they never raised the issue that wasn't raised in this court in their letter brief they argue that we didn't raise that we raise it in our in our on and that is certainly the the statute in this particular instance has no potential impact on interstate or international commerce all of the activities took place within the state of louisiana in point of fact this was the area where the delta farms and then it's filled with water and the only act as far as we can sell the only activity that takes place in this area is serving the small class lawns with oil wells in this in this is no no no no one is going into this area and transporting goods in interstate or national commerce it's difficult to imagine how plugging in abandoned operations in waters in the interior of the state of we would ever pass international international uniformity of that law in its international interstate relation now of course there is no contention that the loss of the statute of question contravenes any purpose expressed why not the congress congress has never seen fit to regulate indemnity agreements congress has never seen fit to camp to regulate oil and gas operations in state curatorial waters in point of fact in passing a submerged lands that congress expressed they gave the states the right to manage lease develop and use the submerge lands and state their core waters in accordance with applicable state law so far or hitting the states regulate and it's authorized by congress as i've said there's no interference with interstate or international supreme court in determining whether the death of the high seas act or the  know i think the number ought to be which predominates which is the most important is that it that that would comport with the screen gorge languaging incur where they say principal objective primary all the other circuit would also be consistent with grand isle shipyard where the court said where does the majority of the work take place in this particular case the platform related activity consistent with the majority of the  imagine a situation where you have an insurance policy on a marina and you sixty percent of the premium was what was for insuring the buildings and the piers and the docks and twenty percent was for the hole the marina aspects would be would not be incidental they would not be but they would not but i don't think any court would consider that a marine insurance policy when most of the premium was for insuring real estate local inherently local does not mean that the activities have to extend across the states borders because the nature of the application of comparisons that should be treated the same way as other parts of the lifecycle of an alright gas well off shore but we still have that new test that both sides have been talking about an inch of deal with whether the vessel is playing a substantial role in the activity so so first of all all the work that was done on those three wells were done from the  being made by our side the same way or have been done on shore on dry land equipment is the same equipment wasn't moved off the vessel onto the platform equipment that was actually being used to plug in abandoning the well truck where they hire the crew and the vessel to go out and do the job  is not the question we are not questioning whether this was a these were water something to jurisdiction and but the court since the beginning of the republic the the courts have held that the states have considerable power to regulate marathon place on the platform it's not it's an awful sight that cast is it is it is it is certain it's something that can be determined it can be determined from work records of where the people were actually working  submit that i'm not suggesting an answer to it i'm just trying to zero in on where we are we have an arm doc opinion is down here and you're not in the heart of talking about it and it's just very new and i think it controls escape so under the door on test and the footnote that follows that the part the judge about referred to will not only consider the time spent on the vessel but also the relative importance and value of the vessel based work to completing the contract and he has  relative relatively insignificant compared to the work done on the platform and the work and what was contributed to this job by the plugging in abandon get back to you soon as possible we'll take a brief recess