(Mt) – University College London Management Essay

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Coursework 2 Assessment Criteria Executive Summary (one page maximum) 5 Requirement and Marking Criteria Marks Available Introduction to brand– brief discussion on brand’s background, financial performance and marketing activities. Clear description of the problem or challenge that is going to be addressed with this new product or service 5 Critical internal and external analysis of the organisation’s market environment and operating environment, using suitable 10 Justification of the rationale for the new product or service using suitable models, frameworks and research to justify your decision 30 NPD strategy, detailing the options for the process that should be followed in the development of the new product or service, citing relevant research to justify 30 your choice Conclusion and recommendations (clarity and justification) including implementation plan, specific recommendations with action plan highlighting risk 10 mitigation and contingency plans Westminster Harvard referencing style and written presentation, use of references and range and quality of sources (as detailed in Appendix 1), layout and structure, writing style, pages numbered, adherence to specification Total 100 *If less than 7 peer-reviewed academic references (i.e., from academic journals) and relevant marketing reports are cited your report will be capped at 60% as it will not be deemed to be based upon enough reliable research. 10 6MARK012W New Product Development LECTURE 8 DR KATE INGSA Today’s Agenda • Recap: Managing Uncertainty within firms • Intellectual Property Patent Trademarks Copyright Infringement Counterfeits 6MARK012W NEW PRODUCT DEVELOPMENT 2 https://dressx.com/ 3 4 5 /05/20XX Source: 8https://dressx.com/collections/all-collections/products/orange-corset-alena-akhmadulina 6 Intellectual Property 19 Intellectual Property • Intellectual property is something that you create using your mind – for example, a story, an invention, an artistic work or a symbol • Concerns the legal rights associated with creative effort or commercial reputation • Organisation’s managers and the NPD team should be aware of the variety of ways that intellectual property can affect the management of innovation and the development of new products • The rapid advance of the Internet and e-commerce has created a whole new set of problems concerning intellectual property rights • To protect your novel idea, this is the simplest and cheapest course of action – just keep your idea a secret (as with the recipe for Coca-Cola) 20 What Intellectual Property is Having the right type of intellectual property protection helps you to stop people stealing or copying: • the names of your products or brands • your inventions • the design or look of your products • things you write, make or produce Copyright, patents, designs and trade marks are all types of intellectual property protection While you may get some types of protection automatically, others you have to apply for 21 Intellectual Property: GOV.UK According to the UK government, you own intellectual property, if you: • Created it (and it meets the requirements for copyright, a patent, or a design) • Bought intellectual property rights from the creator or a previous owner • Have a brand that could be a trade mark, for example, a well-known product name Intellectual property can: • Have more than one owner • Belong to people or businesses • Be sold or transferred Intellectual property rights allow you to make money from the intellectual property you own Source: https://www.gov.uk/intellectual-property-an-overview 22 Managing Intellectual Property • The keep-it-secret approach prevents anyone else seeing or finding out the idea. The owner can take their intellectual property to their grave, safe in the knowledge that no one will inherit it • This approach is fine, unless you are seeking some form of commercial exploitation and, ultimately, a financial reward, usually in the form of royalties • Royalties = a payment made to writers, people who have invented things, owners of property, etc. every time their books, devices, land, etc. are bought or used by others (Cambridge Dictionary, 2022) • One of the dangers of trying to keep your idea a secret, is that someone else might develop an idea similar to yours and apply for legal protection and seek commercial exploitation • The issues of intellectual property are continually with us and touch us probably more than we realise 23 Managing Intellectual Property – Example • The author is always the owner of his or her work and the writing of an academic paper entitles the student to claim the copyright on that essay • Indeed, the submission of an academic paper to a scientific journal for publication requires the author to sign a license for the publisher to use the intellectual property Publisher: owns the right to use the journal article content Authors: Sign a license when the journal article is submitted to the publisher 24 AN OVERVIEW OF THE MAIN TYPES OF INTELLECTUAL PROPERTY 25 THE MAIN TYPES OF INTELLECTUAL PROPERTY Type of intellectual property Patents Copyright Registered designs Registered trademarks Key features of this type of protection Offers a 20-year monopoly Provides exclusive rights to create individuals for the protection of their literary or artistic productions As protected by registration, is for the outward appearance of an article and provides exclusive rights for up to 15 years Is a distinctive name, mark, or symbol that is identified with a company’s products (Trott, 2021, p. 178) 26 Trade Secrets • There are certain business activities and processes that are not patented, copyrighted or trademarked – Many businesses regard these as trade secrets • It could be special ways of working, price costings, or business strategies • The most famous example is the recipe of Coca-Cola, which is not patented. This is because Coca-Cola did not want to reveal the recipe to its competitors • Unfortunately, the law covering intellectual property is less clear about the term ‘trade secret’. There is no satisfactory legal definition of this term (Bainbridge, 1996) 27 An Introduction to ‘Patents’ 28 An Introduction to ‘Patent’ • A patent = a contract between an individual or organisation and the state • The rationale behind the granting of a temporary monopoly by the state is to encourage creativity and innovation within an economy • By the individual or organisation disclosing in the patent sufficient detail of invention, the state will confer the legal right to stop others from benefiting from the invention (Derwent, 1998, cited in Trott, 2021, p.181) • The state, however, has no obligation to prevent others benefiting from it • This is the responsibility of the individual or organisation who is granted the patent • Major criticism of the patent system = the costs of defending a patent against infringement can be high 29 A Brief History of the ‘Patent System’ • The origins of Patent system stretched back to 400 years • The word ‘patent’ comes from the practice of monarchs in the Middle Ages (500-1500) conferring rights and privileges by means of ‘open letters’, that is, documents on which the royal seal was not broken when they were opened • This is distinct from ‘closed letters’ that were not intended for public views • ‘Open letters’ were intended from display and inspection by any interested party 30 The UK ‘Patent System’ • The UK Patent Office was set up in 1852 to act as the United Kingdom’s sole office for granting patents of invention • The UK Patent Office changed its name in April 2007 to the ‘UK Intellectual Property Office’ – to reflect that patents now represented only part of its activities along with Registered Designs and Trademarks Source: https://www.gov.uk/government/organisations/intellectual-property-office 31 The ‘Patent System’ Monopoly for 20 years Patent system Heavy annual renewal fees have to be paid to keep patent in force Annual fees required Patent agents 32 The ‘Patent System’ Monopoly for 20 years Patent system • Patents are granted to individuals and organisations that can lay claim to a new product or manufacturing process or to an improvement of an existing product or process that was not previously known • The granting of patent gives the ‘patentee’ a monopoly to make, use or sell the invention for a fixed period of time, which in Europe, the United Kingdom and the United States, is 20 years from the date the patent application was first filed • In return for this monopoly, the patentee pays a fee to cover the costs of processing the patent and, more importantly, publicly discloses of the invention • The idea must be new and not an extension of what is already known 33 Annual fees required 34 The ‘Patent System’ Annual Patent fees agents required • The role of the patent agent combines scientific or engineering knowledge with legal knowledge and expertise and it is a specialised field of work • Many large companies have in-house patent agents who prepare patents for the company’s scientists Patent system • They may also search patent databases around the world on behalf of the company’s scientists 35 The ‘Patent’ Criteria For a patent to benefited from legal protection, it must meet strict criteria: Novelty Inventive steps Industrial applications 36 The ‘Patent’ Criteria • The Patent Act 1997, section 2(1), stipulates that Novelty Not already known to the public before the date a patent is applied for ‘an invention shall be taken to be new if it does not form part of the state of the art’ State of the art = all matter, in other words, written or oral or even anticipation It is therefore part of the state of the art if the information which has been disclosed enables the public to know the product under a description sufficient to work the invention Source: Trott (2021), p. 182; GOV.UK – Manual of Patent Practice (2022) 37 The ‘Patent’ Criteria • Section 3 of the Patent Act 1997 states that Inventive steps Not an obvious modification of what is already known ‘an invention shall be taken to involve an inventive step if it is not obvious to a person skilled in the art’ • In the United States, the term ‘non-obvious’ is used as a requirement for patentability • Although the basic principle is roughly the same, the assessment of the inventive step and non-obviousness varies from one country to another 38 The ‘Patent’ Criteria • A set of rules in the United Kingdom courts was laid out by the Court of Appeal in determining the requirements for inventive steps: Inventive steps Not an obvious modification of what is already known 1. Identifying the inventive concept embodied in the patent; 2. Imputing to a normally skilled, but unimaginative, addressee what was common general knowledge in the art at the priority date; 3. Identifying the differences, if any, between the matter cited and the alleged invention; and 4. Deciding whether those differences, viewed without any knowledge of the alleged invention, constituted steps that would have been obvious to the skilled man or whether they required any degree of invention 39 The ‘Patent’ Criteria • Under the Patent Act, an invention shall be taken to be capable of industrial application if it can be a machine, product or process For example: Industrial applications Can be made or used in any kind of industry • Penicillin was a discovery that was not patentable, but the process of isolating and storing Penicillin clearly had industrial applications and thus, was patentable Methods for mass production of Penicillin were patented in 1945 by Andrew Jackson Moyer 40 Exclusions from Patents • Discoveries (as opposed to inventions), scientific theory and mathematical processes are not patentable under the Patent Act 1988 • Similarly, literary artistic works and designs are covered by other forms of intellectual property, such as trademarks, copyrights and registered designs 41 Source: Trott (2022), p.184 42 The Configuration of a Patent • Patents are generally intended to cover products or processes that possess or contain new functional or technical aspects; • Patents are concerned with how things work, what they do, how they do it, what they are made of or how they are made • Most patents are for incremental improvements in known technology evolution rather than revolution. The technology does not have to be complex 43 The Configuration of a Patent • For a patent to be granted, its contents need to be made public so that others can be given the opportunity to challenge the granting of a monopoly • There is a formal registering and indexing system to enable patents to be accessed easily by the public • Patents follows a very formal specification with details concerning country of origin, filing date, personal details of applicant, and etc. These are accompanied by an internationally agreed numbering system for easy identification • Patent Specification and Patent Abstract are classified and indexed in various ways to facilitate search 44 The Configuration of a Patent Patent Specification • A detailed description of the invention and must disclose enough information to enable someone else to repeat the invention Patent Abstract • A short statement printed on the front page of the patent specification • Precise and methodological • Identifies the technical subject of the invention and that advance that it presents • Contains references to other scientific papers • Usually are accompanied by a drawing • Breadth and scope of invention • Abstracts are published in weekly information booklets 45 Source: https://www.gov.uk/patent-your-invention 46 47 Patentability • In other words, your invention must make a technical contribution • This means you can’t, for example, patent a continual motion machine • Inventions relating to computer software may be patentable, but only if they involve something more (technical effect) than just software running on a computer in a technically ordinary way 48 Advantages of owning a Patent ‘Freedom to operate’ • In a semiconductor industry, freedom to operate is an important issue because a lot of innovations overlap • Large semiconductor firms cross-license patents and allow competition to use each other’s patent • A strong patent portfolio provides firm with a stronger negotiating position • If firms do not provide ‘freedom to operate’, they can block • Patenting with the intention to block competition is quite common, and in semiconductor industry, 75 percent of the participants declared blocking as a reason to patent (Cohen et al., 2000) 49 Reasons why firms ‘patent’ Source: Trott (2022), p.190 50 Alternative strategies to patenting Source: Trott (2022), p.192 51 TRADEMARK 52 A trademark can be a word, phrase, symbol, or design that distinguishes the source of the goods or services. Also, as trade dress, it can be the appearance of a product or its packaging, including size, shape, colour, texture, graphics, and appearance (e.g, retail store or website) (Apple, 2022) 53 Trademarks • For a less technology-intensive industries where the use of patents is limited, trademarks offer one of the few methods of differentiating a company’s products • Trademarks are closely associated with business image, goodwill and reputation • Many trademarks have become synonymous with particular products: Mars & Chocolate Confectionary Hoover & Vacuum Cleaner Nestle and coffee 54 Trademarks • The public rely on many trademarks as indicating quality, value for money and origins of goods Section 1(1) of the Trade Marks Act 1994 defines a trademark as: “being any sign capable of being represented graphically which is capable of distinguishing goods or services of one undertaking from those of other undertakings” • Some of the first trademarks were used by gold and silversmiths to mark their own work • The first registered trademark, No 1, was issued to Bass in 1890 for their red triangle mark for pale ale 55 Trademarks: Restrictions and Principles In particular, a trademark should: • • • Satisfy the requirement of Section 1(1) A trademark should be distinctive in itself It should not describe in any way the product or service to which it relates Usually words that are considered generic are not trademarked • Trade mark or service mark will not be registered if it could be confused with the trademark of a similar product that has already been registered ‘Velva-glo’ was refused as a trademark for paints because it was judged to be too near the word ‘Vel-Glo’, which was already registered • • • Be distinctive • • Trademark Not cause confusion with previous trademarks Sound and smells and containers could now be registered Some perfumes are trademarked Coca-Cola have applied to registered their container for Coca-Cola Unilever also applied Domestos container for trademarks Not be deceptive • Should not attempt to deceive the customer • In 1990, the attempt to register Orlwoola, as an artificial fibre would not be possible, since the word could persuade people to believe the material is made of wool 56 Trademarks: Restrictions and Principles For example: • An attempt to register the word ‘beef’ as a trademark for a range of foods would not be possible, since other traders would want to use the word ‘beef’ in their course of their trade • It would be acceptable to use the word ‘beef’ in association with a range of clothing because this would be considered distinctive Be distinctive Trademark • Laudatory (expressing praise: subjective, and not descriptive) terms such as ‘heavenly’ cannot be used to describe a range of cosmetic products, since it is a laudatory term 57 Trademarks: Restrictions and Principles • There are proposals to provide more effective trademark protection against counterfeits • The extent of the changes is evident from the increase from 19 articles to 57 in the Trade Marks Directive 58 59 Source: https://creative.starbucks.com/logos/ 60 Source: https://www.apple.com/uk/legal/intellectual-property/guidelinesfor3rdparties.html 61 Source: https://www.apple.com/legal/intellectual-property/trademark/appletmlist.html 62 Source: https://trademarks.ipo.gov.uk/ipo-tmtext 63 Brand names NAMES 64 Brand names • Increasingly, the link between the brand name and the trademark is becoming closer and stronger • The literature tends to separate the two, with brands remaining in the sphere of marketing and trademarks within the sphere of law • However, brand names and trademarks are cousins. They both serve to facilitate identity and origin • The origin indicates a certain level of quality, as reflected in the goods • While many brands have been registered as trademarks 65 Source: https://www.bluetooth.com/develop-with-bluetooth/marketing-branding/#:~:text=This%20is%20why%20so%20many,Bluetooth%20products%20they%20already%20own. 66 Source: https://www.bose.co.uk/en_gb/products/headphones/earbuds/bose-sport-earbuds.html#v=sport_earbuds_triple_black 67 Brand Names: Brand Equity • Like other capital assets owned by a firm, such as manufacturing equipment or land, a brand can also be considered an asset, and a valuable one at that • ‘Brand Equity’ is the term used to describe the value of a brand name 1. The total value of a brand as a separable asset – when it is sold or included on a balance sheet; and 2. A measure of the strength of consumers’ to a brand; and 3. A description of the associations and beliefs the consumer has about the brand 68 Brand Names: Brand Equity • Brand Equity creates value for both customers and the firm • The customers clearly can use brand names as simplifying heuristics for processing large amounts of information • The brand can also give customers confidence in the purchasing situation • Firms benefit enormously from having strong brand names – investment in a brand name can be leveraged through brand extensions and increased distributions • High brand equity = allows higher prices to be charged, hence it is a significance competitive advantage 69 70 71 72 Copyright • According to GOV.UK, copyright protects your work and stops others from using it without your permission • You get copyright protection automatically – you don’t have to apply or pay a fee. There isn’t a register of copyright works in the UK You automatically get copyright protection when you create: • original literary, dramatic, musical and artistic work, including illustration and photography • original non-literary written work, such as software, web content and databases • sound and music recordings • film and television recordings • broadcasts • the layout of published editions of written, dramatic and musical works You can mark your work with the copyright symbol (©), your name and the year of creation. *Whether you mark the work or not doesn’t affect the level of protection you have 73 Copyright • This area of the law on intellectual property rights has changed significantly over the past few years • For the author of creative material to obtain copyright protection, it must be in a tangible form so that it can be communicated or reproduced • Computer software manufacturers are particularly concerned about the illegal copying of their programmes • The music industry has also battled with this same problem for many years • It is common knowledge that this was an exceptionally difficult area of law to enforce and new technology may, at last, provide copyright holders with an advantage • The impact of this maybe to hinder creativity in the long term 74 75 Copyright • The duration of copyright protection varies, according to the description of the work • In the United Kingdom, for literary, musical, dramatic, and artistic works, copyright expires 70 years after the death of the author, in other cases, 50 years after the calendar year in which it was first published 76 77 78 How to Copyright a Song (British Library, 2022) • As a literary work, copyright on lyrics lasts for 70 years from the end of the calendar year in which the author dies. The same applies to music, as an artistic work. • These laws apply to songs created in the UK, songs created in other countries may have different rules, Source: https://www.bl.uk/business-and-ip-centre/articles/how-to-copyright-a-song 79 Copyright in Music Industry in Practice Copyright process begins RECORD LABEL Record label may invest in music production. If this is the case, master rights belongs to the record label Compose music (melody) Process of soundrecording and mastering into the original version of the artistic work Artist(s) Compose a song lyrics Publishing Rights: Owner/Right to publish the artistic work A finished song Commercial version Monetisation opportunity Master Rights: Original version of the artistic work output (song) 80 Public Performance License Agreement (PPL) = agreement between a music user and the owner of a copyrighted composition (song) that grants permission to play a song in public, online, or on radio • Types of agreement varies in different context/countries 81 Synchronisation License Fees = They are fees paid for the use of music in visual media productions of various kinds • This license fee is needed for e.g. short video clips, slide shows, TV productions, short films and feature films • This is a matter of merging or synchronising music and visual media • The fees are determined by the Publisher(s) or Master Owner(s) who administer the Synchronisation rights to the Composition or Master Recording 82 Copyright in Music Industry in Practice RECORD LABEL SAMPLE ROYALTY: 70/30 Rule Artist(s) 15% Music Composer 5% Word Composer 5% Producer 5% *Number breakdowns are illustrative example, not taking into consideration of any possible complications 83 INFRINGEMENT 84 Remedy Against Infringement • There are some forms of infringement of a commercial nature, such as dealing with infringing copies that carry criminal penalties • HM customs has powers to seize infringing printed material and civil action can be brought by the plaintiff for one or more of the following: 1. 2. 3. Damages: The owner of the copyright can bring a civil case and ask the court for damages which can be expected to be calculated on the basis of compensation for the actual loss suffered Injunction: An order of the court that prohibits a person making infringing copies of work of copyright Accounts: This is a useful alternative for the plaintiff in that it enables access to the profits made from the infringement of copyright. This is useful, especially, if the amount is likely to exceed that which might be expected from an award of damages 85 Source: Trott, 2021; https://www.reuters.com/article/us-apple-qualcomm-idUaSKCN1QW2KB; https://www.reuters.com/legal/transactional/appleloses-bid-second-bite-qualcomm-patents-after-license-2021-11-10/ 86 COUNTERFEIT GOODS and IP 8/05/20XX 87 Counterfeit Goods • The production and sale of counterfeit products is big business in international economy • The value of counterfeit products marketed annually in the world is estimated to be over $1 trillion • China is most evident in terms of producing and selling of counterfeit goods (Hung, 2003; Naim, 2005) • The massive expansion of the Chinese economy has led to a huge increase in foreign direct investment (FDI) and international technology transfer (ITT) and has brought the issue of intellectual property to the fore • The extent of product counterfeiting operations in China is astounding; estimates range from 10 to 20 percent of all consumer goods manufacturing in the country 88 Counterfeit Goods • Recent research by Schmiele (2013), analysing German firms with innovation activities in China, revealed that firms with international R&D activities are increasing their chances of losing technological knowledge to their local competitors abroad • The research illustrated three different types of IP infringements from abroad: 1. The usage of firms’ technical inventions 2. Product piracy 3. Copying of corporate names and designs 89 Source: https://hbr.org/2018/05/8-ways-brands-can-fight-counterfeits-in-china 90 91 92 93 94 Another long battle for foreign companies such as Supreme, who finally secured its trademark in China after a lengthy legal battle for six years in May 2020 to safeguard its iconic branding against imitators Source: https://hypebeast.com/2020/5/supreme-china-trademark-registration-shanghai-imitation-store 95 THE BEST WAY TO PROTECT YOUR IP RIGHTS IS TO USE THEM PATENT Source: https://www.popularmechanics.com/technology/design/g20051677/patents-changed-the-world/ 96 THE BEST WAY TO PROTECT YOUR IP RIGHTS IS TO USE THEM TRADEMARK 97 THE BEST WAY TO PROTECT YOUR IP RIGHTS IS TO USE THEM COPYRIGHT 98 Any questions? Don’t forget to read a Case Study from Trott (2021) Page 205-210 for the seminar 99 Alibaba Using Cryptocurrency as a Payment OptionTemplate Student registration number: module code: CONTENTS Introduction Technology A company brief introduction A new method Cryptocurrency A new payment Advantages + disadvantages Introduction 1. Alibaba is one of the largest e-commerce platforms in the world. 2. The company’s country of origin is China. 3.Common payment modes include; PayPal, debit or credit card, and wire transfer. 4.Cryptocurrency should be an option given its various advantages. Alibaba Vs Global Competitors • One of Alibaba’s goal is to leverage cloud computing power. • Judging from the data shown, it still has a lot to improve on regarding its business operations • It is the third largest global provide of Infrastructure as a Service (Iaas). • Diversification is key in developing a strong market position. ‘Disruption’ is the New Normal • Companies such as BlackBerry, Blockbuster and Kodak failed to innovate and faced the consequences. • Netflix, Amazon and Uber pioneered different technologies to their respective industries and succeeded. • Cryptocurrency is a new technology that has a lot of potential. • Alibaba should utilize cryptocurrency as a payment method to diversify its investments portfolio. Cryptocurrency • Cryptocurrency is a digital currency characterized by a decentralized ledger that uses cryptography. • The first cryptocurrency, Bitcoin, was released in 2009. • More than 550 cryptocurrencies have been developed over the past years. • Security and efficiency are the main selling points of this technology The Innovation Process (Cryptocurrency) • Innovation = theoretical conception + technical invention + commercial exploitation • Alibaba needs to get ahead of the market and adopt cryptocurrency. • The technology’s popularity increases annually making it a good niche for commercial exploitation. Techonology Cryptography Blockchain Cryptocurrency mining Practical Byzantine Fault Tolerance (PBFT) Cryptocurrency Acceptance and Government Dynamics • • • Popularity increase Support from countries like China. High volatility is a concern for many people. Ad/Disad Advantages of Cryptocurrency • Security • It is a fairer and more transparent system. • Currency is not tied to any currency therefore not affected by inflation Disadvantages of Cryptocurrency • Extremely volatile. • un-environmentally friendly. • Expensive to implement. popularity threats Cryptocurrency’s Potential Impact on Alibaba threats options • The currency’s popularity is increasing • Reduction in cybersecurity threats • Increased payment options. Conclusion • Cryptocurrency is a new technology that has huge potential. • Adding it as a payment option will allow Alibaba to diversify its investment portfolio. • Its secure channels will reduce data theft that is rampant in ecommerce platforms. • It is a good way to gain a competitive advantage in the market. References • Alladi, T., Chamola, V., Parizi, R. M., & Choo, K. K. R. (2019). Blockchain Applications for Industry 4.0 and Industrial IoT: A review. IEEE Access, 7, 176935-176951. https://ieeexplore.ieee.org/iel7/6287639/8600701/08917991.pdf • Farell, R. (2015). An analysis of the cryptocurrency industry. https://repository.upenn.edu/cgi/viewcontent.cgi?article=1133&context=wharton_research_scholars • Hairudin, A., Sifat, I. M., Mohamad, A., & Yusof, Y. (2020). Cryptocurrencies: A survey on Acceptance, Governance and Market Dynamics. International Journal of Finance & Economics. https://www.researchgate.net/profile/Imtiaz-Sifat/publication/347167178_Cryptocurrencies_A_survey_on_acceptance_governan ce_and_market_dynamics/links/5fd86d9445851553a0ba22c3/Cryptocurrencies-A-survey-on-acceptance-governance-and-marketdynamics.pdf • Ismanto, L., Ar, H. S., Fajar, A. N., & Bachtiar, S. (2019, July). Blockchain as E-Commerce Platform in Indonesia. In Journal of Physics: Conference Series (Vol. 1179, No. 1, p. 012114). IOP Publishing. https://iopscience.iop.org/article/10.1088/1742-6596/1179/1/012114/pdf • Riley, J. (2021). The Current Status of Cryptocurrency Regulation in China and its effect around the World. China and WTO Review, 7(1), 135-152. https://scholar.archive.org/work/bcj2onzgpfce3corozucowpmce/access/wayback/http://cwr.yiil.org/home/pdf/archives/2021v7n1 /cwr_v7n1_06.pdf

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