PTAB - Cisco Systems, Inc. v. C-Cation Techs., LLC - Declines to Consider Declaration Arguments

This week the Patent Trial and Appeal Board (PTAB) designated Cisco Systems, Inc. v. C-Cation Techs., LLC, IPR2014-00454 (Paper 12)(Aug. 29, 2014) an informative opinion. In the opinion, an expanded five-judge panel denied Cisco's petition for inter partes review, because the petition was not likely to prevail against a single claim. The opinion stated the petition position for unpatentability was not sufficiently explained and merely cited to some parts of a 250-page declaration. The cites were characterized as prohibited incorporation by reference and an attempt to sidestep the 60-page limit on inter partes review petitions.

The opinion suggests to me to institute inter partes review requires the petition not the declaration do the "heavy lifting" and the last place to look for help in supporting conclusory arguments is the currently overloaded PTAB.

Copyright © 2014 Robert Moll. All rights reserved.

Legal Times - CEO, IP expert: ‘Crowdsourcing’ improves exam process, makes for stronger patents

Tonight, I recommending Jessica M. Karmasek's Legal Times article: CEO, IP expert: ‘Crowdsourcing’ improves exam process, makes for stronger patents.

Copyright © 2014 Robert Moll. All rights reserved.

USPTO - New Website - Beta Version

The USPTO announced its new website this week:

"The USPTO encourages you to explore the public beta version of its new website. The site is part of the agency’s rollout of “Next Generation” technologies that will improve the experience of doing business with the USPTO.

In developing the new site, we met with hundreds of users—both frequent and new visitors to the site—to learn what information they look for and study how they attempt to find it. We conducted an in-depth analysis of site navigation, extensive user experience testing of the new design, and wide-ranging best practices comparisons. The new navigation makes it easier to access services and accomplish tasks. Users will no longer need to be familiar with the USPTO’s organizational structure in order to find the content they’re looking for. The site will also become increasingly mobile friendly as we add new functionality, making it more convenient than ever to work with the USPTO.

The site is easy to use for everyone. Each tab features links for beginners, but expert users can turn to the Quick Links feature for instant access to the tools they need. Further, you can still access detailed information about the agency in the About Us section. During the beta period, the old site will continue to be available in parallel with the new site.

We are excited about this work in progress, and your feedback will help us ensure a final product that best meets your needs. Take a look around, and tell us what you think. Find a link to the feedback site within the yellow banner at the top of any page on the beta site."

Copyright © 2014 Robert Moll. All rights reserved.

USPTO - IP Stakeholders Discuss Harmonization of Substantive Patent Law at USPTO Roundtable

If you are interested in international patent harmonization, you should read the USPTO's Chief Policy Officer and Director for International Affairs Shira Perlmutter's post:

"On Wednesday, November 19, 2014, the USPTO hosted a roundtable on International Harmonization of Substantive Patent Law at our headquarters in Alexandria, Virginia. Roundtables like this one are essential tools for the USPTO to hear and understand stakeholder views on key intellectual property topics and their effects on various stakeholder and public policy interests, and we were glad to have a broad representation of stakeholders join us for the event.

In her opening remarks, Deputy Under Secretary of Commerce for Intellectual Property and Deputy Director of the USPTO Michelle K. Lee said that although the USPTO and offices around the world have in recent years invested significantly in work sharing, the lack of harmonized laws related to key examination issues remains a barrier to more efficient and effective reuse of work. These key issues include the definition and scope of prior art, the grace period, as well as issues related to conditions for patentability, including novelty and obviousness.

Following Deputy Under Secretary Lee’s remarks, Commissioner for Patents Peggy Focarino introduced patent experts from the USPTO, the Japan Patent Office, the European Patent Office, and the U.K. Intellectual Property Office, who presented reports on the results of recent surveys on specific harmonization issues, including the grace period.

The roundtable discussion that followed was moderated by Robert Armitage, former General Counsel for Eli Lilly and Company, and featured panelists representing a broad spectrum of U.S. stakeholder interests, including: Q. Todd Dickinson, former USPTO Director; Herb Wamsley, Executive Director, Intellectual Property Owners Association of America; Hans Sauer, Associate General Counsel, Biotechnology Industry Organization; and James Love, Director, Knowledge Ecology International.

The panelists gave their views on the importance of harmonization and its impacts on stakeholders and the public, and indicated a willingness to be flexible in achieving workable compromise solutions. We will use this input and the position of flexibility as we work with partner offices to determine an appropriate course to decrease work sharing barriers.

Throughout the next year, the USPTO Office of Policy and International Affairs will work closely with our international counterparts in Group B+, our group in the World Intellectual Property Organization (WIPO), to establish a clear path forward in patent law harmonization. Read Deputy Director Lee’s remarks to the heads of Group B+ offices at WIPO, September 23, 2014 in Geneva, Switzerland.

Learn more about the Roundtable on International Harmonization of Substantive Patent Law or watch the webcast."

Copyright © 2014 Robert Moll. All rights reserved.

USPTO - 2014 Interim Guidance on Patent Subject Matter Eligibility

The USPTO has published the 2014 Interim Guidance on Patent Subject Matter Eligibility (Interim Eligibility Guidance) for examiners to use when determining subject matter eligibility under 35 U.S.C. 101 in view of U.S. Supreme Court decisions, including Alice Corp. v. CLS Bank, Association for Molecular Pathology v. Myriad, and Mayo Collaborative Serv. v. Prometheus Labs., Inc..

"The Interim Eligibility Guidance supplements the June 25, 2014 Preliminary Examination Instructions issued in view of Alice Corp. and supersedes the March 4, 2014 Procedure for Subject Matter Eligibility Analysis of Claims Reciting or Involving Laws of Nature/Natural Principles, Natural Phenomena, and/or Natural Products issued in view of Mayo and Myriad."

The USPTO expects to update the guidance in view of cases and in response to public feedback and gave the following claims to illustrate the analysis in the Interim Eligibility Guidance: Nature-Based Product Examples and promises to follow with abstract idea examples soon.

The USPTO is also seeking public comments:

"The USPTO is interested in receiving public feedback on the Interim Eligibility Guidance and the claim examples.  Comments may be submitted in writing.  Additionally, a public Eligibility Forum will be held where stakeholders will have an opportunity to provide oral feedback.  Details on submitting written comments and attending the Eligibility Forum follow below.

Any member of the public may submit written comments on the Interim Eligibility Guidance and claim example sets by electronic mail message over the Internet addressed to 2014_interim_guidance@uspto.gov.  Electronic comments submitted in plain text are preferred, but also may be submitted in ADOBE® portable document format or MICROSOFT WORD® format.  The comments will be available for public inspection here at this Web page.  Because comments will be available for public inspection, information that is not desired to be made public, such as an address or a phone number, should not be included in the comments.  Comments will be accepted until March 16, 2015.

A public forum will be hosted at the Alexandria campus of the USPTO on Jan. 21, 2015, to receive public feedback from any interested member of the public.  The Eligibility Forum will be an opportunity for the Office to provide an overview of the Interim Eligibility Guidance and for participants to present their interpretation of the impact of Supreme Court precedent on the complex legal and technical issues involved in subject matter eligibility analysis during examination by providing oral feedback on the Interim Eligibility Guidance and claim example sets.  Individuals will be provided an opportunity to make a presentation, to the extent that time permits.

Date and Location:  The Eligibility Forum will be held on Jan. 21, 2015, from 1pm – 5pm EST, in the Madison Auditorium North (Concourse Level), Madison Building, 600 Dulany Street, Alexandria, VA 22314. The meeting will also be accessible via WebEx.

Requests for Attendance at the Eligibility Forum:  Requests for attendance to the Eligibility Forum should be submitted by electronic mail through the Internet to 2014_interim_guidance@uspto.gov by JAN. 9, 2015.

Requests for attendance must include the attendee's name, affiliation, title, mailing address, and telephone number.  An Internet e-mail address, if available, should also be provided. When requesting attendance, individuals should indicate whether they wish to make a formal presentation.  The Office will attempt to accommodate all persons wishing to make a presentation, but may need to limit the length or number of presentations given time constraints.  Individuals will be notified of accepted requests for attendance by the USPTO no later than one week prior to the date of the meeting.  Space is limited.  Accordingly, it may not be possible to accommodate all requests, and only those with an accepted attendance request will be permitted to attend.  If necessary, non-accepted requesters will be notified by the USPTO.  The meeting will also be accessible via WebEx. Access instructions will be posted on this page by the forum date.

In order to ensure a broad cross-section of attendees, the USPTO reserves the right to limit the number of attendees from any single organization or law firm.  Therefore, organizations and law firms must designate their official representatives."

For more information, the USPTO recommends calling Raul Tamayo at (571) 272-7728 or Jennifer Lo at (571) 272- 7640 or sending an email to raul.tamayo@uspto.gov or jennifer.lo@uspto.gov.

Copyright © 2014 Robert Moll. All rights reserved.

IP Watchdog - Secret Examination Procedures at the USPTO: My Experience with SAWS

If you are interested in the USPTO's Sensitive Application Warning System (SAWS), I recommend reading entrepreneur Devon Rolf's guest post on IP Watchdog: Secret Examination Procedures at the USPTO: My Experience with SAWS.

Does SAWS have a basis in statutory law and/or regulatory rules? The article makes it sounds like SAWS is, among other things, designed to disallow US patent applications that could generate "undue publicity" or "embarrassment." I am not sure how much latitude Congress is granting the USPTO, but perhaps the USPTO can help applicants understand how this all works.

Copyright © 2014 Robert Moll. All rights reserved.

Supreme Court - Kimble v. Marvel Entertainment - Reviewing If A Patent Licensee Must Pay After Patent Expiration

Today, the US Supreme Court granted a petition for certiorari in Kimble v. Marvel Entertainment Inc. to review if a patent licensee has an obligation to pay royalties after patent expiration.

As background, U.S. Patent No. 5,072,856 to Kimble (Kimble) relates to a Spider-Man glove, which Kimble discussed with Marvel's predecessor. Marvel decided it could make the "Web Blaster" without Kimble's help. Kimble sued for patent infringement and breach of an oral agreement. A district court granted summary judgment of non-infringement, but a jury decided Marvel breached the agreement. This led to a settlement where Marvel agreed to buy the patent and pay royalties on future sales. The patent expired but the contract required Marvel to continue to pay royalties for sales. Kimble sued for breach of contract when the settlement unraveled. Marvel filed a DJ arguing successfully that Kimble couldn't get royalties for post-expiration sales. The Ninth Circuit opinion affirmed. Kimble filed a petition for certiorari to the Supreme Court.

The petitioner asked Brulotte v. Thys Co. (1964) be overruled. Brulotte had held a royalty agreement that goes beyond patent expiration is unlawful per se. The petitioner argued "Brulotte is the most widely criticized of this Court’s intellectual property and competition law decisions. Three panels of the courts of appeals (including the panel below), the Justice Department, the Federal Trade Commission, and virtually every treatise and article in the field have called on this Court to reconsider Brulotte, and to replace its rigid per se prohibition on post expiration patent royalties with a contextualized rule of reason analysis."

Note the Solicitor General's brief advised against review, since it said Brulotte is not about competition, but the Court's interpretation of federal patent law of allowing free access to an invention after the patent expires.

Also see Marvel's opposition brief.

Copyright © 2014 Robert Moll. All rights reserved.

World’s Five Largest Intellectual Property Offices Release Annual IP5 Statistics Report

The USPTO announced the following:

"A coalition of the world’s five largest patent offices – the IP5 – recently announced the release of the 2013 IP5 Statistics Report. The Report has been designed to facilitate an understanding of operations and patent procedures among the Offices, while providing a means for gauging inventive activity, technology flow, and comparing procedures. The IP5 is comprised of the U.S. Department of Commerce’s United States Patent and Trademark Office (USPTO), the European Patent Office (EPO), the Japan Patent Office (JPO), the Korean Intellectual Property Office (KIPO), and the State Intellectual Property Office of the People’s Republic of China (SIPO).

According to the Report’s Executive Summary, the IP5 Offices granted almost 957,000 patents in 2013 – an increase of 4 percent compared to 2012. In addition, 2.1 million patent applications were filed in the IP5 Offices in 2013, which represents an 11 percent increase over the previous year.

In addition to the report itself, the IP5 offices also provide detailed statistical data sheets for historical numbers of patent application filings going back to the 1980s and patent grants broken down by International Patent Classification (IPC) codes and country of origin. The additional statistical data also includes an office by office comparison of fees associated with the patent process, including those associated with services by the World Intellectual Property Organization (WIPO).

The IP5 Offices, which together handle about 89 percent of the world’s patent applications, began meeting in 2007. They have since worked together to explore ways to further optimize joint efforts to improve quality and efficiency of the examination process and to explore and optimize work sharing opportunities between the Offices.

The IP5 Statistics Report was first released in 1983 as a project of the Trilateral Cooperation –EPO, JPO, and USPTO. In 2008, KIPO joined the effort and the first Four Office Statistics Report was produced. The 2011 IP5 Statistics Report represented a milestone in IP5 cooperation, encompassing the full cooperation of all the IP5 Offices including SIPO. The IP5 Offices intends to continue holding discussions on statistics and improving IP5 cooperation for next year’s Statistics Report."

Copyright © 2014 Robert Moll. All rights reserved.

Professor Robin Feldman - Transparency - US Patent Ownership

If you are interested in the problems arising from the ability to hide US patent ownership, I recommend reading Professor Robin Feldman's article Transparency proposing regulation borrowed from corporate securities law to identify the owners of US patents. Professor Feldman asks: "Who stands to win and lose when a patent system created to foster innovation is being utilized to hide and distort patent ownership?"

From the abstract of the article:

"The United States patent regime is a quintessential notice system. Implicit in its design is the concept that one attempting to license a patent can identify those who hold the requisite rights and the territory that the patent holders claim as their own. As the system has evolved, however, it bears little resemblance to the idealized form. Little scholarship has addressed problems related to notice within the modern patent system, largely because these problems have sprung up so recently. In the last five to seven years, an entire Hobbit’s world has been created under the foliage. Moreover, historic scholarly discussions of notice generally have focused on the role of governmental actors in ensuring that a patent can be properly understood and interpreted. In contrast, this article argues that market information is a critical element of the notice function of patents. One can think of the mechanisms for providing that market information as 'Transparency'.

To address transparency insufficiencies, one need not write on a blank slate. Rather, this article suggests borrowing from the substantial body of well-developed doctrine and literature concerning disclosure in the realm of corporate securities and explores how these doctrines could be molded to patent concerns.

The patent asset is imbued with public interest by virtue of the fact that it is a government grant, bestowed for constitutional purposes. As with the trading of public securities, the trading of an asset imbued with the public interest must be sufficiently regulated to ensure proper functioning of that trading market."

Copyright © 2014 Robert Moll. All rights reserved.

Yahoo Tech News - The US Government Has a Secret System for Stalling Patents

Tonight, I suggest reading the Yahoo News article The US Government Has a Secret System for Stalling Patents.

The article notes that documents obtained under the Freedom of Information Act (FOIA) reveal the USPTO's Sensitive Application Warning System (SAWS).has been imposing extra scrutiny and delay on any US patent application designated as containing sensitive subject matter. The USPTO may do this without publishing that the application is a SAWS case. What makes subject matter sensitive? An application might be designated if it describes (1) a business method; (2) algorithms rejected under 35 USC 101; (3) claims that might be used (i.e., infringed) by the USPTO; (4) subject matter embarrassing to the USPTO; and (5) subject matter likely to trigger media attention.

Copyright © 2014 Robert Moll. All rights reserved.

District Court Judge Orders Nebraska to Pay Patent Owners' Attorney Fees

In Activision TV Inc. v. John Bruning, the US District Court for the district of Nebraska ordered the state of Nebraska to pay $725,000 in attorney fees, because the state attorney general (AG) violated the First Amendment in sending cease and desist letters to the law firm representing two non-practicing entities: (1) stating their patent enforcement letters could be in violation of the Nebraska Consumer Protection Act; and (2) barring the law firm from initiating any new patent infringement enforcement efforts. The court held that the attorney general failed to prove the patent owners' actions were "objectively and subjectively baseless and done in bad faith."

Initially this AG's action may seem strange. But at the time the AG took action, the media blitz regarding patent trolls was in full force. Now the ruling states in so many words the AG's "strong arming" patent litigant was not saving the public from harm, but damaging the patent owner's federal rights to enforce their patents. Perhaps the judge perceived this was also little more than political grandstanding based on little or no fact investigation. Now the public whom this AG allegedly sought to protect gets to pay the patent owner's attorney fees.

Copyright © 2014 Robert Moll. All rights reserved.

Cisco Systems Sues Arista Networks for US Patent and Copyright Infringement

Cisco Systems recently sued Arista Networks alleging its networking products infringe 14 Cisco patents and a number of copyrights. Arista stock dropped -7%.

Cisco claims Arista Network's rapid ascent is due to patent infringement and extensive copying from Cisco user manuals and over 500 Cisco commands used to configure networking products. Whether any of this proves true, Arista appears to be a rising competitor which Cisco would like to slow down. Arista includes a number of key people that left Cisco, went public six months ago, and has a market valuation of nearly $5 billion. It will be interesting to see if Arista files any counterclaims.

Cisco's Mark Chandler tells us his view in Protecting Innovation: "In the thirteen years I've been General Counsel of Cisco, I can count on one hand the number of times we've initiated suit against a competitor, supplier or customer. It's therefore only after thoughtful and serious consideration that we are today filing two lawsuits to stop Arista’s repeated and pervasive copying of key inventions in Cisco products. These suits cover key Cisco proprietary patented features and Cisco's copyrighted materials."

Cisco's patent infringement complaint including patents

Cisco's copyright infringement complaint

Copyright © 2014 Robert Moll. All rights reserved.

Supreme Court - Commil USA, LLC. v. Cisco Systems - Is Defendant's Good Faith Belief of Patent Invalidity A Defense to Induced Infringement?

Yesterday, the US Supreme Court granted Commil's petition for certiorari to review the Federal Circuit decision in Commil USA, LLC v. Cisco Systems Inc.. There the Federal Circuit held a defendant's good-faith belief a patent is invalid is a defense to induced infringement under 35 USC § 271(b). The Federal Circuit stated it could "see no principled distinction between a good-faith belief of invalidity and a good faith belief of non-infringement for the purpose of whether a defendant possessed the specific intent to induce infringement of a patent."

Generally, a defendant can be liable for actively inducing (encouraging) infringement: (1) if the party induced directly infringes a patent claim; and (2) if the defendant has specific, knowing intent to encourage infringement of the patent claim which is more than intent to cause acts later held to infringe. Intent can be proven through circumstantial evidence or deliberate indifference to a known risk a patent exists.

Cisco Systems' brief in opposition

Solicitor General's brief

Copyright © 2014 Robert Moll. All rights reserved.

Federal Circuit - DDR Holdings v. Hotels.com, LLP - Software Patent Claim Held Patent Eligible

In DDR Holdings v. Hotels.com, LLP, the Federal Circuit applying Alice v. CLS Bank found a software patent claim that satisfies 35 USC 101. Here's the representative claim:

A system useful in an outsource provider serving web pages offering commercial opportunities, the system comprising:
(a) a computer store containing data, for each of a plurality of first web pages, defining a plurality of visually perceptible elements, which visually perceptible elements correspond to the plurality of first web pages;

(i) wherein each of the first web pages belongs to one of a plurality of web page owners;

(ii) wherein each of the first web pages displays at least one active link associated with a commerce object associated with a buying opportunity of a selected one of a plurality of merchants; and

(iii) wherein the selected merchant, the outsource provider, and the owner of the first web page displaying the associated link are each third parties with respect to one other;

(b) a computer server at the outsource provider, which computer server is coupled to the computer store and programmed to:

(i) receive from the web browser of a computer user a signal indicating activation of one of the links displayed by one of the first web pages;

(ii) automatically identify as the source page the one of the first web pages on which the link has been activated;

(iii) in response to identification of the source page, automatically retrieve the stored data corresponding to the source page; and

(iv) using the data retrieved, automatically generate and transmit to the web browser a second web page that displays: (A) information associated with the commerce object associated with the link that has been activated, and (B) the plurality of visually perceptible elements visually corresponding to the source page.

Here's some commentary on DDR Holdings:

Michael Borella - DDR Holdings, LLC v. Hotels.com, L.P. (2014)

Gene Quinn - Federal Circuit Finds Software Patent Claim Patent Eligible

Copyright © 2014 Robert Moll. All rights reserved.

Professor Ronald Mann - Is the Patent Act more like the Sherman Act or the securities laws?

Professor Ronald Mann has a thought provoking article Is the Patent Act more like the Sherman Act or the securities laws? He discusses how the Supreme Court interprets various sections of the US Patent Act in very different ways.

As Professor Mann puts it: "In some areas, the Justices view the language of the statute as calling for them to pour judicially created content into vague and general words in the statute: the most obvious examples are patentability cases like Bilski v. Kappos, Mayo Collaborative Services v. Prometheus Laboratories, and Alice Corp. v. CLS Bank. I’d probably put the Court’s analysis of definiteness in Nautilus v. Biosig in the same pile."

"In other situations, the Court seems much more inclined to treat cases as purely statutory, to be resolved almost entirely by parsing the statute, however detailed or general it might be. Here I’m thinking of cases like Octane Fitness v. Icon and Highmark v. Allcare, cases that (in Justice Sonia Sotomayor’s words) “begin and end with” the language of the Patent Act. Limelight Networks v. Akamai Technologies – or at least Justice Samuel Alito’s explanation of the result – is another example."

In my opinion, Professor Mann is right. And we have watched the Supreme Court pour more judicial content into 35 USC 101. But why not resolve software patent eligibility standard by parsing the literal broad terms of 35 USC 101? I know talk about 150 years precedent, but also consider when Benson added an abstract idea exception to the broad language of 35 USC 101, the Supreme Court in effect wrote a "narrower 35 USC 101." Justice William Douglas apparently was seeking to not allow wholly preempting mathematical algorithm and expressed that patenting of software programs in general was a policy question and the Court was not competent to decide.

Further, Justice Douglas stated: "If these programs are to be patentable, considerable problems are raised which only committees of Congress can manage, for broad powers of investigation are needed, including hearings which canvass the wide variety of views which those operating in this field entertain. The technological problems tendered in the many briefs before us indicate to us that considered action by the Congress is needed."

It has been a while since the suggestion was made, but it seems maybe this is where the entire issue needs to go now-- before Congress.

Copyright © 2014 Robert Moll. All rights reserved.

Robert Sachs - The Day the Exception Swallowed the Rule: Is Any Software Patent Eligible After Ultramercial III?

In The Day the Exception Swallowed the Rule: Is Any Software Patent Eligible After Ultramercial III? Robert Sachs argues that the Federal Circuit misinterpreted the US Supreme Court's Alice v. CLS Bank decision on patent eligibility under 35 USC 101.

It is encouraging to read a patent attorney eloquently point out the flaws in the Federal Circuit's decision rather than concede, but these type of arguments must be presented before the Federal Circuit not just posted in a blog to change its understanding of software patent eligibility.

Copyright © 2014 Robert Moll. All rights reserved.

After Alice v. CLS Bank - Software Patent Eligibility & 3D Printing?

In evaluating the impact of Alice v. CLS Bank it is important to recognize that "all software is not created equal."

1. In both Alice and Bilski, the US Supreme Court held business methods are not categorically excluded and patent ineligibility arose from improperly claiming an "abstract idea." Yet lower courts are interpreting Alice as nearly always preventing patent eligibility of business methods. Thus, you may get a business method patent in the USPTO, but expect both issuance and enforcement to be a challenge.

2. Non-business method software patents are still issuing in great numbers. In Patent Reform: Impact of Alice on Business Method Professor Dennis Crouch observes a chart in James Bessen's article that indicates a slow-down in issuance of business methods, but no decline in other software categories.

3. Software invention claimed properly in conjunction with a physical process are not likely to held an abstract idea under Alice v. CLS Bank. For example, Diamond v. Diehr held a method for curing synthetic rubber including steps using a mathematical formula and a programmed digital computer was patentable subject matter under 35 U.S.C. §101.

4. US patent claims like those in Diamond v. Diehr will issue may play a role in 3D printing technology because a great patent portfolio define the industry leadership.

Here's some commentary on what other attorney's think:

In 3-D Printing: Challenges and Opportunities (Part I), Michael Rosen describes how 3-D printer technology likely relates to IP and patents in the US.

In Many 3D Printing Patents Are Expiring Soon: Here’s A Round Up & Overview of Them, John Hornick and Dan Rowland discuss key 3D printing patents that are expiring and the recently settled 3D Systems v. Form Factor case.

In Formlabs, 3D Systems settle their 3D printing patent battle, Signe Brewster notes the 3D Systems v. Form Factor settlement after two years of litigation, but cautions that startups should not draw too much comfort given the patenting efforts in this industry.

Copyright © 2014 Robert Moll. All rights reserved.