DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
Claim Objections
Claims 1, 9, 12, 15 and 16 are objected to because of the following informalities:
(claim 1, line 5) “one or more actuator” should be changed to either “an actuator” or “one or more actuators”.
(claim 1, line 6) “one or more hydraulic cylinder” should be changed to either “a hydraulic cylinder” or “one or more hydraulic cylinders”.
(claim 1, line 12) “one or more control valve” should be changed to “a control valve” or “one or more control valves”.
(claim 1, line 15) “configured adjust” should be changed to “configured to adjust”.
(claim 1, line 16) “one or more control element” should be changed to “a control element” or “one or more control elements”.
(claim 9, line 2) “positioned one either side” should be changed to “positioned on either side”.
(claim 12, line 5) “one or more actuator” should be changed to either “an actuator” or “one or more actuators”.
(claim 12, line 6) “one or more hydraulic cylinder” should be changed to either “a hydraulic cylinder” or “one or more hydraulic cylinders”.
(claim 12, line 16) “one or more control valve” should be changed to “a control valve” or “one or more control valves”.
(claim 12, line 19) “configured adjust” should be changed to “configured to adjust”.
(claim 12, line 20) “one or more control element” should be changed to “a control element” or “one or more control elements”.
(claim 15, line 2) “raise and lower loader arms” should be changed to “raise and lower said loader arms”.
(claim 16, line 19) “one or more control valve” should be changed to “a control valve” or “one or more control valves”.
(claim 16, line 22) “configured adjust” should be changed to “configured to adjust”.
Appropriate correction is required.
Claim Interpretation
The following is a quotation of 35 U.S.C. 112(f):
(f) Element in Claim for a Combination. – An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The following is a quotation of pre-AIA 35 U.S.C. 112, sixth paragraph:
An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.
The claims in this application are given their broadest reasonable interpretation using the plain meaning of the claim language in light of the specification as it would be understood by one of ordinary skill in the art. The broadest reasonable interpretation of a claim element (also commonly referred to as a claim limitation) is limited by the description in the specification when 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is invoked.
As explained in MPEP § 2181, subsection I, claim limitations that meet the following three-prong test will be interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph:
(A) the claim limitation uses the term “means” or “step” or a term used as a substitute for “means” that is a generic placeholder (also called a nonce term or a non-structural term having no specific structural meaning) for performing the claimed function;
(B) the term “means” or “step” or the generic placeholder is modified by functional language, typically, but not always linked by the transition word “for” (e.g., “means for”) or another linking word or phrase, such as “configured to” or “so that”; and
(C) the term “means” or “step” or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
Use of the word “means” (or “step”) in a claim with functional language creates a rebuttable presumption that the claim limitation is to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites sufficient structure, material, or acts to entirely perform the recited function.
Absence of the word “means” (or “step”) in a claim creates a rebuttable presumption that the claim limitation is not to be treated in accordance with 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph. The presumption that the claim limitation is not interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, is rebutted when the claim limitation recites function without reciting sufficient structure, material or acts to entirely perform the recited function.
Claim limitations in this application that use the word “means” (or “step”) are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action. Conversely, claim limitations in this application that do not use the word “means” (or “step”) are not being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, except as otherwise indicated in an Office action.
This application includes one or more claim limitations that do not use the word “means,” but are nonetheless being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, because the claim limitation(s) uses a generic placeholder that is coupled with functional language without reciting sufficient structure to perform the recited function and the generic placeholder is not preceded by a structural modifier. Such claim limitation(s) is/are: “one or more control element…configured to be manipulated by a user to generate an electrical control signal” in claims 1 and 12, “a drive assembly configured to propel” in claims 7 and 16, “one or more control elements…configured to be manipulated by a user to generate an electrical control signals” in claim 17.
Because this/these claim limitation(s) is/are being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, it/they is/are being interpreted to cover the corresponding structure described in the specification as performing the claimed function, and equivalents thereof.
If applicant does not intend to have this/these limitation(s) interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph, applicant may: (1) amend the claim limitation(s) to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph (e.g., by reciting sufficient structure to perform the claimed function); or (2) present a sufficient showing that the claim limitation(s) recite(s) sufficient structure to perform the claimed function so as to avoid it/them being interpreted under 35 U.S.C. 112(f) or pre-AIA 35 U.S.C. 112, sixth paragraph.
Claim Rejections - 35 USC § 102
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of the appropriate paragraphs of 35 U.S.C. 102 that form the basis for the rejections under this section made in this Office action:
A person shall be entitled to a patent unless –
(a)(1) the claimed invention was patented, described in a printed publication, or in public use, on sale, or otherwise available to the public before the effective filing date of the claimed invention.
Claims 1-12 and 15 are rejected under 35 U.S.C. 102(a)(1) as being anticipated by Hansen et al. (US 2017/0284316).
As concerns claim 1, Hansen shows a work machine (200) comprising: a frame (210) presenting an interior compartment (paragraph 0033: within the frame); an operator area (250, 255); loader arms (230, 234) supported on said frame; one or more actuator (238) operatively associated with said loader arms (Fig. 2 & 3), wherein said one or more actuator comprises one or more hydraulic cylinder (paragraph 0039); an engine or motor (220, 420) positioned within the interior compartment (paragraph 0033); an auxiliary pump (425) configured to provide hydraulic power to the one or more actuator (438, 431), wherein said auxiliary pump receives rotary power from said engine or motor (Fig. 5; paragraph 0050), and wherein said auxiliary pump is a variable displacement pump (paragraph 0050); one or more control valve (466) hydraulically connecting said auxiliary pump to said one or more actuator (Fig. 5), wherein said one or more control valve is an open center control valve that includes an adjustable spool and an electrical actuator configured to adjust a position of said spool (paragraph 0034: actuation of operator input devices can generate signals in the form of electrical signals, hydraulic signals, and/or mechanical signals, wherein signals generated in response to operator input devices are provided to various components on the power machine for controlling various functions on the power machine; paragraph 0049: a controller that receives signals (collectively, 463) from one or more user input devices (464) and, responsive to at least one or more signals from the user input devices, provides control signals (collectively 465) to control operation of various work elements of the power machine, control of the lift and tilt functions is accomplished by providing control signals (465C) for selectively actuating a control valve assembly (466) to provide pressurized fluid to the lift and tilt cylinders (438, 431), respectively; & paragraph 0051: control valve assembly (466) is an open center multiple spool valve arrangement (not shown), with the position of the spools being controlled, at least in part, by actuators that receive control signals (465C) and responsively shifting the spools to provide hydraulic flow via conduits (467A, 467B) to the lift cylinder (438), and the tilt cylinder (431), respectively); and one or more control element (260, 464) associated with said operator area (Fig. 2), wherein said one or more control element is configured to be manipulated by a user to generate an electrical control signal (463, 465C) for the electrical actuator of the one or more control valve (paragraph 0034: actuation of operator input devices can generate signals in the form of electrical signals, hydraulic signals, and/or mechanical signals, wherein signals generated in response to operator input devices are provided to various components on the power machine for controlling various functions on the power machine; paragraph 0049: a controller that receives signals (collectively, 463) from one or more user input devices (464) and, responsive to at least one or more signals from the user input devices, provides control signals (collectively 465) to control operation of various work elements of the power machine, control of the lift and tilt functions is accomplished by providing control signals (465C) for selectively actuating a control valve assembly (466) to provide pressurized fluid to the lift and tilt cylinders (438, 431), respectively; & paragraph 0051: control valve assembly (466) is an open center multiple spool valve arrangement (not shown), with the position of the spools being controlled, at least in part, by actuators that receive control signals (465C) and responsively shifting the spools to provide hydraulic flow via conduits (467A, 467B) to the lift cylinder (438), and the tilt cylinder (431), respectively).
As concerns claim 2, Hansen shows wherein said operator area comprises a cab (250), and wherein no hydraulic lines (electrical signals) extend from said cab to said frame (paragraph 0034).
As concerns claim 3, Hansen shows wherein said one or more actuator comprises lift actuators (238, 438) extending between the frame and the loader arms (Fig. 2 & 3).
As concerns claim 4, Hansen shows a hitch assembly (270) pivotally connected to said loader arms (Fig. 2).
As concerns claim 5, Hansen shows wherein said one or more actuator comprises tilt actuators (235, 431) extending between the loader arms and the hitch assembly (Fig. 2).
As concerns claim 6, Hansen shows wherein said auxiliary pump is positioned forward of said engine or motor (Fig. 5).
As concerns claim 7, Hansen shows a drive assembly (440A, 440B) configured to propel said frame over a ground surface; a pair of drive motors configured to power said drive assembly (paragraph 0050); and a pair of hydrostatic transmissions (424A, 424B) configured to provide hydraulic power to said pair of drive motors.
As concerns claim 8, Hansen shows wherein said engine or motor provides rotary power to said pair of hydrostatic transmissions (Fig. 5; paragraph 0050).
As concerns claim 9, Hansen shows wherein said pair of drive motors are positioned on either side of the auxiliary pump (Fig. 5; paragraph 0050).
As concerns claim 10, Hansen shows a hydraulic reservoir (hydraulic fluid source) for holding hydraulic fluid, wherein said hydraulic reservoir is positioned in the interior compartment of the frame.
As concerns claim 11, Hansen shows a hydraulic output (472) for connecting to an attachment (480), wherein said one or more control valve hydraulically connects said auxiliary pump to said hydraulic output (Fig. 5).
As concerns claim 12, Hansen shows a work machine (200) comprising: a frame (210) presenting an interior compartment (paragraph 0033: within the frame); an operator area (250, 255); loader arms (230, 234) supported on said frame; one or more actuator (238) operatively associated with said loader arms (Fig. 2 & 3), wherein said one or more actuator comprises one or more hydraulic cylinder (paragraph 0039); an engine or motor (220, 420) positioned within the interior compartment (paragraph 0033); a drive assembly (440A, 440B) configured to propel said work machine over a ground surface, said drive assembly comprising a pair of transversely-spaced endless tracks that support said frame on the ground surface (paragraph 0029); a pair of drive motors configured to power said drive assembly (paragraph 0050); an auxiliary pump (425) configured to provide hydraulic power to the one or more actuator (438, 431), wherein said auxiliary pump receives rotary power from said engine or motor (Fig. 5; paragraph 0050), and wherein said auxiliary pump is a variable displacement pump (paragraph 0050); one or more control valve (466) hydraulically connecting said auxiliary pump to said one or more actuator (Fig. 5), wherein said one or more control valve is an open center control valve that includes an adjustable spool and an electrical actuator configured to adjust a position of said spool (paragraph 0034: actuation of operator input devices can generate signals in the form of electrical signals, hydraulic signals, and/or mechanical signals, wherein signals generated in response to operator input devices are provided to various components on the power machine for controlling various functions on the power machine; paragraph 0049: a controller that receives signals (collectively, 463) from one or more user input devices (464) and, responsive to at least one or more signals from the user input devices, provides control signals (collectively 465) to control operation of various work elements of the power machine, control of the lift and tilt functions is accomplished by providing control signals (465C) for selectively actuating a control valve assembly (466) to provide pressurized fluid to the lift and tilt cylinders (438, 431), respectively; & paragraph 0051: control valve assembly (466) is an open center multiple spool valve arrangement (not shown), with the position of the spools being controlled, at least in part, by actuators that receive control signals (465C) and responsively shifting the spools to provide hydraulic flow via conduits (467A, 467B) to the lift cylinder (438), and the tilt cylinder (431), respectively); and one or more control element (260, 464) associated with said operator area (Fig. 2), wherein said one or more control element is configured to be manipulated by a user to generate an electrical control signal (463, 465C) for the electrical actuator of the one or more control valve (paragraph 0034: actuation of operator input devices can generate signals in the form of electrical signals, hydraulic signals, and/or mechanical signals, wherein signals generated in response to operator input devices are provided to various components on the power machine for controlling various functions on the power machine; paragraph 0049: a controller that receives signals (collectively, 463) from one or more user input devices (464) and, responsive to at least one or more signals from the user input devices, provides control signals (collectively 465) to control operation of various work elements of the power machine, control of the lift and tilt functions is accomplished by providing control signals (465C) for selectively actuating a control valve assembly (466) to provide pressurized fluid to the lift and tilt cylinders (438, 431), respectively; & paragraph 0051: control valve assembly (466) is an open center multiple spool valve arrangement (not shown), with the position of the spools being controlled, at least in part, by actuators that receive control signals (465C) and responsively shifting the spools to provide hydraulic flow via conduits (467A, 467B) to the lift cylinder (438), and the tilt cylinder (431), respectively).
As concerns claim 15, Hansen shows wherein the one or more actuator includes lift actuators (238, 438) operable to raise and lower said loader arms of the work machine (Fig. 2 & 3) and tilt actuators (235, 431) operable to adjust an orientation of a hitch assembly (270) pivotally connected to said loader arms (Fig. 2).
Claim Rejections - 35 USC § 103
In the event the determination of the status of the application as subject to AIA 35 U.S.C. 102 and 103 (or as subject to pre-AIA 35 U.S.C. 102 and 103) is incorrect, any correction of the statutory basis (i.e., changing from AIA to pre-AIA ) for the rejection will not be considered a new ground of rejection if the prior art relied upon, and the rationale supporting the rejection, would be the same under either status.
The following is a quotation of 35 U.S.C. 103 which forms the basis for all obviousness rejections set forth in this Office action:
A patent for a claimed invention may not be obtained, notwithstanding that the claimed invention is not identically disclosed as set forth in section 102, if the differences between the claimed invention and the prior art are such that the claimed invention as a whole would have been obvious before the effective filing date of the claimed invention to a person having ordinary skill in the art to which the claimed invention pertains. Patentability shall not be negated by the manner in which the invention was made.
Claims 13, 14 and 16-20 are rejected under 35 U.S.C. 103 as being unpatentable over Hansen et al. alone.
As concerns claim 13, Hansen shows wherein said auxiliary pump (425) is forward of said engine or motor (Fig. 5), a pair of hydrostatic transmissions (424A, 424B) that receive rotary power from said engine or motor (Fig. 5; paragraph 0050) and configured to provide hydraulic power to said pair of drive motors (paragraph 0050). Hansen discloses the claimed invention except for wherein the pair of hydrostatic transmissions are positioned forward of said auxiliary pump. It would have been an obvious matter of design choice to have positioned the pair of hydrostatic transmissions forward of the auxiliary pump, as Applicant has not disclosed that it solves any stated problem of the prior art or is for any particular purpose other than being an alternative to positioning the auxiliary pump forward of the pair of hydrostatic transmissions. Furthermore, one of ordinary skill in the art would have expected the invention to perform equally well with the auxiliary pump being positioned forward of the pair of hydrostatic transmissions because the pumps would still have been capable of being powered by the engine in order to provide hydraulic power. Additionally, it has been held that rearranging parts of an invention involves only routine skill in the art. Thus, one of ordinary skill in the art would have recognized that positioning the pair of hydrostatic transmissions forward of the auxiliary pump would have provided predictable results and a reasonable expectation of success. Therefore, it would have been obvious to modify Hansen to obtain the invention as specified in the claim.
As concerns claim 14, Hansen shows wherein said pair of drive motors are positioned on either side of said auxiliary pump (Fig. 5; paragraph 0050).
As concerns claim 16, Hansen shows a work machine (200) comprising: a frame (210) presenting an interior compartment (paragraph 0033: within the frame); a drive assembly (440A, 440B) configured to propel said work machine over a ground surface; an operator area (250, 255); loader arms (230, 234) supported on said frame; a plurality of actuators (238) operatively associated with said loader arms (Fig. 2 & 3), wherein said plurality of actuators comprises hydraulic cylinders (paragraph 0039); an engine or motor (220, 420) positioned within the interior compartment (paragraph 0033); a pair of drive motors configured to power said drive assembly (paragraph 0050); a pair of hydrostatic transmissions (424A, 424B) that receive rotary power from said engine or motor (Fig. 5; paragraph 0050) and positioned forward of said engine or motor (Fig. 5) and configured to provide hydraulic power to said pair of drive motors (paragraph 0050); an auxiliary pump (425) configured to provide hydraulic power to the plurality of actuators (438, 431), wherein said auxiliary pump receives rotary power from said engine or motor (Fig. 5; paragraph 0050), wherein said auxiliary pump is positioned between said pair of drive motors (Fig. 5; paragraph 0050), and wherein said auxiliary pump is a variable displacement pump (paragraph 0050); and one or more control valve (466) hydraulically connecting said auxiliary pump to said plurality of actuators (Fig. 5), wherein said one or more control valve is an open center control valve that includes an adjustable spool and an actuator configured to adjust a position of said spool (paragraph 0034: actuation of operator input devices can generate signals in the form of electrical signals, hydraulic signals, and/or mechanical signals, wherein signals generated in response to operator input devices are provided to various components on the power machine for controlling various functions on the power machine; paragraph 0049: a controller that receives signals (collectively, 463) from one or more user input devices (464) and, responsive to at least one or more signals from the user input devices, provides control signals (collectively 465) to control operation of various work elements of the power machine, control of the lift and tilt functions is accomplished by providing control signals (465C) for selectively actuating a control valve assembly (466) to provide pressurized fluid to the lift and tilt cylinders (438, 431), respectively; & paragraph 0051: control valve assembly (466) is an open center multiple spool valve arrangement (not shown), with the position of the spools being controlled, at least in part, by actuators that receive control signals (465C) and responsively shifting the spools to provide hydraulic flow via conduits (467A, 467B) to the lift cylinder (438), and the tilt cylinder (431), respectively). Hansen discloses the claimed invention except for wherein said auxiliary pump is positioned between said engine or motor and said pair of hydrostatic transmissions. It would have been an obvious matter of design choice to have positioned the auxiliary pump between the engine and the pair of hydrostatic transmissions, as Applicant has not disclosed that it solves any stated problem of the prior art or is for any particular purpose other than being an alternative to positioning the pair of hydrostatic transmissions between the engine and the auxiliary pump. Furthermore, one of ordinary skill in the art would have expected the invention to perform equally well with the pair of hydrostatic transmissions being positioned between the engine and the auxiliary pump because the pumps would still have been capable of being powered by the engine in order to provide hydraulic power. Additionally, it has been held that rearranging parts of an invention involves only routine skill in the art. Thus, one of ordinary skill in the art would have recognized that positioning the auxiliary pump between the engine and the pair of hydrostatic transmissions would have provided predictable results and a reasonable expectation of success. Therefore, it would have been obvious to modify Hansen to obtain the invention as specified in the claim.
As concerns claim 17, Hansen shows wherein said actuator of said one or more control valve is an electrical actuator (paragraph 0034: actuation of operator input devices can generate signals in the form of electrical signals, hydraulic signals, and/or mechanical signals, wherein signals generated in response to operator input devices are provided to various components on the power machine for controlling various functions on the power machine; paragraph 0049: a controller that receives signals (collectively, 463) from one or more user input devices (464) and, responsive to at least one or more signals from the user input devices, provides control signals (collectively 465) to control operation of various work elements of the power machine, control of the lift and tilt functions is accomplished by providing control signals (465C) for selectively actuating a control valve assembly (466) to provide pressurized fluid to the lift and tilt cylinders (438, 431), respectively; & paragraph 0051: control valve assembly (466) is an open center multiple spool valve arrangement (not shown), with the position of the spools being controlled, at least in part, by actuators that receive control signals (465C) and responsively shifting the spools to provide hydraulic flow via conduits (467A, 467B) to the lift cylinder (438), and the tilt cylinder (431), respectively), further comprising one or more control element (260, 464) associated with said operator area (Fig. 2), wherein said one or more control element is configured to be manipulated by a user to generate an electrical control signal (463, 465C) for the electrical actuator of the one or more control valve (paragraph 0034: actuation of operator input devices can generate signals in the form of electrical signals, hydraulic signals, and/or mechanical signals, wherein signals generated in response to operator input devices are provided to various components on the power machine for controlling various functions on the power machine; paragraph 0049: a controller that receives signals (collectively, 463) from one or more user input devices (464) and, responsive to at least one or more signals from the user input devices, provides control signals (collectively 465) to control operation of various work elements of the power machine, control of the lift and tilt functions is accomplished by providing control signals (465C) for selectively actuating a control valve assembly (466) to provide pressurized fluid to the lift and tilt cylinders (438, 431), respectively; & paragraph 0051: control valve assembly (466) is an open center multiple spool valve arrangement (not shown), with the position of the spools being controlled, at least in part, by actuators that receive control signals (465C) and responsively shifting the spools to provide hydraulic flow via conduits (467A, 467B) to the lift cylinder (438), and the tilt cylinder (431), respectively).
As concerns claim 18, Hansen shows wherein said plurality of actuators comprise lift actuators (238, 438) extending between the frame and the loader arms (Fig. 2 & 3).
As concerns claim 19, Hansen shows a hitch assembly (270) pivotally connected to said loader arms (Fig. 2).
As concerns claim 20, Hansen shows wherein said plurality of actuators comprise tilt actuators (235, 431) extending between the loader arms and the hitch assembly (Fig. 2).
Conclusion
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure. Mahrenholz et al. (US 2020/0181876) and Bock et al. (US 2009/0078488) each show a work machine having a control valve that includes an adjustable spool and an electrical actuator configured to adjust a position of the spool.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MATTHEW R BUCK whose telephone number is (571)270-3653. The examiner can normally be reached Monday-Thursday 6:30-5.
Examiner interviews are available via telephone, in-person, and video conferencing using a USPTO supplied web-based collaboration tool. To schedule an interview, applicant is encouraged to use the USPTO Automated Interview Request (AIR) at http://www.uspto.gov/interviewpractice.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Nicole Coy can be reached at (571)272-5405. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
Information regarding the status of published or unpublished applications may be obtained from Patent Center. Unpublished application information in Patent Center is available to registered users. To file and manage patent submissions in Patent Center, visit: https://patentcenter.uspto.gov. Visit https://www.uspto.gov/patents/apply/patent-center for more information about Patent Center and https://www.uspto.gov/patents/docx for information about filing in DOCX format. For additional questions, contact the Electronic Business Center (EBC) at 866-217-9197 (toll-free). If you would like assistance from a USPTO Customer Service Representative, call 800-786-9199 (IN USA OR CANADA) or 571-272-1000.
/MATTHEW R BUCK/Primary Examiner, Art Unit 3672
Prosecution Insights