three issues to the court and i'm happy to answer any questions about any of those issues but i'd like to focus on one of the issues which is the grant of summary judgment on the merits as to the applicability of your law one hundred and seventy three district court held that essentially it didn't make much difference whether michigan law or dominican republic law applied because in the court you are law one hundred and seventy three dollars would not apply because of the effect of a subsequent trade agreement after the date of entry into force the agreement that it will continue to apply to a covered contract signed after the date of entry into force of the agreement and the term cover contract is very important here that the not say contract it says covered contract it's a defined term within the aircraft and the defined term covered contract refers back to the definition in d r law one seventy three that definition is a very very broad definition it says that it actually doesn't talk about a covered contract or concession contract which are the terms used  it refers to license agreement and it defines that as any form of established relations between licensee and license or so it's it's understood to be much broader than a single or even a written contract not even to require written contract but you talk about the nature of the relationship and when it was a stout wished and i think that's a very important point here because in this case we haven't established relationship no dispute there was an established relationship that existed prior to the aircraft we have written contracts also signed prior to the aircraft reflecting that established relationship you know you can also g assessment that's correct well that's that's true now the the point is though that i think that's exactly what d'yer law one hundred and seventy three dollars contemplates is that you would continue to have this relationship it might be established through contract rules or new contracts but it's the establishment of the relations between the parties and when that occurred that matters not any particular contract when that particular contract was entered into that's an a foreign language that we you know have to try and figure out so but i think the fact that it defined license agreement so broadly is is the answer we have to look to the plain language of that act and it says any form of the damage relations had they intended to limit it to contract or talk about when contracts were entered into or when they were renewed it could have done so and it didn't and it also makes it very clear that at no time once there's an established relation can a supplier terminate or not renew the relationship it is intended to be in perpetuity because what's intended to be protected here is the interest of the dealer having invested and made efforts to build this business and to you know connect with these customers and that's what the dominican republic was trying to protect so it wouldn't make sense to say well five years then you could sign a new contract and then you could just terminate that and that would be fine so i think retroactive and the definition back in d r law when seventy three didn't use their own definition it used the r one seventy three dollars and that definition is so broad and it focuses on the establishment of the relationship which again was supposed to protect the dominican republic dealer from having this cut off after having spent money and time and effort in building this business so i think that's what's really important here now i acknowledge that your character does say sign and  that's very confusing because you know they decided then they go back and define it cover contract in a way that doesn't really mean written contract or signed contract and that's problematic but i think in light of the fact that they use that year law and seventy three definition i think in light of the fact that it's clearly intended not to go back and disrupt the relationship that existed prior to the aircraft or which in this case had existed for years i think it should be understood to mean because systems with the with the definition of covered contract which is establish relations and not simply a single contract or even a written contract and i point out again we do have signed contracts from prior to between these parties so i think that's important you know and it's also important to remember that as to yachts came to the dominican republic and subjected itself to this law at a time when the aircraft was not in place and perhaps not that language in their contracts again you know had the our camp to intended to say that if you enter into a renewal or a new contract had it intended to make that clear it could have done so it could have simply used the term contract but it did not use the term covered contract made it fine term refers to the definition however who were going to go that route the if the contract said you know we're going to not apply law one hundred and seventy three you would still apply law one hundred and seventy three so that's a public policy now they did entered into de aircraft in two thousand and seven but again they made it clear i think that they wanted that to apply prospectively only and not affect prior established relations again by using that definition that refers back to the our law one hundred and seventy three rather than a different definition that would have indicated that you could enter new hand tracks even though you have established relations and thereby cut off your law one hundred and seventy three so i think thing that those let that language superseded cuts it off is really if there is a dispute about performance under those contracts clearly the parties would look to those most recent agreements to say if your seller required number of products did you have the right dollar value pulling none of the parties would soundtracks superseded all prior agreements between th these questions and does the district court correctly applied but lot in rendering its decision i would also note that there are some other arguments that the council hasn't addressed regarding a court's seventy three are says the are cast if you if you need all of the facts relevant to that analysis then decided and harmed by the court there's nothing left for the other trial that could potentially impact on this particular issue it's separate and distinct it went through the relevant factors and not exercising its discretion to certify this if you i don't think there's any debate about that and we believe properly before the court so i would simply urge your honour's to look at d r cast an honest face that says what it says if they wanted to grandfather prior that the parties specifically selected michigan and whether it's federal or state court as the proper form that wasn't something that had started at the very beginning of their relationship so let was not a a a new fine print that she lived in at the end that was something that was an inherent part of the party's relationship from the very beginning i would also no junkers certified the ruling or the partial judgment pursuant to rule fifty four b how do we have jurisdiction over the form order based upon the certification under fifty four  exercised your stiction in the st place and i think it comes down to an issue of it's not subject matter jurisdiction but it really comes down to the fundamental question of whether or not the district court has any business opening its filing proceeding in the case or whether it you have a sting that's an issue again which is an abuse of discretion question and the court went through its analysis underbrush heart and other  bstention cases looked at each of the factors and determined that it was appropriate for the federal district court to take the matter on and proceed want to mention the dominican republic case the trial court did hold that the dominican republic did not have jurisdiction in the michigan had jurisdiction that he sit on appeal pending right now no decision yet and if there is a heavily on its conclusion that the our law one hundred and seventy three would not apply and therefore the dominican republic did not have a material interested in applying its law and or the law did not significantly differ from michigan law and you know as i discussed in the in the st argument i think that was an incorrect conclusion and i think if that conclusion had been different it would have certainly affected the court's weighing of those factors and so if that conclusion is wrong then those factors might not have been assessed correctly as far as judge reference question about the jurisdiction with certification of a higher form order i don't believe that question has actually been addressed in this circuit but i did cite a case from the th circuit the o'brien case d o'brien versus o'brien and associates that basically said when a court certifies an order as a final order the court should have jurisdiction to review all of the orders that led up to the entry of that final order i don't say that the court should have jurisdiction to assess all of the orders entered in the case but if the court does not have jurisdiction to assess the entry  order that relates to entry of the final order then it would never have jurisdiction and it would never be able to be assessed because this is now a final order and it has to be decided now so the issue of form one convenience  applies to any form of establish relations it's such a broad definition it's clearly not related to a single contract it doesn't even necessarily require it written contract and because the are law applied here twe consistent with its use of term covered contract that's all that i have to say on those topics of the court has any questions i'm happy to answer them i have not i think we've exhausted our questions