by Dennis Crouch
One of the more shocking patent decisions of 2023 was Judge Alsup’s holding in Sonos, Inc. v. Google LLC, No. C 20-06754 WHA, 2023 WL 6542320 (N.D. Cal. Oct. 6, 2023). The scathing opinion left two Sonos multi-zone smart-speaker patents unenforceable due to prosecution laches and a rejection of the $32 million jury verdict. Sonos had amended its claims after after learning of Google’s particular product, and Judge Alsup found that approach inequitable, concluding that the patentee was “wringing fresh claims to read on a competitor’s products from an ancient application.” But, Sonos’ prosecution approach in the case is a widespread practice in the field and so the case raises significant questions about both patent enforcement strategies and equitable loss of rights based upon “late claiming” where claims are amended in response to market conditions.
The Appeal Brief: A Closer Look
Sonos has now filed an appeal brief that challenges Judge Alsup’s decision on several grounds, emphasizing the fairness of their patent prosecution process and arguing against the application of prosecution laches. The brief details the timeline of Sonos’s patent filings, innovations, and claim amendments, arguing these were done in good faith and within the bounds of patent law norms. I’ll reprint the introduction here:
The district court has strong views about “the way the patent system should work.” But those views conflict with the Patent Act, the Federal Rules of Civil Procedure, and this Court’s precedent. Undeterred, the district court rewrote patent law and reconstituted the judicial role to erase a $32.5 million jury verdict and throw out other patent claims that should have been tried.
To override the jury verdict, the district court recast the doctrine of prosecution laches in an unprecedented way to declare two of Sonos’s patents unenforceable. The court recognized that Sonos prosecuted the patent family diligently through several continuation applications off a 2006 provisional application. The court also acknowledged that Sonos did nothing that extended its patents’ terms. Yet the court held that Sonos took too long to prosecute the specific claims it asserted against Google here. The court was most troubled that Sonos added the asserted claims in a continuation application after Google brought its infringing products to market. But Sonos disclosed the invention years before Google even began investing in those products, and informed Google about that patent family. In fact, Sonos had already secured patents in the same family with broader claims covering Google’s products. At any rate, “amend[ing] [to] insert claims intended to cover a competitor’s product” is not “in any manner improper”—and, in fact, is entirely compatible with Congress’s design. Kingsdown Med. Consultants, Ltd. v. Hollister Inc., 863 F.2d 867, 874 (Fed. Cir. 1988). If this Court condones this novel application of prosecution laches, it will endanger many thousands of patents secured through standard continuation practice and discourage the early and complete disclosure of new innovations.
The district court also found the asserted claims invalid on the ground that Sonos did not supply adequate written description as of the claimed priority date. The court had previously rejected Google’s summary judgment motion on written description, and Google did not try that defense or a priority-date challenge to the jury. Yet the court took the reins of Google’s defense and crafted a narrative of Sonos’s subterfuge to justify its invalidity ruling. The court hinted at this story for the first time in the middle of trial, but waited until after trial to recount it fully, depriving Sonos of any opportunity to present testimony refuting it. The court found that written description for the asserted claims depended on a single sentence that Sonos added to the specification by amendment in 2019. It ignored that the specification contained additional support for the claims and the sentence in question had been incorporated by reference into every earlier application in the priority chain. Nevertheless, the court concluded that Sonos had tricked the Patent Office into allowing the amendment. That finding was inconsistent with the record evidence and depended on multiple disputed facts that would have been for jurors to decide—if anyone had ever presented the issues to them.
These intrusions into the jury’s domain were not isolated to the two patents that went to trial. On two other patents, the district court granted Google summary judgment of invalidity. But it did so only by resolving factual disputes about the prior art. This is not how Congress said the patent system should work, nor how the Federal Rules say the judicial system should work. This Court should reverse the post-trial laches and invalidity rulings on the ’885 and ’966 patents. And it should vacate the summary judgment rulings on the ’615 and ’033 patents to allow Sonos to try its case to a jury.
The outcome of the appeal could have significant implications for how patents are prosecuted and enforced. A reversal of Judge Alsup’s ruling might affirm the validity of strategic claim amendments, provided they are done within the legal boundaries. Conversely, upholding the decision could set a precedent that restricts how patent holders can amend claims in response to emerging technologies and competitors.
Sonos lead appellate counsel is Joshua Rosenkranz (Orrick), and the team includes George Lee (Lee Sullivan). Dan Bagatell (Perkins Coie) is lead appellate counsel for Google. Google has 40 days to file its responsive brief.
It’s at least footnote-worthy to mention the doctrine of intervening rights. There are certainly conflicting policy interests here, including long-standing practice. But to be clear, we’re not talking about drafting new claims that could be asserted against products/sales that have accumulated prior to issuance of the later-filed continuations.
Does the Fed Circuit intend to overall Kingsdown Medical Consultants v. Hollister?
“It should be made clear at the outset of the present discussion that there is nothing improper, illegal or inequitable in filing a patent application for the purpose of obtaining a right to exclude a known competitor’s product from the market; nor is it in any manner improper to amend or insert claims intended to cover a competitor’s product the applicant’s attorney has learned about during the prosecution of a patent application. Any such amendment or insertion must comply with all statutes and regulations, of course, but, if it does, its genesis in the marketplace is simply irrelevant and cannot of itself evidence deceitful intent. State Indus., Inc. v. A.O. Smith Corp., 751 F.2d 1226, 1235, 224 USPQ 418, 424 (Fed. Cir. 1985).”
Just to be clear about the k00k00 beliefs of the patent maximalists who spread their drool here and how deeply they think about their ridiculous selves, let’s consider a competitor that has been making and selling product X for ten years (to the tune of $10 million in profits per year). Let’s say I have a patent filed 10 years ago with continuations pending and I realize there is language “incorporated by reference” that I can rely on to (theoretically) draft a new claim that reads on product X. Absent laches, when is the latest time during which I can (1) obtain that patent claim and (2) file a lawsuit against the defendant seeking damages for at least one year of infringement.
Why would you think a properly prepared and currently live patent should be denied that which the patent bargain exists for?
Do you think just because someone else makes a product that infringes is somehow excused?
But keep on gaslighting that you are not anti-patent there, Malcolm.
It is common practice to rely on text incorporated by reference from parents of the continuation. This is SOP for doing freedom to operate opinions.
Nothing unusual about it at all.
But for Malcolm, it is a sure sign of Grifters.
¯\_(ツ)_/¯
+1
Even if Greg types a mere two characters, he cannot help himself from his OMB-TDS Kool-aid hidden signaling.
But at least here, Greg indicates for a second time how he might feel about the Israel/Hamas fiasco.
NO OTHER of our typical commentators from the Left of Center to the Sprint Left has even dared as much.
Go figure.
“ It is common practice to rely on text incorporated by reference from parents of the continuation.”
Parents of the continuation with different disclosures? You mean provisonal applications?
Because what’s far, far more common when making a claim amendment in a continuation is to rely on the text that is already right there verbatim in the application, like it’s supposed to be.
Your version of “it’s supposed to” is notorious for not being in accord with actual law.
Don’t change the subject, Billy. Nobody serious believes that applicants should be able to reach into the past and write claims using ANY words and phrases that were simply “known in the art” but appear nowhere in the patent specification or in the specification of any application claimed as a patent. To the extent there are exceptions buried in some stale case law, they are rare and probably worth a half can of beans at best.
Anyway, my point stands. The overwhelming majority of claim amendments rely on verbatim text in the specification and not text found in some reference that is “incorporated by reference.” To suggest that any other practice is “common” is to mislead.
Your point – as banal as it may be – stands for what it actually means.
This is not the broad sweep that you think it means.
And there was no “changing the subject” by me. Your odd penchant of misaimed accusations notwithstanding.
“ there was no “changing the subject” by me.”
That’s because I cut you off, Billy.
LOL – you “cut me off”…?
Neat trick on a blog wherein you have zero control or capability of so doing.
But you be you, Malcolm.
By the by – the closest thing to “cut you off” that might even be a possible analogy is when a post chases the other person away.
Like how when I ask you about the Israel/Hamas fiasco, you run away.
Thank you for proving my point for me Malcolm.
Again.
I think too that people are forgetting or not addressing the fact that laches is a doctrine created by the courts and, as such, should be used only in extraordinary cases. It is a form of equity when the result is just terrible when the law is applied.
Just outrageous to expand laches given these facts.
+1
Prosecution laches is a court-made doctrine, but it does go back more than a century to at least Woodbridge v. United States, 263 U.S. 50 (1923).
The most interesting legal question presented by this appeal is not whether there was unreasonable delay, but whether prosecution laches applies at all. The brief makes the argument that prosecution laches is a doctrine rooted in the pre-GATT world in which patent term extended 17 years from issuance. Statements in many early prosecution laches cases, and more recent Federal Circuit cases (like the Lemelson cases), did emphasize to the potentially indefinite extension of the patent monopoly, e.g., submarine patents, as one big reason for the doctrine’s existence. The brief here argues that the rationale for prosecution laches just doesn’t make sense in the post-GATT world where patent term is largely fixed based on the original application filing date (subject to PTA). In other words, the argument goes, even if Sonos unreasonably delayed, it doesn’t make any difference because that conduct did not extend the length of its patent monopoly, so prosecution laches should not apply.
It’s hard to predict what the Federal Circuit will do here. I remember people making very similar arguments long long ago predicting that obviousness-type double patenting also did not make sense in the post-GATT world, yet that doctrine survived and flourished. My prediction is that the Federal Circuit will likely say that prosecution laches is not categorically dead for post-GATT patents, even though (as a practical matter) it may be harder to prevail on that defense in the post-GATT world.
On the WD aspect, this case is interesting for those who want to “keep something pending” at the EPO” for up to 20 years following the priority filing date. No problem: simply file a succession of divisionals.
The problem is how to avoid “adding matter” each time one files amended claims because Europe is watchful against Applicants who amend to “improve their position” wrt competitors’ emerging products. Competitors must be able to base a reliable FTO opinion on theorioginal WO-A publication, regardless how long is the succession of divisionals, it is thought. And that’s right, isn’t it, also in the USA?
What an EPO Examiner thinks about such an amendment is similar to what the Caliph said about the Library at Alexandria: Either the amendment adds matter or it doesn’t. If it does, it is forbidden. If it doesn’t, there is no need to make it.
There is an echo of that here, isn’t there? If only the patent owner had refrained from adding the controversial sentence to the specification, might they not have succeeded, after all?
:dull;
Yes MaxDrie, both Europe and the US have prohibitions against adding new matter.
“At any rate, “amend[ing] [to] insert claims intended to cover a competitor’s product” is not “in any manner improper”—and, in fact, is entirely compatible with Congress’s design. Kingsdown Med. Consultants, Ltd. v. Hollister Inc., 863 F.2d 867, 874 (Fed. Cir. 1988). If this Court condones this novel application of prosecution laches, it will endanger many thousands of patents secured through standard continuation practice and discourage the early and complete disclosure of new innovations.”
What if, after being made aware of patentee’s claims, the alleged infringer makes a change so that their product, etc., does not literally fall within the scope of the claims. DOE is DOA usually. So, the patentee checks to see if he has the disclosure to pursue claims that literally read on the product. In my opinion, this is usually how it works. One small change can take a product out of literal land. Good luck with DOE.
As someone else mentioned, anyone preparing an opinion should not just be looking at the claims IF a continuing application is pending.
Patent Mom, I understand your argument, but I don’t think the scenario you’ve proposed is comparable to the facts in this particular case. The case here did not involve a patentee who filed a reasonably prompt continuation to propose new claims, after realizing a flaw with a literal infringement reading of its original claims.
The facts here are very different; the non-provisional application was filed in 2007, claiming priority to a 2006 provisional. The specific asserted claims were first introduced in 2020 through a 2019 continuation. And as detailed in the opinion, Sonos apparently had actual knowledge as of 2014 of Google’s intention to release products with multi-zone functionality, and those products were in fact commercially introduced by Google in 2015.
You thus have a delay of 13+ years from original application filing, and a delay of 6+ years from Sonos’ actual knowledge, before Sonos introduced claims attempting to cover a multi-zone feature. This is why, as I mentioned in a comment below, an affirmance of Judge Alsup’s opinion would not be a death knell for all late claiming practices in any context. If the CAFC were to affirm Judge Alsup’s decision here, it is likely it would include language emphasizing the unusual facts on which the outcome was based.
And it is just as likely it would not limit its holding, with the present court.
I do not know all the facts. For example, there could have been a change in counsel, who took a fresh look at the specification.
Regardless, even a limited holding opens Pandora’s Box. There is nothing inappropriate about the action.
+1
Are you not entitled to claim all the inventions that are described and enabled in your original filing?
Only until there are no pending applications is an applicant precluded from claiming an invention that was properly described and enabled in the original specification.
Absolutely – and as long as the “chain” is alive, all is proper.
Alsup is simply off the reservation.
“ Are you not entitled to claim all the inventions that are described and enabled in your original filing?”
And apparently according to some of the k00k00 types here “described in the patent” includes every element disclosed in every reference that is “incorporated” into the patent. Seems like a lot of liability to foist on the public but, hey, Dr. James Lindsay visited Endor and everybody’s moving to China anyway.
I see you tryingto make a point.
You just don’t make it.
Maybe less on the attempted insult, and more on the “point.”
Good point Lode. We’d all (well, except perhaps for Malcomtent, of course) better hope the CAFC doesn’t Rule 36 this one.
‘Cause if they do, . . .
Late claiming is a strange concept, one where the law and the view of the “everyman” on the street diverge so vastly.
It’s been the law, for more than 30 years, that “late claiming” is permissible provided that the late-submitted claims otherwise comply with the patent rules. To quote Judge Markey’s decision from Kingsdown Medical Consultants, Ltd. v. Hollister Inc., 863 F.2d 867, 874 (Fed. Cir. 1988): “It should be made clear at the outset of the present discussion that there is nothing improper, illegal or inequitable in filing a patent application for the purpose of obtaining a right to exclude a known competitor’s product from the market; nor is it in any manner improper to amend or insert claims intended to cover a competitor’s product the applicant’s attorney has learned about during the prosecution of a patent application. Any such amendment or insertion must comply with all statutes and regulations, of course, but, if it does, its genesis in the marketplace is simply irrelevant and cannot of itself evidence deceitful intent.”
That case obviously dealt with inequitable conduct and not prosecution laches (which does not have the same intent requirement), but the idea that “late claiming” is an accepted and arguably encouraged practice, is deeply ingrained into the psyches of patent practitioners.
But if you ask “normies” out there, they see late claiming as a deceitful practice, and judges routinely grant motions to preclude defendants from making “late claiming” arguments to a jury because they will severely prejudice the jury against the plaintiff/patentee. There have been numerous focus group studies on this, and the results are consistent; it feels like “cheating” to the average person for a patentee to write a new claim with the intention of covering an existing product. It also doesn’t surprise me that a generalist judge, like Judge Alsup, would take a position similar to the “normies” and one at odds with established patent practice.
The obvious answer to the late claiming question is that, if the written description supports and enables the late-filed claim, then what’s the big deal? The patentee in this situation isn’t introducing anything into its patent that wasn’t already part of the disclosed invention of its original application, even the motivation for a particular claim or set of claims was something it saw in the market after filing.
The flipside of this argument is that, of course as we all know, “late claiming” scenarios incentivize patentees to press the limits of their written description to the absolute breaking point, which often results in claims of dubious validity issuing without much if any 112 scrutiny which are almost impossible to invalidate in district court (since 112 issues was something the Examiner would have “considered”). In this case, Sonos waited until 2020 to file these claims, despite claiming priority back to a 2007 non-provisional application, and there is an allegation that some new matter was introduced into the specification with the 2019 amendment without informing the Examiner.
It will be interesting to see how this case turns out, but I suspect it will be decided largely on its facts; even affirmed, it won’t result in a broad pronouncement against late claiming given the somewhat unusual facts here.
“It also doesn’t surprise me that a generalist judge, like Judge Alsup, would take a position similar to the “normies””
Judge Alsup has handled a LOT of patent cases. Your use of the term “normie” in any context highlights you as a bit of an imbecile but in this context … wow.
“ The patentee in this situation isn’t introducing anything into its patent that wasn’t already part of the disclosed invention”
Except that the patentee did amend their specification to provide express verbiage that was, if I’m not mistaken, also put into a late-filed claim in a continuation. And then the patentee somehow “forgot” or otherwise failed to point this fact out to Judge Alsup.
“ even affirmed, it won’t result in a broad pronouncement against late claiming ”
Of course it won’t because that’s not what the case is about.
“Except that the patentee did amend their specification to provide express verbiage that was, if I’m not mistaken, also put into a late-filed claim in a continuation. ”
It was not new matter at the time of the amendment, so your point is…?
“And then the patentee somehow “forgot” or otherwise failed to point this fact out to Judge Alsup.”
And again, this is false. They pointed out the complete record to the Judge. They have no obligation further than that. It was the other side that made the flub.
Your penchant against patent holders is shining through – again.
Judge Alsup has handled a LOT of patent cases.
Funny you mention that as a case came out today from the Federal Circuit in which Alsap was reversed by the Federal Circuit. The Defendant-Appellee was Meta.
It happens.
That verbiage had been incorporated by reference. As such, it can be added later and is not considered new matter.
“Incorporation by reference” does not provide an unlimited grab bag of verbiage for claim amendments. There is case law around this topic.
Note: I’m not saying that what was pulled out of the incorporated reference in this case was out of bounds. But the 112 issue doesn’t disappear just because the spec incorporates by reference the Library of Congress.
From their brief:
“It ignored that the specification contained additional support for the claims and the sentence in question had been incorporated by reference into every earlier application in the priority chain.”
Prophet, you say:
>Judge Alsup has handled a LOT of patent cases. Your use of the term
>“normie” in any context highlights you as a bit of an imbecile but in
>this context … wow.
FWIW if you bothered to read my comment, you’d see that I never called Judge Alsup a normie, but a “generalist” judge. Judge Alsup has done a number of patent cases but they do represent a small percentage of his overall docket, consistent with all but a small handful of federal district court judges. As a generalist, he’s far less likely to feel constrained by the prevailing wisdom of those who spend all of their time on patent prosecution.
“ Judge Alsup has done a number of patent cases”
LOL
Try “hundreds.” He’s one of the more experienced District Court Judges in the country in that regard, particularly in the logic arts.
Are you insinuating that volume of cases provides indicator of “correct knowledge?”
Wouldn’t that be the opposite of your view in regards to Texas judges?
(Not the first time that your view of Judges runs into the bite of ‘be careful of what you wish for’)
Lode_Runner: I basically agree. I think too that you need to incorporate the outrageous attempt to extend the laches doctrine when it simply does not apply.
There was no intentional delay of prosecution. There was no intent to deceive anyone or ill purpose in their conduct with the PTO. The public was aware of their specification and that it was still pending.
A good comment, that the Fed. Cir. has held that “late claiming,” i.e., adding or changing claims at any time, no matter how long the application has been kept pending in serial continuations, is legal in the U.S. as long as there is original specification 112 support, yet that seems strange to some people, like this D. C. judge, and those in some other countries. Kingsdown Medical Consultants, Ltd. v. Hollister Inc., 863 F.2d 867, 874 (Fed. Cir. 1988) in particular. Even though the U.S. even allows after a patent issues [with a time limitation, etc.] claim broadening reissues.
However, the very long serial prosecutions with many late-added claims of Mr. Lemelson, and PTO lack of enforcement of either prosecution laches or docket control from true priority. did lead to changing U.S. patent terms – from 17 years from issuance to 20 plus or minus years from earliest priority application claim. As noted, that puts a time limit on applicant-delayed prosecution.
P.S. Re the additional issue here, of a specification amendment allegedly needed [or not] to provide some language support for some late-added claims, note that both the 112 “written description” and “enablement” requirements are considered fact rather than legal issues. And, as noted, the defendants burden below. Also, as an invalidity argument, supported with clear and convincing evidence. All that is logically going to affect how the Fed. Cir. will deal with this issue in this appeal.
I agree. I would point out also that there was a “late claiming” limitation in the (pre-AIA) interferences section of the statute (35 USC 135(b)). It prevented adding a claim to an application to provoke an interference more than one year after the same or substantially the same subject matter appeared in a granted patent or published application. But that is gone now, along with interferences, and the statutory section has been converted into a provision regarding derivation proceedings with a one-year deadline for filing a petition for a derivation proceeding. The old section could be the origin though of much former “late claiming” jurisprudence that this judge somehow seeks to resurrect.
Two thoughts:
1) I am skeptical that—if you asked a representative sample of non-patent-professionals about this subject—they would have any particular at all, or at least one that was not entirely mutable according to the phrasing of the question.
2) There are surely patent-related questions on which public opinion is relevant, but this is not one.
Tw”o”…
S”u”rely…
Never ending spigot of kool-aid.
It’s worth remembering that late claiming does limit your damages under Section 154(d) i.e., there is a statutory limit on it.
FWIW, I’d guess that if you explained to normie that you can almost-always avoid patent infringement by making a trivial change to your product (i.e, one part with same function/way/result as the patentee’s part), they’d also consider that as “cheating.” Lawyers!
IIRC, there was a federal circuit decision many years ago, concerning a pre-GATT patent, that involved the question of laches. Application was for a small molecule – a new active pharmaceutical ingredient. The applicant was a small pharmaceutical company that didn’t have the wherewithal to run the FDA gauntlet alone, so it looked for a strategic partner, but it took several years to find one. On several occasions during that time, it received a notice of allowance, and each time it filed a continuation. Once it had secured a partner, it paid the issue fee for the next allowance.
When the patentee went to assert the patent, the defendant argued prosecution laches. The CAFC didn’t bite, and noted that because of the FDA approval process, the applicant merely wanted to be sure that there would be a product to protect – and that if the patent life was too short b/c the issue fee was paid at a time when there was no strategic partner, the drug would never have made it to market.
That decision was authored by Judge Newman.
link?
I’m not sure if this is the case Mr. Feigelson has in mind, but it’s an old prosecution laches case involving repeated continuation filings in response to the examiner’s lack of utility rejections due to no FDA approval (or something like that). It was an opinion by Judge Lourie, with Judge Newman joining (Judge Prost dissenting).
link to cafc.uscourts.gov
Thanks, that’s the case I was thinking of. I’d forgotten some of the details, like the fact that it was Lourie (!) who authored the decision, with Newman joining and (surprise!) Prost dissenting.
The critical point on the laches issue was that (a) there has to be prejudice to the accused infringer for laches to apply, and (b) there was no prejudice to the defendant Barr, since without FDA approval there was no product in the market to copy, the patentee actually lost Patent Term Extension time due its delay in prosecution and thus harmed itself, and Barr itself waited four years after the first date it could have filed an ANDA to do so.
“And, it also should be noted that, when one considers the public interest, the public has benefited here by the fact that Cancer Research did develop and market temozolomide, induced by the protection of its patent. Cancer Research should not lose that protection because its patent issuance was delayed under circumstances where no one suffered prejudice”
He also noted that “the facts of this case are not likely to be frequently repeated, as patent terms are now measured from effective filing date, id § 154(c)(1), subject to only limited extensions provided by statute, not by delaying issuance by refiling”.
Thank you both.
There was also a denial of rehearing en banc, with dissents by Judge Prost and Judge Dyk. The vote was 5-5, so there was no “majority” in favor of rehearing.
Given the changes in the makeup of the judges since 2011, I have to wonder how strong of a precedent this case is.
link to cafc.uscourts.gov
As strong as any other precedent.
Do you think ‘numbers’ change the strength?
Would that not be like being “a little bit” pregnant?
yes nobody noticed you didn’t answer Snowflake.
so go rest and in the morning provide a 500 word essay about ‘remanding back’
where is it morning where you are?
eight days later on an unconnected discussion thread….
You’ve tried this trick many times in the past, Shifty.
Has it ever worked for you?
(why would I answer YOUR point to the good professor on “remanding back?”)
Excellent point, Dan. Thanks for sharing that.
“p”oint…
In the midst of the worst border crisis EVER (and one entirely due to Puppet Biden), Greg wants to signal with Yglesias OMB-TDS nonsense?
Put
the
Kool-aid
Down.
“the worst fake border crisis EVER”
LOL. Even worse than the fake caravan of 200,000 Mexican gang members and escaped prisoners that assaulted the border in 2018?
Fake…?
I see that you have not received your updated Sprint Left talking points that moved the issue from “denial” to “blame Trump.”
C’mon Man.
Oh snap I noticed two people speaking Mexican at the grocery store today. Probably plotting to steal some jobs from Billy’s friends!
U m, nice – keep those eyes clenched tight as those Sanctuary City mayors keep whining.
Since you are pretending to not understanding world events, have you heard of this fiasco between Israel and Hamas?
This is in response to your “speaking Mexican” comment. It is called Spanish. There is no separate Mexican language. My husband is from Mexico. There may be some native dialects, but they speak Spanish generally.
It’s sarcasm. Are your husband’s papers in order, by the way? Probably it’s time for an audit and perhaps another test to confirm his fitness for our proud nation in this time of crisis and dilution of True American stock. I gather you’ve reproduced already which is how these invaders tend to operate.
Why are you such an arse? My husband is a naturalized citizen.
And he loves this country, and loves Trump. He was a republican before I was.
He is against the invasion at the southern border. See, unlike you, he knows the cartels are the ones running the southern border. They charge thousands per person. Guess what happens to the women and children if they cannot pay. Go on. Guess. Here is a hint. It has something to do with trafficking.
“ My husband is a naturalized citizen.”
Haha. Good luck with that. Does he his long form birth certificate? And I mean the really long one that he definitely doesn’t have. He doesn’t have that one? Oh, that’s a pity.
“He loves this country, and loves Trump.”
LOL. Any other con artist, r a p i s t defamers on his list of loved ones or is it just this particular spray-tanned bag of snail waste that your deportable hubby loves?
And there is your discrimination coming out. He cannot run for President, it is in the Constitution. So, no worries there. Since you are a foreigner, you do not understand.
Now address the cartels running the border.