Tag Archives: independent contractors

The Independent Contractor vs. Employee Issue Gets Kinky

Although some think whether an individual is an independent contractor or an employee is a new legal question brought about by the gig economy digital platforms like Uber, the truth of the matter is the issue has been around for decades. As I say in my new book, Thriving in the Gig Economy  due out in May , when the news of the Uber lawsuit first broke, my former CFO called me from Toronto just to reminisce about old times in the compliance wars.  It was remarkable to us, that so many people and the media for sure seemed to view the Uber situation as a new development.

Of course the employment lawyers in the crowd also appreciate how pervasive this problem has been.  In its recent blog post, Littler chose to honor April Fool's Day by recounting some of the more bizarre employment cases that occurred this year.  http://www.jdsupra.com/legalnews/these-foolish-things-the-oddest-56353/,  My favorite was the case of a strip club in Ohio, where an exotic dancer sued the bar on the grounds that she should have been classified as an employee rather than as an independent contractor.

Credit J.D.S. from Shutterstock.com

There were several considerations arguing for independent contractor status.  Dancers were not paid by The Brass Pole, but rather by its patrons for individuals dances.  Dancers also made their own schedules and provided their own materials/costumes.  The bar offered no training; only experienced dancers were engaged.  Whether they were able to work for other establishments was a bit murky, but there was no explicit prohibition.  The Brass Pole did have a number of rules  the dancers needed to abide by including no chewing gum on stage, never refusing a drink and no boyfriends/spouses in the bar during the performances. http://www.lazzarolawfirm.com/Lester-opinion.pdf These rules were not meant to impose direction or control, but rather to ensure the efficient operation of the establishment.

The definition of an independent contractor, or for that matter, an employee, is never simple.  The Sixth Circuit court in Ohio used what they refer to as an "Economic Realities" test.  The six factor test, as outlined in the legal opinion in the case is based on:  "1) the permanency of the relationship between the parties; 2) the degree of skill required for the rendering of the services; 3) the worker’s investment in equipment or materials for the task; 4) the worker’s opportunity for profit or loss, depending upon his skill; ... 5) the degree of the alleged employer's right to control the manner in which the work is performed[; and] ... [6)] whether the service rendered is an integral part of the alleged employer’s business."

The first five items seemed to indicate that the dancers could be valid independent contractors. The dancers were regular, experienced and supplied their own costumes.  They determined when and how long they performed, which determined their income, and little to no control was exerted over them.  The problem, however, was whether the dancers were an integral part of the business.  Apparently the proprietor did attempt to claim that they were a bar which happened to have exotic dancers, rather than an exotic dancing locale that served drinks.  The judge didn't buy that argument and ordered a summary judgement for the plaintiffs, saying, "“[n]o reasonable juror could conclude that customers primarily came to the club for its other offerings, which included beer, liquor, and frozen burgers from Sam’s Club.”http://www.jdsupra.com/legalnews/these-foolish-things-the-oddest-56353/

At least the Brass Pole case was resolved.  The larger Uber lawsuit still has yet to be fully argued.  I for one am hopeful that it will be put to the test, because it could be this high profile case which finally puts some clarity on this very ambiguous area of the law.

The Gig Economy and the Office

Harvard Business Review published an interesting article by Professor Diane Mulcahey last week called, "Will the Gig Economy Make the Office Obsolete?" https://hbr.org/2017/03/will-the-gig-economy-make-the-office-obsolete .  The point Mulcahey makes is that when companies use independent workers  for key projects, these gig workers  are being  judged by their results; their presence or absence in a certain physical location is not germane to their performance.

What is interesting to note is the historical pattern of work locations.  Prior to the industrial revolution, work of most types  tended to be done at home.  Fishermen and soldiers are key exceptions here.  The work was not separate from life, but rather an embedded part of it.  As Alice Kessler Harris, a History Professor at Columbia put it, " the workplace was an extension of the household." http://gender.stanford.edu/news/2014/historical-view-american-workplace Professions which did have offices, i.e. doctors, were typically co-located at home. Although certain work was gender related, women tended the farm just as much as men helped with the weaving.  It was all just a part of life.

Marion McGovern

A portion of Diego Rivera's murals depicting American industrialization at the Detroit Institute of Art

But life changed with the advent of industrialization,  because the location of work shifted, with many roles requiring an onsite presences, whether at a factory, a warehouse or an office.  Along with that shift, came set hours and shifts which delineated work time. These separate  workplaces were often in conflict with  household schedules and further accelerated the segregation of work from home life.  As more women entered the work force the conflicting demands of work and household became all more acute.

However fast forward to the end of the 20th century. As the knowledge economy grew in importance, supported by technological enhancements, the time and place where work could be done became less important. With increased connectivity and advances in software and security, remote work has become commonplace. Coupling that with hard working employees who want more work life balance, many companies have made moves to reduce their physical office footprint.  Indeed, software company, Citrix, has predicted that by 2020, 70% of people would work away from the office as much as they worked at their office.

Add to this the increasing adoption as a strategic business practice of using independent consultants, high-end gig economy workers, for projects throughout the organization and the question of worker location becomes even more pertinent.  Most of these gig economy workers rate flexibility and control over their lives as key reasons for pursuing the independent career path.  In researching my upcoming book, Thriving in the Gig Economy, I read half a dozen different studies about the reasons independent consultants choose this path and flexibility is chief among them all. Whether they work at a client office, a co-working space or a home office, these professionals want be in charge,  They want the balance in life that comes from control.  They want their work to be an extension of their household just like it was 200 years ago.  As the saying goes, what comes around, goes around.

 

Advice for the Gig Economy on Retirement

Mark Miller, a journalist who writes about financial matters surrounding aging and retirement wrote a nice piece today  called "Retirement in the Gig Economy".http://www.wealthmanagement.com/retirement-planning/retirement-gig-economy  He discussed how Uber has a partnership with Betterment,https://www.betterment.com/why-betterment/ a fintech company that optimizes returns for investors through technology-enabled smart rebalancing and global diversification.  For Betterment it is a lead generation play, for Uber it is a way to deflect attention from the no benefits independent contractor issue, by providing some elective options.

He also mentions Honest Dollar, another fintech player that developed specialized retirement products for clients. One of those enabled  clients who engaged independent contractors to offer those contractors access to retirement products (IRAs, SEP IRAs etc.)  directly through its platform by a deduction from their fee payments. Goldman Sachs bought Honest Dollar in March, because they are "revolutionizing the retirement industry" by appealing to small businesses and gig workers.

Another firm in the space is Ubiquity,  a San Francisco based “fin tech” firm that is focused on providing retirement vehicles for small business and sole proprietorships, or as their website says, the “other 40 million”https://www.myubiquity.com/educate/. The company has their own version of an individual 401K, which they call a “single (k)”.  It has a flat fee and can be set up online. A single(k) enables an independent to make a larger contribution to retirement then would be allowed in a typical IRA or Roth IRA.

These firms are important for gig workers to know about, because they are providing solutions in today's environment.  What is more exciting are the opportunities that may come tomorrow. With very little fanfare, the Senate Finance Committee unanimously recommended Senate Bill 3471, The Retirement Enhancement and Savings Act. (RESA) The bill would enable a pool of employers to contribute to retirement programs.  No action was taken by the 2016 Congress, but given the support for the measure, there is an expectation it will be taken up in 2017.

That would bode well for other efforts that are underway for pooled employer programs.  New legislation  is expected to be introduced in New York state in this year. Handy, a digital platform for handymen and household workers, along with Tech NYC, a New York state trade association, is introducing a portable benefits bill Gig Economy workers. http://www.villagevoice.com/news/uber-but-for-benefits-ny-tech-companies-propose-a-gig-economy-solution-9517993 The proposed voluntary program envisions a 2.5% fee paid by participating companies into a benefits fund. Workers could access the fund to purchase benefits, whether health insurance or pensions.  The catch, according to some, is that the bill defines the workers as independent contractors, effectively cutting these gig workers off from employment benefits like overtime.  The bill’s proponents point to the need for incremental progress toward the goal of improving the social safety net.

Little steps can help.  As the saying goes, a journey of 1000 steps begins with one.

A New Operating System for the Gig Economy

An article in Forbes today suggested the title of this post, that companies need a new operating system for the Gig Economy.  The article entitled, "How Businesses must Adapt to Accommodate the Growing Freelance Workforce",  http://www.forbes.com/sites/under30network/2016/12/05/how-businesses-must-adapt-to-accommodate-the-growing-freelance-workforce/?utm_source=TWITTER#17edc57f42f5 was written by Peter Johnston, the CEO  and Founder of Lystable,  one of the companies that now comprise what I like to call  the Gig Economy EcoSystem.

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These firms and their founders, like Peter, have recognized that the independent work trend in the United States is not going away.  Between workers wanting more flexibility, technology reducing the market frictions of just in time expertise and a highly mobile workforce the usage of independent workers will only increase.  Given this expected growth, there is money to be made in creating enabling mechanisms to make it easy more more companies to jump on the band wagon.

Lystable, https://www.lystable.com  along with others like ShortList https://shortlist.co/about/ promise to eliminate the logistical problems that can make engaging consultants a human supply chain nightmare.  For unlike employment and its sourcing partner, recruiting wherein a centralized corporate solution is offered, securing independent consulting services often tends to be a one-off endeavor in most companies.  Procurement ( and not recruiting typically) may imposes guidelines and rules that may be followed or not; many savvy managers have figured out over the years how to get around those pesky rules in order for the department to bring in their talent of choice. These external workforce platforms capture contract details, engagement letters, Statements of Work (SOWs)and payment details. Many handle on-boarding and post project reviews. Perhaps most importantly though, they provide an overall dashboard for how external expertise is being deployed in the enterprise.

Johnston points out thee business benefits which are real.  Speaking as someone who dealt with the initial forays of procurement in the vendor management world, creating an appropriate environment for independent talent us well overdue. Changing that operating system is key, but so too is changing the mindset.  Efficiently and effectively using independent talent is a competitive advantage.  And now, as deployment methods are becoming more enabled and thereby  making the workers more mobile, those workers have more options.  They can go to their client of choice.  So just as employers want to be the "Employer of Choice", they also need to give some thought to being the "Client of Choice. " For many firms, that will be quite an operating system change.

Work, Jobs and the Gig Economy

As I work on my book, Thriving in the Gig Economy , I have had the opportunity to talk to many experts, from CEOs to futurists about the future of work.  I was thrilled last week when one of them shared my pet peeve, one that is all the more acute in an election year --  the fact that so many Americans equate work and jobs.  Work is so much more than a job, or more precisely a "regular full-time job".  work encompasses all sorts of pursuits, from part-time work, to self-employment to gigs to volunteering.

If you look at the definition, http://www.merriam-webster.com/dictionary/work, it is "an activity in which one exerts strength or faculties to do or perform something:"  In fact in all 11 definitions cited, the word "employment" never appears.

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None the less, we constantly hear our politicians talking about how important it is to create jobs.Yes that is important, but as the world is changing with technology and new work models.  What is unfortunate about this focus on jobs and not work is the attachment of social infrastructure to employment. Employer provided  health and retirement benefits are great for current employees, but leave all of the other workers, from part-timers to gig workers potentially at a disadvantage.  Moreover, the employment oriented fringes may constrain an individual's entrepreneurial path; it will be tougher to become an independent consultant if the Affordable Care Act is repealed.

That said, the government has a vested interest in bolstering traditional  employment structures, and that interest is not in benefits but in taxes.  It is a lot easier to collect employment taxes from companies than from a myriad of individuals. As such, the argument that we need to revise our vision of employment, can fall on deaf ears.

Charles Handy, an Irish economist and expert in the world of work, said in his new book, The Second Curve, writes, “The strange truth is, if you have a so-called proper full-time job today, you are in the minority.  The world has changed and few have noticed.”  We need to take notice and enable opportunity accordingly.

Yet Another Research Report on the Gig Economy

Albert Einstein once said, "If we knew what we were doing we wouldn't call it research." How fitting in this case.  Yet another report came out this week estimating the size of the gig economy. Pymnts.com released their research http://www.pymnts.com/gig-economy/2016/gig-economy-growing/ done in conjunction with Hyperwallet, which attempts to define the the size of the independent work marketplace.

This is on the heels  of the recent McKinsey Global Institute  (MGI) study, "Independent Work: Choice Necessity and the Gig Economy."http://www.mckinsey.com/global-themes/employment-and-growth/independent-work-choice-necessity-and-the-gig-economy.  In that comprehensive report, the authors had a significant disclaimer about the problem of data collection in this area. The annual contingent labor study done by the Department of Labor was discontinued in 2005, so thee are no government statistics about participation. Various entities,including companies in the space, academics and think tanks, have launched efforts  to explore the subject.  So there is no dearth of data about the gig economy, the problem is each study has been  done with a slightly different approach. In fact the MGI study even included a great graph comparing the size estimates emerging from these disparate research projects. It tried to isolate the specific industry segment which was being addressed by the researchers.  For example, it  listed 5 different studies, including their own,  that sized the independent workforce in the US as a percentage of the working population.  The results were broad ranging,  from as little as 16% to as high as 27%

So given that the numbers don't quite jive, who is right? Since I am working on my new book, Thriving in the Gig Economy, I have been wrestling with this issue quite a bit.  I have decided that  potentially they are all right; you just need to be cognizant of how they have framed the question. MBO Partners, for example , provides the best ( and only) historical perspective, having issued its report on the State of Independence in America  for each of the last 6 years. https://www.mbopartners.com/state-of-independence/mbo-partners-state-of-independence-in-america-2016 They focus on independent consultants in the professional services space and estimate the market size at just south of 40 million participants. They define 3 primary categories of independents: full time, part time and occasional.  MGI, on the other hand, has a higher size estimate based on four categories of workers, including two groups, who are working in this way out of financial pressure rather than personal choice. They include some categories of workers, like doctors and therapists, who may or may not be captured in the MBO Partners data.

One area that has very limited data available is the use of digital talent platforms by gig workers.  The new PYMNTS report is targeted specifically at this.  In fact, they specifically don't include the group of "freelancers" who may get their work from intermediaries, like M Squared Consulting http://www.msquared.com or Business Talent Group. https://businesstalentgroup.com/business-strategy-consulting-google/?gclid=CLLwv-vy-c8CFUKTfgod6t8HGA.  Given the exclusion of this key population, the graph which showed the type of professional services procured through the digital talent marketplaces was telling.  The professional service in the highest demand was photography. The senior level independent consultants do not appear to be represented.  I have yet to comprehensively go through this report, so I can't speak to conclusions the authors may have reached.  Perhaps there will be more to come on this in the future.  At the very least, there may be more to come in my book.

 

 

The Gig Economy – A Class Act…or not…

gig economy

Since I am working on my book, Thriving in the Gig Economy, I have been paying particular attention to the various Uber  employment lawsuits.  Even though  I am focusing on the high end of the gig economy where independent consultants sell their services and intellectual capital, the commodity end of Uber drivers can't be ignored, since it seems to garner all of the headlines.

This week a rather important ruling occurred that seemed to receive very little attention, which is surprising, since it suggests Uber's independent contractor lawsuits may lose class action status.

Last week,  a Ninth Circuit panel effectively reversed a decision from 2015 . A year ago, a judge had said that that the arbitration agreement in Uber's contract with its drivers was unenforceable.  The contract was designed to say if you have any dispute with us, Uber, you need to resolve it through arbitration rather than through the courts.  In this particular case, three drivers had sued Uber for saying they violated the Fair Credit Reporting Act (FCRA) when the company ran background checks on their driving records.  The FCRA, as all recruiting managers know, is the law that requires candidates for employment authorize any  background checks.   The decision said that Uber's arbitration clauses were fair, valid and enforceable.

By asserting that the arbitration clauses are valid in this case will have implications in the attempts of some drivers to create a class action.  As an outside observer, I applaud this.  Since I have the gig economy on the brain  and am an avid Uber customer, I have taken to quizzing all of my drivers about there thoughts on the lawsuit.  I wish I had thought to jot down the results, since my sample size is now in statistically valid territory.  That said, my recollections of the results are these:

  • Only one of about 25 wanted to be an employee
  • 2-3 did not know about the lawsuit at all
  • The majority did it part time to fit their schedule , as one said to me last Sunday, "why watch a football game when I can earn some extra cash for 2 hours?"
  • Most had other jobs including teacher, masseuss, contractors, programmers, hairdressers etc.
  • A large minority also worked for the other driving services

My very unscientific conclusion then is that it is a very diverse driver pool.  A key attribute of a class action lawsuit is that the participants in the class are largely similar.  I don't know that this is the case.  It is time for the independent contractor laws to be brought into the current century in a time when the gig economy of indepndent workers of all sorts is growing.  Potentially these lawsuits facing Uber will help make that happen. .

The Gig Economy Eco System

Employment in the Gig Economy

As the politicians debate the implications of the gig economy, they typically just talk about jobs.  They lament that so many gig workers don't have benefits and are being taken advantage of by those running the powerful digital platforms. As I have said here often, they seldom mention the professional gig economy workers, 91% of whom have self selected this career path.  But perhaps the bigger oversight is that they fail to recognize the jobs that are being created serving the new needs of the gig economy and its workers.

Take a recent press release from ShiftPixy. http://www.shiftpixy.com This app is a way for

From the ShiftPIxy website

From the ShiftPixy website

companies in need of shift workers to recruit contingent gig workers to fill their scheduling gaps. This means that a small business can use this app, rather than trying their luck at all the digital sites. what Kayak did for travel, it is doing for low-end contingent labor.

Employment Laws and the Gig Economy

Moreover, the Shift Pixy guys have paid attention to the employment law issues that have bedeviled some of the large talent platforms like Uber and Handy.  ShiftPixy employs the gig workers on behalf of its clients.  By employing them, it enables them to accrue enough part-time hours from various clients to qualify for benefits typically only accorded to full-time employees.

In case you are wondering, I don't have an investment in Shiftpixy so this is not a commercial.  It is recognition that someone has solved not just one but two key problem with the gig economy. First they just bit the bullet and made the employment call. Since the laws are murky ( another favorite subject of mine) they built an employment infrastructure that is easily accessible via an app that takes the employment risk away from their clients.  "You want a shift worker to bag groceries, great, they would have to be an employee.  Since you don't want them to be your employee, we will handle that. " Most of the digital platforms put the onus on the buyer to figure out the employment law issues, so ShftPixy took that off the table, making it safe for any size company to engage a gig worker. In the spirit of full disclosure I  think that is especially brilliant idea, since I did the same thing 15 years ago, when I started Collabrus, a company designed to employ consultants when they need to be employed by nature of the work or as a risk management strategy.

ShiftPixy is solving another more intractable problem though, by creating a structure that consolidates part-time hours to enable benefits eligibility.  It sounds straightforward, but it is actually a pretty complicated business model.

In the end, Shift Pixy is a small start-up with a little staff, but none the less, they are themselves a job creator.  They have their own employees, but they will also be creating opportunities for various part-time workers to get additional shifts in a way that suits their lifestyle and financial needs.

So as the politicians lament the loss of traditional jobs, I say lets applaud the innovators who are creating the economic infrastructure to strengthen the new world of work.

Wrestling the independent contractor problem

Independent Contractors and Entertainment Law

This week  World Wrestling Entertainment (WWE) was sued on behalf of dozens for former wrestlers who claim the company hid the adverse neurological effects of repeated poundings received in the wrestling ring. This misrepresentation and concealment of the potential injuries faced was compounded by the fact that the wrestlers are not employees, but independent contractors  who are not covered by insurance .images

In the spirit of full disclosure, I must first say I have never understood why wrestling is considered a sport. ( Similarly I never understood why boxing is  in the Olympics either. )

The truth of the matter is  WWE is not a sport, but rather  entertainment. They are not legitimate contests, but rather scripted promotions, with specially choreographed moves designed to titillate the  audience.   These intentional moves are part of the reason the plaintiffs are seeking to be seen as employees; they were required to do these moves , hence WWE exerted direction and control, ergo there is an employment relationship. 

Of course, it is not that simple.  This claim has been made several times over the years , yet the issue has never been resolved.  The claims were not dismissed, but settled which means the body of law governing the relationship has never been addressed. In other words, WWE has successfully avoided the legal determination of  the employment status of the wrestlers.

As a rational and fairly non violent person, it is hard for me to believe that any entertainer engaged in body slamming and head bashing moves would be unaware of the inherent physical and neurological risks involved.  Given the litigious nature of America, entertainment and sports, it is also hard to believe that the contracts committing the talent were silent on this subject. None the less, it does appear this suit could have merit.

In response to an earlier lawsuit in 2007, the WWE replied that its talent were independent contractors because they could negotiate their own contracts aimages-1nd had no corporate duties.   They were much like the talent on soap operas, the company argued. However, the argument is specious on several counts.  First, employees can also negotiate their agreements, so that is not a differentiation.  Second, they have duties in terms of dress code and appearance requirements.  And although a comparison could be made to soap opera talent, that  talent is unionized.  Jess Ventura tried and failed to unionize the WWE talent, but perhaps that is another option.

Various legal experts have chimed in on the independent contractor issue. Since independent contractor is an undefined term in the law, it is typically governed by the IRS 20 points.  These 20 conditions need not all be true to make one an independent contractor, which adds to the ambiguity.  According to a recent University of Louisville Law Review study, the  consensus seems to be that WWE wrestlers meet the employee criteria in 16 of the 20 points. Most legal experts seem to see it the plaintiffs way.

Many of the wrestling cognoscenti have lamented the fact that few wrestlers wanted to challenge their employment status in the courts.  Well that day has now come.  I can’t help but wonder if all the focus on uber drivers and independent contractor status didn’t prompt some additional discussions. WWE says the suit will be quickly dismissed.  I am interested to wait and see.

 

I am Uber the Uber Lawsuit

Uber Lawsuit and The Independent Contractor

Last month, Uber settled the  class action lawsuit involving its drivers in Mass and CA. The court papers reveal that the settlement was $84 million, while some estimates put actual damages, had they lost as trial at anywhere from $750 million to $4.1billion.  Is anyone surprised they settled?

Part of me hoped that the case would continue to the courts, since such a case might  have brought some needed clarity to the mess that is independent contractor  versus employee regulations.

In 1993, I started a firm, Collabrus, because of this very ambiguity.   Collabrus acted as an employer for consultants during a project when the nature of the work or the client’s risk profile warranted that structure. It offered health insurance as well as specialized benefits designed for consultants, like low cost errors and omissions insurance. In setting up and running that business I learned more about independent contractor compliance than I ever cared to know, hence my interest in the Uber case.

I thought, had it continued, the Uber case could go either way. One of the reasons that this is such an ambiguous area is because “independent contractor” is an undefined term in the law. Much of our employment law is derived from British master servant laws which date back to the 14th century. In fact, they were developed following the massive carnage of the bubonic plague; since so many had died, laws were needed to define who of the remainder were the masters and who were the servants. Back then independent contractors (ICs) were not part of the picture.

Since there is no legal definition of an IC, though some states have done so, tests have been developed that take into account agency law constructs as well as other factors. The IRS has put the most widely used framework together in its “20 Points” that define an independent contractor. These include things like having their own tools, being able to experience a financial loss, and receiving no training. Unfortunately, not all of the conditions need to be met, and some are more important than others. This makes for a very murky picture of who may be an IC and who may be an employee. In the last 20 years, the two key things that businesses have drawn from the “20 Points” are that the most important considerations are direction and control. If you direct and/or control the work of someone, they are likely your employee.

So lets consider the Uber driver. One thing Uber has going for them is that they don’t train their drivers; drivers come to them knowing how to operate a vehicle. Uber may certify that the driving record be clean, but this wouldn’t be considered training or direction. The fact that drivers can set their own schedule is also a plus for Uber, since it reduces that sense of control. The fact that so many drivers are very part-time, i.e. less than 10 hours, is also a plus for them. Technology, though, muddies the picture. Drivers are given an iPhone by Uber to be able to hook up to their ride-haling platform. As such, Uber is providing the tools to some extent. Perhaps the biggest issue, and the one that an Administrative Law Judge highlighted in a ruling in 2015 where he deemed a Southern California driver an employee, is that Uber sets the pricing of all rides. As such, this is preeminent control over the driver.

Given my interest in the subject and being a very regular customer of Uber, I quiz every driver about their thoughts on the lawsuit.  I have yet to encounter a driver who wants to be an employee.  Most are teachers or students or retirees, who want the flexibility of time. The one suggestion I did get was that Uber could have done a better job helping the driver prepare for the tax implications of being an IC; as one teacher said, he'd always been a W2 employee, so it never occurred to him that he needed to save all of his receipts.  So maybe Uber just needs a wonderful flyer, brochure or even app, entitled"Making the Most Money with Uber  - How to Manage your Business Expenses."  That seems like it would be a lot cheaper than another court case.

 

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