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After the successful launch of our website, we have started looking for the graphic designers, who are well versed with the marketing and promotional methods. So, we are offering this wonderful design to those graphic designers who can deliver outstanding results., e.g., Union Labor Life Ins. Co. v. Crothers, 813 F.2d at 135-36; Kroblin Refrigerated Xpress, Inc. v. Pitterich, 805 F.2d at 96. Thus, for the sake of clarity, this court en banc has previously held that this circuit's precedents impose a duty on the parties before the court to present their legal positions in terms that are intelligible to a court. See Gipson, 964 F.2d at 450. This court en banc also has held that a district court must apply this court's precedents as they stand, and it must not create precedents that restrict the legal positions of the parties in future cases. See United States v. Ramos, 961 F.2d 1003, 1008 (1st Cir.1992). We have not, however, yet determined what it means for a party to present its position in terms that are intelligible to a court, or what sort of "concession" by a party will so satisfy this requirement. 15 The situation presented in this appeal is analogous to that presented in Union Labor Life Ins. Co. v. Crothers, 813 F.2d at 136, in which this court held that the defendant had waived its right to challenge the sufficiency of the plaintiff's jurisdictional allegation by failing to present its position in terms that were intelligible to the court. In Crothers, the plaintiff filed suit in federal court, alleging jurisdiction pursuant to the Labor Management Relations Act, 29 U.S.C. §§ 141 et seq. (1988). The defendant claimed that the district court lacked jurisdiction because the plaintiff had failed to make a jurisdictional allegation in the manner prescribed by section 301(a) of the LMRA. 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