Date:
20061222
Docket: A-168-05
Citation: 2006 FCA 421
CORAM: RICHARD
C.J.
NOËL
J.A.
EVANS
J.A.
BETWEEN:
APOTEX INC.
Appellant
(Respondent)
and
SANOFI-SYNTHELABO CANADA INC.
and SANOFI-SYNTHELABO
Respondents
(Applicants)
and
THE MINISTER OF HEALTH
Respondent
(Respondent)
REASONS FOR JUDGMENT
NOËL J.A.
[1]
This is an
appeal from the judgment of Shore J. of the Federal Court (2005 FC 390)
prohibiting the Respondent Minister of Health from issuing a Notice of
Compliance (“NOC”) to Apotex Inc. (“Apotex” or “the appellant”), pursuant to
the Patented Medicines (Notice of Compliance) Regulations, SOR/93-133
(“NOC Regulations”), with respect to its 75 mg clopidogrel bisulfate tablets
until the expiry of Canadian Letters Patent No. 1,336,777 (“the ‘777 Patent”).
[2]
The
appellant alleges that the patent in issue is invalid on the grounds of
anticipation, obviousness and double patenting and that accordingly there was
no basis for the issuance of an order of prohibition.
RELEVANT FACTS
[3]
By Notice
of Application dated April 28, 2003, Sanofi-Synthelabo Canada Inc. and
Sanofi-Synthelabo (collectively “the respondent” or “Sanofi”) initiated a
proceeding before the Federal Court seeking an order, in accordance with
subsection 6(1) of the NOC Regulations, prohibiting the Minister from issuing a
NOC to Apotex in connection with its 75 mg clopidogrel bisulfate tablets until
the expiry of Sanofi’s ‘777 Patent in 2012.
[4]
The ‘777 Patent
relates to the invention of clopidogrel, a process for its preparation and
pharmaceutical compositions containing it. Clopidogrel is one half of a larger
chemical compound: Methyl alpha-5- (4, 5, 6, 7 tetrahydro (3,2-c) thieno pyridyl)
(2-chlorophenyl)-acetate. The compound in question is a racemate: a substance
containing equal amounts of two optical isomers, known as the dextro-rotatory
isomer (also known as the d enantiomer, and represented by [+]) and the
levo-rotatory isomer (also known as the l enantiomer, and represented by
[-]). Clopidogrel is the common name for the dextro-rotatory isomer of the
compound.
[5]
The dextro-rotatory
isomer has beneficial properties over both the racemate and the levo-rotatory
isomer. Specifically, the advantages of the dextro-rotatory isomer are that it
contains all of the platelet aggregation inhibiting activity and is less toxic
and better tolerated (Reasons, paras. 22 and 81):
In an
unexpected manner only the dextro-rotatory enantiomer Id exhibits a
platelet aggregation inhibiting activity, the levo-rotatory enantiomer I1 being
inactive. Moreover, the inactive levo-rotatory enantiomer I1 is the
less well tolerated of the two enantiomers (‘777 Patent A.B. Vol. 1 p. 71).
[6]
The ‘777
Patent also relates to the invention of the bisulfate salt of the
dextro-rotatory isomer. The dextro-rotatory isomer in a free base form (i.e.
not as a salt) exists as an oil. Oily products are difficult to purify and
products which can be purified by crystallization (e.g. salts) are better
suited for the preparation of pharmaceutical compositions. It was observed by
the inventors that many of the salts of the dextro-rotatory isomer precipitated
in an amorphous form and/or were hygroscopic, a property which makes them
difficult to handle on an industrial scale. Therefore, many of the salts
classically used in pharmacy proved to be difficult to purify. The ‘777 Patent
states that the claimed bisulfate salts crystallized easily, were not
hygroscopic and were sufficiently water soluble to make their use particularly
advantageous in pharmaceutical compositions (Reasons, para. 23).
[7]
On March
10, 2003, Apotex served a Notice of Allegation (“NOA”) on Sanofi in an attempt
to obtain a NOC for a generic version of Sanofi’s 75 mg clopidogrel bisulfate
tablets, which are commercially known to as PLAVIX. In the NOA, Apotex alleges
that claims 1, 3, 10, and 11 of the ‘777 Patent are invalid because they are
anticipated by Canadian Letters Patent No. 1,194,875 (“the ‘875 Patent”),
published on its issue date of October 8, 1985. Alternatively, Apotex alleges
that all of the said claims are invalid on the basis of obviousness or double
patenting.
[8]
The
construction of these claims is not in dispute.
[9]
The ‘875 Patent,
as well as its American and French counterparts, discloses and claims a large
class of compounds useful in providing platelet aggregation inhibiting
activity, and a process for the preparation of such compounds. While the ‘875 Patent
discloses over 250,000 possible different compounds, only 21 individual
compounds are specifically identified (referred to as derivatives 1-21). All
of these derivatives are racemates. Example 1 at page 3 of the ‘875 Patent deals
with derivative No. 1 which is the racemate from which the separated isomers
were obtained in the ‘777 Patent (‘875 Patent, page 3, A.B., Vol. VII at
p. 2372).
[10]
The Applications
Judge notes that the compounds identified in the ‘875 Patent can exist as
racemates or isomers, and quotes in his reasons the passages of the ‘875 Patent
which state the existence of isomers directly or by reference to other claims
(Reasons, para. 29). However, there is no teaching on how to separate the
racemates into their isomers, and no mention or suggestion that there are any
pharmaceutical or toxicological differences between the isomers of the
disclosed racemates with respect to activity or tolerability (Reasons, para.
30).
DECISION UNDER APPEAL
[11]
In the decision
under appeal Shore J. held that the ‘777 Patent was valid and rejected Apotex’ allegations
of anticipation, obviousness and double patenting. In particular, the
Applications Judge concluded, that claim 1 of the ‘777 Patent was not
anticipated by the prior art, since an ordinary person skilled in the art who
followed the teachings of the ‘875 Patent would only be able to replicate the
racemate and not the dextro-rotatory isomer (Reasons, para. 88).
[12]
He further
held that claim 1 was not obvious, since a chemist would not be able to
determine which isomer possessed the beneficial properties without first separating
the optical isomer and testing them (Reasons, para. 89).
[13]
The
Applications Judge further found that claim 3 was neither anticipated, nor
obvious, since the ‘875 Patent does not explain how to obtain a separated
dextro-rotatory isomer of the racemate, and there is sufficient inventive
ingenuity in the selection of the bisulfate salt that it could not have been
obtained following the prior art (Reasons, paras. 90 and 91).
[14]
Finally, given
these findings, the Applications Judge held that claims 10 and 11 with respect
to pharmaceutical compositions of the dextro-rotatory isomer of the racemate
are neither anticipated, nor obvious (Reasons, para. 92).
ISSUES
[15]
The
issues, as defined by the appellant, are restricted to the following three questions
of law:
a.
Did the Applications Judge err in failing to
adopt the perspective of the notional technician skilled in the art for the
purpose of construing the ‘777 Patent and the prior patents, and for the
purpose of assessing the questions of anticipation, obviousness and double
patenting?
b.
Did the Applications Judge err in stripping the
notional person skilled in the art of the ability to perform workshop activity
when assessing the questions of anticipation, obviousness and double patenting,
and by finding that the application of known techniques to ascertain the
inherent properties of known compounds was inventive?
c.
Did the Applications Judge err in failing to
follow this Court’s decision in SmithKline Beecham Pharma Inc. v. Apotex Inc.
on the question of anticipation?
ANALYSIS
Preliminary Comment
[16]
As
background to its arguments on appeal, the appellant claims that Shore J. erred
in treating the patent in issue as a valid selection patent. Although Shore J.
did not actually use the expression “selection patent”, he did conduct his
analysis on the basis that the ‘777 Patent came within that description. Simply
put, a valid selection patent is one which claims an advantage for a compound
within a previously disclosed class of compounds which has not been disclosed
in the prior patent.
[17]
The law
with respect to selection patents was recently applied by this Court in Pfizer
Canada Inc. v. (Minister of Health), 2006 FCA 214 (Pfizer v. Canada).
Malone J.A. writing for the Court explained the rationale for the treatment
given to selection patents:
[3] There are two general
classes of chemical patents. The first is the 'originating patent' where there
is an originating invention involving the discovery of a new reaction or a new
compound. The second is the 'selection patent', which is based on a selection
from related compounds derived from the original compound and which have been
described in general terms and claimed in the originating patent (see In the
Matter of I.G. Farbenindustrie A.G.'s Patents, (1930) 47 R.P.C. 283 at page
321 per Maugham J.).
[4] While there is little
Canadian jurisprudence on the subject of selection patents, its elements are
well defined in I.G. Farbenindustrie. Lord Diplock cited this decision
with approval in the House of Lords where he stated that the 'inventive step in
a selection patent lies in the discovery that one or more members of a
previously known class of products possess some special advantage for a
particular purpose which could not be predicted before the discovery was made'
(see Beecham Group Ltd. v. Bristol Laboratories International S.A.
[1978] R.P.C. 521 at page 579). All claimed members of the known class must
have the advantage and the advantage must not be one that those skilled in the
art would expect to find in a large number of the previously disclosed class
(i.e. a quality of special character) (see I.G. Farbenindustrie at page
323).
[5] Selection patents exist to
encourage researchers to further use their inventive skills so as to discover
new advantages for compounds within the known class. A selection patent can be
claimed for a selection from a class of thousands or for a selection of one out
of two (see for example I.G. Farbenindustrie at page 323 and E.I.
Dupont de Nemours & Co (Witsiepse's) Application,[1982] F.S.R. 303
(H.L) at page 310).
[18]
In E.I. Dupont de
Nemours & Co., Lord Wilberforce provided the following guidance in determining
when a prior publication will preclude the patenting of a related development
(pp. 310-311):
…, disclosing a prior
invention does not amount to prior publication of a later invention if the
former merely points the way which might lead to the latter. A much quoted and
useful passage is that from the judgment of the Court of Appeal in General
Tire & Rubber Co. v. Firestone Tyre & Rubber Co. [1972] R.P.C. 456
at 486. There Sachs L.J. said:
“A signpost, however,
clear, upon the road to the patentee’s invention will not suffice. The prior
inventor must be clearly shown to have planted his flag at the precise
destination before the patentee.”
Attractive metaphors may
be dangerous for those in search of precision, but the passage illustrates the
necessity that the alleged prior disclosure must clearly indicate that use of
the relevant material (i.e. that ultimately selected) does result in a product
having the advantages predicted for the class. The point is well put by the New
Zealand Court of Appeal. Dealing with semi-synthetic penicillin, the court
(per Cooke J.) said:
“If such a compound has
not been made before, its properties often cannot be predicted with any
confidence; and where that is the case we do not consider that the invention
claimed can fairly or accurately be described as ‘published’, even if a skilled
chemist would realize that to make the compound by routine means would be
practicable. A making of the compound and a discovery of its properties is
necessary before the ‘invention’ has occurred and can be published.” (My
emphasis)
This is in line with,
but adds a useful precision to what was said by Maugham J.:
“It must be remembered,
of course, that the selected compounds have not been made before, or the patent
would fail for want of novelty.” (I.G. Farbenindustrie A.G.’s Patents, 1.c. p.
321.)
[19]
The ‘875 Patent and the ‘777
Patent lend themselves to the analysis predicated for selection patents. The
‘875 Patent discloses a general class of compounds useful in providing platelet
aggregation inhibiting activity and a process for the preparation of such
compounds. The ‘777 Patent on the other hand identifies the dextro-rotatory
isomer of a particular racemate disclosed in the ‘875 Patent which has never
been separated and which, once separated, produces an isomer found to have
special properties.
[20]
It follows
that both patents must be examined to see whether the ‘875 Patent directs the
way to this isomer (clopidogrel) and its special properties with sufficient
clarity to bring it within the ambit of the ‘875 Patent. This is how the
Applications Judge conducted his analysis and this is the background against
which the appellant’s allegations of invalidity are to be assessed in this
appeal.
Invalidity Based on Anticipation
[21]
The appellant
argues that the Applications judge erred in failing to apply the legal test for
anticipation as formulated in SmithKline Beecham Pharma Inc. v. Apotex Inc.,
2002 FCA 216 (SmithKline). The SmithKline case, the appellant
argues, is precisely analogous to the case at bar and should have been followed
by Shore J. The appellant further argues that Shore J. erred in not permitting
the person skilled in the art to exercise mechanical skill by employing trial
and error experiments to arrive at the invention. Finally, the appellant
submits that Shore J. erred by mistaking the inventor for the notional skilled
person.
The Test
[22]
The test
for anticipation was set out by Hugessen J.A. in Beloit Canada Ltd. v.
Valmet Oy (1986), 8 C.P.R. (3d) 289 (F.C.A.) at p. 297, and later adopted
by the Supreme Court in Free World Trust v. Électro Santé Inc., [2000] 2
S.C.R. 1024 (Free World), at paragraph 26:
One must, in effect, be
able to look at a prior single publication and find in it all the information
which, for practical purposes, is needed to produce the claimed invention
without the exercise of any inventive skill. The prior publication must contain
so clear a direction that a skilled person reading and following it would in
every case and without the possibility of error be led to the claimed
invention. [emphasis added]
[23]
Thus, the
prior art must provide clear and sufficient direction which, if followed, would
be within the claim. If further ingenuity is required to put the prior art
into practice, it is not anticipation. In Free World, at paragraph 25,
the Supreme Court of Canada noted the difficulty of establishing anticipation:
Anticipation by
publication is a difficult defence to establish because courts recognize that
it is all too easy after an invention has been disclosed to find its
antecedents in bits and pieces of earlier learning. It takes little ingenuity
to assemble a dossier of prior art with the benefit of 20-20 hindsight.
[24]
In SmithKline,
the test for anticipation was explained by Linden J.A. He held, at paragraph
19:
The cases referred to by
SmithKline [Pfizer Canada Inc. v. Apotex Inc. (1997), 77 C.P.R.
(3d) 547; Farbwerke Hoechst v. Halocarbon (Ontario) Ltd., [1979] 2 S.C.R. 929, at page 942; and General
Tire & Rubber Co. v. Firestone Tyre & Rubber Co., [1972] R.P.C. 457 (C.A.)] are distinguishable
from the situation before this Court. In each of the cases cited by SmithKline,
the instructions of the prior art set out a general class of compounds or
reactions from which one could arrive at the later invention. The later
inventions were not anticipated in those cases because the particular compounds
in the claimed invention were not identified in the prior art and, therefore,
the identification of the particular compounds used in the claimed invention
was novel and inventive. In those cases, the prior art did not "enable a
person of ordinary skill and knowledge in the field to understand . . . `the
nature of the invention and carry it into practical use without the aid of inventive
genius but purely by mechanical skill'" (Free World Trust, supra,
at paragraph 26). Since the prior art in those cases did not clearly and simply
describe the latter alleged invention, a further inventive step was required.
Linden J.A. added that where an “inventive step or skill”
was required, there could be no anticipation.
[25]
In the
present case, the Applications Judge found that the impugned claims of the ‘777
Patent were not anticipated. His conclusion was based on the finding that,
although the ‘875 Patent generally discloses the existence of optical isomers
as part of a large class of compounds, it does not specially disclose the optical
isomers of the compound in question or their properties. Shore J. also noted
that if one were to follow the teachings of the prior art, one would obtain a
racemate, and never an optical isomer (Reasons, para. 60).
[26]
In holding
that anticipation had not been demonstrated, Shore J. relied on the decision of
the Federal Court, Trial Division in Pfizer Canada Inc.
v. Apotex Inc. (1997), 77 C.P.R. (3d) 547 (Pfizer v. Apotex). In that case, a prior art
patent was found not to be an anticipation of a specific compound because one
could follow the prior art and not be able to make the compound. While Apotex
argued before Shore J. that Pfizer v. Apotex was implicitly overuled by SmithKline,
he found that the latter decision merely distinguished Pfizer v. Apotex
on its facts. It did not, as Apotex suggested, preclude a finding that
a prior art patent that does not identify a specific compound of a broad
generic class of compounds is not anticipated (Reasons, para. 59 infine).
[27]
There is
no doubt about the correctness of that conclusion, given the recent pronouncement
by this Court in Pfizer v. Canada, supra in which the Court upheld the
validity of a patent as a selection patent despite the fact that the claimed
substance came within the general class of compounds claimed in a prior patent.
[28]
In my
respectful view, it was open to the Application Judge on the record before him
to conclude that the ‘875 Patent did not specifically lead to the claimed
invention. The processes disclosed only resulted in a racemate and although Example
1 in the ‘875 Patent refers to the separation of the isomers “if desired” there
are no references to techniques for separating the isomers (Reasons, para.
29). Indeed, the evidence shows that it is impossible to predict which method
of separating the enantiomers will work.
Trial and Error
[29]
Apotex
attempted to fill the gap by insisting on the uncontested fact that the methods
for separating the enantiomers are well known to persons skilled in the art.
According to Apotex such a person could eventually obtain the isomer through what
amounts to mere verification.
[30]
However, the
Applications Judge found that the evidence with respect to the methods of
separation including that of the inventor, shows that the identification of
clopidogrel and its advantages required extensive investigation over a period
of months (Reasons, paras 68 to 70). Shore J. further found that the special
properties of the claimed isomer could not have been ascertained before it was
produced and tested (Reasons, paras. 81 and 82). These findings are
inconsistent with Apotex’ argument that only mere verification was involved
(i.e., confirming predicted and predictable qualities of known compounds) and
indeed exclude the possibility of anticipation (see Pfizer v. Canada, supra, at paras. 21 to 24).
[31]
Shore J.
went on to find that the ‘875 Patent did not disclose the advantages which flow
from using only the dextro-rotatory isomer (i.e., in contrast with the
levo-rotatory isomer, it is both more active and less toxic). He found that
both these beneficial properties were unexpected and could not have been
anticipated from the teachings of the ‘875 Patent.
[32]
At the
hearing of the appeal, Apotex argued that there was no evidentiary foundation
for the finding that the advantages of the dextro-rotatory isomer were
unexpected. Counsel for Apotex referred to the evidence of Dr. McClelland, that
on the basis of the prior art it was known that these advantages would “often”
result. Counsel argued that if this is so, the alleged advantages could not
have been unexpected.
[33]
However,
counsel for the respondent took us to the affidavit evidence and the transcript
of Dr. McClelland’s cross-examination and demonstrated that while Dr.
McClelland did indicate that you “often” get more activity, the answer to the question
whether this increased activity was to be found in the levo-rotatory isomer
(the l enantiomer) or the dextro-rotatory isomer (the d
enantiomer) was unknown (see the Affidavit of Dr. McClelland, A.B.,Vol. II, p.
369 at para. 42 and the Cross-examination of Dr. McClelland, A.B., Vol. III, at
pages 928-930). Moreover, there was no evidence that the person skilled in the
art would know that the more active isomer would also be less toxic
(Cross-examination of Dr. McClelland, supra, question 322).
Person Skilled in the Art
[34]
Apotex further
argues that Shore J. erred in confusing the inventor of the compound (Mr.
Badorc) with the ordinary person skilled in the art. According to Apotex, this
error was compounded when Shore J. concluded that, since Mr. Badorc did not
easily arrive at the invention, it could not have been anticipated (Appellant’s
Memorandum, paras. 31-34).
[35]
With
respect, I do not believe that to be the case. Shore J. set the parameters of
the ordinary person skilled in the art, based on the description proposed by
the parties at paragraphs 18 and 19 of his reasons, and concluded at paragraph
69 that Mr. Badorc “possessed the characteristics” of a person skilled in the
art. In my view, this shows that Shore J. did not equate Mr. Badorc to the
notional construct of the skilled person. Rather, he held that, although the
inventor, Mr. Badorc also had the characteristics of the person skilled in the
art.
[36]
According
to Shore J., even though Mr. Badorc possessed these characteristics, he was
still unable to separate the isomer “in every event and without the possibility
of error”. Not only does this show that the prior art was lacking in clarity
and direction for the separation of the isomers in question, it also serves to
demonstrate that, despite Mr. Badorc’s intuitive abilities, he was unable to
replicate the experiment without difficulty and without error.
[37]
In my
respectful view, Apotex has failed to demonstrate that in this case, the prior
art would lead the person skilled in the art in every case and without the
possibility of error to the claimed invention. The argument that Shore J. erred
in concluding that the ‘777 Patent is invalid based on anticipation must
accordingly fail.
Obviousness
[38]
The test
for obviousness was set out in Beloit,
at 294:
The test for
obviousness is not to ask what competent inventors did or would have done to solve
the problem. Inventors are by definition inventive. The classical touchstone
for obviousness is the technician skilled in the art but having no scintilla of
inventiveness or imagination; a paragon of deduction and dexterity, wholly
devoid of intuition; a triumph of the left hemisphere over the right. The
question to be asked is whether this mythical creature (the man in the Clapham
omnibus of patent law) would, in the light of the state of the art and of
common general knowledge as at the claimed date of invention, have come
directly and without difficulty to the solution taught by the patent. It is a
very difficult test to satisfy.
[39]
Apotex
submits that Shore J. incorrectly applied this test. In its memorandum, it
argues that the correct approach to determine the obviousness of a claim for a
single enantiomer of a previously-known racemate was described in the recent
Federal Court decision refusing the issuance of an order of prohibition in Janssen-Ortho
Inc. v. Novopharm Ltd., 2004 FC 1631, per Mosley J (Appellant’s Memorandum,
para. 46). In that case, it was found that the claims for levofloxacin, its
salts and their formulations were obvious, even though the process required the
skilled person to separate the enantiomers, compare their utility and prepare
suitable formulations. Apotex takes the position in its memorandum that the
separation process involved in the present case is indistinguishable. Mosley
J’s decision was confirmed on appeal, but on grounds which do not address its
merits (2005 FCA 2; leave to appeal to the S.C.C. refused, [2005] 1 S.C.R. 776).
[40]
However, since
that time and after Apotex filed its memorandum, Hughes J. of the Federal Court
rendered a further decision in an infringement case involving the same patent and
the same parties in which, relying on a more fulsome record, he declined to
follow the approach predicated by Mosley J. and indeed came to the opposite
conclusion on the issue with which we are concerned (see Janssen-Ortho Inc.
v. Novopharm Ltd., 2006 FC 1234 at paras. 115-116). Apotex, without
withdrawing its argument that Mosley J. adopted the proper approach, did not
speak to this argument at the hearing of the appeal. Given that the decision
of Hughes J. is currently under appeal it is sufficient to say that I can
detect no error in Shore J’s application of the law to the facts before him.
[41]
Beyond
this first argument, Apotex repeats and adopts the submissions made with
respect to anticipation (as applicable) insisting that, since the methods of
separation were well known, the claimed invention and its advantages would have
been obvious to the person skilled in the art (Memorandum, paras. 54-57).
[42]
However, as
alluded to earlier, Shore J. found that although well known, the separation
techniques had to be tried with uncertainty as to which would actually result
in a successful separation. He further found that the person skilled would not
know, before separating the racemate into its isomers and then testing the
separated isomers, what the properties of the dextro-rotatory isomer would be
(Reasons, para. 81). Similarly, he found that the person skilled in the art
would not know before trying the different salts in combination with the
dextro-rotatory isomer what the bisulfate salt’s beneficial properties would be
(Reasons, para. 82). Moreover, it would seem from the evidence of Mr. Badorc
that each of the methods of separation presented their own technical
difficulties. It was not a matter of mechanically going through questions on a
checklist.
[43]
These
findings of fact as to the difficulty involved in producing the claimed
compounds and the impossibility of predicting the claimed advantages before the
compounds could be produced and actually tested are amply supported by the
record and unchallenged by Apotex (otherwise than by its attempt to recast
these findings through its own – and in my respectful view flawed – vision of
the person skilled in the art).
[44]
In the
end, Shore J. held, at paragraph 84 of his reasons, that “a person skilled in
the art would not, in light of the prior art, have been led directly and
without difficulty to the dextro-rotatory isomer of the racemate, its bisulfate
salt and their pharmaceutical compositions.” It has not been shown that Shore
J. committed any reviewable error in coming to this conclusion.
Double Patenting
[45]
Finally,
Apotex submits that the claims for the ‘777 Patent are invalid for double
patenting. A claim of a patent is invalid for double patenting if the same
invention is the subject of a prior patent. The rule is that no person may obtain
two patents for the same invention thereby extending the statutory monopoly for
what is claimed in the first patent (Whirlpool v. Canco, 2006, 9 C.P.R.
(4th) 129 at para. 63 (S.C.C.).
[46]
The short
answer to this argument is that in this case, the relevant art relied upon for
double patenting is the same as that which has been canvassed in the analysis
pertaining to anticipation and obviousness. Since, based on that analysis, the
‘875 Patent and the ‘777 Patent claim different and distinct compounds, there
cannot be “double patenting”.
[47]
I would
dismiss the appeal with costs.
“Marc
Noël”
“I
agree
J. Richard C.J.”
“I
agree
John M. Evans J.A.”
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