Second, here too, the main references in the table are to the introductory chapter and the literary review, which includes references to relevant sources (even in the reference to page 19 of the defendants' article, there is no novelty that is not written on the introductory pages). Not only that, but with respect to one of the quotes from the defendants' article that was presented in the table, the explicit reference to the plaintiff's article together with Prof. Nota was omitted. Thus it was written in the defendants' article:
"The somewhat flexible and ambiguous definition of the Process concept in the ISO 9001 and ISO 9004 does not address the level of process complexity of global organization [4], including their systemic complexity"
On the other hand, in the quotation of the sentence in the table in the opinion, the reference to the source [4] - a 2018 article by the plaintiff together with Prof. Neta - was omitted:
Bashan A., Notea, A (2018). A hierarchial model for quality management systems in global organizations, international Journal of Quality & Reliability Management, 37(7), 2001-1398.
Third, the need to expand the procedural approach to the aforementioned ISO standards for the quality management of global organizations was further brought up in defendant 1's research proposal, from January 2021, i.e., about six months before the plaintiff submitted Articles 8 and 9 to defendant 2. In other words, the conditions of access to the sources from which the copying was allegedly carried out (a condition stated in the Almagor case as cited above) are not met. In this regard, I will refer to, for example, page 7 of 23 (defendant 1's research proposal), in which defendant 1 translated into English a sentence from the plaintiff's book from 2014, the content of which is almost identical to the quote quoted above from the defendants' article, regarding the need to expand the procedural approach. Although the defendants' article referred to an article in English by the plaintiff and Prof. Nota, and not to the plaintiff's book in Hebrew from 2014, the important point is that the details of the source from which the trial was taken, as a source created by the plaintiff, remain intact.