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Re: Pool man got in accident/insurance denied liability/popped it for 25K (CSLG)calishitlawguru  07/16/18
Re: RATE Justice Sotomayor's future law clerk.,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.  07/16/18
Re: RATE Justice Sotomayor's future law clerkthis nigga eating memes!  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: what is your plan to escape wagecuckery?pedude  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGcannon  07/16/18
Re: Rate this Jewish Wapo Reporter walk his shit back in real timeguy who gets it  07/16/18
Re: Rate my kid's first birthday set up (CSLG)calishitlawguru  07/16/18
Re: RATE Justice Sotomayor's future law clerkDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGBuck \"The Club\" Paulette  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: Pool man got in accident/insurance denied liability/popped it for 25K (CSLG)Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Would you creampie fhia legal teen headed to mars?BOOM  07/16/18
Re: Remember when libs were decent people?honiara  07/16/18
Re: RATE Justice Sotomayor's future law clerkbeckersted.  07/16/18
Re: lol at taking a young lib get in her 20s with hyphenated name seriouslyJFC  07/16/18
Re: Rate my kid's first birthday set up (CSLG)....::::..::..,,....,........,..,,,,,.  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flame:D  07/16/18
Re: $27,000 balloontypical lib pundit  07/16/18
Re: RATE this HuffPo tweet re Trump Tape (link)cannon  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flameboner police?  07/16/18
Re: RATE Justice Sotomayor's future law clerk.,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.  07/16/18
Re: RATE Justice Sotomayor's future law clerkscholarship community account  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flame.....;;,,.........;.;.;.;.,;,;,;.;.;,;  07/16/18
Re: will next generation of libspawn have four hyphenated surnames? and then eight?grand arbre  07/16/18
Re: Libs boycotting GERBER for CEO comment that tranny men cannot give birtha jewish man wearing hugo boss driving a mercedes  07/16/18
Re: the genocidal leftboner police?  07/16/18
Re: Whoa Trump is speaking fluent Russian at this press conference. Also a red tiesmell the glove  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGDrakeMallard  07/16/18
Re: RATE Justice Sotomayor's future law clerkDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGTaylor Swift is not a hobby she is a lifestyle  07/16/18
Re: Rate my kid's first birthday set up (CSLG)calishitlawguru  07/16/18
Re: lol at taking a young lib get in her 20s with hyphenated name seriouslygrand arbre  07/16/18
Re: RATE Justice Sotomayor's future law clerk.,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.  07/16/18
Re: Dr Federer & Mirka In Ibiza For Wimby Finals (PIC) #tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: RATE Justice Sotomayor's future law clerkJFC  07/16/18
Re: Pool man got in accident/insurance denied liability/popped it for 25K (CSLG)calishitlawguru  07/16/18
Re: Libs boycotting GERBER for CEO comment that tranny men cannot give birthgrand arbre  07/16/18
Re: RATE Justice Sotomayor's future law clerkSir Incelot  07/16/18
Re: Need to make a car that runs off piss, shit and trashBOOM  07/16/18
Re: resist dormpfhtda jewish man wearing hugo boss driving a mercedes  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGYours For The Revolution  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGTaylor Swift is not a hobby she is a lifestyle  07/16/18
Re: $27,000 balloonESL Wilbur  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMING*A poaster\'s wounded pride*  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGYours For The Revolution  07/16/18
Re: Remember when libs were decent people?loans originated on or after July 1, 2018,  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: Mike Bryan Hits 455 Weeks At #1 #tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Remember when libs were decent people?Bedroom Bully  07/16/18
Re: $27,000 balloon,.,.,.,..,.,.,,.,.,.,.,.,.,.  07/16/18
Re: will next generation of libspawn have four hyphenated surnames? and then eight?a jewish man wearing hugo boss driving a mercedes  07/16/18
Re: reminder: if you don't vape youre a bottomboner police?  07/16/18
Re: Whoa Trump is speaking fluent Russian at this press conference. Also a red tieDrakeMallard  07/16/18
Re: *checks binance* *revises redfin parameters accordingly* *all houses disappear*typical lib pundit  07/16/18
Re: resist dormpfhtdboner police?  07/16/18
Re: Reminder: Politics literally mean shit...typical lib pundit  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flamegoi toy  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Bedroom Bully  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.:D  07/16/18
Re: lol at taking a young lib get in her 20s with hyphenated name seriouslyProgression to the Mean  07/16/18
Re: hey did you guys hear about the politics this weekend?MoreDoughHi  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGcannon  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGBoichester United  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGDrakeMallard  07/16/18
Re: what are some prestigious medium/smaller citiesMoreDoughHi  07/16/18
Re: hey did you guys hear about the politics this weekend?a jewish man wearing hugo boss driving a mercedes  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Sir Incelot  07/16/18
Re: what are some prestigious medium/smaller citiesESL TM..,..;;.  07/16/18
Re: *checks binance* *revises redfin parameters accordingly* *all houses disappear*ESL Wilbur  07/16/18
Re: lol at taking a young lib get in her 20s with hyphenated name seriouslyHoldUp.(I Now Live as a Gay Man)  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Sir Incelot  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: Reminder: Politics literally mean shit...BOOM  07/16/18
Re: what are some prestigious medium/smaller citiesSotomayor McCheese  07/16/18
Re: RATE Justice Sotomayor's future law clerka jewish man wearing hugo boss driving a mercedes  07/16/18
Re: Need to make a car that runs off piss, shit and trashSexually frustrated male poasting into the void  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGESL TM..,..;;.  07/16/18
Re: lol at taking a young lib get in her 20s with hyphenated name seriouslyBOOM  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Sir Incelot  07/16/18
Re: RATE Justice Sotomayor's future law clerkDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGHoldUp.(I Now Live as a Gay Man)  07/16/18
Re: Need to make a car that runs off piss, shit and trashMoreDoughHi  07/16/18
Re: RATE Justice Sotomayor's future law clerkESL Wilbur  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMING*A poaster\'s wounded pride*  07/16/18
Re: Boi Next Door (Pics)Versace Nigga Fuck Piece (No L\'s)  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Thanks Mario! But our partner is in another castle  07/16/18
Re: RATE Justice Sotomayor's future law clerktypical lib pundit  07/16/18
Re: Need to make a car that runs off piss, shit and trashBOOM  07/16/18
Re: Kerber Guaranteed Into The Tennis HOF? #tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Ocazia-Cortez is an hispanic identitarian, not a 'socialist'Sir Incelot  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Such anathema to us!  07/16/18
Re: TRUMP: "The US acted stupidly"ESL TM..,..;;.  07/16/18
Re: Not a poli sci guy but should gop pres donate $1M to HRC's campaign?MoreDoughHi  07/16/18
Re: Oil falls to $69 but gas still at $3 gallon ljlBOOM  07/16/18
Re: TRUMP: "The US acted stupidly"ESL TM..,..;;.  07/16/18
Re: After Weekend Of Mixed Emotions, Lawyer & Tennis Fan Takes His Life (NYT)#tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Things Libs loved in 1985: PA Steelworkers, low interest rates, infrastructuregrand arbre  07/16/18
Re: TRUMP: "The US acted stupidly"ESL TM..,..;;.  07/16/18
Re: Kerber Guaranteed Into The Tennis HOF? #tennisToro XI  07/16/18
Re: RATE Justice Sotomayor's future law clerk.,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.  07/16/18
Re: TRUMP: "The US acted stupidly"Such anathema to us!  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGESL TM..,..;;.  07/16/18
Re: FCC Chairman Ajit Pai stabs Donald Trump in the back.:D  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGESL TM..,..;;.  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flameDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: TRUMP: "The US acted stupidly".....;;,,.........;.;.;.;.,;,;,;.;.;,;  07/16/18
Re: After Weekend Of Mixed Emotions, Lawyer & Tennis Fan Takes His Life (NYT)#tennisToro XI  07/16/18
Re: Planned Parenthood commercial: protect your right to fuck anyone anytime! (Literfroodfrood  07/16/18
Re: Rate this Jewish Wapo Reporter walk his shit back in real timeESL TM..,..;;.  07/16/18
Re: Remember when libs were decent people?Sir Incelot  07/16/18
Re: TRUMP: "The US acted stupidly"michael doodikoff  07/16/18
Re: tranny gf: *Clutched*; shrew GF: *clutches own bowels/slime*alzabo  07/16/18
Re: Male gorillas: Let's give females equal votes about tribal invadersHoldUp.(I Now Live as a Gay Man)  07/16/18
Re: dumbest thing you've ever been yelled at for at work?a jewish man wearing hugo boss driving a mercedes  07/16/18
Re: That 1 yr old baby is actually a 41 yr old MS 13 jeffe. [daily mail link]Morning In America  07/16/18
Re: Remember when libs were decent people?Sir Incelot  07/16/18
Re: xo Bernie Sanders: "Are blacks violent? Yes. Do I need their votes? Absolutely."......,,.......  07/16/18
Re: Rate this Jewish Wapo Reporter walk his shit back in real timeESL TM..,..;;.  07/16/18
Re: GF wants produce not from Walmart, I am holding firm.,.,,.,,..,.,.,:,:,,...,::,...,:,.,..:..,:.::,.  07/16/18
Re: Kerber Guaranteed Into The Tennis HOF? #tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: HAHAURFUCKED BACK FROM THE WASTELAND AND TAKING Q'S!!! UP AND AT EM BOYS!!......,,.......  07/16/18
Re: "Unemployment is low because everyone has two jobs -- Alexandria Ocasio Cortez.,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.  07/16/18
Re: HAHAURFUCKED BACK FROM THE WASTELAND AND TAKING Q'S!!! UP AND AT EM BOYS!!......,,.......  07/16/18
Re: dumbest thing you've ever been yelled at for at work?Morning In America  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: Kerber Guaranteed Into The Tennis HOF? #tennisToro XI  07/16/18
Re: After Weekend Of Mixed Emotions, Lawyer & Tennis Fan Takes His Life (NYT)#tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: every actor who ever said n-word on screen should get 50yrs prisonbiglaw lives matter (retired)  07/16/18
Re: Remember when libs were decent people?Maori woman performing defiant haka  07/16/18
Re: Alexandria Ocasio Cortez Says Capitalism Will Not Always Exist.,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.  07/16/18
Re: Male gorillas: Let's give females equal votes about tribal invadersfemales are strong as hell  07/16/18
Re: Vermont law school revokes tenure for 75% of facultytypical lib pundit  07/16/18
Re: RATE Justice Sotomayor's future law clerkdead lahey  07/16/18
Re: Planned Parenthood commercial: protect your right to fuck anyone anytime! (LiterToro XI  07/16/18
Re: Ocazia-Cortez is an hispanic identitarian, not a 'socialist'females are strong as hell  07/16/18
Re: Remember back in 2011 when we asked if tranny rights were next?Versace Nigga Fuck Piece (No L\'s)  07/16/18
Re: Putin wore his $500,000 Vacheron Constantin to summit, it's that seriousLetsGetOutofThisTown  07/16/18
Re: Male gorillas: Let's give females equal votes about tribal invadersgrand arbre  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flamegoi toy  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Maori woman performing defiant haka  07/16/18
Re: RATE Justice Sotomayor's future law clerk;.,.;...;;.,.,.;;.,.,.,..;;..,......,.,..;;;;;...,  07/16/18
Re: Kerber Guaranteed Into The Tennis HOF? #tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Buy TSLAActualLawyer  07/16/18
Re: Things Libs loved in 2015: Russia, Teslas, saying "elections have consequences"HoldUp.(I Now Live as a Gay Man)  07/16/18
Re: Scary story abt NJ hospital waving Russian agents into US like 3rd base coachESL TM..,..;;.  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Remember when libs were decent people?Consuela  07/16/18
Re: Scary story abt NJ hospital waving Russian agents into US like 3rd base coachESL TM..,..;;.  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGYours For The Revolution  07/16/18
Re: There is only one relationship that matters for the survival of the World.Versace Nigga Fuck Piece (No L\'s)  07/16/18
Re: dumbest thing you've ever been yelled at for at work?[_____Sign Here____]  07/16/18
Re: To the point where I know rebuying is a joke..ESL Wilbur  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flameDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Money and the entire economy is a lie.. people just charge what they wantBOOM  07/16/18
Re: Kim Basinger in L.A. Confidential (1997)mountain view  07/16/18
Re: Planned Parenthood commercial: protect your right to fuck anyone anytime! (LiterSotomayor McCheese  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine..,.,...,..,..,.,:,,:,,..,:::,.,.,:,.,.:..:.,:.::,,  07/16/18
Re: There is only one relationship that matters for the survival of the World.HoldUp.(I Now Live as a Gay Man)  07/16/18
Re: Rate this Jewish Wapo Reporter walk his shit back in real timeVersace Nigga Fuck Piece (No L\'s)  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.beckersted.  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.Thanks Mario! But our partner is in another castle  07/16/18
Re: To the point where I know rebuying is a joke..BOOM  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.:D  07/16/18
Re: Planned Parenthood commercial: protect your right to fuck anyone anytime! (LiterSotomayor McCheese  07/16/18
Re: Journalist tossed from Trump/Putin presser.HoldUp.(I Now Live as a Gay Man)  07/16/18
Re: Bourdain was MURDERED for being a secret Trumpmo (DailyMail)ESL TM..,..;;.  07/16/18
Re: Oil falls to $69 but gas still at $3 gallon ljlActualLawyer  07/16/18
Re: at work, just got yelled atfemales are strong as hell  07/16/18
Re: Two minutes of Kavanaugh "rapping" at his Yale roommates wedding reception (vid)Versace Nigga Fuck Piece (No L\'s)  07/16/18
Re: Kerber Guaranteed Into The Tennis HOF? #tennisToro XI  07/16/18
Re: Oil falls to $69 but gas still at $3 gallon ljl.;:..;:;.:.;.,,,.,.:,.;;,;;;..;,  07/16/18
Re: Ocazia-Cortez is an hispanic identitarian, not a 'socialist'.,.,,.,,..,.,.,:,:,,...,::,...,:,.,..:..,:.::,.  07/16/18
Re: HAHAURFUCKED BACK FROM THE WASTELAND AND TAKING Q'S!!! UP AND AT EM BOYS!!bullet with butterfly wings  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.DrakeMallard  07/16/18
Re: at work, just got yelled atESL TM..,..;;.  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flamecorporate slave watching CLEs on mute  07/16/18
Re: After Weekend Of Mixed Emotions, Lawyer & Tennis Fan Takes His Life (NYT)#tennisToro XI  07/16/18
Re: Bourdain was MURDERED for being a secret Trumpmo (DailyMail)bumpin that bone thugs \'til i die  07/16/18
Re: After Weekend Of Mixed Emotions, Lawyer & Tennis Fan Takes His Life (NYT)#tennisVersace Nigga Fuck Piece (No L\'s)  07/16/18
Re: :D, admit it: you love ice cream.,.,.;;,;.,..,:,,:,;.,:::,..;.,:,.,..:.,,.:.,:.::,  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.beckersted.  07/16/18
Re: :D, admit it: you love ice cream:D  07/16/18
Re: Oil falls to $69 but gas still at $3 gallon ljlBOOM  07/16/18
Re: :D, admit it: you love ice cream.,.,.;;,;.,..,:,,:,;.,:::,..;.,:,.,..:.,,.:.,:.::,  07/16/18
Re: at work, just got yelled atfemales are strong as hell  07/16/18
Re: Journalist tossed from Trump/Putin presser.DrakeMallard  07/16/18
Re: think I realized that "fitness exercise" over sports is utter and complete flamegoi toy  07/16/18
Re: TRUMP: "The US acted stupidly".....;;,,.........;.;.;.;.,;,;,;.;.;,;  07/16/18
Re: Kerber Guaranteed Into The Tennis HOF? #tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Reporter: "Senator, my name's Chaim Levine and--" Bernie: *makes air parenthesesVersace Nigga Fuck Piece (No L\'s)  07/16/18
Re: at work, just got yelled atzarathustra  07/16/18
Re: Bourdain was MURDERED for being a secret Trumpmo (DailyMail)females are strong as hell  07/16/18
Re: Journalist tossed from Trump/Putin presser.HoldUp.(I Now Live as a Gay Man)  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: Chandler starts trial this week. Who wants to come with me to watch (CSLG)calishitlawguru  07/16/18
Re: *luis looking at blockfolio* *Don't Look Back in Anger - Oasis.mp3 plays*mountain view  07/16/18
Re: A 3 year old JAGUAR escaped from his enclosure & killed 5 alpacas/1 emu/2 foxes*A poaster\'s wounded pride*  07/16/18
Re: TRUMP: "The US acted stupidly"ESL TM..,..;;.  07/16/18
Re: Alexandria Ocasio-Cortez discusses Israel/Palestine.:D  07/16/18
Re: Hypo: You are born into a white working class family with a 170 IQVersace Nigga Fuck Piece (No L\'s)  07/16/18
Re: You guys notice the media sleight of hand from "Collusion" to "Meddling"?ESL Wilbur  07/16/18
Re: TRUMP: "The US acted stupidly".....;;,,.........;.;.;.;.,;,;,;.;.;,;  07/16/18
Re: libs have successfully forcememed the bullshit russian interference narrativegrand arbre  07/16/18
Re: *checks binance* *revises redfin parameters accordingly* *all houses disappear*leolenin  07/16/18
Re: You guys notice the media sleight of hand from "Collusion" to "Meddling"?mountain view  07/16/18
Re: Anybody got tips on Harlem Shake?ESL Wilbur  07/16/18
Re: Whoa Trump is speaking fluent Russian at this press conference. Also a red tiet bone  07/16/18
Re: Whoa Trump is speaking fluent Russian at this press conference. Also a red tieDrakeMallard  07/16/18
Re: libs have successfully forcememed the bullshit russian interference narrativefemales are strong as hell  07/16/18
Re: *luis looking at blockfolio* *Don't Look Back in Anger - Oasis.mp3 plays*ESL Wilbur  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGt bone  07/16/18
Re: Sam Cohen looking hot as fuck in a purple bikini #DBGDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: You guys notice the media sleight of hand from "Collusion" to "Meddling"?guy who gets it  07/16/18
Re: Planned Parenthood commercial: protect your right to fuck anyone anytime! (Literbumpin that bone thugs \'til i die  07/16/18
Re: TRUMP PUTIN PRESS CONFERENCE UPCOMINGYours For The Revolution  07/16/18
Re: After Weekend Of Mixed Emotions, Lawyer & Tennis Fan Takes His Life (NYT)#tennisDjavid Ben Gurion, FOUR TIMES Champ of Wimbledon  07/16/18
Re: Things Libs loved in 2015: Russia, Teslas, saying "elections have consequences"HBS \'14 Buddy  07/16/18
Re: President Trump Holds a Joint Press Conference with the President of the RussianHoldUp.(I Now Live as a Gay Man)  07/16/18
Re: TRUMP: "The US acted stupidly"t bone  07/16/18
Re: ITT: We share our favorite Anime and MangasVersace Nigga Fuck Piece (No L\'s)  07/16/18
Re: You guys notice the media sleight of hand from "Collusion" to "Meddling"?DrakeMallard  07/16/18
Re: Sam Cohen looking hot as fuck in a purple bikini #DBGToro XI  07/16/18
Re: *luis looking at blockfolio* *Don't Look Back in Anger - Oasis.mp3 plays*mountain view  07/16/18
Re: libs have successfully forcememed the bullshit russian interference narrativet bone  07/16/18
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Show Thread
Date: July 16th, 2018 11:51 AM
Author: calishitlawguru

Persian jew. Cool dude. He is part of my hookah crew every couple weeks.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:50 AM
Author: .,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.

Fair point. As it happens, she has at least one LR article
https://search.proquest.com/docview/1762693452



The Great Balancing Act: The Effect of the America Invents Act on the Division of Power Between the Patent and Trademark Office and the Federal Circuit
Ali, Samiyyah R. Vanderbilt Law Review; Nashville Vol. 69, Iss. 1, (Jan 2016): 217-248.

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INTRODUCTION

The United States Constitution grants Congress the power "[t]o promote the Progress of Science and useful Arts"1 by entering into a bargain that drives patent policy: Congress grants a patent to the inventor for a limited time, in exchange for the benefit to society of the invention.2 The Constitution empowered Congress with broad authority,3 and Congress has, as in many areas of the law,4 created several entities that shape patent policy.5 Despite Congress's creation of the United States Patent and Trademark Office ( "PTO"), tasked with the regulation of patent applications and grants, 6 courts-specifically semi-specialized appellate courts -have driven patent policy for nearly two centuries.7

Beginning in 1982 when Congress established a single, specialized court with near-exclusive appellate jurisdiction in patent cases, the Unites States Court of Appeals for the Federal Circuit, the judiciary has dominated the interpretation of the patent statute.8 From the initial Patent Act of 17909 to the most recent overhaul of the patent system,10 Congress has drafted laws in broad terms, implicitly leaving much substantive law for the patent institutions, specifically the PTO and the Federal Circuit, to interpret.11 Despite several amendments to the Patent Act, Congress has not yet given the PTO rulemaking authority over substantive questions of patent law.12 The result is a legal hybrid whereby the PTO examines and issues patents -a process that necessarily invokes patentability determinations-while the Federal Circuit assumes primary authority of interpreting substantive questions of patent law.13 Surprisingly, however, the Federal Circuit has consistently refused to grant any deference to the legal conclusions of the PTO,14 and attempts at patent policy reform have been marred by the power struggle between the PTO and the Federal Circuit over substantive patent law.15

Despite qualifying as the most substantial overhaul to the patent system,16 the America Invents Act of 2011 ( "AIA")17 continues this trend. The AIA did not grant the PTO expansive authority to promulgate rules of substantive patent law, despite early versions of legislation and numerous scholarly proposals requesting such authority.18 Congress did, however, grant the PTO new powers to be implemented after the PTO has issued a patent -most notably a postgrant review proceeding akin to an adjudicatory hearing wherein third parties may challenge the validity of granted patents.19 Many scholars understand the AIA 's new grant of power as Congress's indication that the PTO reviews patents with force-of-law power, thus warranting judicial deference to its interpretations of substantive patent law and installing the PTO as the primary interpreter of the patent statute.20

However, not all scholars agree.21 The argument for judicial deference is well articulated under administrative law, but even if interpreting the AIA 's grant of adjudicatory powers to the PTO would serve as a trigger for deference,22 the potential impact of such a deferential shift on the patent system and policy is unclear. Two facts are undisputed: (1) the AIA expands the power of the PTO,23 and (2) the Federal Circuit is uniquely positioned as the only court of appeals with subject matter jurisdiction over patent disputes, as its rulings are binding on all United States district courts.24 What scholars still dispute is whether Congress, in enacting the AIA, intended to designate the PTO as the single interpreter of the Patent Act and permanently change the balance of power between the PTO and the Federal Circuit.

This Note argues that, considering the new authority established in the AIA and the complex distribution of patent authority among the judiciary, executive, and Congress, the traditional Chevron25 framework for administrative deference is ill-suited to promote desired patent policy reform. Thus, a more flexible approach, likely Skidmore26 deference, is ideal to honor Congress 's complex institutional design of the patent system. Part I of this Note discusses the historical balance of power between agencies and courts from the first patent statute and the creation of the Federal Circuit to the Patent Act of 1952, using a historical analysis to highlight preexisting tensions. Part II analyzes and critiques the scholarly calls for Chevron deference for post-grant review proceedings established under the AIA. Part III argues that courts should grant Skidmore deference to the PTO's interpretations of substantive patent law, facilitating the necessary checks and balances on the creation of patent law and policy.

I. CONGRESSIONAL DELEGATION OF PATENT POWER BETWEEN AGENCIES AND COURTS

Although patent law is of great importance to the American economy-fostering continuous innovation to progress society27- Congress, tasked with continuously responding to rapid technological change, has neither the time nor expertise to retain exclusive control over patent reform.28 The U.S. patent system thus has a unique institutional structure, primarily featuring the PTO, an agency designated with the task of determining patentability;29 the Federal Circuit, an appellate court of near-exclusive national jurisdiction;30 and a non-comprehensive statute that leaves significant room for interpretation.31 This Part provides a brief overview of the history of the PTO, the creation of the Federal Circuit, and the relationship of those bodies in creating patent policy upon the delegation of Congress. Next, this Part discusses the treatment of calls for judicial deference under the Patent Act of 1952.

A. The History of the Patent and Trademark Office

Congressional delegation of the constitutional patent power32 predates the PTO, originating in the late eighteenth century. Under the Patent Act of 1790, Congress granted the Secretary of State, the Secretary of War, and the United States Attorney General authority to examine patent applications and issue patents.33 Congress expanded the scope of executive power over patents in the Patent Act of 1836, which created the first Patent Office and empowered it with broad authority.34 Under the Patent Act of 1836, the Patent Office gained authority "to superintend, execute, and perform, all such acts and things touching and respecting the granting and issuing of patents for new and useful discoveries, inventions, and improvements."35 Congress did not, however, enumerate any specific authority of the Patent Office to make rules interpreting substantive patent law.

Patent law was untouched by significant reform until the Patent Act of 1952, which created the modern PTO and tasked it with the mission to "foster[ ] innovation and competition primarily through examining patent applications and determining which inventions warrant the grant of a patent."36 Congress specifically endowed the PTO with the power to promulgate rules for conducting proceedings in the PTO and rules governing the conduct of patent practitioners.37 Notably, however, the statute did not grant any substantive rulemaking authority to the PTO.38 Considering the lack of congressional delegation of substantive rulemaking authority over the Patent Act of 1952 and the Federal Circuit's persistent refusal to grant judicial deference to the agency's substantive interpretations of the Patent Act, many considered the PTO a weak administrative agency.39 Consequently, the judiciary has historically assumed the role as "the most important expositor of the substantive law of patents in the United States," filling the gaps Congress left in the patent statutes.40

B. The Creation of Semi-specialized Federal Courts

Following the creation in 1891 of the modern three -tier federal courts system-i.e., regional district courts, regional courts of appeals, and the United States Supreme Court-patent appeals were indistinct from appeals in other areas of law. Thus, the regional courts of appeals maintained jurisdiction over patent appeals for nearly a century.41 The widespread jurisdiction led to numerous circuit splits on important patent issues, which prompted congressional intervention to streamline appellate authority over patent disputes, as well as patent policymaking.

1. Creation of the Court of Customs and Patent Appeals

In 1929, Congress empowered the Court of Customs and Patent Appeals ( "CCPA"), an Article I court, to hear appeals from the Patent Office and other agencies' proceedings. However, the CCPA's jurisdiction over patent appeals was not exclusive ;42 patent litigation was still reviewed by regional circuit courts, which lead to circuit splits and significant forum-shopping.43 The CCPA's unexpected execution of primarily judicial (and emphatically non-administrative) power prompted Congress to convert the CCPA into an Article III court.44 The CCPA's patent jurisprudence changed significantly when Congress overhauled the Patent Act in 1952, bolstering the scheme for resolving patentability and infringement disputes. Congress 's failure to grant the PTO substantive rulemaking authority consequently positioned the CCPA to make important decisions regarding the implementation and interpretation of the Patent Act.45 Despite the prominent influence of the CCPA in patent lawmaking and policy, Congress continued to seek increased uniformity in patent law across jurisdictions.46

By 1977, the Senate was considering reform to the judiciary; it even contemplated a National Court of Appeals.47 Within this debate, senators commonly acknowledged that the patent system needed reform and uniformity to eliminate circuit splits and chaotic treatment of patent law caused by competing appellate interpretations.48

2. The Federal Circuit and Exclusive Jurisdiction Over Patent Appeals

The Federal Courts Improvement Act ( "FCIA") provided the desired uniformity: the creation of the Federal Circuit with exclusive jurisdiction over three sources of appeals: (1) federal district court cases "arising under" the patent laws, (2) proceedings within the PTO, and (3) International Trade Commission ( "ITC") investigations over potentially infringing imported products.49 The Federal Circuit had an important mandate -to use its expertise and specialization to establish uniformity in the development and application of patent law.50

After the creation of the Federal Circuit, other institutional actors-namely, the Supreme Court and Congress -retreated from substantive patent lawmaking and deferred to the Federal Circuit's decisionmaking. Namely, the Supreme Court and Congress, the two institutions that previously directed patent law, seemingly lost interest in substantive patent law.51 The Supreme Court heard only two substantive patent issues from 1982 to 2001, and Congress did not make any substantive changes to patent law until the AIA in 2011.52 This new apathy shown by the Supreme Court and Congress, coupled with the PTO's lack of substantive rulemaking power, aggrandized the role of the Federal Circuit into a powerful creator of patent policy.53

C. The Patent Act of 1952 and Denials of Judicial Deference

Historically, the patent system has maintained a tenuous relationship with administrative law. Though the PTO is an executive agency tasked with all initial patentability determinations, the Federal Circuit has continuously resisted meaningfully engaging traditional administrative law principles when reviewing the PTO's decisions and interpretations, beginning principally with the Patent Act of 1952.54 Thus, the courts have generally refused to apply the traditional deference regimes to the PTO, leaving the courts with the ultimate say on patent policy.

1. The Chevron Doctrine and "Step Zero"

Congress often delegates its lawmaking authority when it does not have the capacity, resources, or time to resolve and develop every detail of a legislative scheme.55 In delegating its lawmaking authority, Congress has a choice of interpreter. Historically, courts have declared that it is the role, even the responsibility, of the court to say what the law is.56 However, in the modern administrative state, Congress may delegate the authority to interpret its statutory provisions to agencies through their empowering statutes.57 Meanwhile, courts, when reviewing an agency's action and interpretation of statutory provisions, must determine whether Congress delegated interpretive authority to the agency, warranting a high level of deference to the agency interpreting within that authority, or whether such interpretive power exceeds the power of the agency, leaving the court with responsibility to say what the law is.58 This analytical deference framework, derived from Chevron, U.S.A., Inc. v. NRDC, Inc., relies on a theory of congressional delegation whereby Congress "delegate[s] interpretive authority to the agency whenever it fails to resolve the meaning of particular statutory language," either implicitly (by leaving gaps in the statute for the agency to fill) or explicitly.59

In Chevron, the Court established a two-part test governing judicial review of agency interpretations.60 First, the court determines whether Congress has spoken directly to the specific question at issue.61 If there is no ambiguity in Congress's intent, both the court and agency must follow that unambiguously expressed intent.62 However, if Congress has explicitly left a gap for the agency to fill, then it has intended to delegate interpretive power to the agency. In this scenario, the court, under the second step of Chevron, must defer to the agency's reasonable interpretation of the statute.63 The Court suggested several reasons for Congress's intent to delegate to agencies (instead of courts) the authority to fill gaps in statutes: "agency expertise, lack of legislative foresight, . . . to obtain consensus on an issue while allowing divergent coalitions to 'take their chances' on a favorable decision at the administrative level," 64 and the separation-of-powers implication that political value judgments should be made by the politically accountable branches of government, not unelected judges.65

Following Chevron, the Court further clarified the deference regime, creating a "prequel" to Chevron, also known as "Step Zero."66 In United States v. Mead Corp.,67 the Court held that an agency is only entitled to Chevron deference "when it appears that Congress delegated authority to the agency generally to make rules carrying the force of law, and that the agency interpretation claiming deference was promulgated in the exercise of such authority."68 That is, before applying Chevron, a court must determine if Congress intended to defer to the agency on this type of interpretation of this specific type of statute in this particular context.69 A court must consider the agency's conferred authority alongside other statutory context in determining whether "Congress would expect the agency to be able to speak with the force of law" to fill the gaps and ambiguity in the statute.70

The Supreme Court further recognized that notice-and-comment rulemaking and formal adjudication are strong indicators of delegation warranting Chevron deference, assuming that Congress intentionally granted such authority to conduct a "formal administrative procedure" involving fairness and deliberation with the expectation that the agency bind with the force of law.71

2. Skidmore Deference

If Chevron does not apply because the statute fails at either of the aforementioned steps, the proper framework typically implemented is outlined in Skidmore v. Swift & Co.,72 which provides for a sliding scale of deference depending on the persuasiveness of the agency 's interpretive process.73 Skidmore, predating both the Administrative Procedure Act ("APA") and Chevron, held that even when the courts (rather than an agency) maintain the primary responsibility for statutory interpretation, the court should give due weight to an agency's interpretation of its own organic statute because of its familiarity with its provisions.74 Although Skidmore was decided long before the creation of Mead's Step Zero, scholars and courts generally agree that if Chevron does not apply, courts will give Skidmore deference to agency interpretations "within the agency's peculiar sphere of action," including patent law.75

Under Chevron, courts defer to reasonable interpretations regardless of the thoroughness or consistency of the agency's reasoning.76 Conversely, Skidmore requires an ad hoc approach in determining the appropriate weight accorded to an administrative interpretation given an agency's expertise, experience, and judgment.77 The court particularly inquires into the "thoroughness evident in its consideration, the validity of its reasoning, its consistency with earlier and later pronouncements, and all those factors which give it power to persuade, if lacking power to control." 78 The weight of Skidmore deference ultimately turns on the power of the agency to persuade the court, not that its interpretation is correct, but that it reflects informed consideration and supported reasoning by the agency. Because Skidmore presents a sliding-scale approach, the court is not bound to a specific level of deference in every case.

3. No Substantive Rulemaking Authority Under the Patent Act

The primary goal of patent law is to foster innovation.79 Yet it would be a daunting task, requiring a substantial expenditure of resources, to require the PTO at the early stages of patent-application examination to make an individualized inquiry and determine whether a particular patent actually promotes innovation.80 Instead, the Patent Act of 1952 instructs the PTO to make a patentability determination through a threshold examination of the patent for satisfaction of the validity standards under the statute. This role necessarily involves significant consideration of innovation, cost of patents, and benefits to consumers.81 These standards, however, are far from clear; the statute is broad and "skeletal in structure," thus necessitating a substantial legal interpretation to derive any practical use from its words.82

Consider, as an example, the requirement that the patent cover patent-eligible subject matter.83 The Patent Act of 1952 (and accordingly, the PTO) requires that the subject matter of a patent application be a "new and useful process, machine, manufacture, or composition of matter."84 The Supreme Court has long held that abstract ideas do not constitute patentable subject matter.85 If a potential patentee submits for patenting a software embedded on a CDROM and the PTO determines that the software, even in the form of a tangible disk, is an "abstract idea" and thus unpatentable, the PTO is making a substantive interpretive rule that will receive no judicial deference.86 The Federal Circuit has assumed exclusive responsibility for interpreting the substantive law of the Patent Act and has not deferred to the PTO on such matters.87 This places the PTO, which is charged with enforcing the statute, in a difficult position-it must determine if each patent meets the statutory standard, yet it lacks the authority to promulgate rules to interpret the substantive provisions of the statute.88

4. The Federal Circuit's Resistance to Administrative Principles

The PTO is unique among other prominent agencies in its lack of significant authority to issue substantive rules; consequently, its legal interpretations of the Patent Act do not receive Chevron deference.89 The Federal Circuit has only granted judicial deference to the PTO when the PTO is interpreting statutory provisions related to the conduct or procedures within the agency.90 Many scholars have suggested that the failure of Congress to give the PTO substantive interpretative powers of the Patent Act has rendered it a weak administrative agency.91 Others have blamed the Federal Circuit for creating for itself the role as the dominant, and maybe sole, player in patent policy.92

Indeed, the Federal Circuit has contributed to the balance of power in the patent system by continuously denying deference . The PTO, however, has not remained silent.93 Three cases best characterize the Federal Circuit's treatment of administrative law in patent cases and its narrow construction of the agency's authority: Animal Legal Defense Fund v. Quigg,94 Merck & Co. v. Kessler,95 and Dickinson v. Zurko.96

In Quigg, the PTO issued a notice stating that non-human organisms such as animals were patentable under 35 U.S.C. § 101, prompting a number of animal rights organizations to challenge the agency's failure to comply with the APA's97 required notice-andcomment procedures.98 The Federal Circuit ruled in favor of the PTO, holding that the notice was an interpretive rule, which is exempt from APA requirements, and not a substantive rule, which constitutes a "change in existing law or policy." 99 The court reasoned that the type of substantive declaration that would require APA compliance is not within the PTO's limited authority to promulgate rules governing the conduct of its proceedings.100 Quigg created some confusion around the distinction between interpretive and substantive rules,101 but the decision undoubtedly limited the PTO's authority.102

Five years after Quigg, the PTO again defended a statutory interpretation in Merck-a "Notice of Final Determination"103 that interpreted a statute limiting the length of potential patent term extensions for certain patents related to the pharmaceutical industry.104 This time, the Federal Circuit ruled against the PTO, firmly holding that the "broadest of the PTO's rulemaking powers" under 35 U.S.C. § 6(a) "authorize[s] the Commissioner to promulgate regulations directed only to the 'conduct of proceedings in the [PTO] '; NOT . . . the authority to issue substantive rules."105 Although the court in Merck refused to grant deference to the PTO's interpretation, it did not address the PTO's authority to promulgate rules at all.106 Nonetheless, the decision, perhaps inadvertently, served as the impetus for deying the PTO any substantive rulemaking authority in patent law.107 Prompted by the limiting nature of Merck, the PTO began asserting more influence over patent law and policy.108

The final case, Dickinson, centered on the applicability of the APA to the PTO. The Supreme Court examined whether the Patent Act specifies a judicial standard of review and to what extent that should displace the APA.109 Notably, the Patent Act predates the APA, which was enacted in 1946, and subsequent amendments did not add any language concerning how PTO actions should be reviewed in courts. Until 1999, the Federal Circuit held that the APA did not apply to its review of the PTO.110 The Supreme Court disagreed,111 holding that the APA sets the "governing standards for review of [PTO] fact-finding" and rejecting the Federal Circuit's less deferential clearly erroneous standard of review.112 Several patent scholars praise Dickinson as a monumental move by the Supreme Court to apply administrative law to the patent system.113 However, the decision did not fundamentally challenge the Federal Circuit's failure to apply administrative principles of deference to the PTO's substantive statutory interpretation.114 After Dickinson, Congress remained silent-at least until 2011.

II. THE LEAHY-SMITH AMERICA INVENTS ACT OF 2011 AND RENEWED CALLS FOR CHEVRON DEFERENCE

In 2011, Congress conducted the first significant reform to the patent system in sixty years115 with the enactment of the AIA.116 This Part provides a brief overview of the AIA's changes to the patent system, which were made in response to the many calls for patent reform. It then analyzes the arguments for judicial deference, triggered by the AIA 's creation of new PTO post-grant proceedings.

A. Long-Awaited Reforms and the Enactment of the AIA

For decades, Congress debated the necessity of reforming the patent system. Since the enactment of the Patent Act of 1952, patent practitioners and scholars complained of delays in the patent examination and review processes as well as the overwhelming number of low-quality patents, colloquially termed "bad patents," frequently issued by the PTO.117 Many patent scholars and practitioners praise the meaningful reforms in the AIA, considering it the "most significant overhaul to our patent system, since the founding fathers first conceived of codifying a grand bargain between society and invention."118 Indeed, the Act bolsters the PTO's authority and provides for important, comprehensive changes to resolve significant problems in the patent system.119

The relevant additions to the PTO's primary responsibilities stem from the creation of the Patent Trial and Appeal Board ( "PTAB"). The Act instructs the agency to appoint "administrative patent judges . . . of competent legal knowledge and scientific ability"120 who are tasked with reviewing examiners ' rejections of patent applications and appeals for reexaminations of patent applications, as well as conducting proceedings after initial patent grants121-namely, the "inter partes review"122 and the "post-grant review."123 Although the AIA implemented many changes relevant to the discussion of the balance of power between the PTO and the Federal Circuit, this Note focuses on the post-grant review and inter partes review proceedings, the creation of which served as the impetus for scholarly calls for judicial deference.

The inter partes review ("IPR") proceeding allows a challenger, within nine months of the issuance of a patent, to institute a proceeding to review the patent and request its cancellation under two specific requirements for patentability.124 The PTO director has authority to authorize an IPR if he determines that the petition raises a "reasonable likelihood that the petitioner would prevail with respect to at least [one] of the claims challenged."125 The Act also empowers the director to prescribe certain regulations, including establishing the standards and procedures for inter partes review, including regulating discovery and granting protective orders.126

The post-grant review ("PGR") proceeding is similar to, but broader in scope than, the IPR. The AIA permits a challenger to request the cancellation of patent claims as unpatentable on any ground of patent validity, not solely the two validity requirements permitted under the inter partes review.127 Additionally, the AIA imposes a standard for PGR: the director must determine that the challenger's petition "demonstrate[s] that it is more likely than not that at least [one] of the claim challenges is unpatentable."128 The director is again empowered to prescribe regulations to develop the procedural aspects of the proceeding, including the submission of supplemental information, discovery standards, sanctions for litigation abuse, and granting protected orders.129

Both proceedings result in a "final written decision with respect to the patentability of any [challenged] patent claim." 130 However, the PGR proceedings are the more robust tool. The purpose of instituting PGR proceedings was to address the infiltration of weak patents by "weed[ing them out] before they have an adverse effect on the market."131 These proceedings are the PTO's most robust tool for invalidating patents because of the allowance of third-party challenges, a deviation from other proceedings involving only the patent owner and the agency; the broad scope of possible grounds for challenge, including any statutory requirement of patentability; and the "adversarial, courtlike proceeding"132 conducted at the PTAB as a potential alternative to litigation.133 Indeed, the PGR provisions serve as the rationalization for renewed calls for judicial deference to PTO interpretations of the Patent Act.134

B. The Argument for Chevron Deference for Newly Created PTO Proceedings

Although the AIA created the PTAB and added significant postgrant review proceedings to the PTO's authority, the AIA did not fulfill all of scholars' requests. Despite the "repeated, vocal calls to do so " from the various actors in the patent system,135 Congress failed to grant the PTO any substantive rulemaking authority in the AIA. 136 Nevertheless, scholars suggest that the AIA's changes are a significant enough shift in the control of patent policymaking from the Federal Circuit to the PTO to merit systemic judicial deference.137

1. Chevron Deference for Post-grant Review Proceedings

Several patent practitioners and owners criticized Congress 's refusal to grant the PTO substantive rulemaking authority under the Patent Act, which would have likely entitled its authorized interpretations to Chevron deference.138 Even in the absence of such authority, scholars have begun arguing that the AIA 's creation of postgrant review proceedings is a trigger for Chevron deference under Mead.139 Given the characteristics that both inter partes review and PGR share with judicial proceedings (e.g., adversarial, trial-like proceedings, oral arguments, discovery, and administrative patent judges), there is a strong argument that Congress implicitly140 intended these proceedings to bind with the force of the law and trigger the high level of deference to agency interpretation advanced by Chevron.141

The foremost scholar leading the charge for Chevron deference, Professor Melissa Wasserman, indicates four primary justifications for this argument: (1) the ambiguity of the Patent Act, (2) the formality of PGR proceedings as an implicit delegation by Congress of authority to bind with the force of the law, (3) an explicit intent of such a grant of authority in the statutory language, and (4) the expertise theory of congressional delegation.142 It is undisputed that the Patent Act is often ambiguous and leaves several gaps for the interpreter (whether the agency or the court) to fill in determining standards for patentability. Thus, this Note focuses on the latter three points of analysis.

The nature of the post-grant review established under the AIA, as mentioned above, is a trial-like, adversarial proceeding, which may constitute the type of formal adjudication contemplated under Mead's Step Zero. Meanwhile, the APA states that the following signals formal adjudication: "every case of adjudication required by statute to be determined on the record after opportunity for an agency hearing." 143 While the AIA does not use the phrase "on the record," it does require the administrator of post-grant review proceedings to provide "either party with the right to an oral hearing as part of the proceeding."144 Furthermore, the AIA provides for sanctions or other consequences "for individuals who violate a policy announced during an agency's adjudication"-another indicator of the binding effect of the proceedings.145 Thus, the argument for Chevron deference is that Congress intended the PGR proceedings to take place through formal procedures, both meeting and exceeding several formal adjudication requirements under the APA.146 It so follows that Congress's intent to establish the post-grant review as formal adjudication should warrant Chevron deference for the PTO's interpretation of the Patent Act made during those proceedings.147

Next, the call for Chevron deference relies on specific statutory language describing PGR as a demonstration of explicit congressional intent. Under the provision for post-grant review, the director is instructed to determine whether the challenger has shown that it is more likely than not that a challenged claim is unpatentable.148 The director may also proceed with PGR if the challenger's petition "raises a novel or unsettled legal question that is important to other patents or patent applications."149 Professor Wasserman points to this language as Congress's intention that "the agency . . . make policy or law that affects the rights of many people," as opposed to solely determining factual issues between specific parties.150 Thus, Professor Wasserman argues that Congress intended the PTO to play a more significant policymaking function than before, given the PTO's new power to resolve broad legal questions and the broad capacity of post-grant review to settle disputes on any grounds of patentability.151

Finally, Professor Wasserman turns to the expertise theory originally highlighted by the Chevron Court.152 Despite the specialization of the Federal Circuit, she determines that the PTO is more capable of determining patentability standards to accomplish the overarching goal of innovation than the judiciary. 153 Although some Federal Circuit judges hold scientific degrees, which are helpful for patent determinations, virtually all PTO examiners hold advanced scientific degrees in the precise areas of their work . Further, the PTO has mechanisms-including hearings, studies, collaboration with other agencies, and facilitated communication with patent constituents -to make the necessary patent policy decisions.154

2. Elephant or Mouse?

Professor Wasserman presents a compelling argument for the application of administrative law to the patent system: if Congress, in enacting the AIA and creating post-grant review proceedings, intended PGR to bind with the force of law, the PTO should receive Chevron deference for its interpretations of substantive patent law. Nevertheless, some scholars are hesitant to accept such a radical shift to the patent system.155 Considering the Federal Circuit's historical refusal to afford any judicial deference to the PTO's interpretations of the Patent Act's substantive provisions, granting the high level of deference contemplated under Chevron would be dramatic.156 Though Mead demands deference when Congress intended for the agency's interpretations to bind with the force of the law, the Supreme Court has recognized "extraordinary cases [where] there may be reason to hesitate before concluding that Congress has intended such an implicit delegation."157 The Court has expressed its skepticism that Congress would "alter the fundamental details of a regulatory scheme in vague terms or ancillary provisions . . . [by] hid[ing] elephants in mouseholes."158 That is, Congress would not implictly delegate a task to an agency that would change a long-standing and pervasive regulatory structure.

Some scholars have invoked the "elephants in mouseholes" doctrine to temper the expectations that the AIA manifests Co ngress's intent to wholly shift the role of patent policymaking from the courts to the PTO, reasoning that "a new grant of authority to the [PTO] to effectively displace [the Federal Circuit] as the primary means to those ends seems to [be] more 'elephant' than 'mouse.' "159 Though the court has only applied the doctrine in extraordinary cases,160 the patent system may merit the doctrine's application. To find a power shift sufficient to warrant Chevron deference, one must accept that Congress has "turned on its head" a legal regime it earlier created-one with a single court with exclusive, specialized jurisdiction over patent appeals and a task to clarify and unify patent law.161

The AIA lacks any clear, express congressional intent to remove from the court its historical, enduring and near-exclusive role in determining patentability standards, which Congress arguably would abrogate if desired.162 And the legislative history similarly lacks any such indication.163 Though the legislative history reveals discussion of proposals to grant the PTO substantive rulemaking authority, explicit proposals were ultimately rejected despite multiple attempts to insert them.164 Still, the elephants in mouseholes doctrine may be insufficient to overcome Professor Wasserman's administrative law arguments, particularly given the high bar for cases meriting the application of the doctrine165 and the common reluctance to infer meaning from congressional inaction.166

III. FINDING BALANCE IN SKIDMORE: A FLEXIBLE DEFERENCE MODEL FOR THE PATENT SYSTEM

This Note does not contest Professor Wasserman's premise that the PTO deserves some deference. But given the significant changes in the AIA and the Dickinson Court's rejection of patent exceptionalism from administrative law, the Federal Circuit 's current tradition of granting no deference is misguided. This Note suggests that perhaps the answer is not so binary-rather, the answer may lie somewhere between Chevron deference and the continuation of the no-deference regime.

Instead of subjecting the complex institutional design of the patent system to the rigid confines of the Chevron scheme, the Federal Circuit should rely on a flexible model of judicial deference that can accommodate policymaking of the many actors in the patent system and effectively accomplish the ultimate goal of innovation. First, this Part acknowledges that the courts will, and should, deviate from applying traditional Chevron deference when congressional intent necessitates an alternative scheme. Second, this Part seeks to establish that the patent system deserves a closer look into congressional intent before applying Chevron. Finally, this Part proposes the application of Skidmore as a sufficient, though not exclusive, deference regime to accomplish the goals of the patent system.

A. Chevron Deference Does Not Always Apply

Following the Supreme Court's unanimous decision in Chevron, courts have routinely upheld reasonable agency interpretations of statutory provisions under the theory that Congress leaves gaps as implicit delegations of interpretive power to administrative agencies, where not contrary to statute.167 Mead limited Chevron, however, in creating "Step Zero "-a step that determines whether Congress intended for the agency to serve as the primary interpreter of its organic statute before triggering Chevron deference.168 Mead infers such intent when Congress intends for (1) the agency to make "generalized determinations that may affect the rights of many," (2) the agency to make binding law and policy,169 and (3) for the agency, not the court, to serve as the interpreter of the statute. Mead names two indicators in statutory grants of authority-rulemaking power and formal adjudication-as sufficient to infer congressional intent to delegate authority to the agency.170

1. Holding the Trigger of Chevron Deference

Though these procedural indicators have been termed safe harbors,171 it remains disputed whether the existence, and execution, of either rulemaking power or formal adjudication is sufficient to automatically trigger Chevron deference.172 Notably, in his concurring opinion in National Cable & Telecommunications Ass'n v. Brand X Internet Services , Justice Breyer reasoned that procedural formality was "not a sufficient condition [for Chevron deference] because Congress may have intended not to leave the matter of a particular interpretation up to the agency, irrespective of the procedure the agency uses to arrive at that interpretation, say, where an unusually basic legal question is at issue."173 At first glance, Justice Breyer's statement may appear remarkable. After all, Mead augments the Chevron doctrine to delineate two safe harbors for deferential review.

However, upon closer look, Justice Breyer's statement reflects the inherent meaning of both Mead and Chevron. Consider the suggestion that Chevron, in instructing courts to defer to agency interpretations when Congress has implicitly delegated the appropriate authority, "rests on a rational reconstruction of congressional intent about local judicial deference to agency interpretations."174 While the inferences made from the traditional safe harbors of rulemaking and adjudication are strong, they may not be absolute if congressional intent suggests otherwise.

If rulemaking power and formal adjudication are thus viewed as proxies for congressional intent-instead of automatic triggers for Chevron deference -then the Mead inquiry requires a broad statutory context and any indicators of congressional intent to delegate to agencies.175 In Brand X , for example, Justice Breyer joined the majority in applying Chevron deference after the court considered: agency expertise, "the interstitial nature of the legal question," the "importance of the question," "complexity of that administration," and "careful consideration the Agency has given the questio n."176 Furthermore, given Congress 's usual silence on judicial review standards, Chevron, viewed as a purely judicial construction, is a "fictionalized statement of legislative desire," which ultimately reflects the court's own policy judgments about statutory interpretation.177 Often the choice of procedural authority granted to the agency may sufficiently demonstrate Congress 's intent. But Chevron should not automatically apply in the presence of those formalities when congressional intent suggests the need for a different model of deference to support Congress's legislative goals. Thus, if Congress intends a particular regulatory scheme, like within the patent system, courts should hesitate before applying Chevron deference.

2. Deviations from Chevron Are Not Uncommon

Although administrative law jurisprudence has long relied on Chevron deference, particularly its application in the presence of statutory rulemaking and formal adjudication, the presumption that statutory ambiguity implies congressional delegation has never applied uniformly across all cases.178 Indeed, courts have often invoked a broad spectrum of deference when deciding whether and how much to defer to agencies' statutory interpretations.179 This is particularly true when Congress has designated more than one institutional actor as a policymaker in the field, as it has done with patents.180

Scholars have suggested that the Court sometimes takes an ad hoc approach that considers statutory context and legislative history in determining whether to defer to an agency.181 One such example is Martin v. Occupational Safety & Health Review Commission, where the Court reviewed the Occupational Health and Safety Act of 1970, a "split-enforcement statute " delegating powers to both the Secretary of Labor (tasked with setting and enforcing workplace standards) and the Occupational Safety and Health Review Commission (tasked with adjudicatory functions).182 The Court made a "particularized inquiry of congressional delegation . . . examin[ing] the inferences that could be drawn about legislative intent from the statutory context and the legislative history."183 Similarly, Chevron seems difficult to apply when there is jurisdictional overlap-i.e., when Congress might allocate authority between different actors in potentially diverging or integrated ways.184 The ad hoc approach is beneficial for complex regulatory schemes, as it allows the courts to consider the agency's expertise and opinions, while also respecting congressional intent.

B. The Patent System Requires a Second Look Before Pulling the Chevron Trigger

Though scholars use the term "jurisdictional overlap" to refer to overlapping or concurrent authority between two or more agencies,185 the principle should extend to a system-such as the patent system- in which Congress has delegated significant authority to an agency to implement a statute and charged the agency with unifying the area of law to a semi-specialized federal court.186 Neither the Federal Circuit nor the PTO are sole patent policymakers. Rather, Congress intentionally designed a shared model of patent law and policymaking, akin to overlapping jurisdiction. Thus, courts should take a closer look before applying Chevron deference to the aforementioned AIA provisions.

1. The Federal Circuit and the PTO as Sole Regulators

The Federal Circuit, despite its long-standing role as the expositor of substantive patent law,187 encounters difficulty as a policymaker. In general, scholars point to both the limited resources to conduct complex economic inquiries and technical competence as two notable deficiencies in a judicial policymaking scheme.188 Though the Federal Circuit avoids some of these concerns because of its specialization in patent law and prevalence of patent specialists on the bench,189 the court is still limited to shaping policy through the lens of the cases and facts before it.190

Meanwhile, the PTO has long been criticized for lacking the capacity to serve as the primary interpreter of the Patent Act. Scholars have pointed to the potential for industry capture ("the co -opting of regulatory agencies by [industry] groups") ,191 pointing to the recent example of Covered Business Method Patents gaining an entirely separate post-issuance proceeding under the AIA in response to heavy bank lobbying.192 Similarly, the PTO (like other agencies) may be subject to political capture by other branches of the government using the agencies for their own ends.193 Additionally, scholars point to the abundance of bad patents the PTO issues, perhaps as an indicator of the agency's weakness.194 Finally, some scholars suggest that the PTO structure itself, established long before the APA and Chevron, overly constrains PTO discretion and needs restructuring to allow the PTO to serve as a statutory interpreter. Thus, it is easy to conclude that the Federal Circuit and the PTO each lack the capacity to serve as the sole interpreter of the Patent Act.

2. A Shared Model of Patent Policymaking

The complexity of the patent system exists because Congress tasks both the PTO and the Federal Circuit, institutions from different sides of the governmental tracks, with significant objectives within patent law and policy. Neither appears capable of serving as the sole policymaker. The PTO routinely decides the patentability of patent applications195 with the goal of fostering technological innovation, 196 and the Federal Circuit reviews appeals of validity and patent infringement to provide for uniformity in patent law.197

Further complicating the patent system, there are multiple agencies other than the PTO that deal with patent law and to some extent influence patent policy.198 For example, the International Trade Commission, an independent agency governed by the Tariff Act of 1930, which excludes the importation of goods that infringe U.S. patents,199 has influenced patent policy by implementing standards for infringement remedies that have been adopted by federal courts.200 While the Federal Trade Commission does not interpret patent law, it has demonstrated the ability to influence patent policy in the pharmaceutical field by coordinating the generic-drug-market entry process with the patent process.201 The Food and Drug Administration formulates patent policy relating to drugs and therapeutic proteins.202 The National Institutes of Health ("NIH") is involved in influencing the evolution of DNA-patent jurisprudence.203 Given these shared roles in creating patent policy, it is clear that Congress intended to take an integrative approach to patent policymaking.

The patent system, viewed as a complex system with multiple policy actors in different contexts, benefits from diversification. The diversity, in competence, expertise, and scope of authority-as well as the competition between the primary actors, the PTO and the Federal Circuit-may be more likely to accomplish the goals of the patent system than either the PTO or the Federal Circuit alone.204 Thus, by allowing the Federal Circuit and PTO to continue the ir historically criticized interbranch competition,205 Congress is in fact using the competition to "bring policy closer to [its preferences] than would delegation of a single agent."206

Given the complexity of the patent system, the traditional deference framework, namely Chevron deference, is a poor fit for understanding the relationship between the Federal Circuit and the PTO. Further, it fails to provide a sufficiently flexible deference regime that promotes the integrative administration of patent law. The first step of Chevron, which asks whether there is ambiguity in the statute left for the agency to fill, calls for the mechanical grant of deference when such ambiguity exists. The Patent Act is undoubtedly ambiguous-Congress has continuously written the substantive patent laws broadly, leaving several gaps.207 Thus, the Chevron step two inquiry turns on whether Congress intended the PTO alone to fill those gaps, which , under the traditional deference scheme, calls for the Mead analysis.

Even considering the addition of the PGR proceedings in the AIA, there is reason to conclude that congressional intent warrants deviation from the Chevron analysis. Chevron's first step appears to assume that Congress either is or is not implicitly delegating to an agency, but it does not account for the many other actors in the patent system. Thus, the near-automatic application of deference inappropriately ignores Congress 's intent to delegate patent policymaking to a diverse group of agencies and courts, each with unique, yet interdependent, contributions to patent law.

Chevron's second step directs the court to defer to the agency's statutory interpretation as long as it is reasonable . But this step similarly fails the patent system because the reasonableness inquiry is incomplete. The court should look not only to the justifications provided by the agency, but also to concerns of other patent actors and the greater policy concerns implicated by substantive patent law interpretations. Because Chevron is inflexible and inadequate for this task, granting strong judicial deference to the PTO undermines the goals and structure of the patent system. Accordingly, the court must select an appropriate deference regime that accounts for rightful contributions of and competition among the many patent players.

C. Skidmore Is Sufficient and Ideal for Integrated Reform of the Patent System

Given the complex and collaborative nature of patent regulation and policymaking, Skidmore provides a strong example of a deference regime capable of contouring to the needs of the patent system. Although Skidmore deference may be considered the second choice for agencies under Mead Step Zero, only granted upon the denial of Chevron deference, the doctrine is "far from meaningless."208 In practice, courts applying Skidmore often are highly deferential in favor of government agencies.209 The primary difference between Chevron and Skidmore is the court's discretion to acknowledge the expertise of the agency while still considering other important factors involved in congressional delegation, ultimately providing for a more holistic view of policymaking and the interpretation of substantive law.

Applying Skidmore deference to the PTO's interpretations of substantive law would provide courts with the flexibility to determine the necessary deference by considering the PTO 's rationale alongside broader patent policy issues. Importantly, it would do this without compromising the concerns enumerated in Professor Wasserman's calls for judicial deference. In addition to the traditional considerations under Skidmore,210 a court has latitude to consider other factors that demonstrate the persuasiveness of the agency's interpretation. Thus, in patent cases, the court can give weight to: the PTO's expertise and prior practices, its collaboration with other patent actors, the practical effects of the interpretation on other patent agencies and in other patent technologies, and broader goals within patent policy. This approach enables courts to consider the PTO's interpretation in the context of the entire patent system, promoting collaboration in the accomplishment of patent policy goals and providing more consistency and uniformity across the entire field of patent law.

The application of Skidmore in the patent field potentially raises two important concerns: (1) binding judicial interpretation and (2) excessive judicial discretion. First, because the court is exercising its interpretation powers under Skidmore instead of granting strong judicial deference, the court's determination of the organic statute 's meaning is binding.211 Despite the force of the court's interpretation, however, it is potentially reversible. The agency can propose changes to the court's interpretation, and the court will again consider the relevant Skidmore factors. Though this erects a barrier to the PTO not present under Chevron, its effect is not undesirable -the PTO should be prepared to assert and defend its reasoning whenever it seeks deference. Second, the flexibility of Skidmore may provide courts, particularly the Federal Circuit which has refused to grant any deference, with too much latitude in rejecting an agency's argument as unpersuasive.212 Though this is an important concern, the benefits of applying Skidmore to PTO interpretations overcome the risk. As the court would be required to consider several factors to determine "persuasiveness," a Skidmore analysis forces transparency of both the court and the agency, ultimately bolstering the legitimacy and uniformity of both patent actors without sacrificing necessary flexibility. Therefore, Skidmore is better suited than Chevron to give due deference to the PTO's expertise and contour to the unique structure of the patent system.

Consider again the dilemma presented by patent-eligible subject matter: the PTO must make daily determinations of patentability to issue each patent, yet its interpretations of the AIA's provisions receive no deference from the Federal Circuit. 213 Under the current regime, the Federal Circuit largely underestimates the PTO's expertise and perspective. Under Chevron, the court would stop after evaluating the reasonableness of the PTO's sole interpretation. If the court instead applied Skidmore, it would consider the PTO's experience, longstanding practices, and expertise in making these frequent decisions, while also considering whether the agency's reasoning addresses other concerns of patent policy. For example, the Federal Circuit might decide whether the PTO considered how the interpretation would apply across the different patentable technologies, whether the measure of patentability is consistent with the NIH's concerns about patenting DNA, or whether the proposed standard furthers the overall patent goal of innovation. This level of individualized inquiry well supports Congress's complex and integrated design of the patent system. Thus, the Federal Circuit should end its ongoing practice of denying (or avoiding) deference to the PTO and adopt a Skidmore inquiry when faced with agency interpretations of the Patent Act.

CONCLUSION

In constructing the patent system to facilitate the ultimate goal of technological innovation, Congress created a uniquely hybrid legal structure. After Congress enacted the America Invents Act of 2011, greatly expanding the responsibilities of the PTO (including the addition of new adjudicatory proceedings), the balance of power between the PTO and the Federal Circuit became ripe for reexamination.

Despite some scholars ' renewed calls for the PTO to receive Chevron deference for its statutory interpretations of substantive patent law, such a grand shift in the policymaking power within the patent system seems more like an elephant, not a mouse. Chevron deference to the PTO is inappropriate given the complexity of the institutional design of patent law intended by Congress. Chevron, perhaps, is too binary-asking the question of whether or not Congress intended the agency to be the primary interpreter of its organic statute. In the patent regime, Congress did not intend to delegate the interpretive and policymaking task solely to the PTO. Instead, Congress intentionally appointed several institutions, primarily the Federal Circuit and PTO, with overlapping jurisdiction and potentially competing approaches, to best foster the patent system's goal of encouraging innovation.

Thus, though some deference is surely deserved, courts should make a particularized, ad hoc inquiry into the interpretative process of the agency, a concept familiar to Mead , before deciding how much deference is appropriate. This Note recommends the application of Skidmore deference as appropriate for such a task, given its slidingscale deference approach, but leaves for later consideration other possible deference models that may fit the patent system. The Federal Circuit should thus abandon its historical no-deference approach and conduct the particularized inquiry necessary to properly maintain the balance among the patent system's many actors.
Footnote

1. U.S. CONST. art. I, § 8, cl. 8 (granting Congress the power "[t]o promote the Progress of Science and useful Arts, by securing for limited Times to Authors and Inventors the exclusive Right to their respective Writings and Discoveries").

2. Sarah Tran, Administrative Law, Patents, and Distorted Rules , 80 GEO. WASH. L. REV. 831, 855 (2012).

3. Id.

4. See William Weaver, Note, Multiple-Agency Delegations & One-Agency Chevron, 67 VAND. L. REV. 275, 276 (2014) (describing Congress's frequent delegation).

5. Arti K. Rai, Patent Validity Across the Executive Branch: Ex Ante Foundations for Policy Development, 61 DUKE L.J. 1237, 1237 (2012) ("In patent law, as in most areas of law, Congress, courts, and administrative agencies are the key inst itutions with the potential to shape policy.").

6. Tran, supra note 2, at 834 n.5.

7. See Rai, supra note 5, at 1237 ("In practice, though, courts have generally been regarded as the dominant players in shaping patent policy.").

8. Id. at 1238.

9. Patent Act of 1790, ch. 7, § 1, 1 Stat. 109, 109 -10 (1790) (granting authority to examine and issue patents to the Secretary of State, the Secretary of War, and the Attorney General).

10. Leahy-Smith America Invents Act, Pub. L. No. 112-29, 125 Stat. 284 (2011).

11. Rai, supra note 5, at 1237-38. There are other agencies that influence patent policy, and those are mentioned later in this analysis. See id. at 1239-42 (considering the other agency actors that make patent policy, including the International Trade Commission and the Federal Trade Commission).

12. See John M. Golden, Patentable Subject Matter and Institutional Choice , 89 TEX. L. REV. 1041, 1044 (2011) (explaining that the PTO "lacks binding interpretive author ity on matters of substantive law").

13. Id. at 1043.

14. See Melissa F. Wasserman, The Changing Guard of Patent Law: Chevron Deference for the PTO, 54 WM. & MARY L. REV. 1959, 1962 (2013) ("[T]he [PTO] lacks robust substantive rulemaking authority and receives no judicial deference for its legal interpretations of the Patent Act.").

15. Sarah Tran, Patent Powers , 25 HARV. J.L. & TECH. 609, 626 (2012).

16. David Kappos, Re-Inventing the U.S. Patent System, USPTO: DIRECTOR'S FORUM (Sept. 16, 2011, 5:45 PM), http://www.uspto.gov/blog/director/entry/re_inventing_the_us_patent [http://perma.cc/D424-829H].

17. Leahy-Smith America Invents Act, Pub. L. No. 112-29, 125 Stat. 284 (2011).

18. Rai, supra note 5, at 1239 ("[T]he AIA did not give the agency the expansive rulemaking authority over questions of substantive patent law that had been proposed in earlier versions of the legislation.").

19. Joe Matal, A Guide to the Legislative History of the America Invents Act: Part I of II , 21 FED. CIR. B.J. 435, 435 (2011).

20. Wasserman, supra note 14, at 1966-67; see also Rai, supra note 5, at 1239 ("[P]atent -law scholars are beginning to treat the PTO as a full-fledged participant in the institutional debate."); Tran, supra note 15, at 610 ("[The AIA] will likely change forever the institutional structure of the patent system, particularly the roles of the Patent Office and Federal Circuit and the relationship between administrative law and patent law.").

21. See Sapna Kumar, The Accidental Agency? , 65 FLA. L. REV. 229, 238 (2013) ("Congress did not substantially alter the balance of power between the Federal Circuit and the PTO .").

22. An agency's interpretation of its organic stat ute is entitled to judicial deference if Congress delegated to it the authority to issue interpretations that carry the force of law and the agency has used that authority in interpreting the statute. United States v. Mead Corp., 533 U.S. 218, 226-27 (2001).

23. Matal, supra note 19, at 435; Wasserman, supra note 14, at 1964.

24. 28 U.S.C. § 1295 (2012); see also J. Jonas Anderson, Patent Dialogue, 92 N.C. L. REV. 1049, 1051 (2014) (discussing the jurisdiction of the Federal Circuit).

25. Chevron, U.S.A., Inc. v. Nat. Res. Def. Council, Inc., 467 U.S. 837, 837 (1984).

26. Skidmore v. Swift & Co., 323 U.S. 134, 134 (1944).

27. Paul R. Gugliuzza, The Federal Circuit as a Federal Court , 54 WM. & MARY L. REV. 1791, 1800 (2013) (explaining the economic benefits of patent innovation).

28. See Rai, supra note 5, at 1266 (explaining that Congress is "usually unable to act quickly in the face of rapid technological development" and thus must delegate to other actors in the patent system).

29. 35 U.S.C. § 131 (2012) ("The [USPTO] Director shall cause an examination to be made of the application . . . and if on such examination it appears that the applicant is entitled to a patent under the law, the Director shall issue a patent therefor.").

30. 28 U.S.C. § 1295 (2012).

31. Golden, supra note 12, at 1044.

32. U.S. CONST. art. I, § 8, cl. 8 (granting Congress the power "[t]o promote the Progress of Science and useful Arts, by securing for limited Times to Authors and Inventors the exclusive Right to their respective Writings and Discoveries").

33. Patent Act of 1790, ch. 7, § 1, 1 Stat. 109, 109 -10 (1790).

34. Tran, supra note 15, at 617.

35. Patent Act of 1836, ch. 357, § 1, 5 Stat. 117, 117 -18 (1836).

36. Wasserman, supra note 14, at 1967.

37. Patent Act of 1952, Pub. L. No. 82-593, § 6, 66 Stat. 792, 793. See Kumar, supra note 21, at 237 (noting that the "procedural rules are promulgated through notice-and-comment rulemaking" and are "bind[ing on] patent applicants") ; Tran, supra note 15, at 617 (discussing the Patent Act of 1952).

38. See Wasserman, supra note 14, at 1962 ("[T]he [PTO] lacks robust substantive rulemaking authority."). But see Tran, supra note 15, at 617-18 (interpreting the 1952 Act as "encompassing the authority to promulgate some substantive rules," such as finding a patent invalid if the patent agent withheld material facts during pro secution (emphasis added)). Interpretations of the Patent Act of 1952's grant of authority to make binding rules is discussed infra Section I.C.

39. Gugliuzza, supra note 27, at 1820. This Note discusses changes to the perception of the PTO as a weak agency resulting from the enactment of the AIA infra Part II.

40. Michael J. Burstein, Rules for Patents , 52 WM. & MARY L. REV. 1747, 1757 (2011).

41. Gugliuzza, supra note 27, at 1800.

42. Id. The CCPA also maintained jurisdiction over patent appeals from the International Trade Commission ("ITC"). Kumar, supra note 21, at 234. The ITC is given little discussion in this Note, but it should be noted that the ITC does not have concurrent authority over the Patent Act. The ITC is an independent agency governed by the Tariff Act of 1930, which grants it authority to exclude from the United States the importation of goods that infringe patents. Id. at 238.

43. Kumar, supra note 21, at 234.

44. See id. at 239-40 (stating that it was "unclear what changed in the court's mission" when Congress converted the CCPA to an Article III court).

45. See id. at 240-41 (discussing the CCPA's ability to make important choices regarding implementation of the 1952 Act).

46. Id. at 234.

47. Id. at 243.

48. See id. "For example,

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:50 AM
Author: this nigga eating memes!

affirmative action extends to law school, too...which is why law schools don't like multiple choice tests--hard to give affirmative action bonus points

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:50 AM
Author: t bone(ggtp)


lol he just threw a soccer ball at melania

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:50 AM
Author: pedude

if any, that is...

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:50 AM
Author: cannon

Cited a treaty between the countries regarding cooperation on criminal investigations. Said Mueller was welcome to send a formal request under the obligations of the treaty and they would cooperate with their law enforcement officials involved

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:50 AM
Author: guy who gets it(donny)


the fact that he is grasping at stuff like this is pure support for their Fake News label

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:50 AM
Author: calishitlawguru

The ones who make good money are. There are tons of chiros out there that have no idea what they are doing and make 40-50K a year. I have chiros begging me for business all the time.

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:50 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


good school?

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:49 AM
Author: t bone(ggtp)




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Date: July 16th, 2018 11:49 AM
Author: Buck \"The Club\" Paulette



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Date: July 16th, 2018 11:49 AM
Author: t bone(ggtp)


we have a treaty in place to deal with criminal matters between russia and us, present the evidence through those channels and we'll go through the procedures. but we also expect you to consider russian criminals in the us like some tax evader guy who was funneling money to hillary clinton.

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:49 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


doc is a jew, right?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:49 AM
Author: BOOM

https://www.wnct.com/national/teen-might-be-first-person-on-mars/1305495445

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:49 AM
Author: honiara

"libs"
"decent"

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Show Thread
Date: July 16th, 2018 11:49 AM
Author: beckersted.

For a small handful of poasters, that is the default.

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Date: July 16th, 2018 11:49 AM
Author: JFC

well-established she is cuck

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Date: July 16th, 2018 11:49 AM
Author: ....::::..::..,,....,........,..,,,,,.

Is pretty much every Chiro already hooked in with a lawyer in SoCal?

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Show Thread
Date: July 16th, 2018 11:48 AM
Author: :D(5000 mcg B12/wk, 150 mcg iodine/day, 250 mg algal DHA-EPA/day)


http://xoxohth.com/thread.php?thread_id=3710655&mc=121&forum_id=2

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Show Thread
Date: July 16th, 2018 11:48 AM
Author: typical lib pundit

Who cares that children are starving in the U.K. Libs needed to get their rage out, so well worth every penny

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Show Thread
Date: July 16th, 2018 11:48 AM
Author: cannon

Lmao

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Date: July 16th, 2018 11:48 AM
Author: boner police?



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Date: July 16th, 2018 11:48 AM
Author: .,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.

https://pbs.twimg.com/media/DO3Q-SxX0AACRXd.jpg:large

SOLVED: the mystery of the eaten Vanderbilt Law Library volumes...

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:48 AM
Author: scholarship community account

What indication is there that she was picked for any other reason than merit? She clerked for Srinivasan on the DC circuit and graduated top of her class at a good school. Unless it’s your position that no minority ever can achieve a scotus clerkship on merit.

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:48 AM
Author: .....;;,,.........;.;.;.;.,;,;,;.;.;,;

A true autist knows that counting reps and "best times" is how to make solo training into a reptile brained competitive endeavor. There was a great article on slate a while back about how this (clearly autistic) cyclist downloaded strava and became obsessed with keeping the best times on all the climbs in her city. Just do that.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:47 AM
Author: grand arbre

Are you counting the "bin" prefix?

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:47 AM
Author: a jewish man wearing hugo boss driving a mercedes

hilarious how much absurdist parody has turned into mainstream liberal dogma.

https://www.youtube.com/watch?v=R79yYo2aOZs

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:47 AM
Author: boner police?



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Date: July 16th, 2018 11:47 AM
Author: smell the glove

Nah, that's not Russian -- he's not saying "Das Svedanya," he's saying "Dat's sweet on ya."

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:47 AM
Author: DrakeMallard(Let's get dangerous)




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Date: July 16th, 2018 11:47 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)




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Show Thread
Date: July 16th, 2018 11:46 AM
Author: Taylor Swift is not a hobby she is a lifestyle

There's no gold fringe on those American flags. This is true America, folks.

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:46 AM
Author: calishitlawguru

There is no such thing as prestigious chiropractors. They only make good money because they do PI.

(http://templocation/thread.php?thread_id=123)

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Date: July 16th, 2018 11:46 AM
Author: grand arbre

(Amy Coney Barrett)

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Date: July 16th, 2018 11:46 AM
Author: .,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.

burrito farts FTW

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:46 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


https://www.tennisworldusa.org/tennis/news/Roger_Federer/57794/roger-federer-and-wife-mirka-enjoy-holidays-in-ibiza/

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:46 AM
Author: JFC

clerked for xo sri & xo thapar...

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: calishitlawguru

Nah, my client is a super cool guy. One of my best clients ever. He treated without missing any appointments, was appreciative with the settlement, never called me with questions, and told all his friends about me. We shot the shit in Spanish and drank some beers on my coach for a bit during the party.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: grand arbre



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: Sir Incelot

“An insider’s Guide to Clerkships”

Step 1: Be a black female

Step 2: ???

Step 3: Get Sotomayor Clerkship

Step 4: Collect dat Big Law Bonus and serve as token firm minority

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: BOOM

180

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: a jewish man wearing hugo boss driving a mercedes



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: Yours For The Revolution(Pederastrian)


missed it. what did he say?


(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: Taylor Swift is not a hobby she is a lifestyle



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: ESL Wilbur(Short Pride World Wide)


lol at the filename.

I thought this thing was going to be like a Macy's parade balloon

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:45 AM
Author: *A poaster\'s wounded pride*

It's literally Trump and Putin vs FBI/shadow DOJ. What a time to be alive.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:44 AM
Author: Yours For The Revolution(Pederastrian)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:44 AM
Author: loans originated on or after July 1, 2018,

So suddenly got on board with tax cuts, the religious right, deregulation for business and the environment, anti-abortion judges, the end of public section unions, etc.?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:44 AM
Author: t bone(ggtp)


pretty clever response tbf

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:44 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


https://www.atpworldtour.com/en/news/mike-bryan-no-1-atp-doubles-rankings-2018

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:44 AM
Author: Bedroom Bully(All poasts are performance art )


No you were just young and clueless

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:44 AM
Author: ,.,.,.,..,.,.,,.,.,.,.,.,.,.

https://media.breitbart.com/media/2018/07/Trump-Small.png

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: a jewish man wearing hugo boss driving a mercedes



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: boner police?



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: DrakeMallard(Let's get dangerous)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: typical lib pundit



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: boner police?



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: typical lib pundit

Go on...

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: goi toy

It's almost like the expertise of others can help you achieve yours goals even if you're not a professional athlete

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: Bedroom Bully(All poasts are performance art )


I'm not exactly an expert on foreign policy but I am an expert on knowing a systemically racist patriarchy when I see one

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:43 AM
Author: :D(5000 mcg B12/wk, 150 mcg iodine/day, 250 mg algal DHA-EPA/day)


I believe Guamians are allowed to leave their homes.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: Progression to the Mean(Dork Enlightenment)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: MoreDoughHi

fuck u op

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: cannon

Putin calling Mueller's bluff on the indicted Russian officials

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: Boichester United

"We ran a brilliant campaign, and that's why I'm President."

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: DrakeMallard(Let's get dangerous)


TRUMP: "I would rather take a political risk in pursuit of peace than risk peace in pursuit of politics."

Libs: NUCLEAR WAR NOW! CAN'T FORGIVE FOR LETTING SHE LOSE!

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: MoreDoughHi

annapolis

key west

jupiter

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: a jewish man wearing hugo boss driving a mercedes



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: Sir Incelot

Or PR, considering her heritage?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:42 AM
Author: ESL TM..,..;;.

lolno

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: ESL Wilbur(Short Pride World Wide)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: HoldUp.(I Now Live as a Gay Man)



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: Sir Incelot

Jews realize that if they are ostracized by the Dems, then they have nowhere else to go (other than the trains).

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: t bone(ggtp)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: BOOM



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: Sotomayor McCheese

I'm from La Jolla.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: a jewish man wearing hugo boss driving a mercedes

not sure her chambers are such a hub of activity that remedial measures are necessary.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: Sexually frustrated male poasting into the void



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: ESL TM..,..;;.



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:41 AM
Author: BOOM

Is this some sort of a joke?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: Sir Incelot



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


thapar was that desperate for clerks he got this thing?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: HoldUp.(I Now Live as a Gay Man)



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: MoreDoughHi

then halford will be dale jr.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: ESL Wilbur(Short Pride World Wide)


seems to be eating well....

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: *A poaster\'s wounded pride*

Trump is incredible. Everything about him defies convention. Truly an honor to be alive in 2018 as a witness.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)


mazel tov

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:40 AM
Author: Thanks Mario! But our partner is in another castle( )


jfc.

But WHY are political candidates asked about Israel and never, say, Guam (which is an actual US territory)?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:39 AM
Author: typical lib pundit

Feel bad for the other clerks who will have to work that much harder to pick up the work for her - and for this clerk as well

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:39 AM
Author: BOOM



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:39 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


the biggest knock against her is that she's been dominated any time she gets good competition. prime henin utterly dominated her.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:39 AM
Author: Sir Incelot

If it walks like a duck...

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:39 AM
Author: Such anathema to us!(as The Americans)


"othered"

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:39 AM
Author: ESL TM..,..;;.

Lib media: "Omg, so unbecoming of the POTUS. Doesn't matter if it is true, no one is supposed to say that! If Hillary Clinton was the first female POTUS then this wouldn't happen!"

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:39 AM
Author: MoreDoughHi

http://www.politifact.com/punditfact/statements/2016/aug/28/david-plouffe/yes-donald-trump-donated-100000-clinton-foundation/

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: BOOM

Cr

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: ESL TM..,..;;.



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


maybe his asspicking distracts him and makes him play worse and he should just fucking serve up an ace.



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: grand arbre

http://www.presidency.ucsb.edu/ws/index.php?pid=29608

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: ESL TM..,..;;.



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: Toro XI

idk about most overrated, but certainly she has a lot of negatives that people seem to ignore

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: .,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.

Samiyyah Ali is Easily Distracted
http://gabbysidibe.ytmnd.com/

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: Such anathema to us!(as The Americans)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: t bone(ggtp)


No collusion people

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:38 AM
Author: ESL TM..,..;;.



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: :D(5000 mcg B12/wk, 150 mcg iodine/day, 250 mg algal DHA-EPA/day)


https://www.politico.com/story/2018/07/16/fcc-sends-sinclair-mega-deal-to-likely-doom-722423
wtf

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: ESL TM..,..;;.

Fuck da

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


poor rc?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: .....;;,,.........;.;.;.;.,;,;,;.;.;,;

This is such a bullshit talking point. Nothing remotely on the level of 2016 happened in the 1996 Russian election. You have to go back to the CIA in the 50s to find the U.S. intervening at that level. And what the Russians did in the U.S. is weaksauce compared to what they've done a several countries in Europe. In 1996, we strongarmed the IMF to give Russia a loan when we knew Yeltsin and his cronies were just going to piss it all away, and there were politically connected U.S. PR people helping Yeltsin (i.e. what Manafort claims he was doing in Ukraine and a dozen other shady places, but without the assassinations and millions of dollars paid under the table). Link to U.S. hacking into the party committee comms and publishing them in an effort to embarrass one side and help the other or some other act of actual sabotage of an opponent?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: Toro XI

yeah a total fuckup. you can't have 3 cons. set points and not get one. at that level it can't happen.

what does speed of play have to do with it? btw, i read somewhere that during that match on tough points during his serve Djoker was averaging almost 32 seconds before play.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: froodfrood( )


Virginal conservatcucks declare war on dildos to eliminate the competition.

https://www.vanityfair.com/news/2016/04/ted-cruz-texas-sex-toy-ban

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: ESL TM..,..;;.

Jfc, when are reporters going to get that this bullshit makes them look far worse than Trump. Remember the stupid Japanese Koi incident that turned out to be bullshit?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:37 AM
Author: Sir Incelot

lol

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:36 AM
Author: michael doodikoff

also, to my recollection, no one said "pussy"


(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:36 AM
Author: alzabo



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:36 AM
Author: HoldUp.(I Now Live as a Gay Man)



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:36 AM
Author: a jewish man wearing hugo boss driving a mercedes

lol.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:36 AM
Author: Morning In America



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:36 AM
Author: Sir Incelot

Weird flame

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:36 AM
Author: ......,,.......



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: ESL TM..,..;;.

Whoa there, Carnando whoever still holds that title (the guy who writes about picking up $10 tranny hookers and rawdogging them).

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: .,.,,.,,..,.,.,:,:,,...,::,...,:,.,..:..,:.::,.

ime, buying expensive food that she actually eats is far less annoying than her buying regular stuff that gets thrown out.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


cr. most overrated hack of all time.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: ......,,.......



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: .,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.

oh, what a SCHOLAR!
https://twitter.com/bennyjohnson/status/1018874752126148616

Socialist Ocasio-Cortez confronted with booming economy & low unemployment numbers. She says "Unemployment is low because everyone has two jobs” and "Capitalism has not always existed in the world and will not always exist in the world.”

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: ......,,.......



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: Morning In America

https://m.youtube.com/watch?v=XLcB0fD8Ikg#

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:35 AM
Author: t bone(ggtp)


will sarah call on FAKENEWS CNN

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: Toro XI

btw, Serena literally played one decent player the entire tournament and got straight-setted.

her 4R/QF/SF opponents had all never been that far in a major.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


oh ok. ESL tennisworldusa seemed to say that he was up 3-0 in the 5th.

yeah, he DF'd when he was up 6-3 in that breaker, no??

maybe lance should play faster on his serve so that he doesnt get behind and have to dig himself out of those holes, no?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: biglaw lives matter (retired)



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: Maori woman performing defiant haka

They dont gaf about the underdog. Just like they dont care about blacks. It's all a ploy

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: .,.,...,;..,.,.,:,,:,...,:::,.,.,:,,,.:.,:.,:.::,.

Socialist Alexandria Ocasio-Cortez is the new darling of the Democratic party. In a recent interview, however, the upstart politico running in a hyper-liberal district in New York did not show command of the issues. Ocasio-Cortez was being interviewed by Margaret Hoover on the PBS show ‘Firing Line.’

Hoover asked very basic, softball questions of the young congressional candidate. In explaining her positions on the economy, Hoover asked Ocasio-Cortez “Do you think that capitalism has failed to deliver for working class Americans?” Hoover cited a currently booming US economy and low unemployment.

“Unemployment is low because everyone has two jobs,” Ocasio-Cortez explained, lamenting that people are employed but having to work long hours, “Capitalism has not always existed in the world and will not always exist in the world,” she continued.

Later in the interview, Ocasio-Cortez was asked if she thinks capitalism would survive as an economic system. Ocasio-Cortez shrugged and said that was a “good question” and believes our economy will “evolve.”

The 27-year old also called Israel occupiers of Palestinian land. When pushed on the comment, she mumbled and demurred ultimately admitting that she does not know anything on the issue.

https://twitter.com/bennyjohnson/status/1018874752126148616



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: females are strong as hell

Female gorillas have more sense than libs

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: typical lib pundit

https://vtdigger.org/2018/07/15/vermont-law-school-revokes-tenure-75-percent-faculty/

"Professors interviewed by VTDigger are concerned that the 75 percent reduction in tenured faculty will damage the school’s reputation as one of the nation’s top-ranked environmental law schools."

will damage the school’s reputation as one of the nation’s top-ranked environmental law schools

will damage the school’s reputation as one of the nation’s top-ranked environmental law schools

will damage the school’s reputation as one of the nation’s top-ranked environmental law schools

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:34 AM
Author: dead lahey

Ho Lee Fuk

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: Toro XI

I mean I even like clubbing and shit, much more than probably most poasters, but let's not act like there aren't plenty of other fun and worthwhile things one can do with one's time.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: females are strong as hell

You think maybe religious ritual isn’t comparable to sports lingo? Are you jewish?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)


absolutely devastating

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: LetsGetOutofThisTown

fking love that watch. IWC is 180.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: grand arbre



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: goi toy

You're basically a huge fucking loser if you're not trying to maximize your physical potential in the gym.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: Maori woman performing defiant haka

Hopefully jews do something useful for once and bury this retard

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:33 AM
Author: ;.,.;...;;.,.,.;;.,.,.,..;;..,......,.,..;;;;;...,

https://law.vanderbilt.edu/news/sammiyah-ali-16-will-clerk-for-supreme-court-justice-sonia-sotomayor-in-2018/

Samiyyah Ali ’16 will clerk for Supreme Court Justice Sonia Sotomayor in 2018
Nov 17, 2017

Samiyyah Ali ’16 will serve as a law clerk to Justice Sonia Sotomayor of the U.S. Supreme Court for the term beginning October 2018.

Ali is currently serving as a law clerk to Judge Sri Srinivasan of the U.S. Court of Appeals for the D.C. Circuit in Washington. During the 2016-17 term, she was a law clerk for Judge Amul Thapar, then of the U.S. District Court for the Eastern District of Kentucky. Judge Thapar has since been appointed to the U.S. Court of Appeals for the Sixth Circuit.

Ali holds an undergraduate degree in psychology from Duke University and an M.A. in higher education from The Ohio State University, where she worked before entering law school. At Vanderbilt, she was Executive Editor of the Vanderbilt Law Review, vice president of the Black Law Students Association, president of the VLS Ambassadors, and a member of OUTLaw. A recipient of both the Hess and Ethel and Cecil Roberts scholarships, Ali earned numerous book awards, was selected for the Cal Turner Program for Moral Leadership in the Professions, and participated in the Vanderbilt Legal Academy Scholars Program. At graduation, she received the Bennett Douglas Bell Memorial Award, which recognizes the student “who is not only well versed in the law, but who shows the highest conception of the ethics of the profession,” and the National Association of Women Lawyers Outstanding Scholar Award. She was elected to the Order of the Coif and received a Dean’s Leadership Award.

“Samiyyah had a stellar academic record at Vanderbilt, and she touched and impacted almost every part of Vanderbilt during her time here,” said Michael Bressman, who heads Vanderbilt’s Clerkship Program. “We take tremendous pride in her achievements.”

Ali is a native of Atlanta, Georgia.

https://twitter.com/samiali10?lang=en

https://law.vanderbilt.edu/images/events/2017-Branstetter-SamiyyahAli-poster-WEB.jpg



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:32 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


anti-german sentiment could have kept her out before

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:32 AM
Author: ActualLawyer

Down over tweets, will jump to over $1,000 in a few years once the Semis are online and Amazon buys a fleet of them when truck driver shortage reaches critical mass

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:32 AM
Author: HoldUp.(I Now Live as a Gay Man)



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:31 AM
Author: ESL TM..,..;;.

tcr

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:31 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


sup ahmed?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:31 AM
Author: Consuela



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:31 AM
Author: ESL TM..,..;;.

lol, wow, haha

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:31 AM
Author: Yours For The Revolution(Pederastrian)


lmao @ the russian journo's question

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:31 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)


penis-anus

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: [_____Sign Here____](CircuitCitySpecial)


Having the page numbering on the right side of the doc. Partner was upset for a few minutes and asking "Why would you put it on the right side? No one does that."



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: ESL Wilbur(Short Pride World Wide)


it's a GREAT time to re-buy sub 500. You should be buying as much as you can afford

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


shit logic. professional athletes need to achieve absolute peak performance and need trainers, physios, nutritionists to help them maximize and preserve their bodies bc they're training 8 hours a day or more and they need very small improvements to get better at their sport.

a normal grown man who is in the gym for general health reasons doesnt need another man to watch him squat and deadlift and bench press and run on the treadmill.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: BOOM

Truth

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: mountain view(aide de camp)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: Sotomayor McCheese

No. Just make it three countries. We don't want East Coasters out here even if they are politically aligned with us.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: .,.,...,..,..,.,:,,:,,..,:::,.,.,:,.,.:..:.,:.::,,

lol what a dumbass. israel has been occupying palestine for decades, it's literally an "occupation." doesn't mean that israel was wrong to do it, though. The US occupied germany and japan, etc.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: HoldUp.(I Now Live as a Gay Man)



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)


titcq

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:30 AM
Author: beckersted.

but that's the point.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: Thanks Mario! But our partner is in another castle( )




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: BOOM



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: :D(5000 mcg B12/wk, 150 mcg iodine/day, 250 mg algal DHA-EPA/day)


She was asked the question...

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: Sotomayor McCheese

Yep. PP does a ton of STD screening/treatment.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: HoldUp.(I Now Live as a Gay Man)

libs great majority of white house press corps, this actually lines up if not flame

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: ESL TM..,..;;.

He sounds high as fuck.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: ActualLawyer

You are an idiot if you don't buy an electric car, or at least a hybrid. Gas will be at $80+ in Dec.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: females are strong as hell

(risk averse pansy)

Job market is hot as fuck right now. He’ll be making more money in 3 months

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: Toro XI

she was guaranteed anyway imo with 2 majors and a YE #1, but yes now she's a no-brainer

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:29 AM
Author: .;:..;:;.:.;.,,,.,.:,.;;,;;;..;,

Hehe?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: .,.,,.,,..,.,.,:,:,,...,::,...,:,.,..:..,:.::,.

and somehow you guys never called Obama out for this shit

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: bullet with butterfly wings

SORRY BEING RAISED ON KRAFT DINNER AND GOOSEBUMPS BOOKS FAILED TO ADEQUATELY PREPARE YOU FOR THE FUCKING HUNGER GAMES OF TODAY'S CUTTHROAT PROFESSIONAL WORLD!!!

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: DrakeMallard(Let's get dangerous)


Jews are fucking irate that an anti-jewish dem is getting traction

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: ESL TM..,..;;.

(bad idea bear)

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: corporate slave watching CLEs on mute

Odd case. I do think there's something sports or basically any competitive event can give you that mindless repetition of workout can't, but you can simulate this competitive feeling even in your own workouts. Download one of the fitness apps and you can compare how fast you run a certain area vs everyone else in your city and try to move up the board, try to beat your personal bests, etc.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: Toro XI

i did watch the semi -- nadal was never up in the 5th. he was up 3-0 in the 4th, which he won.

i knew nadal was going to lose when he didn't break from 15-40 at 4-all. for some reason of all the top players Nadal consistently gets behind early in his service games more often, but then digs out better than all of them. but as he was serving 2nd in the 5th, once you get past 4-all the pressure becomes enormous, and Djoker was always in the position of being 2 poins away, whereas nadal was always like 6 points away.

i do think outside of the first set nadal was the better player, but the big error was not winning the tiebreak in the 3rd when he was up 6-3.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: bumpin that bone thugs \'til i die(askav)


the last thing you do before you die is cross a clinton

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:28 AM
Author: .,.,.;;,;.,..,:,,:,;.,:::,..;.,:,.,..:.,,.:.,:.::,

u luv it tho

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: beckersted.

putting aside a bunch of things, i've noticed that her opinions--as ill founded as they are--about israel keep bubbling to the top of coverage of her. a chick who likely will be in the House and everything is israel, israel, israel.

mind you, i don't agree with her in pretty much anything.

with that said...keep flying too close to the sun. it's becoming obvious now and it's a little annoying. keep it up.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: :D(5000 mcg B12/wk, 150 mcg iodine/day, 250 mg algal DHA-EPA/day)


dairy very bad

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: BOOM

https://www.google.com/amp/s/www.cnbc.com/amp/2018/07/16/oil-falls-as-mnuchin-says-oil-buyers-may-get-iran-sanctions-waivers.html

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: .,.,.;;,;.,..,:,,:,;.,:::,..;.,:,.,..:.,,.:.,:.::,



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: females are strong as hell

Tell your boss to fire you if he’s so smart

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: DrakeMallard(Let's get dangerous)


JFC I'm shocked the media shitlibs didn't rip him apart limb from limb with that kind of hate speech

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: goi toy

I consider myself a fan of yours, but we all know you're a twink. Time to get off the "how to be a man" highhorse here. Almost every single professional athlete on the planet has a trainer or coach telling them how to work out. It's fine to rely on the expertise of others for exercise.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: .....;;,,.........;.;.;.;.,;,;,;.;.;,;

LOL at these Yosemite Sam fuming faggot comrades.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


heil!

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:27 AM
Author: zarathustra

called out gen x

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:26 AM
Author: females are strong as hell

“Bourdain also bizarrely said Jared Kushner's eyebrows appeared 'manscaped' and said he 'was a born snitch'”

Lol nothing ‘bizarre’ about this characterization, he knew.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:26 AM
Author: HoldUp.(I Now Live as a Gay Man)

seriously?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:26 AM
Author: t bone(ggtp)


RADICAL ISLAMIC TERRORISM is a GLOBAL MENACE

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:26 AM
Author: calishitlawguru

I think their top offer was like 14K. We did a 998 for 35K a month or two ago. It's a low speed rear end accident. We will either get nothing or a lot. It's kind of a zero sum type accident. If the jury believes the injury it is worth 50-100K (since she didn't get surgery). If they don't believe causation they will give her probably a few thousand for soft tissue injury.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:26 AM
Author: mountain view(aide de camp)


i was thinking big picture

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:26 AM
Author: *A poaster\'s wounded pride*

A young male jaguar at the Audubon Zoo in New Orleans slipped out of its enclosure in the dark of night and went on a territorial killing rampage, attacking alpacas and foxes and an emu trapped in their own habitats before veterinarians armed with tranquilizers managed to sedate it.

The big cat — a 3-year-old named Valerio — was first reported missing at 7:20 a.m. Saturday, before the zoo opened, officials said. By 8:15 a.m., the jaguar had been located, tranquilized and returned to its enclosure by veterinarians.

But by then, the carnage was already considerable: Four alpacas, a fox and the emu were dead, and several other animals were injured, zoo officials said Saturday. On Sunday, zoo officials raised the death toll to eight, announcing that a fifth alpaca and a second fox had died.

No humans were injured by the jaguar, although the circumstances of the escape sparked worry at what might have been: The “jaguar jungle” is also home to a children’s play area.

Zoo officials insisted at a news conference Saturday that the facility was safe for the general public, even though they wouldn’t say how the apex predator managed to escape and either kill or injure every alpaca on zoo property.

“An investigation is underway and we will release information when available,” the zoo said Sunday afternoon. “Initial findings concluded keeper error was not a factor in this incident.”

The New Orleans Advocate reported that the roof over the jaguar enclosure had been compromised.

In addition to the slain animals, another injured fox was being cared for. “Rusty fared well overnight; he will continue to be monitored and treated by expert animal care professionals,” the zoo said Sunday morning.

Zoo officials said they planed to sedate Valerio, the jaguar, on Sunday, to examine him “for any injuries sustained during his time outside of the exhibit.”


The jaguar did not appear to be eating the animals it went after but rather was engaged in a territorial display, said Kyle Burks, the zoo’s vice president and managing director. The animals it pounced on — a red fox named Maggie Mae; Elmo the emu; and the four alpacas, named Alexandria, Micia, Noel and Lil Melody, according to the Advocate — in their own enclosures were unable to escape.

The zoo was closed Saturday as officials tried to discover how the feline escaped. Grief counselors were also brought in for traumatized staff. The zoo reopened Sunday.

But the incident was certain to raise questions about the dangers of caging apex predators that have evolved to hunt and kill and will quickly pounce on prey animals — or humans — if safeguards break down.



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:26 AM
Author: ESL TM..,..;;.



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: :D(5000 mcg B12/wk, 150 mcg iodine/day, 250 mg algal DHA-EPA/day)


(graduate degree holding Swamp creature that thinks people follow foreign policy and the nuanced policy positions of out of district members of Congress)

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)


Legit answer? deal drugs until 18, become a rapper. no downsides, infinite teen pussy, etc etc etc.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: ESL Wilbur(Short Pride World Wide)


she would have won, too, if it weren't for those meddling russians

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: .....;;,,.........;.;.;.;.,;,;,;.;.;,;

It's going to be awesome with Drake gets outed as Eric Trump tp.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: grand arbre

Universal suffrage is a terrible idea on its face

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: leolenin



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: mountain view(aide de camp)


it's tough to keep track of it all tbh

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:25 AM
Author: ESL Wilbur(Short Pride World Wide)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: t bone(ggtp)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: DrakeMallard(Let's get dangerous)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: females are strong as hell

It’s helpful for identifying the ~15% of the politically conscious population that is not braindet

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: ESL Wilbur(Short Pride World Wide)


did you check the price today bro

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: t bone(ggtp)


TRUMP upgraded Russia-US relations to "not the worst ever"

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: guy who gets it(donny)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: bumpin that bone thugs \'til i die(askav)


thread took a predictable turn

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: Yours For The Revolution(Pederastrian)


at LENGTH

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


it's benzo level hitlery threading, breh

but did u watch the SF tho? lance was up 3-0 in the 5th. wtf happened?

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: HBS \'14 Buddy



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:24 AM
Author: HoldUp.(I Now Live as a Gay Man)

crushing

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: t bone(ggtp)


that was the ussr

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: Versace Nigga Fuck Piece (No L\'s)(Ethical Boihole Consumption)


It took me a while before I could watch anime sober. still usually get high and binge the 2nd half of any given season I'm watching.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: DrakeMallard(Let's get dangerous)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: Toro XI

she looks great there with those bikini bottom straps hiked up, like she should be in one of those 80s tit movies like Bikini Carwash Company or something

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: mountain view(aide de camp)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: t bone(ggtp)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: animeboi

harsh, but fair.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: females are strong as hell

How dare he criticize deep state policy

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: DrakeMallard(Let's get dangerous)


http://www.nydailynews.com/archives/news/jfk-jr-mulled-run-senate-2000-article-1.847866

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: a jewish man wearing hugo boss driving a mercedes

to a large part of the population, at least, the narrative is simply accepted as fact. talk show hosts can now just mention the "connection" and their dumbshit audiences eat it up. all this without a shred of evidence. it's scary.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:23 AM
Author: logan thincock

So brave! Hope she gets coverage bigly going into this midterm. Bluewave!

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:22 AM
Author: LathamTouchedMe

He was from the Nation magazine. Apparently he was handing out an op-ed from the Nation calling for better relations between the US and Russia to everyone present.

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:22 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)


no

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:22 AM
Author: Toro XI

?? neither of those were predictions or anything

in any event i did not watch a single minute of either final this weekend.

actually that's not true -- when i heard (zuc)KERBER(g) won I caught some of the 2nd set in the replay

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:22 AM
Author: Guy Debord

Fuucccckkkkk! And these people are always so sure that this is a "rule"

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:22 AM
Author: Djavid Ben Gurion, FOUR TIMES Champ of Wimbledon(*)




(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:22 AM
Author: t bone(ggtp)


TRUMP speaking now

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:21 AM
Author: Oh, you travel?



(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:21 AM
Author: Yours For The Revolution(Pederastrian)


that was SS

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:21 AM
Author: HoldUp.(I Now Live as a Gay Man)

can only imagine what he's feeling now

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:21 AM
Author: leolenin

aren't you like 5'7"

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:21 AM
Author: t bone(ggtp)


this was the weakest ejection ive ever seen, very light touch from the finns

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:20 AM
Author: Bedroom Bully(All poasts are performance art )


Cr this message dovetails nicely with the other lib message that rape is rampant and sex is a gravely serious act

(http://templocation/thread.php?thread_id=123)

Show Thread
Date: July 16th, 2018 11:20 AM
Author: Sir Incelot

He got off easy. They should have just guillotined him in front of the others.

(http://templocation/thread.php?thread_id=123)