On 15 March 2019, a Facebook Live video was broadcast from Christchurch, New Zealand, documenting a terror attack which resulted in the death of fifty-one people. This attack highlighted a weakness in social media protections and a gap in legislation globally. In response, the Criminal Code Amendment (Sharing of Abhorrent Violent Material) Act 2019 (Cth) seeks to make internet service and social media providers accountable for the removal of abhorrent and violent content. This legislation sent waves through the international community, attracting criticisms for its fast adoption, perceived unrealistic obligations and harsh penalties, as well as its broad extraterritorial reach. This article will explore these criticisms. It asks, how is the Act exercising extraterritorial jurisdiction? Is there an unrealistic burden created? And if there is a breach, who will be charged? The article concludes that if these challenges are not adequately addressed, the Act will not only fail to achieve its goal of reducing the accessibility of abhorrent violent material, but will also pose a serious threat to the protection of human rights.
{"title":"The Sharing of Abhorrent Violent Materials Act: The realities and implications of Australia’s new laws regulating social media companies","authors":"Jasmine Valcic","doi":"10.53300/001c.19107","DOIUrl":"https://doi.org/10.53300/001c.19107","url":null,"abstract":"On 15 March 2019, a Facebook Live video was broadcast from Christchurch, New Zealand, documenting a terror attack which resulted in the death of fifty-one people. This attack highlighted a weakness in social media protections and a gap in legislation globally. In response, the Criminal Code Amendment (Sharing of Abhorrent Violent Material) Act 2019 (Cth) seeks to make internet service and social media providers accountable for the removal of abhorrent and violent content. This legislation sent waves through the international community, attracting criticisms for its fast adoption, perceived unrealistic obligations and harsh penalties, as well as its broad extraterritorial reach. This article will explore these criticisms. It asks, how is the Act exercising extraterritorial jurisdiction? Is there an unrealistic burden created? And if there is a breach, who will be charged? The article concludes that if these challenges are not adequately addressed, the Act will not only fail to achieve its goal of reducing the accessibility of abhorrent violent material, but will also pose a serious threat to the protection of human rights.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2021-02-04","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"43067228","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Natural law theories hold that human action is oriented towards certain intrinsic goods and governed by practical principles accessible to us by virtue of our nature. These goods and principles make up the content of natural law. This essay argues that both the content of natural law and our understanding of its requirements evolve throughout human history. This represents a diachronic, rather than synchronic, understanding of natural law. This perspective is contrasted with the ‘new natural law theory’ of Germain Grisez and John Finnis, which depicts natural law as timeless and unchanging. Finnis seems to think that natural law does not change because it exists in the mind of God; however, a belief in God as the source of natural law is equally consistent with a diachronic perspective. I defend this view through reference to the writings of Thomas Aquinas and the structure of the biblical narrative.
{"title":"Is Natural Law Timeless?","authors":"J. Crowe","doi":"10.53300/001c.18651","DOIUrl":"https://doi.org/10.53300/001c.18651","url":null,"abstract":"Natural law theories hold that human action is oriented towards certain intrinsic goods and governed by practical principles accessible to us by virtue of our nature. These goods and principles make up the content of natural law. This essay argues that both the content of natural law and our understanding of its requirements evolve throughout human history. This represents a diachronic, rather than synchronic, understanding of natural law. This perspective is contrasted with the ‘new natural law theory’ of Germain Grisez and John Finnis, which depicts natural law as timeless and unchanging. Finnis seems to think that natural law does not change because it exists in the mind of God; however, a belief in God as the source of natural law is equally consistent with a diachronic perspective. I defend this view through reference to the writings of Thomas Aquinas and the structure of the biblical narrative.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2021-01-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45258562","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article presents a novel way of prosecuting wartime environmental damage committed by non-state parties to the Rome Statute at the International Criminal Court. The current legal framework applicable during armed conflicts has many gaps and weaknesses, leaving the environment as a silent victim. The stringent threshold that must be met before environmental damage is prohibited under international humanitarian law has failed to offer any real protection, particularly in non-international armed conflicts, despite their growing prevalence. Furthermore, destruction of the environment has not materialised as a distinct crime in international law; rather, it is treated as a material element or underlying act of other crimes in the Rome Statute. Where states involved in armed conflicts are not party to the Rome Statute, individuals can seemingly enjoy impunity for serious environmental harm arising during the conflict. This article will illustrate how individuals from non-state parties could face criminal responsibility for environmental crimes where one element of the crime, namely environmental damage, is committed on the territory of a state party. This offers a novel, albeit limited route for addressing the gaps in the current law.
{"title":"Prosecution of Wartime Environmental Damage by Non-State Parties at the International Criminal Court","authors":"J. Schaffer","doi":"10.53300/001c.17931","DOIUrl":"https://doi.org/10.53300/001c.17931","url":null,"abstract":"This article presents a novel way of prosecuting wartime environmental damage committed by non-state parties to the Rome Statute at the International Criminal Court. The current legal framework applicable during armed conflicts has many gaps and weaknesses, leaving the environment as a silent victim. The stringent threshold that must be met before environmental damage is prohibited under international humanitarian law has failed to offer any real protection, particularly in non-international armed conflicts, despite their growing prevalence. Furthermore, destruction of the environment has not materialised as a distinct crime in international law; rather, it is treated as a material element or underlying act of other crimes in the Rome Statute. Where states involved in armed conflicts are not party to the Rome Statute, individuals can seemingly enjoy impunity for serious environmental harm arising during the conflict. This article will illustrate how individuals from non-state parties could face criminal responsibility for environmental crimes where one element of the crime, namely environmental damage, is committed on the territory of a state party. This offers a novel, albeit limited route for addressing the gaps in the current law.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-11-05","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"49629536","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article examines law firms’ need to replace the billable hour with alternative fee arrangements and discusses the ethical and managerial hurdles they will face when making this transition. It analyses the characteristics of client demand for legal pricing models and determines that client demand can only be satisfied by firms that implement alternative fee arrangements. This proposition is supported by research which suggests that alternative fee arrangements optimise firm profitability and enable firms to retain their clients whose bargaining power has been enlarged by technology. Finally, this article provides practical guidance on factors firms must consider when adopting alternative fee arrangements, specifically legal ethics issues and managerial challenges that must be addressed when implementing disruptive innovations. Ultimately, the author intends to highlight the industry-wide misalignment between client demand and the billable hour, and persuade firms to optimise their profitability and chances of survival by adopting alternative fee arrangements.
{"title":"Out with the Old, in with the Alternative: A Critical Examination of How Lawyers Can Use Alternative Fee Arrangements to Satisfy Increasingly Powerful Clients","authors":"Joshua Yan","doi":"10.53300/001C.17541","DOIUrl":"https://doi.org/10.53300/001C.17541","url":null,"abstract":"This article examines law firms’ need to replace the billable hour with alternative fee arrangements and discusses the ethical and managerial hurdles they will face when making this transition. It analyses the characteristics of client demand for legal pricing models and determines that client demand can only be satisfied by firms that implement alternative fee arrangements. This proposition is supported by research which suggests that alternative fee arrangements optimise firm profitability and enable firms to retain their clients whose bargaining power has been enlarged by technology. Finally, this article provides practical guidance on factors firms must consider when adopting alternative fee arrangements, specifically legal ethics issues and managerial challenges that must be addressed when implementing disruptive innovations. Ultimately, the author intends to highlight the industry-wide misalignment between client demand and the billable hour, and persuade firms to optimise their profitability and chances of survival by adopting alternative fee arrangements.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-10-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46122567","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
{"title":"Pedra Branca: Story of the Unheard Cases by S Jayakumar, Tommy Koh and Lionel Yee","authors":"Jing Zhi Wong","doi":"10.53300/001c.13473","DOIUrl":"https://doi.org/10.53300/001c.13473","url":null,"abstract":"","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":"1 1","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-06-25","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"43431023","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The commencement of the Human Rights Act 2019 (Qld) on 1 January 2020 heralded a new era in public sector decision-making in Queensland, and the community has high expectations of a regime that obliges the three arms of government to consider people’s human rights when performing their functions. How do we achieve the Act’s objective of building a genuine human rights culture within the public sector? How can the Act make a real difference to the lives of those people most in need of human rights protection? This article, written by the Queensland Human Rights Commissioner, addresses these questions and provides an overview of the Queensland Human Rights Commission’s plan for the successful implementation of the Act in Queensland. The article is an edited version of a Twilight Seminar presented to the Faculty of Law at Bond University on 6 February 2020.
{"title":"Making Rights Real: The Promise and Potential Pitfalls of the Human Rights Act 2019 (Qld)","authors":"S. McDougall","doi":"10.53300/001C.13243","DOIUrl":"https://doi.org/10.53300/001C.13243","url":null,"abstract":"The commencement of the Human Rights Act 2019 (Qld) on 1 January 2020 heralded a new era in public sector decision-making in Queensland, and the community has high expectations of a regime that obliges the three arms of government to consider people’s human rights when performing their functions. \u0000\u0000How do we achieve the Act’s objective of building a genuine human rights culture within the public sector? How can the Act make a real difference to the lives of those people most in need of human rights protection? \u0000\u0000This article, written by the Queensland Human Rights Commissioner, addresses these questions and provides an overview of the Queensland Human Rights Commission’s plan for the successful implementation of the Act in Queensland. \u0000\u0000The article is an edited version of a Twilight Seminar presented to the Faculty of Law at Bond University on 6 February 2020.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-06-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48522761","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The United States, via the Online Copyright Infringement Liability Limitation Act, provides a safe harbour from copyright liability for online service providers. This safe harbour has been described as one of the laws that ‘built’ Silicon Valley. Despite the experience in the United States, Australia has not extended its own copyright safe harbour provisions to online service providers. This article seeks to understand the underlying reasons for such different approaches by adopting a comparative analysis methodology. After reviewing the legislative history and case law in the United States and in Australia, this article presents evidence suggesting copyright safe harbours support innovation. As such, this article contends there is a need to reconsider the scope of Australia’s copyright safe harbour. However, it is also demonstrated that the approach taken by the United States has not been without its flaws and, therefore, rather than a complete adoption of this position, Australia should consider a more ‘balanced’ approach—namely, extending the copyright safe harbour, while also introducing amendments to bring clarity and balance to the safe harbour provisions.
{"title":"A Quiet Harbour: Finding a Balanced Approach to the Copyright Liability of Online Service Providers","authors":"S. Alexander","doi":"10.53300/001C.11885","DOIUrl":"https://doi.org/10.53300/001C.11885","url":null,"abstract":"The United States, via the Online Copyright Infringement Liability Limitation Act, provides a safe harbour from copyright liability for online service providers. This safe harbour has been described as one of the laws that ‘built’ Silicon Valley. Despite the experience in the United States, Australia has not extended its own copyright safe harbour provisions to online service providers. This article seeks to understand the underlying reasons for such different approaches by adopting a comparative analysis methodology. After reviewing the legislative history and case law in the United States and in Australia, this article presents evidence suggesting copyright safe harbours support innovation. As such, this article contends there is a need to reconsider the scope of Australia’s copyright safe harbour. However, it is also demonstrated that the approach taken by the United States has not been without its flaws and, therefore, rather than a complete adoption of this position, Australia should consider a more ‘balanced’ approach—namely, extending the copyright safe harbour, while also introducing amendments to bring clarity and balance to the safe harbour provisions.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-02-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45240592","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In International Human Rights Law, the International Covenant on Economic, Social and Cultural Rights defines the right to health as the right of everyone to the enjoyment of the highest attainable standard of physical and mental health. Millions of people use traditional and complementary medicine (‘T&CM’) to realise their right to health. This article analyses whether the scope of the right to health includes T&CM. Although not expressly provided for in the legally binding treaties, there is substantial evidence in international law to infer a right to T&CM as part of the right to health. The article analyses some of the failings of T&CM policy and regulation in Australia and offers a draft convention article in the recently proposed Framework Convention on Global Health (‘FCGH’) which codifies an express and legally binding right to T&CM. This would assist States Parties address the policy, legislative and regulatory gaps that currently exist regarding T&CM. A clear duty imposed on States Parties would ensure everyone including indigenous peoples have access to quality, safe, culturally appropriate, and effective T&CM health care facilities, goods and services. States Parties including the Australian Government might then more effectively harness the potential contribution of T&CM, and fundamentally reorientate health systems towards significantly more cost-effective wellness and people centred health care in realising the right to health for all.
{"title":"Evolution and Complementarity? Traditional and Complementary Medicine as Part of the International Human Rights Law Right to Health","authors":"Angela Doolan, G. Carne","doi":"10.53300/001C.11881","DOIUrl":"https://doi.org/10.53300/001C.11881","url":null,"abstract":"In International Human Rights Law, the International Covenant on Economic, Social and Cultural Rights defines the right to health as the right of everyone to the enjoyment of the highest attainable standard of physical and mental health. Millions of people use traditional and complementary medicine (‘T&CM’) to realise their right to health. This article analyses whether the scope of the right to health includes T&CM. Although not expressly provided for in the legally binding treaties, there is substantial evidence in international law to infer a right to T&CM as part of the right to health. The article analyses some of the failings of T&CM policy and regulation in Australia and offers a draft convention article in the recently proposed Framework Convention on Global Health (‘FCGH’) which codifies an express and legally binding right to T&CM. This would assist States Parties address the policy, legislative and regulatory gaps that currently exist regarding T&CM. A clear duty imposed on States Parties would ensure everyone including indigenous peoples have access to quality, safe, culturally appropriate, and effective T&CM health care facilities, goods and services. States Parties including the Australian Government might then more effectively harness the potential contribution of T&CM, and fundamentally reorientate health systems towards significantly more cost-effective wellness and people centred health care in realising the right to health for all.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-02-06","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48187471","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The Australian Financial Services Reform Act 2001 (Cth) requires that licenced banking and financial services providers establish internal dispute resolution (‘IDR’) systems complying with requirements promulgated by the Australian Securities and Investments Commission (‘ASIC’). In addition, licence holders are required to be members of an ASIC approved External Dispute Resolution (‘EDR’) scheme so that if a complaint is not resolved following the use of internal mechanisms, an external dispute resolution facility is available for most banking consumers. In late 2018, a new EDR body was established, the Australian Financial Complaints Authority (‘AFCA’), to deal with external complaints. The 2018 Royal Commission into the banking and finance sector uncovered significant issues in terms of the banking and financial sector and raised a number of serious concerns that were largely linked to how consumers contracted with banks and other organisations however information about existing complaint handling arrangements was limited. In particular, there was little demographic information about consumers who use IDR and EDR arrangements or what factors may be relevant in terms of the settlement of complaints and disputes. In this regard, currently sections 912A(1)(g), (2) of the Corporations Act direct the form of AFSL holders’ IDR and EDR systems, but they do not impose any obligations on AFSL holders in terms of conduct when providing the systems. In terms of consumers more generally, it is unclear how many consumers could be classified as ‘vulnerable’ and may settle a dispute on less favourable terms because the impact of proceeding may place them in an even more disadvantageous position. It is suggested that better reporting in relation to IDR and EDR activity together with targeted independent advocacy services and training of relevant staff in respect of the Australian Consumer Law could assist consumers and enable more effective reporting of misconduct issues.
{"title":"Treating Vulnerable Consumers ‘Fairly’ When They Make a Complaint About Banking or Finance in Australia","authors":"Tania Sourdin, Mirella Atherton","doi":"10.53300/001c.11636","DOIUrl":"https://doi.org/10.53300/001c.11636","url":null,"abstract":"The Australian Financial Services Reform Act 2001 (Cth) requires that licenced banking and financial services providers establish internal dispute resolution (‘IDR’) systems complying with requirements promulgated by the Australian Securities and Investments Commission (‘ASIC’). In addition, licence holders are required to be members of an ASIC approved External Dispute Resolution (‘EDR’) scheme so that if a complaint is not resolved following the use of internal mechanisms, an external dispute resolution facility is available for most banking consumers. In late 2018, a new EDR body was established, the Australian Financial Complaints Authority (‘AFCA’), to deal with external complaints. The 2018 Royal Commission into the banking and finance sector uncovered significant issues in terms of the banking and financial sector and raised a number of serious concerns that were largely linked to how consumers contracted with banks and other organisations however information about existing complaint handling arrangements was limited. In particular, there was little demographic information about consumers who use IDR and EDR arrangements or what factors may be relevant in terms of the settlement of complaints and disputes. In this regard, currently sections 912A(1)(g), (2) of the Corporations Act direct the form of AFSL holders’ IDR and EDR systems, but they do not impose any obligations on AFSL holders in terms of conduct when providing the systems. In terms of consumers more generally, it is unclear how many consumers could be classified as ‘vulnerable’ and may settle a dispute on less favourable terms because the impact of proceeding may place them in an even more disadvantageous position. It is suggested that better reporting in relation to IDR and EDR activity together with targeted independent advocacy services and training of relevant staff in respect of the Australian Consumer Law could assist consumers and enable more effective reporting of misconduct issues.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-01-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44192363","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article examines what differences there are, if any, between the rights and powers of a trustee. Although these terms are commonly applied to distinguish between various aspects of trusteeship, there is no clear explanation of the basis of this taxonomy. This article argues that there is no conceptual difference between these two terms, and that they should merely be seen as labels of convenience and convention. As a result, the law should be understood as giving trustees a range of abilities, with there being no principled difference between what are commonly called rights and powers. This conclusion not only answers an unresolved taxonomical issue, but may also have implications for statutory interpretation and the constraints that trustees have when they exercise functions vested in them.
{"title":"Trustee Rights and Powers: A Taxonomical Analysis","authors":"Chris T S Chiam","doi":"10.53300/001C.11637","DOIUrl":"https://doi.org/10.53300/001C.11637","url":null,"abstract":"This article examines what differences there are, if any, between the rights and powers of a trustee. Although these terms are commonly applied to distinguish between various aspects of trusteeship, there is no clear explanation of the basis of this taxonomy. This article argues that there is no conceptual difference between these two terms, and that they should merely be seen as labels of convenience and convention. As a result, the law should be understood as giving trustees a range of abilities, with there being no principled difference between what are commonly called rights and powers. This conclusion not only answers an unresolved taxonomical issue, but may also have implications for statutory interpretation and the constraints that trustees have when they exercise functions vested in them.","PeriodicalId":33279,"journal":{"name":"Bond Law Review","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2020-01-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44911338","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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