# NS ATTORNEYS AT LAW



### December 9, 2015 Electronic Submission U.S
. Department ofTransportation Docket Operations Management System 1200 New Jersey Ave., S
.E. Washington D.C. 20590 Eckert Seamans Cherin & Mellott, LLC 1717 Pennsylvania Avenue, N.W. 12tl' Floor Washington, D.C. 20006 Ta 202 659 6600 FAX 202 659 6699 www.eckertseamans.com

Edward J. Longosz, II elongosz@eckertseamans.com Direct: (202) 659-6610



### RE: Petition of The Zurich Services Corporation for an Exemption Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 Dear Sir or Madam: Pursuan t to Section 333 ofthe FAA Modernization and Reform Act of2012 and 14 CFR Part 11, The Zurich Services Corporation (ZSC) hereby applies for an exemption from Federal Aviation Regulations permitting it to operate small unmanned aerial systems (UAS) for aerial data collection and research and development (R&D) purposes. ZSC requests that FAA review Zurich's application and grant the requested exemption authority on an expedited basis as the opera tions proposed herein differ in no material respect from those proposed in applications submitted by a variety ofinsurance providers and that the FAA has approved on a regular basis
. See, e.g. , 

### Exemption Nos
. 11367 to ADM Crop Risk Services; 11293 to Erie Insurance Group; 11 188 and 11175 to State Farm; 11273 to AIG; and 11309 and 11274 to USAA. ZSC is seeking authority to operate UAS for the following purposes:
• Aerial Data Collection- ZSC will utilize UAS for aerial data collection in support of its operations related to risk assessment, risk improvement, loss prevention, claim assessment surveys, and catastrophe response ofZSC's clients.
• Research and Development- ZSC will perform R&D activities to evaluate how UAS can be utilized as part ofZSC risk assessment activities, to better understand potential uses ofUAS across the many industries that our clients represent, and to better understand the risks of operating UAS in order to develop mitigation guidance. 

### Because ZSC's Petition for Exemption and Operations and Safety manual contain commercially sensitive information and operational data that ZSC would not disclose in theATTORNEYS AT LAW U.S. Department ofTransportation December 9, 2015 Page 2


### ordinary course ofbusiness, ZSC requests that its submissions in this docket be afforded confidential treatment pursuant to 14 CFR §11.35(b)
. Similarly, these documents contain operating conditions and procedures that are not available to the public and are thus protected from release under the Freedom oflnformation Act, 5 U.S .C. §552 et. seq., and any other requirements established by the FAA pursuant to Section 333 ofthe FAA Reform Act. ZSC's petition is organized as follows: 1. Description ofthe Petitioner 2. Types of Operations Proposed 3. Proposed UAS 4
. Relevant Statutory Authority 5. Application Information 6. Regulations From Which an Exemption is Requested 7
. Public Interest 8
. Operating Parameters 9. Federal Register Summary 10
. Conclusion 

### 1. The Petitioner The Zurich Services Corporation (ZSC) is an Illinois Company and a wholly owned subsidiary of Zurich Holding Company ofAmerica, Inc., a Delaware Corporation
. ZSC provides a number of services to the member companies ofZurich in North America (Zurich), to Zurich insureds, and to other third parties. These services include among other things underwriting risk assessments and postincident surveys and assessments. 2. Proposed UAS Operations
a. Operate UAS for R&D purposes at test sites owned or controlled by ZSC 

### ZSC is requesting an exemption pursuant to Section 333 to conduct research and development at ZSC owned or controlled facilities or property, and facilities owned by third party vendors
. The facilities are not open to the general public and access during UAS operations will be limited to those employees or contractors engaged in the development work itself. All UAS operations will occur outside ofcontrolled air space and will be conducted in accordance with all applicable federal aviation regulations and in accordance with any special conditions or limitations specific to ZSC's exemption
. The testing proposed above will allow ZSC:
• to identify the best and most appropriate uses ofUAS technology;

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• to refine its understanding ofthe data it is able to capture by a UAS; U.S. Department ofTransportation December 9, 2015 Page 3

• to identify operational environments where the sensing technology is most effective (e.g. , how do the sensors perform over different type ofpaved surfaces) ; • to refine ZSC's UAS operational procedures; b. Operate UAS in connection with ZSC's various risk assessment, risk management, and loss prevention surveys, and related claim assessment activities 

### As a leading provider ofproperty and casualty related insurance, Zurich constantly seeks to understand the causes and effects ofaccidents and losses in the market place. ZSC regularly conducts risk assessments and risk improvement surveys and uses that information to advise Zurich's policyholders on best practices and suggest various safety improvements. ZSC intends to use UAS to perform a number ofthese risk assessment and improvement surveys since the subjects are often large areas (e
.g. , roof surveys, walking and surface areas, including sidewalks, lobbies, parking areas, construction sites, etc.) best observed from an aerial perspective. Use ofUASs will be less costly and safer than employing the use ofa full-size rotorcraft and ZSC's research activities will identify how to best utilize UASs in context ofrisk assessment and improvement survey work
. It 

### will be ZSC policy and practice to operate UASs in connection with these risk surveys only after obtaining written permission from the relevant policyholder(s) and in accordance with all FAA regulations governing UAS operations and the conditions and limitations specific to ZSC's exemption authority
. 3. Proposed 

### UAS ZSC proposes to conduct its operations with DJI Phantom 3 Pro and DJI Inspire 1 UAS
. As FAA is aware, thousands ofDJI UAS are in use throughout the United States and DJI's UAS are among the safest and highly-automated aircraft currently available
. The DJI Phantom 3 Pro is a lightweight multi-rotor copter weighing less than 3 lbs. that will be operated at a maximum speed ofless than 40 mph. The DJI Phantom 3 Pro has numerous features to ensure safe flight operations including pre-programmed operating modes that can limit altitude and speed, and provide geo-fencing to ensure flight opera tions are conducted within safe parameters. Iflost link occurs between the controller and the UAS, the DJI Phantom 3 Pro's Failsafe and Return

-to-Home features will activate and return to the take-off point. The DJI Inspire 1 is a lightweight multi-rotor copter weighing less than 7 lbs. that will be operated a t a maximum speed ofless than 40 mph. Similar to the Phantom 3 Pro, the Inspire 1 also has features to ensure safe operations including Failsafe and Return-to-Home features in the event oflost link from the controller to the UAS.

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### 4. Relevant Statutory Authority and Precedent U.S. Department ofTransportation December 9, 20 15 Page 4



### This petition for exemption is submitted in accordance with Section 3 3 3 ofthe FAA Modernization and Ref orm Act of2012. Section 333 directs the Secretary ofTransportation to consider whether certain UASs may operate safely in the National Airspace System before completion ofthe rulemaking required under section 332 ofthe FMRA
. The Secretary is required to determine which types ofUASs do not create a hazard to users ofthe NAS or the public or pose a threat to national security in light ofthe UASs ' size, weight, speed and operational capability and whether operations will occur near airports or populated areas and within the visual line of sight ofthe operator. The FMRA illustrates Congress' s intent to have the FAA issue exemptions and allow civil UASs, so long as they operate within the necessary safety parameters. In addition, the Federal Aviation Act expressly grants the FAA the authority to issue exemptions
. This statutory authority by its terms includes exempting civil aircraft, as the term is defined under §40101 ofthe act which includes UAS , from the requirement that all civil aircraft have a current airworthiness certificate
. The administrator may grant an exemption from a requirement ofa regulation prescribed under §§44701(a) or (b) or in §§44702-44716 of the act ifthe Administrator finds the exemption is in the public interest. Finally, the FAA has issued exemptions authorizing the use of small UAS for aerial data collection in support of similar inspection and surveying activities
. 

### See, e.g, Exemption No. 11273, Docket No. FAA-2014-0913 (authorizing AIG's use ofUAS for insurance underwriting and inspection purposes); Exemption No
. 11293, Docket No. FAA-2014-0692 (authorizing Erie Insurance's proposal to operate UAS in connection with its insurance underwriting and claims adjustment business). 5. Applicant Information The Name and Address ofthe applicant is: The Zurich Services Corporation 1400 American Lane Schaumburg, Il 60196 E-Mail : Jon
.Tate @ZurichNA.com Telephone : + 847-605-7533 Fax: +847-413-5407 6. Regulations from which exemptions are requested.
a. 14 C.F.R. Part 21, Subpart H: Airwmihiness Certificates and 14 C.F.R § 91.203U.S. Department ofTransportation December 9, 20 15 Page 5 ATTORNEYS AT LAW
b. 14 C.F.R §§ 45.23(b), 45,27(a) , 91.9(c) : Aircraft Marking and Identification Requirements
c. 14 C.F
.R. 61.113: Private Pilot Privileges and Limitations: Pilot In Command. d
. 14 C
.P .R § 91.9(b)(2): Civil Aircraft Flight Manual In The Aircraft
e. 14 C.P
.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration f
. 14 C.P
.R 91.7(a): Civil Aircraft Airworthiness g. 14 C.P.R 91.109(a) : Flightlnstruction h
. 14 C.P
.R.§ 91.119: Minimum Safe Altitudes
1. 14 C. P.R.§ 91.121: Altimeter Settings j. 14 C.P.R. § 91.151(a): Fuel Requirements for Flights in VFR Conditions k. 14 C
.P
.R. §§ 91.405(a), 91.407(a)(l ), 91.409(a)(2), 91.417(a) and (b): Maintenance Inspections We request an exemption from the following Federal Aviation Requirements (FARS) to the extent necessary to request the requested UAS operations for the reasons listed below.


### a. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates and 14 C.F.R 

### § 91.203 14 C.F.R Part 21 Subpart Hand 14 C
.F
.R § 91.203 establish the need for and protocols for airworthiness certificates
. The two UAS models ZSC intends to operate (the DJI Phantom 3 Pro and DJI Inspire 1) will, by design, provide an equivalent level of safety for the following reasons: They will weigh Jess than 40 pounds including payload
. They will travel at less than 40 miles per hour. There will be no pilots or passengers on board the aircraft. They will be powered by batteries and will use no flammable fuels
. They will be operated within the parameters described in the Operations Manual and in accordance wi th all FAA operational regulations. They will only be operated under VFR conditions.

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They will be operated under the close control ofan actual operator and observer and only within the operator's line ofsight. They will be operated in accordance with any applicable NOT AMs (Notice to Airmen) and will never be operated in controlled airspace
. In summary, ZSC will guarantee that an equivalent level of safety is achieved by operating pursuant to the standards enumerated above, the procedures outlined in the Operations and Safety manuals, and all applicable FAA regulations, limitations, and conditions. 

### b. 14 C.F.R §§ 45.23(b), 45,27(a), 91.9(c): Aircraft Marking and Identification Requirements ZSC requests an exemption from FAA's regulations governing aircraft markings since the markings cited in these regulations are too large to be affixed to the UAS ZSC intends to operate. ZSC will achieve an equivalent level of safety by marking its UAS in accordance with FAA's VAS-specific guidance and with letters and numbers ofan appropriate size
. (ZSC has been following the activities ofFAA's UAS Registration Task Force and will comply with any VAS-specific registration requirements FAA issues on a going forward basis
.)


### c. 14 C.F.R. 61.113 Under Section 61.113 , private pilots may not operate aircraft for compensation or hire
. ZSC seeks an exemption from this limitation given the unique qualities ofUAS operation and because ZSC's UAS :
• will be flown by pilots appropriately-trained in the safe opera tion ofthe UAS ;
• will not carry pilots or passengers;
• will not operate in controlled airspaces ;
• will be in visual range ofthe PIC at all times ; and
• will be flown in flights that are planned and controlled in advance
. The risks associated with operating UASs are markedly diminished from the risks associated with the typical commercial aircraft. A properly trained holder ofan airline transport, commercial, private, recreational, or sport pilot certificate will have the skills together with the necessary aeronautical knowledge to safely operate UASs for commercial purposes; and, as a result, the safety standards contemplated by Section 61
. 113 will be exceeded by the operations proposed by ZSC and ZSC requests that its pilots be exempted from 61
. 113 ' s prohibition on

# NS ATTORNEYS AT LAW U
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. Department ofTransportation December 9, 2015 Page 7



### commercial operations provided that the UAS operations conducted are undertaken pursuant to its Operations and Safety manuals and all applicable FAA regulations. d. 14 C.F.R § 91.9(b)(2): Civil Aircraft Flight Manual In The Aircraft; 14 C.F.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration 

### Due to the small size ofthe UAS, is simply not possible to stow copies ofthe flight manual or any other documentation on board the UAS itself. Instead, ZSC requests an exemption that will allow the PIC to maintain copies ofthe Flight Manual and other required documentation at his or her control station provided they are ready for inspection at all times. ZSC understands that this arrangement has already been approved by the FAA ChiefCounsel' s office.
e. 14 C.F.R 91.7(a): Civil Aircraft Airworthiness 

### This section requires that no aircraft be operated unless it is airworthy condition. The FAA has stated that no exemption is required to the extent that the requirements ofPart 21 are waived or found inapplicable. Accordingly, we request that the requirements for §91.7 be treated in accordance with the section above covering: 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates and 14 C.F.R § 91.203 f. 14 C.F.R 91.109(a): Flight Instruction 

### ZSC requests an exemption from 91.1 09(a)'s requirement that all flight training take place in aircraft equipped with dual controls. The UAS ZSC intends to operate is controlled via sophisticated radio transmitters, not traditional flight controls positioned onthe aircraft itself. A level of safety equivalent with 91.1 09(a) will be achieved by ensuring ZSC's UAS pilots have received adequate training in advance ofoperating in a "live" environment, the pilot in command is at the operations center during all flight instruction operations. the pilot in command maintains constant line of sight contact with the UAS, NOTAMs are appropriately filed, and flights are conducted in accordance with ZSC's Operations and Safety manual and away from any members ofthe public
. g. 14 C.F.R. § 91.119: Minimum Safe Altitudes 

### ZSC requests an exemption from Section 91.119 ' s mandate that the UAS be operated above non-congested areas at an altitude of 500 feet AGL or higher. The UAS operations envisioned by ZSC will comply with FAA's guidance by opera ting at altitudes less than 400 feet AGL. An equivalent level of safety is achieved due to the small size, low speed, and low weight ofthe UAS, its operation under VFR rules by an appropriately trained pilot and its operation in areas away from persons or structures not involved in the operation; including crowded or congested areas.

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h. 14 C.F.R. § 91.121: Altimeter Settings U.S. Department ofTransportation December 9, 2015 Page 8

ZSC requests an exemption from this section requiring the use ofa barometric altimeter to maintain proper cruising altitude or flight level. ZSC intends to operate UAS equipped with GPS, not barometric, altimeters
. An equivalent level ofsafety will be achieved by having the PIC confirm altitudes using the GPS altimeter. i. 14 C.F.R. § 91.151(a): Fuel Requirements for Flights in VFR Conditions As FAA is aware, UASs are powered by lithium polymer batteries in lieu offlammable fuels
. ZSC requests an exemption to the fuel requirements ofthis section, allowing it to conduct flight operations while maintaining a 25% reserve on the battery life ofthe UAS
. An equivalent, ifnot improved level of safety will exist as there are no flammable fuels stored onboard, the UAS flies at lower elevations and speeds, and within the line ofsight ofthe PIC. As such, that PIC is easily able to determine battery life and safely land the UAS quickly when the 25% limit is reached
. Furthermore, ZSC will employ industry best practices when charging and storing the lithium batteries that will power its aircraft. For the aforementioned reasons, ZSC ' s UAS operations will achieve an equivalent level ofsafety to that mandated by Section 91.151(a)
. 

### j. 14 C.F.R. §§ 91.405(a), 91.407(a)(l), 91.409(a)(2), 91.417(a) and (b): Maintenance Inspections ZSC requests that it be exempted from the regulations cited above to the extent they are applicable to aircraft that have been issued airworthiness certificates by FAA. ZSC will achieve equivalent levels of safety by ensuring its UASs are maintained in accordance with manufacturer recommendations and pursuant to ZSC's Operations and Safety manuals
. Please note that the manufacturer's manual establishes requirements for :
• a flight operations checklist that includes all the aircraft's components; • maintenance log books and records; • routine maintenance; • annual maintenance ; • post flight maintenance; and • maintenance based on hours offlight. The manufacturer's manual contemplates that the UAS owner will undertake the outlined maintenance as the owner/operator is in the best position to judge whether maintenance is required and is the party most familiar with the aircraft' s performance
. By complying with the manufacturer' s maintenance standards and the standards in its own Operations and SafetyATTORNEYS AT LAW U.S. Department ofTransportation December 9, 2015 Page 9

Manuals, ZSC will ensure it achieves levels of safety equivalent to those mandated in the FARs enumerated above
. 7. Public Interest Granting ZSC's request for exemption(s) furthers the public interest
. The UAS operations proposed by ZSC will further Congress' national policy goal ofintegrating UASs into the National Airspace System in a safe and controlled way. By operating UASs instead offull-scale fixed wing aircraft or rotorcraft, ZSC will be reducing the already minimal risks to the public posed by its surveying activities. UASs can perform many visual or infra-red surveys far more safely than either a typical fixed wing aircraft or helicopter can. By definition, the smaller size and low weight ofthe UAS reduces any risks posed to persons on the ground should an accident occur. Taking photos with UAS-mounted camera also reduces the risk to members ofthe public employed in bridge, roof, construction or other types of site surveys as they would no longer be exposed to the perils offalling from these elevated structures. The additional insight gained from these UASs will allow ZSC to provide the funds needed to allow for relieffrom the event and allow Zurich to settle claims faster for those members ofthe public it insures
. Finally, the risk assessment and risk management surveys that the UAS enable will allow ZSC to better prevent accidents and advise on accident reduction methods, which is clearly in the public interest. The UAS system will accomplish by allowing ZSC to identify problems from that air that ZSC simply cannot see using today's technology
. Particularly on large scale sites, ZSC needs to be able to employ better survey methods than the typical walk around or drive around methods currently used
. An aerial view would give ZSC a much better vision ofthe loss producing conditions that may exist on a specific site. This will give ZSC the opportunity to offer recommendations for risk reduction and loss prevention, both ofwhich are clearly in the public interest. 8. Operating Parameters The proposed operations in this Petition for Exemption qualify for expedited approval under Section 333 ofthe Reform Act. Each ofthe statutory criteria and o ther relevant factors are satisfied
. a. Approval is warranted based on the 

### VAS's size, weight, and operational capability

# NS U.S. Department ofTransportation December 9, 2015 Page 10 ATTORNEYS AT LAW
ZSC will employ the UAS s identified in the accompanying Operations Manual. These UASs will be used for all of the operations as set forth in the Operations Manual. Each of these UASs have characteristics in common that warrant approval. All ofthe UASs will be limited to a maximum flight speed of 40 mph , and vertical ascent speed will be limited to 15 mph, and none of the devices have a weight in excess 

### of 40 pounds
. Each ofthe UASs have an integrated GPS system to calculate the UAS position and height and to relay that information via secure connection to the operator. In addition, each contains a failsafe mode if its connection to the remote control is lost. The system permits the vehicle to return to a predetermined location and land to prevent injury or damage. b. Approval is warranted based on the operational restrictions set forth in ZSC's operations manual ZSC's Operations Manual and the manufacturers' maintenance and flight manuals contain all of the procedures and limitations necessary to successfully perform R&D and inspections of Zurich's customers' property before, during and after catastrophes or other loss events. To assist the FAA in its safety assessment of ZSC's operations, below is a summary of operational limitations and conditions which will ensure a level of safety equal to or exceeding the level of safety for operations conducted under current regulatory guidelines: 1. The UAS employed by ZSC will weigh less than 40 pounds including payload
. 2. The UAS will be operated within visual line of sight ofthe pilot in control (PIC) at all times
. 3
. UAS operations will not be conducted during night, as defined in 14 CFR § 1.1. All operations will be conducted under visual meteorological conditions ("VMC"). Ifflight at night is required, a special request will first be made at the FAA office closest to the proposed area ofoperations
. 4
. All flight operations will utilize a visual observer (VO)
. The UAS will be operated within the visual line of sight ofthe PIC and VO at all times
. The VO may be used to satisfy the visual line of sight requirement. The VO and PIC will always be able to communicate verbally at all times
. 5
. Maximum total flight time for each operational flight will be limited to the amount oftime the UAS can be flown and still maintain a reserve battery power ofno less than 25%. 6
. Flights will be operated at an altitude ofno more than 400 feet AGL and will not be conducted within controlled airspace
.

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### 7
. Flights will be operated at a lateral distance of at least 500 feet from any persons or property not associated with the operation who have not given pnor perrn1sswn. 8. Flights will be limited to a speed of40 m.p.h., and vertical ascent will be limited to 15 

### m.p.h. 9. Minimum crew for each operation will consist ofthe UAS Pilot, one or more Visual Observers as necessary to safely conduct the mission, and a Sensor Operator, if the sensor requires human direction or control. 10
. The pilot will hold either an airline transport, commercial, private, recreational, or sport pilot certificate
. The pilot will also hold a current FAA airman medical certificate or a valid U.S
. driver' s license issued by the state, the District of Columbia, Puerto Rico, a territory , a possession, or the Federal government. 11
. 

### The pilot will have sufficient experience and recurrent training to safely conduct flights in accordance with the standards set forth in the Operations Manual. 12. 

### The UAS will operate in accordance with the safety and operational requirements ofits respective manuals
. 13
. 

### Prior to each flight the PIC will inspect the UAS to ensure that it is in a condition for safe flight. Ifthe inspection reveals a condition that affects the safe operation ofthe UAS, the aircraft will be prohibited from operating until the necessary maintenance has been performed and the UAS is found to be in a condition for safe flight. At the same time, a Mission Plan will be prepared that will set forth the operating limitations for the flight and will identify any potential hazards associated with the mission
. 14. 

### The UAS will not operate within 5 nautical miles ofan airport reference point (ARP) as denoted in the current FAA Airport/Facility Directory (AFD) or for airports not denoted with an ARP, the center ofthe airport symbol as denoted on the current FAA-published aeronautical chmi, unless a letter ofagreement with that airport's management is obtained or otherwise permitted by a GOA issued to the exemption holder. The letter of agreement with the airport management will be made available to the Administrator or any law enf orcement official upon request.ATTORNEYS AT LAW U.S. Department ofTransp01tation December 9, 2015 Page 12

15
. Ifthe UAS loses communications with its operator, it will have the capability to return to a pre-dete1mined location within the operational area and land
. 16. Contingency plans will be in place to safely terminate flight ifthere is a loss ofcommunication between the pilot and the observer. 17. The UAS will have the capability to abort a flight in case ofunpredicted obstacles or emergencies
. 9. Federal Register Summary Pursuant to 14 CFR Part 11, the following summary is provided for publication in the Federal Register, should it be determined that publication is needed: ZSC seeks an exemption from the following rules : 1. 14 C.F.R. Part 21, Subpart H: Airworthiness Certificates and 14 C.F.R § 91.203 2
. 14 C.F.R §§ 45.23(b), 45,27(a), 91.9(c): Aircraft Marking and Identification Requirements 3
. 14 C.P.R
. 61.113: Private Pilot Privileges and Limitations: Pilot In Command. 4. 14 C.F.R § 91.9(b)(2): Civil Aircraft Flight Manual In The Aircraft 5. 14 C.F.R. § 91.203(a) & (b): Carrying Civil Aircraft Certification and Registration 6
. 14 C.F.R 91.7(a): Civil Aircraft Air Worthiness 7. 14 C.F.R 91.109(a): Flight Instruction 8. 14 C.F.R. § 91.119: Minimum Safe Altitudes 9. 14 C.F.R. § 91.121: Altimeter Settings 10
. 14 C
.F
.R
. § 91.151(a): Fuel Requirements for Flights in VFR Conditions 11. 14 C.P.R
. §§ 91.405(a), 91.407(a)(l ), 91.409(a)(2), 91.417(a) and (b) : Maintenance Inspections The exemptions will improve safety by reducing the risks ofaccidents to the general public as well as property owners from the substantial risk ofperforming similar work using typical fixed wing or helicopter aircraft, currently available today
. 10. Conclusion ZSC believes that the information contained in this petition and its Operations and Safety manuals satisfy the criteria provided in Section 333 ofthe Federal Modernization and Reform Act of2012 and FAA's standards for granting exemptions under Section 3 3 3 that authorize the use ofUASs in connection with commercial activities.

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Ifyou have any questions or require any additional information, please do not hesitate to contact us. Eckert Seamans Cherin & Mellott, LLC

Edward J
. LonM osz, II, Esquire Evelyn D
. Sahr, Esquire Jonathan Linde, Esquire