On Friday, October 7, 1994, Congress passed the Digital Telephony and Communications Privacy Improvements Act of 1994. Also known as the "Digital Telephony Bill," "Network Wiretap Bill" , and "Communications Assistance for Law Enforcement Act" , the law is intended "to make clear a telecommunications carrier's duty to cooperate in the interception of communications for law enforcement purposes" . A long time subject of debate among technophiles, this bill is feared by many who think it heralds a loss of privacy.
The Washington Post reports on the purpose of the bill: "Law enforcement officials have worried that the networks, which use the digital technology of computers, would render existing phone surveillance techniques useless" . The legislation forces phone companies to modify their networks, making them accessible to law-enforcement wiretaps. Furthermore, the bill requires all future technology to accommodate the FBI's eavesdropping needs.
The Digital Telephony Bill has been a topic of debate between the FBI, telephone companies, and civil liberty and privacy groups for the past two years. But the real argument behind wiretapping started years before then. In order to understand the state of affairs today and in order to appreciate all sides of the argument, we will have to start by looking at the history of lawful wiretapping. Later, we will come back to the present and examine the Digital Telephony Bill in more detail.
What we have to do is to understand where we've come from those days back in 1928 when Justice Brandeis said, "Ways may some day be developed by which the government, without removing papers from secret drawers, can reproduce them in court and by which will be enabled to expose to a jury the most intimate occurrences of the home. Can it be that the Constitution affords no protection against such invasions of individual society?" 
It is, of course, important to understand not only where we've come from, but how we did it, and why.
Wiretapping is a relatively new development in our society (at least, legal wiretapping; Rep. Edwards admitted during the hearing mentioned above: "When I was an FBI agent... it was illegal for us to tap telephones. As I seem to remember, we did it anyway, but I don't... but I won't admit it." ). The history of legal wiretapping in the United States started in 1968, when Congress passed the Omnibus Crime Control and Safe Streets Act of 1969 (18 U.S.C. Sec. 2518(9)). Title III of the act contained comprehensive federal legislation regarding electronic surveillance. It established strict procedures conducting "interception of a wire, oral, or electronic communication" . According to the statute,
Since the passage of this Act, 37 states have passed electronic surveillance laws . Among states that still do not allow wiretaps are California and Illinois .
It should perhaps be noted that an order for installation and use of a pen register (used to identify the numbers dialed or transmitted on the phone line) or a trap and trace device (used to identify the number from which a wire or electronic communication was transmitted) is much more readily obtainable (18 U.S.C. Sec. 3123). In this case, it suffices to show that "the information likely to be obtained by such installation and use is relevant to an ongoing criminal investigation" .
Since 1968, law enforcement agencies on both state and federal levels have been exercising the power given to them by the Omnibus Crime Control Act to obtain wiretap orders. To get an idea of the numbers involved: according to the FBI Director Louis Freeh,
In 1992, a total of 919 Title III orders, as well as an estimated 9,000 pen-register orders, were authorized for all federal, state and local law enforcement agencies. Of that total, only 340 were procured by the federal government, of which only 252 were applied for by the FBI. Approximately two-thirds of the criminal-related electronic surveillance conducted in the United States is carried out by state and local law enforcement agencies" .
According to Dorothy Denning, "In the decade from 1982-1991, state and federal agencies conducted 7,467 taps, which have thus far led to 19,259 convictions" . According to Robert Hanson's statistics up until and including 1990, "about 40% of wiretaps were requested by federal authorities... About 60% of taps were regarding drug offenses, and 14% for gambling offenses" .
Freeh claims that electronic surveillance is one of the most important investigative techniques used by law enforcement agencies:
Though used sparingly, electronic surveillance has been extremely effective, leading to the convictions of thousands of dangerous criminals involved in drug trafficking, organized crime, violent crime, kidnapping, crimes against children, and public corruption. Its evidence has secured the convictions of more than 22,000 dangerous felons over the past decade. Aside from its great importance as an investigative tool, electronic surveillance frequently has been essential in preventing crimes and saving human life, such as preventing murders, saving numerous lives threatened by terrorist attacks, dismantling organized crime groups which prey on people through extortion and violence, and in attacking the national and international drug cartels whose illegal drugs so ravage society and cause incalculable personal injury .
The reason such a critical tool has been used so sparingly, according to the FBI Director, is that it is only employed in the most important dangerous cases, such as terrorism, espionage, drug trafficking, organized crime, and kidnapping.
Back in 1968, wiretapping was pretty straightforward: you simply plugged alligator clips into the phone wires and listened in. With recent advances in digital telephony, however, wiretapping is becoming increasingly more difficult. Some of the obvious complications are caused by time-multiplexed lines, fiber optic transmissions, and the increasing number of mobile telecommunication networks and architectures.
The FBI Director Louis Freeh put it rather dramatically during the House Judiciary Committee hearing:
The United States is facing a grave and growing problem. New telecommunications technology is impeding or preventing law enforcement from conducting court-authorized electronic surveillance .
Or, from a more down-to-earth Briefing Report to the Subcommittee on Telecommunications and Finance, Committee on Energy and Commerce of the House of Representatives by the United States General Accounting Office (GAO/IMTEC-92-68BR, July 1992),
The FBI now has the technical ability required to wiretap certain technologies, such as analog voice communications carried over public networks' copper wire. However, since 1986, the FBI has become increasingly aware of the potential loss of wiretapping capability due to the rapid deployment of new technologies, such as cellular and integrated voice and data services, and the emergence of new technologies such as Personal Communication Services, satellites, and Personal Communication Numbers.
There are six current or imminent telecommunications technologies that the FBI needs to be able to wiretap. These are (1) analog and digital using copper wire transport, (2) analog and digital using fiber optic transport, (3) Integrated Services Digital Network (ISDN), (4) Private Branch Exchange (PBX), (5) broadband, and (6) cellular. There are also three future technologies for which wiretapping capabilities need to be addressed: (1) satellite switches, (2) Personal Communication Services (PCS), and (3) Personal Communication Number (PCN). Further, the FBI needs to be able to wiretap any special features, such as call forwarding or electronic mail .
In short, the FBI fell behind the curve on digital communications technology. The Digital Telephony Bill is a way for law enforcement agencies to both catch up with the technology and to make sure they never fall behind again. As Rep. Henry Hyde from Illinois put it, "We want to make sure that the technological advances in the field of telecommunications, which are considerable and ongoing and enormous, will not foreclose the ability of the FBI and other law enforcement agencies to conduct legal electronic surveillance" .
An important claim made by Freeh repeatedly during the hearing is that the FBI is "not seeking any expansion of the authority Congress gave to law enforcement when the wiretapping law was enacted 25 years ago... we are asking for the balance to be maintained instead of being changed" .
The bill was initially introduced by the Bush administration, at the request of the FBI. Wired magazine reports: "The initial proposals were unpopular and met with great opposition, preventing them from moving through Congress" . On October 9, however, the New York Times reported that "the bill passed the Senate unanimously late on Friday and goes to President Clinton, who has said he favors the legislation" .
It looks like the Digital Telephony Bill has just become a reality. Having looked at the history of electronic surveillance and the motivations behind the bill, let us now examine in more detail the bill itself.
The final incarnation of the Digital Telephony Bill (SB 2375 and HR 4922)  consists of three titles, of which Title I is the most interesting for our purposes as it deals with electronic surveillance.
In Title I, two definitions are of utmost importance:
The distinction between information services and telecommunications carriers is an important one. Title I applies only to the latter; providers of information services are not required to ensure easy eavesdropping capabilities. As stated in "EFF Statement on and Analysis of Digital Telephony Act" of October 8,
Jerry Berman, EFF's Policy Director, said: "Although we remain unconvinced that this legislation is necessary, the bill draws a hard line around the Internet and other online networks. We have carved cyberspace out of this legislation".
Berman added, "The fact that the Internet, BBS's, Prodigy, and other online networks are not required to meet the surveillance capability requirements is a significant victory for all users of this important communications medium" .
Another important observation is that the category of telecommunications carriers seems to be broader than that of common carriers, as it includes any entity providing "a replacement for a substantial portion of the local telephone exchange service." According to CyberWire Dispatch, "this new category [was] penciled at the insistence of the telephone companies facing the threat of having to bear the entire burden for making the FBI's job easier" . And indeed, Roy Neel, the President of United States Telephone Association complained in his March 18, 1994 testimony before the Senate Judiciary Committee that "in the face of... developing multiplicity of communications providers... the [old version of the] bill places all of the requirements on the common carrier alone" .
The gist of the bill's most important section is that "a telecommunications carrier shall ensure that its equipment, facilities, or services that provide a customer or subscriber with the ability to originate, terminate, or direct communications are capable of" :
To sum it up, the FBI is allowed to wiretap telecommunications, pursuant to a court order, in the privacy of their own offices; the telecommunications carriers, and not the FBI, are responsible for making that a reality.
There are also important limitations made explicit in Section 2602. The FBI is not authorized to require or prohibit any specific design of equipment, facilities, or system configurations to be employed by telecommunications carriers in compliance with the statute. Furthermore, a telecommunications carrier is not responsible for decrypting, or ensuring the government's ability to decrypt, any communication encrypted by a subscriber or customer, "unless the encryption was provided by the carrier and the carrier possesses the information necessary to decrypt the communication."
According to Section 2603, on or before November 30, 1995 the Attorney General shall make available to telecommunications carriers his estimates on both the actual and the maximum number of communication interceptions (as well as pen registers and trap and trace devices) that authorized law enforcement agencies may conduct by the date that is 4 years from the enactment of the title. The telecommunications carriers are then responsible, within 3 years, to ensure their ability to accommodate the estimated maximum capacity. Furthermore, the Attorney General shall periodically publish any increases in the maximum capacity requirement; the carriers are again responsible to comply within 3 years.
In cases of non-compliance, the Attorney General may obtain an order directing that a telecommunications carrier comply with the Act. Non-compliance can be punished by civil penalty of up to $10,000 per day for each day in violation after the issuance of the order.
The bill requires the government to reimburse carriers for all reasonable costs associated with complying with the capacity requirements. In other words, the government will pay for upgrades of current features or services, as well as any future upgrades which may be necessary, pursuant to published notices of capacity requirements (Sec. 2608). There is $500,000,000 authorized for appropriation to cover the costs of government reimbursements to carriers for the next 4 years. In the event that a smaller sum is actually appropriated, the bill allows a court to determine whether a carrier must comply (Sec. 2608 (d)).
At the previously mentioned hearing before the House Judiciary Committee, Freeh was questioned about the extent to which digital telephony has impaired the FBI's ability to conduct wiretaps:
SEN. LEAHY: [H]ave you had any instances where you've had a court order for a wiretap that couldn't be executed because of digital telephony?
MR. FREEH: We have instances of 91 cases -- this was based on a 1993 informal survey which the FBI did with respect to state and local law enforcement authorities. I can break that down for you.
SEN. LEAHY: In fact you did. In your statement you say that... of those wiretap orders, in 10 instances the cellular provider didn't have enough capacity; in 29 instances special calling features were the problem; in 30 instances the cellular provider could not give you dialed number information .
In March, this unimpressive number, 91, left many skeptics unconvinced. And then, in response to a CPSR Freedom of Information Act lawsuit, the FBI released 185 pages of documents concerning its Digital Telephony Initiative. From EFF's archive:
The newly disclosed material raises serious doubts as to the accuracy of the FBI's claims that advances in telecommunications technology have hampered law enforcement efforts to execute court-authorized wiretaps... The FBI documents reveal that the Bureau initiated a well-orchestrated public relations campaign in support of "proposed legislation to compel telecommunications industry cooperation in assuring our digital telephony intercept requirements are met." ... However, despite efforts to obtain documentation from the field in support of Bureau claims of a "crisis facing law enforcement," the response from FBI Field Offices was that they experienced no difficulty in conducting electronic surveillance .
The President of the Telephone Association was not very supportive of the FBI's case either:
USTA is aware of only a handful of instances in which there has been difficulty in providing assistance. These were caused by oversights in the original statute authorizing wiretapping which left certain issues, such as liability, unresolved. These oversights were quickly rectified, and since then there has been a long history of unblemished cooperation between LECs and law enforcement agencies .
Neel stressed, during his testimony, USTA's willingness to cooperate with law enforcement, and his belief that the "current statute" (Sec. 2518) provides a good ground for such cooperation. The Digital Telephony bill, on the other hand, "ignored the historical relationship we have enjoyed with law enforcement. It is a punitive approach with unjustifiably harsh penalty provisions. It also forces local exchange carriers to become, in effect, agents of the law enforcement community, rather than maintaining the more appropriate arms-length relationship between common carriers and law enforcement" .
None of the civil libertarians, including the EFF, CPSR, and the ACLU , seem to think that the FBI has made a compelling case that "new communications technologies hamper the ability of law enforcement agencies to execute court orders for electronic surveillance" . In the March 18 hearing, Jerry Berman, Executive Director of EFF, stressed this point before the Judiciary Committee:
The most fundamental question that needs to be resolved is whether this legislation is necessary. In our view neither the Bush nor Clinton Administrations have made a persuasive case. They argue that electronic surveillance is essential to law enforcement. but they have not demonstrated that their access to communications subject to judicial warrants have been impaired. They have pointed to problems encountered with call forwarding and cellular communications, but carriers have been able to meet new requirements through cooperative efforts .
This fundamental question has since been swept under the rug.
Privacy issues are the ones central to the wiretap debate. An individual's privacy is valued enormously in American society. Yet the underlying assumption behind the Digital Telephony Bill -- and indeed, the 1968 wiretapping legislation -- is that the government has a right to conduct electronic surveillance for law enforcement purposes. Thus, as the FBI is aiming to preserve the power to wiretap granted to it in 1968, there are still people wondering whether that power is justified in the first place. Going back to the quote by Justice Brandeis back in 1928, "can it be that the Constitution affords no protection against" wiretapping?
Besides the fundamental objections to wiretapping on the basis of invasion of privacy, there are objections to the Digital Telephony Bill in particular. Some feel that, contrary to FBI claims, the bill is aimed to expand the authority given to law enforcement agencies. Wired reports:
The proposed legislation would establish a dangerous precedent for the future. The legislation would, for the first time, mandate that our means of communication be designed to facilitate government interception. The future of the National Information Infrastructure may be at stake .
Similar concerns have been expressed by numerous private parties. Mike Crawford, in his letter to the president (posted on comp.org.eff.talk), says:
I urge you to veto the Digital Telephony Bill (SB 2375). This bill represents an unprecedented invasion of our right to privacy.
While the law enforcement agencies have authority to wiretap telephones, until now there has been no law ensuring that they will succeed in such taps. It is as if building contractors were required to build hidden cameras into our homes. While court orders may be required to _legally_ turn on such surveillance, I would sleep much easier at night if such a surveillance method were not present at all .
It is understandable, however, that, from the FBI's and the government's point of view, law enforcement must not be sacrificed for privacy. As Freeh put it,
[W]e need and we will have a superhighway of information, but I think Americans want to have a cop on that highway. Whether he's a Vermont state trooper or whether she's a Pennsylvanian trooper or a Californian Highway Patrolman, we need that protection on that highway, and I think we can do it. And I don't see the privacy issues as being real issues once they're discussed .
The question is, how right is the FBI Director? How real are the privacy issues to American people? What is the correct balance between citizens' rights of privacy and the interests of law enforcement that Rep. Hyde promised us "both the Senate and the House will work together to... ensure" ? Everybody has different answers to these questions. Neel notes, for example:
A dramatic illustration of the primacy that our citizens place on their privacy is the fact that while the media is rife with stories about violent crime, a poll conducted two weeks ago by the Yankelovich Partners and reported in Time Magazine March 14 found that "two-thirds of Americans said that it was more important to protect privacy of phone calls than to preserve the ability of the police to conduct wiretaps" .
It must be noted with respect to the wiretap bill that the EFF has put great effort into ensuring that privacy safeguards appear in the bill. For example, "EFF pushed for the addition of stronger protections against indiscriminate access to online transactional records." Also due to the EFF, "The bill recognizes a citizen's right to use encryption" . Berman stated after the bill was passed by Congress:
There are numerous opportunities under this bill for public oversight and intervention to ensure that privacy is not short-changed. EFF will closely monitor the bill's implementation, and we stand ready to intervene if privacy is threatened .
Some people are concerned that requiring technology modifications to support taps would impede new technologies. From CyberWire Dispatch:
[In] a May 22, 992 memo from the office of the Vice President office, Jim Jukes... points out that implementing the bill could stall "emerging technologies" such as the fledgling personal communications services industry. Owing to the fact the Clinton Administration is banking on the communications industry to pony up more than $10 billion and pour it into government coffers when it bids for PCS spectrum licenses later this year, Jukes appears to be a prophet when he wonders why the FBI chose not to estimate what the economic benefit would be if these PCS technologies didn't get off the ground sooner than later due to restrictive measures in the wiretap bill .
There is more evidence of related concerns within the government circles. Here is an excerpt from the debate between Freeh and Leahy at the March 18 hearing:
SEN. LEAHY: [The telephone companies are] moving forward in technology; they've told you this technology is something you can't tap into. It's obviously technology they feel they want or they wouldn't be moving forward in it... You're saying, wait a minute, we've got to be able to tap into this and we're going to go to the Congress, get legislation to tap into it. Well then, doesn't it follow that that technology has either got to change, stop, wait or develop some new feature to work, and it's not going to be the technology that they have made the corporate decision to go forward with.
MR. FREEH: Well, again, I respectfully disagree... [A]t the meeting last Friday, the GTE representative told us that they are now building switches [that] will be marketed two or three years from now. What he said is, look, give me the requirements; I have to -- we have to -- the industry has to know what the requirements are and we'll build those into the switches, in effect -- not that they want to do it and not that they'd rather do something else, but... they're not telling us that this is an impossibility.
SEN. LEAHY: What if we told [the American people] we have some major technological advances that are coming that would make your life easier, but we're going to hold it up; we're also going to add significant costs, both -- to you through taxes, and what not, to do this.
MR. FREEH: Well, it's a cost-benefit analysis .
And indeed it is a cost-benefit analysis, just like the issue of law enforcement versus privacy. What is more important to Americans: an ability to partake in the evolving technological advances, or better law enforcement (that is, if we assume that the bill does indeed promise better law enforcement)?
To telephone companies, this matter is, naturally, of primary concern. During his testimony, Neel expressed his disappointment at the government's lack of support, in this instance, of the speedy advance of the information infrastructure:
I have already referred to the legislation advocated by the Administration, designed to hasten the advent of the "information superhighway." The priority of this effort should not be underestimated... But all of these advances are the outgrowth of the speedy deployment of a modern information infrastructure. This bill calls into question the priority of this effort and creates an enormous speed bump in the information superhighway .
Finally, there is the issue of costs: the costs of the bill to the telephone companies, to the government, and to the public at large. Again, CyberWire Dispatch has a cutting remark on the issue:
The FBI continues to insist that its "easy access" wiretap bill will cost industry little, compared to the "economic benefit from the continued use of electronic surveillance," which Bureau briefing documents say equate to "billions of dollars per year," collected through "fines, recoveries, restitution, forfeitures and prevented economic loss." FBI Director Louis Freeh, appearing on the TV show "Meet The Press" stated that the wiretap bill would cost the industry just $300 million to implement.
Someone donate money to Freeh so he can buy a clue .
Freeh is not alone. Dorothy Denning cites more figures which seem to indicate enormous savings brought about by the bill:
During the period 1985-1991, court-ordered electronic surveillance conducted just by the FBI led to 7,324 convictions, almost $300 million in fines being levied, over $750 million in recoveries, restitutions, and court-ordered forfeitures, and close to $2 billion in prevented potential economic loss. Since the FBI conducts fewer than one-third of all intercepts, the total benefits derived from electronic surveillance by all law enforcement agencies is considerably higher .
As Robin Hanson notices, however, Denning offers no support for her claims, and appears to be relaying internal FBI figures, which the FBI itself has neither revealed nor explained to the public .
On the other side of the issue, Roy Neel has several objections to the FBI's estimates. Firstly, if the public opinion of the wiretap bill translates into reduced use of the system, the result will be "the loss of billions of dollars in potential revenue, and along with that many of the jobs, the taxes, and the benefits that we anticipate from the information age" . Secondly, there are costs associated with updating the networks to comply with the bill:
First we have to have some idea of how much these system upgrades will cost. The Bureau has expressed significant interest in the issue of call forwarding. Preliminary USTA estimates are that the software upgrades alone necessary to capture the needed information at the originating end of these calls would cost between $180 million and $1.8 billion.
In addition, new equipment and software would have to be developed to assure that carriers have the "ability to intercept the content of communications," particularly in the approximately 1,200 ISDN switches deployed throughout the nation. Estimated costs here are approximately $450 million.
This does not even anticipate the costs associated with newer technologies such as photonics and asynchronous transfer mode. USTA's technical disciplines department does not even have rough cost estimates on these items, but they will certainly be significant.
The point here is not that we cannot make the adjustments law enforcement says it needs. In fact, we can. However, there will be costs involved - costs that will likely go far beyond the Bureau's estimates both in number of dollars and number of years... [W]e strongly question law enforcement's technical ability to be the judge of what constitutes "reasonable and cost-effective charges directly associated with modifications required to assure common carrier compliance" .
There was much debate in the last two years as to who should pay the costs associated with the required upgrades. Some consider the government's decision to put up $500 million for this project, instead of making phone companies come up with the money, a major concession. But the funny thing is, regardless of the outcome of that debate, we would be the ones picking up the tab -- if not as taxpayers, then as telephone companies' customers. And since we are the ones paying for this bill, the question is, is it worth it to us?
The Digital Telephony Bill has provoked a great deal of controversy since its original appearance in 1992. The debate has focused on many of the issues which are deemed important in our society -- in particular, privacy and freedom of expression. We have seen these issues come up repeatedly throughout our country's history, and we will undoubtedly see them come up again.
As the FBI Director Louis Freeh pointed out, finding the balance between the interests of law enforcement and the costs associated with the bill -- among them, invasion of privacy, potential impediment of new technologies, and huge sums of money -- amounts to performing a cost-benefit analysis. We, the ones affected by the bill, need to decide what the correct balance is: whether our privacy and our money are more important to us than the FBI's ability to conduct electronic surveillance.
Independent of what the correct balance is, the Digital Telephony Bill sets a precedent by establishing a particular distribution of costs and benefits. The bill itself is just another stage in the on-going privacy debate. Today, this debate is centered around the bill; tomorrow, it will be the Clipper Chip; after that, the focus will shift to the laws of Cyberspace. At every stage, we need to be careful as a society to establish precedents that will lead us toward the correct balance.
 The Washington Post, "Network Wiretap Bill Passes," by Elizabeth Corcoran. Saturday, October 8, 1994.
 Digital Telephony Bill as passed by the Senate on October 7, 1994
 Joint Hearing of the Technology and Law Subcommittee of the Senate Judiciary Committee and the Civil and Constitutional Rights Subcommittee of the House Judiciary Committee. Subject: wiretapping. Witness: FBI Director Louis Freeh. March 18, 1994.
 United States Code, Title 18
 Robin Hanson, Can Wiretaps Remain Cost-effective? May 12, 1993.
 Dorothy Denning, To Tap Or Not To Tap. Comm. of the ACM, Vol. 36, No. 3, March 1993, pp. 24-33.
 FBI Advanced Communications Technologies Pose Wiretapping Challenges. United States General Accounting Office, Briefing Report to the Chairman, Subcommittee on Telecommunications and Finance, Committee on Energy and Commerce, House of Representatives (GAO/IMTEC-92-68BR). July 17, 1992.
 Wired, "Stop the Digital Telephony Bill." November 1994.
 New York Times, "Clinton Gets a Wiretapping Bill That Covers New Technologies," by Sabra Chartrand. Sunday, October 9, 1994.
 EFF Statement on and Analysis of Digital Telephony Act. October 8, 1994.
 CyberWire Dispatch, FBI Buys In, by Brock Meeks. July 29, 1994.
 Prepared Testimony of Roy Neel, President of United States Telephone Association before the Senate Judiciary Committee, Subcommittee on Technology and the Law. March 18, 1994.
 Description of 185 pages of released FBI documents concerning the Bureau's Digital Telephony Initiative.
 ACLU Opposes FBI Wiretap Access Bill. September 26, 1994.
 Testimony of Jerry Berman, Executive Director, Electronic Frontier Foundation (on behalf of EFF and DPSWG) concerning the Digital Telephony and Communications Privacy Improvement Act of 1994. March 18, 1994.
 Letter to the President, posted on comp.org.eff.talk. Mike Crawford (crawford@scipp.UCSC.EDU). October 10, 1994.
 CyberWire Dispatch FOIA article.
 Senators' Confusion, posted on comp.org.cpsr.talk. email@example.com. October 11, 1994.
 The Wiretap Watch, Issue 1.05, cpsr-announce-errors@Sunnyside.COM. October 6, 1994.