Combating Opioid Misuse – COMBAT (Curb Opioid Misuse By Advancing Technology Act of 2016)

The Congress recently introduced a bill on the COMBAT Act (Curb Opioid Misuse By Advancing Technology Act of 2016) to incentivize the development of abuse-deterrent opioids by amending the Federal Food, Drug, and Cosmetic Act to extend the exclusivity period for certain drug products developed or labeled so as to reduce drug abuse, and for other purposes.

Implications on Exclusivity to Certain New Drug Applications (NDAs) –

The COMBAT Act would amend Section 505(c)(3)(E) of the Federal Food, Drug, and Cosmetic Act i.e. 21 U.S.C. 355(c)(3)(E) by adding at the end the following:

(vi) With respect to an application described in clause (iii) or a supplement to an application described in clause (iv), if such application or supplement is approved on or after the date of enactment of the Curb Opioid Misuse By Advancing Technology Act of 2016, the 3-year period specified in each such clause shall be extended for an additional period of 12 months if the person submitting such application or supplement provides documentation to the Secretary demonstrating that the drug that is the subject of the application or supplement—

(I) is approved, in whole or in part, on the basis of one or more new clinical abuse potential studies; and

(II) is approved with labeling that characterizes the abuse-deterrent properties of the drug product.

Implications on Exclusivity to Certain Abbreviated New Drug Applications (ANDAs) –

The COMBAT Act would amend Section 505(j)(5) of the Federal Food, Drug, and Cosmetic Act i.e. 21 U.S.C. 355(j)(5) as following

(1) in subparagraph (B), by adding at the end the following:

‘‘(v) With respect to an abbreviated application described in clause (iv), if such application is approved on or after the date of enactment of the Curb Opioid Misuse By Advancing Technology Act of 2016, the 180-day period specified in such clause shall be extended for an additional period of 60 days if the first applicant submitting the abbreviated application provides documentation to the Secretary demonstrating that the listed drug referred to paragraph (2)(A)(i) and referenced in the abbreviated application—

(I) is approved, in whole or in part, on the basis of one or more new clinical abuse potential studies; and

(II) is approved with labeling that characterizes the abuse-deterrent properties of the drug product.

 (2) in subparagraph (F), by adding at the end the following:

‘‘(vi) With respect to an application described in clause (iii) or a supplement to an application described in clause (iv), if such application or supplement is approved on or after the date of enactment of the Curb Opioid Misuse By Advancing Technology Act of 2016, the 3-year period specified in each such clause shall be extended for an additional period of 12 months if the person submitting such application or supplement provides documentation to the Secretary demonstrating that the drug that is the subject of the application or supplement—

(I) is approved, in whole or in part, on the basis of one or more new clinical abuse potential studies; and

(II) is approved with labeling that characterizes the abuse-deterrent properties of that drug product.

Access copy of the bill here

About the Author: Mr. Tapan Shah, Senior Patent Associate, Khurana & Khurana, Advocates and IP Attorneys and can be reached at: tapan@khuranaandkhurana.com.

Notification Related to Abeyance of Mass Abandonment Orders: A Sigh of Relief to Trademark Applicants

Reportedly, the Trade Mark registry has abandoned huge number of trademark application since 28th March 2016. The Intellectual Property Attorneys Association, an organization based in Delhi, filed writ petition at Delhi High court alleging that the trademark registry has cancelled an unusually huge number of trademark applications without issuing notices to the applicants or their agents. Through a separate petition Tata Steels Ltd also moved to the court seeking stay on the order affecting its rights by such abandonment.

The matter was taken on board on dated 4th April 2016 considering the urgency and seriousness of the matter and the Hon’ble Delhi High Court stayed all orders issued after 20th March 2016 by the Registrar of Trademarks, for abandonment of the trademark applications.

The Hon’ble Delhi Court held that considering the startling figures of disposal within a short period of time as well as the serious allegations in the writ petition, the orders of the abandonment passed by the respondents on or after 20th March, 2016 were stayed. Also, it was ordered that till further orders, the respondents shall not treat any Trade Mark applications as abandoned without proper notice to an effected party as provided under Sections 21, 128 and 132 of the Trade Marks Act, 1999

Pursuant to the Order by the Hon’ble Delhi High Court in the said writ petition, Trade mark registry passed notification dated 11th April 2016 notifying that abandonment orders passed by the Registrar of Trade Marks after 20/03/2016 are being kept in abeyance. The applicants or their authorized agents concerned can file the reply to examination reports containing office objections either through comprehensive E-filing services of trademarks available at the official website or through email. In case, the reply has already been filed and the office has erroneously treated applications as abandoned, information to this effect may also be sent through email at abhishek.p@nic.in along with copy of the reply already filed. It is further indicated that further action in this regard will be taken in accordance with the law and the directions/orders of the Hon’ble court in ongoing writ petitions. The detailed notification can be accessed here.

About the Author: Mr. Abhijeet Deshmukh, Trade Mark Attorney, Khurana & Khurana, Advocates and IP Attorneys and can be reached at:Abhijeet@khuranaandkhurana.com.

Snapshot of the Latest Examination Guidelines for Computer-Related Inventions (CRIs) in India – Feb 2016

Indian Patent Office (IPO) has come up with another set of revised guidelines indicating how CRIs would be examined in India. This piece is a quick update and summary of the guidelines, although practically speaking, nothing much has really changed as regards the interpretation of the statute Section 3(k) is concerned and the tests mentioned in the instant guidelines are substantially the same as the previous guideline and are in consistency even the original intent of the statute.

Brief of the Guideline

The guideline essentially starts with definition/interpretation of various terms relating to computer-based inventions, followed by how novelty/non-obviousness (inventive step) is to be interpreted/evaluated. Section 4.4.4 relates to how section 3(k) excludes mathematical methods or business methods or computer programme per se or algorithms. The guideline states:

Computer programmes are often claimed in the form of algorithms as method claims or system claims with some ‘means’ indicating the functions of flow charts or process steps. The algorithm related claims are even wider than the computer programmes claimed by themselves as a single algorithm can be implemented through different programmes in different computer languages. If, in substance, claims in any form such as method/process, apparatus/system/device, computer program product/ computer readable medium belong to the said excluded categories, they would not be patentable.

The guideline further goes onto state:

Even when the issue is related to hardware/software relation, (e.g., when the claims recite ‘processor is programmed to… or ‘apparatus comprising a processor and configured / programmed to…..) the expression of the functionality as a ‘method’, is judged on its substance. It is well-established that, in patentability cases, the focus should be on the underlying substance of the invention, not the particular form in which it is claimed. The Patents Act clearly excludes computer programmes per se and the exclusion should not be allowed to be avoided merely by camouflaging the substance of the claim by wording (e.g. different sub-routines are performed in different physical locations such as processors will not suffice).

In sum therefore, a subject matter that is expressed simply as a sequence of steps/flow diagram would have lower chances of being held patentable until the steps indicate an improvement in the underlying hardware/substance of the invention. Type of the claim (be it system or method) would therefore have little dent on eligibility of patentable subject matter as it is only the form/expression of the claim, and does not indicate whether the core inventive step is on the functionality/steps or on the underlying tangible medium. Therefore a “processor configured to process a financial transaction” would not be patentable but a “processor configured to optimize the structure segments of a data block of a network packet might be”.

The guidelines further mention that means + function claims would not be patentable unless the means is clearly expressed in the form of a physical/tangible component and at a part of the inventive step lies in in the means part of the claim. In case the means do not constitute inventive step but the function does, patentability may not be rendered to be strong.

The guideline then further goes onto mention exclusivity of mathematical methods and business methods from patentability. The guideline further states that subject matters relating to computer programmes, set of instructions, routines, sub-routines, storage medium with instructions, database, among other like expressions would not be held patentable in India. Finally, before the guideline proceeds forward to give examples of subject matters that are not patentable in India, below are given as the tests/indicators that would be followed by the examiners to determine patentability of the CRIs.

Examiners may rely on the following three stage test in examining CRI applications:

(1) Properly construe the claim and identify the actual contribution;

(2) If the contribution lies only in mathematical method, business method or algorithm, deny the claim;

(3) If the contribution lies in the field of computer programme, check whether it is claimed in conjunction with a novel hardware and proceed to other steps to determine patentability with respect to the invention. The computer programme in itself is never patentable. If the contribution lies solely in the computer programme, deny the claim. If the contribution lies in both the computer programme as well as hardware, proceed to other steps of patentability.

In sum therefore, the present guidelines re-iterate the same conclusion as made in the previously issued guidelines wherein it was stressed that in India, in order to get a patentable subject matter, the inventive step has to be on the underlying hardware, and therefore subject matters that relate to reduction in processing time, optimization of memory, firmware, image/video/graphics processing, network packet processing, among other like subject matters would be patentable. However, what contrasts the position of the IPO is an exemplary recently issued patent, which we respectfully believe does not meet the patentability criteria outlined in the instant guideline, and hence gives the same old impression that what is intended by the statute (and also outlined in the instant guideline) might not actually be practically followed on a daily basis during prosecution of multiple cases.

Just for instance, a simple review of Granted Patent 271931 relating to Instant Messaging System gives an impression that step 3 of the three stage test is not being followed critically as no clear novel hardware element/technical effect has been identified/substantiated and the claimed subject matter incorporates two types of authentication, wherein confidential information is processed by a first type, and non-confidential information is processed by the second type, making the contribution of the invention to lie solely in the computer programme. Even while responding to the 3k objection, the Applicant submitted that it is necessary for the messaging system to learn whether first authentication and second authentication are passed successfully, and that interaction with exterior is necessary for carrying out the determination step (of whether first/second authentication is passed). It is further argued that the present invention facilitates the user to perform non-confidential data related operation, and that security requirements of the messaging are met. Would leave it to an open assessment if the arguments are strong enough to overcome the cited 3k objection!!!

About the Author: Mr. Tarun Khurana, Partner and Patent Attorney in IIPRD can be reached: Tarun@iiprd.com.

IP Workshop held at ITS Engineering College, Greater Noida

IIPRD in association with Khurana and Khurana, Advocates and IP attorneys has recently conducted an IP Workshop on 12th of March, 2016 at “ITS Engineering College”, Greater Noida. Hereinbelow are the snapshots of activities conducted at the workshop –

As a part of our ongoing Educational and Awareness Programme on IPR, IIPRD takes pride to have successfully conducted yet another Symposium on IPR – “Intellectual Property Leveraging and Management” at ITS Engineering College, Greater Noida. The objective was to sensitize the faculty members and attendees across all verticals towards growing need of effectively leveraging Intellectual Properties.

The presentation was given by Mr. Tarun Khurana, a Co-Founder and Partner in IIPRD – an Intellectual Property Consulting and Commercialization/Licensing Firm. Mr. Gyanveer Singh, Head of IT Practise Group, IIPRD shared the dais with him. The Workshop covered the broad areas of Intellectual Property Rights with special emphasis on Patents and related matters. Mr. Gyanveer Singh shared knowledge on basics of the Intellectual Property Rights, aspects of conducting prior-art searches and preparation of patent applications. Mr. Tarun Khurana shared knowhow on various facets of IP protection and enforcement strategies discussing several case laws and case studies.

This distinctive symposium platform contributed further in the area of IP knowledge dissemination with broad coverage on mandate of each IPR, their protection in India and worldwide, IP commercialization, valuation and infringement analysis.

https://www.linkedin.com/pulse/one-day-symposium-intellectual-property-rights-ipr-leveraging-singh

IP Workshop held at Our Corporate Office – Greater Noida

IIPRD in association with Khurana and Khurana, Advocates and IP attorneys has recently conducted an IP Workshop on 15th of January, 2016 at Our Corporate Office, Greater Noida. Hereinbelow are the snapshots of activities conducted at the workshop –

As a part of our ongoing Educational and Awareness Programme on IPR, IIPRD takes pride to have successfully conducted yet another Programme on IPR – “IP Leveraging and Management” at our Corporate Office, Greater Noida. The objective was to sensitize the Industrialists, Scientists, Educationalists and other attendees towards growing need of effectively leveraging Intellectual Properties.

IP practitioners working in law firms as well as IP departments of innovation based companies and representatives of some premium academic institutions and industries attended the workshop. The Participants represented organisations viz. Fiserv, Global Logic India Ltd., Info Edge (India) Ltd., CSIR- HQ- Delhi, Vee Excel Drugs and Pharmaceuticals (P) Ltd, to name a few.

The keynote address and presentation were rendered by Mr. Vinod Khurana, Founder of IIPRD and Khurana and Khurana, advocates and IP Attorneys, and Mr. Tarun Khurana, a Co-Founder and Partner in IIPRD – an Intellectual Property Consulting and Commercialization/Licensing Firm. Both the IP specialists shared knowhow on various facets of IP protection and enforcement strategies discussing several case laws and case studies. They illuminated ways to the audience on how IP can be effectively Protected, Managed, and Commercialized.

The Workshop covered the broad areas of Intellectual Property Rights with special emphasis on Patents & Trademarks. It presented an opportunity for academicians, practitioners and consultants to exchange ideas and explore emerging issues on IP Leveraging and Management.

IP Workshop held at Hotel Hilton – Jaipur

IIPRD in association with Khurana and Khurana, Advocates and IP attorneys has recently conducted an IP Workshop on 8th of February, 2016 at “Hotel Hilton”, Jaipur. Hereinbelow are the snapshots of activities conducted at the workshop –

As a part of our ongoing Educational and Awareness Programme on IPR, IIPRD takes pride to have successfully completed yet another Programme on IPR – “IP Leveraging and Management” at Hotel Hilton, Jaipur. The objective was to sensitize the Industrialists, Scientists, Educationalists and other attendees towards growing need of effectively leveraging Intellectual Properties.

The Participants include IP practitioners working in law firms as well as IP departments of innovation based companies and representatives of some premium academic institutions and industries. Representatives from IIS University, University Of Rajasthan, IIHMR, Jaipur National University, S K N Agriculture University, Manipal University, Polycon, Awakey, Head Start, S P Biotech, Avis Life Pharma, Rajasthan Patrika, Ayumed Pharma, Startup Labs, Dhewa  Biotech (P) Ltd were a few participants amongst others.

The keynote address and presentation were given by Mr. Vinod Khurana, Founder of IIPRD and Khurana and Khurana, advocates and IP Attorneys, and Mr. Tarun Khurana, a Co-Founder and Partner in IIPRD – an Intellectual Property Consulting and Commercialization/Licensing Firm. Both the IP specialists shared know how on various facets of IP protection and enforcement strategies discussing several case laws and case studies. They illuminated ways to the audience of how IP can be effectively Protected, Managed, and Commercialized.

The Workshop covered the broad areas of Intellectual Property Rights with special emphasis on Patents & Trademarks. It presented an opportunity for academicians, practitioners, consultants and students to exchange ideas and explore emerging issues on IP Leveraging and Management.

IP Workshop held at Courtyard By Marriott, Bhopal

IIPRD in association with Khurana and Khurana, Advocates and IP attorneys has recently conducted an IP Workshop on 30th of November, 2015 at “Courtyard By Marriott”, Bhopal. Hereinbelow are the snapshots of activities conducted at the workshop –

As a part of our ongoing Educational and Awareness Programme on IPR, IIPRD takes pride to have successfully concluded yet another Conference on IPR – “IP Leveraging and Management” at Courtyard By Marriott, Bhopal. The objective was to sensitize the Industrialists, Scientists, Educationalists and attendees towards growing need of effectively leveraging Intellectual Properties.

The Participants included IP practitioners working in law firms as well as IP departments of innovation based companies and representatives of some premium academic institutions and industries. Tesla Transformers Ltd, 3B BlackBio Biotech India Ltd, Senior Scientists from ICAR, Research Fellows from IIT-Indore, Central Institute of Agricultural Engineering, HEG and Members of Association of All Industries, Manipur amongst others.

The keynote address and presentation were rendered by Mr. Tarun Khurana, a Co-Founder and Partner in IIPRD – an Intellectual Property Consulting and Commercialization/Licensing Firm. Mr. Mohinder Vig, Head of Trade Mark Practise Group, IIPRD shared the dais with him. While Mr. Tarun Khurana shared knowhow on various facets of IP protection and enforcement strategies discussing several case laws and case studies, Mr. Mohinder Vig addressed topics related to basics of trademarks and copyrights, their protection in India and worldwide and discussed points to be taken care of during assignment/transfer of rights. They illuminated ways to the audience on how IP can be effectively Protected, Managed, and Commercialized.

The Workshop covered the broad areas of Intellectual Property Rights with special emphasis on Patents & Trademarks. It presented an opportunity for academicians, practitioners, consultants and students to exchange ideas and explore emerging issues on IP Leveraging and Management.

Khurana & Khurana Publication – Compendium of Trademark Case Summaries – 2015

The Indian trademark jurisprudence in its expeditiously evolving journey saw 2015 attaching many feathers to its hat. With increasing number of litigations, consequently fostering enhanced enforcement and settlements has stimulated players in the ecosystem in being more sensitized and mindful towards the IP lifecycle in India – from filing to injunctions. Significant changes in the Trademark office and courts have been witnessed to have a direct influence on the confidence and awareness of stakeholders in the IP ecosystem. To mention a few:

– increase in trademark filings by 300% over the last decade

– becoming a member of the Madrid Protocol

– increase in number of ‘Anton Pillar’s’ order and ‘John Doe’ orders (aka ‘Ashok Kumar’ in India)

– awarding punitive damages in IP matters

– increase in injunctions based on ‘Passing Off’ principle

With that background and Khurana and Khurana’s involvement in trademark litigations, we provide herewith a compendium of certain key judgment summaries, that reflect a diverse range of issues discussed and adjudicated upon in the Indian courts pertaining to the interpretation/ implementation of various provisions of The Trademark Act, 1999 and can be accessed here:

Khurana & Khurana Publication – Compendium of Trademark Case Summaries – 2015.

About the Author: Mr. Amarjeet Kumar, Senior Associate (Litigation), Khurana & Khurana, Advocates and IP Attorneys and can be reached at:Amarjeet@khuranaandkhurana.com.

Who Owns the Invention – the Employee and Employer Conundrum

As India’s participation in global trade, including with countries with strict patent regimes, increases, the need of aligning patent policies and practices in India with global standards is being felt.

If we look globally, and particularly at the competitive needs of global groupings (ASEAN, TPP etc) and countries with strict patent laws like US, Germany, UK etc, there is a call for a relook at the ownership rights of employees and employer. The stress of ‘Make in India’ on IPR further shows its future prospects, and thereby, need of policies more in line with the international standard.

 As per WIPO website for most countries,’ if an employee has developed an invention in execution of his/her employment contract – i.e. usually during his/her working time within the enterprise – the invention (and the related patent rights) will belong to the enterprise’.

For Patents

What the WIPO website means, in essence, is that in the absence of an assignment of invention agreement, employees will have rights over their inventions (and any related patents) unless  they were hired to work on or solve a particular problem and  the invention relates to that  problem. Further, independent contractors own anything they invent unless they enter into an agreement to assign their rights to the company for which they are working. So, simply put, if a employee invents something, while working in employer’s factory, but which is unrelated to his job responsibilities per se, then the employee owns the patent.

The U.S. Supreme Court partially comes to the rescue of the employer since, per them, “where an [employee] during his hours of employment, working with his [employer’s] materials and appliances, conceives and perfects an invention for which he obtains a patent, he must accord his master a nonexclusive right to practice the invention”.[1] For patents, this rule is known as the “shopright doctrine”, giving a nonexclusive license to the employer for using the invention without paying royalties to the employee, although the employee owns the invention. The employee also has the right to exploit it commercially, such as by selling or licensing it to other users. Even where the employee works on the invention on his own time, if the employer’s resources are used to any significant extent, this rule usually applies.

For copyrights

Under the Copyright Act, for major economies with minor modifications, “work made for hire” is the work done by an employee within the scope of employment and the employer has right over it. In case of an independent contractor, the employer will not have any rights over the work. So, it is better for the employer to enter into an agreement to have claims over the intellectual property rights.

The “scope of employment” limitation means that the employer is only entitled to rights over the works that the employee produces under the scope of the employer. For example, if you are a fashion designer by day and a song writer by night, your employer is entitled to rights of your designs but not your songs.

Unless there is a written agreement with independent contractors, hired to produce written content, designs, logos, etc to addresses the issue in their case, contractors will own their creations even if a company paid the contractor to produce the copyrighted work.

Here’s a list of the nine types of work done by independent contractors that can be considered work-for-hire:

  1. a contribution to a collective work;
  2. a part of a motion picture or other audiovisual work;
  3. a translation;
  4. a supplementary work;
  5. a compilation;
  6. an instructional text;
  7. a test;
  8. answer material for a test; or
  9. an atlas

For work not falling into one of the nine work-for-hire categories mentioned above, some or all of the rights must be explicitly assigned by a copyright to the company through an agreement. And for these nine work-for-hire categories the contractors own their creations as mentioned before.

Conclusion

  • Ideally the employers should execute an employment contract or better sign an assignment of invention agreement with the employees to secure rights over intellectual property developed by the employee. In any scenario, the employee will always retain the right to be named as the inventor, unless expressly renounced by him/her.
  • The employer should enter into a written transfer and confidentiality agreement with the employee, to secure the internally developed software, reports, or important materials before the employee goes to another job. The agreement should contain the details of any work created during employee’s tenure with the company or utilizing company’s resources, which now belongs to the employer. In case of an independent contractor, the employer should execute a confidentiality agreement with the individual and the company he or she is employed by, regarding the newly developed work.

References:

  1. http://smallbusiness.findlaw.com/intellectual-property/law-regarding-the-rights-to-inventions-made-by-employees.html
  2. http://lansingbusinessnews.com/law-at-work/1886-protecting-intellectual-property-rights-in-the-workplace.html
  3. http://www.wipo.int/patents/en/faq_patents.html
  4. http://blog.legalhero.com/who-owns-what-ownership-issues-for-employee-created-intellectual-property

About the Author: Harsh, Junior Patent Associate at IIPRD and can be reached at: harsh@iiprd.com.

Medecins Sans Frontieres (msf) Challenges Pfizer’s Patent Application on Pneumonia Vaccine in India

Médecins Sans Frontières (MSF) also known as Doctors Without Borders, an international humanitarian-aid non-governmental organization, has filed a pre-grant opposition in India to prevent US pharmaceutical company “Pfizer” from getting a patent on the pneumococcal conjugate vaccine (PCV13, marketed as Prevenar 13®).

Prevenar 13® is the world’s largest selling vaccine for infants and toddlers, that helps prevent invasive disease caused by 13 types of Streptococcus pneumoniae. Prevenar 13® contains extracts from thirteen of the most common types of Streptococcus pneumoniae bacteria which are responsible for causing invasive diseases such as pneumonia, blood poisoning and meningitis.  The vaccine works by preparing the body’s defences to fight the infection, without causing the disease.

The patent application (8081/DELNP/2007) filed by Pfizer, if granted, would allow the company to keep controlling the PCV 13 vaccine market until 2026 in India. Pfizer’s patent application covers a multivalent immunogenic composition comprising 13 distinct polysaccharide-protein conjugates, wherein each of the conjugates contains a capsular polysaccharide from a different serotype of Streptococcus pneumoniae conjugated to a carrier protein together with a physiologically acceptable vehicle. Pfizer claimed it should be awarded a patent because the method of conjugating 13 serotypes of streptococcus pneumonia into a single carrier is new but MSF claimed it was not inventive.

MSF said it decided to oppose Pfizer’s patent application “after years of fruitless negotiations” with Pfizer to lower the vaccine’s price for use in its projects. While Pfizer offers the pneumonia vaccine at a discounted rate for $10 per child, a vaccine producer in India, Serum Institute, has announced that it could supply the vaccine to MSF and countries in need for $6 per child.

MSF has filed a “pre-grant opposition”, an administrative process that allows third parties to formally challenge validity of pending patent applications before they are granted, arguing that Pfizer’s claimed method is too obvious to deserve a patent under Indian law, pointing out that an equivalent patent was already revoked by the European Patent Office (EPO) and the validity of South Korean equivalent is currently being challenged.

 “Our pre-grant opposition shows that the method Pfizer is trying to patent is too obvious to deserve a patent under Indian law, and is just a way to guarantee a market monopoly for Pfizer for many years to come,” said Leena Menghaney, Head of MSF’s Access Campaign in South Asia. “India must rebuff demands from pharmaceutical companies, which are backed by diplomatic pressure tactics of the U.S. and other governments, that India change its patentability standards to restrict generic competition.  Pfizer’s unmerited patent application on the pneumonia vaccine should be rejected, opening the door to more affordable versions of the vaccines being produced.”

“This is the first time a vaccine (biosimilar) patent has been challenged in India by a medical organisation, with the goal of millions more children being protected against deadly pneumonia”, MSF further claimed.

About the Author: Antony David, Senior Patent Associate at Khurana & Khurana, Advocates and IP Attorneys and can be reached at: antony@khuranaandkhurana.com.

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