Mike Cernovich: Based Lawyer of Gamergate
Two days prior to New Years’ 2015, the Gamergate movement had its first major personality debate streamed online between Chris Kluwe (@ChrisWarcraft), former NFL player and casual video game culture pundit, and Mike Cernovich (@PlayDangerously), a 1st amendment lawyer based in Los Angeles who had controversially taken to the movement in October. Though framed as an argument between “sides” of the controversy, the pair was not elected by any particular consensus; the two had engaged in mutual criticism over Twitter and arranged the debate personally, taking it upon themselves to represent the myriad controversies and disconnects that had coagulated over the course of a five-month horror show — one rife with character assassination, intimidation tactics, harassment, and speculation of legal ramifications for major parties involved.
The debate was a Waterloo for Cernovich, who was unable to glibly hide behind asynchronous Twitter exchanges as Kluwe called out both his and the movement’s myriad failings, half-truths, and muddying of waters. Reactions from Gamergate ran the gamut of emotions from frantic damage control to resigned disappointment. They did not, however, frame it as a loss for Gamergate; to them, Cernovich was never a leader so much as a de facto figurehead. This is part of Gamergate culture, which itself is a mutation of the culture of Chan message boards, a phenomenon documented in depth by Jay Allen, known by his Twitter handle @a_man_in_black.
Chan culture, and Gamergate, is marketed as a diaspora with no entry criteria, central knowledge base, or, most importantly, leadership. Supposedly, this allows its members to work towards implicit communal goals without fear of identification or consequence; if someone is deemed detrimental to the movement’s PR, they can hypothetically be forcibly disassociated from the collective.
But with no leaders, power vacuums begin to form, ripe for occupation by anyone with a personality and an agenda. E-celebrity status is awarded to anyone with visibility and a megaphone who is willing to spout agreeable rhetoric. Some vociferous supporters become “more equal than others.” In Gamergate, these figureheads are often lauded for their notable anti-progressive streaks, or their willingness to lend legitimacy to the movement by way of their professional credentials, existing stigmas be damned.
If you’re intimidating enough, you might just find yourself “based.”
“Based,” a term popularized by Lil’ B, has been co-opted by Chan culture — and by extension, Gamergate — as a superlative reserved for anyone allying themselves with the movement that uses their credentials or platform to rise above the anonymous fray and further their cause.
Enter Mike Cernovich, Gamergate’s “Based Lawyer.”
The elevation of Cernovich to unofficial Gamergate spokesman is not the first time the movement attempted to throw around legal weight. Early in Gamergate, a supporter identifying as “Lawfag” promised legal support to its members, as well as legal consequence to anyone who may cross the movement. This fell apart quickly when Lawfag was revealed to be merely married to an attorney and attempting to raise $35,000 to hire his wife for a nonspecific “investigation” into serial Gamergate harassment targets Anita Sarkeesian and Zoe Quinn.
No less craven was Cernovich’s entry into the fray, as his primary motives of making a name for himself and pushing an antiprogrssive agenda had been thrust into the limelight in an embarrassing online pantsing by Matt Binder. The difference, though, is that Cernovich was willing to follow through with what may have been otherwise considered idle boasts, and he (by most accounts) has some steez in 1st amendment law circles. At least professionally, Mike’s acumen is respected by free speech badasses like Popehat and Marc Randazza.
Mike Cernovich entered the Gamergate fray in earnest when he got in contact with Eron Gjoni (the ex-boyfriend of game developer Zoe Quinn), whose novella-length screed against Quinn’s personal life gave ample fodder to the anti-progressive mob in the video game world that had been demanding her head since 2013. Gjoni’s posturing was that of the innocent whistleblower, airing his personal grievances against an ex who he felt had wronged him. Behind the scenes, however, he was engaging with and directing the mob that eventually coalesced as Gamergate, which formed under a hashtag coined by conservative actor Adam Baldwin in reference to a conspiracy video that had been spawned from Gjoni’s revenge post.
Gjoni had designed the post to go viral and inflict as much damage as possible against Quinn. He enlisted the mob that would later become Gamergate to do most of his dirty work for him, hiding behind the First Amendment and laundering all responsibility for the nightmare Quinn was then forced to endure. Gamergate took his manifesto and added a batshit line of quickly-debunked professional intrigue to disguise their motivations for trying to ruin her life, turning an embarrassing act of depraved, self-righteous sociopathy into the game industry shitstorm of the decade. Each decisive defeat exposing their true motivations, they continued to spin new and more desperate angles of purported relevancy to their crusade, with Gjoni’s blessing and support fueling them all the while.
Understandably, Quinn soon after filed for an abuse prevention order against Gjoni, who remained dead-set on trying to ruin her life, even creating his first Twitter account to inject himself into conversations with her friends and taunt her during the apex of the harassment. He had gone so far as to feed Gamergate by calling around to hotels Zoe had stayed at (hoping to corroborate spurious claims of infidelity), all while claiming he was trying to “calm them down.”
Given the extreme circumstances of Gjoni’s malicious behavior, his gaming of plausible deniability, and the violent rhetoric of the horde he whipped up, the provisions of the protective order included clauses ordering him to cease any broadcasts of Zoe’s personal information (a tactic he used during multiple AMAs with Gamergate to chum the waters) and cease public support of Gamergate — a movement explicitly referred to by the presiding judge in the protective order as a “hate mob.”
This became inconvenient for Gjoni, who was planning a “sequel” to his first post to more effectively rain hell down on Zoe. It was at this point that Cernovich got involved, contacting Gjoni to provide counsel for what he perceived as a violation of Gjoni’s First Amendment rights to orchestrate hellfire and harass the shit out of his ex.
It’s not uncommon for First Amendment litigators to take on unpopular causes to vindicate freedom of speech, even causes as caustic as Gamergate. Cernovich’s motivations ran deeper; Since 2004, his personal blog on law, Crime & Federalism, had taken an increasingly hostile stance against women and feminists. Gamergate was the perfect cause célèbre for Mike. In one stroke, he could both become infamous within an otherwise clueless movement based on his legal credentials, and further his social agenda with a new audience of frothing young anti-progressives.
Casual denigration of the discipline you represent seems to be a common thread among the heroes of Gamergate, and Mike Cernovich is no exception; a good look for free speech advocacy would quickly take a backseat to the allure of notoriety for himself. First Amendment law would become a cudgel that Cernovich wields — with exception — to try and destroy lives, if only to give him more room to beat his chest.
A Means to an End
It’s hard to know where to begin with Mike Cernovich; his Twitter history is replete with truly gag-inducing expositions about women, trans people, the overweight, rape, and any other social topic which might require even a mote of nuance or human decency. His use of his legal credentials and standing in the First Amendment community, however, requires further examination. In the case of individuals who cross Gamergate, he is quick to drop legal or criminal threats more becoming of a paper tiger than an attorney of his supposed stature. Gamergaters eat up every last drop with aplomb.
One could certainly argue that Cernovich is in it for the e-peen; to lord over a sad little fiefdom of Internet harassers who will reach and claw for anyone to take them seriously beyond the clear mark of evil they lend to the movement through individual harassment and threats, all the while purporting to be above the fray.
That is not to say, however, that Mike himself does not lend his muscle to that avenue of inquisition as well. Cernovich seems to be of the strain of First Amendment lawyers who take to the craft simply to see how far they can legally push the boundaries of fair play and common decency, with Mike himself threatening to use legal channels to intimidate and harass any significant detractor.
This tactic and mindset is nothing new for Mike Cernovich. As far back as 2010, he was doxxing people (see: screenshots to the left) on his Crime & Federalism blog — usually those who he felt had wronged him in some way — and often going above and beyond the duty of a criminal defense attorney to protect a client (odious as they might be) by actually defending the substance of what they are doing. His notion of the act is one of pragmatism in the midst of what he considers to be Internet warfare; when his opinions dictate his skin in the game, nothing is off-limits in the ensuing firefight.
Mike will also occasionally throw his financial resources behind asinine conspiracy theories, such as an investigation into Gawker Media for hiring “Weird Twitter” personalities to astroturf against Gamergate. If Gamergate has so much as a sneaking suspicion about or grapevine allegation against someone, Mike is there to back it up with dollars, legal gesticulation, and hearty endorsement of even fringe theories by the movement.
When Cernovich is not targeting individual people, he lends his stature as a First Amendment advocate generally to Gamergate as a morale booster, typically in the form of endorsing frivolous civil lawsuits, criminal complaints, or outright libel that, curiously, would seem to fly in the face of basic tenets within First Amendment advocacy circles. Let’s take a trip through a sampler platter of Mike’s online gymnastics, with some case studies for thought:
Mike Cernovich and the IGDA
In November, the International Game Developers Association linked to Randi Harper’s “GGAutoblocker”, a tool that identifies and pre-emptively blocks Gamergate supporters based on who they follow (including Mike himself, who had become a Gamergate figurehead at that point), as an anti-harassment resource. Randi and her tool had been in Gamergate’s craw for a few weeks at that point, making her a major target of Gamergate’s harassment and doxxing, some from Mike himself.
Accusations of the GGAutoblocker “suppressing free speech” came at a steady clip, and one would think that a First Amendment advocate would gently explain to Gamergate that the right to free speech does not include a right to an audience. However, this would mean denying Gamergate’s rabid sense of entitlement to the lives and time of the people they demonize, a trait that anyone looking to curry favor with them would do well to pander to. And pander he did.
Randi proved herself to be a formidable target, and with only Gamergate’s cheap intimidation tactics to bolster him, Mike began to invoke his raison d’être in Gamergate’s hall of heroes: empty legal threats. In this case, against the IGDA for endorsing Randi’s tool, under the pretense of it constituting blanket defamation.
More seasoned proponents of First Amendment law, however, were less than impressed.
Any sleight against Mike Cernovich or his causes can quickly become a personal vendetta for Based Lawyer, and if compromising his commitment to free speech will make him popular with Gamergate, come hell or high water, he will find a reason to put on his litigator pants and bloviate.
It is not surprising that Mike’s cries of defamation came and went like a ship passing in the night; in fact, to date, absolutely nothing of note has come from any of Mike’s multitudinous “investigations” or filings. Those threatened with subpoenas and legal action by Gamergate’s Based Laywer appear to have nothing to fear. Mike may be a bully and a master troll, but he’s smart. For all his posturing, he seems to know that he often has no case, but this doesn’t stop him from trying to play the popular (or perhaps simply populous) side of the field when it suits him.
When actionable legal routes of attack fail him, though, Cernovich abandons his litigator’s mantle and uses his platform and standing as an authority on law to engage in professional trench warfare instead.
The Curious Case of Margaret Pless (Updated 5–1–2015)
On October 20th, Margaret Pless, who goes by the handle @idlediletante on Twitter, put together one of the first cohesive chronicles of Cernovich and his actions within the Gamergate sphere. Despite her fairly modest intentions to merely expose Cernovich for his pandering and online abuse, Pless, in an admittedly shortsighted move, included in her article an image captured from Google Street View of the address Cernovich listed as his workplace with the State Bar of California’s public index of attorneys, in an attempt to imply he was not currently working in an actual law firm.
Pless had reached out to Cernovich for review before the article went live, with no response from Mike; but in a failure of due diligence, she had not realized that Mike had listed his personal residence as the business address (a common practice for attorneys who maintain a home office).
Whether or not this could be considered a legitimate “dox,” given that information provided to the State Bar is intended to be accessible by anyone interacting with the providing attorney, most can agree that, whatever the aims of the article, it was in poor form and certainly a violation of Mike’s personal boundaries. Pless later realized this after Cernovich raised the issue on Twitter, removing the image and address from the article.
In most cases, this would be the end of the story. Not so for Mike Cernovich — he had an axe to grind, and Pless’ mistake would be his flint.
Zoe Quinn, Mike’s primary target since his first foray into Gamergate, happened to retweet Pless’ article after skimming its contents. Upon learning of Pless’ oversight, she undid her retweet. But this gaffe proved to be too juicy an opportunity for Mike to refrain from implicating Zoe in an increasingly hysterical and nonsensical snowball of accusations.
Pless responded to Cernovich’s attempt to implicate Quinn with another article. Calling him out on his seemingly at-will coupling of blame to whatever target he saw fit to smear, Pless encouraged people to file complaints of his online harassment to the California State Bar and LA Crimestoppers, a nonprofit organization that investigates claims of online abuse and escalates them to the authorities as necessary.
Mike himself has a history of filing investigatory or accusatory reports to various levels of action groups or law enforcement for varying levels of hyperbole, so one would think this would go over about as evenly.
Mike, however, did not take Pless’ Crimestoppers or Bar Association inquests very well. Frankly, neither did his more sensible peers. Nobody, however, could foresee the extent to which these nuisance filings would be elevated in import and seriousness by Cernovich. For weeks afterwards, he couldn’t even decide which “truths” best suited his narrative; whether Zoe or Margaret had doxxed him, if a SWAT team had been sent to his house, or even what he was really angry about. His version of events and accountabilities became a quantum superposition of impossible libels.
That last tweet should come as a surprise, since if we are responsible for the acts of our friends, Cernovich could possibly be held accountable for his friend Roosh V posting photos of Margaret during their ensuing campaign of intimidation per usual. Replete, of course, with empty threats of litigation:
For Zoe Quinn, though, whose only role in the fiasco was a too-hasty and quickly-reversed retweet, Mike’s recourse came in the form of hiring a private investigator to stalk both her and her partner, Alex Lifschitz, and turn over any findings for Cernovich to use as a nuclear option.
Mike Cernovich’s PIs have been quite busy over the course of Gamergate. anyone crossing his path can apparently look forward to having a private dick rummaging through their dumpster, or simply giving their legal records to Cernovich for further harassment.
This is what Based Lawyer does best with the resources at his disposal: Using his money, private investigators, and knowledge of actionable free speech to see just how dirty he can fight, and how far he can go with his intimidation.
In his mind, the knowledge of First Amendment law is best purposed for understanding how far past the realm of good taste you can venture before you fall subject to ironclad legal definitions of “creepy stalking shitbag.” His interest in the field appears to have mutated into something entirely self-serving; when his legal acumen fails to provide a solution, he has a predilection for going after what he perceives to be easy targets. In these cases, intimidation is the means and the end. His desire to stir the shit is so dense that logic cannot escape its gravitational pull.
This density would eventually turn a coarse lump of paranoia into a sparkling diamond of willful malice.
In an article published on his legal blog, Mike made the allegation that Zoe and Margaret had attempted to murder him by having him SWATted. This is a practice in which someone spoofs a phone number and makes calls to law enforcement implicating imminent and serious danger to — or from — a particular person, with the intent of having a SWAT team descend on their location and injure or kill the target. A Bungie executive suffered this kind of harassment over the course of Gamergate, and Gamergate itself took to planning a similar operation targeting Chris Kluwe following his debate with Cernovich. In the case of one critic of Gamergate, they followed through — on the wrong target.
Mike’s claims come gussied up in the same kind of legalese and pomp as his other hot takes on case law, complete with what must pass for “research” to connect several questionable points of varying relevance, veracity, and hyperbole to his completely fabricated conclusion.
This was not a case of attempted murder; it’s not even in the same hemisphere as attempted murder. (For the curious, the actual elements of attempted murder are a specific intent to kill and a direct but ineffectual act toward accomplishing the intended killing. See, e.g., People v. McCloud, 211 Cal. App. 4th 788, 803 (Cal. App. 2d Dist. 2012).) Subject to his own standards, Cernovich would be entombed at the bottom of the Mariana Trench for the safety of the general public.
Mike would continue this mealy-mouthed crusade for weeks, grasping tightly at straws to implicate both Quinn and Lifschitz for “death threats” and implicating Quinn in an honest-to-god SWATting of an innocent person.
The people who mocked Mike for his overreaction were missing the point, of course. Even Gamergate viewed his article as performance art. Mike knew full well that his allegations of attempted murder were full of shit to bursting. Cernovich’s ultimate goal was this:
This is standard operating procedure for Mike Cernovich. He has employed these muddying tactics before — in one case, in service to his friend and peer, first amendment powerhouse Marc Randazza, though not explicitly at his behest.
Mike Cernovich would turn to this smear tactic even after Gamergate had drifted from its apogee; When Quinn was called upon to give a congressional briefing about the abuse she had faced at the hands of Gamergate and people like Mike vis-à-vis his aforementioned P.I. badgering tactics, he again responded with an asinine blog post parroting his deranged SWAT accusations. Joining those were assertions that Quinn had committed perjury (despite congressional briefings not being given under oath), that he had never stalked Quinn & Lifschitz’s address (despite boasting of his P.I.’s in-person research in Boston, and while paradoxically admitting to hiring a P.I. in the previous sentence and threatening that he had their new address in Seattle), and implications that Quinn had him targeted for murder by members of a message board that hasn’t existed since 2009. Then, in a series of rapidly-deleted tweets, he again boasted of his actual goal — littering search engines to sate thin-skinned grudges.
Mike deals in the destruction of reputations, and his intent will not be hampered for lack of raw material to work with. In his efforts at trolling or bullying, particularly against women and “SJWs,” his clear intelligence is seemingly bulwarked by his narcissism and ego. He seeks to to dominate, to control people and their names and reputations, and that is the most dangerous kind of person to park behind a bar exam.
It’s no wonder, then, that he immediately used his article to mount a more direct assault on Zoe Quinn’s livelihood:
But for all his impressive mental gymnastics, Mike’s masterstroke was received like a wet shart. Even with all his google-fu, the only other website that even paid this story a crumb of attention was Reaxxion, a pro-Gamergate website started by Mike’s associate Roosh V in a similar attempt to monetize gullible, angry male gamers. A functioning frontal lobe is all that’s needed to understand how thinly-sliced Cernovich’s narrative is, if you can even then be bothered to conduct an ounce of ancillary research.
But when legal threats and professional character assassination both fail to connect, Cernovich may desperately take one last craven avenue of bullying.
Burn the Witch
When Mike Cernovich first came to Gamergate, his pretense was to assist Eron Gjoni in fighting, on First Amendment grounds, what he considered to be an overbroad protective order filed against him by Zoe Quinn (one that Eron had taken to repeatedly breaking to further antagonize her).
Given Mike’s existing sentiments on feminism and the issues with distrust of women (especially in cases of sexual assault), it was a perfect intersection of Cernovich’s interests. But with Quinn’s pesky continued existence in the face of adversity, Cernovich would go above and beyond to make an example of her.
Affidavits in cases like Quinn’s are a matter of public record, and can be obtained by those who have the means and desire to procure copies. Cernovich obviously had the credentials and networks to get Quinn’s painlessly through perfectly legal channels, and did so in order to make them accessible to anyone with interest in Quinn’s case, all during a time when Gamergate was looking for every conceivable angle to demonize her.
There is nothing illegal about Cernovich acquiring and releasing a copy of the affidavit. Given the circumstances surrounding Zoe’s harassment at the hands of Gamergate — who, as of the time of this writing, appear to be digging around to find people she went to high school with — it may certainly be in poor judgment. It would be one thing to publish them in a dedicated forum for legal discussions or free speech advocacy.
As for Mike Cernovich’s preferred venue for commentary? Well…
Return of Kings, the Men’s Right’s Activist hub owned by none other than that old Based Lawyer mainstay, Roosh V.
Roosh himself is infamous enough in Pick-Up Artist and Men’s Rights circles to merit callout on the Southern Poverty Law Center’s digest of misogynist sites and personalities; Return of Kings publishes the kind of articles that attempt to justify the murder of women by men who felt entitled to sex; they count among their many contributers people like Matt Forney (a follower of Mike’s), who authors articles such as guides on how to beat women and get away with it. It’s a trash fire all the way down.
And they don’t exactly have a friendly history towards Quinn, either — they had used her photo in an article entitled “5 Reasons why Girls with Tattoos or Piercings are Broken.”
Mike Cernovich knew full well that Quinn had been facing persistent (and often unnervingly credible) threats of violence for months, but in line with his position on rape culture generally, took it upon himself to be the arbiter of their veracity. Adding to a horrifyingly long list of compromises to her personal safety, Quinn now had to worry about Mike acting as a legal pipeline to groups that encourage violence against women as a means to an end, and had previously singled out her in particular for derision. Legal? Yes. Reckless? Malicious? Absolutely. It doesn’t help that Mike has been personally riling up this contingent of violent sexists for weeks on end, including the author of the aforementioned article on beating women.
Gamergate naturally took to the report with the tenacity of a velociraptor, using it to further pick apart Quinn’s personal life — while conveniently glossing over details such as allegations of Eron’s physical abuse towards Quinn and his purported history of violence with loved ones.
This jarring disinterest in objective exploration of the facts underpinning his crusade against Quinn (and progressive figures generally) is unsurprising. What Mike Cernovich sees in Quinn is the same kind of deceptive she-devil that he and his followers perpetually prop up as a gender norm. He is more than willing to use whatever tools he has at his disposal, legally and financially, to vicariously sate personal vendettas from long ago — the “false rape claim” he profiles on his Crime & Federalism post from 2009 is his own.
The modern day Men’s Rights movement is comprised, in large part, of a fresh crop of angry young men who want to see people like Quinn get their overdue comeuppance for denying men the glory inherent in their warped notions of manhood — and much like the right-wing agitators who have come to recruit from Gamergate for their own ends, Cernovich seems willing and ready to become the MRA Clarence Darrow. To what further ends, we’ve yet to see, but his continued presence in First Amendment circles is certain to be his sword, and it is theirs exclusively.
Profile of a Based Lawyer (Updated 1/7/2015 with Dan Olson incident)
As has already been mentioned, Mike Cernovich is certainly smart. His methods of agitation are all perfectly legal, and perfectly sociopathic. It is growing increasingly difficult to tell which Mike Cernovich dominates his agenda: The defender of First Amendment rights, or the sexist bully who will twist the law to his own ends and notoriety. This, sadly, was not always the dichotomy — his blog, going back to 2004 as a law student, paints the picture of a far tamer, more reasonable man, interested in cases of authority figures abusing their stations, and where justice was denied to the weak. But years of unchecked bluster seems to have have corrupted him absolutely. First Amendment law is now the quasi-ethical mask Mike wears over his delusions of grandeur and petty malice for social progressives.
Certainly, his loyalty to Gamergate is unfaltering. As of the time of this writing, there have been statements from 8chan founder and Gamergate hero Frederick Brennan that he is retaining Cernovich as counsel to represent him in arbitration against Patreon, a privately owned company who recently removed 8chan’s funding page from their service upon revelation that were unapologetically hosting child pornography in violation of Patreon’s ToS (and human decency). 8chan also happens to be a major hub of Gamergate activity, having provided shelter to the horde after they were forcibly removed from other websites due to their toxicity. The removal of 8chan from Patreon came about in large part as a result of Dan Olson (@FoldableHuman) writing a harrowing investigatory report (warning: not mind-safe) on the child pornography allegations, the unsettling research for which was protected under Canadian free speech laws. One would think Gamergate would distance themselves from such evils, but once again, they proved themselves beyond parody by defending the contents of the child pornography boards rather than admit wrongdoing on the part of Brennan.
This did not stop Cernovich from trying to pander to Gamergate on the subject under the pretense of his legal credibility as a free speech advocate, even going so far as to endorse their conspiracy theory that Olson has uploaded the trove of sexualized child imagery himself, over the course of months, to somehow “frame” 8chan and Brennan (who had admitted in an interivew in the Daily Dot that he knew and approved of the content’s existence on free speech grounds). Cernovich’s free speech advocacy seems to stop at state lines (Olson is Canadian); His selective enforcement of principle is sadly predictable. For Mike Cernovich, protection of free speech stops with criticism of Gamergate, even if child exploitation must be the hill on which the battle flag is planted.
While Cernovich is remaining shifty on the situation regarding his representation of Brennan on the matter, this is hardly unexpected, as Cernovich and Marc Randazza have worked with Brennan before for his prior legal needs. And as with his other toxic associations, this kind of case may (sadly) be a natural fit for Cernovich.
Reached for comment, an anonymous California attorney had this to say about Cernovich’s conduct as it reflects on his standing as a legal professional:
The problem with Mike Cernovich is that an attorney’s bluster needs to be commensurate with his successes in the field to have any real sway. Marc Randazza gets to be a dick because he’s successful. Marty Singer gets to be a dick because he’s successful. As far as I can tell, Cernovich’s only success has been in being a dick. He regularly goes on the offensive without any real basis for it, so it’s not surprising that he’s yet to follow through on the majority of his legal threats. And that’s a big problem when it comes to representing clients, because if you have a history of bloviating without solid legal footing, nobody will take you seriously when you’re in the right. How can you provide adequate representation when a quick Google search shows that your zeal invariably boils down to mere chest-puffing? What competent opposing counsel wouldn’t immediately call your bluff?
But if there is one thing that cements Mike Cernovich’s reputation as a man who repurposes sound disciplinary understanding for his own gains, it’s this:
Please stop recommending juice fasts, Mike.
(Aurini is already all skull and bones.)