Journal of Intellectual Property Law & Practice Advance Access published online on November 21, 2007
Journal of Intellectual Property Law & Practice, doi:10.1093/jiplp/jpm186
| ||||||||||||||||||||||||||||||||||||||||||||||||||
© The Author (2007). Published by Oxford University Press. All rights reserved
The great free beer debate or, what ales the patent system?
Virtual Worlds, with their own economies and political systems, have become commonplace.1 This report summarizes the history of the Free Beer debate, which occurred some years ago in Wasted Life, the first virtual world to feature a patent system. For those unfamiliar with Wasted Life, suffice to say that its countries and institutions are closely based on those of our own world, though the many colourful personalities are, of course, entirely fictitious creations of the players themselves.
The seeds of the controversy sprouted in the brewery-dominated world of the late 20th century, in which huge monopoly brewing brands sold their products through tied chains of pubs. Advances in brewing technology had made beer affordable for the masses, but at a cost: the taste was uniform and bland, the ingredients numerous and unknown. CAMRA, the Campaign for Real Ale, mounted ineffective protests which, however, were influential in the academic community. Colleges, with their subsidized bars, produced a generation of students and lecturers who wanted good beer but lacked both the means and the inclination to pay brewery prices.
 |
The home brew ethos |
|---|
 Top The home brew ethos The development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
This was the home brew era—a heady period of individual experimentation, using the recently developed, cheap, home-brewing kits. A cottage brew-your-own industry grew up, under the radar of the major brewery chains. Individuals (mostly students and lecturers) brewed beer for themselves and their friends—much of it undrinkable. One of the poorer yeast micro-organisms produced during this era was acquired by the company later known as Micro-org, which rocketed to success by marketing it for use with the International Brewing Machines' just-launched, home brew kit. Within a few short years, the home brewing industry was transformed: instead of a plethora of competing kits and yeasts, most home brew looked and tasted the same. It left a bitter taste in many a mouth.
The microbrewery movement raised the torch of the early home brewers in rebellion against the de facto dominance of Micro-org.2 The first and most influential of the microbrewers was Robert Staleman. His beer, LNG,3 was a super-cooled dark stout, born out of the science labs of Stanford and developed with public funds. Those who tried it said it was indistinguishable from the leading commercial brand (though their judgments may have been affected by intoxication and hypothermia). As it was served at liquid nitrogen temperatures, his beer had little impact on the mass market: the average beer glass often cracked under the thermal stress, and thicker-walled beer mugs inevitably did so.
There were dark mutterings in the brewing industry that Staleman's work had been funded by the glass manufacturers in an attempt to foist a new generation of hi-tech beer glasses on the public. However, in university science departments, where Liquid Nitrogen Gas cooling apparatus was available, sales of unbreakable half-litre Pyrex® beakers soared, and Staleman's beer became the first choice of science students and lecturers.
Staleman's re-creation was a classic feat of reverse brewing which earned him widespread praise, as much for his ground-breaking decision to make the recipe available free of charge as for the undoubted technical quality of his work. Beer without payment resonated powerfully with students who were learning to ignore IP, by plagiarizing essays, photocopying textbooks, and downloading music without paying the authors. This, then, marked the beginning of the ‘Free Beer’ movement.
|
The development of the European beer exclusion |
|---|
|
TopThe home brew ethosThe development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
In Europe, meanwhile, brewing was in an age of transition. With the introduction of the European Patent Convention in the 1970s, the powerful Bavarian brewing lobby (their position entrenched by the centuries-old ‘Reinheitsgebot’, the Bavarian Purity Law of beer) had succeeded in excluding protection for beer from the European Patent Convention, but only beer ‘as such’.4
This unsatisfactory legislation led to endless test cases. Almost theological were the debates conducted before the Boards of Appeal of the European Patent Office (EPO), as the European Anti-Patent Office was then known (before it raised its inventive step requirement). The International Section of CEIPI held a forum at l'Académie de la bière in Strasbourg to discuss the matter. Some learned commentators considered that the exclusion was on ethical grounds, but it was pointed out that in that case, it would have covered strong liquor. Some considered beer drinking a private, non-commercial matter to be kept beyond the reach of patent law, but it was pointed out that brewing was big business. Some considered that it arose from the difficulty of searching the plethora of prior beers on the market, a difficulty compounded by the fact that, after a lengthy search, recalling the results was almost impossible. However, no search, however exhausting, is ever exhaustive. There was no clear answer.
As a practical matter, it was clear from the outset to patent attorneys that beer patents could be obtained, provided only that an attorney of the highest skill and experience5 was employed. Brewing equipment and processes were held patentable unless beer was the inevitable product, so that many patent applications of that era boast colourful illustrations, almost certainly created by the patent attorney, of brewing lemonade, wine, fruit juice, and so on in classic beer machinery.
Many of the early Board of Appeal test cases were brought by International Brewing Machines, and the endearingly erratic quality of these decisions may be explained by their practice of not attending the oral proceedings, but sending instead a crate of the beer concerned as evidence which the Boards of Appeal were obliged, under Article 113(1),6 to consume before reaching a decision.
The emphasis at first was on form rather than on substance. Thus, whilst claims to beer were unallowable, carefully crafted ‘use’ claims (eg ‘Use of X in the manufacture of a beverage for non-medicinal intoxication of a mammal’) slipped down smoothly. The English courts, amongst others, criticized such semantic sophism, famously holding7 that ‘beer is beer, whether claimed alone, in a glass, on the tongue, in the stomach, in the bloodstream, or in any other manner whatsoever’.
|
Stupefaction at the EPO |
|---|
|
TopThe home brew ethosThe development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
A key case concerned shandy: it turned on whether a mixture of beer and lemonade was ‘beer as such’. The point became of considerable economic importance as the beer makers marketed shandy in competition with newer alcoholic beverages (the so-called ‘Alcopops’). Clearly, if other ingredients predominated, the brew could not be considered ‘beer as such’—the question was, where to draw the line?
From the shandy case, the Boards of Appeal distilled the so-called ‘Stupefying Effect Test’.8 The theoretical basis rested in the effect-based approach developed at the EPO. Accordingly, ‘is it beer’ was the wrong question: the right approach was to ask ‘does it have the effect of beer’? Thus, sufficiently diluted by other non-beer ingredients as to lose its ‘stupefying power’, a beverage was no longer ‘beer as such’. This satisfied the powerful German brewing interests, by keeping beer patents out of their core business of strong beers (while, of course, allowing them to patent their glasses and brewing machinery).
Having derived the principle of Stupefaction from the shandy cases, the Boards began to apply it to other beverages such as cider and wine and even to recreational drugs.9 Their approach became the de facto law of the EPO and enabled the then-President, Mr Brandname, to announce proudly in the EPO 1994 Annual Report that ‘The EPO now grants brewing-related inventions—while not granting beer claims per se’. National courts were initially slow to take it up, but at the annual meeting of the European Patent Judges (a notoriously convivial affair) the Board of Appeal explained their reasoning with extensive reference to the beer samples provided in the case. After a rigorous testing of the evidence, national judges agreed that their reasoning was completely sound, and Stupefying Effect was adopted across the EU.
Finally, in the late 1990s, matters were brought to a head when the Boards were forced to confront a challenging International Brewing Machines test case: beer diluted with water. This was held, in a landmark judgment, not to be beer per se. The Board went a short hop further to comment, obiter, that a weak beer could be considered as a mixture of beer and water, and therefore that beer itself was patentable, provided it met the Stupefying Effect Test.
That was too much to swallow for many critics. Stupefying Effect came under the microscope. Many considered the test too subjective. ‘Itsh a term of art’ slurred a UK Appeal Court judge in one national beer case. Quite unlike the superficially similar ‘Technical Effect’ test, which is of course not in any sense a matter of subjective opinion, Stupefying Effect suffered two drawbacks: firstly, everyone has a different reaction to alcohol, and hence becomes stupefied by a different amount, and secondly, it is notoriously difficult for anyone (Board of Appeal members included) to detect their own level of intoxication. Thus, decisions reached by Appeal Boards accustomed to a wide variety of innovations in the beer art, after sampling the invention in question, while making perfect sense at the time to the Board members themselves, were sometimes greeted with incredulity or incomprehension by outsiders.
Nonetheless, President Brandname's industry-friendly stance, and the generous approach of the Boards of Appeal, led to a flood of beer-related patent filings. Most of them came from the USA (where relentless experimentation was essential due to the very poor taste of commercially available mass-market beers). However, there were some Europeans too; for example, SAPF GmbH (formerly a large fruit juice manufacturer, and a rising contender in the professional beer market) which began an aggressive patent filing policy.
At the height of this era, a misguided UK government reformed licensing laws to allow all-day drinking, triggering an upsurge in beer consumption. Investors now poured millions into the brewing sector, despite warnings from the Head of the Central Bank that this was mere ‘intoxicate exuberance’ and ‘froth—all head and no body’ and to protect their investment, they demanded the filing of patents for the most minor nuances of flavour or texture. Patent attorneys sensed business, and many boasted openly about their ability to ‘get anything granted’. As the Poet wisely said, ‘those whom the Gods would destroy, they first make drunk’—their boasts would later return to haunt them.
|
Consumerism and the Open Sauce movement |
|---|
|
TopThe home brew ethosThe development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
Meanwhile, however, forces of consumerism were brewing in Europe. Concern over food technology (for example, genetically modified foodstuffs: the so-called ‘Frankenfoods’) gave a powerful impetus to the Green parties all over Europe and in the European Parliament itself10 and to the Organic Farming industry. Food labelling requirements became more widespread, and the public was shocked to discover that food and drink had become more chemically complex than the average industrial polymer.
At the extreme end of the food labelling spectrum was the Open Sauce movement, started by a group of disgruntled sub-chefs, who demanded that all sauces and other liquid products be marked not only with a full list of ingredients but also with the recipe for their preparation. They led by example, and their re-creations of classic sauces (whilst derided by leading chefs as ‘derivative’11) attained some popularity amongst failed, and would-be, cooks seeking to impress on a budget at suburban dinner parties.12
Open Sauce principles naturally became the stuff of pub discussion. Many regular drinkers were dissatisfied with the bland and uniform taste of Micro-org's consumer-market beers and, after a few drinks, became vociferous in their demands for labelling of all beers with the recipe used.13 Even International Brewing Machines and Micro-org flirted with Open Sauce on a few of their more obscure specialist beers.
On campus, organic beer experiments became all the rage in chemistry and microbiology departments, and Open Sauce principles were enthusiastically adopted. Sharing recipes meant that those sufficiently sober to read the small print and replicate the process without error14 were able to develop new beers incrementally—although after a few pints these always seemed to taste remarkably like the latest flavour on offer from Micro-org, rather than being strikingly innovative. The rise of the internet also helped—students and fringe groups had become accustomed to downloading recipes for matters as disparate as recreational drugs and explosives, and were quick to turn the same talents to brewing.
However, the indecent haste of development, combined with the variety of pungent organic substances included in the ingredients, meant that insect infestations were frequent, so that the beer thus produced often contained bugs. Students, of course, will drink anything alcoholic provided it is free, but the high bug levels prevented the acceptance of these early Open Sauce beers in the mass consumer market.
|
The Free Beer movement |
|---|
|
TopThe home brew ethosThe development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
The development which finally took Open Sauce beers off-campus and all the way into the political arena was the alliance with Staleman's LNG project. The flagship beer was GUINNUX, a stout for the mass market, based on LNG but drinkable from commercially available glasses, which required no expensive cryogenic hardware, and was largely free from the risk of hypothermia. College and off-campus microbrewers took the revolutionary step of supplying beer free through bars run by enthusiastic acolytes. This combination of Open Sauce and Free Beer was a heady brew indeed.
Public gullibility had never been higher: this was, after all, the era of ‘free’ air travel, ‘free’ mobile phones, and fixed premium rate TV telephone quizzes. Free Beer exerted such a powerful hold over the mind of the intoxicated and the poor that the proposition could not fail. There was, it seemed, such a thing as a free (liquid) lunch after all.
However, as the chemistry lecturers who acted as the voice of the Free Beer industry were at pains to point out,15 ‘free’ was not, strictly speaking, a statement about price but one about attitude. It invoked the spirit of the home brewers of blessed memory (who were already venerated as part of a hazily golden past) and indicated generalized freedom from restraints—a concept which, given the dis-inhibiting effects of alcohol, was attractive to its target market.
In fact, first time visitors to ‘Free Beer’ bars were initially surprised by the range of charges they actually had to pay. They were expected to bring their own beer glass and, if the glass were unsuitable for the beer, they would be charged for a suitable glass, or for advice on how to resolve the problem. They had to download their own beer from the tap—a slow process in those days of narrow gauge pipes—or pay the staff to do so. For those concerned about persistent rumours concerning the lack of security in Free Beer bars, there was sometimes a security fee. Many bar staff charged for maintenance of the tables and chairs. A key issue was the bug problem. Free Beer bars typically charged a sieving fee for serving beer through a sieve to remove the larger bugs, and a callout charge each time they were asked to remove smaller bugs from a glass of beer. Finally, many consumers felt that the beer, when it arrived, did not quite taste as expected; it was as if it had been rushed to the bar in an unfinished condition. Bar staff were on hand, for a fee, to add any missing ingredients. Of course, it is only fair to say that commercial beers and bars often had the same problems, but they were normally resolved free, the consumer having bought the service in the price paid for the beer.
Some, therefore, suspected that the total cost of drinking Free Beer was higher than that of beer supplied by Micro-org and the big brewers, but the charging basis was sufficiently complex that few could reliably perform the calculations required to prove this after the drinking had commenced.
The Free Beer enthusiasts found powerful supporters within government. Most national and EU government institutions provided licensed canteens and restaurants, but these (like any other government institution) were perpetually under pressure to reduce their costs. These departments contained many who prided themselves on their brewing knowledge and they, like bureaucrats everywhere, had an interest in expanding their internal empires. Open Sauce Free Beer (with its combination of low procurement costs and high manpower requirements) met these conflicting demands.
|
The struggle to legislate in Europe |
|---|
|
TopThe home brew ethosThe development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
The Commission,16 located, as they were, in Brussels (a city with a long and proud tradition of beer drinking, and one of the few to boast a beer museum) were themselves amongst the heaviest consumers of beer per capita in the Europe. The legislators soon found they had a conflict of interest in passing brewing laws, as their executive branch had already sold itself to the Free Beer movement. Thus, there would be many a slip twixt the cup and the lip when the Intellectual Property Directorate of the Commission attempted to pass legislation which would have made the ‘Stupefying Effect Test’ statutory in the EU.
Widespread access to the internet meant that every drunk with a computer could now read patent laws, EPO decisions, and the ill-judged boasts of patent attorneys. The impact resembled that of the printing press in the birth of the Protestant revolt. Drinkers everywhere, unfamiliar with the Byzantine negotiations which had led to the ‘beer as such’ exclusion, assumed that the existence of beer patents threatened the Free Beer movement.
A moment's sober reflection would have laid this assumption to rest—it has, of course, long been a maxim of patent law that a Free Beer claim is unallowable. There had been no case where a small brewer had been sued, or even threatened, under a beer patent, in fact, quite the reverse: a successful small brewer had driven a Micro-org brew off the market for 6 months with a yeast compression patent of their own.
However, scare stories began to circulate in bars. The mathematically challenged feared that the price of free beer would triple. It was said that beer patents would stop the NHS offering blood donors the traditional pint of Guinness®, so that anaemia would kill millions. It was said that the big breweries would raid pubs and bars, as in the Prohibition at its height, and every drinker would face waking in jail. Patent attorneys acting for Big Beer were muzzled by accusations that they were paid in kind by their clients and were thereby too drunk to talk sense on the subject.17
Legislators and patent examiners became the target of an anti-patent email hate campaign. Protestors particularly impressed gullible politicians by claiming that they personally would be affected—superimposing photographs of them on ‘Wanted—for Patent Infringement’ posters cause some apparently to turn themselves in to the local police, who could do no more than offer them a cell in which to sober up. An almost Lutheran rebellion against the high priests and citadels of IP, fuelled by cheap alcohol and a legal literacy level that was laughable and lamentable by turns, threatened the defenestration of the glass-and-chrome EPO building.
EU political street fighting would be incomplete without a hint of xenophobia. The natural target, and the one most calculated to unite European politicians, was the USA. However, within the EU a ‘German Patent Family’ (picked apparently at random and linked only by nationality) were vilified in Free Beer bars on posters which were conveniently shaped to be pasted over a dartboard. ‘We demand the head of this arrogant official’, read the poster for one mild-mannered, teetotal senior Patent Office official. Many German patent attorneys who failed to be thus honoured were deeply disappointed.
Within the Commission, the protestors found a sympathetic ear at the Directorate General of Beer Procurement (‘DG BP’—known, it is said, in the Intellectual Property Directorate as ‘DG Ban Patents’). The Commission draft law, though supported by the democratically elected EU governments acting through the EU Council, was defeated at the European Parliament, where the chair of the Liquid Affairs Committee was shocked by the incoherently violent tone of the protests.18
More surprising, to an outsider, was the extraordinary intervention of Mikhail Retard, the head of the Cultural Affairs committee. Retard was a failed former Prime Minister, who fell, or was pushed, from that position after only 3 years in 1991; lost his seat in the national Chamber in 1993; led his party to their very worst ever defeat in the European Parliament Elections of 1994; and remained their leader for only a year. Despite the dashing of his own hopes of supreme office, however, he nobly continued to assist his party's candidates to defeat in successive national Presidential elections.19
Although the son of a scientist, his education followed the traditional elite administrative track, leaving his mind admirably uncluttered by technology or IP, let alone patents. However, he may have assumed that brewers' yeast cultures fell within his Cultural Affairs remit (there is, at any rate, no rational explanation for his involvement) and his background and demonstrated competence admirably suited him, in his own eyes, to the task. Further, his home nation was famous for winemakers (and wine drinkers) and only bit-part players in the international brewery business, enabling him to play gesture politics at the expense of other nations without significantly engaging his own national interests. Accordingly, he prepared and proposed a set of amendments that were, either ineptly or designedly, fashioned to eviscerate and invert the draft legislation.
These went further than banning beer patents and patents for any machine which could conceivably be used to brew beer. They contained the ‘drunkard's defence’—that any act commissioned or performed by a person demonstrably intoxicated could not as a matter of law infringe any patent. Further, since it was supposed that no sober person would wish to infringe a patent, any putative infringer was to be deemed drunk unless the contrary were proven. Even the invertebrate European Parliament (outside his own committee) found that unpalatable. Consensus proved impossible. The draft legislation, already swaying on its feet, now collapsed ignominiously in a corner, and none had the heart to reawaken it.
|
The morning after |
|---|
|
TopThe home brew ethosThe development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
Bizarrely, but with some success,20 the Free Beer movement now decided to reform, and then control, the European Patent system itself, calling conferences at which those they had lambasted were invited to speak (surprisingly, some accepted). Geopolitics came to their aid. Since agreement on a suitable President of the EPO had proved impossible due to fallout from a regrettable post-Imperial military venture in the Middle East, it was decided instead to select a grossly unsuitable one: Napoleon Bodypart.
An MEP from a political dynasty21 with no legal qualifications or past patent office experience, he was the perfect stalking horse—inexperienced, yet politically attuned to the chill prevailing winds from Brussels. However, at least he had no political skeletons in the cupboard.22 The independence of the EPO, theoretically a non-EU organization, was now over in practice, and transparency in policy making was to be replaced by political fixing and deal breaking. A national judge attempted to get him to refer the conflicting case law on beer patentability to the EPO Enlarged Board for resolution, but in a supremely Nelsonic moment, he held his closed eye to the judgment and declared ‘I see no contradiction’.
The rest, of course, is history. Without publicly announcing a policy shift, the European Anti-Patent Office (as it became shortly afterwards) and the European national Courts now gave an old law a new meaning. Stupefying Effect was consigned to the urinal of history, rendering thousands of expensively obtained beer patents invalid and condemning to poverty the unfortunate patent agents who had made a career from brewing-related inventions.23
Devoid of protection, innovation at International Brewing and Micro-org withered on the bine. Meanwhile, Open Sauce beer became increasingly homogenized, as more and more brewers adopted others' recipes rather than developing their own. Some Free Beer supporters were shocked to see Gwynn Tortoise, the author of GUINNUX, found a company to sell cans of GUINNUX at commercial prices and apply for slews of beer patents. The world had come full circle—domination by a single variety of bland, uniform beer was back. It went beyond Europe: GUINNUX was replicated, free of charge, throughout the developing world, killing off any domestic innovation there and leading to a general reduction of economic activity due to widespread drunken torpor. The Free Beer movement had conquered the virtual world, but left it with a hangover and a bitter taste in its mouth the morning after.
|
And back in the real world... |
|---|
|
TopThe home brew ethosThe development of the...Stupefaction at the EPOConsumerism and the Open...The Free Beer movementThe struggle to legislate...The morning afterAnd back in the... |
|---|
How did this storm in a virtual pint pot come to be? One should not assume that the virtual legislators, examiners, or judges made any of the key decisions under the influence of alcohol. One can only hope that they did so, rather than simply caring too little about innovation and caving in to vigorous though misguided lobbying. We can, at least, draw comfort from the fact that ours is the real world, and theirs is merely a humorous pastiche—our real-world equivalents of these colourful avatars of virtual Europe suffer from none of their drawbacks, and would never treat brewing (let alone important industries, like information technology) so shabbily.
If we shadows have offended,Think but this and all is mended:
That you have but slumbered here
While these visions did appear.24
If we offend, it is with our good will.That you should think, we come not to offend,
But with good will. To show our simple skill
That is the true beginning of our end.25
|
Footnotes |
|---|
* European Patent Attorney; Partner, R.G.C. Jenkins & Co., London. These are the author's personal views, not those of his firm.
1 In Intellectual Property Law journals, at any rate.
2 Accepted by most drinkers, though an artistically inclined minority—recognizable by wearing either black polo neck jerseys or white shirts with the top button done up and no tie—stayed loyal to the cider provided by Apple Inc.
3 The name is an amusingly recursive acronym: ‘LNG's Not Guinness® Extra Cool’.
4 Art 52 EPC ‘The following shall not be regarded as inventions ... beers. These provisions ... shall exclude patentability ... only to the extent to which a European patent application or European patent relates to suchsubject-matter ... as such.’
5 And, of course, cost. For the classic exposition of these views, see Patenting Beer under the European Patent Convention by Kenneth Beersford.
6 Art 113(1) EPC ‘The decisions of the European Patent Office must take into account the evidence submitted by the parties concerned’.
7 In G. Ale's Patent Application—alas, Mr Ale appeared as a litigant in person, and seemed for some reason unable to express himself clearly.
8 The name is derived from the effect of the brew on the skilled but unsuspecting drinker, not the effect of the Board of Appeal decisions on the skilled but unsuspecting reader.
9 Though, in the latter cases, we understand that samples were never requested and, if offered, would politely but firmly be refused by the Chairman of the Appeal Board.
10 On the basis that the public, as so often, were happy to indulge in gesture politics when electing members of a powerless, spineless, and supine gravy train.
11 As well as many less printable epithets.
12 It was said, however, that their handwriting was so awful, and their recipes so terse, that they were difficult to use, unless you employed the author to assist you in the cooking process—certainly, many of the leading lights in the movement made most of their income from such consultancy and assistance work.
13 And, indeed, in all their demands on any subject.
14 A rather smaller group than might have been hoped.
15 In a wide range of obscure- and little-read academic journals.
16 Who had by then taken control of European IP policy.
17 In fairness, there was enough truth in the charge that many held their tongues.
18 Fuelled, no doubt, by the fine local brews for which both Brussels and Strasbourg are so rightly famed.
19 They were said to be ‘hoist by their own Retard’.
20 And amidst mutterings that the alcoholics had taken over the brewery.
21 His father, the Emperor, being noted for his hauteur in office.
22 Other than those of the 351 foetuses scandalously discovered in 2005 at the hospital of which he had been in charge, and for which he was personally reprimanded—though not found guilty of actual criminality.
23 Not to mention their expensively educated offspring.
24 Puck, A Midsummer Night's Dream.
25 Peter Quince, A Midsummer Night's Dream.
CiteULike 
Connotea 
Del.icio.us What's this?
| ||||||||||||||||||||||||||||||||||||||||||||||||||