You will be given a definition of a task first, then some input of the task.
In this task, you will be presented with a text and a pronoun. You should write an implausible answer to the question of what is the pronoun's reference. Even though there exist multiple wrong answers, we only need a single wrong answer. Position of the pronoun in the text is showed within two "_"s.

He argues ejusdem generis that the Constitution's unenumerated rights (such as the 9th Amendment or the Privileges or Immunities clause of the 14th Amendment) are procedural in nature rather than substantive, thus protecting rights to democratic processes but not rights of a substantive nature. Justice Stone's Footnote Four from United States v. Carolene Products Co. (1938) is a chief inspiration for Ely's theory of judicial review. In _her_ recent book on Hans Kelsen, Sandrine Baume identified Ely as a significant defender of the ``compatibility of judicial review with the very principles of democracy.'' <sep>, Pronoun: her
Output:
Carolene Products Co.