Actual notice could take the form of a letter to the accused infringer, particularly calling his attention to the published application (First Years, Inc. v Munchkin, Inc. (W.D. Wis., 2008)). However, the direct intervention of the patent owner is not required if the accused infringer learned of the application on his own (K-TEC, Inc. v Vita-Mix Corp. (D. Utah, 2010)). Yet merely being supplied with the application in a collection of thousands of documents need not be considered actual notice (Arendi Holding Ltd. v Microsoft Corp. (D. Del. 2010)). It may be sufficient to alert the accused infringer of the published application without pointing out the “specific manner by which a defendant is believed to be practicing the inventions” (First Years). Applicants should consult an attorney before notifying an infringer of a published application, as a targeted patent claim analysis may be needed in states with anti-trolling legislation.