![]() Tauzin-Dingell Is Evil Homepage
Fact Sheets: 1 through 10
Presented by:
New Networks Institute Bruce Kushnick 826 Broadway, Suite 900 New York, NY 10003
The "Internet Freedom and Broadband Deployment Act", HR 1542, presented by Representatives Tauzin * Dingell is an attempt by Bell campaign-financed Congressmen to forget history and give more money to the Bell companies, all in the name of Broadband. If this bill goes through, America has been cheated twice. Fact: In many states, customers have already paid for a fiber-optic broadband future in the form of higher local bills. State and federal regulators changed state and federal laws to give the Bell companies money to roll out broadband. Fact: By 2001, over half of America's households, and almost all schools, libraries, and government agencies should have been upgraded to fiber-optics. Instead of delivering, the Bells pocketed some $58 billion dollars in extra charges, and America today is still using a copper network. Fact: The Bells profit margins are over 250% higher than America's best companies. The Bells are still monopolies, and therefore, their profits are in violation of current "fair and reasonable" statutes. Fact: A Recent Department of Justice Report on BellSouth's Louisiana and Georgia found that the phone networks were not properly open to competition. Rep. Billy Tauzin represents Louisiana. So how can we trust Tauzin-Dingell will bring in competition when Rep. Tauzin can't even get his state's phone company to comply with current laws? Instead of giving the Bells more of America's money, it's time to hold them accountable for their actions and get what America was promised. Do not let history repeat itself. Tauzin-Dingell Fact Sheets
The Bells' Broken Broadband Promises Cost Customers $58 Billion and Their Fiber-Optic Future Tauzin-Dingell will give the Bell companies more money for broadband, even though history shows that the Bell companies never fulfilled their continued promises to deploy high-speed networks. Here are quotes directly from the Bells' Annual Reports: By 2001, over half of America's households should have been rewired with fiber optics. None of these statements proved to be true, even though state and federal laws were changed to give the Bells more money for construction. NNI estimates that $58 billion was already collected for a fiber-optic future that never arrived. To read our report, published by NetAction: http://www.netaction.org/broadband/bells/ NOTE: NYNEX and Bell Atlantic are now part of Verizon. Pacific Telesis, Ameritech, and Southwestern Bell are now part of SBC. NYNEX, 1993 Annual Report "We're prepared to install between 1.5 and 2 million fiber-optic lines through 1996 to begin building our portion of the Information Superhighway." Bell Atlantic 1993 Annual Report "We expect Bell Atlantic's enhanced network will be ready to serve 8.75 million homes by the end of the year 2000. By the end of 1998, we plan to wire the top 20 markets... These investments will help establish Bell Atlantic as a world leader in what is clearly the high growth opportunity for the 1990's and beyond." Pacific Telesis 1993 Annual Report: "Using a combination of fiber optics and coaxial cable, Pacific Bell expects to provide broadband services to more than 1.5 million homes by the end of 1996, 5 million homes by the end of the decade." U S West 1993 Annual Report "In 1993 the company announced its intentions to build a 'broadband', interactive telecommunications network... US West anticipates converting 100,000 access lines to this technology by the end of 1994, and 500,000 access lines annually beginning in 1995." Ameritech Investor Fact Book, March 1994 "We're building a video network that will extend to six million customers within six years." These promises didn't start in the 1990's. Zane E Barnes, Chairman of Southwestern Bell, in 1988 talked about the imminent rollout of ISDN. (now SBC) (Source: Southwestern Bell 1988 Annual Report: "Southwestern Bell company, the subsidiary that provides telephone network service, is bringing high tech home to millions of people. Or take this pledge by Pac Bell to have all of its schools connected with ISDN by 1996. Pac Bell's "Education First" program. (Pacific Telesis First Quarter Report, 3/31/94) "Pacific Bell Helps Bring Schools On-line. As part of a continuing commitment to education in California, Pacific Bell has launched "Education First", a $100 million program to connect the state's schools to the communications superhighway. By the end of 1996, all of the nearly 7,400 public K-12 schools, libraries, and community colleges in Pacific Bell territory will have access to the company's Integrated Services Digital Network (ISDN), which enables simultaneous transmission of voice, data and video signals over a signals telephone line." By 2000, in many states ALL schools, hospitals, libraries and jails should have had fiber-optic based broadband by now: Ameritech, Ohio Bell, Alternate Regulation Plan, September 20, 1994 "21. INFRASTRUCTURE COMMITMENTS The Company's infrastructure commitment in this Plan shall consist of the commitment to deploy, within five years of the effective date of the Plan and within the Company's existing service territory, broadband two-way fully interactive high quality distance learning capabilities to all state chartered high schools including vocational, technical schools, colleges and universities; deploy broadband facilities to all hospitals, libraries, county jails and state, county and federal court buildings " And the deployment of residential services was supposed to be both urban and rural. Bell Atlantic, Pennsylvania Bell Annual Report 1998 "The Pennsylvania Plan requires deployment of a universal broadband network, which must be completed in phases: 20% by 1998... Deployment must be reasonably balanced among urban, suburban and rural areas." The outcome in most states could be summarized by the Comments made by the New Jersey Ratepayer Advocate: New Jersey Public Advocate about NJ Bell Atlantic, (4/97) "...low income and residential customers have paid for the fiber-optic lines every month but have not yet benefited." There are thousands of other examples. The bottom line is that Tauzin-Dingell will give the Bells new financial incentives, even though they never fulfilled any of the stated obligations.
Broken Broadband Promises of Verizon, (NYNEX, Bell Atlantic, etc.) Verizon was supposed to have over 11 million households wired with fiber-optics by 2000. None of these services exist today. Verizon was also supposed to have over 7 million households with ADSL by 1999. At the end of 2000, Verizon had about 540,000 lines of ADSL. NOTE: ADSL is an inferior product over the old copper networks. The Original Promises: (1) NYNEX, NYNEX 1993 Annual Report, "We're prepared to install between 1.5 and 2 million fiber-optic lines through 1996 to begin building our portion of the Information Superhighway." (2) Bell Atlantic, Bell Atlantic 1993 Annual Report, "First, we announced our intention to lead the country in the deployment of the information highway. We will spend $11 billion over the next five years to rapidly build full-service networks capable of providing these (interactive, multi-media communications, entertainment and information) services within the Bell Atlantic Region." (3) Bell Atlantic, Pennsylvania, Bell PA Annual Report 1998 "The Pennsylvania Plan requires deployment of a universal broadband network, which must be completed in phases: 20% by 1998... Deployment must be reasonably balanced among urban, suburban and rural areas." (4) NYNEX Massachusetts (Testimony from Alternate Regulation 94-50) "(In Massachusetts, NYNEX will) deploy a fiber-based broadband network, with initial deployment to approximately 330,000 access lines, by year-end 1995." (5) Bell Atlantic DSL lines (DSL Infospeed Resellers Program, 10/98) "Bell Atlantic plans to service 2 million lines in 1998 and an additional 5 million in 1999. Bell Monopoly Profits Outrageous: America's Phone Customers Are Being Overcharged By Their Local Bell Companies About $200 Per Household In 2000. SUBTITLE: Bell Profits Violate Every State and Federal "Fair and Reasonable" Statute.
In 2000, the Bells' profits were 256% above the Business Week 500, 170% above the "Top 9" companies and 212% above the other Utilities. We estimate that $17.1 billion was overcharged in 2000 --- about $200 a household. This overcharging is based on comparing the Bells' profits with these groups of companies, and using the basic assumption that profits are supposed to be "fair and reasonable" which appears in every state and federal law, including the Telecommunications Act of 1996. We believe these excess profits were collected using the pretense of rewiring America with broadband. To read our analysis see: http://newnetworks.com/Bellprofits2001.htm NOTE: Our estimates of the excess profits from the fiber-optic plans, $58 billion, is a cumulative number. We estimate that about half of the customer overcharging, $8.5 billion, was collected in 2001 in the name of broadband. For a detailed accounting see "The Unauthorized Bio of the Baby Bells" , pages 169-215, pages 355-367.) Broken Broadband Promises Hurt the Entire Tech Sector There is a very clear line between the Bell companies' promises and the technology sector going into a recession over the promises of broadband. See our full report "The Fiber-optic Fiasco and America's Copper Dirt Road" at: http://www.newnetworks.com/fiberopitcfiasco.htm In a press release (below) by Bell Atlantic, July 1996, dedicated to their "six-and-one-half-year period." agreement with Lucent technology, the Bell laid out their plan to deliver 'fiber-to-the-curb" services --- meaning the wiring of homes. This contract for fiber-optic broadband was supposed to extend to January 2003. It can be argued that Verizon's failure to go through with any of these plans seriously hurt the entire fiber-optic future, as well as the companies that were planning on offering new services. ---------------------------------------------------------- FOR IMMEDIATE RELEASE July 15, 1996
SWITCHED BROADBAND NETWORK DEPLOYMENT ARLINGTON, VA. -- Bell Atlantic Corp. [NYSE: BEL] has selected Lucent Technologies Inc. [NYSE: LU] as a supplier of key network components for Bell Atlantic's initial Full Service Network deployment in the mid-Atlantic region. Bell Atlantic's investment under the contract could reach several hundred million dollars over a six-and-one-half-year period. Later this year, Bell Atlantic will begin installing fiber-optic facilities and electronics to replace the predominantly copper cables between its telephone switching offices and customers. Fiber-optics provide higher quality and more reliable telephone services at lower operating and maintenance costs. The company plans to add digital video broadcast capabilities to this "fiber-to-the-curb," switched broadband network by the third quarter of 1997, and broadband Internet access, data communications and interactive multimedia capabilities in late 1997 or early 1998. "We began installing high-capacity, high-quality fiber optics more than a decade ago, and we currently have more than 2.2 million fiber miles linking switching offices and key points in our network,"" said Lawrence T. Babbio, Jr., Bell Atlantic vice chairman. "Pushing fiber optics closer to consumers and small businesses will allow us to provide superior quality and great customer service, while simultaneously allowing us to reduce our expenses significantly. "We also will be able to more quickly meet our customers' demands for a variety of new services -- including additional phone lines, high-speed data connections to on-line services and the Internet, and video and interactive services. A wide range of content providers -- including Bell Atlantic Video Services, which will work with our programming and systems venture TELE-TV -- are expected to supply a variety of interactive multimedia services for this platform." Lucent Technologies will supply the local network hardware and software components required between Bell Atlantic's switching offices and customers' homes or small businesses. BroadBand Technologies [NASDAQ: BBTK] of Research Triangle Park, N.C., will work with Lucent Technologies, providing switched broadband network components. Bell Atlantic will be the systems integrator for its Full Service Network. The fiber-to-the-curb architecture that Bell Atlantic will build is the next step in the company's ongoing, aggressive network modernization program. Bell Atlantic's network infrastructure includes digital switching covering more than 90 percent of the company's service area, as well as widely available advanced calling features and high-speed data communications services such as ISDN [Integrated Services Digital Network]. In addition, the company's switched broadband network in Dover Township, N.J. -- the first commercial video dialtone network in the country -- allows a video programmer, FutureVision, to offer digital broadcast services in competition with the local cable television company. Bell Atlantic plans to begin its network upgrade in Philadelphia and southeastern Pennsylvania later this year. The company plans to expand this Full Service Network deployment to other key markets over the next three years. Ultimately, Bell Atlantic expects to serve most of the 12 million homes and small businesses across the mid-Atlantic region with switched broadband networks. Lucent Technologies will provide the SLC*-2000 Access System with FLX** Switched Digital Video. This system includes voice, data, video and power components provided by Lucent Technologies and BroadBand Technologies. "We are delighted to support Bell Atlantic's network modernization program," said Gerry Butters, president of Network Systems' North American Region of Lucent Technologies. "The investment by Bell Atlantic in the switched broadband platform demonstrates its commitment to provide a full complement of integrated, innovative communications services to meet the needs of customers today and into the future." "BroadBand Technologies is pleased to provide a critical technology that will help deliver a rich array of services to Bell Atlantic customers," said Salim A.L. Bhatia, president and CEO of BroadBand Technologies. "By deploying the comprehensive transport and switching platform from Lucent and BroadBand Technologies in the local loop, Bell Atlantic can respond quickly to customers' demands for additional telephone lines today. In addition, it can prepare for the delivery of broadband Internet access, video and other interactive services in the coming months." Network equipment to be supplied by Lucent Technologies and BroadBand Technologies will include host digital terminals [HDTs], optical network units [ONUs], administrative systems and operations support interfaces. HDTs combine digital telephone and video signals, which are carried via fiber-optic cables between the Bell Atlantic switching office and ONUs. These ONUs serve about 25 to 30 homes each and are located "at the curb" on poles or in small cabinets on the ground. They split the integrated signal from the HDT into two distinct signals -- one for telephone service, and one for video, high-speed data and interactive multimedia services. The telephone signal is carried over copper wires into homes and small businesses. The video/interactive signal is carried either by copper or coaxial cable from the ONU to the customer. Liar, Liar, SBC's Pants on Fire ----Where's the Competition? There are two reasons that there is no local competition today. The first is the documented harm to competitors and the second is the fact that SBC, the Bell company that owns three original Bells ---- Southwestern Bell, Ameritech and Pacific Telesis, as well as SNET, (Southern New England Telephone) never fulfilled their stated obligations to compete in 50 major cities by next year, including other parts of the country, and therefore other Bell companies. (See page 3 for a complete list.) In fact, by now, SBC was supposed to be competing in the Miami, Seattle and Washington. (St. Louis Post-Dispatch [2/5/99]) "SBC aims to expand to Boston, Miami, Seattle" "SBC Communications Inc., the No. 2 U.S. local phone company, said Thursday that Boston, Miami and Seattle will be the first three markets where it provides services as part of its plan to buy Ameritech Corp. These plans were based on SBC's claim that they needed to merge with Ameritech, one of the original Bell companies, to give them more cash for the undertaking. The Fort Worth Star-Telegram [12/01/98] "Stephen Carter, president of strategic markets, said the plan is contingent on regulatory approval for SBC's proposed $77.4 billion purchase of Ameritech Corp., expected to be completed in the middle of next year." The merger went through in October 1999 and the first three cities were supposed to be competitive "within a year" of the deal going through. (St. Louis Post-Dispatch [2/5/99]) "The three cities named will be the first targets, with service available within a year of the purchase, SBC said." The deal of course went through, yet SBC has yet to compete in any of the cities mentioned. Had SBC done this plan, the price for local service should have decreased because competition would have lowered prices However, as we stated back in 1998, and we repeat today, we believe that SBC decided to pull a bait and switch --- they told the American public and regulators that they would give America competition in exchange for these mergers. Once the deal went through, they would claim that they could not go forward. They also knew that no regulator, including the FCC or any other group, would be able to or want to do anything about this. Any penalties would simply be the cost of doing business. Will the FCC take action? According to the FCC merger condition SBC is to have 30 markets competitive within 30 months of signing --- October 1999. According to the FCC: "21.Out-of-Territory Competitive Entry (National-Local Strategy) Within 30 months from the merger closing, SBC/Ameritech will enter at least 30 major markets outside of its region as a facilities-based competitive provider of local services to business and residential customers. " However, the FCC did not take their own conditions seriously. Notice that there are penalties of $1.2 billion dollars if the company misses to enter the markets, but it is "voluntary". "SBC/Ameritech is liable for voluntary incentive payments of nearly $1.2 billion dollars if it misses the entry requirements in all 30 markets. This condition will ensure that residential consumers and business customers outside of SBC/Ameritech's region benefit from increased facilities-based local competition." And we all know that the Bell company will never pay anything, yet they will have been able to increase their own market dominance through the Ameritech merger. SBC once again played the American public for chumps. (Source: SBC) Markets where the new SBC
plans to compete under the "National-Local"
strategy, ranked by size: Markets in which SBC and
Ameritech currently offer services, ranked by
size: 1. New York 1 Los Angeles (SBC) 2 Philadelphia 2 Chicago (AIT) 3. Boston 3 Detroit (AIT) 4. Washington 4. Dallas-Fort
Worth (SBC) 5. Miami-Ft.
Lauderdale 5.Houston (SBC) 6. Atlanta- 6 San Francisco (SBC) 7. Minneapolis-St.
Paul 7. San Diego (SBC) 8. Phoenix 8. St. Louis (SBC) 9. Baltimore 9. Cleveland (AIT) 10.
Seattle-Everett 10. San Jose (SBC) 11. Denver-Boulder 11.Kansas City (SBC) 12. Pittsburgh 12. Sacramento (SBC) 13. Tampa-St.
Petersburg 13. Milwaukee (AIT) 14. Portland 14. San Antonio. (SBC) 15. Cincinnati 15. Indianapolis (AIT) 16. Slat Lake
City-Ogden 16. Columbus, OH (AIT) 17. Orlando 17. Hartford/New
Britain (SBC) 18. Buffalo 18. Oklahoma City (SBC) 19 New Orleans 19.Austin (SBC) 20.
Nashville-Davidson 20.Dayton (AIT) 21. Memphis 22. Las Vegas 23. Norfolk -Virginia
Beach 24. Rochester 25. Greensboro -Winston
-Salem 26. Louisville 27. Birmingham 28. Honolulu 29. Providence
-Warwick 30. Albany -Schenectady -
Troy The Bells Harmed the Competitive Industry. The Competitive local companies are on life-support. Thousands of companies, from the competitive local phone companies (CLECs) or the Internet Service Providers (ISP) are having financial difficulties staying afloat and delivering quality service. While Bell funded research would like America to believe that the problems are all being caused by bad business plans, the reality is that the Bell companies have been harming competition through numerous means --- everything from supply sub-standard customer services to outright selling of customers. To read some of the evidence see: http://www.newnetworks.com/clecharm.htm More to the point, the chart below is a collection of the public CLECs. Notice that the average company's value has dropped almost 80% and the industry has lost approximately $130 billion dollars in value. : Company Market Cap 52 Week Ticker ($M) Change Symbol (source: ALTS) Adelphia Business Solutions
$480.7 -86.30% ABIZ Advanced Radio Telecom
$89.7 -94.10% ARTT Allegiance Telecom $2,130.0 -77.50% ALGX Allied Riser $157.6 -89.50% ARCC ChoiceOne Communications
$504.7 -61.60% CWON Convergent Communications
$30.6 -89.00% CONV CoreComm Ltd. $135.0 -94.40% COMM Covad Communications
$3449 -94.90% COVD CTC Communications
$300.7 -68.00% CPTL Cypress Communications
$53.0 -95.00% CYCO DSL.net $132 -93.40% DSLN e.spire Communications
$54.8 -92.40% ESPI Electric Lightwave
$212.4 -79.70% ELIX FiberNet Telecom
Group $137.7 -75.80% FTGX Focal Communications
$932.3 -65.20% FCOM General Communications
$390.0 +16.10% GNCMA ICG** $16.0 -98.00% ICGX Intermedia $855.1 -76.00% 10% ITC^DeltaCom $427.2 -80.10% ITCD Log On America $15.1 -91.30% LOAX McLeodUSA $7,946.0 -52.40% MCLD Mpower Communications
$327.8 -85.90% MPWR Net2000 Communications
$98.5 -63.29%* NTKK Network Access
Solutions $71.0 -95.10% NASC Network Plus $324.6 -85.10% NPLS NorthPoint Communications**
$79.0 -98.00% NPNT NTELOS $269.2 -46.50% NTLO Pac-West Telecom $169.6 -83.50% PACW RCN $756.8 -86.00% RCNC Rhythms
NetConnections $94.5 -97.00% RTHM Teligent $115.4 -97.70% TGNT Time Warner Telecom
$6,713 -06.70% TWTC US LEC $228.3 -77.00% CLEC USOL Holdings $23.3 -78.90% USOL Winstar $1,173.0 -73.50% WCII XO Communications $6,354.0 -66.90% XOXO Total Market Cap $35,247.60 % of loss $133,269.50 -79.43% Market Cap high. $168,517.10 The Bells Impeded Broadband Deployment, not the FCC or the States. Tauzin-Dingell blames the FCC and the states for "impeding" high speed access by imposing regulations. "The imposition of regulations by the Federal Communications Commission and the States has impeded the rapid delivery of high speed Internet access services and Internet backbone services to the public, thereby reducing consumer choice and welfare." This is of course not true. Someone hasn't done their homework. State and Federal laws were changed to accommodate the Bell companies' proposed plans, and instead the Bell companies never fulfilled their promises. Take the case of NYNEX's (now part of Verizon) petition to the FCC for their fiber-optic services, According to the Patriot Ledger: "NYNEX to offer cable TV in Boston suburbs" 12/13/94. "Telephone customers in Boston and its western and northern suburbs will be the first to be offered cable television services by their local phone company, a NYNEX Corp. spokesman said yesterday ." "Federal officials yesterday approved Nynex Corp. plans to offer cable television to customers in Rhode Island and Massachusetts - starting with Somerville ."The long-expected FCC decision, roundly opposed by the cable industry, could propel Nynex into television in 13 communities, some by early 1996, according to company officials." In fact, NYNEX stated that it would begin immediately to roll-out these services. "We will begin construction almost immediately. A good bit of it is going to be aerial, on poles. There will also be some underground," Johnson said. (The Boston Herald, 2/8/95, Finance. Pg. 25) The Massachusetts Public Service Commission also agreed to give NYNEX more money in the form of Alternate Regulation. According to the original NYNEX FCC filing, the Bell stated they would build a fiber-optic service that would replace the old copper wiring (FCC 95-50 ORDER 3/6/ 95) "NYNEX proposes to deploy hybrid fiber optic and coaxial (HFC) broadband networks that will provide advanced voice, data, and video services, including interactive video entertainment, multimedia education, and health care services." And how many customers were supposed to be wired ? --- 300,000 in just Massachusetts by 1995 and a half billion was supposed to be spent. .(Testimony from Alternate Regulation 94-50) "(In Massachusetts, NYNEX will) deploy a fiber-based broadband network, with initial deployment to approximately 330,000 access lines, by year-end 1995." OUTCOME: State and Federal laws were changed. NYNEX pocketed an additional $1 billion dollars in Massachusetts over a three year period. Nothing was built. For a full documented report see: http://newnetworks.com/Masscomplaintsummary.html Billy Tauzin Should Recuse Himself On Voting On Telecom And Broadband Issues. At a time when campaign finance reform is a serious topic, Representative Billy Tauzin should be the porter-child of why the system needs to be fixed. We believe that Rep. Billy Tauzin recuse himself from voting on Telecom and broadband issues, much less create new laws, because of his numerous and obvious ties with the Bell companies. Here are just a few representative samples, compiled by various reporters using disclosure records. To read numerous articles and reports about the Tauzin-Dingell bill see: http://www.newnetworks.com/TauzinDingellisevil.htm To read our summary of why Billy Tauzin should recuse himself from voting on telecom issues see: http://www.newnetworks.com/recusetauzin.htm
Year by Year: A Plan that Failed (A timeline of Pacific Bell's California First plan.)
Source: "PacBell's video bid proving more costly," Elizabeth Douglass, San Diego Union Tribune, Feb. 1, 1998, Page I-1.
BellSouth's Louisiana & Georgia Phone Companies are not Open to Competitors: Rep. Billy Tauzin's Own State Harms Competition. BellSouth has applied in Louisiana and Georgia to enter Long Distance. Their entrance into this new market is requires evidence that the phone networks are open to competition and that the company can pass a basic 14 point checklist. On November 6th, 2001, The Department of Justice (DOJ) issued a report that the Bell South's networks in these states are not properly open to competition and that they should not be allowed in Long Distance at this time. The report found that in this 'information age", the BellSouth (OSS) ordering system requires manual rekeying or faxing of the orders. This in turn also makes the companies make mistakes that block orders or that the orders don't go through. Imagine being a company that had to hand deliver their web-page information, or print and then mail it or fax it. Rep. Billy Tauzin represents the state of Louisiana. It is obvious that he hasn't been able to get the company he regularly lobbies for to pass muster and provide adequate services to competitors. How can Tauzin-Dingell then be able to get the Bell companies to deliver on their promises of broadband. History is clear that the Bell companies did not deliver broadband when they already got financial incentives. And now there is clear proof that the phone companies are not even willing/able to properly open their networks to competition. Instead of the FCC and the Department of Justice considering BellSouth's application to into Long Distance, shouldn't there be penalties for not being able to process orders in a "timely and reasonable" fashion? Is this harm to competition a violation of the Telecom Act. The Full DOJ report http://www.usdoj.gov/atr/public/comments/sec271/bellsouth/9527.htm "Several CLECs attempting to compete with BellSouth in Georgia have complained in state proceedings, and now to this Commission, that BellSouth is processing a large number of their orders manually.(37) To manually process an order, BellSouth's service representatives re-type some or all of the information on the CLEC order form into an internal electronic service order. This manual processing increases the expense of CLEC ordering, lengthens the time required to place customers in service, and creates errors that cause service requests to be improperly rejected or to be provisioned incorrectly.(38)
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