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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 1 of 14
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`IN THE UNITED STATES COURT OF FEDERAL CLAIMS
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`
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`E-NUMERATE SOLUTIONS, INC. and
`E-NUMERATE, LLC,
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`Plaintiffs,
`
`v.
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`THE UNITED STATES OF AMERICA,
`
`Defendant.
`
`C.A. No. 19-859-RTH
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`JOINT STATUS REPORT
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`Plaintiffs e-Numerate Solutions, Inc. and e-Numerate, LLC and Defendant the United
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`States of America (the “Government”) respectfully submit this Joint Status Report pursuant to the
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`Court’s Order of February 29, 2024. ECF 116, page 55 – 56. Per the Court’s request, the parties have
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`followed the general format of the Joint Preliminary Status Report filed on November 19, 2020. ECF-35.
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`The parties have removed the sections from the prior submission that are not germane to the current
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`procedural posture of the case.
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`As set forth in more detail below, the parties are broadly in agreement that the fact discovery
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`period should commence later this month and run for a period of 18 months. However, the parties are in
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`disagreement regarding the timing of certain milestones within that schedule. Per the Court’s request, the
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`parties have proposed a schedule using Judge Albright’s Standing Order governing proceedings in patent
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`cases. ECF 116, page 56. In addition, there are certain disputes between the parties that will require Court
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`involvement at the Scheduling Conference or at a time and in a manner set forth by the Court..
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`Should trial of liability and damages be bifurcated and, if so, why?
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`(a)
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`e-Numerate maintains that a trial of liability and damages should not be bifurcated. The
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 2 of 14
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`Government agrees that discovery need not be bifurcated but submits that a determination as to
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`whether separate trials or evidentiary hearings be held on specific issues can be made at a later date
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`after these issues are further developed.
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`(b) Will additional parties be joined? If so, the parties shall provide a statement
`describing such parties, their relationship to the case, the efforts to effect
`joinder, and the schedule proposed to effect joinder.
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`The parties do not anticipate at this time that any additional parties will be joined in this
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`action.
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`e-Numerate’s Additional Position
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`e-Numerate believes that the Government has improperly limited its search for core
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`technical documents to systems explicitly set forth in the Second Amended Complaint (ECF 53)
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`and/or e-Numerate’s infringement contentions. The great weight of authority holds that such a
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`limitation is inappropriate and that the Government must produce documents relating to all systems
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`in its possession, custody and control that operate in the same manner as the specifically accused
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`systems. See, e.g., Epicrealm, Licensing, LLC v. Autoflex Leasing, Inc., No. 2:05-CV-163, 2007
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`WL 2580969, at *2-3 (E.D. Tex. Aug. 27, 2007); LKQ Corp. v. Kia Motors Am., Inc., No. 21 C
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`3166, 2023 U.S. Dist. LEXIS 84551, 2023 WL 3455315, at *3-4 (N.D. Ill. May 15, 2023)
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`(collecting cases); Invensas Corp. v. Renesas Elecs. Corp., 287 F.R.D. 273, 279-83 & n.9 (D. Del.
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`2012) (same). e-Numerate further believes that the Government has withheld production of
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`documents related to the SEC analytical systems specifically accused of infringement in the
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`Second Amended Complaint. See, e.g., D.I. 53 at Count II, pars. 73 -74 & Ex. G. As set forth
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`below, these two issues need to be addressed at the Scheduling Conference or in a time or manner
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`set forth by the Court. e-Numerate did not pursue this issue against the Government previously
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`because of the Court’s expressed desire to address all claim construction issues in the case first.
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`If the Government produces additional documents implicating additional agencies of the
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 3 of 14
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`United States, e-Numerate may amend the Complaint to name them and their products/systems.
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`Because all of the agencies are part of the United States (the named defendant), e-Numerate does
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`not believe that additional “parties” will be added to the Complaint. e-Numerate has proposed
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`dates further out in the schedule to amend the Complaint and/or add additional agencies to account
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`for these issues.
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`The Government’s Additional Position
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`The Government objects to e-Numerate’s inclusion of a recitation of purported document
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`production deficiencies in a Joint Status Report directed to scheduling issues, particularly when e-
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`Numerate first raised this issue with the Government in a correspondence provided on the
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`afternoon of March 12, 2024. The Government diligently collected and produced core technical
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`documents totaling at least hundreds of thousands of pages in 2021 and 2022, before the deadline
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`for production of core technical documents on August 17, 2022. Dkt. No. 87. e-Numerate delayed
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`raising this issue for more than a year and a half. The Government will respond in due course with
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`respect to any document production issues but they should not impact the default scheduling
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`provided in Judge Albright’s Standing Order.
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`(c)
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`Does either party intend to file a motion pursuant to RCFC 12(b), 12(c), or 56
`and, if so, what is the schedule for the intended filing?
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`e-Numerate’s Position:
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`e-Numerate does not anticipate filing a summary judgment motion until the date set forth
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`in the Scheduling Order entered in this matter. However, e-Numerate believes that the Court
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`should include the following provision relating to summary judgment briefing in this matter
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`based on Judge Albright’s Standing Order:
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`8. The Court does not limit the number of motions for summary judgment (MSJs) or
`Daubert motions party may file. However, absent leave of Court, the cumulative
`page limit for opening briefs for all MSJs is 40 pages per side, for all Daubert
`motions is 40 pages per side,and for all MILs is 15 pages per side. Each responsive
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 4 of 14
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`MSJ, Daubert, and MIL brief is limited to the pages utilized in the opening brief or
`by the local rules, whichever is greater; and the cumulative pages for responsive
`briefs shall be no more than cumulative pages utilized in the opening briefs. Reply
`brief page limits shall be governed by the local rules, but in no event shall the
`cumulative pages of reply briefs exceed 20 pages per side for all MSJs, 20 pages per
`side for all Daubert motions, and 10 pages for all MILs.
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`See Judge Albright Standing Order of January 23, 2024 at page 10, par. 8. This provision is
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`intended to focus the parties on a subset of potential summary judgment motions that may have
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`merit under Fed. R. Civ. P. Rule 56. Conversely, this provision discourages filing multiple
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`summary judgment briefs that independently are allowed the page limit under the local rules. e-
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`Numerate’s counsel has found this provision effective in focusing the parties’ resources on issues
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`that are “summary judgment worthy” under Fed. R. Civ. P. Rule 56 in other cases it has litigated.
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`Contrary to the Government’s argument below, Judge Albright’s Order does not limit the
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`number of summary judgment motions that can be filed. Rather, it limits the amount of briefing
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`on the summary judgment motions.
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`The Government’s Further Position
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`The Government does not anticipate filing a summary judgment motion until the date set
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`forth in the Scheduling Order entered in this matter. However, the Court of Federal Claims does
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`not limit the number of dispositive motions that can be filed by either party. See e.g., Return
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`Mail, Inc. v. United States, No. 11-CV-130 (Fed. Cl. 2011), ECF No. 169 (Defendant’s Motion
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`for Summary Judgment Under 35 U.S.C. § 101), ECF No. 171 (Defendant’s Motion for
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`Summary Judgment Under 35 U.S.C. §§ 305 and 102), ECF No. 172 (Plaintiff’s Motion for
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`Partial Summary Judgment as to Defendant’s Section 101 Affirmative Defense), ECF No. 173
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`(Plaintiff’s Motion for Partial Summary Judgment on Defendant’s Section 305 Affirmative
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`Defense). Moreover, the page limits in the Rules of the Court of Federal Claims are on a per-
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`motion basis as opposed to a cumulative limit as e-Numerate proposes. In any case, setting such
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 5 of 14
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`a limitation is premature given that dispositive motions will not be filed for years.
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`likelihood of
`the
`is
`(d) What
`resolution contemplated?
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`settlement?
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`Is alternative dispute
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`Counsel for the parties have held several informal discussions including a discussion after
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`the Court’s first Markman ruling. Counsel are scheduled to talk via telephone during the week
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`of March 18 in light of the Court’s second Markman ruling. E-Numerate is amenable to a
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`settlement mediation with the Government. The Government believes that some form of
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`alternative dispute resolution (“ADR”) may be useful later in the case.
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`(e)
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`Do the parties anticipate proceeding to trial? Does either party, or do the
`parties jointly, request expedited trial scheduling and, if so, why? A request
`for expedited trial scheduling is generally appropriate when the parties
`anticipate that discovery, if any, can be completed within a 90-day trial
`period, the case can be tried within 3 days, no dispositive motion is
`anticipated, and a bench ruling is sought. The requested place of trial shall be
`stated. Before such a request is made, the parties shall confer specifically on
`this subject.
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`The parties do not request an expedited trial schedule. The parties request that the trial, if
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`any, be held at the U.S. Court of Federal Claims Courthouse in Washington, D.C.
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`e-Numerate’s Further Position:
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`At this time, e-Numerate anticipates proceeding to trial if the case cannot be resolved
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`amicably. E-Numerate respectfully requests that the Court provide guidance to the parties about
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`how many patents/claims it will allow the parties to take to trial as well as how many invalidity
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`theories it will allow the Government to raise per asserted claim and the process the Court will use
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`in making that determination. This guidance will inform the parties about the scope of narrowing
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`that must take place during the two meet and confer dates set forth in Judge Albright’s schedule.
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`See, e.g., VLSI Tech. LLC v. Intel Corp., 2020 U.S. Dist. LEXIS 137485 (D. Del. August 3, 2020).
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`The Government’s proposal to employ the Model Order in this case is contrary to Judge
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 6 of 14
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`Albright’s procedures. See, e.g., Jawbone Innovations, LLC v. Google LLC, 2022 U.S. Dist.
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`LEXIS 41439 at *5 (W.D. Tex. March 8, 2022)(“The Court generally will not require a plaintiff
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`to reduce its number of asserted claims without the benefit of discovery, claim construction, and
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`invalidity contentions.”)
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`Defendant’s Further Position:
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`The Government agrees that guidance from the Court on the number of asserted claims
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`and prior art references would be useful. In the interim, the Government has used the Advisory
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`Council for the United States Court of Appeals for the Federal Circuit’s Model Order Limiting
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`Excess Patent Claims and Prior Art (2013) (“Model Order”)1. The Model Order addresses the
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`collective concern in many jurisdictions relating to the “overwhelming” number of issues
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`presented in many patent cases. Because there is a “consensus that the numbers of asserted
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`claims, claim terms, and prior art references in patent cases are often problematically excessive,”
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`the Advisory Council drafted the Model Order to be a flexible tool to promote effective case
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`management and to limit the burdens on parties and courts when superfluous claims and prior art
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`are maintained. The default numerical limits on the number of asserted patent claims and prior art
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`references contained in the Model Order are workable and can account for the need to balance the
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`need for discovery against the benefits of early streamlining. The Government’s proposal for a
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`reduction of number of asserted claims to thirty-two (32) and prior art references to twelve (12) at
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`approximately two months into fact discovery is based on the limits proposed in this Model Order
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`and is provided after the benefit of claim construction, invalidity contentions, and months of
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`discovery.
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`(f)
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`Is there other information of which the court should be aware at this time?
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`1 Available at https://patentlyo.com/media/docs/2013/07/model-order-excess-claims.pdf; See also,
`https://www.txed.uscourts.gov/sites/default/files/goFiles/13-20.pdf (adopting the limits on number of asserted claims and
`prior art references)
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 7 of 14
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`Yes. The parties previously filed a Joint Stipulation of Dismissal with respect to Count VIII of
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`the Second Amended Complaint which alleged infringement of U.S. Patent No. 10,423,708 (“the
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`‘708 patent”). See Dkt. No. 101. The Court indicated that it would issue an Order to that effect by
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`the time of its Markman ruling. See Dkt. No. 106 at 5:12-19. The parties respectfully request that
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`the Court issue such an Order. The parties’ additional respective positions are set forth below.
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`e-Numerate’s Position
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`e-Numerate respectfully requests that the Court set a date for an in-person Scheduling
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`Conference. e-Numerate wishes to address the following issues at that Scheduling Conference:
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`(1) whether the Court will set a trial date at this time; (2) what procedure the Court will follow in
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`limiting the number of claims/patents that are asserted at trial; (3) whether the Court will include
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`Judge Albright’s provision on summary judgment briefing in the Scheduling Order in this matter;
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`(4) discovery limits; and (5) e-Numerate’s contention that the Government has failed to produce
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`documents related to the SEC analytical systems and improperly limited the scope of its search
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`for systems in its technical document production. Each is addressed in turn.
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`1. Trial
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`e-Numerate sets forth a complete listing of the dates set forth in Judge Albright’s
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`Standing Order. The Government did not believe a schedule had to be submitted for events
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`occurring beyond the close of fact discovery. Whether a trial date will be set at this time is
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`something that should be discussed at the Scheduling Conference.
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`2. Limitations on Asserted Claims/Patents and Invalidity Theories
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`e-Numerate wishes to discuss the procedure the Court will follow in limiting the number
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`of asserted claims/patents and the number of asserted invalidity theories in the case. See, e.g.,
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`VLSI Tech. LLC v. Intel Corp., 2020 U.S. Dist. LEXIS 137485 (D. Del. August 3, 2020);
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 8 of 14
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`Jawbone Innovations, LLC v. Google LLC, 2022 U.S. Dist. LEXIS 41439 at *5 (W.D. Tex.
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`March 8, 2022).
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`3. Judge Albright’s Limitation On Summary Judgment Briefing
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`e-Numerate respectfully requests that the Court impose Judge Albright’s limitation on
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`summary judgment briefing in the Scheduling Order to promote efficient resolution of this
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`matter. See Standing Order of January 23, 2024, page 10, par. 8.
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`4. Discovery Limits
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`Both parties seek an 18-month long fact discovery period, although the parties disagree
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`with the timing of certain milestones in the schedule. The reason for this request is that the case
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`is larger than it was when the Joint Preliminary Status Report was filed. Multiple additional
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`Government agencies have been added and, consequently, more third-party products are
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`implicated. e-Numerate believes that milestones relating to “final contentions” should be set
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`forth at or near the end of the fact discovery period given the magnitude of the case. Third
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`parties have resisted e-Numerate’s discovery efforts and Court intervention will be required under
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`Fed. R. Civ. P. Rule 45. These are additional reasons to delay service of final contentions. e-
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`Numerate did not pursue enforcement of various subpoenas because the Government was
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`asserting, inter alia, that “code for” claims were invalid. Moreover, the fact that the precise
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`contours of the claims were unknown until the Court’s constructions were issued was almost
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`certainly going to be raised as grounds to resist the subpoenas by the third parties.
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`e-Numerate seeks 200 hours of deposition discovery in lieu of the normal 70 hours
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`provided under the Federal Rules. The reason for this request is that e-Numerate will be
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`pursuing multiple third parties in discovery, which e-Numerate estimates may be in excess of 20 -
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`30 third party service providers and/or customers of said third parties in addition to the
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`Government entities implicated in this suit. e-Numerate requests that all testifying experts may
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 9 of 14
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`be deposed by the opposing party and that such depositions do not count towards the hours limit
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`on depositions.
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`e-Numerate requests that there be no limit on the number of document requests and, in
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`any event, e-Numerate requests a ruling by the Court that subpoenas and items requested in a
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`subpoena directed to a third party do not count towards any limit on document requests imposed
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`in this matter.
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`e-Numerate renews its request that the Court set a Status Conference during the fact
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`discovery period to discuss whether and to what extent the parties have agreed that certain third-
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`party products are representative products for liability purposes. e-Numerate contends that
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`any limitation on representative claims should be coupled with an agreement on representative
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`third-party products.
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`Further, e-Numerate requests that all Government agencies collectively constitute one
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`side for purposes of the discovery limitations. For example, if the parties get 200 hours of
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`deposition time, e-Numerate gets 200 hours and the United States gets 200 hours regardless of
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`the number of involved agencies. Put differently, each of the involved government agencies
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`does not receive its own allotment of 200 hours of deposition time.
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`5. The Government’s Production of Technical Documents.
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`e-Numerate contends that the Government has failed to produce documents related to the
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`SEC analytical systems specifically accused of infringement in the Second Amended Complaint.
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`D.I. 53 at Count II, pars. 73 -74 & Ex. G. In addition, e-Numerate contends that the Government
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`improperly limited the scope of its search for systems in its technical document production. By
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`way of example, to the extent that the FDIC/FFIEC, OMB/USDOT, and FERC/DOE and their
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`affiliated agencies have analysis programs used to analyze XBRL filings, these should have been
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`included in the Government’s production. e-Numerate wishes to address how the Court will
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 10 of 14
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`resolve this issue. The Government’s complaint that e-Numerate first raised this issue via letter
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`of March 12, 2024, rings hollow because whether the documents at issue were produced and
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`what was searched for are straight-forward questions.
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`Defendant’s Position
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`
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`
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`1. Amended Contentions in Light of the Court’s Markman decisions
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`The Government served amended invalidity contentions based on the first Markman
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`decision (Dkt. No. 109) more than four months ago and has sought to avoid unnecessary motion
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`practice by obtaining e-Numerate’s consent to file an unopposed motion to amend its prior
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`contentions accordingly. While e-Numerate has indicated it may have some issue with respect to
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`an unidentified subset of the contentions, it has still not provided a detailed response. The
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`Government is also reviewing the Court’s second Markman decision (Dkt. No. 116) to determine
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`if further amendments are needed and while it does not expect such revisions, the Government is
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`prepared to make a motion with respect to first proposed amendments if that is the Court’s
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`preference, notwithstanding e-Numerate incomplete substantive response to date.
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`2. Proposed Schedule
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`The Government has included milestones through the end of fact discovery and while it
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`believes that a schedule for expert discovery and dispositive motion briefing can be deferred it
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`has alternatively provided dates for those as well. The Government respectfully requests that a
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`schedule for motions in limine and Daubert motions be deferred until after summary judgment
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`hearings when the Court and the parties are better positioned to address such issues.
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`In terms of fact discovery, the Government’s proposed dates adhere more closely to
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`Judge Albright’s Standing Order which provides that the date for final contentions is “8 weeks
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`after Markman hearing.” The Government proposal is based on the parties first meaningfully
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`reducing the number of asserted claims and prior art references approximately ten weeks after
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 11 of 14
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`the commencement of fact discovery followed by final contentions two months thereafter. In
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`contrast, e-Numerate proposes that final contentions be provided at the end of fact discovery.
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`Notably, e-Numerate’s infringement contentions are largely directed to publicly available source
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`code, see, e.g., Dkt. No. 44- 4 at n2, 3 (noting — in 2021 — e-Numerate’s reliance on public
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`domain software, its online location, and a lack of detailed contentions with respect to that
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`software), or third-party software providers. It served subpoenas on Toppan Merrill, Oracle
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`Corporation and SAP America three years ago, yet has never sought to amend its contentions or
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`sought Court involvement with respect to third-parties.
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`3. Discovery Limits
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`The Government agrees to the “General Discovery Limits” specified in Standing Order
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`Governing Proceedings (OGP) 4.4—Patent Cases (W.D. Tex. Jan. 23, 2024) as modified below.
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`As previously proposed, the Government agrees to 70 hours of party deposition per side and 40
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`hours of deposition of third parties per side. The Government also agrees to 7 hours of expert
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`deposition per report and that this not count to the total hours of depositions per party. While the
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`Government is uncertain as to the identity of the 20 - 30 third party service providers and/or
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`customers e-Numerate references, it notes that e-Numerate has only issued three third-party
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`subpoenas to date. e-Numerate’s request that there be no limit on the number of document
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`requests is without any support and Judge Albright’s default of 75 requests for production should
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`be used.
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`The Government opposes e-Numerate request as to representative products for liability
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`purposes as e-Numerate has had more than three years to conduct third-party discovery. Dkt. No.
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`36 (“the parties shall be allowed to engage in all necessary third-party discovery.”)
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`Finally, the Government agrees with e-Numerate’s request that the total deposition time
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`for each side should apply to the Government as a whole and not be allotted to each government
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 12 of 14
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`PROPOSED SCHEDULE
`E-Numerate Position
`Government Position
`April 1, 2024
`April 1, 2024
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`agency,
`
`EVENT
`Fact Discovery Opens &
`Initial Disclosures Served
`Deadline To Add Parties
`Deadline for Plaintiffs to
`reduce the number of asserted
`claims to no more than thirty-
`two (32) claims.
`
`May 6, 2024
`June 17, 2024
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`July 15, 2024
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`August 5, 2024
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`August 12, 2024
`August 19, 2024
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`October 1, 2025
`To be scheduled at a later
`date or January 8, 2026
`To be scheduled at a later
`date or February 9, 2026
`To be scheduled at a later
`date or March 12, 2026
`
`To be scheduled at a later
`date or April 3, 2026
`
`December 1, 2024
`e-Numerate contends this is
`contrary to Judge Albright’s
`practice and should take place
`as set forth in Judge
`Albright’s Order.
`e-Numerate contends this is
`contrary to Judge Albright’s
`practice and should take place
`as set forth in Judge
`Albright’s Order.
`
`November 1, 2025=
`
`Deadline for Defendant to
`reduce the number of prior art
`references used for §§ 102-
`103 purposes to no more than
`twelve (12) per patent and
`forty (40) overall.
`Final Infringement and
`Invalidity Contentions
`Deadline to Amend Pleadings December 1, 2024
`February 3, 2025
`Meet and Confer On Claims
`Asserted/Invalidity Theories
`Close of Fact Discovery
`Opening Expert Reports
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`November 1, 2025
`December 5, 2025
`
`Rebuttal Expert Reports
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`January 16, 2026
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`Reply Expert Reports
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`Close of Expert Discovery
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`e-Numerate is willing to meet
`and confer with the
`Government about a date for
`this event if the Court’s
`practice is to allow Reply
`Expert Reports.
`February 13, 2026
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 13 of 14
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`Second Meet and Confer
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`March 6, 2026
`
`Deadline to file Dispositive
`Motions
`Deadline to respond to any
`dispositive motions
`Deadline to reply to any
`dispositive motions
`Daubert Motions
`
`March 27, 2026
`
`Briefing Schedule should be
`pursuant to the Local Rules
`Briefing Schedule should be
`pursuant to the Local Rules
`March 27, 2026
`
`Pretrial Disclosures
`
`May 1, 2026
`
`Objections To Pretrial
`Disclosure/Rebuttal
`Disclosures
`Objections To Rebuttal
`Disclosures/Motions In
`Limine
`File Pretrial Order
`
`June 5, 2026
`
`July 10, 2026
`
`July 31, 2026
`
`Daily Transcript/Real Time
`Reporting
`File Joint Notice
`
`August 28, 2026
`
`August 31, 2026
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`Final Pretrial Conference
`
`September 3, 2026
`
`Trial
`
`September 14, 2026
`
`To be scheduled at a later
`date or May 1, 2026
`To be scheduled at a later
`date or May 15, 2026
`To be scheduled at a later
`date or June 12, 2026
`To be scheduled at a later
`date or June 26, 2026
`To be scheduled at a later
`date
`To be scheduled at a later
`date
`To be scheduled at a later
`date
`
`To be scheduled at a later
`date
`
`To be scheduled at a later
`date
`To be scheduled at a later
`date
`To be scheduled at a later
`date
`To be scheduled at a later
`date
`At the Court’s convenience
`and to be scheduled at a later
`date
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`Case 1:19-cv-00859-RTH Document 117 Filed 03/14/24 Page 14 of 14
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`Dated: March 14, 2024
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`Dated: March 14, 2024
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`Of Counsel:
`ANDREW CURRAN
`Department of Justice
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`Respectfully submitted,
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`O’KELLY & O’Rourke, LLC
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`/s/ Sean T. O’Kelly
`Sean T. O’Kelly
`Gerard M. O’Rourke
`824 N. Market Street, Suite 1001A
`Wilmington, Delaware 19801
`Tel.: (302) 778-4000
`Fax: (302) 295-2873
`sokelly@okorlaw.com
`gorourke@okorlaw.com
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`Attorneys for Plaintiffs
`e-Numerate Solutions,
`Inc. and e-Numerate
`LLC
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`Respectfully submitted,
`
`BRIAN M. BOYNTON
`Principal Deputy Assistant Attorney General
`
`SCOTT BOLDEN
`Director
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`/s/ Shahar Harel
`SHAHAR HAREL
`Trial Attorney
`Commercial Litigation Branch
`Civil Division
`Department of Justice
`Washington, DC 20530
`Email:
`Shahar.Harel@USDOJ.gov
`Telephone:
`(202) 305-3075
`Facsimile:
`(202) 307-0345
`
`COUNSEL FOR THE UNITED STATES OF
`AMERICA
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`14
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