1. 69) For example, although his opinion is not binding on Japanese courts, the Judicial Research Officer of the SCJ (Saikou Saibansho Chousakan) explains that the SCJ did not adopt the identical rule theory. With regard to the 1998 judgments, see Y Kawabe;Saik? Saibansh? Hanrei Kaisetsu Heisei,1998
2. Sake Symposium in Tokyo and Kyoto