Perhaps no other population exposes the clinician to more moral and legal dilemmas than clients with an HIV-positive diagnosis. What does the therapist do about the HIV positive patient who is having sex with unnamed partners and refuses to stop? What should be said in end-of-life decisions? What of the adolescent who is HIV positive but whose guardian does not wish the youth to be informed of his status?

The corporate scandals of the past few years have brought renewed attention to the problem of curtailing dishonest and fraudulent business practices, a problem on which strategic, ethical, and law enforcement interests should be aligned. Unfortunately, several features of federal criminal law and federal law enforcement policy have driven a wedge into this alignment, forcing managers to choose between their ethical obligations and their obligation to obey the law or aid law enforcement. In this article, I examine the nature and (...) implications of the growing divergence between managers’ ethical and legal obligations. After describing the traditional approach to business ethics analysis, I identify the features of federal criminal law and law enforcement policy that are responsible for the divergence and show how they are undermining the efficacy of the traditional approach. I illustrate this effect with the issue of workplace confidentiality. I then argue that the traditional approach must be reformed to give explicit recognition to the legal dimension of normative analysis, and demonstrate how such a reformed approach would function by applying it to three illustrative issues—organizational justice, privacy, and ethical auditing—and supplying a case study—KPMG’s allegedly abusive tax shelters. (shrink)

Statutes criminalizing behavior that risks transmission of HIV/AIDS exemplify use of the criminal law against individuals who are victims of infectious disease. These statutes, despite their frequency, are misguided in terms of the goals of the criminal law and the public health aim of reducing overall burdens of disease, for at least three important reasons. First, they identify individual offenders for punishment, a paradigm that is misplaced in the most typical contexts of transmission of infectious disease and even for HIV/AIDS, (...) despite claims of AIDS exceptionalism. Second, although there are examples of individuals who transmit infectious disease in a manner that fits the criminal law paradigm of identification of individual offenders for deterrence or retribution, these examples are limited and can be accommodated by existing criminal laws not devoted specifically to infectious disease. Third, and most importantly, the current criminal laws regarding HIV/AIDS, like many other criminal laws applied to infectious disease transmission, have been misguided in focusing on punishment of the diseased individual as a wrongful transmitter. Instead of individual offenders, activities that enhance the scale of disease transmission—behaviors that might be characterized as ‘transmission facilitation’—are a more appropriate target for the criminal law. Examples are trafficking in human beings (including sex trafficking, organ trafficking, and labor trafficking), suppression of information about the emergence of infection in circumstances in which there is a legally established obligation to disclose, and intentional or reckless activities to discourage disease treatment or prevention. Difficulties remain with justifications for criminalizing even these behaviors, however, most importantly the need for trust in reducing overall burdens of disease, problems in identifying individual responsible offenders, and potential misalignment between static criminal law and the changing nature of infectious disease. (shrink)

In lieu of an abstract, here is a brief excerpt of the content:Criminal Law, Pain Relief, and Physician Aid in DyingFaye Girsh, Ed.D., Executive DirectorMadam:The article by Cantor and Thomas on “Pain Relief, Acceleration of Death, and Criminal Law” (KIEJ, June 1996) was a tortured attempt to develop criteria for the humane and compassionate physician who tries to serve the needs of a patient in unremitting pain. There are three areas that merit comment.The authors dealt with pain medications that might (...) have the undesirable side effect of causing death. They did not mention tolerance, which usually occurs in a patient with chronic pain and which would require exceedingly high doses to be effective. They did not mention barbiturates, which are preferable to opiates in causing death and which are used increasingly by compassionate physicians to answer the pleas of their suffering patients, but for which there is no excuse about alleviating pain. Would the criminal law just call the prescription of a lethal dose of barbiturates a reckless act and require conviction? Fortunately, juries, as the authors point out, do not balance these formulas on the head of a pin. When they see the circumstances under which these doctors do help their patients, they choose to nullify the law and would ignore the suggestions made in this article.The authors refer to the “consent” of the patient. They do not mention that these doctors are operating with more than consent; they are administering these medications because suffering patients are begging them to put them out of their pain and the indignities of the dying process. The article discusses the process as though it were the same as consent to elective surgery. These patients—with AIDS, cancer, and hopeless neurological degeneration—are not simply agreeing to a procedure; they are desperately seeking a way out. If the criminal law were to develop criteria for physician aid in dying, certainly one of them should be the active, witnessed, repeated request of such a patient for a certain, quick, painless, gentle death.The third point is that physicians do not face prosecution when administering no treatment to a patient whose life could be saved with treatment but who chooses not to receive it. This has been upheld by the U.S. Supreme Court; no criteria for suffering, alternatives, terminality, justifiability, or unbearability are required. The doctor can stand by while the patient dies what may be a protracted, difficult death, but it is within the law. What matters in this situation is the decision of the patient to refuse treatment, and that is absolute. How ironic that the patient who cannot refuse treatment must, with his or her doctor, jump through all these hoops to achieve a peaceful death.One worries that the physician who must balance the risk of “risky pain relief” against the accusation of recklessness will err in the direction of allowing [End Page 103] the patient to bear the pain rather than help with a dose of analgesics that might be considered beyond the stipulated “risk.”Why don’t we just be honest about it? Allow dying or hopelessly ill patients to make the decision about what they want by passing a carefully defined law allowing euthanasia rather than balancing the risk and trying to determine the “purpose” of the physician’s ministrations. We protect some patients from themselves while allowing others almost complete autonomy to make the choice of ending their lives. The authors were right in saying that proponents of rational laws consider this sheer hypocrisy.Faye Girsh, Executive DirectorHemlock Society U.S.A. Denver, COFaye Girsh misconceives our article’s objective as an “attempt to develop criteria” for the humane physician. Our goal in writing the paper was to analyze the current criminal law framework in the hope of sharpening debate and engendering normative critiques. We readily acknowledge tensions in the current legal framework and would support changes in that framework.Copyright © 1997 The Johns Hopkins University Press... (shrink)

Asylum legal aid lawyers are under continuous public scrutiny. On the one hand, these lawyers are portrayed as being solely motivated by profit. On the other hand, they are depicted as leftist activists frustrating the legal system. When assisting their asylum seeking clients under the state's legal aid scheme, lawyers need to balance the client's interest, the public interest in the administration of justice and their own interest in profit or survival. The current book examines this balancing (...) act and explores the role of the institutional context. It does so by studying the decision making of asylum legal aid lawyers in the Netherlands and England in respect of two ethical issues: 'time vs. money' and 'hopeless cases'. This empirical research into lawyers' professional ethics in practice will appeal to scholars engaged in lawyers' ethics, policy makers and those involved in the regulation of the legal profession. Dissertation. [Subject: Politics, Human Rights Law, International Law]. (shrink)

In this paper, I will argue that efforts to legalize aid-in-dying or physician-assisted suicide are attempts to rebrand this sort of death as a good choice. It is common to justify physician-assisted suicide through arguments for a) relieving suffering or b) allowing individual autonomy, but I will show that the problem with these justifications is that once this type of death is judged as acceptable, it is difficult to justify limiting it to a narrow group such as the mentally competent, (...) communicatively able, terminally ill adults designated by these legalization bills. Ultimately, we must either label many more deaths as good deaths, destigmatizing suicide, or we must reject the notion that death at the time we choose is acceptable. I will argue for the latter. (shrink)

In this paper I outline various different objects of investigation that may be picked out by word “law” (or its cognates). All of these objects must be investigated in an integrated way before one can provide a complete philosophical explanation of the nature of law. I begin with the distinction between laws (artefacts) and law (the genre to which the artefacts belong). This leads me to the distinction between the law (of a particular legal system) and law (the genre (...) of artefacts). Then I discuss the contrast between law (the genre of artefacts) and law (the practice). Finally I comment on legality as the name of an ideal for laws and legal systems to live up to. I commend H. L. A. Hart's explanation of the nature of law for investigating these various objects in an integraed way, while nevertheless respecting the distinctions among them. I also criticise some of R. M. Dworkin's work for failing to respect the same distinctions. (shrink)

This article provides a critical analysis of ‘the legal’ in the legal determinants of health, with reference to the Lancet–O’Neill report on that topic. The analysis shows how law is framed as a fluid and porous concept, with legal measures and instruments being conceived as sociopolitical phenomena. I argue that the way that laws are grounded practically as part of a broader concept of politics and evaluated normatively for their instrumental value has important implications for the study (...) of law itself. This, in turn, has implications for how we approach the transdisciplinary ambitions that form a key part of the report’s recommendations to enhance law’s capacity to promote better, more equitable population health at local, national, international and global levels. (shrink)

In most Western European countries and North America, strategies to contain the spread of AIDS have emphasized civil liberties. This may be due more to the epidemiology of the disease than to moral progress.

Major reforms via the Legal Aid, Sentencing and Punishment of Offenders (LASPO) Act 2012 and subsequent reforms have reduced the legal aid budget and the scope of eligibility in criminal as well as civil cases. According to Mansfield et al., the principles of justice that embody the legal aid provision has been neglected by governments for over a decade and as such; created a gap that emasculates the most vulnerable in society, such as recipients of legal (...) aid. This study employs an interview-based approach to investigate alternative perspectives in terms of the cuts and widespread impact on service providers in England and Wales, such as barristers, and solicitors. Detailed qualitative data were collected to provide insights into the diminishing legal aid scheme through the lived experiences of both civil and criminal legal aid providers. The study examines the concerns of service providers regarding their future as public defenders and the future of the judicial system post-LASPO 2012, focusing on safeguarding the rights of individuals facing litigation and ensuring that newly qualified lawyers are not deterred from public defence roles due to the long-term effects of ongoing legal aid cuts. (shrink)

Linking theses of Plato, Wittgenstein, and Weber, section I argues that identification of central cases and settling of focal meanings depend upon the theorist's purpose and, in the case of theory about human affairs—theory adequately attentive to the four irreducible orders in which human persons live and act—upon the purposes for which we intelligibly and intelligently act. Among these purposes, primacy is to be accorded to purposes which are, as best the theorist can judge, reasonable and fit to be adopted (...) by anyone, the theorist included. Section II defends the reasonableness of practical and moral judgments, against Michael Perry's ultimately nihilist claims that egoism's challenge to moral normativity has gone unanswered and that “reason for A” does not entail “reason for” anyone else. Section III takes up Steven Smith's suggestion that such subjectivism is encouraged by the talk in Natural Law and Natural Rights of “pursuing goods,” talk which is individualistic and neglectful of persons, inimical to an understanding of friendship, and impotent in the face of egoism. Here as elsewhere the key is to grasp that understanding any basic or intrinsic human good is to understand it as good for anyone like me and thus—since as I instantiate and embody a universal, viz. human being—as a good common to anyone and everyone. Section IV argues that common good gives reason for exercise and acceptance of authority, and for allegiance, even in time of breakdown. Section V argues that natural law theory is no more dependent on affirming God's existence than any other theory is, in any of the four orders of theory, but equally that is not safe for atheists. For, like any other sound theory, it suggests and is consistent with questions and answers about its grounds, in this case about the source of its normativity and of the human nature that its normative universals presuppose and affirm; and the answers are those argued for, too abstemiously, in the last chapter of NLNR and, more adequately, in the equivalent chapter of Aquinas. (shrink)

Participants in AIDS research may justify noncompliance with protocols by a “coercion defense.” While this defense may not be philosophically successful, a prudent social policy can enhance compliance by encouraging community participation and providing greater access to non‐validated therapies.

This volume reprints in a scholar's edition the first English-language texts on bioethics, John Gregory's (1724-1773) Observations on the Duties and Offices of a Physician and on the Method of Prosecuting Enquiries in Philosophy (London, 1770) and Lectures on the Duties and Qualifications of a Physician (London, 1772). Five previously unpublished manuscripts of Gregory's lectures are also included. An introduction places Gregory's medical ethics and philosophy of medicine in their eighteenth-century contexts of Scottish Enlightenment history and culture, Baconian science (...) and philosophy of medicine, medical practice, the feminine and feminist philosophy of the Bluestocking Circle, and moral sense philosophy, particularly David Hume's concept of sympathy, and provides a bibliography of primary and secondary sources as an aid to teaching and future scholarship. The book's index provides access to Gregory's texts, by using both historical terms and current terminology of bioethics. A volume in the subseries Classics of Medical Ethics. (shrink)

Stigma marks both surrogacy and abortion. Legal change lessens stigma but may not remove it altogether. Post-legalization regulation may reinstall stigma by surrounding a legalized practice with barriers that make exercise of that right more difficult. As a result, law may reenact stigma even as it purports to take it away.

John Coggon argues that the important question for analysts in the fields of public health law and ethics is 'what makes health public?' He offers a conceptual and analytic scrutiny of the salient issues raised by this question, outlines the concepts entailed in, or denoted by, the term 'public health' and argues why and how normative analyses in public health are inquiries in political theory. The arguments expose and explain the political claims inherent in key works in public health (...) ethics. Coggon then develops and defends a particular understanding of political liberalism, describing its implications for critical study of public health policies and practices. Covering important works from legal, moral, and political theory, public health, public health law and ethics, and bioethics, this is a foundational text for scholars, practitioners and policy bodies interested in freedoms, rights and responsibilities relating to health. (shrink)

abstract Most moral philosophers accept that we have obligations to provide at least some aid and assistance to distant strangers in dire need. Philosophers who extend rights and obligations to nonhuman animals, however, have been less than explicit about whether we have any positive duties to free‐roaming or ‘wild’ animals. I argue our obligations to free‐roaming nonhuman animals in dire need are essentially no different to those we have to severely cognitively impaired distant strangers. I address three objections to the (...) view that we have positive duties to free‐roaming nonhuman animals, and respond to the predation objection to animal rights. (shrink)

Of John Stuart Mill's major commitments, none was more passionately pursued than equality; it marks his writings throughout his life, and serves as a uniting force in his comments on many subjects, especially lawand education. This volume presents, in scholarly form for the first time, writings that reveal his goals and methods in diverse circumstances. They begin with his precocious essay on the law of libel and include his influential Subjection of Women, his major essays on slavery, his Inaugural (...) Address at St Andrews, and his contributionsin the struggle to being Governor Eyre of Jamaica to trial. A variety of shorter essays is also presented: such personal documents as his declaration just before amrriage renouncing all legal rights over his wife, and his and Harriett Taylor's companion pieces on marriage, newly edited from manuscript. Also included is Mill's evidence before parliamentary committees on education and the Contagious Diseases Acts. The appendices include ancillary texts and a bibliographic index listing all works and persons mentioned or quoted in the essays. An analytic index gives easy access to the full range of Mill's ideas in these important essays. (shrink)

In the discussion of the responsibilities of society to the HIV infected and uninfected, a serious question seems to have been left out of the picture: To what extent are people who are not infected, have no special relationship to the infected and have no professional responsibilities for the care of AIDS patients under an obligation to come to the aid of people with the HIV? In this paper, I shall examine our responsibilities, as members of society, for the welfare (...) of others to whom we may or may not have a special relationship. I shall argue that those responsibilities flow from the conditions that structure our transactions with others; conditions that make such transactions possible. (shrink)

The aim of this paper is twofold: first, it seeks to provide a better understanding of lawyers’ ethics in practice in the field of publicly funded asylum law. It does so by examining Dutch asylum legal aid lawyers’ moral reasoning in respect of the ethically challenging issue of ‘the hopeless case’, employing a version of Christine Parker’s four approaches to moral reasoning in legal practice: adversarial advocacy, responsible lawyering, moral activism and relational lawyering. Second, it aims to demonstrate (...) the applicability of Parker’s taxonomy, developed in a common law country (Australia), to a civil law country (The Netherlands). This paper shows, in line with what Parker argued, that lawyers may apply a combination of approaches – different ethical considerations carry different in weight in different circumstances. It provides illustrations of situations in which approaches coexist and compete and the circumstances in which one prevails over the other in the area under review. (shrink)

Is the science of moral cognition usefully modelled on aspects of Universal Grammar? Are human beings born with an innate 'moral grammar' that causes them to analyse human action in terms of its moral structure, with just as little awareness as they analyse human speech in terms of its grammatical structure? Questions like these have been at the forefront of moral psychology ever since John Mikhail revived them in his influential work on the linguistic analogy and its implications for (...) jurisprudence and moral theory. In this seminal book, Mikhail offers a careful and sustained analysis of the moral grammar hypothesis, showing how some of John Rawls' original ideas about the linguistic analogy, together with famous thought experiments like the trolley problem, can be used to improve our understanding of moral and legal judgement. (shrink)

The previous decade has seen renewed critical interest in the multiple realization argument. These criticisms constitute a "second wave" of challenges to this central argument in late-20th century philosophy of mind. Unlike the first wave, which challenged the premise that multiple realization is inconsistent with reduction or type identity, this second wave challenges the truth of the multiple realization premise itself. Since psychoneural reductionism was prominent among the explicit targets of the multiple realization argument, one might think that this second (...) wave of challenges provides important aid and comfort to reductionists. In this paper, however, I provide reasons for thinking it does not. This is not to the detriment of psychoneural reductionism because, as I also argue here, and unrecognized by the current non-reductive orthodoxy in philosophy of mind, one key argument among the first wave of criticisms of the multiple realization argument has never been adequately rejoined. (shrink)

ABSTRACT:Legal scholars and business ethicists are interested in many of the same core issues regarding human and firm behavior. The vast amount of legal research being generated by nearly 10,000 law school and business law scholars will inevitably influence business ethics research. This paper describes some of the recent trends in legal scholarship and explores its implications for three significant aspects of business ethics research—methodology, theory, and policy.

Legal codes, such as the Uniform Commercial Code (UCC) examined in this article, are good points of entry for AI and ontology work because of their more straightforward adaptability to relationship linking and rules-based encoding. However, approaches relying on encoding solely on formal code structure are incomplete, missing the rich experience of practitioner expertise that identifies key relationships and decision criteria often supplied by experienced practitioners and process experts from various disciplines (e.g., sociology, political economics, logistics, operations research). This (...) research focuses on the UCC because it transcends the limitations of a formal code, functioning essentially as a composite. AI work can benefit from real-world codes like the UCC, which are essentially formal codes enlightened from a more realistic experience-base from centuries of development in international commercial transactions settings. This paper then describes our initial work in converting an expert system on the U.S. law governing the sale of goods from Article II of the Uniform Commercial Code (UCC), into a knowledge-based system using the Web Ontology Language OWL. (shrink)

This ambitious book examines the notion of legal transparency from a unique cultural and historical perspective. Drawing from their combined academic and practical experience with both Chinese and Western legal traditions, authors John Head and Xing Lijuan explore how an intense debate — pitting legal transparency against legal opaqueness — unfolded in dynastic Chinese law, which began in the dark mists of history and ended formally just over a hundred years ago. They rely on a (...) wide range of both Western and Chinese sources to explain how that great debate was resolved in the early Han Dynasty (around the third century BCE) in a way that molded Chinese law into a sophisticated legal system that for roughly two millennia balanced definitiveness with vagueness, predictability with flexibility, and egalitarianism with privilege — and that reflected cultural values still resonating in China today. Legal Transparency in Dynastic China presents a clear narrative that assumes no prior expertise in Chinese law or history, and it caters to readers interested in issues of good governance, comparative studies, China, history, and law. The book begins by defining “legal transparency” and explaining where it fits into the larger context of the transparency-in-government movement that has gained such momentum in recent years, especially at the urging of Western powers. Then the book explains the fundamentally different values espoused by early Confucianists, for whom society is best governed not through written law but through the exemplary behavior of a highly educated, virtuous, and enlightened elite. After tracing the political and ideological challenges that the Confucianists faced from the Legalists, Head and Xing examine the compromise that resulted in the so-called “Confucianization of the Law” around 200 BCE. They then show how that alloy of competing ideologies characterized Chinese dynastic law for many centuries, resulting in what some would consider the most enduring and effective legal system in human history. (shrink)

This paper considers the hotly debated issue of whether one should grant moral and legal personhood to intelligent robots once they have achieved a certain standard of sophistication based on such criteria as rationality, autonomy, and social relations. The starting point for the analysis is the European Parliament’s resolution on Civil Law Rules on Robotics and its recommendation that robots be granted legal status and electronic personhood. The resolution is discussed against the background of the so-called Robotics Open (...) Letter, which is critical of the Civil Law Rules on Robotics. The paper reviews issues related to the moral and legal status of intelligent robots and the notion of legal personhood, including an analysis of the relation between moral and legal personhood in general and with respect to robots in particular. It examines two analogies, to corporations and animals, that have been proposed to elucidate the moral and legal status of robots. The paper concludes that one should not ascribe moral and legal personhood to currently existing robots, given their technological limitations, but that one should do so once they have achieved a certain level at which they would become comparable to human beings. (shrink)

At the Donald Berman Laboratory for Information Technology and Law, La TrobeUniversity Australia, we have been building legal decision support systems for a dozenyears. Whilst most of our energy has been devoted to conducting research in ArtificialIntelligence and Law, over the past few years we have increasingly focused uponbuilding legal decision support systems that have a commercial focus.In this paper we discuss the evolution of our systems. We begin with a discussion ofrule-based systems and discuss the transition to (...) hybrid rule-based/case-based systems.We next discuss how we have used machine learning in building legal decision supportsystems. Our focus on using machine learning led us to investigate the domains ofexplanation and argumentation. We conclude by discussing our current work onbuilding negotiation support systems and tools for constructing web-based legaldecision support systems. (shrink)

ABSTRACT Principles of justice and equality demand that HIV seropositive individuals and those with AIDS should not be discriminated against in any area of social provision. If social policy on AIDS is constructed in terms of reciprocal obligations, that is if obligations to the HIV seropositive individual and obligations of the HIV seropositive individual are given equal weight, the civil rights of HIV seropositive individuals may be secured and this may create a climate in which HIV seropositive individuals will more (...) readily notify partners, and others at risk of infection, of their HIV status. It is conceivable that such a climate could facilitate greater control of the spread of HIV/aids. (shrink)

As the expansion of the Internet and the digital formatting of all kinds of creative works move us further into the information age, intellectual property issues have become paramount. Computer programs costing thousands of research dollars are now copied in an instant. People who would recoil at the thought of stealing cars, computers, or VCRs regularly steal software or copy their favorite music from a friend's CD. Since the Web has no national boundaries, these issues are international concerns. The contributors-philosophers, (...) legal theorists, and business scholars, among others-address questions such as: Can abstract ideas be owned? How does the violation of intellectual property rights compare to the violation of physical property rights? Can computer software and other digital information be protected? And how should legal systems accommodate the ownership of intellectual property in an information age? Intellectual Property is a lively examination of these and other issues, and an invaluable resource for librarians, lawyers, businesspeople, and scholars. (shrink)

Are all of the commonly accepted aims of the use of law justifiable? Which kinds of behavior are justifiably prohibited, which kinds justifiably required? What uses of law are not defensible? How can the legitimacy or the ille gitimacy of various uses of law be explained or accounted for? These are questions the answering of which involves one in many issues of moral principle, for the answers require that one adopt positions - even if only implicitly - on further questions (...) of what kinds of actions or policies are morally or ethically acceptable. The present work, aimed at questions of these kinds, is thus a study in the ethical evaluation of major uses of legal coercion. It is an attempt to provide a framework within which many questions about the proper uses of law may be fruitfully discussed. The framework, if successful, can be used by anyone asking questions about the defensibility of particular or general uses of law, whether from the perspective of someone considering whether to bring about some new legal provision, from the perspective of someone concerned to evaluate an eXisting provision, or from that of someone concerned more abstractly with questions about the appropriate substance of an ideal legal system. In addressing these and associated issues, I shall be exploring the extent to which an ethics based on respect for persons and their autonomy can handle satisfactorily the problems arising here. (shrink)

There is a fine balance between civil liberties and protection of the public’s health.Legislators, especially those in the western United States, are concerned about selling the Model State Act because of the loss of civil liberties. State constitutions give governors broad powers, such as declaring martial law and giving public health leaders the authority to act. State laws should consider issues such as property rights; taking of businesses and supplies; quarantine and isolation; due process; coordination among states, counties and cities; (...) communication systems; conscription of doctors and nurses; and compensation. When two mock emergency response drills were held in New Mexico, concerns arose regarding opening records associated with dams, national laboratories, waste repositories, and three air force bases. (shrink)

Leading legal scholar John Witte, Jr. explores the role religion played in the development of rights in the Western legal tradition and traces the complex interplay between human rights and religious freedom norms in modern domestic and international law. He examines how US courts are moving towards greater religious freedom, while recent decisions of the pan-European courts in Strasbourg and Luxembourg have harmed new religious minorities and threatened old religious traditions in Europe. Witte argues that the robust (...) promotion and protection of religious freedom is the best way to protect many other fundamental rights today, even though religious freedom and other fundamental rights sometimes clash and need judicious balancing. He also responds to various modern critics who see human rights as a betrayal of Christianity and religious freedom as a betrayal of human rights. (shrink)