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Franklin D.Roosevelt (1882-1945)
Who was the greatest ever American president? A good case could be made for Franklin Delano Roosevelt, who is undoubtedly one of the top three people to have held that office. In his first administration from 1933, he helped drag USA out of the Great Depression. He went on to became the only US president ever to serve for three terms. He brought America into the war against significant domestic opposition, and was instrumental in the final Allied victory. All this, from a man who had become paralysed as a result of polio, contracted in 1921. What a hero!
Born into a privileged old American family - President Theodore Roosevelt was a distant cousin - Roosevelt attended Harvard and became a lawyer. His marriage to Eleanor (a fifth cousin) produced six children, but ended up as an expedient political partnership rather than a loving relationship. The major factor in the breakdown was FDR's long standing affair with Lucy Mercer (codenamed "Mrs Johnson" by the Secret Service).
Roosevelt's career began in the New York Senate. After he supported Woodrow Wilson's bid for the Presidency, he was appointed Assistant Secretary to the Navy in 1913. His rise to power was not plain sailing: he failed in a bid to win election to the Senate in 1914, and was the vice-presidential candidate when James Cox were beaten by Warren Harding in the 1920 presidential election. However, in 1929, he was elected Governor of New York, and his career went from strength to strength.
FDR, however, had lost the use of his legs after contracting polio – or possibly another virus such as Guilllaume Barré - during a vacation in August 1921. He was 39. He did not accept that he was permanently disabled, trying a whole range of therapies, in particular swimming. He spent time at the Warm Springs resort, and subsequently bought the centre and turned it into a polio rehabilitation institute. Nor was FDR willing to be known as disabled. He judged, probably rightly, that the public would not be willing to accept a political leader who had a major impairment. So FDR made strenuous efforts, detailed in Hugh Gallagher's book FDR's Splendid Deception, to conceal the truth about his disability. For example, out of 35,000 photographs of FDR, only two show him in his wheelchair. Nor is there any newsreel footage, or even political cartoons depicting him as disabled. He did not use the wheelchair in public, nor even crutches. He wore callipers, lent on his aides, and laboriously swung his legs to make it appear that he was walking. His determination to conceal the truth, according to Gallagher, took a severe physical and emotional toll on him over the next twenty years.
However, FDR's relationship with disability was not simply about denial. He bought the Warm Springs resort and turned it into a polio rehabilitation centre. FDR built "the Little White House", an accessible holiday home in Warm Springs: he also drove a hand-controlled car. He loved to drive around his Georgia neighbourhood, meeting ordinary men and women. As a person, he was intuitive, not rationalist – no Thomas Jefferson – and had simple tastes, according to Gallagher, who argues that "His paralysis softened the handsome patrician, made him approachable, more human. His physical weakness was something people of every class could understand. At some level of consciousness, perhaps, FDR's paralysis served him a link with ordinary men and women." Famous for his dog, Fala, and his broadcast "Fireside chats", FDR was able to develop the common touch.
Roosevelt also set up the National Foundation for Infantile Paralysis and helped raise huge amounts of money, particularly with the development of the March of Dimes campaign from 1937. Among the beneficiaries of research funds was Jonas Salk, who went on to develop the polio vaccine.
It was the depths of the Depression – with 25% unemployment and a 50% fall in industrial output since 1929 - when in 1932, disabled FDR won the Democratic nomination and subsequently the Presidency of the United States. In his acceptance speech, he said "I pledge you, I pledge myself to a new deal for the American people... This is more than a political campaign. It is a call to arms." He had succeeded by bringing together trades unions, poor whites, Jews, Italians, Poles, African-Americans and Southerners together with the traditional Democrat supporters. As he famously said, in the middle of the banking crisis which heralded his inauguration, "All we have to fear is fear itself".
As President, Roosevelt was extraordinarily interventionist by American standards past and present. For example, he regulated the banks and other parts of the private sector, and used government money to pay the unemployed construct dams and buildings for the Public Works Administration. Vast government enterprises were created and gold was bought back from citizens by the US Treasury. FDR also repealed Prohibition. No wonder he was so easily re-elected for a second term, with unemployment having fallen from 25% to 14%, and the creation of Social Security payments – such as pensions – and Federal rights to belong to a union, to take strike action, and undertake collective bargaining. In his 1944 State of the Union address, FDR argued that economic rights were like a second Bill of Rights: by today's standards, he resembles a European social democrat, rather than any conventional American politician.
At the beginning of the war, FDR gave Britain moral and economic support, and began a covert correspondence with Winston Churchill. From 1940, he rapidly built up the US armed forces. First, 50 older destroyers were given to Britain, followed by the 1941 Lend Lease agreement, contributing $50 billion to the Allies, to be repaid after the war. He told the American people that he wanted USA to be the Arsenal for Democracy, using his charisma to counter the strong isolationist tendency in US politics. He was elected to a third term – against all previous tradition – promising to do all he could to keep USA out of the conflict.
After Pearl Harbor, war was unavoidable. FDR left the administration of the war to his generals. From 1943, he played the key diplomatic role, at the conferences with Churchill in Cairo, and with Churchill and Stalin in Tehran and finally Yalta. Although Stalin backed FDR's plan for the United Nations, FDR failed to understand his true ambitions to create Soviet-backed authoritarian regimes in Eastern Europe.
FDR's health had been in decline since 1940. Part of the problem was that he gave up his daily exercise routine during the war: he stopped standing up, and was wheeled around everywhere. After years of struggle, physical and political, he was also depressed and lonely. By 1944 he was very ill. Stress and smoking, added to his neurological problems, resulted in heart disease. Nevertheless, he was elected President for a fourth time, with Harry Truman as his Vice-President. On March 29, just before the founding conference of the United Nations, FDR died from a stroke.
Barely a month later came the declaration of Victory in Europe. As the New York Times wrote at the time: "Men will thank God on their knees a hundred years from now that Franklin D. Roosevelt was in the White House". But FDR should not be seen as a superhuman leader. He was an ordinary human being, struggling with a disability which perhaps taught him compassion and humility, who achieved remarkable things.
Hugh Gallagher, FDR's Splendid Deception, 1985.
Posted by Tom Shakespeare at 3:55 PM No comments:
Labels: American, physical impairment, politicians
Harriet Tubman (1820-1913)
Never having received appropriate recognition in life, after death, Harriet Tubman became an African American icon and a hero to later generations of Civil Rights activists. Her concrete achievements in war and peace, and her struggles on behalf of African Americans and women in particular, surely make her someone that disabled people can also call a role model.
Harriet Tubman was born a slave in Maryland, and was originally named Araminta Ross. Her grandmother, Modesty, had been brought from Africa – according to the family legend, she was of Ashanti origin, from what is modern day Ghana. Tubman's father managed the timber on a plantation; her mother was a cook. She herself was hired out as a nursemaid aged five or six, and was brutally whipped by her employers. As a teenager, she was in a store when a white man asked her to help restrain another slave. She refused, and when the slave ran away, the white man threw a two pound weight. The iron lump missed the other slave but hit Tubman in the head. She survived the resulting injury, but it caused her siezures and narcolepsy for the rest of her life. Perhaps as a result of the epilepsy, she became very deeply religious, and regularly thereafter had visions and premonitions.
In 1844, Tubman married a freed slave, John Tubman, and changed her name, although remaining enslaved. In 1849, when her owner died, she and her brothers escaped from slavery, only to return. Tubman then escaped again, using the Underground Railway network of abolitionists (including Quakers) to travel north, mainly by night. She later described her feelings on reaching Pennsylvania: "When I found I had crossed that line, I looked at my hands to see if I was the same person. There was such a glory over everything; the sun came like gold through the trees, and over the fields, and I felt like I was in Heaven."
Although she was safe in Philadelphia, she said "I was a stranger in a strange land," because her relatives were enslaved in Maryland, "But I was free, and they should be free." Tubman returned to Maryland to help members of her family escape slavery, then other African Americans, including eventually her own parents. In total, she made 13 expeditions, rescuing 70 slaves, and advising many more on how to make their escape. Often disguised, she became known as "Moses". On one trip, she was able to meet up with her husband, only to find that he had remarried and did not want to come North with her. She reflected later "I was conductor of the Underground Railroad for eight years, and I can say what most conductors can't say – I never ran my train off the track and I never lost a passenger."
Harriet Tubman was in touch with other abolitionists, such as John Brown, Thomas Garrett and William SewardIn 1859, Seward sold her land in Auburn, which became a haven for freed slaves and other African Americans.
Tubman was also in touch with African American activists, such as Frederick Douglass. In 1868, Douglass wrote to Tubman to honor her practical achievements and contrast it with his more public advocacy: "You, on the other hand, have labored in a private way. I have wrought in the day—you in the night. ... The midnight sky and the silent stars have been the witnesses of your devotion to freedom and of your heroism. Excepting John Brown—of sacred memory—I know of no one who has willingly encountered more perils and hardships to serve our enslaved people than you have."
For obvious reasons, Harriet Tubman was a strong supporter of the Union side during the Civil War, although she was frustrated by Abraham Lincoln's unwillingness to enforce emanacipation in conquered Confederate territory. She went to offer her support in Port Royal, South Carolina, serving as a nurse. More unusually, for the time, she also conducted reconnaissance missions for the Union forces, for example providing information which helped in the capture of Jacksonville, Florida. She became the first woman to lead an armed assault in the Civil War during the Combahee River Raid which led to the release of 700 slaves. Despite these efforts, she never received any acknowledgement or pension from the United States government for her service during the conflict.
After the war, Tubman returned to Auburn. More injustice followed when, on a trip to New York, she was roughly handled by a train guard and other white passengers, resulting in her arm being broken. Happily, she also ended up marrying a veteran, Nelson Davis, who was more than twenty years younger than her. They were together for twenty years and adopted a daughter together. But Tubman remained poor and struggled for money, particularly after falling victim to two fraudsters. In her later years, she was an active supporter of women's suffrage, and in the process of speaking and advocating, her own story became more widely known.
Harriet Tubman suffered increasing symptoms from her head injury in the last decades of her life, undergoing brain surgery to relieve her suffering. In 1903, she donated land to her church to open a home for poor African Americans. It was there that in 1913 she died of pneumonia, being buried with full military honours in Auburn. Booker T.Washington spoke at the inauguration of her memorial.
Labels: activists, American, head injury, military leaders, women
Winston Churchill (1874-1965)
"Only a man who knew what it was to discern a gleam of hope in a hopeless situation, whose courage was beyond reason, and whose aggressive spirit burned at its fiercest when he was hemmed in and surrounded by enemies, could have given emotional reality to the words of defiance which rallied and sustained us in the menacing summer of 1940" (Anthony Storr)
Winston Churchill was born prematurely and looked after by a wet-nurse, as was the aristocratic way in 1874. Throughout his childhood, he endured a continuing lack of unconditional love and affection from both his parents which, according to the psychiatrist Anthony Storr, left Churchill psychologically ill-equipped. His salvation was his nanny, Mrs Everest, on whose death he described as "my dearest and most intimate friend during the whole of the twenty years I had lived". However, it seems likely that Churchill also had an underlying genetic disposition towards depression which, interacting with inadequate parenting, resulted in his mental health vulnerabilities. Indeed, his great ancestor the Duke of Marlborough shared his depressive tendencies, as did his own father, Randolph Churchill.
As a child, Churchill was not very impressive: small, thin and with a slight speech impediment, he was bullied at school. In 1893, he wrote from Sandhurst "I am cursed with so feeble a body that I can scarcely support the fatigues of the day; but I suppose I shall get stronger during my stay here." However, he was determined to be tough, and had no lack of physical courage, having exerted willpower to overcome his fears. He was positively reckless in combat during the Boer War and the First World War.
Churchill was also hugely ambitious: writing from India in 1899, he said "What an awful thing it will be if I don't come off. It will break my heart for I have nothing else but ambition to cling to…" Storr suggests that he sought recognition as a way of staving off despair. As Churchill said later "We are all worms. But I do believe I am a glow worm". He had a strong sense that he was being kept for some higher purpose, the cause that finally presented itself when he was sixty-five and his country and the world was in such danger from fascism.
Churchill's energy and stamina are legendary. When Churchill came back into Government at the outbreak of World War Two, it was my grandfather, then Parliamentary Secretary to the Admiralty, who welcomed him as First Lord of the Admiralty and made the introductions to colleagues on Sunday 3 September 1939. In his memoirs, he wrote about the gruelling hours which Churchill kept:
"After a gruelling day's work Churchill became more light-hearted as midnight approached. He threw off fatigue like a garment and relaxed. I can see him now in my mind's eye dictating a speech, wearing an old pair of bedroom slippers and padding up and down his room like a caged lion, hands behind his back, head bent forward. A cigar always protruded from his mouth and through thick clouds of smoke he hissed scintillating sentences at the silent typewriter. He had no prepared notes; he had not even jotted down headlines on the order of his speech. All those distinguished phrases which characterise his speeches came out fashioned spontaneously in the furnace of his imagination...for two or three hours he dictated thus without a break. If he finished by two a.m. he was more wide awake than ever. We vainly suggested it was time for bed. He usually had other ideas. "What about a visit to the war room?" He loved looking at the flags denoting the position of our warships on the oceans of the world."
CP Snow described Churchill as having a strong sense of insight, or intuition, rather than relying on insight. This approach sometimes led him astray, as with the disastrous Dardenelles campaign in the First World War (in which my grandfather fought, and nearly died). But his instincts about Hitler and about Stalin eventually proved to be correct. His brilliance was not that of a thorough or rigorous thinker. Famously, he preferred to have ideas presented to him on half a side of paper, because that was how he himself worked. He could also be very insensitive to the feelings of others, such as the assistants who had to keep him company through the night, and who were not able to take an hour's sleep after lunch or before dinner, as he usually did.
Churchill's doctor, Lord Moran, records the Prime Minister in 1944, talking about his depressive tendencies: "I don't like standing near the edge of a platform when an express train is passing through. I like to stand right back and if possible to get a pillar between me and the train. I don't like to stand by the side of a ship and look down into the water. A second's action would end everything. A few drops of desperation." Yet after the Dardenelles, and in his wilderness years, he may have been deeply depressed, but he was not suicidal. He devised ways of keeping himself going – writing, painting, even bricklaying at his country house at Chartwell.
In his final years, Churchill suffered a recurrence of despair and a sense of his life having been futility, despite all he had achieved for himself and for his country. Hardening of the arteries and possibly Alzheimer's disease may have contributed. His daughter records him as saying late in life "I have achieved a great deal to achieve nothing in the end". Storr suggests that, as a result of a lack of parental affection, "he had a void at the heart of his being which no achievement or honour could ever completely fill".
I am not sure how much I like, as opposed to admire, Churchill. His achievements in diverse fields were extraordinary, even though he hardly deserved the Nobel Prize for Literature: I have an early memory of my grandfather reading to me out of his History of the English Speaking Peoples. Churchill started his career as a Liberal, but was more right wing than this might imply. He was a vigorous advocate of eugenics in the first decades of the twentieth century; he was a supporter of Edward VIII (and Mussolini, at the beginning); he opposed Indian Home Rule and should be assigned some of the blame for the Bengal famine of 1943; he was ultimately responsible for the saturation bombing of German cities in the first half of 1945; his post war term as Prime Minister was not distinguished. Yet despite this and other failures, he was a larger than life man, of ferocious appetites, powerful personality and immense inner drive. Small wonder that he topped a BBC Poll of "One Hundred Greatest Britons" in 2002: to many people, he was not only correct in describing the Second World War as "our finest hour", he was also the architect of Allied victory. With his recurrent depression, his speech impediment, not to mention the physical and mental decline of his last years, Winston Churchill can also be counted, unquestionably, as a person with disability.
Anthony Storr, Churchill's Black Dog
Labels: artists, British, mental impairment, military leaders, politicians, speech impediment, writers
Disability is part of the human condition. At any one time, perhaps 15% of the population have a disability: add illness and ageing and impairment comes to us all. In this blog, I want to share short biographies of famous and not-so-famous disabled people, and by doing so demonstrate the variety and the achievement of disabled lives. I hope it will be interesting and instructive, and welcome suggestions for future subjects.
"A fabulous, inspirational blog" (The Guardian)
Index of biographies
activists actors American amputation ancient Argentinian artists Austrian Belgian Brazilian British chronic disease composer craftsman deafness disfigurement dwarfism Egyptian epilepsy Finnish French German head injury hearing impairment Indian intellectual impairment Italian lawyers lupus medicine medieval mental impairment Mexican military leaders multiple sclerosis musician neuro-muscular impairment New Zealander physical impairment polio Polish politicians reflections Romani schizophrenia scientist scoliosis Scottish speech impediment sports player Swiss Syrian Tourette's syndrome tuberculosis visual impairment wheelchair women writers
Tom Shakespeare


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Home » People » Alex » "Renegade"
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Comparative Patent Remedies
A Blog Devoted to the Comparative Law and Economics of Patent Remedies
HTC v. Nokia: Would a Stay of a Permanent Injunction Pending Design-Around Be Permissible Under U.K. Law?
In HTC Corp. v. Nokia Corp., [2013] EWHC 3778 (Pat. Ct. Dec. 3, 2013), Justice Arnold of the Patents Court of England and Wales concluded that Nokia was entitled to an injunction for the infringement of European Patent (UK) No. 0 998 024. This case has already been discussed by Scott Parker in EPLaw Patent Blog, here, and by Florian Mueller on Foss Patents, here. For present purposes, I'll try not to be overly duplicative or exhaustive, but rather to focus on a few things in particular that struck my attention. The full decision, which I commend to readers' attention, is available here.
Justice Arnold recognized that, under applicable law, injunctions are discretionary. Two of the leading cases addressing the court's discretion are Shelfer v. City of London Lighting Co. Ltd., [1895] 1 WLR 287, and Jaggard v. Sawyer, [1995] 1 W.L.R. 269. (See also my book, pp. 179-82, and this blog post from June.) As Justice Arnold notes, in Shelfer the court stated that the plaintiff has a prima facie entitlement to an injunction, and that a "good working rule" is that "(1) If the injury to the plaintiff 's legal rights is small, (2) And is one which is capable of being estimated in money, (3) And is one which can be adequately compensated by a small money payment, (4) And the case is one in which it would be oppressive to the defendant to grant an injunction . . . then damages in substitution for an injunction may be given." Moreover, in Jaggard, Sir Thomas Bingham stated that "the test is one of oppression, and the court should not slide into application of a general balance of convenience test."
Justice Arnold also discusses other English case law (on injunctions for copyright infringement), articles 3(2) and 12 of the 2004 EC Enforcement Directive and TRIPs, before concluding in para. 32 that the effect of the practical effect of these latter two sources is little different from Justice Pumfrey's requirement, as stated that Navitaire Inc. v. EasyJet Airline CO. Ltd. (No. 2), [2005] EWHC 282 (Ch), [2006] RPC 4, that injunctive relief be granted unless, inter alia, it would be "oppressive" to the defendant in the sense of being "grossly disproportionate to the right protected."
Applying these standards here, the court noted that the patent has six years yet to run and is not standard-essential. Justice Arnold expressed some discomfort with the idea of in effect crafting a compulsory license with six years yet to run. See paras. 14 ("Should the defendant have a duty to account? Should the claimant have the right to inspect the defendant's books? What if the defendant becomes insolvent? Such questions can easily be multiplied. In the case of consensual patent licenses, these questions are generally addressed these days by licence agreements of considerable sophistication. Is the court to include similar terms in its order?"), 34 ("a difficult task in futurology"). One of the more interesting aspects of the opinion, however, is the court's discussion of noninfringing alternatives:
Counsel for HTC relied on the traditional analogy of a patented rivet (or sometimes it is a whistle) on a battleship. An injunction to restrain infringement of that patent by the battleship manufacturer (as opposed to the rivet supplier) would be disproportionate, he argued. But this depends on what the effect of the injunction actually is. If the battleship manufacturer has immediate access to a non-infringing alternative rivet, then the effect of the injunction on him will simply be the cost, if any, of switching from the patented rivet to the non-infringing one (both any one-off costs such as changing the production line and any ongoing cost differential in the component price). Of course, if the cost of switching from the patented rivet to a non-infringing rivet is prohibitive for some reason, then in practice the non-infringing rivet will not be a realistic alternative. Thus whether the injunction is disproportionate depends on the availability and cost of non-infringing alternatives. . . .
Non-infringing alternatives. As I have said an important consideration, and perhaps the single most important consideration, in assessing whether the grant of an injunction to restrain patent infringement would be disproportionate is the availability and cost of non-infringing alternatives.
The problem of "patent hold up" which has been much studied by economists generally arises either where there is no non-infringing alternative or where the cost of switching to the non-infringing alternative is prohibitive. The paradigm example of the former situation is the standard-essential patent. Because it is essential, there is no alternative for products which comply with the standard. That is why standards-setting organisations like ETSI (the European Telecommunications Standards Institute) require owners of standard-essential patents to undertake to grant licences on FRAND (fair, reasonable and non-discriminatory) terms. An example of the latter situation is where a manufacturer has invested a great deal of money in developing and marketing a complex product only to discover, to its surprise, that a vital component of the product infringes a patent, and by the time it discovers this it is too late to switch to a non-infringing alternative except at prohibitive cost. This was one reason why the former phenomenon of so-called "submarine" patents in the USA could be so dangerous.
If non-infringing alternatives are available at non-prohibitive cost, however, then there is unlikely to be a problem of patent hold up. Accordingly, other things being equal, an injunction is unlikely to be disproportionate.
The court concluded that, in the present case, a noninfringing alternative was available to HTC, and that it was "probable that, starting from scratch now, HTC could render all its phones non-infringing within 18 months." As a result, "Taking all of the factors relied on by the parties into account, and in particular the ones discussed above, I am not persuaded that this is a case in which I should exercise my discretion to award damages in lieu of an injunction. Nokia has a legitimate interest in seeking a final injunction to prevent further exploitation of the patented invention by HTC without its consent. This is not a case in which the injury to the patent is small, capable of being estimated in money and adequately compensated by a relatively small money payment. If an injunction were refused, it would have to be on the basis of an order for a running royalty. In those circumstances, refusal of an injunction would be tantamount to imposing a compulsory licence on Nokia in circumstances where HTC could not obtain a compulsory licence by the proper route. Most importantly, the grant of a final injunction would not be disproportionate. The grant of an injunction will not deliver HTC over to Nokia "bound hand and foot, in order to be made subject to any extortionate demand" Nokia may make, because HTC already has some non-infringing alternatives available to it, could have had more non-infringing alternatives available to it by now if it had acted promptly when first sued by Nokia and will in any event have more non-infringing alternatives available to it in a period which is significantly shorter than the remaining term of the Patent" (para. 74).
Nevertheless, the court decided to stay the injunction pending appeal with respect to one of HTC's phones, the "HTC One", but not with respect to other models, applying an approach set forth by Lord Justice Buckley in Minnesota Mining & Manufacturing Co. v. Johnson & Johnson Ltd. (No. 3), [1976] RPC 671. An appeal is expected to be heard in "July or October 2014." Shortly thereafter, as Florian Mueller reports, the appellate court stayed the order as to the HTC Mini as well..
Here's my question: Could the court instead have stayed the injunction for 18 months, the period it would take HTC to complete the design-around? That seems to me to be a more equitable resolution. It avoids requiring the court to craft a six-years-in-duration compulsory license, but at the same time protects HTC from holdup during the design-around period. Staying the matter pending appeal seems more arbitrary, in terms of duration. Lemley & Shapiro have argued in favor of this approach in Patent Holdup and Royalty Stacking, 85 Tex. L. Rev. 1991, 2035-39 (2007), and it seems to me that it would sometimes be a more sensible approach to the either/or solution of injunction or no-injunction. My question--and perhaps readers in the U.K. could enlighten me here--is this: Does a court in the U.K. have discretion to stay an injunction or otherwise delay its entry, other than for the pendency of an appeal? In other words, could Justice Arnold have stayed the injunction for 18 months, or is there something in the applicable U.K. law that would prohibit this?
I will be taking a break from blogging over the Christmas holidays, and will resume shortly after the 1st of the year. Happy holidays to my readers, and all the best in 2014.
Posted by Thomas Cotter at 4:26 AM 3 comments:
Labels: Injunctions, U.K.
Comments on Sidak, Part 4: Closing Thoughts (Cotter and Siebrasse)
Note: I thought I published this post on Friday, and was dismayed to discover today that it wasn't up. Sorry for the technical glitch!
Today, Professor Siebrasse and I offer some further comments to conclude this series on Gregory Sidak's recent article on FRAND.
Cotter: I could probably write several more posts on various aspects of Professor Sidak's paper, but to wrap matters up I'll focus on just one: the use of appropriate heuristics as a proxy for the ex ante incremental value of a patent.
As I mentioned in my previous post, I agree with Sidak—and have stated elsewhere—that it is often impractical to quantify ex ante incremental value (that is, the value that a user would expect to derive from the use of patent X in comparison with the next-best available noninfringing alternative). Litigation occurs months or years after the relevant date (typically the date on which infringement began, though in the SEP context the date just before the standard at issue was adopted is preferable). It may be difficult to determine what the next-best alternative was; what it would have cost to acquire it (and here I agree with Sidak that this should be a relevant consideration, and have so stated in previous work); what its expected net benefits would have been; and so on. Matters are only compounded if the value of the patent depends in large part on the adoption of other complementary technologies, as in the SEP context. Nevertheless, I think it is important to recognize the ex ante incremental value (or, in the present context, the "ex ante contingent incremental value," as discussed in the two previous posts) as the ideal starting point: it is the standard that renders neither the patentee nor the infringer any better or worse off than they would have been, but for the infringement. (Further modifications can then be made to provide for adequate deterrence or to satisfy other goals, if that is desirable.) Recognizing that it may be difficult or impossible to meet the ideal, one can then try to find alternative measures that might be reasonable substitutes. Here, the point is to use substitutes that come as close as we think we reasonably can to approximating ex ante contingent incremental value, and to avoid substitutes that would inflate FRAND (or reasonable) royalties to capture ex post value.
Oddly enough, then, I agree with much of what Sidak has to say about such substitute measures as comparable licenses (pages 1002-07) and (at pages 1011-14) Greg Leonard's "top-down" approach as employed in the Innovatio IP Ventures LLC litigation (which I blogged about here). I need to think more about Sidak's endorsement of "approved contributions" as a better way of estimating the value accruing to an individual SEP owner, over a methodology that applies Marc Shankerman's 1998 estimate that 10% of all electronics patents accounted for 84% of the value of all such patents. I understand his objections to the latter (the study is relatively old and doesn't involve SEPs), but I'm not sure I would sign off on the proposition that all of the patents contributed by a firm with a large number of approved contributions (e.g., Ericsson) should be classified as falling into the top 10%, rather than considering them individually (see p.1039). On the other hand, Sidak's critiques of some of the other possible approaches (e.g., Shapley values, reliance on patent pools that simply divide up royalties by counting patents rather than by estimating their strength) seem at first blush to be pretty sound.
Bottom line: while I disagree strongly with much of Sidak's theoretical analysis, I concur with a fair amount of his practical advice. Perhaps that puts me in company with Judge Robart, whom Sidak castigates time and again for assuming that the ex ante approach is theoretically correct—only to concede (at p.986) that Judge Robart also concluded that the ex ante approach "lack[s] . . . real-world applicability." At the end of the day, I still don't find a huge difference between what Judge Holderman (whom Sidak praises) and Judge Robart (whom he criticizes) were trying to do. Compare In re Innovation IP Ventures LLC Patent Litig., 2013 WL 5593609, at *4-8 (N.D. Ill. Oct. 3, 2013) (adopting Judge Robart's methodology, with modifications reflecting the differing postures of the two cases, i.e., breach of contract versus patent infringement), with Microsoft Corp. v. Motorola, Inc., 2013 WL 2111217, at *20 para. 113 (W.D. Wash Apr. 23, 2103) ("reasonable parties in search of a reasonable royalty rate under the RAND commitment would consider the fact that, to induce the creation of valuable standards, the RAND commitment must guarantee that holders of valuable intellectual property will receive reasonable royalties on that property").
Siebrasse: I also agree with much of what Sidak says about specific heuristics, but in this final comment I will look at one point where I disagree with Sidak, and perhaps also with Professor Cotter. The question is whether the cost of the next-best alternative should be taken into account in determining a reasonable royalty.
Sidak says (936):
to measure a licensee's willingness to pay for the patent accurately, the profit generated using A must be compared with the profit from using B, including the costs of acquiring the rights to technology B.
He provides the following example (937):
Suppose that, relative to using a non-patented alternative, the use of patent A leads to increased revenue of $300, patent B leads to increased revenue of $200, and patent C leads to increased revenue of $100 [but] the licensing cost of patent B is $150, whereas the licensing cost of patent C is only $25.
Sidak concludes that Patent C, not B, is the next-based alternative to A, because C is more profitable net of acquisition costs, and "[i]f one neglects to include the costs of acquiring the lawful rights to use the next-best alternative in the calculation of the incremental value, then the analysis could understate or overstate the prospective licensee's actual willingness to pay" (937-38).
But why is B asking $150? Suppose A does not exist, and the choice is between B and C. B asks $150, and the licensee (L) says no because C is more profitable net of the acquisition costs of B. But that means A walks away, and B gets $0. In principle, B would revise its offer downwards to incrementally less than $125, so that L would licence from B rather than C, making both L and B better off than if B licensed from C for $25. C would presumably respond by lowering its price, but in the end C would not be able to match B, and L would licence from B for $100. More fundamentally, the point of considering the non-infringing alternative is to capture the economic value of the patented invention, which is the economic value of the invention over the next best alternative. This requires ignoring the cost of licensing the alternative in determining which technology is the alternative.
Consequently, my view is that in principle the cost of acquiring the next-best alternative is irrelevant in assessing the patentee's willingness to pay. But what difference does this make to the reasonable royalty determination? As Sidak points out, it affects the licensee's maximum willingness to pay, which sets the upper bound on the bargaining range in the hypothetical negotiation. If the reasonable royalty determination turns on a mechanical split between the maximum willingness to pay and the minimum willingness to accept, as in a 50/50 split proposed as a Nash bargaining solution by some experts post-Uniloc, then whether the cost of the non-infringing alternative is included does directly impact the reasonable royalty. But a Nash bargaining solution is very artificial (and has been rejected for that reason by at least some courts). There is no particular reason, other than the lack of better evidence, for any particular split between the licensee's maximum willingness to pay and the licensor's minimum willingness to accept. It may be that on the facts, B charged $150 for transaction cost reasons, the costs of negotiating an individual royalty with L are greater than the benefits (if L is using only a small volume), so that in fact L's next-best alternative is to licence from C – and yet A has little bargaining power, so that in fact A would have ended up with a royalty of only $30, and L would have captured the vast majority of the incremental value of the patent. For example, perhaps it is clear that A routinely licensed to all comers for $30. That would be the reasonable royalty, regardless of L's theoretical maximum willingness to pay, and regardless of what a licence from B or C might have cost.
The larger point is that there is an important difference between principles, heuristics and facts. If we have little or no factual evidence, and must decide a reasonable royalty on the basis of principles alone, then my view is that the cost in fact of the next-best alternative should not be taken into account, because in principle, that cost might be bargained down. On the other hand, if we have a rich set of facts, then the principles become little more than a sanity check, and it probably doesn't matter whether or we take the cost of the non-infringing alternative into account.
Posted by Thomas Cotter at 5:12 AM No comments:
Labels: Damages, Damages Methodology, United States
Comments on Sidak, Part 3: Should a FRAND Royalty Be Higher than a Reasonable Royalty? (Cotter)
Is there a difference between a reasonable royalty and a FRAND royalty? Put another way, should a reasonable royalty awarded for the infringement of an SEP owned by a non-SSO member be different from a FRAND royalty awarded for the infringement of the same SEP if it were owned by an SSO member that had made a FRAND commitment?
At the outset, I'd like to thank Professor Norman Siebrasse for his two previous posts, which have set the stage for this question. My own views are largely in accord with Professor Siebrasse's, and therefore somewhat at odds with Professor Gregory Sidak's concerns, as expressed in his recent article, that the ex ante valuation framework threatens to undercompensate owners of standard essential patents (SEPs). Nevertheless, Professor Sidak's point about the interdependent value of SEPs is an important one that until now has not received adequate attention in the literature.
First, a brief recap of what I believe the correct approach to be, having read Sidak's paper and Siebrasse's initial comments on it. Suppose that an SSO is just about to decide which of two competing standards to adopt, X or Y. X will incorporate patents A, B, C, D, and E; Y will incorporate a different bundle of patents. The "ex ante incremental value" of A to Implementer Z is the expected incremental contribution of A to Z's use of Standard X (which might not get adopted at all). The "ex ante contingent incremental value" is the expected contribution of A to Z's use of standard X, on the assumption that standard X is adopted. Now let's assume the SSO does indeed adopt standard X. The more realistic ex ante state of the world is the one in which Z and the owner of patent A bargain to a license that is contingent on standard X actually being adopted. If so, then the theoretically correct FRAND royalty is the one based on ex ante contingent incremental value. This royalty allows the patentee to benefit from the fact that the patent has been incorporated into the standard, which is a necessary contingency for any royalty to be owing; but it is still an ex ante measure, not ex post Sidak proposes. The problems with ex post valuations—that they make the patentee better off than it would have been but for the infringement, and exacerbate holdup and royalty stacking risks—remain and should be avoided.
Sidak's proposal appears to rest on his characterization of the SSO as a joint venture, and his concern that if the FRAND royalty is not based on ex post value there will be an insufficient incentive for firms to join the venture. That would be true, however, only if the patentee could expect to recover higher royalties if it was not a member of the SSO and thus not subject to a FRAND commitment; but I don't see why that should be the case. In other words, I don't see any reason why a reasonable royalty awarded for the infringement of an SEP owned by a non-SSO member should be any higher than a FRAND royalty awarded for the infringement of an SEP owned by an SSO member; both amounts should be calculated on the basis of ex ante contingent incremental value and therefore should be the same. (That should apply both for royalties awarded for past infringement and for ongoing royalties awarded in lieu of an injunction, but that's a subject for another post.) In both cases, the correct royalty is the ex ante contingent incremental value: what the parties would have agreed to ex ante, on the assumption that the patent would be incorporated into standard X. On this interpretation, the only thing a FRAND commitment adds to the mix is that it is a commitment and therefore may give rise to some sort of contractual or equitable duty to bargain toward and accept a reasonable royalty. Additionally, being a member of an SSO may confer other benefits, among them the ability to participate in setting the standard and a commitment from other SSO members to license their patents on a FRAND basis (the latter being of concern to operating companies, though not to NPEs). (Sidak mentions, at p.990, that an SEP holder also must take into account "the fixed costs of participation in the SSO," which might include, for example, the possibility that "failure to disclose a potentially essential patent may subject a firm to antitrust scrutiny, and the costs of defending a potential suit." Based on the outcome of the Rambus case in the U.S., this may be a fairly remote risk, however. And non-SSO members may get hit with low-probability-of-success antitrust suits for any number of reasons too.) But the basic point is that it should not be necessary to equate FRAND royalties with ex post values in order to induce participation in the SSO.
Going back to the initial hypothetical, another point to note is that the parties could agree ex ante to a license (1) that is contingent on standard X being adopted, and (2) the amount of which is contingent on how much Z actually uses the invention. This second condition is the very definition of a running royalty, as Siebrasse points out, where the rate and the definition of the base are fixed but the value of the base depends on use. I suppose we could call this the "ex ante double contingent incremental value," though that's a bit wordy. In theory, it's a matter of no difference whether you use the ex ante contingent incremental value or the ex ante double contingent incremental value. (Although I had long forgotten it, it appears that Roger Blair and I, citing a paper by Sherry and Teece, made something like this point in Rethinking Patent Damages, 10 Tex. Intell. Prop. L.J. at 41-42 & n.203 (2001).) In reality, however, parties often prefer to use running royalties because of the difficulty of accurately predicting the amount of use ex ante. Moreover, as Blair and I discussed in another paper (The Elusive Logic of Standing Doctrine in Intellectual Property Law, 74 Tulane L. Rev. 1323, 1397-1401 (2000)), there may be some consequences in terms of efficiency of production as well.
A final observation is that, as Sidak notes, it is often unrealistic in practice to actually apply an ante framework--too many variables are unquantifiable in reality--and that we need to resort to appropriate heuristics. Based on my initial reading, I think that much of Sidak's analysis of what those heuristics should be makes sense. I plan to reread this portion of his article, however, and may address the matter a little more thoughtfully in my next post.
Thomas F. Cotter
Briggs and Morgan Professor of Law
Innovators Network Foundation Intellectual Property Fellow
University of Minnesota Law School
Minneapolis MN 55446
cotte034@umn.edu
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redpajama_set_name: RedPajamaCommonCrawl


II – Be Sure You Got Both Powersupplys Are Connected.
Incompatible HDD or SSD cause your NAS crash. If your HDD is not in compatbility table, Qnap support team will reject to check your Problem. Please be careful about this. Also request Qnap support team to add these HDD models in compatiblity table, so Qnap engineers can start a compatibility test.
Especially for 8+ Bay device, if you forget to plugin second power cable, this will cause your NAS crash & restart Itself.
Broekn HDD cause your NAS restart itself. If one of your HDD gives "Normal" or "Abnormal" error, change broken HDD with a new one. Start a File system check, and smart test for your HDD's.
If you do not use compatbile UPS device, this will cause your NAS crash & restart itself. Just plug out that UPS device and check if problem still exist or not.
This cause problems, espacially if you are using incompatiblr SSD for cahce, this will cause your NAS "restart" itself at every 02.00.. just shut it down.
This page will detail how to run a full test of the NAS memory using the Memtest86+ utility.
This procedure only applies to NAS models with Intel CPU.
A. How to create a Memtest USB boot disk.
3. Connect the NAS with a VGA monitor, USB keyboard, and the bootable USB disk.
6. The memory test will begin automatically.
Go to http://www.memtest.org/#downiso and download the latest "Auto-installer for USB Key" file.
Extract the zip file to the folder you downloaded it to.
[NOTE]: If there are two USB devices, don't select "USB DISK MODULE PMAP". Similar for TS-451+, except you have to change boot order to specify USB flash first by using +/- keys. DON'T select UEFI USB flash device.
8. Press and select "Yes" to save and exit. On TS-451+. press to save and exit.


text:
Boys' Emotional Needs
June 18, 1999 • Volume 9, Issue 23
Is growing up tougher for boys than for girls?
By Sarah Glazer
In the wake of the tragic shootings in Littleton, Colo., in April, new concerns have been expressed by some child-development experts about the societal pressures faced by boys in the United States. (Photo Credit: Douglas Graham, Congressional Quarterly)
The carnage committed in April by two boys in Littleton, Colo., has forced the nation to reexamine the nature of boyhood in America. Some psychologists contend that societal pressures on boys force them to suppress their most vulnerable emotions in service to a rigid idea of manhood. They say the result is a nation of boys depressed, failing in school and occasionally exploding with murderous rage. The new concern about boys follows a decade in which adolescent girls were thought to be suffering a loss in self-esteem and academic achievement, in part because teachers gave them less attention than boys. But now it is the boys who are falling behind and more likely to be in remedial classes, to be suspended and to drop out of school.
Read the Full Report (Subscription Required)
ISSUE TRACKER for Related Reports
Jul. 01, 2022 Youth Mental Health
Jul. 31, 2020 COVID-19 and Mental Health
Oct. 11, 2019 The Insanity Defense
Jul. 12, 2019 Suicide Crisis
Mar. 13, 2015 Prisoners and Mental Illness
Dec. 05, 2014 Treating Schizophrenia
Sep. 12, 2014 Teen Suicide
May 10, 2013 Mental Health Policy
Aug. 03, 2012 Treating ADHD
Jun. 01, 2012 Traumatic Brain Injury
Jun. 26, 2009 Treating Depression
Feb. 13, 2004 Youth Suicide
Feb. 06, 2004 Mental Illness Medication Debate
Mar. 29, 2002 Mental Health Insurance
Feb. 08, 2002 Treating Anxiety
Jul. 16, 1999 Childhood Depression
Jun. 18, 1999 Boys' Emotional Needs
Sep. 12, 1997 Mental Health Policy
Aug. 19, 1994 Prozac
Aug. 06, 1993 Mental Illness
Oct. 09, 1992 Depression
Jun. 14, 1991 Teenage Suicide
Jul. 08, 1988 Biology Invades Psychology
Feb. 13, 1987 The Mentally Ill
Aug. 20, 1982 Mental Health Care Reappraisal
Jun. 12, 1981 Youth Suicide
Sep. 21, 1979 Mental Health Care
Sep. 15, 1978 Brain Research
Jul. 05, 1974 Psychomedicine
Aug. 08, 1973 Emotionally Disturbed Children
Dec. 27, 1972 Mental Depression
Mar. 24, 1972 Schizophrenia: Medical Enigma
Apr. 21, 1971 Approaches to Death
Mar. 03, 1971 Encounter Groups
Nov. 25, 1970 Psychological Counseling of Students
Feb. 19, 1969 Future of Psychiatry
Feb. 02, 1966 New Approaches to Mental Illness
Jan. 22, 1964 Insanity as a Defense
Sep. 25, 1963 Anatomy of Suicide
Nov. 20, 1957 Drugs and Mental Health
Apr. 23, 1954 Mental Health Programs
Jul. 09, 1948 Mental Health
BROWSE RELATED TOPICS:
Elementary and Secondary Education
Students and Social Life


We left Expocaccer. On the way to the first farm we spoke about the Rainforest Alliance certification. There is a premium paid to farmers with the certification for them to invest in the people on the farm, in soil preservation and also there is a minimum amount of land set aside as a reserve. This reserve is left to grow wild to attract indigenous flora and fauna. They work with local universities to see these reserves attract different species. Some of the farms log all fauna that is sighted.
The first variety we saw was Topazio variety (A mundo nuvo and caturra blend). The different levels of ripeness were clear on the tree with the different colours on the tree.
We tasted the fruit it was a semi sweet cherry flavour. The mucilage around the beans is the sweetest. The farm is like most Brazilian farms. Automation of the farms started in the nineties. Most of the coffee is natural (dry process) or pulp natural (semi natural). There is s small amount of washed that is mainly produced for local consumption by the big multi nationals that are not allowed to import coffee, but must use the local coffee. So they get the farmers to produce washed coffee for a different Flavour.
that affect the tree and it takes years to recover.
This farm currently produces 4000 bags 30% pn 70% and very small fully washed.
the farm has 10 varieties and is UTZ and RFA certified.
Once the coffee is in green it is stored in wooden silos for 30 to 40 to ensure the coffee is more uniform. All coffee delivered depulped and clean to coop.
Farm owner was not there but he met us later at the cupping, where he shared a video of the farm which we posted on YouTube.


text:
Miloslav Mečíř and Tomáš Šmíd were the defending champions, but Šmíd did not compete this year.

Mečíř teamed up with Wojciech Fibak and successfully defended his title, by defeating Tom Nijssen and Johan Vekemans 7–6, 5–7, 6–2 in the final.

Seeds

Draw

Draw

References

External links
 Official results archive (ATP)
 Official results archive (ITF)

Doubles

redpajama_set_name: RedPajamaWikipedia


text:
New Vehicle Dealership Specialty
Trust Administration/Probate
Employer Defense Litigation
Sarah M. Ulibarri
Sarah M. Ulibarri is an Associate in the Uncontested Probate and Estate Planning Practice Group at Ferruzzo. Sarah grew up in Littlerock, California before moving to Orange County in 2005. She earned her undergraduate degree in Criminology, Law & Society from the University of California, Irvine in 2008. She earned her Juris Doctor degree, magna cum laude, from Western State College of Law in 2016, and was admitted to the State of Bar of California the same year.
During law school, Sarah received Witkin Awards in Legal Research & Writing I, Constitutional Law II and Remedies, and the IL Summer Honors Fellowship, which provided her the opportunity to study abroad with the 21st Century Law Practice Summer Program in London, England in 2014. She also gained experience by externing for the Hon. Mary Schulte, Ret. in the Orange County Superior Court in 2015. Sarah enjoys being a part of the community and is a member of several legal organizations. She was awarded the 2016 Bar Stipend Award from the Orange County Women Lawyers Association and the 2017 Marjorie Day Award for Associate of the Year from the Robert A. Banyard Inn of Court.
Prior to joining the Firm, Sarah's practice focused on conservatorships (limited and general), guardianships, probate and trust administration, and advanced estate planning. She is passionate about building lasting relationships with her clients. She resides in Anaheim Hills with her husband and children, and enjoys traveling, eating new cuisines, and spending time with her friends and family.
Estate, Probate, & Trust Administration
Estate Planning, Trusts, & Wills
Estate, Probate, & Trust Litigation
State Bar of California, 2016
U.S. District Court, Central District of California, 2018
Criminology, Law & Society from the University of California, Irvine in 2008
Juris Doctor degree, magna cum laude, from Western State College of Law in 2016
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Orange County Bar Association: Trusts & Estates Section, Member
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