Liberty Rights Research Articles

Artificial Intelligence, Copyright Registration, and the Rule of Doubt

Artificial intelligence (“AI”) technology has detonated an explosive burst of seemingly creative expression. Stories, images, music, and even entire books are now being generated very quickly. This development is a major headache for copyright registrars because the copyrightability of works created in this way is uncertain. The almost limitless variability in the extent of human involvement in the creation of a work using an AI tool compounds the uncertainty. In some cases, copyrightability is easy to determine, such as where an author only claims rights in the selection and arrangement of AI-generated output rather than the output itself. But in many cases the registrability of a work created with the aid of an AI technology is far from certain. In these situations, the Copyright Office should apply a rule of doubt to allow registration. This solution appears to be a novel idea, at least as a permanent solution to the problems AI has generated. Nevertheless, approaching the problem in this way would protect authors’ rights to any original contributions they make to AI-assisted works, authors’ interests in the privacy of their creative processes, the interests of authors whose works may have been used without their consent to train AI, and the ability of alleged infringers to challenge the existence and scope of claimed copyrights in AI-generated and AI-assisted works. It would also ease the burden on copyright examiners.

The Unique and Important Jewish Responses to Proposition 8 and Marriage Equality

ABSTRACTMarriage equality is a nascent and fragile civil right in the United States. To protect this civil right we must articulate and preserve diverse religious, ethical, and legal positions from the marriage equality debates. Sadly, and incorrectly, both the popular and scholarly narratives of religions' public role and ethics on marriage equality have been told with a Christocentric and “God versus Gay” framing. Here I push the borders of that frame to include the crucially important story of Judaism and the Prop 8 marriage equality debates. Judaism made and still makes vital and unique contributions to the battle for marriage equality: the majority of Jewish congregations and organizations are in favor of marriage equality, as opposed to the majority of Christianities which are against it. Judaism models diversity within the tradition, for example how to be opposed to same‐sex marriage but not expect that it will be illegal. Jewish positions on marriage equality in the public sphere model how the civil rights of marriage equality and religious liberty can coexist and thrive.

Unlawful Act by a Cultivator or Sharecropper Certifying Land that Does Not Belong to Them

Land registration is an important step in the land administration system to reduce disputes, increase transparency, and ensure compliance with applicable laws and regulations. However, in practice, there are many cases where individuals or groups try to control or claim rights to land that do not belong to them personally, through various unlawful means, including unauthorized certification. This study aims to know and analyze in depth the conditions that must be met in the registration of inherited land and the legal consequences for cultivators/appointees who wrongfully certify land that does not belongs to them. Specifically, this study focuses on the specific legal requirements for registering inherited property and the implications for individuals who attempt to register land illegitimately, highlighting the potential legal repercussions and the need for enforcement of property rights. The findings of this study can be used as a reference for policymakers and legal practitioners.

Cele polityki zagranicznej Saharyjskiej Arabskiej Republiki Demokratycznej w kontekście uwarunkowań międzynarodowych w regionie Maghrebu

THE FOREIGN POLICY OBJECTIVES OF THE SAHRAWI ARAB DEMOCRATIC REPUBLIC IN THE CONTEXT OF INTERNATIONAL CONDITIONS IN THE MAGHREB REGION The Sahrawi Arab Democratic Republic (SADR), founded in February 1976 in the territory of the former Spanish Sahara, belongs today to the so-called unrecognised states category that do not meet all the criteria of the statehood. In the case of the SADR, it enjoys the recognition of several dozen UN members, as well as the most important international regional organisation on the continent – the African Union, however, the Sahrawi government controls only about 20% of the territory it claims rights for. Therefore, the axis of the SADR foreign policy is the constant struggle for international recognition, together with the attempts to exert indirect pressure on Morocco, which could persuade it to adopt the Sahrawi resolution to the protracted conflict over Western Sahara. Both of these goals seem increasingly distant, due to the events of the last three years: the Guerguerat crisis that ended the ceasefire between the POLISARIO Front and Moroccan forces, the decision of the administration of President Donald Trump to open a US consulate in the city of Dakhla in the Moroccan-controlled territory contested by the SADR, and the change in the position of the Spanish government – currently expressing support for the Moroccan plan for Western Sahara autonomy. The article is an attempt to analyse the foreign policy of an unrecognised state such as the SahrawiArab Democratic Republic in the context of international conditions in the region (in this case Maghreb), challenges it faces and the possibility of achieving its goals. The paper is largely based on qualitative data collected during field research over the years 2016-2023 conducted during study visits to Algeria and Spain.

Environmental disclosure as a response to civil liberties and political rights in countries, myth or reality? The moderating role performed by board gender diversity

AbstractThe influence of civil liberties and political rights on environmental disclosure, and the moderating effect of board gender diversity on the relationship between civil liberties and political rights and environmental disclosure, have not to date been studied in detail, as evidenced by the previous literature available. Therefore, this study aims to analyse how these institutional factors affect corporate environmental disclosure practices across different countries. The firms in our sample operate in 36 countries, spread across all the continents, and the period covered is 2009–2019. The database used to collect economic, social, environmental and governance data is Thomson Reuters' ASSET4, while the items for measuring civil liberty and political rights scores come from the Freedom House organisation (https://freedomhouse.org). The method used for estimating the model is the generalised method of moments (GMM) proposed by Arellano and Bond. The main findings of the study show that levels of civil liberty and political rights in the countries where the firms operate are positively associated with environmental disclosure. Furthermore, according to our evidence, the presence of female directors on boards plays a positive moderating role in the relationship between the level of civil liberty and environmental disclosure and between political rights and environmental disclosure. Additional robustness analyses corroborate our findings.

Peculiarities of division of corporate rights of spouses: through the prism of the Supreme Court practice

Introduction. The paper is devoted to the study of the issue of the division of marital property, namely corporate rights, which is the least regulated at the legislative level. The purpose of the paper is to carry out further scientific research of theoretical and practical aspects of the legal regime for division of corporate rights of spouses under Ukrainian legislation. Results. The author analyzes the scientific approaches to the definition of the concept of corporate rights of spouses, and reveals the content and features of the presumption of joint property. The scientific study of the issue of the legal regime of marital property (corporate rights) offers various variations of further development of the approach to the division of marital property at the legislative and case law levels. The paper emphasizes that the property owned by a husband and wife in joint ownership and transferred to the authorized capital of a legal entity becomes the property of the latter and ceases to be the object of joint ownership of the spouses, while one of the spouses receives corporate rights and the other receives the right of claim. The author analyzes the impact of the decision of the Constitutional Court of Ukraine on private law relations, which changed the vector of development of the issue of joint marital property and its possible division. Within the framework of the issue of the legal regime of corporate rights of spouses, the author makes an excursion into the case law on this issue and traces the changes in case law regarding the possibility, procedure and object of division of corporate rights. Conclusion. The author comes to the conclusion that there is no clear legislative regulation of the legal institution of division of corporate rights of spouses, and the dynamic development of judicial practice which establishes different approaches to the practical solution of this issue.

Feminist discontents against multiculturalism: The need for critical multiculturalism

Multiculturalism and feminism both contest the undifferentiated notion of liberal democracy and its overemphasis on individual rights; however, the latter does not conform with the special group rights advocated by multiculturalism. This article explores the tension between the feminist idea of gender equality and the group-specific rights endorsed by multiculturalism. The claim of group-specific rights in multiculturalism does not consider internal gender inequalities. Hence, the article critically analyzes some cultural practices to demonstrate how culture is gendered and how multicultural advocacy of group-specific rights is insensitive to gender discrimination within cultural groups. It employs an integrative literature review as a methodology to assess the theory of multiculturalism and draws a feminist perspective to suggest a critical model of multiculturalism. It is concluded that multiculturalism is not sufficient to combat patriarchal repression embodied in the cultural groups. Thus, the article further seeks to forge a form of multiculturalism that is critical to its own shortcomings and is ready to accommodate gender equality.

Madheshi Dalit Women’s Access to Citizenship and Livelihood Alternatives in Nepal

This article delves into the ramifications of Madheshi Dalit Women’s (MDWs) access to citizenship on their strategies for livelihood. Within the context of Nepal, the discourse surrounding citizenship often portrays the MDWs as immigrants or insufficiently authentic citizens. This perception is rooted in historical social hierarchies that have systematically marginalized individuals possessing multiple subordinate identities, such as Madheshis, Dalits, women and the landless. Remarkably, the MDWs embody all of these identities. The prevailing narrative of a hill-based national identity endorsed by the state has prompted inquiries into the loyalty of the MDWs to the nation, consequently undermining their rightful citizenship claims. Drawing upon qualitative field research conducted in Nepal’s central and eastern Tarai districts, where a significant population of Madheshi Dalits resides, this study investigates the intricate interplay between access to citizenship and its implications for livelihood strategies and survival challenges: land ownership and labour participation. The findings underscore the considerable challenges faced by the MDWs, including limited livelihood options, acute landlessness and unorganized wage labour.

Bonsai's Marketing Strategy Centers on Creating Customer Value

This paper contributes to a different marketing approach on how to describe value from the customer's perspective. This research examines value-based pricing by highlighting a customer-centric approach with a focus on customer value creation to explore what this literature can convey in achieving success. The research locus is the research object of the Jombang Bonsai Community FB community which has 16,645 members. with consideration: Members of the Jombang Bonsai Facebook Community Trust; Own a bonsai plant business; Join the community for at least 2 years. The qualitative approach carried out through the data analysis technique used is the Manual Data Analysis Procedure (MDAP), from the results of interviews accompanied by triangulation of sources and theories to produce findings on customer-centred approach marketing strategies including Price Formation: Product and Services, Authorization Use, Resource Access, Benefit Claim Rights, Buyer Type, Availability, Use, Results, Economic Success. As well as Mechanism Policies: Quantity, Price Formation, Price Conditions, Price Discrimination, Product Characteristics, Customer Identity, Transaction Forms, Market Laws.

MISUSING PREVENTIVE DETENTION IN SECURITY LEGISLATIONS: A HISTORICAL ANALYSIS FROM THE LENS OF PERSONAL LIBERTY

Preventive Detention is an extraordinary instrument used during times of crisis to prevent the commission of criminogenic behaviour by curtailing individual liberty on the apprehension of a criminal act, in the interests of national security. However, within Indian law, this extraordinary power holds a peculiar position in the sense that it is applicable during peacetime as well, an anomaly from the juristic position that it occupies in other jurisdictions. The historical roots of this power are traceable from the colonial era, wherein it was used as a means to silence dissent against the colonial State, yet, even after independence, it was given constitutional recognition and included and incorporated into the constitutional mechanism within Article 22. This is perhaps attributable to the exceptional circumstances surrounding the birth of this nascent nation, yet, over the past seven decades, it has been used as a means of silencing dissent and curtailing the voices of opposition, primarily due to its loose, imprecise, and vague connotation, as well as the blanket power that has been constitutionally granted on the State to exercise preventive detention. Curiously, although the judiciary has historically been an avowed protector of individual liberty and freedom, petitions challenging the validity of preventive detention legislations have often fallen on deaf ears, with the judiciary repeatedly valuing the principles of national security that these legislations envisage to protect over the individual rights of liberty and freedom. Thus, over the past seven decades, the misuse and abuse of preventive detention have become a dark spot in Indian legislative and judicial history. Against this backdrop, this paper is interested in examining the historical development and application of preventive detention laws in India, starting from the colonial period and expanding the discussion to the present, to understand the reasoning for its implementation during the British era, its subsequent inclusion within the constitutional framework, its use and misuse over the decades and the judicial opinion towards its imposition, to try and understand the nuances that this extraordinary power has carried in Indian jurisprudence.

CONSUMER PROTECTION AGAINST DEBTORS ON THE TRANSFER OF MORTGAGE RIGHTS VIA CESSIE

Disparities in financial capabilities in society have resulted in many credit agreements being entered into between consumers as debtors and banks as creditors or lenders, which are also accompanied by collateral in the form of mortgage rights which are used as collateral for payment of receivables by the debtor if he is unable to pay his debts to the creditor. The scope related to credit agreements is increasingly expanding when the model develops that credit agreements can be transferred to third parties through a cessie or receivable transfer agreement which of course poses risks for both creditors and debtors because in principle, when receivables are transferred to the cessie buyer, then the mortgage rights as collateral are also also transferred, including in terms of claim rights by new creditors. Therefore, this issue is interesting to discuss from the perspective of debtor protection as consumers of banking institutions, especially regarding the procedures and requirements that need to be understood regarding the transfer of mortgage collateral through a cessie or receivable transfer agreement. Apart from that, debtors also need to know what legal remedies can be submitted if the credit agreement or receivable transfer procedure causes losses for the debtor. In this research, the author uses a normative juridical research method using literature study and a legal approach. The results of the research show that based on the Consumer Protection Law and Financial Services Authority regulation, the Debtor as a consumer has the right to know clear and accurate information regarding the procedures and requirements of credit agreements including receivable transfer or cessie agreements and the legal consequences for the mortgage rights which he uses as collateral, including filing a complaint and/or legal remedies in litigation and non-litigation as long as he feels disadvantaged. The government needs to aggressively carry out outreach regarding all applicable regulations regarding credit agreements.

The Vocabulary of Right Under the Indonesian Constitution: A Hohfeldian Analysis

This article demonstrates how the Indonesian Constitutional Court interprets the term ‘right’ when deciding issue-level questions involving constitutional doctrine. In doing so, we employ the Hohfeldian scheme that configures right into four different meanings of claim right, privilege, power, and immunity. By looking at the molecular configuration of rights in the context of freedom of religion, natural resource control, educational policies, and fair trial, this we contend that the right under the constitution is interpreted by the Court in a dynamic-yet-configured fashion. In this sense, ‘dynamic’ implies that the Court’s interpretation does not adhere to a fixed or consistent vocabulary, while ‘configured’ suggests that the vocabulary of right is fundamentally configured by both (1) non-relational liberty and (2) power that provides intervention, limitations, or even change over the nature of liberty into liability (i.e., duty to refrain from acting in a certain way). It is manifest that right is hardly expounded by the Court when the term is juxtaposed with any relevant governmental duties and powers. This demonstrates a judicial fabrication of a flexible legal concept used by the judicial authority to justify certain normative objectives.

Juridical Analysis of the Rights and Position of Heirs in Inheritance Disputes: Case Study of Decision Number 9/Pdt.G/2024/PN Tbt

This study delves into the rights and positions of heirs in inheritance disputes, with a detailed analysis of Decision No. 9/Pdt.G/2024/PN Tbt. The primary focus is on how Indonesian law recognizes and upholds the rights of heirs in conflicts over inheritance. The case in question involves the heirs of the late PO Siregar and Turena Br Hutauruk, who were in a legal battle over the division of land and buildings left by the deceased. The study explores the legal principles, evidence, and court decisions that determined the distribution of assets among the heirs. It examines how the court interpreted relevant inheritance laws and applied them to establish the rightful claims of each party involved. By scrutinizing the legal proceedings and outcomes, this research provides insights into the functioning of Indonesian inheritance law, particularly in adjudicating disputes among heirs. The findings contribute to a broader understanding of how inheritance rights are protected and enforced in the legal system

Defense of Freedom of Abortion: An Analysis Based on the Case of Dobbs vs. Jackson Womens Health Organization

This paper delves into the great complexity of the right to abortion. The paper defends the freedom of abortion through perspectives of womens health, the premise that fetuses are human beings, and rights-based theory with reference to arguments by prominent philosophers. The paper discusses the famous thought experiment of the violinist analogy, claim rights, and liberty rights by Judith Jarvis Thomson to argue why abortion should be morally permissible. Moreover, the paper dissects objections to these arguments, revealing their inherent limitations by stating that traveling to other states for abortion is unjust. The paper also uses the minimal decent Samaritan argument to address possible objections. The paper strongly argues that the right to abortion is a legal and moral imperative to fulfill. The paper aims to justify the right to abortion and that people should recognize the current threat to the right to abortion with the case of Dobbes vs. Jackson Women's Health Organization.

Matters related to key features of the by-law contestation administrative proceedings

The article points out that in cases concerning appeals against normative acts in the presence of obvious signs of its unlawfulness and violation of the rights or legitimate interests of a person who has filed a lawsuit against such an act, this lawsuit can be accompanied by an interim remedy stopping the effect of the respective normative act. This is allowed in exceptional cases when, on the basis of the evidence available in the case, the court is convinced that the contested act clearly contradicts the criteria of its lawfulness established by law on administrative proceedings. At the same time, one cannot claim that an exceptional case for stopping the effect of a normative legal act, when the norms of substantive law establish an alternative procedure for the exercise of rights affected by the contested normative legal act (in particular, if it is possible to act on the basis of normative acts having higher legal force). In addition, when deciding the issue of suspending the effect of a normative legal act, the court must observe the limits of judicial intervention in the activities of their issuers and respect their discretionary powers, primarily those that lie in the domain of their exclusive executive functions, especially those that are characterized by political and narrowly-specialized character.
 The author, moreover, maintains that in order to encourage plaintiffs to use their right to claim and procedural rights in good faith, it is proposed to establish the date when the plaintiff learned or should have learned about the violation of his rights and legitimate interests. It is also clarified that termination of a person’s participation in social relations, the participants of which are assigned rights and duties by the relevant normative act, as well as the termination of the normative legal act itself, is the starting point for calculating the timeframe for its appeal to court.
 The article also indicates that there are critical gaps in the legislative provisions, which give rise to uncertainty regarding the impact of the published announcement on the appeal of a normative act on timeframes of appeal to the administrative court for other addressees of the relevant normative legal act, as well as regarding the procedural status of those who expressed their intention to join before consideration of the case on its unlawfulness.

Transformation of Additional Bank Indonesia'scapital Adequacy Ratio (Car) into State Collecting Rights Blbi

The escalation of the monetary crisis in 1997/1998 had an impact on the banking industry in Indonesia, most of the banking industry ran out of money (bokek) so that the existence of banks became insolvent banks. Bank Indonesia, which functions as the last monetary gateway, issued monetary policy with the Liquidity Assistance Fund (BLBI) scheme, which was a bailout fund for Bank Indonesia for insolvent banks affected by the 1997/1998 monetary crisis. Bank Indonesia 's liquidity assistance scheme to obligors ( recipients ) has resulted in Bank Indonesia 's capital adequacy ratio ( CAR ) . Bank Indonesia's Capital Adequat Ratio (CAR) is in free fall. Bank Indonesia is undercapitalized. The government covered Bank Indonesia's lack of capital, not with cash and in full, but with government bonds (SUN), the nominal value of this SUN is equivalent to the amount of BI Liquidity Assistance (BLBI) provided by Bank Indonesia to obligors. SUN is subsequently used by Bank Indonesia as a means of Bank Indonesia's Capital Maintenance Notes (CMN). The Capital Maintenance Notes are then compensated with the transfer of the claim rights (cessie) to the obligor (the BLBI receiving bank), by Bank Indonesia, to the Government. BLBI, which was originally a monetary policy, turned into fiscal policy, changed the legal status of BLBI collection rights, became a government asset in the form of state receivables, but historically the settlement costs which also used SUN have come down short. Fiscal policy, regarding the settlement of collection rights (cessie) turned out to be more expensive than the total collection rights (cessie), on the other hand, with the maturity of government bonds (SUN) used as a CMN facility, resulting in a sustainable government burden, at least this burden continues for up to five presidents and will continue in the administrations of subsequent presidents. This paper study uses a normative approach which is expected to be able to answer the epistemological problems of the theme of this article, which is entitled Transformation of the Addition of the Capital Adequacy Ratio (Car) of Bank Indonesia into BLBI State Collection Rights.

CYBER INFRINGEMENTS: ANALYZING JUDICIAL AND LEGISLATIVE SAFEGUARDS FOR WOMEN'S PRIVACY RIGHTS IN INDIA

Privacy is one of the necessary requirements that cannot be arbitrarily implemented in any society. People in the same continent may understand privacy as an individual right to privacy in different ways. Appreciation of privacy at global level can be interpreted in Universal Declaration of Human Rights as a liberty right, which is an inherent part of the mankind. With that is evident that privacy violation is not limited to the physical spaces; rather, a person can be violated in all types of computer media. As dependency on internet grows and, therefore use of virtual modes, there are several considerations since people may not be prepared for new technologies I n performing everyday tasks. The matter becomes more complicated when privations are committed against the most helpless in the society. Women and sexual minorities take most of the heat of privacy violations since the society today is embedded in a patriarchal system. Women may face various other sub-violations on the internet which may be included under the title of Technology Facilitated gender-based violence (TFGV). Infringement of privacy is a violation of fundamental rights as recognized under the right to life and personal liberty but privacy violations that take place on digital platforms is not acknowledged and recognized yet. Women are vulnerable to a range of sub-violations, referred to as Technology Facilitated Gender-Based Violence while using the internet. Infringing on someone's privacy is a violation of their fundamental rights, such as the right to life and personal liberty. However, privacy violations that occur on digital platforms are yet to be fully recognized and acknowledged. It is imperative to address these issues to ensure that women are safe and secure while using digital platforms. In this paper, research examines the adequacy of current Indian legal frameworks in protecting women's privacy in digital spaces. Its purpose is to propose legal reforms that enhance the protection of women's digital privacy rights, taking into account global standards and best practices. The research objectives underscore the discrepancies between statutory provisions and their practical enforcement, offering a critical analysis of the existing legal framework and proposing enhancements to more effectively safeguard women against cybercrimes.

Exploring Cooperative Mechanisms in the Chinese Agricultural Value Chain: A Game Model Analysis Based on Leading Enterprises and Small Farmers

In the context of agricultural modernization in China, this paper examines the micro-level perspective of agricultural value chains. Drawing from three primary models of agricultural value chain cooperation—namely, “leading enterprises + small farmers”, “leading enterprises + cooperatives + small farmers”, and “corporate integration”—it establishes four game models: the decentralized decision-making game model, the two revenue-sharing game models, and the centralized decision-making game model. It systematically analyzes the cooperation mechanisms between leading enterprises and small farmers in upstream production links of the agricultural value chain, aiming to improve the cooperation strategy between leading enterprises and small farmers, elevate the status of small farmers in the agricultural value chain, promote increased income for farmers, and strengthen the agricultural value chain. The research findings are as follows: Firstly, the traditional contract of “leading enterprise + smallholder farmers” is incomplete, which makes it difficult to avoid opportunism and moral hazard that may arise between the two parties. By comparing multiple parameter values, it is found that this model is at a lower level of agricultural value chain development. Secondly, the model of “leading enterprise + cooperative + smallholder farmers” improves the tightness and stability of cooperation between leading enterprises and smallholder farmers. This model explains to some extent the operability of smallholder farmers sharing the value of the agricultural value chain. Compared with various parameter values, this model is at a medium level between other models. Finally, the “corporate integration” model is a fully vertical integration model. Compared with various parameter values, this model is at an advanced stage of agricultural value chain development. Therefore, agricultural value chains will ultimately develop toward the direction of corporate integration. This study has positive practical significance for enhancing the status and claim rights of small farmers, promoting increased income for farmers, enhancing the consistency of values between leading enterprises and small farmers, strengthening the stability of the agricultural value chain, and ultimately achieving common prosperity and agricultural modernization in China.

The End of Liberal Peacebuilding

The End of Liberal Peacebuilding

Evolution of The Right to Health in India Vis-A-Vis Bioinformatics and Medical Infrastructure in Bengaluru District

Objective: This research aims to identify the study of Right to Health and Development in India especially through the existing framework of Law specifically related to bioinformatics and medical infrastructure laws in India. Methodology: Exploratory and Analytical research is employed in this work using Primary and secondary data from Legislations, Journals, Books, Articles, and reports and also a data set from empirically sourced data. Result: The survey indicated that the Urban Primary Healthcare Centres (UPHC’s) find it difficult to address the Gender Disparities in Health Access, Age-Related Health Service Utilization, Effectiveness of Bioinformatics in Health Management, Impact of Medical Infrastructure on Health Outcomes, Regional Disparities in Health Access, Community Engagement and Health Services, Bioinformatics Adoption and Staff Capacity. Conclusion: Right to health, bioinformatics and medical infrastructure in themselves are a very broad subject matter. The concept of Right to Health aimed at Development in the advent of advances in the technology, the study of medicine and the modes of experimentation, has changed drastically and the approach in respect to the findings involved in these studies have radically changed. Therefore, invariably this has to be dealt with constitutionally as Right to Health is an implied right that has taken birth from the fundamental right of Life and Liberty as envisioned under the Article 21 of the Indian Constitution and the same has to be looked into from a detailed perspective in relation to the medical infrastructure and preservation of the biological samples and subsequent updating in terms of databases. Ultimately the services offered in the UPHC’s by the state should be on par with, if not ahead, of the Private Health Care Centres in order for the concept of Right to Health to be fully realised and the UPHC’s should ensure work, clinical consideration, training, retirement aide, medical care, education and social security of the Doctors and staff at in the UPHC’s.