A nation divided can’t stand secure.
Dave Bittner: Hello, everyone; and welcome to Caveat, N2K CyberWire's Privacy, Surveillance, Law, and Policy Podcast. I'm Dave Bittner. And joining me is my cohost, Ben Yellen, from the University of Maryland Center for Cyber Health and Hazard Strategies. Hey there, Ben.
Ben Yellen: Hello, Dave.
Dave Bittner: On today's show, Ben discusses some major Supreme Court decisions from the just-concluded 2025 term. I've got the story of a license plate reader company dialing back access after media reports reveal potential overt sharing. While this show covers legal topics and Ben is a lawyer, the views expressed do not constitute legal advice. For official legal advice on any of the topics we cover, please contact your attorney. All right. Ben, let's jump right in here. So the Supreme Court session or season, whatever you call it, just wrapped up.
Ben Yellen: Yeah. The playoffs are over. We've had our championship. And, yes; the 2025 term ended. We're recording this on a Tuesday; it ended last Friday.
Dave Bittner: Okay.
Ben Yellen: So they get to take a nice, long summer vacation, travel to Europe, give speeches, go to conferences.
Dave Bittner: Travel around in their RVs.
Ben Yellen: Right. And they are not back in session until the beginning of October.
Dave Bittner: Okay.
Ben Yellen: So there are a couple of very important decisions for our purposes, one that's more of a general decision that I think can be applicable to a lot of the things we talk about and then one that's very central to the -- what we cover on the show.
Dave Bittner: Okay.
Ben Yellen: So I'll talk about the general one first, and that has to do with universal injunctions. So, as a little bit of background here, the Trump administration, when they came in for their second term, issued an executive order basically saying that birthright citizenship in the United States, as it has been defined since our founding, is changing and that, if somebody is born in the United States to two parents, neither of whom are legal US residents, then that child is not subject to the jurisdiction of the United States and, therefore, not a United States citizen.
Dave Bittner: Okay.
Ben Yellen: So this goes against traditional understanding of the Fourteenth Amendment, which holds that anybody born in the United States is a United States citizen.
Dave Bittner: Right.
Ben Yellen: So a bunch of people sued, individuals and also states. And, through these lawsuits, the plaintiffs gained universal injunctions. And what that means is courts ruled that this new executive order not only couldn't be enforced against the plaintiffs themselves but couldn't be enforced against anybody anywhere.
Dave Bittner: So puts a hold on it.
Ben Yellen: Exactly. You couldn't be deported, for example, according to this administration's new definition of citizenship.
Dave Bittner: I see.
Ben Yellen: So let's say in one judicial circuit, the State of Massachusetts is the one that sues to enjoin enforcement of this law. A universal injunction says that doesn't just apply to people living in Massachusetts. It applies across the country.
Dave Bittner: Okay.
Ben Yellen: And there's been a growing pattern in the last 25, 30 years of district court judges across the country issuing these universal injunctions, meaning it applies not just to the plaintiffs, but all across the country. And, when your party is in power in the White House, this grows to be very frustrating because you try and implement policies. People go what's called forum shopping. They find a favorable judge. And the judge, whether they're in Amarillo, Texas or some liberal enclave during a Republican presidency will issue an injunction that applies to the entire country.
Dave Bittner: Now let me -- let me interrupt you just real quick. How far back does this capability go?
Ben Yellen: That's one of the disputes in this case.
Dave Bittner: Okay.
Ben Yellen: What the majority opinion says is it's not well-grounded in our founding and that it really became more prevalent probably in the last 50 years or so.
Dave Bittner: Okay.
Ben Yellen: So you can look at it. There's a lot of good data on the profligate numbers of universal injunctions that we've seen, especially since the year 2000.
Dave Bittner: Okay.
Ben Yellen: So it has been more common recently. The upshot of all of this is that, if there is some executive order or federal policy that seems to be unconstitutional on its face, some plaintiff is going to challenge it. And because of the decision that was handed down last week at the Supreme Court, district courts are going to be unable to issue universal injunctions. Injunctions can only apply to the plaintiffs in that case. This was a 6:3 decision based on normal ideological lines. So we've talked about a lot of cases where there's an executive order or there's even an act of Congress; there is an accusation or an allegation that it violates some principle of the Constitution, First Amendment, Fourteenth Amendment. It gets in front of a district court. And an injunction is put on that policy, and it applies to the entire country. That can't happen anymore. The only way that could happen is if plaintiffs form a class action, and they have to go through the whole process of getting a class of plaintiffs, getting that class certified. That's much more cumbersome.
Dave Bittner: Okay.
Ben Yellen: So the practical result of this is, if you anticipate some policy relating to something that you care about, that you're interested in coming from the Executive Branch, it's going to be a lot harder to get immediate relief unless your jurisdiction, or individuals in your jurisdiction, or your state government is willing to be a party in that lawsuit. So that's something that's really important that happened that I think is worth talking about because it really will apply to any case, including those that we talk about frequently on this podcast.
Dave Bittner: So I have a couple questions.
Ben Yellen: Yeah, yeah.
Dave Bittner: First of all, I guess in the light of current events where folks are being deported at a high rate --
Ben Yellen: Yes.
Dave Bittner: -- is the notion here that the velocity of those deportations will now outstrip the possible velocity of stopping them? In other words, if I grab somebody, take them to another country, it happens too quickly for the enjoinment from --
Ben Yellen: The wheels of justice turn too slowly. Yeah. I mean, that's basically what the dissent said is that this gives the Executive Branch carte blanche to institute policies, and the legal system just simply can't keep up. It's really hard to get a lawsuit together. Got to hire some good lawyers. Your state, if it's the state that's bringing the lawsuit, has to be well-organized. It has to be a state government that's against the policy that's being promulgated by the administration. If it's individual plaintiffs, it has to be plaintiffs who can establish standing. And even if they can't establish standing, individual plaintiffs have a hard time bringing a case in front of a federal judge. It's not easy. It's costly. It's especially not easy to do it expeditiously. So the end-around for this was you just find somebody in the country who can bring a case. There will be a universal injunction, and then that policy is put on hold while courts consider the merits of it. Now that's not going to be able to happen, since we're getting rid of these universal injunctions. Any injunction that's issued, any ruling against a policy will only apply in the jurisdiction which it's brought and to only against the plaintiff, whether that's a single plaintiff, whether it's within a state. It's only going to apply against the parties that were part of that litigation. So, yeah. It is going to slow down the ability to stop policies that are being carried out on something of a mass scale.
Dave Bittner: The other commentary I saw, and I think I've got this right, is that someone was saying this could come back to bite the White House in the butt because I guess a lot of -- a lot of things happen in -- it's the Fifth Circuit?
Ben Yellen: Yes.
Dave Bittner: And so they rely on the Fifth Circuit to do this very thing, and this will take away their ability to do that.
Ben Yellen: Yeah. I mean, I would be more worried -- if I were somebody on the political right, I would be worried about a future Democratic administration where -- let's say President Alexandria Ocasio Cortez forgives all student loans. What happened during the Biden administration is they would go to a district where there's only one federal district court judge. There's one in Amarillo, Texas, which is why I mentioned it.
Dave Bittner: Okay.
Ben Yellen: This judge named Kazmarek, who was nominated by President Trump in his first term, he saw all of the major lawsuits because litigants knew we can get a nationwide injunction if we just go to this one judge. We know he's on our side. We'll get the universal injunction. They're not going to be able to do that anymore. They can go to that judge, but the litigants have to -- are the only ones who are going to be bound by a decision. So it's only going to apply to the specific plaintiffs who bring the case to that judge. So I do think that that would end up hurting a lot of conservative causes in a future where there is a Democratic administration, and I think kind of both sides are being a little too shortsighted about this. A lot of Democrats, including the liberal justices who dissented here, are saying this is a huge problem because it grinds the gears of the judicial branch being able to stop blatantly on constitutional federal actions. But there will be a time in the future when there is a Democratic president where this might end up being advantageous where it stops the ability for the judicial branch to go rogue and issue universal injunctions and vice versa. I think there are conservative members who aren't thinking about the future when they might really appreciate universal injunctions against some liberal policy. So it doesn't fall neatly along ideological lines. I think, assuming that this is a precedent-setting case that survives the test of time, I think it's going to frustrate and please members of both political parties.
Dave Bittner: So suppose a few years down the road everyone collectively decides that this was a bad idea. What's the potential relief to change this? Would this be a legislative move?
Ben Yellen: Yes. So the United States Congress could enact a statute that provides for universal injunctions. The statute that governs the judicial branch right now is the Judiciary Act of 1789. And, if you look at the majority opinion in this decision, it parses that law and comes to the conclusion that that law did not support the widespread use of universal injunctions the way they happen today.
Dave Bittner: Okay.
Ben Yellen: Congress could change that. They could say universal injunctions are legal now, and that's something that they have the power to do.
Dave Bittner: Okay.
Ben Yellen: Do I think that's likely? No, I do not, specifically not in the near term.
Dave Bittner: Yeah.
Ben Yellen: But I could see that being proposed as some type of solution to this problem. It also just could take change to membership of the United States Supreme Court, which happens over a long period of time.
Dave Bittner: Yeah.
Ben Yellen: The Supreme Court reverses previous decisions sometimes. So that would be another avenue to effectuate change on this.
Dave Bittner: Okay. All right. What else you got?
Ben Yellen: So the other case that relates more directly to what we talk about here is a case called Free Speech Coalition, Inc. v. Paxton. Paxton is the Attorney General of State of Texas. You might remember that Texas passed a statute providing for age verification for pornographic websites. So the way they define pornographic websites, I think it's like something like two-thirds of the material has to be pornographic in nature.
Dave Bittner: Right.
Ben Yellen: This is obviously to prevent children from accessing these sites, which I think is a goal that everybody shares. We don't want children being able to view pornographic material.
Dave Bittner: Right.
Ben Yellen: But it burdens adults, and that was the basis of this lawsuit brought by a group representing free speech interests but also supported by the owners of these websites who have a trade organization saying that the process of requiring age verification to use this website puts a chilling effect on adults who have a constitutional right to engage with this material. The Supreme Court, in another 6:3 decision, said that the Texas law is constitutional and that these age verification methods can stay. A big question in this case was what level of scrutiny would apply to a law like this. And I realize this is getting into law school mumbo jumbo. But, if I can just walk through it very quickly --
Dave Bittner: Please.
Ben Yellen: For laws that restrict speech based on that speech's contents, you have to have, in normal parlance, a damn good reason to be instituting a law like that.
Dave Bittner: Right. Okay.
Ben Yellen: In the legal world, we call that strict scrutiny.
Dave Bittner: Okay.
Ben Yellen: So the government has to have a compelling interest. And, basically, there has to be no other way of effectuating that interest than passing the law in question. There was a big question in this case about whether this is a content-based restriction. What Free Speech Coalition and what the pornographic websites were saying and what the dissent is saying in this case is it only applies to a specific type of speech which is pornographic expression. Therefore, that's a content-based restriction. If that's the case, strict scrutiny should apply. Granting that Texas has a compelling interest in keeping children away from pornographic websites, there are other ways to do it that wouldn't be as restrictive. So, for one, you could encourage parents themselves to put up blockers that would prevent their own children from accessing these websites.
Dave Bittner: Right, right. And the websites themselves encourage that. And my understanding is they put, like, flags on their website that said -- that said -- like a beacon that says, This website is pornographic. So please -- so if you're a parent and you install one of those blockers, like, there's no ambiguity, you know. The blocker says, Are you pornographic? And the website says, Yes, we are.
Ben Yellen: Right. Exactly, exactly,
Dave Bittner: Right.
Ben Yellen: So I think that was kind of the best argument for Free Speech Coalition was that Texas might have a compelling interest here; but, given that this is a content-based restriction, you have to use the least restrictive means of achieving that interest. And there are better avenues to do this than these age verification procedures, which sometimes include uploading IDs, having them go through third party validators, which means your personal information could end up on something called the internet.
Dave Bittner: Right.
Ben Yellen: It can be sold, etc., etc., etc. What the majority opinion said is that actually only intermediate scrutiny should apply here, that this isn't really a content-based restriction because it really is intended to apply only against children. There is no provision of this law that prevents adults from accessing these websites. All they have to do is show proof of their age. And because of that, in the Supreme Court's view, this isn't a restriction on content writ large. It's just a restriction on children accessing the content. But it deserves a bit of an increased level of scrutiny, kind of the middle level of scrutiny because it, incidentally, burdens adults' free speech if they have to go through all of these processes and procedures to reach these pornographic websites.
Dave Bittner: Right.
Ben Yellen: So that's why they came up with intermediate scrutiny, which is somewhere between strict scrutiny and the lowest level of review, which is rational basis review.
Dave Bittner: Was intermediate scrutiny a preexisting thing, or is that new for this?
Ben Yellen: It is a preexisting thing. Applies in a very limited number of contexts. One is classifications based on sex and gender subject to intermediate scrutiny. The other is content-neutral restrictions on speech. So city passes a law saying you can't stand outside your neighbor's house with a bullhorn at three in the morning. That's a content-neutral restriction on speech.
Dave Bittner: I see.
Ben Yellen: It applies whether you're reading the phone book or talking about, you know, Gaza and Israel.
Dave Bittner: Right, right.
Ben Yellen: It doesn't depend on the content.
Dave Bittner: Okay.
Ben Yellen: So they're using that intermediate scrutiny here. And, basically, what they say is, under intermediate scrutiny, you don't have to use the least restrictive means of protecting First Amendment rights. As long as the means are rationally related to the government's interest, then it's constitutionally acceptable. And age verification, in the view of the majority here, is a reasonable means to use to achieve that important governmental interest of keeping kids away from pornographic websites. So we're going to see a lot of age verification laws. They've popped up in states across the country. The pornographic websites have been against them. They've fought them at the state legislature level but also in courts. And now we're going to have this precedential ruling that says using common age verification procedures is constitutionally permissible on pornographic websites, even granting that adults have a constitutional right to view this material. And if it incidentally puts a burden on adults' ability to access this material, maybe that person doesn't have valid ID or doesn't want to share their information on the internet, then too bad.
Dave Bittner: Right.
Ben Yellen: The state has met their burden of showing their important governmental objective and that the means are rationally or substantially related to achieving that objective.
Dave Bittner: Huh. What was the dissent?
Ben Yellen: The dissent basically said that this should have been -- this is a content-based restriction. It should have been considered under strict scrutiny. They granted that Texas has that compelling interest in keeping children away from these websites, but the state should have passed a law that used different means, that having age verification procedures isn't the least restrictive means of achieving that objective. And, like I said, they talked about all of the other alternatives that might be easier. Encouraging parents, as you said, to use those features of these websites advertised to keep their kids off of the site. And there are just a big universe of policies that Texas could enact that would be less restrictive than these age verification procedures. So that's basically what the dissent said, that the standard that the majority was using was wrong. And if you apply what in their view is the correct standard, then Texas is not using the least restrictive means from a First Amendment perspective in achieving that objective.
Dave Bittner: So I -- I'm -- it seems to me that the obvious peril here is that, through the process of proving that I am of age, that I make myself vulnerable to some kind of hack or leak or whatever. And next thing I know, you know, the good senator Bittner from the great state of Maryland --
Ben Yellen: We could only be so lucky.
Dave Bittner: -- is a -- you know, a frequent visitor to these sites, right?
Ben Yellen: Right.
Dave Bittner: And so my reputation is damaged. And away goes my seat.
Ben Yellen: That's the risk.
Dave Bittner: And, you know, we ran into this when I was a child with the video rental laws with I believe it was Judge York, who Congress passed a law to -- to make video rental histories private.
Ben Yellen: Yeah.
Dave Bittner: And I think maybe library borrowing as well. So what I wonder is, is there a technological solution here? Because you and I have talked about digital IDs and checking someone's ID. We've talked about some of these systems where you check your ID with a bouncer and how some local bars could potentially be sharing information. Like, let's say somebody got banned from a bar. You know, they could share that. Do not let this person in, right?
Ben Yellen: Right, right.
Dave Bittner: But the flip side of that is, we talked about a system, a technological solution that only shares the information necessary for the verification required.
Ben Yellen: Right.
Dave Bittner: In other words, all it does, all the website asks is, is the person who wants entry of age?
Ben Yellen: Right.
Dave Bittner: And the verification happens locally on my device. It -- my device has knows who I am, where I live, how old I am, my phone number, my address, you know, whatever.
Ben Yellen: Yeah.
Dave Bittner: But all -- the only thing it's answering is, yep. This person's of age.
Ben Yellen: Yeah. So it's kind of unclear whether the Texas law is requiring anything more than that. The way it's worded is that these websites need to basically use, like, universally recognized measures of age verification.
Dave Bittner: Right.
Ben Yellen: And maybe that is what they use. I think the concern from these trade groups and from the Free Speech Coalition is, once this law is actually put into practice, companies are going to be so concerned about being fined or even facing criminal penalties that they don't want to rely on that form of age verification. They want something that's a little bit more strict. So I think that's why there was concern that this law would be stifling First Amendment rights because it would go beyond simply asking people how old they are. It would demand some level of documentation.
Dave Bittner: Yeah. Well, how do you think this will roll through the nation?
Ben Yellen: I think we're going to see a lot of -- as I said, some states have already enacted similar laws to this. I think we're going to see a lot more of them. And I think it might end up hurting the pornographic website industry just because, for a variety of reasons, adults, even if they want to view pornographic materials, might not want to go through the age verification process.
Dave Bittner: Yeah.
Ben Yellen: And obviously there's concerns about the privacy and the integrity of their personal information. So that's going to have a big impact on this industry. Is it a extinction level event for the pornographic industry? I doubt it, given the aggregate demand for pornography in this country.
Dave Bittner: Yeah.
Ben Yellen: But I do think we'll have to look a year or two down the line and try and understand what the impact of this is. It's also not only going to apply to pornographic websites. There's other age restricted material all over the internet. And what this Supreme Court decision is saying is, as it relates to expressive content that might not be suitable for children, whether that's pornographic or whether that's something like a violent video game or violent movie, it is acceptable for states to have age verification measures, even if they incidentally burden the ability of adults to access this material. That's kind of the big impact for the future.
Dave Bittner: It seems to me like an unintended consequence here could be pushing people to black markets.
Ben Yellen: Sure could. Yeah. There's the dark web. People could use Tor. I mean, yeah. That --
Dave Bittner: Right.
Ben Yellen: That could be the alternative. What the Supreme Court would say is not our problem.
Dave Bittner: Right.
Ben Yellen: Like, Texas went through the process of considering what a good law would be. It's our job to determine whether that law is constitutional. It's their job to determine whether that's a solution that's workable, that's actually going to achieve their stated objectives.
Dave Bittner: All right. Well, interesting stuff. I'll tell you what. Let's take a quick break for a message from our sponsor. We will be right back. All right, Ben. My story this week is from the good folks over at 404 Media. And I suppose you could say this is a bit of a follow-up. They did some reporting a little while back about Flock, which is the automated license plate reader company. We've spoken about them.
Ben Yellen: Oh, yeah. We are -- we're the world's foremost podcast experts in automatic license plate readers.
Dave Bittner: License plate readers and stingrays.
Ben Yellen: Yeah.
Dave Bittner: Nobody --
Ben Yellen: Nobody's talked about that more than us.
Dave Bittner: Right, right. So, in response to the reporting that 404 Media had previously done, Flock has actually disabled some of their license plate lookup access for certain states. So they've -- they've disabled national lookup access for law enforcement agencies in Illinois, California, and Virginia. And this follows reporting from 404 Media that, for example, police had performed nationwide searches for ICE Immigration Enforcement, and a Texas officer had used Flock cameras to find a woman who had self-administered an abortion. And so we have these state laws in Illinois, California, and Virginia that prohibit sharing this license plate data out of state or for using it for immigration or healthcare enforcement. So, as a result of this reporting, Flock has clamped down on this. They say they've done a self-audit and found that, yes; perhaps some of their policies needed a little adjustment. But, meanwhile, the Illinois Secretary of State is looking into potential violations by police for sharing this data. What do you make of this, Ben? I mean, to me, this is a nice reminder of the utility and necessity of strong media.
Ben Yellen: That's one really important angle here, that a lot of these investigations came out of media reporting that -- that we covered on this podcast. I think Flock is put in a really difficult position, as are many techno -- technological companies who have created really cool tools. You have some states that are going to embrace those tools. Sometimes the federal government will embrace those tools to effectuate its goals. And then, depending on what those tools are used for, you're going to have states that are adamantly opposed to those tools. And so you have to not only cater your policies but also your business decisions, balancing those interests of some states who think this is going to be great and some states who say, not only can't you use our data, our license plate reader data from our state but we're going to prohibit you from using data obtained in other states to effectuate criminal charges against our citizens. That's probably a really difficult thing to balance. I mean, I almost have some sympathy for them, even though it's a company that's mined a lot of rather personal data. I mean, you can learn a lot about a person if you follow a series of automated license plate reader data points.
Dave Bittner: Right, right.
Ben Yellen: So, yeah. I just think it's really interesting that they have to balance that to stay above water as a business. I imagine that's just something that's really difficult to do.
Dave Bittner: Yeah. This article notes that Virginia's law limits the use of license plate reader data to criminal investigations, human trafficking, stolen vehicles, and missing persons. And that law just went into effect. So that's putting interesting guardrails around it as well so all sorts of things that you can't use this for.
Ben Yellen: Yeah. That's right. And I think if I'm Flock, like, that's probably going to end up hurting my bottom line. But they also just don't want to get on the bad side of these states, especially these blue states who have this really acute interest on two policy areas, abortion and immigration, because we've now seen national agencies, when it comes to immigration using this data to enforce ICE policies, which are quite unpopular in these jurisdictions, and then other states using data that they've obtained from license plate readers to prosecute people for traveling to New York and California and Illinois to obtain abortions.
Dave Bittner: Right.
Ben Yellen: So, yeah. It just becomes kind of dangerous territory for a company that -- that has these cameras.
Dave Bittner: So I -- I wonder, if you compare this to something like gun rights, right --
Ben Yellen: Right.
Dave Bittner: -- I think about someone who -- let's imagine a snowbird, you know, somebody living -- let's just go all the way up the East Coast, right.
Ben Yellen: Maine.
Dave Bittner: Someone lives in Maine, and they spend their winters in Florida. And so, to do so, they get in their car; and they drive all the way down Route 95 down to Florida.
Ben Yellen: Can't have a gun here. Can't have a gun there.
Dave Bittner: Exactly. That's my point.
Ben Yellen: When you get down to the Carolinas, you know.
Dave Bittner: Right. So you've got this patchwork of what's allowed from state to state. And, you know, all you're doing is trying to exercise your Second Amendment right to have your firearm and get it from point A to point B, and you have this patchwork of regulations, right, that -- that you have to be mindful from -- mindful of along the way. And I just wonder, like, you know, how does -- if we look at something like that and then we apply that to these license plate laws, which I suppose are, at their root, privacy laws, are we ending up with this strange situation for interstate travel and perhaps commerce, you know, where someone just in the course of their day-to-day business making their way up and down the East Coast might find themselves in a strange situation.
Ben Yellen: Yeah. I'll give you two answers. In a broad sense, yes. But I also think it's worth noting that, according to this Supreme Court, people do have a constitutional right to, as individuals, to carry firearms in all 50 states and the District of Columbia, subject to certain types of acceptable regulation. That is no longer the case for abortion rights and certainly not the case for the right to be free from Immigration and Customs Enforcement. So I do think it applies differently in those contexts. But, yeah. That's just the nature of our federal system. Like, I think people from other countries probably look at this and think it's so weird that we can just have such drastically different laws between states. But that's kind of the point, that states are these laboratories. People can vote with their feet. And what we're seeing here in this story is just a consequence of that system.
Dave Bittner: Do you have any sense, just to bring it local, for the two of us? Do you have any sense? Has there been any conversations that you're aware of? Because I know you are quite interactive with our state legislature here in Maryland. Have there any -- been any conversations that you've been aware of when it comes to things like license plate data?
Ben Yellen: I've heard it just in the context of broader privacy laws. Maryland now has a comprehensive data privacy law. And I think, even though it's -- I don't think it's explicitly mentioned in the law, certainly something like automatic license plate readers has been considered. And I think for, like, sector-specific laws, you might see references to automatic license plate readers. So, yeah. I think it's certainly on the radar of legislators here.
Dave Bittner: Yeah. Interesting. All right. Well, we will have a link to that story in the show notes, And, of course, we would love to hear from you. If there's something you'd like us to consider for the show, you can email us. It's caveat@n2k.com. And that is Caveat, brought to you by N2K CyberWire. We'd love to hear from you. We're conducting our annual audience survey to learn more about our listeners. We're collecting your insights through the end of this summer. There is a link in the show notes, and we do hope you will check it out. This episode is produced by Liz Stokes. Our executive producer is Jennifer Eiben. The show is mixed by Tré Hester. Peter Kilpe is our publisher. I'm Dave Bittner.
Ben Yellen: I'm Ben Yellen.
Dave Bittner: Thanks for listening.
