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SEPs In The Wake Of Qualcomm: 4 Patenting Issues
Bylined Articles
This article is the first in a series of articles that are designed to examine key standard-essential patent issues that are shaping the usage and treatment of SEPs now and for years to come. This article will cover the top four considerations when patenting standardized technologies; the second in the series will cover the top four considerations when seeking to enforce SEPs; and the third will cover the top four considerations when defending against SEP attacks.
As emerging standards, such as 5G, become increasingly adopted, the impact of SEPs will become even more significant. For example, obtaining a patent that is essential to a standard, or that may become essential to a future standard, may yield a large number of potential infringers and potentially infringing products. SEP holders may choose to monetize their SEPs by aggressively licensing them.
As the proliferation and relative importance of SEPs continues to increase, it will become increasingly imperative for SEP holders and SEP applicants to carefully consider the choices that they make during the SEP procurement and declaration processes as those choices will have an enormous impact on their ability to enforce and license their patents in the future.
SEPs are more relevant now than ever. The value of SEPs continues to grow in view of emerging Alice case law as well as new U.S. Patent and Trademark Office guidelines providing guidance for patent eligibility.[1] Under this emerging landscape, the development of strong SEPs and diverse SEP portfolios has become even more valuable.
Qualcomm Inc. displayed this type of diverse SEP portfolio strategy in the widely discussed Federal Trade Commission v. Qualcomm case.[2] As massive judgments and settlements continue to occur in common SEP fields such as wireless communications, the question of whether to declare a patent as essential to a standard is as important as ever.[3] But the potential benefits of pursuing an SEP must be balanced with an understanding of the potential consequences that may result.
In fact, several of these consequences were also highlighted in the recent Qualcomm case where the district court enjoined Qualcomm from continuing various licensing practices relating to its SEPs — finding that its tactics were anti-competitive — and requiring Qualcomm to make exhaustive SEP licenses available to rival chip manufacturers on fair, reasonable and nondiscriminatory terms. In view of these considerations, this article will address the top four things to know when seeking to obtain a patent directed toward a standardized technology.
Obtaining a Strong Patent Comes First
While a primary focus of drafting an SEP application may be to cover elements essential to a standardized technology, the application itself should also consider how the technology might evolve in the future and what industries are likely to adopt the technology. Doing so will help ensure the resulting SEP has the broadest reach and longest usefulness possible.
When taking these considerations into account, drafters should seek to vary the scope of the claims to target different potential infringers. For example, drafting claims to target different infringers along a supply chain, and different levels of implementation of the technology, will aid in variability as well as help guard against unexpected changes in the adoption of the underlying technology. For example, if the standardized technology is a communication protocol, drafters could draft claims directed to a method of performing the communication protocol, a specific integrated circuit that uses the protocol, or even an end-user electronic device that uses the protocol.
As seen from the recent Qualcomm case, Qualcomm also uses this portfolio diversity approach. In particular, "[Qualcomm] holds and licenses three broad categories of patents: (1) cellular standard essential patents ("SEPs"); (2) non-cellular SEPs; and (3) non-SEPs, which also are known as implementation patents. ... Cellular SEPs are patents necessary to practice a particular cellular standard. ... By contrast, non-cellular SEPs are necessary to the practice of a non-cellular standard."[4]
While Qualcomm primarily licenses its patents on a "portfolio bases" where licensees receive rights to all three categories of Qualcomm patents, Qualcomm also occasionally offers separate licenses to its SEPs.[5] Qualcomm explained that licensing the entire diverse portfolio is preferable, however, because licensing the portfolio yields a higher royalty rate than SEP-only licenses.[6]
To illustrate an application of this strategy to a future standardized technology such as the emerging 5G standard, implementers may use 5G communications in many different industries, such as automobiles, home appliances, smart sensors or robotics. Varying claim scope to cover such industries would aid in generating a broad SEP portfolio covering different applications. A best practice would be to generate a portfolio having SEPs directed to the standard itself while also having different patents, or different claims within each patent, directed to different applications of the standardized technology. The broad coverage from this type of SEP portfolio may also provide avenues for survivability against potential invalidity challenges.
While varying claim scope will aid in SEP survivability as well as broad infringement coverage, the variation of claim scope may impact royalty rate calculations when enforcing SEPs. During litigation, judges and juries will attempt to quantify the value of an SEP as it relates to the standardized technology and to the infringing product, each of which will vary depending on whether the SEP covers an entire end product or a subcomponent of the end product. By having a portfolio with varying scope, the claims can address each of these issues and aid in maximizing a received royalty.
In addition to varying claim scope, drafters should also take caution to avoid certain pitfalls that would reduce the strength of an SEP application, such as claims being subject to divided infringement and easy design around alternatives. Other considerations may be specific to the particular standardized technology. For example, drafters should consider whether an invention is a required part or an optional part of the standardized technology. Essentiality and infringement may be more difficult to prove when claims are drafted only toward optional features.
Other considerations include whether the claims allow for infringement to be easily detected, and whether the standardized technology is emerging (and subject to change) — i.e., standards directed toward artificial intelligence, blockchain and 5G — or a legacy technology such as 4G. Each of these considerations must be carefully weighed when seeking to obtain a patent directed toward a standardized technology.
Different Standards-Setting Organizations Have Different SEP Disclosure Rules
While pursuing an SEP, a company may also be participating in the development of the standard they are seeking to obtain a patent on. Different standards-setting organizations have different rules for participating in the development of a standard and may require the disclosure of patents and applications relevant to the standard. If a company wishes to obtain an SEP directed toward a technology governed by such an SSO, the company must understand and adhere to these rules.
These rules are generally codified in a series of contracts between companies and SSOs — e.g., SSO membership application, intellectual property rights policies, assertion forms and different SSOs may have different contract terms and may be subject to different jurisdictions governing the enforcement of those contracts.
The IP rights policies for the Institute of Electrical and Electronics Engineers and Internet Engineering Task Force provide good examples to illustrate these points. The IEEE is a professional association for electrical and electronic engineering, telecommunications and computer engineering.[7] The IEEE Standards Association is an organization within the IEEE responsible for developing global standards, such as the Wi-Fi standard (IEEE 802.11).[8] The IEEE-SA utilizes bylaws that describe the process of adopting a standard.[9]
First, an IEEE-approved organization must sponsor a standard and provide public notice of the intent to develop a standard.[10] At this point, the IEEE-SA expects interested members with IP rights relevant to the proposed standard to come forward and provide a letter of assurance.[11] The bylaws indicate that the letter of assurance should be provided prior to the approval of the standard.[12] While the IEEE encourages the disclosure of IP rights that are potentially relevant to a standardized technology, the IEEE does not explicitly provide consequences for lack of disclosure.[13]
In contrast to the IEEE, the IETF explicitly requires disclosure of potential IP rights if a party wishes to participate in the development of a standard.[14] The IETF maintains standards related to internet architecture and internet communications. Contributors to standards and participants in the IETF are required to disclose IP rights that may be relevant to a standard.[15]
Contributing to or participating in IETF activities related to a standardized technology without making required IP rights disclosures is a violation of IETF policy.[16] A failure to disclose relevant IP rights may result in sanctions from the IETF that may prevent the company from further contributing to or participating in IETF activities.[17] While the IETF requires contributors to disclose patents, the IETF does not maintain any positions on applicability to a standard or validity of patents.[18]
While these types of SSO disclosure requirements have not been challenged legally, the European Commission (the executive branch of the European Union) has recently criticized SSOs for their handling of disclosures.[19] The European Commission has acknowledged that SSOs typically maintain databases that collect "large amounts of declaration data" but has criticized SSOs for not providing "user-friendly accessibility to interested parties" and "lack[ing] essential quality features."[20]
In response to these issues, the European Commission has called on SSOs to update their declaration systems to provide up-to-date information on SEPs.[21] The European Commission has suggested disclosing up-to-date ownership or licensor status for an SEP, reporting the main outcomes of "final decisions, positive or negative, on declared SEPs (including on essentiality and patent validity)" and requiring that SEP owners "at least make reference to the section of the standard that is relevant to the SEP and to the link with the patent family."[22]
In view of these guidelines, SEP owners may face updated disclosure requirements in the near future. The difference in these disclosure requirements highlights the importance of gaining a full and complete understanding of the disclosure requirements put in place by each SSO.
The Pros and Cons of Declaring Your Patent Essential to a Standard
However, understanding the disclosure requirements put in place by a particular SSO is only half the battle. Next, SEP holders and applicants must then decide whether it is in their best interests to make an affirmative declaration that their patent or application is essential to a standard. Here, we address the considerations on both sides and explain several factors to consider when deciding whether to declare a patent or patent application as essential to a standardized technology.
One of the major benefits of declaring a patent or patent application as essential to a standard is the stronger negotiating position provided during enforcement. Owning an asset alleged to be essential to a standardized technology inherently means that any implementers utilizing the standard will be infringing your patent. Infringement is easier to prove and designing around the standardized technology will be difficult — assuming the patent is truly essential to the standard. Implementers will likely face difficulties using nonstandard technology. Similarly, widely adopted standards will implicate a large number of companies and products. In this case, the large number of potential infringers may lead to larger royalties.
These benefits for SEP holders, and corresponding challenges for SEP implementers, are the driving force behind the recent proliferation of patent pools directed toward SEPs. For example, Avanci LLC uses these understood realities of SEPs to bring SEP holders/licensors and SEP implementers/licensees together. To date, Avanci has signed up about 30 licensors and about a dozen licensees and procured licensee agreements with several auto manufacturers at a royalty rate of about $15 per vehicle.[23]
Additionally, if a company participates in the early stages of a standard-setting process, there is a higher likelihood that the specific technology being advocated for by that company eventually becomes adopted as the standard. Therefore, the underlying patents and applications owned by that company have a higher likelihood of reading on the ultimately adopted standard. And since many SSOs require, or encourage, participating companies to disclose their IP rights (effectively a standard-essential declaration), a company may find that disclosing their patent or application to the SSO and being able to exert its influence on what technology is adopted as the standard is advantageous to not disclosing its patent or application and having no influence on whether the technology that it developed is adopted as the standard.
On the other hand, a drawback of declaring a patent or patent application as essential to a standard is the loss of some enforcement or licensing rights. For example, an explicit condition for declaring a patent as essential is an agreement to license the SEP on fair, reasonable and nondiscriminatory terms. Standard-essential declarations may then force companies into licensing their SEPs on acceptable FRAND terms and may further prevent the companies from charging potentially higher royalty rates.
Similarly, in many cases, injunctive relief becomes more difficult to obtain. For example, the IEEE's IP rights disclosure requirements include a prohibition against seeking injunctions or exclusion orders against implementers so long as the implementers are not acting or negotiating in bad faith.[24] Moreover, the potential consequences can become even more complicated as these FRAND obligations may subject companies to unfavorable contract laws, antitrust issues and unpredictable FRAND decisions.[25]
As an example of how these drawbacks can play themselves out, we again look to the recent Qualcomm case. In that case, the court ruled that Qualcomm's licensing practices in the markets for code-division multiple access and premium long-term evolution modem chips violated Sections 1 and 2 of the Sherman Act and Section 5 of the Federal Trade Commission Act, were anti-competitive and harmed consumers.[26]
The court subsequently enjoined Qualcomm from continuing these practices, stating specifically that: (1) it could no longer condition the supply of modem chips on a customer's patent license status; (2) it cannot enter into express or de facto exclusive dealing agreements for the supply of modem chips; (3) it must make exhaustive SEP licenses available to rival chip manufacturers on fair, reasonable and nondiscriminatory terms; (4) it cannot interfere with a customer's ability to communicate with a government agency about potential law enforcement or regulatory matter; and (5) it must submit to compliance and monitoring procedures for seven years.[27]
Additionally, on the issue of validity, declaring a patent as essential to a standard may provide a guided path to implementers to invalidate the SEP. For example, if the SEP is merely directed to an incremental improvement to an existing standard, a challenger may be able to prove that the improvement was obvious. Specifically, the challenger may be able to use a combination of a prior standardized technology with SSO working group documents to show the obviousness of the SEP.
As a result, a company considering whether to declare its patents or patent applications as essential to a standardized technology should carefully consider how closely their claims track the standard, each SSO's disclosure requirements, and its own short and long term goals for its IP rights.
Declaring Your Patent as Being Essential to a Standard Is Not a Guarantee
If a company ultimately decides to declare its intellectual property as essential to a standard, an important detail to keep in mind is that SSOs rarely vet or comment on the applicability of a declared patent to a standard or the validity of the patent in general. Further, even if an SSO identifies a patent as potentially being part of a standard, a court could completely disagree. Thus, an SSO's acknowledgment of a patent as being essential to a standard is not a guarantee of enforceability.
Consider the following example, the IEEE-SA bylaws indicate that patent owners should provide letters of assurance prior to the approval of the standard[28] and expressly state that the IEEE is not responsible for "identifying Essential Patent Claims for which a license may be required," nor is it responsible for "determining whether any licensing terms or conditions … are reasonable or non-discriminatory."[29] Upon receiving a letter of assurance, a statement indicating that the patent may be applicable to the standard is simply listed on the IEEE-SA website.[30]
The IETF operates in a similar manner taking "no position regarding the validity or scope of any intellectual property rights or other rights that might be claimed to pertain to the implementation or use of the technology described in any IETF documents … nor does it represent that it has made any independent effort to identify any such rights."[31] Patent owners simply complete a form indicating the type of license they are willing to provide.[32]
In this manner, declaring to an SSO that a patent is essential to a standard provides no guarantees when trying to enforce the SEP. Courts have further explained that the determination of whether a particular patent is essential to a standard is a factual question requiring examination beyond a mere declaration.[33] Further, jurisdictions around the world are experimenting with ways to verify whether claims are essential to a standardized technology.
For example, the previously described European Commission has proposed several approaches including having SSOs confirm essentiality, coordinating with patent offices to perform independent essentiality checks, and establishing an independent European body tasked with essentiality assessments.[34]
Similar approaches have been recently advocated for by industry players such as Raymond Millien, vice president and global chief intellectual property counsel for Volvo Car Corporation, and Jan Schnitzer, general counsel and head of IP at u-blox AG[35], and commentators such as former USPTO Director David Kappos, and may be adopted in the United States in the near future. In this manner, patent owners may be required to prove essentiality under a moving target of laws and procedures. Merely relying on the implementation of a standard as being evidence of infringement may be insufficient to enforce a declared, but unproven, SEP.
While SEPs are enticing assets to pursue as standardized technologies continue to emerge, patent owners should understand several aspects of the process for obtaining SEPs. In particular, patent owners should employ best practices for patent drafting to obtain a patent or patent portfolio resilient against invalidity challenges, essentiality challenges, future changes to the underlying standard, and potential design around alternatives.
Further, patent owners should understand their obligations to SSOs as well as SSO policies regarding patent disclosure and FRAND obligations beyond just a royalty rate. Finally, patent owners should also understand that a mere declaration that a patent is essential to a standard may not be sufficient when attempting to enforce an SEP during litigation. Each of these considerations should be taken into account when drafting an SEP application — including the level of detail to include in the specification and the appropriate scope to pursue in the claims — when participating in a standard setting process and when determining whether to declare a patent as essential to a standard.
Ryan Richardson and Michael Specht are directors and Timothy Tang is an associate at Sterne Kessler Goldstein & Fox PLLC. The opinions expressed are those of the author(s) and do not necessarily reflect the views of the firm, its clients, or Portfolio Media Inc., or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice.
[1] USPTO, 2019 Revised Patent Subject Matter Eligibility Guidance (January 7, 2019), https://www.govinfo.gov/content/pkg/FR-2019-01-07/pdf/2018-28282.pdf
[2] Fed. Trade Comm'n v. Qualcomm Inc., Findings of Fact and Conclusions of Law, Case No. 17-CV-00220-LHK (N.D. Cal. May 21, 2019), https://www.ftc.gov/system/files/documents/cases/qualcomm_findings_of_fact_and_conclusions_of_law.pdf. This decision is currently on appeal to the 9th U.S. Circuit Court of Appeals.
[3] See Dani Kass, Intellectual Ventures Striking Deals In Wireless IP Fights (June 19, 2019), https://www.law360.com/articles/1170451/intellectual-ventures-striking-deals-in-wireless-ip-fights; Dave Simpson, T-Mobile Owes IV $34M, Ericsson Owes $9M: Patent Trial Jury (February 8, 2019), https://www.law360.com/articles/1127627/t-mobile-owes-iv-34m-ericsson-owes-9m-patent-trial-jury.
[4] Fed. Trade Comm'n v. Qualcomm Inc., Findings of Fact and Conclusions of Law at 6 (internal citations omitted).
[7] IEEE, About IEEE, https://www.ieee.org/about/index.html.
[8] IEEE Standards Association, IEEE 802.11-2016 IEEE Standard for Information Technology, https://standards.ieee.org/standard/802_11-2016.html.
[9] See generally, IEEE, IEEE-SA Standards Board Bylaws (March 2019), http://standards.ieee.org/develop/policies/bylaws/sb_bylaws.pdf.
[10] IEEE-SA Patent Policy, 10 (April 24, 2019), https://development.standards.ieee.org/myproject/Public/mytools/mob/patut.pdf.
[11] Id. [12] IEEE-SA Standards Board Bylaws, 6.2, paragraph 2.
[13] If a Letter of Assurance cannot be obtained, the matter will be referred to the Patent Committee who will consider the conduct and make a recommendation to the IEEE-SA Standards Board. IEEE-SA Standards Board Bylaws at 6.2; IEEE-SA Patent Policy, 11.
[14] Internet Engineering Task Force (IETF), RFC 8179 – Intellectual Property Rights in IETF Technology (May 2017), https://tools.ietf.org/html/rfc8179.
[15] See RFC 8179 ("Any Contributor who reasonably and personally knows of IPR meeting the conditions of Section 5.6 which the Contributor believes Covers or may ultimately Cover his or her written Contribution that is intended to be used as an input into the IETF Standards Process, or which the Contributor reasonably and personally knows his or her employer or sponsor may assert against Implementing Technologies based on such written Contribution, must make a disclosure in accordance with Section 5.")
[16] See RFC 8179, section 6 (Failure to Disclose – "Contributing to or Participating in IETF activities about a technology without making required IPR disclosures is a violation of IETF policy.")
[18] Id. at section 4 (The IETF "disclaim[s] any responsibility for identifying the existence of or for evaluating the applicability of any IPR, disclosed or otherwise, to any IETF technology, specification, or standard, and will take no position on the validity or scope of any such IPR."); see also IETF, Intellectual property rights, https://www.ietf.org/standards/ipr/
[19] See European Commission, Communication From the Commission to the European Parliament, the Council and the European Economic and Social Committee – Setting Out the EU Approach to Standard Essential Patents (November 29, 2017), 3, https://ec.europa.eu/docsroom/documents/26583/attachments/1/translations/en/renditions/native.
[21] Id. at 3-4.
[23] See Business Wire, The Avanci Licensing Platform Adds SK Telecom, ASUSTeK and Datang Mobile as New Patent Owners (July 10, 2019), https://www.businesswire.com/news/home/20190710005020/en/Avanci-Licensing-Platform-Adds-SK-Telecom-ASUSTeK; see also Avanci, PRICING, http://avanci.com/pricing/
[24] See IEEE-SA Patent Policy, 32; IEEE-SA Bylaws at 6.2.
[25] Matthew Bultman, International Patent Roundup: European FRAND Edition (August 2, 2019), https://www.law360.com/ip/articles/1184562/international-patent-roundup-european-frand-edition?nl_pk=a8cf340c-5be5-4920-903c-80ba96df438d&utm_source=newsletter&utm_medium=email&utm_campaign=ip
[26] See Fed. Trade Comm'n v. Qualcomm Inc., Findings of Fact and Conclusions of Law, 18-22, 208-16 [27] Id. at 227-33.
[28] See IEEE-SA Bylaws at 6.2; IEEE-SA Patent Policy, 10. [29] IEEE-SA Bylaws at 6.2. [30] IEEE-SA Patent Policy, 35.
[31] IETF, Intellectual property rights, https://www.ietf.org/standards/ipr/ [
32] See IETF, The Patent Disclosure and Licensing Declaration Template for Specific IPR Disclosures, https://datatracker.ietf.org/ipr/new-specific/
[33] See Cellular Communications Equipment LLC v. HTC Corp., 6:16-CV-363-KNM, Order Denying Motion for Summary Judgment (August 9, 2018); see also In re Certain Magnetic Data Storage Tapes and Cartridges Containing the Same (Fujifilm v. Sony), 337-TA-1012, Notice of Commission Final Determination of Violation of Section 337 (March 8, 2018).
[34] European Commission, Communication From the Commission to the European Parliament, the Council and the European Economic and Social Committee – Setting Out the EU Approach to Standard Essential Patents at 5
[35] Raymond Millien and Jan Schnitzer, The EPO should rule on SEPs, say top European auto patent players (September 7, 2018), https://www.iam-media.com/frandseps/millien-epo-seps
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Michael D. Specht
Ryan C. Richardson
Timothy L. Tang


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When the Streets Were Paved With….
"Gardez l'eau!" was the watch-cry of English town-dwellers from Norman times, to warn pedestrians of the imminent arrival of the contents of a chamber-pot being emptied from an upper story window. Although the English no longer dispose of their waste in this way, the cry lives on in the nick-name for the room now devoted to the purpose – the loo.
Humans have always produced waste. For dispersed populations this has not been a problem, but even the most modest degree of urbanisation brings the need for some form of waste management. Until the middle of the 18th century, English towns relied on householders to do their bit, or whatever they saw as their bit, to keep the streets clean. There was some assistance from industry, though, as solid waste (particularly canine) was much sought-after for tanning, and as a source of saltpetre for making gunpowder. The demand for nightsoil and "pure", as the canine version of this resource was then known could not, however, keep up with the supply, and English urban streets were indescribably filthy, with predictable consequences for public health. Streets like this could not be "swept" in the way we understand the word.
The first proposal that London street cleaning should be a public responsibility came in 1751 from a customs official called Corbyn Morris, who proposed that "…as the preservation of the health of the people is of great importance, it is proposed that the cleaning of this city, should be put under one uniform public management, and all the filth be…conveyed by the Thames to proper distance in the country". Not much came of this, and London continued to grow and to befoul its streets and watercourses.
By the middle of the 19th century, urban pollution was catastrophic and outbreaks of cholera were regular. Parliament was finally moved to act, and in response pioneers like Bazalgette engineered massive systems for draining the city of its liquid waste. At the same time, more and more earthen streets were being paved and pavements laid, to segregate pedestrian and vehicular traffic.
Finally, there were streets to sweep!
The new cities of the industrial North had more new streets than anywhere else, and their burghers were inordinately proud of them. They also had an almost religious faith in the power of machinery to solve life's problems. It's no surprise, then, that the first patent for a street sweeping machine should be awarded in 1843 to a Manchester man for a horse-drawn street sweeping machine. Across the Atlantic six years later an African-American called CS Bishop came up with a similar device. The first motorised street cleaning machines appeared just before World War One.
These machines were literally sweepers – attempts to remove finer material than could be captured with a bristle brush had to wait until the latter half of the 20th century.
By the 1960s there was a growing realisation that the fine dust left behind by contemporary sweepers posed a variety of challenges to human health. It contained substantial quantities of asbestos from braking materials, and created an extra burden on the waste water if allowed to simply be washed away in the rain, as was then the practice. Serious attention began to be paid to designing cleverer street cleaning machinery.
The world leader today in street cleaning machinery is Hako. Hako was founded in 1948 and originally made light agricultural machinery. It made its first street sweeper in 1961, but the real milestone came in 1975, with the first European scrubber-drier.
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Home World UN rights office calls on Thailand to amend royal insult law
UN rights office calls on Thailand to amend royal insult law
The United Nations human rights office called on Thailand on Friday to amend its lese majeste law which it said had been used against at least 35 activists, one as young as 16, in recent weeks.
It said Thailand should stop using the law, which bans insulting the monarchy, and other serious criminal charges against protesters, noting that criminalising such acts violates freedom of expression.
Prosecutions, which had stopped in 2018, restarted after protesters broke longstanding taboos by calling for reforms to curb the powers of King Maha Vajiralongkorn during months of street demonstrations. Those found guilty under the royal insult law face three to 15 years in prison.
The spokesperson for the U.N. High Commissioner for Human Rights noted that charges had also been filed against protesters for sedition and computer crimes offences.
"We call on the Government of Thailand to stop the repeated use of such serious criminal charges against individuals for exercising their rights to freedom of expression and peaceful assembly," spokeswoman Ravina Shamdasani told a news briefing in Geneva.
Nigerian military miraculously rescue over 300 schoolboys kidnapped by Boko Haram
The office of U.N. High Commissioner for Human Rights Michelle Bachelet urged Thailand to change the lese majeste law to bring it in line with the right to freedom of opinion and expression.
In response, a Thai foreign ministry spokesman said the law was not aimed at curbing freedom of expression and was similar to libel laws.
"In the past couple of months, protestors have not been arrested solely for the exercise of the right to freedom of expression and peaceful assembly," Tanee Sangrat said in a statement.
"Those arrested had violated other Thai laws and admittedly the majority have been released."
Youth-led protests began in July to call for the removal of Prime Minister Prayuth Chan-ocha, a former junta leader, and for the drafting of a new constitution.
They later called for reforms to the monarchy: seeking the king to be more clearly accountable under the constitution and the reversal of changes that gave him control of royal finances and some army units among other demands.
Ravina Shamdasani
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Boarding Schools for Pre-Teen Boys in Appleton, Wisconsin
Home » Boarding Schools for Pre-Teen Boys in Appleton, Wisconsin
Are You Looking for a Boarding School in Appleton, Wisconsin for an 8-12-Year-Old Pre-Teen Boy? Not Many Therapeutic Boarding Schools in Wisconsin Work with Pre-Teen Boys.
Vision Boys Academy (located in Missouri) Offers Age-Appropriate Counseling and Therapy for Troubled Boys from Appleton, Wisconsin and Across the USA. Older Troubled Teen Boys in Appleton, Wisconsin are Not Admitted for the VBA Therapeutic Program – Since it is Specialized Just for Pre-Teen Boys.
Dealing with pre-teen boys (ages 8-12) from Appleton, Wisconsin, is very different from guiding teenage boys. Their issues and attitudes are different. That's why the expert residential staff and counselors at Vision Boys Academy, a boarding school for troubled pre-teen boys, use specialized, age-appropriate counseling for a struggling boy's bad behavior, academic ability, and daily choices.
Boundary-based discipline, which includes setting clearly defined limits, communicating expectations frequently, and following through on consequences, helps Appleton, Wisconsin, 8-12-year-olds mend their attitudes and behavior. The experts at Vision Boys Academy, a faith-based boarding school for troubled boys, will help tidy up the path of your at-risk 8-12-year-old son.
A struggling pre-teen boy in Appleton, Wisconsin, is more likely to be able to discuss their feelings and learn how to solve problems while spending time with a counselor or parent. However, he will typically only think about the here and now without considering or discussing the future. Also, pre-teen boys learn from counseling and therapy better through hands-on activities.
The therapeutic boarding school for troubled pre-teen boys from Appleton, Wisconsin, focuses on building one-on-one relationships with each troubled boy and establishing active listening and correction.
The goal is to help boys accept responsibility for their negative behavior and speak to staff, parents, and peers respectfully. When a struggling boy at Vision Boys Academy understands and accepts responsibility for his actions, he is shown how to better handle his frustrations and thereby adjust his negative behavior.
Our Boarding School for Preteen Boys from Wisconsin, Offers Motivation and Inspiration from a Christian Outlook
A specialized program of consistent daily encouragement of fair, structured rules and expectations can help your troubled boy learn to make the right decisions in the future. Some boys need to concentrate ongetting caught up in school. Other boys need to understand the worth of respecting others and themselves. And some boys need a change of environment.
The safe, daily structured Christian boarding school program for boys at Vision Boys Academy supports an 8-12-year-old boy's personal, spiritual and academic growth, as well as physical growth with lots of rest, healthy meals, and outdoor activities.
When Seeking a Boarding School in Appleton, Wisconsin, Just for Pre-Teen Boys, You Will Be Happy to Know that VBA Helps Boys Gain an Appreciation for God's Love
Vision Boys Academy May Be a Better Alternative than Other Boarding Schools for Pre-Teen Boys in Appleton, Wisconsin, Especially Boys Who Have Been Adopted
VBA doesn't mix older, more experienced boys with pre-teen boys. Most therapeutic boarding schools in Appleton, Wisconsin, don't offer separate spaces for pre-teen boys. Instead, they are all housed together. We don't think that is appropriate or effectual for pre-adolescent boys. In fact, it can be harmful.
With a heart for assisting adopted or at-risk boys, Vision Boys Academy's Director, Shawn Parker, started the program focusing on pre-teen boys. The ordained Baptist minister and his staff share biblical counseling and mentoring to the boys as they live, learn, and play on the beautiful VBA campus. Guiding at-risk pre-adolescent boys (ages 8-12) to be upright and honorable young men is a thrill and life purpose for each of the dedicated staff at Vision Boys Academy.
More abou boarding schools for pre-teen boys in Appleton, Wisconsin:
Appleton is a city in Outagamie, Calumet, and Winnebago Counties in the U.S. state of Wisconsin. It is situated on the Fox River, 30 miles southwest of Green Bay and 100 miles (161 km) north of Milwaukee. Appleton is the county seat of Outagamie County. The population was 78,086 at the 2010 census. Appleton is the principal city of the Appleton, Wisconsin Metropolitan Statistical Area, which is included in the Appleton-Oshkosh-Neenah, Wisconsin Combined Statistical Area.
Excerpt about boarding schools for pre-teen boys in Appleton, Wisconsin, used with permission from Wikipedia.
Contact Missouri's Vision Boys Academy, a Christian boarding school for troubled pre-teen boys. Be sure to include VBA in your search for Christian boarding schools in Appleton, Wisconsin, for an age 8-12 pre-teen boy. Call (888) 500-4090 now to learn more.
Should you need help finding schools for troubled teens, addiction treatment for teens, best troubled teen schools, therapeutic boarding schools, boarding school for troubled youth, or therapeutic schools, please let us know. Vision Boys Academy, formerly Victory Boys Academy, is a small Christian boarding school for pre-teen boys, ages 12 and under. Vision Boys Academy is for at-risk boys with anger, lack of motivation, failure in school, rebellion, disrespect, troubled with the law, school expulsion, and more. It is considered one of these types of programs: emotional growth schools, boarding schools, boys homes for troubled youth, therapeutic boarding schools for troubled boys, boys ranches, and boarding schools for troubled boys that help rebellious and troubled pre-teen boys who are defiant or out of control. Your troubled pre-teen boy can benefit from this disciplined Christian boarding school. Our adolescent boys home is much more effective than Christian military schools, boot camps, wilderness programs, or residential treatment centers. If you are searching for a residential boarding school, troubled teen school, or troubled teen boarding school, you have found one that is also faith-based.


Pupils assist members of the public at the tills to pack their shopping bags.
To foster close links with the community and to raise money for worthy local causes such as Riding for the Disabled.
A recent initiative, suggested to the school by WCAVA, our town's volunteering group. It came about through a recognition that we would like to be able to raise money for local charities.
This project began in December 2017.
Overseen by a member of the non-teaching staff and supported by a rotation of 6 teaching staff.
Monies raised to date have suggested that members of the public have been grateful for the assistance of our pupils.
Around 30 year 11 pupils to date but the intention is to increase that number as the academic year unfolds.


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Apothecary Farms Opening New Garden of the Gods Dispensary
Thomas Mitchell January 19, 2023 10:39AM
The new dispensary will be located at 414 Garden of the Gods Road, ten minutes away from the popular outdoor area. Courtesy of Apothecary Farms
While record low medical marijuana sales are forcing some Colorado Springs dispensaries to close, Apothecary Farms has plans for a new store.
The growing chain of dispensaries will open a new location at 414 Garden of the Gods Road on Saturday, January 28, with a grand opening that includes product discounts, gear giveaways, food trucks and music from Apothecary favorite DJ Terpenoid.
Apothecary Farms has owned a second dispensary license in Colorado Springs for several years, according to marketing director Brent McDonald, but the license was connected to a cultivation. If Apothecary Farms wanted to use that license, the new store would have to be at the same location as the grow, or the growing license would have to be voided first. Record low prices for wholesale marijuana made that decision a little easier.
"It didn't make sense to keep that grow up anymore, and the dispensary and grow had to be together unless the grow was shut down. So we kept the dispensary license active, knowing we would eventually find the right location," McDonald explains.
The right location? A former car wash turned liquor store that also houses a gas station. It's "sort of small, but perfect for a dispensary," McDonald says, with Garden of the Gods a ten-minute drive away and a handful of hotels nearby.
"Our current store in the Springs, our mothership location, is in an industrial area. It's not an ideal high-traffic location. This was a play for the future," he notes.
Founded over seven years ago as a lone medical marijuana store in Colorado Springs focused on extracted products, Apothecary Farms is now one of the rare multi-state dispensary chains based in southern Colorado. The company had opened stores in Denver and Pueblo before recently expanding into Oklahoma, where it now has five medical marijuana dispensaries. Apothecary Extracts, a marijuana extraction brand under Apothecary Farms ownership, sells products at hundreds of dispensaries across both states.
Operating a dispensary off Interstate 25 and Garden of the Gods Road should give Apothecary Farms a stronger brand presence in its home town, according to McDonald, as well as a prime setup if the city ever allows recreational pot sales — but that's still a matter of if, not when.
In November, Colorado Springs voters soundly rejected a measure that would have allowed the city's 100-plus medical dispensaries to offer recreational sales, after a decade-long ban. Despite over $1 million in campaign support, the measure faced strong opposition from Mayor John Suthers and a slew of advertisements against the proposal.
"We were all surprised to see it lose the way it did. There was just no public support. The mayor was running propaganda about bringing more homeless to Colorado Springs, increasing drug use and hurting our relationship with the military," McDonald says. "We all thought it would pass, no problem, and then it got absolutely trounced. If we get another opportunity on the ballot, we'll need more grassroots and guerrilla marketing campaigns, and targeting current patients and advocates. I just didn't see that happening at dispensaries or around town the last time."
In the meantime, Apothecary has at least one more acquisition in its sights, this one on the cultivation and production side, but McDonald says the company isn't ready to share details just yet.
Thomas Mitchell has written about all things cannabis for Westword since 2014, covering sports, real estate and general news along the way for publications such as the Arizona Republic, Inman and Fox Sports. He's currently the cannabis editor for westword.com.
Contact: Thomas Mitchell
Facebook: Thomas Mitchell
Instagram: @tompettie/
Ask a Stoner: Where Can I Watch Football and Smoke Weed in Denver?
Reader: Age Limit at 4/20 Fest? How Old Is Too Old?


The new 2015 swimwear is in from the likes of Lise Charmel, Empreinte and Prima Donna. Here's a small selection of what we have on offer.
Do pop in and take a look or call on 0113 307 0011 for further details.
Remember, you can follow us on Twitter or "like" our page on Facebook.


You wake up in an internal representation of your conscience where your goal is to collect 100 memory fragments throughout increasingly complicated and increasing in size levels, or dreams. But there is a catch! These levels are not illuminated. You have a Photon gun that you can use to light your way up as you go through these levels. Initially this is only in form of colorful balls, or photons, that your shoot from your gun, and they light up a certain area. As you collect fragments, the upgrades will become available for you, such as a flashlight attachment, a scan grenade – that shows an outline of the world around you and highlights points of interest, and others. Once you collect 100 fragments the final room will open where you can go to end the game.
Most of the music ingame was composed specifically for PD, by a very talented friend of ours, Toteki. However you are welcome to turn it off through settings and put some of your own chillout (or adrenaline pumped) music in the background. Overall we aim to provide a mystique filled ambiance with just the right challenge level for you to spend your time.


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The Psychology of Big Bang
September 15, 2018 March 29, 2019 jarue Column, Writing 2 Comments
Big Bang is the only theory taught in school. It is the only opinion introduced or ever presented. It seems to be a form of mental programming. Consider the ramifications of believing in the Big Bang. It makes use feel small in a randomly exploded universe that's 13.8 billion years old. We don't feel important as a fish that crawled out of pond scum to fornicate into a monkey. We don't like being considered a creatures from a black lagoon. We lose confidence in our humanity as a tiny cinder of a random cosmic detonation. The psychology of Big Bang controls our every outlook. It puts us on the outskirts of a spiraling arm, orbiting the center of a vacuous black hole eating every form of light without prejudice. And none of this can be directly observed. These secrets were scribed by the hands of an elite few in academia. What is the weight of their feather on your mind?
Halton Arp pulled up to the train tracks and shut off his motor. He could have made it across, but he wanted to feel the train's energy. He got out and sat on the hood of his Buick with his arms folded. Stillness settled across his mind as he saw the train approaching. A giant steel centipede of wheels and coal was barreling down the track and Halton was as cool as a cucumber. He understood the universe and closed his eyes as the doppler effect raised the pitch of the train whistle. He felt torque vibrating the road moments before a gush of wind smashed him in the face and kept pounding. He opened his eyes to a cold fast blur of metallic snake segments carving a thundering will through the atmosphere. Nothing can stop a train that's coming. Halton feels the rumble of passage in his kneecaps. The arthritis was killing him and he wanted to get home. The train was so loud he missed his cell phone ringing. There was a message waiting for him on his voicemail. He lost his job as the train was passing. He knew that call would come eventually. Halton didn't believe in Big Bang.
Big Bang cosmology is massively flawed. It contradicts itself in cosmic homogeneity. We see a universe of smooth peanut butter while a Big Bang model should look chunky. Our observation directly contradicts what we are taught yet the scientific community still enforces it. The Big Bang is cosmic dogma. The Big Bang is based on telescope red-shift measurements. Red shift is like the Doppler Effect of the train whistle but with starlight instead of sound. The pitch of the red shift determines the direction and momentum of its signal. It's why they think the universe exploded. It's how we measure its size, shape, and distance. The red-shift is the keystone of astrophysics and the cornerstone of Big Bang theory.
Deep past the northern wing of the Milky Way galaxy is a little known binary star system. The bigger star is sucking the tail out of the smaller star like a Frappuccino. Halton discovered these stars presenting a conflict of red shifts. They should be light years away from each other. Yet here they were, one drinking the other like a liquidated coconut. Halton added this image to his collection of 386 galaxies in his, Atlas of Peculiar Galaxies. His colleagues had finally had enough. They cleared their throats as they explained the observatory owed the scientific community an obligation to not squander the facilities' resources on claims that have little or no merit.
The Big Bang universe has always had a big weight problem. To compensate for the physics they invented a substance called dark matter. Big Banger's insist 96% of the universe is hidden in a veil of darkness. Dark matter or dark energy can only be perceived by a few elite theoreticians and each one's work depends on the accuracy of red shift. The clergy of academia is as rampant in astronomy as it was in climatology. How does a dark matter psychology change your experience? Do you feel more confident being told you only have 4% visibility?
How much does Big Bang's feather weigh on your mind as a belief? How small are we in an ever-expanding explosion? How weightless, rudderless and unimportant is a man in a soup that's 14 billion light years across and still spilling? Evolution is an expensive psychology in a cold vacuum that doesn't match our observations. So why is it such a large part of our programming?
Think of the weight of every feather placed on your mind by our programmers. Do you stand tall under a psychology of Big Bang? Beware the theory that makes you into a kernel of gruel in a dark cosmic spittle. You are a living Sequoia of breathing skin with feet. Let the moon see your fingertips reach for splendor. Unlock your psychology from the barrel of monkeys. Place yourself back in the center of a torus. Make this your universe and take its feather as your new psychology. How heavy is your mind now?
The Psyop of Relativity
The Litany of Space
The Vanderbilt Alters
Queen Lady Gaga
astronomy, big bang, cosmology, Halton Arp, psychology, Redshift, relativity
The Reptilian Space Pope
c0rrupti0nusa
This is great, love your writing! So… we're we going with this, what's your conclusion? Read some unsettling things recently – the stars aren't planets, just dots in the sky…
Quantum mechanics says the observer affects his/her reality.


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UK scientists have found a gene in mice that, if faulty, may increase the risk of ovarian cancer.
Mice lacking the gene were twice as likely to develop ovarian tumours, as well as showing signs of infertility, according to a new study.
If the gene has a similar role in humans, it could lead to new screening tests, say scientists at the London Research Institute, Cancer Research UK.
The study looked at a gene known as Helq, which is involved in repairing damaged DNA.
Mice lacking the gene were twice as likely to develop ovarian tumours compared with those with a normal copy.
Dr Simon Boulton, senior author from Cancer Research UK's London Research Institute, said: "Our findings show that if there are problems with the Helq gene in mice it increases the chance of them developing ovarian and other tumours.
"This is an exciting finding because this might also be true for women with errors in Helq, and the next step will be to see if this is the case.
Dr Julie Sharp, Cancer Research UK's senior science information manager, said the study pulled together clues from a series of experiments building a picture of cell faults that could lead to ovarian cancer in women.
Ovarian cancer is the fifth most common cancer in women in the UK.
About 7,000 women are diagnosed with ovarian cancer each year and about 4,300 die from the disease.
The lifetime risk of a woman developing cancer of the ovary is about 1 in 50, or 2%, but this may be higher in women with a strong family history of ovarian cancer, breast cancer, or both.