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The concept of reification, central to this project, requires some additional elucidation before the path to sustainable critique can be cleared. Social sciences describe human-constructed realities through analogies, whose artificiality is progressively naturalized—lost to intellectual understanding and theoretical consideration—until they come finally to appear “as facts of nature, results of cosmic laws, or manifestations of divine will.” 50 Different moments in theorizing, as chapters 3 through 5 show, set out to undo or criticize an existing theoretical or political common sense, combining long-standing fact-value traditions (captured in IR by the traditions of realism, liberalism, and the like but drawn from normative political-theory traditions of much older vintage) with particular methodological approaches to produce paradigmatic research programs. Each does so by positing its own particular reifications in distinction to others; over time, these, too, are lost to intellectual understanding and theoretical consideration. Assumptions that emerged in dynamic interaction with and in response to a changing political and scholarly reality take on the qualities of received wisdom. They thus come to be conflated with the world they were meant to describe—“merge[d] with the world of nature,” as Berger and Luckmann put it, equated with things-in-themselves that cannot disclose themselves otherwise. 51 Th e term reifi cation itself has a complicated heritage. Its usage here derives from Karl Marx’s notion of commodity fetishism and from the subsequent work of Hungarian Marxist theorist Georg Luk á cs. 52 Yet as Gillian Rose has observed, the term has “no canonical source, and has become prominent and debased as much by insinuation as by scrupulous examination.” 53 Certainly, contemporary social-scientifi c and social-theoretic usages vary widely. Deployed loosely, it oft en appears as a synonym for a class of logical confl ations akin to Alfred North Whitehead’s “fallacy of misplaced concreteness.” 54 Yet that looseness, Timothy Bewes has recently noted, has an ironic eff ect: it renders the term “susceptible to the problem it denotes”; reifi cation takes on precisely the sort of pseudoscientifi c agency that its promulgators ostensibly meant to critique. 55 Here, reification is construed as a highly particular kind of forgetting: of the distinction between theoretical concepts and the real-world things they mean to describe or to which they refer. 56 All theory—including this one—relies to some degree on such forgetting, as it inheres in the particular ways in which the former can, and cannot, adequately describe the latter. Yet that forgetting has a distinctive chain of potential analytical and normative effects. The sanctity of sentient life is frequently an unintended casualty of it; left to its own devices, reification “thingifies” sentient beings, blurring the moral separations traditionally made between them and inanimate objects. Th e same intellectual process that transforms a stand of trees into lumber or a hilltop into coal—that is, transforms them into fungible commodities or factors in economic production—can transform human beings as well: men and women become labor in economic terms or force assets in military-strategic ones. Th e “instruments or means of thought,” initially meant to pave the road to human betterment, thereby “become independent of the purpose of thought.” 57 This process of forgetting has distinctive consequences for IR, given the vocation earlier described for it. Theory’s reliance on reification suggests that theorists are not merely describing the world when they fit complex events into paradigmatic research traditions. Rather, they are redacting it. As King, Keohane, and Verba observe: Even the most comprehensive description done by the best cultural interpreters with the most detailed contextual understanding will drastically simplify, reify, and reduce the reality that has been observed. . . . No description, no matter how thick . . . comes close to capturing the full “blooming and buzzing” reality of the world. 58 Given the proximity of IR’s policy analyses to the use of extreme and deadly force, this reliance upon “drastic simplification and reduction” presents a dilemma. 59 Without it, there would be no hope of creating practical knowledge, no hope of intelligently stewarding a world that presents real and abiding challenges. 60 Yet with it, one risks naturalizing the ontological assumptions of particular fact-value traditions and their derived scholarly research programs, such that these take on an “objective” imprimatur. Theory, it would seem, can live neither with reifi cation nor without it. Some mode of managing or checking its effects must therefore be found, if IR’s historic vocation is to be made good upon.

The possibility of objective social inquiry in the form of explanatory critique has been defended through philosophical argument about the basic nature of the world and of knowledge (ontology and epistemology). In practice, however, there will always be various constraints which undermine or condition the realisation of this possibility. This is because producing knowledge is a social practice which is not purely cognitive, and is thus subject to a range of non-cognitive as well as cognitive determinations or influences: social science always only happens in a context which is at once always understood, preconceptualised, and codetermined by non-cognitive factors too. So that, on this stance, social theory appears, at its best, in the form of conditioned critique. As critique, it presupposes and engages with those preconceptualisations; as conditioned, it is subject in its genesis, reception and effect, to extra-scientific, extra-cognitive and non-ideational, as well as scientific, cognitive and ideational, determinations (whose critical understanding is itself part of the business of theory). This is of course an implication of historical materialism. (Bhaskar 1986: 170). Different kinds of constraint can be distinguished analytically (in practice such constraints occur simultaneously or in combination). Like any social practice, the activity of producing knowledge is simultaneously a social and a material practice, subject to both social and material determinations and constraints. The discussion here focuses mainly on the social factors constraining the production of objective knowledge. The significance for knowledge production of the enormous international inequalities in material conditions is a very important area of inquiry, but cannot be included within the scope of the current discussion. What kinds of social factors might constrain the process of social inquiry into international relations? One set of constraints arise from the ways in which our location in society influences what we know about society. The kind of objective knowledge being defended here is that which provides a more adequate account of the social world, and, in doing so, provides an implicit or explicit critique of prevailing ideas (ideologies) which misrepresent the social world. Although considerable debate within and between social sciences is conducted primarily at the level of theory or method – for example, the so-called ‘inter-paradigm debates’ in International Relations – where disagreements really matter are ultimately over how we understand and explain concrete events and conditions, and processes of change or lack of change. Here historical knowledge is crucial. Ideologies which misrepresent the world in various ways, and as such are factually wrong, are parasitic for their acceptance on ignorance of what actually is the case. This might sound very simplistic; but how many people are really very well informed about the history and current detail of social conditions in their own country or region – including, very importantly, the international or global constitution of their own history – let alone the histories of ‘other places’? 35 . There is nothing straightforward or easy about becoming well informed about concrete histories. Such an enterprise takes time; and for those unfortunate enough only to speak English, probably requires mastering a different language in the process (which, for Anglophones studying African histories and realities, for example, will probably still only be the colonial European language). We should therefore heed Engels’ observation made in the nineteenth century: The demonstration of the materialist conception even upon a single historical example was a scientific task requiring years of quiet research, for it is evident that mere empty talk can achieve nothing in this context and that only an abundance of critically examined historical material which has been completely mastered can make it possible to solve such a problem. (Engels 1859: 221) To have ‘years of quiet research’ seems a luxury today in the light of competing demands on our time from teaching, the compulsion to publish and keep abreast of disciplinary debates, not to mention family life. We should therefore also heed the advice of Aijaz Ahmad: ‘the ground reality is that there is no alternative to picking up small chunks and doing them well’ (1997: 59-60). Recognising the limits of our knowledge of substantive histories, and attempting to overcome them bit by bit, is surely always better than a false confidence in our authority deriving from lack of awareness of how little we know about the world. These constraints are relevant in all cases regardless of whether the researcher is examining their own or another society. What more specific problems arise when studying societies other than those we come from? What about for example a European IR scholar doing research about Africa – or an African scholar doing research about Europe? 36 Such questions are especially pertinent to International Relations. Given the basic importance of knowing about a place, its peoples and history, it is arguably likely that local intellectuals might be better informed about their own particular people, country or region than foreigners, especially where the question of language is concerned. There is nothing intrinsic about this however; and of course nationality / place of origin are not the only social influences on what we know. Our class position and gender are especially significant in influencing our general outlook, ‘common-sense’ understandings, core assumptions about the world, and what we know about our own society through direct experience. A variety of different social factors will combine to influence and condition the perspective of a particular researcher and thus potentially influence the knowledge they produce. However, initial influences deriving from our social position (in a particular society and in the world), once recognised, can be countered. Social position influences but does not determine the production of knowledge. We are not trapped forever to only produce the viewpoint consistent with our particular social origin or location. A commitment to objectivity in social inquiry, or what I have called ‘epistemological internationalism’, implies ’attempts to escape from the bias of one’s own subjectivity and one’s own historical place’” (Collier 2003: 137). A careful scholar from any part of the world, when studying a society other than their own, must ensure they do not assume that theoretical categories deriving from some particular historically specific process of social change can automatically be applied to the analysis of a different society with its own history; still less should the categories referring to historically specific social forms developed in one society be used as a norm with which to compare and, implicitly or explicitly, evaluate historically specific social forms of another society. Yet these are standard methodological procedures in Western social inquiry. The researcher should endeavour to find out as much as possible about the historical production and current conditions in that society from a variety of sources – by consulting people in that society, by reading literature of that society, local newspapers, and, importantly of course, by reading work produced by that society’s intellectuals. This seems so obvious as not to be worth mentioning; yet it is surprising, for example, how many Western Africanist scholars appear to pay little attention to the work of African intellectuals.. Mahmood Mamdani has criticised: Eurocentrism … has a tendency to view its object as lacking in a capacity to comprehend their own history as a step in taking the initiative to making it. While reading some of the better known Africanist works during a teaching job in the US in 1989, I was struck by how little attempt most Africanists made to read African intellectuals. For I had always taken it for granted that, should I want to study North American society, I would approach it through its own intelligentsia, through their writings, their self-reflection. Matters are different with the Africanist who tends to approach Africa as one would a zoo. For the collectivity of animals, no matter how interesting and intricate its internal organisation, has no capacity for self-reflection and self-transformation! In this sense, Eurocentrism mutilates the experience of both the West and of the rest, mythologizing the former and caricaturing the latter. (Mamdani 1995: 609).

The ‘common-sense’ view pervading recent discussions of epistemology, ontology and methodology in IR asserts that objectivity implies value-free neutrality. However, objective social inquiry has an inherent tendency to be critical, in various senses. To the extent that objective knowledge provides a better and more adequate account of reality than other ideas, such knowledge is inherently critical (implicitly or explicitly) of those ideas. 30 In other words critical social inquiry does not (or not only) manifest its ‘criticalness’ through self-claimed labels of being critical or siding with the oppressed, but through the substantive critique of prevailing ideas. Objective social knowledge constitutes a specific form of criticism: explanatory critique. The critique of dominant ideas or ideologies is elaborated through providing a more adequate explanation of aspects of the world, and in so doing exposing what is wrong with the dominant ideology. This may also entail revealing the social conditions which give rise to ideologies, thus exposing the necessary and causal relation between particular social relations and particular ideological conceptions.

In societies which are constituted by unequal structures of social relations giving rise to unequal power and conflicting interests, the reproduction of those structured relations is in the interests of the powerful, whereas transformation of existing structured relations is in the interests of the weak. Because ideas inform social action they are casually efficacious either in securing the reproduction of existing social relations (usually as an unintended consequence of social practice), or in informing social action aimed at transforming social relations. This is why ideas cannot be ‘neutral’. Ideas which provide a misrepresentation of the nature of society, the causes of unequal social conditions, and the conflicting interests of the weak and powerful, will tend to help secure the reproduction of prevailing social relations. Ideas which provide a more adequate account of the way society is structured and how structured social relations produce concrete conditions of inequality and exploitation can potentially inform efforts to change those social relations. In this sense, ideas which are false are ideological and, in serving to promote the reproduction of the status quo and avoid attempts at radical change, are in the interests of the powerful. An account which is objective will contradict ideological ideas, implicitly or explicitly criticising them for their false or flawed accounts of reality. The criticism here arises not, or not only, from pointing out the coincidence between ideologies and the interests of the powerful, nor from a prior normative stance of solidarity with the oppressed, but from exposing the flaws in dominant ideologies through a more adequate account of the nature and causes of social conditions 31 .

Clients seeking trademark registrations often ask how much use of a mark in interstate commerce is needed for success. Earlier this month the Federal Circuit answered that question when it reversed a decision by the Trademark Trial and Appeal Board (“TTAB”) that cancelled a trademark of a church in Zion, Illinois at the behest of apparel giant Adidas.

Trademark registration applicants submit evidence of “bona fide use of the mark in interstate commerce,” which generally means commercial use of the mark between two states. The bona fide use must be in the ordinary course of trade, and not a transaction made merely to reserve a right in a mark.

Today, five prominent national organizations—the Biotechnology Innovation Organization, the Cystic Fibrosis Foundation, the Infectious Diseases Society of America, the Partnership to Fight Infectious Disease, and The Pew Charitable Trusts—issued the following statement in response to the reintroduction of the Pioneering Antimicrobial Subscriptions to End Upsurging Resistance (PASTEUR) Act:

The reintroduction of the bipartisan PASTEUR Act by the U.S House of Representatives and the Senate is a critical step forward to address the antimicrobial resistance crisis that threatens the public health and U.S. national security and preparedness. We applaud the efforts of Senators Michael Bennet (D-CO) and Todd Young (R-IN) and Representatives Drew Ferguson (R-GA) and Scott Peters (D-CA) to keep this vital issue a key priority for congressional action this year.

The PASTEUR Act (H.R. 8920 and S. 4760), a bipartisan bill cosponsored by Sens. Michael Bennet (D-Colo.) and Todd Young (R-Ind.) and Reps. Mike Doyle (D-Pa.) and Drew Ferguson (R-Ga.), would implement a version of this model.

Under the PASTEUR Act, the federal government would create market incentives for the development of lifesaving antimicrobial drugs. Developers would be paid contractually agreed-upon amounts annually, for a duration ranging from five years up to the antimicrobial’s patent life. The subscription contract eligibility and value would be based on the clinical need and novelty of the drug.

A U.S. Supreme Court decision Monday granting presidents broad immunity from prosecution gives those leaders the power to commit crimes under the guise of official action, posing a direct threat to democracy and the rule of law, UC Berkeley scholars said. 

In a 6-3 ruling, the high court’s conservative majority found that the nation’s chief executive cannot be held legally liable for actions taken within the scope of official, core constitutional duties. Further, the justices ruled, courts cannot explore a president’s motives when assessing whether a president had broken the law. 

Under APRA, similar to CCPA/CPRA, covered entities must establish, implement, and maintain data security practices that are appropriate to the entity's size, the nature and scope of the entity's data practices, the volume, nature, and sensitivity of the data, and state-of-the-art administrative, technical, and physical safeguards. The legislation provides a list of specific practices that covered entities must follow. For example, covered entities must routinely identify and assess any reasonably foreseeable risk to each system maintained by the covered entity and must take preventative and corrective action to mitigate any such risk.

Enforcement and Penalties

Will the U.S. finally join most developed nations and pass a comprehensive federal privacy law? Some believe this may be the year that the U.S. does just that.

Calls for passage of a comprehensive U.S. federal privacy law have come not just from privacy activists – many in industry want it as well. The challenges of complying with the current labyrinth of state privacy laws has caused significant frustration among many businesses, leading to complicated compliance programs, unpredictability, and friction in developing a “one size fits all” approach to privacy in the U.S. Further, organizations have had to struggle with awkward consumer relations where privacy rights often depend upon an individual’s state of residence. While a federal comprehensive privacy law will certainly bring more businesses into the fold and require additional compliance measures for most covered businesses, the flipside is that a federal privacy law could pave the way for businesses to streamline and standardize their U.S. approach to privacy.

Our study has several limitations that open up room for future research. First, we have a survivorship bias in our data since we are not able to identify those social startups that failed during our observation time. Further studies could therefore expand the literature on social startup survival and examine whether social startup trademarking also reduces the likelihood of failure. Second, our results might suffer from omitted variable bias. Since prior research shows that social startups that receive early external funding have higher employment growth rates and greater economic performance (e.g., Cacciolatti et al., 2020; Rey-Martí et al., 2016), this might be a variable to explain some of our trademark effects. For example, it could be the case that trademarking increases the likelihood of external funding, which then increases employment growth rates. Therefore, we encourage future research to investigate this mediation relationship since we were not able to collect funding rounds of social startups within their first three years of existence. Furthermore, future studies could use further proxies for the economic and sustainability outcomes of social startups. While the number of created jobs is an established growth parameter (e.g., Henderson, 2002; Lall and Park, 2020), research thus far lacks quantitative evidence on the sustainability outcomes of social startups. Since our proxy of sustainability outcomes of a social startup is an indirect measure, we encourage further research to replicate our findings based on a more direct measure of sustainability outcomes (e.g., using a survey approach). Such a study would allow a more detailed distinction between different SDGs and their achievements. From the perspective of trademark research, such a study would help to clarify the underlying mechanisms of the relationship between IPRs and SDGs. Third, our findings relate to German social startups, which reduces the generalizability of our findings since sustainable entrepreneurship has been proven to differ geographically (e.g., Defourny and Nyssens, 2010; Fichter and Tiemann, 2018; Kerlin, 2006). Future research should thus investigate other geographical areas, in particular, since the use of IPRs also varies between different regulatory contexts (e.g., Cohen et al., 2002; Maskus, 2000).

QUESTION: WHAT IS THE DIFFERENCE BETWEEN A CONVENTIONAL TRADEMARK APPLICATION AND AN INTENT-TO-USE (ITU) APPLICATION?

Answer: Prior to November 16, 1989, an applicant for federal registration of a trademark had to first use the mark in commerce. A so-called conventional trademark application is filed after the applicant has already used the trademark in commerce. If the mark has not yet been used in commerce, the applicant can file an intent-to-use (ITU) application, as long as the applicant has a bona fide good faith intent to use the mark in commerce. ITU applications are examined in the same manner as conventional applications, i.e., the examining attorney does a search and examines the application to determine if the subject mark of the application is likely to cause confusion in view of previously registered marks, and also considers the other statutory requirements for registration. However, before an ITU application can mature to registration, the applicant must use the mark in commerce and submit a statement with the USPTO attesting to such use. The USPTO charges a fee to receive this statement of use.

“This means that even if a business is only having a few sales, debatably meeting the new “minimal use” requirement, if they are investing heavily in advertising and putting sincere efforts to raise their sales, then they maintain the trademark.”

Maintenance is solved—CFFC vs Adidas below

However, although abandonment could be prevented through de minimis use of a trademark, the law requires such use not to be merely token defensive use but good faith use with the intention of preserving a right in a mark, which, consequently, leads to abandonment. The trademark law also allows mark owners to cease using one version of a mark in favor of a modified one without the former being abandoned as long as a similar, continuous commercial impression is derived from the first and modified versions of the same mark.

WASHINGTON—U.S. Senators Dan Sullivan (R-Alaska), Mike Crapo (R-Idaho), Steve Daines (R-Mont.), Lisa Murkowski (R-Alaska), and Jim Risch (R-Idaho) today introduced the Judicial Efficiency Improvement Act of 2023, a bill that would split the massively overburdened Ninth U.S. Circuit Court of Appeals and create a new Twelfth U.S. Circuit Court of Appeals. In addition to the split, the legislation would codify the Judicial Conference’s most recent recommendations to enhance the effectiveness of the federal judiciary by authorizing 66 new permanent district court judgeships, converting seven temporary district court judgeships into permanent posts, and authorizing two new appellate court judgeships for the Ninth Circuit.

“Non-partisan judicial commissions going back 50 years have determined the Ninth Circuit suffers from ‘serious difficulties with backlog and delay’ due to its immense size and scope,” said Sen. Sullivan. “Those deficiencies have only gotten worse with time and the explosion of growth in the American West, leaving citizens under the Ninth Circuit’s jurisdiction—including all Alaskans—with less-than equal access to justice. As a former Ninth Circuit law clerk, I saw firsthand the court using shortcuts to manage its workload. The solution—splitting the Ninth Circuit—shouldn’t be controversial. We’ve split circuits and created new ones in the past to address the changes in our country’s population. What is controversial is stubbornly maintaining the status quo and undermining millions of Americans’ faith in their own access to justice. It is time for members of Congress to put the politics aside, end the delays and shortcuts, and finally approve these critical new judgeships and a new circuit court.”

The U.S. Congress has been trying for several years now to adopt comprehensive federal legislation for privacy protection. In April 2024, a bipartisan and bicameral bill proposal was introduced in the form of a "discussion draft"1. This follows various attempts, including the American Data Privacy and Protection Act (ADPPA)2 of 2022, from which it borrows some elements. After the adoption of laws by states such as California or Illinois, Congress is aiming to take the lead and define a singular national approach that preempts state laws3 and aims to avoid a patchwork of laws. APRA also echoes the GDPR. 

Initial reactions seem rather positive4, acknowledging a significant legislative turning point and the rise of data protection. However, it is uncertain whether the law can be adopted before the end of the year given the U.S. political calendar (November elections).

USDA DC Circuit 08 – United States Court of Appeals, District of Columbia Circuit, April 29, 2008, “AKTIESELSKABET AF 21 NOVEMBER 2001 v. FAME JEANS INC (2008)", Findlaw, https://caselaw.findlaw.com/court/us-dc-circuit/1471864.html /$antiP/

Since Fame Jeans filed its application on January 9, 2004, Bestseller must establish use, either actual or constructive, before that date.7  Constructive use can arise under § 7(c), which grants priority, based on filing date, to a U.S. application or to a foreign application that was followed by a timely U.S. application under § 44(d).  Bestseller filed a U.S. application on December 6, 2004, based on its 1991 Danish registration.   It neither complied with the six-month timeliness requirement of § 44(d) nor even filed its application under § 44(d).  Therefore, Bestseller cannot demonstrate any constructive use prior to Fame's filing date.   However, Bestseller has adequately alleged actual use.   Although the complaint does not set forth trademark use to earn Bestseller rights in the Jack & Jones mark, an opposer who has made enough “analogous” use can still defeat a registration.   See Malcolm Nicol & Co. v. Witco Corp., 881 F.2d 1063, 1065 (Fed.Cir.1989) (quoting 3 McCarthy, supra, § 20:4 (1984)).

§1051(b) of U.S. Code § 1051 ND – "15 U.S. Code § 1051", Cornell Law School – Legal Information Institute, https://www.law.cornell.edu/uscode/text/15/1051 /$antiP/

(b) Application for bona fide intention to use trademark

Weinberg 17 – Peter Weinberg, 7-1-2017, "Use in commerce for federal trademark registration: the Federal Circuit slowly moves towards the Supreme Court", No Publication, https://casetext.com/analysis/use-in-commerce-for-federal-trademark-registration-the-federal-circuit-slowly-moves-towards-the-supreme-court?sort=relevance&resultsNav=false&q= /$antiP/

In Gonzales v. Raich, the Court upheld the federal prohibition of marijuana under Congress’ Commerce Clause power, even as to a medical marijuana patient who grew marijuana for her own use and not for sale or distribution to anyone.See 545 U.S. 1, 1-10 (2005). The Court explained that when “a general regulatory statute bears a substantial relation to commerce, the de minimis character of individual instances arising under that statute is of no consequence.”Id. at 17 (internal quotations omitted). The Court further explained that “[o]ur case law firmly establishes Congress’ power to regulate purely local activities that are part of an economic ‘class of activities’ that have a substantial effect on interstate commerce.” Id.; see also Taylor v. US, 136 S. Ct. 2074, 2081 (2016) (“And it makes no difference under our cases that any actual or threatened effect on commerce in a particular case is minimal.).

Rudensky 19 – Rachel Rudensky, 12-2-2019, "Unitary Design Mark Rescues a Phrase Which Failed To Function As A Trademark", Case Text, https://casetext.com/analysis/unitary-design-mark-rescues-a-phrase-which-failed-to-function-as-a-trademark?sort=relevance&resultsNav=false&q= /$antiP/

On remand, the Board first considered the question of whether CFFC’s lack of sales of any caps and minimal sales of shirts during the relevant period constituted “abandonment” under the Lanham Act. In general, Section 45 of the Lanham Act, 15 U.S.C. § 1127, provides for a rebuttable presumption of abandonment if a trademark has not been used during a three-year period. In this case, there was evidence that the CFFC sold two shirts during the relevant period. As the Federal Circuit had held, there is no de minimis test for “use in commerce.” Accordingly, the sale of two shirts was enough to overcome the abandonment claim as to shirts.

USPTO 23 – United States Patent and Trademark Office, 11-1-2023, " Adamson Systems Engineering, Inc. v. Peavey Electronics Corporation", Trademark Trial and Appeal Board, https://ttabvue.uspto.gov/ttabvue/ttabvue-92076586-CAN-51.pdf /$antiP/

Respondent tries to liken its de minimis domestic sales from 2016-2021 to Christian Faith Fellowship Church v. Adidas, where a church’s pre-registration sale of two hats bearing its mark sufficed to support registration of the mark.83 As Petitioner correctly observes, however, that case did not concern abandonment, but the scope of commerce that may be regulated by the U.S. Congress.84 Christian Faith Fellowship Church v. Adidas AG, 841 F.3d 986, 120 USPQ2d 1640 (Fed. Cir. 2016); Ahal Al-Sara Group for Trading v. American Flash, Inc., 2023 USPQ2d 79, *7-8 (TTAB 2023). Respondent’s sales to dealers in the United States and Puerto Rico fall within that scope, but from 2016-2021, fell to de minimis or zero, year to year.