Category: Internet

Bitcoins Are Property, Sayeth The IRS

Posted by Ari Good, JD LLM on May 22, 2014

IRS States Bitcoins Are Property

So the IRS has issued a Notice on the virtual currency known as Bitcoin: It’s not a currency, it’s property. Jolly good, you say, so what? Well, that decision has some major tax implications for the future of what adherents will insist is a virtual currency, or “cryptocurrency”. That has a number of important tax considerations, but for the uninitiated let’s start with the basics, that is, what the heck is Bitcoin?

For these purposes let’s ignore the IRS and grant Bitcoin respect as a “virtual currency”, that is, a medium of exchange, something intangible asset that people can trade for other goods or services (or, other Bitcoins). It owes its existence to computer programmer Satoshi Nakamoto, who created the algorithms related to Bitcoin in and around 2009. It has no tangible existence – one cannot carry a Bitcoin in one’s wallet – but rather depends upon two types of technology for its existence: “peer to peer networking” and “public key encryption”. If you find the technical stuff boring, skip down to “Bitcoins Are Property” below.

Bitcoin Technology

Peer to peer communication is, put simply, stuff that lots and lots of different people on lots and lots of computers do in a “distributed” or decentralized manner, that is, there is no single computer or person that controls what goes on. Napster was one of the first and best known peer to peer networks for sharing music. Millions of different people had songs on their computers. These people used Napster’s software, which you could download onto your computer for free, to share the files over the internet with anyone else also running Napster.

No one was in charge – you simple stood up to be recognized as a “node” on the Napster network, sort of like establishing your own bus stop along a busy route. Then you shared what you had in the same way as you might conduct a pot luck dinner at your local church. The church opens its doors, provides the meeting space (and perhaps one of those big silver coffee makers), and everyone brings their own dishes to share. There are rules: clean up after yourself, don’t show up empty handed, but otherwise no one is in charge of the event. Simple.

Then there’s part two – public key encryption. The deep specifics of this system are beyond the scope of this article (and my comprehension), but in simplest terms PKI is a system by which people can share information securely using a “public” key, an external reference that functions a bit like a PO Box, combined with each user’s “private” key, like the key to that box. You send someone a private letter by referencing their PO Box (which is public), but only the owner can open (or “decrypt”, in the computer world) the letter by using their private key.

These technologies are critical to Bitcoin in that its creators needed a system that allowed them to be traded and exchanged using a decentralized (peer-to-peer) secure (PKI-based) system. When Mr. Nakamoto created his alogrithm he set a finite limit on the number of Bitcoins that will ever exist: 21 million. There are currently around 12 million in circulation, with about 9 million more to be discovered. They are created just as virtually as they are traded: anyone so inclined, and with the computer resources and knowledge to do it, can “mine” Bitcoins by verifying existing Bitcoin transactions. The miners get a commission, in essence, for adding value to the entire virtual monetary world. So, whether you bought your Bitcoins, received them in exchange for goods or services, or mined them you have created or received something of value.

Bretton Woods participants — Tea time at Bretton Woods

What is Currency?

In addition to technology what makes up a currency is, put simply, that people think its a currency, or a “medium of exchange”. If I give you a dollar for a lollipop there’s an immediate understanding that what I am giving you has some intrinsic, quantifiable value (that is, a dollar is worth, surprisingly, $1), that the dollar has an equivalent value in goods or services (lollipops), and that the recipient of my dollar can reuse it to exchange for something else that he might want (say, balloons). This latter part is important. Part of what makes a currency a currency is not only what the original two transacting parties think (our agreement to exchange dollar for lollipop), but that everyone else understands that what both of the parties got has some measurable value. In monetary terms the dollar is therefore not only our “medium of exchange”, but is also recognized as “legal tender” for the transaction. Who decides what is “legal tender”? The simple answer is the government, in part because of the United States Constitution and in part under policies that have evolved over the years. For a fascinating history on what makes money what is it (and who gets to decide that) read up on the exceptional Heritage website.

IRS Rules Bitcoins Are Property

As the use (and trading) of Bitcoins has grown so has the government’s interest in them. Part of why the IRS would care involves whether someone has “acceded to wealth” when they create, sell or exchange a Bitcoin. In other words, has someone to the transaction gotten richer by dealing in Bitcoins rather than a “true” currency? It is a longstanding principle of tax law that such accessions to wealth are “income” which might be taxable to the recipient. I have acceded to wealth, for example, if someone gives me a dollar (for nothing in return), a share of stock or a piece of real estate

Having looked at the issue the IRS came down to the conclusion that Bitcoins are property, not a “currency”. In so doing the US government made using Bitcoin as a medium of exchange much more complicated. This is because, put simply, you, the Bitcoin user, must now keep track of what you paid for your Bitcoin, where it came from, and whether you have tax consequences when you use it to purchase something. This is a whole host of worries you never have to deal with when you use a “true” currency.

The Tax Consequences of Using Bitcoins

So what exactly do you have to track and bother with? The answer, in short, is your “basis”. Basis is just a word. It means “what is my investment in this thing”. If you paid $10 for a share of stock, that is your basis in it (more technically, your “cost basis”). If that stock appreciates to $15 and you sell it, you have “acceded to wealth” by $5, on which you pay tax. So, when it comes to Bitcoins, according to the IRS, go forth and buy, sell and exchange it however you like, however, be sure you track your basis and report your gain (or loss) each time you do it.

This is a huge pain, perhaps by design. Tracking one’s basis in readily exchangeable, intangible things like stock, or now Bitcoins, is extremely complicated. Stock brokers use highly sophisticated software that tracks stock transactions, accounting for all of the Byzantine and upside down rules that govern these transactions. Few, if any, Bitcoin users are prepared for this level of reporting. Figuring out your gain or loss also assumes that you are able to trace exactly which Bitcoin you purchased to use for your cup of coffee. This is similarly difficult given that Bitcoins are “tumbled” into “blocks”, that is, virtually sliced and diced so that it is unclear which Bitcoin you got, or who created or received it. This serves to protect Bitcoin users’ privacy, something the government is viewing with increasing hostility.

Philosophically I am disappointed, though hardly surprised, with this decision. Our entire banking system, really, the entire global economy is in large part based on the dollar as a medium of exchange. That serves an important purpose in that it lends predictability to how oil, carrots or lollipops are priced. There are many “data points”, that is, places to compare, contrast and get an idea of what something should cost. The downside, however, is that it preserves a government’s monopoly on how you do business. Again, this is desirable in many ways, but has a dark side: the government, not you, decides what the currency is worth. The more currency the government prints, the less it can buy or earn in the form of interest. You, the buyer, might not see that the dollar you had yesterday is not the dollar you have today, but those who are exchanging their oil, carrots and lollipops do. Words you hear a lot like “purchasing power” and “inflation” can be tricky to grasp, but are very important to how people live.

What Now?

The matter is not entirely settled. Changing how things work depends on how good the idea is, how strong are the forces against it and who has more patience. Congress, not the IRS, has the ultimate constitutional authority to determine what is considered a “true” currency, and in time this may be the case. Further, the IRS may have done recent Bitcoin purchasers a service. Where you have gains you can also have losses. Just as you accede to wealth through appreciated Bitcoins, you can claim a loss when you didn’t buy so well. As a practical matter, the IRS is entirely unprepared to enforce its new position regarding Bitcoins, as it is unlikely that more than a tiny fraction of this bureaucracy understand them. So, time will tell.

I want to hear from you! Should Bitcoin be considered “currency”? Does the confidentiality of Bitcoin transactions outweigh the risk that they could be used for illicit purposes? Leave a comment, or contact me for a stimulating discussion over a cup of coffee.

Feds Release Details on Megaupload’s Kim Dotcom Criminal Copyright Case

Posted by Ari Good, JD LLM on December 23, 2013

A Deluge of Emails Shows Intent to Violate Criminal Copyright Law

In a test of the reach of American copyright law, the U.S. Department of Justice (U.S. DOJ) has released a 200 page summary of its criminal case against Kim Dotcom. The Feds claim that its documents prove Dotcom’s intent to violate criminal copyright law with his shuttered website, Megaupload. They also claim his criminal enterprise caused the American entertainment industry $500 million in lost profits. Now it’s up to New Zealand officias to decide whether the U.S. can extradite Dotcom to face these charges.

Who is Kim Dotcom?

The eponymous Dotcom, born Kim Schmitz, was a notorious hacker in his native Germany. Police eventually arrested him in 1994 for trafficking in stolen phone cards, but he evaded serious punishment for what a judge called “youthful foolishness” (despite being 20 at the time of his arrest). He eventually moved on to Thailand to dodge charges of insider trading in the early 2000’s. Thailand authorities arrested him anyways and deported him back to Germany. Dotcom again managed to avoid a prison term and left for Hong Kong in 2003.

It was around this time that Dotcom set up Megaupload (among some more questionable investment activity). He generously called his file hosting and sharing website a “provider of cloud storage services” or cyberlocker. More dubious commentators would call it a internet piracy mecca. At one point, Megaupload was the 13th most popular site on the internet and claimed 4% of the world’s traffic.

The Feds’ Case for Criminal Copyright

In 2012, the U.S. DOJ indicted Dotcom in U.S. federal court on criminal charges ranging from Conspiracy to Commit Copyright Infringement to Racketeering. By that time Dotcom had become a resident of New Zealand. Briefly imprisoned there, Dotcom is now out on bail and hiding away in his New Zealand mansion.

Emails and Skype messages released by the U.S. DOJ appear to show Dotcom had less than honest intentions for Megaupload.

“I have a feeling that Kim tolerates a certain amount of copyright violation.”

But digging deeper into the U.S. DOJ’s summary, there doesn’t appear to be much in the way of direct admission by Dotcom of an intent to violate criminal copyright law. Rather, there is a lot of innuendo and circumstantial evidence. Dotcom forwarded emails to other corporate officers about piracy and Megaupload, complained of lost revenue when employees complied with DMCA requests, and was included in emails by other Megauplaod officials who made more direct admissions.

The U.S. DOJ’s other problem with this international caper, though, is Dotcom’s residence in New Zealand. They’ll have to wait until at least 2014 for judicial authorities there to decide whether the U.S. can extradite Dotcom.

Dotcom’s Defense to Criminal Copyright Charges

Dotcom appeared to have relied upon a distorted understanding of U.S. copyright law to justify his actions. Dotcom, in the U.S. DOJ’s release, repeatedly referred to DMCA takedown requests. This part of copyright law requires copyright holders to inform ISP’s of copyright infringing material before the ISP needs to remove that material. Of course, the infringing content providor must have had a good faith belief their actions were legal in the first place. Or that they were at least ignorant of its legality.

An extension of this defense theory is that Megaupload is simply a “cloud” storage platform. Prosecutors cannot hold Dotcom responsible if people use the site for online piracy. Not suprisingly, a host of witnesses, including the MPAA, RIAA, and BSA, are ready to go to court to dispute Dotcom’s story of benevolent intentions.

This story warrants further attention to see how far the reach of U.S. copyright law can extend.

Ari Good, JD LLM, a tax, aviation and entertainment lawyer, is the shareholder of Good Attorneys at Law, P.A. He graduated from the DePaul University College of Law in 1997 and obtained his L.L.M. in Taxation from the University of Florida.

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The Right to Digital Public Performance

Posted by Ari Good, JD LLM on August 16, 2013

The Six Rights of Copyright – Part VI: The Right to Digital Public Performance

The Bundle of Rights That Make Up Copyright

The digital public performance right is the sixth and final part in our series on what makes a Copyright. The prior five rights reviewed are linked below. To refresh, the six parts of copyright are:

The right to reproduce the copyrighted work
The right to prepare derivative works based upon the work
The right to distribute copies of the work to the public
The right to publicly perform the copyrighted work
The right to publicly display the copyrighted work
(sound recording only) The right to digitally transmit to publicly perform the copyrighted work

We’re individually exploring each of these rights to get behind the opaque curtain of copyright. An understanding of each right and how they operate will allow you, the creator, to be in a better position to take advantage of your copyright.

There are a couple words of caution. First, the practical effect of these exclusive rights will depend on the type of copyrighted work (literary works, musical works, motion pictures, sound recordings, etc.). Second, these are exclusive rights. The law allows the copyright holder only to exercise these rights.

VI: The Right to Digital Public Performance of Sound Recordings

The right to digital public performance of sound recordings is an extension of the traditional right to public performance. Copyright holders have the exclusive right to publicly perform their sound recordings–a particular recording of a musical composition (e.g. master recording, masters)–via digital transmission (e.g. internet, satellite radio). The older right to public performance specifically excludes sound recordings. This right is limited because it does not cover analog transmissions such as traditional radio or television.

Why the Right to Digital Public Performance?

Digital Public Performance - Webcasting — Digital Public Performance: Webcasting

Congress created this copyright protection (DPRSRA legislation) because of advances in technology. High quality digital copies of sound recordings became easy and cheap to make in the 1990’s. Suddenly, people could readily profit from this practice and artists had little legal recourse. The digital public performance right creates a partial solution for this gap in copyright law. Groups that want to legally play sound recordings via digital transmission (think Spotify and Pandora) now must pay for that right. It was perfectly legal to not pay prior to this legal update. An organization called Sound Exchange currently administers the licensing of sound recordings.

There is a three-tier system that sets the licensing fee for sound recordings. The first tier doesn’t require certain broadcasters to pay any licensing fees. The second tier requires broadcasters to pay a “statutory” licensing fee set by the Copyright Board. The third tier requires broadcasters to negotiate the licensing fee directly with the copyright holders. Much of the highly publicized dispute over fees for sound recordings is about this second tier payment structure. Artists, broadcasters, and other interested groups vehemently disagree about the correct licensing fee amount and how to calculate that fee.

Limitations on the Right to Public Display

The most important limitation on copyright protection for sound recordings is that it only covers digital transmission. It’s business as usual for analog broadcasters in radio and television. The details of the digital public performance right also has many more nuances. It’s a fair complaint by sound recording copyright holders that they’re treated unfairly when compared to musical composition copyright holders. It’s also safe to say that no one (artists, broadcasters, and copyright holders) is actually satisfied with this copyright protection.

Ari Good, JD LLM, is a Miami entertainment lawyer and aspiring musician himself who represents DJs, live musicians, fashion models, and other entertainers in copyright, licensing, and contract matters.

Contact us toll free at (877) 771-1131 or by email to info@goodattorneysatlaw.com.

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The Six Rights of Copyright – Part IV: The Right to Publicly Perform

Posted by Ari Good, JD LLM on May 15, 2013

The Right to Publicly Perform is the fourth part in our series on what makes a Copyright. The prior three rights reviewed are linked below for you to get up to speed. To refresh, the six parts of copyright are:

The right to reproduce the copyrighted work
The right to prepare derivative works based upon the work
The right to distribute copies of the work to the public
The right to publicly perform the copyrighted work
The right to publicly display the copyrighted work
(sound recording only) The right to digitally transmit to publicly perform the copyrighted work

To try to get behind the curtain of copyright, we’re individually exploring each of these six rights. An understanding of each and how they operate will allow you, the creator, to be in a better position to take advantage of your copyright.

There are a couple words of caution. First, the practical effect of these exclusive rights will depend on the type of copyrighted work (literary works, musical works, motion pictures, sound recordings, etc.). Second, these are exclusive rights. The law allows only the copyright holder to exercise these rights.

IV. The Right to Publicly Perform the Copyrighted Work

The right to publicly perform means only the copyright owners, or others they authorize, may perform their works publicly.

This right prohibits would be thieves from performing a copyrighted work before the masses and profiting from that theft. As an exclusive right, anyone wishing to perform a copyrighted work publicly must first obtain permission from the copyright owners. Copyright owners, at least in the music industry, are often different from the people who created the work in the first place. How far this right extends depends on answering two questions.

What acts does a performance cover?
When is that performance public?

The definition of performance under the Copyright Act goes beyond the usual examples of live works.

Right to Publicly Perform — Live Public Performance

The term performance certainly covers situations when a person executes a copyrighted work live. Examples of this include a band playing music in front of a crowd, a theater company performing a ballet before an audience, or people watching a film at the movie theater. However, it also covers analog or digital transmission of performances by radio, television, and internet streaming. Examples of transmitted performances include a song played on the radio, a recording of the ballet played on television, and a film screened for locals at a community park. A performance occurs when the work is done live and when someone transmits a recording of the work.

The definition of public under the Copyright Act means any group beyond family and close friends.

A performance is public when the work is performed: (1) in a place open to the public, or (2) at a place where a substantial number of persons outside of a normal circle of a family and its social acquaintances are gathered. In plain English, music you play for your family (3rd cousins need not apply) or close friends (not everyone on your Facebook friends list) will be a private performance. Putting out flyers for your upcoming rendition of Britney Spears’ greatest hits, however, would be a public performance. A performance is also public when you transmit the copyrighted work to a general audience. This happens when a radio station plays a song, a television show includes that song during a dramatic break up scene, or you stream the song from your internet radio station. Transmission of a performance will be public unless you restrict it to only your family or close friends. As a general rule, live or recorded performances that can reach more than a few people will be public performances.

The traditional right to public performance applies to musical works, but not sound recordings.

Copyright owners of musical works (songwriters and music publishers) gain the traditional right to public performance. Copyright owners of sound recordings (record labels), however, are left out in the cold. A musical work is the composition, arrangement, lyrics, and other details that embody a song. A sound recording is a specific performance of that musical work. A musical work results when a band gets together to create an album. A sound recording results when that same band goes into the studio to record the album. The practical effect of this distinction is that analog radio stations must obtain a license only for musical works before playing songs on the air. They don’t need permission from the owners of sound recordings that they actually broadcast. This is true even though radio stations would have nothing to play without these sound recordings.

Three U.S. Performance Rights Organizations (PRO’s) (BMI, ASCAP, and SESAC) handle the vast majority of licensing and royalty issues for musical works. There is a vast sea of musical works out there. PRO’s strive to organize this complex network by licensing musical works on behalf of songwriters and bands. The PRO’s then collect royalties for the licenses and send checks to the songwriters and bands. The PRO’s are certainly not charitable entities, however, and take a cut of the royalties to cover the expenses in managing the system. Some would say too big of a cut.

This oddity of the traditional public performance right has its roots in the history of Copyright. Copyright protection existed long before people could record music and sheet music (an example of musical works) was the standard. Copyright protection for musical works was necessary at that time, but obviously not so for non-existent sound recordings. Copyright law failed to keep up with evolving technology, however, when sound recordings emerged to provide people with a different way to access music.

Congress tried to fix the problem by passing the Digital Performance in Sound Recordings Act (DPSRA). This created the sixth right of Copyright: the right to perform publicly by digital transmission. The DPSRA did provide relief for sound recording owners, but also created a volatile two-class system. Internet radio stations like Pandora and Spotify now have to obtain licenses and pay royalties to copyright owners of musical and sound recordings. Analog radio stations, on the other hand, continue to enjoy preferential treatment and only have to answer to copyright owners of musical works. Analog radio stations have a huge financial advantage over internet radio stations as a result.

The right to public performance does have its limitations.

For every rule, there are exceptions. The right to public performance is no different. Charitable, non-profit, and educational groups may publicly perform copyrighted works without permission if it’s for a reason recognized by law. Certain businesses may also play copyrighted music without permission for their customers if they play by the rules.

The business must receive the music from a licensed radio, cable, satellite, or television broadcast;
The business must be on the smaller side;
The business must play it only in their establishment;
The business cannot charge an admission fee.

A club that charges admission to listen to a recording of the latest, greatest pop album is not going to fall into this exception. The ubiquitous Fair Use exception to copyright protection can come into play for the public performance right, too.

That’s a lot to go over! Go ahead and ask questions if you have them, or leave a comment if have an interesting anecdote about the public performance right.

– Ari Good, Esq.

Ari Good, JD LLM, a tax, aviation and entertainment lawyer, is the Shareholder of Good Attorneys At Law, P.A. Ari Mr. Good received his BA, With Distinction, from the University of Michigan in 1993. He graduated from the DePaul University College of Law in 1997 and received his LL.M. in Taxation from the University of Florida. Ari represents DJs, live musicians, fashion models and other entertainers in copyright, licensing and contract matters.

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Royalty Free Samples: A Peculiar Problem of Producing Music

Posted by Ari Good, JD LLM on May 9, 2013 with 1 Comment

A common question from DJs and music producers is: “what right do I have to create and protect my own music using ‘royalty free’ samples, beats, and loops?” Can you copyright work that you derive from these sources? The simple answer is yes, if certain requirements are met. This situation is a textbook example of derivative works and rights (one of the six exclusive rights of copyright). Artists can copyright derivative musical works as long as they had the necessary permission to use the original source material. Let’s break down the issue in detail:

1. The source material must be “royalty free”, or really, “royalties paid”, for you to use them in your own music.

As a refresher, there are typically two parties in music business who own the bundle of rights we call “copyright” and would want a royalty if their music is used. The first are the owners of the musical compositions themselves (the arrangement, lyrics, etc.), typically music publishing companies, who have purchased these rights from the original musicians. The second are the owners of the master recordings, typically the record labels.

Say, for example, you wanted to use a sample from the Rolling Stones song Shattered from their studio album, Some Girls (and who wouldn’t?). You would need to obtain permission from (and pay royalties to): (1) the Rolling Stones’ music publisher, for the music composition, and (2) the Rolling Stones’ record label, for the master rights to the recording. (Quiz: if you recorded your own version of Shattered, you would only need to obtain permission from the Rolling Stones’ music publisher, since the master recording is no longer involved).

Now, in the case of commercially available loops and samples, it’s usually a bit of a misnomer that samples you purchase are royalty free. Rather, the company offering the loops has paid the necessary royalty or royalties that allows them to copy and resell the loops to you. You, as the loop buyer, may then use the loops to create derivative works. Getting beyond use, however, requires some additional steps.

2. In order to protect your new creation, the loop seller’s terms and conditions must grant you the right not only to use and make derivative works, but also to copy the royalty free source material.

You must have permission to copy and prepare derivative works from royalty free source material before you can copyright your new creation. The following is an example of terms and conditions that give you the right to use your loops to create derivative works and copy the material into your own, protectable creation:

The Sounds remain the property of its manufacturer and/or Loopmasters Limited. (Collectively, “Licensor”) and are licensed to you as the original end-user (“Licensee”), for use subject to the provisions below. All rights not expressly granted herein are reserved exclusively by Licensor.

The Sounds in a category of ‘Sample Pack’:

1. The Licensee may use the Sounds in combination with other sounds in music productions (which include soundtracks of such as films, video productions, radio/TV programs or commercials, computer games and multimedia presentations, library music), public performances, and other reasonable musical purposes within musical compositions.

English: You can use the loops in multiple ways, when combined with other music.

2. The Licensee may modify the Sounds and may use the Sounds for commercial purposes as part of a musical composition with other sounds.

English: You can alter the loops and use them in your own musical creations.

3. The Licensee MAY NOT use the Sounds in isolation as sound effects (i.e. a sequence of musical events) or within any competitive products that are sold or relicensed to multiple third parties. In these scenarios, the Licensee must arrange an extension with Loopmasters Limited.

English: You can’t just take our loops, then turn around and use them other than as something of your own. Also, you can’t just turn around and resell our loops again without talking to us first.

4. A right to use the sounds is granted only to the Licensee and is NOT transferable. This license expressly forbids resale, re-licensing or other distribution of the Sounds, either as they exist or any modification thereof. You cannot sell, loan, rent, lease, assign, upload to or download from any server, or transfer all or any of the enclosed sounds to another user, or for use in any competitive product.

English: Only you, not others, can use the loops.

5. Licensor will not be responsible if the sounds does not fit the particular purpose of the Licensee.

English: If you’re not happy with the loops, tough luck.

PLEASE NOTE:

This is a general licence which covers all Loopmasters products, it may not apply to products from other labels that we represent at Loopmasters.com – if in doubt please email us or contact the label directly.

English: If you’re unsure that you’re using the loops properly, ask before that use.

You can only copyright musical derivative works if you have the necessary license for the royalty free source material.

3. The musical derivative work must be substantially different from the royalty free source material.

Although it’s common sense, a work must be noticeably different from the royalty free source material to be derivative. A purchased music sample is not a derivative work unless you somehow alter, transform, or adapt it. This is usually not a problem for DJs, who may merge multiple samples or layer their own musical ideas over the sample. Even the act of arranging different samples in a unique way is enough. Your editorial idea for the arrangement is the added element making it a new, derivative work.

You can only copyright derivative works if they are substantially different from the royalty free source material.

4. Derivative works do not have copyright over the royalty free source material.

It’s worth noting that creating a derivative work from royalty free samples, drum beats, or loops doesn’t give you copyright to the source material. You don’t become free to do whatever you want with the source material once you create a derivative work. This means that you can’t sell, give away, or publicly play the source material as a stand alone. Your rights to the source material only cover its use in your new creation.

If you have any questions about royalty free music that were not discussed, leave a comment and I’ll respond.

– Ari Good, Esq.

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