On April 26, 2021, the theme of World IP Day 2021 is “”. Since I founded the IP Innovation Clinic in 2010, the Clinic has helped countless innovators, entrepreneurs, and small businesses to do exactly that. Our students have provided basic legal information to clients who otherwise would not have any access to it. To date, the Clinic has subsidized over $2,000,000CDN of legal fees that would otherwise have been paid by those without access to resources. This past year, the Clinic has expanded its impact through the recently launched , a free legal chatbot which uses a vast database of credible IP information to answer users’ initial IP questions and guide them to the type of legal help they need. This is only the beginning of the ChatBot’s story.

In a critical time of Covid-19 isolation, I aim to ensure that the IP Innovation ChatBot’s content is accessible and attuned to the unique realities of underrepresented communities in Canada’s intellectual property (IP) innovation ecosystem; namely, women and indigenous peoples. Having assisted clients in these underrepresented groups in the IP Innovation Clinic, and through my own research and writing in this area, I have seen first-hand the distinct struggles these groups confront in the traditional IP innovation ecosystem and the distinct challenges they face to bring their innovations to society; from being silenced in their ideation phase to lacking adequate resources and know-how to develop IP strategies attuned to their unique needs and perspectives.

This AI-powered initiative has been launched thanks to the Canadian government’s , and supports its mandate to increase IP awareness and education by making IP information more accessible. These learnings can easily be applied to other areas of the law.

The ChatBot has been realized due to visionary IP Innovation Clinic champions backing our work, Innovation 91ŃÇÉŤ at 91ŃÇÉŤ, Ontario Centre of Innovation (OCI) at the very outset and Bergeron Entrepreneurs Science and Technology (BEST) Program at Lassonde School of Engineering and Norton Rose Fulbright (NRF) Canada LLP. Indeed, the technical and legal expertise of Partner, Maya Medeiros, and Al Hounsell at NRF, and our Osgoode JD team of students led by Ryan Wong, class of 2021. It is also an honour to work closely with other leaders in the federal government such as the Konstantinos Georgaras, CEO (Interim) at the Canadian Intellectual Property Office (CIPO) and Jennifer Miller, Erin Campbell and their teams at Innovation, Science and Economic Development (ISED), who understand and work hard to overcome the challenges Canadian innovators face.

I previously uncovered the various challenges that underrepresented communities face in the IP innovation system and how grassroots initiatives, such as IP legal clinics, can assist in and in more recent work to use the power of artificial intelligence (AI) to build an IP Innovation ChatBot to make IP law more accessible. Going forward, I plan to expand on this foundational and empirical work to build the IP Innovation Clinic and the ChatBot to make the IP innovation ecosystem more accessible.

Ultimately, in an era of increasing technological disruption and lingering societal inequality and pandemic isolation, I hope to influence future legal education and make our justice system accessible to all Canadians.

Indeed, AI applications, including legal chatbots, use machine learning to make the law more understandable, manageable, useful, accessible, predictable, and efficient. Legal chatbots increase access to justice through their wider reach and lower costs. Many underrepresented communities receive either inadequate or no legal help at all. Technology currently cannot provide complex legal advice, but AI-powered online legal services can cost-effectively deliver accessible, basic legal help. Some, like our IP Innovation ChatBot, do so for free. Chatbots can thus democratize access to basic legal services for the underserved, and therefore deserve greater study and adoption.

Since its January 29, 2021 launch, the IP Innovation ChatBot has been a magnet for public use. Several members of the legal community have already inquired to learn how to emulate it. With the information from these analyses, I plan to design and build an enhanced, interactive, dynamic, and accessible portal powered by next-generation artificial intelligence operating on big data curated by our pioneering IP Innovation ChatBot.

The ChatBot will remain a free, sophisticated, and smart online tool, driven by AI and designed to cater to underrepresented and disenfranchised innovators. It will soon house key IP resources and information, leading updates, and links to Canadian and international government IP resources. The ChatBot’s scaled-up national platform will analyse its amassed archive of data and identify common IP knowledge translation problems to devise and anticipate solutions. Adapted for the COVID-19 era and beyond, the ChatBot will support the next generation of lawyers, educate and stimulate innovation from underrepresented communities, provide start-up entrepreneurs with access to IP resources, and be the public’s go-to tool for independent and impartial IP knowledge.

Prof Pina D’Agostino is Associate Professor at Osgoode Hall Law School and Founder and Director of IP Osgoode, the IPilogue, the IP Innovation Clinic, and officially since January 2021 the recently launched IP Innovation Clinic ChatBot.

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, Founder and Director of IP Osgoode, opened the event by highlighting the ’s success throughout its years in making IP information more accessible and elevating diverse voices in the IP and innovation space. Professor D’Agostino laid out the event agenda, introduced the exceptional team behind the , and the for the Launch Event.

Following Professor D’Agostino’s remarks, , Vice President of Research and Innovation at 91ŃÇÉŤ, provided land acknowledgements and highlighted 91ŃÇɫ’s commitment to welcoming diverse voices to the academic space. Dr. Asif echoed the importance of making credible IP knowledge more accessible through tools such as the IP Innovation Clinic ChatBot.

, Associate Director at Lab introduced , Co-Founder & CEO of . Nikita’s inspiring story of turning his vision into reality, with the help of the BEST Lab, the IP Osgoode Innovation Clinic, and the Schulich School of Business, is a testament to the remarkable achievements that are possible through collaboration. Nikita, alongside his partner at Skygauge Robotics, , used BEST Lab resources to invent and develop a drone which uses ultra-sound technology to inspect metal structures. aims to provide a safe, efficient, and cost-effective way to inspect metal structures. With the help of the IP Innovation Clinic, Nikita and Skygauge patented their invention.

After Nikita’s presentation, it was time for the demo. The ChatBot was developed through the efforts of , Partner at Norton Rose Fulbright Canada LLP, Senior Innovation Lawyer at Norton Rose, , JD Candidate and IP Innovation Clinic Coordinator, and at IP Osgoode. Al Hounsell provided a primer on artificial intelligence (AI) and how it can be utilized to deliver legal information to clients, innovators, and entrepreneurs. The can be classified as a rules-and-pattern-based AI system because it derives its baseline system of rules from information fed to it by legal experts. The ChatBot gets “smarter” by identifying patterns in its users’ input. The ChatBot identifies two key components form these patterns: intents and entities. Intents are what the ChatBot users intend to derive from the questions they ask. Entities modify intents in an AI-based system. In the context of the ChatBot, as Ryan demonstrated in the demo, entities can be defined as the alternative ways in which a question can be asked. As a result, the more familiar the ChatBot becomes with different iterations of a question, the more intelligent and competent it becomes.

The final portion of the event was a thoughtful panel discussion moderated by Osgoode Hall Law School about navigating the IP and innovation ecosystem. The came from different sectors in the IP and innovation space. Each one brought a valuable perspective on the pressing IP and innovation issues that Canada and the world face, including economic growth, accessibility, and elevating diverse voices . A common theme running through the panel discussion was the importance of creating an inclusive and accessible environment for Canadian innovators of all backgrounds to flourish; and elevating voices from underserved communities who have been left out of the conversation for too long.

The deepened my understanding of how AI can easily, accessibly, and cost-effectively deliver information to users. Intellectual property assets are often a business’s first and most valuable assets, especially in its early stages. However, many innovators cannot access legal advice about their IP rights so early on in their business. I hope that free and user-friendly tools, such as the , can alleviate some of the barriers that currently halt innovation.

For more information and a full recording of the ChatBot Launch Event, click

Written by Bonnie Hassanzadeh, IPilogue Editor and Clinic Fellow at Osgoode Innovation Clinic.

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Reposted with permission from the author. Originally published on

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Maya Medeiros

Q1 Do you believe that it is important to have more women involved in the IP system?

I believe that diversity (including gender diversity) in business generally is important as it provides a range of perspectives for better decision making and problem solving to increase performance. This extends to the IP system, which includes IP professionals such as lawyers and agents, as well as innovators or IP creators. IP, and particularly patents, can be looked at through a “problem and solution” lens and a diverse set of players should highlight a wider range of problems, “eureka moments”, and innovative solutions.

Q2 Have you noticed a gender gap in your industry? Is the situation changing?

There is a gender gap in the legal industry and technology industry so the intersection of these industries further widens the gap. I am lucky to be part of a diverse team at my firm but I know this is not the norm. We are starting to see more data which creates awareness so hopefully this will lead to solutions.

Q3 Do you think it is more difficult for female innovators and entrepreneurs to secure funding (and, therefore, be able to afford IP costs)?

indicates that women-led ventures secure a lot less funding which suggests it is more difficult for female innovators and entrepreneurs to secure funding. A business network often leads to funding opportunities (or at least introductions) and if most of the network is made up of men it is likely harder for women to establish themselves within the network.

I am involved in (with their Radical Generosity funding model) as an activator and part of a global community of women that exclusively fund women-led ventures and provide business support. and join the community.

If a female innovator is solving a problem that targets female demographic it may be harder for male investors to understand the market and the value of the solution. also shows that the investor/financial industry is also predominantly male ().

Q4 Are there unique challenges that female inventors and entrepreneurs face?

The challenge of securing funding discussed above is significant if the inventor or entrepreneur cannot bootstrap their venture. There is also the significant problem of unconscious bias and the unfair results it can lead to particularly in industries where females are not well represented. suggests a lack of females in leadership positions which leads to a smaller pool of female mentors. In my personal experience, female mentorship has been very important for navigating issues in the professional world (and personal world).

Q5 How can the innovation and IP ecosystems become more inclusive for under-represented groups, such as female entrepreneurs?

Both men and women in leadership roles should take active steps to provide assistance to female entrepreneurs, such as informal strategy discussions, feedback on business plans, and mentorship generally.

Q6 What types of assistance will benefit female entrepreneurs?

An increase in funding opportunities can address the lack of funding noted above. Mentorship and business networks targeting female entrepreneurs can also provide support for their business. Sponsorship programs can be established and linked to funding models. A sponsor may be rewarded if a female entrepreneur meets significant milestones with their support, for example. Increased flexibility in the workplace can help both women and men, particularly when they are also caregivers or have other significant family roles.

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Digital therapeutics can revolutionize healthcare but the regulatory complexities slow the innovation process. Health tech investors, innovators, and regulators have struggled for more than a decade to reach clear consensus on how software-based diagnostics and therapeutics should be regulated – or whether they should be regulated at all. Mobile apps with medical related functions can be subject to layers of regulation relating to medical devices, privacy, consumer protection, practicing medicine, advertising, kickbacks, data protection and intellectual property. To further complicate matters, regulatory requirements vary from country to country. This uncertainty can dissuade companies from innovating in this space, despite the promising public health benefits. Regulators have tried to provide guidance through white papers on the health claims app developers and other wellness devices (like smartwatches and wearables) are allowed to make but there is still great uncertainty for trailblazing use cases. Industry participants have sought regulatory approval for strong, FDA-backed claims of their apps’ efficacy in treating specific medical conditions such as addiction, attention deficit (ADHD), depression, chronic pain and more, so while Pear’s reSET is the first such milestone, but it likely won’t be the last.

However, while observers may expect that reSET’s precedent heralds an opening of the floodgates to FDA-approved, app based therapeutics, don’t bet on it. Perhaps a few other leaders in ‘digital therapeutics’ are poised to achieve approval within the year, including ’s Project EVO (a game which treats ADHD), but barriers to approval remain and will likely become steeper. While FDA approval is a critical step, hard and expensive work remains to establish billing codes in the US and elsewhere. Convincing insurers to pay for reSET will take time, and may require costly legal battles to enforce patient access. For example, the mandates insurance coverage and access to treatments for mental health in the US but its specific application to digital therapeutics may have to be tested and clarified in court. Early leaders may work to establish moats around their initial advantages. Regulatory winners like Pear will be strongly incentivised to push hard for FDA enforcement against the language and claims of other apps. The convergence of technology and health care make digital therapeutics poised to be the next intellectual property battleground to further increase the risks and obstacles for participants entering the arena.

Questions remain, too, about ‘side doors’ to market approval, including the FDA’s designation of “substantial equivalence,” the regulatory approval pathway most frequently used by competitors and generic followers of a new therapeutic. Active ingredients - the essential unit of a drug, from a regulatory standpoint – may not be as obvious in an app, and the long term market advantage of regulated digital therapeutics may turn on as-yet-undefined ‘digital active ingredients’. Pear Therapeutics’ FDA approved app is a key milestone for digital health but an early one.

Maya Medeiros is a lawyer, patent agent, and trade-mark agent at Norton Rose Fulbright LLP Canada (Toronto). Maya Medeiros’ practice focuses on the creation and management of intellectual property assets in Canada, the United States and around the world. 

Dr. Graeme Moffat is VP Research and Regulatory Affairs at Toronto scale-up , developers of the Muse brain sensing headband.

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Artificial intelligence (“AI”) is a technical field of computer science that includes machine learning, natural language processing, speech processing, expert systems, robotics and machine vision. The term “artificial intelligence” is sometimes challenged in favor of machine intelligence or machine learning.

Machine learning automates decision making using programming rules and in some cases training data sets. Human subject matter experts can provide feedback on results as part of a training process. Machine learning can adapt its programming based on the training process and feedback. The data can be represented by various graph and network structures. For example, an artificial neural network or neural net is a system designed to process information by simulating the framework of biological brains. Deep learning involves abstract representations of data to optimize the machine learning process. Supervised learning uses labelled training data examples to infer functions that can be used for processing new data. A computer can predict or ”guess” the meaning of new data based on the training data set, graph and network structures, and feedback. Reinforcement learning involves rules to control software action in an environment to maximize a reward. Reinforcement learning may not need training data examples with labelled data sets.

Expert systems can solve scheduling, optimization, and planning problems. Speech processing includes conversion between speech (audio) and text. Natural language processing derives meaning, context, or sentiment in textual data using grammars and graph structures. Machine vision can detect patterns in visual content for object tracking, audio and face recognition, for example. Robotics involves the use of biologics systems to automate and mechanically control machine movements.

INTELLECTUAL PROPERTY FOR AI

Technology enterprises and start-ups are both competing and constructively working together to develop and deploy AI products and services. Companies and research institutions should clearly define and protect their intellectual property with registrations and documentation, especially when working with multiple third parties. A company may then control use of its IP rights, including permitted use under licensing and collaborative arrangements.

Copyright

Copyright automatically extends to computer code, visual interface features, audio, video guides, application programming interface (API) structure and other works. Computer code may cover particulars such as source code, pseudo code, machine code and purpose-built hardware or firmware. Copyright is an important intellectual property asset particularly if the program design provides computational and usability efficiencies. Ownership and confidentiality of the copyright should clearly be set out in a written agreement.

Companies may also benefit from placing digital locks on their products and services for security. Circumvention of digital locks is an offence in some jurisdictions and may provide relief against unauthorized parties. Companies should have policies for developers incorporating third party copyright, even if inadvertently, as it may impact ownership of the technology and freedom to operate. Employees or a contracted developer, for example, may incorporate third-party source code without authorization which may impact ownership.

AI systems involve large data sets. These data sets and algorithms are important IP assets for the company. Contractual terms with end users and third parties should clearly specify permitted use. Some jurisdictions provide specialized IP protection for database rights.

Brand

Brands may include a word mark, logo or icon protected as registered or unregistered trade-marks, the latter of which can prevent competitors from unlawfully passing off on or diluting the goodwill of a brand. Companies can develop their brands with quality customer service and trust to establish goodwill in their brand with customers and the general public. A strong brand helps AI companies differentiate their products and services from competitors. AI technology and algorithmic accountability can help a company develop good will for their brand. Companies are often stewards of important data, assets and documentation, a reputable brand may be of paramount importance to customers.

Trade Secrets

Trade secrets are common law rights that provide protection over secret business information, and may protect material such as confidential backend server processes, code and ‘‘secret sauce.” Trade secrets require no formal registration, but companies must also take reasonable steps to keep it secret. In turn, the protected information may be protected for an unlimited period of time as long as it is kept secret and has commercial value. Misappropriation (e.g., unauthorized use) of trade secrets is regarded as unfair business practice. Trade secrets may take various forms such as customer lists, source code and technical documentation, among others.

Trade secret protection has limitations, particularly if relied on as protection for vital company assets. Trade secret rights may be difficult to establish or enforce, and enforcement may be practically ineffective against third parties who obtain the invention indirectly from an unauthorized discloser. Trade secret protection may prevent collaboration and integration with other entities in developing AI products and services. Trade secrets also do not protect against independent development of the secret innovation by third parties.

Industrial Designs

Industrial designs can be used to protect visual features of physical articles such as electronic cards, transaction machines, as well as computer interfaces, animations and icons. Design protection can be a valuable asset, especially if a given feature helps promote the distinctiveness of the brand, products and services, or increases the usability of a product.

Patents

Patents provide a mechanism to exclude others from making, using or selling the patented technology, which may help companies obtain or maintain market share, and protect research and development investments. Patents can provide a competitive advantage, and may also be used defensively as a negotiation tool. Patent publications can also be cited against subsequently filed applications to prevent grant.

A technology development strategy should consider if patent protection is available for core technology innovation. Companies should also be aware of other publications and litigations, as competitors and other players may have their own patents or pending applications. In contrast with trade secrets, granted patents may be enforced against third parties that make, use or sell the claimed invention, despite independent development. Given the quickly evolving AI market, obtaining early priority dates is important in view of the ‘‘first to file” nature of the patent system.

Patent Eligibility

Generally, patents are granted worldwide for new, useful, and non-obvious inventions of patentable subject matter. Computer implemented inventions are under a greater level of scrutiny and not all AI related innovations are per se patentable. The jurisprudence determining whether technology is indeed patentable subject matter is constantly evolving. Patent offices, along with the courts, have struggled with establishing clear delineations of what is patentable and what is not patentable. Highlighting salient technical features such as technical advantages and practical implementation details can increase the likelihood of success during patent examination. The description should highlight discernible effects generated by the AI innovation or use case.

REMARKS

Current AI agents are winning games of Jeopardy and Go against human experts but the scientific field of cognitive computing is still relatively young. The notion that computers can simulate cognitive intelligence raises philosophical questions about whether the mind can be modelled and the ethics of programming machines for human-like decision making. Given the importance of data analytics, companies continue to invest in research and develop in AI to advance their processing and data mining capabilities.

An IP strategy for AI development and deployment will layer intellectual property rights to protect different aspects of the innovation. Companies can clearly define and protect their intellectual property with registrations and documentation. Clear agreements on intellectual property rights should be established between third parties to manage risk.

Maya Medeiros is a lawyer, patent agent, and trade-mark agent at Norton Rose Fulbright LLP Canada (Toronto). Maya Medeiros’ practice focuses on the creation and management of intellectual property assets in Canada, the United States and around the world.

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Similar to other traditional industries, a digital revolution for financial services is underway. Financial technology, or ‘‘FinTech,” is an accelerating technical sector gaining in popularity with both traditional financial institutions and new market entrants.  Competitors are forming constructive partnerships to collaborate, efficiently develop, and deploy new FinTech products and services. Patents for core technology provide a mechanism to exclude others from making, using or selling patented technology. A company may also permit use of patented technology by third parties or contribute to a patent pool using various licensing arrangements while still maintaining control of its intellectual property rights. However, recent case law and patent office guidelines make obtaining global patent protection for FinTech an increasingly complex matter.

FINTECH PRIMER

FinTech is transforming the financial sector by supplementing or replacing traditional services, business models and providers. FinTech may create brand new market opportunities or give a competitive edge in relation to traditional offerings. This may have broad ranging implications for diverse stakeholders, including major financial institutions, insurance companies, hedge funds, institutional investors, ratings agencies, audit and accounting firms, regulators, technology companies, consortiums, not-for-profits and start-ups. Indeed, large institutions may be making significant investments upgrading or replacing legacy technology systems with new FinTech products.

PAYMENTS

Digital wallet technology is currently already in public use and will likely be employed on a widespread scale in the future. Digital cards include credit cards, debit cards, public transportation cards and other value cards offered by different companies. Mobile technology companies and retailers are entering the payment space with smartphone payment tokens, networks and applications. Digital payment accounts like PayPal are also widely accepted on e-commerce platforms and by the public at large, with intramember payment exchanges often not involving traditional financial institutions. Shopify, for example, is an online and brick-and-mortar transaction platform provider based in Ottawa, and raised $131 million in its initial public offering. Another payment company, Adyen, is now valued at $2.3 billion that enables Web companies such as Facebook and Yelp to accept and process payments, and provides mobile-payment tools for clients such as Uber and Airbnb. Finally, Nanopay, a Toronto-based provider of a payment and loyalty mobile application that combines identity, loyalty and payment into a single-use transaction token for contactless payment, recently acquired the Mintchip digital payment platform from Royal Canadian Mint.[1]

BLOCK CHAIN

A block chain is a decentralized peer-to-peer network of nodes recording authenticated, encrypted transactions as a distributed public ledger, thereby providing a trust and verification system [2] by using programmed rules to govern the replication of the ledger across the computing nodes of the networks. Initially invented as a solution to the weaknesses of a trust-based model,[3] the increased use and development of block chain infrastructure is changing payment and secure transaction ledgering services by providing increased security, integrity and verifiability of transactions. Currently, public block chain technology may be used under open license with transparency to help third parties understand the technology offering and associated security levels to build interoperable, trusted solutions. Private and hybrid block chain networks are also being developed by companies individually and working together through consortiums.

While block chains are well known as the technology underlying the transaction database for digital currency,[4] block chains can also be utilized in other types of applications. These include verifying proof-of-existence, smart contracts that automatically execute when certain conditions are met, verifying origin and delivery of products, and peer-to-peer exchanges. For example, Slock develops technology that combines block chain and the Internet for peers to rent, share or sell ‘‘things” such as parking spots and apartments.

LENDING

New lending, investing, and fundraising models are emerging. Indeed, crowdfunding platforms like Kickstarter enable an organization or individual to reach out directly to a community to raise capital for a business, product or creative endeavour. SeedsUp, another example, is a Canadian equity crowdfunding platform for limited private placement offerings for early stage businesses.

FinTech also generates financial inclusion and opens new markets through the provision of microfinance solutions, which offers small amounts of financing to new customers that may not have been qualified for traditional funding sources.[5] A prime example of this is M-Pesa, a mobile-phone microfinancing service that launched in 2007 by Vodafone for the largest mobile network operators in Kenya and Tanzania — Safaricom and Vodacom.

New personal investment solutions are also emerging. Toronto start-up Borrowell offers online lending technology to provide low-interest personal and business loans, and the low-fee automatic rebalancing system by another fellow Toronto start-up, Wealthsimple, recently raised $10 million in Series A funding
from Power Financial Corporation.[6]

REGULATORY COMPLIANCE AND AUDIT

Establishing fairness and trustworthiness of financial transactions becomes increasingly complex as different types of financial transactions emerge. Organizations expend significant resources to adhere with evolving regulatory requirements.[7]  The rise of FinTech provides innovative tools that may help alleviate the burdens of such compliance, validation and verification.

Companies can leverage technology such as distributed ledgers, block chains, encryption, automation, and others to perform tasks which otherwise would have been impractical or impossible with traditional methods. While these technologies are starting to gain in capability and acceptance, it is a challenge to understand how evolving jurisprudence and regulatory activities apply to FinTech innovation. Legal requirements may develop out of step with technology, and compliance may be uncertain where regulation is drafted around outdated or obsolete technologies.

The full article is available in the latest issue of the , volume 28(3), pp. 303-314.

Maya Medeiros is a lawyer, patent agent, and trade-mark agent at Norton Rose Fulbright LLP Canada (Toronto). Maya Medeiros’ practice focuses on the creation and management of intellectual property assets in Canada, the United States and around the world.

Brian Chau is an Associate at Norton Rose Fulbright, focusing on intellectual property, primarily patent prosecution, strategy, and portfolio management.

[1] There are several other examples: Adyen also provides point of sale technology for retailers, and Braintree (acquired by PayPal) provides an online and mobile payment application that aggregates different payment options and currencies, and offers an API for developers.

[2] The Standing Senate Committee on Banking, Trade and Commerce, Digital Currency <http://www.parl.gc.ca/Content/SEN/Committee/412/banc/rms/
12jun15/home-e.htm>.

[3] S. Nakamoto, Bitcoin: A Peer-to-Peer Electronic Cash System (2008).

[4]  A digital currency secured with encryption is a cryptocurrency. A prime example is Bitcoin, which is the most widely used cryptocurrency-issuing system built on a block chain framework. Cryptography greatly decreases the vulnerability of the block chain to unauthorized or malicious changes.

[5] Many people worldwide, for example, do not have access to traditional banks.

[6] Financial Post, online: <http://business.financialpost.com/entrepreneur/fpstartups/wealthsimple-aims-to-turn-financial-services-industry-on-its-headwith-
new-low-coast-approach-to-investing>.

[7] Dodd-Frank Wall Street Reform and Consumer Protection Act (Pub. L. 111-203, H.R. 4173), Sarbanes-Oxley Act of 2002 (Pub. L. 107-204, 116 Stat. 745).

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