Ex Parte TohDownload PDFPatent Trial and Appeal BoardNov 9, 201713929138 (P.T.A.B. Nov. 9, 2017) Copy Citation United States Patent and Trademark Office UNITED STATES DEPARTMENT OF COMMERCE United States Patent and Trademark Office Address: COMMISSIONER FOR PATENTS P.O.Box 1450 Alexandria, Virginia 22313-1450 www.uspto.gov APPLICATION NO. FILING DATE FIRST NAMED INVENTOR ATTORNEY DOCKET NO. CONFIRMATION NO. 13/929,138 06/27/2013 Chin H. Toh 13-0559-US-NP 6323 63759 7590 11/14/2017 DTTKFW YFF EXAMINER YEE & ASSOCIATES, P.C. WYNNE, DAVID J P.O. BOX 802333 DALLAS, TX 75380 ART UNIT PAPER NUMBER 2121 NOTIFICATION DATE DELIVERY MODE 11/14/2017 ELECTRONIC Please find below and/or attached an Office communication concerning this application or proceeding. The time period for reply, if any, is set in the attached communication. Notice of the Office communication was sent electronically on above-indicated "Notification Date" to the following e-mail address(es): ptonotifs @yeeiplaw.com mgamez @ yeeiplaw. com patentadmin @ boeing. com PTOL-90A (Rev. 04/07) UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE PATENT TRIAL AND APPEAL BOARD Ex parte THE BOEING CORPORATION Appeal 2017-0050531,2 Application 13/929,138 Technology Center 2100 Before DENISE M. POTHIER, JASON J. CHUNG, and JASON M. REPKO, Administrative Patent Judges. POTHIER, Administrative Patent Judge. DECISION ON APPEAL STATEMENT OF THE CASE Appellant appeals under 35 U.S.C. § 134(a) from the Examiner’s rejection of claims 1—20. We have jurisdiction under 35 U.S.C. § 6(b). We affirm. 1 The record reflects the sole inventor is Chin H. Toh. 2 Throughout this opinion, we refer to (1) the Final Action (Final Act.) mailed March 10, 2016, (2) the Advisory Action (Adv. Act.) mailed June 15, 2016, (3) the Appeal Brief (App. Br.) filed August 4, 2016, (4) the Examiner’s Answer (Ans.) mailed December 1, 2016, and (5) the Reply Brief (Reply Br.) filed February 1, 2017. Appeal 2017-005053 Application 13/929,138 Invention Appellant’s invention “relates to a method and apparatus for managing a set of parameters for a tooling system in real-time using digital modeling and feedback control.” See Spec. 11. Such a tooling system may include a system for installing fastening elements, such as rivets, used to assemble aircraft components. Id. 2—6. The system ensures that the rivets formed by the tooling system meet a required specification. Id. 11 5-8. Claim 1 is reproduced below with emphasis: 1. A method for performing a riveting operation by a riveting system, the method comprising: modifying, iteratively by a computer system, a current set of parameter values for a set of parameters for the riveting system, until the current set of parameter values predict the riveting operation producing a riveted structure that meets a set of criteria, to form a final set of parameter values; performing the riveting operation with the riveting system using the final set of parameter values to produce the riveted structure; determining, by the computer system, whether the riveted structure of the riveting operation meets the set of criteria based on sensor data about the riveted structure of the riveting operation; and identifying, by the computer system, a new set of parameter values as the current set of parameter values to be evaluated in response to a determination that the riveted structure of the riveting operation does not meet the set of criteria. App. Br. 20 (Claims App’x). The Examiner relies on the following as evidence of unpatentability: Gajewski US 5,675,887 Oct. 14, 1997 Mauer US 2001/0027597 A1 Oct. 11, 2001 2 Appeal 2017-005053 Application 13/929,138 Annis Kulkami US 7,620,150 B1 US 7,933,679 B1 Nov. 17, 2009 Apr. 26, 2011 The Rejections Claims 1—4, 8—12, and 14—20 are rejected under 35 U.S.C. § 103 as unpatentable over Kulkami and Gajewski. Final Act. 5—15. Claims 5 and 13 are rejected under 35 U.S.C. § 103 as unpatentable over Kulkami, Gajewski, and Mauer. Id. at 16—19. Claims 6 and 73 are rejected under 35 U.S.C. § 103 as unpatentable over Kulkami, Gajewski, Mauer, and Annis. Id. at 19—24.4 OBVIOUSNESS REJECTION OVER KULKARNI AND GAJEWSKI Regarding independent claim l,5 the Examiner finds that Kulkami and Gajewski teaches all its limitations. Specifically, the Examiner finds Kulkami teaches the step of “determining, by the computer system, whether the riveted stmcture of the riveting operation meets the set of criteria based on sensor data about the riveted stmcture of the riveting operation,” with the exception of the rivet features and the data being “sensor data.” See Final Act. 6 (citing Kulkami 5:56—59, steps 327, 310). The Examiner turns to 3 An after-final amendment submitted May 10, 2016, and entered by the Advisory Action dated June 15, 2016, does not include a claim dependency for claim 7. Based on the previous amendment submitted November 19, 2015, we presume claim 7 depends from claim 1 for purposes of this opinion. 4 The Examiner withdraws the rejection of claim 9 under 35 U.S.C. § 112(b) or 12 as being indefinite. Ans. 2. 5 Claims 1—4, 8—12, and 14—20 are argued as a group. App. Br. 11—13. We select claim 1 as representative. See 37 C.F.R. § 41.37(c)(l)(iv). 3 Appeal 2017-005053 Application 13/929,138 Gajewski, in combination in Kulkami, to teach these missing features. Id. at 6—7 (citing Gajewski 1:11—27, 6:42—49, Abstract and Kulkami 1:12—18). Appellant argues Kulkami and Gajewski fail to teach the recited “determining” step. App. Br. 11—13. Specifically, Appellant asserts Kulkami’s validation and feedback process is not performed by a computer system but rather a machinist. Id. at 12 (citing Kulkami 5:56—59); Reply Br. 2—3. Additionally, Appellant contends Gajewski’s sensor data does not relate to the recited “riveted stmcture of the riveting operation” and does not meet “a set of criteria” based on a sensor data about the riveting operation’s riveted stmcture as recited. App. Br. 12—13 (citing Gajewski 6:42—49); Reply Br. 3^4. ISSUE Under § 103, has the Examiner erred in rejecting claim 1 by finding that Kulkami and Gajewski collectively would have taught or suggested “determining, by the computer system, whether the riveted stmcture of the riveting operation meets the set of criteria based on sensor data about the riveted stmcture of the riveting operation”? ANALYSIS Based on the record before us, we find no error in the Examiner’s rejection. Appellant asserts Kulkami’s mapped process that determines whether there are problematic issues with tool life or part quality (Kulkami 5:56—57) does not involve a computer system but rather a machinist. App. Br. 12; Reply Br. 2—3. We are not persuaded by Appellant’s assertion. 4 Appeal 2017-005053 Application 13/929,138 Kulkami discusses a “traditional approach” taken to select “machining process parameters: is a trial and error method based on machinist’s experience.” Kulkami 1:22—24. Kulkami explains “[t]he present method involves machining process optimization using finite element analysis, mechanistic modeling, and optional vibrational analysis to overcome the disadvantages of the traditional approach” and this method is “carried out via computer simulation instead of in a machine shop” to eliminate the need for time-consuming shop trials. Id. at 1:29—35. As such, Kulkami teaches and suggests to one skilled in the art that Kulkami’s discussion in column 5 related to “optimization” drilling operations uses a computer system for simulation. Granted, Kulkami also states the data generated using computer simulation is validated in the machine shop to evaluate the tools performance with the optimized parameters. Id. at 1:36—38, 5:53—56. Although admitting Kulkami “is silent as to how validation in the machine stop is performed” (Reply Br. 3), Appellant asserts that the validation “could only be performed by a machinist who has ‘experienced’ the issues” {id.). We are not persuaded. First, the rejection is based on obviousness—not anticipation—and thus, Kulkami does not have to disclose expressly or inherently using a computer system to determine whether a set of criteria based on sensor data has been met. Second, Appellant’s assertion that validation can only be performed by a machinist is based solely on Kulkami’s silence related to the validation process. But, an obviousness “analysis need not seek out precise teachings” of the claim, “for a court can take account of the inferences and creative steps that a person or ordinary skill in the art would have 5 Appeal 2017-005053 Application 13/929,138 employed.” KSRInt’l Co. v. Teleflex Inc., 550 U.S. 398, 418 (2007). Kulkami at least suggests to ordinarily skilled artisans, when accounting for their inferences and creative steps, automating the “validation process” in the machine shop by using a computer system. For example, one skilled in the art would have recognized a computer system assists in determining whether certain criteria or thresholds have been met based on sensor data, especially given that “feedback is provided [to the optimization process] for further analysis.” Kulkami 5:57—58, Fig. 3 (“Y” at box 327); see also Ans. 2 (stating Figure 2A “shows feedback being returned to a computer.”) Third, Gajewski, when combined with Kulkami, further teaches and suggests the “determining” step uses a computer system, as recited, because its technique uses controller 100 and processor 120 for deciding whether the calculated length is proper (see Gajewski 6:49—52, Abstract, Figs. 2—3). See also Ans. 2—3 and Adv. Act. 2 (noting Gajewski determines acceptability by a sensor and computer). Appellant next argues Gajewski fails to teach or suggest “sensor data about the riveted stmcture of the riveting operation” as recited in claim 1. In particular, Appellant asserts Gajewski does not predict a riveted stmcture that meets a criteria set based on current parameters for a riveting stmcture. App. Br. 13. Yet, the rejection relies on both Kulkami and Gajewski to teach this disputed limitation. Final Act. 6—7; see also Ans. 3. Appellant cannot show nonobviousness by attacking Gajewski individually. See In re Merck & Co., 800 F.2d 1091, 1097 (Fed. Cir. 1986). Moreover, Gajewski teaches measuring spent rivet mandrels and their lengths during riveting (e.g., a riveting operation) based on sensor data and determining compliance based on this sensed data. Gajewski 6:41—61, 6 Appeal 2017-005053 Application 13/929,138 Abstract; see also Ans. 3. Specifically, Gajewski teaches rivet sensor 72 (e.g., a laser detector) detects each spent mandrel 62 and each mandrel’s length for determining whether or not the rivet was properly crushed during installation. Id. at 6:41—49, Abstract. As such, Gajewski teaches or suggests determining whether a riveted structure (e.g., the crushed rivet) of a riveting operation (e.g., rivet crushing) meets a criteria (e.g., properly crushed or not) based on a sensor data (e.g., spent mandrel data sensed by rivet sensor 72/laser detector). See id. at 6:41—52; see also Adv. Act. 2. Appellant asserts Gajewski’s spent mandrel is not a rivet and thus Gajewski “is not directed to a set of criteria for a ‘riveted structure’.” Reply Br. 4. This argument is unavailing. Notably, claim 1 broadly recites “sensor data about the riveted structure of the riveting operation.” App. Br. 20, Claims App’x (emphasis added); see also Adv. Act. 2. Although the measured spent mandrel (e.g., 62) is not part of the rivet but rather is broken off when installing the rivet (Gajewski 4:6—16, cited in Reply Br. 4), the sensor data measured (e.g., mandrel’s length) is “about the riveted structure” because the data is used to determine whether the rivet was properly crushed, as previously discussed, as well as to determine whether rivet placement has occurred (Gajewski 4:23—25, 6:44^49). See Adv. Act. 2. This broad interpretation of “sensor data about the riveted structure” is also consistent with the Specification, which discusses varying sensor data used identify rivet properties (see Spec. 142), and is therefore reasonable. Because Gajewski’s data measures whether the rivet was crushed properly and rivet placement has occurred, we disagree that Gajewski is “silent” regarding a riveting operation’s rivet structure as asserted. Reply Br. 3^4. 7 Appeal 2017-005053 Application 13/929,138 For the foregoing reasons, Appellant has not persuaded us of error in the rejection of independent claim 1 and claims 2-4, 8—12, and 14—20, which are not argued separately (App. Br. 13). OBVIOUSNESS REJECTION OVER KULKARNI, GAJEWSKI, AND MAUER Regarding claims 5 and 13, the Examiner finds that Kulkami and Gajewski teaches many of its limitations and turns to Mauer to teach the recited “the set of criteria includes specifications about a set of properties of the riveted structure” limitations. Final Act. 16—17 (citing Mauer || 55, 60, 65, Fig. 13e). Appellant argues that Mauer measures only one end shape of a rivet and “interface properties” and thus does not disclose the recited property that includes “a second end shape of the rivet.” App. Br. 15. We are not persuaded. As explained, the Examiner maps Mauer’s external head position to the recited “first end shape of a rivet,” Mauer’s expansion of the diverging distal end to the recited “second end shape of the rivet,” and Mauer’s length data to the recited “interface properties.” Ans. 3 (citing Mauer 160). The Examiner’s position is reasonable. Specifically, Mauer discusses an acceptable riveted joint has (1) a rivet’s external head surface positioned flush and co-planar with an exterior surface (e.g., a rivet’s first end shape) and (2) a rivet’s distal end sufficiently expanded to engage a workpiece without piercing the workpiece’s die-side. Mauer | 55, Fig. 13e; see also Final Act. 17. Mauer further addresses detecting tolerances of a plate/workpiece’s thickness (e.g., acceptable for a specific joint) as well as a rivet’s length (e.g., acceptable size), which are akin to the recited interface 8 Appeal 2017-005053 Application 13/929,138 properties. See Mauer | 60; see also Final Act. 17 (discussing Mauer | 60). We disagree that the latter detection, especially the rivet’s length, is “silent in regard to a ‘riveted structure.’” See Reply Br. 5—6. In the Reply Brief, Appellant presents new arguments, including (1) Mauer does not teach the “interface properties”6 and (2) “after a ‘riveting operation’ in Appellant's claim, plates are fastened together by a rivet which is a wholly different structure than the pieces examined by Mauer.” Reply Br. 5. Because these arguments were not raised in the Appeal Brief and are not responsive an argument raised in the Examiner’s Answer, these arguments are not considered. 37 C.F.R. § 41.41(b)(2). For the foregoing reasons, Appellant has not persuaded us of error in the rejection of claims 5 and 13. OBVIOUSNESS REJECTION OVER KULKARNI, GAJEWSKI, MAUER, AND ANNIS Claim 6 The Examiner finds that Kulkami, Gajewski, and Mauer teach generating the sensor data about a set of properties of the riveted structure of the riveting operation using a laser sensor device, wherein the set of properties includes at least one of a first end shape of a rivet in the riveted structure produced by the riveting operation, and a second end shape of the rivet in the riveted structure produced by the riveting operation as recited in claim 6. Final Act. 19—22. Specifically, the Examiner turns to (1) Gajewski in combination with Kulkami to teach generating sensor data 6 Appellant takes the opposite position in the Appeal Brief. See App. Br. 15 (indicating Mauer teaches the “interface properties” limitation). 9 Appeal 2017-005053 Application 13/929,138 about riveted structure properties using a laser sensor device (id. at 19—20 (citing Gajewski 6:42-49)) and (2) Mauer in combination with Kulkami and Gajewski to teach the particularly recited sensor data has properties that include rivet end shapes produced during the riveted operation (id. at 21—22 (citing Mauer || 55, 60, 65, Fig. 13e)). Appellant argues Gajewski’s laser detector 72 detects the presence of spent mandrels and each mandrel’s length but the detected data generated by the sensor is not “about the head shapes of rivets installed into a riveted structure.” App. Br. 17. Appellant further contends Gajewski’s laser detector is not capable of generating data about the rivet’s head shape. Id. at 16—17; Reply Br. 6. Appellant asserts Mauer measures rivet size and joint quality based on force and is not directly measured using a laser sensor. App. Br. 17 (citing Mauer | 58 and discussing the sensors are force sensors). Additionally, Appellant contends the Examiner has not explained how Gajewski’s laser sensor would have been modified to measure Mauer’s joint quality characteristics and such a modification would require more than a simple substitution of parts. Id. Other than the reasons presented in the disclosure, Appellant argues the Examiner has not provided any rational basis to combine the references and arrive at the claimed invention that uses a laser device to measure rivet end shapes. Id. ISSUE Under § 103, has the Examiner erred in rejecting claim 6 by finding that Kulkami, Gajewski, and Mauer collectively would have taught or suggested “generating the sensor data about a set of properties of the riveted stmcture of the riveting operation using a laser sensor device, wherein the 10 Appeal 2017-005053 Application 13/929,138 set of properties includes at least one of a first end shape of a rivet in the riveted structure produced by the riveting operation, and a second end shape of the rivet in the riveted structure produced by the riveting operation”? ANALYSIS The crux of this issue hinges on whether Gajewski’s laser detector 72 has the ability to be used to generate the recited “sensor data” having properties that include a rivet’s first end shape and a rivet’s second end shape, produced by a riveting operation as recited in claim 6. Appellant argues the Examiner’s assertion that Gajewski’s laser detector is capable of such measurements “is based on conjecture and not evidence.” Reply Br. 6. Given the record, we determine Gajewski’s sensor when combined with Kulkami and Mauer teaches such a capability. Notably, claim 6 “does not require a laser to specifically measure the shape, but rather to simply use a laser to generate data about a shape.” Ans. 3^4. As such, the cited art (e.g., Gajewski) does not need to teach a laser sensor device measures the recited rivet end shapes. Rather, the cited art needs at least to suggest using a laser sensor to generate sensor data about a first end shape of a rivet produced by a riveting operation and a second end shape of the rivet produced by the riveting operation as recited. See id. Turning to the disclosure, the Specification states various sensor systems can be used to generate the sensor data, including rivet end shapes. See Spec. 42, 54—55, Fig. 5. These sensor systems generate sensor data, including laser imaging data or other data types. See id. The disclosure provides no more details related to how rivet end shape data is obtained using the sensor (e.g., the sensor’s circuity or how the sensor is 11 Appeal 2017-005053 Application 13/929,138 programmed), such that the Specification distinguishes a laser sensor used to generate sensor data about rivet end shapes from other types of laser sensors. See id. As such, the disclosure describes generic laser sensors have the ability to be used to generate the disclosed sensor data, including data about the rivet end-shape properties. Similarly, Gajewski teaches detector 72 can be “of any type including proximity, infrared, optical, etc.” and describes a particular sensor as “a laser detector.” Gajewski 4:29—30, 6:42—43. Thus, Gajewski discloses at least one sensor type (e.g., laser) that corresponds to the Specification’s sensors, which, as explained above, have the ability to generate rivet end shape data. Compare id. with Spec. 42. Additionally, the Examiner determines “Gajewski’s laser is capable of detecting a position of a mandrel, and thus is capable of detecting data about a shape of an end of a rivet.” Ans. 6; Adv. Act. 2. For example, Gajewski’s laser detector 72 detects the presence of each spent mandrel 62 at a particular laser beam position. See Gajewski 4:22-31, 6:42-46. The Examiner further states “Gajewski's laser certainly generates data about the properties of a rivet (using a laser to detect a spent mandrel) as it determines whether or not a rivet was crushed properly.” Ans. 6; Adv. Act. 2. Specifically, Gajewski teaches laser detector 72 assists in the calculating the spent mandrel’s length and in determining whether or not the rivet was properly crushed. Gajewski 6:44-49, 59—61. Gajewski states a mandrel’s length is calculated based on a vacuum pressure sensor and the laser signal (e.g., its laser interruption time). Id. at 6:49—61. As such, the sensed data from Gajewski’s laser detector is used to determine a rivet’s length. See id. Although Gajewski does not discuss explicitly detecting a 12 Appeal 2017-005053 Application 13/929,138 shape (see Ans. 3) and the detected spent mandrel’s length disclosed in Gajewski is not a rivet’s end shape as argued (Reply Br. 6), the above teachings suggests to one skilled in the art that Gajewski’s laser detector has the ability to generate sensor data about a rivet’s first end shape and second end shape as recited in claim 6. Moreover, we fail to see a structural or programmed distinction between the disclosed sensors in the Specification and Gajewski’s laser sensor. Regarding the additional assertion that the Examiner has not provided a rational basis to combine Gajewski with Mauer so as to arrive at the claimed invention (App. Br. 17), we are not persuaded. Above, when discussing claim 5, we explained Mauer teaches examining a rivet’s end shapes in order to determine acceptable riveted joints. We refer above for more details. Also, as discussed above, Gajewski’s laser detector has the ability to be used to generate the recited rivet end shapes. Thus, one skilled in the art would have recognized that using a laser sensor, like Gajewski’s laser detector, was one of several, known techniques for generating the recited rivet end-shape, sensor data in claim 6. See Final Act. 20; see also Ans. 3. That is, a laser sensor device is one of a finite number of predictable solutions known to those artisans of ordinarily skill for generating claim 6’s sensor data and, given Gajewski’s teachings, one skilled in the art would have had good reason to try a laser sensor to obtain the recited sensor data in claim 6. See KSR Inti Co. v. Teleflex Inc., 550 U.S. 398, 421 (2007). Moreover, Gajewski teaches one skilled in the art was concerned with whether the rivets installed during a riveting operation are crushed properly. See Final Act 20 (citing Gajewski 6:44—49); see also Ans. 3. Mauer teaches other properties measured (e.g., rivet end shapes) to assist in determining 13 Appeal 2017-005053 Application 13/929,138 whether the rivet joint is acceptable and properly installed. See Final Act 21—22 (citing Mauer || 55, 60, 65, Fig. 13e). As such, Mauer suggests other useful properties known by an ordinarily skilled artisan to obtain for determining whether a rivet has been installed properly during a riveting operation. See id. (discussing Mauer’s metrics as important and good quality measures for proper rivet installation); see also Ans. 3. One skilled in the art would have recognized combining these teachings in order to generate various, useful sensor data about rivets (e.g., end shapes) and to determine whether the rivets have been properly installed. See Final Act 21—22. Such an addition as taught by Mauer would have also improved the combined Kulkami/Gajewski process of determining whether the rivet has been properly crushed. Contrary to Appellant’s assertion (App. Br. 17), we thus conclude the Examiner has provided at least one reason having a rational underpinning to combine Mauer with Kulkami and Gajewski and to arrive at the “generating the sensor data about a set of properties of the riveted structure” step as recited in claim 6. Moreover, as discussed above, the rejection does not propose to modify Gajewski’s laser sensor as argued {id.) but rather to use Gajewski’s laser detector to generate the recited sensor data. See Final Act. 21—22; see also Ans. 3. For the foregoing reasons, Appellant has not persuaded us of error in the rejection of claim 6. Claim 7 Regarding claim 7, the Examiner finds that Kulkami, Gajewski, Annis, and Mauer teach many of its limitations, including “generating the sensor data . . . using a backscatter x-ray sensor device.” Final Act. 21—24. 14 Appeal 2017-005053 Application 13/929,138 The rejection states one skilled in the art would have combined Annis’s teaching to use a backscatter x-ray device with Kulkami in order to allow for 3-D imaging and to assist in identifying in riveting process problems. Id. at 23 (citing Annis 2:26—32, 36-49). The rejection further states one skilled in the art would have combined Mauer’s teaching to detect interface properties between a rivet and a set of plates with Kulkami in order to obtain good measures of the end shapes and interface properties that detect whether the rivet is properly installed, including whether the rivet’s length is out of tolerance. Id. at 24 (citing Mauer || 55, 60, 65, Fig. 13e). Appellant argues that the rejection for claim 7 has no rationale for combining the references and contains an unconnected statement with disembodied benefit. App. Br. 18—19. In particular, Appellant argues there is no explanation why one would have been led to modify Kulkami to include Annis’s backscatter x-ray device absent impermissible hindsight. Id. We are not persuaded. As stated above, the Examiner states using a backscatter x-ray device as taught by Annis would assist in identifying problems in riveting operations by allowing for 3-D imaging. See Final Act. 23 (citing Annis 2:26—32, 36-49). The Examiner thus articulates a reason with some rational underpinning to combine the references’ teachings and to justify the Examiner’s obviousness conclusion. See id. Moreover, the cited passages in Annis also suggest to one skilled in the art that an x-ray backscatter device assists in rapid inspection—another desired result. See Annis 2:28—30, cited and discussed in Ans. 4. In the Reply Brief, Appellant argues Annis is silent regarding the recited “interface properties of an interference fit.” Reply Br. 7. This argument is inconsistent with the rejection as presented, which relies on 15 Appeal 2017-005053 Application 13/929,138 Mauer in combination with Kulkami and Annis to teach this recited feature. See Final Act. 22—24. For the foregoing reasons, Appellant has not persuaded us of error in the rejection of claim 7. DECISION We affirm the Examiner’s rejection of claims 1—20 under § 103. No time period for taking any subsequent action in connection with this appeal may be extended under 37 C.F.R. § 1.136(a)(l)(iv). AFFIRMED 16 Copy with citationCopy as parenthetical citation