Privacy in Commonwealth Caribbean law: emerging trends in the protection of sexual citizenship

This article will explore the three recent judgments of Jovil Williams and Jason Campbell v AG of St. Christopher and Nevis & Chief of Police;¹1 Suit No: NEVHC 2013/0120, Williams J, (Supreme Court of St. Kitts Nevis, 21st March 2016) (unreported).View all notes Caleb Orozco v AG of Belize²2 Claim No. 668 of 2010 (Supreme Court of Belize, 10th August, 2016) (unreported).View all notes and Therese Ho vs Lendl Simmons³3 High Court Claim CV.2014-01949 (Supreme Court of Trinidad and Tobago, 26th October, 2015) (unreported) [32].View all notes which have broken new ground in constitutional law and the law of torts concerning the protection of (the right to) privacy. It is argued that these judgments hold substantial promise towards the making of a meaningful sexual citizenship in the Caribbean; a citizenship which protects the sexual autonomy of citizens and prevents or redresses the invasion or breach of these rights.     

Judge or be judged: accepting judicial appointment in an unlawful regime

Judicial independence is generally accepted as a key component of the rule of law. It empowers judges to make unbiased decisions without concern for political repercussions. In countries governed by an unconstitutional, unlawful or corrupt regime, such as Zimbabwe,2 International Bar Association Human Rights Institute, Zimbabwe: Report Highlighting the Critical Situation Faced by Judges and Lawyers in Zimbabwe (2001). View all notes Swaziland,3 International Bar Association Human Rights Institute, Swaziland: Law, Custom and Politics – Constitutional Crisis and the Breakdown in the Rule of Law (2003). View all notes Pakistan4 International Crisis Group, Building Judicial Independence in Pakistan (9 November 2004). Available at: www.crisigroup.org/home/index.cfm?1=1&id=3100, accessed 1 February 2010. View all notes and Fiji,5 International Bar Association Human Rights Institute, Dire Straits: A Report on the Rule of Law in Fiji (2009). View all notes that independence, and in turn the rule of law, is threatened. More particularly, acceptance of judicial office in an unlawful regime could be regarded as making an implicit bargain with the government to recognise its validity.6 See, in relation to Fiji, Chief Justice R. French, Judges in Fiji face ‘interim’ problem, The Australian (Sydney), 2 May 2008. View all notes

This article begins with a discussion of the importance of judicial independence, both from a national and an international perspective. It then examines the standards of judicial integrity and some of the factors that impact upon independence, including appointment and tenure, and the less obvious influence of jurisdiction. The article then moves on to consider the issues arising from acceptance of judicial office in an illegal regime in the context of Fiji, where lawyers and judicial officers have recently been forced to decide whether or not to accept appointment in a regime with an unelected government. After outlining the background to the latest events in Fiji, the article examines the competing considerations and ethical dilemmas involved in deciding whether to accept judicial appointment in an illegal regime. It then goes on to consider the possible repercussions of accepting such appointment from both a disciplinary and criminal perspective.     

The Digital Economy Act 2010: subscriber monitoring and the right to privacy under Article 8 of the ECHR

This paper critically assesses the compatibility of s3 Digital Economy Act 2010 (DEA) with Article 8 of the European Convention on Human Rights (1950) (ECHR). The analysis draws on Ofcom’s Initial Obligations and two UK cases, namely: British Telecommunications Plc & Anor, R (on the application of) v The Secretary of State for Business, Innovation and Skills,¹1 British Telecommunications Plc & Anor, R (on the application of) v The Secretary of State for Business, Innovation and Skills [2011] EWHC 1021 (Admin).View all notes and R (British Telecommunications plc and TalkTalk Telecom Group plc) v Secretary of State for Culture, Olympics, Media and Sport and others.²2 R (British Telecommunications plc and TalkTalk Telecom Group plc) v Secretary of State for Culture, Olympics, Media and Sport and others [2012] EWCA Civ 232.View all notes It argues that the implementation of this obligation allows directed surveillance of subscribers’ activities without legal authorisation under the Regulation of Investigatory Powers Act 2000 (RIPA). It also analyses compliance with the Strasbourg Court’s three-part, non-cumulative test, to determine whether s3 of the DEA is, firstly, ‘in accordance with the law’; secondly, pursues one or more legitimate aims contained within Article 8(2) of the Convention; and thirdly, is ‘necessary’ and ‘proportionate’. It concludes that unless the implementation of s3 of the DEA required the involvement of State authorities and was specifically targeted at serious, commercial scale online copyright infringement cases it could infringe part one and part three of the ECtHR’s test, thereby violating subscribers’ Article 8 ECHR rights.     

Seeing things differently: restorative justice and school discipline1

… helping to incorporate the principles of human rights, democracy, tolerance and mutual respect, the rule of law and peaceful resolution of conflicts into the daily practice of teaching and learning …2 2. Council of Europe (2004) Education for Europe, retrieved from http://www.coe.int/T/E/Cultural_Co-operation/education View all notes     

Copyright infringement and potential technological prevention measures in UK universities

Sony Music v. Easyinternetcafe´ 1 Sony Music Entertainment (UK) Ltd, Sony Music Entertainment Inc., Polydor Limited, UMG Recordings Inc. and Virgin Records Limited (claimants) v. Easyinternatcafe Ltd [2003] EWHC 62 (Ch) in the High Court of Justice Chancery Division 28 January 2002. Case No: HC 02 C01798. View all notes has introduced a new facet to the debate concerning the copyright legality of peer-to-peer file transfer. The judgment and subsequent settlement has highlighted that companies offering services that are used to infringe copyright may be held to account in the UK courts. Liability may extend from the private to the public sector and the British Phonographic Industry (BPI)2 The action was supported by the BPI's international sister organization: The International Federation of the Phonographic Industry (IFPI). View all notes has reinforced this theme recently. In March 2003 every university in Britain received a letter pointing out the legal risks of universities acting as copyright infringement facilitators. By allowing students to download copyright material such as software, Mp3s and DVDs, universities and their vice-chancellors may face injunctions, damages, costs and potential criminal sanctions. This paper first, briefly reviews the history and literature concerning peer-to-peer file sharing and secondly provides a preliminary discussion of the heads of peer-to-peer copyright infringement liability with regard to UK universities. Although the law at present gives no clear precedent in regard to the university sector, the area is unlikely to remain static. It is feasible that student copyright infringement liability could be transferred to universities in the future if universities do not show due diligence when dealing with copyright infringement. Thirdly this paper outlines the technological and administrative actions that may be taken to satisfy the British Phonographic Industry (BPI) and other copyright holders that UK universities are showing due diligence in preventing student copyright infringement. It is proposed that the university sector will follow the Internet service providers (ISPs) and will begin to work with the collecting and enforcement societies to prevent copyright infringement, perhaps in a similar way to the operation of the Copyright Licensing Agency (CLA). This article puts forward two main reasons for this: First, to avoid the potential legal costs of a copyright infringement action and secondly as the majority of downloading of copyrighted Mp3s, DVDs and computer software does not constitute an academic pastime or fulfil any worthwhile university endorsed learning aims it should be actively discouraged.3 Certain limited peer-to-peer use may fulfil legitimate educational goals: This area in the UK is governed by the Copyright, Design and Patents Act of 1998 in sections 28–44. View all notes     

Trends in US Imports of Amphibians in Light of the Potential Spread of Chytrid Fungus,Batrachochytrium dendrobatidis (Bd), and Implications for Conservation

Amphibian populations around the world are declining in part due to diseases from infection with the chytrid fungi Batrachochytrium dendrobatidis (Bd) and Batrachochytrium salamandrivorans (Bs). While declines in more charismatic megafauna are common sources of public awareness and concern, such as the loss of elephants to poaching or polar bears to climate change, amphibians have been suffering a dramatic decline due to the outbreak of deadly fungal diseases with relatively little public attention. Various amphibian advocacy groups work to raise awareness of the issue, but given the limited funding and resources allocated to this cause, there remains a general lack of momentum to tackle the growing conservation threats to this group of animals and to examine policy weaknesses that may need to be adapted to help ensure their conservation. The international trade in live amphibians certainly contributes towards the global spread of these pathogens, but the true extent of spread remains unknown. To determine the degree to which the importation of amphibians into the United States was correlated with presence of known vectors of Bd spread, we compared US Fish and Wildlife Service wildlife trade records for all commercially traded live animals imported to the US from 2006 to 2014 against known species-level infection susceptibility. Approximately 26,859,034 live amphibians were imported into the US for commercial purposes between January 2006 and December 2014.¹¹ Deanna H. Olson et al., Mapping the Global Emergence of Batrachochytrium dendrobatidis, the Amphibian Chytrid Fungus, 8 PLOS One, 27 February 2013, e56802, at 11.View all notes^,22 Id.View all notes Of these, 59.8% were specimens of species known to be susceptible to Bd infection and therefore may have introduced Bd into the country. Our findings demonstrate significant declines in the annual import quantities of 14 Bd-susceptible species between 2006 and 2014. These reductions could be due to a variety of factors, ranging from possible increased domestic production and a reduced need for foreign-sourced animals to reduced demand from changing market behaviors to the potential disease-driven decline of wild populations and greater difficulty in supplying these specimens. Our research supports the need for continued implementation of US policy, particularly the Lacey Act, to closely regulate wildlife imports to reduce the spread of highly virulent pathogens that threaten native species. Additionally, a rapid response mechanism is needed to control the introduction and spread of wildlife disease vectors when emergencies arise. Although the impact of the wildlife trade is just one facet of the overall amphibian conservation landscape, the information we present herein provides reason to develop increasingly robust rapid-response policies to protect wild amphibian populations in the midst of an emerging global disease crisis.     

Camera/video phones in schools: law and practice

The emergence of mobile phones with built-in digital cameras is creating legal and ethical concerns for school systems throughout the world. Users of such phones can instantly email, print or post pictures to other MMS1 1. MMS stands for Multimedia Messaging Services. MMS is frequently used to send photos from camera phones to other MMS phones or email addresses. View all notes phones or websites. Local authorities and schools in Britain, Europe, USA, Canada, Australia and elsewhere have introduced outright bans on their use because of the problems or risks they pose if misused. Risks concerned with pupils surreptitiously photographing other pupils in changing rooms or photographing examination papers are obvious examples. The article examines some worldwide examples of the misuse of camera phones in schools and the issues and problems that emerged. A landmark decision concerning the European Data Privacy Directive (Directive 95/46/EC) in the case of Bodil Lindqvist by the European Court of Justice is explored and the implications for camera phones considered. The article concludes by stating that because of their ubiquity and social potency, it is probably a mistake and an overreaction for education authorities or schools to introduce blanket bans on the possession of camera phones. Rather they need to devise sensible agreements and policies on camera phone usage.     

The challenges of prisoner reentry faced by Native American returning offenders

This article examines the economic, social, and cultural challenges American Indian¹1. We recognize there are no universally accepted or accurate labels for the Indigenous Peoples of North America. Although individual tribal names are preferred, we have chosen to use the term American Indian or Native American to represent the collective population that is present within this study.View all notes inmates face as they reintegrate back into a rural reservation community. Utilizing surveys, focus groups, and in-depth interviews with a variety of stakeholder groups, including community corrections, law enforcement, treatment providers, and tribal leaders, this research explores the reentry challenges faced by Native American returning offenders. Findings indicated that although similarities exist with other reentry populations, especially other minority groups, several unique challenges appear. The possible policy implications of these findings for the reentry process are also discussed.     

SMPIL Comments on the Long Island Nitrogen Action Plan

In early 2016, the New York State Department of Environmental Conservation, in conjunction with the Long Island Regional Planning Council, released the Conceptual Draft Scope for the Long Island Nitrogen Action Plan (LINAP).¹1 N.Y. State Department of Environmental Conservation, Long Island Nitrogen Action Plan, http://www.dec.ny.gov/lands/103654.html (accessed February 23, 2016).View all notes Pursuant to standard administrative procedures, the planners sought public comment in response to the Draft Scope Plan. SMPIL Consulting assessed and identified numerous areas for improvement and, therefore, submitted comments to the LINAP planners. These comments incorporated scientific and legal suggestions on a myriad of topics including upland land use, modeling, climate change, and adaptive management. The following article details these comments and notes the responses of the Department of Environmental Conservation as published on their Web site.     

Burning,Building, and Burying: Coal Combustion Residual Disposal in North Carolina

The fate of coal combustion residuals (CCRs) in North Carolina and the rest of the United States is noteworthy, particularly in light of the recent spills in Eden, North Carolina, and Kingston, Tennessee. The safe storage of coal combustion residuals should be a priority of the state and the federal government, in order to protect the drinking water of citizens from contaminants, like arsenic, lead, cadmium, selenium, and mercury.¹1 “Coal Ash: The Toxic Threat to Our Health and Environment,” Physicians for Social Responsibility and EarthJustice, http://www.psr.org/assets/pdfs/coal-ash.pdf (accessed September 19, 2015).View all notes Recently, North Carolina has taken steps with the passage of Senate Bill 729, entitled Coal Ash Management Act, and other legislation in order to promote safe storage of CCRs through a capped landfill system, complete with synthetic liners and leachate collection system. This article highlights not only the legislative enactments surrounding the disposal of coal ash in North Carolina, but also the effectiveness of such practices, both in North Carolina and the greater United States as a whole.     

Law school accreditation in the New Independent States of the former Soviet Union: what steps for the future?

Legal education reform has recently emerged as a key component in the rule of law promotion in the former Soviet Union republics,1 1. See Jane M. Picker & Sidney Picker, Jr, Educating Russia's future lawyers—any role for the United States? (2000) 33 Vanderbilt Journal of Transnational Law 17, 18–19, arguing that the core building block of the rule of law rests on legal education. See John M. Burman, The role of clinical legal education in developing the rule of law in Russia (2002) Wyoming Law Review at 90, 101, stating that reform of the legal education is the most effective way of creating a culture of law. See Peter J. Sahlas & Carl Chastenay, Russian legal education: post-communist stagnation or revival? (1998) 48 Journal of Legal Education 194 at 194, arguing that “a system of legal education can do more than teach the society's rules to successive generations: it can inspire values of justice and promote social progress”. See also Mark Dietrich, Three foundations of the rule of law: education, advocacy and judicial reform, in: Law in Transition (London, EBRD, Autumn 2002), at p. 57, available at: http://www.ebrd.com/ pubs/law/lit/english/aut02.pdf. The author points out that reform of legal education is the single most important reform to be undertaken in the NIS region. If law students are not taught how to think critically, question authority and be guided by the ethical values of the profession while in law school, it is difficult to expect that they will become honest advocates, judges or prosecutors in the future. View all notes now sovereign and independent states collectively known, for the purpose of this paper, as the New Independent States (NIS). Scholarly articles and international forums2 2. See Europe and Central Asia Division of the Legal Department, World Bank, Selected Issues (2001) Challenges and Strategies. The World Bank Forum on Legal and Judicial Reform in Eastern Europe and the Former Soviet Union 33; see also Dietrich, op. cit., at 58. View all notes suggest that legal education reform could be advanced by developing and implementing accreditation procedures for law schools, updating law school curricula, establishing transparent and rigorous grading standards, and retraining the law faculty. This paper discusses just one of these measures, namely the development and implementation of quality evaluation and accreditation procedures for law schools in the NIS region. In order to explore this issue in detail, the paper has been structured into six parts.

?Part I provides a brief overview of legal education in the Soviet Union, thus placing the issues tackled in this paper into a historical perspective. Part II describes the main changes occurring in the higher education system in general and legal education in particular in the NIS region after 1991, emphasising new challenges that privatisation of the higher education sector posed to the quality of legal education, thus triggering an urgent need for quality-assurance and accreditation mechanisms. The currently existent NIS practices of licensing, evaluation and accreditation of academic institutions, including law faculties within multi-disciplinary academic institutions, as well as separate law schools, are described in Part III. Parts IV and V adopt a comparative approach to accreditation by providing an overview of accreditation procedures in the United States, and the recent initiative and trends in quality evaluation and accreditation in Western Europe. Drawing upon the information provided in Parts I–V, Part VI offers concrete suggestions and recommendations for improving the implementation of accreditation procedures in the NIS region. The materials contained herein represent the opinions of the author and editors and should not be construed to be the view of either the American Bar Association or the Central European and Eurasian Law Initiative. The views expressed herein have not been approved by the House of Delegates or the Board of Governors of the ABA and, accordingly, should not be construed as representing the policy of the ABA. Nothing contained in this report is to be considered as the rendering of legal advice for specific cases, and readers are responsible for obtaining such advice from their own legal counsel. This report is intended for educational and informational purposes only. Research performed on Westlaw country of West Group. View all notes     

The RedTube copyright infringement affair in Germany: shame on who?

Recently, tens of thousands of German Internet users were confronted with copyright infringement claims for allegedly watching porn clips on the streaming platform RedTube.com. The alleged copyright infringers received ‘Abmahnung’ cease and desist letters that gave them an opportunity to settle copyright infringements out of court by paying rights-holders €250 in compensation. While in cases relating to peer-to-peer file-sharing, the IP address of a peer can easily be identified,¹1. In order to identify the subscriber of a certain IP address at a given time, the rights-holders will file a disclosure request with a court. For details see below, Section 2.3.View all notes the RedTube case raises the question how consumers of a stream could be identified. In addition, it raises the question of whether the consumption of a stream is illegal under German law. Assuming that this is not the case, this analysis of the RedTube case highlights that the system of Abmahnungen is prone to abuse in an Internet context. Several weaknesses of the current system are identified, which show that disclosure requests are not thoroughly assessed by courts and that lawyers are far too willing to send out cease and desist letters although an infringement is not obvious. This environment allowed the emergence of anti-piracy business models that succeed in turning infringements into profit and that do not hesitate to make unfounded claims.     

New Zealand: Public Registers Report

In September 2007, the Commonwealth Law Bulletin (Vol. 33, No. 3), published an article on the New Zealand Law Commission’s Issues Paper on Public Registers (IP 3, 2007), including the four options for reform that the Commission was putting forward for consideration by interested persons.

The Law Commission’s Public Registers Report ¹ 1 New Zealand Law Commission’s Public Registers Report, NZLC R 101 2008. (the Report) has now been published, completing stage 2 of the Law Commission’s four stage Privacy Review.

It is available on the Law Commission’s website at http://www.lawcom.govt.nz.     

Constitutional foundations of commercial and investment arbitration in Nigerian law and practice

Ten years ago Sir Anthony Mason, a former Chief Justice of Australia, warned that ‘a failure to strike the right balance between judicial independence and judicial accountability will result in either an unacceptable weakening of judicial independence or inadequate accountability’. ¹ 1 Judicial Commission of New South Wales (1997) Fragile Bastion – Judicial Independence in the Nineties and Beyond (Sydney: Judicial Commission of New South Wales), Chapt 1, p. 2.

This article examines some of the evolving aspects of judicial independence and judicial accountability within and outside the Commonwealth Caribbean and highlights some of the practical problems that occur in our region or are likely to arise. Decisions of courts and emerging practices in other parts of the Commonwealth provide excellent guidance and lessons for us in the Caribbean.

Judicial independence and accountability are not esoteric matters. They are principles that, admittedly, may resonate particularly with judicial officers because they tend to affect judicial officers in practical ways. But they are principles that are fundamental to good governance in democratic societies. Indeed, Commonwealth Heads of Government acknowledged the importance of these two principles when, at their meeting in Abuja, Nigeria, in 2003, they adopted the Latimer House Guidelines ² 2 The Latimer House Guidelines for the Commonwealth, 19 June 1998. as Commonwealth Principles. Such importance and respect are now accorded judicial independence that the UK Parliament actually enshrined the principle in the text of the Constitutional Reform Act 2005: ‘The Lord Chancellor, other Ministers of the Crown and all with responsibility for matters relating to the judiciary… must uphold the continued independence of the judiciary.’ ³ 3 Section 3(1).

Although this article will discuss judicial independence and accountability separately, it will be argued that the two concepts are not inconsistent and must coexist.     

Gender and Juvenile Drug Abuse: A General Strain Theory Perspective

This study is a partial test of Robert Agnew's (2006 Agnew , Robert. 2006 . “Pressured Into Crime: General Strain Theory.” Pp. 201 – 209 in Criminological Theory: Past to Present. , 3rd ed. , edited by F. T. Cullen and R. Agnew . Oxford , England : Oxford University Press . [Google Scholar]) general strain theory. The sample consists of 39,879 juveniles between the ages of 10 and 17 from a metropolitan area in Texas with more than 5 million people. Logistic regression is used to determine the effect of living situation on drug offenders, drug recidivists, and juvenile court case outcome when race, abuse, sex, and mental health problems are controlled. Gender-specific analysis is used to test L. Broidy and R. Agnew's (1997 Agnew , Robert and Timothy Brezina . 1997 . “Relational Problems With Peers, Gender, and Delinquency.” Youth & Society 84 – 111 .[Crossref], [Web of Science ®] , [Google Scholar]) hypothesis that girls and boys react differently to strain. Results show partial support for the influence of a strained living situation on drug offenders, drug recidivists, and case outcome. Support is found for the hypothesis that boys' and girls' experiences with strain differ.     

Gallery Districts of Barcelona: The Strategic Play of Art Dealers

This article focuses on Barcelona's art market to explore the underlying factors behind the clustering of art dealers in several of the city's districts. Drawing upon quantitative and qualitative data, the article analyzes how such clustering reveals a strategic action in the sense attributed to it by Crozier and Friedberg (1981 Crozier, Michel and Friedberg, Erhard. 1981. L’acteur et le système, Paris: Éditions du Seuil.  [Google Scholar]). Gallery districts are not a reflection of structural factors (economic, urban development-related, or social) but are the result of a combination of strategic choices—either individual or collective—which explain the permanence of leading gallery districts or the emergence of new ones.     

People’s justice for everyone

Both William Dean Howells and Edward Bellamy imagine brotherhood as the basis for new social orders in response to the trauma of the Civil War. Responding to the way in which the Civil War had pitted “brother against brother” in a “house divided,” Howells and Bellamy differently seek to reconstitute the American national family through revisioning brotherhood as universal, just, and equitable. William Dean Howells’s 1890 Howells WD (1890) A hazard of new fortunes New York Signet Classics 1965  [Google Scholar] A Hazard of New Fortunes illustrates the difficulties of aligning men in brotherhood following the Civil War and amidst the economic upheaval of the last decades of the 19th century. Bellamy’s 1888 Bellamy E (1888) Looking Backward, 2000‐1887 (Cecilia Tichi, Ed.) New York Penguin Books 1985  [Google Scholar] Looking Backward and Howells’s Altrurian romances (A Traveller from Altruria [1894 Howells WD (1894) A traveler from Altruria In E. J. Cady, R. Gottesman, &; Da. J. Nordloh (Eds.), The Altrurian romances (pp. 5–179) Bloomington Indiana University Press 1968  [Google Scholar]], “Letters of an Altrurian Traveller, I‐V” [1893 Howells WD (1893‐1894) Letters of an Altrurian traveller, I‐V In Edwin J. Cady, Ronald Gottesman, and David J. Nordloh (Eds.) The Altrurian romances (pp. 181–263) Bloomington Indiana University Press 1968  [Google Scholar]‐94] and Through the Eye of the Needle [1907 Howells WD (1907) Through the eye of the needle. 1907 In Edwin J. Cady, Ronald Gottesman, and David J. Nordloh (Eds.), The Altrurian romances (pp. 265–442) Bloomington Indiana University Press 1968  [Google Scholar]]) demonstrate brotherhood’s importance to new visions of community. Brotherhood’s promise for remaking the nation gives rise to the Nationalist movement, which emerged to make real Bellamy’s vision of the future. Brotherhood is a powerful organizing principle for utopian endeavor in post‐Civil War America, despite the limitations coincident with brotherhood, such as the difficulty of imagining brotherhood across race and gender lines.     

Ethnicity and Violent Crime: The Ethnic Structure of Networks of Youths Suspected of Violent Offences in Stockholm

This study employs network analysis in order to study patterns of co-offending among youths suspected of violent offences in Stockholm. The study's objective is to examine the ethnic structure of relations among persons suspected of committing violent offences together. The Swedish media have presented information suggesting that violent conflicts between Swedish youths and youths with an immigrant background, based on ethnic conflicts between these groups, are common. The study also discusses the relevance of this image. The study's findings show that violent offences committed by youths in Stockholm are of an ethnically heterogeneous character. At the same time there is a tendency for marginalized and segregated ethnic groups to join together to some extent. The findings may be interpreted as indicating that youth violence in Stockholm today is characterized by ethnic diversity, but that increased ethnic segregation may lead to an increase in the level of ethnically related violent crime. Apparently there is a perception that ethnic conflicts do occur, which persists despite the fact that such conflicts are not common. It is of concern that the occurrence of such perceptions, not least in the Swedish media, may lead to an increase in the level of conflicts of this kind.1 ¹The author would like to thank David Shannon for his translation of the text.