Opinion of the European Economic and Social Committee on ‘Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions — Tackling online disinformation: a European Approach’ (COM(2018) 236 final)
Date: 2018-09-19
Institutions: European Economic and Social Committee
Subjects: Internet, digital literacy, disinformation, dissemination of information, education, election, freedom of expression, information, information user, press








C_2018440EN.01018301.xml










6.12.2018   


EN


Official Journal of the European Union


C 440/183






Opinion of the European Economic and Social Committee on ‘Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions — Tackling online disinformation: a European Approach’
(COM(2018) 236 final)
(2018/C 440/32)






Rapporteur:



Martin SIECKER











Consultation


European Commission, 18/06/2018




Legal basis


Article 304 TFEU




Section responsible


Section for Transport, Energy, Infrastructure and the Information Society




Adopted in section


06/09/2018




Adopted at plenary


19/09/2018




Plenary session No


537




Outcome of vote
(for/against/abstentions)


121/16/34




1.   Conclusions and recommendations









1.1.


Freedom of information and expression is inviolable in the EU, yet this freedom is used to overturn the Union’s principles in order to make debate and critical thinking impossible, and not as a tool to inform or persuade, but as a weapon. Disinformation is used as an extreme form of abuse of media which aims to influence social and political processes and is particularly potent when it is sponsored by governments and used in international relations. Current acute cases are (amongst many others) Russian state-sponsored disinformation, the Brexit campaign that only can be classified as a frontal attack on the EU and intervention in the elections in the USA. All those destabilising actions raise great concerns for European civil society.












1.2.


A variety of tools and methods are currently used to undermine European values and external actions of the EU, as well as to develop and provoke separatist and nationalistic attitudes, manipulate the public and conduct direct interference in the domestic policy of sovereign countries and the EU as a whole. Moreover, the growing influence of cyber offensive capabilities and increased weaponisation of technologies to achieve political goals is observed. The impact of such actions is often underestimated (1).












1.3.


The EESC agrees with the Commission’s call for more responsibility on the part of social media platforms. However, despite the existence of several studies and policy papers produced by European specialists in the last few years, the communication lacks any practical mandatory steps to ensure this.












1.4.


On the basis of available research the EU should ensure and continue research on the impact of disinformation in Europe, including by monitoring Europeans’ resilience to disinformation in future Eurobarometer surveys. Those surveys should not only include generic data on fake news but also identify the true situation of Europeans’ immunity to disinformation. The Commission’s lack of urgency and ambition fails to address fundamental issues like the support schemes for traditional media in order to ensure the fundamental right of citizens to qualitative and reliable information, investigating the feasibility of setting up public-private partnerships to create paid online platforms that offer safe and affordable online services, exploring the opportunities to create more transparency around and supervision over the underlying algorithms of these online systems and looking into the possibility of breaking apart monopolies to restore a level playing field for fair competition, in order to prevent the progressive corruption of society.












1.5.


The EESC regrets that both the Communication and the HLEG report fail to mention Russia as the major source of hostile disinformation against the EU. Yet the first step in solving any problem is to admit that there is one.












1.6.


Based on the European Parliament Resolution of 15 of June 2017 on online platforms and the digital single market (2), the Commission refers to the EESC calls for the dutiful enforcement of existing legal regulations relating to online platforms. In addition the EESC invites the Commission to finish discussion of the legal liability regime for online platforms and implement targeted regulation of the online platforms with respect to their definition and character. Online platforms and social networks should commit to such measures so as to ensure transparency by explaining how algorithms select the news put forward, and be encouraged to take effective measures to improve the visibility of reliable, trustworthy news and facilitate users’ access to it.












1.7.


One of the problems with disinformation is the fact that it is impossible to check the identity of the sources spreading disinformation throughout the internet. It is too easy to operate in cyberspace with a fake identity — and in general that is exactly what those who are active online with malicious intent do. The Commission presents several proposals, which are set out in the Joint Communication on Cybersecurity published in September 2017. The problem is that these proposals are not mandatory. If we really want to make a difference in the fight against disinformation we may need more strict measures regarding identification when people are operating proactively on the internet. After all, that is how the quality media operate, in compliance with the 1954 Code of Bordeaux, which was drawn up by the International Federation of Journalists and sets very clear and strict principles for how to work with sources. The names and addresses of sources always have to be known to the editorial staff.












1.8.


The EESC agrees with the Commission that the fact-checking community should work closely together. Similar networks already exist, including one under the umbrella of the East StratCom Task Force. The problem is that they need sufficient funding, an element that is currently missing. The EESC calls on the Commission and Member States to fully support the efforts of the East StratCom Task Force. This should include not only a proper budget, but also active involvement by all Member States in its work, based on sending seconded experts to the East StratCom Task Force and creating contact points. The website presenting the results of this task force’s efforts (3) should be more proactively communicated in order to raise public awareness in the EU of the threats.




2.   Gist of the Commission Communication









2.1.


A well-functioning, free and pluralistic information ecosystem based on high professional standards is indispensable to healthy democratic debate. The Commission is attentive to the threats posed by disinformation to our open and democratic societies.












2.2.


The Commission intends to present a comprehensive approach aimed at responding to those threats by promoting digital ecosystems (4) based on transparency and privileging high-quality information, empowering citizens against disinformation and protecting our democracies and policy-making processes.












2.3.


The Commission calls on all relevant players to significantly step up their efforts to adequately address the problem of disinformation. It considers that the proposed actions will, if effectively implemented, materially contribute to countering disinformation online.












2.4.


The Commission identifies three main causes of the problem (creation of disinformation, amplification through social and other online media, dissemination by users of online platforms) and presents a number of proposals to tackle it, in five policy areas:






—


create a more transparent, trustworthy and accountable online ecosystem,










—


secure and resilient election processes,










—


fostering education and media literacy,










—


support for quality journalism as an essential element of a democratic society,










—


countering internal and external disinformation threats through strategic communication.








3.   General remarks









3.1.


The growth in organised disinformation from various state and non-state actors presents a real threat to democracy. These destabilising forces include governments of nations bigger than any EU Member State. The EU is the appropriate partner to act if it wants to counter this threat because, unlike any single Member State, the Union has the critical mass and resources that puts it in a unique position to develop and implement strategies and policies to address this complex issue.












3.2.


The proper functioning of democracy depends on well-informed citizens who can make educated choices based on reliable facts and trusted opinions. Crucial to this is a system of independent, reliable and transparent media enterprises with a special position for public broadcasters, employing sizeable professional staffs to collect, check, assess, analyse and interpret news sources in order to safeguard a certain level of quality and soundness of the stories published.












3.3.


There is a difference between fake news and disinformation. Fake news has existed throughout history: it is a catch-all term encompassing rumours, war propaganda, hate speech, sensation, lies, selective use of facts, etc. The invention of the printing press in the 15th century enabled distribution of (fake) news on a larger scale, and its geographical reach increased further after the introduction of the postage stamp in 1840. Digital technology and the internet have taken away the last barriers to unlimited distribution.












3.4.


Disinformation is defined as verifiable false or misleading information that is created, presented and disseminated for economic gain, or to intentionally deceive the public, which may cause harm to democratic processes and influence elections and is a serious threat to society (5).












3.5.


There are multiple parties in the chain of disinformation: those who create it, those who consume as well as online platforms that play an overarching role in the whole process by facilitating distribution.
Those who create it (governments, religious institutions, business conglomerates, political parties, ideological organisations, amongst others) do so for various reasons (to influence and manipulate public opinion, confirm their presumed superiority, make or increase a profit, gain power, create hate, justify exclusion, etc.).
Those who distribute it (in particular online platforms, but also traditional media) have different motives including financial benefits or deliberate manipulation.
Those who consume it (internet users) are often not critical enough as consumers and are subsequently deliberately manipulated by the online platforms. The intermediary tech companies like Twitter, Google and Facebook (to mention only a few) facilitate unlimited and uncontrolled sharing of content on online platforms in exchange for collecting private data that enable these platforms to create huge profits with microtargeted advertising that delivers tailor-made commercial messages to strictly defined target groups. Consumers’ ignorance concerning digital self-protection contributes to the growth of the problem.












3.6.


The tech companies in question have a shared responsibility since they play an overarching role in the process. They do not identify themselves as publishers but as ‘just’ online platforms that distribute information and other content created by established media without having to pay the cost of content creation in the form of editorial staff. The content is distributed from other sources without checking, assessing, analysing or interpreting the material they are publishing. ‘Google is not “just” a platform. It frames, shapes and distorts how we see the world’ was one of the conclusions of the article ‘The great Brexit robbery: how our democracy was hijacked’ published by the Guardian, which analysed how a ‘shadowy, global operation by […] the disparate forces of the Leave campaign influenced the result of the EU referendum’. Because disinformation and reliable news are presented indistinguishably, users find it difficult to separate one from the other. Thus tech companies should prioritise becoming transparent about the rules and the data. It is especially important how transparent the links are between advertising revenue policies of platforms and dissemination of disinformation. (In this respect the current negotiations on the Code of Practice on Disinformation that should have been published by the end of July 2018 should be closely monitored.)




4.   Specific remarks









4.1.


Despite the diversity of messages, channels, tools, levels, ambitions and tactical aims, and notwithstanding its rapidly adapting nature, the strategic objective of disinformation campaigns is to undermine liberal democracy, to sow and amplify mistrust in credible sources of information, in the geopolitical direction of a country and in the work of intergovernmental organisations. Disinformation is used to exploit and amplify divisions between different socio-economic groups based on their nation, race, income, age, education and occupation. Besides well recognised forms such as news outlets, usage of online platforms, mass emails etc., it functions through various forms, e.g. public relations agencies, lobbyists, think tanks, non-governmental organisations, elite influencers, party politics, expert community, cultural activities and European far-right and far-left movements which in return receive payment through various ‘independent’ public trusts, off-shore accounts, etc.












4.2.


The Russian Government is employing a wide range of tools and instruments in its disinformation campaigns as the European Parliament (6), the European Commission (7) and the European Council (8) already established. These disinformation campaigns should be taken with the highest level of seriousness. It is part of Russian military doctrine and accepted by the top hierarchy of the most important Russian state-owned media. These campaigns are directly aimed at harming liberal democracy, rule of law and human rights, and at silencing those institutions, intergovernmental organisations, politicians and individuals who defend them (9).












4.3.


We live in an era characterised by strongly polarised political and democratic relations. According to think tanks such as Freedom House, the Economist Intelligence Unit and others, democracy has been under growing pressure since the global economic crisis in 2008. One of the results of this is a new type of political leadership with a profile that represents a rupture with the democratic tradition we have built in Europe in the last 70 years. Instead of democratically chosen liberal leadership we see more and more ‘strong men’ whose elections are surrounded by penetrating questions concerning the integrity of the processes they were elected in. We were familiar with that kind of leadership outside of the sphere of influence of the EU, for example in Russia and China. But with representatives like Trump, Erdogan and elected ‘illiberal democrats’ in Member States of the EU — who all have become famous because of their preference for disinformation, their contempt for democracy and their cracked relationship with the rule of law — the phenomenon is becoming extremely loud and incredibly close.












4.4.


A properly functioning democracy depends on well-informed citizens who make educated choices based on reliable facts and trusted opinions, but ‘reliability’ and ‘trust’ are concepts that are no longer self-evident in our society today. In this kind of highly polarised societal climate, and with an overflow of information, people are very vulnerable to disinformation, which makes it relatively easy to manipulate their behaviour. We have seen such destabilising operations with high success rates in general elections in various Member States and also during other events such as the Brexit campaign, disinformation campaigns concerning the assaults on the Crimea and Ukraine, and the 2014 attack with a Russian military BUK system missile on Malaysian Airlines flight MH 17, in which all 298 occupants were massacred. The Commission is encouraged to search for more proactive ways to educate the public about the threats faced from disinformation campaigns, cyber-attacks, and the overall impact of foreign influence on society. For example by following recent developments in other countries, to provide accessible and attractive information to citizens about urgent cybersecurity issues which include tips and best practices on how best to protect their daily digital surroundings.












4.5.


The EESC agrees with the Commission that, given the complexity of the matter and the fast pace of development in the digital environment, any political response should be comprehensive, continually assess the phenomenon of disinformation and adjust policy objectives in the light of its evolution. There is no single solution that addresses all the challenges, but doing nothing is not an option. The Commission’s proposals are a step in the right direction but we need to do more and better. Transparency, diversity, credibility and inclusiveness should guide action to tackle disinformation, while simultaneously protecting freedom of speech and other fundamental rights.












4.6.


Russia seems to be particularly active in the field of disinformation and hybrid warfare against the West with a focus on the EU. To counter that we urgently need a more transparent, trustworthy and accountable online ecosystem. The EESC would recommend the use of the Prague Manual, a study funded by the Ministry of Foreign Affairs of the Netherlands and the International Visegrad Fund, which gives a clear overview of hostile Russian subversion in the EU and of the threat it represents towards democracy. Even though there are Member States that still doubt the existence of any such threat or that even contribute to its spread, the study is very clear in its judgement that it is absolutely necessary for the EU to take action. The study comes up with concrete proposals on how to design and implement strategies against hostile and subversive influences.












4.7.


The role of online platforms has been morally reprehensible in relation to disinformation. In a relatively short period of time these platforms have essentially developed a kind of public utility function similar to that of telephone companies, broadcasters and newspapers in the past. To make ‘free’ use of the services of online platforms, users pay with personal data that enable these platforms to sell an enormous amount of microtargeted advertising as illustrated by the Cambridge Analytica case. This warped (in terms of privacy) revenue model is too lucrative for these platforms to abolish it on a voluntary basis. There have been voices suggesting that platforms like Facebook should also offer a credible and well-functioning Facebook-like service, which would require users to pay an affordable amount of money in exchange for the guarantee that their privacy would be respected. The question arises of whether potential users still have enough faith and confidence in the credibility and integrity of portals like Facebook after the way the company behind it accounted for its behaviour to the US Senate. To increase public confidence in online platforms and protect citizens against this form of abuse, including mistreatment and sharing of personal data, these platforms must be regulated as previously shown by the Code of Conduct on countering illegal hate speech online from 2016, the GDPR or the NIS directives. However, self-regulation, as proposed by the Commission, is only a first step in this regard and should be accompanied by further measures taken by the Commission.












4.8.


Andrew Keen, a British entrepreneur and writer who is known as the Antichrist of the Internet, published four very critical books on the development of the internet. He is not against the internet or social media, but he does consider the activities of the big tech companies, aimed at collecting sensitive information about people, as the core of the problem. Privacy is a very precious good, it defines who we are. The so-called free-of-charge business model — where we do not pay with money but with giving up our privacy — will destroy our privacy. Keen draws parallels with the 19th Century, when the Industrial Revolution generated change on a scale that can be compared with the scale of change the Digital Revolution is generating right now. When change is defined as a revolution it usually comes with massive problems. In the 19th Century we managed to solve those problems with tools like innovation, regulation, consumer choices, civil action and education. His message is human intelligence can do it again — not artificial intelligence — and we have to utilise all the resources we used to constrain the previous revolution to ensure we control the Digital Revolution and prevent it from dominating us.












4.9.


On the basis of available research the EU should ensure and continue research on the impact of disinformation in Europe, including by monitoring Europeans’ resilience to disinformation in future Eurobarometer surveys. Those surveys should not only include generic data on fake news but also identify the true situation of Europeans’ immunity to disinformation. The Commission’s lack of urgency and ambition fails to address fundamental issues like the support schemes for traditional media in order to ensure the fundamental right of citizens to qualitative and reliable information, investigating the feasibility of setting up public-private partnerships to create paid online platforms that offer safe and affordable online services, exploring the opportunities to create more transparency around and supervision over the underlying algorithms of these online systems and looking into the possibility of breaking apart monopolies to restore a level playing field for fair competition, in order to prevent the progressive corruption of society.












4.10.


It could be profitable for instance to look into the possibility of creating an online platform based on a public-private partnership that guarantees the privacy of users. A European platform of this kind with the Commission as a co-funding public partner could be a very attractive and promising proposition as an alternative to Mark Zuckerberg’s Manipulation Machine and other big private and commercial monopolies from the USA and China. Such a platform should guarantee to respect the privacy of its users.












4.11.


In a market economy a price has to be paid for everything, but with this alternative the currency would be money instead of privacy. The bulk of the required budget for this semi-public service could be financed with tax money, as all public services are. For the rest of the budget users would have to pay a relative small amount of money to safeguard their privacy against the insatiable private data-hunger of the current ‘social’ platforms. If the EU and the national governments of the Member States officially declared such a platform to be a preferred partner and used it as an alternative for the current data devouring predators it would have the economy of scale required to have a chance of competing with the current market players. The EU could also use existing search engines that guarantee absolute privacy as their preferred partners, install them as default applications on all computers used by EU institutions and recommend them as default applications to governmental institutions in the Member States. The Commission could also play a more pro-active role and investigate regulatory possibilities relating to algorithms and breaking up monopolies.












4.12.


Though fact checking is not the solution to the problem, it is nonetheless of high importance. It serves as the first step towards understanding, exposing and analysing disinformation, which is necessary before further counter-measures can be designed. It also takes a great deal of effort to gain the attention of wider audiences, as not everybody uses social media platforms or even the internet. Inhabitants of remote regions may be especially difficult to reach. Visibility in the media is important. Television is still the most common source of information for people, and regular programmes explaining cases of disinformation in national languages can significantly contribute to public awareness of the problem. It is important for the fact-checking process to be undertaken by professionals, in order to avoid the mistakes that marked the Commission’s first attempt recently. Cooperation with publishing houses and media organisations whose journalists are involved in fact-checking can prevent such problems.












4.13.


One of the problems with disinformation is the fact that it is impossible to check the identity of the sources spreading disinformation through the internet. It is too easy to operate in cyberspace with a fake identity — and in general that is exactly what those who are active online with malicious intent do. The Commission presents several proposals, which are set out in the Joint Communication on Cybersecurity published in September 2017. The problem is that these proposals are not mandatory: users could choose to only engage on online platforms with others who have identified themselves; the Commission will promote the use of voluntary online systems allowing the identification of suppliers of information, etc. Of course, there is a potential conflict of interest between privacy and full control and it should be possible to maintain anonymity when surfing the internet passively. However, if we really want to make a difference in the fight against disinformation we may need more strict measures regarding identification when people are operating proactively on the internet. After all, that is how the quality media operate, in compliance with the 1954 Code of Bordeaux, which was drawn up by the International Federation of Journalists and sets very clear and strict principles for how to work with sources. There are sometimes valid reasons why traditional quality news organisations publish stories with anonymous sources, but they always include an indication that the name and address of the source are known to the editorial staff.












4.14.


Technologies are neither ‘good’ nor ‘bad’ — they are neutral. They can be used in a good or a bad way, but that depends upon the choices made by the people using them. New, emerging technologies such as those now being used in the art of disinformation also have the potential to play a central role in tackling disinformation. The EESC therefore welcomes the Commission’s intention to make full use of the Horizon 2020 work programme and its successor Horizon Europe to mobilise research and technologies like artificial intelligence, blockchain and algorithms in order to better identify sources, validate the reliability of information and assess the quality and accuracy of data sources in the future. However, detailed analysis of other funding possibilities for tackling disinformation is crucial, as most of the initiatives are not applicable to the Horizon Programmes.












4.15.


Secure and resilient election processes are the basis for democracy in the EU, but the security and resilience of those processes are no longer guaranteed. In recent years, online manipulation and disinformation tactics were detected during elections in at least 18 countries, and disinformation tactics contributed to a seventh consecutive year of overall decline in internet freedom. The EESC welcomes the initiatives the Commission has taken to identify best practices for identifying, mitigating and managing risks to the electoral process from cyberattacks and disinformation with a view to the 2019 European Parliament elections.












4.16.


Media and digital skills as well as civic education are crucial building blocks in increasing society’s resilience, especially given that young people, who have a high presence on online platforms, are very receptive to disinformation. Education policy is a government responsibility, and thus organising this at all levels of national education systems and training teachers on this topic is a task for national governments. Unfortunately, governments frequently neglect to give media and information literacy education in their national education systems a prominent position on their political agendas. This should be improved in the first instance, but media and information literacy also goes beyond education systems. It needs to be promoted and improved among all societal groups, regardless of age. In these areas non-governmental organisations should play a role. Many of these organisations are already working throughout Europe, but most of them operate on a small scale and do not have the necessary outreach. National cooperation initiatives between the non-governmental organisations and national governments could fill this gap.












4.17.


Quality news media and reliable journalism play an essential role in providing the public with sound and diverse information. These traditional media are experiencing financial problems, as the platforms are distributing content produced by the traditional media without reimbursing them for the costs they have incurred and then capturing the income from these media by selling advertising. To improve the position of publishers and ensure rights holders will be compensated for their work when the fruit of their labour is used by others for commercial purposes a rapid agreement on the EU copyright reform would be welcome. Moreover, it is recommended that solutions be sought to expand the initiative announced by the European Parliament in September 2018 on the European funding specifically to support investigative journalism in the EU. A strong and reliable press leads to a resilient and defensible democracy where the values of truth and accountability persist. Funding is particularly important for smaller media outlets who are often faced with lawsuits and vexatious claims designed to shut them down.












4.18.


To counter internal and external disinformation threats, the Commission set up the East StratCom Task Force in 2015 to focus on proactive strategic communication on EU policies in order to counter destabilising attempts from Russia. The EESC would welcome it if the Commission could be more proactive in communicating the work of East StratCom to the general public and directing them to the information on the task force’s website to raise public awareness of the threats to our democracy and to increase resistance against these threats. It is also necessary to increase the task force’s budget. A budget of EUR 1 000 000 was agreed on by the European Parliament in October 2017. That budget is barely comparable to the financial resources invested by other players such as the Russian Federation. (The US State Department estimates that the Kremlin’s sophisticated influence campaign effort includes a USD 1,4 billion a year internal and external propaganda apparatus, which claims to reach some 600 million people in 130 countries and 30 languages).












4.19.


Beside other actions the Commission is encouraged to pay attention to the fact that national institutions and regulations on information security in Member States are often underdeveloped. The regulatory environment is outdated, thus preventing the relevant regulatory agencies from duly scrutinising disinformation channels for compliance with legislative norms. The intra-institutional cooperation is inadequate, there is a clear deficiency of national long-term strategies aimed at combating foreign-led disinformation campaigns and producing coherent narratives towards vulnerable groups of the population. A thorough review of the EU Audiovisual Media Services Directive, which currently allows a media outlet to be registered in any EU Member State as long as one of the media company’s board members resides in that country, is crucial as well, as it allows audiences in European countries to be reached, while exploiting loopholes in EU regulations.





Brussels, 19 September 2018.


The President of the European Economic and Social Committee

Luca JAHIER




(1)  Information report REX/432 ‘How media is used to influence social and political processes in the EU and Eastern neighbouring countries’.

(2)  2016/2276 (INI).

(3)  https://euvsdisinfo.eu

(4)  The Commission uses the word ‘ecosystems’ in its document. The word ‘infrastructure’ might be better in place in this context.

(5)  Commission Communication COM(2018) 236 final.

(6)  http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+TA+P8-TA-2017-0272+0+DOC+PDF+V0//EN

(7)  http://ec.europa.eu/newsroom/dae/document.cfm?doc_id=50271

(8)  http://www.consilium.europa.eu/en/meetings/european-council/2015/03/19-20/; http://www.consilium.europa.eu/media/33457/22-euco-final-conclusions-en.pdf; https://www.consilium.europa.eu/media/35936/28-euco-final-conclusions-en.pdf

(9)  ‘The Strategy and Tactics of the Pro-Kremlin Disinformation Campaign’, EEAS.




ANNEX
The following amendment, which received at least a quarter of the votes cast, was rejected during the discussions:

Point 4.3










4.3.




We live in an era characterised by strongly polarised political and democratic relations. According to think tanks such as Freedom House, the Economist Intelligence Unit and others, democracy has been under growing pressure since the global economic crisis in 2008. One of the results of this is a new type of political leadership with a profile that represents a rupture with the democratic tradition we have built in Europe in the last 70 years. Instead of democratically chosen liberal leadership we see more and more ‘strong men’ whose elections are surrounded by penetrating questions concerning the integrity of the processes they were elected in. We were familiar with that kind of leadership outside of the sphere of influence of the EU, for example in Russia and China. But with representatives like Trump, Erdogan and elected ‘illiberal democrats’ in Member States of the EU — who all have become famous because of their preference for disinformation, their contempt for democracy and their cracked relationship with the rule of law — the phenomenon is becoming extremely loud and incredibly close.







Outcome of the vote







Votes in favour:


68




Votes against:


82




Abstentions:


24