Category Name

Trademark Modernization Act

In an effort to help combat an increase in fraudulent trademark filings and registrations, the Trademark Modernization Act of 2020 (TMA) was signed into law on December 27, 202. The TMA addresses improper use claims and fake or doctored specimen submissions for trademarks by providing new mechanisms for challenging trademark applications and registrations on non-use grounds. The TMA also addresses the enforcement of trademark registrations by making it easier for trademark registrants to obtain injunction relief against alleged infringers. Letter of Protest Third parties may challenge a pending trademark application before that application is published for opposition by submitting a letter of protest to the USPTO. A Letter of Protest enables a third party to submit evidence that supports a ground for refusing registration of another party’s pending trademark. This submission differs from a conventional trademark opposition, which is filed during the thirty days that the application is published for opposition. Unfortunately, the Letter of Protest process has been underutilized due to the USPTO not having a formal process for submitting and reviewing Letters of Protest. The TMA tasks the Director of the USPTO to develop formalized processes for submitting and evaluating evidence by third parties supporting the refusal of another party’s pending trademark application. The Director is tasked with establishing these processes within a year. Once the USPTO formalizes the processes for submitting and evaluating Letters of Protest, trademark watch services that provide trademark owners with notice of potentially conflicting trademark applications will become even more critical. Ex Parte Expungement and Reexamination Proceedings In contrast to other countries, the US requires submission of a sworn statement of use that includes a first use date and a specimen demonstrating use of the mark for the defined goods and services before a trademark registration will issue.  A significant problem for the USPTO and legitimate trademark owners has been false assertions of use and fake specimens of use. The TMA established the new Expungement and Reexamination procedures to help alleviate some of these problems. Currently, inter parte Cancellation proceedings allow for petitions before the Trademark Trial and Appeal Board (TTAB) to cancel trademark registrations for abandonment or lack of use. This proceeding is similar to court litigation in that both the petitioner and the trademark owner must engage in the proceedings in an attempt to prove their case before the TTAB. The new ex parte Expungement and Reexamination Proceedings may also be used to petition to cancel a trademark registration for lack of use. However, in contrast to existing Cancellation proceedings, the petitioner will not continue to engage after filing the petition with the USPTO Director. Also, the USPTO Director has discretion on the commencement of either the Expungement and Reexamination Proceeding. The ex parte Expungement Proceeding provides for third-party filing of a petition for an expungement of a trademark registration on the ground that the trademark was never used in US commerce. A petition for expungement cannot be brought until three years after the registration’s issuance and remain available for the registration’s lifetime. The Reexamination Proceeding provides for third party filing of a petition for a reexamination of the trademark registration on the ground that the trademark was not used in US commerce before its relevant date, the relevant date being either the filing date of a use-based application or the statement of use date of an intent-to-use application. A petition for reexamination must be brought within five years of the registration’s issuance.  In both proceedings, the petitioning party must raise relevant arguments, submit supporting proofs, and pay a fee. The USPTO Director will decide whether or not a proceeding will be instituted. The USPTO Director may also commence both proceedings on his or her initiative. If a proceeding is initiated, the registrant may respond with evidence demonstrating the trademark’s use for the subject goods and services or that the non-use is excusable. Restoring Presumption of Irreparable Harm Preliminary injunctions are a valuable tool for trademark owners when combating trademark infringement. The TMA resolves a circuit split as to the standard for issuing preliminary injunctions in trademark infringement, cybersquatting, and false advertising matters. A showing that a trademark owner will suffer irreparable harm is a requirement for preliminary injunctions and other injunctive relief. The TMA restores the presumption that a trademark owner will suffer irreparable harm when either trademark infringement is found or it is shown a likelihood of success of prevailing on the merits in a preliminary injunction context. With this legislation, the TMA has restored a necessary element for trademark owners seeking injunctive relief from infringement of their trademark.

Continue Reading
Category Name

TEACHING AWAY AND MOTIVATION TO COMBINE

Teaching away and motivation to combine are defenses that may be used to help overcome an obviousness-type rejection of claims in a patent or patent application. In General Electric Company v. Raytheon Technologies Corporation, General Electric (GE) appealed a decision by the Patent and Appeal Board (Board) that a patent for a two-stage turbine engine owned by Raytheon Technologies (Raytheon) was nonobvious. GE argued to the Board that the patent was obvious over the combination of two references, Wendus and Moxon. Wendus teaches a one-stage high-pressure turbine. Moxon teaches that a transition from a two-stage design to a single-stage design is unlikely because of the increased performance demands required to improve a single-stage turbine engine’s fuel efficiency. The Board held that Wendus taught away from a combination with Moxon and that the evidence presented as a whole did not demonstrate a motivation to combine the two references. In its appeal before the Court of Appels (Court), GE challenged the Board’s legal standard for both teaching away and motivation to combine as applied in its nonobvious holding. According to the Board, Wendus taught away from a combination with Moxon because it expressly considered at least some of the tradeoffs between one-stage and two-stage designs and specifically chose the one-stage design. In reviewing the Board’s application of teaching away, the Court stated that “a reference does not teach away if it merely expresses a general preference for an alternative invention but does not criticize, discredit, or otherwise discourage investigation into the invention claimed.” The Court explained that Wendus did not make a single negative statement about the use of a two-stage high-pressure turbine. Rather, Wendus teaches that a one-stage turbine might be lighter and cheaper to manufacture and maintain than a two-stage turbine. However, teaching that a specific design may be optimal or standard for a defined set of criteria does not criticize, discredit, or otherwise discourage investigation into other designs. A such, the Court held that Wendus did not teach away from a combination with Moxon. According to the Board, because Wendus specifically chose a one-stage design, the evidence presented in the proceeding as a whole could not persuasively demonstrate a motivation to modify. The Court noted that its precedent does not require that the motivation to combine be the best option but rather only a suitable option from which the prior art does not teach away. Rather, “any need or problem known in the field of endeavor at the time of invention and addressed by the patent can provide a reason for combining the elements in the manner claimed.” Also, a design preference might have simultaneous advantages and disadvantages which do not necessarily obviate a motivation to combine. As such, the Court held that the Board lacked substantial evidence for its conclusion that GE did not establish a motivation to combine the references. The Court further held that it did not matter that GE did not explain why an artisan would be motivated to use each element disclosed in Wendus. That Wendus treats each of the disclosed elements as desirable was enough to motivate an artisan to combine them with a two-stage turbine, as long as the artisan believed there was a reasonable likelihood that the combination would succeed. In prosecuting a patent application or enforcing an issued patent, it is important to understand how these defenses may be applied effectively against an obviousness-type rejection. Contact John C. Laurence Law Today Why hire a patent attorney? The answer is simple: to help you protect your business. John C. Laurence is experienced in developing, prosecuting, and enforcing patent rights. He understands the patent process, leverages your patent to earn money for you, and protect your patent from infringement. If you have questions about patent rights and how to move forward, contact John C. Laurence Law online or at 917-997-9967 for your free consultation.

Continue Reading
Trademarks

When You Should Consider Hiring A Trademark Attorney

If you are an inventor or business owner, you probably take great pride in your invention or business. But merely having an invention or a company isn’t all it takes to have a successful business. Building your brand is crucial to the future growth and success of your business. Thus, it is important to start thinking about what you can do to build and protect your brand. But how do you go about doing that? One great way to do so is to begin the process of registering a trademark. A trademark is a fantastic way to set yourself apart from other competing companies. By registering a trademark, you can help potential consumers distinguish your company from the rest. This, in turn, will allow you to more effectively further the success of your business. If you have not yet registered a trademark for your company, it may be time to hire a trademark attorney. Even though you can technically complete a trademark application on your own, the process of registration is not always simple. The benefits of having a trademark lawyer to help guide you through the complexities of the registration process cannot be overstated. If you want to know more about the trademark registration process and how a trademark attorney can help you, contact John C. Laurence Law, PLLC, today. Trademark attorney John C. Laurence has dedicated his practice to helping businesses protect their brands, and he will fight to do the same for you. What Is a Trademark? The United States Patent and Trademark Office (USPTO) defines a trademark as a word, phrase, symbol, and/or design that identifies and distinguishes the source of the goods of one party from those of another party. Common examples of things you can trademark include: Logos, Slogans, Product names, and Brand names. If you want to set your invention or brand apart from others on the market, a trademark is a great place to start. Benefits of Registering Your Trademark You can actually acquire a trademark automatically by using the mark in “commerce” in connection with your goods or services. However, taking the steps to register your trademark with your state or the USPTO also provides you with additional advantages. Some of these advantages include: Presumed ownership of the mark in the event a dispute arises; Notice to other parties that you own the mark; Exclusive right to use the mark statewide and nationwide; Rights to prevent others from using the mark; and Enforcement rights against others who do use the mark. A trademark does more than just set your brand apart. A properly registered trademark can help you protect and expand the reach of your brand. Are Trademarks Different from Patents or Copyrights? Yes, definitely. Patents, trademarks, and copyrights all fall under the general umbrella of intellectual property (IP). However, each one protects separate and distinct rights.  Another distinction between these types of IP is the duration of protection. Unlike patents and copyrights, trademark rights last forever as long as you continue to use the trademark in commerce, make required periodic filings, and pay the requisite fees. Why Hire a Trademark Attorney? So if you can file a trademark application on your own, you might be wondering, Why hire a trademark attorney at all? It might seem tempting to go ahead and file on your own in an attempt to save money on hiring an attorney. However, hiring an experienced trademark attorney can be a great benefit that can actually save you time and money in the long run. Assistance with Pre-Registration Trademark Clearance Search Before you register a trademark, it is important to do a preliminary check for other marks that already exist that may be similar to the one you’re considering. Otherwise, you risk applying for a mark that could potentially be blocked from registration due to similarities to an existing mark. A trademark attorney can conduct a comprehensive clearance search for trademarks in the USPTO database that may conflict with yours. These types of precursory searches can prevent costly litigation down the line arising out of disputes where another company alleges your trademark is so similar to their own that you are creating confusion within the marketplace. Application Process After confirming there are no similar marks already registered, a trademark attorney can help prepare your trademark application. The USPTO has complex requirements that must be met before your trademark application can be accepted. In some cases, the USPTO may issue  an “office action” with questions, requests for clarifications, or a rejection of  your proposed mark. An attorney can prepare responses to an office action to address any potential issues that are raised by the examiner. Trademark attorneys are used to going through this application process and can help you ensure that you take all of the appropriate steps to  maximize the possibility of your nark being registered. Post-Registration After you register your trademark, this is not the end of the road for your brand. It is your responsibility to monitor the use of your trademark in the marketplace. Understandably, most business owners are more concerned about operating their business than monitoring whether other people are using their trademark. However, this is still important to ensuring that others are not diluting the strength of the brand you’ve built. This is another function that  a trademark attorney can help with. A trademark attorney can monitor new filings with the USPTO, keep track of any unauthorized use of your trademark by other entities, and advise you on the best ways to enforce your trademark rights and prevent further infringement by the other  parties. Additionally, the USPTO requires you to renew your trademark registration after the fifth from registration and every 10 years after that . A trademark attorney can ensure that all the required documents are filed accurately and in a timely manner so your trademark registration will not lapse. Instead of policing the use of your trademark and keeping up with these periodic filings, let an attorney take these things […]

Continue Reading
Patents

Canada Rejects Problem-Solution Approach for Computer Implemented Patent

The Canadian Federal Court has rejected the problem-solution approach as adopted by the Canadian Intellectual Property Office (CIPO) for assessing patentable subject matter in favor of the purposive constructive approach as set out in the Whirlpool and Free World Trust cases. In Choueifaty v. Canada, representative independent claim 1 reads as follows: “A computer-implemented method for providing an anti-benchmark portfolio, the method comprising: acquiring, using a computer system, data regarding a first group of securities in a first portfolio, wherein the computer system comprises a computer processor and memory coupled to said processor, identifying, using a computer system, a second group of securities to be included in a second portfolio based on said data and on risk characteristics of said second group of securities, and providing, using a computer system, the individual weightings for each of the securities in said second portfolio according to one or more portfolio optimization procedures that maximizes the anti-benchmark ratio for the second portfolio wherein the anti-benchmark ratio is represented by the quotient of: a numerator comprising an inner product of a row vector of holdings in said second portfolio and a column vector of a risk characteristic of return associated with said holdings in said second portfolio; and a denominator comprising the square root of a scalar formed by an inner product of said row vector of said holdings in said second portfolio and a product of a covariance matrix and a column vector of said holdings of said second portfolio.” Under Section 2 of the Patent Act, only those elements in a claim identified as essential may be considered in determining whether the subject matter of that claim qualifies as an “invention.” Under the problem-solution approach, only those claim elements that solve an identified problem may be defined as “essential.” Using this approach, it was determined that the representative claim’s “essential” elements were “directed to a scheme or rules involving mere calculations” for weighing securities. It was further determined that these “essential” elements reflected an “optimization procedure” and not a “computer implementation.” As such, the claim was found to be non-statutory. Under the purposive constructive approach, a claim element is “essential” if (1) modifying or substituting that element changes the way the invention works and (2) the intention of the inventor, considering the express language of the claim, or inferred from it, is that the element is “essential.” Accordingly, unlike the problem-solution approach, the purposive constructive approach does not require that “essential” elements of a claim solve an identified problem. While Choueifaty may be appealed, it may provide some clarity for patent applications in Canada that claim a computer implemented method.

Continue Reading
Patents

The Intersection of Trade Secrets and Patents

A federal court in New Orleans has allowed a trade secret claim to proceed to trial, even though the alleged trade secrets were disclosed in a patent application. Cajun Servs. Unlimited, LLC v. Benton Energy Serv. Co., No. 17-0491 (R. Doc. 241). The lawsuit concerns Cajun’s patented elevator roller insert system (ERIS), which is a technology used in drilling for oil. Before filing its patent application, Cajun agreed to rent ERIS to Benton Energy. While renting ERIS, Benton Energy hired a third party to reverse engineer ERIS, using drawings and prototypes supplied with the rented system. Cajun eventually filed its patent application for ERIS while still renting the system to Denton Energy. Cajun initially brought claims for trade secret theft and unfair trade practices. Once a patent was granted for ERIS, Cajun added a patent infringement claim against Benton Energy. In response, Benton Energy filed a summary judgment motion on Cajun’s trade secret claims. Benton Energy attempted to argue that trade secret claims failed as a matter of law because Cajun publicly disclosed the ERIS technology in its patent application. That is, the information could not be a trade secret because it was no longer a “secret” since it was disclosed in the patent application. The court disagreed. It noted that “publication of the ‘862 Patent application does not deprive Plaintiffs of a cause of action for misappropriation of trade secrets before the patent application was published.” In other words, the subsequent patent application did not absolve Benton Energy from liability for any misappropriation that occurred before the patent publication. A non-provisional patent application in the U.S. is normally published eighteen months after its earliest priority date. A non-publication request may be made to prevent publication of the non-provisional application. This holding confirms that before publication, the information disclosed in a patent application may still be afforded trade secret protection. If you need assistance with a patent application, please contact an experienced patent lawyer.

Continue Reading
Patents

Protecting Individual Replacement Parts

In Automotive Body Parts Ass’n v. Ford Global Techs. (Fed. Cir. 2019), Ford accused the Automotive Body Parts Association (ABPA) of infringing Ford’s design patents that cover individual parts of Ford’s F-150 truck. The ABPA argued that the patented designs are functional. ABPA further argued the application of doctrines of exhaustion and repair to these patented designs. The design patent D489,299, titled “Exterior of Vehicle Hood,” claims “[t]he ornamental design for exterior of vehicle hood,” as shown in Figure 1 below. The design patent D501,685, titled “Vehicle Head Lamp,” claims “[t]he ornamental design for a vehicle headlamp, as shown below in Figures 1 and 2. A design patent must be directed to an “ornamental design for an article of manufacture” and not one “dictated by function.” High Point Design LLC v. Buyers Direct, Inc., 730 F.3d 1301, 1315 (Fed. Cir. 2013) (interpreting 35 U.S.C. § 171(a)). Although the article of manufacture itself is typically functional, the protected design elements themselves may not be “primarily functional.” As to functionality, ABPA states that consumers seeking replacement parts prefer hoods and headlamps that restore the original appearance of their vehicles. As such, ABPA concludes that there is a functional benefit to designs that are aesthetically compatible with those vehicles. Specifically, ABPA argues that Ford’s protected hood and headlamp designs are functional because they aesthetically match the F-150 truck. The Court disagreed with the ABPA’s functionality arguments. Specifically, the Court held that even in the context of a consumer’s preference for a particular design to match other parts of a whole, the aesthetic appeal of a design to consumers is inadequate to render that design functional. As to exhaustion, ABPA asserts that the sale of an F-150 truck exhausts any design patents embodied in the truck and permits use of Ford’s designs on replacement parts so long as those parts are intended for use with Ford’s trucks. The Court declined to apply exhaustion to the protected hood and headlamp designs sold by a third party as replacement parts, the Court noting that exhaustion attaches only to items embodying the protected designs sold by, or with the authorization of, the patentee. As to the right or repair, ABPA argues that purchasers of Ford’s F-150 trucks are licensed to repair those trucks using replacement parts that embody Ford’s hood and headlamp design patents. The Court also rejected ABPA repair argument noting that the right of repair does not permit a complete reconstruction of a patented device or component. As such, a purchaser may replace “individual unpatented component” of the patented article but does not permit the purchaser to infringe other patents by manufacturing separate patented components of the purchased article. Accordingly, the new hoods and headlamps in question are subject to Ford’s design patents, and manufacturing new copies of those designs constitutes infringement. This decision reinforces the use of design patents to protect the manufacturer of individual replacement parts to be used in a purchased article.

Continue Reading
Trademarks

U.S. Licensed Attorney Requirement for Foreign Trademark Applicants and Registrants

The USPTO has amended the Rules of Practice in Trademark Cases to require applicants, registrants, or parties to a trademark proceeding whose domicile is not located in the United States or its territories to be represented by an attorney who is in an active member in good standing of the bar of a state in the United States. A stated purpose of the rule change is to instill greater confidence in the public that U.S. trademark registrations that issue to foreign applicants are not subject to invalidation for reasons such as improper signatures and use claims. Another stated purpose is to enable the USPTO to more effectively use available mechanisms to enforce foreign applicant compliance with statutory and regulatory requirements in trademark matters. The rule change is effective on August 3, 2019.

Continue Reading
Trademarks

Supreme Court Finds Bar on Scandalous and Immoral Trademarks Unconstitutional

The Supreme Court has upheld the Federal Circuit’s decision in In re Brunetti, 877 F.3d 1330 (Fed. Cir. 2017) holding that the provision of the Lanham Act that bars the registration of “immoral or scandalous” trademarks violates the First Amendment. Iancu v. Brunetti, No. 18-302, 6/24/2019. The trademark at issue is the mark “F U C T” which Brunetti uses for a clothing line. The Patent and Trademark Office (“PTO”) barred registration of this mark as being “immoral or scandalous” as required by the Lanham Act, categorizing “F U C T” as “a total vulgar,” “extremely offensive” and “therefore unregistrable” mark. Brunetti appealed the rejection. In Matal v Tam (2017), a parallel provision of the Lanham Act that bars registration of disparaging marks was found unconstitutional as being viewpoint based. Similarly, the key question here is whether the “immoral or scandalous” provision is viewpoint neutral or viewpoint based. The Court found the “immoral or scandalous” provision viewpoint based. Specifically, the Court noted that the Lanham Act “permits registration of marks that champion society’s sense of rectitude and morality, but not marks that denigrate those concepts” and that it “allows registration of marks when their messages accord with, but not when their messages defy, society’s sense of decency or propriety.” As such, the Court held that “put the pair of overlapping terms together and the statute, on its face, distinguishes between two opposed sets of ideas: those aligned with conventional moral standards and those hostile to them; those inducing societal nods of approval and those provoking offense and condemnation.” As such, the Court ruled that the Lanham Act’s ban on federal registration of “immoral or scandalous” trademarks is unconstitutional under the First Amendment. In a concurring opinion, Justice Alito noted that the Court’s “decision does not prevent Congress from adopting a more carefully focused statute that precludes the registration of marks containing vulgar terms that play no real part in the expression of ideas.”

Continue Reading
Patents

Predictability and Criticality as Factors in the Evaluation of a Patent Specification

The Court of Appeals vacated the decision of the Patent Trial and Appeal Board in In Re Global IP Holdings (Fed. Cir. 2019), instructing the Board to include predictability and criticality as factors to consider in determining whether Global IP’s written description satisfies the proper legal standard. Global IP filed a reissue application in U.S. Patent No. 8,690,233 to replace the term “thermoplastic” with “plastic” in three independent claims. In the reissue application, the inventor filed a declaration that, at the time of the invention, he was aware of the use of plastics other than thermoplastics for the formation of a sandwich-type composite panel with a cellular core. The Examiner rejected Global’s reissue claims finding that “the specification only supports thermoplastics“ and that Global “cannot claim the full range of plastics, which would include thermosetting as well as thermoplastics” thereby introducing new matter. The Board affirmed the Examiner’s rejection explaining that “regardless of the predictability of results of substituting alternatives, or the actual criticality of thermoplastics in the overall invention, [Globla’s] Specification, as a whole, indicates to one skilled in the art that the inventors have possession only of the skins and core comprising specifically thermoplastics.” The Court held that the Board was mistaken in its legal analysis of whether Global’s specification complies with the written description requirement. The Court stated that “the level of detail required to satisfy the written description requirement varies depending on the nature and scope of the claims and on the complexity and predictability of the relevant technology.” The Court further stated that, in addition to predictability, the criticality or importance of an unclaimed limitation to the invention can be relevant to the written description inquiry. Accordingly, a variation that is predictable to a person of ordinary skill in the art is more likely to be covered by a specification. Moreover, variations of a non-critical component of the invention are more likely to be covered by the specification.

Continue Reading
Trademarks

Bankruptcy and Trademark License Agreements

In Mission Product Holdings, Inc. v Tempnology, LLC (Supreme Court 2019), the Supreme Court addressed whether a rejection by a licensor in a bankruptcy proceeding “terminates rights of the licensee that would survive the licensor’s breach under applicable nonbankruptcy law.” The Supreme Court answered no to this question, holding that a rejection breaches a contract but does not rescind it. Tempnology entered into an agreement with Mission that granted Mission a non-exclusive license to use Tempnology’s Coolcore trademarks. Before the expiration of this agreement, Tempnology filed for Chapter 11 bankruptcy and asked the Bankruptcy Court to allow it to reject this agreement. The Bankruptcy Court approved the rejection, which meant that Tempnology could stop performing under the agreement and that Mission could assert a claim for damages resulting from Tempnology’s nonperformance. The Bankruptcy Court also agreed with Tempnology’s assertion that under a traditional view of Section 365 of the Bankruptcy Code, this rejection also terminated the rights it had granted Mission to use the Coolcore trademarks. The Bankruptcy Appellate Panel reversed this holding based on a prior decision by the Court of Appeals for the Seventh Circuit that held that rejection of a contract “constitutes a breach” of that contract. The Appellate Panel explained that outside of bankruptcy, the breach of an agreement does not eliminate those rights that the agreement had already conferred on the non-breaching party. The Court of Appeals for the First Circuit rejected the Appellate Panel’s decision and reinstated the Bankruptcy Court’s decision terminating Mission’s trademark license. The Court of Appeals reasoned that special features of trademark law required that the trademark license be terminated. Specifically, the majority reasoned that if a licensee can keep using a mark after an agreement’s rejection, the licensor will need to carry on its monitoring activities which would frustrate the principal aim of a rejection — namely, to release the debtor’s estate from burdensome obligations. The Supreme Court rejected the Court of Appeals reasoning holding that a rejection breaches a contract but does not rescind it. The Supreme Court noted that according to the plain language of Section 365, a rejection “constitutes a breach of a contract,” deemed to have occurred “immediately before the date of the filing of the petition.” The Supreme Court further noted that Section 365 reflects a general bankruptcy rule that the estate cannot possess anything more than the debtor itself did outside bankruptcy. This rule prevents a debtor in bankruptcy from recapturing interests it had given up, namely the rights to the trademark license. Tempnology’s main argument rested on the negative inference drawn from the fact that Section 365(n) provides that licensees of some intellectual property rights retain contractual rights after rejection. The specific intellectual property rights including patents but do not trademarks. In response, the Supreme Court noted that in enacting Section 365(n), Congress did nothing to alter the natural reading of Section 365 that rejection and breach have the same result. Tempnology also argued that a trademark licensor’s duty to monitor and “exercise quality control over the goods and services sold” required that rejection of the agreement also revoke the trademark license. The Supreme Court noted that in allowing rejection of an agreement, Section 365 does not grant the debtor an exemption from all the burdens that generally applicable law, including contracts and trademarks, imposes on property owners. This ruling changes the traditional view of bankruptcy and emphasizes the need to clearly define in the trademark license agreement what happens to trademark license rights under various circumstances, including bankruptcy.

Continue Reading