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The Sone decision reinforced a standard, often quoted from the earlier case Delafield v. Parish , 25 N.Y. 9, that sets a relatively low bar for capacity compared to other legal competencies. SONE-174

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In the world of industrial design and consumer electronics, managing noise pollution is critical. A "sone" is defined such that (the loudness level of a 1,000 Hz tone at 40 dB SPL). Perception of Loudness