Okay, number 15-5016 at L. Christopher Van Hollen Jr., versus Federal Election Commission at L. Center for an individual freedom appellate. Mr. Kirby for the appellate, Ms. Carol for the appellate. May I please the court. I'm Tom Kirby, Council for the Center for Individual Freedom. I'll be arguing on behalf of the appellants. I'd like to reserve five minutes for a bottle. This appeal concerns the validity of an FAC regulation. That regulation provides that if corporations or labor unions independently spend for electionering communications, which is a particular category of political speech, they then must report and disclose contributions they receive. Quote for the purposes of furthering, close quote, that type of speech
. In a moment of bipartisan unity, the FAC borrowed that standard from the statute that was amended to regulate electionering communications. That standard applied to contributions made to parties engaged in so-called express advocacy. Express advocacy being speech that explicitly advocates for or against an identified candidate using one of the Buckley Magic words, both for elect defeat, that sort of thing. Point of appellant congressman to give you the model of this title that I know of Van Hollen persuaded the district court initially that this regulation that borrowing this standard from the underlying statute violated the statute itself. And the district court struck down the regulation at step one of Chevron, holding there with a clear prohibition of the use of this regulatory standard. We feel in this court reversed this court held that if you look at the statutory language on its face or using all of the traditional tools of statutory construction. There is room for this regulation for this regulatory standard. It was not clearly prohibited. There was a gap for the FEC to fill. And this court demanded the district court to consider Chevron step two and to consider related APAR betrayance issues that the district court had not reached because it had found a clear statutory prohibition of this regulation. On remaining the district court, nothing done it, again, this struck down the regulation. The district court said, okay, the statute doesn't preclude this regulation, but this regulatory standard. But nonetheless, this standard is forbidden by the statutory language and purpose
. And because it violates the statutory purpose clearly, it's also arbitrary and nutritious to use this regulatory standard. And so once again, the district court struck the statute down. Once again, we have a deal. In our briefs, we discuss a number of reasons that we respectfully disagree with the district court. But there are two overarching points that I like to focus on this morning, so the guidance of court, of course. And the first of those points is this. Contrary to the district court's belief, this statute does not require the federal election commission to maximize contribute contributor disclosures at all costs. It is certainly true that when Congress decided to go beyond regulating express advocacy and regulate election or communications, Congress intended for the contributions related to election or communications to be subject to disclosure provisions. And in that sense, these election and communication amendments were intended to increase disclosure. But Congress never said we have to have absolute disclosure without regard for costs or other considerations. Secondly, and this I think is interesting as well, there is no evidence that imposing the broader contributor disclosure standard on election and communications, the standard for which Congressman Ben Holland advocates. There is no evidence that imposing that more intrudership and more burdensome standard would produce more contributor disclosure. And the reason is very simple
. Electuring communications and express advocacy are mutually exclusive under the statute. If you've got expressed advocacy, you do not have an election and communication. The statute provides an explicit standard of disclosure or express advocacy, namely contributors who contributed for the purpose of supporting that speech. So if anyone faced what they thought was a burdensome or intrusive disclosure standard, because they were engaging in election and communication. And remember an election or communication already mentions a candidate or it's not an election or communication. All they have to do is drop in one of the Buckley Magic Word, the vote for reelect, beat something like that. That kicks them over into the statutory versioning for express advocacy. And their only obligation at that point is to disclose contributors who contributed for the purpose of supporting the speech. Now we don't have to speculate that that would happen because we had a laboratory experiment during the time that the district court's first ruling wasn't effected. And as we discussed in our papers, that's exactly what happened. Well, let me come back to this first point, which I think is really ultimately the determinative point that the statute simply doesn't have this unlimited disclosure purpose that seems to underlie the whole district court. You have to make it sufficiently inconsistent with what the district court ruled sufficiently ambiguous that you should have ruled differently. That's right
. But she really does. I'm sure I'm going to say if you read the decision, but of course you read the decision. Don't mean say that. But you really, as you read her decision, she relies on the belief time after time after time that there is this intent on the part of Congress to require essentially a maximum disclosure, unlimited disclosure. And then she says, and these various considerations undermine that purpose. But that's not what Congress did. There is constitutional interest on the other side, which has always been a proposal to me. Because there's a line of Supreme Court cases, it's not just a MAC entire. It's the Stratton and the Watch Hour case. There are several others that say that there's a part of the freedom of speech is the right to make anonymous speech. That's right. And the Supreme Court in upholding the McCain Findle ball, failed to mention that. The lion of the authority is still there
. And so, and I noticed that the Federal Election Commission at least hints at it doesn't cite the case and whatever. But it's a puzzle about how to square McCain Findle decision with the McCommill decision, right? With that line of authority, in fact, there's an opinion by Judge Easterbrook on the 7th Circuit. I don't know if you're familiar with majors versus Able, where he filed an opinion and it was not concurring or not the sending or anything. It was just called, I don't know. It was Dupatante. Yes, it was Dupatante. Here's my best effort at reconciling those principles for purposes of this case. I happen to think the ability to speak in honestly is very important and it's gotten short shrill. But the Federalists. Yeah. But shifting to what is necessary for the disposition of this case, the Supreme Court in Buckley and its progeny have said that at minimum, you have to recognize the compelled disclosure of the this type, or a substantial burden on speech. Now, they've said that burden can be sustained if it's reasonably tailored and sufficiently necessary to achieving a sufficiently important important government entrance. But what the Supreme Court has told us at least is where you're imposing this burden of disclosure, you have to have tailoring of some kind
. You have to show that what you're doing is necessary. Now, the district court seemed to believe that because the Supreme Court had allowed compelled disclosure in a number of cases that there was no longer any constitutional concern. And the law can just freely compelled disclosure willy knowing. But that's not what the Supreme Court has said. And one of the four, one of the things that the FEC said in adopting this regulation was we're trying to balance these various associational privacy rights against the needs of the statute. And we think we've achieved that because we could adequately tailor the statute. They tailored the statute by limiting the scope of disclosure with respect to election and communications to what the Supreme Court had said in Massachusetts. And the statute of law was to use the sentence for why was exactly the kind of disclosure necessary with respect with press advocacy. The district court's decision with respect to that was to say, let me see if I actually copied that down. It certainly was a striking statement. I didn't actually quote it in my notes. But what the district court said was Congress didn't order tailoring. Congress ordered exactly the opposite
. Well, I don't think Congress did number one, but number two, there would be a very interesting question where the Congress in the regulation of core political speech could order that there'd be no tailoring. I don't think it did. I think the elected election commission undertook tailoring here. And I think that's one of the many reasons. And I noticed that the district court gave summarized the opinion and gave three reasons at the beginning of that opinion. The second reason that strikes me as totally incorrect on the basis of the record says that there's no commentator asked the agency to include a purpose requirement. That's just not accurate. That is not accurate. There's just this is exactly for that. That is right. Moreover, in the notice of proposed rulemaking, the agency told everyone, here are the two polar possibilities of regulation. We might adopt, but we're also thinking about doing something in the middle. And they said we'd like, we'd like comments on whether or not it would be wise to adjust the disclosure standard
. It's almost in the language they end up using. In fact, there were comments that supported that particular approach, your honor. But even if they had not been once the agency upfront, this closes. This is the kind of thing we're thinking about doing. Then they're free to go ahead and do it, even if nobody likes to comment at all. But you're right. There were comments. And the comments did support the outcome that we have here. And that outcome is consistent with the important message. I'll talk about anything you want me to talk about, but my message today is what the FEC did is fully consistent with the language of the statute. And we know that for four reasons. The first reason we know we've already talked about a little bit is it's consistent with the language of the statute both on its face. And when read using traditional tools of statutory construction, and we know that because this court has told us so
. So we can start with that proposition that this regulation is consistent with what the statute actually says. The regulation change from the contribute language to dominate language. Is there an explanation for a while they did that and b what they thought the effect of it was? Well, your honor. The first time they established this regulation in this area. You should go with the one we've got now. When they got to the one we got now, they went back to contribute. I don't know why they went back to contribute, but it is the statutory language. They said they were borrowing the language relating to express advocacy. And I suppose they thought that made sense. The original regulation dealing only with individuals and partnerships. They moved back and forth between the two. That can be moved. That's right
. I guess it doesn't matter why. It doesn't matter if that's entirely a red herring your honor. There weren't any individuals and partnerships asking for any changes with respect to this proposal. The second round is a road with that hurry. That's exactly right. The second reason we know what the regulation did is consistent with the regulatory purpose is this business of how the federal election campaign act, which is the control and statute here treats expressed at the same. You'll recall that the statute that provides for regulation of election communications is an amendment to FICA. FICA is the overriding statute. FICA is explicit that with respect to express advocacy, people explicitly saying vote for or elect the thief this candidate. It's enough if they disclose contributors who contributed to support that kind of speech. Now, if Congress really intended through FICA to demand unlimited disclosure of all contributions without regard to contributor purpose, it would make no sense to have that very limited disclosure with respect to the clearest form of political advocacy. So we know from the structure of the statute that Congress was not in this statute attempting to achieve unlimited disclosure with respect to contributions. It's hard for me to understand where the application of this falls in the corporate field. It seems that it's just got to be nonprofits. I mean, people don't donate money to Microsoft for the motor company. Through the general treasury. I think your honor, the primary effect is upon nonprofit corporations. Many nonprofit entities are in fact incorporated. And the statute of regulation doesn't distinguish between business corporations and nonprofit corporations. They're all covered by this regulation. I think with business corporations. I don't want to see three corporations have to disclose in their returns. A file would be internal revenue service, the names of people that give them gifts and contributions. There is some such disclosure requirement, Your Honor. If you push me very far into that, I'm not a tax lawyer. But it is true that there is a requirement of disclosure
. It seems that it's just got to be nonprofits. I mean, people don't donate money to Microsoft for the motor company. Through the general treasury. I think your honor, the primary effect is upon nonprofit corporations. Many nonprofit entities are in fact incorporated. And the statute of regulation doesn't distinguish between business corporations and nonprofit corporations. They're all covered by this regulation. I think with business corporations. I don't want to see three corporations have to disclose in their returns. A file would be internal revenue service, the names of people that give them gifts and contributions. There is some such disclosure requirement, Your Honor. If you push me very far into that, I'm not a tax lawyer. But it is true that there is a requirement of disclosure. Is that considered by the names of the contributors considered return information that the IRS is prohibited from disclosing? I'm going to return out and look to my co-counsel. It is not publicly available with that. May I cancel it with my ex-vert here? Give it a raise to control with the exit. It's on the confidential part of the form and not told names and addresses or not. I believe that to be true. But this is the gentleman in that list itself. This is a disclosure that wouldn't be required. Otherwise, as to whether for profit businesses sometimes receive contributions, Your Honor, it gets into the whole question of what do you mean by a contribution? There are contributions to capital. There may be contributions to retirement funds that are owned by the corporation. The corporation may have charitable operations or employee picnic areas or all sorts of things that may get contributions of one kind or another. And this all sounds very far removed from federal election campaign issues except that. If you accept Congressman that all in this position that whenever the corporation makes some substantial expenditure out of it, and you accept the general funds, it has to identify all of its contributors. That's the kind of disclosure you start getting
. Is that considered by the names of the contributors considered return information that the IRS is prohibited from disclosing? I'm going to return out and look to my co-counsel. It is not publicly available with that. May I cancel it with my ex-vert here? Give it a raise to control with the exit. It's on the confidential part of the form and not told names and addresses or not. I believe that to be true. But this is the gentleman in that list itself. This is a disclosure that wouldn't be required. Otherwise, as to whether for profit businesses sometimes receive contributions, Your Honor, it gets into the whole question of what do you mean by a contribution? There are contributions to capital. There may be contributions to retirement funds that are owned by the corporation. The corporation may have charitable operations or employee picnic areas or all sorts of things that may get contributions of one kind or another. And this all sounds very far removed from federal election campaign issues except that. If you accept Congressman that all in this position that whenever the corporation makes some substantial expenditure out of it, and you accept the general funds, it has to identify all of its contributors. That's the kind of disclosure you start getting. A for-profit corporation spends money on a radio ad up in Washington State, and they got a contribution to an employee area down in Louisiana. And they've got to disclose that. Is it a means something with respect to their speech up in Washington State? Your Honor, I see that I'm into my rebuttal time here. I would like to reserve that time. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Now. Thank you. Thank you
. A for-profit corporation spends money on a radio ad up in Washington State, and they got a contribution to an employee area down in Louisiana. And they've got to disclose that. Is it a means something with respect to their speech up in Washington State? Your Honor, I see that I'm into my rebuttal time here. I would like to reserve that time. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Now. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you
. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you
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Okay, number 15-5016 at L. Christopher Van Hollen Jr., versus Federal Election Commission at L. Center for an individual freedom appellate. Mr. Kirby for the appellate, Ms. Carol for the appellate. May I please the court. I'm Tom Kirby, Council for the Center for Individual Freedom. I'll be arguing on behalf of the appellants. I'd like to reserve five minutes for a bottle. This appeal concerns the validity of an FAC regulation. That regulation provides that if corporations or labor unions independently spend for electionering communications, which is a particular category of political speech, they then must report and disclose contributions they receive. Quote for the purposes of furthering, close quote, that type of speech. In a moment of bipartisan unity, the FAC borrowed that standard from the statute that was amended to regulate electionering communications. That standard applied to contributions made to parties engaged in so-called express advocacy. Express advocacy being speech that explicitly advocates for or against an identified candidate using one of the Buckley Magic words, both for elect defeat, that sort of thing. Point of appellant congressman to give you the model of this title that I know of Van Hollen persuaded the district court initially that this regulation that borrowing this standard from the underlying statute violated the statute itself. And the district court struck down the regulation at step one of Chevron, holding there with a clear prohibition of the use of this regulatory standard. We feel in this court reversed this court held that if you look at the statutory language on its face or using all of the traditional tools of statutory construction. There is room for this regulation for this regulatory standard. It was not clearly prohibited. There was a gap for the FEC to fill. And this court demanded the district court to consider Chevron step two and to consider related APAR betrayance issues that the district court had not reached because it had found a clear statutory prohibition of this regulation. On remaining the district court, nothing done it, again, this struck down the regulation. The district court said, okay, the statute doesn't preclude this regulation, but this regulatory standard. But nonetheless, this standard is forbidden by the statutory language and purpose. And because it violates the statutory purpose clearly, it's also arbitrary and nutritious to use this regulatory standard. And so once again, the district court struck the statute down. Once again, we have a deal. In our briefs, we discuss a number of reasons that we respectfully disagree with the district court. But there are two overarching points that I like to focus on this morning, so the guidance of court, of course. And the first of those points is this. Contrary to the district court's belief, this statute does not require the federal election commission to maximize contribute contributor disclosures at all costs. It is certainly true that when Congress decided to go beyond regulating express advocacy and regulate election or communications, Congress intended for the contributions related to election or communications to be subject to disclosure provisions. And in that sense, these election and communication amendments were intended to increase disclosure. But Congress never said we have to have absolute disclosure without regard for costs or other considerations. Secondly, and this I think is interesting as well, there is no evidence that imposing the broader contributor disclosure standard on election and communications, the standard for which Congressman Ben Holland advocates. There is no evidence that imposing that more intrudership and more burdensome standard would produce more contributor disclosure. And the reason is very simple. Electuring communications and express advocacy are mutually exclusive under the statute. If you've got expressed advocacy, you do not have an election and communication. The statute provides an explicit standard of disclosure or express advocacy, namely contributors who contributed for the purpose of supporting that speech. So if anyone faced what they thought was a burdensome or intrusive disclosure standard, because they were engaging in election and communication. And remember an election or communication already mentions a candidate or it's not an election or communication. All they have to do is drop in one of the Buckley Magic Word, the vote for reelect, beat something like that. That kicks them over into the statutory versioning for express advocacy. And their only obligation at that point is to disclose contributors who contributed for the purpose of supporting the speech. Now we don't have to speculate that that would happen because we had a laboratory experiment during the time that the district court's first ruling wasn't effected. And as we discussed in our papers, that's exactly what happened. Well, let me come back to this first point, which I think is really ultimately the determinative point that the statute simply doesn't have this unlimited disclosure purpose that seems to underlie the whole district court. You have to make it sufficiently inconsistent with what the district court ruled sufficiently ambiguous that you should have ruled differently. That's right. But she really does. I'm sure I'm going to say if you read the decision, but of course you read the decision. Don't mean say that. But you really, as you read her decision, she relies on the belief time after time after time that there is this intent on the part of Congress to require essentially a maximum disclosure, unlimited disclosure. And then she says, and these various considerations undermine that purpose. But that's not what Congress did. There is constitutional interest on the other side, which has always been a proposal to me. Because there's a line of Supreme Court cases, it's not just a MAC entire. It's the Stratton and the Watch Hour case. There are several others that say that there's a part of the freedom of speech is the right to make anonymous speech. That's right. And the Supreme Court in upholding the McCain Findle ball, failed to mention that. The lion of the authority is still there. And so, and I noticed that the Federal Election Commission at least hints at it doesn't cite the case and whatever. But it's a puzzle about how to square McCain Findle decision with the McCommill decision, right? With that line of authority, in fact, there's an opinion by Judge Easterbrook on the 7th Circuit. I don't know if you're familiar with majors versus Able, where he filed an opinion and it was not concurring or not the sending or anything. It was just called, I don't know. It was Dupatante. Yes, it was Dupatante. Here's my best effort at reconciling those principles for purposes of this case. I happen to think the ability to speak in honestly is very important and it's gotten short shrill. But the Federalists. Yeah. But shifting to what is necessary for the disposition of this case, the Supreme Court in Buckley and its progeny have said that at minimum, you have to recognize the compelled disclosure of the this type, or a substantial burden on speech. Now, they've said that burden can be sustained if it's reasonably tailored and sufficiently necessary to achieving a sufficiently important important government entrance. But what the Supreme Court has told us at least is where you're imposing this burden of disclosure, you have to have tailoring of some kind. You have to show that what you're doing is necessary. Now, the district court seemed to believe that because the Supreme Court had allowed compelled disclosure in a number of cases that there was no longer any constitutional concern. And the law can just freely compelled disclosure willy knowing. But that's not what the Supreme Court has said. And one of the four, one of the things that the FEC said in adopting this regulation was we're trying to balance these various associational privacy rights against the needs of the statute. And we think we've achieved that because we could adequately tailor the statute. They tailored the statute by limiting the scope of disclosure with respect to election and communications to what the Supreme Court had said in Massachusetts. And the statute of law was to use the sentence for why was exactly the kind of disclosure necessary with respect with press advocacy. The district court's decision with respect to that was to say, let me see if I actually copied that down. It certainly was a striking statement. I didn't actually quote it in my notes. But what the district court said was Congress didn't order tailoring. Congress ordered exactly the opposite. Well, I don't think Congress did number one, but number two, there would be a very interesting question where the Congress in the regulation of core political speech could order that there'd be no tailoring. I don't think it did. I think the elected election commission undertook tailoring here. And I think that's one of the many reasons. And I noticed that the district court gave summarized the opinion and gave three reasons at the beginning of that opinion. The second reason that strikes me as totally incorrect on the basis of the record says that there's no commentator asked the agency to include a purpose requirement. That's just not accurate. That is not accurate. There's just this is exactly for that. That is right. Moreover, in the notice of proposed rulemaking, the agency told everyone, here are the two polar possibilities of regulation. We might adopt, but we're also thinking about doing something in the middle. And they said we'd like, we'd like comments on whether or not it would be wise to adjust the disclosure standard. It's almost in the language they end up using. In fact, there were comments that supported that particular approach, your honor. But even if they had not been once the agency upfront, this closes. This is the kind of thing we're thinking about doing. Then they're free to go ahead and do it, even if nobody likes to comment at all. But you're right. There were comments. And the comments did support the outcome that we have here. And that outcome is consistent with the important message. I'll talk about anything you want me to talk about, but my message today is what the FEC did is fully consistent with the language of the statute. And we know that for four reasons. The first reason we know we've already talked about a little bit is it's consistent with the language of the statute both on its face. And when read using traditional tools of statutory construction, and we know that because this court has told us so. So we can start with that proposition that this regulation is consistent with what the statute actually says. The regulation change from the contribute language to dominate language. Is there an explanation for a while they did that and b what they thought the effect of it was? Well, your honor. The first time they established this regulation in this area. You should go with the one we've got now. When they got to the one we got now, they went back to contribute. I don't know why they went back to contribute, but it is the statutory language. They said they were borrowing the language relating to express advocacy. And I suppose they thought that made sense. The original regulation dealing only with individuals and partnerships. They moved back and forth between the two. That can be moved. That's right. I guess it doesn't matter why. It doesn't matter if that's entirely a red herring your honor. There weren't any individuals and partnerships asking for any changes with respect to this proposal. The second round is a road with that hurry. That's exactly right. The second reason we know what the regulation did is consistent with the regulatory purpose is this business of how the federal election campaign act, which is the control and statute here treats expressed at the same. You'll recall that the statute that provides for regulation of election communications is an amendment to FICA. FICA is the overriding statute. FICA is explicit that with respect to express advocacy, people explicitly saying vote for or elect the thief this candidate. It's enough if they disclose contributors who contributed to support that kind of speech. Now, if Congress really intended through FICA to demand unlimited disclosure of all contributions without regard to contributor purpose, it would make no sense to have that very limited disclosure with respect to the clearest form of political advocacy. So we know from the structure of the statute that Congress was not in this statute attempting to achieve unlimited disclosure with respect to contributions. It's hard for me to understand where the application of this falls in the corporate field. It seems that it's just got to be nonprofits. I mean, people don't donate money to Microsoft for the motor company. Through the general treasury. I think your honor, the primary effect is upon nonprofit corporations. Many nonprofit entities are in fact incorporated. And the statute of regulation doesn't distinguish between business corporations and nonprofit corporations. They're all covered by this regulation. I think with business corporations. I don't want to see three corporations have to disclose in their returns. A file would be internal revenue service, the names of people that give them gifts and contributions. There is some such disclosure requirement, Your Honor. If you push me very far into that, I'm not a tax lawyer. But it is true that there is a requirement of disclosure. Is that considered by the names of the contributors considered return information that the IRS is prohibited from disclosing? I'm going to return out and look to my co-counsel. It is not publicly available with that. May I cancel it with my ex-vert here? Give it a raise to control with the exit. It's on the confidential part of the form and not told names and addresses or not. I believe that to be true. But this is the gentleman in that list itself. This is a disclosure that wouldn't be required. Otherwise, as to whether for profit businesses sometimes receive contributions, Your Honor, it gets into the whole question of what do you mean by a contribution? There are contributions to capital. There may be contributions to retirement funds that are owned by the corporation. The corporation may have charitable operations or employee picnic areas or all sorts of things that may get contributions of one kind or another. And this all sounds very far removed from federal election campaign issues except that. If you accept Congressman that all in this position that whenever the corporation makes some substantial expenditure out of it, and you accept the general funds, it has to identify all of its contributors. That's the kind of disclosure you start getting. A for-profit corporation spends money on a radio ad up in Washington State, and they got a contribution to an employee area down in Louisiana. And they've got to disclose that. Is it a means something with respect to their speech up in Washington State? Your Honor, I see that I'm into my rebuttal time here. I would like to reserve that time. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Now. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you. Thank you