Chia-Yu Chang @ Law, P.C. 315 W. 70th Street, #12L New York, NY 10023
(212)769-1756 cychang at cychanglaw dot com
Chia-Yu Chang is an attorney admitted to practice in NY and before USPTO, and practices primarily in intellectual property (patent, trademark, copyright, trade secret), corporation, commercial transaction, finance, and estate planning. Before joining the legal profession, Chia-Yu was a fixed-income research analyst with Salomon Brothers. He holds a BS degree in geology from National Taiwan University, MS degrees from Indiana University and Columbia University, and a JD degree from Benjamin N. Cardozo School of Law. On the personal side, Chia-Yu has practiced Tai-Chi for over 20 years, and is currently learning Taiko drumming.
The Inevitable, But IMPORTANT, Disclaimer
All the materials presented in this web site are for information only. They are not legal advices.
© 2005-Present Chia-Yu Chang.
Friday, July 14. 2017
- Easier said than done
"Free expression is the base of human rights, the root of human nature and the mother of truth. To kill free speech is to insult human rights, to stifle human nature and to suppress truth." - Liu Xio Bo, Chinese dissident.
"But when men have realized that time has upset many fighting faiths, they may come to believe even more than they believe the very foundations of their own conduct that the ultimate good desired is better reached by free trade in ideas -- that the best test of truth is the power of the thought to get itself accepted in the competition of the market, and that truth is the only ground upon which their wishes safely can be carried out." Oliver Wendell Holmes, US Supreme Court Justice in his dissent in Abrams v. United States.
It is often the dissidents or dissenters who champion freedom of speech. The powers often resent or repress speeches. It's human nature! That is why a system of check and balance is fundamental and essential to democracy and freedom of speech, no matter how we define the terms!
Tuesday, July 19. 2016
- Because liberty is not a given
"Turkey coup: Purge widens to education sector." http://www.bbc.com/news/world-europe-36838347
"More than 15,000 education staff in Turkey have been suspended after last week's failed coup, as a purge of state officials widens still further."
"More than 1,500 university deans have also been ordered to resign and the licences of 21,000 teachers working at private institutions revoked."
"The army, judiciary, security and civil service have all been targeted following Friday's coup attempt:
"The removal of thousands of officials has alarmed international observers, with the UN urging Turkey to uphold the rule of law and defend human rights."
"The President of the European Parliament, Martin Schulz, has accused Turkey of carrying out "revenge" against its opponents and critics."
Thursday, July 24. 2014
- A work in progress
On 7/17/2014, the Department of Financial Services of the State of New York published a draft of its long-awaited proposal to regulate Bitcoin and other decentralized virtual currencies. The proposed rules was officially published on 7/23/2014, beginning a 45-day comment period before the rules can be finalized.
In essence, the proposed regulations require certain participants in virtual currency activities to apply for a license, and adopt a regulatory framework that combines 6 main component areas: License Application, Consumer Protection, Anti-Money Laundering, Cyber Security, Business Operation, and Records, Reports, & Examination. The table below groups each of the 18 sections of the proposed regulations (except Section 200.1 Introduction, Section 200.2 Definitions, & Section 200.21 Transitional period) into the 6 main component areas.
Note that in the existing regulatory schemes for NY financial service sectors, separate anti-money laundering rules apply to non-banks, such as check cashers or money transmitters, and to banks. By including a separate set of anti-money laundering rules for virtual currencies (in addition to the other component areas), the NY DFS has placed the sector in a distinct category on the same standing as money transmitters, or banks.
Therefore, one can hope that such a regulatory framework can accelerate the acceptance of decentralized virtual currencies as a legitimate financial sector, similar to money transmitters or banks. Such benefits aside, however, the proposed regulations do raise some concerns, particularly the high costs of compliance, the lack of exemptions for small businesses, the broad scope of the definition of virtual currency business activities, the 100% reserve requirement, and the permissible investments for retained earning. These and other potential issues, some of them gathered from internet sources, are briefly summarized in the table below.
Just like any new statutory or regulatory framework, the Bitcoin regulations proposed by NY DFS are a work in progress. It remains to be seen whether and how the final regulations will deviate significantly from the proposed ones. Given that the public has been given the minimally required comment period of 45 days, however, no major revisions are expected.
Wednesday, June 4. 2014
- Because liberty is not a given
94 Search Terms That China Bans Because Of Tiananmen Square (http://www.businessinsider.com/words-china-banned-from-search-engines-after-tiananmen-square-2014-6)
In memory of the 25th anniversary of June 4, 1989.
Thursday, April 10. 2014
- The “separate entity rule” in an increasingly connected world
Does a NY court have the power to order Bank of China, which runs 2 branches in NY, to turn over properties owned by a customer based in Dubai and held in a branch located in China, for the benefit of a US judgment creditor?
Before 2009, a majority of the NY courts that had faced questions similar to the one above answered them consistently with a “No”, based primarily on a court-created doctrine known as the “separate entity rule.” According to the rule, for certain purposes (including garnishment), a NY branch of a foreign bank is treated as a separate entity from the other foreign branches or the parent bank. Consequently, even though NY laws authorize the courts to garnish a debtor’s properties held at a third party bank, for foreign banks, the courts have limited that power to only their NY branches, separate from any other foreign branches or the parent banks.
Four primary policy rationales have been given by these courts in support of the separate entity rule: (1) inconvenience to the bank’s operations; (2) competing claims to the same asset; (3) risks of forum shopping; & (4) international comity. These rationales, however, have evolved over time. Particularly, technology advances have significantly eroded the influence of the “inconvenience to bank” rationale, even leading a court to completely invalidate the rule in 1980. Moreover, opponents of the rule have argued that the rule allows debtors to evade their obligations by removing assets abroad, depriving creditors of a US forum to enforce court judgments. They have also argued that the rule gives a competitive advantage to foreign banks against US banks.
The gradual evolution of the separate entity rule took a quantum leap in 2009, when the NY Court of Appeal decided the case Koehler v. Bank of Bermuda. In Koehler, the highest court of NY, in a divided 4-3 decision, held that as long as a foreign bank (Bank of Bermuda) is subject to the personal jurisdiction of the state, NY courts have the power to order the bank to turn over assets held at its foreign branches.
The majority’s opinion in Koehler did not explicitly mention the separate entity rule, because Bank of Bermuda had consented to NY’s personal jurisdiction. Some courts and commentators, however, have construed Koehler to have implicitly invalidated the rule.
As a result of the increased uncertainties regarding the validity of the separate entity rule, after Koehler, courts in NY have seen a rise in lawsuits against international banks operating in NY to compel the banks to turn over customer assets they held in non-US branches. Many of the plaintiffs in these lawsuits were foreign creditors and the bank customers were foreign debtors. For examples, in these cases, the nationalities of the creditors spread from Korea, Chile, Germany, Norway, and Cayman Island to Lebanon. The debtors’ nationalities included, among others, China, India, Brazil, Philippine, and Mexico. And the assets were held in bank branches located in places as disparate as Germany, Canada, France, Pakistan, Spain, Canada, China, Philippine, and Thailand.
Substantial concerns regarding this new trend arose among the courts and the banking industry. Finally, in 2014, facing fact patterns similar to the one in the Bank of China question raised at the beginning of this posting, the Second Circuit Court of Appeals asked the NY Court of Appeals to answer whether the separate entity rule is still a good law. The Court of Appeals is expected to decide the question in 2015.
Recently, the US Supreme Court has significantly restricted the scope of powers (ie, personal jurisdiction) states can assert over foreign entities doing business in US, based on the constitutional due process requirements. As a result, the NY Court of Appeals is likely to uphold the validity of the separate entity rule. Regardless of how the Court decides, nonetheless, in an increasingly connected world of global economy, the walls erected by the separate entity rule will inevitably become increasingly porous. The battle over the separate entity rule is but a reflection of the globalization trend, where the goals of global banking increasingly conflict with the goals of global judgment enforcement.
Conflicts, however, may motivate searches for resolutions. And if these searches are successful, the policy rationales behind the separate entity rule may lose their significance. For example, with respect to international comity, it will most likely be a long time before nations are willing to give full faith & credit to the judicial judgments of other nations. But some types of bi-lateral or multi-lateral agreements providing for international judicial judgment registration systems, similar to the international patent & trademark registration systems, are potentially feasible within a generation’s time.
Until that happens, the separate entity rule will likely continue to be the mainstay of global banking in US, specifically in NY.
 E.g., NY CPLR §§5222; 5225(b); & 5227.
 See, e.g., Fidelity Partners v. Philippine Export & Foreign Loan Guarantee, 921 F. Supp. 1113, 1119 (SDNY 1996). (“This rule […] provides that ‘each branch of a bank is a separate entity, [and is] in no way concerned with accounts maintained by depositors in other branches or at a home office.’”)
 See, e.g., Geoffrey Sant, The Rejection of the Separate Entity Rule Validates the Separate Entity Rule, 65 SMU L. Rev. 813 (Fall 2012).
 It would be burdensome or impossible for an international bank to perform constant checks and transfers of its global assets.
 The judgment debtor and one or more judgment creditors, through other branches, may claim the same asset.
 NY courts would become the clearinghouse of the world for post-judgment enforcement actions, creating impractical burdens on the court system.
 The law & rules of a country should respect those of another country.
 Digitrex v. Johnson et al., 491 F.Supp. 66, 68 (SDNY 1980) (“We believe that this rule is no longer valid.”)
 See, e.g., Tire Engineering & Distribution v. Bank of China, 13-1519 at pp.22-23 (2nd Cir. 2014).
 Koehler v. Bank of Bermuda, 12 NY3d 533 (2009).
 “[NY law] contains no express territorial limitation barring the entry of a turnover order that requires a garnishee to transfer money or property in New York from another state or country.”
 See, e.g., Geoffrey Sant, Supra at 829-835.
 Tire Engineering & Distribution, Supra.
 Specifically, in Daimler v. Bauman, 571 US ___ (January 14, 2014), the US Supreme Court unanimously held that a German company could not be sued in CA by Argentine plaintiffs for acts committed in Argentina, even though the German company had conducted business in CA through a US subsidiary. This decision may be a critical factor in the NY separate entity rule case, even if not binding.
Monday, March 31. 2014
- Trade secrets +1; patents -1
The America Invents Act, enacted on September 16, 2011, amended the Patent Act in several critical areas. One of the amendments was directed to §273, which provides a defense to infringement for “prior use” of a patented invention.
Generally, §273 allows an entity that has been accused of infringing certain types of patents to escape liability if the entity has first used the patented invention at least 1 year before the effective filing date of the patent. The permissible “prior use” can be either internal or public. Even before the enactment of the previous §273 in 1999, there had been calls for a broad “prior use” defense for all patentable inventions since at least as early as the 1960s, but Congress was not able to act on these calls. Primarily because of the commercialization of the internet, the proliferation of business method patents, and the 1998 State Street decision where the Federal Circuit explicitly held that business methods were patent eligible, Congress was able to gather enough votes in 1999 to pass a “prior use” defense under the previous §273, but only for the narrow scope of “methods of doing or conducting business.”
As an example, Company A began using a business method internally as a trade secret in 1995. Company A did not apply for a patent for the method, having determined that business methods generally were not patentable. In 2000, however, Company B obtained a patent on the same method, and accused Company A for infringing the patent. In such a case, Company A can raise the “prior use” defense pursuant to the previous §273 to prove that it is not liable for infringement.
Under the previous §273, however, if Company A had used a method of manufacturing, instead of a method of conducting business, it would not have been able to avail itself to the “prior use” defense. Because of this, proponents for a broader scope of the “prior use” defense had argued that the absence of such a broader defense would lessen the competitiveness of US manufacturers with foreign competitors, and encourage US corporations to move manufacturing overseas.
In the amended §273, Congress was finally able to expand the “prior use” defense to virtually all patentable subject matters, including processes, machines, manufactures, or compositions. Under the amended §273, an entity accused of infringing a patent can escape liability if it had invented and commercially used the patented invention at least 1 year before the earlier of the effective filing date of the invention or the date when the invention was disclosed to the public.
In practice, the expanded “prior use” defense under the amended §273 will further encourage inventors to use trade secrets, instead of patents, to protect their inventions. In this round of disclosure against secrecy, therefore, secrecy has scored a win. In terms of public policy, however, we should keep in mind that one of the primary rationales for granting patents is to encourage public disclosure of inventions, so the general public can share and build on the fruits of individual intellectual endeavors. We should continue to monitor and assess the practical implications and impacts of such a shift from disclosure to secrecy.
Additionally, AIA includes many other provisions to improve the patent system, such as prior art submission, post-grant review, inter partes review, and fee-setting power of USPTO. USPTO has also embarked on several initiatives, such as incorporations of crowdsourcing for prior arts. Let’s hope these and other future changes will achieve the right balance between disclosure and secrecy in encouraging innovations and ensuring competitions.
 Public Law 112-29.
 See, e.g., Joe Matal, A Guide to the Legislative History of the America Invents Act, Part II of II, 21 Fed. Cir. B. J. 539, 555 (2012), available at http://www.uspto.gov/aia_implementation/guide_to_aia_part_2.pdf.
 §4302(a) of the American Inventors Protection Act, Public Law 106-113, titled the First Inventor Defense Act, codified as 35 U.S.C. §273(a)(3).
 If US manufacturers used patents to protect their inventions, the patents would be difficult to enforce overseas. On the other hand, if US manufactures used trade secrets for protection, they would be subject to attacks by others who obtained patents on the inventions. See, e.g., Matal, at 552. §271(g) of Patent Act, enacted in 1998, partially alleviated this concern by providing that an imported product made overseas using a process patented in US would be liable for infringement. See, e.g., http://www.finnegan.com/resources/articles/articlesdetail.aspx?news=c9459d08-6491-4e06-8ab2-aa12db3045b7.
 “IN GENERAL. -- A person shall be entitled to a defense […] with respect to subject matter consisting of a process, or consisting of a machine, manufacture, or composition of matter used in a manufacturing or other commercial process, that would otherwise infringe a claimed invention being asserted against the person[.]” Sec. 5(a) of the America Invents Act, codified as 35 U.S.C. §273(a).
Thursday, February 16. 2012
- Augmenting shareholder activism
In recent years, institutional investors concerned with climate risks, particularly public pension funds, have sought to leverage their financial prowess to effect changes in climate-related regulations and corporate governance. For example, they petitioned SEC to require expanded disclosures of public corporations’ exposures to climate risks and their contingency plans, resulting in the promulgation by SEC in 2010 of a set of guidelines regarding such disclosure requirements. (See here.) Furthermore, investors have undertaken shareholder activism via resolutions and proxy votes to influence corporate policies regarding climate risks, for example to demand greater disclosure. (See here.)
These efforts have placed in the public domain more and more information related to the climate risk exposures and policies of publicly traded companies, which can spawn further public scrutiny and analyses, increase public awareness, encourage broader participation, and induce further disclosures in a benign cycle. There are, however, limitations to both approaches. On the one hand, regulators are reluctant to impose stringent regulations on the private sectors due to the weak economy. On the other hand, unlike public pension funds, shareholder activism is generally not viable for mutual funds, because of regulatory requirements on diversification, costs, and conflicts of interests; or for hedge funds, because of their short-term time horizons. (See here.)
Therefore, it may be useful to augment shareholder activism with bondholder activism to effect changes in corporate climate risk practices. US corporate bond market is sizeable, exceeding $7 trillion as of Q2 2011 according to Wikipedia, dominated primarily by institutional investors. Corporate bondholders as a whole, consequently, can exert significant influences on bond-issuing corporations.
As I mentioned previously, equity shareholders affect corporate governance primarily through shareholder resolutions, proxy votes, or even derivative actions. This means the influences of shareholders arise primarily after the purchase of the shares. Bondholders, on the other hand, affect corporate governance primarily through the terms of the bond indentures and therefore can assert influences both before and after the purchase of the bonds. For example, if prospective buyers are concerned with potential negative impacts from climate-related events (hurricane, flood, coastal line erosion, drought, etc) on the payment capability of an issuer corporation, the prospective buyers may negotiate to modify the interest rate, maturity, call/put features, or other numerical terms of the bonds. Or, they can negotiate to add a climate risk covenant to the bond indenture that is linked to certain climate risk factors such as enactment of climate legislation, inclusion of US in an international climate treaty, or the occurrence of some physical events. The threat of the inclusion of such climate-related provisions in the bond offering may impose significant influence on the borrower corporation’s climate policies.
Since such pre-purchase negotiations improve the performance of the bonds, mutual fund managers should be more willing to participate in the negotiations, without being overly concerned with the possibility of upsetting the corporate managers and thus losing future businesses from the corporation. Hedge funds may also find it easier to agree to terms that comport with their short-term profit strategies, as well as other long-term climate concerns. As a result, the aggregate influence of all potential bondholders can be much greater than that of shareholders. Finally, post-purchase/issuance, monitoring & enforcement of the terms and covenants of the bond indentures may be performed by hedge funds, which have gained tremendous experience in enforcing bondholder rights in recent years. (See here.)
As far as I know, this idea of augmenting shareholder activism with bondholder activism in affecting corporate climate policies has not been practiced before. Will it work? I am hoping to find out soon.
Thursday, January 26. 2012
- Making the case for the formation of national climate-change insurance markets
In mitigating the impacts of climate change, market-based regulations (aka, cap-&-trade) have been championed as the preferred policy tool. (See my previous post on regulations, markets, & innovations.) EU has adopted cap-&-trade regulations for carbon emissions and established carbon credit markets, under the Kyoto Protocol, since 2005. And the northeastern states in US have been auctioning off carbon emission allowances to the power generators under the RGGI (Regional Greenhouse Gas Initiative) platform since 2008. California is set to begin emission trading soon.
The prices of the carbon credits traded in EU and under RGGI, however, have plunged precipitously. (See here & here.) Moreover, the Chicago Climate Exchange ceased trading carbon credit products in 2010. Recently, Canada withdrew from the Kyoto Protocol, and New Jersey broke away from RGGI. These developments raised serious doubts whether markets can be an effective policy tool with respect to climate change.
If not viewed as a policy tool, nonetheless, the carbon markets have done exactly what they are supposed to do. – Efficiently reflecting the aggregate balance of supply and demand. The decline in carbon prices reflects (among others) the over supply of credits issued by the EU governments, and the under demand in US & China for lack of policy supports (and also in EU for the weak economy). Therefore, as much as policy-makers and businesses engage in the wishful thinking that the markets would do the works on their behalf, the markets know better to call their bluff.
The lessons: Markets cannot function as an effective regulatory tool without adequate policy supports or implementation. On their own, however, markets can function as an efficient signal as to the aggregate impacts of supply and demand factors, including policy supports and economical conditions.
These lessons learned from the market-based efforts in climate change mitigation may have some important bearings on climate change adaptation. Adaptation has taken a back seat to mitigation in the climate change debates. This is understandable. After all, it makes sense to target directly the root of the problems (free emission of carbon). Moreover, reducing carbon emissions is associated with one clear objective, finite risk parameters (atmospheric CO2 concentration, mean temperature, & mean sea level), acceptable predictive models with large data sets, quantifiable risk levels and reduction targets, tangible commercial products, well-articulated technological solutions, and a definable timeframe.
Adapting to climate change, on the other hand, has none of these characteristics. There is not one central theme, but rather a murky set of sundry tasks that must be performed locally in response to unpredictable local conditions (eg, hurricane, flood, drought, extreme precipitation, sea level rise, heat wave, biodiversity changes, vegetation shifts, disease spread, healthcare, allocation of water & food, etc). And, other than water, there is no easily identifiable tangible commercial products associated with climate change adaptation. Adaptation, in short, is simply a tough sale!
The falling carbon prices, however, attests to the difficulties in achieving the mitigation goals considered necessary to maintain the atmospheric CO2 concentration at comfortable levels. Adaptation, therefore, is increasingly becoming an inevitable reality in the 21st century. And yet, even though the public sectors have taken initiatives to address adaptation needs (see eg here), for the private sectors, adaptation remains a murky set of ill-defined speculative sundry tasks, and very little concrete actions have been taken to address the issues. (Eg, see here.) Without the extensive participation of the private sectors, public sector efforts in adaptation will not likely to be effective.
This is where I think markets may play a useful policy role in stimulating private sector adaptation efforts, not as a regulatory tool but by providing a signal as to the aggregate balance of the supply & demand factors, including climate science developments, policy supports, or economic conditions. Specifically, the market I have in mind is the catastrophe insurance market.
Currently, climate sciences are still unable to reliably forecast local climate variations (city or town) for more than a few days into the future. (Even if some high-resolution modeling tools may exist, my guess is they are likely to be extremely pricy and not widely available.) As a result, the most common way for businesses or individuals to manage their climate change risks is to purchase catastrophe insurances. These insurance markets thus provide a signal as to the aggregate supply & demand for climate change risk shifting, which in turn point to the aggregate supply & demand for adaptation.
If these insurance market prices are widely accessible to the general public, like the prices of Treasury and other debt securities widely available to the public through the media or internet, they may serve to better inform the public of the state of climate change risks, and thus stimulate more concrete actions. In most markets in US, both private insurance carriers and public governments (states & federal) offer climate-related insurance coverage, such as flood or hurricane insurance policies. (Eg, see here.) In fact, in some markets, the federal government plays a significant role. For example, by 2007, the federal National Flood Insurance Program (NFIP), established in 1968, has become the primary flood insurer in US. (See here.)
Therefore, the federal government should establish an agency to oversee and underwrite all federal climate-related insurances, and also ensure the establishments of sound and secure secondary markets in these insurance products and extensive distribution of the pricing information to the general public. Just like the Treasury securities markets, such national climate-related insurance markets may serve as a benchmark for the creation and pricing of other related markets, and as the basis for the creation of other analysis and decision-making tools. These national markets, pricing information, and additional tools should hopefully raise the public awareness of the risks of climate change, and thus the needs for adaptation, and facilitate informed and educated concrete actions in adaptation.
Of course, this is a very primitive idea. Many further considerations need yet to be worked out. For example, many insurance policies are not standardized, unlike Treasury securities. The premiums may not properly reflect the market supply & demand because of government subsidies. The markets may lack liquidity if the risks rise above a certain threshold. But, hopefully this will be a start!!!
Friday, December 9. 2011
- At the Climate Change & Green Energy seminar
Here is the ppt slides of my presentation at the 11/14/2011 Climate Change & Green Energy seminar, co-sponsored by TECO & ACUNS. The program can be found here. The title of my presentation is "Global Warming Mitigation -- Challenges, Taiwan, & Geoengeering".
Monday, September 5. 2011
- Patents used primarily to attract VCs by software startups
UC Berkeley Law School conducted a comprehensive patent survey in 2008, asking young start-up technology companies to respond to several patent-related questions. (See here and here.) More specifically, the survey included the following questions (not exhaustive):
The ~1300 companies that responded to the survey encompassed the software, computer hardware, biotechnology, and medical device industries. More than 700 of them, however, were software companies. One of the co-authors, Pamela Pamuelson, wrote an interesting article in 2010 summarizing the survey results particularly of software companies. Below is a quick recap of her summaries:
Therefore, the first finding of the survey is that software startups generally do not consider patents important in gaining competitive advantages. Unlike biotech or medical device companies, software companies prefer using first-mover advantage, complementary assets, copyright, trade secret, trademark, or reverse engineering to compete in the marketplace. (Click on thumbnail above to view original chart.)
The survey also revealed, however, that those companies backed by VC were much more likely to apply for patents than non-VC-backed companies. -- The software startups that participated in the survey were originally selected from 2 databases: ~500 from Dunn & Breadstreet (DB) and ~200 from VentureXpert (VX). About 10-15% of the DB companies and all of the VX companies were backed by VCs. In responding to the question whether they currently held or were seeking patents, only ~1/4 of the DB companies (with 85-90% not backed by VC) answered positively. On the other hand, ~2/3 of the VX companies answered positively.
From the survey results, it appears software startups use patents primarily to attract or retain VC investments, rather than as a competitive advantage in the marketplace. It is not clear, however, whether the change in strategy toward patents (with or without VC investments) was caused by the perception of the software entrepreneurs regarding VCs, or by the actual requirements of the VCs.
But, perceived or not, the fact that VCs and software entrepreneurs may hold such different views toward the values of patents is significant. It points to the need of a flexible patent system.
(Page 1 of 7, totaling 69 entries) » next page
Freedom of Speech
Friday, July 14 2017
Treasure and preserve what we have
Tuesday, July 19 2016
Bitcoin regulations proposed by New York regulator
Thursday, July 24 2014
Treasure and preserve what we have
Wednesday, June 4 2014
Global banking v global judgment enforcement
Thursday, April 10 2014
Expanded “prior use” defense under AIA
Monday, March 31 2014
Bondholder activism in affecting corporate climate policies
Thursday, February 16 2012
Climate change adaptation & market-based regulation
Thursday, January 26 2012
11/14/2011 Presentation on Climate Change
Friday, December 9 2011
Software patents and venture capital
Monday, September 5 2011