Hunter Valley Signs Pty. Limited v Bartco Traffic Equipment Pty Ltd

[2023] APO 37

IP AUSTRALIA

AUSTRALIAN PATENT OFFICE

Hunter Valley Signs Pty. Limited v Bartco Traffic Equipment Pty Ltd [2023] APO 37

Patent Application:             2016210770

Title:METHOD AND APPARATUS FOR INDICATING CONDITIONS

Patent Applicant:                Bartco Traffic Equipment Pty Ltd

Opponent:Hunter Valley Signs Pty. Limited

Delegate:Xavier Gisz

Decision Date:  23 June 2023

Hearing Date:  30 March 2023, in Video Conference

Catchwords:  PATENTS - opposition under section 104 – allowability under subsections 102(2)(a) and 102(2)(b) considered – amendments do not comply with 102(2)(a) – opposition succeeds – costs awarded against the applicant

Representation:                   Counsel for the applicant: James Samargis

Patent attorney for the applicant: Matt Pini

Patent attorney for the opponent: Andrew Caska

IP AUSTRALIA

AUSTRALIAN PATENT OFFICE

Patent Application:             2016210770

Title:METHOD AND APPARATUS FOR INDICATING CONDITIONS

Patent Applicant:                Bartco Traffic Equipment Pty Ltd

Date of Decision:                23 June 2023

DECISION

The amendments do not comply with s 102(2)(a).

The Applicant has 2 months from the date of this decision to propose suitable amendments to overcome this deficiency.

Costs according to Schedule 8 are awarded against the Applicant.

REASONS FOR DECISION

Background

1.      The present matter is part of an ongoing s 59 opposition. The s 59 opposition has resulted in the decision: Hunter Valley Signs Pty. Limited v Bartco Traffic Equipment Pty Ltd [2021] APO 28 (the first decision) which was issued on 2 July 2021 where I found claims 1 to 6, 8 to 17, 21 and 22 of the present application (the Application) lacked an inventive step and allowed the Applicant 2 months to propose amendments to overcome the finding. Bartco Traffic Equipment Pty Ltd (the Applicant) filed a Statement of Proposed Amendments on 2 September 2021.

2.      On 21 October 2021 the amendments were advertised and a 2 month window provided for opposition. On 17 December 2021 Hunter Valley Signs Pty. Limited (the Opponent) filed a notice of opposition to the allowance of the amendments. On 17 January 2022 the Opponent filed a Statement of Grounds and Particulars.

3.      On 18 January 2022 a Delegate asked the parties to indicate (within 7 days) if they intended to file evidence. On 25 January 2022 the Applicant indicated that they would be filing evidence. The Opponent did not respond, which was taken to mean that they did not intend to file any evidence in support of their opposition.

4.      On 28 January 2022 the Delegate proposed a timetable for the filing of evidence and allowed the parties to make comments on the proposed timetable. No comments were received and on 7 February 2022 the Delegate made the direction for the timetable for the parties to file evidence. The Applicant had 2 months to file evidence in answer and the Opponent had 1 month (from the date the Commissioner advised the evidence in answer was complete) to file evidence in reply.

5.      The Applicant filed evidence in answer on 7 April 2022; the Commissioner acknowledged receipt of the evidence on 13 April 2022. The Opponent filed evidence in reply on 12 May 2022.

6.      There was then a prolonged dialogue between the Applicant and the Delegate about: a) whether the evidence in reply was properly in reply, and b) the Applicant’s intention to file information to be considered under Reg 5.23. Eventually, the Applicant filed a challenge to the evidence in reply on 4 November 2022. On 17 January 2023 a Delegate found that paragraphs 6‑10 of the Sasse declaration (from the Evidence in Reply) was not properly in reply.

7.      On 24 February 2023 the parties were informed that the hearing would take place on 30 March 2023. On 16 March 2023 the Opponent filed written submissions for the hearing.

8.      On 23 March 2023 the Applicant filed written submissions for the hearing and a declaration by Matt Pini with accompanying exhibits. The Applicant requested that the declaration be considered under Reg 5.23. On 29 March 2023 the Applicant filed four additional declarations (with accompanying exhibits) and requested that these also be considered under Reg 5.23.

9.      On 27 March 2023 I informed the parties that the decision on whether I would rely on the information supplied by the Applicant under Reg 5.23 would occur after the hearing.

Reg 5.23

10.   I have decided that I will not rely on the information supplied by the Applicant, and thus do not need to invoke Regulation 5.23. The reasons for this will be made clear in the decision below.

Grounds of Oppositions

11. The Statement of Grounds and Particulars opposes the amendments under subsections 102(2)(a) and 102(2)(b) of the Patents Act. Under s 102(2)(b), it is asserted that the proposed amendments would not comply with subsections 40(2) or 40(3) as follows:

·s 40(2)(a) - the specification does not disclose the invention in a manner which is clear enough and complete enough for the invention [as claimed] to be performed by a person skilled in the relevant art.

·s 40(2)(aa) - the specification does not disclose the best method known to the applicant of performing the invention

·s 40(3) - the claims are not clear and succinct and supported by matter disclosed in the specification

The evidence

Evidence in Support

12.   No Evidence in Support of the opposition was filed by the Opponent.

Evidence in Answer

13.   Evidence in answer comprises a Statutory Declaration of Jonathan Garton (the Garton Declaration) dated 6 April 2022 with curriculum vitae annexed.

Evidence in Reply

14.   Evidence in reply comprises a declaration of Luke Sasse (the Sasse Declaration) dated 12 May 2022 with annexures of Exhibits LSA and LSB.

15.   Paragraphs 6 to 10 of the Sasse Declaration have been found to be not properly in reply and so are excluded from evidence in reply.

The relevant legislation

16. The present opposition is governed by the Patents Act 1990 (the Act) as amended by the Intellectual Property Laws Amendment (Raising the Bar) Act 2012 (the Raising the Bar Act).

17. The relevant provision of the Act is subsection 102(2), which is set out below:

(2) An amendment of a complete specification is not allowable after the relevant time if, as a result of the amendment:

(a) a claim of the specification would not in substance fall within the scope of the claims of the specification before amendment; or
(b) the specification would not comply with subsection 40(2), (3) or (3A).

18.   Subsection 102(2A)(a) states that the “relevant time” means after the specification has been accepted. As the present specification had been accepted when the amendments were requested, the requirements of subsection 102(2) apply.

19.   Notably the legislation requires that the failure to meet the requirements of subsections 102(1) and (2) must be the result of the amendment (RGC Mineral Sands Ltd v Wimmera Industrial Minerals Pty Ltd [1998] FCA 1358; 42 IPR 353 at page 360). If any of these matters was pre-existing then it will not result in an amendment being not allowable (Apotex Pty Ltd v Les Laboratoires Servier (No 2) [2009] FCA 1019).

Applicable Law

20. The standard of proof that applies to section 104 opposition proceedings under the Raising the Bar Act has not been expressly stated in the Act. However, as reasoned by the Delegate in Cytec Industries Inc v Nalco Company [2018] APO 4 at [18]: “it is a logical inference that the standard required is the balance of probabilities (consistent with the amendment to section 60(3A) that allows the Commissioner to refuse a patent application if satisfied on the balance of probabilities that a ground of opposition exists), and it is the opponent who carries the onus of proof.”

21.   Relevant principles applying to s102(2)(a) are conveniently laid out by Yates J in Bristol-Myers Squibb Company v Apotex Pty Ltd [2010] FCA 814 at [40]:

“Consideration of the prohibition in s 102(2)(a) requires a comparison between the proposed new claims and the claims of the specification immediately before amendment. Once again the prohibition is conditioned on a state of affairs existing as a result of the amendment, namely that a claim would not in substance fall within the scope of the claims before amendment. Thus the identification of the amendment is, once again, an important first step. Moreover, the reference to “within the scope of the claims” before amendment is significant. The comparison is not between a particular amended claim and that claim before amendment. The expression “within the scope of the claims” directs attention to all the claims. For this reason a practical test is to ask whether an amendment makes anything an infringement which would not have been an infringement before the amendment…”

22.   Relevant to determining the scope, claim construction was discussed by Bennett J in H Lundbeck A/S v Alphapharm Pty Ltd [2009] FCAFC 70 (‘Lundbeck’) at [118]-[120]:

“…the words in a claim should be read through the eyes of the skilled addressee in the context in which they appear. Words used in a specification, including the claims, are to be given the meaning which the person skilled in the art would attach to them, having regard to his or her own general knowledge and to what is disclosed in the body of the specification… construction of a specification, including the claims, is ultimately a question of law for the Court… While the claims define the monopoly claimed in the words of the patentee's choosing, the specification should be read as a whole… It is not permissible to read into a claim an additional integer or limitation to vary or qualify the claim by reference to the body of the specification… However, terms in the claim which are unclear may be defined or clarified by reference to the body of the specification...”

The amendments

23.   A marked-up version on the amendments to the independent claims are shown below:

1.        An automated sign for indicating environmental conditions comprising a segmented conditions rating scale physically disposed on a substrate for public display wherein an illuminated display panel is operatively associated with each segment of the segmented conditions rating scale, whereby the illuminated display panels are controlled to illuminate one display panel at any one time so as to indicate by way of a selected segment environmental conditions in accordance with a received communications signal comprising prevailing environmental conditions and each of the illuminated display panels are adapted to be visible and distinguishable from each other illuminated display panel by one or a combination of:

each illuminated display panel comprising an array of high intensity light emitting elements;

the light emitting elements having distinguishable colours for each illuminated display panel;

the disposition of each illuminated display panel of the automated sign.; and,

each illuminated display panel is adapted to be visible and distinguishable from each other illuminated display panel at a distance of at least 2 kilometres.

9.         A8.     An automated sign for conveying status of an environmental condition, the automated sign comprising:

a plurality of sections that are segmented and spaced with respect to each other and that are permanently visible, each segmented and spaced section representing a level of status of the environmental condition; and

a plurality of illuminated regions that are each operatively associated with a respective section, each illuminated region having a light source,

whereby, in use, the light sources are controlled, in accordance with a received communications signal comprising prevailing environmental conditions, to be selectively illuminated one illuminated region at any one time such that the illuminated regions and sections together convey a visual indication of a selected status level of the environmental condition and where each illuminated region in operative association with its respective section is adapted to be visible and distinguishable from each other illuminated region in operative association with its respective section by one or a combination of:

each illuminated region comprising an array of high intensity light emitting elements;

the light emitting elements having distinguishable colours for each section;

the disposition of each illuminated region on the automated sign.; and,

10each illuminated region is adapted to be visible and distinguishable from each other illuminated region at a distance of at least 2 kilometres.

23. A

22.      An automated warning sign for conveying status of an environmental condition, the automated warning sign comprising:

a plurality of light sources whereby each of the plurality of light sources is operatively associated with one of a plurality of segments of a segmented condition rating scale physically disposed on a substrate for public display wherein in combination the light sources and their operatively associated segments are adapted to be selectively illuminated one segment illuminated at any one time for displaying a plurality of distinct status levels of the environmental condition;

an electronic control system for controlling illumination of the light sources; and

at least one sensor that detects an observable environmental condition, and which is in communication with the electronic control system;

wherein the electronic control system automatically changes the status condition displayed by the light sources in response to a predetermined change in the environmental condition detected by the sensor and each of the plurality of segments are adapted to be visible and distinguishable from each other by one or a combination of:

each of the plurality of light sources comprising an array of high intensity light emitting elements;

the light emitting elements having distinguishable colours for each respective segment;

the disposition of each segment on the automated warning sign.

24.   A clean copy of the amendments to the independent claims is shown below:

1. An automated sign for indicating environmental conditions comprising a segmented conditions rating scale physically disposed on a substrate for public display wherein an illuminated display panel is operatively associated with each segment of the segmented conditions rating scale, whereby the illuminated display panels are controlled to illuminate one display panel at any one time so as to indicate by way of a selected segment environmental conditions in accordance with a received communications signal comprising prevailing environmental conditions and each of the illuminated display panels are adapted to be visible and distinguishable from each other illuminated display panel by one or a combination of:

each illuminated display panel comprising an array of high intensity light emitting elements;

the light emitting elements having distinguishable colours for each illuminated display panel;

the disposition of each illuminated display panel of the automated sign; and,

each illuminated display panel is adapted to be visible and distinguishable from each other illuminated display panel at a distance of at least 2 kilometres.

8. An automated sign for conveying status of an environmental condition, the automated sign comprising:

a plurality of sections that are segmented and spaced with respect to each other and that are permanently visible, each segmented and spaced section representing a level of status of the environmental condition; and

a plurality of illuminated regions that are each operatively associated with a respective section, each illuminated region having a light source,

whereby, in use, the light sources are controlled, in accordance with a received communications signal comprising prevailing environmental conditions, to be selectively illuminated one illuminated region at any one time such that the illuminated regions and sections together convey a visual indication of a selected status level of the environmental condition and where each illuminated region in operative association with its respective section is adapted to be visible and distinguishable from each other illuminated region in operative association with its respective section by one or a combination of:

each illuminated region comprising an array of high intensity light emitting elements;

the light emitting elements having distinguishable colours for each section;

the disposition of each illuminated region on the automated sign; and,

each illuminated region is adapted to be visible and distinguishable from each other illuminated region at a distance of at least 2 kilometres.

22. An automated warning sign for conveying status of an environmental condition, the automated warning sign comprising:

a plurality of light sources whereby each of the plurality of light sources is operatively associated with one of a plurality of segments of a segmented condition rating scale physically disposed on a substrate for public display wherein in combination the light sources and their operatively associated segments are adapted to be selectively illuminated one segment illuminated at any one time for displaying a plurality of distinct status levels of the environmental condition;

an electronic control system for controlling illumination of the light sources; and

at least one sensor that detects an observable environmental condition, and which is in communication with the electronic control system;

wherein the electronic control system automatically changes the status condition displayed by the light sources in response to a predetermined change in the environmental condition detected by the sensor and each of the plurality of segments are adapted to be visible and distinguishable from each other by one or a combination of:

each of the plurality of light sources comprising an array of high intensity light emitting elements;

the light emitting elements having distinguishable colours for each respective segment;

the disposition of each segment on the automated warning sign.

s 102(2)(a)

25.   The Opponent states in their submissions at paragraphs 22-24:

“The relevant portion of the amendment recites:

“….and each of the illuminated display panels are adapted to be visible and distinguishable from each other illuminated display panel by one or a combination of:
(Feature 1) each illuminated display panel comprising an array of high intensity light emitting elements;
(Feature 2) the light emitting elements having distinguishable colours for each illuminated display panel;
(Feature 3) the disposition of each illuminated display panel of the automated sign;
(Feature 4) and, each illuminated display panel is adapted to be visible and distinguishable from each other illuminated display panel at a distance of at least 2 kilometres”.

The broadest scope of this amendment is therefore each illuminated panel being visible and distinguishable from each other illuminated display panel by “only one” of - Feature 1 or Feature 2 or Feature 3 or Feature 4.

Claim 1 as amended may be read as only limited to Feature 4 “…each illuminated display panel is adapted to be visible and distinguishable from each other illuminated display panel at a distance of at least 2 kilometres” – but not limited to Feature 4 in addition to at least one of features 1, 2 or 3. Therefore, it is broader in scope than the claims prior to the amendments.” (emphasis in original)

26.   In the hearing the Opponent also noted that the indentation of the added feature was the same as the indentation of the three optional features immediately above it. The Opponent argued that the indentation was suggestive that the added feature was intended to be a fourth optional feature in addition to the previous three optional features.

27.   The Applicant states in their submissions at paragraph 13:

“We submit the Opponent’s interpretation of the scope of the amended claims going beyond the scope of the claims before the amendment can only be sustained by an absurd construction of the claims, which is not allowable. The Opponent’s interpretation of the amended independent claims overlooks the use of punctuation to parse the limiting features of these two independent claims such that the newly introduced 2-kilometre feature must always be added to whatever notional combination of features that are previously defined by the independent claims. In particular, the three (3) features subject to the “one or a combination of” language are preceded by a full colon before these itemised features as recited in proposed amended independent claims 1 and 8 and each of these three (3) features is separated by a semicolon. Importantly, the 2-kilometre feature that follows is immediately preceded by “and,” in order to complete the parsing of features of each claim to always include this feature introduced by the proposed amendments. In contrast to this plain English interpretation, the Opponent overlooks the function of the conjunctive “and” followed by a comma to separate the new 2-kilometre feature from the three original features immediately preceding, which are themselves separated by the semicolons appearing in the independent claims. Accordingly, the 2-kilometere feature, parsed by appearing in a next line, remains in addition to the other features of the independent claims and not in a selective combination with any of the other features of the independent claims, as the Opponent would have it interpreted.” (emphasis in original)

28.   I am unaware of any grammatical rule in which a comma immediately following the word “and” would signify a new clause following a list. On the other hand, patent claims are written in an unusual style in that each claim is a (long) single sentence and consequently claims will sometimes make creative use of punctuation.

29.   To summarise the arguments of each party, the comma could be construed as either: a) emphatically indicating the last option in the list (Opponent’s submissions), or b) a signifier of a new clause in the claim (Applicant’s submissions).

30.   Both of these constructions utilise the comma to parse the last clause of the claim. The difference in the two alternative constructions is the “hierarchy” of the parsed clause. The Opponent argues that the parsed clause is the same hierarchy as the clauses it immediately follows (thus providing another alternative in the list), whereas the Applicant argues that the parsed clause is a level higher in the hierarchy than the clauses it immediately follows (thus an additional feature of the claim).

31.   One aspect of the punctuation of the amendments not mentioned by the parties is that the full stop that was at the end of the third item on the list has been replaced by a semi-colon. This is significant because each of the other items on the list also ends with a semi-colon. This use of the same punctuation suggests that the third item on the list will be followed by a fourth item on the list.

32.   Claims often contain clauses with different hierarchies. The hierarchy level of a clause is typically made clear with prefacing words, punctuation and formatting. In this case, because the clause is immediately following a list there are no prefacing words (or, at the least, it is unclear which words are intended to preface the clause). The punctuation (the comma) has parsed the final clause of the claim but left its hierarchy ambiguous. Which leaves the formatting to consider.

33.   The formatting (indenting) of the “2km feature” does not resolve the ambiguity. The indentation of the first line of the “2km feature” is in line with both the first word of the claim and the first word of each of the three optional features, thus could plausibly be in either the list level hierarchy or the main level hierarchy.

34.   To summarise, most of the paths of enquiry I have undertaken to resolve the ambiguity of the “2-kilometer feature” have been indeterminate. I note the use of semi-colons to separate items in the list of alternative features in the claim suggests that “2-kilometer feature” belongs to this list.

35.   Overall, I construe the amendments to claims 1 and 8 such that the “2-kilometer feature” is a fourth optional feature in addition to the list of the previous three optional features. With this construction, claims 1 and 8 are no longer limited to any one of the three previously defined optional features, and can instead include as an alternative the fourth optional feature. Thus, the amended claims 1 and 8 are not fully within the scope of the claim before amendment.

36.   Consequently, the amendment expands the scope of the claims and does not comply with s 102(2)(a).

37.   The Applicant has already proposed further amendment in their submissions (at paragraph 34), if the current amendment was found to fail under s 102(2)(a). I consider the proposed further amendment, insofar as it relates to claim 1, complies with s 102(2)(a).

38.   A marked-up version of this proposed further amendment to claim 1 is shown below:

1. An automated sign for indicating environmental conditions comprising a segmented conditions rating scale physically disposed on a substrate for public display wherein an illuminated display panel is operatively associated with each segment of the segmented conditions rating scale, whereby the illuminated display panels are controlled to illuminate one display panel at any one time so as to indicate by way of a selected segment environmental conditions in accordance with a received communications signal comprising prevailing environmental conditions and each of the illuminated display panels are adapted to be visible and distinguishable from each other illuminated display panel at a distance of at least 2 kilometres by one or a combination of:

each illuminated display panel comprising an array of high intensity light emitting elements;

the light emitting elements having distinguishable colours for each illuminated display panel;

the disposition of each illuminated display panel of the automated sign; and,

each illuminated display panel is adapted to be visible and distinguishable from each other illuminated display panel at a distance of at least 2 kilometres.

39.   It is assumed that, if further amendments are filed following this decision, a similar amendment would be made to claim 8 to overcome the s 102(2)(a) deficiency.

s 102(2)(b)

40.   Pre-existing defects in the specification are not relevant to the consideration of the allowability of amendments under section 102, as noted by Bennett J in Apotex Pty Ltd v Les Laboratoires Servier (No 2) [2009] FCA 1019 at [28].

41.   A deficiency in the support of the claims could only arise as a result of the amendments if either: a) the amendments broaden, rather than narrow the scope of the claims, or b) amendments to the description or drawing add information beyond that which was originally filed. The Opponent has not argued, nor does it appear, that the amendments to the description add information beyond that which was originally filed. Although I have found that the amendments are not allowable under s 102(2)(a), a satisfactory resolution to the issue has already been proposed. Once the s 102(2)(a) issue is corrected, the amendments only narrow the claims.

42.   I see little point in determining if the aspect of the amendments which have already been found to fail under s 102(2)(a) would also fail under the s 40(3) (support) arm of s 102(2)(b). This is because the amended claims are so broad that they do not include within their scope the feature that was added (only including it as an optional feature); This is also the feature which the opponent argues lacks support (if it had been found to be a non-optional feature).

43.   Moreover, since the proposed further amendment would be substantially in alignment with the prior dependent claim 7, it is hard to see how any of the alleged s 40(3) (support) matters could be as a result of the amendment. Thus, the parties’ submissions on the support for the “2-kilometer feature” and the Applicant’s evidence requested to be considered under Reg 5.23 would not be determinative of the allowability of the amendments. Consequently, I will not rely upon the information provided by the Applicant under Reg 5.23.

44.   I note that the Opponent could raise their concerns with the “2-kilometer feature” in the amended claims in the final determination of the s 59 opposition; however these concerns can only be raised in relation to whether that the amendments: a) overcome the deficiencies identified in the previous decision and b) introduce any new deficiencies. Pre-existing deficiencies are excluded from consideration in the final determination.

45.   Any deficiency in the s 40(2)(a) (clear enough and complete enough) and s 40(2)(aa) (best method) is purely a matter of the description and drawings, not the claims. Although the description has been amended, the Opponent has not raised any concerns with the amendments to the description. Furthermore, I cannot see any issues under s 40(2)(a) or s 40(2)(aa) arising as a result of the amendments to the description.

46.   A deficiency in s 40(3) (clarity) is an issue that could arise from the amendments to the claims and has not yet been fully considered and I will consider below.

Clarity

“fixed display panel”

47.   In the hearing the Opponent raised a new aspect of their opposition that had not been raised in their written submissions. In particular, the Opponent argued that claim 7 included the words “fixed display panel” and, while the amendments to claim 1 incorporate the words of claim 7 the amendments omit the word “fixed”.

48.   I invited the parties to provide written submissions on this point after the hearing. the Applicant provided written submissions, while the Opponent declined to provide written submissions.

49.   The Applicant’s submissions on the clarity of the amendments regarding the omission of the word “fixed” from the amendment to claim 1 are as follows:

“The limitation of “fixed” is ascribed to the display panels. The display panels are themselves a clearly defined feature or element of the claimed invention. Omitting the further limitation of the display panels being fixed does not affect the clarity of the display panels as recited in any of the claims. Fixed display panels would mean that the display panels are fastened securely in position on the claimed automated sign. Display panels that are recited in a claim, as they are in claim 1 before and after amendment, means that the display panels may or may not be fastened securely in position on the claimed automated sign. The “fixed” limitation is not an essential feature of the invention and the Applicant is afforded the right to claim or not to claim this feature in the independent claims.”

50.   It appears that the phrase “each other fixed display panel” in claim 7 prior to amendment did not have an antecedent, since the other panels being referred to are illuminated display panels. Thus the term “each other illuminated display panel” (which does have an antecedent) has been substituted. That is, there was a pre-existing (minor) clarity problem in claim 7 prior to amendment, however this has been corrected during the incorporation of claim 7 into claim 1

51.   The omission of the word “fixed” in the amendments to claim 1 does not result in a lack of clarity.

Conclusion

52.   The amendments do not comply with s 102(2)(a).

53.   The Applicant has 2 months from the date of this decision to formally propose suitable amendments to overcome this deficiency. The further (informally) proposed amendments already provided in the Applicant’s submissions are considered suitable amendments to overcome the deficiency.

Costs

54.   It is typical that costs should follow the event.

55.   The course of the opposition has deviated from the standard path. For example, the Applicant’s introduction of information outside of the evidentiary periods, and the Opponent raising matters that were not detailed in the Statement of Grounds and Particulars or their written submissions. However, I do not consider these deviations sufficient to vary the costs from those set out in Schedule 8.

56.   The Opponent has been successful in opposition to the allowance of the amendments. Costs according to Schedule 8 are awarded against the Applicant.

Xavier Gisz

Delegate of the Commissioner of Patents