Nicira, Inc.Download PDFPatent Trials and Appeals BoardMar 18, 20212019005973 (P.T.A.B. Mar. 18, 2021) 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. 15/386,214 12/21/2016 Kaushal Bansal N320.02 (NCRA.P0570) 9731 109858 7590 03/18/2021 ADELI LLP P.O. Box 516 Pacific Palisades, CA 90272 EXAMINER TRAN, ELLEN C ART UNIT PAPER NUMBER 2433 NOTIFICATION DATE DELIVERY MODE 03/18/2021 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): ipadmin@vmware.com mail@adelillp.com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE ____________ BEFORE THE PATENT TRIAL AND APPEAL BOARD ____________ Ex parte KAUSHAL BANSAL, UDAY MASUREKAR, SHADAB SHAH, JAMES JOSEPH STABILE, and STEVEN PETERS ___________ Appeal 2019-005973 Application 15/386,214 Technology Center 2400 ____________ Before JASON V. MORGAN, MICHAEL J. STRAUSS, and JAMES B. ARPIN, Administrative Patent Judges. ARPIN, Administrative Patent Judge. DECISION ON APPEAL Appellant1 appeals under 35 U.S.C. § 134(a) from the Examiner’s decision rejecting claims 1, 4–10, 13, and 16–26, all of the pending claims. Final Act. 2.2 Claims 3, 4, 11, 12, 14, and 15 are cancelled. Id. We have 1 “Appellant” refers to “applicant” as defined in 37 C.F.R. § 1.42. Appellant identifies the real parties-in-interest as VMware, Inc., and Nicira, Inc. Appeal Br. 2. 2 In this Decision, we refer to Appellant’s Appeal Brief (“Appeal Br.,” filed March 22, 2019) and Reply Brief (“Reply Br.,” filed August 6, 2019); the Final Office Action (“Final Act.,” mailed August 23, 2018) and the Examiner’s Answer (“Ans.,” mailed June 6, 2019); and the Specification (“Spec.,” filed December 21, 2016). Rather than repeat the Examiner’s findings and Appellant’s contentions in their entirety, we refer to these documents. Appeal 2019-005973 Application 15/386,214 2 jurisdiction under 35 U.S.C. § 6(b). We reverse. STATEMENT OF THE CASE The claimed methods and machine readable media relate to “distributing firewall configuration in a datacenter comprising multiple host machines.” Spec., Abstract. As noted above, claims 1, 4–10, 13, and 16–26 are pending. Claims 1 and 13 are independent. Appeal Br. 39 (claim 1), 41–42 (claim 13) (Claims App.). Claims 4–10 and 22–26 depend directly or indirectly from claim 1, and claims 16–21 depend directly or indirectly from claim 13. Id. at 39–44. Claim 1, reproduced below with disputed limitations emphasized, is illustrative. 1. A method for distributing firewall rules in a datacenter comprising a plurality of host machines, the method comprising: at a network manager executing on a computer of the datacenter, in a firewall rule that is associated with a first version number, identifying a particular group identifier that represents a set of at least one enforcement node; to translate the particular group identifier, retrieving from a translation storage, which stores previous translation results for a plurality of group identifiers, a previous translation result of the particular group identifier that has one of the first version number and a subsequent version number; using a set of at least one enforcement node identifier that is part of the retrieved translation result to modify the firewall rule by replacing the particular group identifier with at least one retrieved enforcement node identifier; and Appeal 2019-005973 Application 15/386,214 3 distributing the modified firewall rule to a host machine associated with an enforcement node identified in the modified firewall rule, wherein the host machine uses the modified firewall rule to process packets for the enforcement node in accordance with a firewall action specified by the modified firewall rule. Id. at 39 (emphasis added). REFERENCES AND REJECTIONS3 The Examiner relies upon the following references: Name4 Reference Issued/Publ’d Filed Litvin US 2009/0249472 A1 Oct. 1, 2009 Jan. 5, 2009 Lotem US 8,621,552 B1 Dec. 31, 2013 May 21, 2008 The Examiner rejects claims 1, 4–10, 13, and 16–26 under 35 U.S.C. § 112(a) as lacking an enabling disclosure. Final Act. 12–13. The Examiner also rejects claims 1, 4–10, 13, and 16–26 under 35 U.S.C. § 112(b) as indefinite. Id. at 13. Further, the Examiner rejects claims 1, 4–10, 13, and 16–26 under 35 U.S.C. § 103 as obvious over the combined teachings of Litvin and Lotem. Id. at 14–19. We review the appealed rejections for error based upon the issues identified by Appellant, and in light of the contentions and evidence produced thereon. Ex parte Frye, 94 USPQ2d 1072, 1075 (BPAI 2010) (precedential). Although Appellant challenges the obviousness rejection of 3 The Examiner withdraws rejections of claims 1, 4–10, 13, and 16–26 under 35 U.S.C. § 101 as directed to patent ineligible subject matter, without significantly more, and as lacking patentable utility. Ans. 11; see Final Act. 6–12. 4 All reference citations are to the first named inventor only. Appeal 2019-005973 Application 15/386,214 4 certain dependent claims separately, for the most part, the Examiner and Appellant focus their findings and contentions on claim 1; so do we. See, e.g., Appeal Br. 17, 27–28; Ans. 12, 17, 23. We address the rejections below. ANALYSIS A. Lack of Enablement As noted above, the Examiner rejects claims 1, 4–10, 13, and 16–26 as lacking an enabling disclosure. Final Act. 3–5, 12–13. For the reasons given below, we do not sustain the rejection for lack of enablement. 35 U.S.C. § 112(a) requires that The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention. (Emphasis added.) The Examiner rejects claims 1, 4–10, 13, and 16–26 for lack of enablement because “[t]he claims appear to be directed to writing a software program (i.e. a firewall) and distributing firewall rules, however the language utilized in the claims with numerous grammatical errors make it impossible to understand and utilize the claimed invention, therefore the claims lack enablement.” Final Act. 12–13; see Ans. 12–15. This, however, is insufficient to show a lack of enablement. The Manual of Patent Examination Procedure (MPEP) states: Any analysis of whether a particular claim is supported by the disclosure in an application requires a determination of Appeal 2019-005973 Application 15/386,214 5 whether that disclosure, when filed, contained sufficient information regarding the subject matter of the claims as to enable one skilled in the pertinent art to make and use the claimed invention. The standard for determining whether the specification meets the enablement requirement was cast in the Supreme Court decision of Minerals Separation Ltd. v. Hyde, 242 U.S. 261, 270 (1916) which postured the question: is the experimentation needed to practice the invention undue or unreasonable? That standard is still the one to be applied. In re Wands, 858 F.2d 731, 737 . . . (Fed. Cir. 1988). Accordingly, even though the statute does not use the term “undue experimentation,” it has been interpreted to require that the claimed invention be enabled so that any person skilled in the art can make and use the invention without undue experimentation. [Id.] MPEP5 § 2164.01 (“Test of Enablement”; emphasis added). Nevertheless, the Examiner, who bears the initial burden, fails to explain adequately why the disclosure, as filed, is not sufficiently complete to enable one of ordinary skill in the art to make and use the invention of claims 1, 4–10, 13, and 16–26 without undue experimentation. See In re Wright, 999 F.2d 1557, 1561–62 (Fed. Cir. 1993) (citing In re Marzocchi, 439 F.2d 220, 223–24 (CCPA 1971)) (The Office bears the “initial burden” when rejecting claims for lack of enablement.). The rejection before us does not include adequate discussion of the Wands factors to provide the Appellant or the Board with an indication as to why one would have to engage in undue experimentation to practice the claimed invention. See Wands, 858 F.2d at 736–37 (“Enablement is not precluded by the necessity for some experimentation . . . . However, experimentation needed to 5 All references to the MPEP are to the Ninth Edition, Revision 10.2019 (Last Revised June 2020). Appeal 2019-005973 Application 15/386,214 6 practice the invention must not be undue experimentation. The key word is ‘undue,’ not ‘experimentation.’”). Although the Examiner is not required to provide a discussion of every Wands factor, the Examiner’s rejection does not make evident that any of these factors has been considered or that the Examiner relies on evidence sufficient to support the conclusion of lack of enablement. Id. Accordingly, the Examiner has not established that the claims at issue are not enabled, and we do not sustain the Examiner’s lack of enablement rejection of claims 1, 4–10, 13, and 16–26. B. Indefiniteness 35 U.S.C. § 112(b) requires that “[t]he specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the inventor or a joint inventor regards as the invention.” (Emphasis added.) The Examiner finds: As explained above [with respect to the lack of enablement rejection], the claims appear to be directed to writing a software program (i.e. a firewall) and distributing firewall rules, however the language utilized is riddled with grammatical errors mak[ing] it impossible to understand and utilize the claimed invention, therefore the claims are indefinite. Final Act. 13 (emphasis added); see Ans. 15–17. Moreover, the Examiner asserts, “the amendment of the claim filed 23 April 201[8] the Applicant’s representative has gone to extreme lengths to confuse the Examiner and the record with the numerous deletions and addition in the claims” (Ans. 16), and “the Applicant’s representative did not schedule any interviews or file any after final amendments with this application and went straight to appeal” (id. at 17). The Examiner proposes a rewritten version of claim 1 for Appellant to adopt. Id. at 16. Appeal 2019-005973 Application 15/386,214 7 Appellant responds: The Office Action, however, fails to identify any specific grammatical errors or any specific term or phrase that is indefinite and why the metes and bounds are unclear. The Office Action asserts that the claims appear to be directed to writing a software program which (i) is not a remotely accurate characterization of the claims as described above in Subsection I.A and (ii) does not address the actual language of the claims. Accordingly, the Office Action fails to provide enough information for the applicant to prepare a meaningful response. Appellant respectfully submits that the rejection based on 35 U.S.C. §112(b) is therefore improper. Appeal Br. 18; see Reply Br. 5–6. We agree with Appellant. Initially, we agree with Appellant that although the Examiner asserts the claims contain numerous grammatical errors, the Examiner makes almost no attempt to identify those alleged errors. At most, the Examiner alleges it is not clear what is meant by “a computer of the datacenter, in a firewall rule.” Ans. 13 (discussing claim 1 in the context of the lack of enablement rejection). However, this challenged language is a combination of the last few words of the first limitation of claim 1 with the first few words of its second limitation. See Appeal Br. 39 (Claims App.) (reproduced above). This takes both sets of words out of context, and it is not surprising that taken out of context the combination makes no sense. As Appellant notes, The Office action must set forth the specific term or phrase that is indefinite and why the metes and bounds are unclear. Since a rejection requires the applicant to respond by explaining why claim language would be recognized by a person of ordinary skill in the art as definite or by amending the claim, the Office action should provide enough information for the applicant to prepare a meaningful response. Appeal Br. 17–18 (quoting MPEP § 2173.02(III)(B) (“Determining Whether Appeal 2019-005973 Application 15/386,214 8 Claim Language is Definite”); emphasis added)). Here, we are persuaded the Examiner fails to explain what terms are found indefinite and why. The Examiner’s rewriting of claim 1 does not substitute for the necessary findings. In rewriting the claim, the Examiner still fails to identify “the specific term or phrase that is indefinite and why the metes and bounds are unclear.” Although we do not disagree that Appellant could rewrite claims 1 and 13 to achieve improved clarity and ease of understanding, that is not the test for indefiniteness. Moreover, “[i]t is the applicants’ burden to precisely define the invention, not the [Office’s].” In re Morris, 127 F.3d 1048, 1056 (Fed. Cir. 1997). On this record, no conclusions can be drawn from Appellant’s decision not to adopt the Examiner’s choice of claim language, not to file its own further claim amendments, or not to seek an interview. Reply Br. 6; see Ans. 16–17. Further, we do not draw adverse inferences from the timing of Appellant’s decision to appeal. Reply Br. 6; see Ans. 17. On this record, we are not persuaded that the Examiner shows that Appellant’s claim 1 or claim 13, which recites limitations corresponding to those recited in claim 1, is indefinite. For the reasons given above, we do not sustain the indefiniteness rejection of claims 1 and 13, or of claims 4–10 and 16–26, which depend therefrom. C. Obviousness Over Litvin and Lotem As noted above, the Examiner rejects claims 1, 4–10, 13, and 16–26 as obvious over the combined teachings of Litvin and Lotem. Final Act. 14– 19. Appellant contests the rejection of claim 1. Appeal Br. 9–12. For the reasons given below, we are persuaded the Examiner errs, and we do not sustain this rejection. Appeal 2019-005973 Application 15/386,214 9 With respect to claim 1, the Examiner finds that Litvin teaches or suggests “in a firewall rule that is associated with a first version number, identifying a particular group identifier that represents a set of at least one enforcement node.” Final Act. 14 (citing Litvin ¶¶ 15, 24, 77, Fig. 4); Appeal Br. 39 (Claims App.) (emphasis added). Further, the Examiner finds that Lotem teaches or suggests: to translate the particular group identifier, retrieving from a translation storage, which stores previous translation results for a plurality of group identifiers, a previous translation result of the particular group identifier that has one of the first version number and a subsequent version number; [and] using a set of at least one enforcement node identifier that is part of the retrieved translation result to modify the firewall rule by replacing the particular group identifier with at least one retrieved enforcement node identifier. Final Act. 15 (citing Lotem, Abstract, 1:53–2:31); Appeal Br. 39 (Claims App.) (emphases added). Appeal 2019-005973 Application 15/386,214 10 Litvin’s Figure 4 is reproduced below. Figure 4 depicts firewall coordinator 400 connected to multiple host nodes 410, 412, 414, each of which has its own virtual network firewall 420, 422, 424. Litvin ¶¶ 29, 77. Each host node includes various virtual machines (VMs). Id. “The virtual machines are controlled by control program 165 on control server 120.” Id. ¶ 77. Litvin explains that firewall policies relating to a given virtual machine are needed on the host node hosting that machine. Id. ¶ 15. The firewall coordinator keeps track of the location of the virtual machines and makes sure that the necessary firewall policy is supplied to the host node hosting a particular machine. Id.; see id. ¶ 24. Further, “[t]he virtual machine policy updater 1224 also receives notice (e.g., identifiers of virtual machines and the host nodes on which they are running) from the virtual Appeal 2019-005973 Application 15/386,214 11 machine tracker 1208 when policies for a running virtual machine are updated.” Id. ¶ 128 (emphases added); see Final Act. 14–15. Lotem discloses: A method for evaluating a deployment of a network access change request, the method includes: (a) formatting a network access change request to provide a formatted network access change request; wherein the formatted network access change request includes multiple formatted request items; wherein the multiple formatted request items includes a requested access type, an address of an access source, an address of an access destination; (b) determining multiple relationships between the multiple formatted request items and corresponding items of at least one entity out of a network model and a current network policy; and ( c) responding to the network access change request in response to the multiple determined relationships. Lotem, Abstract (emphasis added), 1:53–65; see id. at 12:48–13:3 (describing content of a network access change request); 28:57–61 (describing use of recorded configurations). Lotem further discloses that for each new configuration version of the firewall, the Access Change Assurance (ACA) – that is, a method for assuring access change requests – creates a configuration record, including details of the configuration, such as ID and date, and references to the current and previous configurations. Id. at 31:45–50; see Ans. 18; see also Lotem, 31:63–65 (“The ACA environment can produce a daily report that presents the configuration changes performed for firewalls in the organization, their content, and verification results.”). Appellant contends the Examiner errs for two reasons. Appeal Br. 18–19. Specifically, Appellant contends: First, the Office Action failed to cite references that disclose or suggest replacing a group identifier in a firewall rule with at least one enforcement node identifier retrieved from a translation storage storing previous translation results for Appeal 2019-005973 Application 15/386,214 12 multiple group identifiers. Second, the Office Action failed to cite references that disclose or suggest identifying a particular group identifier in a firewall rule associated with a first version number, and retrieving from a translation storage, which stores previous translation results for multiple group identifiers, a previous translation result of the particular group identifier that has one of the first version number and a subsequent version number. Instead, the references are directed to (1) to implementing a firewall in a system with multiple host nodes executing multiple virtual machines (Litvin) and (2) using network models to generate a formatted firewall access change request from an unformatted network access change request (Lotem). Id. (emphases added). In response to Appellant’s first reason, the Examiner finds the combination of Litvin’s and Lotem’s teachings teach or suggest “replacing a group identifier in a firewall rule with at least one enforcement node identifier retrieved from a translation storage storing previous translation results for multiple group identifiers.” Ans. 17; see Appeal Br. 18. In particular, the Examiner finds Litvin discloses, “how connection data is stored in a firewall connection table, which data include virtual machine identifier that is the connection’s source or destination.” Ans. 17. Litvin further discloses a single connection table on each host node may include the connection data for each of the virtual machines on that host node. Id. In addition, Litvin discloses utilizing a firewall coordinator, which may be software stored on particular virtual machine or stored in a computer readable medium, that coordinates firewall updates according to policies received which involves transferring the connection table data to the host, on which the particular virtual machine is running. Id. Because “Lotem teaches modifying firewall rules using change requests which indicates Appeal 2019-005973 Application 15/386,214 13 identifiers of host nodes as well as virtual machines in the update requests,” the Examiner finds that the combed teachings of these references teach or suggest the disputed limitation. Id. at 17–18. Appellant contends that the Examiner fails to show where Litvin or Lotem, alone or in combination, teach(es) or suggest(s) “in a firewall rule that is associated with a first version number, identifying a particular group identifier that represents a set of at least one enforcement node.” Reply Br. 7; Appeal Br. 39 (Claims App.) (emphasis added); see Appeal Br. 23–24. Specifically, Appellant contends: Litvin does not actually describe group identifiers in firewalls rules that represent enforcement nodes. In a later use of Litvin regarding distribution of the modified firewall rule to a host machine, the [Examiner] cites to ¶¶115-117 of Litvin, which describes identifiers for VMs in firewall rules. Office Action, pg. 14-15. However, these identifiers represent the sources and destinations of packets to which the firewall rule is applied, not the enforcement nodes. The points of enforcement in Litvin are virtual network firewalls, and the firewall rules of Litvin very clearly do not contain group identifiers that represent the virtual network firewalls. Litvin, Figures 4-6 and 14B. Nowhere does Litvin disclose or suggest any such enforcement node identifier or group identifiers representing enforcement node identifiers in a firewall rule. Appeal Br. 23 (emphasis added); see Reply Br. 8 (“The reference to Litvin includes yet more discussion regarding IP addresses, which as indicated repeatedly do not logically correspond to either the group identifiers or the enforcement node identifiers.”). Similarly, Appellant contends the Examiner “refers to portions of Lotem regarding the [access change request (ACR)] being formatted to include source and destination IP addresses in place of abstract source and destination identifiers, but that (as in Litvin) these refer Appeal 2019-005973 Application 15/386,214 14 to sources and destinations of packets rather than enforcement nodes.” Reply Br. 7 (emphasis added); see Appeal Br. 24. We agree with Appellant. In response to Appellant’s second reason, the Examiner finds the combination of Litvin’s and Lotem’s teachings teach or suggest “updating firewall rules (which includes version number) as well identifying which node the firewall operates on see Litvin paragraphs 15 and 24 note the ‘minimum required version number’ is interpreted equivalent to ‘security policy’, ‘firewall policy’ [,] ‘firewall update’ etc[.] . . . .”6 Ans. 18. The Examiner finds: In addition see Lotem col. 28, lines 57-61, “Each time a new version of the firewall model is created the model is conveniently recorded in a configurations repository (stage 7140).[”] The recorded configurations can be used as a reference for identifying and examining future changes in the configuration of firewalls and col. 31, lines 44-50 “Creating Configuration Change Records (Stage 7100). For each new configuration version of a firewall, ACA creates a configuration change record. . . . ” Id. The further Examiner finds, Litvin clearly teaches a firewall coordinator that tracks the locations of virtual machine, when a virtual machine is moved to a new or different host node the firewall operating on the host node is updated for the virtual machine. This updating would change destination addresses located in a firewall connection table to include the identifier of the new or different host node. see Lotem col. 1, line 53 through col. 2, line 31. Ans. 21 (emphasis added). Therefore, we understand the Examiner finds that Lotem’s teaching of configuration change records, together with 6 Appellant correctly notes that claim 1 does not recite a “minimum required version number.” Appeal Br. 9. The Examiner cites no support from the Specification for this interpretation. But see Spec., Abstract (“The firewall rule is associated with a minimum required version number.”) Appeal 2019-005973 Application 15/386,214 15 Litvin’s teachings of tracking virtual machine locations in hot nodes, teaches or suggests “a translation storage” and the configuration updates stored in the configuration change records include a first version or a subsequent version of the configurations. See Ans. 21–23. Nevertheless, although the Examiner concedes that Litvin does not teach or suggest translating the group identifier or retrieving a previous translation result (see Final Act. 15), the Examiner finds the applied references together teach retrieving a previous translation result (Ans. 22). Appellant contends, however, that because allowing a packet to communicate does not translate anything, the Examiner fails to explain how information about allowed packets corresponds to “previous translation results for a plurality of group identifiers.” Reply Br. 10; Appeal Br. 39 (Claims App.). Further, claim 1 recites, “previous translation results for group identifiers,” and Appellant asserts, “the packets are not group identifiers (i.e., they do not represent sets of enforcement nodes), nor are the source and destination addresses.” Reply Br. 10; Appeal Br. 39 (Claims App.) (emphasis added). Similarly, with respect to Lotem, Appellant contends, the network and firewall models are not previous translation results of a group identifier, and a saved network or firewall model retrieved for topology analysis for translation of a network ACR cannot possibly have a same Change Request ID as the ACR (or subsequent Change Request ID for that matter) as any model retrieved from the configuration storage of Lotem must be based upon a previous ACR. In addition, the Change Request IDs are not version numbers because they are not numbers associated with or representing a version. Appeal 2019-005973 Application 15/386,214 16 Reply Br. 10; see Appeal Br. 27 (“The Change Request IDs are merely alphanumeric identifiers assigned to change requests.”; citing Lotem, 12:50– 67). We agree with Appellant. On this record, we are persuaded the Examiner errs in finding that independent claim 1 is rendered obvious over the combined teachings of Litvin and Lotem, and we do not sustain that rejection. Because Appellant relies solely on its contentions with respect to claim 1 to overcome the obviousness rejection of independent claim 13, we also do not sustain the rejection of that claim. Because, like their base claims, the Examiner also rejects the dependent claims only on the combined teachings of Litvin and Lotem, we also do not sustain the obviousness rejection of those claims.7 Appeal Br. 27–28. DECISION 1. The Examiner errs in rejecting: a. claims 1, 4–10, 13, and 16–26 under 35 U.S.C. § 112(a) as lacking enablement; b. claims 1, 4–10, 13, and 16–26 under 35 U.S.C. § 112(b) as indefinite; and c. claims 1, 4–10, 13, and 16–26 under 35 U.S.C. § 103 as obvious over the combined teachings of Litvin and Lotem. 2. Thus, on this record, claims 1, 4–10, 13, and 16–26 are not unpatentable. 7 Although Appellant separately challenges the rejection of dependent claims 4–10, 16–20, 24, and 25, because reversal of the rejection of independent claims 1 and 13 is dispositive, we do not reach those separate challenges. See Appeal Br. 28–37; Reply Br. 11–19. Appeal 2019-005973 Application 15/386,214 17 CONCLUSION We reverse the Examiner’s rejections of claims 1, 4–10, 13, and 16– 26. In summary: Claims Rejected 35 U.S.C. § Reference(s)/Basis Affirmed Reversed 1, 4–10, 13, 16–26 112(a) Lack of Enablement 1, 4–10, 13, 16–26 1, 4–10, 13, 16–26 112(b) Indefiniteness 1, 4–10, 13, 16–26 1, 4–10, 13, 16–26 103 Litvin, Lotem 1, 4–10, 13, 16–26 Overall Outcome 1, 4–10, 13, 16–26 REVERSED Copy with citationCopy as parenthetical citation