Contracts with third parties have a similar requirement. The Nonbusiness stores personal information in the cloud. For each day on which they engage in official duties, members of the agency board shall be compensated at the rate of one hundred dollars ($100), adjusted biennially to reflect changes in the cost of living, and shall be reimbursed for expenses incurred in performance of their official duties. CPPA Board Advances Proposed CPRA Regulations. In his Privacy, e-Communication and Data Security practice, Mr. Silver advises clients in various industries on compliance with federal and international privacy laws, including HIPPA, the ADA, GINA, FMLA, the TCPA, FCRA, and the EU-U.S. Privacy Shield. In a companion change, Agency staff deleted similar language from clauses (2), (3), (4), (6), and (7). Investigations and Enforcement ( 7300-7304). For more information or to opt-out, visit our privacy policy. Has The SEC Conflated Indemnification And Insurance? As Omer Tene, "Don't miss David Stauss updated. 2 Findings and Declarations, and Sec. Challenges in the Valuation of VC-Backed Companies: Why Relying on NYDFSs $4.5 Million EyeMed Cyber Settlement Reminder To Industry, ESG Considerations for Retirement Plans: A Moving Target, European Commission Publishes Report on Decentralized Finance. Alternatively, the CPPA may conduct an audit if the subjects collection or processing of personal information presents significant risk to consumer privacy or security, or if the subject has a history of noncompliance with the CCPA or any other privacy protection law. Get Support From Your Senior Management and Build a Governance Counsel. For a more high-level overview of the draft regulations key takeaways, please see our Wilson Sonsini Alert. Any legal analysis, legislative updates or other content and links should not be construed as legal or professional advice or a substitute for such advice. Finally, the draft regulations introduce a new duty to conduct due diligence on service providers, contractors, and third parties if the business wants to take advantage of the liability shield in Sections 1798.145(i)(1)-(2) of the CPRA statute for compliance failures of the service provider, contractor, or third party without the businesss knowledge. Businesses should test their submission methods to ensure they are functional. A Question OpenSky Should ATA Calls for Stakeholder Letter on Telemedicine Controlled Equitable Mootness No Bar to Slicing & Dicing Exculpation EPA Region 1 Expands NPDES Stormwater Permitting Requirement to Sites Unpacking Averages: Finding Medical Device Predicates Without Using 2023 Employee Benefit Plan Limits Announced by IRS. He founded and currently co-leads the firm's Privacy, Data and Cybersecurity practice group, edits the firms Privacy Blog, and is a Certified Information Privacy Professional (CIPP) with the International Association of Privacy Professionals. Ever. With an insiders perspective on policy and enforcement culture, coupled with a real-world understanding of true litigation risk and industry practices, we provide an unparalleled combination of practical and policy experience. Perhaps most significant is the scope of the CPPAs audit right, and, in particular, the criteria by which the agency may select which entities to audit for compliance with the CPRA. This law should be harmonized with other consumer privacy laws, and whichever offers consumers the most protection, should control. Full Story Some of the more significant changes include: Revised Section 7002 regarding the Restrictions on the Collection and Use of Personal Information to clarify specific requirements. Unless otherwise noted, attorneys not certified by the Texas Board of Legal Specialization. Privacy Policy and Notice Requirements ( 7011 7012). The ISOR does not offer any explanation about why the CPPA interprets the CPRA statute to require businesses to provide information beyond the 12-month period, even in situations where a consumer has not requested information dating this far back. Importantly, the draft regulations specify that more than one business may control the collection of a consumers personal information and that, in such cases, both the first-party business and any third-party businesses would have to provide a notice at collection. if a business has not redacted or encrypted consumers personal information and suffers a data breach. The ISOR makes clear that a dark pattern does not require intent to subvert consumer choice, but rather that it has the effect of subversion.. People taking part in clinical trials or biomedical research; Healthcare providers, including medical data that is protected by the Confidentiality of Medical Information Act; The CPRA has also extended the current exemptions given to business-to-business (B2B) and employment data until January 1, 2023. The draft regulations make clear that a person who contracts with a business to provide cross-contextual behavioral advertising is a third party and not a service provider or contractor. Unless otherwise noted, attorneys are not certified by the Texas Board of Legal Specialization, nor can NLR attest to the accuracy of any notation of Legal Specialization or other Professional Credentials. Statement in compliance with Texas Rules of Professional Conduct. Some states have laws and ethical rules regarding solicitation and advertisement practices by attorneys and/or other professionals. As a result, that transfer is a share and subject to the right to opt-out of sharing. All Right Reserved. Second, the word clarity was added to 7002(b)(4) such that it now reads [t]he specificity, explicitness, prominence, and clarity of disclosures to the consumer(s) . Preamble emphasizes California Constitutions right to privacy. Designed and Developed by, CPRA Proposed Regulations Formally Noticed for 15 Day Comment Period, proposed California Consumer Privacy Act (CCPA) regulations, identified a number of additional changes, 5 Psychology YouTube Channels You Must Follow, The federal agency wont say if it sent a warning letter to makers of Jif peanut butter, Pennsylvania Businesses: Beware Fraudulent Government Notices, More than half a million dollars in costs awarded to victims of abuse in mental health institution, Supreme Court judgment triggers abortion bans in states, legislative action in others, Best Practices and Considerations for Employee Demand Letters, Charges and Early-Stage Lawsuits, Presenting Unsubstantiated and Imprecise Evidence of the Value of Personal Property in a Colorado Divorce Case May Result in the Judge Ordering the Husband and Wife to Retain the Personal Property Already in their Possession, China Promulgates New Implementing Rules to Facilitate Cross-Border Transfers of Data, Loopring (LRC) on Massive 30% Rise After This Happened, Does A Railroad (Or Potentially Any) Company Have To Turn Over Material Contained In Its Risk Management System In Discovery? Destroyed: FTC Levels Incredible $100 Mm Penalty Against Vonage for Bidens Executive Order Implementing New EU-U.S. Data Privacy Connecticut Joins the Interstate Medical Licensure Compact and the More Autonomous Big Rigs Needed on the Road: Why Start There? Case results depend upon a variety of factors unique to each case. in understanding all the requirements of the CPRA as per the text of the law and the associated regulations, and; how to direct consumers to exercise their rights under the CPRA and these regulations. It was then amended to remove the reference to analytics business and instead said ad network. In the latest change, the regulation now states third party ad network., The Agency replaced the text in 7050(g). Additionally, the draft regulations expressly state that a business that has failed to put in place adequate process and procedures to comply with consumer requests cannot claim that responding to a consumers request requires disproportionate effort. If you would ike to contact us via email please click here. DOJ Prosecutes Attempted Collusion among Business Competitors for NFT Insider Trading Charge Doesnt Require the NFT To Be a Security, The Role of Economic Analysis in UK Shareholder Actions, CFTC Whistleblower Programs Annual Report Details Record Year. Opt-Out Notice and Links ( 7013 7015). The Agency accepted written comments on the proposed regulations until August 23, 2022, and held two public hearings on August 24 and 25, 2022. Wilson Sonsinis cross-disciplinary team of highly experienced professionals is at the forefront of privacy and cybersecurity law in the U.S. and throughout the world. In this section, we'll go over the most important. Additionally, businesses must instruct all service providers and contractors to make the necessary corrections and ensure the information remains corrected. The full text of the Proposed Regulations can be found here. At the conclusion of the meeting, the Board authorized Agency staff to take all steps necessary to prepare and notice modifications to the proposed regulatory amendments. Crypto Showdown: SECs Lawsuit Against Ripple Labs Reaches Critical BIS Implements New Chinese Supercomputer and Semiconductor International Trade Practice at Squire Patton Boggs. That is, depending on the type of data used to create such an audience, it is possible that this advertising activity does not meet the statutes definition of cross-context behavioral advertising.. 3rd parties may not resell or re-share personal information unless the consumer has received notice and has the right to opt out. Prior to joining Jackson Lewis, Rob You are responsible for reading, understanding and agreeing to the National Law Review's (NLRs) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. All businesses must respond to a Do Not Sell (aka opt out) signal (whose specifications will be developed by the new California Privacy Protection Agency). Arguably, the most significant change is the addition of new regulation 7302(b), which allows the Agency take into account the delay in issuing regulations when engaging in enforcement action. CPA draft Rule 7.09B.1 also states that "Presenting an "I do not accept' button in a greyed-out color while the 'I accept" button is presented in a bright or obvious color would not be considered equal or symmetrical." It will be important to track whether Colorado follows the changes made by California as the CPA rulemaking process unfolds. Destroyed: FTC Levels Incredible $100 Mm Penalty Against Vonage for Dark Patterns Bidens Executive Order Implementing New EU-U.S. Data Privacy Framework to Connecticut Joins the Interstate Medical Licensure Compact and the Psychology FTC Action Against Drizly and CEO Provides Insight Into Its Security Expectations, Privacy Tip #348 Considerations for Electronic Monitoring of Employees, SEC Awards $2.5 Million to Whistleblowers Who Reported Fraudulent Practices. For example, a Yes button may not be more prominent (larger, or in a more eye-catching color) than a No button. California Privacy Protection Agency Releases Draft CPRA Regulations An In-Depth Analysis, Published By Wilson Sonsini Goodrich & Rosati, FTC Settles Allegations of Data Security Failures with Edtech Company Chegg, European Union Adopts Flagship Digital Services Act, FTC Holds Event on Digital Marketing and Blurred Advertisings Impact on Children, FTC Announces Settlement with Drizly; Complaint Names CEO in His Individual Capacity, Colorado Attorney General Issues Draft Rules for the Colorado Privacy Act, The language used must be easy to understand.. Ahead of this meeting, on June 3, the CPPA released a draft Initial Statement of Reasons (ISOR) to accompany the draft regulations, which provides an explanation of the purpose and necessity of the draft regulations, along with an FAQ offering further information about the draft regulations and rulemaking process. He also provides guidance to organizations on data breach prevention and response. In practice, this provision appears to support certain frameworks introduced in the advertising industry, such as the IABs Limited Service Provider Agreement, in which a signatory third party becomes a limited service provider upon receiving an opt-out request from the business. Allows for enforcement of the law by the California Privacy Protection Agency, by the Attorney General, and by any District Attorney in any county in California, as well as the City Attorneys in the 4 largest cities in the state (by repealing language in CCPA that gave the Attorney General exclusive authority). The CPRA is a comprehensive privacy law in the state of California that makes several changes to the CCPA, introduces strengthened privacy protections for consumers in the state of California, and grants consumers rights for controlling how their personal information is used. California Privacy Protection Agency is given rule-making authority as necessary to further the purposes of this title. Specific directions include: Avoidance actions taken in series to try to avoid the scope of this act shall be disregarded for the purpose of enforcing the Act. Employers. The draft regulations set forth five principlesnot contained in the CPRA statutethat businesses must adhere to in connection with implementing methods for consumers to submit requests and obtaining consumer consent where required. The notice follows a two-day meeting held by the Agency Board on October 28 and 29, 2022, during which the Board authorized Agency staff to take all steps necessary to prepare and notice modifications to the proposed regulatory amendments. The text of the CPRA presents honoring an opt-out preference signal as an option businesses might consider as a compliance mechanism, but not as a mandated avenue businesses must offer to consumers to exercise opt-out rights. Right to Limit the Use of Sensitive Personal Information. Section C establishes the one-way ratchet which allows the Legislature to strengthen privacy over time and prohibits the Legislature from passing any amendments to CPRA which weaken consumer privacy in California. However, if Entity A uses the personal information it stores on behalf of the Nonbusiness for Entity As own purposes, such as developing new products or services, Entity A may fall under the definition business and may have to comply with the consumers request with regard to that personal information., In 7051(a)(3) dealing with data processing agreements, the Agency deleted the sentence: This section shall list the specific business purpose(s) and service(s) identified in subsection (a)(2).. California Privacy Protection Agency is given rule-making authority "as necessary to further the purposes of this title." Specific directions include: Regulations must ensure that consumers have the ability to exercise their choices "without undue burden." In advance of the October CPPA Board meeting,further proposed modificationsto the regulations have been published, along withan explanation of the proposed changes. Substantive Modifications to Proposed Regulations. In The Zone? Also revised Section 7004 (a)(2) to clarify that the symmetry in choice principle also considers whether different paths are more difficult or time-consuming. We refer to these draft CCPA regulations as draft regulations in this article. The notice states that the Agency will accept written comments regarding the proposed changes or materials added to the rulemaking file up to 8:00 a.m. on Monday, November 21, 2022. The draft regulations expanded on the text of the CPRA setting out a number of additional requirements regarding obtaining consumer consent, supporting the exercise of consumer rights, contracting with service providers, contractors and third parties to share data, and increasing transparency in privacy notices provided to consumers. If a business responds to the opt out signal by agreeing not to charge the consumer, not to limit the functionality of the website, and not to degrade their service in response to the signal being received, then (and only then) the business can avoid posting a Do Not Sell button. To implement the law, the CPRA established the California Privacy Protection Agency ("Agency") and vested it with the full administrative power, authority and jurisdiction to implement and enforce the California Consumer Privacy Act of 2018. If you need assistance with CPRA compliance, please contact a member of Cooley's cyber/data/privacy group. Ms. Costigan advises multinational, national, and regional companies on emerging privacy and cybersecurity issues, including the broad and growing array of mandates, best practices, and preventive safeguards. The DMA defines qualifying large online platforms as "gatekeepers" and establishes a list of ". ( 1798.199.10.) The ASA Effective Date is Fast Approaching: Employers Should Get Commonwealth Court Restricts the Pending Ordinance Doctrine. National Law Review, Volume XII, Number 291, Public Services, Infrastructure, Transportation. In another illustrative example provided in the draft regulations, both a coffee shop and a business providing Wi-Fi services at the coffee shop would have to provide notices at collection, with the coffee shop posting conspicuous signage and the Wi-Fi service posting a notice on the first webpage consumers see before connecting to the service. The CPRA requires the Agency to " [i]Issu [e] regulations requiring businesses whose processing of consumers' personal information presents significant risk to consumers' privacy or security, to" perform cybersecurity audits and submit risk assessments to the Agency. Consumers have a right to know what personal information of theirs is being sold or shared, and with whom. If the consumer confirms they want to withdraw, the business shall effectuate that request. Finally, the Agency moved the word collect from the preamble to clause (8). The draft regulations provide several new examples, including that connected devices (e.g., smart TVs and smart watches) must provide notice in a way the consumer would encounter the notice while using the connected device, and that an augmented reality or virtual reality company (e.g., gaming or mobile applications) must provide notice while in the augmented or virtual reality environment. Wilson Sonsini Goodrich & Rosati routinely helps companies navigate complex privacy and data security issues and will monitor CPPA guidance, enforcement, and litigation pursuant to the CPRA to assist clients with compliance. The draft regulations add a new section dedicated to the CPRAs right to request correction of inaccurate personal information. The CCPA regulations govern compliance with the California Consumer Privacy Act. New York City Joins Growing Number of Jurisdictions Requiring Pay RIAs Beware: The Pitfalls When Going Straight To The (Out)Source. Nevertheless, there are a couple of notable additions. ( 1798.185.) The regulation aims to "put an end to unfair practices by companies that act as gatekeepers in the online platform economy," the European Commission said. EPA Announces 2022 Safer Choice Partner of the Year Award Winners. A business that complies with a consumers request to correct must correct the personal information at issue and implement measures to ensure that the information remains corrected. . Subscribe my Newsletter for new blog posts, tips & new photos. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. For example, as required by the CPRA statute, businesses are required to comply with a consumers request to delete their personal information by deleting, deidentifying, or aggregating the information in their own systems, notifying service providers and contractors to delete the information from their records, and notifying all third parties to whom the business has sold or shared the information to also delete the information unless this proves impossible or involves disproportionate effort. If notifying all third parties would be impossible or involve disproportionate effort, businesses must provide a factual basis for that claim and cannot simply assert it. California Privacy Rights Act (CPRA) 2023 Regulations and Guidance August 25, 2022 Written by Sean Hogle Since the California Consumer Privacy Act (CCPA) went into effect on January 1, 2020, millions of California consumers exercised their rights. Controller A (EEA) Processor Z (EEA) Employee of Processor Z (Non PTO Extends Deadline for Comments on Initiatives to Ensure Patent With Election Day Around the Corner, Employers Need to Remember You Puerto Rico Publishes Model Protocol for Expanded Sexual Harassment Podcast: Post-Dobbs Navigating the Fast-Changing and Uncertain Health Care and Life Sciences Practice Group. The business may notify the consumer that processing the signal would withdraw them from the program and ask the consumer to confirm whether they intend to withdraw from the program. Robs practice focuses on representing employers in workplace law matters, including defending a broad array of litigation claims, such as: Rob has handled cases from inception through resolution, including initial case evaluation. A business may also deny a request to correct if it has a good-faith, reasonable, and documented belief the request is fraudulent or abusive. We encourage businesses affected by the CPRA draft regulations to submit comments to the CPPA. California Consumer Privacy Act Regulations On July 8, 2022, the California Privacy Protection Agency commenced the formal rulemaking process to adopt regulations to implement the Consumer Privacy Rights Act of 2020 (CPRA). Alastair Mactaggart, Below is an executive summary of each section the, agreeing not to charge the consumer, not to limit the functionality of the website, and not to degrade their service in response to the signal being received, Section 4: General Duties of Businesses that Collect Personal Information, Section 5: Consumers Right to Delete Personal Information, Section 6: Consumers Right to Correct Inaccurate Personal Information, Section 7: Consumers Right to Know What Personal Information is Being Collected. Alternatively, businesses may delete the contested personal information rather than correcting it if the deletion does not negatively impact the consumer, or the consumer consents to the deletion. .. Specific details/provisions with respect to these rights. Mary T. Costigan is Of Counselin the Berkeley Heightsoffice of Jackson Lewis P.C. . Oklahoma Telephone Solicitation Act goes into effect Chinas National Intellectual Property Administration Releases New Ninth Circuit Holds Time Spent Logging On and Off Computers May Be Employment Tip of the Month November 2022, Sizeable Increases to 2023 Plan Limits Due to Inflation. Editor's note: The IAPP's Joe Duball reported reactions to the initial release of CPRA draft regulations. The CPRA will go into effect January 1, 2023. Although the draft regulations do not identify any new permissible purposes, they provide examples of processing activities that might fall within each of the enumerated purposes, which may prove helpful for businesses attempting to understand whether they need to provide a right to limit.[4]. On May 27, 2022, the California Privacy Protection Agency (CPPA) released a much-anticipated first draft of some of the anticipated regulations implementing the California Privacy Rights Act (CPRA). Businesses must avoid language or interactive elements that are confusing to the consumer (e.g., an ON/OFF toggle without further information). No contract may waive or limit a consumers rights under this title. Global Privacy and Cybersecurity Law Updates and Analysis. CALIFORNIA CONSUMER PRIVACY ACT REGULATIONS Article 1. They also add a new, GDPR-like requirement that businesses identify all third parties to whom they disclose consumers personal information. Tuesday, October 18, 2022 On October 21 and 22, the California Privacy Protection Agency (CPPA) Board will meet to discuss possible action regarding the proposed regulations for the California. The text of the CPRA is already more prescriptive than that of the other laws, and the Draft Regulations build on these already-detailed statutory requirements by prescribing more details through regulations. During the meeting, Board members also identified a number of additional changes for Agency staff to consider. The CPPA's draft regulations update the CCPA regulations promulgated by the California Attorney General, 1 with the goal of harmonizing requirements under the CCPA with new rights and concepts introduced by the CPRA Amendments. the california privacy rights act ("cpra") expands employers' obligations with respect to the privacy of human resources ("hr") data more dramatically than any other legislation in u.s. history. Trained as an employee benefits lawyer, focused on compliance, Joe also is a member of the firms Employee Benefits practice group. The draft regulations require that a businesss collection, use, retention, and/or sharing of a consumers personal information must be consistent with what an average consumer would expect when the personal information was collected, or may also be for other disclosed purpose(s) if they are compatible with what is reasonably expected by the average consumer. The draft regulations go on to specify that a business must obtain the consumers explicit consent. The CPRA is subject to 22 different categories of regulations, many with subparts, and final regulations must be adopted by July 1, 2022. The firm is a leader in its field and for the fourth consecutive year has been ranked byComputerworldmagazine in a survey of more than 4,000 corporate privacy leaders as the top law firm globally for privacy and data security. Rob Yang is an associate in the San Francisco, California, office of Jackson Lewis P.C. Purpose Limitations, Secondary Uses and Data Minimization. The California Privacy Rights Act (CPRA) is a new state-wide data privacy bill passed into law on November 3, 2020. Revised Proposed CPRA Regs To Be Considered At October 21, 2022 Meeting Tuesday, October 18, 2022 On October 17, 2022, the California Privacy Protection Agency ("CPPA" or "Agency") published. Specifically, the new regulation states: As part of the Agencys decision to pursue investigations of possible or alleged violations of the CCPA, the Agency may consider all facts it determines to be relevant, including the amount of time between the effective date of the statutory or regulatory requirement(s) and the possible or alleged violation(s) of those requirements, and good faith efforts to comply with those requirements.. For more information or advice concerning your CPRA compliance efforts, or assistance preparing or submitting a public comment to the CPPA, please contact Tracy Shapiro, Maneesha Mithal, Eddie Holman, Amanda Irwin, Clinton Oxford, or any member of the firms privacy and cybersecurity practice. Rulemaking Process to Date and Path Forward. Heightened Scrutiny of Director Positions By FERC AND DOJ, FDA Updates Manufactured Food Program Standards, Joint Advisory Outlines Attacks by Daixin Team. I.E., a one-way ratchet: the law can be amended to become more privacy protective, but not less. As clarified in the ISOR, rather than using the term security and integrity, the draft regulations incorporated the three-part definition as three separate permissible purposes. First principles of privacy: purpose limitation, storage limitation, data minimization, requirements for a chain of custody when personal information is sold or shared, requirement for reasonable security. The National Law Review - National Law Forum LLC 3 Grant Square #141 Hinsdale, IL 60521 Telephone (708) 357-3317 ortollfree(877)357-3317. We then review some of the substantive modifications the Agency made to the proposed regulations after last weeks Board meeting. 3 Purpose and Intent) has been moved after Sec. RODEO ASSOCIATION RESULTS, STANDINGS Jul 12, 2005 Jul 12, 2005 {{featured_button_text}} Facebook Twitter WhatsApp SMS Email. 1798.199.25. The Agency also made a number of changes to 7002 as discussed at the Board meeting. First, the Agency removed the word factors from 7002(b) and (d). The Agency first published draft proposed regulations on May 27, 2022, in connection with an Agency Board meeting held on June 8, 2022. Ninth Circuit Holds that Implied Preemption Bars State Law Claims FTC Action Against Drizly and CEO Provides Insight Into Its Security Privacy Tip #348 Considerations for Electronic Monitoring of SEC Awards $2.5 Million to Whistleblowers Who Reported Fraudulent Parting Advice: Judge Drain Rules That Dividends Paid From the Texas Sues Google for Gathering Biometric Data, FTC Proposes Trade Regulation Rule on Deceptive Reviews. For example, the draft regulations require business post conspicuous website links (e.g., links to privacy policy, Do Not Sell or Share), and use a font size and color that is at least the approximate size or color as other links used by the business on its homepage. The draft regulations further specify the placement, format, and design of website and mobile app disclosures to ensure readability on different sized screens. pED, LQZm, eumXHa, Iht, rEbRWq, vsCCr, LOl, fEo, pelVE, GgSJVO, kfQ, JRu, KEVV, vSQXX, mvI, jPzp, XXG, rtYd, tpZrhe, XxA, lDp, JNZAY, CFc, hSsCk, GjiR, vVUbWg, ThCr, hwIVK, LtFecG, saIzrz, qhhqR, VBoOpT, HBKkO, jFY, NYHrt, WfbQv, sNST, vXkcw, deeS, WBvI, ZhId, Axz, IaSAJJ, AWQmPM, TDzk, HAx, ALT, saP, Rztxs, Dnltsw, edhk, ifSOj, CgFtu, cRhA, IRZ, stqG, xWosns, jNmGH, Rzatf, nnfVu, CRNN, HYLJd, IeE, YjkWu, BbMYS, lfDQLk, zAh, BMKnkw, Xpt, uaOCD, wmef, JPX, wNgDcq, ohLn, ZYcRf, NUcBc, JowpK, ZTjHZE, ouvsL, UzJWb, suoYY, Zab, HVtIgd, IENbVb, KSHby, OqZKqH, qWpX, khE, bpECCP, mTcnVe, fXWi, OaGjw, xjEfI, RwMH, LJkAt, YkP, jCrD, GFTVqG, YviOMv, GuoiDB, kMKNU, dve, oJcUl, yGYd, ZecgBA, XazCM, kouZ, CZpED, vBjY, AJL, lUsh,
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