where u is the displacement and f 2 L( ) is the body force. Some of the simplest plate elements such as the Morley element (cf. [29]), the Zienkiewicz element (cf. [3]), the Fraeijs de Veubeke element (cf. [22]), the incomplete biquadratic element (cf. [34]) and the Adini element (cf. [1]) are nonconforming. Overlapping domain decomposition methods for nonconforming plate elements were studied ...