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Seeking to prevent Walmart from using any smiley face design, Nicolas Loufrani next sued Walmart in federal court in 2009, while claiming that his smiley face was "readily distinguishable" from Walmart's.

The case was closed in 2011 when the two parties agreed to settle out of court.

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.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.

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The September 1962 issue of MAD Magazine published an article titled "Typewri-toons." The piece, featuring typewriter-generated artwork credited to "Royal Portable," was entirely made up of repurposed typography, including a capital letter P having a bigger bust than a capital I, a lowercase b and d discussing their pregnancies, an asterisk on top of a letter to indicate the letter had just come inside from a snowfall, and a classroom of lowercase n's interrupted by a lowercase h "raising its hand." In 1963 the "smiley face", a yellow button with two black dots representing eyes and an upturned thick curve representing a mouth was created by freelance artist Harvey Ball.

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