the united states and timely filed for asylum throughout the course of their immigration proceedings there was no doubt and the record fully supports the conclusion that petitioner suffered outrageous acts of violence evidence did the oral testimony that the documents presented compel the conclusion that petitioners were members of a social group by virtue of which they could seek protection in the united states and we urge the court to find that they were members of a social group this is the system in the soviet former soviet union is is is distinctly different that what we have in the united states i myself am a refugee i came here when i was five and i do know the persecution that we ran from in order to seek protection in the united states after the disintegration of the soviet union and the fall of communism what quickly transpired in russia was  russia there are reported killings of business persons of people who attempt to carve out their own ideology as i want to be a democrat i want to have a free economy i don't want to commit corruption i don't want to be motivated by greed i don't want to submit to my aggressors demands that i introduce them to my business partners and they be murdered i don't want to to to promote the small this i mean how do you  d you know would it be just rich people would it be you know that's i think that's the problem we're struggling with it's not like ok you're catholic it's not like if you're belong you belong to a group that you know a political group or something like that there's a you know it's part of who how do we know who these people are that i know that there's always some jeff we it's a little trickier thank you ron and yes i agree it is it is very tricky and i think that the in the sense of what we see in america as you know i went to school i did well and i'm a great business person and i'm a new entrepreneur or looking at it in the context of the government in the former soviet union we're looking at it in the context as individuals who want to practice the free market who want to practice open economy who who want to have negotiations who don't want to submit to oppressors demands and and i think when you look at a social group  it's inextricably intertwined with their political opinion i do not support corruption i will not proliferate your crimes i will not do this and as a basis and as as as as the reason for not doing this they are outrageously punished they are not murdered they are killed they are imprisoned and most of them flee to to seek protection from our government this case appears to be strange because here we have people from russia who believe in the free enterprise and the free enterprise system is not a social system it's a political system political belief just like  constitution i think on the days of the death of ronald reagan here we got the federal government wanted to export people who believe in the cup was just to back to russia absolutely on the argument that is before the ninth circuit and we believe that there is a basis to make an argument that there is that argument  and the asylum application which the petitioner submitted along with all of the other documentation of their beatings and their reports yes your honor they are in the record we are thank you address that issue first the quote inquired about the state department reports and where that would be found in the record page three fifty six administrative record in this case the court does address that specifically addresses the issue of criminal groups in overarching criminal organization and in russia this is not the case most organizations most mafias are local gangs concentrating in a few areas of criminal acquire their legal activities it goes on to state that we talked about the that businessmen small and large are targeted individuals who travel abroad individuals who have relatives abroad and i thought had access to foreign currency people planning to emigrate and therefore believe take cash from the sale of their privatized housing and it goes through an exhaust change the economic climate in russia they have been difficulties and the police have been overwhelmed it does speak to the fact that government actually that the criminal groupings in situations like this has increased if the government is addressing this issue secondly even with petitioners may have suffered this issue again the central issue is whether or not it can be doing that this is on the political opinion the state department report shows that individuals are being targeted not because of their political opinion but because of access to whether lays out these groups and individuals beyond this new business people who are suffering and maybe are they believe in this new capital system and these individuals who have been targeted because of their money in looking at several cases that this  where they have granted that economic persecution has been enough even in the case the petition to provide to the court today these are all issues in which there was some funny political opinion but that is not the issue here as the chairman by what has been written b for information on conditions in foreign nations and looking at that the state department report shows that they have not been targeted because of their political opinion i just see my time is ending so i will in summation one thing  also shows that while there has been some difficulty in the government spawning the government has allocation of resources are responding to that issue but secondly this is an issue in which it even based on and with the political opinion i would argue with respect to china don't think that is an issue if you look at the petitioners early admission first of all the petitioner businesspersons admitted that this is an issue in which timber is important but the issue is not political opinion but i desire to competition they also have admitted in the ministry of record that these individuals have no interest in the politics and actually found the ministry of record at page one forty eight and the petition also makes the same admission that  individuals have no interest in their political opinion and that is at page the ministry of record i believe one fourteen yes at one fourteen the with regard to the social group that is contrary it the initial attorney that represented the petitioners was later for other reasons disbarred and they sought the counsel of another attorney who in fact made it an issue he quoted in his reply brief to the board of immigration appeals the case of borgia which stands for the proposition that we will not submit to the aggressors demands that extortion plot but extortion based at least in part on the political opinion corrientes the necessary nexus to find that persecution resulted as the basis of a political opinion and that there should be some protection based on the integrated grounds that we have that argument was never addressed by the board they made a specific finding that we find that there were criminal organizations that targeted the and that members you know targeted our client our their response but that they are not in a social group they never approach the issue of well is there a political opinion what about the case of borgia so i believe it is properly and in front of the court and we have in our briefing at least attributed a portion of of of  of our argument to the fact that there is a political opinion that you can have a political if opinion claimed or can in a social group and that's really what this case is about and this is not a case of local gangs or mafia persecution this is a case of government persecution petitioner specifically recognized and their record points out of the fact that there were there were members of the k g b that she recognized when she was a when her son was assaulted they reported it numerous times to the authorities they were driven out of business their life was threatened the petitioner female lost her ability to conceive to conceive children after she had a miscarriage as as all of you judges have said this is truly a capitalist system this is a way of life and it's and we have to look at it not in the vacuum that it's been but but but as a global as a global issue thank you