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 Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
4. Claims 25 is rejected under 35 U.S.C. 101 because the claimed recitation of a use, without setting forth any steps involved in the process, results in an improper definition of a process, i.e., results in a claim which is not a proper process claim under 35 U.S.C. 101. See for example Ex parte Dunki, 153 USPQ 678 (Bd.App. 1967) and Clinical Products, Ltd. v. Brenner, 255 F. Supp. 131, 149 USPQ 475 (D.D.C. 1966).
Claim Rejections - 35 USC § 112
The following is a quotation of 35 U.S.C. 112(b):
(b) CONCLUSION.—The 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.
The following is a quotation of 35 U.S.C. 112 (pre-AIA ), second paragraph:
The specification shall conclude with one or more claims particularly pointing out and distinctly claiming the subject matter which the applicant regards as his invention.
6. Claims 20, 23 and 25 are rejected under 35 U.S.C. 112(b) or 35 U.S.C. 112 (pre-AIA ), second paragraph, as being indefinite for failing to particularly point out and distinctly claim the subject matter which the inventor or a joint inventor, or for pre-AIA the applicant regards as the invention.
A broad range or limitation together with a narrow range or limitation that falls within the broad range or limitation (in the same claim) may be considered indefinite if the resulting claim does not clearly set forth the metes and bounds of the patent protection desired. See MPEP § 2173.05(c). In the present instance, claims 20 and 23 recite the broad recitation 1) constant flow rate (claim 20, limitation c), 2) finalizing (claim 20, limitation d) and 3) selected from the group of…. (claim 23), and the claim also recites 1) “preferably” being identical to flow rate (RA1), 2) “preferably” in the presence…” and 3) “preferably” a wooden substrate, which is the narrower statement of the range/limitation. The claim(s) are considered indefinite because there is a question or doubt as to whether the feature introduced by such narrower language is (a) merely exemplary of the remainder of the claim, and therefore not required, or (b) a required feature of the claims.
9. Claim 25 provides for the use of the polymer composition, but, since the claim does not set forth any steps involved in the method/process, it is unclear what method/process applicant is intending to encompass. A claim is indefinite where it merely recites a use without any active, positive steps delimiting how this use is actually practiced.
Claim Rejections - 35 USC § 102
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.
Claim(s) 1, 3, 8-16, 18-19, 22-23 and 25 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by US 2012/0095131 (herein Kinoshita) as evidenced by US 2015/0323850 (herein Shitagami).
As to claims 1 and 11, Kinoshita discloses an aqueious non-fluorine containing vinyl polymer suspension comprising the vinyl polymer prepared from the free radical emulsion polymerization of a mixture (reading on monomer mixtures A) and specifically note that a pre-emulsion (A1) monomer mixture is first polymerized prior to polymerization of the rest of the mixture (A2) comprising polymerizing (see examples, specifically example 4 and table 1):
Reading on claim limitation
Example 4 monomer name
Amount
Weight% total
(i)
Glycidyl methacrylate
(GMA)
10
15.5
N-methylol acrylamide
0.5
2-hydroxy ethyl methacrylate
5
(ii)
methacryloxyl propyl trimethoxy silane
1.5
1.5
(iii)
Allyl methacrylate
1.5
1.5
(iv)
Adeka Reasoap SR-10
2
2
further non-ionic monomer
Styrene
30
80
Phenoxy ethyl acrylate
20
Methyl methacrylate
14.8
Butyl acrylate
9
Acrylonitrile
5
Acrylamide
2.5
Acrylic acid
0.2
The copolymer is mixed with a crosslinking agent (crosslinker). See paragraph 97-99, 115 and examples (table 3).
Note that Reasoap SR-10 is an Alkyl ether-based anionic surfactant (paragraph 133) that is a reactive emulsifying agent having an ethylenically unsaturated group (see paragraphs 56-58) and thus is copolymerizable. Specifically, Reasoap SR-10 has the structure shown below, wherein n=10 and B is NH4+. See paragraph 149 and 373-374 of Shitagami for evidence. This reads on the claimed structure wherein R= C8 to C15 alkyl group, n=10, X=SO3- and M is is NH4+.
PNG
media_image1.png
287
472
media_image1.png
Greyscale
As to claim 3, acrylic acid reads on (v) and acrylamide reads on (vi). See example 4 in table 1.
As to claim 8, the crosslinkable group containing monomer is hydroxylethyl methacrylate reading on -CH2-OH, etc.
As to claim 9, 4-methacryloxyl propyl trimethoxy silane has the structure –(CH2)n-Si(OR)3 wherein n=3 and R=methyl (1 carbon alkyl).
As to claim 10, allyl methacrylate has two (meth)acrylic groups and allyl groups.
As to claim 12, the monomer is acrylic acid. See example 4. Also see paragraph 45 disclosing other carboxyl group containing monomers such as phosphoric acid bearing monomers, sulfonic acid bearing monomers, etc.
As to claim 13, nitrogen containing monomers such as N,N-diethylaminopropyl acrylic amide are taught as alternatives to acrylamide (b). See paragraph 31.
As to claim 14, see example 45 in table 3 wherein the amount of copolymer is 100 parts and the amount of crosslinker is 6.0, thus the weight ratio is about 16.7 and within the claimed range. Also see paragraph 115, wherein the crosslinker is present in 1-40 parts per 100 parts polymer.
As to claim 15, the crosslinker (crosslinking agent) may be two carboxylic acid such as phthalic acid. See paragraph 99.
As to claim 16, the crosslinker may be adipic acid dihydrazide. See paragraph 49.
As to claims 18-19, where the preparation of the polymer dispersion is prepared via preparing a monomer mixture pre-emulsion of 1% of the monomer mixture (A1) in a feed vessel and feeding it into a reactor and polymerizing the mixture followed by, after delay, feeding the rest (A2) in the vessel and polymerizing. See examples, specifically example 4.
As to claim 22, coating compositions (paragraph 78-80 and examples) comprising the polymer dispersion and leveling agents (paragraph 119), surfactants (paragraph 25 and examples), and thickening agents (examples).
As to claims 23 and 25, a substrate (aluminum foil, a metal) is coated with the composition. See examples and paragraphs 143, 147, and 151.
Claim(s) 1, 3, 7-19 and 22-25 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by JP 2010138256 (herein Hiroki) as evidenced by US 20240336772 (herein Balk) and US 2020/0002548 (herein Qian).
In setting forth the instant rejection, the machine translation supplied by applicant on 1/22/26 has been relied upon.
As to claims 1, 11-12, 15-16, Hiroki discloses an aqueous, non-fluorine containing vinyl polymer dispersion comprising:
The reaction product of free radical emulsion polymerized monomers (A) of a mixture (A1) and (A2), wherein the monomers are listed in example 7 of table 1, which is reproduced below
Reading on claim limitation
Example 4 monomer name
Amount
Weight% total
(i)
Glycidyl methacrylate
(GMA)
3
5.5
Diacetone acrylamide
(DAAM)
1.5
2-hydroxy ethyl methacrylate
(2-HEMA)
1
(ii)
γ-methacryloxyl propyl trimethoxy silane
(KBM-502)
0.25
0.25
(iii)
Triallyl cyanurate
(TAC)
0.5
0.5
(iv)
Adeka Reasoap SR-1025
1
1
further non-ionic monomer
Methyl methacrylate
(MMA)
35.5
93
Cyclohexyl methacrylate
(CHMA)
10
n-Butyl acrylate
(n-BMA)
5
2-ethylhexyl acrylate
(2-EHA)
24.5
Methyl methacrylate
(MMA)
18
(v)
Acrylic acid
1
1
The composition is split into two monomer mixtures (a) and (b), reading on claimed mixtures A1 and A2. Also the composition comprises the crosslinker adipic acid dihydrazide (ADH) in 0.7 parts per 100 parts polymer, thus reading on claimed crosslinker B.
As to Adeka Reasoap SR-1025 reading on iv, SR-1025 has the structure below (paragraph 228), wherein R1=alkyl, C1-C20 and n=10 and Y=SO3-NH4+. See paragraph 228 and 327 of Balk for evidence. The R1 group is specifically C10-C14 alkyl group. See paragraph 74 of Qian for evidence. Thus, reading on the claimed formula of claim 11 wherein R=C10-C14, M= NH4+ and X= SO3-.
PNG
media_image2.png
179
565
media_image2.png
Greyscale
As to claims 3 and 13, the polymer comprises acrylic acid reading on v (see example 7) and may comprise the nitrogen containing monomer may be dimethylaminoethyl methacrlate. See paragraph 42.
As to claim 7, table 2 shows that the Tg of layer A (first monomer mixture A1) is 98 oC and the Tg of the second layer block B (second monomer mixture A2) is 10 oC. Also see paragraph 27-29 and 43-44 of the broader disclosure teaching glass transition temperatures (Tg) that fall within the claimed range. Therefore, as seen in table 1, the monomer compositions A1 and A2 are different, the difference in the Tg is more than 20 °C and the Tg of A1 is 98 ° C.
As to claim 8, the pendant group of (i) is CH2OH, etc. See 2-HEMA in table 1.
As to claim 9, 4-methacryloxyl propyl trimethoxy silane (KBM-502)Be has the structure –(CH2)n-Si(OR)3 wherein n=3 and R=methyl (1 carbon alkyl).
As to claim 10, triallyl cyanurate (TAC) in table 1 has three allyl groups.
As to claim 14, the ratio is 100 to 0.7, which is within the claimed range. See example 7 and table 1.
As to claim 17, the solid content is about 42.5 wt% in example 7, the minimum film formation temperature (MFT) is 25 ° C and the particle size (diameter) is taught as 50 to 300 nm (paragraph 77). Also note that the MFT is broadly less than 60 ° C (paragraph 78) and the solid content is generally 20-80 wt% (paragraph 82).
As to claims 18-19, A1 is polymerized in a vessel followed by polymerization of A2 to yield the copolymer reading on all the claimed steps. See examples, specifically example 7.
As to claim 21, the method produces a solid content is about 42.5 wt% in example 7, the minimum film formation temperature (MFT) is 25 ° C and the particle size (diameter) is taught as 50 to 300 nm (paragraph 77). Also note that the MFT is broadly less than 60 ° C (paragraph 78) and the solid content is generally 20-80 wt% (paragraph 82). Further, as described in the examples, the monomer mixture b (reading on claimed A2) is added when the first monomer mixture a (claimed A1) is still being polymerized, thus would yield a gradient.
As to claims 22-23 and 25, Hiroki discloses coating compositions of the dispersion on substrate such as wood, glass, metal, etc. (see paragraph 85 and 117) comprising additives such as pigments, leveling agents, UV absorbers, etc. See paragraph 83.
As to claim 24, a method of coating the substrate is taught by applying the composition onto a substrate and coating to a thickness of about 4 mil in the examples (about 100 µm) by spray coating (examples) and curing the coating at 130 ° C for about 5 minutes (examples).
Claim(s) 1-4, 7 and 9-15 and 17-25 is/are rejected under 35 U.S.C. 102(a)(1) as being anticipated by JP 2008069249 (herein Kanji) as evidenced by US 2015/0323850 (herein Shitagami).
In setting forth the instant rejection, the machine translation supplied by applicant on 1/22/26 has been relied upon.
As to claims 1-4 and 11-14, Hiroki discloses an aqueous, non-fluorine containing vinyl polymer dispersion comprising:
The reaction product of free radical emulsion polymerized monomers (A) of a mixture (A1) and (A2), wherein the monomers are listed in example A17 of table 1, which is reproduced below
Monomer Mixture of Kanji
Reading on claim limitation
Example 4/monomer name
Amount
Weight% total
emulsifier
(iv)
Adeka Reasoap SR-10
1
1
Monomer mixture 1 (reading on A1)
further non-ionic monomer
Methyl methacrylate
(MMA)
47
47
(v)
Acrylic Acid
(AA)
2
2
(iii)
trimethylolpropane trimethacrylate
(TMPTMA)
1
1
Monomer mixture 2 (reading on A2)
further non-ionic monomer
2-Ethylhexyl acrylate
(2-EHA)
22
44
Methyl methacrylate
(MMA)
22
(i)
and
(vi)
2-isopropenyl-2-oxazoline
(IPO)
5
5
(ii)
γ-methacryloxyl propyl trimethoxy silane
(TMSMA)
1
1
Example A17 is mixed with a crosslinker (crosslinking agent) B1 in example 35 in table 5 in a ratio of 99/1. Also the composition comprises the crosslinker adipic acid dihydrazide (ADH) in 0.7 parts per 100 parts polymer, thus reading on claimed crosslinker B. Also note that IPO reads on both components (i) and (vi).
Note that Reasoap SR-10 is a reactive emulsifier. See examples. Specifically, Reasoap SR-10 has the structure shown below, wherein n=10 and B is NH4+. See paragraph 149 and 373-374 of Shitagami for evidence. This reads on the claimed structure wherein R= C8 to C15 alkyl group, n=10, X=SO3- and M is is NH4+.
PNG
media_image1.png
287
472
media_image1.png
Greyscale
As to claim 7, table 1 shows that the Tg of mixture 1 (first monomer mixture A1) is 105 oC and the Tg of the mixture 2 (second monomer mixture A2) is 0 oC. Also see paragraph 27-29 and 43-44 of the broader disclosure teaching glass transition temperatures (Tg) that fall within the claimed range. Therefore, as seen in table 1, the monomer compositions A1 and A2 are different, the difference in the Tg is more than 20 °C and the Tg of A1 is 105 ° C.
As to claim 9, 4-methacryloxyl propyl trimethoxy silane (KBM-502)Be has the structure –(CH2)n-Si(OR)3 wherein n=3 and R=methyl (1 carbon alkyl).
As to claim 10, TMPTMA has three methacrylic groups.
As to claim 15, the crosslinker B1 has a carboxylic acid. See example B1.
As to claim 17, A (the nonvolatile content, NV) is taught as 44 wt% in example A17 (see table 1), which is roughly the same when mixed with the crosslinker B1 in example 35. The particle size is taught as 50 to 200 nm (see paragraph 55). The particle size of polymer A17 is 139 in table 1. The MFT of polymer A17 in table 1 is 54 ° C.
As to claims 18-19, A1 is polymerized in a vessel followed by polymerization of A2 to yield the copolymer reading on all the claimed steps. See examples, specifically example A17.
As to claim 20, example A17 (which is substantially similar to A1) a pre-emulsion (A1) of monomer mixture A1 is feed in 10% of the monomer mixture (examples) and copolymerized with the surfactant and initiator at 80 ° C. Next the remainer of the monomer miture A1 is feed and it is polymerized over 3 hours (120 minutes addition plus 60 minutes) at a flow rate (dropwise). Afterwards, A2 was added over 120 minutes at 80 ° C. The pH was adjusted to through addition of a neutralizing agent (ammonia). Afterwards, crosslinker (B1) is added in example 35.
As to claim 21, table 1 shows that the Tg of mixture 1 (first monomer mixture A1) is 105 oC and the Tg of the mixture 2 (second monomer mixture A2) is 0 oC. Also see paragraph 27-29 and 43-44 of the broader disclosure teaching glass transition temperatures (Tg) that fall within the claimed range. Therefore, as seen in table 1, the monomer compositions A1 and A2 are different, the difference in the Tg is more than 20 °C and the Tg of A1 is 105 ° C. Further, as described in the examples, the monomer mixture 2 (reading on claimed A2) is added when monomer mixture 1 a (claimed A1) is still being polymerized, thus would yield a gradient.
As to claims 22-23 and 25, Hiroki discloses coating compositions of the dispersion on substrate such as wood, glass, metal, etc. (see paragraph 31-33) comprising additives such as pigments, thickeners, etc. See paragraph 62.
Claim Rejections - 35 USC § 103
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.
Claim(s) 2 and 4 is/are rejected under 35 U.S.C. 103 as being unpatentable over US 2012/0095131 (herein Kinoshita) as evidenced by US 2015/0323850 (herein Shitagami).
The discussion with respect to Kinoshita set-forth above is incorporated herein by reference.
As to claim 2, as discussed above for claim 1, Kinoshita discloses a composition with values within all the ranges with the proviso that (i) is 15.5 and just outside the claimed range for example 4.
However, Kinoshita discloses that (i), which is referred to as (A) is present in 0.1 to 20 wt%, which substantially overlaps the claimed range. See paragraph 26. It is well settled that where the prior art describes the components of a claimed compound or compositions in concentrations within or overlapping the claimed concentrations a prima facie case of obviousness is established. See In re Harris, 409 F.3d 1339, 1343, 74 USPQ2d 1951, 1953 (Fed. Cir 2005); In re Peterson, 315 F.3d 1325, 1329, 65 USPQ 2d 1379, 1382 (Fed. Cir. 1997); In re Woodruff, 919 F.2d 1575, 1578 16 USPQ2d 1934, 1936-37 (CCPA 1990); In re Malagari, 499 F.2d 1297, 1303, 182 USPQ 549, 553 (CCPA 1974). Also see MPEP 2144.05 stating that when there is overlap with the claimed ranges and the prior art, a prima facie case of obviousness exists. Therefore, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to select any amount within the disclosed ranges, including amounts within the scope of the instant claims.
As to claim 4, acrylic acid is present in 0.2 wt%. See example 4.
Claim(s) 2 and 4 is/are rejected under 35 U.S.C. 103 as being unpatentable over JP 2010138256 (herein Hiroki) as evidenced by US 20240336772 (herein Balk) and US 2020/0002548 (herein Qian).
The discussion with respect to Hiroki set-forth above is incorporated herein by reference.
As to claims 2 and 4, as discussed above for claim 1, Hiroki discloses a composition with values within all the ranges with the proviso that (ii) is 0.25 and just outside the claimed range for example 7.
However, Hiroki discloses that (i), referred to as monomer (b), which is referred to as (A) is present in 0.1 to 12 wt%, which substantially overlaps the claimed range. See paragraph 47-48. It is well settled that where the prior art describes the components of a claimed compound or compositions in concentrations within or overlapping the claimed concentrations a prima facie case of obviousness is established. See In re Harris, 409 F.3d 1339, 1343, 74 USPQ2d 1951, 1953 (Fed. Cir 2005); In re Peterson, 315 F.3d 1325, 1329, 65 USPQ 2d 1379, 1382 (Fed. Cir. 1997); In re Woodruff, 919 F.2d 1575, 1578 16 USPQ2d 1934, 1936-37 (CCPA 1990); In re Malagari, 499 F.2d 1297, 1303, 182 USPQ 549, 553 (CCPA 1974). Also see MPEP 2144.05 stating that when there is overlap with the claimed ranges and the prior art, a prima facie case of obviousness exists. Therefore, it would have been obvious to one of ordinary skill in the art at the time the invention was filed to select any amount within the disclosed ranges, including amounts within the scope of the instant claims.
Claim(s) 5-6 is/are rejected under 35 U.S.C. 103 as being unpatentable over JP 2008069249 (herein Kanji) as evidenced by US 2015/0323850 (herein Shitagami) in view of US 2014/0065435 (herein Overbeek).
The discussion with respect to Kanji set-forth above is incorporated herein by reference.
As to claims 5-6, Kanji is silent on the monomers being from a renewable feedstock.
Overbeek teaches similar vinyl polymers for coatings. See paragraph 1-5 and examples. Overbeek teaches that the polymers may be produced using at least 20 wt% bio-renewable monomers (paragraph 1, preferably greater than 50 wt%, see paragraph 22, thus more than 20 wt% of the carbon). The switch to bio-renewable monomers (bio-based) is advantageous in order to improve sustainability with concerns about depletion of fossil fuel resources and an increase in carbon dioxide. See paragraph 5.
Therefore, it would have been obvious at the time of the invention to have modified the polymers of Kanji with bio-based renewable monomers of Overbeek because one would want to improve sustainability and reduce concerns about depletion of fossil fuel resources and an increase in carbon dioxide. See paragraph 5 of Overbeek.
Claim(s) 5-6 is/are rejected under 35 U.S.C. 103 as being unpatentable over JP 2010138256 (herein Hiroki) as evidenced by US 20240336772 (herein Balk) and US 2020/0002548 (herein Qian) in view of US 2014/0065435 (herein Overbeek).
The discussion with respect to Hiroki set-forth above is incorporated herein by reference.
As to claims 5-6, Hiroki is silent on the monomers being from a renewable feedstock.
Overbeek teaches similar vinyl polymers for coatings. See paragraph 1-5 and examples. Overbeek teaches that the polymers may be produced using at least 20 wt% bio-renewable monomers (paragraph 1, preferably greater than 50 wt%, see paragraph 22, thus more than 20 wt% of the carbon). The switch to bio-renewable monomers (bio-based) is advantageous in order to improve sustainability with concerns about depletion of fossil fuel resources and an increase in carbon dioxide. See paragraph 5.
Therefore, it would have been obvious at the time of the invention to have modified the polymers of Hiroki with bio-based renewable monomers of Overbeek because one would want to improve sustainability and reduce concerns about depletion of fossil fuel resources and an increase in carbon dioxide. See paragraph 5 of Overbeek.
Claim(s) 5-6 is/are rejected under 35 U.S.C. 103 as being unpatentable over US 2012/0095131 (herein Kinoshita) as evidenced by US 2015/0323850 (herein Shitagami) in view of US 2014/0065435 (herein Overbeek).
The discussion with respect to Kinoshita set-forth above is incorporated herein by reference.
As to claims 5-6, Kinoshita is silent on the monomers being from a renewable feedstock.
Overbeek teaches similar vinyl polymers for coatings. See paragraph 1-5 and examples. Overbeek teaches that the polymers may be produced using at least 20 wt% bio-renewable monomers (paragraph 1, preferably greater than 50 wt%, see paragraph 22, thus more than 20 wt% of the carbon). The switch to bio-renewable monomers (bio-based) is advantageous in order to improve sustainability with concerns about depletion of fossil fuel resources and an increase in carbon dioxide. See paragraph 5.
Therefore, it would have been obvious at the time of the invention to have modified the polymers of Kinoshita with bio-based renewable monomers of Overbeek because one would want to improve sustainability and reduce concerns about depletion of fossil fuel resources and an increase in carbon dioxide. See paragraph 5 of Overbeek.
Conclusion
Any inquiry concerning this communication or earlier communications from the examiner should be directed to MARK S KAUCHER whose telephone number is (571)270-7340. The examiner can normally be reached M-F 8-6 PM EST.
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, Arrie Lanee Reuther can be reached at (571) 270-7026. 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.
/MARK S KAUCHER/Primary Examiner, Art Unit 1764
Prosecution Insights