court actually keller on behalf of the appellant's i'd like to reserve four minutes of my time for a bottle please granted the district court's decision should be reversed per three reasons that i'd like to state briefly at the outset if i met first the decision below reads more like findings of fact and conclusions of law as opposed to an order granting summary judgment pursuant to rule fifty six to provide just one illustration of this look at what the district court said on the six donovan factor on whether drivers are integral to the business something that we experience on the court of appeals sometimes as well the use of the word fines when what we really mean is concluded and district judges do it as well but a handstand from your point of view it can be a bit especially when we're in the context of a motion for summary judgment to the important point though whether or not the plaintiffs status is that  lawyer or independent contractor is a legal conclusion is it not it's a mixed question along factor in this is what the sixth circuit setting power and that's what i believe this court seven value is still subject to the same standard of review though says that go into any one where all of the six factors involved disputed issues of material fact then as in any other case we're talking about something that not to be subject to a grade of summary judgment if i understand your honour's question correctly i believe the answer is yes but i want to make an important clarification on how it back in to the language that i just quoted from the district court even if the historical facts are not disputed inferences can still be drawn from those facts and not of the classic derogative of the jury look at what the district court said here we're trying you're talking very obstructive though when you say that i mean i think we need to talk specifics you would agree with you that we need to look at disputes of material fact or the lack thereof with respect to each of those factors individual right each of the six pack absolutely ana and i would agree with and then it would be for the district court to wait if you will and that's what is required with a factor test even if the court cannot and should not be making factual determinations it does have to weigh the relative importance to reach the legal conclusion there are two components to your honor's question let me answer the uncontroversial part i think it is undisputed that the donovan factors are questions of fact that's what this court seven pilot marca and so if there's a reasonable reasonable dispute about historical fact or the inference is that can be drawn from those historical facts that has to go to a jury the second component of this question is whether once the jury comes back and says here of a sixth on of impactors we find these three this way or these three that way and how strongly we find them for one party or another does the district court then as a matter of wall weigh the factors i would submit to your honor that the answer is no mix questions of law in fact go to juries all the time under the seventh amendment judge easter books concurrence and warrants and points this out the six circuit and teller pointed out but  you don't need to get to that more controversial part of my answer your honor to resolve this dispute because on the six donovan factors which again are indisputably questions of fact the district court here took it upon itself not through sloppy language but through what the district court actually did it to resolve the factual questions and again i'd like to return to the language of the district court's order with respect to the six donovan back what did you hope i said i'm not interested in that language at the moment very good the the dispute as to material fact is which way the control factor cuts and how substantially cuts in favor one party or another here of a fact then if that's the case if substantiality is the question draw an inference that it cuts for one party or another but the opposite extreme is also possible if we want to go to logical conclusions the position of my able opponents would be that no case should ever go to a jury because the donovan factors often do not involve disputes as to historical fact but they do involve disputes as to what inferences to draw let's look at control to return to judge green always question on the question of control here are the facts that will perhaps and we agree it should be allowed to present these two or jury we're not asking the court to reverse and render we're simply asking for the trial or fact to be impaneled points to its contract that disavows an employee employer relationship while that can't be dispositive undervalue america goober notes that drivers have the flexibility to log into the app whenever they want and they don't have to ask permission to take vacation time also true and by america to present back to our jury let's look at the countervailing facts wilbur sets the price of rockets there's no dispute about that this court in martin said that the ability separate is itself a significant indication of control and again your sister circuit in persuasive authority and power said the same thing you were doesn't just set the price of rhymes unilaterally and in real time changes the price based on proprietary algorithms that import of that contract because unless i've missed it certainly none of this court's jer's prudence to the other cases i've looked at help me with just how the existence of that contract as well as its terms factor into our analysis here is we are bound to apply it under dial america and the six fact of course consider that factor on with the six explicit factors of god this is the reason i don't think i can be more helpful your honor because the donovan factors are geared around a question that is also a question of fact what is true as a matter economic reality  i got to be agreement there's no way to sign a signatory of that agreement can come away thinking that there is an employer employee relationship doesn't matter what they think your honor respectfully be f l i say is not designed to implement contracts it's often designed to work out if people could just put clear contractual language in there and one agreement saying that we're disavowing an employee isn't whether it's dispositive right the point is it's relevant it was a play in the consideration i totally agree your honor entitle to present this to the trier of fact we are not disputing that there is a relevance to the contractual language but look at all of the other facts according to new standard not your explanation here if i understand you correctly you're essentially saying  t when there is a factor test presented by court of appeals or other other court there was always going to be a genuine dispute because there are always going to be arguments that are presented that may be presented that are somewhat persuasive on either side and when that circumstance happens then we have to go to a jury and what i haven't heard is your disposition of the district courts carefully enough that it has said to the benefit of your adversary talk about those four factors i'm happy to your honor so let me continue with respect to control because i think there are additional facts that you're wrong and should consider that would demonstrate that this is the sort of case that you're going to the jury i'm not committing to the position at all that every case should go to a jury cell attacks and apply in clear cut cases but this is not such a case so in addition to setting the price and unilaterally changing the primes who tells these drivers where they can drive and turns them off if they drive outside of a particular territory and perhaps most important of all we're collects payment from the rider  resolves all disputes and issues refunds the drivers have no recourse if chooses to do that if i had my phone on i would show you the reckless how that happens and you can take additional notice of it and then this is extremely important who doesn't tell the drivers where they're going or how much money they're going to make from a rock until the lot the driver is already on location a rider is in the car and the driver clicks the begin trip button who likes to analogize it so when it talks about the control factor to the yellow pages it says it's just yelling troll say to control fact it is to trip benefit in your detriment because the drivers can say you know i don't want to go to that part of town that's correct your honor that's a significant amount of control for transportation company again think about the yellow pages when you let your finger do the walking i don't understand that seriously because if you just the regular taxi there are controls that the taxi commission has over you whether it's philadelphia new york cetera you're not able to say i won't do that that's illegal so i'm not allowed sure why that and i'm not trying to your detriment their benefit in thinking about control while you're on i'm not trying to suggest that taxis are employees of the regulatory commission but the difference here is whoever controls where the drivers go pers eisley for their benefit they're not implementing these contractual formalities just because they have some public policy minded reason like a regulatory commission might this is all designed to maximize hooper profitability which by the way is fine we think that may well be the most efficient way for google to run its business it may be the most efficient way to provide service to customers we're not criticizing her for having this business model but if it's going to choose to wield this level of control then it has to treat the people that it's controlling as employees or at least this factor could reasonably be construed i'll continue of course your office art piece but if you send i saw the red light i want to make sure that if we were of course that i'm merely saying that i have a mensch respect for the way that chooses to run its business but the control prong to the extent there wielding this control not the way a regulatory commission does they don't care about public policy they care about they care about their business and so when these bit of time talking about the the reality of the self incorporation of the three for the story so i understand that there are different levels and degrees your argument is a result as a driver doesn't make that much and is you know caught in the box that puts it right now and then locks is you know the business have the lease agreement and so forth that creates revenue expenses it's it's true it seems to someone looking from the outside that this is a result relies on the lease agreement to have the lease with the helpers and that's really all i have but you know when you pierce through all of it it sounds like the hopers are the ones who have a relationship with  and not principally resign so help me understand that from your perspective there is a lot on pat they're gonna let him start where you concluded about the helpers having to interact with rumor that is precisely right and the six circuiting teller and the eleventh under this factor which is in the investment factor do the employees or the punitive employees make an investment that's where the helper's problem comes into play both your and your colleagues on the six or seven circuits that when the suppose at helpers  have to be subject to the same terms and conditions that are imposed by the putative employer that doesn't cut in favor of independence so i want to start with that second i will answer those cases the  are imposing the same tones and conditions the same controls that we previously talked about on the drivers that mr rhys auckland's on a suppose a helpers and the reason that that makes sense your honour's is those hopers are not being brought on by m impart his great managerial still having built this independent company on those helpers of the those helpers can maximize his returns they're simply simply people that he's bringing on a signed leases so that they can go drive her to there's another important aspect of it looks like right there i mean that's a business enterprise i don't understand why we should describe employer status to her when mr was you know through hard work etc you know has essentially built a business that is not dependent on an uber because here's here's the problem that i have when i look at the model either mr rezai his brother and all of the helpers are  business because as i understand the record in help if i'm wrong he is really he and the business entity if you will have a relationship with blakley they have a relationship with lift and they also provide private services so they've made a business decision that hoovers the best way for them to make money while your honor the case is made clear that the donovan factors have to be viewed through the prism of economic reality and so what matters is not what the drivers could do but what they actually electrician or a plumber that you would find actually through the yellow pages which wouldn't control the problems and wouldn't tell electrician where to go to and wouldn't an issue refunds on behalf of customers and electrician comes to your house performs a single job or a plumber comes to your house on cl and leaks and yes you pay him for that service but he has lots of independent sources of income and so when you're looking at this factor it is absolutely relevant that mr was octal rives ninety eight percent of his income for mover as opposed to the inverse of that which is only two percent of doing over one hundred trips and was receiving i'm going to eleven thousand dollars a month from black line why should be penalized for his business decision in two thousand and fifteen and sixteen not to use black line or to use black to use a ray of leads that he could choose from it's not that he should be p it's not that he were should be penalized your honor it's a question of what we should do based on this factual record to determine whether these drivers are dependent or independent of goober and i know that we're talking about mysteries are and i'm happy to continue doing so but i do want to know it's not fair to lump these three individual point gives together and simply view them through mr overstocks lens there's also mr sure contractual intent was that they were utilizing the drivers as independent contractors and not as we i think only aware federal and state labor lawyer and i think  pulling away or a contract form is not binding they are in a better position to tell you what they were thinking but i would be highly surprised if they didn't have their legal department trapped in these agreements to maximize the odds that they can escape the strictures of the oth test when confer need with a case that also involves a detailed written time track what are we to do with it i think that you should take the contract and into account if you're acting as the trier of fact in a bench trial and you should allow the consider the existence of the contract and the contractual language within the familiar cell attacks playing walk and so if you believe that that's the single factor the talks over the line to say no reasonable jury whichever donovan factor you're considering probably  the of the employment status of workers is a legal one and you said that in the context of reviewing a bench trial decision your honor where of course the standard can be different the findings of fact and conclusions of law that a will fifty two is of course a legal conclusion and so that's what this court was reviewing i'm aware of no precedent from this court or any other court of appeals that says the only way a jury gets a donovan factors is through a special verdict form they have to come back and say yes or no and the degree to which what each factor goes a particular way and then that gets handed to the judge to resolve the alternate legal question as a matter of law and so this is a classic mixed question of law in fact unless you're going to be the first court of appeals to say ultimately a question of law and this includes how to weigh the doj in factors and to come to a conclusion about what the better television of the circumstances were in favor of employees that is more independent contractor status you help me with the way in which your adversary has framed the question right so if i understood his argument when a court of appeals such as ours has  multiple factors then when you go through when you have to go through he weighing process that should leave a court to say summary judgment is not appropriate so when you have to say looks at six factors if i understand correctly there's a way in there's there some argument to be made on one side there's some argument to be made on another that in his view that fact that that is the way that it's presented creates a genuine dispute which must go to trial and that's one of the and i think that's really framed it and i'd like you to specifically address live streaming of the issue is that it is incorrect there are three tiers that we need to consider there's at the top the ultimate legal question was the point to an employee or an independent contractor is is and this court has made abundantly clear that this ultimately is a question of law with respect to the six donovan factors that brings us to the i call it the second tier the second tier explores six factors that these to be clear not elements you don't have to check six boxes if they are not equally weighted where it has to be for two in order to come to a conclusion ultimately donovan martin and all the other cases make clear that at the end of the day the question of law is based totality of the circumstances and the six factors are merely a in assessing the ultimate legal question and so my colleague is incorrect in suggesting that the six factors under donovan are themselves factual questions they are tools to reach the ultimate legal conclusion they are things that the court should consider and take into account when reaching the ultimate legal conclusion and so it is not surprising to see cases granting summary judgment and this court affirming summary judgment when some of those factors are deemed to weigh in favor of employment status and others weigh in favor of independent contractors that because ultimately those tools are merely aides to the ultimate legal conclusion of whether under the totality of the circumstances as a matter of law the plaintiff is an employee or independent contractor so the mistake of my colleague is to assume that just what i call second tier this consideration of the six factors present factual questions certainly how we view those six factors depends on the third tier the subsidiary historical fact these are the things that a jury gets to decide what actually happened are there disputes is there a red light testimony and a green light testimony that a jury needs to actually consider when ascertaining the status of the individual in this case there are no genuine disputes as to any of the historical facts in response to your question directly challenging  for the jury to weigh all the different factors it's very clear from this court's precedent dating back to bow america that the weighing of the factors and the assessment ultimately of the totality of the circumstances is for the court not for the jury and so this and it's also true and by the way consistent with the contract which is relevant not only for its statement of intent that these individuals be treated as independent contractors but also it's abdication of any ability to control the very thing you're talking about which is that they can obtain lives through private efforts they can obtain rides through lift or black line there is abundant evidence in the record that even mr issa bonnie's company for emo  had private clients that they attained through their own private marketing efforts that for one of the helpers one of the drivers under freema was his exclusive way of generating revenue he did not drive trips that were identified  actual testimony in the record from all three planets mr sabai included is that there were no restraints on their ability to engage in other activity in fact while they were on line on the graph awaiting trip requests they were also engaged in marketing activities with respect to their other businesses you heard my my questions to mischief tellers regarding the presence of a contract in these cases and if there's one difficulty that mole time factor tests presented to a court it is it becomes harder to extract some kind of rule singular what we're supposed to do with the fact of the existence of a contract little loan its contents can you add anything to that discussion many of the cases that talk about contracts in an independent contractor dispute come to the conclusion that we can all agree with which is that the mere fact that the contract says this is an independent contractor relationship does not dispositive the parties can't contract themselves away from their source no we all know that a s i said mr keller the problem is that doesn't get a scary that's right and that's why the district court very appropriately noticed it when one stating that same legal observation that it's not just that the contract says that these folks are independent contractors but that the contract actually includes many provisions which are relevant to the donovan factors control for example the fact that the contract specifically says that you can provide transportation services using leads generated outside new graph that you can negotiate the price that the price set within you graft is the default but that if a driver wants to negotiate that price down the drivers free to do that that there is no required limitation on where the driver goes while they're online big can go anywhere they want the app only has functionality for riders within the philadelphia metropolit an area of is this this aspect of the app so sure if if one of these drivers went to nebraska they're unlikely to get any trip requests but they're not restricted in going either to nebraska or overseas as mystery's acted or anywhere within the philadelphia metropolitan area they can go wherever they want and that's set forth in the contract so the contract does a whole lot more than say you are independent contractors and confirms the party's mutual intent to have that type of relationship the contract goes into great detail the fees drivers can go online and offline whatever they want they can go wherever they want they  the price down they can cancel trips they can do all of these things and those those indicia of lack of control are not only a matter of contract between the driver and the company but they're also reflected in the undisputed admitted facts within the record what what my colleague tends to do is you tend to confuse the need to identify a genuine dispute of material fact with the ability on his part to use disputed rhetoric and employment sounding so take if you will your third description would you call the historical factual determinations vary and as i understand it that's the only place where genuine plaintiffs says at page ten of their of opening group the drivers who repeatedly cancel trips after accepting them are fired now what they're doing here is using employment sounding terminology fired to try to persuade this court that these people look like employees on the same page they refer to suspending drivers other employment sounding term who fail to accept it why would you or kirby the act of a no right with my permit these are not supported by the record evidence so we look rezai notifying him that they've noticed that on his rider account his passenger account the one you and i might use he was repeatedly going online as a passenger asking for trips seeing the good accepted and then cancelling the trip and he was doing so according to the email gormley high number of times and continuously doing so this this evidence actually has nothing to do with mr rezaei as a driver it has to do with him as a rider of using the app and sending all these drivers off to go pick them up only to find out that the trip was cancelled by this result so that's the evidence so they take this in their brief they try to persuade you that this sounds like an equipment relationship but when they point to the evidence they're not actually point to any evidence t and that's a question of fact and when you have control as a factor and you present some facts that way of favor of saying there is no control they have some facts that way in favor of that there is that there is control that vats not the presentation of genuine disputes as to materially well my point with that example is that there's not even a genuine dispute of fact not forgetting the tiriel for a minute there was no dispute as to what the factual record was or the evidence mr was off even admitted in his deposition that he personally as a driver can fall between a hundred and one thousand trips he couldn't remember for sure with no consequence the record evidence is that there was no consequence for were looking at six different factors and i totality of the circumstances analysis i would still answer that this is not a material fact judge poor you had a question and that one apparent dispute that kept catching my attention because the scientists mentioned it a few times in the briefs and as far as i could tell it or didn't respond to it was and this goes to it's part of control the assertion now who were black drivers are giving us a limited territory and i think you're nebraska example may be just the answer that you're seeing here is your answer that it's not a territory is just the scope of rides that you're able to get in a particular market if you want to work in both philadelphia and the brain aska can you sign up for both but of those apps and so this is another perfect example just like their misuse of the term firing when they refer to territory look at the record they cite to two things they cite to the contract itself which includes a definition of territory which essentially means the the area within which the app will function and in this case we're generally speaking about the philadelphia metropolitan market so the the undisputed record is that you could even leave the market and maybe not all the way to nebraska but you could be on the outside of the market and if there's a rider within the market who can use the app and they request a trip and you're the closest driver you'll still get that trip requests and you can come into the territory and take a trip what i'm talking about so that's that's one of it's just a contract that says there's a territory it doesn't even say what the territory is the other evidence that they cite you is an issue in which mr savant a left his phone online in the airport for you affection is a lot of discussion on the record about the special requirements at airports designed to prevent improper solicitations at baggage claim site or perfectly consistent with p p a regulations and it's it's appropriate but he left his phone inside the airport and went home which was essentially a fraud on  the on the other drivers who were waiting for their turn to receive a trip request and so he was told you can't be in the airport for another for even two weeks now that actually didn't restrict his ability to be a transportation provider anywhere else using the google app or even within the airport for some other company for his private business so we can actually control where he engages as a free mobile driver which is really what he is he can go anywhere he wants in philadelphia they can go anywhere they want we can't send them and say you have to go to center city you have to go to the stadium you have to go to the airport we can't even tell them to go online we can't schedule them we can't tell them to stay on line we can't tell them to accept trips we can't prevent them from canceling trips they can go anywhere they want they can go offline whenever they want they don't have to accept trips which brings us to the suspension factor they use the suspension rhetoric all that means is if you don't accept three trips in a row you're moved offline you can go right back online if you want to we just assume record three non acceptance is that maybe you're not actually interested in providing trip so as a system integrity measure undisputed fact we take you off on the point to all of these facts are understood it there's no historical facts regarding territory that is actually in dispute the question for the court as a legal matter is whether that matters at all and so back to  point about materiality even if we could come up with a genuine dispute of an historical fact we would still have to ask ourselves if you ing that fashion in a light most favorable to employees that it would tip the balance in the w all of the other undisputed facts that demonstrate independent contractors does so let's assume that one of these facts actually did include a red light green light dispute or testimony the role of the court or met scenario is to view that fact with this new fact flip in favor of the planet and if that flipping of that one fact does not change the court's legal view of the plaintiff's status as an independent contractor then it's not a material fact in that context because it doesn't change the outcome a dispute a fact is only that serial if resolving it in favor of the nonmoving party is sufficient to send the case in favor of the nonmoving party there could in theory be disputed facts in this record the appellant's on appeal it was their duty in their opening brief to point to concrete evidence in the record from which this court could look at the record and say ok i see a red light green light dispute of fact now the court would have to take that dispute look at it in the light most favorable to the plaintiff and ask itself viewing ash one fact in a different way does that change the outcome and if the answer is that it does not change the outcome that it's not a material fact and of course you can see it's because you're from the district or despite looking at a couple of facts differently the problem in this case for that in their entire opening brief they do not point to any evidence in the record from which a reasonable fact finder could look at the evidence and conclude that the fact was assessed by the district court in an improper way but for those reasons i would us the court to affirm thank you your honors i'd like to start with some sage words from a colleague in a sister circle if we were to have multiple factors we also should have a trial an approach in which no ascertainable legal rule determines a unique outcome is one in which the trier of fact plays the princip declared that there be some kind of weight given to an express or written contract between the parties you could of course do that your honor i don't see any bill would not conflict with existing racial that that would be in tension with your existing cases which have already dealt with contract language that discipline thousand employee employer relationship says it's not dispositive and still allows what i say you yourself could not answer my question as to what we do with that treasure well your honor i can have it come to grips with that have we i i will try now to answer your question in a better way from my previous answer which is to say the contract is relevant it can be taken into account i'm not sure there's any basis and certainly my adversary has not requested that the court announce a new rule of law saying that in weighing all of these factors extra weight is going to be given to the contract formality and that that way is going to prove dispositive in this case you're free to do it but i don't see any basis in the text or history of the f i f a or the donovan factors in the analysis interpreting it that would allow the court to say more about contract for in this particular case as opposed to every other where employees have tried to or employers have tried to disavow an employee relationship and again i would urge the court i'm sure you have it in front of you as well so what if i love america which states quite clearly that the donovan factors are questions of fact that's at seven fifty seven f section thirteen eighty one and footnote four and so again your honour's look at the drawing of inferences that occurred here from the just before i colle dispute of historical fact that's an overly cramped view of the jury's role that has i believe in any other context no basis in law you don't say that juries are all only allowed to fight about green light yellow light the jur classically get to result in princes and again i point to the fact that the district court felt comfortable not just issuing findings but speaking about the degree to which certain factors went our way work versus way think about what that means in the summary judgment context there's a spectrum of possibilities as to each factor strong for her to strong for the drivers the only way that you could say for example on the six donovan factor drug greenaway that it's slightly favors the drivers under a proper  is no reasonable jury could find that the factor slightly favors hoover and no reasonable jury could find that the factor moderately favors us the only thing a reasonable jury could do along this long continuum of possibilities is comeback because  honor and that's how i think jury trials and the f l s a context of being conducted throughout the country and as i previously remark juries almost never get special perfect forms in these cases they don't have to come back to the district court judge and say we found these four factors one way substantially moderately and slightly we found these other two factors this way now you go back into your chambers and issue the decision as a matter of law these are almost always general verdict cases that's because mix questions of law back always go to juries and so  just as your honor was pointing out in the opening that sometimes loose language is used in the cases at the district court and the court of appeals level yes the ultimate conclusion of employee status can be thought of as a question of law it's about the words in a statute but it's a mixed question instances where workers or necessarily working in a geographic in the jane significator area judge belsen correctly pointed out that you know this is the gate economy that these drivers many of them that driving important and useful question your honor a couple of responses first not to dodge your question but as to b s three plaintiffs this is not some side gig business not a couple of bucks of extra income while they're going to grad school at night these are people  who rely on the overwhelming majority of their income to put food on their tables so with respect to these three pointers not analysis doesn't apply i get the broader point though that the economy is certainly changing rapidly and there are lots of people even though it's not in the record here who are using as a side and perhaps the analysis would be different as to them but i i would note that since the roosevelt administration there's been lots of technological change and companies have been adjusting the contribution of labor into their workforce and the returns that come from labor we've gone through decades of that and so it's easy to fall in the trap of thinking we're in this great technological moment and so much is happening now and so perhaps we need new rules of law in order to address th situation that technology has been changing for a long time and to the extent that there is a policy reason to treat bigger economy as different from every other business that has been technologically adjusting for the last seventy years that's something that's better taken up with an article one solution as opposed to a market threat or but my question really isn't good to technology it goes to subjective expectations and understanding of what the relationship is ordinarily you look to a contract to see what the subject of understanding is are but if the but if both parties go into this relationship with a with a different understanding then the meat miners or the pickle pickers had should that be relevant i don't think that there's any precedent saying that's not subjective understanding of the parties  something that should not more weight the parties may well want by contract and no amount of time we don't really want to talk about the subject of understanding even if we simply looked at the contract they're doing i think that the contract manifests the objective understanding based on the written text but my point was going to be that you know the reason the minimum wage exists is to provide a better level of england's it were that's a policy argument as well i would like to know as a matter of economic reality how any entrepreneur can craft a business model upon which he can have some measure of confidence going forward if these cases are going to be decided based upon the subjective expectations of various workers out there were individuals providing these services one person being a part timer who's going to school another who has no other opportunities available and is trying to make a full time occupation out of this how can the business owner craft a business model that is in any way  possible presenting possible expectations for him if there is that much variance if you're honest question is also a good one and indeed when we're operating in the realm of standards as opposed to bright line rules there's going to be a zone of uncertainty and that means both sides are taking some risk but let me make it very concrete in this case we work and have a very different business model that we're drilling question a lot of control and still add value in the marketplace for example you c on to the app and get to choose your riders and see the different star ratings and rider that has a cleaner car and a better history and more positive reviews or you know there's more to go where you're taking your you would know exactly where you're taking him and you'd be able to connect directly with the writer