`
`COMMISSIONERS:
`
`192 3000
`
`
`
`DOCKET NO.
`
`UNITED STATES OF AMERICA
`BEFORE THE FEDERAL TRADE COMMISSION
`
`Rebecca Kelly Slaughter, Acting Chairwoman
`
` Noah Joshua Phillips
`Rohit Chopra
`Christine S. Wilson
`
`________________________________________________
`
`In the Matter of
`
`MOVIEPASS, INC., a corporation,
`
`
` HELIOS AND MATHESON ANALYTICS,
`INC., a corporation,
`
`MITCHELL LOWE, individually and as an
`officer of MOVIEPASS, INC., and
`
`
`THEODORE FARNSWORTH, individually and
`as an officer of HELIOS AND MATHESON
`
` ANALYTICS, INC.
`
`________________________________________________
`
`
`
`
`COMPLAINT
`
`
`
`The Federal Trade Commission, having reason to believe that MoviePass, Inc., a
`
`corporation, Helios and Matheson Analytics, Inc., a corporation, Mitchell Lowe, individually and
`as an officer of MoviePass, Inc., and Theodore Farnsworth, individually and as an officer of
`Helios and Matheson Analytics, Inc. (collectively, “Respondents”), have violated the provisions
`of the Federal Trade Commission Act, 15 U.S.C. § 45, and the Restore Online Shoppers’
`Confidence Act (“ROSCA”), 15 U.S.C. § 8403, and it appearing to the Commission that this
`proceeding is in the public interest, alleges:
`
`
`
`1.
`
`
`2.
`
`Respondent MoviePass, Inc. is a Delaware corporation with its principal place of
`business at 350 Fifth Avenue, Suite 5330, New York, New York 10118. Respondent
`MoviePass is a subsidiary of Helios and Matheson Analytics, Inc., which acquired a
`controlling interest in August 2017 and more than 90 percent of the company by April
`2018.
`
`Respondent Helios and Matheson Analytics, Inc. (“Helios”) is a Delaware
`corporation with its principal place of business also at 350 Fifth Avenue, Suite 5330,
`New York, New York 10118.
`
`

`

`
`
`3.
`
`
`
`4.
`
`
`
`5.
`
`
`
`6.
`
`
`
`7.
`
`
`8.
`
`
`9.
`
`
`
`
`
`
`
`
`
`Respondent Mitchell Lowe (“Lowe”) is the Chief Executive Officer of Respondent
`MoviePass. Individually or in concert with others, he controlled or had the authority
`to control, or participated in the acts and practices of Respondent MoviePass,
`including those relating to its advertising, marketing, public relations, data security,
`customer service, and the acts and practices alleged in this complaint. At all times
`material to this complaint, his principal office or place of business was the same as
`that of Respondents MoviePass and Helios.
`
`Respondent Theodore Farnsworth (“Farnsworth”) was the Chief Executive Officer of
`Helios until September 2019. Individually or in concert with others, he controlled or
`had the authority to control, or participated in the acts and practices of Respondents
`MoviePass and Helios, including those relating to Respondent MoviePass’s
`advertising, marketing, public relations, customer service, and the acts and practices
`alleged in this complaint. At all times material to this complaint, his principal office
`or place of business was the same as that of Respondents MoviePass and Helios.
`
`Respondents MoviePass and Helios (collectively, “Corporate Respondents”) have
`operated as a common enterprise while engaging in the unlawful acts and practices
`alleged below. Corporate Respondents have conducted the business practices
`described below through interrelated companies that have common ownership,
`managers, employees, and office locations. Because these Corporate Respondents
`have operated as a common enterprise, each of them is jointly and severally liable for
`the acts and practices alleged below. Lowe and Farnsworth have formulated, directed,
`controlled, or had the authority to control, or participated in the acts and practices of
`the common enterprise alleged in this complaint.
`
`Respondents have advertised, offered for sale, sold, and distributed services to
`consumers, including the MoviePass movie viewing subscription service.
`
`The acts and practices of Respondents alleged in this complaint have been in or
`affecting commerce, as “commerce” is defined in Section 4 of the Federal Trade
`Commission Act.
`
`RESPONDENTS’ BUSINESS PRACTICES
`
`In 2011, Respondent MoviePass launched a “MoviePass” subscription service that
`allowed consumers to view movies at their local theaters for a monthly fee. Between
`2011 and 2017, Respondent MoviePass offered a variety of subscription plans at
`different price points, which were generally sold through a negative option in which
`consumers continued to pay a monthly fee for the service unless they affirmatively
`canceled their subscriptions.
`
`In August 2017, Respondents re-launched the MoviePass service nationwide, offering
`consumers “unlimited” movie viewings at theaters for $9.95 per month, again sold as
`a negative option. Respondents expressly marketed the service (a) as offering
`
`2
`
`

`

`
`
`
`
`
`
`
`
`“Unlimited movies for only $9.95/month”; (b) as providing access to “ANY MOVIE
`ANY THEATER ANY DAY,” including “ALL MAJOR MOVIES” in “ALL
`MAJOR THEATERS”; and (c) as allowing consumers to “[e]njoy a new movie every
`day.” The following marketing materials were representative of its advertisements
`during the period material to this complaint:
`
`
`Figure 1 (image produced to the FTC by Respondent MoviePass on June 14, 2019).
`
`
`
`3
`
`

`

`
`
`
`
`
`
`Figure 2 (image produced to the FTC by Respondent MoviePass on June 14, 2019).
`
`
`
`
`
`Figure 3 (image produced to the FTC by Respondent MoviePass on June 14, 2019).
`
`
`
`
`4
`
`

`

`
`
`
`
`
`10.
`
`
`11.
`
`
`
`12.
`
`Respondents had attracted approximately 3.2 million subscribers to MoviePass by
`early 2018. By this time, however, Corporate Respondents were already incurring
`financial losses due to the cost of the movie tickets subscribers acquired through the
`service.
`
`
`a. In Respondent Helios’s April 2018 Form 10-K filing, its auditors “expressed
`
`substantial doubt about [Respondent Helios’s] ability to continue as a going
`concern.”
`
`
`b. In a May 2018 SEC filing, Respondent Helios provided a “Financial Update” in
`which it disclosed that it ran an average cash deficit of $21.7 million per month
`from September 30, 2017 to April 30, 2018.
`
`RESPONDENTS DECEPTIVELY PREVENTED SUBSCRIBERS FROM USING
`MOVIEPASS AS ADVERTISED
` 
` 
`In April 2018, Respondents devised and implemented “password disruption” and
`“ticket verification” programs in tandem to limit frequent MoviePass users’ ability to
`
`view movies through the service as advertised.
`
`
`
`13.
`
`
`14.
`
`Password Disruption. Under Respondents’ password disruption program,
`Respondents invalidated the passwords of the 75,000 subscribers who used the
`service most frequently while claiming that “we have detected suspicious activity or
`
`
`potential fraud” on the affected subscribers’ accounts.
`
`This representation regarding purported “suspicious activity” caused one MoviePass
`executive to advise that it “could insinuate there may have been a data breach”
`(emphasis in original) and another to advise that “[i]t will go on [an online forum]
`
`and suspicions will arise … ‘were they hacked?’ ‘Is our data really safe?’”
`
`
`The password disruption program impeded subscribers’ ability to view movies
`because MoviePass’s password reset process often failed.
`
`
`
`a. To reset their passwords, subscribers generally had to complete four steps:
`(i) enter their email addresses into the MoviePass app’s “Reset Password” tool;
`(ii) wait for Respondent MoviePass to send an email with a password reset
`hyperlink; (iii) respond to the email by clicking on a hyperlink in the email; and
`(iv) fill out password reset information on a webpage accessed by the hyperlink.
`
`
`
`b. Subscribers were often unable to reset their passwords because (i) the app would
`not accept their email address; (ii) the subscriber would never receive a password
`reset email; or (iii) the email’s hyperlink would lead to a “Page Not Found”
`notification.
`
`
`c. Indeed, when discussing the password disruption program, a MoviePass executive
`acknowledged that subscribers using a common smartphone operating system
`
`
`5
`
`

`

`
`
`
`
`15.
`
`
`16.
`
`would encounter technical difficulty in resetting their passwords.
`
`
`d. When subscribers attempted to contact MoviePass’s customer service about their
`inability to reset their MoviePass passwords, Respondents often responded weeks
`later or not at all.
`
`
`e. As a result of password reset failures and related poor customer service,
`subscribers who were required to reset their passwords were often unable to reset
`their passwords or to reset their passwords in a timely manner.
`
`Both Lowe and Farnsworth knew of, ordered, or helped execute the password
`disruption program.
`
`
`a. On April 11, 2018, an employee of Respondent Helios, writing from Farnsworth’s
`personal email address and expressly “on behalf of Ted [Farnsworth]” to Lowe
`and others, proposed a notice that informed subscribers that their account
`passwords were required to be reset due to “suspicious activity or potential
`fraud.”
`
`
`b. Lowe circulated the proposed notice to MoviePass executives for comment and
`personally ordered subscribers’ passwords to be disrupted in accordance with this
`plan. Lowe also personally chose the number of consumers who would be
`affected by the program.
`
`Both Lowe and Farnsworth were aware of the deceptive nature of the password
`disruption program even at the time they were formulating it and understood its
`negative effect on consumers.
`
`
`a. When Lowe and Farnsworth presented the disruption program to other executives
`of Respondent MoviePass, one executive warned that the password disruption
` program “would be targeting all of our heavy users” and that “there is a high risk
`
`this would catch the FTC’s attention (and State AG’s attention) and could
`reinvigorate their questioning of MoviePass, this time from a Consumer
`Protection standpoint.” (Emphasis in original).
`
`
`b. Another executive agreed, warning of “FTC Fears: All [the other MoviePass
`executive’s] notes about FTC and PR [public relations] fire are my main concerns
`as I think the PR backlash will flame the FTC stuff.” (Emphasis in original).
`
`
`c. In response to these concerns, Lowe responded, “Ok I get it. So let[’]s try this
`with a small group. Let[’]s say 2% of our highest volume users.”
`
`
`d. Respondents MoviePass and Lowe tracked the effect of password disruption on
`subscribers’ use of the service. For example, Respondents MoviePass and Lowe
`found that only one-half of affected subscribers had successfully reset their
`
`6
`
`

`

`
`
`
`
`
`17.
`
`
`18.
`
`
`19.
`
`
`20.
`
`
`21.
`
`
`22.
`
`
`23.
`
`passwords one week after they executed their plan.
`
` Respondents’ password disruption program prevented many subscribers who were
`
`using MoviePass in compliance with its terms of use from viewing movies with their
`MoviePass subscriptions.
`
`Ticket Verification. Also in April 2018, Respondents imposed a ticket verification
`program to prevent certain subscribers from using the service.
`
`The ticket verification program required subscribers to take and submit pictures of
`their physical movie ticket stubs for approval through the MoviePass app within a
`certain timeframe. Only tickets accepted by Respondent MoviePass’s automated
`system qualified as properly submitted, and the program terms warned: (a) that
`
`subscribers whose pictures were not verified by the automated system would not be
`able to view future films until they uploaded a photo; and (b) that subscribers whose
`pictures were not verified by the automated system more than once would have their
`subscriptions canceled.
`
`
`Respondents imposed this ticket verification requirement on the 20 percent of
`subscribers who used the MoviePass service most frequently while representing to
`these approximately 450,000 consumers that they had been “randomly selected” for
`the program and that it was intended to ensure compliance with MoviePass’s terms of
`use.
`
`The ticket verification program obstructed thousands of subscribers’ ability to use
`MoviePass because: (a) the automated ticket verification program often did not
`function on certain common smartphone operating systems; (b) the program’s
`software often failed to recognize pictures of the ticket stubs subscribers submitted;
`and (c) Respondents were unable to handle the volume of customer service
`complaints relating to the program, which left subscribers’ complaints unresolved.
`
`Both Lowe and Farnsworth knew of, ordered, or helped execute the ticket verification
`program.
`
`
`a. Lowe was aware of the ticket verification program and personally chose the
`number of consumers who would be subject to the program.
`
`
`b. Farnsworth was aware of the ticket verification program and received at least one
`report about the program’s effect on consumers.
`
`Lowe was aware that the ticket verification program was deceptive and understood its
`negative effect on consumers.
`
`
`a. Respondents MoviePass and Lowe used the program to limit consumers’ viewing
`of a major motion picture. When a MoviePass executive suggested that they delay
`an increase of ticket verification as “dry powder” to reduce ticket purchases for an
`
`7
`
`

`

`
`
`
`
`
`
`upcoming major film release, Lowe responded, “Yes i [sic] agree to hold our
`
` powder for [the film].”
`
`
`b. When Lowe was advised by a MoviePass executive that the ticket verification and
`password disruption programs would render Respondent MoviePass “not [] able
`to keep up in incoming [consumer complaint] volume this weekend,” Lowe
`responded, “Yep we understand.”
`
`
`c. Respondents MoviePass and Lowe tracked the program’s effect on subscribers
`and the anticipated reduction in usage the program would cause.
`
`Respondents’ ticket verification program prevented many subscribers who were using
`MoviePass in compliance with its terms of use from viewing movies with their
`MoviePass subscriptions.
` 
`
`Trip Wires. By approximately August 2018, Respondents devised another program to
`prevent frequent users from viewing one movie per day with MoviePass as
`Respondents had advertised: undisclosed financial thresholds that Respondents
`referred to as “trip wires.”
`
`To implement trip wires, Respondents placed subscribers into groups based upon how
`frequently they used MoviePass. Respondents assigned a dollar allotment to each
`group so that subscribers in the same group would collectively only be able to
`
`purchase a limited number of tickets using the MoviePass service.
`
`Respondents typically imposed their trip wire financial thresholds on subscribers who
`viewed more than three movies per month using MoviePass—far fewer than the “one
`movie per day” limit that MoviePass represented when marketing MoviePass.
`
`Subscribers were unaware that they had been placed in these groups or that they were
`subject to these financial trip wires: the practice was not disclosed in Respondents’
`advertising or terms of use, and MoviePass customer service did not tell affected
`subscribers who had lost access to MoviePass that they were subject to them.
`
`Once a given group hit its “trip wire” threshold, Respondents denied access to the
`MoviePass service to all subscribers in that group. Subscribers affected by the trip
`wire would be unable to use the MoviePass service when they attempted to use it,
`
`often after having already traveled to a movie theater intending to use the service.
`
`Both Lowe and Farnsworth knew of, ordered, or helped execute the trip wire
`
`program.
`
`
`a. Lowe was aware of the trip wire program and personally set the trip wire
`thresholds.
`
`
`
`24.
`
`
`25.
`
`
`26.
`
`
`27.
`
`
`28.
`
`
`29.
`
`
`30.
`
`8
`
`

`

`
`
`
`
`
`31.
`
`
`32.
`
`
`
`
`
`33.
`
`
`34.
`
`
`35.
`
`
`36.
`
`
`b. Farnsworth was aware of the trip wire program and received at least one report
`about its implementation and effect on consumers.
`
`Lowe was aware that trip wire program was deceptive and understood its negative
`effect on consumers.
`
`
`a. On April 4, 2019, Lowe explained in an email that the “beauty of the cap [i.e. trip
`wire financial threshold]” was that “heavy users compete against other heavy
`users for tickets.”
`
`
`b. The following week, Lowe participated in correspondence regarding trip wire-
`related consumer complaints where a senior manager noted that “[w]e do have our
`hands tied as far as an explanation goes as we do not want to tell them they’ve
`consumed too much . . . These users are under the assumption that they’re
`uncapped, so it’s going to be tricky coming up with the right wording.”
`
`Respondents’ trip wire program prevented many subscribers who were using
`MoviePass in compliance with its terms of use from viewing movies with their
`MoviePass subscriptions.
` 
`
`RESTORE ONLINE SHOPPERS’ CONFIDENCE ACT
`
`
`In 2010, Congress passed the Restore Online Shoppers’ Confidence Act, 15 U.S.C.
`§§ 8401 et seq., which became effective on December 29, 2010. Congress passed
`ROSCA because “[c]onsumer confidence is essential to the growth of online
`commerce. To continue its development as a marketplace, the Internet must provide
`
`consumers with clear, accurate information and give sellers an opportunity to fairly
`compete with one another for consumers’ business.” Section 2 of ROSCA, 15 U.S.C.
`§ 8401.
` 
`Section 4 of ROSCA, 15 U.S.C. § 8403, generally prohibits charging consumers for
`goods or services sold in transactions effected on the Internet through a negative
`option feature, as that term is defined in the Commission’s Telemarketing Sales Rule
`(“TSR”), 16 C.F.R. § 310.2(w), unless the seller (1) clearly and conspicuously
`discloses all material terms of the transaction before obtaining the consumer’s billing
`information, (2) obtains the consumer’s express informed consent before making the
`charge, and (3) provides a simple mechanism to stop recurring charges. See 15 U.S.C.
`§ 8403.
` 
`The TSR defines a negative option feature as: “in an offer or agreement to sell or
`
`provide any goods or services, a provision under which the consumer’s silence or
`failure to take an affirmative action to reject goods or services or to cancel the
`agreement is interpreted by the seller as acceptance of the offer.” 16 C.F.R.
`§ 310.2(w).
` 
`As described in Paragraphs 8 to 10, above, Respondents have advertised and sold
`subscriptions to the MoviePass service to consumers through a negative option
`9
`
`

`

`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`37.
`
`
`
`
`
`
`38.
`
`
`39.
`
`
`40.
`
`
`41.
`
`feature as defined by the TSR. See 16 C.F.R. § 310.2(w).
` 
`Pursuant to Section 5 of ROSCA, 15 U.S.C. § 8404, a violation of ROSCA is a
`violation of a rule promulgated under Section 18 of the FTC Act, 15 U.S.C. § 57a.
` 
`
`VIOLATIONS OF THE FTC ACT
`
`Count I – All Respondents
`Misrepresenting MoviePass
`
`In connection with the advertising, promotion, offering for sale, or sale of the
`MoviePass subscription service, Respondents have represented, directly or indirectly,
`expressly or by implication, that consumers who purchase a MoviePass subscription:
`
`
`a. could use MoviePass to view one movie per day at their local movie theaters; and
`
`
`b. could use MoviePass to view any movie, in any theater, at any time.
`
`In numerous instances in which Respondents made these representations, consumers
`who purchased a MoviePass subscription:
` 
`
`a. could not use MoviePass to view one movie per day at their local movie theaters;
`and
` 
`
`b. could not use MoviePass to view any movie, in any theater, at any time.
`
` 
`
`Therefore, the representations set forth in Paragraph 38 are false or misleading.
`
`VIOLATIONS OF ROSCA
` 
`
`Count II – All Respondents
`Violations of ROSCA
`
`In numerous instances, in connection with charging consumers for goods or services
`sold in transactions effected on the Internet through a negative option feature, as
`described in Paragraphs 11—32 above, Respondents have failed to:
`
`
`a. clearly and conspicuously disclose all material terms of the transaction before
`obtaining the consumer’s billing information; or
`
`
`b. obtain the consumer’s express informed consent before charging the consumer’s
`credit card, debit card, bank account, or other financial account for the
`
`transaction.
`
`Respondents’ practices as set forth in Paragraph 40 are a violation of Section 4 of
`ROSCA, 15 U.S.C. § 8403, and are therefore a violation of a rule promulgated under
`Section 18 of the FTC Act, 15 U.S.C. § 57a, 15 U.S.C. § 8404(a), and therefore
`10
`
`

`

`
`
`
`
`constitute an unfair or deceptive act or practice in violation of Section 5(a) of the FTC
`
`Act, 15 U.S.C. § 45(a).
`
`
`RESPONDENTS’ FAILURE TO TAKE REASONABLE MEASURES
`TO SECURE CONSUMERS’ DATA
`
` Respondent MoviePass collected significant amounts of personal information from
`
`consumers in connection with its subscriptions, including first name, last name, postal
`address, email address, birth date, gender, credit card number, CVV, expiration date,
`billing address, card type, geolocation information, user reviews, and movies
`attended.
`
`
`In MoviePass’s privacy policy, Respondent MoviePass made representations about its
`data security practices concerning personal information collected from consumers.
`
`Respondent MoviePass represented, in relevant part, that it “takes information
`security very seriously” and “uses reasonable administrative technical, physical, and
`managerial measures to protect [consumers’] personal details from unauthorized
`access.”
`
`Respondent MoviePass further represented that it stored consumers’ email addresses
`and payment information in “an encrypted form.”
`
`Lowe was responsible for Respondent MoviePass’s consumer response and
`communication policies, practices, and procedures. These responsibilities include
`oversight of the representations Respondent MoviePass has made to consumers
`regarding data security.
`
`Lowe was also responsible for the oversight of Respondent MoviePass’s data security
`practices.
`
`On August 20, 2019, media outlets reported that a security researcher had allegedly
`breached an exposed Respondent MoviePass database containing large amounts of
`consumers’ personal information.
`
`Respondent MoviePass confirmed the data breach on August 22, 2019 through a
`prepared statement, acknowledging “a security vulnerability that may have exposed
`subscriber records” and promising to “diligently [] investigate the scope of [the]
`incident and its potential impact on [MoviePass’s] subscribers.”
`
`Following an investigation into the breach, Respondent MoviePass found that certain
`personal information of consumers had been exposed between April 25, 2019, and
`August 20, 2019.
`
`According to Respondent MoviePass’s analysis, the breach exposed a server
`containing unencrypted personal information. The unencrypted information contained
`
`
`
`42.
`
`
`43.
`
`
`44.
`
`
`45.
`
`
`46.
`
`
`47.
`
`
`48.
`
`
`49.
`
`
`50.
`
`
`51.
`
`11
`
`

`

`
`
`
`52.
`
`
`53.
`
`
`
`
`
`
`
`54.
`
`
`
`approximately 28,191 consumers’ financial information—i.e., the name on the credit
`card, the credit card number, the expiration date of credit card, the billing address,
`and the type of card—and other personal information, including first name, last name,
`postal address, email address, birth date, gender, geolocation, user reviews, and
`movies attended.
`
`Respondent MoviePass’s analysis also indicated that the exposed server was accessed
`several times from countries where the company does not operate or otherwise have
`any relationships.
`
`This breach was made possible by the failure of Respondents MoviePass and Lowe to
`take reasonable steps to protect consumers’ personal information stored on its
`network from unauthorized access. In fact, Respondents MoviePass and Lowe
`engaged in a number of practices that failed to provide reasonable security for
`consumers’ personal information stored on its network. Among other things,
`Respondents MoviePass and Lowe:
`
`
`a. Stored consumers’ personal information, including financial information and
`email addresses in clear text;
`
`
`b. Failed to assess the risks to the personal information stored on its network, such
`as by conducting periodic risk assessments or performing vulnerability and
`penetration testing of the network;
`
`
`c. Failed to maintain and manage security controls that protect and restrict access to
`consumers’ personal information. For example, Respondent MoviePass disabled
`its firewall and loaded consumers’ personal information onto a server in April
`2019 in a manner that left the information accessible to any parties with an
`internet connection;
`
`
`
`d. Failed to provide adequate security training to its employees; and
`
`
`e. Failed to implement safeguards to detect anomalous activity and/or cybersecurity
`events, such as an adequate intrusion prevention or detection system to alert of
`potentially unauthorized access to Respondent MoviePass’s network or servers.
` 
`
`VIOLATIONS OF THE FTC ACT
`
`Count III – Respondents MoviePass, Helios, and Lowe
`
`Deceptive Failure to Take Reasonable Measures to Protect Consumer Data
`
`As described in Paragraphs 43—45, Respondents MoviePass, Helios, and Lowe have
`represented, directly or indirectly, expressly or by implication, that they used reasonable
`administrative, technical, physical, and managerial measures to protect consumers’
`personal information from unauthorized access.
`
`
`
`12
`
`

`

`
`
`
`55.
`
`
`
`
`
`56.
`
`In fact, as set forth in Paragraphs 48—53, Respondents MoviePass, Helios, and Lowe
`have failed to use reasonable administrative, technical, physical, and managerial
`measures to protect consumers’ personal data from unauthorized access. Therefore, the
`representations set forth in Paragraph 54 are false or misleading.
`
`VIOLATIONS OF SECTION 5 AND ROSCA
`
`The acts and practices of Respondents as alleged in this complaint constitute unfair or
`deceptive acts or practices, and the making of false advertisements, in or affecting
`commerce in violation of Section 5(a) of the Federal Trade Commission Act and Section
`4 of the Restore Online Shoppers’ Confidence Act.
`
`
`THEREFORE, the Federal Trade Commission this _______ day of _______, 2021, has
`
`issued this Complaint against Respondents.
`
`
`
`
`
`
`SEAL:
`
`
`By the Commission.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` Tabor
`
`April
`
`J.
`
`
`
`
` Secretary
`Acting
`
`
`
`
`
`
`
`13
`
`