Recent developments in bipartisan patent legislation

By Jason Rantanen

This past spring, Senators Tillis (R-NC) and Coons (D-DE), ranking members of the Senate Judiciary Committee, together with Representative Collins, Johnson and Stivers, released draft bill text for bipartisan patent legislation focusing especially on Section 101 (read here).  The Senate Judiciary Subcommittee on Intellectual Property conducted hearings on patent eligibility and disclosure requirements in June, and there was a sense that a proposed bill would drop before the August recess.  With the Senate recess beginning on Saturday, that is looking unlikely.  More likely we will see something in a few weeks, once Congress reconvenes.

There’s still a day and a half to go, however, and two recent letters to the Senate Judiciary Subcommittee on Intellectual Property have presented opposing viewpoints on the central issue being addressed by the proposed legislation: patent-eligible subject matter.

Letter from medical, health and civil rights organizations:

The first, signed by over 200 organizations, including the ACLU, Mayo Clinic Laboratories and Women’s March, begins:

We, the undersigned civil rights, medical, scientific, patient advocacy, and women’s health organizations, write to express our opposition to the recent proposal to amend Section 101 of the Patent Act. The draft legislation if enacted would authorize patenting products and laws of nature, abstract ideas, and other general fields of knowledge. Most troublingly, the legislation would permit patenting of human genes and naturally-occurring associations between genes and diseases. Allowing these patents will prevent the discovery of novel treatments for diseases including cancer, muscular dystrophy, Alzheimer’s disease, heart disease, and other rare and common diseases. It would also create barriers to patients’ access to potentially lifesaving genomic tests, eliminate access to confirmatory testing and dramatically increase the cost of tests that have benefited from innovation that led to reduced costs of DNA sequencing technology. Further, it will stymie competition for developing and improving diagnostic and medical tests, and increase the cost and hinder advancement of targeted therapeutics involving genomic markers. That means higher costs for patients, payers, and the healthcare system overall.

It further asserts that:

The draft legislation released by your offices not only rewrites Section 101 of the Patent Act, it states explicitly that any judicially created exception to patent-eligibility will be abrogated, thereby overturning the Mayo, Myriad, and Alice decisions. If enacted, this threatens to take us back to a time of greater uncertainty regarding patent eligibility. The draft goes further than that, as well. Beyond explicitly abrogating judicial precedent holding that genes, isolated from the genome, are not patentable, the legislation also would define the concept of what is useful to mean “any invention or discovery that provides specific and practical utility in any field of technology through human intervention.” This language essentially adopts the argument for patenting isolated genes that the Supreme Court rejected in Myriad. Myriad argued for, and the PTO granted,15 the patents on the BRCA1 and BRCA2 genes because the DNA was “isolated” from the cell through an act of human intervention. Isolation is required for scientific work with DNA, and permitting patents on isolated DNA resulted in the issuance of patents covering an estimated 20% of the human genome.16 Defining “useful” to include essentially any invention or discovery that was developed through human intervention reinvigorates the argument that human genes are patent-eligible.

Read the whole letter here: ACLU Letter

Law Professor Response Letter

A letter in response, signed by a group of 24 law professors, former government officials, and scholars (some of whom testified at the June hearings) opens with:

As law professors, former government officials, and scholars, we write to express our support for the congressional effort at reforming patent eligibility doctrine. As Congress considers legislation to bring balance back to the patent system in promoting the high-tech and biopharmaceutical inventions that drive the U.S. innovation economy, it is imperative that its deliberations are based on accurate statements of the law and of the real-world performance of the U.S. patent system.

The letter takes direct aim at the health and civil rights’ organizations’ letter:

We are deeply concerned about misapprehensions of law and misleading rhetoric in a recent letter to Congress submitted by the American Civil Liberties Union (ACLU) and other medical and policy organizations that oppose this legislative reform effort. Their claim, for instance, that the “draft legislation if enacted would authorize patenting products and laws of nature, abstract ideas, and other general fields of knowledge” is a profoundly mistaken and inaccurate statement. Rather, the proposed amendments preclude “implicit or judicially created exceptions to subject matter eligibility,” and do not eliminate constitutional and statutory bars to patenting laws of nature, abstract ideas, and general fields of knowledge.

Read the full letter here: Law professor response letter

Stay tuned for a third perspective, offered by Syracuse University  College of Law professor Shubha Ghosh.

44 thoughts on “Recent developments in bipartisan patent legislation

  1. 6

    It should not escape anybody’s attention that the “Law Professors” in their Response engage in the same sort of dissembling and refusal to address the issues that those professors engage in when you confront them directly about the issues. This behavior was documented here in real time during the run-up to Mayo and afterwards. It’s not just “professors”, of course. It includes attorneys as well. Refusing to address the issues is a tactical strategy that is often employed by those who do not have an answer.

    What’s hilarious is that these people somehow expect everyone else to pretend that we can’t see what their doing. Because — oh my! — it would be so “uncivil” to point out that they are dissembling cowards with cr @ppy arguments. Boo hoo hoo hoo! After all, you only had YEARS to figure out a reasonable “revision”, people. And look what you came up with: a stinky pile of pure unadulterated self-dealing horses—t.

    1. 6.1

      ROTFLMAO

      Hricik and Michael Risch both signed that ridiculous letter, along with disgraced Judge Rader. Leftsin, of course, is another total hack. Too flippin’ funny.

      Other than the disgraceful aspects, what do all these three people share in common? Refusal to engage in the obvious issues beyond the most surface levels. Hricik especially. Good grief, you people are P-A-T-H-E-T-I-C.

      1. 6.1.1

        So you FINALLY clicked through and read the letter, eh?

        (Hmm, maybe not – maybe you just clicked through to see the names at the end of the letter and have not as of yet STILL bothered to read it)

  2. 5

    Greg DeLaffatus pretends to be a “civil” person. Greg’s game is to ignore anybody who doesn’t like to play pattycake with him. That’s the game where you point out to Greg some basic facts relating to his strange, radical views on subject matter eligibility and the manner in which these “proposed revisions” have been shoveled at Congress, and then Greg refuses to address those facts.

    And then when you point out that Greg is NOT addressing the issue, he throws a little tantrum and pretends that you don’t exist. He’s a super serious guy! Totally not just a silly weasel running around spewing three syllable words and making it appear as if obvious uncontroverted concepts (e.g., “Congress has more impact on patent laws than the Constitution”) are s00per d00per deep.

    Say, Greg, does the First Amendment put any limits on the patent laws? Tell everyone. Say, Greg: if your claim recites a step of drinking milk and a step of thinking about a non-obvious correlation, isn’t that pretty much the same as a claim that recites just a step of thinking about the correlation, at least from the perspective of us milk-drinkers?

    [crickets]

    Like I said: dude has some weird beliefs that he just doesn’t want to talk about for some mysterious reason. Yes, it’s oh-so-mysterious … Maybe Dennis knows the answer.

    1. 5.1

      Greg DeLaffatus pretends to be a “civil” person.

      Even in bashing Greg (who most certainly deserves a fair amount of bashing), you get things wrong.

      Greg does NOT “pretend” to be civil.

      He is civil.

      To a fault.

      To your point of “Greg’s game is to ignore anybody who doesn’t like to play pattycake with him.” – I agree partially, and only to the extent that Greg may stay engaged with someone NOT playing pattycake, but only as long as that person does not really challenge Greg’s legal views. The moment that an erstwhile challenge does appear, is the moment Greg disappears.

      He wears a mask of civility as a front to his inte11ectual cowardice.

      Certainly, he IS civil, and does conduct his posts mostly** in a civil manner.

      ** I say mostly, because his snide “shots from the sidelines” certainly are NOT civil, albeit they lack the sharpness of words that actually engaging on the merits would allow.

      As to “not wanting to talk about”… I am STILL waiting for you to compose an actual and cogent First Amendment argument. ALL that you do is mouth the words – and such simply is not enough for a proper First Amendment argument. 1L’s typically are not provided the opportunity for First Amendment law, and in fact, most law schools do not have First Amendment Law as a required class. Mine certainly did not (although I did take the specialty class, and if I remember correctly, I had the High A in that class).

      1. 5.1.1

        Remember, folks: Bildo fancies himself to be a glibertarian. And yet …

        Funny stuff.

        1. 5.1.1.1

          What is the point of your attempted put-down here?

          You address nothing on point, make some glib semi-political comment, and expect anyone to derive any meaning from your mumblings?

          1. 5.1.1.1.1

            Meanwhile:

            In his dissent, Kavanaugh called for a sweeping expansion of the Second Amendment, beyond even what his two Republican colleagues were willing to endorse. Regarding assault rifles, the future Trump appointee argued that these weapons should enjoy the same nearly un@ssailable level of level of constitutional protection the Supreme Court afforded to handguns in its 2008 decision in District of Columbia v. Heller.

            Hey, is this ps y-ch0-p@thic R-p-yu-k-k-ke @ h 0le also the drunken r@pey fratboy guy with the “scissors” that Bildo keeps ranting about?

            1. 5.1.1.1.1.1

              You are doing that “one-bucketing” thing again…

  3. 4

    Dennis, Jason:

    Your “honors”, is there any way you could restore more civility to this blogsite? It seems there are several comment posters who consistently write things in a way that would never be put into a legal brief or said in open court without getting a contempt citation. I enjoy the posted articles themselves, but the outright rudeness in the comment section makes many series of posts virtually unreadable and unedifying. Perhaps, as site monitors, you could introduce some kind of temporary timeout for any aggredious lack of manners.

    Thank you.

    1. 4.1

      there are several comment posters who consistently write things in a way that would never be put into a legal brief or said in open court without getting a contempt citation

      Dear Mark,

      Blog comments aren’t “legal briefs” and we aren’t in “open court.” Adherence to silly norms of “civility” and court rules is one way in which powerful moneyed interests snake their terrible ideas into legislation and legal doctrines which benefit only them at the expense of those who do not have the same access (i.e., money).

      Do you have something meaningful to say? Then say it. If you don’t like Sherry Knowles or Ted Sichelman or Kevin Noonan getting ripped to shreds for being a pack of dissembling shills, then for goodness sake rise up defend their incredible intelligence and honesty. And then get ready for some counter-examples that you will have to explain. And then of course you’ll just start another round of whimpering and lying.

      For goodness sake, it’s not as if we haven’t been watching and documenting the behavior of these despicable greedy people for almost a decade now. Don’t like it? Too bad for you. Go to Big Jeans or Kevin’s place and bask in the “civility” (LOL!) there. Thank you for your comment.

      1. 4.1.1

        Norms of civility are not “silly”, even in a blog forum such as this. While some degree of leeway should be given to online posting, arguments disagreeing with someone can still be made with courtesy and decorum. Failing to maintain a respectful attitude contributes nothing of value to an argument. The second paragraph of post 3 below is an example of useless ranting that does not advance your case, but providing a clear, cogent argument instead would.

        1. 4.1.1.1

          First time here, Mark?

          MM (aka Malcolm Mooney, aka Malcolm, and over at PatentDocs, more pseudonyms than you would imagine), has been posting in that “style” of his for a documented 14 and a half years.

          1. 4.1.1.1.1

            No. I’ve seen it before; but it seems to be getting much worse over time.

            I was raised not to say or write anything that you wouldn’t be willing to say in a direct face-to-face conversation without getting a bloody nose. It seems the relative anonymity of the internet gives some posters temporary insanity, but it’s still a poor excuse.

            1. 4.1.1.1.1.1

              Meh, for me it is far less the “saying of it,” as I tend to ascribe to the words of John Maynard Keynes.

              Rather, it is the MINDLESSNESS of the rants from Malcolm, as even IF they are connected to patent law, they advance no cogent line of thought — leastwise one that has not had counter points presented for years now that he refuses to acknowledge, understand, and integrate into ANY type of dialogue.

              He
              Just
              Does
              Not
              Care

              Instead, as has been the case for most all of his span here (I had to LOL, as autocorrect wrote that as spam), Malcolm is only interested in a drive-by monologue, Internet shout down style of rhetoric.

            2. 4.1.1.1.1.2

              direct face-to-face conversation

              Right. That’s the kind of conversation where First Person says X, then, directly in response to statement X, an obvious follow-up question is asked by Second Person, and then the First Person answers the question directly (as opposed to kicking up dust, or moving the goalpost, or accusing the person of being “anti-patent” just for asking the question, or pretending that the question wasn’t even asked).

              I love those kinds of “direct” conversations. Unfortunately, greedy dissembling proponents of this awful legislation — who are the same people who relentlessly fought against the Mayo v. Prometheus decision in the first place — NEVER EVER want to have such conversations.

              Guess why that is, Mark. Go ahead. Take your best guess. You’re a very serious and civil person! Let’s hear your words.

              1. 4.1.1.1.1.2.1

                It’s opposite day folks (otherwise known as the typical Malcolm meme of Accuse Others of That Which Malcolm Does).

                But please, do continue your hypocrisies.

        2. 4.1.1.2

          providing a clear, cogent argument

          Trying not to laugh as I type but here goes …

          Dearest Mark, you super awesome and thoughtful dude, with all due respect and civility, none of the signatories of that letter give one f—–ng d-mn about “clear cogent arguments”.

          It’s highly likely that no other people on this beautiful planet are more familiar with the “clear cogent arguments” relating to the most glaring failure of the proposed 101 revisions than Hricik and Noonan. Risch and Leftsin are also very much aware of the issues. In fact, pretty much everybody there is aware of the issues although it’s entirely possible that some of those super “civil” people lack the intelligence to process them (does that surprise you? it shouldn’t).

          But let’s address YOUR needs here. Just so we’re not wasting everybody’s time, can you please summarize for everyone the salient facts regarding

          (1) the claims at issue in Mayo and how they relate to the prior art;

          (2) Prometheus’ experts testimony regarding what acts constituted infringement of those claims; and

          (3) the essential holding of the case, in your own words, and how that holding would impact my ability to claim, e.g., a method comprising a step of (i) using the prior art to collect data about your child’s eating habits and (ii) communicating a non-obvious inference to you or anybody else based on that data.

          That shouldn’t take more than a paragraph or two and a few minutes of your time. We can get started on our “cogent, clear” discussion as soon as you provide this basic information.

          Thank you for the comment.

    2. 4.2

      A few thoughts that are worth exactly as much as you have paid for them:

      (1) I would also favor a more aggressive moderation. Bans for the top two offenders would do much to improve the atmosphere around here.

      (2) That said, it is neither realistic nor fair to expect the bloggers in charge of this blog to put in that kind of effort. If the banned poster wants to keep going, it will require little effort on the banned posters part to invent a new identity or access a new IP address. It would, therefore, require a lot of diligence on Dennis’ or Jason’s part to make the ban stick. Who wants that kind of headache?

      (3) The only reason to follow the comments around here—or to participate—is because it is fun to do so. There is nothing else at stake. Congress and the courts know little and care less about what we say on these fora, so no one’s arguments around here make any practical difference in the real world.

      (4) Precisely because the only reason to participate around here is because it is fun, it follows that one should not participate if it is not fun.

      (5) If you find that it could be fun, but for the presence of certain other participants, I assure you that with a little practice you can learn to ignore selectively. I can tell you from personal experience that it requires very little effort to cultivate the ability to ignore, and it improves the experience enormously.

      1. 4.2.1

        Your “(1)” most likely commits an egregious error in confusing the fully proper rhetorical use of sarcasm and sharp language for what is easily the very worst on the blog (Malcolm).

        Heed JMK.

        Your “(2)” is easily false. If you have any doubt, then you should pay attention to Malcolm’s 0bsess10n and note the (third year in a row award winning) blog over at IPWatchdog, at which place posting policies are objectively and fairly evenly enforced that eliminate the very type of blight that Malcolm IS, while retaining the ability for people to employ sarcasm.

        Oh wait, you do post there and should already know that.

        As for your “(3),” you obviously have not been paying attention as MY posts on the absurdities of the score board being broken have been reflected in the writings of the courts AND in the comments of Director Iancu.

        Now your stuff may be being ignored; but please, do not deign to talk for everyone.

        Your “(4)” is merely another way of saying that posting is optional and by choice. Ok.

        Your “(5)” is your choice (as always), but such selectivity carries the risk of you developing a less critically capable mind and a more “bubble chamber” approach of selectively reinforcing your already held beliefs.

    3. 4.3

      Mark, many of us sympathize with your desire for more civility on this and other blogsites. All one can do is ignore all the frequent non-substantive personal in sults by those with physiological needs for that behavior [like our President], and look for the useful peals of substantive wisdom that one can find buried in all that garbage. [Which includes bizarre rationalizations that a mere “you are wrong and stupid” is a substantive, effective or useful remark on a legal blog.]

      1. 4.3.1

        The desire for “more civility” should NEVER over power the substantive engagement on legal issues, even — or perhaps more accurately — especially on tough legal issues.

        And while Malcolm is (nigh singly) the closest approximation to Trump on these boards, there is an unsettling amount of inte11ectual cowardice from posters who like to pretend otherwise (and even spout about using their “real names” as if that were some inoculation or perhaps excuse from such engagements).

        One can be — and I posit, should be BOTH substantive AND sharp. This is especially true given the type of forum in which “Drive By Monologues” not only happen, but certain editorial policies actually tend to promote such vehicles.

  4. 3

    What are the names of the disgusting liars who wrote the second letter? Publish them right up front so we all can remember them.

    Sherry Knowles is a pile of human trash and has the intelligence of a Petri dish. She couldn’t discuss these issues honestly if you paid her to do it. So she lies. And lies. And lies.

    1. 3.1

      And yet more of the sadly typical Malcolm Number One meme of Accuse Others Of That Which Malcolm Does….

    2. 3.2

      “What are the names of the disgusting liars who wrote the second letter? Publish them right up front so we all can remember them.”

      They’re in, you know, the letter.

      1. 3.2.1

        Ben,

        Do you really think that Malcolm took the time to — you know — actually click through and read the letter….?

        Really?

        ALL that you see from him is his SAME canned rant.

      2. 3.2.2

        I know that. They should be above the fold, as they say.

        These people need to be remembered for the lying, gaping @ h0 les that they are. Enshrined, as it were.

    3. 3.3

      So she lies. And lies. And lies.

      Really?

      Then it should be ultra easy for you to back up your accusation with a bona fide example (and NOT just something that you merely FEEL is not right).

      Of course, we both know that your standard operating procedure is the “drive-by monologue” dissembling, so we will NOT see you actually back up your mealy-mouth L 1 E S.

  5. 2

    To repeat my comment in the immediately above blog:
    In my view, the biggest issue with the draft Senate legislation’s broadening of 101 is that it’s express elimination of “new,” and all of the long-standing Sup. Ct. “exceptions” to patentable subject matter, is being accompanied by oral representations that they are all covered by other provisions of the patent statute. That could be true under 112 for “abstract” claims, but neither 112 or 102 fully precludes patenting of the other “exceptions.”

    1. 2.1

      It’s a total pile of self-serving lies. The hacks pushing these revisions have no clue about what they were doing except that they want their State Street
      playground back and screw everybody else.

      1. 2.1.1

        It’s a total pile of self-serving [l 1 e s].

        LOL – as if most ANYTHING that you have written does not fit that description….

        More of the typical Malcolm meme of Accuse Others….

  6. 1

    Props to Sherry Knowles who PROMPTLY blasted the ACLU (as was noted by Senator Tillis AT his hearings).

    1. 1.1

      Rather, the proposed amendments preclude “implicit or judicially created exceptions to subject matter eligibility,” and do not eliminate constitutional and statutory bars to patenting laws of nature, abstract ideas, and general fields of knowledge.

      I wish the response letter would actually discuss the constitutional bars to patenting laws of nature, abstract ideas, and general fields of knowledge. It makes that statement, and then never returns to the idea (it later briefly discusses the constitutional authorization to have patent laws, but never any constitutional bars). It seems misleading to say that there are constitutional bars and then not explicitly identify them.

      1. 1.1.1

        How in the world did you miss the very next sentence which give you your answer (and not at all unsurprisingly, is the answer that I have been giving here for several years) (emphasis added):

        First, pursuant to the constitutional authorization to Congress to enact patent laws “to promote the Progress in . . . the useful Arts,” the patent system secures an exclusive right only in new products, processes, and compositions of matter that constitute the “useful Arts.”

        1. 1.1.1.1

          First, pursuant to the constitutional authorization to Congress to enact patent laws “to promote the Progress in . . . the useful Arts,” the patent system secures an exclusive right only in new products, processes, and compositions of matter that constitute the “useful Arts.” Thus, it is a longstanding and fundamental requirement in the patent statutes that only inventions or discoveries falling within the statutory categories in § 101—and in its predecessor statutes dating back to the first Patent Act of 1790—are eligible for patent protection.

          This is a poorly written paragraph.

          First, pursuant to the constitutional authorization to Congress to enact patent laws “to promote the Progress in . . . the useful Arts,” the patent system secures an exclusive right only in new products, processes, and compositions of matter that constitute the “useful Arts.”

          This is a tautology. It is saying that the Constitution allows what the Constitution allows. There is no discussion of what the “useful arts” actually are and there is no discussion of what the Constitution actually bars from being patented. The answer may be, “the Constitution does not bar any subject matter.” However, if that is the case, then don’t claim that there are adequate constitutional bars so the lawmakers don’t have to worry about the concerns raised in the ACLU letter.

          Thus, it is a longstanding and fundamental requirement in the patent statutes that only inventions or discoveries falling within the statutory categories in § 101—and in its predecessor statutes dating back to the first Patent Act of 1790—are eligible for patent protection.

          This does not follow from the previous sentences… and is complete nonsense from a logic perspective. Seriously, did a 1L write this? The statute may define what the legislature has long though of as the “useful arts,” but this has nothing to do with the Constitution or any purported constitutional bars (there is no discussion of why these statutory categories in § 101 are required by the Constitution).

          1. 1.1.1.1.1

            Seriously, did a 1L write this?

            No, it was written by self-identified “expert” who is not really an “expert” in anything except being a dust-kicking lying hack.

            These people are truly disgusting. Hilarious, though, to see Bildo of all people trying to resuscitate this rotting corpse. He must love the taste.

          2. 1.1.1.1.2

            Just a few thoughts in response:

            1) I share your frustration with tautologous nature of “the constitutional authorization… secures an exclusive right only in new… compositions of matter that constitute the ‘useful Arts.'” It seems to me that a lot of arguments in this space rather unhelpfully tend to conflate what the Constitution says, and what the Patent Act says, as if the two were one and the same.

            2) I think that it is illusory to imagine that the Constitution actually confines patents to the “useful arts.” Goodness knows that the U.S. copyright act is not actually confined to “science” (i.e., the other half of “Science and the Useful Arts”). Anyone who is predicating an argument on the basis that the Constitution will stop the patent act from reading on untoward subject matter is actually imagining a Constitution with much more clarity and force of constraint than is evident in the case law. It is hard to point to any actual holding of any actual case that would show that the IP clause actually limits what sorts of patents can be granted in any way about which ordinary citizens might care.

            1. 1.1.1.1.2.1

              Is it really hard to imagine a First Amendment limit on what can be patented, Greg?

              I suppose it depends on how tiny your imagination is.

              1. 1.1.1.1.2.1.1

                It is hard to imagine you ever actually making a cogent First Amendment argument…

          3. 1.1.1.1.3

            Squirrel, much like the audience that you wish to align with, you engage in your own “tautology” with:

            don’t have to worry about the concerns raised in the ACLU letter.

            What exactly is a concern (other than the broken scoreboard Supreme Court legislating from the bench that these groups want to hold onto) that survives the critical scrutiny and counter points already put on the table by a whole host of people (including me), directly raised by Sherry Knowles, and acknowledged by Senator Tillis at HIS Congressional hearings?

            Can you do more than parrot the score of that broken scoreboard?

            1. 1.1.1.1.3.1

              You, unsurprisingly, miss the mark.

              This the professor letter was a response to the ACLU letter. Thus, the primary point of the letter was to dispute the ACLU letter. It failed to do that by providing cursory and misleading arguments. A critique of the letter in the context in which it was sent is certainly warranted.

              Even if you assume that the concerns expressed in the ACLU letter are not as dire as the ACLU presents them to be, the professor’s letter is unpersuasive. There may be more persuasive arguments out there, but this letter is not it. It is mind boggling that so many people that are held up as notable voices in the profession put their name to that letter.

              1. 1.1.1.1.3.1.1

                The ACLU letter was nothing but whining and was itself full of the fault that you wish to attribute to the response to the ACLU letter.

                It is NOT I that unsurprisingly misses the mark.

                So, AGAIN, I ask of you:

                What exactly is a concern (other than the broken scoreboard Supreme Court legislating from the bench that these groups want to hold onto) that survives the critical scrutiny and counter points already put on the table by a whole host of people (including me), directly raised by Sherry Knowles, and acknowledged by Senator Tillis at HIS Congressional hearings?

                Apply just a little critical thinking in YOUR comments.

      2. 1.1.2

        It seems misleading to say that there are constitutional bars and then not explicitly identify them.

        “Seems”?

        LOL

        Congrats, anyway, for recognizing the game that is being played by these relentlessly dishonest hacks.

        1. 1.1.2.1

          relentlessly dishonest hacks

          Malcolm and his nigh ever present Accuse Others meme…

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