Laurence Kaye on Digital Media Law

Digital Britain: Blueprint for the future?

Dear reader

'Digital Britain', published June 16th, is not modest in its stated ambition: "Digital Britain is the government's vision of an of an economy and society where core working activities are based around knowledge, skills and information. It represents a strategic plan to accelerate growth in the digital industries and cement the UK's position as a world leader for innovation, investment and quality."

It's certainly in keeping with the zeitgeist in its use of social media tools. You can get social media news releases and check out the Digital Britain Dashboard' on 'Pageflakes'.

So it's a bit odd that things seem to have gone a bit quiet after the initial flurry of reactions to its proposals for 'next generation' broadband networks, legislation to deal with illicit P2P file sharing and 'top slicing' the BBC licence fee primarilty to fund broadcast regional news.

I think the reason is that Digital Britain is big in scope and ambition. Whether it all adds up to blueprint for keeping - putting? -  the UK into the global no. 1 spot is a moot point. But there's a lot to it.

I see 'Digital Britain' as a website, a mix of of its own 'original' content (e.g. on the issues I've justs mentioned) plus lots of snippets and hyperlinks pointing to other developments which are already in process. But does it all add up to systemic change? Potentially "yes", but there's obviously a big question mark about how far circumstances will allow 'Digital Britain' to deliver its vision.

Also, it's probably fair to say that the most significant areas of change focus on the network and the funding of public sector content and services rather than in the area of copyright and commercial content.

With those caveats here are some reasons why, in overall terms, Digital Britain gets a 'yes' vote in the scale of its ambition and scope.

The importance of public sector content

Public sector is no longer just about broadcast media. The Report states that Government commissiong may represent as much as 30% of total investment in professional UK online content (source: research by Analysys). Think central and local Government information. Also think the arts, cultural and scientific institutions. So plans about how those institutions licence their content are hugely significant to the digital content sector. Check out Chapter 8 ("the Journey to Digital Government'.

The same chapter is also worth reading to see how dramatic the shift is to the Web as the main platform for accessing public services - the 'Digital Switchover of Public Services'.

Legislative plans on illegal P2P filesharing

OK, not exactly new - you can see the background here - we can now the Government's plans taking shape. OFCOM will be charged with a duty to take steps to reduce copyright infringement. It will discharge this duty by requiring ISPs to accept 2 conditions: (1) to notify account holders where their account appears to have been used for infringement and (2) an obligation to maintain and make available - based on a Court order - data about enable 'serious infringers' to be identified to enable court action. These 2 obligations will be based on a detailed code of practice to be drafted, possibly by a yet to be created industry body - a 'rights agency' or 'rights authority'.

If these measures do not achieve a 70% target for reduction of unlawful file sharing, of  OFCOM will be able to impose additional conditions on ISPs requiring them to apply technical measures such as Blocking (Site, IP, URL), Protocol blocking, Port blocking and Bandwidth capping. The Government has published a Consultation on these proposals which can be found here.

Online = Offline penalties

Again, not in the category of 'originality' - but nonetheless important - Digital Britain announces the Government's intention to introduce exceptional statutory maxima of £50,000 for all IP offences. This was Recommendation 36 of the Gowers Review.

UK copyright law - some significant tweaks

Digital Britain gives pointers to some of the proposals that resulted from the Gowers Review are likely to see the legislative light of day. It talks about updating existing copyright exceptions to allow certain public institutions to make preservation copies of films and sound recordings and also to enable educational institutions to communicate copies of material to 'distance learning' students.

Digital Britain also refers to plans to introduce legislation to enable commercial schemes to operate under  collecting societies could licence 'orphan works' - copyright works whose authors can't be found. This isn't a minor issue. The British Library estimate that 40% of their archive count as orphan works.

These are covered in Chapter 4 which also mentions another potential change which would greatly increase the range of works which can be licensed by collecting societies. Following the example in the Nordic countries, collecting societies may be able to offer licences over works which have not been mandated to them by the relevant rights holders.

UK copyright law - other changes?

Digital Britain's focus is, of course, the UK only. So any of the other 'big issues' that are currently floating around, such as broad provisions for 'fair use', fall into the remit of the EU and the World Intelectual Property Organisation. So on these issues, Digital Britain doesn't so much duck the question as defer to the work being led by the IPO following publication of 'Strategic Priorities for Copyright' which has an international and strategic focus. 'SABIP', the Strategic Advisory Board for Intellectual Property Policy', is currently working on a number of issues - check out my post here. As a member of SABIP's Copyright Expert Panel, I'm involved in this.

What about support for innovation in the creative industries?

To be frank, it's a bit of a hotch potch here. But there's certainly some prospective good news for the computer games industry on potential tax breaks; some discussion about rights-based funding mechanisms such as levies and cable re-transmission fees and a few thoughts about film, cinema and literature. These can be found in Chapter 4.

So when you add it all up, it's a landscape of significant and ongoing change. But for the world of commercial content, the future ultimately lies not in Digital Britain but in new business models.

Watch out for my next post on the 'Why Pay for Content?', the topic of a recent debate hosted by the Publishers Association on June 24th. Although it focused on academic and professional publishing, the question is at no.1 on the agendas of most sectors of the content industries.

Have a good week.

Laurie Kaye
 

A year's lifespan for every tweet?

Dear reader,

I will be blogging soon about Digital Britain so watch this space. In the meantime, Yasmin weighs up a regulatory development in the field of data retention in this post and in a related article on our website.

Laurie

The Data Retention (EC Directive) Regulations 2009

Landline and mobile phone providers have been required to retain certain communications data (e.g. time/length of call, name/address of caller) since 2007. New Regulations introduced a couple of months ago have extended this obligation to cover internet, email and VOIP as well, which could potentially see every post, tweet and poke being compulsorily retained for 12 months.

This move may be seen as a welcome and necessary weapon in the fight against terrorism and other serious crime which can be incited, orchestrated or even conducted online. However, others would counter that it is a threat to privacy as well as an extra compliance burden for service providers.

The new Regulations came into force on 6th April and require certain providers of telephone and internet services to retain communications data for a year. This ‘communications data’ relates to the who/when/where of a communication (but not the content) and ranges from log on/call times and durations to the  names and addresses of people sending and receiving communications (callers, callees, emailers, emailees... YouTubers? Twitterers?)

Only public communications providers who are notified by the Secretary of State will be required to comply with the Regulations. It remains to be seen which companies will receive such notification, but  ISPs (e.g. BT Internet) will certainly be notified, as will mobile phone providers (if they haven't already, e.g. O2) and VOIP operators (e.g. Skype). It will be interesting to see whether the Government will extend such notification to search engines (Google?) and website operators – particularly social networking sites (Facebook?), where mass communication (Twitter?) is key.

Pros

The Home Office has pointed out that communications data has long proved valuable for law enforcement purposes, in detecting crimes, investigating suspects and prosecuting offenders. Although many communications providers already retain this information in any event, they delete it as soon as their business purposes have been met (whether because of data protection legislation or the costs of storage). The Home Office argues that long running investigations, which may require communications data some time after a crime has been detected, tend to relate to the most serious crimes and as such there is a strong public interest in obliging relevant companies to preserve such evidence.

If every email, IM, tweet and post is logged along with the sender’s name, address and geographical location at the time, then law enforcers will find it easier to verify alibis, trace contacts and track movements. Criminals will be unable to rely on the perceived anonymity of the Web to disguise their activities. The Regulations send a clear message that people cannot hide behind online personalities to conduct criminal behaviour – ‘no avatar is an island’, if you like.

Cons

However, despite the stated benefits of the Regulations as a crime fighting tool, legitimate data protection concerns have been raised by privacy groups, who object to being monitored (or spied on) and criticise the measure as a step towards a ‘Big Brother’ state. As the Government has not had a good track record recently with safeguarding data, concerns over the generation and retention of increasing amounts of data are perhaps justified.

What I see as the biggest concern is the fact that the Regulations do not limit the disclosure and use of the data to investigation of the serious crimes on the basis of which the Regulations are justified. The Regulations blandly state that “Access to data retained in accordance with these Regulations may be obtained only (a) in specific cases, and (b) in circumstances in which disclosure of the data is permitted or required by law.” It is not difficult to envisage courts interpreting this provision widely and ordering disclosure in civil cases where this information would be useful – for example, defamation claims (to discover the details of a big-mouth blogger) and divorce cases (to check a cheating spouse’s phone calls). We have previously postedon how 'Norwich Pharmacal' orders have been made to disclose the contact details of certain libellous chat room participants. We may see increasing similar instances as more companies are required to hold more data for longer, meaning more data is available for disclosure under court order. This may not necessarily be a bad thing, but it does depart from the stated purpose of the Regulations and the reasoning behind their introduction.  

We should not forget that the Regulations will impose an additional compliance burden on the notified public communications providers. The extent to which this is an issue depends on the amount of companies notified under the Regulations and the additional measures they will have to take to understand and implement their obligations under the Regulations. The Regulations have gone some way to addressing this by stating that the Secretary of State “may reimburse any expenses incurred by a public communications provider in complying with the provisions of these Regulations.” However, this subsidy ultimately comes from credit-crunched UK taxpayers, who may query the efficacy and efficiency of setting up the systems required to implement the Regulations.

If you are keen to find out more about these Regulations, please see my article and the Explanatory Memorandum.

Enjoy the weekend!

Yasmin Joomraty

Web 2.0, UGC, Mash ups: who owns the data, who is responsible?

Dear reader

I gave a presentation on this subject at the European Directory Publishers Conference in Barcelona on May 29th. (I arrived just as the Barcelona team were on their triumphal tour around the City. As a Manchester United supporter, the pleasure of being in this great City was small compensation!).

The directory publishing industry has moved rapidly from a traditional, print-based business with a well-established annual cycle of data gathering, production and distribution to the front line of Web 2.0. Whilst print still continues, the hot topics are now about building online communities and search-driven directories 'on the fly' combining proprietary content, web harvested information and user generated content.

So I thought you might like to read my presentation given to the conference and to take a look at my slides. You can view them here.

Have a good week.

Laurie

Copyright: green shoots?

Dear reader

You'll have read from previous posts about the recurring theme (or is it a formula?) of new business models + effective copyright enforcement = 21st century copyright.

It seems to me that 'green shoots' of both elements are springing up around us. But where's the anecdotal evidence?

Business models?

Let's start on the business model side. Amongst many challenges, two of the biggest are streamlining the cost and efficiency of clearing rights for online services and how to 'monetise' - horrible expression - content.

So it was interesting to see the announcement reported in the FT yesterday that PRS for Music is lowering the prices for pricing music online by almost two thirds - good news for streaming services like 'Spotify'. The FT reported that PRS wil receive 0.085p per song played online, down from 0.2p. In return, PRS' share of advertising or other revenues from services will rise from 8% to 10.5%.

Meanwhile, Facebook has taken a US$200m investment from the Russian company Digital Sky Technologies, valuing Facebook's preferred stock at US$10b. Whilst the valuation undoubtedly appealed to Facebook, Yuri Milner, founder of DSG which has stakes in 30 internet companies in Russia, was quoted in the FT yesterday, saying that "our network focused on monetisation a bit earlier than Facebook."

And then we have the resurgence of the debate within the newspaper industry about paid for content, although sceptics argue that only premium content, and not 'news of the day', may support subscription or other paid for models. But perhaps the advertising revenue sharing deal struck by PRS has potential for the newspaper industry in its relationship with search.

Effective copyright enforcement

It seems to me to be pretty clear that the 'credit crunch', and the loss of the financial services industies ability -at least for the time being - to sustain ever rising revenues, both for itself and the taxman, has raised the economic profile and signficance of the creative industries. In turn, that's leading to a joining up of the dots betweeen.......creative content.........jobs...........copyright enforcement. Under the headline 'Unions and publishers join to fight piracy', the FT reported today - that representatives of media unions on both sides of the Atlantic are co-ordinating their approach as the 'Digital Britain' report nears publication. Following the proposals in the interim Report and then Consultation on the Digital Rights Agency, momentum will gather for a legislative solution involving ISP's to the issue of illegal file sharing.

Getting that sorted won't be easy. Just take a look around Europe. With thanks to my colleague Angela Mills at EPC, here's a couple of key developments. The EU's Telecoms Package is still bogged down with Amendment 138,  a measure that would force Member States to say, in their national law, that internet access can never be restricted without a “prior decision” from a judiciary authority. Meanwhile, France is going to create a high authority for the copyright protection and the dissemination of works on the internet (Hadopi). It is being created in order to avoid the need for judicial prosecution.  The national debate has been stormy and it is not over yet: the Socialist opposition has gone to the Constitutional Court considering the planned measure to be “easily circumvented, counter-productive, unworkable and costly”. The Court will give its decision by June 19th and it could yet end up with the ECJ. So watch this space!

One thing is for sure. National measures to deal with the issue of illegal file sharing - here and around Europe and beyond - will be taken.

Enjoy your week. I'm off to Barcelona today to talk about "Web 2.0, UGC, Mash ups : who owns the data, who is responsible?" at the European Association of Database Publishers (EADP)Congress. As a Manchester United supporter, I'm hoping Barcelona's supporters won't gloat! Well, at least the excellent tapas will be some small consolation.

Laurie Kaye

Profiling, Targeting, Behavioural Advertising

Dear Reader,

My colleague, Yasmin Joomraty, attended a very interesting forum on 'Behavioural Targeting, Social Networking and the Challenges of Online Privacy' earlier this week. We were discussing her views and I asked her to blog about them so here follow her personal reflections on profiling, targeting and behavioural advertising...

(Yasmin writes) "I returned to my desk today to write up my take on the issues discussed at the Westminster eForum. At the forum, the Assistant Information Commissioner had mentioned the 'Personal Information Promise' on the ICO website to which companies can sign up. I Googled it to find out more. As soon as I had keyed "personal info" into the search bar, top of the list of Google's suggested search terms for my search was - you guessed it - "Personal Information Promise". In light of the comments the delegate from Phorm had made regarding search engines profiling and targeting users in more ways than Phorm would ever wish to, I chuckled to myself at this timely demonstration. 

I then went to look up "privacy enhancing technologies" and, again, no sooner had I typed "privacy e" but Google had guessed what I was looking for. Handy, yes. But a little disconcerting in light of the 'challenges for online privacy' I was contemplating.

We have written in the past about Google's raps on the knuckles over keyword advertising, legal battles over 'scraping' third party content, book deals struck, thumbnails infringing copyright, sniping over news snippets - the list goes on - and I thought I knew a lot about Google... Except for what Google knows about me.

Google's Privacy Overview states, predictably, that:

• "Google uses cookies and other technologies to enhance your online experience and to learn about how you use Google services in order to improve the quality of our services."

and 

• "Google’s servers automatically record information when you visit our website or use some of our products, including the URL, IP address, browser type and language, and the date and time of your request."

So that explains the customised search suggestions. Google knows my IP address and has tracked my online behaviour in order to provide me with this service - which, incidentally, I do not remember signing up for. This raises 3 questions for me:

1. What constitutes personal data? An IP address has been held to be personal data. So Google has obligations under the DPA here. 
2. Does it matter whether information about me constitutes personal data or not? As technologies evolve and trackers can find out more about me, should the obligations under the DPA stop at personal data? Do I have a valid objection to companies building up a profile of me which, although it does not constitute personal data, consists only of numbers and codes, and is never even read by a human but simply passes through a 'black box' (as the Phorm delegate called it), but which nevertheless corresponds to me and my habits, some of which may be private? As society understands the new technologies better, there is scope for data about my behaviour finding its way to third parties and even saying private things about me to others? For example, if a friend uses my laptop and notices that the suggested search terms and targeted ads are geared towards Botox, this may reveal something about me that is private and if not constitutes then relates to personal data. 
3. Have I consented? I would describe myself as protective over my online presence and reluctant to receive marketing communications - I tend to search for opt-outs and actively select my preferences. The notion of informed consent is often debated but it seems to me that if I find it difficult to ascertain what Google is doing with my information and how to opt out of the same, then how will the 'reasonable man' who is not actively looking or notified?  

More worryingly, another point in Google's Privacy Overview is: 

• "Google collects personal information when you register for a Google service or otherwise voluntarily provide such information. We may combine personal information collected from you with information from other Google services or third parties to provide a better user experience, including customizing content for you."

Does this include/anticipate collaboration with Phorm-like behavioural trackers?

As new technologies and social attitudes merge to cause the shift in media, publishing and entertainment from a 'one to many' broadcast to the two way dialogue of 'many to many' communication, so advertising is reaching its holy grail of targeting specific individuals with relevant messages. 

An individual's online presence makes him part of the online world (consumer, broadcaster, commentator, buyer, seller, MMORPG player all in one) in a way that he never was before TV remotes had red buttons. The fact that that individual has an online presence exposes him to risks which do not apply in the offline world. These risks mostly centre on that individual's data - the type he chooses to share and the type he does not know he is sharing.

However, advertising has rich benefits and should not be unduly stifled. It is the driver for online growth and funds much of our virtual activities. It offers choice to consumers and can entertain, inform and empower.

The difficulty, as always, is in getting the balance right."  

Yasmin Joomraty   

Report on the European Commission's Content Online Platform

Dear Reader

The European Commission has just published its Final Report on the Content Online Platform which was set up as part of its 'Creative Content' initiative to get stakeholders together to debate key issues. You can read it here - Download Col_platform_report (2).

What struck me on first read were these:

• Although the pace of change is slow in some areas - like solutions for multi-territorial licences - in other areas today's 'hot topic' seems distinctly cold tomorrow. Take a look at the conclusions about 'DRM' in the sense of technical protection measures. The growth of TPM-free services has moved on the debate.
• There are no 'one size fits all solutions'. What is right for, say, film and music online is not the same for online publishing.
• There is an odd disconnect between (1) the different approaches in Member States for tackling piracy, where the debate is mired in parochial and industry- specific concerns versus (2) the almost universal recognition that a lack of a common and consistent approach will hold back the development of successful cross-border business models.
• Solutions are needed tailored to individual industry needs and 'soft law', such as Codes of Practice and common standards, will get us more quickly to where we all want to be....

a rich and diverse range of online offerings which give consumers what they want and which deliver a fair return to creators and producers.

Have a good week.

Laurie Kaye

 

Copyright and Consumers

Dear Reader,  

The UK Government has been criticised on a number of fronts in the last week in the context of its privacy laws – see the European Commissioner’s rap on the knuckles for the UK’s ‘liberal approach to data protection’ and the Joseph Rowntree Reform Trust’s report on the UK Government’s intrusive databases.

We will follow these data protection issues and blog about them in due course. However, in light of last week's Pirate Bay decision (the topic of our last post), we have decided to focus on the UK’s copyright laws, which have been criticised in a report by Consumers International, the international consumer rights organisation.

On its blog, Consumers International emphasises that IP is a consumer issue because although the “intellectual property system is often portrayed as a battleground in which the creators of content are pitted against lawless "counterfeiters" and "pirates”…the biggest impact of harsh intellectual property laws has not been on commercial counterfeiters, but on ordinary consumers.” The biggest bugbear is that some countries’ laws are out of sync with new technologies and consumer expectations (e.g. format shifting):  

“These unbalanced laws prohibit everyday activities such as uploading a home video with music to YouTube, backing up your DVD collection, creating a fan website - even, in many countries, using a VCR or an iPod. Even if these laws are not enforced (which, too often, they are), they wrongly allow consumers to be branded as thieves and outlaws.”

Consumers International’s country report on the UK concludes that “UK copyright law is substantially different from that of other countries. It is generally very restrictive. Copyright is treated as [a] property right…There are no fair use exception[s] in UK law, only some limited permitted acts. There is no provision that may be termed “private copying” exception and UK copyright law does not distinguish between private or corporate copyright infringement...Non-profit or private use are generally not a mitigating factor in UK law.”

But the flip side of the coin is that the UK copyright system incentivises creativity and protects rightsholders. The UK Creative Industries are a major source of export-driven revenue for UK plc and those industries are underpinned by copyright. So consumer demands must be balanced with safeguarding the well being of those industries.

We will be blogging shortly on Digital Britain and SABIP. In the meantime, it is clear that the consumer-driven pressure for copyright reform continues.

The overall message is that we need to strike a balance in protecting creativity and investment whilst meeting the demands of new technology and consumer expectations.

Laurence Kaye / Yasmin Joomraty

Pirates Defeated in Sweden

Dear Reader,

The judgment handed down in Sweden last week, which sentenced the owners of the file sharing website Pirate Bay to a year in prison and a hefty fine, has unleashed a torrent of opinions from bloggers on the copyright/consumer debate. It's even led to speculation that search engine links could infringe copyright.

Why the 'link' between Pirate Bay and search? Well, .torrent files are a more sophisticated type of Internet link (such as an http hyperlink) and the Pirate Bay is an “open database” of .torrent files.

But the key point in the Pirate Bay decision is that the vast majority of content for which people searched via the Pirate Bay site site was copyright infringing material and this was central to their business model. Whilst Google and other search engines may return some links to illegal content, the vast majority of content indexed and linked to by Google as a search engine is not in that category.
In fact, the Pirate Bay decision is consistent with the line of cases on P2P file sharing software in Kazaa and Grokster. In Grokster, the US Supreme Court decided that Grokster, Streamcast and other providers of file sharing software can be held responsible for copyright infringement carried out by their users where they take "affirmative steps to  foster infringement."

But the US Supreme Court was concerned about the potentially 'chilling' effect of its decision, especially bearing in mind that P2P software can be used as a very effective way of distributing content in a legal way. So the Court made it clear that mere knowledge of potential or actual infringement was not enough to make a distributor liable; instead, the Court must find what it called 'culpable expressions or conduct on the distributor's part which show that it intended the use of its device to infringe copyright'. And that's the key point.

Litigation, as they say, is a 'turkey shoot' and given the dearth of case law in this area it's hard to be certain that we would have had the same outcome if the Pirate Bay case had been heard in the UK. But there's certainly a good chance that the result would be the same.

The nearest UK case is CBS v Amstrad which established that just because a person supplies a product (or, presumably, a service) which may be used to infringe copyright, this does not necessarily mean that person has authorised the infringement. Specifically, the UK court held that Amstrad had not authorised infringement by selling twin-deck tape recorders which might have facilitated copying in breach of copyright, but did not "authorise" such a breach because they could also be used for copying legitimate material.

However, in the Amstrad case, one of the factors that the court took account in reaching this decision was that Amstrad had made it clear in advertising the product that certain copying would require permission from the copyright owner and that Amstrad did not have authority to grant any required permission.

Pirate Bay, by contrast, has consistently goaded the media and positioned itself as leading a rebellion against copyright laws and, as already noted, the vast majority of content that people looked for via the Pirate Bay site site was copyright infringing material.

So I don't think that the Pirate Bay decision shakes the foundation of the Internet. If you market something which is designed and marketed to encourage people to take stuff belonging to someone else for free, what do you expect? Sure, it reinforces the need for more legitimate business models to deliver content to consumers, but the solution lies there, and not just taking the stuff.

Have a good week.

Laurie Kaye

Protection of children - New Legislation for Websites

Dear Reader,

From October this year, if you operate a website which has interactive features used by children, you will be required to vet new staff you employ to act as moderators on the website. This means that their names must be registered with the Independent Safeguarding Authority (ISA), a public body which has been set up to prevent unsuitable people from working with children. From 2010 you will also be required to ensure all existing staff moderators are ISA-registered (even if they have already undergone a CRB check).   

The relevant legislation is The Safeguarding Vulnerable Groups Act 2006, which provides for the maintenance of a register of people who are banned from certain activities relating to children (a 'barred list'). Under a commencement order which came into force in January this year, this Act will apply to regulate moderators of websites with interactive features aimed at children. 

You can read more about this development in the law by reading the article on our website.

Yasmin Joomraty and Mailin Bala

SABIP & Strategic Priorities For Copyright

Dear reader

SABIP (Strategic Advisory Board for Intellectual Property), which was established in June 2008 as a follow-up to the Gowers Review, this week published its paper 'Strategic Priorities For Copyright'. It identifies six areas for its work programme:-

1. The role of the copyright system in fostering creativity and innovation.
2. Issues concerning the ownership and coverage of copyright.
3. Rights management techniques and technologies.
4. The relationship between copyright and contract law.
5. Possible simplification of the copyright framework.
6. The implications of changing attitudes and practices among consumers.

So pretty fundamental questions! But underlying all these issues is the single, central question which is posed on page 11 of the Paper: "Does the paradigm shift towards a digital economy necessitate an equally fundamental adaptation of the copyright framework or its component parts? Alternatively, can innovation within the existing framework bring about effective adaptation in a more incremental way?"

I can't comment too much because I am a member of SABIP's Copyright  Expert Panel which provided input to SABIP. But I would encourage everyone who has an interest or stake in copyright to give their views to info@sabip, preferably by the end of May. Don't feel that learned treatises are essential. Short submissions on particular issues, especially where supported by evidence or practical experience, will be equally valuable.

Laurie Kaye