Guest Post: Intermediary liability in defamation cases - Parle, Mouthshut & Visakha cases to clarify the law

Chaitanya Ramachandran, who has blogged for us previously over hereand here, has sent us this excellent guest post analyzing the extent of intermediary liability in the context of defamation lawsuits. The specific backdrop to this post is first the recent litigation by Parle against Facebook, Twitter & Google, second the problems being faced by Mouthshut.com and third the pending appeal before the Supreme Court against the decision of the Andhra Pradesh High Court where the Court refused to quash criminal summons issued to Google in a defamation case filed by an asbestos firm in A.P.   

Intermediary Liability and Defamation – Finding the Right Balance between Free Speech and Reputational Interests

By  Chaitanya Ramachandran

The issue of intermediary liability for defamatory content has come to prominence following two recent

developments. The first is a case recently instituted in the Bombay High Court by Parle Agro against Google, Facebook and Twitter (see herefor the full story), in which Parle has alleged that these Internet companies should be liable as intermediaries for “promoting” defamatory content, which in this case was a viral post alleging that Parle’s popular mango drink Frooti is contaminated. The second is the revelation by Mouthshut.com (a popular review website) of the large number of takedown requests and legal notices it has received to date from companies that are unhappy with reviews of their products (details available here). These developments must be viewed in the context of increasing hostility towards social media websites from various interest groups in India; corporates are only the latest to join the ranks of political, religious, and other groups that routinely demand that social media websites take down “offensive” content.

The Problem With Notice and Takedown under the IT Rules

This worrying trend has been fueled in India by the Information Technology (Intermediaries guidelines) Rules, 2011, which correspond to s.79 of the IT Act, the main statutory provision governing intermediary liability. The rules specify the standard of “due diligence” expected of intermediaries, and, inter alia, require user agreements to prohibit the uploading of defamatory content. While this is not a particularly burdensome requirement in itself, its primary means of enforcement – namely the notice and takedown regime under rule 3(4) – is deeply flawed. Intermediaries who have received takedown notices must “act within thirty six hours and where applicable, work with [the] user or owner of such information to disable such information…”.  This provision gives any “affected person” carte blanche to issue a takedown notice to an intermediary, who in turn has virtually no choice but to comply for fear of losing safe harbour protection (the need for intermediaries to act swiftly has been stressed by the AP High Court in this judgment).  Therefore, this is an effectively unilateral notice and takedown regime that leaves the power of “affected persons” to issue takedown notices (including frivolous or unwarranted ones) virtually unchecked. By contrast, the new notice and takedown regime for copyright infringement (which we previously blogged about here) requires copyright holders to undertake to file suit within 21 days of the take down request, failing which the intermediary may legally reinstate the content that was taken down.  By burdening notice issuers with an obligation to file suit, this system ensures that all claims will ultimately be evaluated by a court of law, and also, to an extent, discourages aggrieved parties from issuing frivolous notices. The regime under the IT Rules does not impose an equivalent obligation on notice issuers.

Unsurprisingly, Mouthshut.com has filed a petition in the Supreme Court challengingthe IT Rules. Significantly, the bench observed during an interim hearing that curbs on freedom of speech should be restricted to those permitted by Article 19(2) of the Constitution. Given that the notice and takedown regime under the IT Rules potentially permits affected persons to exceed the scope of the established Constitutional restrictions on free speech in a completely private process, a very strong case exists for the existing rules to be struck down.

Intermediary Liability and Defamation

Although the existing notice and takedown regime for defamatory statements is flawed, this is not to say that all claims against intermediaries for defamatory content are without substance. With respect the Bombay High Court case, there is no doubt that a false statement relating to the purity of Parle’s products has the potential to cause vast losses to Parle, especially as summer is a crucial sales period for soft drinks like Frooti.  The difficult question is, where should the line be drawn between Parle’s reputational and commercial interests and Facebook’s interest in avoiding the massive costs and impracticability of policing its website for defamatory content?

This is not a new problem; the law of defamation has always had to grapple both with authors who make defamatory statements and publishers who, knowingly or unknowingly, disseminate them. However, the analogy between Internet intermediaries and print media publishers is not perfect. A single Internet intermediary can potentially reach a much larger number of readers than a single print publisher; at the same time, the number of posts or webpages hosted by intermediaries like Facebook and Google must surely be orders of magnitude larger than the number of articles published by a print publisher. This is probably why disgruntled groups regularly target intermediaries. Individual authors are responsible for creating viral posts such as the one targeting Parle; but the only practical way of controlling the damage done by such posts is to target the intermediary, who has some power to control the dissemination of the material.

Intermediaries may be targeted in two ways. The first is the notice and takedown situation described above, in which the intermediary is not itself found liable for defamatory content as long as it complies with a takedown notice under the applicable legal framework. The advantage of a well-designed notice and takedown system is that it does not require intermediaries to police their services, albeit at the cost of having to comply with takedown notices. The second way in which intermediaries may be targeted is fault-based; a situation in which intermediaries are deemed to have knowingly published defamatory material, and are sued in their capacity as publishers. A notice and takedown situation may evolve into a fault-based situation if the intermediary refuses to comply with a legitimate takedown request, although this view is contestable. For example, earlier this year, the English Court of Appeal decided that Google would be liable as a publisher of defamatory content where it failed to comply with a takedown notice within a “reasonable time”.

However, in the typical case of a user authoring a defamatory post that subsequently goes viral, the petitioner’s remedy should ordinarily be restricted to a timely takedown. Of course, the problem is that the existing framework is unworkable, and needs to be replaced with a balanced regime that circumscribes the power of notice issuers. Parle may be genuinely aggrieved, as may be some of the parties that have issued notices to Mouthshut.com (especially those that are victims of fake reviews or sabotage by their competitors), but the solution cannot be to sue intermediaries for “promoting” defamatory content where their role has not gone beyond hosting such content without actual knowledge of its defamatory nature. This would only continue the trend of chilling free speech online, and would also adversely affect Internet companies’ incentives to innovate by providing newer and better tools for people to communicate.

Conclusion

The law as it exists today in India does not adequately protect the interests of Internet intermediaries in cases where their users post defamatory content. It is essential for the law to lead the way by laying down robust norms protecting the interests of intermediaries, because there is a worrying amount of hostility towards social media in India today. The best way of striking a balance between protecting the reputational interests of parties that find themselves being defamed and protecting free speech online may be to redesign the notice and takedown regime under the IT Act. A well-designed system would permit genuinely aggrieved parties to require a takedown of content pending final determination by a court of law, while simultaneously discouraging frivolous notices by, for example, explicitly restricting the grounds to those currently recognized under Article 19(2).

Read More

Breaking News: Kerala HC ends suo moto proceedings against the grant of Attukal deity trademark

We reportedthat the Attukal Bhagawathy Temple Trust (“Trust”) in Kerala had secured trademark

protection for the picture of its deity (Trademark No. 1420800) and the title ‘Sabarimala of Women’ (Trademark No. 1420799) under Class 42 (for temple Services, social services, welfare services and cultural activities). The Division Bench of the Kerala High Court initiated suo moto case against the aforesaid registrations in early 2009 based on a petition faxed by Mr. Praveen Raj. The High Court later appointed Mr. Santhosh Mathew, Partner, M/s. Ninan and Mathew Advocates, as the amicus curiae.The High Court rendered its judgment on the aforesaid matter today. [For my earlier post analysing the legality of grant of trademark, see here].

The Court ended the suo moto proceedings and declined to grant relief on merits. It was clarified that the the grant shall not adversely affect the devotees’ right to worship. The Trust, by virtue of the registration, can restrain others from providing services in the name of the Deity for monetary benefits. However, charitable services in the name of the Deity cannot be restrained.

[As the judgment was delivered only a couple of hours back, I do not have a copy of the judgment. I shall later carry a detailed post on the judgment. Presently, I am just carrying a post on the operative part of the judgment (as I could gather from my sources in Kerala HC).]

Read More

Copyright Amendments: A Fair Balance?

In a belated post (and a severely belated one at that), we bring you this special report on a conference held last year in Kolkata titled ‘Copyright Amendments, 2012: A Fair Balance?’

The two-day event was organized by the MHRD IP Chair at National University of Juridical Sciences (NUJS) with the help of the following partners: 

i) MHRD IP Chair at Cochin University of Science and Technology (CUSAT) 

ii) IPTLS (a student run IP and tech law society) and 

iii) NUJS Law Review 

This conference was one of the first to rigorously brainstorm the contentious 2012 copyright amendments. A detailed report on the conference can be found on the SpicyIP resource page. The report is a collective effort of a number of dedicated student volunteers who took elaborate notes throughout the conference. 

For those interested in a more audiovisual feel, we’ve uploaded most of the sessions on this Youtube link. 

For those with little time to read the entire conference report, here is a short version (well, not really, but as with most other things in life, I use the term in a relative sense). 

Summary of Copyright Conference

Welcome Address: 

Prof Shamnad Basheer, the MHRD IP Chair at WB NUJS opened the conference along with the student MC’s, Arun Mal and Amba Kak. 

Prof. (Dr.) Ishwara Bhat, the Vice Chancellor of WB NUJS and the Registrar, Dr. Surajit Mukhopadhyay extended a warm welcome to all present. Dr. Mukhopadhyay, a professor of social sciences, shared his insightful views on copyright norms and access to knowledge. Deploying his deep knowledge of ancient scriptures, Prof. Bhat reminded the audience of the importance of knowledge sharing/dissemination. 

Introductory Session: 

The session began with two special presentations from individuals who’d contributed significantly to the crafting of the amendments, Prof. N.S. Gopalakrishnan and Mr G.R. Raghavender. Prof. Gopalakrishnan [Part I & Part II] began the proceedings with a wonderful sweep of the social, economic and political narratives that informed the 2012 Amendments. He noted that the changes were brought in to balance three broad principles, namely; promotion of creativity, facilitation of access and the social dimensions of copyright. 

As many of you know by now, Prof NSG was thanked profusely for his services to the nation by a golden handshake meted out by his home institution (CUSAT). For those interested, our protest petition against his untimely handshake garnered 300 signatures and is open for signatures for another 3-4 days or so. So please do sign up if you wish to lend your name to this cause. 

Following Prof NSG, Mr. Raghavender, the Registrar of Copyrights piloted us through a wonderful and insightful examination of the history behind the amendments. 

Session I: Copyright & Entertainment 

The first session focused on the impact of the amendments on the entertainment industry. Voicing the interests of radio broadcasters, Prashant Pandey, CEO of Radio Mirchi welcomed the statutory licensing provisions. Tracing the evolution of private radio industry in India in a compelling narrative, he persuasively argued that the monopolistic behaviour of copyright societies and owners rendered many radio stations financially unviable. Prashant rightly noted that the newly introduced statutory licensing provisions would greatly benefit copyright owners as well as consumers. 

Arun Mohan, a practicing advocate at Madras High Court, was highly critical of the amendments dealing with mandatory royalty sharing. Noting that the drafting of the amendments left much to be desired, Arun also reflected on the fact that the amendments could have done with better homework of comparative positions in the US etc. He also rightly noted that a key solution is also to strengthen unions and collective bargaining power. 

Anjum Rajabali, who heads the Copyright Committee at the Film Writers’ Association, responded by noting that it was indeed the weak bargaining power of artists and lack of good business practices in the industry that prompted the statutory intervention. 

This was followed by a round table discussion on the on the future of entertainment in India. [Part I, Part II & Part III] The moderator, Dr. Madhukar Sinha, Professor at Centre for WTO Studies, in his opening remark noted the star-power is no longer the driving force for Indian films and asked the panelists on measures taken to improve access to entertainment. The panelists of this round table discussion were Phulak Bagchi (Vice-President, Legal & Regulatory Affairs, Star India), Anjum Rajabali (Film Writers’ Association) and Rajesh Dhupad (Jt. Secretary, South India Music Companies Association). It was a vibrant session with lots of interesting thoughts from the various panelists. 

Section II: Copyright & Technology 

The second session dealt with technological protection measures (TPMs) and intermediary liability exemption in Section 52 and its impact on the IT sector. 

Pranesh Prakash, Policy Director at the Centre for Internet and Society, questioned the need for introducing the provisions on TPMs as India was not a signatory to the WIPO agreements, namely; WCT and WPPT. Nonetheless, Pranesh hailed the provisions as being more evolved than most other pari materia provisions around the world. In the round table discussion that followed later, Prof Dr. V.C. Vivekanandan, MHRD IP Chair at NALSAR suggested that the provisions might have been inserted to placate the US. 

Praneshs’ presentation was followed by an insightful and well researched presentation on safe harbour provisions by Rajendra Kumar, Partner at K&S Partners. Kumar traced the evolution of intermediary liability jurisprudence around the world, most notably the US and EU. He noted that the Indian provisions were akin to conduit safe harbour provisions in the EU directive. He opined that Section 52(1)(c) lacked clarity in terms of not clearly spelling out as to which intermediaries were entitled to the exemption. Pranesh suggested that the provision was applicable to search engines and perhaps storage services depending on the interpretation of the word ‘incidental’ in the provision. 

Prof. Basheer, moderating the round table discussion, asked the panelists if a broad construction of the word ‘access’ in Sec. 52(1)(c) would effectively render redundant the exception provided in sub-clause (b). Prof. Gopalakrishnan suggested that the difference between both clauses rests on the ‘technical processes’ involved in the transient or incidental storage. If the incidental or transient storage is for longer duration, there is a need for checks and balances and Cl. (c) addresses these concerns. 

Session III: Copyright Limitations & Exceptions 

Pranesh Prakash spoke on the legality of parallel imports and observed that there is no statutory basis providing for an exclusive right to import copyrighted works. He went on to defend his hypothesis based on text of Section 2(m) and 51(b)(iv). Pranesh further criticized the decision of Justice Manmohan Singh of the Delhi High Court in John Wiley v. Prabhat Chandra Kumar Jain for recognizing a right to export works under the Copyright Act instead of contract law. 

Following this presentation, the copyright registrar, Mr Raghavender drew attention to a study conducted in New Zealand which demonstrated positive spillovers of parallel imports. Further, he informed the audience of an on-going study by National Commission of Applied Economic Research to determine whether or not parallel imports ought to be legalized in India. 

Abhishek Malhotra, Partner at TMT Law Partners delivered a riveting presentation on the statutory licensing scheme, noting that the amendments were prompted by demands for unreasonable royalties from music labels. Abhishek also highlighted the possibility of constitutional challenge to Section 31D. 

In a provocative presentation, Amlan explored the educational exception in the backdrop of the Delhi University photocopying row. He argued in favour of a broad interpretation as would promote access. The presentation elicited sharp reactions from the audience. One of the audience suggested that DU students have the financial means to afford a license and should therefore take a license without relying on the exception. Sheetal Chopra, representing FICCI, highlighted the loss of royalties from photocopies. 

In response, Prof. Basheer cautioned that this case was about educational course packs and that the statute provided a broad enough framework to exclude educational photocopying. Further, it was evident that a majority of academic scholars preferred enhanced readership over the paltry economic benefits through royalties. Lastly, he cautioned that while some DU students might be able to afford licenses offered today, such students are not representative of all Indian students, a large percentage of whom struggle to even pay their tuition. 

Ujwala Uppaluri, a fourth year student at NUJS, explored the impact of the amendments on public libraries in India. Ujwala welcomed the exception for storage of electronic copies by non-commercial public libraries and rightly stressed the need for digital preservation of works. Mr. Raghavender woed the fact that there was no express provision for inter-library loans, especially in the context of digital copies. Prof. Gopalakrishan observed that virtual libraries require significantly different rules and that it requires a fresh look as in when virtual libraries become a reality. 

The session ended with a passionate presentation by Prof. Sam Taraporevala, Director at Xavier’s Resource Center for the Visually Challenged, narrating the ‘unique Indian story’ in campaigning for and obtaining a special copyright exceptions for the benefit of people with disabilities. The amendments were a result of prolonged efforts from several individuals and civil society organizations. Prof. Taraporevala further noted that there is need to ensure accessible books in real time and proposed for setting up of National Library for Accessible Content in consonance with UNCRPD. 

Session IV: Copyright Enforcement, Adjudication & Governance 

Pravin Anand, one of India’s leading IP lawyers began this session by delivering a scintillating presentation on: ‘Copyright Enforcement: Will the amendments make a Difference?’. He applauded the Delhi High Court for measures aimed at making court processes quicker and more efficient and noted in particular that the collection of evidence by local commissioners had eased the pressure on regular judges who were already clogged with backlogs. He also highlighted the fact that the Delhi High Court had often taken the lead in IP jurisprudence by interalia being the first to Anton Pillar orders, Mareva injunctions etc. 

Sheetal Chopra, Joint Director at FICCI passionately advocated for more stringent antipiracy measures. She noted the significant losses made by the entertainment industry as a result of piracy and highlighted the role of camcorders in promoting piracy. 

She recorded her displeasure at the amendments to Section 52(1)(a) which allowed for reproduction for ‘personal or private use’, arguing that this effectively legitimized the use of cam-cording devices. Ms. Chopra further expressed her dissatisfaction with lack of penal action against those manufacturing devices with the sole objective of circumvention. In response, Mr. Prakash and Mr. Sinha suggested that affordable pricing is the most effective solution to piracy. (Note: we are given to believe that the government is now initiating measures to criminalise the possession of camcorders in cinema halls. This comes at the behest of concerted advocacy by several Bollywood producers, FICCI, USIBC, MPAA etc. 

The constitutional validity of the composition of the Copyright Board was challenged in the Madras High Court recently. Ananth Padmanabhan, counsel for the challenger (SIMCA) argued quite persuasively that the appointment and qualification of Board members did not conform to constitutional principles laid down by the Supreme Court recently in relation to the National Company Law Tribunal (NCLT). Mr. Padmanabhan rightly noted that the amendments were a missed opportunity to cure infirmities in the Board. 

Achille Forler, Managing Director of Deep Emotions and a regular commentator at SpicyIP, was confident that the statutory licensing scheme would transform the industry. Mr. Forler opined that the mandatory licensing of music through copyright societies would be advantageous for users and also that societies would be in a better position to distribute royalties for lyricists and composers. However, Mr. Forler emphasized that IPRS in its present state required significant reforms to function effectively. 

The session ended with Dr. Anirban Mazumdar, Assistant Professor at NUJS, rightly highlighting the key administrative, adjudicatory and logistical complexities ahead of us. 

Acknowledgments: 

But for the passion, commitment and support of a number of people, this conference would never have materialized. I thank each of them below: 

i) As with most other IP events at NUJS, the most significant contributor was Sai Vinod, who worked tirelessly to make this happen. He also goaded several of his classmates and friends to work around the clock and pull off this stellar event. Our sincere gratitude to all of them: Vasudha Sharma, Nitika Gupta, Akshay Sharma, Amba Kak, Arun Mal, Pranav Narain, Aman Taneja, Abin Francis, Jaimini Vyas, Sahil Arora, Raveena Paul, Isha Narain, Siddharta Srivastava, Pranjal Singh, Sreyan Chatterjee, Shyam Gopal, Aparajita Lath, Abhinav Shrivastava, Asha Racheal Joy, Ashna Ashesh, Nidhi Rao, Nivedita Saksena, S. Varsha and Indrajeet Sircar. 

ii) The NUJS law review and in particular Smaran Shetty and Nimisha Srinivas for proposing a special issue devoted to the copyright amendments. Their prompting essentially served as the impetus for the conference. 

iii) The Ministry of HRD and in particular the Secretary, Shri Ashok Jha, the Joint Secretary, Ms Veena Ish and the Copyright Registrar, Mr Raghavender, the Registrar of Copyrights for their continuous support to all our IP activities. 

iv) Prof Ishwar Bhat for his enthusiastic encouragement of IP activities at NUJS. 

v) Prof NSG who readily agreed to combine his conference budget with ours in order to pull off this 2 day event with aplomb. 

vi) K&S Partners, a leading IP law firm and specifically Latha Nair and Rajendra Kumar, who immediately agreed to fund our conference in view of the shortfall at the last minute. I cannot thank them enough. 

vii) Sumeet Malik for his generous donation of latest versions of the Copyright Act to all present at the conference and for agreeing to publish a special issue of the NUJS law review (published and printed by EBC) as well as a book analyzing the amendments. 

viii) Arnab Roy for his wonderful magic in setting up a creativity theme based village (with Baul singers, Santhali dancers, weavers, potters and what not) to entertain the conference delegates and speakers). Thanks also to Manab Da for all his organizational work around the IP chair and the conference.

There were many others who contributed to the show,but unfortunately space constraints stand in the way of naming them: we are immensely grateful to each one of them for their time and commitment to the cause. 

NUJS Law Review Special Issue: 

We were fortunate enough to convince a number of our conference speakers to convert their presentations to papers. This special issue has just come back from the printers, thanks to a terrific team of student editors and the efforts of Sumeet Malik and his team at EBC. 

Given that the NUJS law review is an open access publication, all these articles will be available for convenient consumption on your computers soon. Stay tuned.

Read More

Eucador Trademark Registry decision on Gandhi Trademark opposition

Two years ago, we had blogged about the opposition filed by Shri. Lalit Bhasin in his personal capacity before the Eucador Trademark Registry about the registration of the name and image of the Father of the Nation, Mahatma Gandhi as the "ARROZ GANDHI" (Gandhi Rice) trademark. The registration was sought as an international Class 30 mark with respect to "‘aged or old rice, also medium and long grain rice’ that may or may not come from India".  The grounds of Shri. Bhasin's opposition as well as an analysis of the situation under Eucador law can be found here and here.

The Eucador Trademark Registry through its order on June 6, 2013 has accepted the opposition filed by Shri. Bhasin and rejected the registration of the ARROZ GANDHI mark. The Trademark Registry held that Shri. Bhasin had a legitimate interest in opposing the registration as he had the capacity, power and rights that every Indian citizen for defendng his/her national symbols and the characters that form part of the culture and identity of their country. In this case, the name and image of Mahatma Gandhi, the Father of the Nation, is one of the most highly revered  and the highest national symbol of India. The Trademark Registry also stated that it was also an icon of spirituality in India. Therefore, Shri. Bhasin had a legitimate interest as well as the capacity, power and rights to oppose the application for the registration of the "ARROZ GANDHI" mark.

 Additionally, the Trademark Registry considered the fact that the ARROZ GANDHI mark contained the Gandhi drawing with all its graphic elements. This, when comparing the similarities and not the differences, stated  the Trademark Registry, infringes the copyright of the Gandhi drawing.

Therefore, the rights of personality and publicity of a national figure in a foreign country and consequently, the prohibition on deriving financial benefit from such a person's name and likeness has been recognized by Eucador and therein lies the significance of this judgment.

Read More

Computer Confusion Confounded

Computer software patentability continues to confound. So says this caustic certiorari petition filed at the US Supreme Court, passed on by the wonderful Hal Wegner who, in his inimitable style, transmits latest US patent developments to many of us through his email group. 

For those interested, a copy of this petition that takes issue with a rather splintered CAFC decision in CLS vs Alice Corp is available on Managing Intellectual Property, a leading global IP magazine.

So how do we get out of this jurisprudential morass of a mess? In the context of India at least, I've proposed a rather simple reading of the statutory exclusion in this editorial in the Mint. I extract the key portions of the piece below:

"The Indian Patents Act makes it amply clear that computer programs per se are not patentable. Period! 

The term “per se” only means that if the invention involves something more than mere “computer software”, it is patentable. If the addition is merely cosmetic, such as an incorporation of hardware or other apparatus in a manner well known to a person skilled in the art, then it ought not to be granted a patent, since the inventive contribution resides solely in the computer program. We may require more fine-tuning on this, but let’s leave that to the courts rather than relying on the patent manual for conclusively interpreting this section.

Much like India, the UK also excludes software per se from the scope of patentability. And yet, owing to pressures from industry and in a bid to somehow harmonize with the European position, this exclusion has been all but eviscerated through clever legal sophistry. Consider a recent UK Court of Appeals case (Symbian Ltd v. Comptroller General of Patents), which states that if a software program makes some kind of a “technical contribution”, it ought to be patentable. One is hard-pressed to think of any software program that might fail this “technical contribution” test, particularly when a patent application covering such programs, is crafted by a clever patent attorney. 

Indian judges ought to eschew such legal casuistry in favour of a simple straightforward reading of section 3(k), which excludes computer programs per se from patentability."

This view appears to sync with the IPAB's decision in the Rediff case. 

If software requires protection at all, the patent system is far from optimal. It provides 20 years of protection, a time frame completely at odds with the shelf life of most software. And then there's the issue of prior art searching, patent stacking, hold ups, defensive patenting etc. Its high time policy makers began considering a more optimal sui generis style protection for this contentious subject matter that continues to confound at an exponential rate.

ps: For those interested in the latest Indian developments on this front, Aparajitha reflected on stakeholder feedback to the IPO's latest set of draft guidelines on patentability of software inventions. And CH Unni of the Mint did a terrific take on this issue here.

Read More