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Supreme Court ruling makes “obvious” patents harder to defend

In a decision issued today, the US Supreme Court reinvigorated the "obviousness test" used to determine whether a patent should be issued. Ruling in the case of KSR v. Teleflex, the Court found that the US Court of Appeals for the Federal Circuit, which handles patent appeals, had not been using a stringent-enough standard to determine whether a patent was infringing. HangZhou Night Net

At issue in KSR v. Teleflex is a gas pedal manufactured by KSR. The pedal has an electronic sensor that automatically adjusts its height to the height of the driver. Teleflex claimed that KSR's products infringed on a patent it held. KSR said that Teleflex's patent combining a sensor and a gas pedal was one that failed the obviousness test, and as such, should not have been granted.

Patent law appeared to be on KSR's side: 1952 legislation mandated that an invention could not be patented if a "person having ordinary skill in the art" would consider it obvious. KSR argued that the US Patent and Trademark Office should have denied Teleflex's patent, as it only combines components performing functions they were previously known to do. However, the Federal Circuit had adopted a higher standard, ruling that those challenging a patent had to show that there was a "teaching, suggestion, or motivation" tying the earlier inventions together.

KSR had plenty of support from the likes of Intel, Microsoft, Cisco, and GM, while Teleflex's supporters included GE, 3M, DuPont, and a number of other companies concerned that some of their patent holdings would be harmed should the Court side with KSR.

SCOTUS found KSR's arguments convincing, ruling that the Federal Circuit had failed to apply the obviousness test. "The results of ordinary innovation are not the subject of exclusive rights under the patent laws," Justice Anthony Kennedy wrote for the Court. "Were it otherwise, patents might stifle rather than promote the progress of useful arts."

The Supreme Court also said that the Federal Circuit's conception of a patent's obviousness was too narrow. "The Circuit first erred in holding that courts and patent examiners should look only to the problem the patentee was trying to solve," according to Justice Kennedy's opinion. "Second, the appeals court erred in assuming that a person of ordinary skill in the art attempting to solve a problem will be led only to those prior art elements designed to solve the same problem."

The end result is that Teleflex's patent has been invalidated and more importantly, the Federal Circuit will now have to pay closer attention to a patent's obviousness. That may be good news for Vonage in its appeal of a court's decision that its VoIP service infringes on three Verizon patents. Our analysis of the patents indicates that they, too, may fail the obviousness test.

More importantly, the Supreme Court ruling is good news for a patent system in dire need of fixing. New legislation introduced to Congress a couple of weeks ago is another attempt at a fix. The bill would streamline the patent appeal process while switching the US patent system from a first-to-invent to a first-to-file system. It would also cap the amount of damages that could be awarded for infringing patents.

Talk to the hand: chimps, bonobos and the development of language

Regardless of one's feelings regarding zoos, it doesn't take much time spent in the primate house to come away with a feeling of kinship to our closest living relatives. Although not human, we recognize in chimpanzees and bonobos some of the same traits we display. HangZhou Night Net

It's not an observation that escapes biologists, either. Researchers are often interested in the common behaviors and traits we share with other higher primates to give us clues as to the evolutionary origins of human intelligence. A new study published this week in PNAS from scientists at the Yerkes National Primate Research Center has looked at the use of hand gestures by chimpanzees and bonobos as a form of communication. The idea behind this study is to gain a better understanding of the roots of human language development.

Although both species of primate use vocalizations and facial expressions to communicate, they also use hand gestures. Unlike the vocalizations and facial expressions, however, hand gestures don't mean the same things to both chimpanzees and bonobos. They stem from, and are interpreted by, different parts of the brain.

The study involved looking at the different facial/vocal and manual displays from two groups of bonobos and two groups of chimpanzees. The researchers identified 31 different manual gestures, and 18 facial/vocal displays that related to a range of different behavioral activities such as grooming, feeding, playing, and so on. It turns out that the facial/vocal displays could be recognized regardless of whether the viewer belonged to the same group or even species.

But when it came to hand gestures, most interpretations were specific to individual groups; a chimpanzee from one group would not be expected to know that a certain hand signal used by group A meant "please groom me." Hand signals were also found to be context dependent: "A good example of a shared gesture is the open-hand begging gesture, used by both apes and humans. This gesture can be used for food, if there is food around, but it also can be used to beg for help, for support, for money and so on. It's meaning is context-dependent,"said Frans de Waal, one of the authors of the paper.

I'm most interested by the commonality of certain hand gestures between these ape species and ourselves; the begging example given above, for one. It seems that some aspects of our behavior have been hard-wired in since before the human race could have been said to exist.

For developers, Windows Live now means business

Microsoft wants to be a part of the next great web startup. This week at MIX07, the company modified the terms of its Windows Live application programming interface (API) license so that small businesses could freely use the services. HangZhou Night Net

The overview of the new license is as follows:

Microsoft is enabling access to a broad set of Windows Live Platform services with a single, easy-to-understand pricing model based on the number of unique users (UUs) accessing your site or Web application. These terms are intended to remove costs associated with many Web applications and provide predictable costs for larger Web applications. There are some exceptions to the UU-based model: (1) Search: free up to 750,000 search queries/month, (2) Virtual Earth: free up to 3 million map tiles/month; and (3) Silverlight Streaming: free up to 4GB storage and unlimited outbound streaming, and no limit on the number of users that can view those streams.

According to the terms of use, if a site has over 1 million unique users, it will be charged US$0.25 per unique user per year or it must share a portion of its advertising revenue with Microsoft. Search and Virtual Earth do not apply to in this scenario as commercial agreements are necessary when the limits of the two services are reached.

According to Microsoft, the license restructuring has been done to show that the company can and does support small businesses. Whitney Burk, a spokesperson for Microsoft's Online Services Group, said that Microsoft wants to be there when the next great startup company emerges. "We're saying to all those small guys out there, bet your business on Microsoft. If you become the next YouTube, great news for you and great news for us."

Because some of the underlying services provided by the APIs are still in beta, Microsoft is currently not enforcing the new pricing schema. However, even with the fee, the APIs are still a bargain. The two that I've used the most, Search and Virtual Earth, have clear documentation, excellent examples, and are straightforward to use.

With the new terms of use in place, businesses will be able to create and profit from their Windows Live mashups, and I wouldn't doubt that companies will create applications far more powerful than anything available in Windows Live right now. As a matter of fact, I'm predicting that Windows Live will almost solely be made of APIs in two years.

PC gaming? The rumors of its death are highly exaggerated

It seems like a lot of attention is focused on console gaming these days, and for many companies, that's where the easy money is. The problem with this focus is that it limits your audience; a more casual game that requires little in the way of hardware power can tap into the largest market in the world: the non-enthusiast PC. Everyone has one in the home, and while we don't all have $300 video cards, it's not hard to find a game or two that will run on modest systems. Of course, if you're willing to spend the money, the PC is also the most powerful gaming platform on the market. It's an adaptive system for games, and therein lies its strength. The New York Times just took a look at the new popularity of PC gaming, focusing on this two-pronged attack. HangZhou Night Net

Anita Frazier, an industry analyst for the NPD Group, a market research firm, noted that in the first two months of 2007, domestic retail sales of PC games reached $203 million, a 48 percent increase over the $136.8 million in the period a year earlier. She noted that these figures do not include revenue generated by PC game sales online, or online subscriptions to play PC games.

“Yes, it does look like a fluke, doesn’t it?” Ms. Frazier said. “Rest assured it’s not.”

World of Warcraft and RPGs are doing a lot to fuel this trend, and Microsoft is pushing their Games for Windows initiative to make PC games more visible at retail and easier to run via Vista. Hook up the 360 controller and you have an experience that's very console-like, in fact. Add to that Microsoft's plan to bring Live to the PC and you have a strong push to get customers back into PC gaming.

PC gaming always has its ups and downs, but it's nice to see the mainstream media take note of one of the upswings.

The hunt for the rarest Pok?mon of all: the game itself

I'm ashamed to admit that I had almost completely forgotten about a monumental event. The first full Pokémon title for the DS and the nearly-guaranteed million copy seller had launched on Sunday and I was oblivious, leaving me without a preorder. Needing to grab a copy for the upcoming review, I was left with little choice but to begin an adventure of epic proportions to scour local retailers for a copy of the game. HangZhou Night Net

I instantly started to ring up the local Electronics Boutiques. At store after store I was shot down, laughed at, and immediately rejected: there was nary a free copy of the game to be found. Most of the EBs told me the same thing: all they got were their preorders shipment. The number of preorders was staggering: one store had even remarked that they'd already handed out almost 100 copies between yesterday and today. The Pokémon money-making machine was in full effect, and it appeared that I was to go without my fix of the little critters for at least a week.

And so the hunt began. As though I were the mother of a crying child, I couldn't accept defeat at the hands of EB, and so I left to traverse the entire greater metropolitan Toronto area. Circuit City, Zellers, Walmart, The Source, Microplay, Futureshop, and countless mom-and-pop game stores: no one could provide me with the drug I so fiendishly sought. A 22-year-old man rapt by the whims of small imaginary creatures; the sting of each denial of the product was second only to the strange looks and laughs that my dedication to the creatures had rendered. Everywhere I went, stares followed. "It's for you?" they'd question, to which I would reluctantly reply, "Yes." Upon leaving the third local Walmart, I finally decided to just give up and admit defeat: I'd missed my chance for Poké-glory.

As I drove home in somber silence, I noted a Best Buy along the way. With but a glimmer of hope still left in my mind, I decided to throw caution to the wind and veered into the parking lot. I approached the automatic doors of my destiny with hesitation. Carefully and slowly, I wandered through the fearful aisles of the mega-store until I fell upon the game section. And there it was: shining in all its diamond glory, one final copy of Pokémon Diamond. Hand quaking with anticipation, I reached forward, plucked the title from its nesting place and ran to the counter as though I were a four-year-old boy. Glory was mine, as soon would be every trainer badge in the city.

Through rain, sleet and hail of the Canadian mock-spring, I returned home. I've now chosen my starting Pokémon—Turtwig—and my adventure is about to begin. Next time you hear from me, I'll be a Poké-master. Keep your eyes out for the full review in two days. Until then, wish me luck: it's time Poké-battle.

Will Leopard usher in the era of Blu-ray?

Over at Spymac Michael Simon retells the story of high-definition video on the Mac, starting with Steve Jobs' proclamation that 2005 would be the "year of HD." HangZhou Night Net

Apple's video editing software, even at the low end in the form of iMovie, has had HD support for some years. DVD Player (mysteriously not updated a week ago along with the rest of the Final Cut Studio suite) will play HD content burned to regular DVD media and DVD Studio Pro will even author HD DVD projects, but no Blu-ray so far, even though Apple is on the board of directors of the Blu-ray Disc Association. In the Spymac article, Michael Simon speculates that the delayed Leopard release could pave the way for Blu-ray compatible Macs by the end of the year:

And now, as it becomes increasingly clear that iLife's delay is directly related to Leopard's, I expect to see a late fall event to usher in native Blu-ray support in OS X, along with an internal drive option for the iMac and MacBook Pro, at the very least. Rather than relegating Blu-ray to the most expensive Mac, like Apple did with the SuperDrive, I think the lower-end models will get the next-generation optical drives first, as Apple looks to bring high-end video production to masses.

He talks about HD video production, not consumption. But are consumers going to be interested in the ability to burn their own projects to expensive Blu-ray discs when players for these discs are still sparse? Also, HD cameras are still priced well above what the average consumer is prepared to pay to film the kids' antics. There are three problems with Blu-ray and HD DVD that could have something to do with why Apple hasn't offered any HD drives yet.

    Price and availability: last year, Sony couldn't supply as many PS3s as it wanted to, because the blue lasers that power Blu-ray (and HD DVD) were in short supply. Currently, the drives are still expensive.DRM: playing back Hollywood content from an HD disc requires heavy DRM, including HDCP protection of the DVI or HDMI link to the display, which Apple's computers and displays do not yet support.The format war: Blu-ray is gaining ground on HD DVD in the US, but HD DVD is doing better in Europe. There is still no clear winner.

However, each of these problems could be reduced in scope by the time that we have Leopard in our hands. Prices going down is a given; Intel's new GMA3000 graphics chips support HDCP, and Blu-ray is outselling HD DVD (in the US). But what Apple's strategy is going to be will be hard to predict. They could adopt the ability to burn HD discs across the board, but I expect this will cut into their margins too much for the lower-end Macs. Being able to play HD discs across the board with burners in the higher-end models would be a sensible alternative. Or if the situation with price, DRM and the format war doesn't improve enough, Apple may only offer the ability to burn and read HD discs—without being able to play protected content—as a built-to-order or external option. This would be good enough for those of us who author HD projects or burn massive amounts of data to optical discs.

Fujitsu debuts e-paper tablet device (updated)

At some point, I'm going to write my very last e-paper/e-ink article for Ars. After almost a decade of thin, flexible, low-power displays being "three to five years away," I can finally see that the time for e-paper's mass-market debut is almost upon us. A case in point is Fujitsu's new FLEPia portable tablet, samples of which are now available in limited supply as of this past Friday. HangZhou Night Net

FLEPia boasts an array of impressive features, starting with its display. The device is based on Fujitsu's e-paper technology, a technology that the company announced over two years ago. In a nutshell, Fujitsu's e-paper works by sandwiching a thin layer of liquid crystal between two sheets of plastic. The application of an electrical charge causes a pixel of the liquid crystal to change states from clear to opaque, with the result that multi-pixel displays require energy only when the image is changed. Red, green, and blue layers of the material are fused together to make color versions of the display that can output either 8 or 4,096 colors.

This display technology, which appears as an XGA touchscreen in the FLEPia device, is backed by pretty standard PDA-level hardware: an Intel XScale processor, an 802.11b/g card, USB 2.0 support, a headphone jack, an SD card, and so on. The tablet runs Windows CE 5.0, and its battery can stand up to 50 hours of usage.

With a physical profile right out of Star Trek and a lightweight, color e-paper-based display that comes in standard paper sizes (A4 and A5), it might seem at first that FLEPia means that e-paper is now just another display technology. And if it's just another display technology, then I can quit writing about e-paper, right? Well, no.

The A5 and A4 models that were announced on Friday carry price tags of $1,264.85 and $2,107.81, respectively. According to Fujitsu, these things won't hit consumer-level price points until at least 2010, which puts them… yep, three to five years away.

Oh well. At least the Sony Reader has finally brought e-ink to the mass market. Of course, judging by reviews, the monochrome device is hobbled by a number of implementation issues that make me want to steer clear of it for the time being. Maybe by the time Sony fixes the problems to the point where they can nail the "mass" part of "mass market," Fujitsu or someone else will be further along with a potential competitor.

Update: The price originally quoted was for lots of ten, and not individual units. This was by all accounts clearly marked on the Japanese press release, but not being a reader of Japanese I didn’t catch it. The correct prices have now been included.

H. pylori infection might protect against asthma

The topic of H. pylori and ulcers is one we've covered a few times here at Nobel Intent. Back in 2005, an antipodean duo received a Nobel Prize for their work that showed that this bacteria could cause ulcers, and more recently there has been work that has shown that H. pylori has been with us since our earliest days as humans. HangZhou Night Net

Now, a new paper published in the Archives of Internal Medicine* has identified a putative new role for this bug, and it's a beneficial one. H. pylori infection is endemic across the developing world but not so in the industrialized nations, and its prevalence in this group of countries decreases with each generation.

Gastroeosophogeal reflux disease (GERD) is on the increase in the developed world, as is asthma. There is also a link between them; asthma patients are twice as likely to suffer from GERD as non-asthmtics, and it's believed that the stomach acid causes lung injury. It might not seem obvious, but H. pylori infection is actually thought to be protective against developing GERD.

This new study utilizes data collected from the Third National Health Nutrition Examination Survey (NHANES III), which ran from 1988-1994 and included around 40,000 individuals. The researchers at the New York University School of Medicine looked for patients that tested positive for H. pylori, and for the more virulent strain, known as CagA. They found that there was an inverse correlation between H. pylori infection and asthma prevalence, with this link being strongest for those who had the CagA strain; they were 20 percent less likely to have ever been diagnosed with asthma than uninfected individuals. The study also identified a link between H. pylori and protection against sensitivity to allergens, another factor involved in asthma.

Additional studies are required to elucidate the mechanism behind a protective role for H. pylori in asthma, but it's certainly an intriguing notion.

*Arch Intern Med. 2007;167:821-827.

Counter-factual computation is counter-factual

Last year we reported on a Nature paper that purported to show that a light-based quantum computer could make a calculation, even when no light entered the computer. To summarize; light entered the computer and was split so that half traveled down one path (path A), and half down a second (path B). The light in the second path enters the device that actually performs the computation, which also splits the light so that some travels along a third path (path C). The computation is performed by changing the distance light must travel along the third path. The three paths of light are then sequentially recombined. The upshot is that results can be obtained, even when the photon is known to have never entered the part of the computer that performs the calculation—counter-factual computation. HangZhou Night Net

Research published this month in Physical Review Letters shows that this is not really the case. If one carefully examines the chance of finding the photon in each path during the computation, a paradox is quickly revealed. The idea is that the entrance to the computer preselects a set of photon states and the exit of the computer post-selects from the preselected states. The upshot is that if the photon didn't pass through the either paths B and C, it couldn't have entered the computer at all.

This is not to say that Horsten et al wasted their time. Their experimental results have revealed an interesting paradox, which throws some light on the effects and limitations of quantum non-demolition measurements—measurements that don't actually make a measurement. As an aside, the author notes that the Bohmian interpretation of quantum mechanics does support quantum counter-factual computation. This may mean that there is fruitful line of experimental work that might distinguish between the standard interpretation of quantum mechanics and Bohmian mechanics opening up.

Former Apple General Counsel in hot water with the SEC

There has been a lot of allegation and investigation in the Apple stock options backdating probe, but it appears the SEC is getting ready to throw the book at a few people for the roles they apparently had in the backdating. In particular, the SEC looks to be taking action against Apple's former General Council Nancy Heinen and former CFO Fred Anderson. HangZhou Night Net

While backdating of stock options isn't necessarily illegal, in this case it does appear to have been done illegally. In particular, Heinen is alleged to have approved the forging of documents involved in the backdating of the options. Rather unsurprisingly, forged documents make backdated options illegal, so Ms. Heinen may have a hard time mounting a defense. She is also implicated in another backdating transaction which she and Fred Anderson benefited from, along with a number of other Apple executives. In this case, Heinen and Anderson chose to backdate options and chose the date as well. This means that they earned more from the options than they should have, which the SEC also doesn't like.

It's important to note that these aren't criminal charges—only securities fraud charges brought by the SEC. But these charges are still a fairly big deal, as getting in trouble with the SEC isn't a good thing… particularly if you're a CFO, since the penalties range from fines to restrictions on what jobs you can hold. Both Heinen and Anderson are arguing that they were merely following the instructions of other board members, and/or that they weren't familiar with the rules for backdating. Given that Heinen was the general counsel, I would expect her to be familiar with the rules; and after the Enron and related scandals, I suspect that both defenses won't hold very much weight with the SEC.

Presidential debates to go online in 2008: will it matter?

Some debates between presidential candidates will be going online in 2008 in an entirely new format, according to the Associated Press. Questions for the candidates will be submitted in advance by the general public. The candidates will then debate with each other "live" via individual cameras from their respective locales and hosted online, where viewers will be able to comment and blog realtime in response to the candidates' answers. HangZhou Night Net

The decision to host an online presidential debate sprung out of a partnership between political blog The Huffington Post, Slate Magazine, and Yahoo! The brain and name behind The Huffington Post, Arianna Huffington, contacted Slate editor Jacob Weisberg and PBS host Charlie Rose to get the ball rolling. "It was clear to me, the 2008 campaign was going to be dominated by what's happening on line — new technologies, new media like never before," she told the AP.

The debates will be hosted and produced by Yahoo!, with Rose moderating, and Huffington and Weisberg organizing the event.

Huffington, Weisberg, and Yahoo! maintain that the online format will change how the debates, and the candidates, are viewed by the public. Yahoo!'s Scott Moore told the AP that he feels the online debates will be "a really significant, historic opportunity for the candidates to test their debate skills in a brand new format."

But is it really that revolutionary to take the tired, old and broken "debate" format and slap it up online?

Not quite there

When speaking to the AP, Moore compared the change in formats to the first televised debates between Kennedy and Nixon—members of the public who watched the debates on TV had a much different view who had "won" than those who had listened to it on the radio. But the technical difference in format, from TV to the Internet, won't be as drastic of a change—the debates will still be presented as videos for viewers to watch, just like they were before. In fact, aside from no longer being in the physical presence of one another, it doesn't seem that there will be much difference at all.

Sure, candidates will be addressing questions from denizens of the Internet, but this "town hall meeting" style isn't new, either. If candidates' responses have become so preplanned and scripted that presidential debates in general have become nothing more than a traditional dog and pony show, how will taking filtered questions from online readers change that?

Don't get me wrong, these new and improved debates could seize an opportunity to enliven the communication style of the discussion. What would make the presidential debates much more interesting to citizens of the 'Net would be to allow viewers to ask questions realtime—moderated, of course—of the candidates and have them answer right then and there, with no pre-approved topics. That seems like an unlikely situation, though, as it would be taking the candidates too far out of their strategic comfort zones.

But that's exactly what this whole "online" thing is supposed to be about, is it not? For presidential debates to truly be worthwhile online events, we'd like to see realtime communication, flowing in two directions. We'd like to see users not only ask the questions, but also be able to follow-up to the answers. Maybe then someone might point out when these politicians have dodged the questions or flubbed their numbers. Do you think we'll ever see a candidate get down and dirty, arguing online through true blogs, chat rooms, and forums sans kid-gloves moderation?

Microsoft triples number of security labs

With the Forefront Client Security product schedules to be released next month, Microsoft has decided to open two additional centers to increase its ability to detect and address software flaws. InformationWeek is reporting that the two new labs will be located in Dublin and Tokyo and will concentrate in creating signatures to assist administrators in the detection and removal of malicious programs. HangZhou Night Net

Until now, Microsoft has only had a single location for this kind of research, located on its Redmond campus. Now that the company is pushing hard into both the home user security market with its struggling Windows Live OneCare, and businesswith Forefront, an integrated suite ofcombined antivirus and antispyware solution for desktops and servers, it is starting to invest more resources into early detection for exploits. In the past most security problems with Microsoft software have come to light when third parties have posted abouttheir existence or even offered code which enabled malicious users to take advantage of the flaws. Perhaps now we will see a shorter time between the time problems are documented and when Microsoft releases a patch to mitigate the problem.

Other software security companies like McAfee and Symantec have invested heavily in centers that monitor the Internet for suspicious activity or look for flaws with new software—Microsoft is just following suit. What I'd like to know isif those of us who do not use Microsoft's security products but still use their other software will reap the benefits from the company's new efforts.This is a good chance for Microsoft to address claims that it spends too much time sitting on vulnerabilities and only fixes them once they are disclosed to the public.

DNA analysis confirms a recently described mammal is a living fossil

Because of a combination of interest and improved technology, new species have been described at a fairly high rate in recent years. But new mammals remain fairly hard to come by; perhaps one new mammalian species a year is typical, and many of these are simply variants of well-described species. That's why the discovery of the Laotian rock rat was exceptional. Although it was clearly a rodent, it was visually distinct from the rodent species we're familiar with. When video of the rat appeared, its strange gait and comfort with humans enhanced the otherworldly impression it made. What exactly was this creature? HangZhou Night Net

Its discoverers named it a new species. But a later publication suggested that the creature's strangeness wasn't because it was new, but rather because it might be old: it was proposed that the Laotian rock rat (Laonastes aenigmamus) was the last surviving member of a once-large group of rodents that was known only by fossils. Although the group had vanished from the fossil record 11 million years ago, the morphological similarities were striking. The rock rat, it was proposed, is a living fossil.

DNA sequence analysis has now joined the argument and comes down strongly in favor of the living fossil contention. Not only is the rock rat like nothing we've ever seen before, it's not much like anything we've ever sequenced before.

The authors of the new report sequenced a small set of genes (six genes totaling 5.5 kilobases) in species from every major group of rodents. They also examined a number of repetitive sequence elements from the same groups. The data suggested that the rock rat split from the rest of rodents about 44 million years ago. For context, all existing primates derive from a speciation event about 50 million years ago.

Given this sequence data, it appears that Laonastes is the only living member of an entire family of mammals, the otherwise extinct Diatomyidae. When I first reported on the rock rat, I suggested that it might provide a unique opportunity to test our ability to accurately resolve evolutionary trees based on little more than the appearance of fossils. It is a pleasure to report that the paleontologists got it almost exactly right: the relationships they proposed, as well as the dates of separation, are strongly supported by the new molecular data. This suggests that we can view relationships proposed solely due to fossil evidence with a bit more confidence.

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