BILL ANALYSIS Ó
SENATE JUDICIARY COMMITTEE
Senator Noreen Evans, Chair
2013-2014 Regular Session
SB 686 (Jackson)
As Amended April 22, 2013
Hearing Date: April 30, 2013
Fiscal: Yes
Urgency: No
BCP
SUBJECT
Vehicles: Vehicle Dealer
DESCRIPTION
This bill would prohibit a vehicle dealer from selling, leasing,
renting, loaning, or otherwise transferring ownership of a used
vehicle, if the dealer knows or should have known that the
vehicle is subject to a manufacturer's safety recall. This bill
would similarly prohibit a rental company that is a dealer from
selling or transferring ownership of a used vehicle that is
subject to a manufacturer's safety recall. Those prohibitions
would not apply if the defect was repaired as required.
This bill would require a dealer that does not have knowledge of
a recall to stake specified steps to obtain the vehicle's safety
recall status. This bill would deem rental companies to have
knowledge of a manufacturer's safety recall if they receive
notification of the recall pursuant to federal law. Once auto
manufacturers are required to provide vehicle safety status on a
publicly accessible Internet Web site, this bill would require
both dealers and rental companies to check that database to
obtain the safety recall status of a vehicle.
This bill would make a violation of the above prohibitions
actionable under the Consumers Legal Remedies Act and the Unfair
Competition Law, as specified.
This bill would also prohibit the advertising or sale of a used
vehicle as "certified" if the dealer knows or should have known
that the vehicle is subject to a manufacturer's safety recall.
(more)
SB 686 (Jackson)
Page 2 of ?
BACKGROUND
The National Highway Traffic Safety Administration (NHTSA) has
the authority under federal law to issue vehicle safety
standards and to require manufacturers to recall vehicles that
have safety defects or do not meet safety standards. If a safety
defect is identified, manufacturers are required to notify the
NHTSA, owners, dealers and distributors, and, correct the defect
at no change (unless the vehicle is more than 10 years old).
Recently, concerns have been raised about the risks of
purchasing a car subject to a safety recall and, as a result,
steps that could be taken to reduce those risks.
As an example of the serious risks posed by safety recalls, a
2012 article published on Edmunds.com entitled "Recalled but
Unrepaired Cars Are a Safety Risk to Consumers," reported:
In April 2009, General Motors [(GM)] began sending
registered letters to owners of more than 1.4 million of its
cars equipped with 3.8-liter V6 engines, notifying them of a
recall for 1997-2003 V6-equipped Chevrolets, Buicks,
Oldsmobiles and Pontiacs to address a potential engine fire
hazard. The previous year, the company had sent letters to
owners of 207,000 Buicks and Pontiacs with turbocharged
versions of the same engine for the same problem.
By the time the 2009 recall was issued, there had been
reports filed with the [NHTSA] of almost 250 fires in such
cars. The problem was thought to be caused by oil that had
spilled or leaked onto heated exhaust manifold surfaces. In
some cases, the oil caught fire and the flames spread to
plastic parts, including the spark plug wiring channel and
the upper intake manifolds and engine covers.
As almost all car-fire warnings do, the letters also urged
owners not to park the cars in their garages or near homes
or other flammable structures until the recall work had been
completed.
But not every owner of a fire-prone GM vehicle has seen that
letter. Although the rate of incidents is steadily
declining, there have been at least 250 additional engine
fires since the recall was announced three years ago,
according to reports filed with NHTSA.
In many cases, the owners of the burned-up cars said they
SB 686 (Jackson)
Page 3 of ?
were not aware that there had been a recall. Most had
purchased the vehicles used. Many didn't know if the
required repair work had ever been done. Some of the cars
that were parked in garages are believed in several cases to
have caused structural damage or damage to other vehicles as
flames spread.
In response to concerns about the sale of recalled vehicles,
this bill would generally prohibit the sale, lease, renting,
loaning, or otherwise transferring ownership of a used vehicle
that is subject to a manufacturer's safety recall. This bill
would similarly prohibit a dealer from advertising or selling
a used vehicle as "certified" if it is subject to a
manufacturer's safety recall.
CHANGES TO EXISTING LAW
1. Existing federal law , Part 577 of 49 C.F.R. 577.1, sets
forth the requirements for when manufacturers must notify
vehicle owners, dealers, and distributors about a defect that
relates to motor vehicle safety or noncompliance with a
federal motor vehicle safety standard. (49 C.F.R. 577.1 et
seq.)
Existing state law prohibits any person from acting as a
dealer, remanufacturer, manufacturer, or transporter, as
specified, without having first been issued a license or
temporary permit, as specified. (Veh. Code Sec. 11700.)
Existing state law prohibits a holder of a license from, among
other things, making or disseminating any statement which is
untrue or misleading and which is known, or which by the
reasonable exercise of case should be known to be untrue or
misleading, as specified. (Veh. Code Sec. 11713(a).)
Existing law prohibits a dealer or person holding a retail
seller's permit from selling a new or used vehicle that is not
in compliance with the Vehicle Code and departmental
regulations, unless the vehicle is sold to another dealer,
sold for the purpose of being legally wrecked or dismantled,
or sold exclusively for off-highway use, as specified. (Veh.
Code Sec. 24007 (a)(1).)
Existing law provides that when a federal motor vehicle
SB 686 (Jackson)
Page 4 of ?
standard is established under federal law, as specified, no
dealer shall sell or offer for sale a vehicle to which the
standard is applicable, and no person shall sell or offer for
an item of equipment sale for use upon a vehicle to which the
standard is applicable unless: (1) the vehicle conforms to
the applicable federal standard; or (2) the vehicle or
equipment bears a certification, as specified. (Veh. Code
Sec. 24011.)
This bill would additionally prohibit a dealer from selling,
leasing for a term of less than four months, renting, loaning,
or otherwise transferring ownership of a used vehicle if the
dealer knows or should have known that the vehicle is subject
to a manufacturer's safety recall, unless the repairs required
to correct the defect have been performed on the vehicle.
This bill would provide that a dealer is deemed to have
knowledge of a manufacturer's safety recall if either: (1) the
dealer receives notification from the manufacturer; or (2) the
dealer is a franchisee of the manufacturer.
This bill would provide that, in the absence of knowledge and
until auto manufacturers are required to provide vehicle
safety recall data on a publicly accessible Internet Web Site,
a dealer shall obtain information about a vehicle's safety
recall status prior to completing a transaction, as specified,
from at least one of the following sources: (1) the Internet
Web site of the manufacturer; (2) a toll-free telephone,
provided that the manufacturer has made the safety recall
status available at that number; (3) another dealer that is a
franchisee of the manufacturer; or (4) a commonly available
vehicle history report, provided that the safety recall status
of the vehicle is available.
This bill would provide that, when auto manufacturers are
required to provide vehicle safety recall data on a publicly
accessible Internet Web site, as specified, a dealer shall
obtain information about a used vehicle's safety recall status
from that database.
This bill would state that a violation of the above
prohibition is actionable under the Consumer Legal Remedies
Act, the Unfair Competition Law, Business and Professions Code
Section 17500 (relating to false advertising), or any other
applicable statute or federal law. This bill would state that
the provided rights and remedies are cumulative and shall not
SB 686 (Jackson)
Page 5 of ?
be construed as restricting any right or remedy that is
otherwise available.
This bill would apply the above prohibitions to a rental
company, as defined under existing law, only when the rental
company is also a licensed dealer and is selling or
transferring ownership of a used vehicle. This bill would
provide that a rental company is deemed to have actual
knowledge when it receives notification of the manufacturer's
safety recall pursuant to federal law.
2. Existing law provides that it is a violation of the Vehicle
Code for a holder of any dealer's license to advertise or sell
a used vehicle as "certified" or use any similar descriptive
term in the advertisement or sale of a used vehicle that
implies the vehicle has been certified to meet the terms of a
used vehicle certification program if any of the following
apply: (1) the dealer knows or should have known that the
odometer does not indicate actual mileage; (2) the dealer
knows or should have known that the vehicle was reacquired by
a dealer or manufacturer pursuant to state or federal warranty
laws; (3) the title has been inscribed with "lemon law
buyback," "manufacturer repurchase," "salvage," junk,"
nonrepairable," "flood," or similar title designation; (4) the
vehicle has sustained damage, as specified, that after repair
substantially impairs the use or safety of the vehicle; (5)
the dealer knows or should have known that the vehicle has
sustained frame damage; (6) the dealer fails to provide a
completed inspection report; (7) the dealer disclaims any
warranties of merchantability; (8) the vehicle is sold "AS IS"
or (9) the term "certified" or any similar term is used in a
manner that is untrue or misleading. (Veh. Code Sec.
11713.18.)
This bill would additionally make it a violation of the
Vehicle Code for a dealer to advertise or sell a vehicle as
"certified" if the dealer knows or should have known that the
vehicle is subject to a manufacturer's safety recall, as
specified.
COMMENT
1. Stated need for the bill
SB 686 (Jackson)
Page 6 of ?
According to the author:
Franchised new car dealers are prohibited by federal law
from selling or leasing new vehicles that are under a safety
recall, but new and used car dealers are not prohibited from
selling, loaning, renting, or leasing used cars that have
outstanding, unrepaired safety recalls pending. Also, there
is no specific state law that prohibits dealers from selling
new recalled vehicles to provide relief for victims under
state law, consistent with federal law.
The sales of unrepaired recalled used vehicles to
unsuspecting used car buyers is a serious problem that has
been documented by the U.S. Governmental Accountability
Office (GAO) [in] a recent June 2011 report, as well as
numerous news reports, including widely reported
investigations by CBS (NY) and news organizations throughout
California. In some cases, consumers have experienced
life-threatening defects that were subject to safety
recalls, and became manifest shortly after purchase. For
example, some vehicles caught fire. Another had an axle
that broke and caused the vehicle to flip over.
[. . .]
SB 686 prohibits car dealers from selling, leasing,
displaying, renting, loaning or offering for sale a new or
used vehicle is the vehicle has a defect subject to the
manufacturer's recall, unless repairs to correct the defect
have been performed on the vehicle. It also prohibits car
dealers from selling vehicles with open safety recalls as
"certified."
This bill will protect consumers from potentially harmful
vehicle defects by helping to ensure that the vehicles they
purchase are free from outstanding, unrepaired safety
recalls.
2. Safety recalls
As background, safety recalls are necessary when a motor vehicle
or item of motor vehicle equipment does not comply with a
Federal Motor Vehicle Safety Standard, or, when there is a
safety-related defect in the vehicle or equipment. The National
Highway Traffic Safety Administration (NHTSA) notes that
"[g]enerally, a safety defect is defined as a problem that
exists in a motor vehicle or item of motor vehicle equipment
that: (1) poses a risk to motor vehicle safety; and (2) may
SB 686 (Jackson)
Page 7 of ?
exist in a group of vehicles of the same design or manufacture,
or items of equipment of the same type and manufacture." Sample
defects provided by the NHTSA include steering components that
break and cause a loss of control, problems with fuel system
components that may cause vehicle fires, accelerator controls
that may stick, and child safety seats that contain defective
safety belts that create a risk of injury. (Motor Vehicle
Defects and Safety Recalls: What every vehicle owner should
know, U.S. Department of Transportation
[as of
Apr. 25, 2013].)
In response to concerns about the sale of vehicles subject to a
safety recall, this bill seeks to prevent a car dealer from
selling, leasing for an initial term of less than four months,
renting, loaning or otherwise transferring ownership of a
vehicle that is subject to a manufacturer's safety recall
(unless the required repairs have been performed). Consumers
for Auto Reliability and Safety (CARS), sponsor, asserts:
In 2010, a record 14.9 million vehicles were recalled by
manufacturers. A U.S.
Government Accountability Office (GAO) study, published in
June 2011, reported that "Owners of vehicles subject to a
recall do not always get them fixed, posing a risk to
owners, as well as to vehicle passengers, other drivers, and
pedestrians. According to NHTSA, on average only about 70
percent of vehicles subject to a recall are fixed within the
18-month period during which manufacturers provide recall
completion data to the agency."
Enactment of SB 686 is necessary because, while franchised
new car dealers are
prohibited by federal law from selling or leasing new
vehicles that are under a safety recall, there is no
prohibition against selling, loaning, renting, or leasing
used cars that have been recalled, but not repaired. . . .
The sales of unrepaired recalled used vehicles to
unsuspecting used car buyers is a serious problem that has
been documented by the [U.S. Government Accountability
Office] and numerous news reports. In some cases, consumers
have been killed or injured due to defects in vehicles that
were subject to safety recalls. Sometimes these tragic
incidents were entirely preventable, with minimal effort on
the part of the selling dealer.
SB 686 (Jackson)
Page 8 of ?
Staff notes that the purchase of a vehicle has traditionally
been among the most difficult and confusing, as well as one of
the biggest, transactions for consumers. As a matter of a good
business practice (and to ensure continued customer
satisfaction), it would appear that dealers should have an
incentive to repair recalled vehicles in order to avoid to avoid
a situation where a customer is injured as a result of a known
safety-defect. On this point, a June 2011 Report from the U.S.
Government General Accountability Office entitled: Auto Safety:
NHTSA Has Options to Improve the Safety Defect Recall Process
found that:
Used-car dealerships we spoke with told us that when they
become aware of a vehicle defect, they either remedy the
defect before the sale of the vehicle or notify potential
buyers of the safety defect because it is a good business
practice. Nevertheless, in some instances, a used-car dealer
may not be aware that an outstanding safety defect exists in
a vehicle. In particular, a used-vehicle dealer association
with over 20,000 members told us that because used dealers
do not have a franchise agreement with the manufacturers,
they do not receive the defect notices that manufacturers
send to franchised dealers. Moreover, used-car dealers we
spoke with told us that generally they do not receive defect
notices from manufacturers, except in certain cases, such as
when a used dealer purchases previously leased vehicles
directly from a manufacturer. (Id. at p. 28.)
Accordingly, the opposition expresses concern about the ability
of a dealer to discover whether a car is recalled and about the
liability associated with a violation of the prohibitions.
a. Ability to determine whether a vehicle is subject to a
safety recall
Inherent in the prohibition on selling, leasing, renting, or
loaning recalled vehicles is the ability for a dealer to
determine whether a car has been recalled. The Independent
Automobile Dealers Association of California (IADAC), in
opposition, states that "[w]hile we laud your efforts to help
the consumer, the legislation is impossible to comply with and
puts the used car dealers in jeopardy and open to numerous
lawsuits if an honest mistake was made by the dealer." IADAC
asserts that there currently is no database available for a
dealer to quickly access and retrieve reliable information to
determine if a vehicle has a recall on it. The California New
SB 686 (Jackson)
Page 9 of ?
Car Dealers Association (CNCDA), in opposition, notes that
Congress passed legislation last year requiring the creation
of a free Internet database containing information about each
recall and whether it has been completed for each vehicle, and
asserts that "unless and until this database is operational,
compliance with SB 686 would be impossible."
In response to concerns that it is impossible to determine
whether or not a car is subject to a safety recall, CARS
notes:
In order to determine whether a vehicle has an open
safety recall, dealers have several quick, easy, no-cost
options. They can first check the make, model and year
on the NHTSA website to find out if there were any
recalls for that make, model and year. Then if there
are, they can then search for a specific Vehicle
Identification Number (VIN) on the manufacturer's
website, call the manufacturer's toll-free number, or
contact a dealer of that make. Or they can search for a
specific VIN on the manufacturer's website or contact a
dealer of that make directly. These are the same options
that are available to consumers. All are available at no
cost to the public.
In addition, under the Moving Ahead for Progress in the
21st Century Act (MAP-21), signed into law by President
Obama July 6, 2012, within one year after the date of
enactment, the Secretary of Transportation must require
that motor vehicle safety recall information, searchable
by VIN, be available to the public. NHTSA has proposed
that manufacturers provide the data on a daily, "real
time" basis.
Staff notes that given the existing options above, and that a
federal law already requires the creation of the database
sought by the opposition, it is unclear exactly how it would
be impossible to determine whether a specific vehicle is
subject to a safety recall. Although checking for a recall
would arguably create some additional workload, at least one
support letter submitted to the Committee by Salvatore A.
Cerrito, a former owner of car dealerships, stated that
checking to see if a vehicle has an open safety recall is
"simple, and not overly time-consuming or burdensome,
particularly considering the stakes involved should someone be
harmed by a vehicle that was being recalled by the
SB 686 (Jackson)
Page 10 of ?
manufacturer."
It should also be noted that the April 22, 2013 amendments
further clarify the steps that a dealer is required to take,
namely, if the dealer does not have actual knowledge of a
recall, the dealer must obtain information about a vehicle's
safety recall status from: (1) the Internet Web site of the
manufacturer; (2) the manufacturer's toll-free number; (3)
another dealer that is a franchisee of the manufacturer; or
(4) a commonly available vehicle history report. The
amendments further specify that when automakers are required
to provide vehicle safety recall data on a publically
accessible Internet Web site (pursuant to existing federal
law), a dealer must obtain information about a used vehicle's
safety recall status from that database.
It should also be noted that manufacturers are required to
repair recalled vehicles at no cost (provided that the car is
not more than 10 years old), and that dealers who do acquire a
vehicle that is subject to a recall may always elect to sell
the car at wholesale if they do not want to get the defect
repaired.
b. Scope of prohibition
As noted above, the proposed prohibitions regarding the sale
of used vehicles that are subject to a safety recall would
apply to new and used car dealers. IADAC, in opposition,
asserts that "[i]f the intent of this bill is to protect the
consumer from a vehicle that has been recalled, this only
scratches the surface as new and used dealers combined sell
only 35[percent] of used cars [while] the other 65[percent]
are sold by private parties and governmental bodies." The
author, in response, asserts:
First, dealers are in the business of selling cars, so
they have an obligation to the public to ensure that they
are safe. Second, consumers who receive recall notices
often do decide not to keep driving their cars, or
restrict their driving activity, or limit who can drive
the car (for example, not allow their teenagers to drive
it) until it's fixed. Third, when people buy or rent a
car from a dealer, they expect it to be safe before it's
offered for sale or rent.
Staff notes that it is not uncommon for the State of
SB 686 (Jackson)
Page 11 of ?
California to impose requirements on licensed entities in
order to protect consumers, and that dealers appear to be much
better equipped than the average consumer to determine whether
or not a car is subject to an outstanding safety recall.
3. Rental companies
Prior to the recent amendments, the prohibition on the sale or
renting of a vehicle subject to safety recall applied to all
licensed dealers. The April 22, 2013 amendments created a new
section that only applies to rental companies that are also
licensed as a dealer - that section does not include a
prohibition on the renting or loaning of vehicles that are
subject to a manufacturer's safety recall. Since rental
companies generally own the vehicles they rent out (and
therefore would directly receive recall notices from the
manufacturer), the new rental company section provides that they
are deemed to have knowledge upon receiving notification of the
manufacturer's safety recall. Absent receipt of such a notice,
rental companies would have to take the same steps as a dealer
to check for a recall. Regarding the exemption for rental
companies, the author notes that they will be covered by federal
legislation that will be introduced soon. Hertz Corporation, in
support, states:
Hertz does not rent or sell cars that are subject to recall.
In fact, Hertz is actively working with the sponsor of SB
686 to pass federal legislation that would establish clear,
national requirements prohibiting the sale or rental of a
vehicle that is the subject of an active recall.
While we continue to believe that a federal solution is
preferable to a patchwork of varying state requirements,
Hertz is comfortable supporting SB 686 because it is
consistent with our policy that no car subject to a recall
should be rented or sold.
CNCDA, in opposition, asserts that rental companies are
different from dealers in that "[w]hile a rental company is
notified directly by the manufacturer when a vehicle it owns is
recalled, car dealers receive no such notification (unless
franchised to sell that make). For example, a Chevrolet dealer
will not be notified by Toyota if a used Toyota in inventory is
recalled. Nor does that dealer have access to information
concerning whether the vehicle has been recalled, or, if so,
whether the defect has been repaired."
SB 686 (Jackson)
Page 12 of ?
4. Liability for violations
To enforce the prohibitions relating to vehicles subject to a
safety recall, this bill would state that a violation by a
dealer is actionable under the Consumer Legal Remedies Act
(CLRA), the Unfair Competition Law, Business and Professions
Code Section 17500 (false advertising), or any other applicable
state or federal law. Consumers who suffer a violation of the
CLRA may bring an action to recover actual damages, an order
enjoining the methods, acts or practices, restitution, punitive
damages, and any other relief that the court deems proper.
(Civ. Code Sec. 1780.) The Unfair Competition Law, which
includes false advertising prohibited by Business and
Professions Code Section 17500, similarly provides injunctive
relief and authorizes a court to impose civil penalties for
violations.
The IADAC, in opposition, contends that this bill would open
dealers to "numerous lawsuits if an honest mistake was made,"
and the Consumer Financial Services Association (CFSA) contends
that SB 686 "would effectively establish a private right of
action against a financial institution that holds the note on a
said vehicle. Financial institutions have no way to protect
themselves from the strict liability called for in [SB 686] and
this would have a chilling effect on the auto lending industry."
It should be noted that CFSA states their argument is based on
Federal Trade Commission Rule 433, related to Holder in Due
Course, which CFSA asserts provides that consumers have a right
to seek redress against the holder of a contract, regardless of
whether or not the contract was originated by another party.
The sponsor, in response, asserts, that liability only attaches
if dealers were to violate the law, if "[financial institutions]
don't have confidence the dealer is complying with the law, and
they are concerned about their liability, they can do their own
check before agreeing to take assignment of the loan, as the
loan documents include the VIN."
It should also be noted that the April 22, 2013 amendments limit
violations to circumstances where a dealer "knew or should have
known" that the vehicle is subject to a manufacturer's safety
recall, thus, arguably limiting liability in cases where a
dealer had no way to find out that a car was subject to a safety
recall.
SB 686 (Jackson)
Page 13 of ?
5. "Certified" vehicles
This bill would additionally prohibit a dealer from advertising
or selling a used vehicle as "certified" if the dealer knows or
should have known that the vehicle is subject to a
manufacturer's recall. CARS, in support, states:
Franchised car dealers commonly display "certified" vehicles
in a separate area of the car lot, distinguished by banners
and other promotional signage and materials. In addition,
major retailers of used cars such as Carmax advertise that
all of the used vehicles they offer for sale are
"certified." Based on public perception that "certified"
vehicles are the cream of the used car crop, they command a
higher price - often thousands of dollars above the price of
a non-certified vehicle. Consumers are led to believe that
they do not have to obtain their own inspection, as the
dealer has carefully inspected the vehicle prior to sale.
Considering that "certified" vehicles are generally perceived
as being superior to other non-certified vehicles, applying
the prohibition to certified vehicles is arguably consistent
with the intent of the bill. The California Chamber of
Commerce (CalChamber), in opposition, asserts that this bill
would completely prohibit a licensed dealer from selling a
vehicle as "certified" if it has been subject to a safety
recall, despite the fact that the defect has been repaired.
Considering that the intent of the bill is to allow sale of
"certified" vehicles after the necessary repairs have been
completed, the following amendment is suggested to clarify the
language with respect to the sale of certified vehicles:
Suggested amendment :
On page 3, line 31 after "recall" insert:
and the repairs required to correct the defect have not
been performed on the vehicle
6. Opposition's concerns
The opposition's main concern appears to be the requirement to
check for a safety recall prior to the establishment of a
national database. CalChamber, in opposition, asserts that
"Congress passed legislation last year to create a searchable
database by make, model, and VIN to identify whether a
SB 686 (Jackson)
Page 14 of ?
specific vehicle was subject to a recall and had been
repaired. Until this database is created, SB 686 subjects
dealers to an essentially impossible standard." The Chamber
of Commerce also contends that the term "safety" is undefined
and extremely subjective.
The Civil Justice Association of California, in opposition,
similarly asserts that until the national database is created,
SB 686 subjects dealers to unwarranted lawsuits.
Support : California Public Interest Research Group; Consumer
Action; Consumer Federation of California; Consumers Union;
Consumer Watchdog; Consumer Attorneys of California; Hertz
Corporation; Trauma Foundation
Opposition : California Chamber of Commerce; California
Financial Services Association; California New Car Dealers
Association; Civil Justice Association of California;
Independent Automobile Dealers Association of California
HISTORY
Source : Consumers for Auto Reliability and Safety
Related Pending Legislation : AB 964 (Brown and Bonta), would
include manufacturer's safety recalls on the list of prohibited
conditions for certified vehicles. It would also add a required
pre-sale disclosure for all used vehicles regarding
manufacturer's recalls and the other safety and warranty issues.
This bill is in the Assembly Committee on Business, Professions
and Consumer Protections.
Prior Legislation : AB 753 (Monning, 2011), would have expressly
prohibited a rental car company from renting a vehicle that is
subject to a recall notice unless the vehicle has been repaired
as specified in the notice. This bill died in the Senate
Committee on
Appropriations.
**************
SB 686 (Jackson)
Page 15 of ?