Given a text passage, come up with an appropriate title for it. The title should accurately represent what the main focus of the passage is. The title of a passage may be present in the first few sentences of the passage and/or be referred to multiple times in the passage. The title should be 1-5 words long.

Ex Input:
A Dakhma ( Persian : ; Avestan : lit . '' tower of silence '' ) , also called a Tower of Silence , is a circular , raised structure built by Zoroastrians for excarnation -- that is , for dead bodies to be exposed to carrion birds .

Ex Output:
Tower of Silence

Ex Input:
Bank of America Home Loans is the mortgage unit of Bank of America . In 2008 , Bank of America purchased the failing Countrywide Financial for $4.1 billion . In 2006 , Countrywide financed 20 % of all mortgages in the United States , at a value of about 3.5 % of United States GDP , a proportion greater than any other single mortgage lender .

Ex Output:
Bank of America Home Loans

Ex Input:
Gitlow v. New York , 268 U.S. 652 ( 1925 ) , was a decision by the Supreme Court of the United States holding that the Fourteenth Amendment to the United States Constitution had extended the reach of certain limitations on federal government authority set forth in the First Amendment -- specifically the provisions protecting freedom of speech and freedom of the press -- to the governments of the individual states . It was one of a series of Supreme Court cases that defined the scope of the First Amendment 's protection of free speech and established the standard to which a state or the federal government would be held when it criminalized speech or writing .

Ex Output:
Gitlow v. New York