PROMOTING TRANSPARENCY:

Nasdaq Market
Data Proposals

N as d a q G l o b a l In fo r m a t i o n Se r vi ces

In 2005, in response to changing market dynamics
and technology advancements, the Securities andExchange Commission made major changes to the1970s-era investor-protection rules that knit U.S.
stock exchanges into a National Market System.
Oliver Albers,
Head of Global Partnerships,
Nasdaq Global Information Services

This year, as one of several announced roundtables,
the SEC is convening a discussion to consider the
impact of technological advances in more recent
years, with a focus on equity market access andmarket data.
While Nasdaq recognizes the SEC has other, urgent priorities—such as
standards for investment advisers, fixed-income market reform, andtreatment of new asset classes such as cryptocurrencies—we welcome
the thoughtful discourse on exchange market data being convened byregulators in coordination with market participants and the investing
public. Nasdaq operates the world’s second-largest stock exchange and is
the global pioneer in using technology to strengthen and expand accessto the equity markets both for companies and investors.
Beyond our heritage of technological innovation, Nasdaq is sensitive tothe responsibilities of regulated exchanges. Exchanges are the neutral
meeting grounds, trusted by participants for establishing fair, safe,
efficient, transparent, and reliable markets. Exchanges provide constantand proven surveillance against fraud and abuse—and are essential
guarantors of the public confidence that makes U.S. capital markets theenvy of the world.
To be sure, there remains room for improvement, and Nasdaq is gratefulfor the opportunity to participate in this discussion. This document
offers a summary of Nasdaq’s perspective and our proposed reforms foraddressing important issues raised by market participants as it relates
to the governance and regulatory framework for the consolidated data
feeds, commonly called the “SIP feeds” or the “consolidated tape.” Our

NASDAQ GLOBAL INFORMATION SERVICES

proposed enhancements to that framework build on our 2017 Blueprint to Revitalize Capital Markets, whichembraces the role of the U.S. equities market as a fundamental engine of innovation, economic growth, andprosperity, and lays out a vision to create a healthier environment for more companies to access the publicmarkets and improve trading activity.1
Our vision for the U.S. market data future covers

Our conclusion is that such tectonic changes tothree areas:

U.S. equity market infrastructure would raise risky• Enhancing stakeholder participation in
SIP governance• Encouraging better price discovery via
the consolidated feeds• Clarifying the Vendor Display Rule tooperational complexities, legal and regulatory
questions, and possible unintended consequences—with little upside. Those who would fundamentally
alter our national system must also ensure that suchalterations would not produce perverse outcomes or
be harmful to investors.

give broker-dealers clarity, choice, andSpecifically, while any consortium-led constructflexibility on their use of SIP feeds

introduces complexity in governance andand alternative data products

management, there are fundamental benefits thatmarket participants and investors receive from

Our analysis finds that the regulatory scheme forhaving a single-source-of-truth for core best-quote

U.S. stock market data—both consolidated feeds

and trade data coming from the intricately networked

and proprietary feeds—is currently accomplishingand fragmented U.S. equity market ecosystem thatits primary goals: It produces a reliable, industry-

the SEC created with Regulation NMS. Given thestandard reference price for every stock at low

routing obligations that Regulation NMS establishes,or no cost to retail investors, while encouraging

it is critical to have a single source of data to serve as

innovation and competition among exchanges andthe regulatory basis of broker-dealer and exchange

market participants. It also has been a catalyst for arouting obligations. This system ensures an investor

flourishing and innovative market data industry thatcan be confident that her order will automaticallyprovides more choice and value every day to theroute to the venue with the best quoted price based

retail and institutional investor alike. The reforms

on the SIP feed. This is a critical element of creating

proposed by Nasdaq would enhance the current

a sense of fairness and confidence in the U.S.

system and strengthen the quality of markets for thecapital markets. We respectfully suggest that before

investing public, while continuing to foster innovation

proposing changes to today’s regulated market dataand competition among market participants.

model, it is incumbent upon the SEC to consider theThis document also addresses the broader
question of whether we should embark upon more
foundational changes to the SIPs (CTA, CQ, andUTP plans) themselves—such as either eliminatingthem altogether or proliferating them through a“distributed SIP” or “multiple competing SIPs.”

significant potential consequences and risks to thebroader capital markets ecosystem that has beencreated through Regulation NMS.
With that in mind, Nasdaq is proposing some importantbut measured modifications to the construct thatexists today, founded on the principles and context
laid out below.

Nasdaq, “The Promise of Market Reform: Reigniting America’s Economic Engine” (2018), available at https://business.nasdaq.com/media/Nasdaq_
Blueprint_to_Revitalize_Capital_Markets_April_2018_tcm5044-43175.pdf.

13

Principles
In recent remarks on market structure and market data, the SEC’schairman and the head of its Division of Trading and Markets
reaffirmed key principles that should be preserved and protected
when contemplating changes to the regulatory apparatus governing the
National Market System.
Among these principles are ensuring fair, orderly, and efficient markets;
focusing on the long-term interests of retail investors; leveraging
transparency to energize competitive forces that are more productive
than prescriptive regulations; and taking a holistic and collaborative
approach to the market structure discussion.
We strongly endorse these principles. As a self-regulatory organization,
or SRO, Nasdaq has an essential role in ensuring fair and orderly
securities markets and in protecting the interests of investors. The
strength of our exchange depends on our ability to serve all sides of themarket as a fair and honest market steward. Core to Nasdaq’s missionis the belief that markets are stronger when they are transparent andcreate a level playing field for investors.
To the list of principles enumerated by SEC leadership in the context of
this discussion, we would respectfully add one more issue that is criticalto any discussion about market structure and market data: Our financial
system is stronger when our exchanges are vibrant, when competition
between and among exchanges and other financial information
providers is robust, and when more trading happens in public rather
than in “dark” venues, where investors do not benefit from proper pricediscovery.2

As former SEC Chair Mary Jo White said in 2015, “Transparency has long been the hallmark of the
U.S. securities markets, and I have been concerned by the lack of it in these dark venues.” See Kevin
Dugan, “SEC chief takes aim at predatory traders in ‘dark pools,’” New York Post, March 25, 2015,
available at https://nypost.com/2015/03/25/sec-chief-takes-aim-at-predatory-traders-in-dark-pools/.

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NASDAQ GLOBAL INFORMATION SERVICES

The Role of Vibrant
Exchanges in the
U.S. Equity Markets
Beyond bringing buyers and sellers together,exchanges in the U.S. stock market perform a variety
of other publicly valuable functions. Market structurereforms should be careful to preserve or enhancethese benefits to the investing public.

in our market system as a core element of our freemarket society. These benefits are critical to thesuccess of our economy, and therefore underpin theneed for the U.S. stock exchanges to be fundamentallysound and strong. Strong exchanges in a competitivemarket invest more in functionality, resilience, andsecurity to give investors fairer and faster access tothe market, resulting in greater confidence and moreaccurate price discovery. Strong exchanges invest ininnovations that enhance trading efficiencies, help

Exchanges bring issuers to investors and police

drive down retail investor costs, democratize market

markets for manipulation. They incentivize market

access, and enable more accurate price discovery.

makers to provide continuous two-sided quotes

Strong exchanges invent and deploy sophisticatedso that investors have constant access to liquidity,

electronic surveillance tools that uncover market

which, in turn, provides a transparent market withabuse and manipulation. Strong exchanges integrate

tight spreads and a detailed record of trades. The U.S.

the latest and best security capabilities to create asystem of an interlinked network of actionable quotes

safe and secure trading experience.

ensures buyers and sellers trade at the best prices
available—and it creates benchmarks for all othertrades, including those that take place off-exchange.

Robust and effective regulation by exchanges has
been proven to play a crucial role in the creationand distribution of safe and reliable market data.

Exchanges also provide independent official market

The number-one job for Nasdaq and other SROs

opening and closing auctions, which are importantis maintaining fair and orderly securities markets

events that allow ETFs, mutual funds, and otherand protecting the interests of investors, including

investment instruments to thrive by trading large

enforcing compliance with the Exchange Act by ouramounts of stock with minimal impact on the market

broker-dealer members and listed companies.

in a transparent, safe, and efficient way. Closing
prices are widely used as benchmarks throughout theindustry. The market close therefore draws liquidity
across the entire market ecosystem, driven in partby growth in passive funds that seek to align theirperformance with the underlying index they aim
to match. Exchanges advertise imbalances between
supply and demand at the close to encourage
investors to correct the imbalance and improve true
price discovery.

Nasdaq directly invests millions of dollars each year
to meet and exceed these responsibilities. Currently,
Nasdaq technology runs dozens of algorithms acrossservers that process more than 4 billion messages per
day to detect potential market abuse or manipulation.
Nasdaq also employs a large team of analysts who
dissect the information that emanates from ourtechnology to identify and eliminate market fraud.
The initial listing and continued listing functions
are similarly characterized by constant exchange

The benefits that exchanges bring to the equity

monitoring and surveillance using innovative, often

capital markets greatly reduce transaction costs for

proprietary technology. The end result of this careful

investors, lower the cost of capital, and enable growthmonitoring and regulation are quotes and trades thatfor the thousands of companies that underpin ourinvestors can safely rely on when making crucial

economy. Most importantly, they create confidence

investment decisions. Nasdaq’s self-regulatory5

functions are critical; if SROs did not perform them,data makes accurate price discovery possible. The

then the SEC would be forced to hire hundreds of new

digitization of market data enables self-service

staff to replace them to continue protecting investors.

online trading that has empowered hundreds of

Ultimately, vibrant exchanges are essential tomillions of retail investors and slashed transaction

maintaining and increasing public confidence in the
U.S. capital markets, making them the most trusted
and accessible in the world. Today, the United States
has a multiplicity and growing number of licensed
exchanges—more than any other major economy—
which promotes competition and innovation. As we
consider reforms to the rules that address market
structure and market data, we should proceed witha shared goal of strengthening U.S. exchanges andpreserving their competitive incentives to improve,fees to historical lows. The engineering of market
data powers investment vehicles such as ETFs thatfurther drive down retail costs and drive up market
access and investments. The merging of market datawith other datasets enables and inspires innovative
startups around the world. The mining of market data
produces insights for investors and intelligence forregulators. And the consolidation of core market data
via the SIPs allows the United States to combine thestability of a national market with the dynamism of aadapt, and innovate in ways that help the investor

competitive one.

and the economy. This is a goal of many other

Moreover, these uses of market data would be

advanced economies around the world.

inconceivable in the absence of efficient, reliable
stock exchanges, the most successful of which

Market Data in Context
A simplistic view of exchange market data defines
it merely as the collection of buy and sell orders
communicated on stock-trading platforms bymarket participants.

make constant investments in data-processing
infrastructure, cybersecurity, and fraud prevention,and new services and products that attract and retain
market participants in an intensely competitive
business. In this light, market data is not properly
understood as a raw material, but as a value-added

But that daily collection of billions of individual

product resulting from decades of refinement anddata points is also the essential fuel for the entire

from billions in investment and innovation across themarket. The efficient, systematic processing of market

capital markets ecosystem.

NASDAQ GLOBAL INFORMATION SERVICESLike all structured data in the age of the internet,

declined over the past 10 years, while total SIP

Big Data, and AI, the rise in value of market data

revenue has stayed flat (revenue to off-exchange

has accelerated in recent years. Market participants

trading venues, notably large banks and electronic

clamor for more inputs, more efficient delivery, andbrokers, has increased).3 Flat revenue has come evensmarter versions to provide ways to reduce theiras exchanges have invested millions in technology

risk or compete more effectively. In addition to theand cybersecurity improvements in the SIPs tocore quotation and trade data that are fed into theprovide the data at ever-smaller fractions of aconsolidated SIP “tapes,” exchanges and securities

millisecond and increase overall market resiliency.

industry participants—as well as other financial

Meanwhile, the landscape for proprietary market

information companies—have developed proprietarydata is so intensely competitive that Nasdaq isdata businesses that produce myriad other data-

reducing fees on products, especially those geared

based products. The proprietary data sector istoward retail investors.4

intensely competitive and incentivizes companies to

The persistent affordability of market data comes asderive new, more useful, and more affordable ways
to present market data to their customers.

companies and consumers are spending much moreon other data and information services, driven by

Despite this acceleration in market data’s value

cybersecurity and infrastructure imperatives. Overall

and utility, it remains remarkably and persistently

corporate-sector costs associated with cybersecurity

affordable. The vast majority of retail investors canhave doubled since 2009. Corporate IT costs are

get core market data from the SIPs in real time as

expected to reach $3.7 trillion in 2018, an increase ofpart of the low-cost service they get from an online

6.2 percent from 2017.5

brokerage account or financial app. Meanwhile,

This analysis suggests that the current market for U.S.

the competitive proprietary data market (which,depending on product, offers data feeds that canbe more limited or even more comprehensive than
SIP data, depending on investor needs) produces
additional value and choice.

stock market data is efficient and competitive. That
does not lead us to conclude it is perfect, however,and Nasdaq appreciates that in a data-driven
economy, companies are naturally scrutinizing alldata costs and looking for efficiencies.

With innovation and competition, the share ofrevenue that exchanges derive from the SIPs has

In 2018, the UTP and CTA published trade and quote revenue distributed to participants for Tapes A, B and C, beginning in 2007. This data shows thegeneral growth of revenue associated with off-exchange trading. This growth is more pronounced when former alternative trading systems, or ATSs,
that later became exchanges are removed from the calculation. This variance results from the inclusion of ATSs in the 2007 data that have since become
exchanges and are categorized as such in the later data sets. See UTP Plan Administration, “2018–Q1” (2018), available at http://utpplan.com/DOC/
UTP_Revenue_Disclosure.pdf; New York Stock Exchange, “Consolidated Tape Association” (n.d.), available at https://www.nyse.com/publicdocs/ctaplan/
notifications/trader-update/Q1%202018%20CTA%20Financial%20Disclosure.pdf.

3

In 2016, Nasdaq lowered the price of Nasdaq Basic Enterprise Cap. Nasdaq Basic has saved the industry $202 million since its 2009 launch and is
projected to save the industry $242 million by the end of 2018. For many market participants, this proprietary data is a valuable substitute for more
expensive, consolidated offerings. Moreover, Nasdaq Basic provides customers with more choices in circumstances where they determine that they do notneed more data.

4

Gartner, “Gartner Says Global IT Spending to Reach $3.7 Trillion in 2018,” Press Release, January 16, 2018, available at https://www.gartner.com/
newsroom/id/3845563.

57

Policy Reforms to Improve
the Market Data Ecosystem
Nasdaq recommends that a stakeholder conversation about market data
explore three areas for reform:
ENHANCE MULTI-STAKEHOLDER PARTICIPATION IN SIPS GOVERNANCE
Nasdaq shares the securities industry’s view that the SIPs are a public
good and should be governed through a partnership between theexchanges and the industry, with appropriate government oversight andextensive public transparency. To that end, we recommend building on
the transparency advances of recent years and expanding the authority
and responsibilities of the advisory committees, particularly on fee andpolicy-related matters.6
The Securities Information Processors, or SIPs, are entities mandated
by the government with collecting and disseminating consolidated coremarket data feeds—thus allowing investors to see the National Best Bid
and Offer prices of any stock at any time, regardless of the exchange on
which it is being traded.
Under the current governance structure, the SIPs are operated by acommittee of SROs, which are intensely regulated by the SEC, that
contribute their data into the public data feeds. These operating
committees are, in turn, advised by advisory committees composed ofother securities industry stakeholders. The operating committees andadvisory committees meet quarterly with the SEC, which exercises
oversight authority over the SIPs. The SEC reviews for consistency withexisting law the rationale for any new data product or fee increase.
When the SIPs were established, an important rationale for limiting
operating responsibility to self-regulatory organizations was to focus
SIPs on the SROs’ statutory obligation to create a fair marketplace. A
stakeholder who was a “consumer” of market data and not a “provider”
of it might be less focused on or less aware of the need to invest in theinfrastructure, oversight, and surveillance that creates the high-quality
market data product than would an exchange, given the heightened legal
obligations borne by SROs to maintain a fair and efficient market.

Among SIP transparency advances in recent years has been the transfer of almost all governanceitems into the general operating committee session, publishing an easy-to-read Reg NMS formula
document, adding three advisors to the now-11-member SIP Advisory Committee, reducing
confidential treatment of SIP governance documents, publishing minutes on the open website,
increasing visibility into latency figures, and publishing the executive committee agenda.

6

NASDAQ GLOBAL INFORMATION SERVICES

But given that the operating committee sets the• The general investing public should

revenues, fees, and investments made by the SIPs,

also have a voice on the advisory

it has naturally long been a goal of certain broker-

committees, as the SIPs are designed

dealers, asset managers, and other securities industry
professionals to have a more prominent voice in thosefor public benefit.

decisions—although it should be kept in mind that the

Nasdaq would also welcome a conversation

SEC, representing the public, is always present andabout how to increase public transparency of SIP

must approve all major actions of the SIPs.

operations, including requiring more public visibility

Nasdaq believes an enhanced SIP governancemodel should be developed in consultation with all
stakeholders and the SEC, and should adhere to thefollowing principles:• SIP governance should be structured

into general session meetings of the operating
committees—and continuing to limit time spent inexecutive session.
ENCOURAGE BETTER PRICE DISCOVERY
VIA MARKET DATA FEEDS

in a way that reflects a true public

Under the current SIP system, equity exchanges andinterest partnership between

other trading platforms provide quote and tradeexchanges and the industry, whiledata to the SIPs, which turn them into consolidated

also reflecting the differing legal

feeds of stock market activity. Market participants

obligations among market participants.
• Increased authority for the advisorycommittees should be coupled with

pay a subscription fee to access to the feeds. The
subscription fees pay for the operation of the
SIPs, and any leftover funds are distributed to theparticipants according to a revenue formula that

increased obligations to promote

proportionately allocates revenue based on the

public transparency.

quotes and trades each exchange or platform reports.

• Expanding the powers of the advisory

The SIP revenue formula presents a policy

committees could magnify potential

opportunity to incentivize the improvement of public

conflicts of interest among advisory

quotes and hold all trading platforms accountable forcommittee members, so those conflicts

best execution, whether they are “lit” or “dark.”need to be acknowledged

Quotes on public, or “lit,” exchanges form theand mitigated.

benchmarks for ETFs and mutual funds that account– For example, market participantsthat operate their own “dark pools”
are simultaneously SIP customers
and SIP revenue recipients, as wellas SRO competitors, complicating
their interests.

for the clear majority of activity by retail investors
and managers of passively managed products, aswell as the reference prices from which derivatives
compute their value. Best execution of “lit” quotes
is the most transparent form of price discovery andsaves investors from trade-throughs. If the goal of
the consolidated feed is to improve the quality of9the market, then the revenue formula should aim to

Before 2015, industry participants had a very good

improve the quality of quotes on public exchanges,

general understanding of the Vendor Display Rule

where available liquidity is always on display.

and how to apply it. That year, a no-action letter was

Policymakers and stakeholders today should consider

issued by the SEC in response to a question fromanew how to allocate SIP revenues in a way thatstrengthens “lit” quotes and rewards behavior that
increases market quality, tightens spreads, deepens

BATS Global Markets. Specifically, this new guidanceraised more questions than it answered because it
referred to the rule covering circumstances where aquotes, and holds accountable for best execution the

trading decision is “made” rather than “implemented.”8nearly 40 percent of trades that occur off-exchange.7

While it is obviously a matter of significant public

CLARIFY THE VENDOR DISPLAY RULE TO
GIVE BROKER-DEALERS CLARITY, CHOICE,AND FLEXIBILITY ON THEIR USE OF SIPS AND
ALTERNATIVE DATA PRODUCTS
While this may seem an arcane and technicalquestion, it has significant implications for themarket data discussion. Clarity on this rule could
reduce even further the already-low market data
costs for retail brokerages.
The Vendor Display Rule is shorthand for a provision
in SEC regulations that requires broker-dealers
to show the “consolidated display” of a stock toinvestors, in a “context in which a trading … decision
can be implemented.” Effectively, it means brokerdealers must display SIPs data to an investor—rather
than data from a single exchange such as Nasdaq or
NYSE—in circumstances covered by the rule.

interest for broker-dealers to execute a customer’s
trade request at the national best price using SIP dataas the most reliable reference point, it is not at all
self-evident that the investor’s interest is harmed bydisplaying quotes from a single large exchange when
she is merely contemplating a trade or assessing themarket. Indeed, the investor’s interests may well beadvanced by making it clear that his broker-dealer
has flexibility to choose lower-cost proprietary
market data products in that assessment context.
The forthcoming market data discussion convenedby the SEC is a welcome opportunity to provide theindustry with additional clarity about the Vendor
Display Rule. We might also take up the related but
broader question about whether “display” of SIP
data is still something that needs to be regulated orwhether the public interest is sufficiently served byrequiring that trades are executed using SIP data as
the reference price.

Off-exchange dark trading has increased by roughly 82 percent between January 2007 and January 2018. Nearly 40 percent of U.S. equity trading
volume today takes place in off-exchange venues

7

To understand why, consider the analogy to a car-buying transaction. A consumer can “make a decision” to buy a car after seeing a TV advertisement,
but she does not actually “implement the decision” until the point of sale. In the car-buying context, consumer protection rules are more rigorous at the
dealership than on television because regulators recognize a clear distinction between the two scenarios. Similar clarity would be welcome in the context
of the Vendor Display Rule.

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NASDAQ GLOBAL INFORMATION SERVICES

Conclusion
As we can see from the above discussion, aThis anomaly naturally creates interest among

conversation in the United States about the

stakeholders to critique the foundational structure of

regulation of stock market data—and access to that

the SIPs. From time to time, market participants will

data—naturally tends to discussion of the Securities

question whether we need the SIPs at all—or whether

Information Processors.

there should be many more of them competing withOn the one hand, U.S. financial markets are envied

one another.

around the world for their ability to instantly andWe expect the roundtable convened by the SEC toreliably generate a “best price” for any stock at any

again surface these critiques and broad questions. And

time, while allowing for competition among exchanges

while we agree with stakeholders that foundational

and all the benefits that competition creates:

questions about the SIPs are important andefficiency, service, value, innovation. That’s a win-win

worthwhile topics of discussion, we believe raisingfor investors and for the U.S. economy, which also

them also raises the risk of distracting and derailing abenefits from the public confidence and institutional

more focused and more productive conversation.

integrity that the SIPs engender. The SIPs are avaluable part of our equity market infrastructure anddeserve to be preserved and strengthened.

For example, the idea of a “distributed” SIP or
multiple competing SIPs would introduce new
operational complexities, legal and regulatory

On the other hand, the SIPs are an anomaly inquestions, and possible unintended consequences—that they are government-mandated entities thateven as it is unclear that competing SIPs would

convene competing private entities into collectives

satisfactorily resolve concerns about issues such asthat set prices for a government-mandated product:

geographic latency. (For example, at any point inconsolidated core market data.

time, the National Best Bid and Offer snapshot fora stock could differ among distributed SIPs because
the data still has to travel from exchanges, which arethemselves not individually “distributed.”)11

The contemporaneous debate about the SEC’s

potential unintended consequences to investors andproposed Transaction Fee Pilot provides a timely

the markets and whether the proposal is a pretext

cautionary tale about embarking on a reform pathfor other commercial motivations. At a minimum, we

without clearly establishing that there is actuallyshould not subject investors and the capital markets

a problem to fix or establishing that the existing

to multiple risky experiments simultaneously.

infrastructure is insufficient to fix the problem. This

Ultimately, our analysis suggests that the regulatory

market-altering “pilot,” which is, in fact, a real-time
experiment on the critical infrastructure of the U.S.
economy, risks undermining the public reference priceand harming public companies and their investors—all
in a manner that is potentially contrary to statutory
norms—and in pursuit of a solution to a problem thathas not been established.

scheme for U.S. stock market data is accomplishingits goals: It produces a reliable national reference
price for every stock at low or no cost to retailinvestors, while also providing the data at a very
reasonable cost to market participants. It encourages
innovation and competition among exchanges andmarket participants. And it allows for an innovative

With respect to structural experimentation with themarket data industry that provides even more choice

SIPs, we would urge the SEC to consider a distributedand value to the retail and specialist investor alike.

SIP using the same approach we have argued for theThose are the foundations of a healthy equities

Transaction Fee Pilot.9 In other words, the SEC shouldmarket, and they are the reason ours is the crownestablish whether investors or public companies arejewel of the global system. To be sure, there remains

actually harmed by any structural problem. Next,

room for improvement, and Nasdaq is grateful forit should exhaust existing tools before undertaking

the opportunity to suggest the above reforms and to

major changes—the SIPs, after all, have dramaticallyparticipate in the broader discussion.

increased processing speeds in recent years,
accomplishing in tens of microseconds what used totake several milliseconds. As important is exploring

Letter from Nasdaq to the Securities and Exchange Commission, May 25, 2018, available at https://www.sec.gov/comments/s7-05-18/s70518-3718533162485.pdf.

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