DETAILED ACTION
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
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 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.
Information Disclosure Statements
The Information Disclosure Statements (IDS) filed on 9/24/2024, 5/14/2025, and 11/11/2025 have been acknowledged.
Priority
Acknowledgment is made of applicant's claim for foreign priority based on an application filed in Japan on 9/29/2023.
Specification
The lengthy specification has not been checked to the extent necessary to determine the presence of all possible minor errors. Applicant's cooperation is requested in correcting any errors of which applicant may become aware of, in the specification.
Status of Application
Claims 1 and 6-10 are pending.
Claim 10 has been added.
Claims 2-5 have been cancelled.
Claims 1 and 6-9 have been amended.
Claims 1, 8, and 9 are the independent claims.
This Final Office action is in response to the “Amendments and Remarks” received on 5/12/2026.
Response to Arguments/Remarks
With respect to Applicant’s remarks filed on 5/12/2026; Applicant's “Amendments and Remarks” have been fully considered. Applicant’s remarks will be addressed in sequential order as they were presented.
Office Note: Claims 2-5 has been cancelled, therefore any rejection or objection pertaining thereupon is now considered moot.
With respect to the claim interpretations under 35 U.S.C. § 112 (f), applicants “Amendment and Remarks” have been fully considered and are persuasive. Therefore the claim interpretations under 35 U.S.C. § 112 (f) have been withdrawn.
With respect to the claim rejections under 35 U.S.C. § 112 (b), applicants “Amendment and Remarks” have been fully considered and were persuasive. Therefore the claim rejections under 35 U.S.C. § 112 (b) have been withdrawn.
With respect to the claim rejections under 35 U.S.C. § 101, applicants “Amendment and Remarks” have been fully considered and were persuasive. Therefore the claim rejections under 35 U.S.C. § 101 have been withdrawn.
With respect to the previous claim rejections under 35 U.S.C. § 102 and § 103, applicant has amended the independent claim and these amendments have changed the scope of the original application and the Office has supplied new grounds for rejection attached below in the FINAL office action and therefore the prior arguments are considered moot.
It is the Office’s stance that all of applicant arguments have been considered and the rejections remain.
Final Office Action
CLAIM INTERPRETATION
During examination, claims are given the broadest reasonable interpretation consistent with the specification and limitations in the specification are not read into the claims. See MPEP §2111, MPEP §2111.01 and In re Yamamoto et al., 222 USPQ 934 10 (Fed. Cir. 1984). Under a broadest reasonable interpretation, words of the claim must be given their plain meaning, unless such meaning is inconsistent with the specification. See MPEP 2111.01 (I). It is further noted it is improper to import claim limitations from the specification, i.e., a particular embodiment appearing in the written description may not be read into a claim when the claim language is broader than the embodiment. See 15 MPEP 2111.01 (II).
A first exception to the prohibition of reading limitations from the specification into the claims is when the Applicant for patent has provided a lexicographic definition for the term. See MPEP §2111.01 (IV). Following a review of the claims in view of the specification herein, the Office has found that Applicant has not provided any lexicographic definitions, either expressly or implicitly, for any claim terms or phrases with any reasonable clarity, deliberateness and precision. Accordingly, the Office concludes that Applicant has not acted as his/her own lexicographer.
A second exception to the prohibition of reading limitations from the specification into the claims is when the claimed feature is written as a means-plus-function. See 35 U.S.C. §112(f) and MPEP §2181-2183. As noted in MPEP §2181, a three prong test is used to determine the scope of a means-plus-function limitation in a claim:
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
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"
the term "means" or "step" or the generic placeholder is not modified by sufficient structure, material, or acts for performing the claimed function.
The Office has found herein that the claims no longer contain limitations of means or means type language that must be analyzed under 35 U.S.C. §112 (f).
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 of this title, 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.
The factual inquiries set forth in Graham v. John Deere Co., 383 U.S. 1, 148 USPQ 459 (1966), that are applied for establishing a background for determining obviousness under 35 U.S.C. 103 are summarized as follows:
1. Determining the scope and contents of the prior art.
2. Ascertaining the differences between the prior art and the claims at issue.
3. Resolving the level of ordinary skill in the pertinent art.
4. Considering objective evidence present in the application indicating obviousness or nonobviousness.
This application currently names joint inventors. In considering patentability of the claims under pre-AIA 35 U.S.C. 103(a), the examiner presumes that the subject matter of the various claims was commonly owned at the time any inventions covered therein were made absent any evidence to the contrary. Applicant is advised of the obligation under 37 CFR 1.56 to point out the inventor and invention dates of each claim that was not commonly owned at the time a later invention was made in order for the examiner to consider the applicability of pre-AIA 35 U.S.C. 103(c) and potential pre-AIA 35 U.S.C. 102(e), (f) or (g) prior art under pre-AIA 35 U.S.C. 103(a).
Claims 1 and 6-10 are rejected under 35 USC 103 as being unpatentable over Okamoto et al. (United States Patent Publication 2024/0127609) in view of Ganlath et al. (United States Patent Publication 2023/0339508) and in further view of Nagasaka et al. (United States Patent Publication 2015/0197246).
With respect to Claim 1: While Okamoto discloses “A vehicle control device comprising” [Okamoto, Abstract, ¶ 0047-0054 with Figure 5];
“a processor that executes instructions to” [Okamoto, ¶ 0014 (The ECU 10 includes a CPU (Central Processing Unit) 11, ROM (Read Only Memory) 12, RAM (Random Access Memory) 13, an interface device 14, and the like. The CPU 11 executes various programs stored in the ROM 12. The ROM 12 is a non-volatile memory that stores data and the like required for the CPU 11 to execute various programs. The RAM 13 is a volatile memory to provide a working region that is deployed when various programs are executed by the CPU 11. The interface device 14 is a communication device for communicating with an external device)];
“recognize a surrounding situation of a vehicle” [Okamoto, ¶ 0049 with Figure 5 (In step S320, the ECU 10 determines whether the object in front of the vehicle SV is the obstacle that may collide with the vehicle SV. If the object is the moving object, the ECU 10 determines that the moving object is the obstacle when the trajectory of the moving object intersects the trajectory of the vehicle SV.)];
“as a detection result, a driving state detector configured to detect a driving state of an occupant of the vehicle” [Okamoto, ¶ 0032 and 0047-0054 with Figure 5];
“determine distracted driving of the occupant on the basis of the detection result” [Okamoto, ¶ 0032 and 0047-0054, with Figure 5 (The distraction state determination unit 120 determines that the driver is in the distraction state when the touch sensor 52 does not detect continuous gripping of the steering wheel by the driver, when the steering angle sensor 34 does not detect a steering operation of a predetermined amount or more by the driver, or when the driver does not detect another driving operation by the driver, during a period from when at least one of the ACC activation switch 61 and the LTA activation switch 65 is turned ON until a predetermined period of time elapses)];
“wherein the processor determines that the occupant is performing distracted driving when a steering operation of the occupant is not detected for a determined period of time or more” [Okamoto, ¶ 0032 and 0047-0054 with Figure 5 (The distraction state determination unit 120 determines that the driver is in the distraction state when the touch sensor 52 does not detect continuous gripping of the steering wheel by the driver, when the steering angle sensor 34 does not detect a steering operation of a predetermined amount or more by the driver, or when the driver does not detect another driving operation by the driver, during a period from when at least one of the ACC activation switch 61 and the LTA activation switch 65 is turned ON until a predetermined period of time elapses)];
“the determined period of time is set on the basis of a contact margin time between an obstacle near the vehicle and the vehicle” [Okamoto, ¶ 0038 and 0047-0054 with Figure 5 (when the driver is in an abnormal state, it is desired to advance the operation of the deceleration control and the alarm by relaxing the execution conditions of the deceleration control and the alarm. When the driver state determination unit 130 determines that the driver is in the abnormal state, the PCS control unit 140 determines whether to execute the deceleration control or the alarm based on the second relaxation threshold time T2′ obtained by subtracting the predetermined quantity Td2 from the second threshold time T2(T2′=T2−Td2). Accordingly, when the abnormality is detected in the driver, the operation of the deceleration control and the alarm can be advanced, and thus the safety can be improved. The predetermined quantity Td2 may be a fixed value or may be a variable value. For example, the predetermined quantity Td2 may be increased as the vehicle speed V is increased)];
“and a speed of the vehicle” [Okamoto, ¶ 0038 and 0047-0054 with Figure 5 (the predetermined quantity Td2 may be increased as the vehicle speed V is increased)];
“the determined period of time is set to be longer as the contact margin time increases” [Okamoto, Abstract, ¶ 0038, 0047-0054 with Figure 5 (the ECU 10 determines whether or not the vehicle SV is likely to collide with the obstacle based on the second relaxation threshold time T2′ obtained by subtracting the predetermined quantity Td2 from the second threshold time T1 (T2′=T2−Td2). Specifically, it is determined whether the condition in which the TTC is equal to or less than the collision determination threshold Tv continues for the second relaxation threshold T2′ or longer. If the determination is No, the ECU 10 returns this routine. On the other hand, if the determination is affirmative (Yes), the ECU 10 advances the process to step S380 to execute the alarm/deceleration control, and returns this routine)];
“and when the contact margin time is equal to or greater than a predetermined value, though the determined period of time is set so that an amount of adjustment of time corresponding to the contact margin time is suppressed” [Okamoto, Abstract, ¶ 0037, 0047-0054 with Figure 5 (The PCS control unit 140 determines that the vehicle SV is highly likely to collide with the obstacle when the state in which TTC is equal to or smaller than the predetermined collision determination threshold Tv continues for a predetermined second threshold T2 or longer) and (if the TTC is greater than the collision-determination-threshold Tv (No), the ECU 10 returns this routine)];
“and based on the contact margin, a slow deceleration control input to gradually decelerate the vehicle to avoid the obstacle near the vehicle” [Okamoto, Abstract, ¶ 0037, 0047-0054 with Figure 5 (The deceleration control is a control for decelerating the vehicle SV such that the deceleration of the vehicle SV coincides with a preset target deceleration by controlling the operation of the braking device 22)].
Okamoto does not specifically state how the drivers attention is being detected, or how to control a vehicle within a lane.
Ganlath, which is also a vehicle control system that measures driver attention teaches “wherein a lack of the steering operation by the occupant is based on a steering torque associated with the steering operation” [Ganlath, ¶ 0029 (A steering wheel torque sensor includes an electronic sensor that records the torque applied to the steering wheel of the ego vehicle. The measurement recorded by the steering wheel torque sensor describes, for example, an amount of torque that a driver is applying to the steering wheel. This torque measurement is an indication of the driver's responsiveness to an event. In some embodiments, the measurement recorded by a steering wheel torque sensor indicates an attention of a driver to the driving interface of the ego vehicle)].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate the teachings of Ganlath into the invention of Okamoto to not only include vehicle control based on objects and driver attentiveness as Okamoto discloses but to also control measure driver attentiveness based on steering wheel torque as taught by Ganlath with a reasonable expectation of success. One would be motivated to incorporate aspects of the cited prior art Ganlath into Okamoto to create a more robust system that not only measures driver attentiveness on a scale based on the actual control of the driver on the steering wheel, but can also differentiate between medical conditions and attentiveness [Ganlath, ¶ 0029]. Additionally, the claimed invention is merely a combination of old, well known elements measuring driver awareness for a more in-depth vehicle control system and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art before the effective filing date of the claimed invention would have recognized that the results of the combination would have been predictable.
Further, Okamoto does not specifically state staying in the center of the lane.
Nagasaka, which is also vehicle control system teaches “and based on the contact margin, applying a centering control input to center the vehicle and a slow deceleration control input to gradually decelerate the vehicle to avoid the obstacle near the vehicle” [Nagasaka, ¶ 0030-0033 and 0039 (potential vehicle path 314 lies along the center of the lane) and (The path planner 122 can also be configured to decelerate the vehicle 200 to avoid objects of interest if no potential vehicle paths 314, 316, 318, 320, 322 allow the vehicle 200 to maintain a threshold distance to the relevant objects of interest)].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate the teachings of Nagasaka into the invention of Okamoto to not only include vehicle control (decelerating) based on objects and driver attentiveness as Okamoto discloses but to control the vehicle in the center of the lane, and decelerate when objects are detected as taught by Nagasaka with a reasonable expectation of success. One would be motivated to incorporate aspects of the cited prior art Nagasaka into Okamoto to create a more robust system that not only measure an object and slow down based on time to collisions and driver attentiveness but also keep in the center of the lane, thus creating less secondary conflicts based on objects in the road. Additionally, the claimed invention is merely a combination of old, well known elements measuring driver awareness for a more in-depth vehicle control system and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art before the effective filing date of the claimed invention would have recognized that the results of the combination would have been predictable.
With respect to Claim 6: Okamoto discloses “The vehicle control device according to claim 1, wherein, based on the contact margin time, a state in which an amount of driving operation of the occupant is less than a threshold value, the determined period of time is set by multiplying a reference time at which a vehicle can be determined to be able to travel without contacting the obstacle and a coefficient set on the basis of the speed of the vehicle” [Okamoto, Abstract, ¶ 0036, 0047-0054 with Figure 5 (When the PCS control unit 140 determines that the object is an obstacle, the PCS control unit 140 calculates a predicted collision time (Time To Collision: TTC) until the vehicle SV collides with the obstacle based on the distance L from the vehicle SV to the obstacle and the relative velocity Vr of the vehicle SV with respect to the obstacle. TTC is an index indicating a possibility that the vehicle SV collides with an obstacle. TTC can be determined by dividing the distance L from own vehicle SV to the obstacle by the relative velocity Vr (TTC=L/Vr))].
With respect to Claim 7: Okamoto discloses “The vehicle control device according to claim 1, where in the processor further executers instructions to control one or both of steering and acceleration or deceleration of the vehicle on the basis of the contact margin time” [Okamoto, Abstract, ¶ 0036, 0047-0054 with Figure 5 (On the other hand, if the determination is affirmative (Yes), the ECU 10 advances the process to Step S380 to execute the alarm/deceleration control, and returns this routine)];
“and perform attention calling to the occupant when the determiner determines that the occupant is performing distracted driving” [Okamoto, Abstract, ¶ 0036, 0047-0054 with Figure 5 (On the other hand, if the determination is affirmative (Yes), the ECU 10 advances the process to Step S380 to execute the alarm/deceleration control, and returns this routine)].
With respect to Claim 8: all limitations have been examined with respect to the vehicle control device in Claims 1 and 6-7. The method taught/disclosed in Claim 8 can clearly perform on the vehicle control device in Claims 1 and 6-7. Therefore Claim 8 is rejected under the same rationale.
With respect to Claim 9: all limitations have been examined with respect to the vehicle control device in Claims 1 and 6-7. The non-transitory computer readable medium taught/disclosed in Claim 9 can clearly perform on the vehicle control device in Claims 1 and 6-7. Therefore Claim 9 is rejected under the same rationale.
With respect to Claim 10: While Okamoto discloses “A vehicle control device comprising” [Okamoto, Abstract, ¶ 0047-0054 with Figure 5];
“a processor that executes instructions to” [Okamoto, ¶ 0014 (The ECU 10 includes a CPU (Central Processing Unit) 11, ROM (Read Only Memory) 12, RAM (Random Access Memory) 13, an interface device 14, and the like. The CPU 11 executes various programs stored in the ROM 12. The ROM 12 is a non-volatile memory that stores data and the like required for the CPU 11 to execute various programs. The RAM 13 is a volatile memory to provide a working region that is deployed when various programs are executed by the CPU 11. The interface device 14 is a communication device for communicating with an external device)];
“recognize a surrounding situation of a vehicle” [Okamoto, ¶ 0049 with Figure 5 (In step S320, the ECU 10 determines whether the object in front of the vehicle SV is the obstacle that may collide with the vehicle SV. If the object is the moving object, the ECU 10 determines that the moving object is the obstacle when the trajectory of the moving object intersects the trajectory of the vehicle SV.)];
“detect a driving state of an occupant of the vehicle” [Okamoto, ¶ 0032 and 0047-0054 with Figure 5];
“determine distracted driving of the occupant on the basis of a result of detection” [Okamoto, ¶ 0032 and 0047-0054, with Figure 5 (The distraction state determination unit 120 determines that the driver is in the distraction state when the touch sensor 52 does not detect continuous gripping of the steering wheel by the driver, when the steering angle sensor 34 does not detect a steering operation of a predetermined amount or more by the driver, or when the driver does not detect another driving operation by the driver, during a period from when at least one of the ACC activation switch 61 and the LTA activation switch 65 is turned ON until a predetermined period of time elapses)];
“wherein the processor determines that the occupant is performing distracted driving when a steering operation of the occupant is not detected for a determined period of time or more” [Okamoto, ¶ 0032 and 0047-0054 with Figure 5 (The distraction state determination unit 120 determines that the driver is in the distraction state when the touch sensor 52 does not detect continuous gripping of the steering wheel by the driver, when the steering angle sensor 34 does not detect a steering operation of a predetermined amount or more by the driver, or when the driver does not detect another driving operation by the driver, during a period from when at least one of the ACC activation switch 61 and the LTA activation switch 65 is turned ON until a predetermined period of time elapses)];
“the determined period of time is set on the basis of a contact margin time between an obstacle near the vehicle and the vehicle” [Okamoto, ¶ 0038 and 0047-0054 with Figure 5 (when the driver is in an abnormal state, it is desired to advance the operation of the deceleration control and the alarm by relaxing the execution conditions of the deceleration control and the alarm. When the driver state determination unit 130 determines that the driver is in the abnormal state, the PCS control unit 140 determines whether to execute the deceleration control or the alarm based on the second relaxation threshold time T2′ obtained by subtracting the predetermined quantity Td2 from the second threshold time T2(T2′=T2−Td2). Accordingly, when the abnormality is detected in the driver, the operation of the deceleration control and the alarm can be advanced, and thus the safety can be improved. The predetermined quantity Td2 may be a fixed value or may be a variable value. For example, the predetermined quantity Td2 may be increased as the vehicle speed V is increased)];
“and a speed of the vehicle” [Okamoto, ¶ 0038 and 0047-0054 with Figure 5 (the predetermined quantity Td2 may be increased as the vehicle speed V is increased)];
“wherein, when the speed of the vehicle is less than a predetermined speed, the determined period of time is set so that an amount of adjustment of time corresponding to the speed of the vehicle is suppressed” [Okamoto, Abstract, ¶ 0037, 0047-0054 with Figure 5 (The PCS control unit 140 determines that the vehicle SV is highly likely to collide with the obstacle when the state in which TTC is equal to or smaller than the predetermined collision determination threshold Tv continues for a predetermined second threshold T2 or longer) and (if the TTC is greater than the collision-determination-threshold Tv (No), the ECU 10 returns this routine)];
“based on the contact margin, a slow deceleration control input to gradually decelerate the vehicle to avoid the obstacle near the vehicle” [Okamoto, Abstract, ¶ 0037, 0047-0054 with Figure 5 (The deceleration control is a control for decelerating the vehicle SV such that the deceleration of the vehicle SV coincides with a preset target deceleration by controlling the operation of the braking device 22)].
Okamoto does not specifically state how the drivers attention is being detected, or how to control a vehicle within a lane.
Ganlath, which is also a vehicle control system that measures driver attention teaches “wherein a lack of the steering operation by the occupant is based on a steering torque associated with the steering operation” [Ganlath, ¶ 0029 (A steering wheel torque sensor includes an electronic sensor that records the torque applied to the steering wheel of the ego vehicle. The measurement recorded by the steering wheel torque sensor describes, for example, an amount of torque that a driver is applying to the steering wheel. This torque measurement is an indication of the driver's responsiveness to an event. In some embodiments, the measurement recorded by a steering wheel torque sensor indicates an attention of a driver to the driving interface of the ego vehicle)].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate the teachings of Ganlath into the invention of Okamoto to not only include vehicle control based on objects and driver attentiveness as Okamoto discloses but to also control measure driver attentiveness based on steering wheel torque as taught by Ganlath with a reasonable expectation of success. One would be motivated to incorporate aspects of the cited prior art Ganlath into Okamoto to create a more robust system that not only measures driver attentiveness on a scale based on the actual control of the driver on the steering wheel, but can also differentiate between medical conditions and attentiveness [Ganlath, ¶ 0029]. Additionally, the claimed invention is merely a combination of old, well known elements measuring driver awareness for a more in-depth vehicle control system and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art before the effective filing date of the claimed invention would have recognized that the results of the combination would have been predictable.
Further, Okamoto does not specifically state staying in the center of the lane.
Nagasaka, which is also vehicle control system teaches “and based on the contact margin, applying a centering control input to center the vehicle and a slow deceleration control input to gradually decelerate the vehicle to avoid the obstacle near the vehicle” [Nagasaka, ¶ 0030-0033 and 0039 (potential vehicle path 314 lies along the center of the lane) and (The path planner 122 can also be configured to decelerate the vehicle 200 to avoid objects of interest if no potential vehicle paths 314, 316, 318, 320, 322 allow the vehicle 200 to maintain a threshold distance to the relevant objects of interest)].
It would have been obvious to one of ordinary skill in the art before the effective filing date of the claimed invention to incorporate the teachings of Nagasaka into the invention of Okamoto to not only include vehicle control (decelerating) based on objects and driver attentiveness as Okamoto discloses but to control the vehicle in the center of the lane, and decelerate when objects are detected as taught by Nagasaka with a reasonable expectation of success. One would be motivated to incorporate aspects of the cited prior art Nagasaka into Okamoto to create a more robust system that not only measure an object and slow down based on time to collisions and driver attentiveness but also keep in the center of the lane, thus creating less secondary conflicts based on objects in the road. Additionally, the claimed invention is merely a combination of old, well known elements measuring driver awareness for a more in-depth vehicle control system and in the combination each element merely would have performed the same function as it did separately, and one of ordinary skill in the art before the effective filing date of the claimed invention would have recognized that the results of the combination would have been predictable.
Prior Art (Not relied upon)
The prior art made of record and not relied upon is considered pertinent to applicant's disclosure can be found in the attached form 892.
Conclusion
Applicant’s amendment necessitated the new ground(s) of rejection presented in this Office action. Accordingly, THIS ACTION IS MADE FINAL. Applicant is reminded of the extension of time policy as set forth in 37 CFR 1.136(a).a).
A shortened statutory period for reply to this final action is set to expire THREE MONTHS from the mailing date of this action. In the event a first reply is filed within TWO MONTHS of the mailing date of this final action and the advisory action is not mailed until after the end of the THREE-MONTH shortened statutory period, then the shortened statutory period will expire on the date the advisory action is mailed, and any extension fee pursuant to 37 CFR 1.136(a) will be calculated from the mailing date of the advisory action. In no event, however, will the statutory period for reply expire later than SIX MONTHS from the date of this final action.
Any inquiry concerning this communication or earlier communications from the examiner should be directed to JESS WHITTINGTON whose telephone number is (571)272-7937. The examiner can normally be reached on 7am -4pm EST.
If attempts to reach the examiner by telephone are unsuccessful, the examiner’s supervisor, Scott Browne can be reached on (571)-270-0151. The fax phone number for the organization where this application or proceeding is assigned is 571-273-8300.
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/JESS WHITTINGTON/Primary Examiner, Art Unit 3666c
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