Somasundaram teaches sending notifications to a first customer, and the first customer gives a second customer authorization to receive notifications while the first customer is away on vacation. Somasundaram ¶¶ 19, 71, 89 (cited at Final Act. 6–10; Ans. 14–18). Paragraphs 19, 71, and 89 of Somasundaram do not state that the first customer stops receiving alerts while away on vacation; these paragraphs merely state that the second customer also receives alerts while on vacation. See e.g., Somasundaram ¶¶ 18, 19 (paragraph 18 discusses a customer receiving alerts and paragraph 19 begins with “[m]oreover” and states that the second customer receives alerts while the first customer is on vacation; paragraphs 18 and 19, therefore, are not alternative embodiments and we interpret paragraphs 18 and 19 as teaching both the first customer and the second customer receiving alerts). We, therefore, agree with the Examiner’s finding that Somasundaram teaches or at least suggests the limitation determine if the agent is unavailable to manage the communication session; determine if the agent is subscribed to real-time notifications; generate the notification for the agent of the enterprise based on the generated subscription report if the agent is unavailable to manage the communication session and if the agent is subscribed to receive real-time notifications; and transmit the generated notification to the agent of the enterprise recited in claim 1 (and similarly recited in claims 9 and 16). Final Act. 6–10 (citing Somasundaram ¶¶ 19, 71, 89); Ans. 14–18 (citing Somasundaram ¶¶ 19, 71, 89). Appellant’s non-analogous art argument is untimely. Reply Br. 4–5. Appellant’s argument is untimely and waived because the Examiner did not Appeal 2020-001260 Application 14/752,854 14 change the theory of unpatentability in the Answer (compare Final Act. 6– 10 with Ans. 14–18), while Appellant proffered new arguments in the Reply Brief (compare Appeal Br. 26 with Reply Br. 4–5) without showing good cause. See 37 C.F.R. § 41.41(b)(2). Even assuming, arguendo, that this argument were not untimely, we determine that Somasundaram is analogous to the present claims. The test for determining whether a prior art reference constitutes analogous art to the claimed invention is: (1) whether the prior art is from the same field of endeavor, regardless of the problem addressed, or (2) if the reference is not within the field of the inventor’s endeavor, whether the reference still is reasonably pertinent to the particular problem with which the inventor is involved. See In re Bigio, 381 F.3d 1320, 1325 (Fed. Cir. 2004). In determining the field of endeavor, we look to the written description and claims, including the structure and function of the invention. Bigio, 381 F.3d at 1326. In defining the field of invention, and in determining the relevance of Somasundaram to the obviousness inquiry, here a broad approach should be taken. Indeed, the Supreme Court provided guidance in determining the applicability of a reference’s teachings in an obviousness inquiry. In KSR Int’l Co. v. Teleflex Inc., the Court explained that if a feature has been used to improve one device, and a person of ordinary skill in the art would have recognized that it would improve a similar device in that field or another, implementing that feature on the similar device is likely obvious. KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398, 417 (2007). Appeal 2020-001260 Application 14/752,854 15 Here, the appropriate scope of the field of endeavor is sending notifications to a second customer while the first customer is away. Somasundaram ¶¶ 19, 71, 89. Appellant characterizes Somasundaram as being in the field of video surveillance. Reply Br. 3. However, in arriving at that description, Appellant too narrowly characterizes the Somasundaram reference. Somasundaram is within the field of endeavor because it teaches sending notifications to a second customer while the first customer is away. Somasundaram ¶¶ 19, 71, 89. Because we determine that Somasundaram is within the same field of endeavor as the claimed invention, we need not consider Appellant’s arguments regarding whether Somasundaram is reasonably pertinent to the particular problem with which Appellant is involved. Appellant does not argue claims 1–6, 8–14, and 16–19 separately with particularity. Appeal Br. 26–27; Reply Br. 2–5. We, therefore, sustain the Examiner’s rejection of: (1) independent claims 1, 9, and 16;11 and (2) dependent claims 2–6, 8, 10–14, and 17–19 under § 101. We have only considered those arguments that Appellant actually raised in the Briefs. Arguments Appellant could have made, but chose not to make, in the Briefs have not been considered and are deemed to be waived. See 37 C.F.R. § 41.37(c)(1)(iv). 11 Independent claims 9 and 16 are method claims that recite conditional limitations, which means that the conditional limitations need not be given patentable weight. Ex parte Schulhauser, No. 2013-007847, 2016 WL 6277792 (PTAB Apr. 28, 2016) (precedential); accord Ans. 18. Appeal 2020-001260 Application 14/752,854 16 CONCLUSION No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § 1.136(a)(1)(iv). See 37 C.F.R. § 1.136(a)(1)(iv). AFFIRMED Claim(s) Rejected 35 U.S.C. § Reference(s)/Basis Affirmed Reversed 1–6, 8–14, 16–19 101 Eligibility 1–6, 8–14, 16–19 1–6, 8–14, 16–19 103 Dwyer, Somasundaram 1–6, 8–14, 16–19 Overall Outcome 1–6, 8–14, 16–19 Copy with citationCopy as parenthetical citation