there has been some question whether the interest of the enemy members is contingent that they might go out of business or something else but in fact it's it's the same virus seller relationship and it's the government has said in its  represent the interests and that is because while we agree with the government that the border should be open to both live cattle and to enjoy beef it's the position of animal and its members that if it is not open to like cattle it should not be opened with the because that creates huge into injury to those members here who are having to hack these pay higher prices for their be here for the animals and compete with increasing imports of honesty from canada and with the restriction on the border the animals cost less north of the border and because of this unfair in this room and three competition intervention should be liberally granted and that it should be liberally construed here and it's the question is whether the government may not represent those interests and opening the border are in pressure simultaneously but beyond that they m it's an intervention case plain and simple we plainly have significant protectable interest and the government simply may not and cannot represent as a interest adequately let me if i may take up on the adequate sea of representation right away as your honors know under the terms of each case of the supreme court and under the precedents of this court there is a very minimal showing required by proposed intervener with respect adequacy of representation we simply have to raise a sufficient doubt kinds of arguments that we made in those briefs which were either not made or lightly made only by the government the point here is not so much finding individual little arguments although remember the standard is that they have to be able to undoubtedly make all commitments but to point out a divergence of interest here with due respect although the case has moved along there is plenty of it yet to go we still have a hearing on july twenty seven which we would very much like to participate  party we have post possible post here in submissions and possible settlement discussions possible of feels possible in sportsmen's of judgment if the judgment is in our favor all these kinds of things we would not be able to do without being a party intervener we can't do simply by our calf at the very end they raised for the first time that usual whether the district court should ban not only our cattle but any beef products made from our cattle from the united states part of this permanent injunction the injunction of beef products in addition to cattle would foreclose the entire u s market and therefore is a matter of supremum importance to our members and the other hand for the national media so c h and representing domestic packers whether beats comes in from things to all people it simply cannot if it's going to represent the interests adequately that it may it cannot possibly represent adequately the interest of a t t and c c a if it's going to represent our interests it can't possibly represent the interest of it and they simply can't bridge that gap in our case we are not constituents of the u s department of agriculture we do not in contrast to the our kaki case which is cited repeatedly by our adversaries we're not facing a situation where the government has the sta and constitutional obligation to reserve represent our interests and there are no other interveners that have successfully intervene in this case that could possibly represent our interest again a distinction with our kaki where there were some other native hawaiian groups that had already successfully intervened now we hear it's like getting problems my goodness if you let us in no telling who on the wings is going to try to come in well the fact the matter is there are no other active intervener motions pending in the district court or in this court other than the ones you have here today and if this court or the district court were to find this as interviewers and someone subsequently came in and sought to intervene the court could as was the case in our copy say well they would have other private intervenors who can represent your interest so that we recalibrate the issue of whether there's adequate representation of that point let me just briefly if i may no questions on the the on permissive intervention made with just a very brief point about  do to defend its rule and that's what is the issue here or what should be an issue is whether the department of agriculture has acted consistent with his obligations to protect animal health protect the  interveners they have set out where they can be at odds with each other and i think that they probably you could always differentiate there are competing interests in fact do you wouldn't really even necessarily be able to get hurt or might not be addressed in this lawsuit even if they weren't intervener oh absolutely absolutely and that's that's obvious in the briefing i think you know you're right they do have different interests and the american media institute which previously did participate in the case has different issues we have a bunch of different parties they're interested that's clear and they don't all have the same interests but that's precisely why we shouldn't relative advantage that's not what this case should be about and unfortunately that's what it's largely become about so i think i would ask the court to consider the point that we made in our  presenting these people with a life or death decision if you look at what it is that they want to advocate and they want to advocate something has nothing to do with the animal protection act they want to advocate either there should be open borders and we should import cattle and be from canada or there should be closed borders we should important either well that isn't anything to do with whether it's riskier not to import any cattle or an a they want to argue that that their argument again has nothing to do with whether the united states is being subject to acceptable and obviously other parties that have a need in making statements in the press that if these people's intervention is granted then they are prepared to intervene because everybody wants to get into this case this should not be a distraction  the agriculture is perfectly capable of just standing on the administrative record its actions and and we don't need anybody else to explain those actions in order for the district court to make an appropriate  places of protection the economic interests of the livestock and related industries given equal weight by congress so the protection of health and welfare of the united states citizens of the united states i submit that there's no support for that statement and it just is a clear indication of what we have here a bunch of people whose interest has nothing to do with the animal action act coming in and saying we want to get into this case because we want to make more money we want to make what congress intended this statute to be used for and it equal weight to their economic interests or anybody's economic interests is just ridiculous t shown by their briefs and by the argument here is that their interests don't really go to the core of what should be at issue in the settlement here which is one is that acceptable level of protection for us cattle and us consumers what thirty seconds make it quick it's already down to twenty five and the animal health protection act provides for the protection of the livestock industry including packers and the livestock industry economics are at issue here contracts it is certainly correct that the contracts that we originally spoke of are no longer because you can expect us buyers to wait month after month after month of delivery of cattle however that is not what the score should be focusing on as to whether the contracts are still in we have demonstrated through the generations that were in the record below that we have a contractor relationships that would be able to be resumed as soon as the injunction it's listed with us virus and that kind of useful in looking at the issue of contracts both present past and future but it's clear that we have contractual relationships that are changing on the result in the outcome of this case and that is a significant protectable interest that's been repeatedly acknowledged by the courts thank you