ADVERTISING BOARD PRESS RELEASE REVIEW JANUARY 2024
The Advertising Board (“Board”) publishes its evaluations on advertisements made on platforms such as social media, websites, etc. through Press Bulletins every month, and imposes sanctions such as administrative fines and suspension of such advertisements.
The 341st Press Bulletin (“Bulletin”) of the Advertising Board, published in January 2024, consists of 162 decisions and various headings such as communication services, durable consumer goods and technology, cosmetics and cleaning products, unfair commercial practices, financial services, food and food supplements, health services, and disguised advertising. Within this framework, in this review study, it has been tried to include the interesting decisions in the Bulletin and especially the decisions imposing administrative fines.
Communication Services
In the review before the Board due to the advertisement regarding the right to cancel subscription published on the website of the digital content platform named TOD TV, it was stated that the consumer, who subscribed to the platform by purchasing the “Taraftar Package” based on the phrases “Cancel at any time! No commitment, unsubscribe at any time.” on the platform’s website, was told that he was told that he did not have the right to cancel and that no refund could be made.
In the evaluation, it was stated that the relevant website affected the consumer’s purchase decision regarding the free cancellation right in the promotions, that incomplete information was provided, causing confusion of meaning, that the said phrases arouse a justified expectation that the consumer who subscribes to any package can terminate the subscription at any time without penal clause and that a refund can be provided, but that the company’s practice in the opposite direction is deceptive and misleading, that the advertisements in question are unfair commercial practices[1], and Krea İçerik Hizmetleri ve Prodüksiyon A. Ş. was imposed an administrative fine of 550,059 TL and penalties to stop the aforementioned advertisements and unfair commercial practices.
Similarly, in the evaluation made upon the rejection of the cancellation request of the consumer who purchased an annual subscription based on the phrases “Cancel at any time” on the BluTV platform website, the Board concluded that the company’s practice was deceptive and misleading and that the advertisements in question were unfair commercial practices, and imposed an administrative fine of 550,059 TL and penalties to stop the aforementioned advertisements and unfair commercial practices on BluTV İletişim ve Dijital Yayın Hizmetleri A.Ş. with the same grounds.
Within the scope of the promotions made on Vodafone Youtube channel using the phrases “112 TL and Fixed Price for 12 Months” regarding the “Lean 4 GB Package” tariff from the tariffs titled “Lean Packages”, it was stated that when the consumer who wanted to benefit from the tariff in question contacted the customer representative, the price in the tariff promotion reached a total of 121 TL including all taxes. As a result of the Board’s examination, it was assessed that the use of the phrase “Fixed Price” creates a justified expectation in the minds of the consumers that the total price to be paid for the service subject to the advertisement is all-inclusive and fixed, but other financial obligations can also be collected from the consumers, therefore, the said advertisement is deceptive and misleading to the consumers, considering the perception level of the average consumer, the said advertisement does not reflect the reality, causes consumer victimisation and is contrary to the principles of fair competition, and Vodafone Telekomünikasyon A. Ş. was imposed a penalty to stop the aforementioned advertisements.
Consumer Durables and Technology
“9 Month Instalments for Advance Price” made by Teknosa on its website
In the examination carried out by the Board within the scope of the advertisements Although the advertisements regarding the “Apple MacBook Pro M2” branded computer offered for sale on the company’s website contain the phrase “9 Month Instalments for Advance Price”, 9 instalments are not made to any credit card on the payment options page, and the consumer who called the customer service regarding the issue was informed that 9 instalments are only possible with a maturity difference in the shopping credit option, Although no credit card is offered 9 instalments without any maturity difference, it has been accepted by the company that the said statement was mistakenly included on the website and therefore, it has been evaluated that there is no situation that is misleading and contrary to the principles of honest competition in the advertisements, and Teknosa İç ve Dış Ticaret A. Ş. was imposed an administrative fine of 347,148 TL and the suspension of the aforementioned advertisements.
In the evaluations carried out within the scope of the discount sale advertisements titled “11% Net Efsane Discount on Electrical Small Home Appliances”, “Philips Brand Days”, “Efsane Brand Days Madame Coco”, “Coupon Rain Deals on Mattresses”, “Super deals on best-selling petshop products” on the platform named “Hepsiburada”, the Board has assessed that the price before the discount in accordance with the Advertisement Legislation for the regulation of discount sale advertisements within the framework of certain rules and conditions, The start and end dates of the discounted sale and if the amount of the goods or services offered for sale at a discount is limited, this amount should be clearly and understandably stated, the pre-discount sale price in the said discounted sale advertisement does not comply with the “lowest price in the last 30 days” price rule, which is a requirement under the legislation, and as another issue, the date information regarding the validity period of the campaign and the amount of stock is not included in the discounted sale advertisements subject to review, in this context, it has been evaluated that the advertisements in question are misleading and deceptive to consumers, and D-Market Elektronik Hizmetler ve Tic. A.Ş. were imposed administrative fines of TRY 128 each, totalling TRY 694,256, and fines to stop the aforementioned advertisements.
Other Goods and Services
It has been determined that Obilet’s website includes promotions such as “Turkey’s most reliable bus and flight ticket platform”, “Turkey’s largest bus ticket website” and “Turkey’s Travel Website #1”. As a result of the Board’s investigations, although the company’s website includes the aforementioned promotions, the information regarding the research results containing the data that form the basis of these claims is not included in places where consumers can clearly see them, therefore, the aforementioned claims cannot be determined in a way that would enable the average consumer to evaluate them objectively, and in this framework, it has been evaluated that the aforementioned promotions are exploitative of consumers’ lack of experience and knowledge, and Obilet Bilişim Sistemleri A.Ş. was imposed an administrative fine of 128 TL and a fine to stop the aforementioned advertisements.
As a result of the Board’s examination of Olimtur’s website, it was determined that the “Pre-Selected Additional Product” and “Misleading Price” practices, for which the Board had previously imposed a suspension penalty on the company, were continued, the ticket prices caused confusion among consumers, and although the ticket price was positioned at the top and on the right in a way to be more easily noticed, the part with the final price was presented in a smaller font size, not bold and difficult to notice, In this context, it has been evaluated that unfair commercial practices are carried out by using tools and methods such as manipulative interface designs that negatively affect the will of consumers to make decisions or choices in digital environments or manipulative interface designs, therefore, the said promotions and practices are misleading and deceptive to consumers, and Olimtur Seyahat Acentaları Oto. Tur. and İnş San. Tic. Ltd. Şti. was imposed an administrative fine of 128 TL and the aforementioned advertisements were suspended.
In the evaluation made by the Board for the advertisements titled “Legendary discounts that come once a year on electronic products”, “Don’t miss out on legendary discounts on legendary products”, “20% net discount in Fairy Dishwashing Detergents in the basket”, “25% discount in the basket on selected paper products”, “Super Prices in Huawei Phones and Accessories Hurry up and Don’t miss out” and “Don’t miss out on discounts that are renewed every 3 hours” within the scope of D-Market website, It has been evaluated that the pre-discount price, which must be included within the framework of the provisions regulated in the Advertisement Legislation, as well as the start and end dates of the discounted sale, and the stock quantities for the product offered for sale at a discount are not included, and D-Market Elektronik Hizmetler ve Ticaret A. Ş. was imposed an administrative fine of 347.128 TL for each advertisement, totalling 388.512 TL, and the aforementioned advertisements were suspended.
As a result of the search results made through Google’s website by entering keywords such as “retrieval ritual”, “love ritual”, “binding ritual”, “reliable psychics”, a large number of psychics, hodja, fortune telling, fortune telling, magic, etc. advertisements were encountered, “Advertisements for services provided by fortune tellers, psychics, astrologers and the like and advertisements for illegal betting and gambling games cannot be made in any way. The situation in question, which is contrary to the provision “Advertisers, advertising agencies and media organisations are obliged to comply with the provisions of this article” in the Law on the Protection of Consumers, has been evaluated together with the provision “Advertisers, advertising agencies and media organisations are obliged to comply with the provisions of this article” and Google Reklamcılık ve Pazarlama Ltd. Şti. has been imposed an administrative fine of 128 TL and penalties for stopping the aforementioned advertisements.
It has been evaluated that the consumer evaluations containing health declarations contrary to the legislation for cosmetic products on the “Product Evaluations” pages on Trendyol’s website mislead consumers by creating the impression that the products offered for sale are pharmaceuticals or human medical products, and in this context, it has been evaluated that the advertisements in question are misleading to consumers and contrary to the principles of fair competition, and Dsm Grup Danışmanlık İletişim ve Satış Ticaret Anonim Şirketi was imposed an administrative fine of 128 TL and fines of 128 TL and fines to stop the aforementioned advertisements and unfair commercial practices.
As a result of the Board’s investigations regarding the advertisements titled “We have a promise to the world” on Beymen’s website and Instagram account; the statement “We have a promise to make all our packaging 100% sustainable in 2024.” in the said advertisements does not specify which brand product or product group it is related to or does not direct to a website where the consumer can get information on this subject, “We have a promise to nature and people with zero waste zero emission target. We promise to reduce water consumption with Jeanologia and BCI”, it has been determined that no reports prepared/verified by an organisation accredited according to the applicable standards are presented to support the statement “We promise to reduce water consumption with Jeanologia and BCI”. Thus, it has been assessed that the claims in the nature of “environmental statement” in the said advertisements do not comply with the principles set out in the Regulation on Commercial Advertisements and Unfair Commercial Practices (“Regulation”), and Beymen Perakende ve Tekstil Yatırımları A.Ş. has been sentenced to stop the said advertisements.
Within the scope of the advertisements and promotions titled “Bambaşka November Discounts up to 60% in the Basket” published on the website of LC Waikiki, the Board imposed a fine on LC Waikiki Mağazacılık Hiz. Tic. A.Ş. was imposed an administrative fine of 128 TL and the suspension of the aforementioned advertisements.[2]
As a result of the Board’s examination of the discount sale advertisements published on Defacto’s website, in order to determine whether the discount sale advertisements for the products in question were made in accordance with Article 14/3 of the Regulation, documents such as receipts, invoices, etc. showing the price change of the relevant products within 30 days prior to the discount date were requested from the company. Upon the determination that the products subject to the review were sold to consumers at lower prices than the pre-discount prices, Defacto Perakende Tic. A.Ş. was imposed an administrative fine of 128 TL and the suspension of the aforementioned advertisements.
In the examination conducted by the Board within the scope of the advertisements and promotions titled “Early November Deals-November Special Discounts” published on the website of FLO, it was seen that although a selected product was offered for sale under the title of “Early November Deals-November Special Discounts”, information such as the price before the discount and the discount rate applied were not included, and in this context, it was determined that the discount sale advertisements for the products in question were not made in accordance with Article 14/3 of the Regulation due to the failure of the relevant company to fulfil the burden of proof. It has been determined that the sale advertisements for the aforementioned products were not made in accordance with the provision 14/3 of the Regulation, and FLO Mağazacılık ve Pazarlama A.Ş. was imposed an administrative fine of 128 TL and a penalty to stop the aforementioned advertisements due to non-compliance with the legislation.
It has been determined that the advertisements and promotions regarding the product under the title of “Opportunity Products” on the website of English Home do not include the price before the discount, discounted product advertisements are made under the title of “Dikkat İndirim Var”, and it has been determined that the said promotions are not made in accordance with Article 14/3 of the Regulation due to the failure to fulfil the burden of proof by the relevant company, and EHM Mağazacılık Sanayi ve Ticaret A.Ş. has been imposed an administrative fine of 128 TL and penalties to stop the aforementioned advertisements due to non-compliance with the legislation.
As a result of the examination carried out by the Board as a result of the sale of selected products at discounted prices on the website of Vivense, it was evaluated that the company acted in violation of Article 14/3 of the Regulation due to the company’s failure to fulfil the burden of proof, and Vivense Teknoloji Hizmetleri ve Ticaret Ş. was imposed an administrative fine of 347,128 TL and fines to stop the aforementioned advertisements.
It was determined that the text message advertisements sent to consumers by Vodafone included the phrases “Digital Personal Loan Starting from 1.79% Interest Rate at ON’da!” and the mobile application advertisements included the phrases “1.79% interest rate Loan for School Needs at ON’da”. As a result of the Board’s examination, it was determined that there were contradictions between the expressions used in the advertisements and promotions sent to consumers due to the inclusion of different expressions on different platforms, the expression stated on the mobile application may cause the perception that a loan can be used at an interest rate of 1.79% in any case, regardless of the credit score, type of loan, etc., and therefore, it was evaluated that the advertisements and promotions in question were misleading and deceptive to consumers, and Vodafone Mall ve Elektronik Hizmetler Tic. Ş. was imposed an administrative fine of 347,128 TL and a fine to stop the aforementioned advertisements.
Although the advertisements and promotions for Samsung branded phones on Samsung’s website included the information that consumers can benefit from Fibabanka purchase and travel loan with “12” monthly instalments and “0%” interest rate, it was determined that the number of instalments was stated as “3” and the interest rate was stated as “3.20%” at the later stages of the purchase process for the product in question. In the statement made by Fibabanka A.Ş., it was stated that in accordance with the BRSA decision, the maturity limit for consumer loans extended for the purchase of mobile phones was determined as 12 months for mobile phones with a price of 12,000 Turkish Liras and below, and 3 months for mobile phones with a price above 12,000 Turkish Liras. However, although the price of the product named “Samsung Galaxy A34 5G” was TL 10,249, the relevant company submitted a loan offer to Fibabanka A.Ş. by transmitting the category code of mobile phones with a price above TL 12,000. As a result of the investigation conducted by the Board, it was assessed that the advertisements and promotions in question were misleading and deceptive to consumers, and Samsung Electronics Istanbul Pazarlama ve Ticaret Limited Şirketi was imposed an administrative fine of TRY 128 and a suspension of the aforementioned advertisements.
As a result of the Board’s examination of the discounted sale advertisements for a product on the platform named “Hepsiburada”, it was determined that the phrase “lowest price of 30 days” was included under the discounted product, but the product was previously offered to the sellers with an amount lower than the non-discounted sales price on the relevant platform. The said promotions do not comply with the “lowest price of the last 30 days” price rule in the Advertisement Legislation and the date information regarding the validity period of the campaign and the amount of stock is not included in the discounted sale advertisement, in this context, it has been evaluated that the said advertisements are misleading and deceptive to consumers and D-Market Elektronik Hizmetler ve Tic. A.Ş. was imposed an administrative fine of 128 TL and the suspension of the aforementioned advertisements.
Cosmetics and Cleaning Products
It has been evaluated that the “+” sign used in the expressions “6000+ Hair Teli” and “2800+ Hair Teli” in the product promotions on Clear’s website, the social media account named clearturkiye on the Instagram platform and various television channels causes confusion in the minds of consumers and creates the impression that the product will grow new hair strands, therefore, the said advertisements are misleading and contrary to the principles of fair competition, and Unilever Sanayi ve Ticaret Türk A. Ş. was imposed an administrative fine of TL 388,526.00 and the suspension of the aforementioned advertisements.
Unfair Commercial Practices
The Board decided to impose an administrative fine of TL 128.00 and a suspension of the aforementioned commercial practices on Evyap Sabun Yağ Glycerin Sanayi ve Ticaret A.Ş. by evaluating that the 4-pack soap product of Duru brand was offered to the market as 320 grams in a 360-gram package and the unit prices of the products were indirectly increased; no change or notification was made on the product packaging that consumers could notice regarding the weight change in violation of the legislation, thus deceiving and misleading consumers and reducing the average consumer’s economic behaviour and ability to make informed decisions.
The Board decided to impose an administrative fine of TRY 701.00 on Hakmar Mağazacılık Limited Şirketi and a fine to stop the aforementioned advertisements due to the inconsistencies between some product prices and cash register prices in the discount poster titled “We are on the side of our people and our state 100 %” published in the market store Hakmar Express. In addition, A101 and Şok Market, which carry out the same activity with Hakmar Express, were imposed administrative fines of TRY 34,701.00 and fines to stop the aforementioned advertisements.
Food and Food Supplements
“35% discount on your order with Müdavim! ” campaigns were examined, the company did not benefit from the promised 35% discount campaign by putting forward a condition that was not included in the campaign conditions, and therefore the advertisements in question did not reflect the truth, Due to the fact that the campaign conditions included in the campaign details may completely eliminate the advantage provided by the main promise and/or may contain incompatibility/contradiction with the main promise, it has been determined that the said condition should be included on the main page of the campaign, and it has been evaluated that the relevant campaign is misleading to consumers and contrary to the principles of fair competition, and it has been decided to impose an administrative fine of 128.00 TL and to suspend the said advertisements on Getir Perakende Lojistik Anonim Şirketi.
In addition, in the Bulletin, due to the existence of the aforementioned reasons, the campaigns “30 TL discount for your first order at Pasaport Pizza!”, “40 TL discount for your first order at Pasaport Pizza!”, “30% discount at Getir Getirsin restaurants!” and “25 TL discount for your first order at Gourmet restaurants! No delivery fee” campaigns, it was decided to impose administrative fines of 1,041,384 TL in total, two more fines of the same amount, and to suspend the aforementioned advertisements.
In the incident subject to the decision, it was seen that the food order placed by the applicant consumer upon the social media announcement that a discount would be provided with the “SICAK30” coupon on food orders to be placed from Trendyol Yemek application was cancelled on the grounds that another order was placed on the same day with the credit card with which the payment was made, however, although the same credit card was used in the payment for both orders, the first order was not placed through the membership account of the applicant consumer.
In the statement made by the company upon the incident, it was stated that the coupon can be used only once by each consumer, that all consumers can benefit from the advantage provided through the coupon only once, and that the coupon, which is announced to consumers on certain days with content published on social media platforms by social media influencers, can be used on the same day.
In its evaluation, the Board stated that the campaign conditions were not announced on the link page of the Trendyol Yemek application, to which consumers were directed to place discounted orders upon the announcements of the social media influencers contracted with the company regarding the coupon, and that the conditions for participation in the campaign did not include an issue stating that the discount could be used only once with the same address and bank card information, and that the applicant consumer was subjected to unfair commercial practice and DSM Grup Danışmanlık İletişim ve Satış Tic. A.Ş. to stop the said unfair commercial practice.
Since it was determined that instant notifications were sent to consumers’ mobile phones for the discounted sale of food products within the scope of the campaign named “July Dated Lucky Hours Campaign” in Migros Virtual Market application, but the products were sold at non-discounted prices, it was evaluated that the promotions regarding the discount sales were deceptive and misleading to consumers and Digital Platform Gıda Hizmetleri A.Ş. was sentenced to stop the said unfair commercial practice.
It was evaluated that the relevant advertisements were misleading and deceptive to consumers on the grounds that “20% Discount on All İskender Varieties Special for First Order” was used on the placemats of Baydöner, but this discount was valid in the past period and the promised discount rate was changed to 15%, and Baydöner Restoranları Anonim Şirketi was imposed an administrative fine of TRY 701.00 and a fine to stop the aforementioned advertisements.
Health Services
In the advertisements published on the social media accounts “Dokun & Değiş Change Centre” on the Facebook platform and “dokun. degisbeauty” social media accounts, the relevant company gives the impression that it provides services in this field and operates in the field of health by listing the names of various medical treatment methods that should be applied by physicians, the medical procedures in question should be applied under the control of a doctor and within health institutions, and the promotion of such medical procedures even by authorised persons is prohibited by the legislation, On the other hand, due to the fact that the type of the enterprise is not clearly stated, consumers are misled and incompletely informed about the field of activity, all these promotions are considered to be misleading, disruptive to public health and contrary to the relevant legislation, and Kulaşan Sağlık ve Eğitim Dan. Ltd. Şti. was imposed an administrative fine of 059 TL and the aforementioned advertisements were suspended.
“Excimer Laser invites you to see flawlessly!” via the “medistatehastanesi” account on the Instagram platform! – Do you want to get rid of your glasses? – 100% Laser Blade-Free Vision Treatment ILASIK (…)” and visuals of surgeries, the promotion made by the health institution by including the statements and visuals of the surgery is considered to be of a nature that exceeds the limit of information and promotional activities permitted by the legislation due to the fact that it creates a commercial appearance to the activities of the organisation and creates demand for medical procedures, and Kavacık Medikal Sağlık Hizmetleri ve Ürünleri Ticaret ve Sanayi Anonim Şirketi was imposed an administrative fine of 059.00 TL and fines to stop the aforementioned advertisements.
Similarly, Levent Hastanesi Anonim Şirketi was imposed an administrative fine of TRY 550,059.00 and Dünya Göz Hastanesi Sanayi ve Ticaret Anonim Şirketi was imposed an administrative fine of TRY 347,128.00 for the advertisements made with the hospital’s social media account on the Instagram platform and Levent Hastanesi Anonim Şirketi was imposed an administrative fine of TRY 550,059.00 and Dünya Göz Hastanesi Sanayi ve Ticaret Anonim Şirketi was imposed an administrative fine of TRY 347,128.00 and the aforementioned advertisements were suspended on the grounds that the promotions made were in the nature of advertisements that impose a commercial appearance on the work of the institution, create demand, direct patients to the said institution and exceed the limit of information and promotion activities permitted for health institutions in the relevant legislation.
Disguised Advertisement
In the story posts made from the social media account named yelizketencii on the Instagram platform, users were directed to Trendyol and Hepsiburada links without any “cooperation, partnership” label indicating that it was an advertisement, and implicit advertisement[3] of the relevant brands was made with such redirection, In addition, Yeliz Ketenci Akkoyun was imposed an administrative fine of TRY 128.00 and a ban on the aforementioned advertisements by Yeliz Ketenci Akkoyun for implicitly advertising a doctor named “Orkun MÜFTÜOĞLU” by including examination images, doctor’s name and praising expressions in the story series titled “Doctor Suggestion” on her social media account.
Principle Decision No. 2024/1
With the amendment to the “Guideline on Advertisements Containing Price Information and Discount Sale Advertisements and Commercial Practices” (“Guideline”), the Board took an important principle decision regarding discount sale advertisements. Pursuant to Article 14 of the Guideline, in advertisements for goods or services offered for sale through a loyalty programme, the impression of a discount, directly or indirectly, cannot be created by using phrases such as “discount”, “savings”, “special discount/opportunity for XY card/members”, “pre-discount price” or visuals such as strikethrough price or downward trend graph. As can be seen from the sample application given below, it is evaluated that an unreal discount perception is created in the eyes of consumers and therefore consumers are misled by both determining the price contrary to the lowest price rule of the last 30 days introduced within the scope of the discounted sales legislation and determining the unrealistic list price, although the price of the toothpaste with a list price of 145 TL, which is offered for sale within the scope of the loyalty program, constantly changes between 90 TL and 50 TL, by organizing a continuous or period-specific discount campaign under the name of “special discount for XY Loyalty Program” over the list price determined mostly above the market averages.
Accordingly, in order to prevent such deceptive practices, the Board has determined as a principle decision that in advertisements for goods or services offered for sale through loyalty programmes, the impression of a discount cannot be created directly or indirectly by using phrases such as “discount”, “savings”, “special discount/opportunity for XY card/members”, “pre-discount price” or visuals such as crossed-out price or downward trend graph. Thus, a holistic step has been taken to protect consumers more effectively against deceptive practices that make price comparisons difficult in discounted sales campaigns.
GRC LEGAL Comment
When we examine the decisions of the Bulletin, it is seen that the Board has subjected e-commerce platforms and mobile applications to strict supervision within the scope of advertising and promotional activities carried out by companies from various sectors, especially in line with discount sales advertisements, and has not refrained from imposing deterrent sanctions for each advertisement for companies that are leaders in the sector.
When the grounds for the decision are taken into consideration, it can be said that the Board has proceeded to change the dynamics in the goods and services market by addressing the relevant legislation, including the health law legislation, with a holistic approach, and in this direction, it has displayed an attitude worthy of the purpose and spirit of the consumer legislation. As a matter of fact, with the Bulletin, the Board has published its principle decision on loyalty card practices, which are frequently encountered by consumers in retail sales, and has taken into consideration today’s practices in order to prevent consumers from being misled and victimised.
In this context, it is of utmost importance that all companies engaged in retail sales activities, especially those engaged in e-commerce activities, take into account the compliance processes with the Advertisement Legislation.
[1] Pursuant to Article 28 of the Regulation on Commercial Advertising and Unfair Commercial Practices, a commercial practice is deemed to be unfair if it does not comply with the requirements of professional care and significantly impairs or is likely to significantly impair the economic behaviour of the average consumer or the average member of the group to which it is directed.
[2] Article 14/3 of the Regulation: “In determining the sales price of a good or service before the discount, the lowest price applied within thirty days prior to the date of the discount is taken as basis.”
[3] Without explicitly stating that it is an advertisement, the inclusion of names, trademarks, logos or other distinctive shapes or expressions, trade names or business names related to goods or services in articles, news, publications and programmes for the purpose of advertising and presenting them in a promotional manner is disguised advertising.
