Business Litigation -
Patent Quick Reference Guide
What is required to properly plead a claim for willful infringement in the different courts?
In In re Seagate Technology, LLC, the Federal Circuit created a two-part test for determining willful infringement in patent cases, requiring: (1) “clear and convincing evidence that the infringer acted despite an objectively high likelihood that its actions constituted infringement of a valid patent,” and (2) a showing that the risk of infringement “was either known or so obvious that it should have been known to the accused infringer.” Under this test, a patentee could not bring a claim for willful infringement unless it was grounded exclusively on the infringer’s pre-filing conduct, or if the plaintiff filed for a preliminary injunction. The Supreme Court abrogated this test in 2016 due to its requirement of objective recklessness that diminished the discretion given to trial courts. The Halo Court further criticized Seagate because an infringer could muster a reasonable noninfringement defense at trial, even if it was unaware of such a defense when it infringed. The Supreme Court did not substitute another test for Seagate, but instead noted that district courts have the discretion to award enhanced damages. 
Leaving trial courts to their own discretion has resulted in differing approaches to willfulness—especially in the analysis of whether continued infringement after service of the complaint can serve as the basis. The majority have not allowed the complaint to serve as a sole basis for willfulness, with some providing distinct reasons why. Some courts issued decisions after Seagate was abrogated but still followed its reasoning. 
The minority of cases have held the allegations in the complaint can support the knowledge factor for post-suit willfulness.
Although the Supreme Court already held that rigid tests are improper for determining enhanced damages based on willful infringement, the Federal Circuit should try again to provide more guidance as to what is necessary to plead willful infringement. Whether the complaint itself can serve as the lone basis for willful infringement is a clear-cut question that still leaves plenty of discretion for the district courts. As it stands now, a patentee can successfully plead and pursue triple damages simply by selecting a certain forum, or by drawing the correct judge within certain fora. Thus, the importance of having a binding answer to this narrow question for the trial courts cannot be overstated.
What evidence of inequitable conduct are trial courts relying upon to render patents unenforceable?
Known as the “atomic bomb” of patent law, unenforceability due to inequitable conduct requires a finding that (1) the accused infringer withheld information that is “but-for” material to patentability; and (2) there was a specific intent to deceive the Patent Office by withholding the material.
A showing of “but-for” materiality, means the Patent Office “would not have allowed a claim had it been aware of the undisclosed prior art.” For example, if claiming a drug product with a pH of a specific range, similar prior art products with pHs in that same range will be considered “but-for” material. As such, if non-disclosed prior art fully anticipates claims of the patent, it too would be but-for material. Courts will critically analyze whether the withheld information is actually material or if an applicant actually made false statements. For example, in Ironburg Inventions Ltd. v. Valve Corporation, the defendant argued prior art that was withheld, “Jimakos,” was material to patentability. However, the PTAB had previously explained that Jimakos’ improvement was to add a “rapid fire feature” and defendant failed to explain how the rapid fire feature is linked to any patentability challenge. In ICM Controls Corp. v. Honeywell Int’l Inc., the defendant alleged plaintiff omitted and misrepresented positions on the term “for actuating” which would have been material to reexamination of the patent-in-suit. In rejecting the defendant’s position, the Court examined the statements with the entire motion and deposition transcript in mind. Although some quotes seemed to contradict the plaintiff’s positions, the Court noted the expert’s immediate rephrasing of a term and the clear statements in the original motion sufficiently demonstrated that plaintiff was not taking inconsistent positions.
To satisfy the second factor, a defendant must demonstrate that a specific intent to deceive the patent office is the single most reasonable inference that can be drawn from the evidence. It often requires several pieces of evidence to meet this high standard and may involve the malfeasant’s excuses and testimony to be considered implausible. The Court often will require other acts by the one with the duty to disclose as well to prove they intended to deceive the patent office. For example, in Belcher Pharmaceuticals,  the one with the duty to disclose, Rubin, had quoted certain material pieces of withheld prior art in an email dated nine months before the patent was filed, and also demonstrated repeated efforts to evade questioning on that prior art. In Total Rebuild,  the one with the duty to disclose, Lavergne, contended he was unaware of the full scope of the invention claimed in the patent-in-suit, but his 25 years of experience in the business and prior statements and emails demonstrated his understanding of what was purportedly novel about the invention, including parts encompassed by withheld prior art. In Deep Fix, LLC, the person with the duty to disclose knew the withheld prior art caused identical claims before the U.S. Receiving Office to be rejected for lack of an inventive step, and also testified she did not want to “bias” the patent office to rely on those references instead of searching for other prior art.
On the other hand, if there is “thin evidence” regarding intentional withholding of evidence, the Court will side with the patentee. In Fuma Int’l LLC v. R.J. Reynolds Vapor Co., the defendant could not prove clearly and convincingly that the patentee intentionally withheld prior art. The defendant alleged the inventor did not disclose certain prior art; however, the inventor testified that he shared the prior art with his original patent attorney, and there was no evidence to the contrary, including plaintiff’s patent attorneys who only testified they could not remember specific details about what was or was not shown to them. The court stated there was some circumstantial evidence that the inventor knew of material prior art and failed to disclose it, but because it was “built on several layers of inference,” including a confusing record as to how many of the prior art products actually contained the material features, and a lack of direct evidence that the inventor did not tell the patent attorneys about the prior art, the Court ruled a reasonable fact finder could not conclude there was a deliberate intent to deceive.
In conclusion, a finding of unenforceability of a patent due to inequitable conduct is a very high standard to meet. Simply proving negligence or even gross negligence is insufficient to satisfy this requirement. A defendant must prove, by clear and convincing evidence, that the single most reasonable inference was a patentee’s intention to deceive the patent office. A patentee must also demonstrate the withheld prior art is actually material to patentability and the Court will critically analyze the evidence before making a determination. As such, the “atomic bomb” of patent law is fittingly named due to its consequences to the patentee, but requires an equally fitting level of evidence by the defendant to prove.
What is the current status by circuit regarding the granting of motions to transfer venue?
Although venue is sometimes considered a mere formality during litigation, different venues may provide strategic advantages or disadvantages for the same patent infringement case. Generally, venue for corporations follows the same guidelines as personal jurisdiction. Under , corporate defendants “shall be deemed to reside in any judicial district in which it is subject to personal jurisdiction at the time the action is commenced.” However, section 1400(b) specifies that venue for patent infringement suits may be proper “where the defendant resides, or where the defendant has committed acts of infringement and has a regular and established place of business.” The general purpose behind these venue requirements is to prevent undue burden on defendants such as unnecessary travel and superfluous expenses. To accommodate these concerns, courts may grant motions to transfer venue “for the convenience of parties and witnesses. . . to any other district or division where it might have been brought or to any district or division to which all parties have consented.” Thus, in order to succeed, transfer must be aimed at a venue where defendants have a stronger presence than the plaintiff’s initial forum, or where both parties previously consented to appear. When a defendant in a patent case challenges venue, “the [p]laintiff bears the burden of establishing proper venue” for the current site. However, it is the moving party’s burden to prove that the new venue is “clearly more convenient” for the court to grant transfer. Thus, defendants have the burden to prove that transfer to the new district is warranted.
Courts run a two-prong test when considering venue transfer, evaluating “(1) whether the action could have been brought in the proposed forum; and (2) whether the transfer would ‘promote the convenience of parties and witnesses and would be in the interests of justice.’” In applying this test, courts may consider factors such as the plaintiff’s choice of forum, convenience of parties and witnesses, proximity to evidence and events of the incident, local interest in the controversy, court efficiency, and familiarity of local courts with the law. These factors are non-exhaustive, and no factor is dispositive. Additionally, most courts use an individualized, case-by-case standard of evaluation.
Although substantive patent issues are addressed by the Federal Circuit Court of Appeals in patent cases, transfer analyses invoke the law of the regional circuits (applied by the Federal Circuit). Some regional circuits have explicit guidelines for evaluating patent venue transfers. The Fifth Circuit, for example, provides a detailed list of public and private interest factors for courts to evaluate. The private interest factors are “‘(1) the relative ease of access to sources of proof; (2) the availability of compulsory process to secure the attendance of witnesses; (3) the cost of attendance for willing witnesses; and (4) all other practical problems that make trial of a case easy, expeditious, and inexpensive,’” while the public interest factors are “‘(1) the administrative difficulties flowing from court congestion; (2) the local interest in having localized interests decided at home; (3) the familiarity of the forum with the law that will govern the case; and (4) the avoidance of unnecessary problems of conflict of laws [or in] the application of foreign law.’” Similar to the Fifth Circuit, courts in the Third Circuit consider private factors such as convenience of witnesses and enforceability of judgment, as well as public factors such as “practical considerations for making trial easy, expeditious, and inexpensive” and “enforceability of judgement”. Even though the Third circuit and Fifth circuit present more orderly lists of public and private factors for courts to consider, their criteria relate to the same principles as other circuits–maximizing the convenience of parties and protecting the interests of justice. Thus, most courts considering venue transfer in patent infringement matters consider similar factors.
Although each circuit presents considerable precedence and guidance for venue transfer evaluation, there are still successful challenges to denials of transfers. The Western District Court of Texas has been criticized recently for its rulings on venue transfer. In Hulu, the Federal Circuit found that the Western District Court “clearly abused its discretion” in denying a defendant’s motion to transfer venue because it (1) incorrectly evaluated the “availability of compulsory process to secure the attendance of witnesses,” (2) erred in its evaluation of witness convenience and location, and (3) miscalculated court efficiency because it overvalued “its own availability to set an early trial date and bring a case to trial earlier than district-wide statistics would suggest”. Similarly, in Samsung the Western District Court of Texas was criticized for “overstat[ing] the concern about waste of judicial resources and risk of inconsistent results,” while undervaluing local interests. Although these two cases might be outliers, they provide clear examples of district courts abusing discretion by taking too much liberty in analyzing motions to transfer venue. Thus, it may be hard for patent parties to predict venue transfer outcomes. In advocating for or against venue transfer, patent litigants should tailor their arguments around the policies and factors described above. Additionally, this is an area that has experienced increased examination from appellate courts because of the prevalence of plaintiffs repeatedly seeking to find ways to use certain preferred venues.
What are the best places to sue, or be sued, in patent infringement actions?
The most popular venues for patent infringement plaintiffs have fluctuated recently due to a litany of factors. Prior to TC Heartland (2017), courts only applied broad personal jurisdiction standards to determine proper venue for patent infringement cases brought against domestic corporations. During this era, patent infringement cases were most common in Texas and California. However, following stricter venue requirements established in TC Heartland, patent litigation filings have shifted heavily towards the District Court of Delaware, likely because of the high amount of businesses headquartered and incorporated there. Still, while Delaware has seen the most patent infringement cases field since 2019, other venues may be seen as more favorable towards plaintiffs.
Like the District of Delaware, the Western District Court of Texas has seen a surge of new cases in recent years. The Western District heard nearly eight hundred cases in 2021 as opposed to less than one hundred cases in 2018. This significant rise may be caused by various factors such as the growing number of businesses migrating to Austin. The Western District of Texas analysis tends to favor plaintiffs. Since 2018, the Western District as a whole has granted 22% of defendant-filed motions to dismiss. These percentages are noteworthy because statistically they tend to favor plaintiffs more than other common patent infringement venues. In the District Court of Delaware, for example, over 44% of defendant-filed motions to dismiss succeed. The differences in these statistics display why many view the Western District of Texas as preferential towards plaintiffs, and why it might soon overtake the District of Delaware for the most popular patent litigation venue.
Although its popularity has fallen a bit since TC Heartland, the Eastern District Court of Texas also tends to be a plaintiff-favored patent infringement venue. In the past three years, only 21% of defendant-filed motions to dismiss have succeeded. Additionally, The Eastern District of Texas has granted only 17% of defendant-filed motions for summary judgement–a number far lower than other top patent venues such as the Central District of California (41%), Northern District of Illinois (41%) and Northern District of California (57%). It should be noted that while the Eastern District of Texas dominated patent infringement filings pre-TC Heartland, it has seen over a 50% decrease in yearly cases since 2017. This is likely due to the massive increase in cases filed in the Western District of Texas and the District of Delaware following stricter venue requirements laid out in TC Heartland. Thus, with venue requirements becoming more stringent and a rising number of cases being filed in the District of Delaware and the Western District of Texas, the Eastern District of Texas seems to be falling towards a less desirable venue for patent litigation.
Overall, patent litigation seems to be most common in Texas and Delaware–two states with significant amounts of businesses. Although it may be tough to determine which forum is most plaintiff-friendly or defendant-friendly, statistics from the past three years show that the Western District of Texas is now likely the most desirable venue for plaintiffs. This trend may change depending on future policy changes, but for now it appears to be here to stay.
Significant local rules applicable to patent cases.
Patent infringement suits present a number of challenges distinct from ordinary litigation such as Markman hearings to determine claim construction and complicated subject matter. Because of these unique challenges, many of the top patent litigation venues have implemented local rules dedicated specifically to patent cases. These local rules typically aim to provide structure and guidelines so that patent infringement litigants know what to expect throughout litigation.
Many jurisdictions popular among patent litigants feature specialized local rules that dictate deadlines and guidelines particular to patent cases, such as timing and procedures for exchanges of infringement and invalidity contentions, claim constructions, and opinions of counsel. These patent local rules often specify disclosure requirements for infringement and invalidity contentions, with some jurisdictions allowing for preliminary contentions, followed-up by final contentions to allow for discovery to refine the parties’ stances; these rules also usually allow parties to exchange amended contentions if the court’s claim construction ruling significantly altered the meaning of key claim terms. Other examples of these guidelines include earlier deadlines for certain pleadings, more stringent requirements for pleadings overall, and limits on the number of claim terms to be construed. While most patent-heavy district courts have similar local rules to each other, some districts stand out.
One of the most blatant examples of local rules impacting patent litigation is the practice in the Western District Court of Texas. Since being sworn in as a judge in 2018, Judge Albright has implemented various local rules that tend to attract patent infringement suits. These “standing orders” are designed to shorten patent litigation by reducing discovery request response deadlines, shortening plaintiff response and defendant reply deadlines, requiring proposed orders to be submitted no later than seven days after the conclusion of discovery hearings, and delaying discovery (except with regard to venue, jurisdictional, and claim construction-related discovery) until after Markman hearings. Judge Albright also places limits on the number of interrogatories, requests for admission, and other discovery tools parties may use. Additionally, Judge Albright’s orders include example schedules for patent infringement cases. These are aimed towards shortening trials and providing structure to parties.
While the Western District of Texas is generally seen as a plaintiff-friendly venue, rules like these may benefit defendants as well. For example, delaying discovery until after Markman hearings may delay business effects on defendants because they can continue their alleged infringement without fear of losing on a motion for summary judgment or injunction. In summary, Judge Albright’s standing orders represent a prime example of local rules impacting how patent litigation operates. While they may be seen as a move to entice patent infringement plaintiffs to file in his district, Albright’s rules seem to be beneficial to both sides of litigation. Perhaps more courts will follow his example to give parties more structure and clearer expectations.
 In re Seagate Technology, LLC, 497 F.3d 1360, 1368-1371 (Fed. Cir. 2007).
 See id. at 1374.
 Halo Electronics, Inc. v. Pulse Electronics, Inc., 579 U.S. 93, 104 (2016).
 Id. at 105.
 Halo Electronics, 579 U.S. at 110 (citing Martin v. Franklin Capital Corp., 546 U.S. 132, 139 (2005).
 E.g. ZapFraud, Inc. v. Barracuda Networks, Inc., 528 F.Supp.3d 247 (D. Del. 2021) (“The purpose of a complaint is to obtain relief from an existing claim and not to create a claim.”); Cooper Lighting, LLC v. Cordelia Lighting, Inc., 2017 WL 3469535 (N.D. Ga. Apr. 6, 2017) (“[P]ermit[ting] such pleading of willfulness could result in enhanced damages in every patent infringement suit.”); Radware, Ltd. v. F5 Networks, Inc., 2016 WL 4427490 (N.D. Cal. Aug. 22, 2016) (insufficient evidence for willfulness finding when there were no allegations of pre-suit knowledge); Princeton Digital Image Corp. v. Ubisoft Entertainment SA, 2016 WL 6594076 (D. Del. Nov. 4, 2016) (dismissing post-suit willfulness claim because the amended complaint does not sufficiently allege egregiousness, but saying post-suit willfulness claims are “cognizable” after Halo).
 E.g., Adidas America, Inc. v. Skechers USA, Inc., 2017 WL 2543811, at *4 (D. Or. June 12, 2017); Cooper Lighting, 2017 WL 3469535, at *2 (agreeing with other courts that Seagate’s conclusion regarding willful infringement based on post-filing conduct is still good law); CG Tech. Development, LLC v. FanDuel, Inc., 2017 WL 58572 (D. Nev. Jan. 4, 2017) (“Although a willful infringement plaintiff need no longer allege objective recklessness, he must allege some egregious misconduct occurring before the initial claim of infringement was filed, otherwise his remedy will ordinarily be limited to a preliminary injunction”) (internal citation omitted).
 Clouding IP, LLC v. Amazon.com, Inc., 2013 WL 2293452 (D. Del. May 24, 2013) (“[T]here appears to be little practical difference between a pre-complaint notice letter informing a defendant about a patentee’s allegation of infringement and a subsequently-superseded original complaint formally alleging infringement.”); Longhorn Vaccines & Diagnostics, LLC v. Spectrum Solutions LLC, 564 F.Supp.3d 1126 (D. Utah 2021); IOEngine, LLC v. PayPal Holdings, Inc., 2019 WL 330515 (D. Del. Jan. 25, 2019) (citing other D. Del. cases); DataQuill Ltd. v. High Tech Computer Corp., 887 F.Supp.2d 999 (S.D. Cal. 2011).
 Therasense, Inc. v. Becton, Dickinson and Co., 649 F.3d 1276, 1287, 1288, 1291 (Fed. Cir. 2011).
 Id. at 1291.
 Belcher Pharmaceuticals, LLC v. Hospira, Inc., 450 F.Supp.3d 512, 548 (D. Del. 2020).
 Total Rebuild, Inc. v. PHC Fluid Power, L.L.C., 417 F.Supp.3d 797, 801 (W.D. La. 2019).
 Ironburg Inventions Ltd. v. Valve Corporation, 418 F.Supp.3d 622, 632 (W.D. Wash. 2019).
 Id. at 632-633.
 ICM Controls Corp. v. Honeywell Int’l Inc., 554 F.Supp.3d 409, 419 (N.D.N.Y. 2021).
 See id. at 420.
 See also Bausch Health Ireland Limited v. Padagis Israel Pharma. Ltd., 2022 WL 1606961, at *3-4 (D.N.J. May 20, 2022) (Court analyzed an allegedly false statement that the invention was “unexpected” against the backdrop of the skill in the art at the time the statement was made and determined the statement was not false).
 Therasense, 649 F.3d at 1290.
 E.g., Deep Fix, LLC v. Marine Well Containment Co. LLC, 2020 WL 773164, at *7 (S.D. Tex. Feb. 18, 2020); Belcher Pharmaceuticals, 450 F. Supp.3d at 549; Total Rebuild, 417 F.Supp.3d at 809.
 Belcher Pharmaceuticals, 450 F.Supp.3d at 549.
 Total Rebuild, 417 F.Supp.3d at 809.
 Deep Fix, LLC, 2020 WL 773164, at *8-9.
 Fuma Int’l LLC v. R.J. Reynolds Vapor Co., 2020 WL 3470458 (M.D.N.C. Mar. 6, 2020).
 Id. at *2.
 Id. at *1.
 28 U.S.C. § 1391(c).
 28 U.S.C. § 1391(c).
 28 U.S.C. § 1400(b).
 28 U.S.C. § 1404(a).
 In re ZTE (USA) Inc., 890 F.3d 1008, 126 U.S.P.Q.2d 1626 (Fed. Cir. 2018).
 Body Science LLC v. Boston Scientific Corp., 846 F.Supp.2d 980, 991, 81 Fed.R.Serv.3d 1094 (N.D. Ill. 2012) (quoting Coffey v. Can Dorn Iron Works, 796 F.2d 217, 219-20 (7th Cir. 1986)).
 B.E. Technology, LLC v. Facebook, Inc., 957 F.Supp.2d 926 (W.D. Tenn. 2013).
 EasyWebb Innovations, LLC v. Facebook, Inc., 888 F.Supp.2d 342, 347 (E.D.N.Y. 2012) (quoting Clarendon Nat’l Ins. Co. v. Pascual, No. 99 Civ. 10840(JGK)(AJP), 2000 WL 270862, at 2 (S.D.N.Y. Mar. 13, 2000) (other citations omitted)).
 See, e.g., Momenta Pharmaceuticals, Inc. v. Amphastar Pharmaceuticals, Inc., 841 F.Supp.2d 514, 522 (D.Mass 2012) (“Factors to be considered in determining whether transfer is warranted include 1) the plaintiff’s choice of forum, 2) the relative convenience of the parties, 3) the convenience of the witnesses and location of documents, 4) any connection between the forum and issues, 5) the law to be applied and 6) the state or public interests at stake.”); EasyWebb Innovations, LLC, 888 F.Supp.2d 342 at 348 (Second Circuit factors include plaintiff’s choice of forum, convenience of witnesses and parties, location of documents, location of the incident, and forum’s familiarity with the governing law); Sunstone Information Defense, Inc. v. F5 Networks, Inc., No. 2:21CV50(RCY), 2021 WL 5804571 (E.D. Va. Dec. 2021); Body Science LLC v. Boston Scientific Corp., 846 F.Supp.2d 980, 992, Fed.R.Serv.3d 1094 (N.D. Ill. 2012) (“In considering the convenience of one venue over another, courts consider five factors: (1) the plaintiff’s choice of forum; (2) the situs of material events; (3) the relative ease of access to sources of proof; (4) the convenience of witnesses; and (5) the convenience to the parties of litigating in the respective forums.”).
 See, e.g., Fitbit, Inc. v. Koninklijke Phillips N.V., 336 F.R.D. 574, 580 (N.D. Cal. 2020) (quoting Ctr. For Biological Diversity v. Kempthorne, No. C 09-1339 CW, 2008 WL 4543043 at 2 (N.D. Cal. Oct. 10, 2008)) (“Courts may examine all these factors, but ‘no single factor is dispositive.’”).
 See, e.g., CamelBak Products, LLC v. Zak Designs, Inc., No. 5:21-CV-0519, 2022 WL 678652 at 1–2 (W.D. Ark. Mar. 2022).
 In re TS Tech USA Corp., 551 F.3d 1315, 1319 (Fed. Cir. 2008).
 In re Volkswagen of America, Inc., 545 F.3d 304, 315, 89 U.S.P.Q.2d 1501 (5th Cir. 2008) (quoting In re Volkswagen AG, 371 F.3d 201, 203 (5th Cir. 2004)).
 Jumara v. State Farn Ins. Co., 55 F.3d 873, 879–80 (3d Cir. 1995).
 See In re Samsung Electronics Co., Ltd., 2 F.4th 1371 (Fed. Cir. 2021) and In re Hulu, LLC, No. 2021-142, 2021 WL 3278194 (Fed. Cir. Aug. 2, 2021).
 In re Hulu, LLC, 2021 WL 3278194 at 5.
 In re Samsung Electronics Co., Ltd., 2 F.4th 1371, 1379–80 (Fed. Cir. 2021).
 TC Heartland LLC v. Kraft Foods Grp. Brands LLC, 137 S. Ct. 1514 (2017).
 Id.; See 28 U.S.C. § 1391.
 In TC Heartland LLC v. Kraft Foods Grp. Brands LLC, the Supreme Court ruled that patent infringement cases must be filed where the defendant either has a physical presence or is incorporated. This narrowed the previous standard for venue, which broadly matched personal jurisdiction and the minimum contacts theory.
 Westlaw Edge, www.westlawcourtexpress.com (June 14, 2022). As of June 14, 2022, the top 5 jurisdictions for patent litigation in the United States are the District Court of Delaware (2,691), The West District Court of Texas (1,747), The Eastern District Court of Texas (1,462), the Central District Court of California (935), the Northern District Court of Illinois (663), and The Northern District Court of Texas (655). To focus on more recent trends, data is limited to the past 3 years.
 Jason W. Wolff et al., Patent Local Rules: Knowing Them Well Can Make Litigating Your Case Smoother, Fish & Richardson (Apr. 22, 2020), https://www.fr.com/patent-local-rules-knowing-them-well-can-make-litigating-your-case-smoother/.
 See, e.g., Patent Rules | Eastern District of Texas | United States District Court, https://www.txed.uscourts.gov/?q=patent-rules (last visited Jul. 28, 2022).
 United States District Court Western District of Texas, Standing Orders: Waco Division, https://www.txwd.uscourts.gov/judges-information/standing-orders/ (last visited June 29, 2022).
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