Jews for Jesus v. Steven C. Brodsky: Reply Brief of Appellant Steven C. Brodsky
United States Court of Appeals for the Third Circuit
UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT
Docket No. 98-6031
JEWS FOR JESUS,
STEVEN C. BRODSKY,
ON EXPEDITED APPEAL FROM AN INTERLOCUTORY ORDER PURSUANT TO 28 U.S.C. 1292(a)(1)
United States District Court, District of New Jersey 98-CV-274 (Hon. Alfred J. Lechner, U.S.D.J.)
REPLY BRIEF OF APPELLANT STEVEN C. BRODSKY
TABLE OF CONTENTSTABLE OF AUTHORITIES...........................ii
I. An injunction forbidding the use of a
combination of words describing a topic of public
and religious interest as the name of an internet
website violates the first amendment. 5Ii. The
district court improperly curtailed appellant's
first amendment rights while unduly extending the
scope of appellee's claimed trademarks in ruling
that an unregistered combination of words
describing a topic of public and religious
interest, using unstylized elements of a stylized
registered mark, may not be used by appellant as
the name of his internet website. 13Iii.
Appellant's use of an unregistered word
combination to promote his religious points of
view on the internet, and to provide access to a
non-profit, non-commercial website sharing his
views, is not commercial speech under the
anti-dilution act. 17Iv. The phrase "jews for
jesus" is generic as applied to jews who are for
jesus. 19V. The district court abused its
discretion by issuing a preliminary injunction
despite appellee's failure to meet its heavy
burden of proving a reasonable likelihood of
confusion sufficient to overcome appellant's
rights under the first amendment...............21
Appellee's brief is of a piece with the shell game it has played with its own self-described stylized trademark - JEWS FOR JESUS - since even before this litigation began. Appellant Steven Brodsky's Appeal Brief ("Brief") set forth eight issues for consideration on this appeal, each addressing a critical finding made by the District Court. Appellee conflates these eight issues into only two, thereby evading careful legal analysis and instead painting an impressionistic "rough justice" picture. Its subject is Steven Brodsky's too-effective criticism of appellee's message. The Constitution, and the law of trademark, are left barely discernible and facts that do not suit appellee's vision are either distorted or painted out of its Opposition Brief ("Opp. Br."). Therefore, before replying to the legal arguments that appellee did bother to address, it is necessary to correct some of the most egregious misstatements in that brief.
Common Law vs. Registered Mark Appellee claims Mr. Brodsky's Brief "ignores" this distinction. Opp. Brief. at 33. In fact, Mr. Brodsky's Brief shows why appellee has no valid common law mark at pages 29, 33-35, and 45-46.
1. AN INJUNCTION FORBIDDING THE USE OF A COMBINATION OF WORDS DESCRIBING A TOPIC OF PUBLIC AND RELIGIOUS INTEREST AS THE NAME OF AN INTERNET WEBSITE VIOLATES THE FIRST AMENDMENT.
Steven Brodsky has argued that the District Court's analysis was erroneously based on the flawed, largely inapposite unpublished decision in Planned Parenthood Fed'n of America, Inc. v. Bucci, 42 U.S.P.Q.2d 1430 (S.D.N.Y.), aff'd unpublished table decision, No. 97-7492 (2d Cir. 1998). Mr. Brodsky's Brief sets out at pages 19-20 the serious legal and logical problems with Planned Parenthood; these points are not addressed by appellee.
The suggestion that Mr. Brodsky "has never offered any meaningful analysis supporting th[e] statement" that there are critical fact distinctions between the cases, Opp. Brief at 22, is fatuous. Mr. Brodsky's Brief explains that Planned Parenthood involved a registered word mark, unlike here, and discusses the distinction between his unequivocal anti-Jews for Jesus message and disclaimer, and the "WELCOME TO THE PLANNED PARENTHOOD WEB PAGE!" message in Planned Parenthood. See 42 U.S.P.Q.2d at 1432, 1438. This "welcome" message, quoted twice by the court in Planned Parenthood, was central to its conclusion that, "It is highly likely that an Internet user will still believe that she has found plaintiff's web site at this point," i.e., after beginning to read the contents of defendant's website. 42 U.S.P.Q.2d at 1438. Appellee's brief follows the court below and ignores these two essential differences between the cases. Similarly, none of the Internet domain name cases cited in the footnote on page 21 of appellee's brief involves a website making a religious, political or social statement about the plaintiff. All involve commercial speech.
Appellee says "there is no colorable argument that Brodsky or his message has [sic] been silenced." One of appellee's main arguments to this effect is that Mr. Brodsky has other websites where he can express his opinion. This approach to the First Amendment has, however, been strongly criticized. Appellee relies largely on Mutual of Omaha Ins. Co. v. Novak, 836 F.2d 397 (8th Cir.), cert. denied, 488 U.S. 933 (1998). In Mutual of Omaha, the defendant Novak used slight variations in the Mutual of Omaha word mark and logo as the basis for a series of products, sold by him, bearing the words "Mutant of Omaha" and "Nuclear Holocaust Insurance." Id. at 398. Unlike here, the object of Novak's social statement was not the plaintiff, and his use of its marks could not be described as fair use or even necessary to express his views about an unrelated topic, nuclear war. Here, in contrast, the subject matter of Steven Brodsky's speech is the idea of Jews for Jesus; hence the domain name, "jewsforjesus."
More significantly, the Mutual of Omaha court found that Novak's use of the plaintiff's marks was commercial. In fact, the court contrasted this commercial use of a mark with the protected use of a trademark by social critics such as Steven Brodsky:
Id. at 403, n. 8. (emphasis added). Thus, even under the authority relied upon by appellee, the non-commercial website in this case would not constitute a trademark infringement. And, under this case cited by appellee - as well as many other cases cited by Mr. Brodsky - appellee's glib overstatement that "trademark law generally prevails over the First Amendment or any other rights," Opp. Brief. at 43, is belied.
Yet, even as so limited, the holding of Mutual of Omaha has been rejected. In Cardtoons, L.C. v. Major League Baseball Players Assoc., 95 F.3d 959 (10th Cir. 1996), the producer of a series of baseball cards was found not to need the permission of the Major League Players Association to sell cards with the ballplayers' pictures on them. The Tenth Circuit rejected a superficial comparison of intellectual property rights to rights in tangible property:
Id. at 971. See also, Rogers v. Grimaldi, 875 F.2d 994, 999-1000 (2d Cir. 1989) (rejecting "no alternative avenues" test).
Nonetheless, appellee insists that all is well as long as Mr. Brodsky can post his message at other websites using other domain names. Opp. Brief at 43. Steven Brodsky can say what he wants, says appellee, as long as no one hears him. But while this approach might suit appellee in this case, it does not suit the Constitution or even, in other contexts, appellee itself. For example, in Jews for Jesus, Inc., v. Massachusetts Bay Transp. Auth., 984 F. 2d 1319 (1st Cir. 1993), Board of Airport Commissioners of the City of Los Angeles v. Jews for Jesus, Inc., 482 U.S. 569 (1987), and Rosen v. Port of Portland, 641 F.2d 1243 (9th Cir. 1981), appellee fought on First Amendment grounds for the right to express its message effectively. In each case the courts upheld its right to do so, viewing "time, place and manner" restrictions dimly. Yet such restrictions on speech are still less ominous than restrictions on "the words and images that may be used by a speaker." Cardtoons, 95 F.3d at 971; accord, Rogers, 875 F.2d at 999 ("a restriction on the location of speech is different from a restriction on the words the speaker may use," citing Cohen).
Faced with Rogers, appellee denies that "jewsforjesus" is an appropriate title for a website about Jews for Jesus. In essence it then admits that if Mr. Brodsky did not use such a succinct and accurate description of his site's content, consisting of unregistered generic words, no one would have gone to his website in the first place. Opp. Brief at 39. This, of course, is the lesson of Rogers, and it supports Mr. Brodsky's argument that he should be able to use the most appropriate title available for his website. As the Second Circuit explained:
875 F.2d at 1000 (emphasis added, except underscore). Appellee meets this by arguing that "jewsforjesus" has "no artistic relevance" to a website debunking the very idea of ... Jews for Jesus! Opp. Brief at 41. Appellee's conception of "no artistic relevance" is far wide of the mark set by the Second Circuit, which upheld the use of "Ginger and Fred" as the title of a movie that had virtually nothing to do with Ginger Rogers or Fred Astaire.
Even if appellee's metaphysical argument that "the true subject matter of Brodsky's sites is not 'Jews for Jesus,'" (Opp. Brief. at 41) were accepted, and "jewsforjesus" were found to be momentarily misleading to some religiously unsophisticated and functionally illiterate Internet users (see Mr. Brodsky's Brief at 35-36), Rogers teaches that the decision below still runs afoul of the Constitution. In Rogers there was evidence of actual confusion - a full 14% of survey respondents mistakenly believed the actress Ginger Rogers had been involved in producing "Ginger and Fred." This percentage dwarfs the three (dubious) claims of actual confusion out of the almost 6,000 known encounters here. Yet the Second Circuit ruled that even a 14% rate of actual confusion as to sponsorship was not sufficient to overcome the First Amendment, where free expression was threatened:
875 F.2d at 1001. Confusion not only as to sponsorship but even as to content will not automatically displace the Constitution:
Id. (emphasis added). Rogers is consistent with a line of free speech cases beginning with New York Times v. Sullivan, 376 U.S. 254 (1964), which hold:
376 U.S. at 271-72, 279 n. 19 (citations omitted). These cases demonstrate that the right to free expression may take precedence over the need to avoid consumer confusion, even where a label or title may be misleading. How much more so does that principle apply here, where (i) Mr. Brodsky's speech is non-commercial, (ii) it concerns a topic (religion) of special First Amendment concern, (iii) the title of his website is not misleading, (iv) the evidence of "confusion" is statistically infinitesimal and (v) such "confusion" was, at worst, evanescent and harmless? The court below refused to balance the slight risk of innocuous confusion against the profound cost of stifling speech, writing the Constitution out of the law. This was error.
II. THE DISTRICT COURT IMPROPERLY CURTAILED APPELLANT'S FIRST AMENDMENT RIGHTS WHILE UNDULY EXTENDING THE SCOPE OF APPELLEE'S CLAIMED TRADEMARKS IN RULING THAT AN UNREGISTERED COMBINATION OF WORDS DESCRIBING A TOPIC OF PUBLIC AND RELIGIOUS INTEREST, USING UNSTYLIZED ELEMENTS OF A STYLIZED REGISTERED MARK, MAY NOT BE USED BY APPELLANT AS THE NAME OF HIS INTERNET WEBSITE
Appellee defends the District Court's unprecedented extension of trademark law to protect an unstylized version of a stylized registered mark by claiming that (1) its JEWS FOR JESUS mark is not stylized (the first time it has ever made such a claim); (2) the stylized portion of the mark JEWS FOR JESUS is immaterial to the rights claimed; (3) this Court's opinion in Natural Footwear, Ltd. v. Hart, Schaffner & Marx, 760 F.2d 1383 (3d Cir. 1984) is wrong. Each of these is addressed below seriatim.
The preposterous claim that JEWS FOR JESUS is not a stylized mark is new to this litigation. Even if there were anything to this claim, it has been waived both by the appellee's own unqualified use of the term in its own papers, A011, A063, A107, and its failure to appeal or in any way object to the District Court's finding that the mark is stylized, A355. Even appellee's motion to supplement the record on this appeal plainly states that its mark is stylized. Therefore the discussion in the Opposition Brief about the protectability of a word "registered in typed format" is irrelevant and seriously lacking in candor.
Appellee claims alternatively that the Star of David portion is not a material part of the stylized JEWS FOR JESUS mark - that it is "inconsequential." Opp. Brief. at 30. Besides defying both sense and the "as shown" disclaimer in the registration, appellee's position is contradicted by its own behavior. Why did appellee not register the words "Jews for Jesus" without any stylized element at all? Discovery has shown that there is no registration for a "plain type" "Jews for Jesus" mark, and that the decision not to apply for one was apparently made upon the advice of counsel. Obviously such an application would have been rejected as generic. That rejection would have hindered appellee's sub rosa strategy of bootstrapping its legitimate rights in the stylized JEWS FOR JESUS mark into a monopoly on the unstylized generic words it could never register.
Appellee's "inconsequential" position is further undermined by the trademark record, considering appellee's registration of the following additional stylized mark, No. 1,537,366 (Laulicht Aff. at ¶ 3):
If, as appellee urges, the Star of David in JEWS FOR JESUS is "inconsequential," is it also inconsequential in the FOR mark? Does appellee then claim rights in the word "FOR"? Such a trademark strategy, if allowed, would certainly keep Steven Brodsky, and appellee's other religious rivals, very quiet. It allow appellee to avert the pain of criticism that motivated this lawsuit. But "a function of free speech under our system is to invite dispute. It may indeed serve its high purpose best when it induces a condition of unrest, creates dissatisfaction with conditions as they are, or even stirs people to anger." Rosen v. Port of Portland, 641 F.2d at 1248, quoting Terminiello v. Chicago, 337 U.S. 1, 4-5 (1949).
Finally, appellee seeks to avoid the implications of this Circuit's rule in Natural Footwear. It cites Professor McCarthy's belief that this Court is simply wrong when it says the rights granted by a trademark registration are essentially limited to the terms and uses of that registration. Opp. Brief. at 33. But Natural Footwear is consistent with the Supreme Court's holding that the holder of an incontestable mark cannot expand its rights "beyond the good or service for which it was originally designated." Park 'N' Fly Inc. v. Dollar Park and Fly, Inc., 469 U.S. 189, 204 (1985).
Appellee wrongly focuses on whether the PTO registration classification is controlling. Opp. Brief. at 33. Mr. Brodsky's Brief does analyze the District Court's flawed classification ruling. But what matters here is the listing, provided by the registrant to the Patent and Trademark Office, of actual uses in commerce, the sine qua non of trademark protection. Appellee ignores this.
Appellee admits that its § 1065 "incontestability" affidavit, setting out the specific continuous uses of the mark over the previous five years, was not before the District Court. Opp. Brief. at 5. But even though appellee has moved to supplement the record on appeal, it has omitted the § 1065 affidavit it refers to in its own brief. On inspection the reasons for this omission are clear. The only use indicated in the affidavit is for religious pamphlets. And the only version of the mark on the affidavit exemplar is not in "plain type" or "block letters," but JEWS FOR JESUS, with a large, prominent Star of David. Laulicht Aff. at ¶ 2, Exh. A.
Appellee sees its stylized trademark registration as a literal carte blanche with which to cashier its enemies, a bootstrap to rights of unlimited scope. But Natural Footwear teaches that trademark registration grants only a carefully circumscribed monopoly on expression. Nothing in appellee's Opposition Brief suggests that the law should be otherwise.
APPELLANT'S USE OF AN UNREGISTERED WORD COMBINATION TO PROMOTE HIS RELIGIOUS POINTS OF VIEW ON THE INTERNET, AND TO PROVIDE ACCESS TO A NON-PROFIT, NON-COMMERCIAL WEBSITE SHARING HIS VIEWS, IS NOT COMMERCIAL SPEECH UNDER THE ANTI-DILUTION ACT.
Appellee, faced with clear Supreme Court authority establishing that neither Steven Brodsky's nor Outreach Judaism's websites are commercial, and that appellee has no cause of action under the Anti-Dilution Act, is forced to resort to the "no bright lines" argument. Opp. Brief. at 48. It ignores the standard of Cincinnati v. Discovery Network, Inc., 507 U.S. 410, 422-23 (1993) (speech is commercial if "proposal of a commercial transaction" is its sole purpose), and lists all sorts of things that Steven Brodsky is alleged to have done. But none of these acts is, separately or together, the proposal of a commercial transaction; merely a religious one. This is not commerce, but a "communicat[ ion] of information, express[ion] of opinion, recitat[ion] of grievances" deserving of constitutional protection. New York Times v. Sullivan, 376 U.S. at 267. See American Civil Liberties Union v. Miller, 977 F. Supp. 1228, 1233 (N.D. Ga. 1997) (statute prohibiting use of trade names or logos in non-commercial commentary in Internet transmission violates First Amendment). The fact that Mr. Brodsky also refers Internet users to Outreach Judaism, an effective advocate of views with which Mr. Brodsky agrees, cannot change this.
Appellee attempts to distinguish Dr. Seuss Enterprises, L.P. v. Penguin Books USA, Inc., 924 F. Supp 1559 (S.D. Cal.), aff'd, 109 F.3d 1394 (9th Cir.), cert. dismissed, 118 S. Ct. 27 (1997), because the trademark use there was a parody. Appellee does not explain what difference that should make in this Court's analysis. And appellee's citation here, Opp. Brief. at 49, of United We Stand America, Inc. v. United We Stand, America New York, Inc., 128 F.3d 86 (2d Cir. 1997) is inapposite. There a breakaway affiliate of a political group sought, by use of its former parent's name, misleadingly to identify itself with the well-known larger group. Id. at 88. The defendant's use of the United We Stand America trademark in this way was correctly found to threaten "significant consumer confusion," id. at 89, with "catastrophic" effects, id. at 90. Because of the depth of the United We Stand deception, its facts resemble not this case but Planned Parenthood. United We Stand also has nothing to do with the Anti-Dilution Act. While the Second Circuit held that "commerce" as used in the Lanham Act was meant to extend congressional jurisdiction over trademarks to its full constitutional extent (which has never been challenged by Mr. Brodsky), it never ruled on the meaning of "commercial use" under 15 U.S.C. § 1125, the Anti-Dilution Act. That statute was not even asserted in United We Stand.
Ultimately appellee must fall back on Planned Parenthood's novel, unprecedented "tests" for commercial use. One equates intellectual "competition" with "commerce." Another says that a trademark use is commercial if it "showcases" or "plugs" something. A third finds commercial use where the defendant intends to show that the party asserting the mark is "wrong." Opp. Brief. at 46-47. These formulations, however, are descriptions of debate, not commercial use of a trademark under § 1125. This Court's approval of any of them as a basis for a finding of "commercial use" would not only eviscerate the Internet as shown by the amicus, but devastate the First Amendment.
THE PHRASE "JEWS FOR JESUS" IS GENERIC AS APPLIED TO JEWS WHO ARE FOR JESUS.
Regarding Mr. Brodsky's argument that the words "Jews for Jesus" are generic, appellee tries several distracting tacks, ignoring the analysis presented by Mr. Brodsky, as it must. It claims that genericness is not a defense to an incontestable mark. Opp. Brief at 23. But Mr. Brodsky has never used appellee's registered JEWS FOR JESUS mark; nor has he ever claimed that this registered stylized mark is generic. It is the unstylized, unregistered words, "Jews for Jesus," the ones comprising the domain name at issue, that Mr. Brodsky maintains are generic. Appellee has no more right to exclusive use of "Jews for Jesus" than the holder of a stylized trademark depicting the words CHOCOLATE FUDGE covered with gooey drips, or even just one letter so stylized, would have to those generic words without the device. See A.J. Canfield Co. v. Honickman, 808 F.2d 291 (3rd Cir. 1986); see also Leejay v. Bed Bath & Beyond, 942 F. Supp. 702 (D. Mass. 1996) (generic phrase not protected by stylized registered mark); Armstrong Cork Co. v. World Carpets, Inc., 76 F.R.D. 613, 615 (N. D. Ga. 1977) (stylized mark not a grant of monopoly in words).
Appellee also ignores the authority establishing that generic use by a trademark proponent amounts to estoppel of the trademark claim. It portrays its own generic uses as "ambiguous" (the same word it used to describe Natural Footwear), and "isolated examples." Opp. Brief. at 24. But appellee cites no authority for the proposition that its own generic use, even if "merely" sporadic, does not work an estoppel. In fact, the examples in Mr. Brodsky's Brief were just samples; there are more. Here is another one, taken from one of appellee's own publications:
A229 (emphasis added, except underscore). There is no suggestion in this excerpt that, to be "a Jew for Jesus," Mr. Stern need formally affiliate with appellee's group or license its purported trademark. Rather, a (profound) spiritual change is contemplated. Once accomplished, Howard Stern - under appellee's own formulation - becomes "a Jew for Jesus." Without a Star of David.
THE DISTRICT COURT ABUSED ITS DISCRETION BY ISSUING A PRELIMINARY INJUNCTION DESPITE APPELLEE'S FAILURE TO MEET ITS HEAVY BURDEN OF PROVING A REASONABLE LIKELIHOOD OF CONFUSION SUFFICIENT TO OVERCOME APPELLANT'S RIGHTS UNDER THE FIRST AMENDMENT.
In defending the District Court's likelihood of confusion analysis, appellee comes again to its prized exhibits: the three "confusion affidavits" of Chellathurai, Kalstein and Sanchez. There is little left to debate regarding whether these affidavits demonstrate confusion, or, more likely, the absence of confusion. This Court will simply have to read them. A076, A080, A257. Appellee suggests that the District Court found "initial interest confusion" here. Opp. Brief. at 37. But this doctrine is mentioned nowhere in the opinion below. Developed in a sales context, it has been applied only where "a potential purchaser is initially confused [such that] the [senior seller] may be precluded from further consideration." Weiss Assoc., Inc. v. HRL Assoc., Inc., 902 F.2d 1546 (Fed. Cir. 1990) (emphasis added). Thus it does not apply here. In fact, in Girl Scouts the Southern District of New York rejected transient confusion as proof of trademark harm in a social-commentary context:
304 F. Supp. at 1231. As the Girl Scouts court recognized, ephemeral moments of confusion that do not threaten to divert sales are not evidence of actionable harm under the Lanham Act. Real harm must be shown to overcome the constitutional protection of free speech:
Id. at 1235. Similarly, there is no evidence in this case of any actionable or even discernible harm that appellee has suffered as a result of Mr. Brodsky's website. Even the court below admitted that the publicity surrounding this dispute was, far from harmful, undoubtedly a boon for appellee. A436-37. And all three supposedly confused affiants found their way to appellee's website, undeterred by Steven Brodsky and more zealous than ever in their devotion to appellee. In fact, their reports to appellee negate the suggestion of confusion; again from Girl Scouts:
Id. at 1231. This passage perfectly describes the three "confusion" affidavits here: indignant, yes, but certain that appellee was not the source of Mr. Brodsky's website. They were not confused.
When actual confusion fails, appellee falls back on intent. Despite the nonconfusing content, despite the explicit disclaimer, Steven Brodsky is said to have intended confusion and therefore, by definition, to have violated the Lanham Act. The evidence proffered for this conclusion is Mr. Brodsky's statement that the "intent behind [his] bogus 'Jews for Jesus' site . . . is to intercept potential converts before they have a chance to see the obscene garbage on the real J4J site." A049. This statement is amenable to more than one interpretation, of course. For example, what does "intercept" mean in the context of this case? Appellee admits that "Brodsky, like any other web site operator, cannot compel an Internet user to visit his site." Opp. Brief. at 39. Obviously, neither can he compel anyone not to visit appellee's website. Appellee sounds a drumbeat of "intent." But what does appellee itself say was Mr. Brodsky's intent? "Providing . . . Internet users with information." Opp. Brief. at 13 (emphasis added).
This Court has stated unequivocally that under the Lanham Act, "evidence of defendant's intent does not relieve plaintiff of its burden of proving likelihood of confusion." American Home Products, 834 F.2d at 371. Appellee has never met its burden. Its "proof" of intent amounts to proof that Mr. Brodsky intended to provide information appellee did not want not provided.
The court below ruled that the law of unfair competition proscribes Steven Brodsky's dissemination of information. The cases and the plain language of the statutes themselves demonstrate the District Court erred. But even if the District Court were right about the Lanham Act and the Anti-Dilution Act, it cannot be right that the First Amendment does not protect Steven Brodsky's right to attempt intellectual "interception," otherwise known as persuasion.
Steven Brodsky's effective expression of dissent threatened - in appellee's own words - to "provid[e] these Internet users with information" that is "antithetical to [appellee's] message and mission." To suppress that message, appellee launched an assault styled as an unfair competition claim. It claims Mr. Brodsky harmed it under the laws of commerce.
But appellee has never described any commercial harm it has suffered. Before Steven Brodsky's website was posted, appellee had a website to promote Christianity to Jews. After the website was posted, appellee had a website to promote Christianity to Jews. Appellee's website was as accessible as ever and there is no evidence that the number of visitors to appellee's website fell. But, there was Steven Brodsky's stinging critique, the fact that it could be found, the possibility that it just might persuade.
Neither the censorship of religious ideas, nor the protection of one creed, are appropriate uses of the law of intellectual property. The Lanham Act is a valuable tool of commerce, not a weapon of religious engagement. The state's role is to guarantee the freedoms of religion and speech, not to be the agency of an ecclesiastical ban. For the foregoing reasons, appellant Steven C. Brodsky respectfully requests that this Court reverse and vacate the order of the District Court.
Dated: May 29, 1998
Page 1 of 1