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His designs were registered at the United States Copyright Office in 1997, and appeared online as files in 1998.

In 1997, The Smiley Company filed a trademark application with the United States Patent and Trademark Office.

Dodge's Manual in 1908 documented the reintroduction of "love and kisses" as the number 88.

Gajadhar and Green comment that both Morse code abbreviations are more succinct than modern abbreviations such as LOL.

is a pictorial representation of a facial expression using punctuation marks, numbers and letters, usually written to express a person's feelings or mood.

In Western countries, emoticons are usually written at a right angle to the direction of the text.

They offer another range of "tone" and feeling through texting that portrays specific emotions through facial gestures while in the midst of text-based cyber communication.

The use of emoticons can be traced back to the 17th century, drawn by a Slovak notary to indicate his satisfaction with the state of his town's municipal financial records in 1635, but they were commonly used in casual and humorous writing.It is to be appended, with the full stop, to every jocular or ironical sentence".although there seems to have been a lapse in cultural continuity between the communities.In 2001, Walmart opposed the registration, citing a likelihood of confusion between the Loufrani smiley and a smiley face Walmart had been using since 1990.The USPTO eventually sided with Walmart and rejected The Smiley Company's application, due to widespread use of smiley face designs.The text of his original proposal, posted to the Carnegie Mellon University computer science general board on 19 September 1982 (), was thought to have been lost, but was recovered 20 years later by Jeff Baird from old backup tapes.