From the Palm Beach Post:
I'm not sure that cheap, plastic toys are the best illustration of the benefits of free trade, but, as this article suggests, it is one of the reasons people support it:
As I usually opt to give the kids books and clothing, the toy prices surprised me. I was a Barbie fanatic as a girl, and I remembered that they cost around $12 then. But 30 years later, Barbies cost only $6.95, unless you opt for one with a more elaborate set of accessories. Even those didn't top $20.
So I piled a few more things in the cart and continued shopping in the ensuing weeks. Tiny Hello Kitty socks for $1, a stuffed hermit crab for $4.95, glitter bouncing balls for $3 each. In the end, I had a large pile of gifts for the kiddies, even though I hadn't really spent all that much money.
"The kids should thank NAFTA Claus," I joked to my husband, Ted, as I wrapped the presents.
At the Science Po School of Law:
Sciences Po's School of Law is seeking to recruit a full professor in "international economic law" for a public‐sector teaching position.
The successful applicant will be required to teach in the School of Law and the Sciences Po undergraduate program. He/she will pursue his/her individual research activities as part of the School of Law's research team in the field of international economic law and the relations between globalization and law.
More details at the link.
I'm going to have to take a look at this more closely to figure out all the implications, but the AB said the following in today's China - Publications decision:
215. ... We note that the question of whether the introductory clause of paragraph 5.1 allows China to assert a defence under Article XX(a) is an issue of legal interpretation falling within the scope of Article 17.6 of the DSU. For these reasons, we have decided to examine this issue ourselves.
233. For all these reasons, we consider that the provisions that China seeks to justify have a clearly discernable, objective link to China's regulation of trade in the relevant products. In the light of this relationship between provisions of China's measures that are inconsistent with China's trading rights commitments, and China's regulation of trade in the relevant products, we find that China may rely upon the introductory clause of paragraph 5.1 of its Accession Protocol and seek to justify these provisions as necessary to protect public morals in China, within the meaning of Article XX(a) of the GATT 1994.
What does this mean for GATT Article XX as a defense to claims under other WTO agreements? Perhaps nothing, as the finding may be limited to the context of para. 5.1 of the Accesion Protocol. More later.
ADDED: On the question of when and whether Article XX can be a defense to claims under agreements other than GATT, paras. 229 and 230 seem to offer the most insights. However, I can't find anything definitive on how the AB would deal with this issue outside the context of para. 5.1 of the Accession Protocol. If the AB does have views on this, it has hidden them well.
Another interesting issue in the decision is the use of arguendo assumptions as part of the reasoning. In paras. 209-215, the AB criticized the Panel's decision to (1) assume that Article XX applied and then (2) consider whether the measure fell under Article XX(a). After rejecting the XX(a) defense, the Panel never addressed the applicability issue. By contrast, instead of avoiding the issue in this way, the AB (as noted above) addressed the applicability of Article XX right at the outset. This approach to arguendo assumptions appears to be in contrast to what the AB itself did in the Shrimp (Thailand) / Customs Bond case (see paras. 310 and 319).
I want to go back to the Staiger/Sykes paper on Intenational Trade and Domestic Regulation that I mentioned a little while ago. At the end of the paper, they present a hypothetical set of facts, based (somewhat) on the EC - Hormones case, which I think provides a good illustration of the boundary between discriminatory measures and non-discriminatory measures that affect trade. Here is their description:
The regulation concerns the intensity with which cows are treated with hormones as part of the production process: we can think of increases in hormone treatment as leading to increases in the amount of beef production per acre of pasture land, and hence as leading to outward shifts in the supply curve of beef. Assuming that individual consumers are unaware or unconcerned about any health risks associated with hormone-treated beef, if the beef industry is unregulated worldwide then there will be an optimal level of hormone treatment that minimizes the cost of beef production, and let us assume that this level is independent of total production.
Now consider the possibility that the home country imposes a non-discriminatory regulation amounting to a total ban on the domestic production and importation of hormone-treated beef. This regulation will not effect the position of the home demand curve for beef (since by assumption consumer demands are not sensitive to the hormone content of the beef they consume), but it will lead to a reduction in global demand for hormone-treated beef and thus to a drop in its world price (assuming that the home country is "large" in economic terms, as in our model). Foreign producers who wish to continue to sell to the home country must now shift at least in part to the production of (higher cost) hormone-free beef. They will be willing to do so in a competitive market as long as the equilibrium price of hormone-free beef sold to the home country is just high enough to cover the additional marginal production cost. Note, however, that because the world price of hormone-treated beef has fallen, the price of hormone-free beef exported to the home market in equilibrium -- which is the price of hormone-treated beef plus the cost of regulatory compliance -- will rise by less than the cost of regulatory compliance. The home country will enjoy whatever benefits flow from compliance with the regulation, but will have externalized some of its cost. This is the regulatory cost-shifting mechanism that is at the heart of our paper.
First off, note that the authors describe the ban as "non-discriminatory." In a sense, it is. It does not explicitly single out foreign or domestic products. Rather, it applies to all products.
However, as they note, there will be a cost to complying with this regulation, some of which will be borne by foreign beef producers. The question I would ask is this: How are the costs broken down as between foreign producers and domestic producers? I see three possibilities:
1) relatively more are borne by foreign producers
2) it is roughly equal as between foreign and domestic producers
3) relatively more are borne by domestic producers
(The "relatively more" and "roughly equal" I have in mind are on a per producer basis).
If it is the first one, then arguably there is discrimination here. Obviously, this depends in part on how you define discrimination. But if you accept that disparate impact is a relevant factor for finding discrimination (there may be other factors as well), there is a good case that the measure is, in fact, discriminatory.
A key issue in this regard is, where was most of the hormone-treated beef being produced prior to the ban? If it was disproportionately a foreign product (e.g., 80% of foreign beef production was hormone-treated, whereas only 10% of domestic beef production was hormone-treated), then there will be a disparate impact.With the second two situations related to the cost breakdown, by contrast, there is pretty clearly no disparate impact (although there may be some people who would find discrimination in spite of this, under one theory or another). On the other hand, there are still costs borne by foreign companies (and thus an impact on trade). The question is, how should measures that have an impact on trade, but are non-discriminatory, be dealt with under trade rules? Not any easy question to answer, and there are probably many different views.
Over at vox, Pravin Krishna and Mine Z. Senses explain how trade can negatively affect income:
In recent research (Krishna and Senses 2009), we have studied a different dimension of the labour market experience and focused on the effect of increased trade on the risk to income (the variance of unpredictable changes to income) experienced by workers in the US.
Our results suggest that increased import penetration has a statistically and economically significant effect on labour income risk in the US manufacturing sector.
Alas, while it would be nice if trade was good for everyone, there are losers. It's useful, I think, to acknowledge this and come up with appropriate responses, as the authors do:
Our finding of economically significant negative effects through the income risk channel does not suggest that the gains from trade are negative overall. Therefore, this research should not be viewed as a call for protection, or support for anti-globalisation arguments. Instead, our results indicate that the income risk channel should be considered seriously when evaluating the costs and benefits of trade and trade policy reform. One implication from our findings is to emphasise to policymakers the need for a social safety net to insure workers against the risks of increased exposure to trade.
Low-cost imports of nutcrackers pose a risk to the age-old woodcraft of eastern Germany's Erzgebirge region, famous for its Christmas ornaments. The Chinese-made replicas may increasingly look like the real thing -- but don't try cracking a nut with them, warns Germany's chief woodcarver.
The German nutcracker -- the bearded, wood-carved soldier who stands to attention in households around the world at Christmas waiting to bite the shells off walnuts -- faces growing competition from cheap Chinese copies that are threatening eastern Germany's centuries-old woodcraft tradition, the industry's leader has warned.
Few other manufacturers in Germany dare to compete with the delicately carved and painted Erzgebirge products. But Chinese-made replicas have been appearing on Christmas market stalls in recent years at a fraction of the price, and they're getting so good that the untrained eye can't tell the difference. Dieter Uhlmann can, however. He's the chairman of the Association of Erzgebirge Craftspeople and Toy Manufacturers.
"Often you'll find Chinese nutcrackers can't actually crack nuts, they'll fall apart if you try," Uhlmann told SPIEGEL ONLINE. "I know most people just use nutcrackers for decoration but they should be able to do their job. It's hard to tell the difference between Erzgebirge and Chinese-made with smaller products, but it's quite easy with the bigger, more complex ones because they don't work as well."
Four Times Cheaper
At a Christmas market along West Berlin's Kurfürstendamm boulevard this week, one stall was selling imported pyramids for around €30 -- about a quarter of the price of an Erzgebirge pyramid. The figures were a little more crudely carved and painted and were covered in an unappealing shiny varnish -- but at a distance of a few meters, it was hard to tell the difference.
Uhlmann said imported replicas are squeezing sales of Erzgebirge products which have been falling gradually since 2002 and are set to reach some €50 million ($73 million) this year. The industry consists of some 300 small firms, many of them family-run or one-person workshops.
Uhlmann declined to give a forecast for business this year but said profits in the sector were generally under pressure from rising costs and falling sales. Chinese imports are here to stay, he said. "There's no point fighting things that can't be fought. We've just got to raise our profile and highlight our strengths."
I like his attitude, although I wouldn't be too surprised to see an anti-dumping case filed at some point, given the low prices and economic harm mentioned in the article.
According to Patrick Thomas and Tom Barry, he is dumping, not to mention violating IP rules, destroying the environment, using genetically modified reindeer and abusing his labor.
I can recall talking with a number of people about the issue of whether a subsidy may exist where the financial contribution goes to one entity, but the benefit is to another. It appears that this issue has come up in the DS379 dispute. Here's a question from the panel to the U.S., and the U.S. response:
35. (To the United States) Please react to China’s argument at the second substantive meeting that there is no support in WTO jurisprudence for the proposition that a subsidy determination may be based on a finding of financial contribution to one entity, and of benefit to another entity, without a prior finding that the first entity received a benefit.
103. China is incorrect. As the Mexico – Olive Oil panel emphasized, a pass-through analysis is not required any time “there is any arms’-length transaction between unrelated companies in the chain of the production of an imported product subject to a countervail investigation. . . .”140 Indeed, paraphrasing the findings of the Appellate Body in US – Countervailing Measures, the panel noted that, “under Article 1.1(b), a benefit might be received by different recipients, . . . the recipient of the benefit might be different from the recipient of the financial contribution, and . . . a subsidy can be bestowed directly or indirectly, and in respect of production, manufacture or export of a product.”141 “In other words, it is not necessary to identify the particular recipient or recipients of the benefit and the particular manner in which a subsidy is bestowed in order to determine that a benefit has been conferred, and that therefore a subsidy exists, within the meaning of Article 1.1(b).”142
104. As the United States has explained,143 in the investigations China challenges, Commerce determined, in accordance with SCM Article 1.1, that China made a financial contribution (i.e., a provision of a good) to the trading companies that purchased input products from state-owned producers.144 Commerce also found that a benefit was conferred upon producers of subject merchandise that purchased input products from the trading companies because the input products were sold for less than adequate remuneration within the meaning of Article 14(d) of the SCM Agreement.145 Commerce explained that “[f]or these transactions, the GOC’s financial contribution (provision of a good) is made to the trading company suppliers that purchase the [input product], while all or some portion of the benefit is conferred on the [subject merchandise] producers who purchase the [input product] from the trading company suppliers.”146 Thus, in these investigations, in some instances, the recipient of the financial contribution, the trading company, was different from the recipient of the benefit that Commerce countervailed, the producer of subject merchandise. This is contemplated by the SCM Agreement, as the Olive Oil panel explained.147
105. It was not necessary to measure any benefit that may have been received by the trading companies. The amount or portion of any benefit received by the trading companies is irrelevant for the purpose of determining the benefit conferred upon the subject merchandise producers. What matters is that Commerce properly identified a financial contribution and the amount of the benefit conferred upon the producers of subject merchandise. As the United States has explained,148 Commerce did so by comparing the price paid by producers of subject merchandise to the trading companies with an appropriate benchmark price. As a result of such comparisons, Commerce determined in the challenged investigations that producers of subject merchandise received a benefit when they purchased government-provided goods because the price paid for such goods was less than the benchmark price.149
106. Commerce’s analysis identified only the amount of benefit that effectively “passed through” the trading companies and was conferred upon producers of subject merchandise. Commerce’s determinations were thus consistent with the requirements of the SCM Agreement and do not raise the concerns at issue in the Appellate Body’s admonition that “. . . Members must not impose duties to offset an amount of the input subsidy that has not passed through to the countervailed processed products.”150
It's the U.S. first written submission in the U.S. - AD Measures on Carrier Bags (DS383) case, related to zeroing. It's five paragraphs long. Here's the fifth and final paragraph:
5. The United States acknowledges the accuracy of Thailand’s description of the Department of Commerce’s use of “zeroing” in calculating the dumping margins for the individually investigated exporters whose margins of dumping were not based on total facts available. The United States recognizes that in US – Softwood Lumber Dumping the Appellate Body found that the use of “zeroing” with respect to the average-to-average comparison methodology in investigations was inconsistent with Article 2.4.2, by interpreting the terms “margins of dumping” and “all comparable export transactions” as used in the first sentence of Article 2.4.2, in an integrated manner.7 The United States acknowledges that this reasoning is equally applicable with respect to Thailand’s claim regarding the individually investigated exporters whose margins of dumping were not based on total facts available in the investigation at issue.
I've blogged about Dani Rodrik and policy space before. He is now making similar points related to the specific case of China, arguing that China's currency undervaluation is a substitute for the protectionist policies it can no longer undertake as a result of joining the WTO:
Let's put aside the question of whether industrial policy is the best path for economic development. Assuming it is, how much does the WTO constrain this? My understanding has always been that the GATT/WTO allows a certain amount of protection, but simply tries to shift as much protection as possible to transparent methods such as tariffs, and away from harder to detect internal measures. So how high are China's tariffs? I'm sure there is a more precise answer than this, but here's what I see in the press release related to China's accession in 2001:
It seems to me that, in its WTO accession terms, China was able to maintain fairly high tariffs on the products it considered important (a high of 65% for agricultural products and 47% for industrial products). Aren't these high enough for it to undertake an effective industrial policy?
I have not seen much written about the U.S. tariffs on Chinese tires since the consultations request was filed. We are now on to the next stage, though, as China has just filed its panel request. At first glance, the main differences between the requests are that the panel request adds a GATT Article II (tariff concessions) claim to the earlier Article I (MFN) claim; and it drops one of the claims under the Accession Protocol.
On behalf of Prof. Alberto Alemanno,
As the European Union is increasingly emerging as de facto global
regulator of all kinds of rules concerning the environment, human
health, and safety, risk regulation is becoming a new lens through which
to analyse the European integration process. Indeed, today the most
important and widespread form of EU regulation in the internal market is
concerned with the government of risk to individuals' health and safety.
The European Journal of Risk Regulation (EJRR) is a new international
journal that provides an innovative forum for informed and scholarly
discussion on how these risks are regulated across policy domains in
Europe and beyond. By focusing on institutional, procedural and
substantive aspects of EU risk regulation, the EJRR strikes a balance
between the interests of the practitioners, notably those increasingly
engaged in regulatory drafting and advice to the industry, and a more
theoretical focus, combining normative articles with timely
contributions on legislative and judicial developments, new literature
and relevant events. The EJRR understands itself as a truly
multi-disciplinary journal. While the central focus of the journal is
the European law regulating inter alia Chemicals (REACH), Nanomaterials,
Pharmaceuticals, Food and Feed, Cosmetics & Medical Devices, Pollution,
Climate Change, Industrial Accidents, Life-style risks anb Public Health
issues, discussion extends to other social sciences, such as inter alia regulation studies,political science, risk analysis, safety science and sociology.
CALL FOR PAPERS:
The EJRR invites submissions for the first two issues of the journal.
The editors are looking for papers that communicate new research,
business analysis and policy insights to an informed readership across
EU regulatory domains. The EJRR is expected to 'go life' in Spring 2010,
and we therefore ask that work be submitted no later than January 30,
2010 in order to be considered for issue 1. Submissions will be reviewed
on a rolling basis beginning December 10, 2009.
Please direct submissions and any questions about our Journal to:
CONTACT: Alberto Alemanno, Associate Professor of Law, HEC Paris
Please find attached a free subscription to the first issue of the
I would be grateful if you could circulate this among your contacts:
The European Journal of Risk Regulation
Carl Baudenbacher, St. Gällen University; President of the EFTA Court.
Marco Bronckers, University of Leiden; partner, VVGB
Theofanis Christoforou, Legal Service, European Commission
José Esteve Pardo, Universitat de Barcelona
Giandomenico Majone, European University Institute
Miguel Maduro, European University Institute; former Advocate General,
European Court of Justice
Jacques Pelkmans, Director, European Economic Studies, College of
Giorgio Sacerdoti, University Bocconi; former Member of the WTO
Nicolas de Sadeleer, Université Saint Louis, Bruxelles
Francis Snyder, Université d'Aix-Marseille III; London School of
Denis Waelbroeck, College of Europe, Bruges; Partner at Ashurst,
Lorenzo Allio, King’s College of London
Alessandra Arcuri, Rotterdam Law School
Lukas Bergkamp, Hutton & Williams
Enrico Bonadio, University of Abertay Dundee
Susana Borras, Copenaghen Business School
Morten Broberg, University of Copenaghen
Justo Corti Varela, Instituto Universitario de EstuDirk Detken, Head Legal Office, European Food Safety Authority
Mary Footer, University of Notthingam
Candido Garcia Molyneaux, Covington & Burling
Minna Heikkila, Head Legal Office, European Chemical Agency
David J. Hornsby, University of the Witwatersrand
Sebastian Kraphol, Bamberg University
Mihail Kritikos, DG Research, European Commission
Bettina Lange, Oxford University
Ragnar Losfedt, King’s College of London
Stéphanie Mahieu, European Court of Justice – Université de Louvain La
Anne Meuwese, Tilburg University
Sara Poli, University of Tor Vergata, Rome
Andrea Renda, CEPS, Luiss University
Reinhard Quick, Head of VCI's Liaison Office Brussels
Claudio Radaelli, Director, Centre for European Governance, Exeter
Vincenzo Salvatore, Head of Legal Office, European Medicines Agency
Olivier Salvi, Ineris
Colin Scott, University College Dublin
Stijn Smismans, Cardiff Law School
Alessandro Spina, EMEA
Geert Van Calster, KU Leuven
Maria Weimer, European University Institute, Fiesole
Jonathan Wiener, Duke Law School
Alberto Alemanno, Editor-in-Chief
Peter Kugel, Associate Editor
My post on the WTO-legality of an import ban on nuclear waste generated a fair amount of discussion (including a reference to the movie Back to the Future!), so I thought I'd follow-up with this quote from Florida Rep. Cliff Stearns, who explains his opposition to the import ban as follows:
"I do believe that if U.S. nuclear companies are to participate in the global nuclear services market and compete effectively with foreign-owned companies, they must simply be able to manage and dispose of the low-level waste incidental to their work and subject to NRC's already strict regulations and requirement. . . I'd like to create jobs. I hope we cannot erect new trade barriers that put our own employers and workers at a competitive disadvantage, which I think simply this bill would do."
(With apologies to Edwin Starr.)
Today's FT has an editorial expressing fear that border taxes in relation to carbon content, if implemented by jurisdictions like the U.S. and E.U., would start a trade war. The FT thinks it's dangerous and dumb to risk trade war. The FT, probably rightly, predicts a lot of litigation. During the litigation, it would be interesting to see whether Article 23 DSU could suppress retaliation and escalation. After litigation concludes, it would be interesting to see whether illegal measures are withdrawn.
But my main question is whether throwing down the border tax gauntlet would be such a bad idea. If the U.S. and E.U. are able to avoid a protectionist level of border taxes, and come up with something that is objectively defensible, perhaps unilateral action could disturb the equilibrium of inaction. Unilateral action might promote multilateralism, as occurred in the establishment of the TRIPS and the DSU in response to the U.S. Special 301 and Section 301 laws. Now, especially with respect to TRIPS, we might find the distributive consequences unattractive, and the distributive consequences of coercing China and India through border taxes might be equally unappealing. But I am more sanguine than the FT that a true trade war might be avoided even if the U.S. and E.U. move to border taxes, and I wonder what else that is politically feasible could cause China and India to contribute to a solution. It looks as though without a contribution from India and China, it will be difficult to get much of a contribution from the U.S., and the dominoes fall from there.
Interestingly, the FT concludes by suggesting that as long as border taxes are only a threat they might be OK. However, the distinction between a trade war and a real war is that a real war usually results in more deaths than peace, while a trade war might actually result in fewer deaths than peace. Indeed, as Edwin Starr might ask today, "Trade war, what is it bad for?" Say it again.
An AEI event on December 11:
Throughout the long debate on health reform, policymakers have overlooked one simple fact: giving everyone health insurance will greatly increase the demand for health services. Without expanding the supply of doctors and the capacity of the health system, health reform means skyrocketing costs and long waits for care. Proposals to limit those costs by imposing price controls will have the perverse effect of making medical practice less attractive, widening the gulf between patient demand and the system's ability to supply services. Dropping the barriers to international trade in medical services could help the U.S. health system cope with the new demands created by health reform. Some 750,000 Americans went abroad for health care in 2007, taking advantage of services that can be 10 percent of the cost of equivalent care in the United States. One study estimates that at least $1 billion could be saved every year if more Americans took advantage of less expensive offshore care.
A distinguished panel of experts will discuss the prospects and barriers to expanding international trade in medical services. Panelists include Jagdish Bhagwati, professor at Columbia University and senior fellow at the Council on Foreign Relations; Aaditya Mattoo, lead economist of the Development Research Group at the World Bank; and Dean Baker, codirector of the Center for Economic and Policy Research. AEI's Joseph Antos will moderate and participate in the discussion.
From Daniel Gros over at vox:
The Commission has estimated that a carbon price of around the €40-50 per tonne would be required to reach the EU’s 2020 commitments. This would imply, at current exchange rates, about $50-70 per tonne. This might be too high for the US, where $30-$40 per tonne has been estimated to be the politically feasible limit. At $40 (€30) per tonne, a border carbon tax on Chinese exports (to the EU) would be a bit more than two times $40 per $1,000 of exports, or approximately 9% on average. Rates would be much higher for energy-intensive products and lower for most others.
Of course, these calculations are based on relative carbon intensity of a country's products. If per capita emissions were being used, the tariff would go the other way (I have not seen specific estimates, aside from this: http://worldtradelaw.typepad.com/ielpblog/2009/10/talking-tough-on-carbon-tariffs.html)
To make this more palatable to developing countries, he proposes the following:
A massive increase in EU tariffs against developing-country exports would certainly make them feel disadvantaged. While global welfare would increase, they might lose. However, there is an easy way out of the political problems. The EU could simply promise to use the proceeds from the tariff to help poorer exporting countries reduce the carbon intensity of their economies.
Now this is interesting. The EU could tax Chinese/Indian imports and then use these taxes to build, say, wind farms in China and India. I wonder if developing countries would go for that.
The other day, I did a short post on a possible U.S. ban on imports of nuclear waste (the importation would be for processing and disposal here in the U.S.). I didn't say anything about the legal issues, because I thought the conclusion was clear -- the ban would be justified under GATT Article XX. However, somebody emailed me with a suggestion that perhaps things were more complicated, so I'll put it out here (briefly) for the audience to comment on.
First off, it's pretty obvious there is a violation here. It's an import ban, which violates GATT Article XI:1. So let's move to GATT Article XX.
For those of you wondering, as I have been, when we might see a report in the EC - Aircraft (DS316) case, the Panel has given some guidance:
The Panel issued its interim report to the parties in September 2009, and is now in the process of finalizing its report. The Panel expects to complete its work before the end of April 2010.
This blog is mostly about international economic "law and policy," as its title indicates. But it's also about the international economic law "community," which includes the people in it. With that in mind, I'm going to talk a bit about one of these people, my good friend and former colleague Petina Gappah of the Advisory Centre on WTO Law.
Most of us trade law types have at least a few interests outside of the field. Personally, I like playing tennis and following the Philadelphia Phillies. Well, Petina has been more productive than that with her interests. She's a writer who is now an award winning author:
A Geneva-based international trade lawyer whose poignant, humane and funny collection of stories about her home country, Zimbabwe, has impressed critics was tonight named winner of the Guardian First Book Award.
Petina Gappah became only the second short story writer to win the award in its 10-year history, the first being Yiyun Li in 2006. Gappah's collection of 13 stories, An Elegy for Easterly, tells of the lives of people, rich and poor, caught up in events over which they have little control.
The Guardian's literary editor, Claire Armitstead, who chaired the judging panel, said she was thrilled to name Gappah as winner, particularly since 2009 is the year of the short story. There had been some wonderful first books, she said, and "Petina Gappah's humane and disarmingly funny mosaic of life in Zimbabwe is undoubtedly one of the very best."
Congratulations, Petina! I wish Petina all the success in the world with her writing career, although perhaps not too much success, because then she might disappear from trade law circles and we'd never get a chance to see her.