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Intellectual Property Litigation Online:
A Brief Overview
Periodical: The Business Suit
Date: Spring 1997
The
Internet (including the World Wide Web) and commercial online services
(collectively “cyberspace”), have been widely
touted as the new frontier of commerce, communications and
entertainment. Cyberspace
is also generally considered to be especially fertile ground for
generating new and difficult legal issues.
Moreover, the online world creates the potential for risks
which may not be faced so frequently or at all in real world
situations, much of it resulting from the relative ease and low
expense of establishing an online presence.
Although this low entry cost creates exciting new opportunities
for entre-peneurs, it also exposes them to unexpected risks:
the small businessperson who previously could not even dream of
advertising his products world wide can now do so but faces the
concomitant risk that he may thereby infringe another’s trademark,
and may potentially be sued for such infringment in, and under the
laws of, any nation on earth!1
Although
cyberspace is yet in its infancy as a forum for commercial, rather
than academic or governmental, endeavors, the proliferation of
litigation which has always followed the incursion of commerce into a
new geographical area has already commenced in cyberspace as
businesses invade the online world.
As one might expect, given that cyberspace is a medium for
transmission of information, the majority of cases to date have been
concerned with the area of intellectual property, and specifically
trademark and copyright infringement.
Accordingly, the following brief overview of cybertort case law
is restricted to these areas.
A.
Copyright Infringement Online
The
United States Copyright Act authorizes protection of “original2
works of authorship fixed3
in any tangible medium of expression.”4
Such protection does not extend to the “ideas” or facts
contained in a work, but rather only to the particular original
“expression” of ideas or facts embodied in the work.5
Copyright law protects eight categories of works: literary
(including software programs); musical (including lyrics); dramatic
(including any accompanying music); pantomimes and choreographic
works; pictorial, graphic and sculptural works; motion pictures and
other audiovisual works; sound recordings;6
and architectural works,7
and, subject to certain exceptions,8
precludes any person from reproducing, adapting, and publicly
distributing, performing, or displaying such works without permission
of the copyright holder.9
Liability
for copyright infringement may be either (1) direct, (2) contributory,
or (3) vicarious. A
person directly infringes another's copyright by either reproducing,
adapting, publicly distributing, performing, displaying, or importing
a copyrighted work.10
Direct infringement is a strict liability tort:
the infringer need not have any knowledge of infringement or
intent to infringe.11
A contributory infringer is one who, with knowledge,
substantially assists in the infringing activity.12
Vicarious liability for copyright infringment exists as to any
person who has the right and ability to control the infringer and
receives a direct financial benefit from the infringement.13
A plaintiff may prove infringment by demonstrating (1)
ownership of the copyright at issue; and (2) copying by the defendant.14
Copying may be proven by showing that defendant had access to
the copyrighted work, that the allegedly infriging work is
“substantially similar” to the copyrighted work, and that one of
the enumerated rights conferred by the Copyright Act has been
implicated by the defendant's actions.15
Remedies for copyright infringement include both damages and
injunctive relief.16
Because
words, pictures and music can be easily, cheaply and anonymously
copied and transmitted through cyberspace, online violation of
copyright is quite likely fairly common. Cases to date have involved asserted violations of copyright
in a diverse body of works, including Playboy centerfolds,17
religious texts,18 computer software
(specifically, video games),19
online catalogs20 and sound recordings.21
It would appear inevitable that every category of copyrightable
work other than architectural or sculptural works will ultimately be
digitizable and ready for transmission online.
One
major issue in online copyright disputes has been whether, to what
extent, and under what theory online service providers (“OSPs”)
may be held liable for infringement of copyright occurring when their
subscribers upload and post copyrighted material using their services.
In Religious Technology Center v. Netcom On-Line Communications
Service, Inc.,22
for example, the plaintiffs owned the copyright in certain literary
works created by L. Ron Hubbard, the founder of Scientology, which
were considered secret religious texts by the adherents of
Scientology. An apostate former Scientologist named Erlich had posted
copies of the works to a Usenet23
newsgroup, and Plaintiffs asserted that Netcom, Erlich’s Internet
service provider, was directly, contributorily and vicariously liable
for Erlich's infringement, seeking both injunctive relief and damages.24
The
court rejected the plaintiffs' claim of direct infringement of the
reproduction right against Netcom, reasoning that Netcom's system
simply allowed others to reproduce Usenet postings by uploading.
Analogizing Netcom’s services to a self-serve copy center,
the court held that Netcom’s actions lacked the “element of
volition or causation” necessary for a finding of direct
infringement.25
The Court also rejected plaintiffs' claim of direct
infringement against Netcom on the ground that such an approach would
render each of thousands of Usenet server operators liable for direct
infringement, a result the court considered unacceptable.26
By
contrast, in Playboy Enterprises, Inc. v. Frena,27
the court found the defendant bulletin board service (“BBS”)
operator liable for direct infringement of the plaintiff's copyrights
in certain photographs, which had been digitized and uploaded onto the
BBS by its subscribers. The
Frena decision reached this conclusion with no discussion of the
concerns articulated by the Netcom court respecting the dangers of
imposing liability for direct infringement on OSPs.28
Rather, it merely noted that defendant had access to the
copyrighted works, that the allegedly infringing works were
substantially similar (indeed, nearly identical) thereto, and that the
public distribution and display rights were violated.29
Similarly,
in Sega Enterprises, Ltd. v. MAPHIA,30
the defendant BBS operators actively encouraged subscribers to upload
copies of plaintiffs' copyrighted video game software, either charged
a direct fee for, or bartered for the privilege of downloading
plaintiff's video games.31
The court granted plaintiff's motion for a preliminary
injunction, finding that “Sega has established a likelihood of
success on the merits of showing a prima facie case of direct and
contributory infringement by Defendants’ operation of the MAPHIA
bulletin board.”32
B.
Trademark Infringement Online
Cyberspace,
like any other medium for mass communication, provides ample
opportunity for commission of trademark infringement or dilution under
the federal Lanham Act33
or state law, as well as common law unfair competition, or “palming
off.” In addition,
trademark controversies have arisen over the online-specific issue of
domain names34
in cases of the allegedly improper use or authorization of online
addresses such as “MCDONALDS.COM” or “MTV.COM.”35
The
Lanham Act is currently the most widely used mechanism for the
protection of trade or service marks, trade names and trade dress.
Section 32(1) of the Act prohibits the unauthorized commercial
use of a federally registered mark in connection with the sale, offer
for sale, distribution or advertisements of goods or services, if
likely to cause confusion, mistake or to deceive.36
Section 43(a) of the Act prohibits (1) the use in commerce of
any mark (whether or not federally registered) if such use is likely
to cause confusion as to the source, sponsorship or affiliation of the
goods or services in question; and (2) any false or misleading
statement in commercial advertising that misrepresents the nature or
attributes of the goods or services advertised, or of competitive
goods or services.37
Successful plaintiffs are entitled to injunctive relief and/or
damages (including treble damages, costs and attorneys’ fees) with
one significant exception: under certain circumstances, Section 32(2)(c) of the Act
prohibits granting injunctive relief against publishers of “newspaper[s],
magazine[s], or other similar periodical or an electronic
communication containing infringing material or violating matter.”38
(Emphasis added.)
A
Lanham Act claim for trademark infringement is not, however, the only
protection available to those whose marks have been improperly used.
The federal government recently added statutory protection
against “dilution” of trademarks,39
entitling a successful plaintiff to equitable relief and, if the
dilution was “willful,” monetary damages.40
State trademark laws provide similar protections to those
afforded under federal law and are commonly added as a pendent cause
of action to claims brought under the Lanham Act.
Finally, although common law “unfair competition,” or
“palming off,” does not involve infringement of a trademark, it
addresses similar problems of customer confusion, the essence of the
tort being “the sale of the goods of one manufacturer or vendor for
those of another.”41
As
noted above, many of the disputes relating to online trademark use
have arisen in the context of registration of Internet domain names.
However, because domain names were initially assigned in the
United States on a first-come, first-served basis,42
many persons were able to register domain names containing or
consisting of trademarks or corporate identifiers.
Thus, although a cyberspace user seeking online information
about McDonald’s hamburgers would be likely to visit a World Wide
Web site with the domain name “MCDONALDS.COM,” the name was at one
point owned not by the fast-food chain, but by a cyberspace journalist
who had registered the domain name.43
Similarly, the domain name “MTV.COM” was at one point
registered to a former MTV host, who used the address for a music
industry Website.44
A
representative case is Intermatic, Inc. v. Toeppen,45
in which the plaintiff Intermatic, Inc. was the holder of the
registered trademark “Intermatic.”
Defendant Toeppen was a so-called “cyber-squatter” who had
registered the domain name “intermatic.com” and numerous others
derived from corporate names with NSI for the apparent purpose of
eliciting payment from the corporations in exchange for the right to
use the domain names.46
Intermatic thereafter sued Toeppen and, on the parties' cross
motions for summary judgment, the court (a) granted Intermatic summary
judgment on its federal trademark dilution claims, (b) denied
Intermatic’s Lanham Act infringement claims and common law unfair
competition claims on grounds that there were genuine issues of fact
as to various issues, (c) denied Toeppen’s summary judgment motion
in its entirety, and (d) issued a preliminary injunction restraining
Toeppen from preventing Intermatic from using the “intermatic.com”
domain name and enjoining him from any use of the “Intermatic”
mark.47
Trademark
disputes have, of course, arisen online in other contexts than that of
domain names. For example, in Sega Enterprises, Ltd. v. MAPHIA,48
each video game posted on the defendants' bulletin board and copied by
its subscribers began with a screen displaying the federally
registered SEGAô trademark and logo,49
and the court accordingly found plaintiff was entitled to a
preliminary injunction under the Lanham Act.50
In Playboy Enterprises, Inc. v. Frena,51
the defendant (a) used the marks PLAYBOYô and PLAYMATEô to identify
files containing plaintiff’s copyrighted photographs, and (b) placed
his own name, BBS name and telephone number on the photographs.52
The court granted plaintiff partial summary judgment, holding
that the use of the marks constituted trademark infringment under
Section 32 of the Lanham Act and the insertion of the defendant’s
name BBS and telephone number was a violation of Section 43(a) of the
Lanham Act.
Conclusion
As
more and more businesses establish a presence online, and as online
commerce becomes more and more widely accepted, cyberspace-related
litigation will embrace not only high profile disputes between large
corporations and involving millions of dollars, but also controversies
involving small businesses and individuals.
Therefore, familiarity with the issues raised by the spread of
commerce online should be a prerequisite for any attorney practicing
business litigation.
Our
Litigation Department specializes in civil litigation at all levels of
the judiciary, and has wide-ranging experience in litigating business,
commercial and entertainment-industry related matters. We have
extensive experience in accounting and partnership, antitrust, and
securities and corporate litigation. Additional areas of emphasis
include copyright and intellectual property, real estate and products
liability litigation as well as in the appellate practice.
Rosenfeld,
Meyer & Susman was founded in 1957.
The Firm’s areas of expertise include: Labor and Employment
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Employee Benefits.
1 The law of jurisdiction in
cyberspace is still in the process of developing. Compare
CompuServe, Inc. v. Patterson, 89 F.3d 1257 (6th Cir.
1996)(where defendant enters into contacts in a jurisdiction
involving knowing and repeated transmission of data over the
Internet, personal jurisdiction is proper); with Bensusan
Restaurant Corp. v. King, 937 F. Supp. 295 (S.D.N.Y.
1996)(passive website that simply makes information available is
not grounds for personal jurisdiction).
See also generally R. Bourque & K. Konrad,
Avoiding Jurisdiction Based On Internet Web Site, N.Y. LAW J.
(Dec. 10, 1996); Comment, Jurisdiction and the Internet:
Fundamental Fairness in the Networked World of Cyberspace,
6 ALB. L.J. SCI. & TECH. 339 (1996). (Return
to article)
2 The prerequisite of
“originality” in fact requires precious little originality, no
artistic merit and, in contrast to patent law, no “novelty.”
Feist Publications, Inc. v. Rural Tel. Service Co., Inc.,
499 U.S. 340, 345, 111 S.Ct. 1282, 113 L.Ed.2d 358 (1991). (Return
to article)
3
There appears to be
little controversy over whether any information sufficiently
permanent to be transmitted online is “fixed” for copyright
purposes. Courts have
held that loading information into a computer’s random access
memory (“RAM”) constitutes a “copy” which implicates the
reproduction right granted copyright holders under ß 106 of the
Act and, a fortiori, the original work from which the copy
was made would of necessity be sufficiently fixed to qualify for
copyright protection. See,
e.g., MAI Sys. Corp. v. Peak Computer, Inc. 991 F.2d
511, 518-19 (9th Cir. 1993) cert. denied 510 U.S. 1033, 114
S.Ct. 671 (1994); Vault Corp. v. Quaid Software Ltd., 847
F.2d 255, 260 (5th Cir. 1988). However, the House Report on the 1976 Copyright Act stated
that “the definition of ‘fixation’ would exclude from the
concept purely evanescent or transitory reproductions such as
thoseÖcaptured momentarily in the ‘memory’ of a computer.”
H.R. Rep. No. 1476, 94th Cong., 2d Sess. 53 (1976), reprinted
in 1976 U.S. Code Cong. & Admin. News 5659.
Nonetheless, copyrighted photographs, novels, stories,
paintings, musical pieces and other works which are digitized and
transmitted online have been held to be sufficiently “fixed”
to be protected under copyright law.
Sega Enterprises, Ltd. v. MAPHIA, 948 F. Supp. 923,
931-32 (N.D. Cal. 1996). For
purposes of this article, it will be assumed that any work capable
of being downloaded onto a computer’s RAM is “fixed” within
the meaning of 17 U.S.C. ß 102. (Return
to article)
4 7 U.S.C. ß 102(a).
Specifically, the Copyright Act protects original works
“fixed in any tangible medium of expression, now known or later
developed, from which they can be perceived, reproduced, or
otherwise communicated, either directly or with the aid of a
machine or device.” Id. (Return
to article)
5 17 U.S.C. ß 102(b)(“In
no case does copyright protection for an original work of
authorship extend to any idea”).
See also M. Nimmer & D. Nimmer, Nimmer On Copyright ß 2.03(D)
(1996) and cases cited therein. (Return
to article)
6 The Copyright Act
distinguishes between “copies” of works and “phonorecords.”
17 U.S.C. ß 101. For
simplicity's sake, both “copies” and “phonorecords” will
hereinafter occasionally be referred to in this article as
“copies” of copyrighted works. (Return
to article)
8 These include:
(1) the fair use doctrine embodied in 17 U.S.C. ß 107,
which allows limited use of copyrighted works for certain —
generally non-commercial — purposes (such as for criticism,
comment, academic use, news reporting or research), where such
uses will not have any substantial adverse effect on the copyright
holder's rights; and (2) the “first sale” doctrine embodied in
17 U.S.C. ß 109, which allows the owner of a lawfully made copy
or phonorecord to sell or (with certain limitations) otherwise
dispose of the copy or phonorecord without facing liability (in
essence treating the legitimately acquired work like any other
piece of personal property).
There is some doubt as to whether or how the first sale
doctrine could be applied in the online context, where an
owner’s “disposal” of a digitized work to another person
would necessarily involve at least the temporary existence of two
copies of the work (one on each computer), thus violating the
copyright holder’s exclusive right to reproduce the work.
For a general discussion of the first sale doctrine in the
context of new media, see Kamarck, The First Sale Doctrine and
Evolving Technologies, MULTIMEDIA L. REP. May, 1996, at 1. (Return
to article)
12 Fonovisa, Inc. v.
Cherry Auction, Inc., 76 F.3d 259, 264 (9th Cir. 1996);
Gershwin Pub. Corp. v. Columbia Artists Management, Inc., 443
F.2d 1159, 1162 92d Cir. 1971). (Return
to article)
13 Shapiro Bernstein
& Co. Inc. v. H. L. Green Company, Inc., 316 F.2d 304 (2d.
Cir. 1963). (Return
to article)
14 Feist Publications,
Inc. v. Rural Tel. Service Co., Inc., 499 U.S. 340, 345, 111
S.Ct. 1282, 113 L.Ed.2d 358 (1991). (Return
to article)
15 Playboy Enterprises,
Inc. v. Frena, 839 F. Supp. 1552, 1556 (M.D. Fla. 1993). (Return
to article)
18 Religious Technology
Ctr. v. Netcom On-Line Communications Servs., Inc., 907 F.
Supp. 1361 (N.D. Cal. 1995); Religious Technology Ctr. v. Lerma,
1996 U.S. Dist. LEXIS 15454; 40 U.S.P.Q.2d (BNA) 1569; 24 Media L.
Rep. 2473 (E.D. Va. Oct. 4, 1996)(plaintiff entitled to summary
judgment on claim of copyright infringement where defendant
published on the Internet texts considered sacred by the Church of
Scientology). (Return
to article)
19 Sega Enterprises, Ltd.
v. MAPHIA, 857 F. Supp. 679 (N.D. Cal. 1994), as modified,
948 F. Supp. 923 (N.D. Cal. 1996). (Return
to article)
20 The Scientist, Inc. v.
Lindsey, 1996 U.S. Dist. LEXIS 7099 (E.D. Pa., May 22,
1996)(plaintiff claims defendants violated its copyright in guide
to scientific products by publication of Internet newsletter;
cross-motions for summary judgment denied because genuine issue of
fact exists as to originality). (Return
to article)
21 Frank Music Corp. v.
CompuServe, Inc., Case No. 93 Civ. 8153 (JFK) in the United
States District Court for the Southern District of New York. (Return
to article)
23 The Usenet has been
defined as: [A] worldwide community of electronic BBSs that is
closely associated with the Internet and with the Internet
community. The
messages in Usenet are organized into thousands of topical groups,
or “Newsgroups” .... As
a Usenet user, you read and contribute (“post”) to your local
Usenet site. Each Usenet site distributes its users’ postings to
other Usenet sites . . . There is no specific network that is the
Usenet. Usenet traffic flows over a wide range of networks,
including the Internet and dial-up phone links. Religious
Technology Center, 907 F. Supp. at 1365, n.4. (Return
to article)
24 Plaintiffs also sued
Klemesrud, the operator of the newsgroup to which Ehrlich had
posted the works. Id., at 1366. (Return
to article)
28 It may be that the
court's inattention to policy and other arguments against holding
OSPs liable for their subscribers' postings was occasioned by the
apparently undisputed fact (discussed by the court in assessing
defendant's liability for trademark infringement) that the
defendant had attempted to take credit for Plaintiff’s work by
placing its own advertisement with its phone number on some of the
photographs.” Id. at 1562.
This likely would cast considerable doubt on any assertion
that the defendant’s actions lacked the “element of causation
or volition” which the Netcom court stated was necessary
to impose liability for direct infringement.
Netcom 907 F. Supp. at 1370. (Return
to article)
31 Id. at 683.
The MAPHIA court specifically cited a message the
defendants posted to their bulletin board users which stated that
“as a free bonus for ordering from Dark Age, you receive a
COMPLIMENTARY Free Download Ratio on our Customer Support BBS.
This is if you cannot get a hold of SuperNintendo or Sega
Genesis games. You
can download up to ten megabites, which is equal to approximately
20 normal-size SuperNintendo or Genesis games.
Id. The court therefore concluded that the defendant
“provides downloading privileges for Sega games to users in
exchange for the uploading of Sega games or other programs or
information or in exchange for payment for other goods thatÖwere
services.” Id.
at 683-684. (Return
to article)
34 Domain names are unique
“addresses” which serve as an identifier of, and means to
contact, a cyberspace user. Because
there is no widely used or sufficiently comprehensive
“directory” of these cyberspace “addresses,” businesses
operating online seek to use easily remembered domain names, such
as their names or some variant thereof
(e.g., “McDonalds”), along with the designation
“.com” (thus, “McDonalds.com”).
The suffix “.com” signifies that the domain name
belongs to a commercial entity. (Return
to article)
35 See, e.g., MTV
Networks v. Curry, 867 F. Sup. 202 (S.D.N.Y. 1994).
See also Quittner, Making a Name on the Internet,
Newsday, at A4 (Oct.
7, 1994); Quittner, Billions Registered, Wired (Oct. 7,
1994). (Return
to article)
“delay
the delivery of [any] issue [of the newspaper or magazine] or
transmission of such electronic communication after the regular
time for such delivery or transmission, and such delay would be
due to the method by which publication and distribution of such
periodical or transmission of such electronic communication is
customarily conducted in accordance with said business practice,
and not due to any method or device adopted to evade this section
or to prevent or delay the issuance of an injunction or
restraining order with respect to such infringing matter or
violating matter.”
(Return
to article)
39 15 U.S.C. ßß 1125(c)
and 1127. Dilution occurs when the value of a well-known mark is
diminished by use which is not likely to lead to confusion among
goods and services. For
example, claims for dilution frequently arise when the mark is
used in connection with a dissimilar and non-competing product or
service, i.e. “Budweiserô
cologne.” See,
e.g., Toys ‘R’ Us, Inc. v. Akkaoui, 1996 U.S. Dist. LEXIS
17090; 40 U.S.P..Q.2d (BNA) 1936 (N.D. Cal. October 29,
1996)(granting preliminary injunction where defendants’ use of
name “Adults ‘R’ Us” for sexually oriented Internet sites
tarnished plaintiffs’ “Toys ‘R’ Us” and “Kids ‘R’
Us” marks); Hasbro, Inc. v. Internet Entertainment Group,
Ltd., 1996 U.S. Dist. LEXIS 11626; 40 U.S.P.Q.2d (BNA) 1479 (W.D.
Wash. February 9, 1996)(preliminary injunction granted where
defendants’ use of “candyland.com” as domain name for
sexually oriented Internet site diluted plaintiffs’ mark in
children’s game); Mead Data Central, Inc. v. Toyota Motor
Sales, U.S.A., Inc., 875 F.2d 1026, 1031 (2d Cir. 1989);
Deere & Co. v. MTD Prod., Inc., 41 F.3d 39, 44 (2d Cir.
1994).
(Return
to article)
41 Hanover Star Milling
Co. v. Metcalf., 240 U.S. 403, 413, 3 S.Ct. 357, 60 L.Ed.2d
713 (1916). It is not
uncommon to confuse the common law tort of misappropriation with
“palming off” or trademark infringement.
However, unlike those torts, misappropriation does not
require any element of deceit or confusion, but merely requires
that the tortfeasor have improperly used the skill, expenditures
or labor of a competitor. Flexitized,
Inc. v. National Flexitized Corp., 335 F.2d 774 (2d Cir. 1964)
cert. denied, 380 U.S.. 913 (1965). (Return
to article)
42 Domain names are issued
and registered by Network Solutions, Inc. (“NSI”), a private
company. For a
general discussion of domain names and the Internet, see
Panavision, Int’l L.P. v. Toeppen, 945 F.Supp. 1296,
1299-1300, 65 U.S.L.W. 2530 (C.D. Cal. 1996). (Return
to article)
43 The journalist
relinquished the name to McDonald's Corp. in exhange for the
company making a contribution to a charity of the author’s
choice. See
Quittner, “Billions Registered,” Wired, p. 50 (Oct. 7, 1994). (Return
to article)
44 MTV Networks v. Curry,
867 F. Sup. 202 (S.D.N.Y. 1994).
See also Comp Examiner Agency v. Juris, Inc., 1996 U.S.
Dist. LEXIS 20259 (C.D. Cal. April 26, 1996, amended May
21, 1996)(court issues injunction precluding legal publishing firm
from using domain name “JURIS.COM,” as it would likely cause
confusion with registered trademark for legal software). (Return
to article)
46 The enterprising Mr.
Toeppen had registered, among others, the domain names “neiman-marcus.com,”
“ramadainn.com,” “ussteel.com” and “britishairways.com.”
947 F. Supp. at 1230. (Return
to article)
47 See also Panavision,
Int’l L.P. v. Toeppen, 945 F.Supp. 1296, 65 U.S.L.W. 2530
(C.D. Cal. 1996)(granting summary judgment on Trademark Dilution
Act claims and enjoining defendant's use of domain names
“panavision.com” and “panaflex.com” derived from
plaintiff’s registered marks); Comp Examiner Agency
v. Juris, Inc. 1996 U.S. Dist. LEXIS 20259 (C.D. Cal.
April 25, 1996)(preliminarily enjoining defendant from using
plaintiff’s mark “Juris” as part of domain name “juris.com”);
Hasbro, Inc. v. Internet Entertainment Group, Ltd., 1996
U.S. Dist. LEXIS 11626; 40 U.S.P.Q.2d (BNA) 1479 (W.D. Wash. Feb.
9, 1996)(preliminary injunction granted where defendants’ use of
“candyland.com” as domain name for sexually oriented Internet
site diluted plaintiffs’ mark in children’s game); and
Cardservice Int’l, Inc. v. McGee, 1997 U.S. Dist. LEXIS 552
(E.D. Va., Jan. 16, 1997). (Return
to article)
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