Estonia has become the country of European entrepreneurs. Something like a small, and yes, icy Silicon Valley in the middle of the European Union. The question is, how the hell have they achieved such an evolution in such a short time? What does the Estonian model hide? What are the ingredients of your success? Well… Here, as we already mentioned in a special video on Patreon, we can highlight several factors: from fiscal policy to its commitment to technology. And, also, among the most important ingredients of Estonian success is its educational system. You may not know it and you never would have imagined it but Estonia has the best educational system in all of Europe. In fact, it calls itself the "Education Nation", the nation of education. In this video we tell you all the details about a unique system
Brain Drain From Britain Delivers Financial Boon to Estonia
The former Soviet satellite state is welcoming British companies looking to escape the tangle of regulations and financial obstacles of doing business in Europe
At first Vicky Brock struggled to place Estonia on the map. And when she flew to the Baltic nation last December, she took just hand luggage, assuming it would be a short trip.
Eleven months later Ms. Brock, a British technology entrepreneur, is still there, living and working as what she calls a “Brexit refugee.”
Ms. Brock split her Scotland-based start-up and set up half of it to operate in Estonia, a country of 1.3 million people that is welcoming companies looking to escape the tangle of regulations and financial obstacles that Brexit imposes on British firms doing business in Europe.
Several thousand other company leaders have done the same, some physically moving like Ms. Brock but most staying in Britain while shifting their business registration to Estonia. By doing so, they can take advantage of the country’s membership in the European Union and therefore gain something Britain has lost: free access to the bloc’s giant single market of more than 400 million people.Britain’s Split From the E.U.What is Brexit? Here is a guide to what it means, how it came about and what the future may hold.
Their departure is a stark example of one of the negative impacts of Brexit, which critics say ties up exporters with mountains of new paperwork, imposes new restrictions on trade and limits their ability to recruit workers from abroad.
For Estonia, the influx of British businesses, especially technology firms, has contributed to a big jump in tax revenues and reinforced the country’s reputation as a hub of innovation.
The situation is a striking turnaround for a country that, like other Baltic States, suffered an exodus of some of its brightest young workers after 2004, when joining the European Union gave its citizens the right to live and work in Britain, then a member country.
Now the brain drain is in the other direction.
Ms. Brock’s technology company, Vistalworks, which combats online illegal trade, was founded in 2019, three years after Britain’s Brexit referendum. She knew that new Brexit-imposed trade and non-tariff barriers could impede her ability to do business in continental Europe, particularly if the rules on data transfers — vital to her company — were altered.
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Then British firms started being frozen out of European research projects and public procurement contracts. So Ms. Brock went “shopping for countries” in which to base her company, prioritizing rule of law, anti-corruption efforts, financial transparency and low taxes
“I didn’t really know where Estonia was but it shone out on all of those lists,” said Ms. Brock, speaking on a video call from a shared work space in her adopted home, Tallinn, the Estonian capital.
She said she plans to hire up to 30 staff members in the next nine months. Eventually, around two-thirds of Vistalworks will be based in Estonia, and those workers will pay income and payroll taxes there, not in Britain. Corporate tax on the European company will be levied in Estonia too.
At the end of 2020 Ms. Brock and her business partner and husband, Stephen Budd, headed to Estonia before a Brexit-related deadline to request residency rights in the Baltic country. They took only hand luggage, expecting a speedy return to Scotland and then a period of reflection on where to live and how to proceed with their business. That plan was upended by coronavirus travel restrictions, forcing them into a choice.
“We are learning Estonian and managing both the U.K. team and the growing E.U. team from here,” she said.
Estonia is only one of a number of countries that offer such opportunities for so-called “digital nomads” who do not need to live in the country. But more than 4,000 British firms have seen the benefit, helping to swell Estonian tax revenues by 60 percent compared to 2020, according to comments by the country’s prime minister, Kaja Kallas, in an interview with the British business newspaper City AM. She estimated the tax gain at 51 million euros.
Estonia has received applications for e-Residency, as it is known, from 176 countries, with Britain ranking fourth in the list of non-European Union nations after Russia, Ukraine and China. Being given e-Residency does not grant you citizenship, tax residency or entry into Estonia or the rest of the European Union.
However it does come with the advantage of a 20 percent tax rate for both income tax and corporate tax. The latter is levied only when profits are distributed (rather than when they are earned), allowing firms to grow with a low tax burden. In Britain the income tax rate for top earners is 40 percent on much of their earnings and, for the very highest paid, it rises above that.
E-residency “clearly increased after Brexit, even before actually, even when the vote happened, we saw a spike,” Ms. Kallas told City AM.
Hannes Lentsius, a director and tax specialist at PwC accountants in Estonia, described the government’s estimates of increased tax revenue as credible and said that the e-Residency scheme had worked well for the country. “Brexit has been part of it,” he said adding that e-Residency “has been a great success, it has marketed Estonia.’’
Another British business owner who saw the potential in Estonia is David Fortune, who co-founded his company, Saher, in 2014. Saher does much of its work with European police departments and border guards, matching innovative technologies, like counter drone systems, to their needs.
Mr. Fortune served for 30 years with the police in North Yorkshire, in the north of England, where he still lives, and is surprised to find himself an Estonian e-Resident.
“As a nearly 60-year-old ex-cop I don’t think I’ve ever thought of myself as a digital nomad,” he said. However, becoming one was pretty easy. The Estonians provided a first-rate service to help him, including advice sessions with tax and customs authorities, he said.
“They answer questions in English within 48 hours,” he said. “I have nothing but praise for the people we have dealt with.”
There are benefits for Estonia too: the growth of the European side of Saher has overtaken the British one, and generates tens of thousands of euros in tax revenue each quarter.
“This was not because we had a downer on the U.K., it’s just about survival and was necessary to grow our business brand as we wanted it to grow,” said Mr. Fortune. But he said he had no plans to physically relocate.
Ruth Paterson spent more than a decade building up her company, Woolly Wormhead, in Britain before Brexit forced her into a business and personal choice. Her online publishing firm sells designs for knitted hats and there was uncertainty over whether Brexit would change digital trading rules, for example on sales taxes. Ms. Paterson was also spending time in Italy — where she is now resident — as well as Britain, so it made sense to base the company in the European Union. She became an e-Resident of Estonia in 2017.
“It was one of the best things I’ve ever done, my turnover doubled in two years,” she said referring to the amount of money flowing into the business during the pre-pandemic period. That, she said, is because the Estonian system is digitalized, integrated and requires less of her time, and she can devote more energy to creative work.
Resource: The New York Times
Estonia – a European and global leader in the digitalisation of public services
November 15, 2021
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Estonia ranks 7th in the DESI 2021, with a score higher than the EU average. The country is a frontrunner in Digital public services and performs very well on Human Capital. There is room for improvement in Connectivity and the deployment of 5G.
“Estonia has achieved a lot on our digital journey, and I am pleased to see that we are once again ranking first in the development of digital public services and among the European top10 countries overall. We are rightfully known as the most advanced digital society in the world. Still, we do have our challenges,” the Estonian minister of Entrepreneurship and Information Technology Andres Sutt noted.
According to the minister, the recently adopted new Digital Agenda 2030 will be the cornerstone of future digital developments. It sets goals and an action plan for maintaining what has been built in the e-Estonia so far and at the same time further developing the Estonian economy, state and society with the help of new digital technologies.
The 1st in digital public services…
Estonia ranks 1st place in the EU on Digital public services and continues to be a strong frontrunner in this area. The share of e-government users has slowly increased in recent years, accounting for 89% of total internet users in the country. Estonia performed better than in 2020 in the number of users using pre-filled forms, scoring 97 (out of 100), and well above the EU average (63).
…but lagging in 5G
On Connectivity, both fixed- and mobile broadband take-up is high. Estonia has high overall coverage of fixed Very High Capacity Network (VHCN) connectivity, except in rural areas where additional investments are needed.
But on a more critical note – the country lags in providing 5G commercial service because the spectrum resources necessary to operate 5G networks have not been allocated yet. Nevertheless, Estonia’s ambition for 5G connectivity is to cover major cities by 2023 and transport corridors by 2025. Estonia has not yet met the Gigabit Society targets. Its ability to meet these targets will depend on the timely adoption of its digital strategy 2030 and the allocation of the 5G ‘pioneer’ bands.
Estonia’s new digital strategy for the period 2030 will be the cornerstone of future digital developments in the country. It will encompass ambitious targets for digital, with a strong focus on digital public services, Connectivity, and cybersecurity.
SMEs need more attention, although e-Invoicing is booming
On the Integration of digital technologies by businesses, the significant potential remains untapped. Despite a very active start-up scene in the country, including some ‘unicorns’ (IT companies that are not yet listed on the stock market but which are privately valued at more than USD 1 billion), not all Estonian businesses are taking full advantage of digital technology and the online economy. According to the report, Estonia needs to continue its efforts to better integrate digital technologies, particularly in Small and Medium-sized Enterprises (SMEs) and more traditional businesses.
Although, our eagle-eyed Managing Director Ave Lauringson noticed a significant improvement in one field concerning companies – the usage of e-Invoices spiked in 2021 to 62% of companies now using them – up from 23% in 2020, and significantly over the EU average of 32%.
Frontrunner in e-government
On Digital public services, Estonia is already well-known for being a top performer in the digitalisation of its administration. It has well-developed e-government systems, with all central government functions and municipalities providing services online. Despite already being a frontrunner in this area, Estonia continues to invest significantly in its e-government services to ensure the country offers the latest technologies to its citizens. Similarly, the COVID-19 pandemic has also demonstrated that Estonia could lead Europe to implement innovative e-health solutions.
One of Europe’s leading countries for digital skills
On Human capital, Estonia ranks 5th, making it one of Europe’s top countries for digital skills. With 62% of Estonians having at least basic digital skills, the country is comfortably above the EU average on this measure.
Decent number of ICT specialists, not enough ICT training
In 2020, ICT specialists accounted for 6.5% of the employed population (EU 4.3%), and ICT graduates represented 8% of total graduates in 2019, significantly above the EU average of 3.9%. However, only 17% of Estonian companies provided ICT training to their employees in 2020 (the same percentage as 2019), below the EU average of 20%. There is a slightly higher share of female ICT specialists in Estonia than in the rest of the EU, although the gender gap remains wide: only 22% of ICT specialists are women (although higher than the EU average).
In addition, Estonia expects to train an additional 7,000 ICT specialists between now and 2027.
Highest number of unicorns per capita
The Estonian start-up ecosystem is very vibrant. There are 1,126 start-ups currently operating in Estonia, according to the most recent data from the Estonian Start-up Database. In 2020, these start-ups generated EUR 782 million in turnover in the country, 43% more than the year before. They also made the labour market more dynamic, employing 6,072 people locally at the end of 2020.
These start-ups benefit from solid and efficient support from State services through the government’s Startup Estonia platform, which aims ‘to supercharge the Estonian start-up ecosystem to be the birthplace of many more start-up success stories to come.’
This support and ecosystem have proven to be successful. Estonia is now the country in Europe with the highest number of unicorns per capita. In total, there are seven unicorns founded by Estonians and/or based in Estonia.
In the last two years, Pipedrive.com (founded in 2010, became a unicorn in 2020.), Zego.com (founded in 2016, became a unicorn in 2021.), and ID.me (founded in 2010, became a unicorn in 2021) joined the four already existing Estonian unicorns: Skype.com (founded in 2003, became a unicorn in 2005), Playtech.com (founded in 1999, became a unicorn in 2007), Wise.com (founded in 2010, became a unicorn in 2015) and Bolt (founded in 2013, became a unicorn in 2018).
Increasing the score of open data progress
In 2021, Estonia also made progress on open data, increasing its score by 24 percentage points compared to 2019. This significant improvement is because public data are increasingly made available to a broader audience. In early 2021, the Estonian Open Data Portal hosted almost 800 datasets from more than 100 publishers, covering agriculture, education, energy, health, governance, and transport. These datasets can then be freely used by academic researchers, start-ups, and companies to build new services or extend existing ones. In addition, the Estonian authorities also significantly improved the cross-border availability of information.
For example, the three Baltic states already allow cross-border exchange of information from their population register, and in 2020 Estonia also started sharing data via the X-Tee (X-Road) initiative with the Finnish authorities. The data are only collected once by one specific institution from one country (the ‘once-only principle) and securely and confidentially.
Estonian government cloud
Estonia has experimented with cloud technologies and completed a pilot project called ‘Estonian government cloud.’ This pilot project proved that cloud technology works for public-sector IT applications and that it is worth considering the more widespread use of cloud technology. In parallel, the government is further investigating public-sector use of cloud computing to understand better what kind of data can be kept on the cloud and what cloud services are required. Estonia is working to build its government cloud to meet these needs.
The 1st country to use vaccination certificates
Estonia was the EU’s first country to use vaccination certificates (having set up a certificate system in April 2021) and has strongly advocated for the EU’s digital COVID certificate (for vaccination, recovery, and testing).
In October 2020, the World Health Organization (WHO) and the Estonian government signed a memorandum of understanding to develop distributed digital infrastructure providing health solutions to the COVID-19 pandemic and other public health needs. In February 2021, the country began working with the WHO on a pilot project to investigate the use of globally recognised electronic vaccine certificates.
Continuously ambitious in e-governance
Estonia continues to work on ambitious projects further to improve its leading position in digitalising public services. The recent pandemic has allowed the country to position itself as a world leader in this area. The new cybersecurity strategy is expected to bolster further Estonia’s position as a European and global leader in the digitalisation of its public services.
97 million euros to further improve public services
Estonia plans to advance the already well-digitalised Estonian public administration further. Almost half (47%) of the measures supporting the Estonian plan’s digital transformation will aim to further digitalize the administration and public services. The total budget for these investments will be EUR 97.43 million.
Meet Estonia’s virtual assistant #Bürokratt.
The most important measures within the plan are as follows:
- The reconfiguration of essential digital public services and the safe transition of these services to cloud infrastructure to increase their resilience, security, and reliability. The IT systems and services of the Estonian public authorities will be migrated to a private cloud and will require large-scale security testing.
- The development of business-event services and a digital gateway improve efficiency in delivering public services and reduce the administrative burden for businesses.
- The redesign of several public services (and the underlying IT systems) to enable their automatic delivery based on life events or business events experienced by citizens (such as a marriage, the birth of a child, or the creation of an enterprise).
- Setting up a national, virtual-assistant platform in the #Bürokratt programme to improve the user-friendliness of access to online public services in Estonia.
- The creation and development of a centre of excellence for data management and open data to foster better control of the data collected and held by the Estonian public authorities. This will aim to improve the quality of the data, increase its use for decision-making, and make the data available as open data so that other stakeholders may also reuse it.
“We have focused directly on people’s well-being and convenience: people have to have the best experience of the digital state, feel safe and secure in our cyberspace, and have good communication connections guaranteed everywhere in Estonia. In terms of public services, we focus on quality and the value created for people in the form of (user)experience, both through proactive life services and making use of the possibilities of AI,” concludes minister Sutt.
According to the Estonian IT minister, the foundation of digital society is high-quality communication connections, where Estonia still has room for development according to the DESI index. “In the following years, we are working on various support measures to accelerate the spread of high-speed internet networks and 5G infrastructure. However, all of our digital state is based on cybersecurity, without which there would be no trust and no users of digital services. We contribute to ensuring that Estonian cyberspace continues to be secure, reliable and withstands the growing cyber threats in the world, “minister Sutt said.
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Estonia’s fully remote e-notary service – 1st state e-service of its kind in Europe
November 17, 2021
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February 2020, just weeks before the pandemic broke out, the Estonian Chamber of Notaries launched the e-notary service as a pilot project that enables the remote authentication of notarial acts to be carried out at Estonian embassies – The first state service of its kind in Europe.
This meant that e-residents and Estonians living overseas no longer had to Visit Estonia each time they needed the services of the local notaries. Although, before this time, 99% of Estonian public services had been digitised for years, the complexities, sensitivity, and risks associated with notarial acts excluded them from this narrative. Notarial services just had to be done in person at local notary offices.
Adaptability in the face of the pandemic
The e-notary service pilot came at a crucial time, but the remote verification could initially only be done at the Estonian embassies in Helsinki, London, Brussels, Stockholm, and Riga. But within months of being launched, it developed into a fully-fledged platform that could be accessed right from the comfort of one’s home. During the first quarter of this year, roughly 91% of all notarial acts by e-residents were carried out via the e-notary service.
“The project was initially planned at a smaller scale. The remote authentication was supposed to be done one-on-one and only by a visit to Estonian embassies. At the time, it couldn’t be done from just anywhere. It had to be at the Estonian embassy closest to you, and our initial pilot had five embassies under its coverage. But towards the end of the pilot phase, we realised that visiting embassies was equally constricting for the clientele. At this point, we had to find a way to make the remote service available beyond embassies,” Robin Lõo, head of Notaries Information System Division of the Centre of Registers and Information Systems, comments.
Gone fully remote
Prior to launching the e-notary system, physical presence at a local notary’s office was required to trade or transfer company shares, buy or sell real estate, attest credentials, or carry out other notarial acts. This made it inconvenient for e-residents and Estonians living abroad to manage their affairs and carry out business transactions from overseas. But with the e-notary service now rolled out to its total capacity, you can carry out all but one type of transaction from anywhere you are in the world.
“There are no limits to the type of notarial services that can be done remotely. You can do everything remotely except marriage or divorce. For that, you just have to see the notary face-to-face in the same room. But anything else, the clients can just be at their home or wherever else they are and do all that needs to be done,” says Katrin Sepp, notary candidate and legal advisor of the Estonian Chamber of Notaries.
Internal e-notary system already in use long before
Like other arms of e-Estonia, the Estonian Chamber of Notaries, was of course, not left out by the waves of digitalisation. Long before the e-notary service was ever to be made accessible to the public, an internal e-service was already being used by the notaries.
The e-Notary self-service platform.
“The possibility of not needing to see notaries face-to-face or not going to their office just became an option with remote authentication. But before that, we already had a standard e-notary system that was being used internally by the notaries and notary offices to prepare contracts, schedule calendars, sign documents, create document templates, access registers, send out documents and data to the registries, issue apostilles, etc. It was just that the existing e-notary service was not available for the public’s use,” Katrin discloses.
Significant improvements to the platform
The e-notary service has improved in diverse ways since the initial pilot was first launched. This is partially due to the impact of the pandemic and the way it has disrupted technological innovations. “Since we went live, the service, particularly from the customer end, has improved in several ways. Three years ago, we didn’t know what we wanted from the video conference, but since COVID-19 hit, we have gotten to see how the likes of Zoom and Skype have improved, and we have incorporated similar improvements into our system. Initially, we wanted just to see each other (the notaries and the clients).
But then, we added a chatbox, zooming/pausing/recording features, and other helpful functionalities.” Robin points out. “Right now, we get feedback from the users, listen to the feedback and discuss that internally. It is a public service, so usability and security are important to us. And of course, our reputation needs to be kept intact as well. This is why we always strive to improve the service,” Katrin adds.
“The biggest upgrade to the e-notary system went live at the beginning of September this year. This upgrade gives room for a hybrid notarial transaction, whereby some of the clients are on seat in-person with the notary while others are connected remotely. Before now, you could only carry out notarial acts either online or offline. Every member of a group or team had to be at the notary office in person with the others or online with the others. Now you can have a big hybrid transaction,” Robin says, smiling.
Data privacy and protection assured
Data privacy and protection remains a recurrent issue and burning topic within the tech sphere, as we’ve seen with Meta (ex. Facebook), the EU’s General Data Protection Regulation (GDPR), and more. With the sensitivity of the data and information exchanged between notaries and their clients, data security and privacy were group members or team members significant for the Chamber of Notaries.
A lot of public services are working in the background of notarial acts.
“Since the notarial contracts are confidential, security is a real big issue. Nobody should see or hear what the notaries and clients are talking about. This is why we developed our platform and server. We aren’t using third-party services, so all communication, including video and audio transmission, is going through our server,” Robin explains. “The digital ID and signing system is also a platform we did not develop ourselves. But since this belongs to the state, all state agencies can make use of it,” Katrin adds.
“We are minimising the occurrence of potential breaches by hosting our own system and using our own video conference platform. We used an open-source code that Andmevaramodified for us, but the server is hosted on the Ministry of Justice’s server. So, to use the e-notary service, every client connects to the server in the Ministry of Justice – no other connection is made. As of yet, we don’t know of vulnerabilities related to the e-service. And since we are not relying on third-party platforms, we would continue our remote notarial authentications even when Zoom, Skype, Facebook, or some other platform is down,” Robin muses.
Collaboration with Veriff and Andmevara
Andmevara was the partner tasked with building the system and they did build the initial version. Still, the Centre of Registers and Information Systems has been in charge of operating, managing, and improving the system on behalf of the Chamber of Notaries since it went live. Veriff’s biometric facial recognition system is also integrated with the e-notary system.
This identification system employs Veriff’s biometric facial recognition system, which uses algorithms to ensure that the person in front of the screen matches the one pictured on their ID. “Users need the service to be simple, intuitive, and fast, and we have been able to achieve that. During the last year, we’ve improved our verification flow to be easily followed, cutting down the average verification time from 90 seconds to 6 seconds,” comments Miina Vilo, an account manager at Veriff.
“Veriff wasn’t initially included as part of the project. The idea to include their face recognition solution came up later towards the end of the project. Of course, this was the case being that our initial plan was to have the consular/embassy workers invite the clients for physical checks and identity verification. When the initiative to fully go remote came up, the idea of including Veriff as part of the solution was brought up. And indeed, Veriff adds an extra layer of security to our e-service because it uses algorithms to verify that the person in front of the screen matches the on the ID,” Robin explains. To make use of the e-notary service, all you need is your Estonian ID card, Smart-ID, or mobile-ID. It’s that simple!
Replication in other public departments
Katrin, from the Estonian Chamber of Notaries, says that the massive success of the e-notary service has made other public departments, including the tax office, interested in a similar solution. And likewise, other notaries in Europe have followed their lead to create a similar solution both for internal and external use.
Resource: E-estonia
Estonia’s largest bank allows crypto trading
23 November 2021
Estonia’s largest bank LHV (LHV1T.TL) will allow customers to trade crypto through its app from next week, the bank announced on Tuesday.
Users will be able to trade major cryptocurrencies such as bitcoin, ethereum and chainlink directly on the app via crypto exchange Bitstamp.
The app will show customers’ crypto assets and allow them to manage them alongside their other investments. It will also offer pre-filled tax forms to people so they can declare crypto transactions quickly and correctly.
Initially, customers will be able to buy and sell eight selected major cryptocurrencies at market prices — bitcoin (BTC-USD), ethereum (ETH-USD), litecoin (LTC-USD), uniswap (UNI3-USD), chainlink (LINK-USD), stellar lumens (XLM-USD), polygon (MATIC-USD) and aave (AAVE-USD).
“In the near future, we plan to add new instruments, order types and other solutions for more convenient trading. In the longer term, we will closely monitor the development of blockchain solutions in the world and, if the right opportunity arises, we are certainly ready to take the next step towards offering blockchain solutions,” said Martin Mets, head of retail Sales, channels and investment Services at LHV.
Transactions will be carried out on the Bitstamp crypto exchange, which is one of the five largest licensed crypto exchanges in the world. Customers’ crypto assets will be securely held on the BitGo platform, part of the Galaxy Digital Group (GLXY.TO).
“We have been interested in blockchain technology for a long time – already in 2015, we experimented with one of the world’s first stablecoin-like solutions, the LHV Cuber platform,” said Madis Toomsalu, chairman of the management board of LHV Group
“In the meantime, we have been waiting for the regulatory environment to evolve, for the market to become organised, and for professional market players to emerge.
“Crypto assets have become a large field in terms of both market value as well as turnovers based on decentralised financial services. We believe that the strengths of blockchain-based solutions in terms of speed, efficiency and security are increasingly being demonstrated.
“We will be the first bank in the Baltics to start offering crypto trading to our clients – as the first step, they will be able to buy and sell crypto assets on the LHV mobile app.”
“Considering the increasingly mature level of development of crypto assets and their rapidly growing popularity as a new asset class, we are ready to add this asset class to the range of products offered to LHV bank clients,” said Mets.
“This is clearly a very volatile and high-risk asset class, but for a risk-conscious client, crypto assets can play an important role in the portfolio.”
Earlier in November, Australia’s Commonwealth Bank started to give clients the option of trading crypto currencies on its banking app.
Marcus Sotiriou, sales trader at UK based digital asset brokerGlobalBlock said: “The LHV news is significant because it shows that the cryptocurrency industry is a global movement and gives weight to the argument that at some point every bank in the world will need to integrate crypto.
“This news has fuelled a bounce in the price of bitcoin which is currently trading at $57,000… but still currently in a downtrend. If bitcoin can break above the $60,000 level that would confirm a double bottom pattern which is a bullish signal and could result in the short term to new all-time-highs.”
Resourse: Yahoo Finances
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