THE LIMITS OF PARODY, IN RELATION TO A COURT CASE REPORT OF URUGUAY
Edgardo Ettlin
1. Parody and its conflicts with Copyright
The
word “PARODY” derives from the Greek “Parodia”, which in turn
derives from “Para” and “Odé”, meaning something like “similar
song”, word that later went on to name any work of burlesque imitation
(although sometimes it has a certain purpose of homage or criticism) of some artistic
work. Very old form of expression, we see it in Literature, in Music, in Theater,
in plastic arts. Parody in Music is not the same as parody with literary
content, or when music has literary content (such as a poetry or a libretto). In
Music the term is used to reuse parts of a work in another, or to adapt it to a
different text than the one originally used, not necessarily for satirical
purposes. When the work is made with parts of different works or different
parts of a work, it already constitutes a “pasticcio” or “pastiche”, a
“scrambled” or a “refrito”. It is around the 19th century that Isaac Disraeli
established the concept of “parody”, especially referred to Literature but
adaptable for all parodies of artistic works, as a work composed on top of
another work, but transferred to a different theme by means of a slight change
of expressions.
A
parody can be made: 1) of a simple historical or legendary episode or
character, or of some event or person of current interest; 2) of an
artistic, academic or technical work (for example, a musical or literary,
theatrical or visual work, or any other particular or composed artistic or
written expression). In turn, parody can be conveyed through literary or
written, musical, acting and visual representations or adaptations,
individually or in combination. For the purposes of these disquisitions,
it is important for us to consider the second: the one based on a written or
artistic work.
Parody
in written and artistic creation implies adapting or using resources from other
people's works. However, unlike simple adaptation or plagiarism, parody is
characterized by:
a)
Because of its purpose:- It has a purpose different from that of
the original work, generally satirical, ridiculous or entertaining (mostly, it
is not necessarily so; eventually trivializing or disrespectful). But it
can also have a purpose of homage, criticism or social, political, moral or
even educational controversy, and even erotic or pornographic. The
characteristic of the parody, especially the one that has literary content, is
that it intends to convey an occasional amusement, or to convey a different
message from that of the original work.
b)
Because of its mechanics:- It is based on a generally known
pre-existing artistic or literary work, in such a way that although the parody
does not have the purpose of being confused with it, taking advantage of it or
parasitizing directly on it, or does not intend to harm economic o moral interests
of the author or of the original work, the evocation or allusion to it is not
absent. In fact, the original work can be the inspiration so that, based on
it, the parody can recreate another object to express a different content of
its own. What's more, the adaptation or the resource that can evoke a
pre-existing work is even of the nature of parody, because with it a very
special way of communicating its message is proposed. However, parody as a
medium. As we said, it pursues an object different from the original work
that it evokes or that gives it circumstantiality. The parody is based
more on the plot and thematic idea of the original work that gives it a basis
or pretext, that on its texts, nevertheless can take them literally in certain
passages, with the brake that it must take care that it does not end up
becoming an adaptation or plagiarism. of the protected text.
c)
Due to its occasionality:- It has a rather fleeting or occasional
purpose. Creativity is not considered nor is its essence, although it
cannot be denied that transposition and re-creation can have their overtones of
creativity. This also goes hand in hand with the purpose of the parody,
which has a more immediate meaning as it aims to be entertainment, or to provoke
(especially when it takes advantage of satire or humor) the predisposition of
the public “lowering its defenses” looking for an emotional impact (which can
range from ridicule to causing animosity) in which a critical, moral or
instructive message is inherent, or even an incitement. But in principle,
that is the end of it. Parody is also not usually proposed in principle,
and it is not its nature, to be successful or commercially exploited; although
it cannot be ruled out that eventually it will not have it. Although it
would not cease to be in a certain way an artistic or even striking expression,
the parodic work does not necessarily intend to be an original work, with artistic
content in itself or with high technique, or that intends to transcend the
centuries as such. Rather, it has a popular and popularizing character
-“popular art”?-). It could be considered, to paraphrase Carmelo
Castiglioni's terminology, a “work not-work”, or more generously a “meta-work”.
But, is parody a “work” in itself? Because sometimes it can end up
constituting a true work by itself.
It
has been argued that parody, whether or not constitutes itself a work, a “non-work”
or a "meta-work", can mean an artistic expression that would be
permissible within the freedom of expression, and that value sometimes collides
with Intellectual Property rights. Since parody supposes the use, intervention
or re-creation of a pre-existing work, and although it does not intend to take
advantage of the original work directly but rather to transmit a message or a
meta-message with different content by taking elements from it, conflicts may
arise between the original creator and the parodic re-creator. Now, since
it is questioned whether or not parody would be a form of artistic creation,
what should be the scope and limits of it in relation to Intellectual Property
rights. These conflicts will normally end up in Justice, and the
Judge must balance these rights to allow their play as much as possible, within
the framework of the Law. Tolerated by the custom of society, the common person
does not associate this parodic adaptation with an intention of plagiarism or
illicit reproduction of works outsiders, nor does it consider it a bad
practice; though for the creator of an original work, having his work
parodied can be a really annoying experience.
Justice
usually finds in some cases what we could call “good parodies”, in which
although the imitative or transposing purpose is clear, the parodic work by its
nature, although it may provoke an evocation of another original work, it does
not pretend to be another work because it intends to exhaust itself in being a
vehicle that transmits a ridiculous, moralizing or controversial content,
different from that of the original work, without necessary commercial
intention. We have extracted these criteria to conceptualize the
"good parody" from some European judicial precedents (“verbi gratia”,
Judgment of the Court of Appeals of Versailles dated 16 March 2018. Judgment of
the 15th Section of the Provincial Court of Barcelona of 10 October 2003.
Judgment of the Provincial Civil Court of Madrid Section 28 of 23 November 2018.
Judgment of the Provincial Civil Court of Madrid Section 13 dated 2 February 2000).
But
we also have the "bad parodies", which are intended to parasitize or
revile the original artistic creation by lowering or diluting its content, or
are intended to be a mere adaptation without that ridiculing, critical or
moralizing purpose, to transmit content or hateful communications, or that
incite resistance or rebellion. On many occasions, they seek an economic
or commercial benefit by taking advantage of an association that the public can
make with the original work.
However,
the Judge in the assessment of a work presented as a parody in confrontation
with a protected literary or an artistic work, must also be in accordance with
what the Law or the international norms of each country tell
him. Depending on the systems, the Judge has more or less margin to
balance any of these rights. The criteria for balancing them can be found
in the so-called “Three-Step Test” (art. 9.2 of the Berne Convention, art. 13
of the Agreement on Trade-Related Aspects of Intellectual Property Rights, art.
10 of the WIPO Copyright Treaty, article 21 of the Andean Decision No.
351/1993), which although it is aimed at the legislation of the States, can
guide the Jurisprudence: 1) the limits and exceptions must be established in
the legislation; 2) it must be analyzed if the doubtful use alters the
normal exploitation of the work; 3) it should be studied whether or not
the doubtful use is fair with respect to the interests of the author.
In
classical international Intellectual Property Law, arts. 2.3 and 12 of the
Berne Convention protect adaptations (within them, we understand parodies even
if they are not named that way) as long as they have the authorization of the
original author. The Berne system, however, does not prevent States from
establishing eventual exceptions “provided that such reproduction does not
conflict with a normal exploitation of the work and does not unreasonably
prejudice the legitimate interests of the author.” (art. 9.2 thereof, see
also art. 13 of the Agreement on Trade-Related Aspects of Intellectual Property
Rights, and art. 10 of the WIPO Copyright Treaty; all already cited) for uses
such as parody. The Universal Copyright Convention does not change things.
In
the European Union, the initial provision states that the States may establish
exceptions or limitations to the protection of Copyright in the case of “use
for the purpose of caricature, parody or pastiche” (art. 5.3. “k” of
Directive No. 2001/29/EC on the Harmonization of Certain Aspects of Copyright
and Related Rights in the Information Society). However, Directive No.
2019/790/EC on Copyright and Related Rights in the Digital Single Market
recommends that “Users should be allowed to upload and make available
content generated by users for the specific purposes of quotation, criticism,
review, caricature, parody or pastiche”, anticipating the possibility that
the Member States guarantee that users can be covered as an exception or
limitation to Copyright, when uploading and making available content generated
by users in the services to share content online, when it comes to “use for
the purpose of caricature, parody or pastiche” (Recital 70. and art.
17.7.inc. 2.“b” of said Directive). Now, the border of what is meant by “parody”
and how much or how it will be allowed, will be given by the legislation of
each European country.
The
art. 51.a of the German Copyright and Related Rights Protection Act states
that “The reproduction, distribution and public performance of a published
work for the purpose of caricature, parody and pastiche is
permitted. Permission… includes the use of an image or other reproduction
of the work used, even if it is protected by Copyright or a related property
right.”. In other words, parody is established as an exception to Copyright
protection. With this freedom, we try to give priority to balancing Intellectual
Property rights with the rights of freedom of expression and artistic freedom,
trying to combine individual and social interests, without detriment to each
other.
In
Spain, the art. 39 of Royal Legislative Decree No. 1/1996 (Intellectual
Property Law) establishes that “The parody of the published work will not be
considered a transformation that requires the consent of the author, as long as
it does not imply a risk of confusion with it or infer damage to the original
work or its author.” In Latin America, it is also the criterion of
art. 47 of Law No. 9,610 of Brazil on Copyright, and similar in
art. 49 of Legislative Decree No. 822 on Copyright of Peru, and in art. 16
literal "d" of Colombian Law No. 1915/2018 amending Law No.
83/1982. In France, art. L122-5 no. 4 of the Intellectual
Property Code states that the author cannot prohibit parody, pastiche and
caricature “taking into account the laws of the genre”. In the
cases of these Laws, the Judge can make a better interpretive and creative
balance, according to each case and the nature of the legal assets at stake.
In
the United States, where there is no specific legislation on parody, Judges are
also free to balance, in examining parody in relation to Copyright, more freely
the individual and social interests involved, and some they have postulated
that it is protected by the First Amendment of the US Constitution that
guarantees freedom of expression, but the basic criterion is that the parodic
use is fair. In this sense, the situation must be analyzed according to
Title 17 Section 107 of the United States Code (“Copyright Law”), to
evaluate as fair use criteria (“fair use”): “1) the purpose and
character of the use, including whether such use is of a commercial nature or
is for nonprofit educational purposes; 2) the nature of the copyrighted work; 3)
the amount and substantiality of the portion used in relation to the
copyrighted work as a whole; and 4) the effect of the use upon the potential
market for or value of the copyrighted work.”. The Jurisprudence of
that country coined a distinction depending on the parody target of the
original work (“target parody”), in which the parodist expresses himself
about the original work transforming it into a mocking, satirical, critical or
homage version, a mere adaptation or use of foreign texts or arts, or if the
work parody is used to redirect the original work by relating it to, or
incorporating, events or themes of political and social interest for which it
was not designed (“weapon parody”). In this last case, the North
American jurisprudential vision is more reluctant or circumspect, with respect
to considering it a fair use of parody. On the other hand, the Court of
Justice of the European Union, interpreting article 5.3. “k” of Directive No.
29/2001/EC, pointed out in case C-201/13 that the meaning and scope of the term
“parody” must take into account its usual meaning in current language, being
enough that it evokes an existing work although it can be differentiated from
it, and it can show a humorous manifestation without interest that it is
projected in the parodied work itself or that it is projected on other
objectives, such as political, social or people, without distinguishing between
“target parody” or “weapon parody”, having to respect a fair balance
between the interests and rights of the owners and the freedom of expression of
who invokes the exception of parody; what is left to the discretion of
each court in each specific case.
In
Uruguay, the parody of a work without the authorization of its author is
prohibited. This is what the arts. 35 and 44 lit. “A” no. 4 of
Law No. 9.739 mark (“Those who recast, copy, extract, adapt, abridge,
reproduce or parody original works, have ownership of those works, provided
they have been done with the authorization of the authors”; “They are
cases of illicit reproduction: The… adaptation or arrangement of a work without
the authorization of the author”). In our opinion, our regulations are
not interested in the distinction between adaptation, extraction, or
parody; they only care about the relevance that there may or may not be in
the similarities and coincidences between the texts. The question is
whether by “adaptation” we also include parody (like parody could be a sort of
adaptation); certain jurisprudence of our country would seem to have
considered it that way, as we will see in the following Section. It is
necessary to point out that the Uruguayan Judge, assuming that the parody is
illegal if it is not authorized by the author, cannot distinguish between “good
parody”, or “bad parody”, or “object parody”, or “weapon parody”, seeming to
have little room left to assess whether fair use of the unauthorized parody was
made to establish a Copyright exception. The approach is concentrated for
the Uruguayan Magistrate in two aspects, whose order of factors will not
alter the product: a) if the use for adaptation or parody was or was not
authorized; b) if there are transcendental similarities or not, of content
between the protected work and the questioned text. Now, art. 45
no. 4º of the Uruguayan Law allows “transcripts made for the purpose of
comment, criticism, or controversy”; It is worth asking if it could be
considered as fair use, the parody that has those purposes within a flexibility
of the term “transcriptions”. In our opinion, it is not prohibited in Uruguay to parody or to adapt a work of public domain, subject to eventual State fees (arts. 34, 40, 42, 60 and 61 of Law No. 9,739).
The
arts. 2nd, 25, 26 and 36 of Law No. 11.723 of Argentina on the Legal
Regime of Intellectual Property, do not allow parody without the consent of the
author, in the same way as Uruguay. If this is authorized when the original
work is in the private domain, the parodist has a co-author's right unless
otherwise agreed, although if he parodied a work in the public domain “he
will be the exclusive owner of its adaptation, transportation, modification or
parody, and will not may object to others adapting, transporting, modifying or
parodying the same work”.
These
disquisitions allow us to handle some elements to consider for the analysis of
the jurisdictional case that we will address.
2.
The “Fischer Case”. A conflict between Author's Rights and ¿Artistic
Freedom?, brought before the Courts.
In
Uruguay, the writer Diego Fischer, author among many works of the book “Al
Encuentro de las Tres Marías. Juana de Ibarbourou más allá del mito” (“To
the encounter of the Three Marias. Juana de Ibarbourou beyond the Myth”),
sued RS as Director of the group of Parodists “Z” and MV as lyricist
author of the musical-theatrical parody work “Juana de América”, which
was presented in performances of the 2016 Carnival season. Damages were sued
for Extracontractual Liability, arguing that the parody work “Juana de
América” constituted an illicit transformation and adaptation, not
authorized by the actor, of the book “Al Encuentro de las Tres Marías…”,
which took some parts of this work for vulgar purposes, harming the literary
merits of the original work, a work of historical novel that rescues unknown
and private aspects of the writer Juana de Ibarbourou not treated until
now. The defendants allege that the libretto for its creation had a
different argument from that of Fischer's book, which chronicled parts of Juana
de Ibarbourou's life that anyone could record, and that two literary works
(one was Fischer's) and an audiovisual documentary had been taken as a source
of information for the preparation, and that an illicit adaptation of Fischer's
book was not made in the theatrical parody; In addition, those required
disputed the existence of the damages that were claimed.
The
litigation dealt with the core of the debate and judgment, on the literary
content of the parody work, in relation to the original and protected work (dated
in time prior to the doubted one, obviously).
It
is necessary to point out that in Uruguay, the “Parodistas” or better
said, the “Parodismo”, constitute a burlesque musical-theatrical genre
of the Uruguayan Carnival, whose creation has a very transitory time of
communication (performances in the Carnival season whose shows in our country actually
extend between January and March of each year, although sometimes they usually
do performances in the rest of the year). This genre usually uses and
adapts foreign music and texts for its creation on the occasion of its own
works, with generally burlesque purposes, although in some cases this has
transcended that character. It is precisely the characteristic and peculiarity
of that expression, the use or adaptation of artistic resources that are
partly foreign (especially musical -popular songs or of the moment- and certain
texts -possibly transcribed or paraphrased-) for the preparation of the works
they represent; hence their name “parodists”. Parodism had
popular and “amateur” origins, although now it has been improved and
even artistically professionalized. It never was and it is never customary
for parodists to request permission to use other people's works, and in fact
this has been an accepted practice in the country, which was even recognized by
the General Association of Authors of Uruguay (AGADU).
Another
genre of Carnival such as the Murga has similar peculiarities to the parodists,
since they are used to (and it is part of their traditional mechanics since
long ago) using in their music, melodies of songs of the moment or well-known,
and on occasion, even fragments or passages from texts by other authors.
Returning
to the Court case in approach, we have to emphasize that the author and the
representative of the doubtful text, used by the group of parodists in their
shows, did not have authorization from the plaintiff Fischer for any purpose,
to eventually adapt or parody his novel.
It
was necessary to analyze, for the purposes of what is required by national
legislation insofar as it does not allow parody of protected works without the
authorization of the author, and assuming that this authorization had not
existed, only if the questioned work had similarities with the protected work
or not. In the assessment of the evidence, the texts (the original and the
one doubted as illicit) were submitted to an expert opinion by the National
Academy of Letters.
The
opinion of the National Academy of Letters analyzed both texts, examining the
frequency and extension of the similarities identified (quantitative elements),
as well as the importance given to the episodes and the words used by the
author of the original work (qualitative elements), in the questioned
text. And it was found that the questioned text contained paraphrased or
literal reproductions, similar to those of the protected work. It was also
found that the situations raised and the selection of facts in the parody “Juana
de América” were also significant aspects that had been highlighted or
constituted a novel revelation in the original work of the novel. The
expert opinion showed that behind the doubtful text, the work of the claimant
could be recognized as the implicit text or hypotext.
With
which it was concluded that the theatrical parody was really, more than a
parody, a mere adaptation of the protected novel of Fischer. It could even show
us that it even took on signs of plagiarism, in the comparison of the
similarities and the findings that there were in that sense.
We
must emphasize that the expert analysis focused on the comparison of the
literary analysis from an academic technical point of view, rather than
analyzing what the purpose of the parodied text was. It could also be
criticized that the comparative analysis should not have been done from the
point of view of a “literate” or literary expert, but should have been
evaluated from the point of view of an average public that consumes books and
shows that obviously the National Academy of Letters does not represent, and in
which as a common observer the Judge should be placed according to prudent
standards of medium sensitivity, when assessing the background in the
opportunity to pass sentence.
The
defendants were aware that they had not requested authorization from anyone for
the parody “Juana de América”, although they tried to postulate that it
is not customary in the genre of Carnival parody to request authorization from
the owners of the works to use or adapt them in their shows.
Judgment
No. 26/2019 of the 18th Civil Court of First Instance and second instance
Judgment No. 44/2020 of the 2nd Civil Court of Appeals ended up lauding the
issue, making the defendants responsible for the damages caused to the actor
Fischer, on the occasion of the adaptation or parody questioned as illegal.
Both
Courts agreed with the expert evidence, in that the doubted parody work was a
partial adaptation with non-direct use (because it was a parody) of the
creation of a pre-existing work. In our opinion, it was no longer a simple
pleasantry about the life of a character (a writer), going beyond satire to
become the adaptation of another work under the pretext of wanting to parody
the life of a character, using without authorization and therefore illegally,
an alien text. Proceeding that had even generated an economic product for
the adapter for the reproduction and for the director of the work for the
representation (there was even interference in the text by introducing a
character), but with injury to the rights of the legitimate author and the
integrity of his work.
Regarding
the issue that it is not customary to request permission from authors of
original works to use them in Carnival parodies, the acting 2nd Civil Court of
Appeals stated that this is not an excuse, since custom is not a formal source
of Law nor does it constitute rights (art. 9 of the Civil Code) in Uruguay; and
that therefore this argument could not be considered.
A
previous and circumstantial statutory problem was cleared up, since all the
litigants were partners of AGADU and it was understood that the lawsuit for
damages derived from non-contractual liability was not hindered by art. 12
of the Statutes of said association in that they were not problems between
partners “as a direct consequence of their quality as such” (in which
case they must be submitted to an Arbitration Court of the association), and
taking into account the expert opinion that clearly recognized the work of the plaintiff
as the basis of origin for the adaptation or parody in question, and not other
sources (without finding in it other reference documents that the defendants
said had been used), once the responsibilities of the defendants for the
aforementioned illicit reproduction were determined, the different items to be
compensated were defined.
In
this regard, we must specify that in Uruguay the examination of parody is not
necessarily verified according to the "Three-Step Test", but rather
by adhering to the following more demanding criteria:
a) the
Judge cares to establish the similarities and coincidences between the
confronted texts, to assess whether or not the debated text is an adaptation or
parody (in this case, it is not necessary to postulate conceptual distinctions
between “adaptation” or “parody”, because both practices are prohibited by the
Law -articles 35 and 44 lit. A number 4 of Uruguayan Law No. 9.739 -). For
which and without prejudice to his criteria, the expert opinion can illustrate
and guide the reasoning of the Judge without having to be servile to him;
b)
having considered that the questioned text is a parodied or adapted text of the
original, it must be determined whether this adaptation or parody was
authorized by the author of the owner of the work;
c)
being admitted as fact in “the Fischer case”, or in its case being proven
(arts. 137 and 139 of the General Code of Process), that express and documented authorization
was not given in its case by the owner of the original work the author of
the questioned text to adopt or parody it, the questioned work must be
considered illicit;
d)
The unauthorized (illicit) use of a work by means of adaptation or parody
merits consideration of the appropriateness of the damages that may have been
inflicted, and if applicable, imposes the obligation to compensate the original
author for the damages that may have been caused (articles 1319 of the Civil
Code and 51 of Law No. 9.739).
In
both instances, the lyricist MV and the director of the parodist group RS were
sentenced jointly and severally (in reality it should have been “in solidum”
because the blame for the co-participation was established by way of guilt, not
fraud -art. 1331 of the Civil Code -) to pay the plausible price that would
have entailed a license or transfer of Copyright to adapt the text, as
consequential damages, as well as a civil fine as punitive damages (art. 51
inc. 1º “in fine” of Law No. 9.739). Although in the first instance they
were sentenced to pay an amount of US$8,000 for consequential damages, and
eight times that amount for civil fines or punitive damages, in the second
instance these values were lowered to US$ 6.500 for the hypothetical license
or transfer (consequential damage) and once that value for a civil fine (punitive
damages). A sentence imposed in the first degree on MV to pay 50% of what
was received for representations through AGADU (considered but not sentenced in
the first instance sentence, although it was increased by the item in that
stage before a request for clarification and extension by interlocutory ruling
of the 18th Civil Court No. 981/2019), it was eliminated in the second instance
when it was determined that material damage was already contemplated in the
conviction for consequential damage.
Likewise,
the defendant RS was ordered to pay the claimant Fischer an amount for
non-pecuniary damage, not for the illicit reproduction, adaptation or parody,
but for the impairment that would have been inflicted by damaging and degrading
statements that he made against the claimant in the press. (what was valued “in
re ipsa”); sentenced to pay US$ 10.000 in the first instance, this figure
was lowered to US$ 7.000.
3. Some considerations on the “Fischer case”
In
our opinion, the sentences that awarded this litigation balanced correctly,
within certain difficulties and inaccuracies that sometimes supposes a Justice
not specialized in matters of intellectual property, the facts, the subjects
and the interests in conflict; as well as plausibly granted the legitimate
successor, within what can always be debatable and within the prudent
discretion that the courts usually take to assess the items of compensation for
damages, the protection that the regulations on Copyright and related rights
protected him . All this provided the courts with the corresponding
evidence, and even taking into account a valuable evidence instrument to weigh
the comparison of the written texts in confrontation, such as the expert
opinion used, produced by the National Academy of Letters.
It
is true that it is not common practice, although custom does not give or
generate rights, that Parodists or Murgas request proper authorization (if
possible in writing, verbal is not enough) to use lyrics or texts that are not
their legitimate authors. Perhaps because it is part of the nature and
tradition of these genres in their artistic expression, of popular roots, and
because major authorial conflicts had never arisen until this case.
Will
this trial mean an instructive so that from now on due care should be taken by
the artistic expressions of the Uruguayan Carnival in terms of avoiding
authorial conflicts? Should this really be necessary, when such practices
in principle do not intend or intend to unduly infect or parasitize protected
works, or harm their legitimate authors?
Should
the artistic expressions of the Murgas and parodic groups be protected, and
should their imitative, re-creative or adaptive practices of other people's
works be considered for the purposes of these expressions, within the freedom
of Art, which is a manifestation of the freedom of thought and expression of
thought? Strictly speaking, National Law does not allow it, because
parodic practices without the authorization of the owner or the beneficiaries
of the original work are forbidden. Should the limiting norms be
considered unconstitutional, or should the protection of rights be emphasized
more on the freedoms of expression and creativity, than on Intellectual Property
rights?
It
all depends on the glass with which you look. However, any response that
wants to be given (which we leave open and subject to the peculiarities of each
specific case) must be framed within a solid foundation of Law. Everything
within the law, nothing outside of it.
Montisvidei, die
secunda mensis Julii A.D. MMXXI
