By Dennis Crouch
In re Bimeda Research & Development (Fed. Cir. 2013)
Bovine mastitis is udderly problematic. Since so many folks now want to buy antibiotic free milk, dairy owners are looking for new ways to address the issue. Bimeda's patent relates to one solution that can be used during a "dry period" – typically prior to a cow giving birth. See U.S. Patent No. 6,506,400. The offered solution essentially involves painting-on a waxy physical barrier to protect the mammary teat canal during the dry period. These seals are not new, but Bimeda's revolution is that its seals do not include any antiinfectives. In 2009, a competitor (Merial Ltd., a Sanofi compani) filed an ex parte reexamination request.
During reexamination, Bimeda added several new claims including a new limitation that the physical barrier seal is made of "an acriflavine-free" formulation. Acriflavine is well known to folks skilled in the art as a treatment for mastitis. However, the original specification does not mention acriflavine. The result is that the PTO Board found the claim unpatentable for failing to comply with the written description requirement of 35 U.S.C. 112. On appeal, the Federal Circuit affirms.
The original patent application must disclose the invention being claimed – otherwise the claim fails the written description requirement and is unpatentable. Written description issues arise most often when a patentee changes claim language during prosecution (as here) and adds new limitations in order to avoid prior art. Written description is often seen as a "technicality" requirement because it applies even when the added limitation would have been easy for someone of skill in the art to add without further instructions in the application specification. The point of the requirement is to make sure that patents are only granted to cover subject matter actually invented.
Here, Bimeda argued that it should be able to add the acriflavine-free limitation because (1) acriflavine is an antiinfective and the application described formulations that were antiinfective free and, the exemplary embodiment (Example 1) described a formulation that was acriflavine-free. Now, to be clear, the example did not spell out that the formulation was "acriflavine-free." Rather, acriflavine was simply not in the list of ingredients.
On appeal the Federal Circuit reviewed the factual question of written description for substantial evidence. Thus, the PTO wins if it can show more a mere scintilla of evidence in support of its findings. The court easily found sufficient evidence.
In this case, the Board found, inter alia, that claim 32 failed the written description requirement because the disclosure did not "describe[] a formulation excluding a specific species of the anti-infective genus, while permitting others to be present." On appeal, Bimeda counters this finding by arguing that the disclosure broadly claims a teat seal formulation utilizing a physical barrier, yet does not expressly exclude any particular antiinfective agents. Bimeda interprets this as tacit indifference to the presence or absence of specific antiinfectives, and contends that the disclosure therefore supports a claim which excludes one particular antiinfective (such as acriflavine) but permits the use of others (such as antibiotics).
Substantial evidence supports the Board's contrary interpretation because the disclosure is generally inconsistent with a formulation which, like claim 32, excludes acriflavine but could include antibiotics.
Judge Clevenger drafted the opinion for the court. Chief Judge Rader also filed a short concurring opinion noting that the usual catchphrase of "possession" is not the correct way to think about written description. In particular, according to Rader, possession makes no sense here where the focus is on a negative limitation. He writes that "the Board places the patentee into a Catch-22: to satisfy written description, the patentee must show possession of something it specifically claims it does not possess." Here, Judge Rader suggested an important element in this case is the fact that Acriflavine is a "well-known species of antiinfective that [has] been used in teat seals to treat bovine mastitis for over 75 years." Along these lines, it makes sense that you could later claim a "wheat-free" bread invention based upon a disclosed bread recipe that includes a list of ingredients for making the bread and where wheat is missing from the ingredient list. Of course
Could the applicant have avoided this by simply incorporating the Encyclopedia Britannica by reference?
sirt,
You are going to wait nine days and post that?
I am embarrassed for you.
Whatever you say, Winston.
Pretty tree in the wrong forest Malcolm.
Care to say anything on point?
Quite in fact
I’m not sure where you picked this up but it’s not English and makes you sound like a t 0 0 l.
Your choice of examples rings once more of your ‘association’ with Malcolm.
Given how extensive his duplicity has been in regards to svckpuppets, it leaves one to wonder.
Plus, you attempt to misdirect by re-defining creepy independent of the propensity to ‘troll.’ Please put the goalposts back.
I will take it then that you acknowledge the fallacy of your first attempted logic and recognize that I am indeed NOT trolling you. Just like I said. You cannot logically have stalking and diversity.
You would be better off simply not trying to spin this.
Diversity – that’s pretty funny, anon.
OK, let me put this in terms that you can understand. Some anonymous guy is at the park every day and all day, sitting on a bench in your dirty trenchcoat and watching a diverse assortment of nine-year olds use the swing set. Several of those kids come by on a regular basis, say every two weeks. A few of them are the anonymous guy’s favorites, so he occasionally mutters something generally unintelligible about “cheerleader outfits” or “circles” as they pass by. Now, each of those kids is far more likely to encounter the anonymous guy on any given trip to the park than the anonymous guy is to encounter him on one of the anonymous guy’s trips to the park. But which is the (diversely) creepy one?
That you have no difficulty does not address the particulars of how and why the PHOSITA can have no iota of inventiveness AND still maintain common sense.
You have not explained why you have no difficulty, nor explained how the apparent contradiction is overcome.
Further, your comment regarding the difference in law between the US and what governs the patent system you are familiar with is a bit of a red herring. Unless you mean to say that the KSR decision was wrong, I cannot tell how you handle that case as it pertains to our discussion.
You are not applying the two edges of the sword correctly, MaxDrei.
The sword of PHOSITA is to be applied equally to the real person of the inventor as to the real person of the accused infringer.
When you have time, then, MaxDrie.
Here your views ring with credibility as you are discussing things within your realm, sans proselytizing. I quite enjoy these posts.
Your logic is fallacy Leopold.
You acknowledge my diversity and then claim I am stalking – you cannot have it both ways.
“I take it, independent of how much of the prior art corpus any particular player happens to have read or seen or heard?”
Yes.
We have been over the math on this before, Leopold – you are more likely to post in response to me than I in response to you – by several orders of magnitude.
I see your logic skills are right up there with your English skills. Since 50% of the comments on this site are yours, everybody is more likely to post in response to you than you to him, if you’re talking about the probabilities attached to a single post. The fact is, though, that you respond to very close to 100% of my comments, whether or not they are directed to you. I respond to maybe 1 or 2% of yours. The former is tantamount to stalking. The latter is merely an occasional lapse of good judgment.
It has to do with how they define their person of ordinary skill, and that their judges and tribunals appropriate that role to themselves, as required by the civil law system of law in Germany, which thus unfortunately blurs the distinction between true evidence and mere attorney argument. The English law jurisdictions can help them with that problem, I believe. (Conversely, Germany can help England, when it comes to who enjoys access to justice.)
No time now, for more than that.
Yeah, anon, I did wonder what “ordinary inventiveness” meant. Germany used to say that you need a higher level of inventive activity to defend your 20 year patent claims against validity attacks than you do those of your 10 year utility patent (Gebrauchsmuster). Perhaps Germany could comment on the meaning of an “ordinary” level of inventiveness?But fortunately for Europe, along came the EPO and now in Europe obviousness is a strict binary question.
That said, I have no difficulty ascribing to Fozzie BOTH common sense and zero inventive acumen. But then unlike you, I’m not subject to any SCOTUS binding precedent on what is meant by ordinary, obvious, common sense, or inventiveness.
Can’t legitimately opine on USA law but i can comment from a position in EPC-land.
Europe does not do triple dameages and sees no need for them, ever. It does do “innocent infringement” though. Mind you, if you are BMW you can’t credibly assert that defence against a claim you infringe an EPO patent in the field of cars.
The PHOSITA has the attributes of no real person. That is why so many non-patent professionals have such trouble with it. It is a legal construct to bring clarity to issues of patent validity. Deeming it to know everything requires no counterpart deeming of the state of knowledge of any one real individual. The accused infringer is a real individual, perhaps with 70,000 employees. No comparison, no 2-edged sword.
Should a government decide to distort the rules of free competition by installing a patent system, it is free to use it to promote the progress of useful arts in the way it thinks best, balancing trade secrets with incentives to patent in whatever way works best. Europe studied how the USA does it and then installed a system of absolute novelty and a right of continued use for those who bring innovation to industry without patenting it. Did it go wrong? As you know, I think not.
Interesting, please expound.
“but to be incapable of one iota of inventive thought”
How would you square KSR with that? Here, PHOSITA has common sense, and has the level of inventiveness that comes along with that common sense.
If you scrap even one iota of inventive thought, where lie common sense?
Notwithstanding the soapbox, good post MaxDrie.
(seriously, no snark intended)
Would you agree that the calculus regarding treble damages needs to be reconfigured in light of “Patent applications are supposed to be read?”
Let’s use a double edged sword – the first edge being that any person attempting to patent something is pre-supposed to have full knowledge of published work in their field. The second edge being that any person not attempting to patent something is pre-supposed to have full knowledge of published work in their field. (of course, a de facto result of this is that we START with the presumption of treble damages, then)
In all fairness, we would not want to treat those would share differently from those who would infringe, would we?
Something tells me that this will not sit will with those holding the Book of Infringer’s Rights.
OK Les, Fairness.
The EPO’s Supreme Court recognises the unfairness of squeezing the owner of a claim with prior art that he could not have known about. We call that earlier filed but later published art 54(3) art and against it you can disclaim freely, to re-establish novelty. Obviousness is not an issue, with 54(3) art.
But what about prior published art. You think Inventors wearing blinkers should get to issue while those who research the prior art should not. That’s not a very good way to Promote the Progress, is it. Patent applications are supposed to be read, as soon as they are A published.
In Europe we decide on prior art attacks objectively. Our PHOSITA is deemed to have read everything but to be incapable of one iota of inventive thought. You want objective (fair)findings on claim validity, I take it, independent of how much of the prior art corpus any particular player happens to have read or seen or heard?
No. I could go looking for it but, then again, so could you. Some Germans to this day still have a hard time keeping novelty and obviousness separate, for reasons connected with their domestic law of patents. It is a weakness that has to be bred out of them, I think.
“aside from the fact that he insists on following me from conversation to conversation”
We have been over the math on this before, Leopold – you are more likely to post in response to me than I in response to you – by several orders of magnitude.
It’s creepy how you employ the same twisted types of ‘logic’ as the one you are so apt to do cheerleading for.
Interesting MaxDrei, do you have any links to stuff by Heinz Bardehle?
I’m more interested in Fairness. And I have seen such things as insistence by the EPO on literal support for every word used in a claim lead to unjust decisions over and over. In a world where an inventor cannot be aware of every piece of prior art prior to filing an application, and where language is an imperfect tool, and where translation is an imperfect process, there needs to be some flexibility in the adjustment of claim language after the fact to allow an application to disavow or disclaim aspects of newly discovered (to the applicant) prior art.
Ah, so you’re still fretting about the 102(e)/103 rejection. Got it.
Regarding anon, the creepy part (aside from the fact that he insists on following me from conversation to conversation) is that he seems to think I understand his pseudo-English babbling.
To tell you the truth, LB, Heinz Bardehle was the one I had in mind, with his concept of “enhanced novelty”, conceived to bridge between Europe and the USA, on the prior art effect of earlier-filed but later-published, rival patent filings.
And right, LB, that from anon is not English and no other language either. He knows what he thinks (I guess) but is not capable of communicating it to others. Curious eh.
But this IS a blog, Leopold, and I am pretty sure you understand what I am saying (well, so much for your levity…)
Your post belies those with whom you are intimate (not sure any of those who typically charge at red capes would charge at that).
That’s not English, anon.
LOL – I wasn’t charging at MaxDrei…
Your post belies those with whom you are intimate (not sure any of those who typically charge at red capes would charge at that).
Come on, anon, give somebody else a chance to charge at the red cape of “MaxDrei said,” why don’t you?
“Who blurs the distinction between novelty and non-obviousness, Max?”
LOL – take a wild guess Leopold. Here’s a hint: “Whatever”
Who blurs the distinction between novelty and non-obviousness, Max?
Les in my example I deliberately left all that stuff open, so you could see that, in any particular real case, the answer on disclosure/novelty/priority/written description/added matter always is “It all depends”.
Obviousness is another thing entirely. Not black and white at all.
In Europe, because of Art 54(3) EPC, I can assure you that we are forced to be 100% clear on whether we are on novelty (etc) or obviousness. You might think that the EPC is a Looking Glass World but I do assure you that keeping rigorously distinct the concepts of novelty and non-obviousness 8as opposed to blurring the distinction) does wonders for the clarity of the law.
Fair enough Max. I accept that it is possible for a negative limitation to be new matter. But, I believe it to be unlikely.
For example, what was in the figures of your glove application. Where 5 fingers always shown or was there a figure showing only the thumb and first finger, implying the rest of the glove was could vary? What is the wording of the claim? Was it for a glove having at least two fingers, wherein at least two of the fingers have feature X? Or, was it for a glove? If it was for a glove, what is the definition of a glove? Must an item of clothing have 5 fingers for it to be considered a glove? If so, what are those things called that the Fagan was wearing in Oliver?
link to psecher.dk
Anyway, in your example, it seems to me we don’t need to get into all that, as a 103 rejection in view of Fagan et al. would suffice.
“I do not understand… do not try again”
Yup – there’s a mind open to understanding…
/eyeroll
Pretty soapbox MaxDrei.
Thanks anon, for giving me an opening, and for prompting me to clarify the matter with Les.
Here is what Les wrote:
“The inventor discovered that ABC alone works, described and claimed same but did not know that ABCD was prior art and could therefore not claim or described ABC and not D. Since the claimed and described combination did not include D, it is not and should not be considered new matter to later specify not D. One of ordinary skill in reading comprehension would have understood that the inventor had ABC and not D in his/her possession at the time of the invention since D was not mentioned as a component.”
Agreed?
In my concrete example, ABC is the glove with the pads X on the thumb, first and second finger. D is the 3rd and 4th finger sleeves, about which Les in his app as filed is silent. The prior art has ABCD so Les amends during prosecution to claim “ABC, but no D”.
Les, I do not see where my concrete example fails. Do you?
Your posting, anon, whether at 7:28 am or pm on August 1st, I simply do not understand. Do us all a favour though. Do not “Try Again”.
MaxDrei, your example falls to the same problem that Ned’s example had.
See my post at 7:28 (Aug 1).
Les suppose you disclose and claim a glove for the left hand with feature “X” on the pads of the thumb and first and second fingers. Perhaps a special glove useful when peeling potatoes.
Now suppose the PTO finds an earlier filing (PA1) for a glove with those same features. You respond with an amendment that specifies bare third and fourth fingers in your glove, and thereby gives your claim novelty over PA1. What would you need in your original application to render that amendment admissible. Perhaps, total silence about the 3rd and 4th fingers? Is it implicit that a glove leaves the 3rd and 4th fingers bare? Is that enough to render your amendment good for i) you ii) the USPTO and iii) the EPO?
Perhaps, but I’m not sure.
You seem to think that it is possible to disclose and claim A, B and C without mention of D and not clearly imply that D is not a required element.
I can’t think of an instance where failure to mention D nevertheless suggests the inclusion of D.
So, while I agree with your post above as written. What is left out is whether or not not mentioning D in the specification always implies that not D is at least an embodiment or not. I say it does, or at least usually does. And I say usually, only to be open minded. I can’t think of an example where it would.
link to free-translator.com
(and all who came after?)
link to juliesorganic.com
link to kentlaw.edu
link to patentlaw.typepad.com
link to wordsdomination.com
link to patentlyo.com
Thanks.
And feel free to repeat the same line (funny, McCracken went through this phase recently…)
Whatever you say, Winston.
Largely unoriginal anti-patent CRP that liberally quotes others from the anti-patent camp.
Credibility: Zero.
Off<>which confers no exclusion on prior art<>On
link to quno.org
(needs funny apps)
LOL, it is like you are attempting to play the male version of Sarah.
Your reference might be picked up if it were in the least way appropriate. What you are attempting, doesn’t even fit.
You should try some other angle.
LOL – I say join in with an intelligent comment anytime you feel like making some minimal effort, my friend, or just keep on mumbling to yourself and laughing at yourself.
Either way is fine with me.
Good luck, clown prince. “Obscure reference”. LOL.
What year were you born, 1984 or something?
Whatever you say, Winston.
Citing Lemley is a first strike…
Not being clear as to why you are linking to the article is a second.
Les, the test remains as to whether you could add the thing you are claiming to the specification without adding new matter. If you could add to the specification "not D," then you could claim "not D."
Les, Whether you could claim something depends on whether that something you claim is disclosed. If what you claim is not described in the specification, but implicit, and you could make explicit that which is implicit by an amendment to the specification without adding new matter, then you should be able to claim it.
Are we in agreement?
I do not understand the Davy Crockett explanation of the notion of an “intermediate generalisation”. So I will myself attempt one.
Consider the independent claim, in the application as filed, as a balloon that defines the periphery of the protected technology. Consider the Best Mode of the Detailed Description as a diamond within that balloon. Consider the independent claim after a prosecution amendment, as a balloon that is smaller than the original balloon, one that is wholly within the original balloon, one that still encloses the same diamond.
[[[[Up, down, right, left. in, out –
where is a connect, where there is a disconnect, etc.. ]]]]
ON<>which confers no exclusion(s) on prior art<>OFF
link to writtendescription.blogspot.com
Les,
Ned is obviously not following you and insists on talking about what he wants to talk about (which only on the surface is intersecting with your points).
See below Ned’s post at 8:03 and my pointing out how Ned is missing the boat at 7:28.
Also see my posts at 8:45/8:47 commenting on your views.
Might? No, No, I AM right. Admit it.
Then, admit that if I am right in this particular case, the blanket rule that will be established by this decision is wrong and the through the looking glass logic applied by the EPO is also wrong.
If inventors have to list everything not needed in there invention, applications will become very very long.
No. Not new matter. D was never mentioned. Clearly the invention did not include D. How is that not clear to you?
Thanks Ned, as my position has been steadfast and true, any closing of the gap in communication can be attributed to you moving closer to accepting what I have always posited.
The credit for such belongs to you.
I haven’t bothered with your obscure reference “said in reply.”
You think yourself clever, but you are not – you are a bore – at best. You just don’t even come close to any sort of ‘becoming.’
Whether or not the claim was found invalid has nothing to do with your arguments, which, quite in fact, are naked assertions and assume the conclusion to be proved. Rather than spend your time trying to think of clever references, spend it with basic legal logic.
Try to think substantive points rather than ‘flash.’ I realize that that is a bit old-fashioned, but since you want to paint yourself as older and presumably (albeit quite questionably) mature, you might recognize what that means.
Jeebus. Obscure references? What year were you born, 1984 or later, or what?
P.S. Have you figured out why you are Winston, yet?
Or are you still thrashing about encumbered by your deficient education?
“Did you see my comments below at 8:45/8:47? They address ”
Oh yes! I did! I did indeed! And they “address” precisely nothing.
Look – you’re obviously of at least average intelligence. The problem you seem to have is, you don’t realize what that means.
I don’t have any “naked assertions” nor am I “assuming the conclusion to be proved”. The claim was found invalid. Deal with it.
Or don’t – if you prefer to continue living in your little fantasy world. That’s fine, too.
But you’re fast becoming uninteresting, and I don’t even come around here all that much (I actually have real work to do – but apparently all your “major corporation” clients don’t care whether you do any work at all – what a gig! I’m quite envious of you…).
Later, Gator.
Les, you might be right because he did disclose a transfer function and that function did not have hysteresis. So, in the example, one might legitimately say “no hysteresis.” But if the transfer function was not disclosed, I would think the argument would have been harder.
anon, I think you and I are finally communicating for some reason.
anon, I was describing Lourie’s description of the original panel’s dissent.
Sent from Windows Mail
Max, the spec did not say“no hysteresis.” It did show a transfer function and that clearly was identical regardless of starting conditions. The claims were limited to a positive description of this transfer function rather than a negative description of a characteristic of the prior art.
Ned,
I do not think you realize just how close you are to the view that software is a patent elibile category with your post at 5:56.
All you have to do is realize what you said and remember that machine components – like rivets, tires and bullets – are patent eligible (as a category) in and of themselves as manufactures.
Anon, it depends on the context. In a circuit having an input and output, it makes no difference whether the math of the circuit is itself circuitry, or a programmed computer. The critical requirement is that the programmed computer is applied to a circuit having an input and output.
In a phone having an input and a display, it similarly makes no difference if the stuff in the middle is all hardware or a programmed computer.
“(as no-name also points out hereabouts, there is no duty to perform a search in the first place).”
Thanks “said in reply.”
Did you see my comments below at 8:45/8:47? They address what you are attempting to do here (use a single edged sword, and ASSume the very conclusion you want to have, that is “now having found”). You naked assertions of “pulling shenanigans” and “spurious” are likewise logically deficient as you are assuming the very conclusion to be proved (and quite disregarding any factual element of inherency – after all, the discussion is presuming that a new-matter rejection is not being made).
It explains nothing (other than you delight in obscure references).
It is a good day. Thanks.
CANARD ALERT:
“For an American, used to wearing down his Examiner with an endless stream of continuing applications, that can be a scary sobering thought.“
MaxDrei, you need to understand reality here in the U.S. There is no such thing as ‘wearing down an examiner.’ Cut and paste and mere repetion of responses are too real and too easy a way out. Just as (maube you realize this) in Europe, the US has a no-new-matter rule and an application properly examined at the get-go has no ‘fear,’ or concern for being ‘worn-down.’ You completely misapply (and show ignorance of) the just-get-it-right admonition.
That you deem yourself worthy to lecture me is hilarious given your oft repeated (what 80 reps?) of your apparent six months experience.
” If your position is correct, then all applications undergoing examination or patents undergoing reexamination are in peril because unforeseen prior art can turn up that cannot be circumvented without an exclusionary negative limitation.”
Hello AC. I understand what you mean. No search will ever be perfect, and (as no-name also points out hereabouts, there is no duty to perform a search in the first place).
However – turning exactly to what you write above, my thinking is that it is a good result if apps under examination right now are in peril due to unforeseen prior art.
That is to say, if what is in their specifications does not define over the prior art, then they don’t deserve a patent. If they can’t define over the prior art, they do not have an invention. Period.
And pulling shenanigans like throwing in a spurious negative limitation to circumvent the prior art should not entitle them to a patent on their (now having found to be a) non-invention.
“…Winston? “
Sheesh, what do they teach you kids in school today?
The fact that you need to ask about that transparent reference explains an awful lot.
Good day.
Well said, Fly. It should have occurred to me that it would have been at oral proceedings that Les got his experience of the EPO. Doubtless in a meeting the day before the Hearing he and his EPO rep found the claim amendment to fix the problem, and presented it for the first time the next day, at orals.
His attorney could do him a favour and draw his attention to the rule in the Implementing Regulations of the EPC that gives an Applicant just the one shot at amending in response to a communication from the Examining Division, with every attempt thereafter to introduce an amendment being subject to the “consent” of the Examining Division. For an American, used to wearing down his Examiner with an endless stream of continuing applications, that can be a scary sobering thought.
In these threads, attorneys are very quick to chastise PTO Examiners for not getting it right first time. But when the tables are turned, and they themselves are required to “get it right first time”, they (in the immortal words of Corporal Jones of Dad’s Army) “….don’t like it up ’em.”
link to en.wikipedia.org
LOL – are you saying that you do not have an anti-patent agenda, Malcolm?
(btw, anti-patent does include anti-business-method patent and anti-software patent).
Come now, what did you say? What? Can’t hear you.
LOL
LOL, are you making an admission Malcolm?
Seems like you want to, but just don’t have the nuts to actually do so outright.
I can see why, given your incessant QQ ing about svckies beign the ‘worst thing evah,’ and how this would (yet again) show you engaging in that which you accuse others of.
Truth hurts and it does in fact svck to be you.
“Give us all a f *cking break already” – that ‘us’ being the royal you and your svckies, right?
Tr 0llb0y: Stop trying to over-read the message
Pretty funny coming from the guy who habitually launches on people who he believes have “imputed” some nefarious aspect of the “anti-patent” agenda.
Another vacuous comment with more of your odd projected fantasies, Malcolm.
@ta boy.
“for a year now you’ve been bragging”
Not. Even. Close. Bub.
“which compels people”
LOL – what compels is that your agenda and self-serving posts are thrown into the spotlight. As I posted, truth hurts and it svcks to be you.
LOL – I see that you STILL have not actually answered the questions – and yes, we both know that they are you.
So Malcolm, why the dissembling? Why the hypocrisy?
hypocritically
Just for grins, Tr 0llb0y, let’s assume that when I post elswewhere on the Internet I don’t use the same pseudonym that I use here. Let’s go even further and assume that sometimes, on some blogs, I login with a different pseudoynm.
How in the f *ck does that make me a “hypocrite”? Are you that psychotically f *cked in the head that you think the only objection people had to your psycho behavior here where for years you posted repetitive insults twenty times a day using different names was that you didn’t always post under the same pseudonym? Really?
Give us all a f *cking break already.
PESKY WABBIT
you accuse me of 1ies and yet you have failed to produce any every single time I call you out on this. Once you attempted with misrepresentations which I shot down.
Of course you did, Tr 0llb0y.
Check the meds. I think you need to take two of those blue capsules, not just one.
You are the one that torched your own pet theory
Right, just like you torched your dad while he slept in the tent and told everyone that the fire was an “accident.” Sure, you caught him in bed with a woman who was not your mom but everyone knows your mom was drinking pretty heavily back then (she hit the bottle hard shortly after she had you).
I do enjoy this game, Tr 0llb0y. It’s about as much fun as a creative person like me can have conversing with a s0ci0pathological l y i n g —h*le like you.
I look forward to playing again. As always, I’ll wait for you to make the first move.