[GNSO-RPM-WG] FW: [Gnso-rpm-trademark] Q#8
claudio di gangi
ipcdigangi at gmail.com
Mon Sep 23 19:31:58 UTC 2019
Rebecca, all,
I join Brian in thanking you for expressing your views so clearly here.
With the benefit of having a little more time, I will reply to your note
- and to the helpful feedback that Mary recently contributed on the list,
prior to our upcoming call on Wednesday.
Thank you.
Cheers,
Claudio
On Mon, Sep 23, 2019 at 11:31 AM BECKHAM, Brian <brian.beckham at wipo.int>
wrote:
> Thanks Rebecca for the clarification (especially on 1 and 4)!
>
>
>
> Claudio, others – any reaction?
>
>
>
> Brian
>
>
>
> *From:* Tushnet, Rebecca <rtushnet at law.harvard.edu>
> *Sent:* Monday, September 23, 2019 3:53 PM
> *To:* BECKHAM, Brian <brian.beckham at wipo.int>; Ariel Liang <
> ariel.liang at icann.org>; gnso-rpm-wg at icann.org
> *Subject:* Re: [GNSO-RPM-WG] FW: [Gnso-rpm-trademark] Q#8
>
>
>
> Thanks. Yes, I did intend to incorporate the broad definition of
> trademarks (where the term is shorthand for trademarks, service marks,
> collective marks, and certification marks).
>
>
>
> For #4, I attempted to be clear that it is not about mandating *or *foreclosing
> other programs that might voluntarily be adopted for specific registries,
> but only about what should happen under the existing RPMs.
>
>
>
> In terms of labeling, I deliberately did not characterize Deloitte's
> practices. I believe #5 is purely descriptive of Deloitte's practices.
> However, aside from GIs, my understanding of our discussion is that there
> is consensus that "other IP" was supposed to refer only to ancillary
> services and thus that Deloitte's current advertising of it as equal to
> registrations, etc. in terms of eligibility for Claims/Notice is not
> consistent with the AGB.
>
>
>
> Rebecca Tushnet
>
> Frank Stanton Professor of First Amendment Law, Harvard Law School
> 703 593 6759
> ------------------------------
>
> *From:* BECKHAM, Brian <brian.beckham at wipo.int>
> *Sent:* Monday, September 23, 2019 5:14 AM
> *To:* Tushnet, Rebecca <rtushnet at law.harvard.edu>; Ariel Liang <
> ariel.liang at icann.org>; gnso-rpm-wg at icann.org <gnso-rpm-wg at icann.org>
> *Subject:* RE: [GNSO-RPM-WG] FW: [Gnso-rpm-trademark] Q#8
>
>
>
> Thanks Rebecca for the attempt at bringing this together.
>
>
>
> I would encourage Claudio and other proponents of related proposals to
> weigh in.
>
>
>
> Rebecca, can you clarify whether No. 4 below is intended to specifically
> foreclose use of any entry in an ancillary database for registry-adopted
> programs such as a founder’s program (i.e., not an “existing RPM”) which
> may have a similar early-allocation effect as a sunrise.
>
>
>
> Also, for No. 1, can you clarify if this is intended to also capture
> Kathy’s email of last Tuesday noting a proposed definition for trademarks:
> “By "trademarks," the WG means "trademarks, service marks, certification
> marks and collective marks.”?
>
>
>
> As we constructively attempt to produce a consensus recommendation on this
> topic, noting the preamble below, I do want to remind the WG however of an
> email from April 2017 expressing concerns about labeling Deloitte’s actions
> (especially given the possibility of differing reasonable interpretations
> about the “other marks” clause):
> https://mm.icann.org/pipermail/gnso-rpm-wg/2017-April/001722.html
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_pipermail_gnso-2Drpm-2Dwg_2017-2DApril_001722.html&d=DwMGaQ&c=WO-RGvefibhHBZq3fL85hQ&r=E-M4OQvQBo8UWqE1LwEiDR3PcWlfM0I-0jiI1c4ous0&m=et_H2dFB0D2ttCTefu6tqaN59DJqm5SX6UhatgAapdg&s=Yiut4ybvRqo3pqM55_6q-RnltcK2NrmzcrvQ38LJc1Q&e=>
> .
>
>
>
> Brian
>
>
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *Tushnet,
> Rebecca
> *Sent:* Monday, September 23, 2019 3:28 AM
> *To:* Ariel Liang <ariel.liang at icann.org>; gnso-rpm-wg at icann.org
> *Subject:* Re: [GNSO-RPM-WG] FW: [Gnso-rpm-trademark] Q#8
>
>
>
> I understand that we’re trying to get some results out the door for public
> comment, and I would suggest that don't need exact wording right now, but
> we do need to clarify that Deloitte is doing the wrong thing. I think we
> may be able to reach consensus about several different things:
>
> 1. The TMCH is for trademarks: those that are registered as
> trademarks, confirmed by court decision as trademarks, or protected by
> statute or treaty that specifies the trademarks covered (as opposed to, for
> example, Lanham Act §43(a), which grants statutory protection to
> unregistered marks but doesn’t specify the marks covered). What counts as
> a trademark should be determined by national law, not by the TMCH.
> 2. Specifically, GIs (that do not also fall under (1)) are not
> trademarks.
> 3. GIs, like other things that are not trademarks, can be the subject
> of ancillary services. These ancillary services are voluntary, not
> mandatory, in new gTLDs. Different providers should be able to compete to
> provide them if desired. There is no existing barrier to multiple
> registries using the same ancillary service, nor should we impose any
> barriers to that possibility.
> 4. GIs and other subject matter of ancillary services should not be
> subject to Sunrise or Notice under the existing RPMs.
> 5. Deloitte is (a) registering GIs under the theory that they are
> covered by "statute/treaty," and (b) indicating to TMCH potential
> registrants that "other IP" is eligible for Claims and Notice in the TMCH
> by grouping “other IP” with registrations, court-confirmed marks, and marks
> protected by statute or treaty in its public-facing materials. Both of
> these practices should stop.
> 6. As long as the public-facing aspects of the RPMs operate properly,
> we should be indifferent to the “back end”—whether ancillary databases are
> in the “same database” or a “different database,” should Deloitte choose to
> operate an ancillary database.
>
> My hope is that, although there may not be universal agreement to each one
> of these statements, we can approach consensus on each individually.
>
>
>
>
>
>
>
> Rebecca Tushnet
>
> Frank Stanton Professor of First Amendment Law, Harvard Law School
> 703 593 6759
> ------------------------------
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> on behalf of Ariel
> Liang <ariel.liang at icann.org>
> *Sent:* Wednesday, September 18, 2019 1:47 PM
> *To:* gnso-rpm-wg at icann.org <gnso-rpm-wg at icann.org>
> *Subject:* [GNSO-RPM-WG] FW: [Gnso-rpm-trademark] Q#8
>
>
>
> Forwarding Claudio’s proposal, which was originally sent to the TM Claims
> Sub Team mailing list.
>
>
>
> Best,
>
> Ariel
>
>
>
> *From: *Gnso-rpm-trademark <gnso-rpm-trademark-bounces at icann.org> on
> behalf of claudio di gangi <ipcdigangi at gmail.com>
> *Date: *Wednesday, September 18, 2019 at 1:43 PM
> *To: *"gnso-rpm-trademark at icann.org" <gnso-rpm-trademark at icann.org>
> *Subject: *Re: [Gnso-rpm-trademark] [GNSO-RPM-WG] Q#8
>
>
>
> Here is my compromise proposal consolidated/clarified in one location:
>
>
>
> *1) Going forward, GI may be accepted in the Clearinghouse (and recorded
> separately as such within the database to distinguish them from TM
> records) under "3.2.4 - other marks that constitute intellectual
> property" OR shall be permitted to be recorded in one ancillary GI
> database, e.g. "the unitary, ancillary GI Database", that all
> registries/registrars may voluntarily connect with;*
>
>
>
> *2) GIs shall NOT be protected during the Sunrise or TM Claims period,
> unless they are also registered as trademarks and otherwise meet the
> qualifying criteria for such trademarks;*
>
>
>
> *3) the protection of GIs (those that are not also registered as
> trademarks) shall NOT be considered a mandatory RPM*
>
> * for any new gTLD registry;*
>
>
>
> *4) for new gTLD registries that desire or choose to protect GIs (as
> permitted by the current rules) based on local laws and/or for other
> consumer protection reasons, GIs may be protected and registered as domain
> names during the Limited Registration Period, and/or by the issuance of a
> GI Claims Notice, and which shall be supported by the unitary, ancillary GI
> database.*
>
>
>
>
>
> On Wed, Sep 18, 2019 at 12:34 PM Kathy Kleiman <kathy at kathykleiman.com>
> wrote:
>
> Claudio and All,
>
> For those who may not be able to follow all of the messages, could you
> send a full set of what you are thinking of for new language/Q#8? At least
> two Pauls have commented, so I am not sure what you are referencing. Having
> it all in one place would be useful.
>
> Tx, Kathy
>
>
>
> <<Rebecca, all,
>
>
>
> I support John's proposal below as the simplest approach, with Paul's
> language about 3.2.4 being the qualifying text for the inclusion of
> GIs, along with a provision this IP database will be centralized for all
> new gTLD registries.
>
>
>
> Rebecca - you asked about the supporting rationale in a recent note, so I
> would like to address your question.
>
>
>
> The purpose is to avoid creating a scenario of having 300 (or pick some
> number) of ancillary databases, each requiring separate submissions and
> validations. Again, I say this because Mary confirmed that currently the
> ancillary database concept is registry-specific. The main TMCH is not
> registry-specific, all new gTLD registries connect to the database in a
> unified manner.
>
>
>
> For the sake of providing examples, <.tea> launches as a new gTLD in the
> next round; that registry will need to expend time and resources to
> collaborate with Deloitte to establish a new ancillary database, and the
> regional authority/producers of DARJEELING TEA, (under the current model)
> would be required to submit the GI registration to the ancillary database
> of <.tea> and have it validated at that time.
>
>
>
> In the same round, <.चाय> launches ("tea" in the Hindi script - a
> language spoken in India, as an IDN), the current model requires
> this same (or different) registry operator to create another new ancillary
> database, with new submissions of registrations, additional validations,
> etc.
>
>
>
> <.drinks>, <.beverages>, <.web>, <.internet>, etc.. the list goes on and
> on, for every new gTLD there has to be separate ancillary databases. Each
> registry and registrar will then have to allocate resources to promote the
> registry-specific database to IP owners around the world, and connect to
> the database from a technical level. I can only imagine the confusion and
> unnecessary costs that this approach would impose on contracted parties and
> the public.
>
>
>
> It would also defeat the purpose and benefit of a having a centralized,
> unified system that simplifies recordation and validation from both an
> administrative and technical basis for all parties.
>
>
>
> The Limited Registration Period is an existing RPM that functions similar
> to Sunrise, but takes place after the Sunrise Period, during which
> time these 3.2.4. marks can be protected. Since it is already permitted, I
> propose that we specify there is a voluntary option for a IP Claims notice
> for these 3.2.4 marks (identical to the TM Claims notice, i.e. using the
> same language).
>
>
>
> These are completely voluntary RPMs for contracted parties - especially,
> for those that operate in jurisdictions where GIs are protected under local
> laws, and/or for those which decide to take proactive measures to prevent
> abusive registrations in their TLD(s) to have a safe namespace for
> their users. Since registries are already allowed to create voluntary RPMs,
> the proposal is based on improving things from a technical and
> administrative basis, in a manner that is fully consistent with the law,
> and with the overall goal of protecting consumers and promoting trust in
> new gTLDs.
>
>
>
> Finally, as Brian noted there is an existing database of GIs, managed by
> OriGin, which Deloitte/IBM can interface with to help simplify the process,
> which is an idea we can include for public comment in association with the
> main recommendation.
>
>
>
> All we need to do is agree that this approach makes sense from a policy
> perspective, and the IRT that follows this PDP can develop the appropriate
> implementation procedures to put everything into place.
>
>
>
> Please let me know of any questions.
>
>
>
> Best regards,
>
> Claudio
>
>
>
>
>
>
>
> On Tue, Sep 17, 2019 at 5:23 PM John McElwaine <
> john.mcelwaine at nelsonmullins.com> wrote:
>
> I would propose simplifying this a bit. The issue that we have is that
> Deloitte should not be placing “other marks that constitute intellectual
> property” in the “Clearinghouse”. The Trademark Clearinghouse is more than
> just to service Sunrise and Claims services. See AGB TMCH Section 1.2
> (“The Clearinghouse will be required to separate its two primary functions:
> (i) authentication and validation of the trademarks in the Clearinghouse;
> and (ii) serving as a database to provide information to the new gTLD
> registries to support pre-launch Sunrise or Trademark Claims Services.
> Whether the same provider could serve both functions or whether two
> providers will be determined in the tender process.”) Unfortunately,
> Section 3.2 muddies the waters and lists “other marks” as being capable of
> inclusion “in the Clearinghouse”.
>
>
>
> However, the purpose behind Section 3.2.2 is provided a bit more light in
> Section 3.6: “Data supporting entry into the Clearinghouse of marks that
> constitute intellectual property of types other than those set forth in
> sections 3.2.1-3.2.3 above shall be determined by the registry operator and
> the Clearinghouse based on the services any given registry operator chooses
> to provide.” With respect to such other IP, the “Trademark Clearinghouse
> Service Provider may provide ancillary services, as long as those services
> and *any data used for those services are kept separate from the
> Clearinghouse database*.”
>
>
>
> Thus, as I mentioned on the call, a simple solution is that we recommend
> “other marks that constitute intellectual property (under 3.2.2 and 3.6)”
> currently in the Trademark Clearinghouse must be placed into a separate
> ancillary database by the operator and not in the Trademark Clearinghouse.
>
>
>
> John
>
>
>
>
>
>
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *Tushnet,
> Rebecca
> *Sent:* Tuesday, September 17, 2019 4:24 PM
> *To:* claudio di gangi <ipcdigangi at gmail.com>; Corwin, Philip <
> pcorwin at verisign.com>
> *Cc:* gnso-rpm-wg at icann.org
> *Subject:* Re: [GNSO-RPM-WG] Q#8
>
>
>
> *◄External Email►* - From: gnso-rpm-wg-bounces at icann.org
>
>
>
> I'm still quite factually confused by this proposal. "Accepted in the
> Clearinghouse" until now has meant "gets Claims and is eligible for Sunrise
> upon proof of use." It appears to me that this is proposing a nontrivial
> technical change (at the very least the implementation of a new coding
> category, which will have to be retrofitted to existing entries), without
> evidence either of its need or its feasibility.
>
>
>
> Relatedly: If GIs are to be treated so differently, why put them in the
> Clearinghouse, given that there is consensus that they shouldn't be used
> for Claims or Sunrise? Kathy's clarifying language allows for registries
> etc. to adopt various business models and for Deloitte and other operators
> to run systems that facilitate those business models, including the ones
> Claudio hypothesizes. (And I'm not sure we should hand Deloitte an extra
> business that would make competition in the market for providing additional
> services less likely.)
>
>
>
>
>
> Rebecca Tushnet
>
> Frank Stanton Professor of First Amendment Law, Harvard Law School
> 703 593 6759
> ------------------------------
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> on behalf of claudio
> di gangi <ipcdigangi at gmail.com>
> *Sent:* Tuesday, September 17, 2019 3:38 PM
> *To:* Corwin, Philip <pcorwin at verisign.com>
> *Cc:* gnso-rpm-wg at icann.org <gnso-rpm-wg at icann.org>
> *Subject:* Re: [GNSO-RPM-WG] Q#8
>
>
>
> thanks, Phil. Very helpful as always.
>
>
>
> I see your point that proposal #1 and #2 overlap, in the sense that they
> both deal with whether GIs should be recorded in the TMCH. My proposal (#3)
> integrates the other two proposals.
>
>
>
> My concern during the call was that I felt a premature signal being
> expressed that agreement was being quickly being reached
> after several members spoke (and I was one of them), while several other
> members asked clarifying questions. I may be mistaken, but don't recall
> Jason or Rebecca objecting to the thoughts I expressed during discussion on
> proposal #1.
>
>
>
> If I am mistaken, and there was a meaningfully larger list of proponents
> for proposal #1 expressed on the call, I am happy to be corrected - please
> let me know.
>
>
>
> From my perspective, the majority of members did not express a position
> while the discussion was taking place, so I was left confused under what
> basis that statement that consensus was reached was based upon.
>
>
>
> This is also why I recently expressed not having the benefit of the
> informal poll that you conducted two weeks ago. Can we please do this
> tomorrow to get a better sense of where folks stand?
>
>
>
> On this same line of reasoning, I was concerned that we did not have full
> participation on the last week's call (where any registries and registrars
> on the call?). Moreover, I indicated last week that I had off-line
> discussions with WG members who expressed support for my suggested
> approach, but were not able to join the call, so I was hoping to hear from
> them on the list prior to Wednesday.
>
>
>
> The transcript and recording were posted by Julie on Friday, 13 Sept. so
> members did not really have much time (Friday and Monday) to reply with
> input before things (I personally feel) got somewhat short-cut this morning
> with the posting that expressed here is the consensus view of the WG, along
> with the associated implementation text.
>
>
>
> My concern when this occurs is it changes the dynamic about how members
> feel about weighing-in and 'going against the thread' so to speak, and also
> may create confusion about the accurate state of play.
>
>
>
> In terms of substance and to clarify, my proposal is based on finding
> common ground and compromise that integrates the two proposals, as per the
> following:
>
>
>
> 1) Going forward, GI are accepted in the Clearinghouse or ONE main
> ancillary database that all registries/registrars can connect to (which
> potentially can be integrated with the main external GI database that
> exists, with Deloitte performing validations);
>
>
>
> 2) GIs are NOT protected during the Sunrise or Claims period, which remain
> for trademarks; which was something that we established during the review
> of Sunrise and Claims.
>
>
>
> 3) the protection of GIs are NOT mandatory for any new gTLD registry
>
>
>
> 4) for new gTLD registries that choose and desire to protect GIs (as the
> current rules permit) because of local laws and/or other reasons, they are
> protected during the Limited Registration Period, to help prevent abusive
> registrations before General Availability.
>
>
>
> The rationale for this approach is that GIs are one of the three major
> forms of IP (patents, trademarks, and GIs) and function as source
> identifiers for goods and services in a manner that is similar
> to trademarks (and can be registered as domains in the same manner). For
> example, GIs are protected in the United States (under the TRIPS agreement)
> as collective or certification marks, think FLORIDA ORANGES or IDAHO
> POTATOES.
>
>
>
> But in other countries, outside of the United States, they are protected
> under local laws that place them on a separate registry, apart from the
> trademark register.
>
>
>
> Hope this helps clarify status, and thanks for everyone's ongoing
> contributions.
>
>
>
> Best regards,
>
> Claudio
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
> On Tue, Sep 17, 2019 at 1:34 PM Corwin, Philip <pcorwin at verisign.com>
> wrote:
>
> Claudio—
>
>
>
> This message reflects the views of the co-chairs.
>
>
>
> Q8 and all of its related proposals were extensively discussed on the
> September 4th call. The meeting on 11 September was a continued
> discussion on Q8 and Q7 in case there were further proposals, and the major
> focus was on Q7 as we had run out of time on the prior call and a new
> modified proposal had been submitted for discussion.
>
>
>
> As regards Q 8, all of the first three proposals converge in that they
> would limit the registration of GIs in the TMCH to “marks” of some sort,
> whether trademarks or collective marks or certification marks; there also
> seemed to be some recognition and agreement that GIs that did not
> constitute “marks” could be recorded in an ancillary database for the
> purpose of assisting certain new gTLDs that recognized and provided some
> additional consideration to them. It appeared to the co-chairs that
> restricting TMCH recordation of GIs to those that constituted “marks” had
> fairly broad support among WG members participating on the calls.
>
>
>
> In regard to your fourth proposal -- “(1) Add the consideration of GIs to
> the policy review of the Sunrise and Claims services; and (2) withhold
> final consideration of the current TMCH proposals relating to GIs, until we
> conclude the policy review of the new gTLD RPMs (as described in the
> Charter).” – the Sunrise and Claims reviews have been concluded, and we are
> now wrapping up (concluding) our review of the new gTLD RPMs. So this
> proposal no longer seems timely or relevant; but if you wish to amend it
> and make a specific proposal for the treatment of GIs in the TMCH, tomorrow
> is the time to make it.
>
>
>
> Finally, as regards your proposal that we withhold a decision until
> Deloitte participated in a call on this subject, we see no reason to do so
> as there is no indication that Deloitte has changed its practice in regard
> to GI recordation since it wrote to the WG two years ago.
>
>
>
> In conclusion, we intend to finish the WG’s consideration of Q8 tomorrow
> but will facilitate discussion of an amended proposal from you if you wish
> to offer one.
>
>
>
> Regards,
>
> Brian
>
> Philip
>
> Kathy
>
>
>
>
>
> Philip S. Corwin
>
> Policy Counsel
>
> VeriSign, Inc.
>
> 12061 Bluemont Way
> Reston, VA 20190
>
> 703-948-4648/Direct
>
> 571-342-7489/Cell
>
>
>
> *"Luck is the residue of design" -- Branch Rickey*
>
>
>
> *From:* GNSO-RPM-WG <gnso-rpm-wg-bounces at icann.org> *On Behalf Of *claudio
> di gangi
> *Sent:* Tuesday, September 17, 2019 11:22 AM
> *To:* Kathy Kleiman <kathy at kathykleiman.com>
> *Cc:* gnso-rpm-wg at icann.org
> *Subject:* [EXTERNAL] Re: [GNSO-RPM-WG] Q#8
>
>
>
> Kathy, all,
>
>
>
> Last week, we spent the first full hour of the call discussing the first
> Question 8 proposal, and zero minutes on the second proposal on Question #8
> (In comparison we spent much time discussing both proposals for question
> #7).
>
>
>
> I am aware that some members spoke in support of the first proposal (I was
> on audio only), but do not know how many, while some others did not speak
> in support, and that we agreed to spend this full week to solicit WG
> members views on the list before moving forward. This week has not yet
> concluded (we have through today), yet new language is being posted below
> now for consideration.
>
>
>
> A few additional points, the week prior Phil conducted an informal poll
> using the Zoom room functionality, which helped provide transparency on WG
> members views for consensus building, which was not done last week on
> Question #8.
>
>
>
> Nor has there been an effort to bring the various proponents together to
> reach a compromise position, which we recently did in the sprint of the
> consensus-building process on Question #7, the design mark topic. So I’m
> not sure why question #8 is being treated so differently in all these
> various ways (as described above) compared to Question #7.
>
>
>
> Can someone kindly shed some light on this disparity in treatment between
> the way we are approaching question 7 and question 8?
>
>
>
> Thanks!
>
>
>
> Best regards,
>
> Claudio
>
>
>
>
>
> On Tuesday, September 17, 2019, Kathy Kleiman <kathy at kathykleiman.com>
> wrote:
>
> All,
>
> Last week we found considerable overlap and common ground on Q#8. I
> promised to circulate language sharing that agreement and slightly refining
> existing proposals.
>
> Q#8:
>
> 3.2 The standards for inclusion in the Clearinghouse are:
>
> 3.2.1 Nationally or regionally registered word marks from all
> jurisdictions.
>
> 3.2.2 Any word mark that has been validated through a court of law or
> other judicial proceeding.
>
> 3.2.3 Any word marks specified in and protected by a statute or treaty *as
> trademarks *[1] in effect at the time the mark is submitted to the
> Clearinghouse for inclusion.
>
> 3.2.4 Other marks that constitute intellectual property. [see below]
>
> 3.2.5 Protections afforded to trademark registrations do not extend to
> applications for registrations, marks.
>
> [1] *By "trademarks," the WG means "trademarks, service marks,
> certification marks and collective marks."*
>
> For purposes of clarity, separate or ancillary databases of the Trademark
> Clearinghouse Provider (or another provider) may include other marks, but
> those databases should not be used for Sunrise or Trademark Claims Notices
> under the RPMs. Registries may use those separate or ancillary databases to
> provide additional services but are not required to do so under the RPMs.
>
> (Appropriate corresponding changes will be percolated across the *Trademark
> Clearinghouse* Applicant Guidebook)
>
> -----------------
>
> Best, Kathy
>
>
>
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