Russia rejects deadline for Annan's Syria peace plan

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Readers Respond to "The Death of Preschool"--and More

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DREAM STATES [More]

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Punishing Prometheus: Part IV - Machine or Transformation, We ...

Guest Post by Robert R. Sachs of?Fenwick & West LLP
Read?Part I;?Part II; and Part III.?

It seems like only yesterday the Court told us that the ?machine or transformation? test was ?a useful and important clue, an investigative tool, for determining whether some claimed inventions are processes under ? 101.? The Court?s reasoning suggested that while passing MoT was not necessary, it was still a sufficient condition for patent eligibility, and if nothing else indicated that the invention was not an abstract idea, law of nature, or natural phenomena.

Now, less than two years later, the Court diminishes the test further: ?we have neither said nor implied that the [machine-or-transformation] test trumps the ?law of nature? exclusion.? What this means in practice is that even if a claim satisfies the MoT test, it could still be deemed unpatentable subject matter, especially by a fact which follows this Court?s method of a) stripping claims down to ?instruction manual? glosses, and b) finding the presence of ?natural relations? to be dispositive evidence of a ?natural law? in the claim.

In short, before Prometheus, you could assert that your claim was patentable subject matter because it satisfied MoT. ?Now MoT does you little if any good?it?s gone from a sufficient condition to a mildly interesting one.

Standing Up for the Patent Bar

For some reason the Court seems to delight in denigrating the role of patent counsel in drafting claims, treating patent attorneys as either mere scriveners or crafty manipulators of words and phrases, clauses and conjunctions. ?Those cases warn us against interpreting patent statutes in ways that make patent eligibility depend simply on the draftsman?s art.?? Indeed, in calling patent attorneys draftmen, apparently the Court believes that all we do is make fancy pictures.?? Name me another legal discipline in which there is a special bar exam, not to mention to a requirement of an engineering or science degree.? What is it about patent law that makes the Court think we?re not lawyers??

Second, I ask you: what?s wrong with making patent eligibility depend on our skill?? The patent is a contract, a quid quo pro:? disclose the invention and in exchange obtain the exclusive right.? The patent act requires patents to recite claims that define the invention, the USPTO examines the claims, and infringement is based on the claims. The validity of every other legal document depends on the ?draftsman?s art,? upon the skill of the lawyer?just ask any licensing attorney, securities lawyer, or trusts and estate attorney.? Why are patent attorneys somehow not given the same level of recognition by the Court, that what we do is a legal activity, that claims are first and foremost legal definitions? That we are charged not just with describing the implementation of an invention to meet the legal test of an enabling disclosure?but with defining by way of a claim the ?metes and bounds? of the invention. ?We are trusted with carefully carving out a space for the broadest yet most precise statement of the invention, surrounded on all sides by the prior art, using nothing more than a single sentence. ?Where other legal writers suffer no consequence for employing laundry lists of verbs, nouns, adjectives?to throw in the kitchen sink of do not fold, spindle, mutilate, tear, shred, distort, etc.?we are compelled by case law to consider every word as critical. ?A misplaced comma, the use of ?the? instead of ?a,? ?at least one? instead of ?each,? can spell the difference between a patent worth millions and patent worth less than wallpaper. ?The California Civil Code includes a section of codified Maxims of Jurisprudence; my favorite is ?Superfluidity does not vitiate.?? True for every attorney but patent attorneys.? Show me another area of legal drafting that is as highly constrained in both form and substance as patent claim writing.

The Court also seems to think that inventors arrive at the patent attorney?s door step with their inventions fully formed, fully understood, and fully explained and explainable. In some cases, in some fields, that may be true?say for those funny hats with fans, beer cans, and scrolling LEDs. But for the majority of technologies, the patent attorney is an active and necessary participant in the creation of the patent and its value. Many inventors simply do not know what they have invented, they lack the framework for understanding their inventions, first in the context of the prior art, and second in the context of how the USPTO and the courts analyze inventions under the law. ?Senior patent attorneys often have significantly more exposure and breadth of experience in their particularly technology areas than the inventors that they advise. They combine their understanding of the patent law, the technology, and the business goals of the inventor to create something that did not previously exist: an intellectual property right. This is no mere scrivener?s recording, from the inventor?s lips to the patent examiner?s ear to the court?s gavel. ?This is legal counseling and crafting at its best.?

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Obstructive Sleep Apnea May Be Linked to Depression

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Garage Shelving ? Creative Ideas For Arranging Your Garage | Free ...

Garages offer ideal extra space for storage for a lot of homes all over the world . Although they are designed to place an automobile within, they are often employed to store surplus things from your home. No matter what you utilize your garage area for, finding the ideal garage shelving can help in organizing ones garage area. Far too frequently this useful area turns into a cluttered drop zone for everything that is spilling out of your home. The issue with the garage area being so chaotic can be quickly fixed, using the correct type of shelves.

Spending some time exploring the different types of storage out there, as well as selecting the style which will work best to suit your needs is the initial thing to complete. Locating the perfect shelving units for your garage will enable you to organize the space quickly. Simple garage area shelving is perfect if you only have a few things to store, while they aren?t designed for large items. Certain pieces of gear and tools have to be kept on the correct shelving; it will ensure that both the item and the garage don?t get damaged. You should attempt not to fill all the floor space with shelves and try to use both the walls and ceiling. Making use of these along with the floor is the ideal solution to your disorder issue.

Deciding on the best type of garage shelving for the walls will encourage the floor space for use for additional items rather than your clutter. There are many different shelves that are designed to be hung about the walls as well as ceiling. The material that you choose for your racks will often be based on your budget. Also the overall look of the garage will need to be considered, often the material of the shelves need not end up being top quality as people may rarely see it. The shelving can be made from plastic, wood or metal, and which one you choose will depend on the weight from the items becoming stored.

If there are higher ceilings in the storage then there are specially designed shelving models that hang from the roof. These enable you to hang, and place things on the shelving, allowing vital space on the floor to not be used. If you decide to match this design of shelves you will want to make sure they are not when it comes to the garage door mechanism. They will should also be installed securely, and also at the correct height often they may be adjusted to suit different needs. Often this design associated with shelving is made of metal, ensuring that it is stronger and strong.

Planning is essential when trying to find the correct shelving solutions for your garage. It can also be the ideal time for a clear out. Regardless of what shelving you use inside your garage you can be certain that it will give you several different benefits. Your storage will be tidier enabling you to discover items faster, and ultimately enabling you to make use of the space for that intended purpose of parking your vehicle. When arranging your garage correctly with the right garage shelving, it will likely be a multipurpose area, making your life easier.

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Top Articles World ? Major Causes And Herbal Remedies For ...

Erectile dysfunction or ED is reportedly the most common sexual dysfunction among men these days. If a man cannot get a penile erection during sexual encounter or cannot sustain the erection until the sexual act is over, he is said to suffer from ED. It can shatter a man?s self-confidence because he will come to feel that his manhood is draining out. A man with ED cannot engage in sex or lead a healthy sexual life.

The common causes of erectile dysfunction are:

1. Stress, anxiety and depression
2. Fatigue
3. Obesity
4. Smoking
5. Alcoholism
6. Drug abuse
7. Pelvic region injury or surgery
8. Spinal cord injury or surgery
9. Hostility with partner
10. Low testosterone
11. Radiation to the testicles
12. Medical conditions like hypertension, diabetes, stroke, high cholesterol, atherosclerosis, cardiac diseases, multiple sclerosis, Parkinson?s disease, Peyronie?s disease, prostatic hyperplasia.
13. Medications like antidepressants, analgesics, hypertension medicines.

Herbal remedies for erectile dysfunction:

1. Withania somnifera or Ashwagandha is an herb quite reputed for curing ED. It also checks stress and anxiety. Furthermore the herb increases the strength of muscles and nerves and promotes overall health. If one has a healthy mind and body his or her sexual performance will also improve.

2. Catuaba bark has aphrodisiac properties. This Brazilian herb is an effective herbal cure for erectile dysfunction and other sexual weaknesses

3. Gingko biloba is a great cure for ED. It stimulates blood flow to the male sex organs, gives rock-hard durable erections. It also increases sexual stamina.

4. Horny goat weed is an overall sexual enhancer. It improves blood flow to the male sex organ and allows the maintenance of the erection as long as the man wants.

5. Maca or Peruvian Viagra is notable for its aphrodisiac properties. It is a powerful solution to the problem of erectile dysfunction.

6. Yohimbe is an herb that has bagged FDA approval as a cure for erectile dysfunction. The sap of the Yohimbe bark actually does the miracle. It addresses both the physiological as well as psychological aspects of ED.

7. Tribulus Terrestris is an herb well known for energizing the genital area. Intake of the herb engorges the corpus cavernosa of the male sex organ with blood and gives hard, lengthy erections.

8. Saw Palmetto is a great herbal cure for ED. The juice of the herb can improve penile erection. Steady usage of this herb can eradicate this disorder completely.

So these are the herbal remedies for erectile dysfunction.

Read about Erectile Dysfunction Herbal Remedy. Also know effective Herbal Treatment for Male Impotence.

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Tags: erectile dysfunction herbal remedies, erectile dysfunction remedies, herbal remedies for erectile dysfunction

Source: http://www.toparticlesworld.com/major-causes-and-herbal-remedies-for-erectile-dysfunction/

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Looking for web marketing company in chicago | SEO

In today?s day and age, we all know the importance of web and therefore it is very vital that each and every business have an online presence. Today, almost 80% of people search on the search engines for the products and services they are interested in. People have gotten so busy with their hectic schedule, that no one really has time to go out and search for the right products and services they are interested in. Internet is a boon is such a scenario and people just surf on the internet and on the basis of the information they find on the net, they make the buying decision. In fact more and more people now are buying goods and services online and this number is increasing day by day. Therefore it is very important that every business owner has an online presence so that their business is put right in front of their target audience and gets business from them through online mediums. If you are looking for a company offering web marketing in Chicago, than you should take into account few things before you finalize the web marketing company in Chicago.

If you are not sure on how to get in touch with a web marketing company in Chicago, than simply type of the search engines ?Web Marketing Chicago? and you will come across whole list of web sites offering web marketing services. Browse through their web sites and if you like their service deliverables as well as their portfolio, than short list them. Set up a face to face meeting with these web marketing companies in Chicago. A good web marketing company will offer whole list of services such as Search Engine Optimization, Pay Per Click Marketing, Banner Advert, Social Media Marketing (Facebook Marketing, Blogging, Twitter, Video Marketing, Image Marketing, Social Bookmarking etc), Affiliate Marketing, Email Marketing, Comparison Shopping and Website Monitoring and Reporting.

When you meet the shortlisted company, ask them to take you through some of the projects they have done in the past. What all web sites they have done web marketing for, and what interesting things they have done for those web sites and the web presence they have gotten out of that. Also, it is very important to find out if they have worked in similar domain as your business is in.

Are you looking for companies offering web marketing in Chicago? Stoode is a leading web marketing company in Chicago which offers web marketing services at affordable rates.

Tags: Internet, WEB

Source: http://www.seogate.net/marketing/looking-web-marketing-company-chicago.html

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