We regularly hear from the U.S. government about the theft of intellectual property by Chinese companies and their government. This is just one of several examples that I have reviewed and analyzed in the past week. I am sure that there are many more attempts that go unreported.

In February 2012, Hanjuan Jin, a former software engineer for Motorola, Inc., was found guilty of stealing more than 1,000 electronic and paper documents from Motorola. Jin was caught by U.S. Customs while attempting to catch a one way flight to China. She had worked for Motorola since 1998. Why did she decide to steal Motorola’s trade secrets? Had she stolen intellectual property prior to 2007? We’ll probably never know…

The 2007 theft was not a “spur of the moment” decision. It had been in the planning phases for approximately a year.

In February 2006, Jin took a medical leave of absence. Between November 2006 and January 2007, Jin flew to China and worked for Sun Kaisens, a Chinese telecommunications company that developed products for the Chinese military. Jin had already spent June through November 2006, in China negotiating with Sun Kaisens. While working for Sun Kaisens, Jin was provided access to classified Chinese military documents.

In February 2007, the plan to steal trade secrets from Motorola kicked in to high gear:

• February 15, Jin returned to the US from China.

• February 22, she bought a one way ticket back to China.

• February 23, she notified Motorola she wished to return to work.

• She went back to work on February 26. Once back on the company’s premise, she accessed large volumes of proprietary documents during normal work hours as well as after hours. She was also observed leaving the building with various documents and possibly a laptop.

• February 27, she volunteered for a layoff from Motorola.

• February 28, Jin was caught trying to leave the country with over 1,000 electronic and paper documents belonging to Motorola. She also had a number of documents marked “secret” belonging to the Chinese military.

Interestingly, Jin was found her not guilty of three counts of economic espionage for the benefit of the People’s Republic of China and its military. She faces a maximum penalty of 10 years in prison on each count of stealing trade secrets.

Given Jin’s frequent trips to China, and the fact that the theft had been in the planning phases for 12 months, it is anyone’s guess regarding how much of Motorola’s intellectual property Sun Kaisens or the Chinese government were able to gain direct access to. Since Jin spent time in China prior to the theft attempting to convince Sun Kaisens to employ her, she likely shared information from memory. Also, since Jin had been employed with Motorola since 1998, it is possible that she had taken information over time in the event that a move to China was in her future.

This case underscores why it is important to protect your company’s trade secrets. Ask yourself the following questions:

• Does your company have trade secrets? Can you list them?
• How are they used within the business?
• Where are they stored?
• What has the company put in place to control and monitor access?
• How would the company know that an employee is about to steal trade secrets?

There are a number of additional questions involving the alignment of people, processes and technology and the protection of trade secrets, but the questions above should generate sufficient food for thought.

Protecting trade secrets requires a multipronged approach. If there are any gaps in the approach, employees or third parties intent on stealing intellectual property will find them. Don’t believe me? Sanofi-Aventis also has experience dealing with Chinese foreign nationals and the theft of trade secrets. For more on that case, click here.

Arguably, the theft of intellectual property can do more damage to a company than the theft of cash. A company can earn more money to replace the money that was stolen, but once a trade secret is no longer “secret”, the damage is done. Many companies look to the legal system to punish the entity or individual that stole their trade secrets. Certainly, the courts can help. But if your organization cannot demonstrate that it took steps to appropriately protect its trade secrets, the courts may not look too kindly on your claim.

Be proactive! Invest the time and effort to protect your company’s intellectual property. Once your intellectual property is in stolen, you may be a company in name, but in reality, you are a shadow of your former self.

“What do you predict will happen to corporate fraud in 2012 versus 2011?”

Here are the final results:

Increase – 55 (70%)

Decrease – 9 (11%)

Stay the same – 11 (14%)

Not Sure – 4 (5%)

The poll generated 79 responses, and numerous insightful comments (see below).

Comments:

“Interesting question, Paul. And interesting current responses indicating expected uptick. My expectation is increased and even explosive EXPOSURE of fraud, including increased enforcement, willingness to come forward, and EXPOSURE also of enforcement failure points and beneficiary parties.”
-Dean Levinson

“It is interesting that the crash of 1907 was fueled by “bucket shops” or financial investment firms operating out of store fronts that sold derivatives. They also were famous for “pump and dump” schemes of giving advice to people on how to buy and sell, but really created false lows and false highs on a given investment. After the crash the bucket shops were outlawed in every state because of how terrible the financial fraud was. In the years prior to the 2008 crash, legislation was passed to allow the sale of derivatives and the federal legislation mandated that all existing laws on the state level outlawing bucket shops were voided….so much for greater state and local control as going hand in hand with deregulation. Well, now you can get an investment account on line….they give suggestions to investors in a manner very similar to the pump and dump schemes from the bucket shops, and they still trade derivatives. Even since the 2008 crash, the bad practices that were once outlawed due to the terrible effects they had are still practiced. 100 years ago, if fraud was discovered, it was outlawed. Today, if the govt. outlaws something, it is seen as too much regulation and prevents job creation, so fraud is legalized. If the govt. tries to regulate that, it is claimed as too intrusive, so the industry tries to make new guidelines for derivative trading and such. If fraud is discovered, it will be legalized. Once it becomes legal, it is not fraudulent. And once there is money to be made through legalized theft, it will fund lobbyist money to make sure the laws remain in tact to enforce the fraud rather than to remove it.”
- Paul Peck

“In the US exposure of corporate fraud will increase in 2012. The key words here are exposure of existing frauds. On the law enforcement side, the FBI is currently inundated with tens of thousands of fraud complaints (over 63,000 reported) and it will take years to catch up. The FBI reported that the sub prime mortgage frauds, misused bailout funds, green frauds, and others would make this true several years ago. On the political side we have groups such as Occupy and the Tea party demanding corrections to government policy that have created and nurtured a culture of corruption and fraud. A new justice department in 2013 will likely have a mandate to clean up some of the problems created during the last four years; this will place pressure on the current justice department to file cases and create the appearance of doing something about it during an election year. I agree will all the previous comments about financial pressures leading to increased corporate fraud; cooking the books is far less likely to occur when profits are growing through honest efforts.”
- John Evangelisti

“Sadly, Paul, I have voted increase. Scott has pretty much nailed it right on the head – as financial distress increases, the “need” increases, many times, to the point where otherwise honest people feel that they have no other option. In the upper echelons, the pressure to meet targets will be immense, and there will be many instances of overstating revenues and understating expenses by said echelons to meet they targets that they have put out in the public eye.That will be exacerbated by potential drops in overall remuneration packages due to lower or non-existent bonuses, again, heightening the perceived need.”
- Alan Hunter

“I believe that fraud will continue in the rise unless whistleblowers are more protected and/or compensated accordingly.”
- Edward Sotomayor

“While the poor economy will continue to trigger fraud, I’m thinking the number of major conspiracies exposed in the corporate world will likely decrease in 2012, given the awareness that has occurred over the past couple years.”
- Don Crocetti

“Thanks Paul for the poll. It would be all too easy to point out that historically in times of recession and economic downturn, corporate fraud increases. With predictions of very slow (if any) economic growth both in the US and UK and the Eurozone crisis, the global picture looks a little gloomy for the foreseeable future. With the aforementioned and the austerity measures across the public sector starting to bite early 2012, I believe the financial pressures on individuals will increase and therefore increase the likelihood of financial misconduct across both private and public sectors. Looks like I will be taking that easy option after all and voting for the increase based on my own experience and history!”
-Scott Grant

Thank you to everyone that took the time to vote or comment. Buckle your seats, it is going to be a bumpy ride in 2012!

Just when you think you’ve heard it all…

This case involves the Pope, travel on corporate jets, the Superbowl, and a celebrity chef. In fact, it is so unusual that I had to include it in our proprietary global knowledge center (enter 8688JGT for 3 months free access). Since it is included in our database, we have already analyzed the case and provided a list of lessons learned. Before I share some of that information here, let’s learn about the fraud.

Patricia K. Smith, the former controller for Baierl Acura, pleaded guilty to taking $10.2 million from the dealership over a 7 year period. Smith moved money from the dealership’s business accounts to her personal account using over 800 Automated Clearing Housing (ACH) transfers. Smith then used the proceeds to fund the following expenses:

•    $1.8 million billed to American Express for private jet charters; travel to seven countries in Europe and four islands in the Caribbean

•    $44,500 for four club-level tickets along with full hospitality at Super Bowl XLV

•    $32,500 for a luncheon for six people prepared by Food Network star Ina Garten at her barn in East Hampton, NY

•    $5,000 for “The Vatican Package,” which included Mass in Papal Audience with VIP seating, air fare for four, VIP tour of the Vatican Museum with a private tour guide, and a private tour of the Sistine Chapel with family before it is open to the public

•    $2,500 for a Phantom of the Opera experience, including costume fitting, wig fitting, an escort onstage during the Hannibal Opera sequence, and four seats for the performance.

She also purchased the following assets which will be subject to forfeiture:

•    Four houses— three in Pennsylvania and one in Georgia

•    10 vehicles, including three Acuras, four Hondas, and a Mustang convertible (At least she remained loyal to Acura / Honda)

•    Stocks, jewelry, cash, gold coins and personal property, including flat-screen televisions, a mink coat and a baby grand piano.

I have my own thoughts on who is to blame, but I would like to hear your perspective before I weigh in. Please register your vote in the poll at the top of the article. I’ll share my thoughts in a subsequent blog post.

FBI Press release

I believe that each instance of fraud provides companies with an opportunity to reassess their entire fraud defense. Some would call this continuous improvement; others would view it as a best practice. Whatever you call it, fraud defenses must be reviewed, tested and re engineered on a regular basis. Waiting for fraud to happen then scrambling to implement controls after the fact makes very little sense. In the airline industry it is called “Tombstone legislation” – someone has to die for changes to be made – only in this case it is small companies that are “dying”. Large companies live to fight another day. At least most of the time – even when the losses are in the millions…

Things to do on first day with new employer:

• Turn up on time – check

• Find desk and log in to computer – check

• Figure out way to embezzle $1 million…

If the reports are to be believed, when Brenda L. Jones started working with Sirius XM Radio she almost immediately embarked on a fraud scheme that resulted in a seven figure loss.  A co-conspirator with the mysterious initials “VP” was not indicted (any guesses why they were not indicted?)

What makes this fraud particularly interesting is the size of the victim company. Sirius XM Radio is not a “Mom & Pop” company with limited resources to deploy in the fight against fraud. Yet, they suffered a huge loss. Had this fraud happened at a small company, it is highly likely that they would have been forced in to bankruptcy.

I am often asked to detail the size of company that I help fight fraud. My answer is small, medium and large – they all need help! Fraud happens at companies of all sizes and many of the best practices are applicable regardless of size.

• Over the course of a year, fraud losses at a large company will typically exceed losses for a small company. But on a per incident basis, there is very little difference. To illustrate the point, take a look at the graph below from the Association of Certified Fraud Examiners 2010 Report to the Nations. There really isn’t that much of a difference between the median loss at a small company (less than 100 employees) and losses at companies with more than 100 employees. With that said, a $155,000 fraud at a small company can close the doors. A $164,000 fraud at a Fortune 500 company is a blip on the radar.

The biggest difference between how fraud is handled at small and large companies can be found in the post-mortem process:

• Not surprisingly, the post-mortem at a large company is focused on preventing the fraud from happening again. Often, employees that failed to uncover the fraud are disciplined or terminated. If the company has an internal audit function, they are often asked to prepare a report that details the control failures and provide recommendations to avoid a similar fraud in the future. Management of the operation where the fraud took place is expected to implement, and subsequently own the changes to the internal control environment. Invariably, the fraud will receive a nickname and over time, the mere mention of the fraud will either silence a room or result in embarrassed chuckles. No one wants to see that fraud happen again.

• The post-mortem at a small company is an entirely different matter. Instead of internal audit reviewing the situation and recommending improvements, the owner or senior executives normally dive in and do their best to understand what really happened. The entire company – not just the department where the fraud took place – is on tender hooks. They literally don’t know whether they will have a job next week. A law firm is normally involved in some shape or fashion and their mere presence sends concerned employees scurrying up and down the corridor looking for someone to tell them what is happening.

Quite simply, the stakes are not the same for large and small companies.

I believe that the post-mortem process at most companies is in need of an overhaul. Very rarely do small or large companies do anything more than deploy controls to stop exactly the same fraud that they just experienced from happening again. That’s understandable. “Scope creep”, “trying to boil the ocean’, “not trying to solve world hunger” are all euphemisms for don’t over engineer the solution.

I agree that it is important to solve the problem at hand. With that said, it is almost guaranteed that a company will experience more than one fraud in its lifetime. Subsequent frauds may duplicate a previous fraud, be a variation on a theme, or something entirely brand new. Will your company be ready?

As for Sirius XM Communications, I am sure the post-mortem process is over by now. I wonder what they did to stop a similar fraud from happening in the future? Anyone want to bet that they expanded the post-mortem process to include an assessment of fraud risk within the entire accounts payable department.

]]> http://fraudhappens.wordpress.com/2012/01/11/post-mortem-of-a-fraud-what-small-and-large-companies-do-differently/feed/ 2 fraudhappens Sat Radio Source: 2012 ACFE Report to the Nations http://fraudhappens.wordpress.com/2012/01/02/the-confession/ http://fraudhappens.wordpress.com/2012/01/02/the-confession/#comments Mon, 02 Jan 2012 20:16:05 +0000 Paul McCormack http://fraudhappens.wordpress.com/?p=633 ]]>

by Paul McCormack

“It is not the criminal things that are hardest to confess, but the ridiculous and the shameful.”

- Jean Jacques Rousseau, (1712-1778) Swiss political philosopher

The employee sitting across the table from me (we’ll call him Bob) looked like he was going to throw up. I didn’t feel any better. I had played this scene over in mind for weeks and hardly slept the night before.

Welcome to my first interview involving a fraud suspect. You can conduct as many “mock” interviews as you like, but until you are sitting face to face with an employee accused of fraud, you really have no clue what it feels like.

Bob clasped his hands together – almost in prayer – and stared directly at me with eyes that appeared on the verge of unloading tears. Below the table, his legs were bouncing at an alarming rate, so much so that the binders in front of me were slowly shuffling towards the edge of the table. It was time to begin…

“Do you know why you’re here?” I asked

“Yes” said Bob. “I did it. I took the money. Can I go home? I need to tell my wife”

Now what am I supposed to do? The employee had confessed without seeing one document. This is easy! Will they all go this smoothly? I composed myself and asked Bob to tell me what he meant. What money? How did he take it? He again asked to go home, but I encouraged him so share his side of the story and review the documents I had compiled. I convinced him that he needed to know what he had just confessed to doing.

We spent the next hour reviewing the investigation binder in detail. During that time, Bob explained how he embezzled over $100,000 from the company. I also shared the mistake he made that resulted in his undoing. At the end of the hour, Bob had explained how he had committed the fraud, but he had not shared why he had done so.

Knowing how the fraud took place is certainly important as employee and third-party fraud tends to follow “tried and tested” modus operandi. There are certainly variations on themes where a fraud includes a “wrinkle” or unusual element that is unique. With nearly 17+ years experience in this arena, I am still learning new and unusual ways to commit fraud. But don’t neglect the “why”… If you really want to make a difference, ask about the how and the why.

Never make any promises to entice the employee to provide the “why” (That can really create much bigger problems down the road). There are a number of tactics to help employees through this phase of the interview. I personally like the “5 Whys” approach.

“Why did you take the money?”

“Lots of reasons. I don’t really want to tell you why.”

“It would really help if you did. I know this has been bothering you for a long time. Why take all that money? What made you take the first step?”

“I didn’t get promoted last year. I deserved it. I did all the work, and he (pointing to his supervisor seated in the far corner) took credit. For everything.”

“But why commit fraud, though? You might have been promoted this year”

Bob looked down and bit his bottom lip.

“I know other people took money and got away with it.”

“In this office?” I asked. “How do you know?”

“I know because I saw them. They gave me money to keep quiet. I shouldn’t have taken it. But then I wanted more.”

“Why take the money? Why not tell someone about what you saw?”

“My kids need clothes and we just don’t have it. My wife hasn’t been able to find a job and we don’t have anyone to look after the kids anyway. The others were fired so I couldn’t get any more money from them.”

It turns out that 2 employees were fired six months prior for absenteeism. Upon further investigation, both had been involved in stealing inventory and selling it on eBay. Bob stumbled across the fraud and agreed to accept kickbacks to keep quiet.

Sometimes the “5 Whys” works. Other times, no matter how you ask the questions, the employee declines to share anything of value. In fact, I had one employee tell me that they needed the money, and then run out of the room! Not much you can do in that type of situation.

Remember: how fraud is committed is always important, but so is the why. Don’t neglect one over the other as understanding both can help your company prevent fraud. Take the time to learn from each fraud. After all, you’ve paid the entrance price; why not watch the entire movie?

Looks like another bookkeeper may have forced their employer to declare bankruptcy. Karen Tripp allegedly embezzled $1.5 million from Seiler-Nabors Construction Company, based in Collierville, Tennessee. The indictment states that Tripp wrote checks to her personal bank account as well as the antiques store that she owned. She also allegedly used the money to buy her children cars, build a mansion and take exotic vacations.

Collierville’s population is just under 45,000. I am sure the Seiler-Nabors bankruptcy will create a sizable ripple effect across the community. The company has already fired 20 employees which will obviously have a direct impact on a number of families.

Christy Klink worked alongside Tripp. She shared her thoughts with Memphis reporters regarding the indictment.

“It’s not going to change anything that happened or change the financial problems it has caused us. It does give us some satisfaction to know she is going to spend a lot of time in jail.”

Klink may be in for a rude awakening if Tripp is found guilty or “cops” a plea. In reality “a lot of time in jail” may not amount to much. It is probably Tripp’s first offense, and I would guess that she’ll serve 2 to 4 years. She’ll probably be ordered to pay the money back and it sounds like there may be some assets that can be liquidated. But, when the IRS comes knocking for the taxes on the $1.5 million (I doubt that Karen declared all of her income), they’ll likely jump to the head of the line demanding payment.

This case is just another example of how fraud can destroy a business. Ultimately, there are very few “winners”. In addition to closing the business and putting 20 people out of work, trust was lost. Trust that their employee was honest. Trust that their mother’s gifts and new house were earned and not stolen, and trust that if you work hard and do the “right thing” for your employees and the community that you’ll be rewarded.

Christy Clink’s father is a part owner of Seiler-Nabors Construction. Clink told reporters that her father had hoped that the company would pay for his retirement.

“He lost my mom about three years ago. He’s not really gotten over that and this comes and destroys him. She’s taken everything. He’s going to lose it all.”

This story involves a small company, but the “lessons learned” can apply to companies of all sizes. If you learn only one thing from this post, please monitor employees that issue payments. This case involved checks, but fraud can just as easily happen with wires, debit cards, credit cards, ACHs and of course cash. When was the last time that you reviewed your bookkeeper’s work? Do you reconcile your company’s bank statements on a daily basis? Who has access to blank checks?

Remember: You can trust but always verify.

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Also, if you would like to share your thought process in the comments section, please do so! You may be the “lone voice”, or in the majority. Either way, you’ll find out!

Thanks for taking the time to vote!

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It is very easy to forget that many law enforcement agencies, including the Federal Bureau of Investigation have a blog. The FBI’s blog is easy to navigate, regularly updated and includes information on a vast range of fraud types that fall within the FBI’s area of operation. It is certainly not aesthetically pleasing, but the format is consistent with the FBI’s persona.

The “news by subject” section is particularly helpful as it provides hyperlinks to topics such as organized crime and white-collar crime. I found the post “Ten Years Later:  The Enron Case” particularly intriguing. Many of the Enron trial exhibits and documents are available online. Personally, it looks fascinating, but I am little biased…

http://www.fbi.gov/news/news_blog

Do you want to learn more about what is happening in fraud today?  Click here

If you believe Diana L. Farmer-Forston, since her early childhood life has been a struggle. But in many respects, her struggles are just beginning. Diana was recently sentenced to two years in prison for embezzling $567,000 from her employer, Bennett and Zydron, a Virginia Beach law firm. In an interesting twist, Diana ended up being scammed out of $300,000 of the fraud proceeds when she agreed to lend a co-worker money to cover expenses associated with their cancer treatment. Allegedly, Diana made her coworker sign a promissory note with a monthly interest rate of 4.5%. Thankfully, the coworker is cancer free. In fact, they never had cancer in the first place.

Hired by the law firm in 2005, Diana didn’t launch her fraud career until 2007. What happened between 2005 and 2007? Did Diana’s struggles from her childhood come back to haunt her? We do know from court filings that her husband of 25 years announced in 1999 that he had decided to undergo a sex change operation. Their marriage ended shortly thereafter. That revelation surely had an impact on Diana, but did it force her to commit fraud seven years later?

Here’s a hint: In many cases, you’ll never figured our exactly what drove an employee to commit fraud.

In Diana’s case, it would likely require extensive therapy to truly undercover the root cause. Diana’s attorney claims that she has struggled with depression and other undisclosed mental health issues since her childhood. He also states that Diana was also around physical, sexual and emotional abuse while growing up. She has apparently had a very difficult journey to date, but her struggles started long before she joined the law firm.

As an employer, you have to focus on what you can control. Certainly, before hiring a new employee, perform background checks, conduct a rigorous interview process and call references. Whether the employee experienced abuse as Diana apparently did it is legally, ethically and morally out of scope during the interview process. Remember, you can’t control what has already happened…

You can control what happens once the employee sets foot in the office. Once they join the organization, make sure that you don’t send messages that help the new employee rationalize that committing fraud is “ok”. Fraud prevention essentially begins during the interview process and continues throughout the employee’s tenure. Assuming that you have not hired an employee that is already an accomplished fraudster, your company has ample opportunity to prevent from fraud happening. I’ll detail many of the tactics you can use to build a culture that prevents fraud in my next post. This post hopefully lays the groundwork.

Bottom line: You can prevent fraud if you focus on what you can directly control. The employee already has ‘baggage’ that they bring to the table. You can’t control how much, or what it contains. You can control how your organization is positioned to prevent and detect fraud. There are no “fool-proof” approaches, but you have far more power than you realize…

Learn more about Diana’s case here

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by Paul McCormack

Companies lose billions every year. Some are shocked that it happened to them. Others, have a line item in their financial plan (Yes, you read that correctly. They plan to lose money to fraud.) Far too many companies are forced to close their doors because of it…

So, why is it so hard for companies to combat fraud? Here are five reasons that I have uncovered during my career:

1. “You work here as well?” – Fraud professionals often talk about their frustration with “silos” that result when departments involved with preventing and detecting fraud don’t talk to each other. In fact, a significant portion of my career has been spent helping break down the silos within organizations. The fraudster – both employee and third-party – is able to exploit the lack of communication between departments for their own benefit. Large companies are particularly guilty. It is not unusual for two or more departments to be actively investigating the same employee! No one has the complete picture of the fraud, yet each department continues to investigate the situation independently while the losses mount.
2. “I don’t want to think about it” – Fraud can be overwhelming, especially for senior executives with an already heavy workload. It is easier not to think about what fraud may be doing to the company’s bottom line. Unfortunately, ignoring the problem will never solve it. In fact, when losses do result (yes, fraud happens) they are often gigantic.
3. “We don’t have the money” – This reason is certainly understandable, especially when you consider the dire state of the global economy. It is probably the biggest hurdle that our firm has to overcome when talking with companies of all sizes. Unless the company has experienced a significant fraud within the last 12 months, there is resistance to any investment in fraud prevention or detection services. Until the company sees a spike in fraudulent activity, why should they worry? Well, unfortunately, you can’t pick a date and time when fraud will happen. It has an uncanny knack of taking place when you can least afford it. The costs to fix the problem are normally far higher than the prevention that was needed in the first place.
4. “Bring it. We’ve got it covered” – From time to time, I run across an exceptionally high performing fraud department. They have the right mix of people, processes and technology to fight fraud. The company’s executives support their efforts and they routinely hire the “best of the best” to join their organization. They have fraud – internal and external – under control. Well, almost. What worked last month, or last year, will not automatically work today. Combating fraud requires a “continuous improvement mindset”. Fraud evolves, so too must the fraud department. Complacency can eventually destroy even the best fraud department. The latest fraud intelligence can literally make the difference between success and failure. Trust me; I’ve seen it happen on more than one occasion.
5. “They were just that good” – I have interviewed 100′s of people who have committed fraud. Many of the schemes that they perpetrated required tremendous vision, drive and determination to execute. Some of the most intelligent individuals that I have met were in fact accomplished fraudsters. The really smart fraudsters are often never caught. Every fraud investigator can cite at least one or two situations where the fraudster got away with it. Some fraudsters are just that good. If they don’t make a mistake, you have almost no chance of catching them.

This list is certainly not all inclusive. I’d love to hear from others as to why fraud is so difficult for companies to fight. Also, if you disagree with any of my observations, feel free to say so!

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