Wednesday is World Press Freedom Day. A free press is vital for a functioning democracy, and how free the press is often indicates the freedom of a country’s citizens. But new numbers from Freedom House show that 2016 was the worst year for press freedom in 13 years, both in the U.S. and internationally.

Freedom House, an independent democracy watchdog, conducts its analysis based on the political, economic, and legal climate for journalists in each country. The countries are then rated from 0-100–the closer to zero, the better. This year, the U.S. went up two points to 23, which is its worst score in a decade. Reporters Without Borders also makes an annual ranking, and on its list the U.S. ended up in 43rd, in between Burkina Faso and Comoros.

#WorldPressFreedomDay | Journalists Under Threat in Both Democracies and Dictatorships https://t.co/oS4ppXgMyA map via @rsf_inter pic.twitter.com/cGyn9w4Bj0

— Human Rights Watch (@hrw) May 3, 2017

Only 13 percent of countries have a completely free press. The criteria for ranking as free are, according to Freedom House, a media environment with extensive political coverage, guaranteed safety for journalists, minimal state intrusion in the media, and no legal or economic pressures on reporters.

President Donald Trump is mentioned as a partial cause of the decline in U.S. press freedom. He has frequently criticized the media for its coverage and often calls mainstream media “fake news.” Back in March, he tweeted that he might push to change the libel laws. And on April 30, White House Chief of Staff Reince Priebus said the administration had “looked at” changing them. Priebus added that the media needs “to be more responsible with how they report the news.”

The failing @nytimes has disgraced the media world. Gotten me wrong for two solid years. Change libel laws? https://t.co/QIqLgvYLLi

— Donald J. Trump (@realDonaldTrump) March 30, 2017

Who’s at the Bottom of the List?

Around the world there are countless examples of journalists who are detained because of what they report. The lowest-ranking countries are dictatorships in Africa, the Middle East, and Asia. But due to violence from drug cartels and organized crime, Mexico is also deemed one of the worst countries to be a journalist. Independent nonprofit organization Committee to Protect Journalists has documented more than 50 killings of journalists in Mexico since 2010.

The CPJ’s report on Mexico shows that convictions for murders of journalists are very rare, and when they do happen, authorities often fail to prove a clear link to journalism. Instead they often frame it as a regular crime, making it hard to keep data accurate and confront the actual problem. Corruption in the government and police force is also a huge problem.

“As Mexican journalists, we feel alone.” Miguel Ángel Dìaz, who was under threat for his work as a journalist. #WPFhttps://t.co/NMugf62xN5pic.twitter.com/oPwat4x38c

— CPJ (@pressfreedom) May 2, 2017

What’s Happening in the U.S.?

But even in the U.S., reporters are sometimes detained for doing their jobs. In February, freelance reporter Jenni Monet was arrested for covering the protests at the Dakota Access Pipeline near Standing Rock. Despite following police instructions to stay behind police lines, she was detained for 30 hours. She was later charged with rioting and trespassing.

“It didn’t matter that I was complying with their instructions and it didn’t matter that they knew I was a member of the press. I was handcuffed and held in a chain link enclosure with 18 other women for hours,” she said. Amnesty International is calling for the charges to be dropped, citing the critical role of reporters in holding governments accountable for human rights abuses.

On #WorldPressFreedomDay, we need YOU to get loud to demand charges be dropped against #DAPL journalist Jenni Monet https://t.co/hbgEqSE9mPpic.twitter.com/1V9vkp4mlW

— AmnestyInternational (@amnestyusa) May 3, 2017

A Spotlight on Turkey

In Turkey, at least 156 media outlets have been shut down and at least 2,500 journalists have been fired since last summer’s failed coup. More than 120 journalists have been jailed, facing terrorism-related charges, because of what they have written or drawn. One newspaper editor and his brother who appeared on a TV panel discussion about the coup were accused of ‘sending subliminal messages’ to the people behind the coup. Both were arrested, as was the TV show’s presenter.

Since the coup, President Erdogan has cracked down on all kinds of dissent. Last weekend, almost 4,000 people were fired from public offices and the government blocked Wikipedia. Now more than 250,000 people have signed an online petition urging the Turkish government to release all the jailed journalists. Many have tweeted photos of themselves using the hashtag #FreeTurkeyMedia, including Chinese artist Ai Weiwei and the Al Jazeera journalists who were imprisoned in Egypt for more than 400 days in 2013.

♫ Ai Weiwei’s done it,
Mandela’s statue’s done it,
Even the #FreeAJStaff‘ve done it,
Let’s do it,
Let’s post a #FreeTurkeyMedia selfie. ♫ pic.twitter.com/aRHrR0e4E8

— FreeTurkeyMedia (@FreeTurkeyMedia) April 24, 2017

Emma Von Zeipel

Emma Von Zeipel is a staff writer at Law Street Media. She is originally from one of the islands of Stockholm, Sweden. After working for Democratic Voice of Burma in Thailand, she ended up in New York City. She has a BA in journalism from Stockholm University and is passionate about human rights, good books, horses, and European chocolate. Contact Emma at EVonZeipel@LawStreetMedia.com.

The post World Press Freedom Day: Worst Outlook for Freedom of the Press in 13 Years appeared first on Law Street.

On March 2, Cecilio Pineda Brito, a nationally known crime reporter, was shot dead by two men on a motorcycle. On March 19, Ricardo Monlui Cabrera, the editorial director of the Córdoba’s Él Politico newspaper and president of his local journalism association, fell victim to similar motorcycle drive-by. Miroslava Breach Velducea, a correspondent for the national newspaper La Jornada, was shot and killed four days later. Last Friday, reporter Maximino Rodriguez Palacio was shot dead in La Paz, Mexico, marking the fourth fatal attack on a journalist in only six weeks.

The recent spate of attacks is shocking but not surprising. Human rights and freedom of the press advocates, both domestic and international, have long been calling for a response to anti-media violence in Mexico.

Freedom House’s 2016 Freedom of the Press Index named Mexico “one of the world’s most dangerous places for journalists and media workers,” citing numerous violent attacks in 2015. Conditions have only been intensifying.

According to a report by Article 19–a non-profit devoted to protecting freedom of expression–suppressive and/or violent attacks on journalists have been on the rise since 2010. The report found 426 acts of aggression against journalists and 11 homicides in 2016. While 2016 was the bloodiest year for journalists under President Enrique Peña Nieto and the worst since 2000, 2017 may surpass it.

Despite these statistics, Peña Nieto’s government seems unconcerned with attacks on journalists. Article 19 reports that the Mexican Special Prosecutor’s Office on Crimes Against Freedom of Expression–known in Mexico as FEADLE, its Spanish acronym–only investigated 118 cases of the 426 acts of aggression against journalists and that 99.75 percent of attacks go unresolved.

Although criminal organizations often take most of the blame for any kind of violence in Mexico, there is a slew of evidence implicating the government in the anti-media violence. In 2016, “State agents” supposedly perpetrated 53 percent of the 426 acts of aggression identified by Article 19–criminal organizations are believed to have perpetrated 4 percent of the attacks.

Last month, Gilberto Israel Navarro Basaldúa, a journalist from the city of Guanajuato, reported that an employee of the municipal government’s economic council had swerved his car and hit Navarro off his motorcycle. Although employees of state and municipal governments are believed to have carried out the majority acts of aggression, Article 19 found 56 examples in which federal officials allegedly attacked the press.

It is clear that the Mexican government is unwilling to protect its media. Peña Nieto has blamed local governments for obstructing investigations but Article 19 found that his government had consistently refused to use its authority to take control of the process. The fact that state workers from all levels of government are believed to be responsible for the majority of acts of aggression against the media perhaps explains why the government is unwilling to investigate and prosecute anti-media crimes.

Historically victimized by criminal organizations and now increasingly victimized by government officials, the Mexican journalists have no place to turn. Freedom of the press has long been under threat in Mexico, but it appears the government is intent on undermining the expressive freedom in its entirety.

Callum Cleary

Callum is an editorial intern at Law Street. He is from Portland OR by way of the United Kingdom. He is a senior at American University double majoring in International Studies and Philosophy with a focus on social justice in Latin America. Contact Callum at Staff@LawStreetMedia.com.

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When Canadian journalist Ed Ou headed to North Dakota recently to cover the pipeline protests at Standing Rock, he didn’t expect the drama to start as soon as he reached the U.S. border. But border officials decided to detain him for over six hours and confiscate his cellphones, something that is uncomfortable for anyone, but critical for a journalist. He compared having the contents of his phones scrutinized with a doctor giving up confidential information about his patients. If Ou’s sources who have given information on the condition of anonymity are revealed, their lives could potentially be in danger.

The U.S. border agent officers asked Ou to tell them how and why he had traveled to every single country he has visited for the past five years, and if he had seen anyone die. Ou has spent 10 years covering the Middle East, Africa, and Central Asia, which could explain the unusual questions. The agents asked to see his phones to make sure he was “not posing next to any dead bodies.” When he refused, explaining that he is a journalist and needed to protect his sources, they simply took them anyway. When he got the phones back later, it looked as if the SIM cards had been tampered with. Agents also photocopied pages from his personal diary. In the end, Ou was denied entry into the U.S. and put on a plane back to Canada, with no other explanation than that his name matched that of “a person of interest.” One officer said that his refusal to cooperate with the phones “did not help.”

The United States Customs and Border Protection declined to comment on the event. But in a statement it said, “Keeping America safe and enforcing our nation’s laws in an increasingly digital world depends on our ability to lawfully examine all materials entering the U.S.” If the authorities think that that means looking into the contacts of a well-published journalist and then refusing him entry with no valid reason, that is a huge problem for freedom of the press in the U.S.

The incident has been criticized by advocates for press freedom as well as by other journalists.

Journalists don’t get much braver or more talented than Ed Ou. What happened to him at the US border is shameful. https://t.co/4jCjUUqMaw

— Trevor Timm (@trevortimm) December 2, 2016

The way journalists are being treated at the US borders is truly alarming. This happened to photographer Ed Ou https://t.co/ZZi1bNNmB8

— Liz Sly (@LizSly) November 30, 2016

Does the United States believe in freedom of speech? Apparently not @CustomsBorder, which bars entry to accomplished photographer @EdOuphoto

— Neil MacFarquhar (@NeilMacFarquhar) November 30, 2016

The American Civil Liberties Union, ACLU, wrote a letter to Customs and Border Protection and the Department of Homeland Security, signed by attorney Hugh Handeyside, in which it called the detention and treatment “harassing and exceptionally intrusive.” It said that border agents should have realized that Ou was a renowned journalist, who had often traveled to the U.S. as he has well-established professional connections with major news outlets such as Reuters, the Associated Press and the New York Times. The letter stated:

We believe that C.B.P. took advantage of Mr. Ou’s application for admission to engage in an opportunistic fishing expedition for sensitive and confidential information that Mr. Ou had gathered through his news-gathering activities in Turkey, Iraq, Somalia and elsewhere.

Ou was on his way to cover the Standing Rock protests on behalf of the Canadian Broadcasting Corporation, which the agents were apparently aware of. But individual border officials should not have the power to affect what ends up in the media. The director of the Freedom of the Press Foundation, Trevor Timm, said that the practice of forcing journalists who have worked in the Middle East to give up their confidential sources just to get into a country puts the U.S. in a very bad light. “If this is requisite for journalists who are not U.S. citizens to enter the U.S., that is an enormous violation of press freedom,” he said.

An important reminder to #journalists that your #data is not safe at the US Border https://t.co/oqEbH8Xz6q @ACLU @edouphoto pic.twitter.com/jvQiO113tN

— MuckRock (@MuckRock) December 1, 2016

For all intents and purposes, the Fourth Amendment does not apply when you’re at the border. Walking on the street, a police officer likely can’t go up to you and randomly search you without a warrant or arrest order. But in an airport or at a border control stop, agents can search you and your electronic devices without reason or permission from a judge. This is because of a loophole in the law that mentions bags and personal property, but was written in a time before most people had their entire private lives stored in a cellphone. A policy from 2009 says that the owner of a digital device needs to be present when agents perform a search, but that rule can be interpreted very loosely. According to the policy, agents can make copies of data, but they need to be erased within a week unless a crime is suspected or there is a probable cause to keep the data.

This incident raises a deeper question, about press freedom and Freedom of Speech in the U.S., as well as what the role of the CBP should be. As Hugh Handeyside from the ACLU said, “conditioning foreign journalists’ admission to the United States on their willingness to agree to intrusive searches encourages similarly abusive treatment of American journalists in other countries.” To treat journalists like this at borders will discourage them from reporting on important events, and stem the flow of information.

Emma Von Zeipel

Emma Von Zeipel is a staff writer at Law Street Media. She is originally from one of the islands of Stockholm, Sweden. After working for Democratic Voice of Burma in Thailand, she ended up in New York City. She has a BA in journalism from Stockholm University and is passionate about human rights, good books, horses, and European chocolate. Contact Emma at EVonZeipel@LawStreetMedia.com.

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The crazy case between Hulk Hogan and Gawker has finally reached a decision–and Hogan has emerged victorious. A jury awarded the famous professional wrestler $115 million after a two week trial, but just six hours of deliberations.

Hulk Hogan sued Gawker after the media company released a sex tape of Hogan and the wife of a former friend of his. Hogan claimed that Gawker violated his privacy by releasing the tape, and that they didn’t reach out to him, or the woman in the tape, Heather Cole, before releasing it publicly on the site in an article entitled: “Even for a Minute, Watching Hulk Hogan Have Sex in a Canopy Bed Is Not Safe for Work but Watch It Anyway.” To read the full details of the case, check out our previous coverage here.

Really, the argument on the part of Hogan’s lawyer came down to privacy, and whether or not the video that Gawker published was actually “newsworthy.” But Gawker’s lawyers argued that this came down to First Amendment rights. Gawker’s attorney, Michael Sullivan, stated his concern that this case would open up a dangerous door for public figures to sue media companies. According to CNN:

Sullivan warned that Hogan’s lawsuit could have a chilling effect on free press if ‘powerful celebrities, politicians and public figures would use our courts to punish people.’ ‘We will all be worse off as a result,’ he said.

Before the ruling came out this evening, Eric Goldman, co-director of Santa Clara University’s High Tech Law Institute spoke to Fusion about the case and stated:

Right now, there’s an ‘anything goes’ mentality when it comes to publishing information about celebrities. If Gawker loses, we might begin to see some rethinking of that mentality. If Gawker wins, I think it will further embolden online publishers that anything related to celebrities is fair game.

Given that the six jurors sided with Hogan, and Gawker did lose, that first consideration may be true. However, it seems like Gawker’s lawyers are going to appeal the case–as Gawker founder Nick Denton read from a written statement:

Given key evidence and the most important witness were both improperly withheld from this jury, we all knew the appeals court will need to resolve the case. … That’s why we feel very positive about the appeal that we have already begun preparing, as we expect to win this case ultimately.

Given the high price tag and high profile nature of this case, the appeal will be one to watch.

Anneliese Mahoney

Anneliese Mahoney is Managing Editor at Law Street and a Connecticut transplant to Washington D.C. She has a Bachelor’s degree in International Affairs from the George Washington University, and a passion for law, politics, and social issues. Contact Anneliese at amahoney@LawStreetMedia.com.

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Here in the United States it’s easy to take the concept of Freedom of the Press for granted. The idea that someone would be jailed for the pieces he writes is almost unthinkable to us. Whether or not that’s actually the reality is a different matter–concerns over whistleblowers and journalists giving up their sources have increased in recent years–the concept of Freedom of Press still dominates American thought when it comes to journalistic rights. But it’s just as easy to forget that those principles don’t hold universal–in many parts of the world, imprisoning journalists for the simple facts of what they write is common practice. There are currently 221 journalists in prison worldwide. In 2014, 67 were killed, and just since the beginning of 2015, an additional 17 have been killed. That’s a problem, and it prompts the question: what can be done?

There are currently 31 nations that have at least one journalist in prison. The worst offenders are China, Iran, and Eritrea, at 44, 30, and 23, respectively. Other nations with a significant number of journalists in prison include Myanmar at ten, Egypt and Syria at 12 each, Vietnam at 16, and Ethiopia at 17.

According to the Committee to Protect Journalists (CPJ)–the organization that conducted the research–more than half of the imprisoned journalists work on a web platform; the majority of the rest work in print. CPJ also explains why the journalists are imprisoned:the majority were accused of being “antistate,” many were arrested on “retaliatory charges,” a few were charged with false news or defamation, and some were arrested for unknown or undisclosed reasons.

In response to these statistics, students at the University of Maryland came up with a project called “Press Uncuffed” to attempt to bring attention to the plight of journalists imprisoned around the world, as well as to provide support to CPJ and support its mission to free these journalists. Here’s a video that outlines the students’ motivations.

The group, led by Pulitzer Prize-winning journalist Dana Priest, will manufacture and sell Lucite bracelets, each of which will be engraved with the name of one of the imprisoned journalists; they are currently in the beginning stages of an indiegogo campaign to make that a reality. They aim to sell these bracelets on May 3, which is “World Press Freedom Day.” The bracelets are made of a see-through material to symbolize the need for transparency in global journalism.

The journalists being highlighted by Press Uncuffed include Reyoot Alemu, who has been imprisoned in Ethiopia on anti-state charges for nearly four years, accused of terrorism. She had written for an independent publication called Feteh, and was highly critical of the government.

There’s also Mahmoud Abou Zeid, nicknamed “Shawkan,” who is in prison in Egypt. He’s a freelance photographer who took pictures after Morsi was ousted. He was accused of many things, including weapons possession and murder, but up to this point it doesn’t appear that official charges were ever filed against him.

Also on the list is Yusuf Ruzimuradov of Uzbekistan. He’s been in prison for more than 16 years after being convicted of being “anti-state” in 1999. He’s one of the longest-imprisoned journalists in the world.

The aim of the Press Uncuffed movement is to bring attention to the plight of those brave journalists who aren’t as fortunate as we are to live in a nation where the press can be considered “free.” Various media companies and other members of the industry, such as HBO and the Knight Foundation, have lent their support. As Press Uncuffed described part of its aim:

We believe the link between information and a free and equitable society is vital and sometimes not fully understood. We hope Press Uncuffed humanizes the people who are risking their lives to give us information and creates a greater appreciation for the role of a free press.

It’s certainly a step in the right direction. While creating this kind of fundraiser won’t necessarily lead to immediate results, it will certainly increase awareness and accountability for  nations that decide to imprison journalists.

Anneliese Mahoney

Anneliese Mahoney is Managing Editor at Law Street and a Connecticut transplant to Washington D.C. She has a Bachelor’s degree in International Affairs from the George Washington University, and a passion for law, politics, and social issues. Contact Anneliese at amahoney@LawStreetMedia.com.

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The American Bill of Rights includes some fundamental freedoms to which we all, as American citizens, are entitled. One of them is called “Freedom of the Press.” It’s a freedom we may take for granted; it’s easy to assume that a nation whose President is often dubbed “the leader of the free world” also has the freest press; however, this year the United States ranked #49 out of 180 nations on Reporters Without Borders’ World Press Freedom Index 2015.

Reporters Without Borders explains its goal as follows:

The aim of the index is to measure freedom of information in 180 countries. It reflects the degree of freedom that journalists, news media and netizens (Internet citizens) enjoy in each country, and the efforts made by the authorities to respect and ensure respect for this freedom. It should not be seen as an indication of the quality of the media in the countries concerned.

The top ten on the list were Finland, Norway, Denmark, the Netherlands, Sweden, New Zealand, Austria, Canada, Jamaica, and Estonia. The lowest ten were Eritrea, North Korea, Turkemenistan, Syria, China, Vietnam, Sudan, Iran, Somalia, and Laos.

The rankings include both quantitative and qualitative data. In order to compile the list, Reporters Without Borders “scores” nations based on seven criteria categories:

• Pluralism: Are different opinions present in the media?
• Media Independence: Does the media function independently of other spheres of influence?
• Environment and Self-Censorship: What sort of journalistic environment is there in the nation?
• Legislative Framework: What sorts of laws govern the news?
• Transparency: How transparent are the institutions that produce the news?
• Infrastructure: How strong are the institutions that produce the news and what support do they have?
• Abuse: What is the violence and harassment toward those in the media like?

This format allows Reporters Without Borders to create a “score” for each nation; the lower the better. A score of 0-15 points shows a “Good Situation;” 15.01-25 points is a “Satisfactory Situation;” 25.01-35 points indicates “Noticeable Problems;” 35.01-55 points is a “Difficult Situation;” and 55.01-100 points is a “Very Serious Situation.” The United States scored a 24.41, so barely in the “Satisfactory Situation” category.

The United States’ place on the list at 49 is tied for the lowest its ever been–it was also 49 in 2007. Last year, the U.S. was three places higher. Reporters Without Borders explained the drop, stating:

In the Americas, the United States (49th, down three places) continues its decline. In 2014, the New York Times journalist James Risen came under government pressure to reveal his sources. Although the Obama administration backed away in that case, it continues its war on information in others, such as WikiLeaks.

Reporters Without Borders also cited the American treatment of Edward Snowden as another reason for the U.S.’s slip down the list. In addition, the treatment of the press in hostile situations, such as the environment in Ferguson, Missouri after the shooting of Michael Brown, was a reason for concern.

The United States’ commitment to Freedom of the Press doesn’t appear to go as far as it could. It’s concerning–hopefully some positive changes will be made in the New Year and we’ll move further up the list when the next rankings are released.

Anneliese Mahoney

Anneliese Mahoney is Managing Editor at Law Street and a Connecticut transplant to Washington D.C. She has a Bachelor’s degree in International Affairs from the George Washington University, and a passion for law, politics, and social issues. Contact Anneliese at amahoney@LawStreetMedia.com.

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Freedom of the Press has always, of course, applied to traditional journalists. If someone accuses a journalist in say, The Washington Post, or the New York Times, or even a small town newspaper of defamation, and the issue is of public concern, the plaintiffs have to prove that there was negligence or worse in order to win damages. Essentially a plaintiff would have to prove that a journalist wrote their story without properly checking out their sources, or some other negligent behavior. If they cannot prove that a reporter didn’t do their due diligence, they cannot be found guilty. This was established by a 1974 Supreme Court case, Gertz v. Robert Welch, Inc.

For years, this 1974 case sufficed as protecting journalists, because official media was really the only kind of media that existed. There was radio, newspapers, and TV, and all of those were mostly composed of people who had journalistic training and were part of a larger company. But with the advent of the internet, everyone can have a blog. In fact, if I so decided, I could go get a free WordPress blog right now and start writing just a few minutes later. And out of that prevalence of individual-driven media came the question: does this freedom of the press also apply to the informal and individual press?

Last week, the 9th US Circuit Court of Appeals ruled that the same standards that apply to journalists in print media also apply to bloggers and anyone else. The Reporters Committee for Freedom of the Press member Gregg Leslie said, “it’s not a special right to the news media. So it’s a good thing for bloggers and citizen journalists and others.”

The case came from a Montana blogger named Crystal L. Cox. In a blog post a few years ago, Cox stated that Obsidian Finance Group and its founder had committed fraud. So Obsidian Finance Group’s co-founder Kevin Padrick sued Cox. During the first trial, Cox lost the case and was ordered to pay the plaintiffs $2.5 million in damages. Cox did not deny that what she reported may have been false, just that she did not do it out of negligence, the same standard that a print reporter would have been held to. With this latest appeal, the 9th District Court agreed with Cox.

The Court stated,

The protections of the First Amendment do not turn on whether the defendant was a trained journalist, formally affiliated with traditional news entities, engaged in conflict-of-interest disclosure, went beyond just assembling others’ writings, or tried to get both sides of a story. As the Supreme Court has accurately warned, a First Amendment distinction between the institutional press and other speakers is unworkable.” They went on to cite cases in which individual speakers have been granted First Amendment rights, despite not being a part of the established press. For example, the First Amendment rights of authors have often been protected, regardless of their training, background, or affiliations.

This is very good news for anyone who has a blog or even a desire to post things in an individual capacity on their social network. It could also go a far way for advocacy groups that work unofficially for candidates and their rights to create media alleging things against candidates. It could also have important ramifications for blogging in other lawsuits. For example, if a blogger is treated as a journalist for the purposes of the First Amendment, they could also be treated as a journalist in a matter like protection of sources.

[LA Times]

—

Anneliese Mahoney (@AMahoney8672) is Lead Editor at Law Street and a Connecticut transplant to Washington D.C. She has a Bachelor’s degree in International Affairs from the George Washington University, and a passion for law, politics, and social issues. Contact Anneliese at amahoney@LawStreetMedia.com.

Featured image courtesy of [Jorge Quinteros via Flickr]

Anneliese Mahoney

Anneliese Mahoney is Managing Editor at Law Street and a Connecticut transplant to Washington D.C. She has a Bachelor’s degree in International Affairs from the George Washington University, and a passion for law, politics, and social issues. Contact Anneliese at amahoney@LawStreetMedia.com.

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