O'Neill defines a curve as "A curve in $E^3$ is a differentiable function $\alpha : I \rightarrow E^3$ from an open interval I and stipulates that the velocity has to be everywhere nonzero. A plane curve in $E^3$ is a curve that lies in a single plane.

A "curve" made of two circles touching one another crosses orthogonally at three points. Does this mean O'Neill was wrong?