|
|
Hi, AfDers
and friends,
President Obama has promoted three Bush regime
negotiated "Free
Trade Agreements"
with So. Korea,
Panama and
Columbia recently
as an important
step to create
jobs here in the
US. In fact,
he included
approval in his
job creation
address to
Congress a few
days ago.
While we know that
these agreements
will result in a
net loss of jobs
in the case of the
So. Korean
agreement and that
the economies of
Panama and
Columbia are so
small that very
few jobs will
result, we
sometimes can feel
that, aside from
the jobs, these
agreements are not
of much
importance.
I offer the below
to show the
importance of
strongly opposing
these
agreements.
The World Trade
Organization (WTO)
has reached two
new decisions this
month which
further empower
corporate decision
making, overriding
local decision
making in favor of
decisions made at
the international
level by privately
empowered WTO
trade tribunals. A
third decision is
expected within
days.
The three
decisions involve
labels of Dolphin
Safe Tuna (we
can't require such
labels anymore),
efforts to reduce
teen smoking (the
US had, among
other actions,
banned the sale of
clove and other
types of favored
cigarettes as
being "trainers"
by cigarette
companies to get
youth addicted to
smoking), and
country of origin
labeling of beef (
the US required
country of origin
labels after the
mad cow and e.coli
scares of the
1990s).
Whereas prior to
the advent of the
WTO, either
Americans states
or the US Congress
was able to decide
on these types of
rules, now the WTO
decides with no
recourse back to
the American court
system. With
every such
decision, our
ability to be a
sovereign people
is
diminished.
Sovereignty
indicates who gets
to decide.
It is clearly not
We, the People any
more.
The three FTAs
being promoted now
by President Obama
contain the same
type of clauses
contained in the
WTO agreement
sited as the basis
for their
anti-democratic
decisions.
Those clauses are
known as Technical
Barriers to Trade
(TBT). Only
the So. Korea,
Panama and
Columbia
agreements will
allow foreign
corporations to
directly sue in
private trade
tribunals for loss
of profit due to
perceived
violations of
TBT. Under
the WTO rules,
corporations were
not directly
empowered to sue;
they had to get
their national
governments to act
on their behave.
In the tuna case,
Mexico sued.
In the tobacco
case, Indonesia
sued. And Canada
and Mexico sued
regarding the
County of Origin
rules.
ACTION
REQUIRED NOW!
Move now to stop
the web of
corporate power
from attacking
democratic
decision
making. Call
your US
Representative and
US Senators and
demand that they
vote against the
US Korea, US
Columbia, and US
Panama Free Trade
Agreements. Click
here to get
contact info.
David
e. Delk,
President |
Alliance for
Democracy |
112 NE 45th
Ave, Portland
OR 97213 |
503.232.5495 |
www.afd-pdx.org |
Today,
U.S. efforts
to reduce
dolphin deaths
by corporate
tuna fishers
through
dolphin-safe
labels on tuna
were
found to
violate the
WTO. This
follows last
week's ruling
that
U.S. efforts
to reduce teen
smoking
violated the
trade
organization's
rules. These
smackdowns of
major consumer
regulations
will be
followed by a
third in the
near future,
when the WTO
is expected to
rule against country
of origin
labeling for
beef.
What
this ruling
means for
consumers and
dolphins
When
the WTO rules
against a
country's
policy, that
country
has to change
the law to
comply, or
risk trade
sanctions.
The
U.S. will have
to get rid of
the
dolphin-safe
labels, or
water down the
policy to
Mexico's
satisfaction.
Mexico's
long-standing
position
(reiterated in
this case) is
that it should
get to receive
a dolphin-safe
label, even
though tuna
corporations
there use
methods to
capture tuna
that are
dangerous for
dolphins.
The
U.S. currently
defines
"dolphin-safe"
as tuna not
caught using
dangerous
purse-seine
nets anywhere
in the world.
For tuna
caught in the
Eastern
Pacific, a
unique region
where dolphins
and tuna swim
together,
additional
steps are
required to
earn the
label.
Shipping
fleets of the
U.S. and many
developing
countries
(like Ecuador)
operating in
the Eastern
Pacific have
been able to
meet these
higher
standards,
thereby giving
greater
assurance to
consumers that
their tuna
purchases are
not harming
dolphins.
In
contrast, much
of the Mexican
fleet has
chosen not to
take such
steps. Mexico
has advocated
use of a
distinct
standard that
even the WTO
acknowledges
is weaker than
the U.S.
standard. The
WTO ruling
wrote of that
distinct
standard:
...
taken alone,
it fails to
address
unobserved
adverse
effects
derived from
repeated
chasing,
encircling and
deploying
purse seine
nets on
dolphins, such
as separation
of mothers and
their
dependent
calves,
killing of
lactating
females
resulting in
higher
indirect
mortality of
dependent
calves and
reduced
reproductive
success due to
acute stress
caused by the
use of
helicopters
and speedboats
during the
chase. 7.739
We also note
that, to the
extent that
the AIDCP
standard
addresses
setting on
dolphins and
not other
fishing
techniques
that may also
result in
adverse
effects on
dolphins, it
would also not
provide an
effective or
appropriate
means of
fulfilling the
US objectives
in this
respect.
Nonetheless,
the WTO ruled
against the
U.S. standard.
(We explore
more of the
details of the
ruling below.)
Initial
reports
indicate that
the Obama
administration
will appeal
the ruling,
although the
track record
of successful
appeals is
very limited
and the WTO
rules against
challenged
policies 90
percent of the
time.
The
broader worry
is that this
ruling leaves
the door wide
open to
attacks on
similar
environmental
and consumer
policies - not
only in the
U.S., but all
WTO member
countries.
What
this ruling
means for
trade policy
All
three of these
cases have
something in
common: none
of them
related to
efforts by the
U.S. to
intentionally
discriminate
against
foreign goods,
nor to protect
our own
producers.
Indeed, in the
beef and
dolphin cases,
no
discrimination
could even be
proved. (In
the smoking
case, a
finding of
"discrimination"
was
established in
a biased
analysis we
detail here.)
This alone
would suggest
that a trade
organization
has no
business
passing
judgment on
such policies.
But we
are in a new
era of trade
policy, where
even
non-discriminatory,
reasonable,
even-handed,
popular
policies (some
with virtually
no impact on
international
trade) can be
ruled against.
What's
more, all
three consumer
policies could
be considered
very "free
market"-oriented.
Rather than
the big old
government
telling
Americans what
they can and
can't consume,
the dolphin
and beef
policies
simply require
honesty in
labeling, so
that the
consumer can
decide on
their own free
will what to
consume, and
let the market
works its
magic.
We've
long known
that more
interventionist
government
policies (like
import bans)
can run afoul
of trade
rules. Indeed,
the two
adverse
rulings at the
WTO's
predecessor
organization
in the early
1990s against
the U.S. ban
on
dolphin-unsafe
tuna led to
the eventual
removal of
that effective
and popular
policy tool.
Now, with
today's
ruling, we
learn that
even
regulation by
more "free
market" means
is on the WTO
chopping
block.
This
is going to
make it harder
for the Obama
administration
to sell
similar
anti-consumer
trade
initiatives
like the
trade deals
with Korea,
Panama and
Colombia to
free-marketeers
and
environmentalists
across the
political
spectrum.
The
long saga of
protecting
dolphins
After
passage of
various
dolphin
protection
laws in the
1980s, the
U.S. fishing
industry
abandoned the
cruel
and
environmentally
devastating
practice of
surrounding
dolphins with
mile-long
purse seine
nets to trap
the schools of
tuna fish
swimming under
the hunting
mammals.
The practice
had led to the
death
of millions of
dolphins in
the Eastern
Tropical
Pacific,
where dolphins
accompany
schools of
tuna.
The U.S. laws
forbid the
sale of tuna
caught with
purse seine
nets.
In 1991, a
General
Agreement on
Tariffs and
Trade (GATT) tribunal
ruled that
this ban
violated GATT
rules
forbidding
discrimination.
With the
debate over
NAFTA’s
passage
raging, Mexico
decided not to
impose trade
sanctions when
the United
States
maintained the
laws. The U.S.
prohibition
was again
successfully
challenged
under GATT by
the European
Union in 1994.
After NAFTA’s
passage, the
Clinton
administration
launched an
intense effort
to change the
U.S. law to
bring it into
compliance
with the
initial
ruling, while
Mexico
threatened a
new WTO case
to enforce the
old ruling.
After a
lengthy battle
with Congress,
the Clinton
administration
managed to
pass a new
policy that
removed the
ban on U.S.
sales of tuna
caught with
purse seine
nets.
However, an
attempt by the
Clinton and
Bush II
administrations
to weaken the
related
labeling law
defining what
could be
labeled
“dolphin safe”
was reversed
after a series
of U.S. court
cases.
Mexico has
been requesting
that tuna caught
through the unsafe
net methods
nevertheless
receive the
dolphin-safe
label, as long as
no dolphin death
was actually
observed. But
scientists and
environmentalists
were concerned
that “not
observing killing”
was not the same
as “not killing,”
and there was
evidence that
on-boat observers
were being paid to
falsify their
reports. Moreover,
dolphin chases
with nets (even
when no deaths are
observed) create
stress factors
that can separate
mother from their
calves and lower
reproduction
rates. Indeed,
dolphin stocks are
not recovering at
the expected rate,
despite lower
observed
killings.
In the
compromise that
removed the ban
in 1997, Congress
had insisted that
the executive
branch conduct a
series of
scientific tests
to demonstrate
that dolphin
protection
wouldn’t be
weakened by the
change requested
by Mexico.
Rather than
fulfill this
requirement,
political
appointees from
the Clinton and
Bush II
administrations
bullied career
civil servants and
scientists to make
favorable
findings.
In a drawn-out
legal battle,
environmentalists
successfully sued
to insist that
Congress’
instructions be
followed. Courts
ordered the
government to
release thousands
of pages of
documentation that
showed the weak to
non-existent
efforts on the
part of the
administrations to
live up to the
letter of the law.
The judge that
ruled in favor of
maintaining the
strong,
scientifically
backed labels
deemed the
government’s
arguments in the
case “Orwellian”
and said that in
his 24 years on
the bench, he had
never “reviewed a
record of agency
action that
contained such a
compelling
portrait of
political
meddling.”
(All
this history and
rulings by Earth
Island Institute
and its allies
can be reviewed
here and here.)
The ruling was
that rarest of
happenings where
justice,
democracy,
science and the
environment all
won.
What
today's ruling
says
Nonetheless,
some of Mexico’s
tuna fleet, as
well as ships
from other
countries,
continued
encirclement
fishing. Despite
this, Mexico has
been importing
canned tuna into
the U.S. for
over a decade,
with sales
mainly for
institutional
and restaurant
use.
Today's
ruling in favor
of Mexico's
challenge of the
U.S.
dolphin-safe
labels can be
read here.
The
panel found that
the policy
violated the
WTO's Agreement
on Technical
Barriers to
Trade, Article
2.2, which
reads:
2.2:
Members shall
ensure that
technical
regulations are
not prepared,
adopted or
applied with a
view to or with
the effect of
creating
unnecessary
obstacles to
international
trade. For this
purpose,
technical
regulations
shall not be
more
trade-restrictive
than necessary
to fulfil a
legitimate
objective,
taking account
of the risks
non-fulfilment
would
create.
Such legitimate
objectives are,
inter alia:
national
security
requirements;
the prevention
of deceptive
practices;
protection of
human health or
safety, animal
or plant life or
health, or the
environment.
In assessing
such risks,
relevant
elements of
consideration
are, inter alia:
available
scientific and
technical
information,
related
processing
technology or
intended
end-uses of
products.
In
addition to this
rule, which
disciplines
"technical
regulations,"
the TBT also has
requirements
related to what
are called
"technical
standards."
"Technical
regulations" are
mandatory to
comply with,
while "technical
standards" are
not mandatory.
The latter are
generally
subjected to
fewer WTO
requirements.
But
compliance with
the dolphin-safe
labels is not
mandatory: tuna
companies from
Mexico or any
other country
that wishes to
export
dolphin-killing
tuna to the U.S.
market are free
to do so.
So
Mexico advanced,
and the WTO
accepted, a
bizarre argument
that the labels
were "mandatory"
because a tuna
corporation
couldn't get the
label unless it
met the
requirements.
But as one of
the three WTO
panelists stated
in a scathing
dissent (on this
one point):
"7.150
According to the
ordinary meaning
of the term,
labelling
requirements are
requirements
that must be
fulfilled in
order to be
allowed to use a
certain label.
Any labelling
scheme foresees
such
requirements –
in fact, if such
requirements
would not exist
and if a certain
label could be
used independent
of whether
specific
requirements are
fulfilled, the
label would
become
meaningless."
So,
we're only at
the very
beginning of the
panel's analysis
and already
they've
over-reached in
a direction that
puts corporate
interests ahead
of other
considerations.
Too bad the
dissent doesn't
change the
overall ruling.
This was
the first time
that a WTO panel
has found a
violation of
this provision,
which has long
troubled
consumer groups,
environmentalists
and others.
There has been
widespread
concern that the
provision
empowered a WTO
panel to
second-guess the
U.S. Congress,
courts or
public, by
elevating the
goal of
maximizing trade
flows over
consumer and
environmental
protection. The
ruling shows
that consumers’
concerns were
well founded.
Part of Mexico's
argument was
that, by
focusing its
labeling
compliance
efforts on the
Eastern Pacific,
the U.S. was not
doing enough to
reduce dolphin
deaths
elsewhere. The
WTO agreed.
The finding is
absurd, and the
logic perverse.
Mexico has among
the world’s
least
dolphin-friendly
policies, and is
now claiming
that the
high-quality
U.S. dolphin
protections
don’t go far
enough. The fact
is, dolphin
mortalities have
plummeted
because of the
U.S. ban and
labeling
requirements.
Mexico pointed
to the improved
but still
inadequate
fatality
statistics to
argue against
the necessity of
the measures
that helped
achieve the
improvements,
measures that
Mexico has
systematically
undermined at
the GATT and
WTO.
U.S. courts
upheld the
strong
dolphin-safe
label because of
the lack of
scientific
evidence that
Mexico’s
approach was
reducing
unobserved
dolphin deaths.
The WTO today
allowed Mexico
to flip the
burden of proof
to its benefit,
with disastrous
consequences for
dolphin
protection.
Mexico produced
no compelling
evidence that
dolphin deaths
were a serious
problem in tuna
fishing outside
of the Eastern
Pacific, or that
tuna caught in
those regions
was wrongly
being labeled
dolphin-safe.
The U.S. was
then asked to do
the impossible
and prove a
negative: that
Mexico’s
propositions
were not true.
Indeed, the WTO
has made very
clear that it
will reject the
precautionary
principle when
it comes to
consumer
protection. What
is says with
this ruling is
that it will
utilize the
precautionary
principle when
it benefits
corporate
interests.
The WTO ruled
that Congress’
reasonable
efforts to focus
compliance
energies in the
Eastern Pacific
were not
"necessary". To
top it all off,
Mexico used as
support for its
arguments the
statements and
actions from the
Clinton and Bush
II
administrations
that the U.S.
courts had
deemed
“political
meddling.” If
there was ever
need for a more
compelling
reason to keep
trade lawyers
out of consumer
and
environmental
protection
issues, this WTO
panel ruling
provides
it.
Other
tidbits
The
panel rulings is
nearly 300 pages
long, so it will
be days before
all the
implications are
clear. Among
some of my
observations:
- Mexico
convinced the
WTO that the
U.S. court
ruling that
sided with the
environmentalists
was a part of
the
WTO-incompatible
U.S. policies.
Will the
executive
branch have to
overturn a
court ruling
in order to
comply? Will
this result in
an
inter-branch
battle?
- This
ruling takes another
swipe at
"softer
regulatory
approaches," in
this case,
cost-benefit
analysis. The
U.S., having
no information
that tuna and
dolphin
associate in
significant
numbers
outside of the
Eastern
Pacific,
reasonably
focused its
dolphin
protections
there. Neither
the WTO nor
Mexico
produced
substantial
evidence to
the contrary.
Instead, they
appeared to
argue that,
when a dolphin
is killed
outside of the
Eastern
Pacific, it is
equally
traumatic for
that dolphin
as a killed
dolphin in the
Eastern
Pacific. (see
paras.
7.538-543,
552, 560-561)
The
implication
seems to be
that the U.S.
has to
regulate
everywhere (no
matter the
cost), or
nowhere. These
panelists are
not exactly
political
science
geniuses, are
they? Or maybe
they are: the
practical
implication is
that states
will face
incentives not
to regulate.
- Mexico
griped that it
was complying
with the
admittedly
lesser dolphin
protection
standards
under the
international
Agreement
on the
International
Dolphin
Conservation
Program
(AIDCP). While
the WTO noted
that the AIDCP
standards
don't achieve
all of the
U.S.
objectives,
the panel
nonetheless
seemed
convinced by
Mexico's
arguments that
the U.S.
should be
doing more to
inform its
consumers
about steps
Mexico was
taking under
the AIDCP,
including
perhaps
through a
separate
label. In
language that
would make Joe
Stiglitz
proud, the
panel writes:
7.575
Moreover, the
Panel notes that
Mexico goes
beyond simply
suggesting that
the use of the
AIDCP dolphin
safe logo be
allowed in the
US market.
Mexico submits
that the
coexistence of
the US and the
AIDCP dolphin
safe labels,
would permit US
consumers to be
"fully informed
of all aspects
of dolphin safe
fishing methods"
(emphasis added)
so that "they
[could] choose
accordingly when
purchasing tuna
products from US
retailers".
The Panel
understands
Mexico's
suggestion as
advocating the
inclusion of
more information
on the dolphin
safe labels
allowed in the
US market on the
actual and
potential
fishery-related
adverse effects
on dolphins. The
Panel considers
that such
addition would
contribute to
informing
consumers about
the precise
dolphin safe
characteristics
of the various
techniques used
to harvest
tuna. In
our view, this
would enhance
the ability of
the dolphin safe
labels to remedy
market failures
arising from
asymmetries of
information
between tuna
producers,
retailers and
final consumers
in the US
market.
Well informed
consumers would
be in a better
position to use
their purchasing
power to
influence the
way tuna
fisheries and
canners operate.
- After
253 pages of
anti-consumer
anti-environment
nonsense, the
WTO panel now
invokes the
consumer
interest as a
reason to
water down the
meaning of
dolphin-safe
labels.
Brilliant! And
despite the
invocation of
economics
terminology,
the panel made
pretty clear
its
indifference
to honest
economic
analysis of
the costs and
benefits of
regulating.
- Tuna
catch
represents
0.008% of
Mexico's GDP.
If Mexico were
willing to
engage in
decades of
trade
wrangling over
such a puny
sector,
imagine
Panama's
motivations
for (say)
using the pending
U.S.-Panama
trade deal to
attack our
efforts to
fight their
tax havens.
Finance
represents
over 8 percent
of Panama's
GDP.
Okay,
and just to
round this out,
let me quote
some of the
debate on the
1997 bill that
contemplated
relaxing the
labeling law to
allow Mexico's
methods to be
considered
dolphin-safe.
Maybe an
interesting
preview of these
members'
reactions to
this latest WTO
ruling and the
pending unfair
trade deals:
“Mr. FARR
of California. Mr.
Chairman, I thank
the gentleman for
yielding. I want
people to take a
look at what they
are being asked to
do. They are being
asked to vote for
a bill and the
title of the bill
is the
International
Dolphin
Conservation
Program Act. Now,
what it is all
about is the
strength of
American markets.
The reason we have
practices that say
we have to fish
safe for dolphins
is because of
these cans that we
sell in American
grocery stores,
and on them is a
symbol that says,
dolphin-safe. What
we want to do by
this law is to
change that. We
want to change
truth in labeling.
[TIME: 1545] This
is all about
labeling, Mr.
Chairman. This is
about the U.S.
market, this is
about the U.S.
consumers, this is
about us. What it
is about is that
this bill says
because of a 1991
trade dispute,
that we ought to
let that dispute
dictate how we
sell products in
American
stores. This
is all wrong,
because what this
bill recognizes is
that in the
process of doing
that we will
double the number
of dolphin that
will be killed.
This is about
access to American
markets. It is
about corporations
who are using the
American markets
to sell their
product, the tuna
that are caught in
the oceans far off
our coastline, but
because the
American public
buys so much tuna,
they know they can
only sell it in
this country if
they do it the way
the consumers want
to do it. Along
comes a law and
says, hey, let us
change that. Let
us change the
labeling on the
can, let us change
the practices, so
in fact we can go
out and in the
process we may
kill more
dolphins. That is
not what the
American public
wants. The
consumer does not
want to be
tricked, does not
want to be
cheated. Remember,
the consumers are
the ones that
started this
process. I urge a
`no' vote on the
bill.” ...
“[Page: H3133] Ms.
ESHOO. Mr.
Chairman, I rise
today in
opposition to H.R.
408, the
International
Dolphin
Conservation
Program Act. This
bill is flawed on
several counts. I
have two primary
concerns. First,
the bill doubles
the amount of
dolphins allowed
to be killed every
year. Second, it
makes a mockery of
the dolphin-safe
label used on all
tuna sold in the
United States.
* As a supporter
of free trade,
including NAFTA, I
do not believe
that trade should
be a reason for
the United States
to change its
definition of
`dolphin-safe.' We
can address the
specific trade
concerns raised by
Mexico and other
countries which
are subject to
tuna embargo
because of their
fishing practices
which result in
the death of
dolphins, without
denying or lying
to the American
consumer.
* If we pass H.R.
408, dolphin-safe
will merely mean
`no dolphin
killed,' even
though dolphins
can be chased,
encircled,
injured, pulled
onto a boat and
dumped back in the
ocean under this
bill. This would
be considered
safe, as long as
the dolphin is not
seen dying on the
boat or in the
net. Mother
dolphins can be
separated from
their feeding
young, chased
dolphins can be
exhausted and
fatigued to the
point of death by
cruel practices,
but it will be
called
dolphin-safe under
this bill.
* I urge my
colleagues to
reject this bill.
Let's keep truth
in labeling. Don't
lie to the
American
consumer...
* Ms. PELOSI. Mr.
Chairman, I rise
in opposition to
this legislation.
H.R. 408 is a
deeply flawed bill
that threatens
marine mammal
populations to the
benefit of foreign
trading partners.
This bill is bad
for trade, bad for
the environment,
and bad for
consumers.
* In 1990,
environmental,
animal and
consumer activists
won a victory with
the advent of the
dolphin-safe label
for commercially
sold tuna. From
that time, no
product could be
labeled
dolphin-safe if
the tuna were
caught by chasing,
harassing, or
netting dolphins.
The dolphin-safe
label has worked
to preserve
dolphin
populations. After
Congress adopted
its ban of
imported tuna
caught using
enclosure nets in
1992, the dolphin
mortality rate
dropped from
100,000 per year
to 2,754 last
year.
* The bill before
us would change
the meaning of
dolphin-safe to
allow activities
that would include
highspeed chases
with boats and
helicopters, the
separation of
mothers from their
calves, the
withholding of
food from trapped
schools and the
deliberate injury
of dolphins to
prevent the school
from escape.
* In fact, almost
any fishing
activity would be
termed
dolphin-safe
provided that no
dolphins were
observed to die
during the catch.
Prior to the
dolphin-safe
label, dolphin
populations had
been depleted by
as much as 80
percent. The
dolphin-safe label
stopped this trend
and proved to be
one of the most
successful
consumer
initiatives in
U.S. history.
Americans care
about what is left
of our natural
environment and
the threatened
creatures who
inhabit it.
* Dolphin-safe
must mean that
dolphins are safe
and not
unnecessarily
injured or killed
in the hunt for
tuna. H.R. 408
allows an increase
in dolphin deaths
and unlimited
injury and
harassment of
dolphins. That is
by no means
dolphin-safe.
* Proponents of
H.R. 408 would
have foreign
trading partners
define our
domestic markets
without
congressional
oversight and
without public
scrutiny. H.R. 408
is designed to
solve a trade
problem defined by
foreign
fisheries--not an
environmental
problem defined by
the American
public. If
enacted, this law
would establish a
precedent for
other labeling
laws designed to
protect and inform
American
consumers.
* Americans rely
on labeling
information. We
cannot allow
foreign interests
to determine our
domestic
priorities and
relax our higher
environmental
standards. If
foreign
corporations are
successful in
relaxing our
labeling laws,
American consumers
will not have
information about
the safety or
origin of the
products they buy.
The dolphin label
works and
consumers have
overwhelmingly
supported
dolphin-safe tuna
at the market.
H.R. 408 is an
attempt by foreign
interests to
compete unfairly
with American
higher standards.
* Mr. Chairman, I
urge our
colleagues to vote
against H.R. 408
which would enable
us to keep the
promise made to
the American
people. Trade
agreements should
not result in the
weakening of U.S.
environmental
laws. I urge a
`no' vote on the
bill.
|
|
|
|
|
|