James C SENGUL 

1 Randolph Terrace 

Fair Lawn, NJ 07410 

Nov 6, 2015 

U.S. Department of Transportation 

Docket Management System 

1200 New Jersey Ave., 

Washington, DC 20590 

"-· .. 

RE: Exemption Request Section 333 ofthe FAA Reform Act and Part 11 of the Federal 

Aviation Regulations from 14 C.P.R. 61.113(a)&(b); 91.7(a); 91.121; 91.151(a); 91.405(a); 

91.407(a)(1); 91.409(a)(1)(2); 91.417(a)(b); 91.119(c) 

ATTACHMENTS: 

Dji F550 Flame Wheel user Manual V.1.9, DJI F450 User Manual 

Dear Sir or Madam: 

Pursuant to the Section 333 of the FAA Modernization and Reform Act of2012 (the "Reform 

Act"), AMA member and Professional Photographer James C SENGUL (the "applicant"), 

operator of an DJI F550 and DJI F450 Unmanned Aircraft Systems ("UAS") seeks an exemption 

from the Federal Aviation Regulations ("F ARs ") to allow for 

1. Aerial photography and/or video for public and/or private use including real estate, 

architecture,land surveying, engineering and other related professional activities. 

2. Aerial video and/or photography for public and/or private use including television, public 

events,cinematography and news gathering. 

3. Aerial inspection/photography of residential/commercial structures under contract with the 

owners or local government authority. 

4. Aerial video/photography or providing live video feed to assist with search and rescue 

operations in cases of an emergency or natural disaster only when the local authorities or 

government has requested it by contract or donation 

In order to operate small unmanned aircraft systems (UAS) commercially in airspace 

regulated by the Federal Aviation Administration (FAA) for .the purposes of aerial 
photography, cinematography, videography, mapping, crop surveying, inspections and 

other flight operations that could be performed safely and more cost effectively with the 

use of small UAS at low altitude within the U.S. national airspace system as compared 

to a manned aircraft. Operations will be performed only at the request of and. with tht( 

authorization and permission of clients or their authorized agents in order to facilitate 

commerce and raise awareness of the beneficial uses of small unmanned air systems. 

So long as such operations are conducted within and under the conditions outlined 

herein or as may be established by the FAA as required by Section 333. 

PUBLIC INTEREST 

My ultra lightweight UAS is battery powered and creates no emissions that can harm the 

environment. The consequence of our ultra lightweight UAS crashing is far less than a 

full size helicopter or fixed wing aircraft; which are heavy, contain a pilot, many 

gallons of combustible fuel and can cause catastrophic devastation to the public. The Smart 

Battery employed in UAS provides immediate visual awareness and percent battery 

charge remaining as well as similar information during flight through Ground Control 

Station. The public's interest is further supported by minimizing the potential for ecological 

damage and crash threats by permitting aerial video/photo capture through my 

battery operated ultra lightweight UAS's. Permitting james C SENGUL to immediately 

fly within national air space furthers economic growth. Granting my exemption request 

substantially furthers the economic impact for the New York, New Jersey and Connecticut area 

for companies and families looking to relocate or build in the areas as well as Not-forProfit I Search and Rescue I Fire Fighting needing enhanced local awareness, all of which 

serve to strengthen and stimulate the community 

APPLICANT CONTACT INFORMATION 

The name, address, and additional contact information for the applicant is: 

James C. SENGUL 

1 Randolph Terrace 

Fair Lawn, NJ 07410 

Phone# 201-923-5710 

Email: csengul@gmail.com 

www.jamescsengul.com 
Regulations from which the exemption is requested: 

14 C.P.R. 61.113(a)&(b); 91.7(a); 91.121; 91.151(a); 91.405(a); 91.407(a)(l); 91.409(a)(1)(2); 

91.417(a)(b); 91.119(c) 

This exemption application is expressly submitted to fulfill Congress' goal in passing Section 

333(a) through (c) of the Reform Act. 

This law directs the Secretary of Transportation to consider whether certain unmanned aircraft 

systems may operate safely in the national airspace system (NAS) before completion of the 

rulemaking required under Section 332 of the Reform Act. In making this determination, the 

Secretary is required to determine which types ofUAS do not create a hazard to users of the 

NAS or the public or pose a threat to national security in light of the following: 

The UAS size, weight, speed, and operational capability; 

Operation of the UAS in close proximity to airports and populated areas; and 

Operation of the UAS within visual line of sight ofthe operator. 

Pursuant to Section 333 of the FAA Modernization and Reform Act of2012 and 14 C.P.R. Part 

11, I, James C SENGUL, a professional photographer with 20 +experience. Preparing this 

exemption request myself, would like to apply for an exemption from the following Code of 

Federal Regulations (C.F.R) to be allowed commercial operation oflightweight Unmanned 

Aircraft Systems (UAS) for aerial imaging and video ofTri State Area (New York, New Jersey, 

Connecticut ) 

I have own a hobby grade DJI F550 hexacopter. (maximum gross weight 10 pounds, equipped 

with six rotors that are driven by electric motors powered by batteries, the U AS has a maximum 

airspeed of 30 knots) manned only with a Sony A6000 camera for the intent of aerial 

photography/videography and videos; following an exemption and approval by the FAA. I have 

flown hobby grade quadcopter for last 3 years without any accident or crash. 

My exemption request would permit operation of ultra-lightweight, unmanned (piloted by remote 

control) in predetermined areas away from general public, airports, heliports and vehicular 

traffic, daylight hours only, under 300ft. and after carefully reviewing, inspecting and examining 

the area of aerial observation. 

I will abide all FAA requirements to ensure this exemption will provide a level of safety at least 

equal to existing rules and will only operate in a safe environment that is strictly controlled, area 

way from power lines, elevated lights, airports and actively populated areas; and I will conduct 

extensive preflight inspections and protocols, during which safety carries primary importance 
14 C.F.R. Part 21, Subpart H: Airworthiness Certificates 14 CFR § 91.203 

Given the size, weight, speed, and limited operating area associated with the aircraft to be 

utilized, I am asking exemption from 14. CPR part21 ,Subpart H(Airworthiness 

Certificates)and§91.203 (a) and (b) (Certifications required),subject to certain conditions and 

limitations, is warranted and meets 

the requirements for an equivalent level of safety under 14 CPR part 11 and Section 3 3 3 of P .L. 

112-95 (Section 333). 

14 C.F.R. 45.27(a): Location of marks; non fixed-wing aircraft. 14 C.F.R. 45.29 (3) 

(c)( d)( e)(t)(h): 

Size of Marks 

Furthermore I request an exemption from §45.23 Marking of the aircraft because my UAS will 

not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Additionally 

two-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the 

minimal lettering requirement. I understand the need for markings and will mark my UAS in the 

largest possible lettering by placing the word "Experimental" or assigned number or name 

(based on a request or ruling by the FAA) on its fuselage as required by §45.29(±) so that anyone 

assisting him as a spotter will see the markings. 

I also ask for an exemption from §§91.405(a),91.407(a)(l), 91.409(a)(2) and 91.417(a) and(b) 

Maintenance inspections may be required and should be granted since they only apply to aircraft 

with an airworthiness certificate. But, as a safety precaution I will perform a preflight inspection 

of my UAS before each flight as outlined in this operating documents. 

14 CFR 61.113 (a) & (b): Private pilot privileges and limitations: Pilot in command. 

Under §61.113 (a) and(b) private pilots are limited to non-commercial operations, however I can 

achieve an equivalent level of safety as achieved by current regulations because my UAS does 

not carry any pilots or passengers. While helpful, a pilots' license will not ensure remote control 

piloting skills. The risks of operating a UAS are far less than the risk levels inherent in the 

commercial activities outlined in 14 CPR part 61 ,et seq., I requests an exemption 

from §61.113 Private Pilot Privileges and Limitations. 
•., '·, 

14 C.F.R. 91.103 (b)(1), (b)(2): Preflight Action 

If granted an exemption I agree to additional safety procedures including, but not limited to: 

1) Keeping my UAS within a radius distance of 1000 feet from the controller to both aid in direct 

line of sight visual observation. 

2) Operate the UAS for 3-7 minutes per flight; land my UAS according to the manufacturer's 

recommended minimum level of battery power. 

3) Operate my UAS only within visual line of sight (VLOS).Daylight hours only. ' 

4) Use the UAS's global positioning system (GPS) flight safety feature; it hovers and then 

slowly lands if communication with the remote control. 

5) Conduct all operations under my own personal and flight safety protocols (including posting a 

warning sign reading: "Attention Aerial Photography in Progress-Remain Back 150 feet"). 

6) I will operate and will actively analyze flight data and other sources of information to 

constantly update and enhance my safety protocols. 

7) Contact respective airports if operations will be within 5 miles to advise them of his estimated 

flight time, flight duration, elevation of flight and other pertinent information. 

8) Always obtain all necessary permissions prior to operation. 

9) Have procedures in place to abort flights in the event of safety breaches or potential danger. 

14 C.F.R. 91.119- Minimum safe altitudes: General 

James C SENGUL seeks exemption from 14 C.P.R. 91.119, which discusses minimum safe 

altitudes. As this exemption is for a sUAS that is a helicopter and the exemption requests 

authority to operate at altitudes up to 400 AGL, or not more than 200 above an elevated platform 

from which filming is planned, an exemption may be needed to allow such operations. 

As set forth herein, except for the limited conditions stated in the Manual, the UAS will never 

operate at higher than 400 AGL. It will however be operated in a restricted area with security 

perimeter, where buildings and people will not be exposed to operations without their 

pre-obtained consent. The equivalent level of safety will be achieved given the size, weight, 

speed of the UAS as well as the location where it is operated. No flight will be taken without 

the permission of the property owner or local officials. Because of the advance notice to 

the property owner and participants in the filming activity, all affected individuals will 

be aware of the planned flight operations as set forth in the Manual. Compared to flight 

operations with aircraft or motorcraft weighting far more than the maximum 55lbs. proposed 

herein and the lack of flammable fuel, any risk associated with these operations is far less 

than those presently presented with conventional aircraft operating at or below 500 AGL 

in the movie industry. In addition,the low-altitude operations of the sUAS will ensure separation 

between these small- UAS operations and the operations of conventional aircraft that must 

comply with Section 91.119 
Aerial videography for geographical awareness of real estate marketing has been around for a 

long time through manned fixed winged aircraft and helicopters, but for small business owners, 

its expense has been cost-prohibitive. Granting this exemption would allow me to provide this 

service at a much lower cost. Further, my small UAS, when used properly, will pose no threat to 

the public given its small size and lack of combustible fuel when compared to larger manned 

aircraft 

Therefore, James C SENGUL respectfully requests the FAA grant an exemption 

pursuant to its application as outlined above. 

Sincerely 

James C SENGUL 
FlameWheel550 

User Manual 

v 1.9 

2013.03.13 Revision 

FLFim6 WHEEL 

www.dji-innovations.com 

@2012 OJ! Innovations All Rights Reserved 
Contents 

Disclaimer ....................................................................................................................... 2 

F550 PrOfile .................................................................................................................... 2 

Contents ......................................................................................................................... 3 

Product Usage Cautions ................................................................................................. 3 

In Box ............................................................................................................................. 4 

Tools Needed ................................................................................................................. 5 

ESC Wiring ..................................................................................................................... S 

Assembly ........................................................................................................................ 6 

ESC Sound Introduction ................................................................................................. 7 

Specifications ................................................................................................................. 7 

Product Usage Cautions 

When flying, the fast rotating propellers of FlameWheel550 will cause serious damage 

and injury. Therefore, please fly with a high safety consciousness. 

1. Keep flying multi-rotor away from objects, such as obstacles, children, 

human beings, high-voltage lines and so on. 

2. Do not get close to or even touch the working motors and propellers, which 

will cause serious injury. 

3. Do not over load the multi-rotor. 

4. Check that the propellers and the motors are installed correctly and firmly 

before flight. 

5. Make sure the rotation direction of each propeller is correct 

6. Check whether all parts of multi-rotor are In good condition before flight. Do 

not fly with old or broken parts. 

7. Use DJI parts as much as possible. 

If you have any problem you cannot solve during installation, please contact our 

customer service. 

©2012 DJilnnovat1ons. All Rights Resetved 3 
In Box 

1010 Propeller Pairs~ Bin Propeller Pairs~ 

ESC >16. 

• t 15A E 

Screws ~6 

·ll 

(<-~2012 DJIInnovat1ons. All Rights A"eserved 4 
Tools Needed 

2.0mm Hex Wrench For frame and motors installation. 

Screw Glue For fastening screws. 

Nylon Cable Tie 

Scissors For binding devices and wires. 

Diagonal Cutting Pliers 

Foam Double Sided Adhesive Tape For fixing receiVer, controller and other modules. 

Soldering-iron & Wires For connecting ESCs' power cables to bottom board. 

ESC Wiring 

ESC ESC 

ESC 

lmporillnt 

o please $Older ESCs to power pads on t>ottoffi board as the figure' shows. 

o 0'*' any insulating method at all $0idertng spots. 1'4!Jk<fsure th~ 1$ no slioi16r open ci~ult. 

o : M~ke surelhe side of power pads. is upward. 

o M~lie sui'!! !h" rotation dii'I!Ciion of each ino!Qr ~~; the !lame · ~ too · way in th!> tigul'l! Ql 

"Assembly shc>ws. If not s.Y,it(:h any of IWO wire cdnneCuons. oithe incorrect mot6rto !;han~ . 

Its rotation direction •. 

~))2012 OJIInnovat1ons All Rights Reserved 5 
Assembly 

0 Install screws by appropriate force 

to prevent breaking threads. 

0 Use adequate screw glue for 

installing screws. I 

0 Please wire neatly. Make sure wires will 

not be cut by frame boards and propellers. 

0 Smooth out the boards edge if necessary. 

0 Please install propellers alter autopilot system configuration procedure. 

0 Make sure the rotation direction of propellers are the same as the figure 

shows. 

0 When mounting the propellers, do not use any thread locker, just tighten 

the nuts to the end manually then use the wrench to tighten it about 50°. 

ltltlp ftgLJr(~ arrns front of cra1t curns dre back of craft See frorn top rnotorson drtns rotate counlf r clock wrsu tt'e propPIIets 1038 motors on drms 

rotate clock wrse use propellers 1038Fl 

©2012 DJI Innovations All Rights Reserved. 6 
) 

ESC Sound Introduction 

ESC State 

Ready 

Throttle stick is not at bottom 

Sound. 

11234567 

BBBBBB ... 

Input signal abnormal 6--------6--------6 ... 

Input voltage abnormal 6B---B6---66--6B ... 

Tips: 

DJI ESCs are specially de$igned for muni·rotor~. When use With DJI autopllot 

systems, you do not have to setup any paraml)ters or calibrate travel range. 

Specifications 

Fraine 

Diagonal Wheelbase 

Frame Weight 

Takeoff Weight 

ESC 

Current 

Signal Frequency 

Battery 

Motor 

Stator size 

KV 

Propeller 

@2012 [),J! Innovations, All Rights Reserved 

550mm 

478g 

1200g - 2400g 

15AOPTO 

30Hz -450Hz 

3S-4SLiPo 

22x12mm 

920rpmN 

10 x3.8in (@38); (Optional8 x4.5in (@48)) 

7 
Disclaimer 

Read this disclaimer carefully before using FlameWheel550. By using this product, you hereby agree to 

this disclaimer and signWy that you have read them fully. RameWheel550 is an excellent mu~l-rotor. Wfth 

a good autopilot, ft will even offer tremendous flight features for low altftude flight working In restricted 

space. Despfte the controller of autopilot operates in the safest manner when the main power battery is 

connected, we strongly recommend customeiS to remove all propelieiS, use power supply from RIC 

system or flight pack battery, and keep children away during system calibration and parameter setup. 

Please respect the AMA's National Model Aircraft Safety Code. DJI Innovations assumes no llabilfty for 

damage(s) or injuries incurred directly or indirectly from the use of this product. 

DJI Ft.AME WHEEL is registered trademark of DJIInnovations. Names of product, brand, etc., appearing 

in this manual are trademarks or registered trademarks of their respective owner companies. This product 

and manual are copyrighted by OJ I Innovations wilh all rights reserved. No part of this product or manual 

shall be reproduced in any fonn without the prior written consent or authorization of DJI Innovations. No 

patent liability Is assumed with respect to the use of the product or Information contained herein. 

F550 Profile 

FlameWheel550 (F550) is a mufti-rotor designed for all pilots for fun or AP. Wfth DJI WKM or NAZA 

autopilot system, ft can achieve hovering, cruising, even rolling and other flight elements. It can be 

applied for entertainment, aerial photography, FPV and other aero-modeling activities. 

©2012 DJIInnovat1ons. All Rights Reserved 2 
Flame Wheel 450 

User Manual Ga2J 

2015.05 Revision 
Disclaimer 

Read this disclaimer carefully before using FlameWheel 450. By using this product. you 

hereby agree to this disclaimer and signify that you have read them fully. FlameWheel 450 

is an excellent multi-rotor. With a good autopilot, it will even offer tremendous flight features 

for low altitude flight working in restricted space. Despite the controller of autopilot operates 

in the safest manner when the main power battery is connected, we strongly recommend 

customers to remove all propellers, use power supply from R/C system or flight pack battery, 

and keep children away during system calibration and parameter setup. Please respect 

the AMA's National Model Aircraft Safety Code.Piease install and use this product in strict 

accordance with the User Manual. SZ DJI Technology Co., Ltd. and its affiliated companies 

assume no liability for damage(s) or injuries incurred directly or indirectly from using, 

installing or refitting this product improperly, including but not limited to using non-designated 

accessories. 

This device complies with part 15 of the FCC Rules. 

DJI FLAME WHEEL is registered trademark of DJI Innovations. Names of product, brand, 

etc., appearing in this manual are trademarks or registered trademarks of their respective 

owner companies. This product and manual are copyrighted by OJI Innovations with all rights 

reserved. No part of this product or manual shall be reproduced in any form without the prior 

written consent or authorization of DJIInnovations. No patent liability is assumed with respect 

to the use of the product or information contained herein. 

F450 Profile 

FlameWheel 450 (F450) is a multi-rotor designed for all pilots for fun or AP. With OJI WKM or NAZA 

autopilot system, it can achieve hovering, cruising, even rolling and other flight elements. It can be 

applied for entertainment, aerial photography, FPV and other aero-modeling activities. 

& Product Usage Cautions 

When flying, the fast rotating propellers of FlameWheel 450 will cause serious damage and 

injury. Therefore, please fly with a high safety consciousness. 

1. Keep flying multi- rotor away from objects, such as obstacles, human beings, high- voltage lines 

and so on. 

2. Do not get close to or even touch the working motors and propellers, which will cause serious injury. 

3. Do not over load the multi- rotor. 

4. Check that the propellers and the motors are installed correctly and firmly before flight. 

5. Check whether all parts of multi- rotor are in good condition before flight. Do not fly with old or 

broken parts. 

6. Use DJI parts as much as possible. 

If you have any problem you cannot solve during installation, please contact our customer service. 
Tools Needed 

2:0mm Hex Wrench 

Screw Glue 

Nylon Cable Tie, Scissors, Diagonal Cutting Pliers 

Foam Double Sided Adhesive Tape 

Soldering-iron & wires 

Preparing for Mounting 

The size of the assembly hole is shown below. 

~ 

c= 

"' 0 

3 

28.2mm 

M6 

N 

OJ 

3 

3 

...,. 

<D 

3 

3 

For frame and motors installation. 

For fastening· screws. 

For binding devices and wires. 

For fixing receiver, controller and 

other modules. 

For connerting ESCs' power 

capl~s t() I:)Qtt()lll b_()ard. 

4 x M3 Thread depth 3mm 

16mm 

& • The screw size is M3. Mount the motors using appropriate screws. 

• Note the thread depth and the size of the screws. Using screws that are too long or 

too large may damage the motor. 

© ?Uh DJI All R1gl1t~; liOSl)n;ecJ 5 
Flame Wheel 450 User Manual 

Attach the propeller with a silver nut onto the Attach the propeller with a black nut onto the 

counter clockwise motor. clockwise motor (which has an indent on the 

screw). 

Silver nut (9450) 

El~ Lock: Tighten the propeller by rotating 

it in this direction. 

Black nut (9450 cw) 

'b 'l"'tJnlock: Remove the propeller by 

rotating it in this direction. 

1. Please solder each ESC to the power pads on the bottom bO(ird as shown in the figure 

below. Make sure that the solder is firmly attached on the power pads and that there is no 

possibility for a short circuit. The power cable is a coaxial power cable. Do not damage the 

protector on the red cable to avoid short circuit. The red core of the coaxial power cable 

is positive, and the shielding layer of the coaxial power cable is negative. Make sure to 

solder them correctly at the proper length (the wires should be just long enough to reach 

the soldering point, face outwards, and should not be bunched up in front of the soldering 

point). 

2. Connect the signal cable to your controller. The orange wire of the signal cable is for the 

control signal; the brown wire of the signal cable is for the GND. 

3. Connect the motor to the ESC. Test the motor and make sure the rotation direction of each 

motor is correct. If not, switch the position of any two cables that are connecting the motor 

to the ESC to change the rotation direction. \, 

6 CQ! 2015 [),Ji AIII110hts Rosorvod 
Flame Wheel 450 User Manual 

& Note that arms CD® point to the nose of aircraft and arms @@ point to the tail of 

aircraft. It is recommended to choose the same color arms for the same direction. 

See from top, motors on arms G)@ rotate counter-clock wise and motors on arms 

®@ rotate clock wise. 

ESC Sound Description 

Description 

Ready 

Description 

Normal 

;1234 

Abnormal 

BBBBBB ... No signal input, or throttle stick is not in the bottom position 

'.\):: You can instantly tell what the unit' s status is by listening to the sounds emitted from 

the ESC. 

Specifications 

Max Allowable Voltage 

Max Allowable Current (Persistent) 

Max Allowable Peak Current (3 seconds) 

PWM Input Signal Level 

Signal Frequency 

Battery 

Weight (without cable) 

Weigh (with cable) 

Stator size 

KV 

Diameter I Thread Pitch 

Weight (Single) 

8 @ 20H5 DJI All ~lights Rt;serveci 

17.4V 

20A 

30A 

3.3 VI 5 V Compatible 

30Hz- 450Hz 

3 S- 4S LiPo 

12.5g 

27g 

23x12mm 

960 rpmN 

57 

24 x 12.7 em (9.4 x 5.0inch) 

13 g 
The content is subject to change. 

Download the latest version from 

http://www.dji.com/product/flame-wheel-arf 

If you have any questions about this document, please contact DJI by 

sending a message to DocSupport@djl.com. 

© 2015 DJI. All Rights Reserved 
FlameWhee1450 User Manual 

.&. • Please solder ESCs to power pads on bottom board as the figure shows. 

• Use any insulating method at all soldering spots. Make sure there is no short or 

open circuit. 

• Make sure the side of power pads is upward. 

Assembly 

1. Install the bottom board. Note to install the screws by appropriate force to prevent 

breaking threads. Use adequate screw glue for installing screws. 

2. Install your flight control system and electronic system. 

3. Install ESCs and motors. Make sure the rotation direction of each motor is the same as the 

way in the figure shows. If not, switch any of two wire connections of the incorrect motor to 

change its rotation direction. 

4. Tidy all cables. Make sure all cables are not be cut by the frame bbards and propellers. 

Smooth out the boards edge if necessary. 

5. Install the top board. 

6. Install the propellers. Please install the propellers after the flight control system 

configuration procedure. Make sure the rotation direction of propellers are the same as the 

figure shows. Tighten the propeller by rotating it in lock direction. Do not use any thread 

lock. 

ScrewM3xS Boltoi'nbGa[d 

.. .'''!.\. 

© 201[1 O.JI All f-'l1ghts Rosorved 7 
In the Box 

· T .op Board 450FBT x 1 

Frame Arms 450FAC x 2 

MotorsCW x2 

Propeller Pairs x 3 

$crews 450-M3 x 8 x 16 

Propeller Removal Clamp x 1 

4 © ?015 DJL All RIQil!f; f~esmvcd 

Bottom Board 450FBB x 1 

Frame Arms 450FAW x 2 

Motors CCW x 2 

ESG X4 

Screws 450·M2:5 x 6 x 24 

Magic Strap 450MSX x 1 

Battery Band 450BBX x 11 

Power Line Pair 450PLP x 1 
Contents 

Disclaimer 2 

F450 Profile 2 

Product Usage Cautions 2 

Contents 3 

In the Box 4 

Tools Needed 5 

Preparing for Mounting 5 

Motor Mounting Description 5 

Propeller Mounting Description 6 

ESC and Motor Wiring Description 6 

Assembly 7 

ESC Sound Description 8 

Specifications 8 

© ?0 h OJt All R1gllts Reserved 3