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According to the American Heritage Dictionary, the term biopiracy means "the commercial development of naturally occurring biological materials, such as plant substances or genetic cell lines , by a technologically advanced country or organization without fair compensation to the countries or peoples on whose territory these materials are located were originally discovered ". The term is only used as a derogatory attribution for others, comparable to the term product piracy .

Origin and use of the term

The term goes back to Pat Mooney , an activist with the Rural Advancement Foundation International (RAFI, now the ETC Group ) in the early 1990s. The Indian environmental activist and author Vandana Shiva was instrumental in spreading the term. NGOs such as BUKO or Greenpeace also use the term to name associated practices.

Some legal scholars criticize the use of the term. Jim Chen (2005) called the term an alarmist exaggeration. Most allegations of biopiracy are so marked by inconsistencies and lies that they belong in the realm of legend . Cynthia M. Ho (2006) differentiates between rhetoric and reality and suggests dropping the use of the term entirely.


According to Robinson (2010), there are three categories of biopiracy:

  • Patent-based biopiracy: The patenting , often dubious or flimsy, of inventions based on biological resources and / or traditional knowledge that were taken from other countries (usually developing countries) or indigenous and local communities without adequate authorization or benefit sharing.
  • Non-patent-based biopiracy: Other forms of intellectual property (e.g. trademarks or plant variety rights ) based on biological resources and / or traditional knowledge extracted from other countries (usually developing countries) or indigenous and local communities without adequate authorization or benefit-sharing.
  • Unlawful appropriation: The unauthorized extraction of biological resources and / or traditional knowledge by local authorities, or possibly other local groups, without benefit sharing.


As a result of the development of new scientific and technical methods ( biotechnology , genetic engineering ), " biomaterial " was also increasingly patented from the 1980s onwards (see: biopatents ). This patent protection, which was formulated very broadly in some cases, also included traditional uses of plants, e.g. B. as a medicinal plant or food plant, for a long time by indigenous peoples in poor countries v. a. the tropics had been used.

The controversy develops mainly because of the different definitions of knowledge in traditional societies and industrialized countries. Traditional knowledge is impersonal knowledge of the entire community and usually has no known discoverer or inventor. The advancement of traditional knowledge through science and technology is based on researchers, whose advancement is recognized as a personal merit. In order to protect research activities against free riders who make use of existing knowledge without having taken the trouble of research, the economic use of research results is protected by patents and copyrights . These rights are - until they expire - the personal property of their creator. For unpatented scientific discoveries, the rule is that they are freely accessible as soon as they are published. Such results can be freely used and further developed by others. Before the introduction of the Biodiversity Convention , traditional knowledge was also part of legally unprotected free knowledge.

As far as the use and utilization of organisms by biotechnology affects unknown species in areas to which no one claims, it is still largely undisputed. This concerns z. B. Cases such as the patenting of the biochemical services of marine microorganisms or algae / seaweed . However, as soon as the plants have been discovered in the habitat of a people or have even been used by them earlier, the use, especially by foreign companies, is viewed by some as piracy.

The term established in this way was later extended to other cases in a further step. Since the adoption of the Biodiversity Convention in 1992, biopiracy has also been used to describe the use of organisms or their genes that originate from the territory of a people or state that they have never used themselves (perhaps not even known). To what extent a group of people or a state actually owns organisms that naturally occur here is a different question than whether one can use their knowledge without their consent. The attribution of ownership is based on a pragmatic approach. With the attribution of property rights, these organisms now have an economic value that they did not have before. This may make it economically viable for the state concerned to maintain it.

Researchers who steal previously unknown organisms in foreign countries or the settlement areas of foreign peoples without their consent become a kind of thief through this mechanism. The moral assessment of the search for usable biotic resources ( bioprospection ) without prior consent is controversial.

Interests and conflicting interests

Parts of the globalization critics explain biopiracy as follows: It is a matter of deliberate theft driven by profit interests by multinational corporations. Especially genetic engineering - agriculture - and seed companies such as Monsanto , Dow AgroSciences , Pioneer Hi-Bred ( Corteva ), Cargill and Bayer CropScience are suspect in this regard. By monopolizing z. For example, in the seed markets with genetically modified varieties, these corporations succeed in displacing traditional cultivation methods and varieties or even criminalize farmers if their traditional seedlings contained patented genetic compounds. The consequences are a dependency of the grower on the patent holder and the reduction of the variety of plants for cultivation and use. Due to the complex legal situation and the high costs, it is almost impossible for representatives of indigenous peoples, who are often among the poorest even in their poor home countries, to enforce even obviously justified claims to defend against unauthorized patents.

In 1992, these discussions led to the adoption of the Convention on Biological Diversity (Convention on Biological Diversity, CBD). As part of that Rio Conference was created using the CBD the principle of "access and benefit sharing" ( Access and Benefit Sharing established) legally. The use of generic resources - also with the aim of developing patented products - should not be restricted, but on the contrary promoted. In return for the use of the generic resources, indigenous and local communities are to participate appropriately in the profits made with the genetic resources and with the knowledge associated with them (access and benefit sharing). Prior to the search for suitable genetic resources ( bioprospection ), the approval of the states in whose area research is to be carried out must also be obtained. The regulations of the CBD and the ABS have met with criticism.

Between nation states and indigenous peoples, both of whom have been granted property rights by the Convention , conflicts of interest must also be expected. Especially modern, internationally well-networked representatives of indigenous peoples with good contacts to NGOs and an enormous public impact in the perception of the industrialized countries see themselves as enemies of the state and vicarious agents of foreign neo- colonialists .

Legal regulations and trade agreements

The worldwide protection of intellectual property is regulated by international agreements. The UN organization WIPO is to coordinate this worldwide. However, some industrialized countries, primarily the USA, are trying to bypass WIPO to enforce stricter rules. With significant support from the USA, the World Trade Organization negotiated the TRIPS Agreement , which has since been binding for the admission of members. The agreement strengthens the rights of patent holders in a special way. Intellectual property of the kind that indigenous peoples have in their traditional knowledge is not protected by the agreement. TRIPS is the only such international agreement which currently also opens up the possibility of sanctions if its provisions are violated.

For the protection of the property of traditionally used animal and plant species as well as for property rights of states to biodiversity in general, the Biodiversity Convention is an essential basis today . After the adoption of the convention, the rules for preventing biopiracy were specified in a follow-up conference in the Nagoya Protocol . The convention has come into force and thus international law, while the Nagoya Protocol has not yet become legally binding. The Federal Republic of Germany has acceded to both agreements and has thus taken on the corresponding voluntary commitments, similar to most industrialized countries. However, since the USA never ratified the convention, the status of v. a. in relation to the TRIPS Agreement. However, prospectors and companies that disregard the rules run a legal risk because their patents may be challenged in many countries.

Documentation of knowledge

The traditional knowledge of indigenous peoples as indigenous knowledge system (Engl. Indigenous knowledge system ), respectively. Linked to this is the research area of ethnobotany . She examines the use of plants, their importance for a socioculture and the related questions. A common strategy for preserving the rights of indigenous peoples to their knowledge is to record this knowledge in publicly accessible directories and databases. In this way, the knowledge is formally introduced into the global knowledge system. In this way, the indigenous knowledge gains general awareness through an "official" route. Thus it is e.g. For global companies, for example, it is far more difficult to acquire traditional knowledge and then pass it off as one's own "new" intellectual achievement. This counteracts the patenting of indigenous knowledge.

Under the regulations on Access and Benefit Sharing , the use of documented traditional knowledge can be released against a license. This creates a mechanism for indigenous and / or traditional communities to participate in the benefits of using knowledge. These efforts are most advanced in India. For example, the "Traditional Knowledge Digital Library", a database for medicinal plants, was set up here. A World Bank initiative tried something similar for Africa. In Europe there were efforts to establish a worldwide organization, which is supposed to collect and administer indigenous knowledge in trust.

Efforts within the framework of the International Seed Treaty of the World Food Organization (FAO) are going in a similar direction . This sets up a fund into which users of the varieties of the main agricultural crops documented in it pay in when they develop this knowledge into patented applications or new varieties. This is intended to finance programs for the protection and sustainable use of plant genetic diversity, especially in developing countries.

Examples of the "biopiracy" discourse

African devil's claw

The African devil's claw Harpagophytum procumbens is a medicinal plant that v. a. for the treatment of rheumatic diseases is of great importance. The medicinal properties of the plant had been known to the San people in the South African Kalahari for a long time, from whom a German colonial official, who was used in Europe, learned about it. Devil's claw preparations are among the most commercially important herbal medicines in Germany today. To this day, devil's claw roots are mainly harvested from the wild by San, although they have to accept extremely poor wages due to their poverty. In order to allow the San to participate in the benefits in the future, a seal from the "Fair Wild Foundation" will inform consumers about fair trade devil's claw.

Basmati rice

Basmati rice was discovered at the foot of the Himalayas thousands of years ago . Since then, it has been consumed all over the world and mainly grown and exported by India and Pakistan. The Indian export market for basmati rice is US $ 350 million and the Pakistani export market is US $ 250 million. In September 1997, the USPTO granted the Texas company RiceTec a patent (No. 5,663,484). The patent consisted of 20 claims and related to a "rice plant that is grown in North, Central, South America or on the Caribbean islands". The patent owner received an exclusive right to the name "Basmati". The protection included "novel rice lines as well as plants and grains of these lines and a method for breeding these lines". According to the patent description, the novelty of the rice lines consisted of "semi-dwarfism, very low photosensitivity and high yield" and the "similarity or superiority of the grains compared to those of high quality Basmati rice". The cross consisted of one of 22 specified Basmati lines and at least two of the 15 known semi-dwarf long grain varieties. The specified Basmati rice lines are listed in the IRRI database as distinct varieties ( i.e. no wild types or land races ) from the Punjab and also belong to the varieties listed in the United States. 9 of the 15 long grain varieties come from IRRI or CIAT .

This patenting has been called biopiracy by several non-governmental organizations. In India it caused a storm of indignation and quickly became a matter of national pride . First, it is a case of theft of the collective intellectual and biological heritage of Indian farmers, second, damage to Indian exporters who have been deprived of an opportunity to market in the US, and third, consumers are misled because the rice sold as "Basmati" is not from India come and have a different quality. The Research Foundation for Science, Technology and Ecology (RFSTE, now Navdanya ) asked the Supreme Court to challenge the patent or to call the World Trade Organization's Dispute Settlement Body . In April 2000, the Government of India challenged claims 15-17, which were a broad definition of protected grains of rice. RiceTec then withdrew these three and one other claim. The USPTO revoked claims 15-17, as well as most of the others, in August 2001. All that remained were those claims that related to the rice lines grown by RiceTec. The names of these rice lines (Bas 867, RT 1117 and RT 1121) formed the new title of the patent. Since then, RiceTec has called its products "Texmati" and "American-style basmati rice".

At the same time as this, RFSTE and two US NGOs submitted a petition to the US Federal Trade Commission (FTC). In the petition they asked for a warning because the term "Basmati" should not be used for rice from other countries. The FTC found in May 2001, however, that the term "Basmati" was not restricted to rice of a certain origin.

In the meantime, the Indian government had prepared two bills. One of them was the Protection of Plant Varieties and Farmers' Rights Act 53 , which was passed in October 2001. The other was passed in December 2002 and implemented the Biodiversity Convention. These laws did not affect the case mentioned (as the US patent had already been granted), but should avoid similar cases in the future. In December 1999 the Indian government also enacted the Geographical Indications of Goods (Registration and Protection) Act, according to which a designation of products from a certain region constitutes a geographical indication, although not a designation of origin . Designations like “Basmati” should be protected in the future.


On October 10, 2000, the Japanese food company Asahi Foods Co. Ltd filed a PCT patent application with the publication number WO 01/25377 with the Japanese Patent Office, the protection u. a. for a fat mixture of fat / oil from Cupuaçu seeds with other fats (cocoa butter) as well as a process for the extraction of the vegetable fat and its utilization in food, the regional European part of which as EP 1 219 698 from the European Patent Office (EPA) on July 3 Released in 2002. After an initial review by the European Patent Office, which classified the specific fat / cocoa butter mixture as inventive but the manufacturing process as known, the EP patent application is deemed to be withdrawn if the annual fee is not paid.

Asahi Foods also held a patent from 2000, which includes an exclusive right of use for a process for the production of cupulates. In fact, this process has been used by the people of the Amazon for many decades. The fruits have always been used by the Amazonian indigenous people. On March 1, 2004, the trademark protection on the Cupuaçu trademark was canceled after protests by NGOs following a decision by the Japanese Patent Office (JPO).


The resin of the balsam tree Commiphora mukul , known as incense, known as guggul , was called bedolach resin in the Bible . In traditional Indian medicine, it is used for a wide variety of uses. Several patents have been issued in America on medical and cosmetic uses that overlap with traditional uses. These patents are still valid today and have not yet been challenged.


Another example is the use of the succulent plant species Hoodia gordonii by the Khoi-San . The San have always used parts of this plant to quench their hunger and thirst during the long hikes they undertake to hunt. The South African government had the plant, which acts as an appetite suppressant, examined and patented the active ingredient as P57. The patent was later sold through a British pharmaceutical company to the American pharmaceutical company Pfizer , who wanted to use it to develop an appetite suppressant without the Khoi-San participating in the proceeds. In court proceedings, the Khoi-San succeeded in securing a share of the profits in the preparations developed from the hoodia plant. Pfizer has since returned the patent. The great majority of the profiteers, however, have not signed a contract with the carriers of traditional knowledge.


In March 1995, the two Indian-born researchers Suman K. Das and Hari Har P. Cohly were granted a patent (US Pat. No. 5,401,504) on turmeric for use as a wound remedy by the University of Mississippi . The Indian Council for Scientific and Industrial Research (CSIR) sued the US Patent Office on the grounds that turmeric has been used to treat wounds and rashes for thousands of years and that its medicinal use is therefore not a new invention. The CSIR relies on an ancient Sanskrit text that was published in 1953 in the Journal of the Indian Medical Association . The US Patent Office then deleted this and other turmeric-related patents.


Maca ( Lepidium meyenii ) is a traditional nutrient and medicinal plant in the Peruvian Andes that has been used by various Quechua - and Aymara - speaking peoples for a long time. Documented reports have been available since the 16th century. The American company PureWorld Inc. has applied for and received several patents on the use of Maca and on the extraction of the active ingredient from the US patent authority. The Peruvian government agency INDECOPI (National Institute for Defense against Competition and the Protection of Intellectual Property) sees this as a case of biopiracy and wants to challenge the patents. The patent protection is still legally binding and various companies are marketing products based on these patents.

Neem tree

Since 1985, American, Japanese and European companies have registered more than 90 patents on the properties and extraction processes of the neem tree . The American company WR Grace set up production facilities for neem processing in India. The industrial demand led to the price of the rye seeds rising from $ 11 to over $ 100 per ton, with the result that smaller Indian companies and poor farmers were no longer able to buy rye seeds.

In 1993, the Neem Campaign was founded in India to take action against allegedly wrongly granted patents.

In particular, the patent EP 0 436 257 B1, which was granted to the US Department of Agriculture in 1994 together with the company WRGrace from the European Patent Office in Munich, caused a sensation. It relates to a “method for controlling fungi on plants” (patent claim 1) or a “method for protecting plants from fungal attack” (patent claim 7), both methods being characterized in that “the fungi / plant are treated with a Neem oil formulation containing 0.1 to 10% of a hydrophobically extracted neem oil that is essentially free of azadirachtin, 0.005 to 5.0% emulsifying surfactant and 0 to 99% water. "

I.a. Right Livelihood Award winner Vandana Shiva objected to the grant of the patent. In May 2000, after two days of negotiations in opposition appeal proceedings before the EPO's technical board of appeal, the patent was revoked due to a lack of “inventive step”, the most important requirement for patentability alongside “novelty”. The Board of Appeal found that the process described in the patent was new at the priority date (December 26, 1989), but in view of the fact that the fungicidal effects of vegetable oils are widely known, no inventive step was required to apply known recipes to previously unused plants and so to get to the patented process.

In the meantime, another patent on Niem products has been finally revoked by the European Patent Office (as of 2005).


Cape pelargoniums, the species Pelargonium reniforme and Pelargonium sidoides endemic to South Africa , are used for the treatment of bronchitis and other diseases. The German company Schwabe -Arzneimittel, whose pelargonium product UMCKALOABO makes a significant contribution to the company's sales, had registered various patents on the medicinal use of Cape pelargoniums. Together with a local citizens' initiative, the African Center for Biosafety, which acted on behalf of a local community in Alice (South Africa) , the Swiss non-governmental organization EvB filed an objection to four patents at the European Patent Office in 2008 and 2009 . They argued that the use and extraction processes had been in use by local healers for a long time, and that Schwabe would not have obtained their consent for the collection or use, nor did they share in the profits from it. Pelargonium has been used as a medicinal product in Germany since 1935, but the production of the active ingredient still requires the collection of wild plants, which Schwabe procures from the South African company Parceval. In May 2010, Schwabe withdrew five patents under the pressure of the oppositions. Complicating the case is that Alice's local Xhosa community did not immigrate to the area until historical time, and has presumably adopted medical knowledge from healers from the long-established San people , so that it is a difficult moral question which local community, if any, should share in the proceeds.

Banisteriopsis caapi

In 1986 Loren Miller, chairman of the "International Plant Medicine Corporation", patented the liana species Banisteriopsis caapi , which is required for the production of the drink ayahuasca , in the USA under patent number 5751. In 1997, Ayahuasca was recognized by the COICA as the intellectual property of indigenous peoples . In 1999 the patent was canceled because the plant was already well known before it was patented. In 2001 the US Patent Office reversed its decision. The patent came into force again. The patenting has triggered protests, especially by COICA, from the start and is considered an example of the exploitation of indigenous cultures.


Individual evidence

  1. Robinson, p. 14.
  3. Biopiracy : Robbery of Diversity. Patent on corn for the DuPont company, Retrieved July 11, 2016
  4. Jim Chen (2006): There's No Such Thing as Biopiracy ... and It's a Good Thing Too. 37. McGeorge Law Review 1.
  5. Cynthia M. Ho: Biopiracy and Beyond: A Consideration of Socio-Cultural Conflicts with Global Patent Policies. In: University of Michigan Journal of Law Reform. 39 (2006), pp. 433-542.
  6. ^ Robinson, Box 1.2: Typologies and Categories of Biopiracy, on p. 21
  7. An overview in Ikechi Mgbeoji (2005): Global Biopiracy: Patents, Plants, and Indigenous Knowledge. publ. by University of British Columbia, ISBN 0-7748-1152-8 .
  8. Overview in: Stephen P. Brush: Indigenous knowledge of natural resources and intellectual property rights: the role of anthropology. In: American Anthropologist. New Series 95 (3) (1993), pp. 653-671. doi : 10.1525 / aa.1993.95.3.02a00060
  9. ^ Johannes F. Imhoff, Antje Labesa, Jutta Wiesea: Bio-mining the microbial treasures of the ocean: New natural products. In: Biotechnology Advances. Volume 29, Issue 5 (2011), pp. 468-482. doi : 10.1016 / j.biotechadv.2011.03.001
  10. Efstathia Ioannou, Vassilios Roussis: Natural Products from Seaweeds. In: Virginia Lanzotti, Efstathia Ioannou (Ed.): Plant-derived Natural Products. Springer, New York 2009, ISBN 978-0-387-85498-4 , pp. 51-81.
  11. cf. the controversy between Rull & Vegas-Villarubia and Vale, Alves & Pimm In: Nature. 453, 2008, p. 26.
  12. Vandana Shiva: Biopiracy. 21st century colonialism. An introduction. Unrast-Verlag, Münster 2002, ISBN 3-89771-416-7 . from the English by Dana Aldea and Klaus Pedersen. Original edition Biopiracy. The plunder of nature and knowledge . South End Press, Boston 1998. ISBN 0-89608-555-4 .
  13. Jacques de Werra (2009): Fighting against biopiracy: does the obligation to disclose in patent applications truly help? Vanderbilt Journal of transnational law 42: 143-179.
  14. Page of the Federal Agency for Nature Conservation on Access and Benefit Sharing
  15. Jay McGown: Out of Africa: Mysteries of Access and Benefit Sharing. Edmonds Institute in cooperation with the African Center for Biosafety. Edmonds, Washington, 2006.
  16. Beth A. Conklin: Shamans versus pirates in the Amazonian treasure chest. In: American Anthropologist. 104 (4) (2002), pp. 1050-1061. doi : 10.1525 / aa.2002.104.4.1050
  17. The WIPO Intergovernmental Committee on Intellectual Property and Genetic Resources, Traditional Knowledge and Folklore is to regulate the intellectual property of indigenous peoples
  18. ^ Michael A. Gollin: New rules for natural products research. In: Nature Biotechnology . 17 (9) (1999), pp. 921-922. doi : 10.1038 / 12921
  19. ( Memento from May 24, 2011 in the Internet Archive ) Definition of an ethnobotanical institute
  20. on the related contradictions and problems: Sita Reddy (2006): Making heritage legible: who owns traditional medical knowledge? International Journal of Cultural Property (2006) 13: 161-188.
  21. Traditional Knowledge Digital Library.
  22. ^ Knowledge and Learning Center Africa Region, World Bank (1998): Indigenous knowledge for development. A framework for action.
  23. Peter Drahos: Indigenous knowledge, intellectual property and biopiracy: Is a global biocollecting society the answer. In: European Intellectual Property Review. (EIPR) 22 (6) (2000), pp. 245-250.
  24. Evangelischer Entwicklungsdienst eed 2004 (Ed.): Biopiraten in der Kalahari? ( Memento from July 11, 2016 in the Internet Archive )
  25. ^ Medicinal plants of South Africa. Between overexploitation and cultivation. Pharmaceutical newspaper online 2010
  26. ^ A b c d Muriel Lightbourne: Of Rice and Men. An Attempt to Assess the Basmati Affair. In: The Journal of World Intellectual Property. 6 (2003), pp. 875-894.
  27. ^ A b c d Harsh V. Chandola: Basmati Rice: Geographical Indication or Mis-Indication. In: The Journal of World Intellectual Property. 9 (2006), pp. 166-188.
  28. Keyword: “Cupuaçu” patent application - information for the press. ( Memento of September 7, 2008 in the Internet Archive ) European Patent Office, press release October 27, 2003.
  29. espacenet - Original document
  30. See online documentation of the Workshop on the Local Management of Agricultural Biodiversity in Rio Branco-Acre, from May 9th to 19th, 2002, documented by the NGO, Michael F. Schmidlehner, Jarbas Anute Costa, Líbia Luisa dos Santos de Almeida. Biopiracy in the Amazon: The Cupuaçu Case.
  31. BUKO campaign against biopiracy: New campaign in the fight against biopiracy on Cupuaçu fruit . (2005; PDF file; 116 kB)
  32. Suman Sahai, Prasmi Pavithran, Indrani Barpujari: Biopiracy. Imitations not innovations. Gene Campaign, New Delhi 2007, ISBN 81-901009-9-8 , p. 39.
  33. Wezi Tjaronda: San cry foul over Hoodia trade. In: New Era (Windhoek). March 9, 2006 , BUKO. ( Memento from August 1, 2007 in the Internet Archive )
  34. ^ Environmental Audit House of Commons - Second Report - APPENDIX 7 - Trade Related Intellectual Property Rights (TRIPs) and Farmers' Rights. Session 1998-99. November 23, 1999.
  35. Begoña Venero Aguirre: Traditional knowledge and patents relating to Lepidium meyenii: an example not to be followed. Courier ACP-EU 201 (2003): 37-38.
  36. Amanda J. Landon: Bioprospecting and biopiracy in Latin America: The case of Maca in Perú. Nebraska Anthropologist 1 (2007): 63-73.
  37. Sebastian Bödeker, Oliver Moldenhauer, Benedikt Rubbel: Wissensallmende ( Memento from May 6, 2012 in the Internet Archive ), Attac BasisTexte 15, p. 32; Helga Keßler: Patent tree. In: time online. 46/1995, p. 45.
  38. No patent on neem tree oil. In: Spiegel online. May 10, 2000.
  39. ^ AF Myburgh (2011): Legal developments in the protection of plant-related traditional knowledge: An intellectual property lawyer's perspective of the international and South African legal framework. South African Journal of Botany 77: 844-849. doi : 10.1016 / j.sajb.2011.09.003
  40. ^ Declaration of Bern: Biopiracy> Pelargonium
  41. Roger Chennells (2013): 'Traditional Knowledge and Benefit Sharing After the Nagoya Protocol: Three Cases from South Africa'. LEAD Law, Environment and Development Journal 9 (2): 163-184. PDF
  42. Christoph Then and Thomas Schweiger: Gene, Monopole and "Life Industry". Documentation on the patenting of Leben, 2000. (PDF file; 363 kB) on page 83.
  43. Chronology at ( Memento from October 31, 2007 in the Internet Archive ), accessed on October 22, 2010.