counsel away quite often going back but i would like to get your description of just how the leak management system there are occasions which which have happened which is essentially given rise in this case where there will be blockers or exceptions blocking conditions that are put on those files so that the seems to be the most controversial in this case with me mismatch that would be another reason that interest in this match between the owner's name and customer records mean there would be a further delay  i don't think any of this matter from a constitutional perspective it's i think i think that there are there are several reasons why the occurrence of these delinquencies and just i'm glad i had the opportunity to describe i very very greatly on this agency for i think it's i think it is it's not only argument but it is legal positivism so explain then what that means our significant the head where border agency princip to the tense but the landlord could take steps that see to it that assure that the landlord to receives whatever notice ten years so we're at least the information which is the correct any errors which is the purpose of the due process clause what they're trying to do is they're trying to say that we ought to have an obligation to let them know when they can talk to their tenants that's our problem that that is something that they need to work out good morning if it please the court i'd like to start with three key points that set up set out our position point number one the property deprivation at issue here is a ken as a practical matter would as a practical matter reduce the risk of a rony as well and if the seri deprivations then such a process is required point number three that inquiry nothing about giving management system that case the kamel court decided was based on abstractions on assumptions we had we had the technical the technical spec documents for the man system to deposition reason doesn't appear until it is at the moment it's perfected upon filing that's that that is correct and as and what happens here quickly is a computer a computer a p g he talks to a computer great common pleas it goes on the is going to address this to if someone's trying to sell their home and you know the title search as a you know three years worth of gas bills not paid you got a problem here you couldn't clean that up pretty quickly right meter peter you bring the count when would what kind of notice is appropriate way n should that notice be deliberate and is there an opportunity to be heard i mean putting aside the notice that the  here's this goes i guess the second prong i've seen you supporting a record for the district courts finding that there is tremendous risk of this the testimony as i recall it was a few i think the city said yeah there have been a few instances for months thinking about that yes yes you're on a stake and the but you're not mistaken that there was testimony about three or four times a month people in  management system that is supposed to protect them from we all together are mistakenly weaned that's what that was but there was much more powerful statement about the systematic problems mainly from that the expert import from fro roger coleman who basically talked about the fact that you know he truly bills are not simply a question of reading a meter there's all sorts of reasons why that might be a difference between what comes up on a bill and what may actually legally be but this  expert testimony mr mr cole should also say that the risk it's not simply a risk of fear is no guest will have a risk also is of unnecessary deprivation but what that's an essential aspect of this particular circumstance here of it you know when you look at what matthew says it's not simply the risk of eric the probable value of the decisional safeguards and whether the necessary or provided to them directly the first first off you run if if i could respectfully say that for constitutional purposes that that actually isn't the right question well i there was evidence that mitchell waterfront did make efforts to get it tenants to notify them of its bills and he tried and they didn't give it to him and meanwhile he found out later  the bill was outside of his knowledge not being paid and was being and was being your ears were accumulating but the reason that i said what i sa situation well i mean you can't dispute that the gas has been provided it's already there of course so so is that not analogous to the mechanics and situation where the materials the materials that i already stated but even if we were to view there to be substituted and in kuwait insure something there is a municipal claim at the most that the significance of that would be that maybe the city's interest is more significant than then the state interest in florida we don't deny that it is in fact judge judge ordered knowledge that there's a very substantial state interest that that's never really been a question here the quite starkly as a steadfast refusal by the city of philadelphia to acknowledge its unassailable constitutional obligations all right thank you we are as we were with mr gottlieb be on your top be on the time you can see that the city can do a better job here but it's job such as it is passes constitutional muster to pass constitutional muster and we're back to chief judge