Given the task definition, example input & output, solve the new input case.
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.
Example: He grew up in Evanston, Illinois the second oldest of five children including his brothers, Fred and Gordon and sisters, Marge (Peppy) and Marilyn. His high school days were spent at New Trier High School in Winnetka, Illinois. MacKenzie studied with Bernard Leach from 1949 to 1952. _His_ simple, wheel-thrown functional pottery is heavily influenced by the oriental aesthetic of Shoji Hamada and Kanjiro Kawai. <sep>, Pronoun: His
Output: Bernard Leach
Based on the text, his refers to MacKenzie and Bernard Leach is a good incorrect answer.

New input case for you: 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.