INTERNATIONAL BUSINESS MACHINES CORPORATIONDownload PDFPatent Trials and Appeals BoardJun 1, 202014327124 - (D) (P.T.A.B. Jun. 1, 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. 14/327,124 07/09/2014 Douglas A. Wood AUS920140128US1 8560 134677 7590 06/01/2020 Terrile Cannatti & Chambers, LLP IBM - POU PO Box 203518 Austin, TX 78720 EXAMINER LINDSEY III, JOHNATHAN J ART UNIT PAPER NUMBER 3629 NOTIFICATION DATE DELIVERY MODE 06/01/2020 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): USPTO@dockettrak.com tmunoz@tcciplaw.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________ Ex parte DOUGLAS A. WOOD ____________ Appeal 2019-006143 Application 14/327,124 Technology Center 3600 ____________ Before KALYAN K. DESHPANDE, CHARLES J. BOUDREAU, and SHARON FENICK, Administrative Patent Judges. BOUDREAU, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE Pursuant to 35 U.S.C. § 134(a), Appellant1 appeals from the Examiner’s decision to reject claims 7–20, which are all of the pending claims. We have jurisdiction under 35 U.S.C. § 6(b)(1). We AFFIRM. 1 We use the word “Appellant” to refer to “applicant” as defined in 37 C.F.R. § 1.42. Appellant identifies International Business Machines Corporation as the real party in interest. Appeal Br. 1. Appeal 2019-006143 Application 14/327,124 2 CLAIMED SUBJECT MATTER Appellant’s invention relates to “automating the layout of a space layout based upon organization requirements and space constraints,” e.g., space planning for a commercial office space. Spec. ¶ 1; see id. ¶¶ 2–3. Claims 7 and 13 are independent. Claim 7, reproduced below, is illustrative of the subject matter on appeal: 7. A system comprising: a processor; a data bus coupled to the processor; and a non-transitory computer-usable medium embodying computer program code, the computer-usable medium being coupled to the data bus, the computer program code used for automating the layout of a space and comprising instructions executable by the processor and configured for: receiving a first set of organization structure data associated with an organization structure, the organization structure data defining how activities are directed to achievement of organization aims, the activities comprising task allocation, coordination and supervision, the first set of organization structure data being received by an integrated workplace management system (IWMS), the organization structure data comprising data associated with an organization structure of an organization, the organization structure data comprising space entitlement rules of the organization, the space entitlement rules comprising whether an organizational role is entitled to an office, a minimum area for the space associated with the organizational role, a placement of the space associated with the organizational role and a feature associated with the organizational role; receiving a first building information model (BIM) comprising a first set of space constraint data associated with a first space, the first BIM being received by the IWMS; Appeal 2019-006143 Application 14/327,124 3 processing the first set of organization structure data and the first set of space constraint data to automatically generate a first space layout corresponding to the first space, the processing performed by the IWMS; and, storing the first space layout in a BIM, the BIM comprising a shared knowledge resource for information about the first space layout, the BIM representing the first space layout as a combination of objects, each object of the combination of objects within the BIM having associated geometry, relations and attributes, the BIM allowing extraction of different views of the first space layout, each of the different views being based on a single definition of each object instance. Appeal Br. 8–9 (Claims App.). REJECTIONS Claims 7–20 stand rejected under 35 U.S.C. § 101 as being directed to non-statutory subject matter. Final Act. 2–9; Ans. 4–12. Claims 7–9, 13–15, 19, and 20 stand rejected under 35 U.S.C. § 103 as being unpatentable over Nagy,2 Hassanain,3 Liggett,4 and Rasane.5 Final Act. 10–22. Claims 10 and 16 stand rejected under 35 U.S.C. § 103 as being unpatentable over Nagy, Hassanain, Liggett, Rasane, and the Examiner’s Official Notice. Final Act. 22–23. 2 Nagy et al., US 2013/0246108 A1 (pub. Sept. 19, 2013). 3 Mohammad A. Hassanain, Analysis of factors influencing office workplace planning and design in corporate facilities, 6 J. Building Appraisal 183 (2010). 4 Robin S. Liggett, Automated facilities layout: past, present and future, 9 Automation in Construction 197 (2000). 5 Rasane et al., US 2013/0169681 A1 (pub. July 4, 2013). Appeal 2019-006143 Application 14/327,124 4 OPINION Rejection Under 35 U.S.C. § 101 An invention is patent-eligible if it claims a “new and useful process, machine, manufacture, or composition of matter, or [a] new and useful improvement thereof.” 35 U.S.C. § 101. However, the U.S. Supreme Court has long interpreted § 101 to “contain[] an important implicit exception: Laws of nature, natural phenomena, and abstract ideas are not patentable.” Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 216 (2014) (quoting Ass’n for Molecular Pathology v. Myriad Genetics, Inc., 569 U.S. 576, 589 (2013)). In Alice, the Supreme Court reiterated the two-step framework previously set forth in Mayo Collaborative Servs. v. Prometheus Labs., Inc., 566 U.S. 66, 75–77 (2012) “for distinguishing patents that claim laws of nature, natural phenomena, and abstract ideas from those that claim patent- eligible applications of those concepts.” Alice, 573 U.S. at 217. The first step in this analysis is to “determine whether the claims at issue are directed to one of those patent-ineligible concepts,” e.g., to an abstract idea. Id. Concepts determined to be abstract ideas include certain methods of organizing human activity, such as fundamental economic practices (id. at 219–20; Bilski v. Kappos, 561 U.S. 593, 611 (2010)); mathematical formulas (Parker v. Flook, 437 U.S. 584, 594–95 (1978)); and mental processes (Gottschalk v. Benson, 409 U.S. 63, 67 (1972)). If it is determined that the claims are directed to a patent-ineligible concept, the second step of the analysis requires consideration of the elements of the claims “individually and ‘as an ordered combination’” to determine whether there are additional elements that “‘transform the nature of the claim’ into a patent-eligible application.” Alice, 573 U.S. at 217 (quoting Mayo, 566 U.S. Appeal 2019-006143 Application 14/327,124 5 at 78, 79). “A claim that recites an abstract idea must include ‘additional features’ to ensure ‘that the [claim] is more than a drafting effort designed to monopolize the [abstract idea].’” Id. at 221 (alterations in original) (quoting Mayo, 566 U.S. at 77). In other words, the claims must contain an “inventive concept,” or some element or combination of elements “sufficient to ensure that the patent in practice amounts to significantly more than a patent upon the [abstract idea] itself.” Id. at 217–18 (quoting Mayo, 566 U.S. at 72–73). “[M]erely requir[ing] generic computer implementation[] fail[s] to transform that abstract idea into a patent-eligible invention.” Id. at 221. In January 2019, the PTO published revised guidance on the application of § 101. 2019 Revised Patent Subject Matter Eligibility Guidance, 84 Fed. Reg. 50 (Jan. 7, 2019) (“Revised Guidance”).6 “All USPTO personnel are, as a matter of internal agency management, expected to follow the guidance.” Id. at 51; see also October 2019 Update at 1. Under that guidance, 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 fundamental economic practices, or mental processes) (“Step 2A, Prong 1”); and 6 In October 2019, in response to received public comments, the PTO issued a further memorandum clarifying the Revised Guidance. USPTO Memorandum, October 2019 Update: Subject Matter Eligibility (Oct. 17, 2019), available at https://www.uspto.gov/sites/default/files/documents/ peg_oct_2019_update.pdf (“October 2019 Update”). Appeal 2019-006143 Application 14/327,124 6 (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 2”).7 See 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 (under “Step 2B”) look to whether the claim (3) adds a specific limitation beyond the judicial exception that is not “well-understood, routine, and 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. See Revised Guidance, 84 Fed. Reg. at 56. The Examiner determines that the claims recite mental processes and, thus, an abstract idea. Ans. 4. The Examiner further determines that the abstract idea is not integrated into a practical application, and that the claims do not contain an inventive concept or include additional elements that are sufficient to amount to significantly more than the abstract idea. Ans. 5, 8; Final Act. 3–4. The Examiner finds that the claims recite insignificant extra- solution activity, do not reflect an improvement in a technical field or computer-related technology, and amount to no more than mere instructions 7 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 determine whether the claim as a whole integrates the exception into a practical application. See Revised Guidance, 84 Fed. Reg. at 54–55 (Section III.A.2). Appeal 2019-006143 Application 14/327,124 7 to apply the abstract idea using generic computer components. Ans. 5, 8; Final Act. 6–7. Appellant argues that the claims “are generally directed to the practical application of automating the layout of a space using an integrated workplace management system” (Appeal Br. 3) and “include far more than a per se recitation [of] mathematical concepts, methods of organizing human activity or mental processes” (Reply Br. 2). Step 2A, Prong 1 We agree with the Examiner that the claims recite a judicial exception, i.e., an abstract idea. See Ans. 4. Specifically, we agree that the claims recite mental processes. See id. For example, independent claim 7 recites “processing the first set of organization structure data and the first set of space constraint data to automatically generate a first space layout corresponding to the first space.” Under its broadest reasonable interpretation, this “processing” limitation covers performance of the limitation in the mind (as does the corresponding limitation in independent claim 13), but for the recitation of generic components. That is, other than the “processor,” “non-transitory computer- usable medium embodying computer program code . . . comprising instructions executable by the processor,” and “integrated workplace management system (IWMS)” recited in claim 7 and similar components recited in claim 13 as performing the recited step, nothing in the claims precludes that step from being performed in the human mind. For example, but for the recitation of the “processor,” “non-transitory computer-usable medium,” and “IWMS,” claim 7 encompasses mentally processing the first Appeal 2019-006143 Application 14/327,124 8 set of organization structure data and the first set of space constraint data to generate a first space layout corresponding to the first space. Accordingly, the claims recite mental processes and, thus, an abstract idea. Step 2A, Prong 2 Because the claims recite an abstract idea, we next look to whether the claims recite additional elements that integrate the abstract idea into a practical application. Revised Guidance, 84 Fed. Reg. at 54. Claim limitations that indicate integration into a practical application include additional elements that reflect an improvement in the functioning of a computer, or an improvement to other technology or technical field. Id. at 55. When a claim recites a judicial exception and fails to integrate the judicial exception into a practical application, the claim is “directed to” the judicial exception. Id. at 51. We agree with the Examiner that the additional limitations recited in the claims do not integrate the recited judicial exception into a practical application. See Ans. 5. For example, claim 7 additionally recites, receiving a first set of organization structure data associated with an organization structure, the organization structure data defining how activities are directed to achievement of organization aims, the activities comprising task allocation, coordination and supervision, the first set of organization structure data being received by an integrated workplace management system (IWMS), the organization structure data comprising data associated with an organization structure of an organization, the organization structure data comprising space entitlement rules of the organization, the space entitlement rules comprising whether an organizational role is entitled to an office, a minimum area for the space associated with the organizational Appeal 2019-006143 Application 14/327,124 9 role, a placement of the space associated with the organizational role and a feature associated with the organizational role; [and] receiving a first building information model (BIM) comprising a first set of space constraint data associated with a first space, the first BIM being received by the IWMS. These “receiving” limitations are recited at a high level of generality (i.e., as general steps of gathering the various information considered in generating the first space layout) and amount to insignificant pre-solution activity. Claim 7 further recites “storing the first space layout in a BIM.” This “storing” limitation is also recited at a high level of generality (i.e., as a general step of storing the generated first space layout) and amounts to insignificant post-solution activity. Accordingly, we agree with the Examiner that the “receiving” and “storing” limitations “describe data gathering and data output,” amounting to insignificant extra-solution activity. See Ans. 5; Revised Guidance, 84 Fed. Reg. at 55; MPEP § 2106.05(g). We further agree with the Examiner that the claims otherwise merely recite generic computer components that similarly fail to integrate the recited abstract idea into a practical application. See Ans. 6–7; Final Act. 5– 6. For example, claim 7 recites a “processor,” “data bus,” “non-transitory computer-usable medium embodying computer program code . . . comprising instructions executable by the processor,” and “integrated workplace management system (IWMS).” These limitations are recited at a high level of generality, i.e., as generic components performing generic computer functions of computer processing, storage, and communication. As the Examiner points out, the claims merely apply the abstract idea using generic computer components and indicate a field of use or technological Appeal 2019-006143 Application 14/327,124 10 environment (i.e., computer software). See Ans. 7; Final Act. 6; Spec. ¶ 1; Revised Guidance, 84 Fed. Reg. at 55; MPEP § 2106.05(f), (h). The claim limitations do not include any particular machine that is integral to the claim. See Ans. 7; Final Act. 6; Revised Guidance, 84 Fed. Reg. at 55; MPEP § 2106.05(b). We also agree with the Examiner that the claims do not recite a technological improvement in addition to the abstract idea. See Final Act. 7. As discussed above, the recited “processor,” “data bus,” “non-transitory computer-usable medium embodying computer program code . . . comprising instructions executable by the processor,” and “integrated workplace management system (IWMS)” are merely generic computer components performing generic functions of computer processing, storage, and communication. The claims “do not require an arguably inventive set of components or methods, such as measurement devices or techniques, that would generate new data. They do not invoke any assertedly inventive programming.” Elec. Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1355 (Fed. Cir. 2016). Although Appellant argues that the claims are directed to “automating the layout of a space using an integrated workplace management system” (Appeal Br. 3), the claims simply recite an existing practice—space planning—with the benefit of generic computer technology. As the Federal Circuit has explained, “mere automation of manual processes using generic computers does not constitute a patentable improvement in computer technology” (Credit Acceptance Corp. v. Westlake Servs., 859 F.3d 1044, 1055 (Fed. Cir. 2017)), particularly where, as here, “the focus of the claims is not on such an improvement in computers as tools, but on certain independently abstract ideas that use computers as tools” (Elec. Appeal 2019-006143 Application 14/327,124 11 Power Grp., LLC v. Alstom S.A., 830 F.3d 1350, 1354 (Fed. Cir. 2016)); see also OIP Techs., Inc. v. Amazon.com, Inc., 788 F.3d 1359, 1363 (Fed. Cir. 2015) (“At best, the claims describe the automation of the fundamental economic concept of offer-based price optimization through the use of generic-computer functions.”)). Thus, the claims do not reflect an improvement in computer functionality or to any other technology or technical field. See Spec. ¶¶ 2–3; Revised Guidance, 84 Fed. Reg. at 55; MPEP § 2106.05(a). Even in combination, the additional limitations do not integrate the abstract idea into a practical application because they do not impose any meaningful limits on practicing the abstract idea. Accordingly, we agree with the Examiner that the claims are directed to an abstract idea. See Ans. 7. Step 2B Turning to Step 2B of the Revised Guidance, we determine that there are no specific limitations beyond the judicial exception, i.e., the abstract idea, that are not well-understood, routine, and conventional in the field. See Alice, 573 U.S. at 225. For example, claim 7 additionally recites, the BIM comprising a shared knowledge resource for information about the first space layout, the BIM representing the first space layout as a combination of objects, each object of the combination of objects within the BIM having associated geometry, relations and attributes, the BIM allowing extraction of different views of the first space layout, each of the different views being based on a single definition of each object instance. We find nothing unconventional in these limitations describing the building information model (BIM). See, e.g., Spec. ¶¶ 4 (listing various examples of building information models), 41 (“Skilled practitioners of the art will be Appeal 2019-006143 Application 14/327,124 12 aware that known BIM design tools allow extraction of different views from various implementations of a BIM for drawing production and other uses. Furthermore, these different views are automatically consistent, being based on a single definition of each object instance.”). The additionally recited “processor,” “data bus coupled to the processor,” “non-transitory computer-usable medium embodying computer program code . . . [and] coupled to the data bus,” “instructions executable by the processor,” and “integrated workplace management system (IWMS)” are mere recitations of generic computer components performing generic computer functions that are well-understood, routine, and conventional, and thus do not amount to significantly more than the abstract idea. See Spec. ¶¶ 3 (“Known approaches . . . include the implementation of an integrated workspace management system (IWMS) . . . .”), 18 (listing various types of computer readable storage media), 20 (listing various computer readable programming languages), 22 (“These computer readable program instructions may be provided to a processor of a general purpose computer, special purpose computer, or other programmable data processing apparatus . . . .”), 25 (generally describing a “processor unit” coupled to a “system bus” in the computer). As indicated by the Examiner, those additional elements amount to no more than mere instructions to apply the abstract idea using generic computer components. See Ans. 8. Mere instructions to apply an abstract idea on a generic computer do not provide an inventive concept. Alice, 573 U.S. at 223–24. Reevaluating the extra-solution activity of “receiving a first set of organization structure data” and “receiving a first building information model (BIM)” (see Revised Guidance, 84 Fed. Reg. at 56 (stating that a Appeal 2019-006143 Application 14/327,124 13 conclusion under Step 2A that an additional element is insignificant extra- solution activity should be reevaluated in Step 2B)), we find nothing unconventional in these steps of gathering the various information considered in generating the first space layout. See, e.g., Spec. ¶ 3 (discussing typical considerations in space planning, such business and space requirements). Appellant has not shown that the claims on appeal add any specific limitation beyond the judicial exception that is not well-understood, routine, and conventional in the field. Appellant also provides no evidence of how the ordered combination is unconventional or amounts to significantly more than the abstract idea to which the claims are otherwise directed. Accordingly, considering the claim elements individually and as an ordered combination, we agree with the Examiner that there are no meaningful claim limitations that represent sufficiently inventive concepts to transform the nature of the claims into a patent-eligible application of the abstract idea. See Ans. 8. For the foregoing reasons, we sustain the Examiner’s rejection of claims 7–20 under 35 U.S.C. § 101. Rejections Under 35 U.S.C. § 103 Claims 7–9, 13–15, 10, and 20 The Examiner determines that independent claims 7 and 13 are unpatentable over Nagy, Hassanain, Liggett, and Rasane. Final Act. 10–18, 20–21. Appellant argues, [N]owhere within Nagy and Hassanain is there any disclosure or suggestion processing organization structure data by an integrated workspace management system (IWMS) to automatically generate a first space layout corresponding to the Appeal 2019-006143 Application 14/327,124 14 first space, the organization structure data comprising data associated with an organization structure of an organization, the organization structure data comprising space entitlement rules of the organization, much less the space entitlement rules comprising whether an organizational role is entitled to an office, a minimum area for the space associated with the organizational role, a placement of the space associated with the organizational role and a feature associated with the organizational role, as required by claim 7 and 13. This deficiency of Nagy and Hassanain is not cured by Liggett or Rasane, taken alone or in combination. Appeal Br. 4–5. These types of conclusory statements, lacking evidence or explanation, are unpersuasive because Appellant does not substantively address the Examiner’s findings or rationale, i.e., does not provide substantive arguments that compare and distinguish the disputed claim limitations from the combined teachings and suggestions of the cited references. See 37 C.F.R. § 41.37(c)(1)(iv) (“A statement which merely points out what a claim recites will not be considered an argument for separate patentability of the claim.”); In re Lovin, 652 F.3d 1349, 1357 (Fed. Cir. 2011) (“[W]e hold that the Board reasonably interpreted Rule 41.37 to require more substantive arguments in an appeal brief than a mere recitation of the claim elements and a naked assertion that the corresponding elements were not found in the prior art.”); In re Kahn, 441 F.3d 977, 985–86 (Fed. Cir. 2006) (explaining that, on appeal to the Board, Appellant has the burden to demonstrate error in the Examiner’s rejection); Ex parte Belinne, No. 2009-004693, 2009 WL 2477843 at *4 (BPAI Aug. 10, 2009) (informative) (finding Appellant did not show error in the Examiner's rejection where the Examiner made extensive specific fact finding with respect to each of the argued claims and, in response, Appellant restated elements of the claim Appeal 2019-006143 Application 14/327,124 15 language and simply argued that the elements were missing from the reference). Appellant has not shown error in the Examiner’s finding of obviousness based on the combination of Nagy, Hassanain, Liggett, and Rasane. For the same reasons, we are unpersuaded by Appellant’s remaining arguments with respect to independent claims 7 and 13, in which Appellant similarly merely recites or paraphrases the claim language and alleges that it is not taught by the cited references, alone or in combination. See Appeal Br. 5–6. Accordingly, we sustain the Examiner’s rejection under 35 U.S.C. § 103 of independent claims 7 and 13 and dependent claims 8, 9, 14, 15, 19, and 20, which are not argued separately. Claims 10 and 16 Dependent claims 10 and 16 recite, inter alia, “performing comparison operations to compare the first space layout to the second space layout, the performance of the comparison operations generating a first set of space utilization metrics respectively associated with the first space layout and the second space layout.” The Examiner finds that, “[u]nder the broadest reasonable interpretation of the claim, the limitation recites steps to evaluate space layouts according to one or more metrics such as cost or efficiency” and takes Official Notice that “it is old and well known in the computer arts to determine the costs and/or efficiency of space layouts.” Final Act. 23. The Examiner then concludes that “it would have been obvious to one having ordinary skill in the art to derive a metric indicating cost or efficiency for each space layout in order to enable building planners Appeal 2019-006143 Application 14/327,124 16 to objectively compare the space layouts.” Id. Appellant argues, [W]hile it may be well known to determine costs or efficiency of space layouts, it is not well known to perform comparison operations to compare a first space layout to a second space layout where the second space layout is generated from a second BIM (building information model) comprising a second set of space constraint data associated with a second space. It is also not well known to generate a set of space utilization metrics associated with the first space layout and the second space layout based upon the comparison operations. Appeal Br. 6. The Examiner does not adequately explain, and it is not apparent to us, where “performing comparison operations” is taught or suggested in the combination of Nagy, Hassanain, Liggett, Rasane, and the Examiner’s Official Notice, where “the performance of the comparison operations generat[es] a first set of space utilization metrics respectively associated with the first space layout and the second space layout.” While the Examiner finds that it would have been obvious to derive a metric for each space layout in order to enable a comparison of the space layouts (see Final Act. 23), the claim limitation requires that performance of the comparison operations generates the space utilization metrics. For the foregoing reasons, we do not sustain the Examiner’s rejection under 35 U.S.C. § 103 of dependent claims 10 and 16. Appeal 2019-006143 Application 14/327,124 17 CONCLUSION We affirm the Examiner’s rejection of claims 7–20 under 35 U.S.C. § 101. We affirm the Examiner’s rejection of claims 7–9, 13–15, 19, and 20 under 35 U.S.C. § 103. We reverse the Examiner’s rejection of claims 10 and 16 under 35 U.S.C. § 103. Because we have affirmed at least one ground of rejection with respect to each claim on appeal, the Examiner’s rejection of claims 7–20 is affirmed. See 37 C.F.R. § 41.50(a)(1). DECISION SUMMARY In summary: TIME PERIOD FOR RESPONSE 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). AFFIRMED Claims Rejected 35 U.S.C. § References/ Basis Affirmed Reversed 7–20 101 Eligibility 7–20 7–9, 13–15, 19, 20 103 Nagy, Hassanain, Liggett, Rasane 7–9, 13–15, 19, 20 10, 16 103 Nagy, Hassanain, Liggett, Rasane, Official Notice 10, 16 Overall Outcome 7–20 Copy with citationCopy as parenthetical citation