Legal Stuff

Summary Judgment Motions Filed in E-book Price-Fixing Suit

23 September 2015

From Publishers Weekly:

Could another e-book price-fixing case against Apple soon head to trial? After a quiet period, summary judgment motions were filed last week in a case in which three defunct e-book retailersclaim that the 2010 conspiracy among Apple and five publishers to fix e-book prices forced them out of business.

The suit, first filed by Australian upstart DNAML in September of 2013, and later joined by Lavoho, LLC, a “successor” to the Diesel eBook Store and Abbey House Media, formerly BooksOnBoard, alleges that the fledgling e-book businesses were harmed “directly and as a proximate result” of the 2010 price-fixing scheme executed by Apple and the five agency publishers (Hachette, HarperCollins, Simon & Schuster, Macmillan and Penguin). In the retailers’s bid for summary judgment, filed last Friday, they argue that the facts of the case—already adjudicated by the court in Apple’s case and affirmed on appeal—are sufficient for Judge Denise Cote to grant summary judgment to DNAML “on the element of liability.”

The retailers contend that the 2010 agency switch “devastated” their nascent business models, which were based on bundling and other discount-driven promotions.

At press time, Apple’s and the publishers’ briefs supporting their motions for summary judgment were not yet public. Both the publishers and Apple have previously argued, however, the nascent retail businesses were hardly players in the e-book market, and could have folded for many reasons.

. . . .

 Cote held that the retailers could pursue the case. It is “more than plausible that a discount retailer was harmed by a conspiracy to remove retailers’ ability to discount e-books,” she found, adding that the retailers were “indisputably competitors in a market in which trade was restrained.”

Link to the rest at Publishers Weekly

PG thinks you shouldn’t hold your breath on this one.

German booksellers seek action on Amazon audio books

22 September 2015

From Reuters:

The association of German book sellers accused Amazon and its subsidiary Audible on Monday of building a monopoly in the audio book business as it lodged complaints with the German competition authority and the European Commission.

The association said in a statement that Amazon and Audible were abusing their dominant market position to force publishers to accept “unreasonable conditions” for the marketing of audio books.

It said more than 90 percent of all downloads of audio books in Germany were made via the Audible or Amazon sites, or via the iTunes store, which is exclusively supplied by Audible.

“The business model of Amazon and Audible is aimed at destroying the excellent book trade structure in Germany. These companies are avowedly on the way to establish a monopoly,” said association head Alexander Skipis.

. . . .

In June, the European Commission opened an investigation into Amazon’s e-book business, examining whether clauses in its contracts prevent publishers from offering more favourable deals to competitors.

Ebooks are a fast-growing industry and Amazon, which popularised the product, is Europe’s biggest player.

Link to the rest at Reuters

Self-Publishing and Living the LLC Dream

16 September 2015

From Scott De Buitléir at the Huffington Post

I’ve always wanted to be a writer, and as a child I imagined my name on the cover of several novels. As I’ve grown up into a digital age, the possibilities for being a writer today seem endless, and nowadays one doesn’t have to rely on the mercy of large publishing companies to grant you your dream come true as self-publishing has fully come into its own in the publishing world.


As more self-publishers rush to place their books on the market, the number of copyright infringement lawsuits have increased. Many authors are now facing lawsuits that not only threaten their writing, but also their personal assets and savings.

It is for reasons like this that many self-published authors are starting to approach their writing as a business and taking the right steps to separate their book income from their personal assets by setting up their writing under a Limited Liability Corporations (LLC) or other business structure.


“[LLCs]… still provides adequate protection of assets while not being as difficult or expensive as setting up a Corporation. Furthermore, an LLC is more versatile and allows you to tax it as a Sole Proprietorship, Partnership, C Corporation or S-Corporation. Basically, it is the best of all worlds and fits nicely in the self-publishing business structure.”


Risks are abound in this industry and increasing every year. Those authors that don’t take the necessary action to protect themselves may find that their “dream come true” turns into a nightmare.

Read the rest here.

From Guest Blogger Randall

‘Will I be burnt next?’ – Into the River author Ted Dawe on book banning

8 September 2015

From The New Zealand Herald:

The author of the first book to be banned in New Zealand for at least 22 years is asking: “Will I be burnt next?”

Ted Dawe, 64, the head of studies at Taylors College for international students in Auckland, is the unlikely subject of the first interim restriction order on a book under the Films, Videos and Publications Classification Act 1993.

His award-winning book for teenagers, Into The River, has been banned from sale or supply under the order issued by the president of the Film and Literature Board of Review, Dr Don Mathieson, QC.

. . . .

In the meantime, media law expert Professor Ursula Cheer has said it was illegal to supply the book even to a friend.

“Having it for your own personal use is okay. Passing it around to your friends is not,” she said.

Mr Dawe said he was “blindsided” by the ban, which was sought by lobby group Family First after deputy chief censor Nic McCully removed a previous R14 restriction on the book on August 14, making it totally unrestricted.

. . . .

“Those two individuals are united in their determination to establish this as a line that will not be crossed. I feel they have wildly overstepped the whole mechanism of looking at art and making judgments on it,” he said.

“New Zealand has taken a giant step towards that sort of regulatory moralising that I think most people felt we had left far in our past.”

He said it was not easy to write a book that teenagers would want to read, or to get it published.

“People involved with teaching boys, especially English teachers, know how important books like this are because they speak to boys about the things that other boys’ books don’t have the firepower or the vitality to do effectively,” he said.

“The book was never about sex and drugs, it was always about bullying people and how that damages people for the rest of their lives. That is really the underlying theme, everything else is just the trappings that go along with that.”

. . . .

The NZ Booksellers Association has placed a notice on its website warning bookshops that they face fines of up to $3000 for an individual or $10,000 for a business if they supply the book.

However the book is still on sale on Amazon at US$24.99 in paperback or US$9.99 on Kindle.

Link to the rest at The New Zealand Herald and thanks to Meryl for the tip.

UMG Poised to Settle Major iTunes Royalty Case with Artists

5 September 2015

From Music Business Worldwide:

Universal Music Group ‘shortly’ expects to settle a major US class action lawsuit with a group of artists, having made a significant offer of monetary compensation.

The suit dates back to 2011, when a group of recording artists filed a claim seeking additional royalties for the online sale of downloads and master ringtones.

These artists – including Public Enemy’s Chuck D, Rob Zombie, the Rick James Estate, Whitesnake (pictured) and Ron Tyson of The Temptations – wish to have their backdated iTunes royalties paid in ‘licence’ terms.

That’s because a ‘licence’ payout typically involved a 50/50 split between label and artist – while just 6-20% of a ‘sale’ transaction ends up with performers.

In 2012, the production company who discovered Eminem, FBT Productions, settled with Universal out of court in a similar case.

UMG isn’t alone in facing such class action claims: in February this year, MBW discovered that Warner concluded an $11.5m settlement with 2,000 artists making claims on the same basis.

Link to the rest at Music Business Worldwide

PG says the distinction between a license and a sale of digital media can be significant.

Who owns your digital afterlife?

31 August 2015

From The San Jose Mercury News:

When a landlord discovered the body of bestselling novelist Marsha Mehran last year in a seaside Irish cottage, the 36-year-old had left behind a trove of literary work.

Some of it, such as the international hit “Pomegranate Soup,” can be found in libraries and bookstores around the world. Other writings were stuck in the Internet cloud, including a password-protected account that only Google knew how to open.

What happens to our emails, online searches, or — in Mehran’s case — digital manuscripts, when we die? It took costly legal maneuvers this summer stretching from Australia to Silicon Valley for her grieving father to find out.

“I wanted to know if Marsha left any notes, anything about her sickness, or about what was going on in the last year or two,” said Abbas Mehran. “What’s the difference between the notebook my daughter left for me, with all the secrets of life, and the digital account that Google has?”

A surge of families struggling with similar questions is driving a behind-the-scenes political battle between tech companies and estate lawyers over who gets the keys to someone’s digital afterlife.

In California, lawmakers will vote in September on a bill backed by Facebook, Yahoo, AOL and a lobby group that represents Google, Microsoft and Apple. Assembly Bill 691 would deny families access to emails of someone who died unless a court finds the person had consented to passing them on to heirs; other digital assets such as photos and documents would also be restricted, with an exception for recent files that affect an estate’s finances. By favoring personal privacy over a family’s wishes, the companies hope to appeal to the unspoken will of their users while also lessening the bureaucratic hassle of complying with millions of posthumous requests.

. . . .

“Many of our privacy rights expire when we pass away,” Carroll said. “Sometimes a family says, ‘I don’t want to read his or her emails. I want my memories the way they are.’ That’s completely valid. But certainly an archivist would argue that often just as important as the manuscript (are) all the notes and correspondence. It reveals more about the author’s thought process and the decisions that were made, how the work came together and what the author was thinking.”

Some companies, such as Yahoo, destroy everything and reveal nothing after a user dies. Others take a case-by-case approach. Facebook and Google now have online tools that allow users to choose their digital heirs and how much they want preserved or deleted upon death.

Link to the rest at  The San Jose Mercury News and thanks to Dave for the tip.

Texas judge orders $10 million set aside for ‘Fifty Shades’ settlement

27 August 2015

From Reuters:

An Australian woman who helped publish “Fifty Shades of Grey” was ordered by a Fort Worth judge on Wednesday to set aside $10 million for a Texas woman a jury said was defrauded out of her share of the royalty rights for the steamy best-selling novel.

Jennifer Pedroza of Arlington could be awarded about $10.7 million once attorneys for her and former business partner Amanda Hayward of Australia settle on the amount she is owed, including attorney fees, court officials said.

. . . .

Pedroza was part of The Writers Coffee Shop, a small independent publisher of ebooks that originally published the “Fifty Shades” trilogy as an e-book and print-on-demand book, according to court papers.

. . . .

The rights to the books written by British author E.L. James were sold to Random House and the deal led to the sale of more than 100 million copies worldwide. A film based on the first book, “Fifty Shades of Grey,” took in more $570 million in the United States and abroad, according to tracking site Box Office Mojo.

A Fort Worth jury decided in February that Pedroza was defrauded out of her share of royalties by Hayward, who tricked Pedroza into signing an agreement that cut her out of her share of the royalties after Hayward signed the deal with Random House.

The jury determined that Pedroza was one of the four original owners of The Writers Coffee Shop and Hayward fraudulently presented the restructuring arrangement so she could keep the Random House money for herself.

Link to the rest at Reuters and thanks to Adam for the tip.

PG says 99% of business contracts are put in a drawer and forgotten after they’re signed.

The other 1% are very minutely examined at some later time.

Author Solutions Case Ends With Settlement

26 August 2015

From Publishers Weekly:

A closely watched lawsuit that had accused self-publishing service provider Author Solutions of fraud appears to be over.

On August 12, Judge Denise Cote ordered the case discontinued without prejudice after being informed by the parties that a settlement had been reached, following a court-ordered conference held on August 11. A settlement was not unexpected, coming just weeks after Cote dealt the plaintiff authors’ case a presumably fatal blow by denying class action status.

The case was first filed in April, 2013, with a group of plaintiff authors pressing an array of claims against Author Solutions, and arguing that a common question augured for a class action: “Did Author Solutions engage in a fraudulent scheme to sell worthless marketing services?” In filings, the plaintiffs alleged that Author Solutions, as part of a company-wide policy, hid from consumers that “it is a telemarketing operation” based on upselling “worthless” services to unsuspecting authors.

. . . .

[T]he firm filed a second potential class action against Author Solutions this spring in the state of Indiana, with new representative author plaintiffs.

Link to the rest at Publishers Weekly and thanks to Jim and several others for the tip.

A quick translation is that the first lawsuit, filed in New York, ended up shooting blanks. The second suit was filed in Indiana, presumably because Indiana law is friendlier to particular elements the claims in this class action.

If defrauded authors were going to receive anything out of settlement of the New York suit, it’s difficult for PG to imagine that class counsel would not have announced it.

PG is not an expert on class actions, but each class must have one or more named plaintiffs. One of the elements of a successful class action claim is that there must be a substantial similarity between the claims of the named plaintiffs and the other class members’ claims. The similarity must be either in the factual settings or the legal questions.

Unless a large number of people were harmed in much the same way, a class action will not fly.

An example of an ideal class action is where a lot of people sign the same form contract that has some substantial defect that harms each of those people to a greater or lesser extent.

Is Amazon Creating a Cultural Monopoly?

25 August 2015

From The New Yorker:

For months, a group of writers calling themselves Authors United have campaigned, mostly unsuccessfully, against the business practices of On Thursday, they mounted their latest challenge, officially requesting that the Department of Justice investigate how Amazon exercises its “power over the book market.” (A spokesman for the Justice Department said it is reviewing the request.) The list of signatories fills twelve pages and reads like an unusually expansive long list for a prestigious writing award; the five hundred and seventy-five writers include Philip Roth, V. S. Naipaul, and Ursula K. Le Guin, along with many longtime contributors to this magazine.

These writers generally aren’t legal experts, however, and they freely acknowledge this near the beginning of their letter to the Justice Department, while asserting that their profession does afford them some degree of expertise: “We are not experts in antitrust law, and this letter is not a legal brief. But we are authors with a deep, collective experience in this field, and we agree with the authorities in economics and law who have asserted that Amazon’s dominant position makes it a monopoly as a seller of books and a monopsony as a buyer of books.”

. . . .

 It is perhaps the writers’ lack of legal expertise that has given them the freedom to put forth what antitrust experts described to me as a highly unorthodox argument: that, even though Amazon’s activities tend to reduce book prices, which is considered good for consumers, they ultimately hurt consumers.

. . . .

 Authors United’s specific argument—that Amazon’s actions are bad for consumers because they make our world less intellectually active and diverse—is unorthodox in its resort to cultural and artistic grounds.

. . . .

 None of this is to suggest, however, that the Department of Justice would have a strong case against Amazon if it were to sue the company and apply Authors United’s reasoning. One reason pricing has been such a popular method of measuring consumer welfare is that it’s easy to quantify: a three-dollar jar of peanut butter is objectively better for consumers than the exact same jar priced at five dollars—forty per cent better. While it may be attractive, on a philosophical level, to argue that Amazon is bad for us because it makes our culture poorer, measuring that effect would be difficult, if not impossible. How would one go about valuing an unpublished masterpiece by an unknown author? This is further complicated by the fact that Amazon makes it easy for authors to self-publish and have their work be seen, without having to go through such traditional gatekeepers as agents and publishers; Amazon might argue that this allows for more free flow of information and ideas.

. . . .

 I spoke with Douglas Preston about these points, mentioning that another antitrust expert I spoke with had supported them, as well. Preston acknowledged, “Not being a lawyer, maybe they’re right—maybe we’re barking up the wrong tree.” Indeed, it’s quite possible the Justice Department will read the Authors United letter and dismiss it as uninformed. But even if that happens, Preston said, it will have been worthwhile for the writers to have made their case. Last fall, Authors United appealed to Amazon’s board of directors to get the company to change its practices; the board seemed unmoved, but the authors’ request was written about in the press. That in itself served the writers’ goal, Preston told me, because it helped disseminate their message to regular people, including Amazon customers. Authors United’s larger mission, he told me, was this: “We hope to show the public that getting products faster and cheaper isn’t necessarily the greatest good. It comes at a human cost.”

Link to the rest at The New Yorker and thanks to Barry for the tip.

If you fail to achieve your original objective, change the objective and claim to have achieved the new one.

The Authors United Letter from an Antitrust Law Perspective

25 August 2015

From author Randall Morris:

Claim 1: Monopoly

AU’s first point is that “Amazon’s dominant position makes it a monopoly as a seller of books and a monopsony as a buyer of books.” The U.S. Supreme Court in U.S. v. Grinnell Corp. (U.S. v. Grinnell Corp.) held that the test for monopoly control under Section 2 of the Sherman Act has two requirements “(1) the possession of monopoly power in the relevant market and (2) the willful acquisition or maintenance of that power as distinguished from growth or development as a consequence of a superior product, business acumen, or historic accident.”

Relevant Market

The first question is “what is the relevant market?” If we look to the AU letter, they allege that Amazon has “unprecedented power over America’s market for books.” They also claim that Amazon has become “the largest publisher and distributor of new books in the world.” I have no idea how they’re defining new books and the U.S. Supreme Court can’t grant relief for a market larger than the United States, so I’d rather focus on “America’s market for books.” They also note that “according to published figures, this one corporation now controls the sale of:
– More than 75 percent of the online sales of physical books.
– More than 65 percent of e-book sales.
– More than 40 percent of sales of new books.
– About 85 percent of e-book sales of self-published authors.”
In their list of figures, it seems that they are alleging that “America’s market for books” is made up of e-books and physical books. The other two figures they list would fall into those two categories. I don’t know if they’re trying to make the relevant market “America’s market for books” or if they maintain that Amazon has two separate monopolies (one in e-book sales and one in physical book sales). Justice Sotomayor (who was still a Circuit judge at this point) gave clarification to what the courts should look for in defining a relevant market. In Todd v. Exxon Corp. (Todd v. Exxon Corp.), she held that “to survive a Rule 12(b)(6) motion to dismiss, an alleged product market must bear a “rational relation to the methodology courts prescribe to define a market for antitrust purposes – analysis of the interchangeability of use or the cross-elasticity of demand,” Gianna Enters. v. Miss World (Jersey) Ltd., 551 F. Supp. 1348, 1354 (S.D.N.Y. 1982), and it must be “plausible.” Hack v. President & Fellows of Yale Coll., 237 F.3d 81, 86 (2d Cir. 2000).” She goes on to say that “cases in which dismissal on the pleadings is appropriate frequently involve either (1) failed attempts to limit a product market to a single brand, franchise, institution, or comparable entity that competes with potential substitutes or (2) failure even to attempt a plausible explanation as to why a market should be limited in a particular way.” In other words, in order to continue with your case and not have it dismissed, you must allege in your complaint a relevant market that plausibly doesn’t have interchangeability of use or cross-elasticity of demand with other products. In our case, e-books and physical books would have to be different enough that they couldn’t be seen as reasonable substitutes for one another. There’s some confusion as to what AU wants the relevant market to be. If they want to maintain that Amazon has a monopoly both in sales of e-books and sales of physical books (two distinct markets) then they would need to “attempt a plausible explanation as to why [the] market should be limited in [this] way.” I see no discussion in their letter of the differences between e-books and physical books and no reason why they should be seen as different markets. AU even admits that their concern is for “America’s market for books.”

Monopoly Power

Now that we have AU’s alleged relevant market, “America’s market for books,” we can look into whether Amazon has monopoly power in this market. A case that is perfectly on point is Bookhouse of Stuyvesant Plaza, Inc. v., Inc. (Bookhouse of Stuyvesant Plaza, Inc. v., Inc.). Bookhouse alleged in their complaint that Amazon controlled “60% of the U.S. e-book market.” They also made claims that Amazon’s market share of the print book market were similar. I’d like to go on a brief tangent related to the relevant market. The judge in Bookhouse also saw one of the problems I found with AU’s letter, they didn’t list enough differences to make it clear that these are two distinct markets. The judge noted that “without more detailed allegations or explanation, the Court cannot reasonably infer that these two markets simultaneously are so different that e-books and print books are not acceptable substitutes, and yet so similar that the Publishers’ market share is the same in both markets.” AU’s letter does allege a different market share for print book sales, but the two numbers seem to be close enough that it should at least be an open question as to whether we’re looking at a U.S. market for books or two markets – e-books and print books. AU has still not addressed the issue of whether e-books and print books are acceptable substitutes for one another.

When looking into Bookhouse’s complaint that Amazon controlled 60% of the e-book market, the judge held that “even if plaintiffs had alleged a cognizable market, plaintiffs’ only allegation suggesting that Amazon possesses monopoly power is that its market share is 60%. See First Am. Compl. ¶¶ 15, 20, 22. But the Second Circuit has held that “[a]bsent additional evidence, such as an ability to control prices or exclude competition,” even “a 64 percent market share is insufficient to infer monopoly power.” PepsiCo, 315 F.3d at 109.” Market share does seem to be AU’s main argument that Amazon is a monopoly. They allege that Amazon has 65% of the e-book market and 75% of the print book market. If these two figures make up “America’s market for books,” then Amazon controls 48.75% of American’s market for books. Absent “an ability to control prices or exclude competition,” this is not enough to establish monopoly control over the market. Even taking their separate figures, 65% of the e-book market would be inadequate to imply monopoly control on its own. I’ll address AU’s predatory pricing issue later on, but I doubt AU’s complaint would survive a 12(b)(6) motion to dismiss on the issue of monopoly control under the first requirement listed in Grinnell above. AU would have an even more difficult time proving the second requirement, that Amazon didn’t gain monopoly power “as a consequence of a superior product, business acumen, or historic accident.”

. . . .

Claim 2: Blocking Sales

AU’s next issue is that “Amazon, to pressure publishers over the past 11 years, has blocked and curtailed the sale of millions of books by thousands of authors.” Their next point seems to raise a similar issue “Amazon, during its dispute with Hachette in 2014, appears to have engaged in content control, selling some books but not others based on the author’s prominence or the book’s political leanings.” Now I question whether either statement is true, but for the purposes of a 12(b)(6) motion, we assume that the facts alleged by the Plaintiff are true. In response to a similar claim, the judge in Bookhouse said, “in essence, plaintiffs complain that Amazon has not allowed them to sell e-books on Amazon’s devices and apps. But no business has a “duty to aid competitors.”” The judge then cites the Supreme Court, noting that “[f]irms may acquire monopoly power by establishing an infrastructure that renders them uniquely suited to serve their customers. Compelling such firms to share the source of their advantage is in some tension with the underlying purpose of antitrust law, since it may lessen the incentive for the monopolist, the rival, or both to invest in those economically beneficial facilities.” That pretty much sounds like the situation between Amazon and AU (most of whom are authors published by the Big 5, Amazon’s rivals.)

. . . .

Claim 4: Predatory Pricing

AU’s next claim is that “Amazon routinely sells many types of books below cost in order to drive less well-capitalized retailers – like Borders – out of business. This practice, known as “loss-leading,” also harms readers by reducing the amount of revenue available for publishers to invest in new books.” Their first sentence is a claim of predatory pricing. Their second sentence, that readers are being harmed, seems to assume that new books can only reach readers via publisher investments and that when this amount is reduced, readers will have reduced selection. I don’t know why they’re alleging this because Amazon still pays the publishers the full amount when they price under their cost. There is no reduction of revenue as far as I understand.

The Supreme Court in Cargill, Inc. v. Monfort of Colorado, Inc. (Cargill, Inc. v. Monfort of Colorado, Inc.) defined predatory pricing as “pricing below an appropriate measure of cost for the purpose of eliminating competitors in the short run and reducing competition in the long run.” That’s what AU is alleging here. They say that Amazon is engaging in predatory pricing to drive competitors like Borders out of business. The Supreme Court later found predatory pricing to have two requirements in Brooke Group Ltd. v. Brown and Williamson Tobacco Corp. (Brooke Group Ltd. v. Brown and Williamson Tobacco Corp.) These requirements are “(1) the prices complained of are below an appropriate measure of its rival’s costs, and (2) that the competitor had a reasonable prospect or a “dangerous probability” of recouping its investment in the alleged scheme.”

I don’t think Amazon was targeting competitors with their below-cost pricing, but I think it could go either way. I agree that there is evidence that they priced below cost at some times, but I doubt they did it to drive Borders and Barnes and Noble out of business. Concerning his book pricing strategy, Jeff Bezos said in an interview (Business Insider Interview with Jeff Bezos), “Books are the competitive set for leisure time. It takes many hours to read a book. It’s a big commitment. If you narrow your field of view and only think about books competing against books, you make really bad decisions. What we really have to do, if we want a healthy culture of long-form reading, is to make books more accessible. Part of that is making them less expensive. Books, in my view, are too expensive. Thirty dollars for a book is too expensive. If I’m only competing against other $30 books, then you don’t get there. If you realize that you’re really competing against Candy Crush and everything else, then you start to say, “Gosh, maybe we should really work on reducing friction on long-form reading.” That’s what Kindle has been about from the very beginning.”

Let’s give AU the benefit of the doubt. Let’s say Amazon was targeting competitors with predatory pricing of books. Let’s say AU could prove that “the prices complained of are below an appropriate measure of its rival’s costs.” They then have to prove the second element which is where I think their argument fails. They would have to prove that Amazon “had a reasonable prospect or a “dangerous probability” of recouping its investment in the alleged scheme.” It is not enough to prove that a company engaged in predatory pricing. The Supreme Court noted in Brooke Group that “recoupment is the ultimate object of an unlawful predatory pricing scheme; it is the means by which a predator profits from predation. Without it, predatory pricing produces lower aggregate prices in the market, and consumer welfare is enhanced.” I don’t see how anyone can prove that Amazon plans on recouping profits when it engages in predatory pricing because Amazon as a company is willing to run on razor-thin margins. It reinvests what it makes in other acquisitions. Let’s give AU the benefit of the doubt on this one as well and say that they could somehow prove this.

Link to the rest at Randy Morris

Here’s a link to Randall Morris books. If you like an author’s post, you can show your appreciation by checking out their books.

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