Will Japan's crypto-friendly environment be the start of the country's mass adoption of cryptocurrency and blockchain?
Japan is considered the third-largest economy in the world. Nevertheless, its perspective regarding cryptocurrency and its utilization in the world market still remains cautious. The past week, however, became an aggressive week for trading in the country. Collaboration with some of the major agencies resulted in the establishment of several new businesses. This is a great opportunity now that the country is establishing a crypto-friendly environment.
Huge enterprises such as Rakuten and Yahoo Japan are rumored to have introduced their own systems in the industry. For cryptocurrency and blockchain technology consultants, this came as a delightful surprise. Industrial experts believe that the latest developments are committed to transforming the situation and would highly benefit the people and the industry.
Japan's burgeoning mass adoption of cryptocurrency has been accepted by most businesses due to the increased payment options from different sectors. This Asian country has taken the lead in the outlining of cryptocurrency regulations. As one of the biggest economies in the world, Japan needs to keep abreast of the latest trends with respect to the cryptocurrency industry.
The approaching G20 summit is expected to be a monumental platform for the nation. It will demonstrate its acceptance of digital currency as it eradicates fundamental barriers. Tokyo is in fact, looking forward to persuading the international community to draft strict guidelines. This is intended for the advancement of the cryptocurrency industry to make it more acceptable across the country.
Rakuten is one of the major e-commerce platforms in the world. The Regulatory Services Agency (RSA) awarded the company the license to exchange cryptocurrency. It replaced the unlicensed exchanged platform called Everybody's Bitcoin on March 1, 2019.
Its chief objective is to establish an extremely secure digital assets exchange as Japan begins to build a crypto-friendly environment. It will be more convenient for users to conduct crypto trading activities and transactions.
Everybody's Bitcoin was providing its financial services to over 30 countries in different regions worldwide with approximately 1.3 billion members.
Yahoo Japan is poised to inaugurate a business in May and has already begun accepting accounts. It is reported to have plans of instituting a crypto exchange this year. It already acquired a 40% stake in Taotao, formerly known as the Bit Arg exchange licensed by the Financial Services Agency (FSA).
DeCurret Co. Ltd. pronounced as "Dikalet", is a cryptocurrency agency based in Tokyo. Its operation started this month, with accounts that are already established. It has an approximate capital of 5.2 billion yen with account acceptance that started on March 27. The company's stock exchange service will commence on April 16 of this year. Aside from BCH, BTC, and ETH, DeCurret will also handle Ripple (XRP) and Light Coin (LTC) totaling 5 different cryptocurrencies in its exchange.
Regardless of the latest downturn in the value of bitcoin and altcoins, the unfriendly market conditions did not dull the enthusiasm of different companies that seek to launch business operations in Japan's crypto-friendly environment.


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Riverside Primary School
London Borough of Southwark
Riverside Primary School is an existing one and a half form entry school including a 26FTE place nursery. The Grade II listed Victorian school building is to be carefully adapted and extended to suit contemporary teaching methods and standards for the 21st century.
The proposed works include constructing a new teaching, entrance and kitchen/dining block, refurbishing the east corner of the school and implementing a new landscape design across the site.
Each of the builds have been designed as single storey blocks as a response to the existing school. The Teaching Block will be constructed to replace the damaged infant block to the northwest corner of the site and will include 3 classrooms, 3 group rooms, a dedicated external play area per classroom, staff office, cloak room and WC areas. The Entrance Block is proposed as a small extension in the east corner of the site to incorporate a general office, accessible WC, waiting/welcome area and a small interview room whilst the Kitchen & Dining Block will replace the existing caretaker building in the northern corner of the site to include a hall, kitchen, office, storage and WC areas. The vacant space within the school (resulting from moving the kitchen/dining facilities into a new block) is to be reappropriated with a new music/staff room and place 2 be.
The landscape design has been developed to integrate the new buildings within an enhanced outdoor learning environment. A new `social quad' is proposed, enabling the easy connection from the new dining hall onto a part covered external seating terrace and then onto the quad. To the rear of the school, dedicated outdoor spaces for Key Stages 1 & 2 are provided to ensure play activities can be easily supervised. Feature areas include a story-telling corner and a quiet garden. Both to the front and rear of the new Key Stage 1 classrooms are breakout spaces for outdoor learning activities. The Foundation Years are also catered for with secure but welcoming nursery and reception play spaces. These can connect directly to the new hard court for activities including tricycle circuits.
Renders by Blackpointdesign

redpajama_set_name: RedPajamaCommonCrawl


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A core issue
I have already reported twice on the Core Wireless v. LG litigation in France: the first time to report on the first instance judgment, and the second time to report on a procedural ruling issued during the appeal proceedings.
Today's post will be about Conversant v. LG… which is exactly the same litigation, since Core Wireless Licensing SARL has now become Conversant Wireless Licensing SARL.
So, the appeal ruling is out – and it basically confirms the first instance judgment.
As a reminder, Conversant (Core) holds a portfolio of Nokia-originating telecom patents. More than a thousand of these patents were declared essential for the 2G, 3G and 4G standards before the European Telecommunications Standards Institute (ETSI).
Core negotiated for several years with South-Korean giant LG Electronics in an attempt to reach a license agreement over this portfolio – but the negotiations failed. In September 2014, Core filed a complaint with the Paris Tribunal de grande instance (TGI), claimed damages and requested that the court should set a royalty rate for LG's telecommunication devices. The complaint was based on a set of five European patents.
The TGI held that there was no evidence of infringement of the five patents by LG, and thus dismissed Core's claims in April 2015.
The many traps of standard essential patent litigation.
Core appealed. When I commented on an interim case management ruling, I assumed that the only remaining issue on appeal was the determination of the royalty rate. This understanding was based on a somewhat misleading comment in the interim ruling – and it was thus incorrect.
In fact, similar issues were raised on appeal as in first instance. The main difference is that Conversant no longer asserted three of the patents initially discussed and preferred to focus on the remaining two.
Conversant still claimed that these two patents were infringed by LG and requested that the court should set a worldwide FRAND royalty rate for its portfolio. LG raised a number of defenses: invalidity of the two patents, absence of FRAND offer by Conversant, exhaustion of rights (based on a Nokia – Qualcomm license), absence of essentiality of the two patents, etc.
The first interesting part of the appeal ruling is a procedural one. The parties and the court made extensive use of the new provisions offered by the law of July 30, 2018 on the protection of trade secrets.
As already explained in the report on the interim ruling, the access to some of the exhibits (especially license agreements) was restricted to the parties' lawyers and to some designated persons having signed confidentiality agreements (especially interpreters and economist experts).
Also, two versions of the written submissions, were filed, namely a complete one and a redacted one deprived of any reference to confidential information relating to the various license agreements at stake.
Finally, the hearing was scheduled over three days.
On the first day, Nokia's FRAND commitment, an alleged abuse of dominant position and the exhaustion defense were debated. During part of the day, access to the courtroom was restricted to the lawyers of the parties as well as a couple of representatives from said parties. This closed session revolved around the most sensitive exhibit (the Nokia-Qualcomm agreement) and the exhaustion defense.
On the second day, the determination of the FRAND rate was discussed. Again, access to the courtroom was restricted to the above persons, plus a number of designated experts, during part of the day – when comparable license agreements were disclosed.
On the third day, validity, essentiality and infringement of the patents were discussed (without any access restriction).
The recent modernization of French procedural rules which has made this type of customized arrangement possible is most commendable – and was long overdue. It has probably put France on an equal footing with other major patent jurisdictions that have long been accustomed to such notions.
As readers may already have noted, a three-day appeal hearing for a patent case, especially at the appeal stage, is truly exceptional in France. This duration was certainly justified by the complexity of the case.
Hence, it could legitimately be assumed that a significant decision would come out of this whole process, namely a worldwide FRAND rate-setting determination. It did not.
First, the court reviewed the two sample patents asserted by Conversant, and addressed the invalidity challenges brought by LG. The court concluded that both patents were valid.
Second, the court addressed whether these two patents, declared as essential, were indeed essential for the standards at stake. Walking in the footsteps of the first instance judges, they concluded that they are not.
Since the demonstration of infringement was solely based on the essentiality of these patents (and on the compliance of LG's devices with the standards), and since no other patent from the portfolio was asserted in the lawsuit, the court was finally not aware of any actual Standard-Essential Patent (SEP) held by Conversant.
As a result, the court did not rule on exhaustion of rights, on the FRAND royalty rate and on all other exciting questions raised by the case.
Again, I guess that a number of stakeholders may be disappointed by this underwhelming decision, not so much because the plaintiff lost, but because legal certainty is currently relatively low when it comes to SEPs, FRAND royalty rates and exhaustion of rights.
Additional guidance from a French court would thus have been welcome.
That being said, looking at the non-essentiality finding in the ruling in more detail is rather interesting.
Claim 1 of the first patent, EP 0978210, is directed to a "method for selecting a base station in a mobile communication system". One of the steps of the method consists in, "in response to recognizing the poor radio signal, measuring", well, a certain something.
According to the relevant technical specifications of the UMTS (3G) and LTE (4G) standards, as explained by the parties and their experts, if a radio connection having a quality lower than a threshold is identified, a measuring step as claimed must be performed. But if the quality of the radio connection is higher than the threshold, the terminal may decide not to perform any measurement, which means that it may conversely decide to perform a measurement anyway.
The court concluded that a terminal which also performs the measurement when there is a good connection would be compliant with the standards but would not infringe the patent. Therefore, the patent is not an SEP.
Claim 1 of the second patent, EP 0950330, can be quoted in its entirety: "A user terminal comprising a wireless interface and a formatting device for formatting a signal for transmission over said wireless interface in accordance with a low level signal format protocol, characterised in that it comprises means for receiving a type signal, wherein said type signal is indicative of a high level signalling protocol to be used in transmitting said signal, and for formatting said signal in accordance with said high level signalling protocol".
According to Conversant's expert, LTE terminals can access both of the so-called IPv4 and IPv6 networks. If a network can work with only one of IPv4 or IPv6, the terminal will use it. If a network can work with both IPv4 and IPv6, the terminal will select one of those. Thus, the claimant argued, the subject-matter of claim 1 is implemented.
However, LG replied that IPv4 and IPv6 are just two versions of the same protocol, and not two different protocols. The court was quite sensitive to this argument, as the patent itself, although it was filed after IPv4 and IPv6 were established, does not distinguish between these versions and only broadly refers to the internet protocol (IP). Besides, the standard does not explicitly state that the terminal should select between IPv4 and IPv6 when both are available. It is thus not possible to consider that such a selection step would be demanded by the standard.
Again, the conclusion is that the patent is not an SEP.
Essentiality was thus the core issue throughout this litigation.
This appeal ruling should come as a warning that claim mapping of a standard is far from being straightforward.
Among the 1,000+ patents of the portfolio, it can be safely assumed that the five (later narrowed down to two) patents asserted in this case were rated as being among the "strongest" or "best" ones by their holder. And yet, even with these two particularly "strong" or "good" patents, the essentiality case was not clear-cut, as delicate issues of claim interpretation arose.
This is not completely surprising, as standards are elaborated quite independently from the patents which may be owned by members of the standard-setting body. Also, a standard contains a number of minimal rules but does not provide all implementation details. Even if, in practice, all implementations use a certain feature, it does not necessarily mean that this feature is required by the standard itself.
This makes me wonder about the proportion of patents declared as potentially essential which would be viewed as actually essential by a court? I assume that proportion could in fact be rather low. Definitely some food for thought for all those involved in license negotiations.
CASE REFERENCE: Cour d'appel de Paris, pôle 5 chambre 1, April 16, 2019, Conversant Wireless Licensing SARL v. LG Electronics France SAS & LG Electronics Inc., RG No. 15/17037.
Posted on April 29, 2019 May 6, 2019 Categories French case law, SEPs2 Comments on A core issue
A packed Pacte
France has a funny bicameral system.
Both chambers of the parliament, the Assemblée nationale and the Sénat, get to debate on, amend and vote bills. But if they fail to agree on the same version of a bill, in the end the Assemblée nationale has the last word.
And so it is with the so-called "Loi Pacte", first discussed on this blog post. There was some suspense as to what the bill would finally contain, as it bounced back and forth, being amended and dis-amended from one chamber to the other. But now the suspense has come to an end as the bill has been finally adopted and will become the law of the land.
Well, unless there is a last minute surprise, as the constitutionality of the bill will likely be challenged in front of the Conseil constitutionnel (our constitutional supreme court) by disgruntled members of parliament.
The final text is here and it is 408 pages long (yes, that is some packed Pacte). It has many different aspects, including some controversial ones – like the privatization of ADP (the company that runs Paris' airports). It also contains some provisions on IP, including just a few ones on patent law – but they are very important provisions indeed.
Basically, the report that I previously made on the draft still stands, although the articles have been renumbered:
The maximum duration of utility certificates will be brought from 6 years to 10 years (article 118).
It will be possible to convert a utility certificate application into a patent application within a deadline which still needs to be determined, whereas only the opposite is possible as of today (article 118).
The government is authorized to rule by way of an ordonnance in order to set up a procedure for third parties to oppose a granted patent (article 121).
The INPI (French patent office) will be able to refuse a patent application if its subject-matter is not an invention or is excluded from patentability, in contrast with the current formulation, per which its subject-matter is "manifestly" not an invention or is "manifestly" excluded from patentability (article 122).
The INPI will be able to refuse a patent application if its subject-matter is not novel or not inventive, in contrast with the current formulation, per which an application may be refused if it was not modified despite a "manifest" lack of novelty (article 122).
Infringement actions will be time-barred five years after the day the right owner knew or should have known the last fact allowing them to act, as opposed to the current formulation, which is five years "from the facts" (article 124).
The statute of limitations will no longer apply to patent nullity actions (article 124).
So, there you have it, I don't know if it is spring or winter, but a new season is definitely coming.
In the year 2525 – if patents can survive.
So what next? Well, first we will have to carefully look at transitional provisions.
In this respect, I have noted the following:
The new provisions on utility certificates shall enter into force when the implementing decree is published, or one year from the publication of the law at the latest.
The timeline for the introduction of the opposition proceedings is still unclear, as it will depend on the regulations (ordonnance) that the government will issue.
Provisions extending the scope of examination of patent applications by the INPI shall enter into force one year from the publication of the law.
The new provision on the statute of limitations for nullity actions will immediately enter into force – but will have no effect on decisions that have become res judicata. It remains to be seen how this will be interpreted in practice.
The bottom line is that, regarding the biggest changes for patent applicants, patent attorneys and the patent office, we have some time to get prepared – but we all know how that usually flies.
The nitty-gritty of the new system is still unclear and will require our full attention.
Moreover, another question mark is how the INPI will adapt to this upheaval.
Based on a report on a meeting between the INPI management and representatives of the patent profession a few weeks ago, the following seems to be contemplated at present:
The projected date of entry into force of the patent opposition proceedings is January 1, 2020 (this is quite ambitious).
The projected start of the examination of inventive step is mid-2021 (this is because the new law will only apply to newly filed applications, I presume).
In terms of HR efforts, 15 patent examiners currently working on a backlog of national search reports will be redeployed to deal with opposition cases, and 16 new patent examiners will be hired to deal in particular with the increased workload related to the examination proceedings.
We also learn from this report that the new French "provisional patent application", that we have heard of a number of times, is not dead. It should be created soon by way of a government decree.
I am curious to know what such a provisional application will look like. So far, patent professionals have been extremely skeptical about this – to put it mildly.
According to one apocryphal anecdote, President Macron was told by a French start-upper a few years ago that U.S. law is much more favorable to innovators than French law, because they have provisional applications in the U.S.
As a reminder, filing a French patent application without claims and without paying any taxes gives you a filing date, which is all you need to later claim priority. So, if there is any truth to this anecdote, it probably means that our President never met a French patent attorney – or at least that such a meeting did not leave as strong an impression as the ones he had with start-up folks. Which, let's face it, is quite understandable.
Posted on April 15, 2019 April 14, 2019 Categories French national law, Opposition proceedings, Proceedings at the INPI5 Comments on A packed Pacte
A travel back in time
Regular readers of this blog are probably aware that Lionel Vial is a frequent contributor.
I am grateful for his thorough reporting on pharma / biotech case law. Today, he once again keeps us apprised of the latest SPC tidbit. As he even provided the illustration, I really have nothing to add but say thanks!
While we are all waiting for the decision of the CJEU in the Santen case (C-673/18) to finally know if, in application of the Neurim (C-130/11) case law, a patented novel medical use in humans of a product having already been authorized for a previous different medical use in humans deserves a supplementary protection certificate (SPC), the decision discussed today will take us back to the pre-Neurim era, a time of uncertainty as we will see.
At that time, the prevailing case law regarding further medical use consisted in Pharmacia Italia SpA (C-31/03) rendered on October 19, 2004, and Yissum (C-202/05) rendered on April 17, 2007.
According to the judgment in Pharmacia Italia SpA:
The grant of a supplementary protection certificate in a Member State of the Community on the basis of a medicinal product for human use authorised in that Member State is precluded by an authorisation to place the product on the market as a veterinary medicinal product granted in another Member State of the Community before the date specified in Article 19(1) of Council Regulation No 1768/92 of 18 June 1992 concerning the creation of a supplementary protection certificate for medicinal products.
On the other hand, the order in Yissum reads:
Article 1(b) of Council Regulation (EEC) No 1768/92 of 18 June 1992 concerning the creation of a supplementary protection certificate for medicinal products […] is to be interpreted as meaning that in a case where a basic patent protects a second medical use of an active ingredient, that use does not form an integral part of the definition of the product.
The DeLorean remains the best way to travel in time with style.
The Regents of the University of Colorado (hereafter the University) was granted European patent No. 1658858 on November 18, 2009 for the use of a botulinum toxin, in particular botulinum toxin type A, in the preparation of a pharmaceutical composition for treating a recalcitrant voiding dysfunction, in particular urinary incontinence.
A corresponding marketing authorization was then granted on August 22, 2011.
The University had six month (that is until February 22, 2012) to file an SPC application. However, since botulinum toxin type A had benefited of previous marketing authorizations and in view of the then prevailing case law, the University considered it impossible to have an SPC granted and therefore no SPC application was filed.
Then the Neurim judgment was rendered on July 19, 2012. It notably provides that:
Articles 3 and 4 of Regulation (EC) No 469/2009 of the European Parliament and of the Council of 6 May 2009 concerning the supplementary protection certificate for medicinal products must be interpreted as meaning that, in a case such as that in the main proceedings, the mere existence of an earlier marketing authorisation obtained for a veterinary medicinal product does not preclude the grant of a supplementary protection certificate for a different application of the same product for which a marketing authorisation has been granted, provided that the application is within the limits of the protection conferred by the basic patent relied upon for the purposes of the application for the supplementary protection certificate.
Neurim has often been considered as a complete reversal of the previous case law.
Besides, for many commentators, it opened the door to SPCs for novel medical uses in humans of products having already been authorized for a previous different medical use in humans.
The University therefore filed an SPC application on September 19, 2012, i.e. within 2 months of the publication of the Neurim judgment, but about 7 months after the end of the deadline for doing so.
The University sought to benefit from the provisions of Article L. 612-16 of the Code de la propriété intellectuelle, according to which:
Where an applicant has not complied with a time limit as regards the Institut National de la Propriété Industrielle, it may submit an appeal for reinstatement of it rights if it is able to give a legitimate reason and if the direct consequence of the hindrance has been refusal of its patent application or of a request or the loss of any other right or means of appeal.
The appeal must be submitted to the Director of the Institut National de la Propriété Industrielle within two months of the cessation of the hindrance. The act that has not been carried out must be accomplished within that period. The appeal shall only be admissible within a period of one year from expiry of the time limit not complied with. […]
However, the INPI (French patent office) was not convinced and rejected the appeal for reinstatement on June 30, 2015.
The University and Allergan (to whom the SPC application and the basic patent had then been assigned) appealed the decision of the Director of the INPI before the Paris Cour d'appel on September 18, 2015.
In a first decision dated September 16, 2016 the Cour d'appel confirmed the decision of the INPI. However, the decision was invalidated by the Cour de cassation, the French Supreme court, on April 5, 2018, for procedural reasons, as the Cour d'appel had neglected notifying observations made by the INPI to the University and Allergan.
The case then came back in front of the Paris Cour d'appel which, albeit with different judges, again confirmed the decision of the INPI on February 12, 2019 in the following terms:
However, according to the terms of article L. 612-16 of the intellectual property code, the legitimate reason must be understood as a "hindrance";
Even considering that the case law of the CJEU, before the Neurim judgement, did not allow the University to expect obtaining an SPC and could therefore discourage it to file an SPC application, the director of the INPI rightly observes that this situation does not characterize a hindrance according to the previously cited provision, given that the case law, be it that of the Court of justice, evolves, that even with the Pharmacia Italia and Yissum case law other operators have indeed filed SPC applications in relation to further medical uses, one of which having given rise to the Neurim judgment, and that the lack of filing of an SPC application by the University was the result of its free appreciation of the latter and not of an objective impossibility, independent of its will.
In any case, pursuant to article 7 of regulation No. 469/2009 concerning the supplementary protection certificate for medicinal products, the University had a six-month period expiring on February 22, 2012 to file its SPC application; the reference for preliminary ruling to the Court of justice of the European Union was received at the Court on March 16, 2011 and published in the OJEU on June 18, 2011; under these conditions, as is rightly observed by the director of the INPI, the University had to consider a possible reversal of the case law of the Court of justice;
As such, the decision of the director of the INPI is exempt from criticism in having retained that the lack of respect of the deadline imparted to the University for filing its SPC application was not due to a hindrance for which it would benefit from a legitimate reason, but to its will not to proceed with a filing that it did not consider appropriate and this in spite of the reference for a preliminary ruling submitted to the Court of justice duly published on June 18, 2011.
Perhaps, this case is an illustration that too much knowledge is sometimes dangerous, and that we, as counsels, should always be careful when giving opinions on the likely outcome of a filing on the basis of our knowledge of established case law, bearing in mind that there is always a possibility, even a remote one, that a case law can be overturned.
In any case, the University and Allergan should refrain from nourishing regrets on their missed filing at least until the result of the Santen referral (C-673/18) is known, as this latter case precisely arises from a decision of rejection of an SPC application by the INPI in relation to a further medical use.
Well, the way I see it, getting SPC law 100% right is a little bit like having to hit a wire with a connecting hook at precisely eighty-eight miles per hour the instant a lightning strikes a tower. Everything will be fine.
CASE REFERENCE: Cour d'appel de Paris, pôle 5 chambre 1, February 12, 2019, The Regents of the University of Colorado & Allergan Inc. v. Directeur de l'Institut National de la Propriété Industrielle, RG No. 18/14291.
Posted on April 8, 2019 April 7, 2019 Categories French case law, Restoration of right, SPCsLeave a comment on A travel back in time
A ruling not so Great for Manitou
In a rather exceptional move, two patent attorneys professional organizations took sides in a lawsuit between two private companies.
In fact, the CNCPI (Compagnie nationale des conseils en propriété industrielle) and the ACPI (Association des conseils en propriété industrielle) filed an intervention in an appeal on points of law in front of the Cour de cassation.
I know this may sound like a nerdy and rather unamusing April Fools' day prank, but it is not. I have temporarily given up on those since reality has started catching up with the imagination of jesters on a daily basis (anyone up to a Brexit joke these days?).
So, yes there was indeed such an intervention, in the litigation pitching British company JC Bamford Excavators Ltd. (JCB) against Manitou BF.
How did we get there and how did this all end?
JCB specializes in the production of manufacturing equipment e.g. for construction and agriculture. Manitou is a French manufacturer of fork lifts and other heavy equipment.
JCB owns in particular two European patents (EP 1532065 and EP 2263965) that it believes have been infringed by Manitou on the French territory.
On April 26-27, 2017, JCB rented a telehandler called Manitou MT 1840 and had tests performed on this device by two JCB employees, in the presence of two French patent attorneys. These tests were aimed at demonstrating infringement of the patents at stake. The two patent attorneys involved in this testing issued a report for JCB.
On May 5, 2017, JCB filed a complaint for patent infringement against Manitou.
A few weeks later, on June 1, 2017, JCB filed a request for an ex parte order to be authorized to carry out an infringement seizure in Manitou's premises. It is somewhat unusual for an infringement seizure to be requested after the infringement proceedings have already been initiated, but it is certainly possible to proceed in such a "reverse" order. The ex parte order was granted the next day.
On June 16, 2017, the infringement seizure was carried out by a bailiff in Manitou's premises. It must have been a rather exhausting one for all those concerned, as it lasted until 2:15 am the next day…
The bailiff was assisted during the seizure by two patent attorneys – as is almost always the case. But the important point here is that the two patent attorneys at stake were those who had assisted JCB with the April testing.
One week later, Manitou filed a motion for canceling the infringement seizure order. The judge rejected the motion in another order dated October 5, 2017. Manitou appealed.
On March 27, 2018, the Paris Cour d'appel set aside the October 2017 order, and canceled the infringement seizure order of June 2017 – thus also canceling at the same time the bailiff's infringement seizure report.
The court expressed the following principle:
[…] The right to a fair trial set out in article 6 of the European Convention on Human Rights [ECHR] requires that the expert assisting the bailiff should be independent from the parties […].
The court then reasoned as follows:
Mr. […] and Mr. […] were designated twice in the same infringement lawsuit between [JCB] and Manitou; a first time on April 26, 2017, upon [JCB]'s request, to perform tests on a Manitou MT 1840 vehicle, and to hand out on May 4, 2017 a private expert report describing the features of the material which was examined; and then by way of an order dated June 2, 2017, in which they were designated as judicial experts to assist the bailiff during the infringement seizure relating again to the MT 1840 model, already examined during the private expertise, as well as to further Manitou models. Obviously, and regardless of their status which requires compliance with rules of ethics, patent attorneys cannot be designated as experts by a judicial authority while they have previously been involved as experts on behalf of one of the parties in the same case […], without violating the impartiality principle required by article 6 [ECHR]. Their designation was illegal, so that the June 2, 2017 order shall be canceled, and the October 5, 2017 order shall be set aside.
JCB filed an appeal on points of law in front of the Cour de cassation.
The Cour de cassation: the Great Manitou of French litigation.
The March 2018 ruling sent some shock waves through the French patent profession as it seemed to establish new requirements for patent attorneys to be able to assist a bailiff during an infringement seizure.
Hit by these shock waves, the two abovementioned patent attorney professional organizations stepped in, in support of JCB's case.
Hot from the dematerialized press, here is now the judgment issued by the cassation judges a few days ago, which the Cour de cassation set aside the March 2018 ruling of the Paris Cour d'appel.
Locating the key part of a cassation judgment is a rather easy task. Such judgments are so brief that there is hardly any meat at all around the key part. So here it comes (broken down into shorter sentences):
The fact that the patent attorney of the seizing party had, on the initiative of the latter, established a report describing the features of the product at stake, does not prevent a later designation, upon request of the seizing party, as an expert to assist the bailiff in a patent infringement seizure. [Indeed], his mission is not subjected to a duty of impartiality since it is not an expertise under articles 232 and following of the Code de procédure civile. [Therefore], by ruling in this manner, the Cour d'appel breached the above legal provisions [i.e. article 6 ECHR and article L. 615-5 Code de la propriété intellectuelle].
I bet this ruling will come as a relief for most of the patent profession.
The mistake made by the Cour d'appel seems to have been to consider the patent attorneys assisting the bailiff as court-appointed judicial experts. They are not.
They are supposed to help the bailiff find evidence of infringement, they are not there to provide an impartial recommendation to a judge regarding the outcome of a discussion.
Calling upon patent attorneys to assist the bailiff, as opposed to employees of the infringement plaintiff for instance (which is prohibited), offers a number of guarantees for the seized party, due to the rules of ethics that patent attorneys have to follow. For instance, a patent attorney should not and will not communicate to the plaintiff any confidential information that he/she becomes privy to during the seizure.
But on the other hand there is no requirement for the patent attorney not to have advised the plaintiff in the past – including regarding the case at hand.
By the way, the CNCPI and ACPI's intervention in the appeal was found admissible.
This may pave the way for similar interventions in the future in case the rights and prerogatives of patent attorneys are at stake in a litigation.
CASE REFERENCE: Cour de cassation, ch. commerciale, March 27, 2019, JC Bamford Excavators Ltd. v. Manitou BF, appeal No. H 18-15.005.
Posted on April 1, 2019 March 31, 2019 Categories French case law, Saisie-contrefaçonLeave a comment on A ruling not so Great for Manitou


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Thailand in semifinals of Continental Futsal Championship
2022, Latest News, ThailandBy Editor AFF September 13, 2022
BANGKOK (13 Sept 2022) – Host Thailand have made the cut to the semifinals of the Continental Futsal Championship 2022 after coming in as the runners-up in the three-team Group A of the meet this year. After two matchdays, Thailand picked up four points following their 2-2 draw with Morocco and then a 3-1 victory…
Singapore Khalsa Association seal Singapore Football League 1 title
2022, Latest News, SingaporeBy Editor AFF September 12, 2022
SINGAPORE (12 Sept 2022) – Singapore Khalsa Association (SKA) have clinched the Singapore Football League (SFL) 1 title for the first time, having completed the 2022 season with 28 points – 6 clear of closest rivals Yishun Sentek Mariners FC. With the triumph, SKA became the 13th winner of the competition and prevented Tiong Bahru…
Back-to-back PTSR crown for Melaka
2022, Latest News, MalaysiaBy Editor AFF September 12, 2022
PETALING JAYA (12 Sept 2022) – Melaka United made it back to back titles in the Tun Sharifah Rodziah Cup (PTSR) when they beat Negeri Sembilan 1-0 in the final that was played at the Kuala Lumpur Stadium in Cheras. With both teams putting up a lively competitive display that stretched all the way to…
Lion City Sailors seal first Deloitte Women's Premier League title
SINGAPORE (11 Sept 2022) – Lion City Sailors FC have secured the 2022 Deloitte Women's Premier League (WPL) title off the back of an unbeaten run with two matches left. Their 4-0 victory against Still Aerion Women's FC at Yishun Stadium earlier tonight was their ninth in 10 matches and put them on 28 points,…
FUTSALCUP: Bintang Timur Surabaya edge Hongyen for first ASEAN crown
KORAT (10 Sept 2022) – Bintang Timur Surabaya (BTS) FC of Indonesia emerged as the new stars of ASEAN club Futsal when they beat Hongyen Thakam FC of Thailand 4-2 in the final of the AFF Futsal Cup 2022 this evening at Terminal 21 in Korat. Following BTS' defeat to the same Hongyen side in…
FIFA publish International Transfer Snapshot
2022, Latest News, Timor LesteBy Editor AFF September 9, 2022
DILI (9 Sept 2022) – FIFA have published their International Transfer Snapshot (1 June – 1 September 2022), an analysis of the international player transfer activity during the transfer window that recently closed. According to the report, transfers showed strong recovery with the number of transfers for men at a new all-time high and an…
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We can understand data dependences by being more explicit about the action specified by an instruction. The action specified by an instruction is clearer if we describe instructions in terms of values rather than registers. We need to name the values in a way that captures changes in register contents over time.
We can capture the intent of a sequence of instructions by replacing register names in all operands with value names. To do this, we use a table that records the value names assigned to each register name. Then we apply the following algorithm.
Replace each source operand by the most recent value name in the designated register column.
Replace the destination operand by a new name and place the new name in the designated register column.
It is important that step 1 is done first. Otherwise, when the same register is used both as a source operand and a destination operand we are indicating that the instruction execution phase cannot begin until its result is ready. This makes it impossible for the execution phase to begin.
We will start with the following instructions.
It can be verified that we have correctly renamed these instructions but first we add the following instruction and examine the renaming process in detail.
First replace $f2 by the most recent value name in the $f2 column. The table below shows the renamed operand in light blue. The values that it depends on are shown in light green.
sub.d $f2, $f2, $f6 sub.d ??, V1, ??
Then replace $f6 by the most recent value name in the $f6 column.
Replace the $f2 destination operand by a new value name V7 and also put V7 into the column for $f2.
Note that the instructions with value names capture the intent of a sequence of instructions by specifying relationships between register values, rather than just registers. This simplifies determining when the execution of an instruction can begin. We only need to check if its source operand values have been computed. The name dependences no longer complicate the picture.
To determine when source operands have been computed, the value registers contain a status bit in addition to a data value. The status bit is initialized to 0 (not ready) when the value register is allocated for an instruction. It is set to 1 when a functional unit writes a result.
An instruction goes through 6 stages in its execution. Each stage can take more than one cycle, but recent processors have reduced the number of cycles per stage in order to reduce power consumption by pipeline registers.
The instruction is fetched from memory or an instruction cache.
The instruction waits, if necessary, in a reservation station until its source operands have valid status and a suitable functional unit is available.
When all source operands are ready and a suitable functional unit is available then execution begins. Different operations can have different latencies; that is, different elapsed times for their execution phase.
When the assigned functional unit completes its execution, it writes the destination operand value to the designated value register.
The value register that was previously assigned to the instruction's destination architectural register can be freed for reuse by another instruction.
The instruction is fetched from memory or an instruction cache and the program counter is incremented.
When the instruction is issued it is assigned a value register number, which identifies the instruction and is used as a destination value name. Source operands architectural register numbers are also translated to value names. Issue circuitry forms a recoded instruction which contains a code for the operation and value names for each operand.
From the time they are issued until the time they are committed, instructions are considered to be "in flight". The destination value registers for in flight instructions are linked together in issue order to form an "in flight" list in the values circuitry.
If both source operands in the recoded instruction have "ready" status, and a functional unit is available to perform the operation, then the recoded instruction can be sent immediately to the functional unit. Otherwise, it is assigned to a reservation slot to wait for source operands to become available and/or for a suitable functional unit to become available.
When all source operands are ready and a suitable functional unit is available then execution begins. The functional unit receives an operation code and the destination value name from a reservation station slot. The source operands can either be retrieved by the reservation station or by the functional unit, depending on the implementation.
The destination operand value and its name are sent to the appropriate register in the values circuitry. The status bit for the named value register is updated to indicate that the value is ready.
If register forwarding is implemented the value and value name are also sent to reservation stations. A reservation station that is waiting for that value name can then capture the value. If other source operands are ready and a functional unit is available it instruction can start execution at the beginning of the next cycle. This is one cycle earlier than waiting for the value register to have a valid value.
its destination value register has "ready" status.
At that time, the value register that was previously assigned to the instruction's destination architectural register can be freed for reuse by another instruction.
The following block diagram and block descriptions are one of several possible implementations of register renaming. The description is not intended to represent how any particular processor implements register renaming. It is mainly intended to make implementation believable. For more information about design options see [Sima00].
Instruction fetch circuitry - fetches instructions from memory or an instruction cache.
Issue circuitry - renames instructions.
Reservation circuitry - holds renamed instructions until they are ready to be executed.
Execution circuitry - performs operations required for instructions.
Values circuitry - manages a numbered set of value registers. The register numbers are used by issue circuitry for renaming operands.
In the literature the value registers are usually called rename registers.
Commit circuitry - frees value registers that are no longer needed.
Instruction fetch circuitry fetches instructions from memory or an instruction cache, incrementing the program counter after each fetch. Instruction fetch circuitry often also has a branch history table for predicting whether or not conditional branches will be taken and a branch target buffer for quick lookup of branch targets.
Issue circuitry renames instruction operands, sending the recoded instruction to the reservation stations. It uses an issue table - a small set of registers, one for each architectural register. This table is essentially hardware for the register columns in the earlier textual renaming tables. The values in the table are value register numbers obtained from the values circuitry.
In some variants of the renaming architecture, issue circuitry may also fetch source values if they are available.
Reservation circuitry holds recoded instructions until they are ready to be executed. An instruction is ready when all of its source operands are valid and there is a suitable free functional unit to perform the operation.
Execution circuitry performs operations required for instructions. Execution circuitry is usually grouped into functional units, each performing a group of operations that involve shared circuity. Most processors, for example, use a load-store functional unit for all memory load and store instructions. For high performance, the functional units are often pipelined to permit starting the execution phase of a new instruction every cycle.
Values circuitry manages a numbered set of value registers. The register numbers are used by issue circuitry for renaming operands. In addition to its value, a value register has a status bit that indicates whether or not its value is valid, a link field for building lists, and a field indicating which architectural register it represents.
Values circuitry uses the link field to build to the following lists.
The free list links together the value registers that are available for assigning to new instruction destination operands.
The in-flight list links together the value registers that have been assigned to instruction destination operands, but not yet committed.
One or (rarely) more speculative execution lists link together the value registers that have been assigned to destination operands for instructions that have been issued speculatively.
Values circuitry also has small registers for keeping track of the start and end of these lists. The start of the free list is a value register number that can be passed to the issue circuitry for naming new values. The start of the in-flight list is the register number for the value register that is to be committed next. When necessary, value registers can be added to the end of these lists.
Commit circuitry frees value registers that are no longer needed. A value register is no longer needed when its architectural register gets assigned a new value. Commit circuitry can be considered a part of the values circuitry since it has access to the free and in-flight lists. In addition, commit circuitry maintains a commit table that maps architectural registers to the value registers that contain their most recently committed values. This table is similar to the issue table in the issue circuitry.
Commit circuitry works with the value register at the head of the in-flight list. The "architectural register" field of that register is used to select an entry from the commit table. This entry specifies the number of the value register that was committed earlier to the architectural register. That value is no longer needed so its register is moved into the free list. Meanwhile the value register at the head head of the in-flight list is removed from the in-flight list and its value register number replaces the old entry in the commit table.
The operation of commit circuitry can be improved by maintaining separate lists for each architectural register. That allows multiple instructions to be committed per cycle. However, it only works correctly if reservation stations capture source operand values as soon as they are ready. The importance of multiple commits per cycle is brought out in Register Renaming Performance.
Modern processors that have a renaming architecture have an organization similar to that described in the previous sections. There are some important changes for improving performance.
Speculative execution involves predicting whether or not conditional branches will be taken and speculative issue of either the instruction at the branch target or the instruction following the branch, depending on the prediction. With speculative execution CPI can be reduced to nearly 1.0.
Speculative execution requires adding circuitry to the instruction fetch circuitry for keeping track of past history of branches. Usually a cache for recent target addresses is added to reduce the time spent on computing branch target addresses. Speculative execution also requires small modifications elsewhere to allow cancellation of instructions that were issued as a result of incorrect predictions.
Super-scalar execution involves issuing multiple instructions in each cycle. For the most part, this uses the same basic architectural components, with widening of paths from the instruction cache to support more instruction fetches and some addition to the issue circuitry to support parallel issue. Modern processors are currently capable of a CPI of issuing in batches of 4 or 5 instructions each cycle. It is difficult to increase the size of an issue batch beyond this point due to the inherent sequential nature of renaming.
Processors usually cannot issue a full batch of instructions on all cycles. Most implementations will not make any attempt to include instructions after a branch in the same issue batch. Instead, the instructions after the branch are issued the following cycle. This results in an average number of issues per cycle of about 2.5, giving a CPI of about 0.4.
Modern operating systems support time sharing between multiple threads, increasing the utilization of the processor. For example, a web server will typically have one thread that just listens for new connection requests. After establishing a connection, that thread passes it to a worker thread. Each worker thread handles only one connection at a time. If one of the worker threads is blocked, for example waiting for information from the file system, other threads can get time on the processor.
Recent processors have added hardware support for multiple threads. The most important hardware change is replication of the issue table - each hardware thread needs it own table. Any hardware fields that record architectural register numbers also have to be expanded to allow including a thread identifier.
Multi-threaded execution can be used to simplify and improve handling of branches. Suppose you had a processor that could issue 4 instructions per cycle and supported 6 threads. Then it has only 4 of the threads active at a time. If a branch instruction is fetched for one of the threads it can be issued, but then the thread made inactive until the branch condition is resolved. That allows the processor to keep issuing 4 instructions per cycle except when at least 3 threads are inactive due to branches.
It is not clear how useful this idea is. Currently, processor implementation is up against a power wall. Increasing the amount of work that gets done per cycle just increases the power consumption and the heat that results.
The first renaming architecture was used for floating point instructions in late high performance models of the IBM 360 family of of computers [Tomasulo]. At that time it was not called register renaming. Tomasulo's architecture did not have value registers. Instead it used reservation station numbers for naming values. Each reservation slot had space for two source operand values. The reservation stations had circuitry to update the source operands when functional units produced result values.
The term "register renaming" was used by compiler writers for a technique that they used for code optimization. The term was later adopted by computer engineers.
Register renaming was used in many processors starting in the mid 1990s. Today it is used in almost every desktop and server processor.


It is very important to learn more about roof repair toronto if you need to have some repairs done to your home. Keep reading to see all of the options available when it comes to roofing companies toronto. You may learn some information about roof repair toronto that will save you money and time.
You shouldn't ever try to fix your roof if it's rainy out, snowing, or if there's ice around. If the roof is slippery or wet, you may fall, resulting in a potentially major injury or even death. If you are doing your roof yourself, work on it when it is sunny and dry outside.
TIP! Do not try to repair a roof if it's raining, snowing or icy outside. If your roof is slippery, you'll likely fall and sustain an injury.
Wear rubber boots when you climb onto your roof. This will help you to keep your balance to stay safe. Any sort of roof repairs are going to put you in a dangerous situation.
You need to consider the climate when choosing a roof type. When you live in a dry climate, go for clay tile. But, clay shouldn't be used in an area that gets a lot of rain. Clay deteriorates quicker then. If you are unsure, you can always ask.
TIP! When considering the materials for your roof, consider the climate in which you live. For instance, certain roofing materials, like clay, are better in cool climates.
Trim your grass prior to the arrival of your contractor. This helps keep debris and falling nails in order. If you get a contractor that has a nail finder with magnets on it, it will work better in shorter grasses.
Mow your lawn before the contractor comes to remove your roof. This can help them easily find any nails they drop, making things easier on both of you. Your contractor may have a nail finder, which works well in tandem with short blades of grass.
TIP! Mow your lawn the day before your roof is replaced. This will ensure he can find any dropped nails easily.
Don't hesitate to interrogate a would-be contractor before signing anything. One inquiry should be about how many nails the roofer will place into every shingle. Generally, three nails are not enough. Question them about their methods and see if you get a satisfactory answer. If not, then find a better contractor option.
When you find a contractor, make sure they are covered by liability insurance. If they have this kind of insurance, it is a good bet they are reliable. Secondly, should something happen to your roof as they are working on it, their insurance will pay for any problems.
TIP! Make sure that your roofer has liability insurance. The mere existence of such a policy bodes well for a contractor's reliability.
Co-workers, friends, and family should be the first resources for picking a contractor. Ask people you know if they were pleased with the work done, the quality of the materials and whether the cost was fair. Ask as many questions as you can to get the best possible repair for your money.
If you have a leaking roof, but the roofing contractor you contacted can't get there for a couple days, you might want to try a temporary fix. Get yourself a piece of heavy plastic and you can nail that over the leaking area. While not ideal, it will provide a temporary solution for you.
TIP! If you have an appointment with a roofer, but he or she is not coming for a couple of days, have a temporary solution in place. Try buying heavy duty plastic and layering it over the area.
Saving a little time and money in the short-term will set you up for more costly repairs in the future. This might seem like a cheap alternative but more damage could occur, costing you lots of money in the long run. The smartest thing to do is to completely fix the problem as quickly as possible to prevent things from getting worse.
Do not make changes to your roof that are not long-term. You may feel like you're saving money, but over time, the problem is only going to get worse, and will cost a lot more to fix. It is in your best interest to address any problem as soon as you can. Cutting corners or delaying the work will almost always end badly.
TIP! Don't use band-aid solutions. You may think you are saving money, but in the long run you could end up spending a lot more due to major damage.
Make sure the roofing toronto contractor you hire is trained and skilled. Look into who knows them – even ask your family and friends for their opinions. Referrals can help you avoid getting an inferior roof installed, along with the cost and frustration of correcting the mistakes.
A roofer who works on their own can wind up costing you more money than someone with a team of workers. A team will usually finish the project faster, thus reducing the final overall cost. If you are hiring a single roofer, be sure that you aren't overcharged for labor.
TIP! Contractors who have their own workers are often a more inexpensive option than those who work alone. The more people working on the roof, the quicker the job can be completed.
Selecting a contractor with additional workers may be your best and cheapest option. A team can work quicker and the price may be more affordable, too. If you have one doing it alone, be sure they're not overcharging for labor.
Identifying the cause of leaks is frustrating but totally doable. You'll find it if you employ a process of elimination along with a buddy system and a water hose. As you do the testing of different areas, use your cellular phone to talk with your buddy if need be.
TIP! Do not get upset if you cannot find sources of leaks in your roof. You will eventually find the source of the leak, by eliminating certain areas, using a hose, and having someone else look at it, as well.
Discuss warranty options with any potential contractor. This is an area where benefits may really vary, so do your homework. Ensure the warranty is given in writing along with your cost estimate. This way there won't be a disagreement later on.
Ask prospective roofing contractors how long their company has been in business. If the company has been in business for quite some time then they probably are able to keep people happy. A roofer who is just breaking into the industry may not be reliable or trustworthy.
TIP! Ask the roofing contractor how long they've been roofing. A company with a long and established reputation for high quality customer service is often your best bet.
If you wish to install a brand new, environmentally-friendly roof, don't overlook using a living roof. This type of roof has soil and plants, just like a garden. You can only do this on flat roofs, but it's great insulation.
If you think your roof might have a leak, try using a garden hose to spray it down. This will let you know if you have a leak and where the leak is. It doesn't cost as much as hiring a professional, so give it a try.
TIP! Use your hose to spray a leaky roof. You'll then see if a leak is there, plus the exact locale so that you can get it fixed.
When hiring a contractor, only hire someone who provides a copy of their license and insurance. If they're not able to do this, then they should not be hired no matter what. If they do poor work that can cause costly damages to your house, you have no recourse.
TIP! When hiring a contractor, only hire someone who provides a copy of their license and insurance. If they can't then look elsewhere.
Speak with your contractor to determine his associations within the industry. The good contractors are going to be involved in these groups so that they keep up with all the latest trends and current information. If they don't happen to be members, then you may just begin to wonder if they are truly dedicated to their chosen field.
Don't forget the little things when hiring a contractor. Do they call you back promptly? Do they show up on time? Your contractor should also provide you with typed estimate for the repairs needed. Your roofer should hold both qualities.
TIP! Don't forget the little things when hiring a contractor. Those who show up on schedule and call you as promised are probably fairly reliable.
Roof maintenance is important and if you do not want to do it yourself, you may be able to hire a roofer to do it. Even a good roofing mississauga job will need some further care, especially in extreme weather conditions. Having a visit once a year can help you maintain your roof.
Always check the condition of roofing materials before they go on your house. Often times, shingles can crack once they've been nailed down and if unnoticed, could be costly down the road. Be certain your materials are intact at all stages of the work.
TIP! Whether you are having a new roof installed or having repairs done, make sure you inspect all materials being used. Often times, shingles can crack once they've been nailed down and if unnoticed, could be costly down the road.
It's dangerous to climb on a roof. Most roof designs are not ideal for the human body; therefore, you need to ensure you stay safe when on your roof. Make sure to wear shoes with rubber soles to prevent slipping. If you can, consider wearing a harness. Last, but not least, have someone with you.
It is dangerous to climb on the roof. A roof is designed to repel the elements, not for being conducive to human beings. Shoes with rubber soles need to be worn so that you don't slip. In addition, use a harness if possible. Lastly, make sure you have a relative or friend helping you.
TIP! There is no doubt that getting on your roof can prove dangerous. Most roofs are not designed to accommodate humans, so it is important that you do your best to stay safe.
This article was easy to read, and informative too! Keep them in mind while making decisions about your roof. They can help you make wise choices. When it comes to the roof over your head, only the best will do.
If a contract isn't in writing, then you shouldn't agree to it. A lot of times when a person has a verbal contract with a roofer they will find that issues occur when the work isn't done right. Getting a contract in writing is the best way to prove that things didn't go according to plan if something were to go wrong.
TIP! Don't agree to contracts that aren't written down. In many cases, folks get into verbal agreements with roofers, only to have problems down the road.
Many people are on the search for info on roof repair toronto. Now you should see that you are armed with all the information you need to be successful. You may feel a little awkward at first, but don't worry. It's natural, and it won't be long before you get the hang of everything.


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Q: BigQuery ASCII 0 Error even with ASCII only characters I am trying to load a pandas dataframe to a bigquery table , but I get the ASCII 0 error. I know for a fact, the text only contains ascii characters, and the issue is with only one column only (unclear which row, however). I have tried the following:

*

*pandas dataframe from API call to BQ table results in  ASCII 0 error

*saved dataframe as a csv in google cloud storage (from API call), upload manually to BQ table results in ASCII 0 error

*download csv from google cloud storage onto local drive, upload manually to BQ table results in ASCII 0 error

*BUT if i take the file in step 3, resave the file, and then upload manually to BQ table, it uploads without issue

I am unsure why step 4 would work and not the others. The data frame only contains two columns, so it is not a matter of other columns that may contain non-ascii characters. I have narrowed it down to the culprit column.
Error:
0it [00:00, ?it/s]Traceback (most recent call last):
  File "/opt/conda/default/lib/python3.7/site-packages/pandas_gbq/gbq.py", line 629, in load_data
    for remaining_rows in chunks:
  File "/opt/conda/default/lib/python3.7/site-packages/tqdm/std.py", line 1081, in __iter__
    for obj in iterable:
  File "/opt/conda/default/lib/python3.7/site-packages/pandas_gbq/load.py", line 82, in load_chunks
    location=location,
  File "/opt/conda/default/lib/python3.7/site-packages/google/cloud/bigquery/job.py", line 734, in result
    return super(_AsyncJob, self).result(timeout=timeout)
  File "/opt/conda/default/lib/python3.7/site-packages/google/api_core/future/polling.py", line 134, in result
    raise self._exception
google.api_core.exceptions.BadRequest: 400 Error while reading data, error message: Error detected while parsing row starting at position: 39540. Error: Bad character (ASCII 0) encountered.

During handling of the above exception, another exception occurred:

Traceback (most recent call last):
  File "/tmp/document_download_20201223_dd87eec0/wd_download.py", line 268, in <module>
    obj.clean_data()
  File "/tmp/document_download_20201223_dd87eec0/wd_download.py", line 248, in clean_data
    self.res_df.to_gbq(datatable,project_id,if_exists='replace')
  File "/opt/conda/default/lib/python3.7/site-packages/pandas/core/frame.py", line 1657, in to_gbq
    credentials=credentials,
  File "/opt/conda/default/lib/python3.7/site-packages/pandas/io/gbq.py", line 228, in to_gbq
    private_key=private_key,
  File "/opt/conda/default/lib/python3.7/site-packages/pandas_gbq/gbq.py", line 1210, in to_gbq
    progress_bar=progress_bar,
  File "/opt/conda/default/lib/python3.7/site-packages/pandas_gbq/gbq.py", line 636, in load_data
    self.process_http_error(ex)
  File "/opt/conda/default/lib/python3.7/site-packages/pandas_gbq/gbq.py", line 435, in process_http_error
    raise GenericGBQException("Reason: {0}".format(ex))
pandas_gbq.gbq.GenericGBQException: Reason: 400 Error while reading data, error message: Error detected while parsing row starting at position: 39540. Error: Bad character (ASCII 0) encountered.

0it [00:02, ?it/s]
Job output is complete

Code for method 1:
self.res_df['clean'] = self.res_df['clean'].apply(lambda x: re.sub(r'[^\x00-\x7f]',r'',x))
self.res_df['clean'] = self.res_df['clean'].apply(lambda x: bytes(x, 'utf-8').decode('utf-8', 'ignore'))
self.res_df.to_gbq(datatable,project_id,if_exists='replace')

redpajama_set_name: RedPajamaStackExchange


text:
Huckleberry finn book annotations for into the wild
A short summary of mark twains the adventures of huckleberry finn. Twain becomes a skilled storyteller, turning out a new book every few years. Adventures of huckleberry finn summary in under five minutes. Huck finn moves in with the widow douglas, who has agreed to care for him. Mark twains the adventures of huckleberry finn is based on the truly american concept of individual freedom. Huckleberry finn begins where things left off after the adventures of tom sawyer. A summary of chapters 710 in mark twains the adventures of huckleberry finn. New challenging vocabulary 3 minimum per chapter thematic threads. Learn exactly what happened in this chapter, scene, or section of the adventures of huckleberry finn and what it means. Throughout the book, twain shows huck in positions where he has to make moral choices between what he believes in and what society thinks is right. Some very pc authors and editors took it upon themselves to change the n word to robot.
The strong point of view, skillful depiction of dialects, and confrontation of issues of race and prejudice have inspired critics to dub it the great american novel. One morning, while canoeing through a creek in search of berries, huck encounters two men running, pleading with huck to let them on his canoe, begging for their lives. Comparison of huck finn and chris mccandless teen ink. At the end of the previous novel, huck and tom find a treasure of twelve thousand dollars, which they divide.
Read chapter 33 of the adventures of huckleberry finn by mark twain. Read chapter 36 of the adventures of huckleberry finn by mark twain. The adventures of huckleberry finn context course hero. A sumptuous annotated edition of the great american novel. Chapter 15 the adventures of huckleberry finn mark. Check out our revolutionary sidebyside summary and analysis. Readers meet huck finn after hes been taken in by widow douglas and her sister. The adventures of huckleberry finn chapter 7 summary. You may purchase your own copy and write directly in the book, or you may borrow a copy from the school and use postits to document your.
Free online summary book notes for huckleberry finn by mark. The adventures of huckleberry finn by mark twain the adventures of huckleberry finn at a glance. Nevertheless, from the beginning the adventures of huckleberry finn was also recognized as a book that would revolutionize american literature. Critical essays themes of into the wild study guide. Though into the wild is a nonfiction book that is, a true story, jon krakauers choice to start it in this fashion encourages the reader to connect christopher mccandlesss journey with that of the fictional character odysseus as well as other characters, like aeneas and the protagonist of dantes divine comedy, who resemble odysseus.
These include mark twains creation huckleberry finn, ishmael from herman. The king learns the lines for juliet and practices swordfighting with the duke in order to perform part of richard iii. Huckleberry finn, by mark twain, complete project gutenberg. Huckleberry finn, by mark twain, complete the project gutenberg ebook of adventures of huckleberry finn, complete by mark twain samuel clemens this ebook is for the use of anyone anywhere at no cost and with almost no restrictions whatsoever.
In chapter 14, paragraphs 16 to 24, twain is able to satirize a few things and with that is also able to establish a new motif for the book as a whole. The adventures of huckleberry finn might join if i would go back to the widow and be respectable. The adventures of tom sawyer and adventures of huckleberry. I had been to school most all the time and could spell and read and write just a little, and could say the multiplication table up to six times seven is thirtyfive, and i dont reckon i could ever get.
Mobydick by herman melville,the adventures of huckleberry finn by mark. Detailed explanations, analysis, and citation info for every important quote on. This book is written in a first person point of viewhuck is known from toms story, the adventures of tom sawyer huck and tom found 6000 dollars, which is a lot of money in this era miss watson is very nice to have taken huck in. The project gutenberg ebook of adventures of huckleberry finn, complete by mark twain samuel clemens this ebook is for the use of anyone anywhere at no cost and with almost no restrictions whatsoever. Now, michael patrick hearn, author of the bestselling the annotated. The purpose of the novel was to provide a popular critique of the society in. Get free homework help on mark twains adventures of huckleberry finn. Just as they do, one of the three men pokes his head out of a door mere feet away from huck. I found huckleberry finn on my bookshelf had been changed to huckleberry finn robotic edition. Chapter thirtythree so i started for town, in the wagon, and when i was halfway i see a wagon coming, and sure enough it was tom sawyer, and i stopped and waited till he come along. People in the time of the gilded age would read this book and sometimes even burn his books.
Using postit notes, annotate your book as you read. The adventures of huckleberry finn chapter 12 summary. Use cliffsnotes the adventures of huckleberry finn study guide today to ace your next test. You may copy it, give it away or reuse it under the terms of the project gutenberg license included with this ebook or online at. The widow she cried over me, and called me a poor lost lamb, and she called me a lot of other names, too, but she never meant no harm by it. The adventures of huckleberry finn begins with a summary of the end of the adventures of tom sawyer and what has transpired since then. The money is put into a trust, and they receive a dollar a day. The annotated huckleberry finn is a landmark edition of an american classic that will further insure twains importance for generations to come. To get away from his violent, drunken father, huckleberry finn fakes his own death and lives wild. This study guide consists of approximately 71 pages of chapter summaries, quotes, character analysis, themes, and more everything you need to sharpen your knowledge of the adventures of huckleberry finn.
She tries to civilize huck in many different ways, including giving him new, clean clothes, teaching him about the bible and god, and trying to educate him. Well, pretty soon the old man was up and around again, and then he went for judge. We cleared everything out of the way, about four or five foot along the middle of the. Need help with chapter 8 in mark twains adventures of huckleberry finn. She put me in them new clothes again, and i couldnt do nothing but sweat and sweat, and. On february 18, 1885, mark twain publishes his famousand famously controversialnovel the adventures of huckleberry finn. The adventures of huckleberry finn focuses on huck and jims journey down the mississippi river. Hearn, who edited the wizard of oz for nortons annotated series, has taken on that formative fiction of american culture, huckleberry finna seemingly transparent work that, as presented in. The adventures of tom sawyer and adventures of huckleberry finn.
The adventures of huckleberry finn is published history. The adventures of huckleberry finn chapter 33 summary. He has been brought up with only natural learning, such as how to survive in the wild. The shores of the mississippi river provide the backdrop for the entire book. Adventures of huckleberry finn, free pdf, ebook global grey. The adventures of huckleberry finn chapter 1 summary. Now, however, huck is no longer scared of pap, and instead notes. Huck shoots a wild pig, butchers it inside the cabin, and spreads the. Adventures of huckleberry finn, also called the adventures of huckleberry finn, novel by mark twain, published in the united kingdom in 1884 and in the united states in 1885. The adventures of huckleberry finn is still banned in some areas to this day. Chapter summary for mark twains the adventures of huckleberry finn, chapter 7 summary. He teams up first with jim, a runaway slave and then later in the story, comes across the duke, the dauphin, the grangerfords and the wilks.
Huckleberry finn starts off his story by telling us that we may know him from a story by mark twain called the adventures of tom sawyer. Into the wild claims to tell the story of chris mccandless greatest adventure and tragic end in the back woods of alaska, but often focuses on krakauers connection with mccandless rather than the subject itself. On his way to town, huck spots the real tom sawyer who, at first, thinks that huck is a ghost. In the wild, huck and jim need to do whatever they can to survive, but superstitions sometimes get. Analysis of the book the adventures of huckleberry finn 1648 words 7 pages. Tom and me found the money that the robbers hid in the cave, and it made us rich. Judge thatcher takes their money and invests it in the bank at six percent interest, so that each boy earns a dollar a day on their money. Chapter thirtysix as soon as we reckoned everybody was asleep, that night, we went down the lightningrod, and shut ourselves up in the leanto, and got out our pile of foxfire, and went to work. Synopsis all modern american literature comes from one book by mark twain called, ernest hemingway once declared. See, huck finn came into a bit of money at the end of tom sawyer, and now hes supposed to stop being a street urchin and start learning to be a gentleman. He catched me a couple of times and thrashed me, but i went to school just the same.
The adventures of huckleberry finn chapter 1 to chapter 5. They then rewrote the book to take away any mention of humans and to roboticise words such as eye which becomes something like optical device. So i got all my traps into my canoe again so as to have them out of sight, and i put out the fire and scattered the ashes around to look. Perfect for acing essays, tests, and quizzes, as well as for writing lesson plans.
Ruddy ap lang 3 september 2015 the value in the adventures of huckleberry finn the adventures of huckleberry finn, written by mark twain, developed into one of the most controversial books in america. In the adventures of huckleberry finn, written by the famous 19th century american novelist and essayist mark twain, we spend time with huck and jim, who are both in search. Adventures of huckleberry finn summary when we meet our narrator huck finn, hes in missouri getting sivilized civilized by two sisters, an unnamed widow and a woman named miss watson. I hope that it will help them to remember pleasantly. However, he sticks it out at the bequest of tom sawyer, who tells him that in order to. He then covers up the hole he cut in the wall and shoots a wild pig outside. Analysis of the book the adventures of huckleberry finn. It is a dreamlike summertime world of hooky and adventure, pranks and punishment, villains and first love, filled with memorable characters. The book was originally scheduled for release in december 1884, but problems with printing and illustrations delayed the u. Mark twain was an american writer born in florida, missouri in 1835. Kemble illustrations from the first edition, as well as countless archival photographs and drawings, some of them previously unpublished, the annotated huckleberry finn is a book no familys library can do without. Read adventures of huckleberry finn by author mark twain, free, online.
First published in 1885, the book has delighted millions of readers, while simultaneously riling contemporary sensibilities, and is still banned in many schools and libraries. The adventures of huckleberry finn is a sequel to his popular novel the adventures of tom sawyer, which features huck as a. Twain publishes thegildedageabout the years following the civil war. The adventures of huckleberry finn by mark twain cliffsnotes. The first american edition of the adventures of huckleberry finn was published in 1885 by new yorks charles l.
Huck and tom sawyer had become rich from all of the treasure they discovered and the widow douglas has adopted huck. Litcharts assigns a color and icon to each theme in adventures of huckleberry finn, which you can use to track the themes throughout the work. Into the wild annotation guide while reading, annotation is one of the best ways to interact with the text on a deeper level. Adventures of huckleberry finn tom sawyers comrade mark twain, michael patrick hearn, e. Into the wild analysis project 350 points directions. The adventures of huckleberry finn by mark twain is an 1884 novel about a boy named huck living in the american south who escapes his abusive father and. Instant downloads of all 1291 litchart pdfs including adventures of huckleberry finn. The annotated huckleberry finn the annotated books. Specific to huckleberry finn i would be looking to annotate commentary about characterization, symbolism especially of the river vs.
Samuel langhorne clemens 18351910, best known to the world by his penname mark twain, was an author and humorist, noted for his novels the adventures of huckleberry finn 1884, which has been called the great american novel, and the adventures of tom sawyer 1876, among many others. What is a complete annotation of the adventures of. A summary of chapters 3235 in mark twains the adventures of huckleberry finn. Huck lives with the widow douglas, and her goal is to sivilize.
Chapter six well, pretty soon the old man was up and around again, and then he went for judge thatcher in the courts to make him give up that money, and he went for me, too, for not stopping school. In mark twains the adventures of huckleberry finn, twain uses satire to further exemplify the points he is trying to getting across to his readers. The adventures of huckleberry finn chapter 6 to chapter 10. My book is for boys and girls, but i hope that men and women. Huckleberry finn toms most well now, and got his bullet around his neck on a watchguard for a watch, and is always seeing what time it is, and so there aint nothing more to write about, and i am rotten glad of it, because if id a knowed what a trouble it was to make a book i wouldnt a tackled it, and aint agoing to no more. Detailed explanations, analysis, and citation info for every important quote on litcharts. Free monkeynotes study guide online book notes summary for. Get free homework help on jon krakauers into the wild. The adventures of huckleberry finn summary and analysis of chapter 6 to chapter 10. Mark twain the adventures of huckleberry finn chap. Unfortunately, without the text at hand, the duke must piece the.
It was an awful sight of money when it was piled up. All modern american literature comes from one book by mark twain called huckleberry finn, ernest hemingway once declared. Annotated bibliography the adventures of huckleberry finn. With this book, twain introduces something new to american fictiona simple, natural writing style that resembles the speech of average americans. Terrified, huck and jim search for the skiff the men used to reach the wreck, at long last finding it. The adventures of huckleberry finn study guide contains a. The adventures of huckleberry finn by mark twain is one of the most popular novels ever written and a classic of american literature. The adventures of huckleberry finn was written by mark twain in 1884. Many people did not like the fact that twain published a book like this in such a time period. This book is written in a first person point of viewhuck is known from toms story, the adventures of tom sawyer huck and tom found 6000 dollars, which is a lot of money in this era. The adventures of huckleberry finn chapter 14 summary. The story is set in precivil war days, though it was written two decades after the war ended. Huckleberry finn and the concept of freedom freebooksummary. Twain the pen name of samuel clemens first introduced huck finn as.
At the end of the previous novel, huck and tom find a treasure of. Read chapter 6 of the adventures of huckleberry finn by mark twain. The book s narrator is huckleberry finn, a youngster whose artless vernacular speech is admirably adapted to detailed and poetic descriptions of scenes, vivid. This tale is about a young boy named huckleberry finn who travels down the mississippi river with a runaway slave named jim. There was things which he stretched, but mainly he told the truth. Twains book tackles many societal issues including slavery, racism, and morality. Well, three or four months run along, and it was well into the winter now. Into the wild begins not with the birth of its main character, or even with the beginning of the journey that the book will trace, but with an important turning point late in christopher mccandlesss trip through the american west. Mark twains classic tale concerns young huckleberry finn who runs away from home.
The adventures of huckleberry finn by mark twain chapter 1. Mark twains classic tale of escape and adventure has been rivetingly retold for todays readers and is as fresh and exciting as when it was first published over a hundred years ago. The duke decides that a great encore would be for the king to perform hamlets soliloquy. The king and duke turn their attention to performing scenes from shakespeare. Tom hatches a wild plan to free jim, adding all sorts of unnecessary. The lot of towheads was troubles we was going to get into with quarrelsome people and all kinds of mean folks, but if we minded our business and didnt talk back and aggravate them, we would pull through and get out of the fog and into the big clear river, which was the free states, and wouldnt have no more trouble.
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When using the inhalers for the first time, maybe difficult. These packages generally come with instructions for use. If you are being prescribed this inhaler at a clinic or hospital, most nurses or doctors will instruct you in the correct use of the device.
The patient need to expel as much air from the lungs first; then place the mouthpiece of the inhaler in the mouth and close the mouth firmly around the mouthpiece. The canister is then depressed to expel the medication in the mouth; which comes out in mists. While this is being done, simultaneously the patient needs to inhale fully. For each dose to be effective, the patient needs to stop their breath for a few seconds to allow the medication to take effect.