Ex Parte Byrd et alDownload PDFBoard of Patent Appeals and InterferencesOct 8, 200909867645 (B.P.A.I. Oct. 8, 2009) Copy Citation UNITED STATES PATENT AND TRADEMARK OFFICE 1 ___________ 2 3 BEFORE THE BOARD OF PATENT APPEALS 4 AND INTERFERENCES 5 ___________ 6 7 Ex parte MARC JESTON BYRD and 8 MANISH KRISHNARAO KALBANDE 9 ___________ 10 11 Appeal 2009-000381 12 Application 09/867,645 13 Technology Center 3600 14 ___________ 15 16 Decided: October 8, 2009 17 ___________ 18 19 Before ANTON W. FETTING, JOSEPH A. FISCHETTI, and BIBHU R. 20 MOHANTY, Administrative Patent Judges. 21 FETTING, Administrative Patent Judge. 22 DECISION ON APPEAL 23 Appeal 2009-000381 Application 09/867,645 2 STATEMENT OF THE CASE 1 Marc Jeston Byrd and Manish Krishriarao Kalbande (Appellants) seek 2 review under 35 U.S.C. § 134 (2002) of a final rejection of claims 1-29, the 3 only claims pending in the application on appeal. 4 We have jurisdiction over the appeal pursuant to 35 U.S.C. § 6(b) 5 (2002). 6 SUMMARY OF DECISION1 7 We AFFIRM-IN-PART. 8 THE INVENTION 9 The Appellants invented a way for delivering customer profile and 10 billing information upon enrollment in Internet bill presentment and 11 payment environments (Specification 2:¶ 001). 12 An understanding of the invention can be derived from a reading of 13 exemplary claims 1 and 8 which are reproduced below [bracketed matter and 14 some paragraphing added]. 15 1 Our decision will make reference to the Appellants’ Appeal Brief (“App. Br.,” filed April 23, 2007) and Reply Brief (“Reply Br.,” filed September 5, 2007), and the Examiner’s Answer (“Ans.,” mailed September 5, 2007). Appeal 2009-000381 Application 09/867,645 3 1. In a bill presentment and payment environment with a 1 scheduled time to communicate billing information with a set of 2 billers, 3 a bill presentment and payment method comprising: 4 [1] receiving customer registration information, including 5 information sufficient to identify the customer; 6 [2] providing the customer identification information to one of 7 the billers 8 as part of a first request indicating enrollment in the bill 9 presentment and payment system; and 10 [3] permitting access by the customer to billing information 11 from the one of the billers at an unscheduled time. 12 8. A system for permitting real-time access by a customer to 13 billing information in an Internet bill presentment and payment 14 environment, 15 the system comprising: 16 [1] a consolidator module; and 17 [2] a biller module, 18 connected to the consolidator module, 19 wherein the biller module includes 20 [3] biller-independent submodules 21 for communicating with the consolidator module; 22 [4] biller-dependent modules 23 for retrieving information from data stored by the 24 biller; and 25 [5] an interface 26 enabling the biller-independent submodules to 27 interact with the biller-dependent submodules. 28 Appeal 2009-000381 Application 09/867,645 4 THE REJECTIONS 1 The Examiner relies upon the following prior art: 2 Haseltine US 6,578,015 B1 Jun. 10, 2003 PR Newswire, Sun-Netscape Alliance's New Internet Billing 3 Consolidation Application to Help Make Internet Billing a Reality for 4 Consumers, Dec 6, 1999. pg. 1 (Newswire) 5 Claims 8-10 stand rejected under 35 U.S.C. § 102(e) as anticipated by 6 Haseltine. 7 Claims 1-7 and 14-20 stand rejected under 35 U.S.C. § 103(a) as 8 unpatentable over Haseltine and Newswire. 9 Claims 11-13 and 21-29 stand rejected under 35 U.S.C. § 103(a) as 10 unpatentable over Haseltine. 11 ISSUES 12 The issue of whether the Appellants have sustained their burden of 13 showing that the Examiner erred in rejecting claims 8-10 under 35 U.S.C. § 14 102(e) as anticipated by Haseltine turns on whether Haseltine describes the 15 data retrieval structure of claim 8. 16 The issue of whether the Appellants have sustained their burden of 17 showing that the Examiner erred in rejecting claims 1-7 and 14-20 under 35 18 U.S.C. § 103(a) as unpatentable over Haseltine and Newswire turns on 19 whether Haseltine describes the data retrieval steps of claims 1 and 6. 20 Appeal 2009-000381 Application 09/867,645 5 The issue of whether the Appellants have sustained their burden of 1 showing that the Examiner erred in rejecting claims 11-13 and 21-29 under 2 35 U.S.C. § 103(a) as unpatentable over Haseltine turns on whether 3 Haseltine describes the data retrieval steps of claims 1 and 6 in the above 4 rejection and on whether Haseltine describes the components enumerated in 5 claims 11 and 12. 6 FACTS PERTINENT TO THE ISSUES 7 The following enumerated Findings of Fact (FF) are believed to be 8 supported by a preponderance of the evidence. 9 Facts Related to Claim Construction 10 01. The term "consolidator" refers to any Internet bill presentment 11 and payment (IBPP) system that is requesting billing data. 12 Specification p.4, ¶ [007]. 13 02. The term "biller" refers to any IBPP system having billing data. 14 Specification p.4, ¶ [007]. 15 Facts Related to the Prior Art 16 Haseltine 17 03. Haseltine is directed to a powerful, automated and flexible 18 infrastructure for electronically presenting, processing, viewing 19 and paying bills and other requests for payment over a computer 20 network, such as the Internet. Haseltine col. 1, ll. 8-14. 21 Appeal 2009-000381 Application 09/867,645 6 04. A secure bill presentment infrastructure should allow customers 1 to be presented with and view bills as they would normally appear 2 with the ability to view a summary and/or a detailed form of the 3 bill and schedule bills for auto-payment to pay the bill 4 electronically. Haseltine 2:6-17. 5 05. Bill consolidators exist, which allow customers to electronically 6 log onto a single site on the World Wide Web (hereafter Web) and 7 pay bills originating from a number of individual billers. Such 8 consolidators may be generally categorized as thin consolidators 9 or thick consolidators. Haseltine 2:31-44. 10 06. Thin consolidators typically carry only bill summaries and refer 11 the customer to the biller's own Web site for further detailed bills 12 and/or further customer service, such as to discuss a disputed bill. 13 Haseltine 2:39-42. 14 07. Thick consolidators typically carry the biller's entire customer 15 data and often act as their own payment processors. In the thick 16 consolidator case, the biller's involvement in the presentment and 17 payment process may be limited to providing the thick 18 consolidator with the necessary customer bill data and collecting 19 the payment after the customer payment has been received and 20 processed. Haseltine 2:42-48. 21 Appeal 2009-000381 Application 09/867,645 7 08. Haseltine describes receiving biller-originated bill data and bill 1 format data over the network into a bill presentment and payment 2 database; storing and validating the inputted bill data and bill 3 format data making the data accessible to the customer; and 4 presenting the bill to the customer. Haseltine 3:1-18. 5 09. Haseltine’s Fig. 3 is a graphical representation of the 6 relationship and communication paths among billers, customers, 7 consolidators and payment processors. When a customer logs 8 onto the Web site of a thick consolidator to view and pay bills for 9 one or more billers having contracted with the thick consolidator, 10 both the bill summary data and the bill detail data may be 11 available from the thick consolidator's database. Any payment 12 requests are sent to a payment processor. Haseltine 9:47 – 10:37. 13 10. A thin consolidator maintains a customer-accessible link to the 14 billers to provide the customer with detail bill data, customer 15 service or other customer services. For example, the thin 16 consolidator may maintain a customer-specific Universal 17 Resource Locator (URL) to the billers' Web site linking the 18 customer directly into a Web page containing the customer's 19 (detailed) billing data. Haseltine 10:45 – 11:14. 20 11. Haseltine’s Fig. 2 illustrates an electronic bill generation and 21 payment cycle in which a biller submit bills data to a translator to 22 transform the data in a format appropriate for storage in the 23 electronic bill presentment and payment database. A bank may be 24 bypassed altogether, and the payment processor may remit the 25 Appeal 2009-000381 Application 09/867,645 8 processed customer payments directly to the biller. Haseltine 1 11:32–61. 2 12. Haseltine’s Fig. 6 is the block diagram of a system architecture 3 for managing the database of Fig. 4 which is coupled to the bill 4 presentment and payment application logic which includes 5 presentment logic for presenting the formatted online customer 6 bill to the customers via the user interface. Haseltine 11:63 – 7 12:11. 8 Newswire 9 13. Newswire is directed to an Internet billing consolidation 10 application. Newswire: Title. 11 14. “[A] common standard for Internet bill presentment and 12 payment will help drive the mass adoption of electronic billing by 13 encouraging multiple billers, such as credit card companies, 14 retailers and utilities, to present bills via the banks' Web sites.” 15 Newswire 2: ¶ 2. 16 15. The consumer can log onto their online banking site to view 17 their bills from their service providers and pay the bills or link to 18 the provider’s site for more detailed billing information. The 19 billers can then reach customers more than once a month. 20 Newswire 2: ¶ 5. 21 16. Billers can also use the application as a secure medium to send 22 detailed information about a customer’s account to the bank’s site. 23 Newswire 2: ¶ 8. 24 Appeal 2009-000381 Application 09/867,645 9 Facts Related To The Level Of Skill In The Art 1 17. Neither the Examiner nor the Appellants have addressed the 2 level of ordinary skill in the pertinent arts of systems analysis and 3 programming, remittance processing systems, bill presentment 4 and payment processing system design, or network systems 5 design. We will therefore consider the cited prior art as 6 representative of the level of ordinary skill in the art. See Okajima 7 v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001) 8 (“[T]he absence of specific findings on the level of skill 9 in the art does not give rise to reversible error “where 10 the prior art itself reflects an appropriate level and a 11 need for testimony is not shown.” (quoting Litton Indus. 12 Prods., Inc. v. Solid State Sys. Corp., 755 F.2d 158, 163, 13 225 USPQ 34, 38 (Fed.Cir.1985).) 14 18. A user interface within a client server architecture on the 15 Internet is a client object to the server that provides data or 16 communications services. 17 Facts Related To Secondary Considerations 18 19. There is no evidence on record of secondary considerations of 19 non-obviousness for our consideration. 20 Appeal 2009-000381 Application 09/867,645 10 PRINCIPLES OF LAW 1 Anticipation 2 "A claim is anticipated only if each and every element as set forth in the 3 claim is found, either expressly or inherently described, in a single prior art 4 reference." Verdegaal Bros. v. Union Oil Co. of California, 814 F.2d 628, 5 631 (Fed. Cir. 1987). "When a claim covers several structures or 6 compositions, either generically or as alternatives, the claim is deemed 7 anticipated if any of the structures or compositions within the scope of the 8 claim is known in the prior art." Brown v. 3M, 265 F.3d 1349, 1351 (Fed. 9 Cir. 2001). "The identical invention must be shown in as complete detail as 10 is contained in the ... claim." Richardson v. Suzuki Motor Co., 868 F.2d 11 1226, 1236 (Fed. Cir. 1989). The elements must be arranged as required by 12 the claim, but this is not an ipsissimis verbis test, i.e., identity of terminology 13 is not required. In re Bond, 910 F.2d 831, 832 (Fed. Cir. 1990). 14 Obviousness 15 A claimed invention is unpatentable if, “the differences between the 16 subject matter sought to be patented and the prior art are such that the 17 subject matter as a whole would have been obvious at the time the invention 18 was made to a person having ordinary skill in the art.” KSR Int’l Co. v. 19 Teleflex Inc., 550 U.S. 398, 399 and 406 (2007); Graham v. John Deere Co., 20 383 U.S. 1, 13-14 (1966). 21 In Graham, the Court held that that the obviousness analysis is 22 bottomed on several basic factual inquiries: “[(1)] the scope and content of 23 the prior art are to be determined; [(2)] differences between the prior art and 24 the claims at issue are to be ascertained; and [(3)] the level of ordinary skill 25 in the pertinent art resolved.” Graham, 383 U.S. at 17. See also KSR, 550 26 Appeal 2009-000381 Application 09/867,645 11 U.S. at 406. “The combination of familiar elements according to known 1 methods is likely to be obvious when it does no more than yield predictable 2 results.” KSR, 550 U.S. at 416. 3 ANALYSIS 4 Claims 8-10 rejected under 35 U.S.C. § 102(e) as anticipated by Haseltine. 5 The Examiner found that Haseltine’s Fig. 3 anticipates the claim 8 6 system, aligning Haseltine’s thick and thin consolidators with the claimed 7 consolidator module Haseltine’s billers with the claimed biller module that 8 contains biller independent and dependent modules. The Examiner found 9 that Haseltine’s interaction between a thick consolidator and its database 10 described biller independent communication and that Haseltine’s interaction 11 between a thin consolidator and its biller described biller dependent 12 communication. The Examiner also found that Haseltine’s interface among 13 billers, consolidators and payment processors described the claim 8 14 interface. Ans. 3. 15 The Appellants present several arguments. They first argue that the 16 thick consolidators and thin consolidators do not constitute the claimed 17 "biller-independent submodules" and "biller-dependent submodules" at least 18 because these consolidators are part of the consolidator module, not the 19 biller module. App. Br. 15. This argument is moot because the Examiner 20 has not aligned the elements as such. Much of the remaining arguments 21 appear to arise from a fundamental misunderstanding of how the Examiner 22 has aligned Haseltine with claim 8. 23 For the Examiner’s findings to make sense, the biller-independent and 24 dependent modules that communicate with the consolidator module and 25 Appeal 2009-000381 Application 09/867,645 12 biller must align with the communication structures of Haseltine. Thus, the 1 Examiner’s phrase of a consolidator module (FIG 3, 350 and 360) is further 2 elaborated by the specific findings that thick consolidators maintain 3 databases of accounts related to the various billers; thin consolidators access 4 information maintained at the biller sites; and interfacing the information 5 obtained at the biller site, with account information maintained at the 6 consolidator and payment processing capabilities. Ans. 3. 7 So we take the Examiner’s reference for biller modules as being the 8 blocks in Fig. 3 referring to the billers, as more precisely referring to the 9 communication links to the billers, and as aligning Haseltine’s 10 communication structure with the claimed biller module. Then Haseltine’s 11 internal communication with its own database, e.g. Haseltine Fig. 6, and 12 external communication with payment processors, e.g. Haseltine Fig. 3: 355, 13 describes the claimed biller independent module. Haseltine’s external 14 communication with billers, e.g. Haseltine Fig. 3: 320, describes claimed 15 biller dependent module. See FF 09 & 10. 16 When the Examiner’s findings are properly understood, the remaining 17 arguments are readily addressed. The next argument is that nothing in 18 Haseltine discloses a thin consolidator "for retrieving information from data 19 stored by the biller," as recited in claim 8. This is in error, and in fact 20 ignores the very purpose of a bill consolidator, which is to retrieve such 21 information. Haseltine describes receiving biller-originated bill data and bill 22 format data over the network into a bill presentment and payment database. 23 FF 08. While this retrieval is asynchronous with respect to a user query, 24 nothing in claim 8 requires such synchronization. 25 Appeal 2009-000381 Application 09/867,645 13 The next argument is that Haseltine does not teach or suggest "biller-1 dependent modules for retrieving information from data stored by the biller; 2 and an interface enabling the biller-independent submodules to interact with 3 the biller-dependent submodules." App. Br. 16. Since Haseltine’s retrieved 4 data is entered into its internal database, this entry describes the required 5 interaction between biller dependent and biller independent modules. The 6 claim does not limit the manner of interaction. 7 As to claims 9 and 10, the Appellants argue that a website where a 8 customer can view and pay bills does not teach or suggest the claimed 9 "client object." The Appellants contend that Haseltine discloses a relational 10 database and does not disclose embodiments implemented as another type of 11 databases. Appellants conclude that that no objects are disclosed by 12 Haseltine so it does not teach or suggest the claimed, “‘a client object, 13 connected to the bill presentment and payment module,’ as recited in claim 14 9.” App. Br. 17, Reply Br. 3. We find to the contrary that Haseltine 15 describes providing a user interface connected to the Internet to its bill 16 presentment and payment module. FF 12. Such a user interface is a client 17 object to the servers feeding it data across the Internet. FF 18. 18 Claims 1-7 and 14-20 rejected under 35 U.S.C. § 103(a) as unpatentable 19 over Haseltine and Newswire. 20 Claims 1 and 6 are the independent method claims in this rejection. 21 Claims 14 and 19 are computer readable media analogs of claims 1 and 6. 22 All of the independent claims require performing a step in an unscheduled 23 time within an environment with scheduled communications. The Examiner 24 Appeal 2009-000381 Application 09/867,645 14 applied Newswire to describe this limitation. This finding is not under 1 contention. 2 As to claim 1, the Appellants argue that neither limitation [1] nor [2] is 3 described. App. Br. 19-20. The Examiner found that Haseltine’s customer 4 registration described limitation [1] and the customer accessing Haseltine’s 5 user interface described limitation [2]. Ans. 4-5. The Appellants contend 6 that because the customers log onto the system where the enrollment data is 7 stored, the customer does not provide identification "information to one of 8 the billers as part of a first request indicating enrollment." App. Br. 19. The 9 Examiner responds that the customer identification and other enrollment 10 information must be provided to the biller for Haseltine to retrieve the 11 billing data. Ans. 17. 12 We agree with the Examiner that customer identification information is 13 required to retrieve customer account information from billers. Clearly 14 Haseltine’s customer registration provides customer identification 15 information. The Appellants next argue that any such transmission to a 16 biller would not be part of the first request. Reply Br. 5. The Appellants 17 appear to be arguing that such a transmission would not be part of the 18 customer registration reception in limitation [1]. This argument is not 19 commensurate with the scope of the claim, as there is no requirement that 20 the first request indicating enrollment in limitation [2] be part of the data 21 reception in limitation [1]. 22 The Appellants also contend that any transmission to the biller after 23 customer enrollment would not be a first request indicating enrollment. 24 Again, the argument is not commensurate with the scope of the claim. The 25 Appeal 2009-000381 Application 09/867,645 15 claim does not specify whether the adjective “first” is meant to denote 1 temporal placement or mere ordinal designation. 2 Further, the Appellants argue that Haseltine’s customer enrollment itself 3 occurs without the request to the biller. But even if the word “first” is 4 construed as temporal placement, the claim does not specify to whom the 5 required first request is made. As the Examiner found, the sending of 6 customer identification information to a biller after customer registration 7 would be the first request to the biller indicating enrollment. 8 Finally, the Appellants argue that Newswire does not describe limitation 9 [2]. App. Br. 21. But as the Examiner responded, Haseltine is applied to 10 show that limitation. Ans. 17. Thus we find that Haseltine does describe 11 limitations [1] and [2]. 12 Claim 2 requires transmitting a second request to the one of the billers to 13 access billing information; and receiving the billing information from the 14 one of the billers. The Examiner found that Haseltine described this when a 15 customer logged onto a biller’s website. Ans. 5. The Appellants argue that 16 such a logon from a link provided by the consolidator cannot constitute 17 “transmitting a second request to the one of the billers to access billing 18 information” but that even if it could, because there is only a single URL for 19 each biller, a second request would be for a different biller than the first. 20 Appeal Br. 21-22. The Appellants’ arguments are unpersuasive. Claim 2 21 does not require the second request to be from the consolidator, only that it 22 be to one of the billers. Haseltine’s link to a biller accessed by a customer 23 would form such a request. FF 10. Since the first request was found to be 24 that performed by the consolidator in setting up the customer’s account with 25 Appeal 2009-000381 Application 09/867,645 16 the biller, there is no issue with a single URL. Also, it would be within the 1 suggested operation of Haseletine for a customer to access the same link 2 twice creating two requests. 3 The Appellants rely on the above arguments in support of claims 3-5 and 4 14-18. App. Br. 22. 5 Independent claim 6 requires receiving, from a requesting IBPP system, 6 a request for information associated with a customer; retrieving the 7 requested information; and forwarding the retrieved information to the 8 requesting IBPP system at an unscheduled time. The Examiner found that 9 Haseltine described this as a continuation of the steps in claim 1. The 10 Examiner found that the initial data retrieval and transmission of customer 11 billing data from a biller to a consolidator following customer registration 12 formed the request, retrieval and forwarding of claim 6. Ans. 18-19. In 13 response the Appellants contend that Newswire does not describe 14 forwarding information at an unscheduled time. Reply Br. 7. This is after 15 the Examiner found that Newswire suggested the desirability and capability 16 of transmitting such information at any time. Ans. 6-7. 17 We agree with the Examiner. Newswire describes how consumers log 18 onto their online banking site to view their bills from their service providers 19 and pay the bills or link to the provider’s site for more detailed billing 20 information so that the billers can then reach customers more than once a 21 month. FF 15. Billers send detailed information about a customer’s account 22 to the bank’s site. FF 16. So billers send detailed information more often 23 than the monthly schedule to the bank’s site. This explicitly recites the 24 Appeal 2009-000381 Application 09/867,645 17 retrieval and forwarding of data at unscheduled times and suggests doing so 1 in response to customer queries for such detailed information. 2 The Appellants rely on the above arguments in support of claims 7, 19, 3 and 20. App. Br. 24. 4 Claims 11-13 and 21-29 rejected under 35 U.S.C. § 103(a) as unpatentable 5 over Haseltine. 6 With respect to claims 11 and 12 depending from claim 8, they each 7 require a server object, which receives a request from the consolidator 8 module; a request handler, connected to the server object; and an 9 implementation object which receives the request from the request handler. 10 The Examiner found that Haseltine described the consolidator module 11 requesting information from the biller and the biller handling and 12 implementing the request. The Examiner found that the use of a server 13 object, request handler, and implementation object would have been an 14 obvious design choice. In response, the Appellants argue that the Examiner 15 has failed to articulate a reason that one of ordinary skill would use such 16 tools. Reply Br. 9. Here we must agree with the Appellants. The Examiner 17 has provided no evidence of the design and use of the tools enumerated in 18 these claims or that there use was in predictable. We find that the Examiner 19 has failed to present a prima facie case as to claims 11 and 12, and as to 20 claim 13 depending from claim 12. 21 The remaining independent claims 21-23 and 28 are similar to claims 1 22 and 6 absent the recitation of scheduled and unscheduled activity for which 23 Newswire was applied. The Appellants argue claim 21 similar to the 24 argument of claim 1 supra and we find them unpersuasive for the same 25 Appeal 2009-000381 Application 09/867,645 18 reasons. App. Br. 27-28. The Appellants rely on the arguments in support 1 of claim 21 for claim 23 and the patentability of claim 23 for dependent 2 claims 24-27. The Appellants also rely on the arguments for claim 2 which 3 we found unpersuasive supra for claim 24. App. Br. 29. The Appellants 4 argue claim 22 similar to the argument of claim 6 supra and we find them 5 unpersuasive for the same reasons. App. Br. 29-30. The Appellants rely on 6 the arguments in support of claim 22 for claim 28 and the patentability of 7 claim 28 for dependent claim 29. 8 CONCLUSIONS OF LAW 9 The Appellants have not sustained their burden of showing that the 10 Examiner erred in rejecting claims 8-10 under 35 U.S.C. § 102(e) as 11 anticipated by Haseltine. 12 The Appellants have not sustained their burden of showing that the 13 Examiner erred in rejecting claims 1-7 and 14-20 under 35 U.S.C. § 103(a) 14 as unpatentable over Haseltine and Newswire. 15 The Appellants have not sustained their burden of showing that the 16 Examiner erred in rejecting claims 21-29 under 35 U.S.C. § 103(a) as 17 unpatentable over Haseltine. 18 The Appellants have sustained their burden of showing that the 19 Examiner erred in rejecting claims 11-13 under 35 U.S.C. § 103(a) as 20 unpatentable over Haseltine. 21 DECISION 22 To summarize, our decision is as follows. 23 Appeal 2009-000381 Application 09/867,645 19 • The rejection of claims 8-10 under 35 U.S.C. § 102(e) as anticipated 1 by Haseltine is sustained. 2 • The rejection of claims 1-7 and 14-20 under 35 U.S.C. § 103(a) as 3 unpatentable over Haseltine and Newswire is sustained. 4 • The rejection of claims 21-29 under 35 U.S.C. § 103(a) as 5 unpatentable over Haseltine is sustained. 6 • The rejection of claims 11-13 under 35 U.S.C. § 103(a) as 7 unpatentable over Haseltine is not sustained. 8 No time period for taking any subsequent action in connection with this 9 appeal may be extended under 37 C.F.R. § 1.136(a)(1)(iv). 10 11 AFFIRMED-IN-PART 12 13 14 15 mev 16 17 SUN MICROSYSTEMS 18 C/O SONNENSCHEIN NATH & ROSENTHAL LLP 19 P.O. 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