Recent Posts

A Freudian Slip?

by Kevin Jon Heller

My favourite entry in the “funny placement coincidences” competition:

funny-coincidence-placement-fails-26__605

I have no political point to make. I just think the photo is fantastic.

Weekly News Wrap: Monday, July 27, 2015

by Jessica Dorsey

Your weekly selection of international law and international relations headlines from around the world:

Africa

  • The Somali militant Islamist group al Shabaab attacked a Mogadishu hotel on Sunday, driving a car packed with explosives through the hotel gate and killing at least 13 people, a first responder and the rebel group said.
  • The European Union is ready to impose sanctions on Burundians failing to help end the Central African nation’s crisis, the EU’s foreign policy chief said on Thursday, following elections that Brussels and Washington say were not credible.

Middle East and Northern Africa

Asia

Europe

Americas

Oceania

UN/World

Events and Announcements: July 26, 2015

by Jessica Dorsey

Events

  • On 24 August 2015 the UCLan Institute for International and Comparative Law organises a One-Day Workshop on International and Comparative Aspects of Responding to War Crimes: Through Law and Alternative Mechanisms. This workshop will address a number of related and distinct international and comparative aspects of war crimes trials, legal policy developments, and will evaluate extra-legal responses using examples of case studies. It is aimed to gather together academics, researchers and others interested in war crimes trials, focusing on legal, historical and political issues of the war crimes trials. Please see the programme and more information here.

Calls for Papers

  • The Anti-Corruption Interest Group of the American Society of International Law, co-chaired by Andy Spalding of the University of Richmond School of Law and Phil Nichols of the Wharton School, is soliciting papers for its first conference/workshop, to be held at the University of Pennsylvania on October 2-3, 2015. Interested persons should submit a one page proposal to Ms. Lauretta Tomasco at tomascol [at] wharton [dot] upenn [dot] edu by August 1, 2015. If accepted, a proposer must supply a five page (or longer) paper by September 25, 2015. Copies of all papers will be distributed to all participants before the conference/workshop; an objective of this meeting is to thoroughly discuss the ideas contained in each paper.  Any submissions that relate to corruption are encouraged.
  • The European Convention for the Protection of Human Rights and Fundamental Freedoms has arguably been the most efficient and effective system for protecting human rights in the world. The European Court of Human Rights monitors compliance with the Convention in the 47 member states of the Council of Europe. However, it appears that there is strong disagreement between some European societies at least about certain basic values. Therefore, the conference will, among others, try to answer the following fundamental questions: What are European values? Is it possible to identify minimum common denominators of European values? Are basic European values similar in Glasgow, Khabarovsk, Rovaniemi and Ceuta? What is the approach of the European Court of Human Rights to the dilemmas posed by European values? What is the role of legal theory and legal philosophy in the search for European values? Which dilemmas and challenges are posed by the search for European values? The conference will be held at the Graduate School of Government and European Studies and the European Faculty of Law in Ljubljana Old Town on 20 and 21 November 2015. The organizers invite researchers undertaking research on the proposed topic to submit abstracts for consideration. Interested applicants should send a 250-word abstract and a CV in narrative form by 1 September 2015 to dignitas [at] fds [dot] si. Authors will be notified of acceptance by 15 September 2015. If you have any questions, please write to dignitas [at] fds [dot] si.

Our previous events and announcements post can be found here. If you would like to post an announcement on Opinio Juris, please contact us with a one-paragraph description of your announcement along with hyperlinks to more information.

Recent International Legal Scholarship on the Crisis in Ukraine

by Chris Borgen

As the fighting in Ukraine continues into its second year, recent reports have variously focused on the promise of a weapons withdrawal and the risk that there is the opening of a new front opening. Recent international legal scholarship has attempted to frame the conflict within the context of international law and consider topics such as issues of legality and responsibility, the role of international law in conflict resolution, and what the conflict itself may show about the state of  international law and the international legal profession.  Following are two recent volumes and a set of videos covering a variety of such concerns:

The first is the current volume of the US Naval War College’s International Law Reports, which contains papers prepared for an October 2014 workshop organized by the West Point Center for the Rule of Law of the U.S. Military Academy and the Stockton Center for the Study of International Law of the U.S. Naval War College. These articles tend to focus on use of force and international humanitarian law related issues including Lieutenant Colonel Shane Reeves and Colonel David Wallace on the combatant status of “little green men,” Geoff Corn on regulating non-international armed conflicts after Tadic, and Opinio Juris’s Jens Ohlin on legitimate self-defense.

I was also one of the workshop participants and my paper, Law, Rhetoric, Strategy: Russia and Self-Determination Before and After Crimea, considers how and why Russia has used international legal arguments concerning self-determination in relation to its intervention in Ukraine. I address the question “of what use is legal rhetoric in the midst of politico-military conflict” by reviewing the laws of self-determination and territorial integrity and considering Russia’s changing arguments concerning these concepts over the cases of Kosovo, South Ossetia, and Ukraine.

In March, the Centre for Polish-Russian Dialogue and Understanding and the Institute of Law Studies of the Polish Academy of Sciences hosted a conference in Warsaw that brought together international lawyers from Russia, Ukraine, across Europe. (I was one of two participants from the U.S.) Given the breadth of views, the discussion was lively. Videos of the presentations are now available online. Panel topics include self-determination and secession (1, 2), use of force issues (1, 2), reactions of the international community (1, 2), issues of recognition and non-recognition (1), and the international responsibility of states and individuals (1).

In the West, we don’t often hear the Russian analyses of the international legal issues in the Ukraine conflict, so I want to highlight contributions by Prof. Anatoly Y. Kapustin, Institute of Legislation and Comparative Law and President of the Russian International Law Association (starting at the 36th minute of the panel on reactions of the international community), Prof. Vladislav Tolstykh of Novosibirsk State University (starting at the 52nd minute of the self-determination panel), and Prof. Evgeniy Voronin of MGIMO University (starting in the 54th minute of the use of force panel).

By the way, my own talk on the self determination panel begins at the 27th minute.

Third, the new issue of the German Law Journal is devoted to a broad range of approaches to assessing the conflict. The opening section uses the perspective of public international law. The next section, as described in the introduction by issue editor Zoran Oklopcic:

upset[s] traditional approaches by interrogating the professional commitments of international lawyers, insisting on the legal and factual hybridity of the conflict, and exposing larger ideational frames and their socio-economic underpinnings that make the conflict in Ukraine legally legible in a particular way.

Following this are discussions steeped in constitutional law and theory and normative political theory. The closing section proposes broader reform agendas and reconsiderations of the roles of law and of international actors. Contributors include organizer Zoran Oklopcic on early-conflict constitution-making, Brad Roth on the rules of secession, self-determination and external intervention, Mikulas Fabry on how to uphold the territorial integrity of Ukraine, Boris Mamlyuk on the Ukraine crisis, Cold War II, and international law, Umut Ozsu on the political economy of self determination, and Jure Vidmar on the annexation of Crimea and the boundaries of the will of the people.

I invite readers to point to other examples of scholarship on the Ukraine crisis via the comments section (or an e-mail to me). I think we all hope that this will become a historical incident rather than continue as a current event.

Guest Post: The Security Council Resolution on the Iran Deal–A Way around the “Reverse Veto”

by Jean Galbraith

[Jean Galbraith is an Assistant Professor at the University of Pennsylvania Law School.] 

The Security Council’s voting procedures make it difficult to pass resolutions – and, typically, difficult to undo resolutions once passed. In an article published not long after the end of the Cold War, David Caron observed that while it is hard to address the difficulty of passing resolutions, the Security Council itself has the power to make it easier for resolutions to be undone once passed. One way, of course, is for the Security Council to put specific time limits on a resolution. But as an alternative Professor Caron suggested that the Security Council could “incorporate in any resolution taking a decision a modified voting procedure for future use in terminating the action taken.” In this way, the Security Council could get around what he described as the “reverse veto” – the default position that a resolution needs another resolution to terminate it and therefore that all P5 members must acquiesce in this termination. Professor Caron described how he had run his idea by a lawyer serving at the mission of one of the P5 but gotten a “quick and dismissive” reaction.

In the Security Council resolution endorsing the Iran deal, we now have something resembling Professor Caron’s suggestion. To see this, one must work through multiple paragraphs of Resolution 2231. To begin with, paragraph 7(a) terminates prior Security Council resolutions imposing sanctions on Iran. But the Resolution further provides that paragraph 7(a) itself can be undone – thus reinstating the prior Security Council resolutions – through what is effectively a modified voting procedure. Specifically, paragraph 11 states that if the Security Council receives a complaint from one of the parties to the Iran deal alleging that there is “significant non-performance of commitments” under the deal, then the Security Council is to “vote on a draft resolution to continue in effect the terminations in paragraph 7(a) of this resolution.” According to paragraph 12, if this draft resolution does not pass, then after a short time lag all the resolutions that had “been terminated pursuant to paragraph 7(a) shall apply in the same manner as they applied before the adoption of this resolution, and the measures contained in paragraphs 7, 8 and 16 to 20 of this resolution shall be terminated, unless the Security Council decides otherwise.” (These “snapback” provisions track the arrangement reached in the Iran deal. Also consistent with that deal, there are further related issues, including that invocation of these provisions could lead Iran to abandon the deal and also a partial limit on the reinstatement of the earlier sanctions as noted earlier on this blog by Julian Ku.)

In other words, paragraphs 7, 8, and 16-20 of Resolution 2231 will automatically terminate if a single P5 member vetoes the draft resolution that follows a complaint submitted to the Security Council by one party to the deal. This flips the usual voting procedure for terminating a resolution. Rather than needing the acquiescence of all the P5 to terminate these provisions, what is now needed is only for one P5 member to block their continuance.

Going forward, the potential for these kinds of modified voting procedures is fascinating to consider. They could increase the likelihood of getting Security Council resolutions ex ante by making it easier for these resolutions to be terminated ex post. They could also reduce the likelihood of stretched interpretations of existing resolutions. For example, if Resolution 678 authorizing the first Gulf War had provided for its own termination through a modified voting procedure, it presumably would have been so terminated before it could have been used by the United States as an asserted legal justification for the second Gulf War. On the flip side, if such modified voting procedures become part of the practice, it is possible that they could be over-used in ways that undermine the effectiveness and stability of the Security Council. It will be very interesting to see whether these kinds of mechanisms get more use in the future.

As someone who studies U.S. constitutional law as well as international law, this issue brings to mind the U.S. constitutional issue of whether a congressional statute can delegate authority to the executive branch but provide that this authority can be terminated in the future through a mere majority vote of one house of Congress (or of both houses of Congress but without Presidential signature). The first instance of this practice that I know of occurred in the Lend-Lease Act and sparked a back-and-forth between President Franklin D. Roosevelt and Attorney General Robert Jackson over the constitutionality of this practice. Ultimately, a majority of the Supreme Court held in INS v. Chadha (1983) that Congress does not have the constitutional authority to develop modified voting procedures for terminating statutory delegations. Even since Chadha, however, the practice of Congress and the President has continued to make use of such procedures, albeit often in more informal ways. In addition, the United States uses modified voting procedures in other contexts, such as the practice-based approach of allowing the President alone (without needing two-thirds of the Senate) to withdraw the United States from treaties where this withdrawal is consistent with international law.

The U.N. Charter does not specify voting procedures for terminating an existing resolution (or other ways in which a resolution might terminate of its own accord). In practice, moreover, the Security Council has long had some flexibility in interpreting its procedures under the U.N. Charter, as demonstrated by its practice of concluding that a resolution can pass with abstentions rather than affirmative votes from P5 members. To me, as to Professor Caron in his article, it seems fairly straightforward that the Security Council has the power to use a modified voting procedure as a condition for the termination of a resolution, just as it can use a fixed termination date. Resolution 2231 is an example of how such modified voting procedures for termination can be useful, and the practice may become more common in the future.

In closing, I thank Opinio Juris for letting me contribute this guest blog post.

Weekly News Wrap: Monday, July 20, 2015

by Jessica Dorsey

Your weekly selection of international law and international relations headlines from around the world:

Africa

Middle East and Northern Africa

Asia

Europe

  • A British man who was last year sentenced by a U.S. court to 12-1/2 years in prison after pleading guilty to running a website that supported the Taliban, has been released, his family said on Sunday.
  • Revelations of U.S. spying in Europe have soured transatlantic relations, prompting a White House apology and, as leak followed leak over the past two years, have fostered feelings of moral superiority among Europeans, yet EU governments are stepping up surveillance of their own citizens.
  • British pilots have participated in airstrikes over Syria on the behalf of allies such as the United States and Canada, the Ministry of Defense said on Friday.

Americas

Oceania

  • Several hundred Australian nationalists and anti-racism activists clashed with police in Melbourne on Saturday in a rare display of violence in a country where immigration is an increasingly emotive political issue.

UN/World

  • The U.N. Security Council must intervene in Burundi to prevent mass atrocities and the risk of a regional conflict, seven independent U.N. human rights investigators said on Thursday.

Events and Announcements: July 19, 2015

by Jessica Dorsey

Announcements

  • A new issue of Theoretical Inquiries in Law has been published online. The title of the issue is “Sovereignty as Trusteeship for Humanity — Historical Antecedents and Their Impact on International Law”. A link to the table of contents can be found here.
  • The Department of Public Law, Jurisprudence and Legal History at Tilburg Law School is hiring two assistant professors (tenure track), one in the History of International Law and the other in General Jurisprudence/Constitutional Law. You can find more information on the site of Academic Transfer and more information on Tilburg’s activities in the field of the history of international law can be found on the website of i-Hilt (Institute of the History of International Law@Tilburg).

Our previous events and announcements post can be found here. If you would like to post an announcement on Opinio Juris, please contact us with a one-paragraph description of your announcement along with hyperlinks to more information.

The Most Distressing Paragraph in the Comoros Review Decision

by Kevin Jon Heller

No matter how many times I read the decision, I keep coming back to this paragraph:

51. As a final note, the Chamber cannot overlook the discrepancy between, on the one hand, the Prosecutor’s conclusion that the identified crimes were so evidently not grave enough to justify action by the Court, of which the raison d’être is to investigate and prosecute international crimes of concern to the international community, and, on the other hand, the attention and concern that these events attracted from the parties involved, also leading to several fact-finding efforts on behalf of States and the United Nations in order to shed light on the events. The Chamber is confident that, when reconsidering her decision, the Prosecutor will fully uphold her mandate under the Statute.

The Pre-Trial Chamber’s comment is mere dicta. But oy gevalt is it dangerous dicta — a dream come true for the ICC’s critics, who have always insisted that the Court’s work will be driven by politics, not law. The paragraph does indeed seem to suggest that the gravity of particular crimes is a function, at least in part, of how much attention the international community pays to them. Such a consideration not only makes a mockery of the Court’s independence, it defies common sense: just as crimes the world obsesses over might be insufficiently grave to warrant investigation, crimes the world ignores could be more than grave enough. You don’t have to be an Israel apologist to see that.

I share the PTC’s confidence the Prosecutor will indeed fully uphold her mandate. And that means she will assess the IDF’s crimes on the Mavi Marmara without regard to what the international community thinks about them.

How Not to Read the Comoros Review Decision (Updated Twice)

by Kevin Jon Heller

Here is the first sentence of Avi Bell’s new editorial in the Times of Israel:

The Pre-Trial Chamber of the International Criminal Court, for the first time in its history, has ordered the ICC Prosecutor to pursue an investigation she has decided to close.

Nope.

You’d think a law professor might make an effort to understand the Comoros review decision before breathlessly intoning “The ICC Declares War on Israel.” And you’d think a major Israeli newspaper would avoid publishing an editorial that can’t make it past the first sentence without making a fundamental — and painfully obvious — mistake.

You’d be wrong on both counts.

UPDATE: Not wanting to be outdone in terms of blatant wrongness, the Council on Foreign Relations and Newsweek have each published an article by Elliott Abrams that makes the same erroneous claim as Bell — one that, not surprisingly, cites Bell’s Times of Israel blog post. Welcome to the right-wing echo chamber.

UPDATE 2: Here is Bell’s thoughtful response to my pointing out that the very first sentence of his blog post contains a substantive error concerning the review decision:

Over the years, I have found Kevin’s comments to be not simply inane and rude, but also a distraction, and not worth responding to. I have made the mistake in the past of trying to engage him on the substance, but have never had any success in getting him to address the issues, since Kevin is unable or unwilling grapple with any law or fact that shows him or his ideology to be mistaken. Kevin’s standard comment is comprised of one or more insults of his opponent while dodging the substance, and his inevitable response to finding himself in a position he cannot defend (generally related to his antipathy to the Jewish state) is to try to shift attention to some tangential triviality. I will not be taking the bait. All the best to you, Kevin.

Notice the one thing that Bell doesn’t say — that I’m wrong. Perhaps he believes the difference between asking the Prosecutor to reconsider her decision not to investigate and ordering her to open a formal investigation is a “tangential triviality.” I doubt most people would agree.

The Pre-Trial Chamber’s Dangerous Comoros Review Decision

by Kevin Jon Heller

In late 2014, the Office of the Prosecutor rejected a request by Comoros to open a formal investigation into Israel’s attack on the Mavi Marmara. To my great surprise, the Pre-Trial Chamber (Judge Kovacs dissenting) has now ordered the OTP to reconsider its decision. The order does not require the OTP to open a formal investigation, because the declination was based on gravity, not on the interests of justice — a critical distinction under Art. 53 of the Rome Statute, as I explain here. But the PTC’s decision leaves little doubt that it expects the OTP to open one. Moreover, the PTC’s decision appears designed to push the OTP to decline to formally investigate a second time (assuming it doesn’t change its mind about the Comoros situation) on the basis of the interests of justice, which would then give the PTC the right to demand the OTP investigate.

To put it simply, this is a deeply problematic and extremely dangerous decision — nothing less than a frontal assault on the OTP’s prosecutorial discretion, despite the PTC’s claims to the contrary. I will explain why in this (very long) post.

At the outset, it is important to emphasise that we are dealing here with situational gravity, not case gravity. In other words, the question is not whether the OTP should have opened a case against specific members of the IDF who were responsible for crimes on the Mavi Marmara, but whether the OTP should have opened a situation into the Comoros situation as a whole. The Rome Statute is notoriously vague about the difference between situational gravity and case gravity, even though it formally adopts the distinction in Art. 53. But it is a critical distinction, because the OTP obviously cannot assess the gravity of an entire situation in the same way that it assesses the gravity of a specific crime within a situation.

The PTC disagrees with nearly every aspect of the OTP’s gravity analysis. It begins by rejecting the OTP’s insistence (in ¶ 62 of its response to Comoro’s request for review) that the gravity of the Comoros situation is limited by the fact that there is no “reasonable basis to believe that ‘senior IDF commanders and Israeli leaders’ were responsible as perpetrators or planners of the apparent war crimes’.” Here is how the PTC responds to that claim:

23. The Chamber is of the view that the Prosecutor erred in the Decision Not to Investigate by failing to consider whether the persons likely to be the object of the investigation into the situation would include those who bear the greatest responsibility for the identified crimes. Contrary to the Prosecutor’s argument at paragraph 62 of her Response, the conclusion in the Decision Not to Investigate that there was not a reasonable basis to believe that “senior IDF commanders and Israeli leaders” were responsible as perpetrators or planners of the identified crimes does not answer the question at issue, which relates to the Prosecutor’s ability to investigate and prosecute those being the most responsible for the crimes under consideration and not as such to the seniority or hierarchical position of those who may be responsible for such crimes.

These are fundamentally irreconcilable conceptions of “potential perpetrator” gravity. The OTP is taking the traditional ICTY/ICTR approach, asking whether the Israeli perpetrators of the crimes on the Mavi Marmara are militarily or politically important enough to justify the time and expense of a formal investigation. The PTC, by contrast, does not care about the relative importance of the perpetrators; it simply wants to know whether the OTP can prosecute the individuals who are most responsible for committing the crimes in question.

To see the difference between the two approaches — and to see why the OTP’s approach is far better — consider a hypothetical situation involving only one crime: a group of the lowest-ranking soldiers from State X executes, against the stated wishes of their commanders, 10 civilians from State Y. The OTP would conclude that the “potential perpetrator” gravity factor militates against opening a formal investigation in State Y, because the crime in question, though terrible, did not involve militarily important perpetrators. The PTC, by contrast, would reach precisely the opposite conclusion concerning gravity, deeming the soldiers “most responsible” for the crime by virtue of the fact that they acted against orders. After all, no one else was responsible for the decision to execute the civilians.

The PTC’s approach to “potential perpetrator” gravity is simply bizarre….

The Latest American Digest on International Law is now Available

by Duncan Hollis

Just a quick note to flag that the Digest of United States Practice in International Law 2014 is now available. You can access it here.  And here’s the accompanying press release from the U.S. State Department:

The Department of State is pleased to announce the release of the 2014 Digest of United States Practice in International Law, covering developments during calendar year 2014. The Digest provides the public with a record of the views and practice of the Government of the United States in public and private international law. The official edition of the 2014 Digest is available exclusively on the State Department’s website at: www.state.gov/s/l/c8183.htm. Past Digests covering 1989 through 2013 are also available on the State Department’s website. The Digest is edited by the Office of the Legal Adviser.

The Digest traces its history back to an 1877 treatise by John Cadwalader, which was followed by multi-volume encyclopedias covering selected areas of international law. The Digest later came to be known to many as “Whiteman’s” after Marjorie Whiteman, the editor from 1963-1971. Beginning in 1973, the Office of the Legal Adviser published the Digest on an annual basis, changing its focus to documentation current to the year. Although publication was temporarily suspended after 1988, the office resumed publication in 2000 and has since produced volumes covering 1989 through 2013.

Guest Post: The Joint Comprehensive Plan of Action Regarding Iran’s Nuclear Program

by Dan Joyner

[Dan Joyner is Professor of Law at the University of Alabama School of Law.  He is the author of the forthcoming book Iran’s Nuclear Program and International Law, which is under contract with Oxford University Press, and is expected in print in 2016.]

The Joint Comprehensive Plan of Action (JCPOA) agreed to by the P5+1 (Germany, France, the U.K., the U.S., China, Russia) and Iran on July 14 is a major success of international diplomacy, possibly to be credited with the avoidance of war.  It is the culmination of twenty months of negotiations between the P5+1 and Iran since the initial Joint Plan of Action (JPOA) was agreed by the parties in November 2013.  See my analysis here of the JPOA when it was concluded.

The JCPOA is comprised of 159 total pages of text, consisting of 18 pages of the JCPOA itself, with a further 141 pages divided among five annexes.  All of the documents can be found at this link.  It is a carefully drafted, well organized document, and compliments are due its drafters.

That being said, it is an extremely complex document, which attempts to address all of the issues in dispute between the parties concerning Iran’s nuclear program, from how many and what type of uranium enrichment centrifuges Iran can maintain in operation, to the technical specifications of transforming the Arak heavy water reactor into an alternate less-proliferation-sensitive design, to excruciatingly detailed provisions on the precise sequencing of sanctions lifting by the U.N. Security Council, the U.S. and the E.U.

The general gist of the JCPOA is easy enough to summarize.  It is a quid pro quo agreement under which Iran agrees to significant limits on its civilian nuclear program, and to an enhanced inspection regime by the International Atomic Energy Agency (IAEA) to verify the continued peaceful nature of its program.  In return, the P5+l agree to a coordinated lifting of the economic and financial sanctions that have been applied against Iran over the past six years by both the Security Council acting multilaterally, and the U.S. and E.U. in particular acting unilaterally.  The end goal of the JCPOA is stated to be that Iran will ultimately be treated as a normal nuclear energy producing state, on par with Japan, Germany and many other Non-Nuclear Weapon States party to the 1968 Nuclear Non-Proliferation Treaty.

The precise sequencing of the implementation of the JCPOA’s commitments was one of the most difficult issues in the negotiations, and the JCPOA has one full annex, Annex V, devoted to the issue.  The implementation plan provides for approximately a 10 year timeline over which the main commitments are to be implemented by the parties.  Technically “UNSCR Termination Day,” on which all Security Council resolutions on Iran will terminate, and on which the Council will no longer be seized of the Iran nuclear issue, is set to occur 10 years from “Adoption Day,” which is scheduled for 90 days after the endorsement of the JCPOA by the Security Council.

Sanctions relief will be staggered, but will begin in earnest on “Implementation Day,” on which date the IAEA will certify that Iran has implemented its primary commitments limiting its nuclear program.  This could occur within approximately six months from “Adoption Day.”  The final, full lifting of all multilateral and unilateral sanctions is set to occur on “Transition Day,” which is defined as 8 years from “Adoption Day,” or when the IAEA reports that all nuclear material in Iran is in peaceful use, whichever is earlier.  So the JCPOA envisions a full lifting of all nuclear-related sanctions on Iran within the next eight years at a maximum, with significant sanctions lifting to occur hopefully within the coming year.

There are a number of important legal observations to make about the JCPOA text.  (more…)