Emerging AI Related IP Challenges
Author: LawSphereX
Category: Technology, Cyber & Privacy
Published:
Updated:
EMERGING AI RELATED IP
CHALLENGES
Fathima Sana. K, LL.M. JSS Law College, Mysuru
ABSTRACT
The simulation of human intelligence processes by computer systems is known as artificial intelligence (AI). Self-correction, reasoning, and learning are some of these processes. AI has been used to a number of industries, including finance, healthcare, transportation, and education. These industries could undergo a revolution thanks to technology, which enhances decisionmaking, precision, and efficiency. Concerns exist, meanwhile, regarding how AI may affect jobs, privacy, and security. This essay starts by summarising the various ways artificial intelligence (AI) has already impacted our legal system and the benefits that have followed. It also discusses the ongoing discussion on whether artificial intelligence (AI) can take the role of lawyers as well as other recent innovations like ChatGPT, DoNotPay, etc.
Even though artificial intelligence (AI) has many potential benefits, using it raises ethical concerns that need to be addressed in the areas of copyright and patency. This essay primarily addresses these intellectual property rights, together with associated Indian legislation and pertinent case law, copyright, and patent concerns. The dispute on the role of morality in legal interpretation has dominated jurisprudence, and with its help, we may be able to define and restrict the use of computers in our legal system Once considered an impossible dream a few decades ago, artificial intelligence has become one of the 21st century's most revolutionary technologies. The foundation of artificial intelligence is creativity and invention, which is being used to advance every industry under the sun. Intellectual property rights are not an exception to this rule.
Artificial intelligence (AI) will impact the intellectual property rights (IPR) sector in two ways: on the one hand, it can undoubtedly bring significant benefits to areas like patent innovation, efficient invention sorting, and providing insights into existing patents similar to new ideas; on the other hand, it also poses a potential risk to the fundamental components of IP rights, namely creativity and innovation. AI and innovation have a complex and nuanced relationship since AI has the potential to both strengthen and undermine the core ideas of intellectual property. Keywords: copyright, patents, law, morality, artificial intelligence (AI), intellectual property rights (IPR)
Introduction
Artificial intelligence (AI) is a rapidly becoming reality in today's society, not only a science fiction idea shown in motion pictures. People are used to the concept that computers will play a big part in the workforce after all these years. But with the advent of artificial intelligence (AI), current technological developments have brought about a revolutionary shift. When he led the first scholarly symposium on the topic in 1956, John McCarthy coined the phrase. “Making a machine behave in ways that would be called intelligent if a human were behaving” is how he specifically defined artificial intelligence. Natural language processing, BOTs, neural circuits, deep learning, machine learning, and cognitive computing are all included2.
Simply put, the computer that we use to store files, process massive amounts of data, do mathematical calculations, and conduct statistical analyses will have a mind of its own and be able to automatically learn from the behaviours that humans have taught it in the past, enabling it to carry out its tasks more quickly and intelligently. Reasoning, information, planning, learning, communication, perception, and object manipulation and movement are all necessary for artificial intelligence to work. With the quality of the data being processed, AI disruption is currently in its early stage, with new potential boundaries being created every day Artificial intelligence is developing swiftly. In a short amount of time, we've gone from quick and easy searches with a few keywords to employing AI for language processing in Alexa, Siri, and even self-driving cars.
It's astounding to see how many individuals—nearly all of us—use artificial intelligence nowadays. AI is, at its core, the study of how to give computers the ability to "learn reason, perceive, infer, communicate, and make decisions like humans do. " The first goal is machine learning, when a computer is trained to become a decision-making machine with minimal programming. Instead of needing us to manually establish the rules, machine learning techniques allow the computer to automatically generate a set of rules for how it should interpret a piece of facts. 1. Artificial intelligence (AI) is being quickly adopted by all of the main economic sectors. AI has completely changed every profession, including but not limited to those in the media, the arts, finance, medicine, and law.
Numerous of these applications will result in the emergence of new legal difficulties and change the areas of specialisation and business practices for attorneys. All services, barring those reliant on expertise and discretion, are vulnerable to technological substitution. "Over 100,000 jobs in the legal sector have a big chance of being automated in the next twenty years," according to the company. Origin The first functional artificial intelligence (AI) programmes were created in the 1950s at the University of Manchester on the Ferranti Mark I computer. 6- The first artificial intelligence programme to find new proofs and prove mathematical theorems was developed in 1955 by Allen Newell and Herbert A. Simon. 7. Subsequently, engineers achieved noteworthy progress in artificial intelligence, which prompted heightened attention from both the government and the corporate sector.
The government realised artificial intelligence (AI) has potential in areas including high volume data processing, translation, and language transcription 8. The benefits of artificial intelligence (AI) in various fields were clear in terms of productivity, adaptability, fatigue resistance, and continuous operation. As a result, businesses and manufacturers started deploying AI-assisted robots in their workforce, especially in manufacturing and production departments. Businesses saw an increase in profitability as a result of this diversification of their technology investments. The idea of integrating AI into all industries evolved as a result of the success seen in these sectors, with the goal of bringing efficiency and ease to a variety of sectors. Tech behemoths like Microsoft and Google led the charge on this project.
But as AI became more involved, questions and critiques started to arise. One well-known drawback was the loss of human jobs, but other concerns also started to surface, such as arbitration challenges. There are societal ramifications to take into account as AI permeates more and more aspects of daily life. Even if there are clear advantages of AI, such higher output and efficiency, there may also be drawbacks that should be considered. One of these worries is how AI would affect human employment, since it could result in job losses. In an AI-driven society, arbitration-related concerns including fairness and decision-making procedures also need to be carefully considered.
In summary, although artificial intelligence (AI) has yielded notable breakthroughs and advantages, a thorough assessment of its societal implications and resolution of any possible drawbacks are imperative to guarantee a fair and impartial incorporation of AI technology. AI'S APPLICATION IN LEGAL SERVICES i. Technology Review with Assistance (TAR) This was the first and most fundamental use of AI in the legal sector, organising, analysing, and searching extraordinarily large and diverse data sets for record-intensive investigations or e-discovery. Due diligence, e-discovery, contract analysis, document review, and legal research are all included in this broad category of technology assisted review.
• Legal Examination Legal research software powered by AI, like electronic search software, allows experts to quickly scan and search through enormous databases of rules, legislation, jurisdictions, case law, etc. Legal research software helps lawyers obtain information and improve their understanding of case law. Efficient and comprehensive research saves time and money for both attorneys and their clients. • Discovery via E-Discovery It describes the practice of looking through electronic data to locate non-privileged information relevant to a claim or lawsuit. With the aid of e-discovery software, attorneys can scan documents utilising search terms or certain criteria, such as dates or geolocation. As a result, lawyers receive responses almost instantly—much faster than scanning paper copies.
• Vigilance It describes the process of looking through electronic data to locate non-privileged information relevant to a claim or lawsuit. Legal practitioners are obligated to verify the facts on behalf of their clients. Based on this information, they advise their clients on what steps to take or how to proceed with the case. In order to provide customers with the best course of action, AI thoroughly reviews the facts and data and evaluates prior decisions taken in comparable situations.
A system known as RAVN was created in the UK to aid with due diligence for real estate transactions, and it was first formally introduced in 2015 by the London law firm Berwin Leighton Paisner. This technology compares property information with official public records to ensure accuracy. The attorney in charge of implementation for the legal company asserts, "Once the programmer has been trained to identify and work with specific variables, it can complete two weeks' worth of work in about two seconds, making it over 12 million times quicker than an associate doing the same task manually. ” • Composing/Drafting These days, a lot of companies create standard and necessary legal contracts using AI-based technologies. These basic templates are created with the help of AI software and may then be modified to satisfy the requirements and wants of customers.
'LegalMation' now uses AI to automate the generation of various litigation-related documents, such as discovery requests and pleadings. Specifio's AI-based software uses a set of claims submitted by the user to automatically create a first-draft patent application while a patent is being prosecuted. CLOEM S. U. S. A. provides many input claim versions to help patent drafters precisely define the scope of their invention. the 2019 release of Google BERT, a notable development in one of Google's progressively rarer modifiable products—its review and research search engine. In addition to searching for certain terms within a query, the search engine can now understand word context thanks to BERT. Compared to traditional manual research assistance, our current AI research tools are better since they enable us to create searches based on concepts rather than just words.
Since legal research and document review duties require a thorough comprehension of the pertinent factual matrix and do not follow a simple question-and-answer structure, only a limited percentage of these jobs can currently be automated ii. Legal Forecasting and Analytics Legal analytics uses big data, algorithms, and AI to find patterns in massive data sets and forecast future events. Artificial intelligence software evaluates and flags papers that provide a significant risk or threat. They identify any hazards or issues with the contract and adjust the pertinent provisions according their clients' wishes. "Should I Settle the Case? " or "If he goes to trial, what are the chances of him winning? " are the first questions a client usually asks a lawyer. The lawyer can get help from artificial intelligence technology in answering these kinds of issues.
As an instance, Lex Machina, now a LexisNexis company use legal analytics to forecast trends and outcomes in intellectual property litigation and is now extending its usage to other types of complicated litigation. iii. Legal Bots :-Legal chatbots are automated programmes that may instruct and advise users on legal matters via a chat interface. Chatbots can help users identify pertinent legal information, offer legal counsel, and respond to frequently asked legal queries. A legal chatbot could be used, for example, to help users decide whether they have a valid legal claim and to advise them on the steps they should take to pursue it. Thanks to chatbots, a wider range of customers—including those who would not be able to afford traditional legal services—may gain simpler access to legal information and services.
10 For example, the DoNotPay online chatbot was developed by a Stanford law graduate. To date, it has helped over 160,000 people pay parking tickets, and it is currently being expanded to help immigrants with their legal concerns. iv. Court Judgement Creating "AI judges" is an additional means of determining judicial decisions. Algorithms are already helping courts in some countries decide on bail and other highly technical situations, with the exception of those involving intangibles like the moral principles of "good faith" and "mercy" in court decisions. 12 One instance of this is the Chinese Supreme People's Court, which created the AI-based programme FaXin to help judges locate precedents. Implications • Enhanced Productivity AI is becoming more and more important in the legal industry.
Major language model-based systems like GPT-3 and GPT-4 have recently been released, and since then, technology that is often accessible, is now capable of performing intricate writing and research tasks at a degree of competence that formerly required highly qualified people. Successful application of the cutting-edge AI technology will enable legal firms to offer services more effectively, at lower costs, and with a higher chance of favourable litigation results. It not only speeds up a lawyer's most tedious and time-consuming activities, but it also increases overall productivity in less time, which, when implemented effectively, might result in significant financial gains for legal businesses. • Enhanced Legal Procedure By leveraging online platforms and resources, attorneys can reach a wider range of customers and provide legal services to marginalised communities.
For example, online dispute resolution can help make legal services more affordable and accessible. It can facilitate quick trials for minor and petty offences. • More Potent Legal Techniques With the aid of these research and analytical tools, solicitors can better prepare themselves by examining prior judicial pronouncement trends and developing cleverer and more effective ways to assist their clients. COULD AI SUBTLE/REPLACE LAWYERS?
The alarming headlines and forecasts that artificial intelligence (AI) might replace lawyers— "The rise of the robot lawyers"—alarmed a number of attorneys who were already unsure about the future of their profession. The phrase "Here Come the Robot Lawyers" and like. The recent reports that a robot lawyer was winning a case in the US legal system were shocking. The article states that throughout a legal case, a defendant will receive advice from an artificial intelligence (AI) created by DoNotPay. According to reports, this is the first time an AI has ever represented a party in court. In 2015, Stanford University computer scientist Joshua Browder founded DoNotPay in California. His goal is to completely replace solicitors with his app so that defendants can save money. The AI will watch court hearings on a smartphone and instruct the defendant to talk through an earphone.
Still, can artificial intelligence completely replace the human mind and its processes? Taking into consideration the advantages that come with AI's acceptance in the legal industry, we may argue that it presents more of an opportunity than a threat to those who practise law. As a result, rather than becoming a revolution, the application of AI in law will evolve. Even while artificial intelligence (AI) is useful for research, document review, and analysis, it's vital to remember that most of these technologies lack independence and are therefore complex. CURRENT AI AND LAW TRENDS These days, a lot of law firms use AI software for research and other necessary connected tasks. The emergence of numerous effective tools that may be integrated into legal services has resulted in the growth of the legal tech startup system.
Among these are a few of these: • ChatGPT OpenAI's ChatGPT is a sophisticated language model with useful uses across a range of industries, including the legal services sector. Legal experts have benefited greatly from ChatGPT's extensive knowledge base and natural language processing capabilities. Contracts, agreements, and case laws can all be effectively analysed and summarised by it, saving attorneys' time and streamlining their research procedures. In addition to producing draft documents and answers to legal questions, ChatGPT may also offer preliminary analysis and suggestions. But one cannot rely on it to the fullest extent. A BBC article states that a lawyer in New York was recently taken to court after one of his firm's members utilised ChatGPT for legal research.
In a recent instance, the lawyer and his firm referenced a number of misleading and inaccurate court cases, which the court found to be incorrect. • Associate Counsel The first AI legal assistant, CoCounsel, was produced by Casetext and is powered by technology from OpenAI, the same firm that made ChatGPT. It is an additional research tool that uses straightforward instructions to assist with legal research. The assistant can automate a lot of tiresome legal chores, like document inspection, deposition preparation, and document summarization. • AI Harvey Harvey, one of the generative AI systems, makes use of OpenAI's most recent LLMs, which have been customised for legal purposes. 3,500 solicitors across 43 legal offices have access to it. Harvey functions similarly to CoCounsel by automating relevant legal tasks.
In terms of data privacy, Harvey strictly complies with its clients' compliance needs by hiding user information and erasing data after a set period of time. It is always possible for users to request that their data be deleted. These are only a handful of the extremely rare cases that have lately been accepted by the global legal community. But the list is limitless, and more of these startups will probably appear soon. AI IN BHARATH In India, artificial intelligence is being used to a wide range of fields, including healthcare, agriculture, banking, and education. AI is being applied to healthcare to improve patient outcomes, diagnose diseases more accurately, and provide individualised treatment strategies. AI is being applied to agriculture to increase food security, minimise waste, and maximise agricultural yields.
Artificial intelligence (AI) is being utilised in finance to automate customer support, identify fraud, and customise financial advise. Artificial Intelligence is being utilised in education to create tailored learning programmes, raise student interest, and improve teacher preparation. These are only a handful of the numerous ways artificial intelligence is being applied to improve Indian society The Ministry of Electronics and Information Technology (MeitY) envisions the National project on AI (NPAI) as an umbrella project for utilising transformative technologies to promote inclusiveness, innovation, and adoption for social benefit. As a result, INDIAai, The National AI Portal of India, is ready to take on the crucial function of serving as The National Programme on AI's content repository.
The public and private sectors in India have developed AI-powered solutions in recent years that have improved the provision of security and health services, impacting millions of lives. Among them are: The MeitY MyGov Corona Helpdesk. Using Haptik and WhatsApp, the MyGov team created the Corona chatbot in six days to provide real information and advise on COVID-19 and counteract the widespread spread of incorrect information.
The Tamil Nadu State Government's "e-Paarvai." To address the scarcity of ophthalmologists, the Tamil Nadu eGovernance Agency (TNeGA) developed the ingenious AI-powered smartphone application E-Paarvai, which can identify whether a person has cataracts in their eyes. The Tamil Nadu State Government's "Uzhavan." An app called "Uzhavan" helps farmers spot bug infestations in their crops and provides prevention measures. A farmer can capture a picture of a crop affected by a pest using even a low-cost smartphone camera and submit it to the Uzhavan app. After the picture is submitted, the integrated intelligence system analyses and recognises the pest, then texts the farmer's phone number with the required Tamil remedies. Similarly, in order to capitalise on the AI revolution in the upcoming years, the Ministry of Electronics and IT developed the following initiatives:
1. India AI, the official platform for AI
2. The government school kids' skill-building YUVAi programme
3. New Law on the Protection of Digital Personal Data
India intentionally prioritised empowerment and inclusivity by developing a plan called "AI for All. " The state minister for electronics and information technology, Rajeev Chandrasekhar, announced that the bill protecting digital personal data will soon be submitted in parliament and that AI will be regulated in India. Intelligent Property Rights (IPR) AND AI In recent years, artificial intelligence (AI) has grown in importance as a field of study in technology. It also has a major effect in the area of intellectual property rights (IPR). The fact that AI is capable of producing original works that can qualify for copyright protection presents one of its hurdles. Sometimes, it's unclear who should have copyright ownership—the AI system or the human developer. This question lacks a definitive answer, thus it will probably generate a lot of discussion in the future.
The domain of patents is another area where AI affects IPR. AI has the potential to both innovate and enhance current inventions. Nevertheless, there are concerns regarding the patentability of inventions produced by AI. This is due to the fact that it's not always obvious who should be credited with creating an invention produced by AI. AI can also be used to locate and evaluate patents that are already in existence. Large amounts of patent data may be searched and analysed with the use of AI techniques, which can be helpful in locating suspected patent infringement as well as other problems. In general, the area where AI and IPR converge is complicated and constantly changing. It is expected that new legal and regulatory frameworks will be created as AI technology develops to handle the potential and problems it presents.
AI-RELATED IPR ISSUES (COPYRIGHT AND PATENT) One of the main IPR issues in regard to AI is patentability. To be granted a patent, an invention needs to be helpful, distinct, and non-obvious. Some have questioned whether AI-related discoveries can be patentable because they can be difficult to classify and sophisticated. Another IPR issue pertaining to AI is copyright protection for works generated by AI. Original and creative works are often protected by copyright. However, when an AI system produces a work entirely, it may be difficult to determine who should retain the copyright. For example, if an AI system creates an artwork, who should own the copyright? Who created the system— the system itself, the instructor, or the programmer who created it?
19 There has been some discussion and uncertainty over copyright protection for works produced by AI because there isn't a clear legal structure in place to handle these matters. Artificial Intelligence (AI) has particular complications that call for a new approach from the current regulatory framework. Business procedures, mathematical formulas, and computer programmes are not regarded as patentable inventions under the current Patents Act of 1970. Moreover, including AI under the Act's purview is hampered by the definitions of "patentee" and "person interested" in Sections 2(p) and 2(t). The patentee or any other interested party is expressly limited by the Act to being human. The Modicum of Creativity and the Sweat of the Brow Doctrine are two key concepts under the Copyright Act that govern how original works are classified.
As though A work's effort and labour are emphasised by the Sweat of the Brow Doctrine, but a minimal level of creativity is acknowledged by the Modicum of Creativity. However, under Section 2(d) of the Act, the "author" of a work is granted copyright ownership. The customary interpretation of "author" to refer to a human or legal person restricts the application of this Act's protection of computer creations. The Copyright Office may refuse to register AI-generated works if they don't have the necessary human authorship and creative input to back up a copyright claim. Thus, the issue of copyright protection for content produced by AI has two sides. The first is whether an AI can be recognised as the author; the second is if AI-produced work is sufficiently creatively advanced to be considered the product of human labour.
THE DEVELOPMENT IN INDIA The legal position regarding the ownership of AI-generated work is not yet clearly addressed by courts in India. Giving an AI authorship rights in an AI-generated work is more complicated than it first seems, and doing so could have serious repercussions. For example, if the AI is granted authorship rights in an AI-generated work and there is copyright infringement of that work or that work infringes on the already existing copyrighted work, the AI cannot enforce its copyrighted work against potential infringement nor can the AI be sued for potentially infringing an already existing copyrighted work. Neither the AI can protect its copyrighted work from future infringement nor the AI can be held liable for allegedly infringing an already existing copyrighted work. This is due to the fact that AI is not a living thing and cannot be sued.
Therefore, before the issue of providing AI rights is addressed, law must establish the legal status of AI. Furthermore, Indian law calculates the 60-year protection period for original literary, theatrical, musical, and creative works from the year of the author's death. Given that AI is infinite, giving it authorship over such a work defeats the very point of the copyright law's time duration of protection.
CITATIONS
DABUS PATENT CASE • CASELAWS The United States Copyright Office's Copyright Review Board denied copyright registration for the work "A Recent Entrance to Paradise" in the name of Stephen Thaler's artificial intelligence system, DABUS. DABUS, claiming to be the author and stating that the AI had independently created the work, filed the aforementioned copyright application in 2018. The copyright office rejected the application on the grounds that "it lacks the human authorship necessary to support a copyright claim."
RAGHAV OWNERSHIP CASE COPYRIGHT
India was temporarily awarded copyright protection for AI works, however later on, a withdrawal notice was issued. The AI painting software "RAGHAV" was registered as a coauthor in an Indian copyrighted work called "Suryast" in 2021. The AI App's owner, Mr. Ankit Sahni, was the other co-author. The Indian Copyright Office first turned down an application for an artwork that listed AI ('RAGHAV') as the only author. But, a second application was submitted in which the AI's owner and another AI were listed as co-authors of an approved piece of art. Remarkably, the Copyright Office withdrew its notice of withdrawal within a year, requesting details regarding the "legal status" of the AI Raghav, citing among other things that the "artist" would be entitled to copyright in an artistic work.
In this case, the most important questions are: Can any artificial intelligence ever be a recognised author and copyright owner? and Who is an author? The Indian Copyright Act, 1957, Section 2(d), which specifies a "author," is where one must look to investigate this. Limitations Renowned English mathematician, cryptanalyst, and computer scientist Alan Mathison Turing published a paper in 1950 titled "Computing Machinery and Intelligence," in which he raised the straightforward yet thought-provoking question, "Can machines think? " Several years after he was instrumental in the destruction of Nazi Germany. The foundation for what we today refer to as artificial intelligence (AI) or machine learning/intelligence was laid by his work and further study. The idea of AI has evolved into something far more sophisticated than scientists could have predicted fifty years ago.
Currently, artificial intelligence (AI), or the ability of a machine to understand and behave as similarly to a human mind as feasible, is a fascinating new frontier in technology. Technology has advanced significantly since the Turin Test in 1950, especially in the area of artificial intelligence (AI). Notable innovations include the 2016 release of Google's Home device, the 2011 release of Apple's virtual assistant Siri, the 2014 release of Microsoft's Cortana, the 2014 release of Amazon's Alexa, and the 2016 development of Hanson Robotics' humanoid robot Sophia. The last ten years have seen a lot of these improvements (2010 to 2019). These days, artificial intelligence can be divided into two categories:
1. Inadequate AI One sort of AI that is frequently used is weak AI, which is utilised by big
businesses like Google, Apple,as well as Microsoft. Its powers are restricted to the jobs it has been trained for, despite the fact that its applications are numerous. Although the techniques employed prevent this AI from thinking or acting in a manner that is similar to the human mind, it may retain data and present it to the user upon request. Thus, this AI does not represent a serious threat within the IP domain.
2 Strong AI
Compared to weak AI, strong AI is a kind of artificial intelligence that is capable of doing cognitive tasks that are more akin to human mental processes. Strong AI can accomplish complicated activities like creating new technologies, while weak AI is restricted to completing specific tasks that it has been designed to do. Strong AI can not only perform these basic operations more effectively than humans or producing original works of intellectual property, such films, music, or designs that are protected by copyright.
CONCLUSION
The world's attention and imagination have been captivated by Artificial Intelligence's (AI) potential to drive innovation in vast technological domains, a fact that has been recognised by scientists, lawyers, politicians, and the general public alike. The tremendous development in artificial intelligence (AI) is increasing system complexity, making it hard for the current legal framework to keep up with the rapid pace of technical advancement. The fast advancement of AI techniques particularly touches on the field of intellectual property (IP), as these techniques influence the creation, manufacturing, and distribution of commercial and cultural goods and services. In addition to sparking policy discussions, these advancements in AI technology have started to materialise as legal problems in cases that are brought before courts and IP agencies.
Without a doubt, artificial intelligence may make a significant contribution to the field of intellectual property rights, but there are still a lot of unanswered problems and uncertainties regarding its application. However, because it can be challenging to identify the offender of an infraction, AI may also be dangerous. Policies and guidelines are needed about artificial intelligence and how liability will be determined. Furthermore, it needs to be made explicit who will own the AI-related work or invention's copyright, patent, or other intellectual property rights. Therefore, it is imperative that AI be thoroughly studied with the use of case law.
REFERENCE
1.https://www.ipwatchdog.com/2024/03/29/artificial-intelligence-cantpatentinventions/id=123226/ [hereinafter So What?]. 2.‘Mounting Artificial Intelligence: Where are we on the time line?’ by Vaishali Singh, para.7. Available at https://blog.scconline.com/post/2024/03/29/mounting-artificialintelligence-where-are-we-on-the-timeline/. (Time:-12:35 pm) 3.Available at https://blog.scconline.com/post/2024/03/29/animals-by-virtue-of-the-fact-thatthey-are-not-humans-lack- locusstandi-under-copyright-act-to-sue-for-copyrightinfringement/.(time:-1 pm)