Intellectual property and competition law

Always an interesting topic ...

Hemphill, C. Scott, Intellectual Property and Competition Law (May 9, 2017). Forthcoming, Oxford Handbook of Intellectual Property Law (Rochelle C. Dreyfuss & Justine Pila eds. 2017). Available at SSRN: https://ssrn.com/abstract=2965617 or http://dx.doi.org/10.2139/ssrn.2965617

And another article of interest:

Lim, Daryl, Retooling the Patent-Antitrust Intersection: Insights from Behavioral Economics (April 14, 2017). 69 Baylor Law Review 124 (2017). Available at SSRN: https://ssrn.com/abstract=2953031

Visibly Faster Turnarounds By Indian Trademark Registry

This morning, when I opened my inbox, one email in particular surprised me. The email contained our first ever “e-certificate” for a trademark application filed just about one year ago! In the past, such prompt action by Indian IP Offices was almost unheard of. But clearly, the technology-enabled procedural changes introduced over the past year or so have begun to bear fruit.

The issues faced by the Registry in printing and dispatching hard copy (Registration Certificates) are quite well-known. On many occasions, the certificates did not reach the intended recipients. This not only caused delay and inconvenience to stakeholders but also imposed needless cost on the Registry as well as Applicants (who had to apply for a duplicate certificate).

About a month ago, the Indian Trademark office, via its notification dated 28^th July 2016, had notified the new system of sending only e-certificates (Registration), and doing away with the century old system of sending hard copies. This was made effective from 1^st August 2016 for all trademark applications:

• published in the Trade Marks Journal on or after November 23^rd, 2015;

• where no request for amendment filed on behalf of the applicant is pending disposal;

• where Trade Mark registry’s database contains the original application;

• where no compliance requirement is pending on part of the applicant; and

• which have not been specifically prohibited for registration by the order of any court, IPAB or any competent authority.

With the adoption of the new system it appears that the Registry is taking every possible step to eliminate the root cause for delay and thus expedite the registration process and deliver on the higher standards outlined in India’s new IP Policy.

Guest post: .sucks me not: Why organisations & celebrities are afraid of this domain!

During a recent trip to San Diego for one of the world’s biggest IP conferences, I, alongside of over 10k IP lawyers from over 100 countries, came across a newly launched gTLD (generic top level domain) named .sucks. The unique launch campaign which involved mainly students who stood around the city holding banners with just .sucks written on it and giving away condoms in nicely wrapped packets with .sucks printed on the wrapper. Mobile signage vans making the rounds across the city captured people’s attention and the curiosity grew because all the signage said was .sucks.

What is .sucks?
.sucks is a new domain name launched by a Cayman Islands based entity called Vox Populi Registry Ltd., which is a subsidiary of Ottawa based Momentous Inc. In 2014, Vox reportedly paid over US$ 3 million to ICANN for the rights to manage the .sucks domain.

Why .sucks?
As per John Berard, Founder-Vox Populi; the .sucks domain is a platform for legitimate critical commentary, which is definitely not being considered true by others. In fact, in a recent statement, California Republican Darrell Issa termed it as “legalized extortion”.

Why the fear?
In today’s socially connected Internet era, bashing of brands (entities or individuals) is becoming more common and trust me, just like any of us, no one likes criticism of any kind. Therefore, entities and celebrities too find it hard to take the criticism that is hurled at them (even if it is a constructive one). A common practice by most of the entities is to troll social media platforms and other web sites to keep a tab on the criticism and handle it in a best possible manner. Since it is almost impossible to keep a track of all the social media sites to handle criticism, time and again it has gone out of control and ended up damaging brands and personal images mainly due to lack of a timely response or mishandling of the same.

With the launch of the .sucks domain, the public and media (including customers and potential customers) will get a specific platform to post their experiences, concerns, opinions and sometime vent out their anger (of course). However, the scary part of this solution would be that someone, other than you (the brand owner), owning that specific platform (www.yourbrand.sucks), would leave you with virtually no control over it!

The pricing controversy
Generally, a new domain is launched through a sunrise period before it is opened to the general public. In this case, Vox fixed the sunrise period price at $2499 which was considered exorbitantly high. The sunrise period was extended by a couple of months which added more fuel to the fire which finally ended on 19th June 2015.

From 21st June 2015 onwards this domain is open for regular registrations with reduced price, however, it is still considered to be high by many, as Vox has created various categories such as “Premium” and “General” under which the “big names” are still selling at the price of $2499.

Role of ICANN (Internet Corporation for Assigned Names and Numbers) and Slip ups
As you all would know, ICANN is the only authority in the world controlling the domain names. It has launched over 400 new domain extensions such as .CEO, .consulting, .social, .menu, .tech etc. in past year or so. However, the .sucks was the only domain which got more attention and criticism across the world for various reasons. Faced with mounting criticism and controversy, ICANN made failed attempts appealing to the U.S. Federal Trade Commission (FTC) and Canada’s Office of Consumer Affairs (OCA) seeking review of the legality of the .sucks domain extension1.

ICANN seems to have made a statement to the effect that it approved the .sucks domain because no one objected to it. The statement goes on to say that ICANN lacks the authority to block the domain or control its pricing.

What are big organisations and celebrities doing?
As of now, several large and well-known organisations like Google, Amazon, Microsoft, Yahoo, eBay, WhatsApp, have registered different variants of the .sucks domain. Similarly, many celebrities such as Taylor Swift, Justin Bieber, Oprah Winfrey, Rihanna, Mark Zuckerberg, Hillary Clinton etc. have registered their own .sucks domains. However, there are still many organisations (such as Twitter, LinkedIn and Indian biggies like Infosys and Wipro) that have apparently not yet taken any action against the potential threats of .sucks domain2.

What should you do?
If you are an organisation of repute or a celebrity and worried about uncontrolled criticism, you must consider registering .sucks domain. Even if you do not wish to have a website with the .sucks domain, Vox provides an option of blocking the domain so no one else can do it. This option actually costs about 25% less!

How to go about it?
If you are lucky or if your brand/name was not considered valuable enough by others, you may check the availability of your .sucks domain at https://www.registry.sucks/ and register or block it.

The domains have been classified as standard, premium, market premium etc., some of which are:

Standard: It includes names that don’t fall under premium or market premium categories and are available on first come first served basis. Registration and annual renewal cost is currently $ 249.

Premium: Vox has created a list of names which it thinks has a high market value. These premium names such as LinkedIn, Twitter, Infosys, Wipro are priced at a much higher cost i.e. $ 2499.

Conclusion
Amidst the raging .sucks controversy, it is expected to gain momentum going forward and drag many entities and celebrities into it. Where a handful of organisations have been proactive in registering this domain as a defensive step, others are either not aware of it or do not consider it to be a potential threat.

In my personal view, it is just a matter of time before disputes over the .sucks domain start, as cyber squatters are out there to make a quick buck and create trouble for valuable brands. In light of the above and without questioning ICANN’s authority or pre-empting what would be the future of this domain, it is recommended that you buy or block the .sucks domain, subject to your brand having market value and also if you believe that someone else might misuse it, if left unregistered. You may also consider blocking/buying it (of course, subject to availability), to avoid paying cyber squatters a hefty price and to give you the option to use this domain in the future if you so wish.

1: https://www.wxnetwork.com/the-controversial-sucks-domain-and-how-to-protect-your-brand/

2: http://marketingland.com/big-brands-sports-teams-celebrities-tech-companies-among-3400-early-sucks-domain-registrants-133621

3: https://www.registry.sucks/products

European Commission leaflet: "Intellectual Property Rights - Europe's asset, Europe's priority

I came across this leaflet via an RSS feed, I think, and rather wish I hadn't bothered. Why on earth is the Commission churning out guff like this at taxpayers' expense? It looks like a rather oversized tri-fold leaflet, and I cannot begin to imagine what the audience for it is supposed to be. It doesn't have a lot of words in it, consistent with modern attention-spans, but those that it does have are rubbish. Commissioner Barnier, who should know better, seems to be saying:

Intellectual property (IP) is the backbone of a competitive European economy, creating jobs and bringing innovative products and services to consumers and companies.

Let's just deconstruct that ... Well, the first thing to annoy me is that the author (and let us assume that the Commissioner did not write it himself) subscribes to the defined-terms-in-brackets school of drafting, even when what goes into the brackets is an abbreviation that no-one is ever going to mistake for something else. Not sure about the backbone metaphor, but let's not fall out over that - especially when once we are past that we are into serious, industrial-strength nonsense.

Consider those claims for intellectual property:

• '... creating jobs...' How does that work? Jobs can only be created by employers. Those employers might have businesses that rely, to a greater or lesser extent, on intellectual property, but that is at least one stage removed from the IP creating the job. IP can't create anything: it just is. By being, it might contribute to an environment in which jobs are created. Equally, abolishing intellectual property would create a lot of jobs, but they wouldn't be created by the absence of IP, they would be created by enterprising businesses making all the things that intellectual property rights previously prevented them from making: pharmaceuticals, DVDs, handbags and the like. Not an attractive proposition, but possibly as effective (or more so) as a job creation measure as strong IP rights.
• '... bringing innovative products and services ...' Here's a classic illustration of the dangers of generalising about IP. Trade marks have an effect on how goods and services get to market, and what happens when they get there, but there is no way in which they affect how innovative the goods and services are. And of course copyright has nothing to do with innovation, though we can concede, can't we, that creativity is not a million miles removed from innovation, so in a piece of non-legal writing it might be allowed. But that still leaves my biggest objection, the allusion to the magical powers of any legal right to deliver anything to anybody. No, the mere existence of intellectual property rights doesn't do that. It takes a James Dyson to innovate, and the business he built to bring new vacuum cleaners to the market. Without intellectual property rights he might never have started, or he might have contented himself with his Hoover Junior vacuum cleaner modified to generate cyclones and therefore much more effective than it had been when it left the Hoover factory - but to ascribe to IP the magical power to do all that: well, it's a bit of an insult to inventors, isn't it? Actually, more than a bit of an insult.
• '... to consumers and companies.' The problem is, you start off something like this and it just has to be a three-part list. I think it's a well-known fact in rhetoric, and I remember reading it in Max Atkinson's 1984 book, Our Masters' Voices, which also taught me about the value of the pause in a speech - a literal claptrap, an indication to the audience that you have reached a point when applause would be appropriate - and which I used to telling effect in a speech to Conservative Party conference in 1983, except for the fact that I hadn't paused to invite applause, I had paused while I worked out what to say next. But it certainly worked. Anyway, this third part of the three-part list is here to make up the numbers, though it's worth observing that any benefit that does not trickle down to consumers is hardly worth having.

The stuff inside the leaflet reads like a conventional justification for the intellectual property system, adapted perhaps to the purpose of justifying the continued and expensive existence of the European Commission - it can hardly be said that without the Commission there would be no IP - nor even that without the EU it would be lacking. But that leads me to the last thing that irritates me about this leaflet: its title refers to 'Europe's asset, Europe's priority'. Another instance of the expansionist Commission speaking for all those countries which aren't part of the Union. It could almost make me wish the UK was among them.

CIPA intellectual property debate

To London, for a debate on the motion: "This house believes that political pressure and a few loud business voices are making the IP systems in Europe less and less relevant to the needs of small enterprises". Organised by the Chartered Institute of Patent Agents, the motion was proposed by Michael Wilcox, a small businessman and serial inventor, and seconded by Vicki Salmon, one of a small number of people who are solicitors and patent agents (so use of the title "attorney" is certainly justified in her case). I remember a small passing-off dispute in which, fairly newly-qualified, she was on the other side - getting on for 20 years ago now. Opposing it were Sean Dennehey from the Patent Office, with whom I once spent a train journey after I encountered him on the Tube when I left my then-office one evening and naturally fell into conversation with the fellow-passenger carrying a souvenir shoulder bag from a patent conference, and James Nurton, editor of Managing Intellectual Property (and INTA Daily News, a publication rather closer to my heart given the coverage afforded to the Capital City Marathon four annual meetings ago, thanks to James).

Thanks to the combined efforts of First Great Western and London Underground, I arrived rather late, but the proposer had not started anyway. I was immediately put on my guard when I saw the screen was displaying a Microsoft PowerPoint window, as opposed to a slide-show in which the functional parts of the interface are removed ... Mr Wilcox admitted to a lack of facility with the technology. Oh, dear. But his story about how the patent system had failed him and his business, and small and medium-sized enterprises throughout the country, was well worth hearing. No matter how often one hears that a patent does not exclude others from using your invention, merely enables you (should you be as well-resourced as, say, Croesus) to sue those who infringe, it's worth being reminded. And applying for a patent puts the results of your research in the public domain, and vulnerable to being taken without permission: big business, he suggested, does little research, but picks up its new ideas from other people. He quoted Joshua Shapiro, whom he described as holding some senior position at IBM:

Large companies routinely infringe intellectual property of start-ups or individual inventors. They will not sign non-disclosure agreements to protect others’ IP. When shown relevant patents, they need to license, they literally say “Sue us”, knowing that deeper pockets trump a valid claim.

He also mentioned several other people from IBM, to demonstrate that big business alone had the ear of the law-makers. But I find that Mr Shapiro was no longer with IBM when he made that comment in this letter to the FT - so was he repeating something he said earlier, when he did work for IBM? It seems unlikely. And the comment is an observation, not a manifesto. So with the benefit of a little research, I find myself less well-disposed towards Mr Wilcox's argument than I was at the time. The fact that he simply ignored the need to keep to time, an essential feature of any debate (for the sake of fairness, apart from anything else) also told against him - though the chairman, Professor Sir Robin Jacob (who else could it possibly be?), should perhaps have been less lenient. As a friend remarked afterwards, he has mellowed.

Vicki's shorter speech (the chairman decreed that both speakers for should go first, like leader and junior in court) rehearsed the arguments against the EU patent and the uniform patent litigation system as it stands, and I must say they become more compelling the more I hear them. Whose interest will reform serve? But we hadn't heard much about anything but patents so far. Sean Dennehey preferred to take the motion apart, arguing that one could not possibly agree with the proposition that political pressure could make the system less relevant to small enterprises, because to do so would be to speak against democracy. No, Sean, with respect, to do so is to recognise the democratic deficit. After all, who voted for you? (I hasten to add that I would have done, given the chance.) James offered a great many statistics to support the proposition that small business makes considerable use of the various systems of protection, but seemed to assume that more patents, trade marks and registered designs was A Good Thing.

The chairman took the opportunity, before opening the floor to contributions, to observe (with the aid of props - a boxful of metal bolts and channels) that Ancon Ltd v ACS Stainless Steel Fixings Ltd [2009] EWCA Civ 498 (16 June 2009) had been fought on a conditional fee arrangement, which he thought might offer one solution to the problem of the cost of patent litigation - but not, I think, for small-scale legal practitioners: you need to be able to carry the people doing the work for which you will be paid only after the case is over, and then not necessarily in full. You can accumulate an awful lot of work in progress with no  immediate prospect of being able to bill it: would it be secure enough to impress the bank, I wonder?

A speaker from the floor, Sabine McNeill of 3D Metrics, drew attention to Shift Happens which she suggested members of the audience should find using Google (other search engines, I should add, are available). I hadn't seen it, so I did, and for the benefit of readers who also haven't seen it I'll embed it below. I'm not sure what it proves as far as this debate was concerned, and for all that the information in it is interesting it's interesting in a tabloidy sort of way ... Sabine stressed how keeping trade secrets confidential is a better to protect your intellectual property (in the widest sense) than applying for a patent and revealing what you have invented to the world at large. This is not necessarily the advice dispensed by the profession, which makes its money from filing applications: "Five patent agents", she said, "would take the money I don't have." A short discussion ensued about the ethics of professional advisers taking an equity stake in lieu of fees: Sir Robin was hard-pressed to see where a conflict might arise, others disagreed, no-one (except perhaps Tibor) seemed to know what the rules say, and Dennis Crouch who happened to be in the audience said that US rules allowed lawyers to take stakes in clients. (I would comment on what the SRA says, but their website won't load so I can't consult the new handbook. Oh, for the days when the Guide to Professional Conduct was a book.)


Mr Justice Arnold's contribution to the debate was to say that copyright also needed to be considered, that the 1988 Act was technologically obsolescent and so much amended under the European Communities Act as to resemble a patchwork quilt - great stuff. He was unimpressed by the Regulatory Reform Bill's attempts to hack it about still further, though restating the exceptions chapter ("permitted acts", surely?) on the basis of the Information Society Directive wasn't a bad idea. (But still no-one had really mentioned trade marks, and I had missed the chance to have my say - even though I was prepared, as I did the other way round at my first Party Conference in - when would that have been? 1978? - to deliver my "for" speech against the motion.)


One other contribution I noted (which is not to say that nothing else was said that was worth paying attention to): Tibor on the Z sections of the Registered Designs Act - "more suitable for labelling sewing machine parts". Excellent stuff. The chairman asked for a show of hands, decided that a count was needed, announced that there were "about 35" in favour, and declared the motion carried in time for the kick-off in the England v Ukraine match, though like most people he stuck around for refreshments afterwards.


Discussion of new copyright legislation was a little off-piste, but it made me wonder whether anyone remembers what it was like back when the 1988 Act was being created. It was very difficult to find enough parliamentary time for the legislative behemoth, which set a record (probably since surpassed) for the number of amendments tabled to it, so it's hardly surprising that the same excuse is trotted out today. Government is the art of the possible (isn't it?) - actually, it's politics that was said to be the art of the possible, by Bismarck no less, but I think the point still stands - so government will try to make necessary amendments to intellectual property laws by using delegated powers, implementing EU directives and making rules to patch up the floundering vessels. I don't expect to see another copyright act in the near future.

Euro-Hargreaves? The Commission's IP Blueprint

There's a lot of blueprinting going on at present. I hope that the Hargreaves Review and the Commission talked to each other, because both have come up with comprehensive reviews within a few days of each other. On 24 May the Commission stuck its oar in, and several recommendations overlap or are identical with those of the Hargreaves Review - which might be an indication of the futility of trying to deal with intellectual property policy at the national level ... Commissioner Barnier said:

IP is the key to innovation – and the word property is the key for an inventor to have the incentive and get the funding for innovation.

Hmm. That could cause controversy, in itself. Property? Is there no alternative? And is there a suggestion of the "means and ends" problem here?

The Commission recommends (in the words of its press release (IP/11/630) - I am under pressure of time, but will return to this and deal with it in greater detail another time):

• Patents: the Commission already launched proposals in April for a unitary patent protection under enhanced cooperation (see IP/11/470). Meanwhile, work will continue on proposals relating to the creation of a unified and specialised patent court for the classical European patents and the future European patents with unitary effect. This would considerably reduce litigation costs and the time it takes to resolve patent disputes. It would also increase legal certainty for business.
• Trade marks: while trade mark registration in the EU has been harmonised in Member States for almost 20 years and the Community trade mark was established 15 years ago, there is an increasing demand for more streamlined, effective and consistent registration systems. The Commission intends to present proposals in 2011 to modernise the trade mark system both at EU and national levels and adapt it to the Internet era.
• Geographical indications (GIs): GIs secure a link between a product's quality and its geographical origin. However, there is currently no such system available at EU level for the protection of non-agricultural products such as Carrara marble or Solingen knives. This leads to an unlevel playing field in the Single Market. The Commission will therefore carry out an in-depth analysis of the existing legal framework in the Member States as well as the potential economic impact of protection for non-agricultural GIs in 2011 and 2012. Depending on the outcome of an impact assessment, these could eventually be followed up by legislative proposals.
• Multi-territorial copyright licensing: While the substantive scope of copyright has been largely harmonised, rights are still licensed on a national basis. In view of the digital Single Market, streamlining copyright licensing and revenue distribution is one of the most important challenges that must be addressed. In the 2nd half of 2011, the Commission will submit a proposal to create a legal framework for the efficient multi-territorial collective management of copyright, in particular in the music sector. It will also establish common rules on the transparent governance and revenue distribution. In the second half of 2011, the Commission will also launch a consultation on the various issues related to the online distribution of audiovisual works.
• Digital libraries: The creation of European digital libraries that preserve and disseminate Europe's rich cultural and intellectual heritage is key to the development of the knowledge economy. To facilitate this, the Commission is also tabling today a legislative proposal that will enable the digitisation and online availability of so-called "orphan works" (works like books and newspaper or magazine articles that are still protected by copyright but where the right holders are not known or cannot be located to obtain copyright permissions) – see MEMO/11/333. Concurrently, the Commission looks forward to concluding a Memorandum of Understanding amongst libraries, publishers, authors and collecting societies to facilitate licensing solutions to digitise and make available out-of-commerce books.
• IPR violations: Counterfeiting and piracy are a growing threat for the economy. Between 2005 and 2009, the number of registered cases at the EU borders of goods suspected of infringing IPR increased from 26 704 to 43 572. Meanwhile, the creative industry estimates that piracy has cost the European music, movie, TV and software industry €10 billion and more than 185 000 jobs in 2008 alone. The Commission is set to intensify its efforts in this area. Firstly, the Commission has tabled a regulation today that is to reinforce the European Observatory on Counterfeiting and Piracy, which it launched in 2009, by entrusting its tasks to the Office for Harmonisation in the Internal Market (OHIM). This will allow the Observatory to benefit from OHIM's intellectual property expertise and strong record of delivery in trade marks and designs. The Regulation now passes to the European Parliament and the Council for consideration. Secondly, in Spring 2012, the Commission will propose to revise the IPR Enforcement Directive (see IP/04/540). The Directive provides for civil law measures allowing right holders to enforce their intellectual property rights but should be adapted, in particular to meet the specific challenges of the digital environment.
• IPR enforcement by customs: Customs supervise all trade crossing EU external borders: they carry out controls for many purposes and have an essential role in fighting the trade in IPR infringing goods. In 2009 only, customs intercepted over 40 000 suspect shipments involving 118 million articles. Whilst the majority of goods intercepted are counterfeit or pirated, customs' unique position at the border allows for the enforcement of a wide range of intellectual property rights. As part of today's overall IPR strategy, the Commission also proposes a new customs regulation, to further reinforce the legal framework for customs' actions. The proposal also aims to tackle the trade in small consignments of counterfeit goods sent by post as the overwhelming majority of these goods results from internet sales.

I like the parallel with the engineering process of blueprinting - though I don't think the verb meaning was intended by the Commission, or anyone else who uses the word in this context:

Dismantling engine and reassembling it to exact specifications and tolerances. This process may help to improve engine performance, smoothness, and reliability. (Dictionary of Automotive Terms.)

The intellectual property system (if I may be forgiven for using such a loose expression) would certainly benefit from this. However, Wikipedia sounds a cautionary note:

Ideally, blueprinting is performed on components removed from the production line before normal balancing and finishing. If finished components are blueprinted, there is the risk that the further removal of material will weaken the component.

Perhaps, then, we're too late. Or maybe the important point is that no-one is suggesting the removal of material from it ...

Statutory definitions

There are no fewer than 20 definitions of this expression on the statute book, none of them in a statute devoted to intellectual property. They are listed in Gray v News Group Newspapers Ltd & Anor [2011] EWHC 349 (Ch):

i) Section 8(2) of the Atomic Energy Authority Act 1986. 

ii) Section 92A(9) of the Building Societies Act 1986. 

iii) Section 88(10) of the Clean Neighbourhoods and Environment Act 2005. 

iv) Section 861(4) of the Companies Act 2006. 

v) Section 712(3) of the Corporation Tax Act 2009. 

vi) Sections 129(2) and 29(6) of the Finance Act 2000. 

vii) Section 8(3) of the Forestry Act 1967. 

viii) Section 9(1A) of the Income and Corporation Taxes Act 1988. 

ix) Sections 195(6) and 306(6) and 536(4) of the Income Tax Act 2007. 

x) Sections 456(1) and 19(6) of the Income Tax (Earnings and Pensions) Act 2003. 

xi) Section 579(2) of the Income Tax (Trading and Other Income) Act 2005. 

xii) Section 15 of the Law Reform (Miscellaneous Provisions) (Scotland) Act 1985. 

xiii) Sections 33B and 35(3C) of the National Heritage Act 1983. 

xiv) Section 72(5) of the Senior Courts Act 1981. 

xv) Paragraph 2 of the Personal Accounts Delivery Authority Winding Up Order 2010/911. 

xvi) Paragraph 9(6) of the Overseas Companies (Execution of Documents and Registration of Charges) Regulations 2009/1917. 

xvii) Paragraph 2 of the Scientific Research Organisation Regulations 2007/3426. 

xviii) Paragraph 1(2) of the Education (Qualifications and Curriculum Authority and Qualifications, Curriculum and Assessment Authority for Wales) (Transfer of Property and Designation of Staff) Order 1997/2172. 

xix) Paragraph 5 of the Employment Tribunals Extension of Jurisdiction (England and Wales) Order 1994/1623. 

xx) Paragraph 5 of the Employment Tribunals Extension of Jurisdiction (Scotland) Order 1994/1624.

One day I will work through them and see what they all say. Numbers iv and xiv are quoted in the Dictionary.