Given the task definition and input, reply with output. In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

battery is to make "physical contact" without causing injury, and that physical contact does not have to be violent in nature. See, e.g., Illinois v. Peck, 260 Ill.App.3d 812, 198 Ill.Dec. 760, 633 N.E.2d 222, 223 (1994) (explaining that 720 ILCS 5/12-3 defines battery as making offensive contact with a victim "by any means," which encompasses spitting at a peace officer). Moreover, a simple battery involving nonviolent physical contact can become "aggravated" by the addition of facts that have nothing to do with physical force. A battery can be aggravated because it causes "great bodily harm," 720 ILCS 5/12-4(a), or because, as here, the victim is a "peace officer," 720 ILCS 5/12 4(b)(6) (2003); see Illinois v. Hale, 77 Ill.2d 114, 32 Ill.Dec. 548, 395 N.E.2d 929, 931-32 (1979) (<HOLDING>); Illinois v. McBrien, 144 Ill.App.3d 489, 98
Holding statements: (A) holding that battery is an inherently included offense of aggravated battery (B) holding that aggravated battery of peace officer encompasses both insulting or provoking contact and battery resulting in bodily harm (C) holding that the evidence is sufficient to sustain a conviction for aggravated battery when the bodily member that is lost or rendered useless in the battery is a tooth (D) holding that aggravated battery is a lesser included offense of manslaughter (E) holding that under maryland common law an assault is an attempted battery an actual battery or a combination of the two
holding that battery is an inherently included offense of aggravated battery