Expectations for Antitrust and the FTC

good afternoon thank you for joining us today at the Mayflower and welcome to all of you tuning in via the live stream I'm Nate casmer vice president and director of the practice groups for the federal Society our program today is sponsored by the federal society's corporations Securities and antitrust Practice Group our thanks as well to the leadership of that group particularly our executive uh committee co-chair swana Gans and uh Dina Kelly who was instrumental in putting together this event uh this program is really a continuation of a series of great Federal Society anti-rust Fireside Chats which we've had over the last two years uh we've been pleased to host officials from current and uh former administrations and proudly feature a wide range of views next month we are planning our next uh lunch and Fireside conversation with new FTC commissioner Melissa Holio on May 21st here at the Mayflower for more info and to register for that event please visit our website fed.org today we are excited to host uh this great conversation between former FTC commissioner Christine Wilson and Adam Cella thank you both for your kindness and joining us for this discussion today our guest bios are provided for you all uh in full on our website uh but let me quickly introduce Adam and hand over the program to him uh when I was looking piing up Adam's bio yesterday the first Adam sell that came up on Google is evidently a famous MMA fighter uh I want to apologize to anyone who rsvped for this program thinking a UFC champion was going to be interviewing the former commissioner um but kidding aside uh Adam Cella is a friend of the society and the chief counsel for the administrative state regulatory reform and antitrust at the house committee on the Judiciary uh before the Jud judiciary committee Adam was an attorney adviser for the FTC and I'm sure you can guess from this pairing who he worked for prior to joining the FTC he was an associate at axen vrep and hark Rider his JD uh is from pen law school and his undergrad was at George Washington University as I hand things off a reminder to our audience that uh we have set aside ample time for your questions at the end of the panel so please think of the challenging and difficult questions in advance also please ensure that whatever you come up with ends with a question mark with that Adam the program is yours thank you um I'm going to begin with the standard disclaimer that we were speaking on behalf of ourselves and not on behalf of anyone anyone else um and I'm gonna I'm gonna cut Christine's intro short you all know who Christine Wilson is I can talk about Georgetown being a law clerk being Chief of Staff of the FTC but most importantly you were commissioner of the federal Trade Commission you're nominated by President Trump you served during the Trump Administration into the Biden Administration where you were uh a commissioner in the minority along with commissioner Phillips and uh you resigned about a year ago a little over a year ago so let's start there it's been over a year since you resigned when you did you wrote an oped in the Wall Street Journal um part of your resignation according to that oped was because of concerns over due process and rule of law those are serious Alle having a year to reflect on that how do you feel about your resignation so first of all thank you for having me thank you to the Federalist society and thank you to Adam for agreeing to ask me only easy softball questions as you can tell so a year in uh to my retirement from the Federal Trade Commission I would say that um I am I have no regrets about taking the course of action that I did I had spent a lot of time in my last two and a half years at the [Music] commission giving speeches writing dissents and speaking in what I felt to be an increasingly strident tone which is not naturally who I am and unfortunately I felt that my objections were not moving the needle sufficiently and so I took the only course of action that I thought might actually make a concrete difference in the near term and I was very pleased to see robust Congressional oversight of the FTC ensue following my resignation I think that uh congressional oversight of independent agencies is an important part of the checks and balances that our framers intended and the FTC has long had a a history of cooperating very closely with Congress providing requested information explaining its initiatives uh and and developing a deep and bipartisan consensus on its approach and uh and I do hope that that's that's the response with which you have been greeted I agree that congressional oversight is very important and I would hope that everyone would not just say that they care about congressional oversight but actually comply with the requests uh from Congress so so so so you have no regrets about your resignation um so for the last year there has not been a republican commissioner there's only been the three Democrats doing largely whatever they want without the voice or the vote of a minority commissioner um there but we are now back at full strength you were in this position of being a minority Republican commissioner what are the major roles and contributions that the two new Republicans can play over the course of the next year so let me say that I am so pleased that Commissioners Fergus Fus and holy o are now there I do think that the FTC operates best when it has a multitude of voices on the commission I did staff briefings and party meetings with my colleagues uh both with commissioner Phillips and with Commissioners Slaughter and Chopra and I felt that I learned from every single interaction and so I think that diversity of perspectives is very important I'll use a phrase that Adam heard me use frequently which is iron sharpens iron and so I believe that uh in the same way that justices uh Scalia and RBG had a very important relationship reading each other's statements and opinions and commenting on them uh allowed those decisions to be refined their perspectives to be refined obviously the FTC is not the Supreme Court but I saw that same uh Paradigm and phenomenon play out when I was there uh during during my tenure when Joe Simons was chair uh I think that uh obviously things changed when I uh when I became part of the minority and I think that there are really important roles for Commissioners Ferguson and hoolio to play Beyond attempting to change votes because that is unlikely to happen there are uh important changes that they can uh perhaps see made at the margins with respect to which theories are pled how they're pled uh with respect to fleshing out the narrative and complaints so that uh the public and the business community and counselors can understand the ftc's true concerns I think that there's a very important role to play with respect to accountability obviously if there are things going on behind the scenes that are nonp public uh the minority may be limited and how it can bring those things to light certainly you and I spent a lot of time first of all trying to figure out all of the shenanigans that were going on and then once we uncovered the shenanigans how to alert the public without violating rules against sharing non-public information so I think that that is another important role that uh that they can play um but so I think identifying overreach and obviously when you look at the non-compete rule when you look at the health breach notification rule uh practitioners understand immediately that uh that there is overreach but having descents that say that and that can then be quoted when litigation uh challenges are brought I think is very important uh we know that courts read the opinions of all of the Commissioners we saw what happened with the fist circuit in alumin grail and uh and the Chamber of Commerce challenge to the non-compete role actually um cites me an embarrassing number of times I texted Sean Heather and said he should start paying me by the word every time he cites me um and so I think those are those are some of the roles that they can play and I think they have they have come out of the gate really strong and I am so pleased with uh with the statements that they've made with the descents that they have posted and I'm looking forward to uh to to hearing from them on important issues in the future so a lot of what you just mentioned um uncovering things that are happening writing iron sharpens iron those I see as commission level issues but another thing you spoke a lot about and wrote a lot about when you were a commissioner was the staff at the FTC how professional they are they are experts in antitrust law that they should be listened to they should be respected they should be able to do their work we have now seen three years of Fairly terrible federal employee Viewpoint survey results for senior leaders at the FTC we also you mentioned Congressional oversight in your first response the house Judiciary Committee released a report that largely just quoted ordinary course documents and testimony from the managers the career managers at the FTC that talked about mismanagement and bottlenecks and the issue the big takeaway of the report was that the career FTC enforcers cannot do their jobs they're because of mismanagement because of bottlenecks they cannot be aggressive antitrust enforcers was that report in general what you know did that report cover what you saw at the FTC and what you were talking about when you spoke and wrote about career staff so I I welcomed the report because again I had some difficulty sharing everything that I was hearing behind the scenes even when I shared the concerns that I was hearing I think people uh perhaps interpreted at least some of my statements as being motivated by Politics as opposed to a genuine concern for the staff and for the agency and so I thought it was it was very helpful for the report to document uh again and again and again what the staff were saying contemporaneously in their own words and uh and the concerns that I shared publicly were the same ones that you identified uh in the report and so I I thought that was I thought that was very helpful in terms of driving home the point that this is not about politics this is about protecting the Integrity of an institution that serves an important purpose in the American economy um with respect to the the point that you made about potential bottlenecks and whether resources are being devoted in the right ways you know we talked a lot in my office about uh you know the good to great no of the Hedgehog and where do you have the most impact understanding the the cold hard brutal facts uh in in that author's words of finite resources and prosecutorial discretion and I gave a speech at one point uh that that noted that governing is hard and there are opportunity costs to every choice that you make about where to devote resources and are resources being devoted to the issues that have the most significant impact on American consumers and I think the report demonstrated a fair amount of frustration staff felt perhaps uh resources are not being devoted in in the right ways and and with all of the attention that was paid to creating new rules especially on the consumer protection side and all of the attention that has been paid to investigating mergers with uh apparently non-merit ious claims uh what is not being investigated a related issue you talked about I want to I want to get to rules but which you just mentioned but a related issue before we get there was brain drain and this has been covered by the Press uh the amount of people especially senior managers that left the FTC how does the FTC based on what you saw recover from the amount of people especially with a lot of experience that are leaving yeah so I think it's an important question it's one that Senator Lee also highlighted during uh an AB antitrust section fall Forum a couple years ago he said I'm normally not one to worry about the fate of the US bureaucracy but even I am concerned about the number of people leaving the Federal Trade Commission and you have at the FTC an unparalleled group of very committed experienced professionals and I have always sung their praises and I will continue to do do that because the the beautiful thing about the FTC is it is The Little Engine That Could it is a small But Mighty agency with people who are motivated by the mission of protecting consumers uh my assistant when when we were at the FTC was a woman who interviewed with several different agencies when she first came to the FTC uh to to Washington DC and she decided to work at the FTC because she was uh she fell in love with a mission it's a mission she could identify with and so she spent counting now what 37 years at the FTC because she's motivated by the mission and so when you lose a lot of people who have experience on the front lines experience in litigation experience in Ru making experience in investigations to understand when the rubber meets the road the kind of case you need to win in court uh that is a significant institutional loss I think it's going to take a very long time to write the course for the FTC but I also wonder who is filling the vacancies that have been made what kinds of factors are being used in hiring what characteristics are considered important I would hope the uh the length of time practicing the depth of experience is Paramount uh I I would hope so but I would ask what what factors are considered most important in hiring decisions these days well the the FTC might not have a long time and and uh the people there of course only matter if the FTC continues to exist or continues to exist as the powerful agency that it is and what I'm getting with this is the Constitutional challenges that um are are there are many that are attacking the FTC right now um too many to list and go through but you've seen discussion I think you've touched on this when you were still at the FTC around plowing forward and taking those challenges on or managing what the ftc's powers actually are and understanding that you do not want to run the FTC into a position where it is a weaker agency if it exists at all when um the Supreme Court and other courts are done with it how would you balance uh those two ideas of plowing ahead versus managing the risk yeah I I think this is another incredibly important question and one that I spent time focusing on while I was there obviously um there are lots of criticisms that are being levied at the FTC uh the Federalist Society of course has always been concerned about the constitutionality of independent agencies the Supreme Court unanimously uh in AMG decided that the FTC had overreached with respect to 13B we had a house Judiciary Committee markup a couple of weeks ago on transferring all of the anti trust authority of the FTC over to doj so we can add uh Congress to the list of detractors for the FTC uh and so I think uh and this is a point that I made when I was there uh Prudence is important when you are setting the path with respect to individual matters but also with respect to uh the the broader Mission and priorities of the agency uh I I think a good steward of the FTC would be concerned about navigating these challenges in a way that uh that takes the longer term into account unfortunately uh what we see instead is I think um continued overreach and throwing caution to the wind the non-compete rule negates the statutes of 46 different states and something like at least 30 million private contracts between employers and employees and I uh was surprised with the rapidity with which that ruem was challenged and uh and and I do think uh the those challenges will uh will be strong and and I think the those lawsuits will be won not by the FTC but by the challengers to to the role well let's let's turn to rle making then since I've raised it ra tce I know you want to talk about it so fine'll drag me there um yeah last week we obv saw the unfair methis competition rule but there are other large significant rules that are getting attention right now and probably should that are we expect to be coming the junky rule the commercial surveillance rule just to name it too so let's take a step back from the unfair methods competition role we just saw and just what are your thoughts on policym through regulation at the Federal Trade Commission so if you've ever seen me speak before you will you will have heard this I think uh rule making is fraught with danger I I come to that view based on my experience in the airline industry with all of the dot Ru making dating back uh you know a couple of decades and the the problem with ruem of course and you wrote me a speech on this is uh you know it it tends to look at a Marketplace as a snapshot in time and even before the rule is finalized the snapshot is out of date and market dynamics have have carried on and uh one of my favorite examples is the care labeling rule uh on the consumer protection side of the house unfortunately the FTC has a care labeling role that hasn't been updated in years and does not reflect the fact that there are new Challengers to dry cleaners called wet cleaners who's heard of a wet cleaner I have one person who also worked in my office who's heard of a wet cleaner because the FTC has not allowed that uh kind of cleaner to be put on the care labeling role and so there is an entire facet of competition that is not being brought to the market because a rule is stifling that innovation in that competition and so I think the kinds of rules that are helpful are those that require a free and Fuller exchange of information between a buyer and seller uh that that uh facilitate more informed decision making that kind of rule count me in so the old version of the funeral rule the old version of the franchise rule the ones that facilitated a spread of information so that buyers can make informed decisions great but uh when we're talking about rules that have broad sweeping reach and that will uh essentially constrain competition and the flow of information in informed decision making um not a fan not a I think I I dissented five or six times on the energy rule I think that might be low I think that might be low I think you had more you had more descents on that one one rule than five or six the um so and what you're talking about there is all consumer protection rul making under Magnus sasas where the at least the statutory Authority does exist uh so let's talk about the unfair methods of competition rule that came down final uh for regarding non-compete agreements the you were at the commission when you were able to uh when the nprm came down and you did write about that but now you've had a chance to review the final rule you started to touch on this but what are your thoughts on the on the final UMC rule so I think you know first of all yes there are challenges out there but businesses need to take this seriously right I think it's important for businesses to begin preparing for the eventuality that the rule may go into effect and so taking a look at the dividing line between uh the senior employees and other employees is important if you're continuing negotiations to bring senior employees on board consider how this rule may impact those discussions I think uh I think that uh it's an important time for businesses in America to assess the kinds of non-competes that they use and if you are using them out of necessity fine if you are using them out of habit maybe take a moment to revisit whether there are other ways to achieve the goals that you want uh I think uh we do see strong challenges to this Rule and I would hope that it does not go into effect but if it doesn't go into effect then what might happen I think uh there are voices in Congress who'd like to see Congress take up a band on non-competes and I think there are a lot of States out there that are also interested and so I think it is um it is a very interesting time obviously uh and a good time for businesses to assess how they use non-competes and whether they uh need to reassess their practices in the future I I gave you a chance to talk about ruem so I'm going to shift now you have anything else to say about rule making the another of your favorite topics though the merger guidelines or merger review in general uh they were issued in December 2023 you were at the commission and wrote a little bit about the RFI regarding merger guidelines possibly coming out and you were open to the idea of exploring changes to mergers the merger guidelines since the 2010 one were over a decade old now you've seen the final version similar question to seeing similar question to seeing the final rule what are your thoughts on the new merger guidelines so I think uh the the new merger guidelines obviously give us a lot of food for thought um I think it's very interesting to trace the final merger guidelines back to the RFI that was issued there's a lot of similarity there in terms of the issues that were foreshadowed in in the RFI um obviously there is an emphasis on labor there is a uh a very disdainful and skeptical view of efficiencies uh there are lots of sites to older cases um and not so much newer cases I I am not a litigator I think uh the the big question is how judges will view the merger guidelines and I look forward to uh to seeing how this issue plays out in court I'm not a litigator but if I were a judge I would expect The Advocates to point to newer case law as well and so I think it'll be interesting to see how judges treat the new merger guidelines and the 2010 guidelines were powerful for that reason and that is not uh that that is to be determined whether they 2023 guidelines are a tool for enforcers to use yeah and and the Supreme Court said in Kimble V Marvel that any trust is an evolving field and we do expect and this is the point that uh commissioner Phillips and I made when the RFI was issued we expect that this is an area where Evolution will continue There is new learning about businesses there is new learning about the field of economics and so we expect it to be inol involving field the question is whether the policies that are staked out are supported by existing precedent and uh sound economics staying in the in the merger review space there's also proposals to change the HSR form or I should say the HSR filing process uh it's going to be it could be quite a a resource intensive activity just to file an HSR uh if this process goes forward now there was um some recent comments that they're going to pair back what was initially proposed although with with this Administration I tend to take a wait and see approach to what they say instead of believing them um when they tell me something what are your thoughts on the HSR filing form and uh you know the potential for this to change all um all mergers so I think this is uh another development and a very long line of developments with respect to merger enforcement that this Administration has taken I think lots of practitioners were surprised and uh perhaps horrified when the proposal was announced I do hope that we see some pairing back because there are we know overtime 3% of mergers are scrutinized under uh Republican or Democrat administrations there was a a continuity there over time most mergers are either competitively benign or beneficial there's a lot of business literature that explains why that is and and so to impose the significantly heightened costs and burdens and expense and time on 100% of mergers is not going to do any favor for our economy and uh and and uh all this was this was actually very pleasing to see that um yes it was sort of a Full Employment Act for HSR lawyers but but even the HSR lawyers have been quick to say this is unreasonable and uh we we do hope that's not the final result so I I believe that if if the final rule looks anything like the proposal that we saw we will see challenges very quickly in the same way that we saw challenges to the non-compete Rule and I do think ultimately a judge would view the changes as arbitrary and capricious based on the evidence that only 3% of all mergers require greater scrutiny uh so uh imposing all of these costs and burdens on 100% of mergers is uh is unjustified it's going to be a difficult position for antitrust lawyers to argue against something that's going to make them so much money but I but they've done it and I'm very pleased about that um all right I want to ask you two forward-looking questions and then we'll open this up to a Q&A from the audience um first you know you are now back in private practice after your your year off that we discussed what are you telling your clients about how to deal with the FTC now in this in this changed atmosphere of heightened uh scrutiny or at least heightened rhetoric around the field of antitrust so I am on on the merger front I think initially there was a lot of concern about uh what the agencies were doing and there was a fair amount of uncertainty uh the message now for clients is we have figured out how to handle that uncertainty and so there are Provisions that can be built into merger agreements to allocate risk you need to plan a significant amount of time to get your deal through the agency the agencies need to understand based on Provisions in your merger agreement that you are willing to spend that time and to litigate if necessary uh and you have fully planned how to allocate the risk as between the two merging parties but I think the the big takeaway for me returning to Private Practice is that there is pent up demand for mergers companies are now proceeding with mergers that they had had on the back burner for a couple of years and there is a game plan and a road map for for companies to follow uh in in addressing the risk that this new climate uh presents and I'm going to talk about rle making one more time I encourage clients trade associations think tanks to uh to put comments on the docket for rules that have been proposed because even if none of those comments are going to be taken into account in the final rule that the commission issues it is important to have that data the empirical analysis the literature cited on the docket so that when Court challenges are rise a judge is able to see that the final role did not take into account and grapple with the the full record and so taking the time to to put those comments in the docket is important even though you will not see immediate results and then third I would say uh I encourage clients associations to to talk to Congress because I think it's important to have informed oversight and so I have I've encouraged clients to do that as well I'm a uh my door's open um I uh no I do not need any more meetings on my calendar thank you um the so now I really want you to look into the future and you mentioned Kimble V Marvel earlier and antitrust is not static it hasn't been for the last 40 years uh despite what critics of the last 40 years fan I trust say uh it does change it does evolve based on modern economics and modern law um when there is another Republican Administration what things do you expect to stick from the past four years or in in other words what is going to stay the same from what happened in the Biden Administration whether that's for better or worse and if you say ruem I am not going to believe you I think the the one area of consensus that I saw during my tenure at the FTC but also across the globe is a greater emphasis on scrutinizing mergers uh merger remedies and making sure that remedies can withstand the test of time I think you know over the years the FTC in particular has done a great job at crafting remedies that do withstand the test of time uh but I think there has been for the last 20 years a a growing skepticism of Behavioral remedies and obviously you know if there are firewalls simple straightforward firewalls fine but with respect to more complex remedies I think that's an area where we saw a bipartisan consensus so in locked Aero jet in alumin grail those were areas where the the remedies would have been so complex so many moving Parts uh so difficult to monitor that the commission on a bipartisan basis said we don't think uh we don't think those remedies are are going to be sufficient and so I think in the area of Behavioral remedies there is uh in particular a a new a new and heightened standard thank you should we open it up now to audience questions um I know yes so thank you for all of your remarks today um on the non-compete rule you spoke mostly to the substance of the rule and how businesses might need to prepare for that I wonder if you could speak a little bit to the principle of the rule I guess so the the idea of the FTC should the rule survived the court challenges having unfair methods of competition rulemaking Authority combined with the new section five policy statement which has a very long laundry list of things that are potentially an unfair method of compet ition and and how that might inter you know impact businesses so I don't think the FTC currently has the authority to engage in competition rulemaking and as you can tell from my remarks today I think rulemaking in general is very bad and so I don't think it should receive the authority to engage in competition rulemaking um so I I uh there's an interesting concept that that bill kavas and uh and others have talked about where where an agency has very broad Authority you should look very closely at the penalties it can impose and vice versa and so I think when you when you couple a very broad interpretation of section five with sweeping ability to engage in ruem and potentially to issue civil penalties um I think I think that's a problem but I I don't think Congress is on the verge of giving competition will making authority to the FTC they they claim to have it right now so so we will see but no I don't expect that uh to be passed anytime soon um since we just marked up the one agency act commissioner thank you so much for being here I had two questions um you mentioned merger guidelines enforcement and rul making I want to turn to the area of 6B studies um in a recent uh open commission meeting you stated that there are three criteria for a good 6B study one it should be objectively designed two it should be cred credible and three it should be data driven we're expecting the FTC to issue several 6B results the next few months and I'm wanting to know kind of your outlook on that given your desense in early proceedings where the FTC had failed to take a holistic approach and failed to take a sup tet's approach with regard to its conclusions I think the FTC has a long history of using all of the tools in the toolkit to use sort of a familiar phrase in terms of informing its policymaking decisions and approaches I think 6B is an important tool in the sense that you can go out into the market you can get uh business information it's not under threat of an investigation it's just uh an exploratory and research tool and uh and the FTC uh following 6B studies in the past time and time and time again has produced very rigorous reports that uh that draw conclusions based on hard facts and lots of empirical data and so I think that is when the FTC does its best work there is a heuristic uh sort of in the cast sunstein nudge type um framework where people develop tunnel vision my husband did uh he did postc conviction review work in Maryland for inmates who had been imprison for Life uh he raised constitutional challenges to the processes that uh they had been subjected to and one of the things that he discovered time and time again is that when police and investigators identify who they believe perpetrated the crime they reject all other evidence to the contrary and so the result they reach is the result that they had predetermined at the outset was the right one regardless of all the other information they saw and it it was a ghastly phenomenon in my husband's cases and it would not be good government to use that approach in policymaking um I want also want to ask you you mentioned um several rfis in your um remarks and I wanted to ask you about the franchise RFI in particular in light of the ftc's departure from consumer protection to Union protection and wanted to ask your views on ftc's staying true to its mission to for example uh update the franchise Rule and kind of do away with its uh protection of unionization there was a recent quote from commissioner borya where he talked about Union neutrality not quite sure what that has to do with antirust law but can you please elaborate on your views on the franchise rule in particular and the ftc's franchise RFI so I think the the franchise RFI was concerning to me at the time because because it seemed to be very one-sided the questions that it posed sought to elicit one set of concerns and again going back to my point about tunnel vision in policymaking uh I I am not sure that that gives us the best outcomes and to go back to my point about the franchise rule I think that rule historically has been important because it elicits information from the franchise or that the franchisee can use to make informed decisions about whether to invest and that purpose is a good and laudable purpose for that rule and I would hate to see us move into other areas of concern because uh I think the FTC needs one predictable credible administrable standard with respect to competition and consumer protection currently that is the consumer welfare standard when you attempt to maximize many goals uh mathematically it's impossible and it leads to a lot of uh uncertainty about what the outcomes will be which is difficult for the business Community to navigate uh makes it very difficult for investment in growth and uh and so I believe the consumer welfare standard is the right Touchstone until someone introduces something better uh sort of the wi in Churchill you know democracy is the worst form of government we've ever seen except for all the others that we've tried so yes democracy is messy but it works the consumer welfare standard may not be perfect but I await the introduction of something better commissioner thank you so much for taking the time today I guess I over the last week or two saw a bunch of rules including the ftc's recent rule um come out of the Congressional review act deadline and I wonder did the Congressional review act ever factor into rulem as you saw it at the FTC maybe not being up against that deadline and do you have any thoughts about the Vitality of the Congressional review act maybe in a future Administration um Visa the FTC people respond to the incentives that are put before them right and I think it's no accident that a lot of rules are coming out now I think the CRA is important uh I know that when President Trump came into office that was a um a big topic of discussion what needed to be examined under the CRA uh and and so I think it is it is a good and important act um but people respond to the incentives put before them pie doesn't have a question good great thank you again Nathan I'll turn back to you um thank you very much uh commissioner Wilson and Adam for uh your service for your insights today we look forward to having you uh back at a future Federal Society event on behalf of the federal Society we're very grateful please join me in thanking them both [Music]

Channel: The Federalist Society

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Keywords: #fedsoc, federalist society, conservative, libertarian, fedsoc, federalism, fed soc

Id: TyWSttOepAU

Length: 42min 40sec (2560 seconds)

Published: Wed May 01 2024