Reviving the Not'Quite Dead

Looking at recent online business statistics, though, how can anyone reasonably believe that online shopping was “lost” or “dead,” much less in need of the “restoration” desired by the new law's authors?

e-Commerce data reported recently in this publication (and in this edition; see, “Fourth Quarter e-Comm: Lookin' Good!” in this issue) showed strong, increased online spending in the 2010 holiday season.

Yet despite that sales data, online technology has undisputedly made many instances of fraud or other abuses possible, which could easily discourage the e-commerce novice from giving up the mall for the upstairs bedroom (see, http://ftc.gov/sentinel/reports/sentinel-annual-reports/sentinel-cy2010.pdf; the preamble to the new law, in Section 2, catalogs the industry's perceived abuses: www.ftc.gov/ogc/stat3/online-shoppers-enrolled.pdf).

ROSCA Origins

Consumer confidence is essential to growing online commerce. To continue marketplace development, the Internet must provide consumers with clear, accurate information, and give sellers an opportunity to compete fairly with one another for business.

An investigation by the Senate Committee on Commerce, Science, and Transportation found abundant evidence that the aggressive sales tactics many companies use against their online customers have undermined consumer confidence in the Internet and, thereby, harmed the American economy.

The Committee showed that in exchange for “bounties” and other payments, hundreds of reputable online retailers and Web sites shared customers' billing information, including credit and debit card numbers, with third-party sellers through a process known as “data pass.” These third-party sellers in turn used aggressive, misleading sales tactics to charge millions of American consumers for membership clubs the consumers did not want.

Third-party sellers offered membership clubs to consumers in the process of completing initial transactions on hundreds of Web sites. These third-party “post-transaction” offers were designed to make consumers think the offers were part of the initial purchase, rather than a new transaction with a new seller.

Third-party sellers charged millions of consumers for membership clubs without ever obtaining consumers' billing information, including credit or debit card information, directly from the consumers. Because third-party sellers acquired consumers' billing information from the initial merchant through data pass, millions of consumers were unaware they had been enrolled in membership clubs.

The use of a data-pass process defied consumers' expectations that they could be charged for a good or a service only if they submitted their billing information, including their complete credit or debit card numbers.

Third-party sellers used free trial periods to enroll members, after which they periodically charged consumers affirmatively canceled memberships. This use of “free-to-pay conversion” and “negative option” sales exploited consumers' expectation of an opportunity to accept or reject the membership club offer at the end of the trial period.

Also, no one can deny the extensive collection of information by online firms for use in marketing, itself a separate subject of concern (see, http://online.wsj.com/public/page/what-they-know-digital-privacy.html).

As an extreme case, a press release by Washington Attorney General Rob McKenna noted that one alleged scammer induced consumers to purchase various services with a $10 rebate offer for taking a pseudo survey (results were not even collected). Although the sponsor earned over $35 million in commissions on sales of programs through this offer, a grand total of one person (in Washington, at least), got the promised rebate (see, www.atg.wa.gov/pressrelease.aspx?id=26164).

Protections in Place

Nonetheless, despite these online-shopping risks, I cannot imagine anyone would seriously fear shoppers may abandon online merchants, considering all the benefits e-commerce provides sellers and buyers alike. In fact, perhaps e-commerce firms should have opposed the 2010 ROSCA law, but not because its requirements are burdensome or even unnecessary (it essentially applies to e-commerce the same ground rules as the Federal Trade Commission (“FTC”) established in 1973 for telemarketing (see, www.ftc.gov/bcp/rulemaking/tsr/index.shtml; www.access.gpo.gov/nara/cfr/waisidx_00/16cfr435_00.html); and, for “negative option” sales, www.access.gpo.gov/nara/cfr/waisidx_00/16cfr425_00.html)). Instead, perhaps online firms should worry that the law's label may discourage shoppers, especially online novices.

ROSCA, the Telemarketing Rule (http://business.ftc.gov/advertising-and-marketing/telemarketing) and the Negative Option Rule (http://business.ftc.gov/documents/accentuate-positive-when-using-negative-option-marketing) all prohibit marketing practices perceived to be deceptive, and potentially abusive, to consumers. ROSCA does this by requiring greater disclosure in three common circumstances already heavily regulated for telemarketers:

1. Transfer of consumer data to a third-party seller (the so-called “data pass”);
2. “Upsells,” or secondary sales to a customer who has already made a purchase; and
3. “Negative option” plans (the requirement to cancel affirmatively, rather than act to renew a subscription or service).

All these sales techniques were regulated in the FTC's Telemarketing and Negative Option Rules, and other existing guidance for mail and phone sales, but those rules did not apply to online sales activity ' hence the need for statutory authority to regulate the same abuses in the online world (see, www.ftc.gov/opa/2010/12/negoption.shtm; http://business.ftc.gov/documents/accentuate-positive-when-using-negative-option-marketing; and www.ftc.gov/os/2009/02/P064202negativeoptionreport.pdf).

But will a well-publicized Congressional attempt to fix consumers' perception of a problem have any effect in the real world (or at least in the virtual one, where many of us do our shopping and purchasing research)? No one can deny that the law was a “feel good” achievement. Upon its passage, in the height of the holiday shopping season, the popular press and state enforcement officers hailed Congress's accomplishment.

According to a study by the Senate Commerce Committee, whose chair, Sen. Jay Rockefeller (D'WV), introduced this bill, there certainly seems to be plenty of opportunity to use the law against firms engaged in deceptive practices online. According to that study, three firms alone earned more than $1.4 billion from practices now prohibited by the new law. Even “legitimate” firms that partnered with firms specializing in the newly illegal practices had plenty of incentive to push the envelope in their sales efforts ' “kickbacks” to such partners exceeded $1 million, according to the report.

From a practical perspective, ROSCA is yet another mandate that e-commerce sellers must satisfy (on top of the welter of overlapping regulation that already exists), particularly if they engage in the “after-sale” sales the Act is intended to regulate. Given the similarity of ROSCA's specific prohibitions to those in the existing Telemarketing Rule, however, the guidance available from the FTC on the earlier Telemarketing Rule should prove helpful in designing promotions to avoid the perceived abuses from the start (see, http://business.ftc.gov/documents/bus27-complying-telemarketing-sales-rule).

Is ROSCA Practical?

Even so, the practical impact of ROSCA seems hard to predict. The new law charges the FTC with enforcement, but given its mention only in passing in the Better Business Bureau's review of the FTC's plans for 2011, such enforcement and rulemaking do not appear to be a high priority (see, www.bbb.org/us/article/a-look-ahead-for-the-ftc-24823). And, as of mid-March, the FTC had not yet (to my knowledge) announced any plans for creating regulations to interpret the law, much less begun enforcement proceedings against violators ' a major incentive for compliance by many firms. (To be fair, the FTC has acted against firms involved in ROSCA-prohibited activities, but under existing consumer-protection statutes it enforces, and its general regulatory authority.) In addition, as at least one commentator, Aaron Kelly of the Kelly Law Firm, noted on his blawg (http://kellylawblog.com/?s=ecommerce), ROSCA's requirements may simply match the best practices that many sellers already employ (and, therefore, do not need to change).

Even worse, ROSCA did not create any private rights of action ' only the FTC and state attorneys general can enforce it. (Similarly, there is no general private right of action to enforce violations of the FTC Act and other FTC regulations.) Because the FTC and attorneys general have unlimited resources and time to police the Internet ' or not, in this age of austerity ' only the most egregious violators of the law will likely be unlucky enough to attract the regulators' attention. (The preceding sentence was clearly stated with tongue firmly planted in cheek, at Congress's simultaneous creation of a right for consumers that created good sound bites for the evening news, and failure to provide for an effective way to enforce that right.) From my personal experience, years of environmental and occupational safety and health laws had only a fraction of the effect in inducing private-industry compliance that a citizen suit under the private right-of-action provisions in environmental laws had on one client (that paid a six-figure fine in one activist group's lawsuit).

For the vast majority of e-commerce firms that treat their customers fairly, therefore, ROSCA will likely be (like most newly passed legislation) a non-event. Certainly, counsel for e-commerce firms must warn the marketing department of the new rules. They must be particularly aware of the limits on joint promotions, lest they design a program that runs afoul of ROSCA, and of the “negative option” rules that lead to unintended renewals.

However, as in many areas of disclosure, such as securities sales, providing full advance disclosure (as ROSCA requires) will not stop consumers from clicking to accept the terms of a sale, no matter how egregious they may be (or the
consumer had known they were, if he or she had taken the time to read them). Instead, policing of the Internet will likely be left to the consumer activists, whose attorneys actually read the fine print ' and try to warn the unwary about the sellers whose tactics bring undesired regulation and criticism to the vast majority of online sellers who follow the rules (or at least try to do so, since they change so frequently).

A recent presentation by David Vladeck, director of the FTC's Bureau of Consumer Protection, provides an interesting update not only on the breadth of regulatory interest in the practices that led to the birth of ROSCA, but also reasonably current data on the size of the problem, and enforcement efforts to combat it (see, www.ftc.gov/speeches/vladeck/110223maawg.pdf).

Educate Consumers

In many ways, then, e-commerce firms interested in increasing sales volume by convincing reluctant e-shoppers to venture online, by demonstrating that they will have online protection, must instead take on the model of the classic Syms ad campaign: “An educated consumer is our best customer” (itself part of a family of federally registered trademarks).

In other words, rather than “restoring” online shoppers' confidence, well-positioned online sellers should instead teach their customers (and prospective customers) in the first place why shopping at their Web site is safe (and more reliable than simply using Google Shopping's feature to sort by price and clicking through at the lowest-cost seller). I have often chosen to pay a bit more than the lowest price available online because I trust a known seller to protect my personal information and credit card number; and, most basically, to have authentic goods delivered reliably.

If we assume that by 2011 most persons who might buy online are doing so, then e-commerce growth will come only by giving “confidence” to those still fearful of safely entering a credit card number at a Web site. Perhaps ROSCA can best be seen as the government's effort to create that shopping atmosphere at all sites, because of an increased regulatory presence, without requiring the consumer to become educated.

Another way the industry has tried to induce the first-time online shopper is the increased use of “familiar” secure login credentials, from trusted sites such as Google, Facebook or other social media sites, as an alternative to each site's own user ID and password. If you are willing to trust Facebook, then you may not worry about identity theft when you take the next step to buy online. Given its explosive growth and the general distrust of government, perhaps Facebook can do more to “restore confidence” than Congress ever could.

In the same vein, another form of education e-commerce firms can use to help customers protect themselves is education about another form of federal rights of consumers ' the benefits of shopping with a credit card, rather than a debit card. Using a true credit card provides the cardholder rights to limit liability from fraud to $50 under federal law, provided the problem is reported in a timely fashion. Similarly, purchase with a credit card gives people leverage against a merchant if the product does not work properly, or a consumer has other disputes ' the seller does not get money while the dispute is pending.

Paying by debit card, in contrast, or gift card, does not include rights applied to credit cards. (Because of these key differences, many consumer groups and government agencies have created lists recommending when to use each of these payment forms, and explaining additional consumer benefits from the Credit Card Accountability and Disclosure Act of 2009.)

Of course, e-commerce firms may have very different economic incentives concerning this advice. As any banker knows, card-system payment processing incurs many fees, and credit card fees are generally among the highest. Even worse, in small transactions, the combination of a fixed, “per transaction” fee and a second fee based on a percentage of the total sale, could eliminate profit, if not transform the sale into a loss for the merchant. As a result, encouraging customers to pay by credit, rather than by debit, for their protection, will cost merchants.

Conclusion

Despite the gloom and doom about online shopping in this article, I must close with the same upbeat information with which I started. Notwithstanding all the problems with online sales, and the publicity they have received, neither the customer nor the merchant has ever “lost” confidence in e-commerce. The ability to find products, at a good price, and have them shipped directly has freed us from the drudgery of wandering through malls, paper catalogs and flea markets. Merchants too, if nimble enough to compete by offering a good selection at an attractive price and a competent logistics and fulfillment department, can reach customers who never would have found a traditional retail location.

Therefore, perhaps the legislation to eliminate the natural attraction of the fraudster to any vibrant market should not have been labeled as a “restoration” of confidence, but rather a maintenance and growth of e-commerce's strengths ' and that work is always worth doing, whether through regulation, legislation or just the bully pulpit of counsel or other reliable messengers educating the public and consumers.

Congress passed the Restore Online Shoppers' Confidence Act (“ROSCA”) to great public acclaim late last year.

But was the new law necessary? (For a summary of the law's provisions, see, “New Law Cracks Down On Deceptive Third-Party e-Commerce Practices,” in the February edition of e-Commerce Law & Strategy, at www.ljnonline.com/issues/ljn_ecommerce/27_10/news/154768-1.html).

Dictionary.com defines restore in several parts, but all refer to bringing back something “lost” or “dead.”

Looking at recent online business statistics, though, how can anyone reasonably believe that online shopping was “lost” or “dead,” much less in need of the “restoration” desired by the new law's authors?

e-Commerce data reported recently in this publication (and in this edition; see, “Fourth Quarter e-Comm: Lookin' Good!” in this issue) showed strong, increased online spending in the 2010 holiday season.

Yet despite that sales data, online technology has undisputedly made many instances of fraud or other abuses possible, which could easily discourage the e-commerce novice from giving up the mall for the upstairs bedroom (see, http://ftc.gov/sentinel/reports/sentinel-annual-reports/sentinel-cy2010.pdf; the preamble to the new law, in Section 2, catalogs the industry's perceived abuses: www.ftc.gov/ogc/stat3/online-shoppers-enrolled.pdf).

ROSCA Origins

Consumer confidence is essential to growing online commerce. To continue marketplace development, the Internet must provide consumers with clear, accurate information, and give sellers an opportunity to compete fairly with one another for business.

An investigation by the Senate Committee on Commerce, Science, and Transportation found abundant evidence that the aggressive sales tactics many companies use against their online customers have undermined consumer confidence in the Internet and, thereby, harmed the American economy.

The Committee showed that in exchange for “bounties” and other payments, hundreds of reputable online retailers and Web sites shared customers' billing information, including credit and debit card numbers, with third-party sellers through a process known as “data pass.” These third-party sellers in turn used aggressive, misleading sales tactics to charge millions of American consumers for membership clubs the consumers did not want.

Third-party sellers offered membership clubs to consumers in the process of completing initial transactions on hundreds of Web sites. These third-party “post-transaction” offers were designed to make consumers think the offers were part of the initial purchase, rather than a new transaction with a new seller.

Third-party sellers charged millions of consumers for membership clubs without ever obtaining consumers' billing information, including credit or debit card information, directly from the consumers. Because third-party sellers acquired consumers' billing information from the initial merchant through data pass, millions of consumers were unaware they had been enrolled in membership clubs.

The use of a data-pass process defied consumers' expectations that they could be charged for a good or a service only if they submitted their billing information, including their complete credit or debit card numbers.

Third-party sellers used free trial periods to enroll members, after which they periodically charged consumers affirmatively canceled memberships. This use of “free-to-pay conversion” and “negative option” sales exploited consumers' expectation of an opportunity to accept or reject the membership club offer at the end of the trial period.

Also, no one can deny the extensive collection of information by online firms for use in marketing, itself a separate subject of concern (see, http://online.wsj.com/public/page/what-they-know-digital-privacy.html).

As an extreme case, a press release by Washington Attorney General Rob McKenna noted that one alleged scammer induced consumers to purchase various services with a $10 rebate offer for taking a pseudo survey (results were not even collected). Although the sponsor earned over $35 million in commissions on sales of programs through this offer, a grand total of one person (in Washington, at least), got the promised rebate (see, www.atg.wa.gov/pressrelease.aspx?id=26164).

Protections in Place

Nonetheless, despite these online-shopping risks, I cannot imagine anyone would seriously fear shoppers may abandon online merchants, considering all the benefits e-commerce provides sellers and buyers alike. In fact, perhaps e-commerce firms should have opposed the 2010 ROSCA law, but not because its requirements are burdensome or even unnecessary (it essentially applies to e-commerce the same ground rules as the Federal Trade Commission (“FTC”) established in 1973 for telemarketing (see, www.ftc.gov/bcp/rulemaking/tsr/index.shtml; www.access.gpo.gov/nara/cfr/waisidx_00/16cfr435_00.html); and, for “negative option” sales, www.access.gpo.gov/nara/cfr/waisidx_00/16cfr425_00.html)). Instead, perhaps online firms should worry that the law's label may discourage shoppers, especially online novices.

ROSCA, the Telemarketing Rule (http://business.ftc.gov/advertising-and-marketing/telemarketing) and the Negative Option Rule (http://business.ftc.gov/documents/accentuate-positive-when-using-negative-option-marketing) all prohibit marketing practices perceived to be deceptive, and potentially abusive, to consumers. ROSCA does this by requiring greater disclosure in three common circumstances already heavily regulated for telemarketers:

1. Transfer of consumer data to a third-party seller (the so-called “data pass”);
2. “Upsells,” or secondary sales to a customer who has already made a purchase; and
3. “Negative option” plans (the requirement to cancel affirmatively, rather than act to renew a subscription or service).

All these sales techniques were regulated in the FTC's Telemarketing and Negative Option Rules, and other existing guidance for mail and phone sales, but those rules did not apply to online sales activity ' hence the need for statutory authority to regulate the same abuses in the online world (see, www.ftc.gov/opa/2010/12/negoption.shtm; http://business.ftc.gov/documents/accentuate-positive-when-using-negative-option-marketing; and www.ftc.gov/os/2009/02/P064202negativeoptionreport.pdf).

But will a well-publicized Congressional attempt to fix consumers' perception of a problem have any effect in the real world (or at least in the virtual one, where many of us do our shopping and purchasing research)? No one can deny that the law was a “feel good” achievement. Upon its passage, in the height of the holiday shopping season, the popular press and state enforcement officers hailed Congress's accomplishment.

According to a study by the Senate Commerce Committee, whose chair, Sen. Jay Rockefeller (D'WV), introduced this bill, there certainly seems to be plenty of opportunity to use the law against firms engaged in deceptive practices online. According to that study, three firms alone earned more than $1.4 billion from practices now prohibited by the new law. Even “legitimate” firms that partnered with firms specializing in the newly illegal practices had plenty of incentive to push the envelope in their sales efforts ' “kickbacks” to such partners exceeded $1 million, according to the report.

From a practical perspective, ROSCA is yet another mandate that e-commerce sellers must satisfy (on top of the welter of overlapping regulation that already exists), particularly if they engage in the “after-sale” sales the Act is intended to regulate. Given the similarity of ROSCA's specific prohibitions to those in the existing Telemarketing Rule, however, the guidance available from the FTC on the earlier Telemarketing Rule should prove helpful in designing promotions to avoid the perceived abuses from the start (see, http://business.ftc.gov/documents/bus27-complying-telemarketing-sales-rule).

Is ROSCA Practical?

Even so, the practical impact of ROSCA seems hard to predict. The new law charges the FTC with enforcement, but given its mention only in passing in the Better Business Bureau's review of the FTC's plans for 2011, such enforcement and rulemaking do not appear to be a high priority (see, www.bbb.org/us/article/a-look-ahead-for-the-ftc-24823). And, as of mid-March, the FTC had not yet (to my knowledge) announced any plans for creating regulations to interpret the law, much less begun enforcement proceedings against violators ' a major incentive for compliance by many firms. (To be fair, the FTC has acted against firms involved in ROSCA-prohibited activities, but under existing consumer-protection statutes it enforces, and its general regulatory authority.) In addition, as at least one commentator, Aaron Kelly of the Kelly Law Firm, noted on his blawg (http://kellylawblog.com/?s=ecommerce), ROSCA's requirements may simply match the best practices that many sellers already employ (and, therefore, do not need to change).

Even worse, ROSCA did not create any private rights of action ' only the FTC and state attorneys general can enforce it. (Similarly, there is no general private right of action to enforce violations of the FTC Act and other FTC regulations.) Because the FTC and attorneys general have unlimited resources and time to police the Internet ' or not, in this age of austerity ' only the most egregious violators of the law will likely be unlucky enough to attract the regulators' attention. (The preceding sentence was clearly stated with tongue firmly planted in cheek, at Congress's simultaneous creation of a right for consumers that created good sound bites for the evening news, and failure to provide for an effective way to enforce that right.) From my personal experience, years of environmental and occupational safety and health laws had only a fraction of the effect in inducing private-industry compliance that a citizen suit under the private right-of-action provisions in environmental laws had on one client (that paid a six-figure fine in one activist group's lawsuit).

For the vast majority of e-commerce firms that treat their customers fairly, therefore, ROSCA will likely be (like most newly passed legislation) a non-event. Certainly, counsel for e-commerce firms must warn the marketing department of the new rules. They must be particularly aware of the limits on joint promotions, lest they design a program that runs afoul of ROSCA, and of the “negative option” rules that lead to unintended renewals.

However, as in many areas of disclosure, such as securities sales, providing full advance disclosure (as ROSCA requires) will not stop consumers from clicking to accept the terms of a sale, no matter how egregious they may be (or the
consumer had known they were, if he or she had taken the time to read them). Instead, policing of the Internet will likely be left to the consumer activists, whose attorneys actually read the fine print ' and try to warn the unwary about the sellers whose tactics bring undesired regulation and criticism to the vast majority of online sellers who follow the rules (or at least try to do so, since they change so frequently).

A recent presentation by David Vladeck, director of the FTC's Bureau of Consumer Protection, provides an interesting update not only on the breadth of regulatory interest in the practices that led to the birth of ROSCA, but also reasonably current data on the size of the problem, and enforcement efforts to combat it (see, www.ftc.gov/speeches/vladeck/110223maawg.pdf).

Educate Consumers

In many ways, then, e-commerce firms interested in increasing sales volume by convincing reluctant e-shoppers to venture online, by demonstrating that they will have online protection, must instead take on the model of the classic Syms ad campaign: “An educated consumer is our best customer” (itself part of a family of federally registered trademarks).

In other words, rather than “restoring” online shoppers' confidence, well-positioned online sellers should instead teach their customers (and prospective customers) in the first place why shopping at their Web site is safe (and more reliable than simply using Google Shopping's feature to sort by price and clicking through at the lowest-cost seller). I have often chosen to pay a bit more than the lowest price available online because I trust a known seller to protect my personal information and credit card number; and, most basically, to have authentic goods delivered reliably.

If we assume that by 2011 most persons who might buy online are doing so, then e-commerce growth will come only by giving “confidence” to those still fearful of safely entering a credit card number at a Web site. Perhaps ROSCA can best be seen as the government's effort to create that shopping atmosphere at all sites, because of an increased regulatory presence, without requiring the consumer to become educated.

Another way the industry has tried to induce the first-time online shopper is the increased use of “familiar” secure login credentials, from trusted sites such as Google, Facebook or other social media sites, as an alternative to each site's own user ID and password. If you are willing to trust Facebook, then you may not worry about identity theft when you take the next step to buy online. Given its explosive growth and the general distrust of government, perhaps Facebook can do more to “restore confidence” than Congress ever could.

In the same vein, another form of education e-commerce firms can use to help customers protect themselves is education about another form of federal rights of consumers ' the benefits of shopping with a credit card, rather than a debit card. Using a true credit card provides the cardholder rights to limit liability from fraud to $50 under federal law, provided the problem is reported in a timely fashion. Similarly, purchase with a credit card gives people leverage against a merchant if the product does not work properly, or a consumer has other disputes ' the seller does not get money while the dispute is pending.

Paying by debit card, in contrast, or gift card, does not include rights applied to credit cards. (Because of these key differences, many consumer groups and government agencies have created lists recommending when to use each of these payment forms, and explaining additional consumer benefits from the Credit Card Accountability and Disclosure Act of 2009.)

Of course, e-commerce firms may have very different economic incentives concerning this advice. As any banker knows, card-system payment processing incurs many fees, and credit card fees are generally among the highest. Even worse, in small transactions, the combination of a fixed, “per transaction” fee and a second fee based on a percentage of the total sale, could eliminate profit, if not transform the sale into a loss for the merchant. As a result, encouraging customers to pay by credit, rather than by debit, for their protection, will cost merchants.

Conclusion

Despite the gloom and doom about online shopping in this article, I must close with the same upbeat information with which I started. Notwithstanding all the problems with online sales, and the publicity they have received, neither the customer nor the merchant has ever “lost” confidence in e-commerce. The ability to find products, at a good price, and have them shipped directly has freed us from the drudgery of wandering through malls, paper catalogs and flea markets. Merchants too, if nimble enough to compete by offering a good selection at an attractive price and a competent logistics and fulfillment department, can reach customers who never would have found a traditional retail location.

Therefore, perhaps the legislation to eliminate the natural attraction of the fraudster to any vibrant market should not have been labeled as a “restoration” of confidence, but rather a maintenance and growth of e-commerce's strengths ' and that work is always worth doing, whether through regulation, legislation or just the bully pulpit of counsel or other reliable messengers educating the public and consumers.