People v. Lloyd (1998) 17 Cal.4th 658 is the principal case on the issue of compliance with the requirements for an appeal on noncertificate grounds. (Lloyd, supra, 17 Cal.4th at p. 664.) In Lloyd, the defendant's notice of appeal was drafted on a form. It bore the handwritten notation: "'Rule 31(d).'" It contained a printed sentence: "'Defendant hereby appeals from the judgment. . . .'" The printed word "judgment" was crossed out and the word "sentence" was handwritten above it. (Lloyd, supra, at pp. 664-665.) Lloyd observed that the notice of appeal was arguably insufficient because it did not expressly state, in the words of rule 31(d), second paragraph, that the appeal was based on grounds occurring after the plea that did not challenge the plea's validity. (Lloyd, supra, at p. 665.) Alternatively, Lloyd observed that the notice was arguably sufficient because it stated impliedly, through its handwritten references to rule 31(d) and "sentence," that the appeal did not challenge the validity of the plea. (Lloyd, supra, at p. 665.) Lloyd allowed the appeal to go forward. (Lloyd, supra, 17 Cal.4th at p. 665.) "There is a requirement that a notice of appeal must 'be liberally construed in favor of its sufficiency.' (Cal. Rules of Court, rule 31(b) now rule 30(a)(4).) There is no requirement that it must make the requisite statement of basis expressly rather than impliedly. On balance--and in light of the People's concession at oral argument--the notice of appeal may be deemed sufficient." (Lloyd, supra, at p. 665.) Lloyd does not articulate the exact concession made by the People at oral argument. In the context of the paragraph's language, the People appear to have conceded generally that a notice of appeal could imply the requisite statement of basis required by rule 31(d), second paragraph, rather than expressly state that basis. However, a subsequent opinion construed the People as making the more specific concession that defendant Lloyd's appeal raised only post-plea matters. (People v. Way (2003) 113 Cal.App.4th 733, 736.) Subsequent to and distinguishing Lloyd, People v. Way, supra, 113 Cal.App.4th 733 dismissed an appeal that stated only that it was "'from the final judgment of conviction. '" (Id. at p. 734.) It concluded that the notice of appeal differed "materially" from the one in Lloyd because it did not impliedly state that the appeal was solely on noncertificate grounds. (Way, supra, at p. 736.) It was from a "judgment" only; it did not refer, as did the Lloyd notice of appeal, to the rule applicable to noncertificate grounds, nor, unlike Lloyd, was it patently from the defendant's sentence only. Finally, unlike Lloyd, the Attorney General did not concede that the notice fell within an exception to a defendant's duty of full and timely compliance with section 1237.5 and rule 31(d). (Way, supra, at p. 736.) "The notice of appeal 'from the final judgment of conviction' cannot be liberally construed as impliedly based solely on noncertificate grounds. Because defendant failed to fully and timely comply with section 1237.5 and rule 31(d), we cannot proceed to the merits of the appeal, and it must be dismissed. " (Way, supra, at p. 736.)