• Judge Orrick Enjoins Huawei from Enforcing Its SEP Injunction Against Samsung

    Both the IAM Blog and FOSS Patents are reporting this morning on an opinion entered by Judge William Orrick (N.D. Cal.) preliminarily enjoining Huawei from enforcing against Samsung the injunction entered by the Intermediate People’s Court in Shenzhen, China, in January.  Here is a copy of Judge Orrick’s opinion.
    As readers of this blog are aware, in January the Chinese court issued an injunction against Samsung’s infringement of two FRAND-committed SEPs owned by Huawei; the court found that Samsung had not negotiated in good faith, and that Huawei had.  (See previous posts here and here.)  Litigation between the parties was already pending in the U.S., however, involving multiple patents on both sides.  (Huawei filed the U.S. action on May 24, 2016, and the Chinese action the next day; Samsung counterclaimed in the U.S. action and has asserted its own patents against Huawei in China, where unlike in the U.S. each patent gets its own separate lawsuit.)  On February 1, 2018, Samsung moved to enjoin Huawei from enforcing the Chinese injunction, and last Friday Judge Orrick granted the motion.  Here are some highlights from the opinion:
    1.  On the standard for granting an antisuit injunction:
    “A federal district court with jurisdiction over the parties has the power to enjoin them from proceeding with an action in the courts of a foreign country, although the power should be ‘used sparingly.’” Seattle Totems Hockey Club, Inc. v. Nat’l Hockey League, 652 F.2d 852, 855 (9th Cir. 1981). “Such injunctions allow the court to restrain a party subject to its jurisdiction from proceeding in a foreign court in circumstances that are unjust.” E. & J. Gallo Winery v. Andina Licores S.A., 446 F.3d 984, 989 (9th Cir. 2006)(“Gallo”). The Ninth Circuit employs “a three-part inquiry for assessing the propriety of such an injunction.” Microsoft Corp. v. Motorola, Inc., 696 F.3d 872, 881 (9th Cir. 2012)(“Microsoft II”); see also Gallo, 446 F.3d at 990 (establishing framework for determining whether to issue anti-suit injunction).

    First, we determine whether or not the parties and the issues are the same in both the domestic and foreign actions, and whether or not the first action is dispositive of the action to be enjoined. Second, we determine whether at least one of the so-called Unterweser factors applies. Finally, we assess whether the injunction’s impact on comity is tolerable (p.6).
    Notably, the moving party doesn’t have to prove the four Winter factors that are usually required for the entry of a preliminary injunction, including likelihood of success on the merits (pp. 7-8).
    2.  The court concludes that the parties and issues are functionally the same, which on its face seems correct (pp. 10-15).
    3.  The court also concludes that “domestic policy and other equitable considerations” favor Samsung, and I’m less sanguine about this:
    Samsung argues that allowing Huawei to enforce the Shenzhen Court’s injunction would frustrate specific domestic policies against injunctive relief on SEPs and general public policies against anticompetitive conduct and breaches of contract. Mot. at 18. The bulk of precedent supports its position. See, e.g., Microsoft II, 696 F.3d at 884 (“Implicit in such a sweeping promise [made by Motorola to standards-setting organization] is, at least arguably, a guarantee that the patent-holder will not take steps to keep would-be users from using the patented material, such as seeking an injunction, but will instead proffer licenses consistent with the commitment made.”); id. at 885 (“[I]njunctive relief against infringement is arguably a remedy inconsistent with th[at] licensing commitment.”); Realtek Semiconductor Corp. v. LSI Corp., Case No. C–12–03451–RMW, 946 F. Supp. 2d 998, 1006–07 (N.D. Cal. 2013)(“In promising to license on RAND terms, defendants here admit that monetary damages, namely a RAND royalty, would be adequate compensation for any injury it has suffered as a result of Realtek’s allegedly infringing conduct.”); Apple, Inc. v. Motorola Mobility, Inc., No. 11-CV-178-BBC, 2012 WL 5416941, at *15 (W.D. Wis. Oct. 29, 2012)(“ I agree with Apple that from a policy and economic standpoint, it makes sense that in most situations owners of declared-essential patents that have made licensing commitments to standards-setting organizations should be precluded from obtaining an injunction or exclusionary order that would bar a company from practicing the patents.”)

    But Huawei insists that there is no “per se rule that injunctions are unavailable for SEPs[.]” Apple Inc. v. Motorola, Inc., 757 F.3d 1286, 1331 (Fed. Cir. 2014), overruled on other grounds by Williamson v. Citrix Online, LLC, 792 F.3d 1339 (Fed. Cir. 2015). It highlights precedent and policy that suggest “an injunction may be justified where an infringer unilaterally refuses a FRAND royalty or unreasonably delays negotiations to the same effect.” Id. at 1332 (citing U.S. Dep’t of Justice and U.S. Patent and Trademark Office, Policy Statement on Remedies for Standard–Essential Patents Subject to Voluntary F/RAND Commitments, at 7–8 (Jan. 8, 2013));see also Makan Delrahim, Asst. Attorney General, Antitrust Division, U.S. Dept. of Justice, Remarks as Prepared for Delivery at USC Gould School of Law – Application of Competition Policy to Technology and IP Licensing: Taking It to the Limit: Respecting Innovation Incentives in the Application of Antitrust Law (Nov. 10, 2017), available at https://www.justice.gov/opa/speech/file/1010746/download (“A patent holder cannot violate the antitrust laws by properly exercising the rights patents confer, such as seeking an injunction or refusing to license such a patent.”)(Greenblatt Decl. ¶ 5, id., Ex. 4, Dkt. No. 240-8).

    That may be true, but the policy that is undermined is this court’s ability to determine the propriety of injunctive relief in the first instance. See, e.g., Zynga, Inc. v. Vostu USA, Inc., No. 11-CV-02959-EJD, 2011 WL 3516164, at *3 (N.D. Cal. Aug. 11, 2011)(“But one clear policy that all federal courts recognize—even those which have been loath to interfere with foreign proceedings—is the need to protect the court’s own jurisdiction.”). There is a risk of inconsistent judgments if I were to find that Huawei is not entitled to seek injunctive relief for its SEPs. See Microsoft I, 871 F. Supp. 2d at 1100 (“Courts have found that court policies against avoiding inconsistent judgments, forum shopping and engaging in duplicative and vexatious litigation sufficient to satisfy this step.”). In addition, in the absence of an antisuit injunction, Samsung faces the risk of significant harm, not just in China, but with impacts percolating around the world. The Chinese injunctions would likely force it to accept Huawei’s licensing terms, before any court has an opportunity to adjudicate the parties’ breach of contract claims.18 Under these circumstances, the Shenzhen Order “interfere[s] with ‘equitable considerations’ by compromising the court’s ability to reach a just result in the case before it free of external pressure on [Samsung] to enter into a ‘holdup’ settlement before the litigation is complete.” Microsoft II, 696 F.3d at 886. As in Microsoft, the Chinese actions “have frustrated this court’s ability to adjudicate issues properly before it.” Microsoft I, 871 F. Supp. at 1100. The integrity of this action, therefore, will be lessened without an anti-suit injunction. See id. (pp. 16-17).
    4.  Finally, the court concludes that the injunction would not have an intolerable impact on comity:
    Samsung points out that the Shenzhen Order provides that “Huawei can agree after the appeal that the injunction will not be enforced, and further states that the Shenzhen Court would also permit non-enforcement if the parties agree to an SEP cross-license.” Shenzhen Order at 209; Xie Decl. ¶ 7. So the relief it seeks would have no impact on the Chinese courts; rather, it asks me to restrain Huawei from enforcing any injunction order until I have the opportunity to determine the propriety of injunctive relief for the parties’ SEPs. It specifically notes that Huawei would remain free to seek damages for infringement of its Chinese patents while this action is pending (p.20).
    I’m not sure I’m surprised by the result, but I have to say that decisions like this do seem a bit hard to square with the territorial nature of patent rights.  I recently blogged about the U.S. Supreme Court’s pending decision in WesternGeco (see here), and I opined that granting damages that are proximately caused by an act of domestic infringement do not intrude upon other countries’ laws, even when those damages are suffered in another country.  Reasonable observers may disagree with me on that, but (to me) it would seem odd to not award damages in a case like WesternGeco but to permit antisuit injunctions in a case like Huawei, where the intrusion on the ability of the foreign court to adjudicate a dispute according to its own lights seems more severe.  I’ll be giving more thought to this matter throughout the day, however, and may come back with some further observations.

    *          *          * 
    In other news, the U.S. Supreme Court is hearing oral argument in the aforementioned WesternGeco case this morning.  I’ll post the transcript when it is available later today.
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  • Dozens Of NGOs Oppose Proposed EU Watch List On IP Rights

    A wide-ranging list of international nongovernmental organisations today issued a letter to European Trade Commissioner Cecilia Malmström opposing a proposal to establish a “watch list” of countries deemed failing to protect European intellectual property. The groups raised concern that the list would violate World Trade Organization rules on intellectual property, have a chilling effect on developing countries’ public health initiatives, and lead to expanded and untenable levels of IP enforcement.

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  • A Look At Facebook Patents Covering ‘Big Brother’ Data Collection Technologies

    Facebook users continue to be shocked at the amount and kind of data being collected by the social media platform, including recent reports about call and SMS text messaging data which Facebook has been collecting from Android mobile users. Along with the political heat Zuckerberg continues to take, Facebook itself could be on the hook for a record fine from the Federal Trade Commission if it’s found that the company’s data practices violate terms of a 2011 consent decree between Facebook and…

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  • IBM’s improvement arguments overcome Alice rejections, win random number generation claims at the PTAB


    Takeaway: The PTAB reversed Alice rejections of pure-software random digital generation claims, crediting the appellants’ improvement argument in the face of examiner criticism of that argument and even in the absence of a reply brief addressing that criticism.

    Details:


    Ex parte Sherwood

    Appeal No. 2017-006552; Application No. 13/906,056; Tech. Center 2100
    Decided: Sep. 28, 2017

    The application on appeal, titled “Balancing Consumption of Random Data”, described improved operation of an apparatus for generating random data in a computer system, and in particular, to the improved operation of obtaining entropy data for seeding the random data generation.  A representative claim on appeal read:

    21.  A digital data apparatus for producing random digital data, comprising:
           at least one physical processor;
           a physical system memory;
           a plurality of entropy sources each generating respective random source digital data having a corresponding level of entropy, including a first entropy source generating random source digital data having a first level of entropy, and a second entropy source generating random source digital data having a second level of entropy lower than said first level of entropy, said second entropy source being independent of said first entropy source;
           a random number generator embodied as computer program code storable in said physical system memory and executable on said at least one physical processor, said random number generator receiving input from each said plurality of entropy sources, said random number generator generating a random digital data output by a deterministic algorithm using input from a selective one of said plurality of entropy sources as a seed for said deterministic algorithm;
           an entropy manager embodied as computer program code storable in said physical system memory and executable on said at least one physical processor, wherein said entropy manager automatically selects one entropy source among said plurality of entropy sources as input for the seed for said deterministic algorithm used by said random number generator, said entropy manager automatically selecting one entropy source among said plurality of entropy sources by determining a minimum level of entropy required by a consuming entity from among multiple possible minimum levels of entropy required, wherein the consuming entity consumes random digital data output by said random number generator to perform at least one data processing function, wherein the minimum level of entropy required by the consuming entity is a minimum level required as input for the seed for said random number generator to produce the random digital data output consumed by the consuming entity, said entropy manager further automatically selecting an entropy source from among said plurality of entropy sources having the lowest corresponding level of entropy which meets said minimum level of entropy required by the consuming entity.

    (Emphasis added.)

    The final rejection held that the claims were directed to the abstract idea of “performing mathematical steps drawn to generating random data, receiving inputs, selecting entropy sources, determining levels of entropy, consuming random data, monitoring/analyzing events, accessing rules, determining levels of entropy, preventing flipping of entropy selection states, and performing cryptographic operations.”  The rejection stated that

    [t]hese steps merely employ basic concepts drawn to manipulating information using mathematical and logical concepts which is similar to the basic concept of manipulating information using mathematical relationships found to be an abstract idea by the courts. The claims do not include additional elements that are sufficient to amount to significantly more than the judicial exception because the claims do not add a meaningful limitation to the abstract steps as they would be routinely used by those having ordinary skill in the art on a general purpose computer.

    With regard to the second step of the Alice framework, the examiner found that the recitation of processor and memory in the claims did not amount to significantly more, and likewise,

    the recitation of elements such as “entropy sources”, “random number generator”, “entropy manager”, and “cryptographic apparatus” are also generic because there is no evidence in the specification that these elements must be specific hardware elements. For example, the claimed random number generator and entropy manager are embodied as code and the claimed cryptographic functionality is defined in the specification as software. A general purpose computer can be programmed to execute code and software.

    The examiner also addressed the applicant’s argument that the claims were directed to an improvement in computer technology:

    [T]he invention as claimed is not drawn to an improved encryption engine for a computer system that improves efficiency. . . . [T]he applicant has failed to point to evidence that using “relatively lower entropy data for certain less essential purposes” improves efficiency of the claimed invention.  The applicant’s arguments cannot take the place of evidence.

    (Emphasis in original.)

    The appeal brief is worth quoting at length:

    [The] invention relates to “improved operation of an apparatus for generating random data in a computer system, and in particular, to the improved operation of obtaining entropy data for seeding the random data generation” . . . Although improved performance is the primary motivation, Appellant’s technique . . . may, by using highest quality random data only when necessary, permit a higher quality of randomness to be used in those circumstances which require it.
    A computer-implemented cryptographic engine or random data generator necessarily receives input in the form of data, i.e., strings of ‘1’s and ‘0’s, and performs a series of mathematical steps and takes branches based on determinations made using data, to produce a final result, which is again data, i.e., strings of ‘1’s and ‘0’s.  . . . [A]ny computer-implemented process can ultimately be reduced to receiving data as input, performing a series of mathematical steps and branches based on determinations made using the data, and producing a result in the form of data.  That is the very essence of a deterministic sequential state machine.  No computer, no matter how fast, sophisticated or advanced over other computers, can do anything beyond these basic steps.
    If any machine or process which is limited to receiving data input, performing mathematical manipulations of the data, making decisions based on results, and outputting data, is deemed an “abstract idea”, the Patent Office might as well give up patenting computer implemented inventions, for all such inventions, no matter how complex or sophisticated, ultimately can be broken down into simple mathematical steps and branches.  This is clearly not what the law is and not what was intended by the recent Supreme Court decision in Alice Corp. v. CLS Bank. . . . [T]t is true that in a very general sense Applicant’s invention does [manipulate information using mathematical relationships].  As does each and every computer-implemented invention that has been patented by the Patent Office. . . . The Examiner’s reasoning appears to be exactly the type of overly broad application of the “abstract idea” doctrine which was disapproved by the Federal Circuit in Enfish. . . .  Appellant’s invention does not come close to pre-empting the field of “manipulating information using mathematical relationships”.

    (Emphasis in original.)

    The examiner answered that:

    [P]reemption is not the test for judging subject matter eligibility under the Alice analysis.  Rather, the test consists of (in summary) determining whether the claimed invention is drawn to a judicially recognized exception.  If so, then the claimed invention is further analyzed to determine whether there is additional subject matter recited that amounts to significantly more than the judicial exception.
    The claims are drawn to apparatuses, methods, and computer program products which perform mathematical steps. These steps manipulate information using mathematical and logical concepts. Ideas such as this have been found by the courts to be abstract. See Parker v. Flook, 437 U.S. 584 (1978); Gottschalk v. Benson, 409 U.S. 63 (1972).  In Flook, the claimed invention was drawn to the abstract idea of gathering numerical information and manipulating it mathematically.  In the instant case, entropy information is gathered in the form of binary numbers and is manipulated mathematically to generate random data, which is also represented in binary.

    The examiner called the appellants’ improvement argument “flawed”:

    Appellant’s only explanation that the claimed invention is an improvement is that computer system efficiency is improved “by using relatively lower entropy data for certain less essential purposes.” . . . However, Appellant never defines what these “purposes” are.  More importantly, the entropy data is used for random number generation, this being the only “purpose” that can be inferred from Appellant’s argument.  How this improves computer system efficiency is not explained in Appellant’s argument. Appellant merely asserts that these purposes exist without citing any evidence as to what they are.

    The appellants did not file a reply brief to address this rebuttal.  Nevertheless, the Board “agree[d] with Appellants that the Examiner has overgeneralized the claimed invention by summarizing it as the mere performance of mathematical steps, or as information gathered in the form of binary numbers that is manipulated mathematically to generate random data”, and took it upon themselves to scour the specification for the inventive concept:

    [The] invention is directed to generating random digital data for use by a consuming entity.  For certain purposes, e.g., strong encryption, random data having higher entropy is required; for other purposes, lower entropy (and thus quicker to gather) random data will suffice. . . . In the invention, an entropy manager determines the minimum level of entropy required by a consuming entity, and selects the random data (i.e., entropy) source that supplies random data having a requisite level of entropy for the consuming entity’s purposes.
    We do agree generally with the Examiner’s conclusion that Appellants’ claimed invention is drawn to an abstract idea. The claims under appeal are drawn to method and apparatus for producing random digital data, including a random number generator for generating said random digital data by following a deterministic algorithm using input from one of a plurality of entropy sources as a seed.
    Appellants persuade us, however, that the claims are, nonetheless, statutory under the second prong of the Alice analysis.  Representative claim 21 recites, inter alia, an entropy manager that “automatically selects one entropy source” from among a plurality, as the seed for the deterministic algorithm. The entropy manager makes this selection “by determining a minimum level of entropy required by a consuming entity . . . the minimum level of entropy required by the consuming entity is a minimum level required as input for the seed for said random number generator . . . said entropy manager further automatically selecting an entropy source from among said plurality of entropy sources having the lowest corresponding level of entropy which meets said minimum level of entropy required by the consuming entity.”
    In support, Appellants’ Specification discloses that “[h]igh-entropy data is difficult for a computer to generate,” and even if one resorts to techniques such as monitoring network traffic, “it takes time in order to gather such random data.” . . . Appellants’ invention, thus, sets forth a system that automatically balances the tradeoff between (a) high entropy, hard to predict (and thus hard to attack) data that is scarce, time-consuming to produce, or both, and (b) lower entropy, less difficult to predict (but less secure) data that is easier to gather, less computationally intensive to produce, or both. See Spec. 9-10.
    We conclude that the function of the entropy manager in the claimed invention results in claims drawn to significantly more than an abstract idea.  See Alice, 134 S. Ct. at 2355.  Like the animation method in McRO Inc. v. Bandai Namco Games America Inc., 837 F.3d 1299 (Fed. Cir. 2016), we conclude that the claims under appeal are limited to rules with specific characteristics.  McRO, 837 F.3d at 1314—15.  Like the self-referential logical table in Enfish, LLC v. Microsoft Corp., 822 F.3d 1327 (Fed. Cir. 2016), we conclude that the appealed claims focus on a specific means or method that improves the relevant technologySee Enfish, 822 F.3d at 1335.  Here, Appellants’ invention focuses on a specific method of providing an entropy manager to make a decision concerning the appropriate entropy level to be employed, in order to supply random digital data of sufficient entropy while conserving computer processing power and/or time.

    (Emphasis added.)  Thus, the Board reversed the subject-matter eligibility rejections, and the appellants were issued their patent (No. 9,934,000).


    My two cents:

    This post in the fifth in a series examining improvement arguments and their rapidly mounting significance in winning reversals of Alice rejections at the Board.  The first post in the series provided a set of practice tips.  This case is an example of an improvement argument winning at step two of the Alice framework, and illustrates the examiner demanding evidence in support of the improvement argument (see practice tip #7) but the appellants not needing it to win.

    The abstract idea to which the examiner alleged the claims were directed (“performing mathematical steps drawn to generating random data, receiving inputs, selecting entropy sources, determining levels of entropy, consuming random data, monitoring/analyzing events, accessing rules, determining levels of entropy, preventing flipping of entropy selection states, and performing cryptographic operations”) is a mouthful, but the Board nonetheless agreed that the claims were drawn to an abstract idea, albeit one of a different description: “producing random digital data, including a random number generator for generating said random digital data by following a deterministic algorithm using input from one of a plurality of entropy sources as a seed.”

    The Board gave no credit to the examiner’s argument that additional evidence was required to show that using “relatively lower entropy data for certain less essential purposes” resulted in an efficiency improvement.  Instead, the Board found the description in the specification to be self-evident of the cause and effect reasoning necessary to support the improvement argument.

    Only about six months elapsed between the docketing of the appeal and the handing down of the Board’s decision.  This seems unusual, as most practitioners are more accustomed to appeal pendency on the order of years rather than months.  According to contemporary PTAB statistics, average appeal pendency for cases originating from technology center 2100 at the time of this decision was 13.2 months, down a spectacular 11.1 months from the same time the previous year.  Although appeal pendency has been dealt with very effectively and continues to fall (it’s down to 13.0 months in 2100 at last count), this appeal was still delivered in less than half the average time.  One can only speculate whether this case was hastened by a PTO directive to build Alice guidance by expediting appeals deciding § 101 controversies, or because of the particular Board section to which the appeal was assigned and the workload thereof, or because of the identity of the real party in interest (IBM) and the volume of applications filed by that particular assignee.  Whatever the reason for the favoritism (if any), the appellants got a good deal with this appeal, only waiting about twice as long as they would have for another Office action.

    We’re not done yet with looking at improvement argument cases, so stay tuned for more.

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  • Federal Circuit Upholds Vanda Fanapt Personalized Method Claims Against Patent Eligibility Challenge

    In Vanda Pharmaceuticals Inc. v. West-Ward Pharmaceuticals Int’l Ltd., a divided panel of the Federal Circuit upheld Vanda’s personalized method of treatment claims relating to its Fanapt® (iloperidone) product against a patent eligibility challenge. Interestingly, where the district court had found the claims eligible at step two of the Mayo/Alice analytical framework, the Federal Circuit…… Continue reading this entry

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  • Conference & CLE Calendar

    April 19, 2018 – “Overcoming § 101 Rejections for Computer and Electronics Related Patents — Leveraging USPTO Guidance and Recent Decisions to Meet 101 Patent Eligibility Requirements” (Strafford) – 1:00 to 2:30 pm (EDT) April 19, 2018 – “When All Else Fails: How, When and Why to Terminate an IP License” (Technology Transfer Tactics) – 1:00 to 2:00 pm (ET) April 23-24, 2018 – Paragraph IV Disputes conference (American Conference Institute) – New York, NY April 24, 2018 – “Trade Secrets Update 2018: Year Two of the DTSA” (McDonnell Boehnen Hulbert & Berghoff LLP) – 10:00 am to 11:15 am…

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  • Eligibility: Preamble Does the Trick for Federal Circuit

    by Dennis Crouch Vanda is an important patent eligibility case drawing a fine line between the the eligible personalized medicine treatment claims and the ineligible methods of Mayo and Ariosa.  Vanda Pharma v. West-Ward Pharma (Fed. Cir. 2018) In a split decision, the Federal Circuit has affirmed the validity/infringement of Vanda’s U.S. Patent No. 8,586,610 covering […]

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  • 換算

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    換算

    $$ Preferably the processing means is programmed such that it can calculate an estimate of the calorific expenditure of the subject for a specified …

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  • Hobart President Vincent resigns on Friday, April 13, 2018 after plagiarism charges

    President Vincent at Hobart has resigned. Previously, IPBiz had discussed accusations against Vincent of plagiarism in his Ph.D. thesis:
    Anonymous accuser asserts copying in doctoral thesis of Gregory J. Vincent

    The New York Post/AP noted on 14 April 2018:

    Hobart and William Smith Colleges announced Friday that Gregory Vincent has resigned as president effective immediately.

    The Finger Lakes Times gave some background on plagiarism:

    And by a college president? It’s exponentially worse.

    The 1983 HWS graduate took over as president in July 2017 after serving most recently as a law professor and vice president at the University of Texas at Austin.

    It was a sweet homecoming to Geneva for Vincent to be named the first HWS graduate and first African-American to be president of the Colleges.

    Besides his HWS bachelor’s degree, Vincent earned a law degree from Ohio State and an education doctorate from the University of Pennsylvania. The dissertation for that EdD is at the center of the HWS trustees’ plagiarism investigation.

    Students at the campus newspaper (Herald) provided some further detail, as given in the FL Times article:


    But the students landed a big journalistic fish by getting Vincent to explain publicly what he believes might have happened.

    “As my dissertation advisor recently confirmed, I had to change the citation style within a very short period of time after my committee approved the dissertation, which led to inadvertent errors in how some of the work was quoted and paraphrased,” Vincent told The Herald. “I deeply regret the extent to which this has caused confusion or misled anyone. I eagerly await the findings of the investigation.”

    Anyone who ever dipped their toe into the murky waters of graduate-level academic writing knows citations and references can be logistical nightmares, requiring mind-numbing attention to detail to avoid plagiarism as well as the confusion Vincent cites.

    Article in Finger Lakes Times on 13 April 2018. The plagiarism thicket at HWS

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