[00:00:14] Speaker 03:
Good morning and welcome to the Ninth Circuit.

[00:00:18] Speaker 03:
Judge Bea and I would like to welcome Judge Fitzgerald, who's joining us from the Central District of California.

[00:00:26] Speaker 03:
Welcome and thank you.

[00:00:27] Speaker 03:
Thank you for the invitation.

[00:00:29] Speaker 03:
Today, we have a number of cases that we will hear oral argument on one case and have a number of cases that are submitted.

[00:00:39] Speaker 03:
The cases that are submitted are Ronald Tolentino versus Gillig LLC.

[00:00:46] Speaker 03:
That matter is submitted.

[00:00:48] Speaker 03:
Wendy Luft versus Martin O'Malley.

[00:00:51] Speaker 03:
That matter is submitted.

[00:00:54] Speaker 03:
United States versus William Weiss, that matter is submitted.

[00:01:00] Speaker 03:
George Kleinman versus Wells Fargo, that matter is submitted.

[00:01:05] Speaker 03:
And Edward Fogg versus Saleen Finance LP, that matter is submitted.

[00:01:13] Speaker 03:
And today we do have argument on Just Goods Inc.

[00:01:16] Speaker 03:
versus Eat Just Inc.

[00:01:18] Speaker 03:
And so Council, when you are ready.

[00:01:52] Speaker 03:
Good morning.

[00:01:53] Speaker 01:
Good morning, your honor.

[00:01:56] Speaker 01:
May it please the court, my name is Philip Wong, and I represent appellants Eat Just Inc.

[00:02:02] Speaker 01:
and Joshua Tetrick.

[00:02:04] Speaker 01:
I'd like to reserve three minutes for rebuttal, please.

[00:02:06] Speaker 03:
Very well.

[00:02:06] Speaker 03:
And pay attention to the clock.

[00:02:09] Speaker 01:
Yes, your honor.

[00:02:12] Speaker 01:
My client's mission is to make plant-based alternatives to household food products, such as egg and mayonnaise.

[00:02:19] Speaker 01:
Our flagship product is Just Egg.

[00:02:22] Speaker 01:
And the question about how we can refer to Just Egg is at the heart of today's appeal.

[00:02:29] Speaker 01:
The term sheet was entered into in 2019 during a mandatory settlement conference with the hope that a more robust settlement agreement would follow.

[00:02:37] Speaker 01:
Eat Just paid millions of dollars in the hopes of buying peace to move on with its business.

[00:02:43] Speaker 01:
And the use of Just Egg was at the heart of that peace.

[00:02:48] Speaker 01:
We reasonably interpreted the plain language of the term sheet

[00:02:51] Speaker 01:
to give us the right to use just egg in text.

[00:02:55] Speaker 03:
Council, so that I understand it, can you just please explain what's ambiguous about paragraph two, if any, that supports your position of the use just eggs with a capitalized just in text?

[00:03:10] Speaker 01:
Yes, Your Honor, we submit that paragraph two is not ambiguous, rather that it's fairly clear that when it refers to, it says,

[00:03:20] Speaker 01:
Just Inc may refer in text to its brand as All Caps Just, so long as All Caps Just is used in connection with our product name.

[00:03:29] Speaker 01:
So All Caps Just is written in there as allowed.

[00:03:34] Speaker 01:
And so when it says with the product name, it's agnostic as to whether or not egg is also All Caps or initial caps as we tend to use it.

[00:03:43] Speaker 03:
But isn't the parentheses that follow not in All Caps?

[00:03:48] Speaker 01:
Correct.

[00:03:48] Speaker 03:
The parentheses is not in all caps, but... Aren't those examples of what's allowed and not allowed?

[00:03:55] Speaker 01:
Sure.

[00:03:55] Speaker 01:
It is an example, but it is that we believe that the examples are meant to illustrate used in connection with the product.

[00:04:03] Speaker 01:
So if you see the changes within the examples, just mayo, just egg, just cookie dough, the changes in there are referring to the different products.

[00:04:11] Speaker 01:
it's not meant to be exclusive as to capitalization structure.

[00:04:16] Speaker 01:
It wouldn't make sense otherwise because just before, excuse the pun, none intended, but just before the just, in what two situations is a null caps?

[00:04:28] Speaker 01:
So we don't believe that the parentheses is meant to be exhaustive of

[00:04:32] Speaker 01:
permissible capitalization structures.

[00:04:34] Speaker 03:
You know, an interesting thing that I thought when I was reading the briefing was this, that there was a complaint that was filed in 2020, and it's part of the complaint.

[00:04:46] Speaker 03:
In fact, it's part of the screenshots.

[00:04:50] Speaker 03:
It wasn't referred to in the complaint, but the word just capitalized with eggs afterwards, that was in the original complaint, but it wasn't being complained about there, but it's being complained about now.

[00:05:07] Speaker 03:
Would you say or would you agree then that they've waived that issue at this point?

[00:05:13] Speaker 01:
Yes, we agree that they waived the issue.

[00:05:14] Speaker 01:
I'm not familiar with the complaint your honor is talking about, but at least as to the motions to enforce filed in 2020, and there were two of them, examples of just with the initial, all caps just, initial caps eggs was replete within their filings.

[00:05:30] Speaker 01:
We counted at least 75 instances of that capitalization structure, and they did not challenge it.

[00:05:37] Speaker 01:
And to add to that, your honor, in the record,

[00:05:40] Speaker 01:
and specifically in ER 267 to 274, you'll see that these issues were extensively litigated.

[00:05:48] Speaker 01:
Examples of our violations were, you know, JGI presented many, many, many examples and they were litigating everything that they could find, but JustAid was not, was conspicuously not litigated.

[00:06:03] Speaker 01:
And therefore, and the first time they brought it up in court was in 2023.

[00:06:08] Speaker 01:
And so, yes, we do believe they've waived it.

[00:06:10] Speaker 01:
And the district court completely ignored this issue.

[00:06:14] Speaker 01:
But yes, we absolutely, we believe they have waived that argument.

[00:06:21] Speaker 02:
But let me ask you about that.

[00:06:26] Speaker 02:
Let's say that we agree with you that the post-filing examples that are being offered wouldn't be granted and that the motion to expand the record would be denied.

[00:06:37] Speaker 02:
The issue was it was raised before the district court.

[00:06:40] Speaker 02:
The district court

[00:06:42] Speaker 02:
certainly could have presumably was considering that before having the contempt sanction that are you saying then that since it was completely ignored that there's no difference to what happened below or that what what exactly then are you saying should be the the review

[00:07:01] Speaker 02:
on that.

[00:07:03] Speaker 02:
Just so I understand it, you're saying it was completely ignored and therefore there's no deference owed to, in that regard, on those issues to what happened in the district court, despite the district court being very well-versed, obviously, in this dispute.

[00:07:20] Speaker 01:
Your Honor, I wouldn't say that there's no deference.

[00:07:22] Speaker 01:
I think the parties agree that abuse of discretion is the standard

[00:07:26] Speaker 01:
That said, because there was no finding of fact, there was no finding below either as to law or fact as to waiver, even on an abuse of discretion standard, the court should review it almost anew because there's no record.

[00:07:43] Speaker 01:
But that being said, I think based on the undisputed facts, this court can nonetheless

[00:07:49] Speaker 01:
either fine waiver on its own, or remand with the finding instructing the district court to fine waiver.

[00:07:56] Speaker 01:
And the undisputed facts are these.

[00:07:57] Speaker 01:
They knew we were using just A. We referenced at least 75 references.

[00:08:02] Speaker 01:
And the specific reference, your honor just pointed out that the red box just, but right above it is just A, which they did not challenge.

[00:08:13] Speaker 01:
Second, there's no dispute that we raised the waiver argument below.

[00:08:18] Speaker 01:
And third, it's undisputed that the district court did not address the waiver argument.

[00:08:23] Speaker 03:
And fourth, JGI considered... The waiver argument only has to detect, correct?

[00:08:28] Speaker 03:
I mean, you don't get around... I mean, how do you get around the social media alleged violation that you used in the social media handle?

[00:08:37] Speaker 03:
How do you get around that, given what the term sheet says?

[00:08:42] Speaker 01:
Sure.

[00:08:44] Speaker 01:
When I'm meaning waiver, I only mean the selective capitalization

[00:08:48] Speaker 01:
and the trademark issue.

[00:08:49] Speaker 01:
As to text, correct?

[00:08:51] Speaker 01:
As to text, but not the social media.

[00:08:54] Speaker 01:
As to the social media handle, Your Honor, we believe that in paragraphs 3 and 15, there's a reference to the new company name, which is meant, we believe, to be flexible.

[00:09:11] Speaker 01:
And it was not meant to be exhaustive as to the only social media handles

[00:09:16] Speaker 01:
that we could ever use.

[00:09:19] Speaker 01:
And because, you know, JGI has made the argument that, well, company name, the company name must be Eat Just Inc.

[00:09:28] Speaker 01:
That's also talked about in paragraph five.

[00:09:30] Speaker 03:
I'm looking at paragraph three.

[00:09:31] Speaker 03:
I don't see, what language specifically do you say says that?

[00:09:35] Speaker 01:
Yes, I'm sorry.

[00:09:36] Speaker 01:
I'm referencing paragraph 15, your honor.

[00:09:38] Speaker 03:
Oh, not three.

[00:09:39] Speaker 03:
You said three and 15, so not three?

[00:09:41] Speaker 01:
Correct.

[00:09:43] Speaker 01:
Okay.

[00:09:43] Speaker 01:
15 says, defendants shall change all social media handles on online platforms to the new company name.

[00:09:50] Speaker 01:
That's the new company name I'm referencing.

[00:09:54] Speaker 01:
Other places in this term, she referred to a new corporate name, and paragraph five says, corporate name shall be Eat Just Inc.

[00:10:01] Speaker 01:
We believe that there's a reason why the words are different, and that it ought to

[00:10:08] Speaker 01:
I mean, different things.

[00:10:09] Speaker 03:
Do you want to save the remaining time?

[00:10:12] Speaker 01:
Yes, I would like to save the remaining time.

[00:10:14] Speaker 03:
All right.

[00:10:32] Speaker 03:
Good morning.

[00:10:33] Speaker 00:
Jill Petrini for plaintiff Just Goods in Appellee.

[00:10:37] Speaker 00:
Our position as a district court should be affirmed in all respects.

[00:10:42] Speaker 00:
It's consistent with your 2022 decision.

[00:10:46] Speaker 00:
It is consistent with the two orders of enforcement of the term sheet and contempt thereof that the district court, which grounded your 2022 decision,

[00:10:59] Speaker 00:
The defendants have failed to meet their heavy burden of waiver.

[00:11:02] Speaker 00:
It's by a clear and convincing standard.

[00:11:05] Speaker 00:
And there has not been an intentional relinquishment of our right to object to this new variation of just.

[00:11:12] Speaker 00:
They continue to emphasize the word just.

[00:11:15] Speaker 00:
And the fact that we didn't point out every single one that they do doesn't mean that we completely gave up our right to ever object.

[00:11:24] Speaker 00:
Why not?

[00:11:25] Speaker 00:
Because we can't determine everything that they've done.

[00:11:28] Speaker 00:
We had one example, and it was one example only.

[00:11:31] Speaker 03:
Hold on, and your complaint in the... In the motion, it wasn't a complaint.

[00:11:34] Speaker 00:
In the motion, excuse me.

[00:11:36] Speaker 03:
Yeah.

[00:11:36] Speaker 03:
In the contempt motion, you indicated in that... You indicated the other violations, but in that you can actually see this in the screenshot itself.

[00:11:46] Speaker 03:
Right.

[00:11:47] Speaker 03:
Quoted, just

[00:11:49] Speaker 03:
eggs, with eggs being lowercase except for the E, being lowercase and used in connection with one another.

[00:11:56] Speaker 03:
Why isn't their argument correct that you've waived it because you knew about it as early as 2020 and you did nothing about that until the latest filing?

[00:12:10] Speaker 00:
But back up for a second.

[00:12:12] Speaker 00:
Remember, there was an email from me March of 2021.

[00:12:15] Speaker 00:
We were asked to supplement the record that you consider it because one thing that it wasn't part of the original record, right?

[00:12:23] Speaker 00:
But neither was the seventy five uses that they've just identified to you.

[00:12:27] Speaker 00:
They were not.

[00:12:28] Speaker 00:
And they've now they brought that up on the motion to stay.

[00:12:31] Speaker 03:
Look, I understand how frustrated you are.

[00:12:35] Speaker 03:
There appears to be several violations and it's hard to just keep them all straight.

[00:12:40] Speaker 03:
But in this instance though, why isn't it fair for them to say, hey, you knew about it from the very beginning and you just didn't bring it up?

[00:12:49] Speaker 00:
One single use.

[00:12:51] Speaker 00:
that we did not identify should not be a complete waiver of our rights.

[00:12:56] Speaker 00:
And it's an abusive discretion standard to review the district court.

[00:13:01] Speaker 00:
The district court did consider waiver.

[00:13:04] Speaker 00:
He certainly did, and he made that clear when he talked in his order denying the motion to stay.

[00:13:10] Speaker 00:
So that is...

[00:13:13] Speaker 00:
that one issue, and it's very small.

[00:13:16] Speaker 00:
It's at the bottom of the screenshot.

[00:13:17] Speaker 00:
I know what you're referring to.

[00:13:19] Speaker 03:
And the other uses are third-party uses.

[00:13:23] Speaker 00:
Right, right, I think it was in Mr. Boss' declaration when it was screenshotted.

[00:13:27] Speaker 00:
But they didn't, it was small, we shouldn't be forever barred from doing that.

[00:13:33] Speaker 00:
And this is just gonna continue, by the way, the emphasis on just.

[00:13:37] Speaker 00:
And I don't want to be back here a third time, but I'm kind of feeling I will be, or Mr. Boss will be as I age out, you know, so there's that.

[00:13:47] Speaker 00:
So I really don't think there's waiver.

[00:13:49] Speaker 00:
The justification,

[00:13:51] Speaker 00:
for using just and capital letters that you just heard, it's just wrong under paragraph two.

[00:13:57] Speaker 00:
The use of just and capital letters in paragraph two was to refer to it as a trademark use because the word just is a common word.

[00:14:08] Speaker 00:
The capitalization throughout the binding term sheet was to indicate when things were used as a trademark.

[00:14:15] Speaker 00:
As opposed, and when referring to its brand in the initial caps, Just Egg, is that is a brand, Just Egg.

[00:14:22] Speaker 00:
It's not descriptive use of, oh, it's a product containing only eggs, which it doesn't because this is not a product.

[00:14:29] Speaker 00:
So that was the intent of that.

[00:14:31] Speaker 00:
That doesn't justify the use of the word just in capital letters like they're doing now.

[00:14:38] Speaker 00:
And certainly the waiver, and you touched upon it, the waiver, going back to that for one second, the waiver cannot apply to the use of JustEgg as taking over the overall brand of the company and for now being social media.

[00:14:51] Speaker 00:
They knew exactly what social media

[00:14:54] Speaker 00:
handles they could use, and they've gone beyond that.

[00:14:57] Speaker 00:
They really don't have any basis for that.

[00:14:59] Speaker 03:
Well, they pointed to paragraph 15.

[00:15:01] Speaker 03:
I guess I didn't understand that argument.

[00:15:03] Speaker 03:
They pointed to paragraph 15.

[00:15:05] Speaker 03:
How do you understand that argument?

[00:15:08] Speaker 00:
I kind of don't, because the new company name is synonymous with the new corporate name.

[00:15:15] Speaker 00:
In fact, paragraph 15 uses both.

[00:15:18] Speaker 00:
And it uses both to refer to the same concept.

[00:15:21] Speaker 00:
The whole concept was, you're going to change your company name.

[00:15:24] Speaker 00:
It was Just Inc.

[00:15:26] Speaker 00:
And you need to pick which one.

[00:15:28] Speaker 00:
It's going to be Make It Just or it's going to be Eat Just.

[00:15:31] Speaker 00:
And that was the, and they were undecided at the settlement conference of which one they were going to go with.

[00:15:36] Speaker 00:
Ultimately, they decided we're going with Eat Just.

[00:15:39] Speaker 00:
So 15 is a reference to the decision of which one you were going to go with.

[00:15:46] Speaker 00:
Or maybe it was going to be something totally different.

[00:15:48] Speaker 00:
That's all that was.

[00:15:49] Speaker 00:
It's not saying that somehow that's any company name that they can come up with.

[00:15:54] Speaker 00:
If that were the case, that would completely nullify paragraph five that says you have to change your corporate name to Eat Just Inc.

[00:16:04] Speaker 00:
within so many days.

[00:16:05] Speaker 00:
If they can now come up with any product name or anything else to use as their company name, whether they formally change the articles of

[00:16:14] Speaker 00:
of incorporation or not, then that just wipes out the whole purpose of the agreement.

[00:16:17] Speaker 00:
You can't emphasize just.

[00:16:19] Speaker 00:
We're just.

[00:16:20] Speaker 00:
They got just plus another word.

[00:16:23] Speaker 00:
And they could only use just plus another word in a particular format.

[00:16:27] Speaker 00:
And you nailed it.

[00:16:28] Speaker 00:
It's with initial caps.

[00:16:29] Speaker 00:
And that's in text.

[00:16:30] Speaker 00:
When they were putting on their products, they had the composite Just Frame logo.

[00:16:35] Speaker 00:
That's what they could use.

[00:16:36] Speaker 00:
And by the way, they raised that issue, the justification of using Just in capital letters before the Ninth Circuit in the briefing that led to the 2022 decision.

[00:16:49] Speaker 00:
And it was rejected.

[00:16:50] Speaker 00:
So the Ninth Circuit has already considered that and it's gone.

[00:16:55] Speaker 00:
I can give you the, it was, they raised it,

[00:16:59] Speaker 00:
It was Docket 13 at pages 27 through 28 in the briefing underlying the 2022 decision.

[00:17:06] Speaker 00:
So that, you really shouldn't consider that argument at all.

[00:17:13] Speaker 00:
The other thing, I've got a few minutes left here.

[00:17:17] Speaker 00:
The registration of Eat Just and Just Egg was never contemplated.

[00:17:24] Speaker 00:
The only thing they could register was the frame logo and the permitted marks in the frame logo and Make It Just.

[00:17:31] Speaker 00:
Make It Just was the only word mark that they were allowed to register, and there's a big difference between a word mark and a design mark.

[00:17:41] Speaker 00:
And that was done with the purpose of distinguishing the parties, products, and companies, because it was a trademark dispute.

[00:17:49] Speaker 00:
That's what we were going to fight with.

[00:17:54] Speaker 00:
To be allowed to use a trademark is very different than to be allowed to register a trademark.

[00:18:00] Speaker 00:
One is common law and one is federal rights.

[00:18:03] Speaker 00:
So that was a negotiated point that you were not going to be able to register a wordmark because the rights afforded by a registration to a wordmark are much broader than to a design mark.

[00:18:15] Speaker 00:
And that's the way it was written.

[00:18:17] Speaker 00:
And it's clear from, I think it's paragraph 12, and it was using defined terms, permitted mark.

[00:18:24] Speaker 00:
The argument that somehow permitted marks include the word just egg is just fiction.

[00:18:30] Speaker 00:
Just egg, word mark.

[00:18:32] Speaker 00:
Permitted marks were defined as

[00:18:35] Speaker 00:
the certain product names, Just Scramble, Just Cookies, Just Egg, in that frame logo format.

[00:18:41] Speaker 00:
That was the definition.

[00:18:42] Speaker 00:
So you can't extrapolate that and say, oh, I have a right to register the word mark.

[00:18:48] Speaker 00:
It's just not true.

[00:18:56] Speaker 00:
I think the last point I'd like to go over, unless you have any other questions, is a per diem fine.

[00:19:01] Speaker 00:
It was appropriate by the district court

[00:19:03] Speaker 00:
This is round two with the Ninth Circuit.

[00:19:07] Speaker 00:
They continue to breach the term sheet.

[00:19:09] Speaker 00:
I guess they don't like the deal that they made, but that's unfortunate.

[00:19:13] Speaker 00:
That's the deal you made.

[00:19:14] Speaker 00:
And that ended the litigation and allowed them to use variations of just as a composite market.

[00:19:21] Speaker 00:
Had they lost the district court, they would have had no use.

[00:19:25] Speaker 00:
So we're going to continue to be here if there's not so much pain financially that that stops them.

[00:19:33] Speaker 00:
The award of attorney's fees is just a cost of doing business for the defendants.

[00:19:38] Speaker 00:
They don't care.

[00:19:39] Speaker 00:
And the per diem fine continues to run.

[00:19:41] Speaker 00:
It wasn't bonded.

[00:19:43] Speaker 00:
It's just accruing as we go.

[00:19:45] Speaker 00:
So apparently the per diem fine is another cost of doing business.

[00:19:49] Speaker 00:
We would like to have the benefit of our deal.

[00:19:52] Speaker 00:
And what it seems like to us as a plaintiff is that the onus has been put on the plaintiff to make sure the defendants comply with the term sheet.

[00:20:01] Speaker 00:
They knew that the capitalization of just was an issue for the district court.

[00:20:06] Speaker 00:
They have orders that say you cannot capitalize just in the corporate name.

[00:20:11] Speaker 00:
You can't capitalize just and make it just.

[00:20:14] Speaker 00:
So they're just going to continue to test the fence.

[00:20:17] Speaker 00:
And it's not our job to police them.

[00:20:20] Speaker 00:
It is our job to enjoy the benefit of the contract.

[00:20:26] Speaker 00:
It's their job to ensure compliance with it.

[00:20:29] Speaker 00:
With that, I have, I think, nine seconds left.

[00:20:32] Speaker 03:
Any additional questions?

[00:20:33] Speaker 03:
No.

[00:20:34] Speaker 03:
Any questions?

[00:20:36] Speaker 03:
Thank you, Counsel.

[00:20:36] Speaker 03:
Thank you.

[00:20:45] Speaker 01:
Your Honor, just a couple of points.

[00:20:48] Speaker 01:
We would also like the deal we made.

[00:20:50] Speaker 01:
The deal we made was the ability to use Just Ag the way it is in the term sheet and in the logo and reliance upon their not pursuing Just Ag.

[00:21:03] Speaker 01:
In your honor reference ER 385, there's another reference I think is even more stark, which is ER 376, where the

[00:21:14] Speaker 01:
JGI circles Just, which they are challenging in their brief.

[00:21:19] Speaker 01:
And right above it is Just Egg.

[00:21:23] Speaker 01:
And I think that example clearly illustrates that we were allowed to use Just Egg in the agreement.

[00:21:30] Speaker 01:
And even if the court finds that it's ambiguous or vague, they have waived the issue.

[00:21:35] Speaker 02:
All right, and counsel, let me ask in regard to the waiver where the argument was just made that the district court considered that in the order to stay.

[00:21:44] Speaker 02:
I take it your position is that that's something that should not be considered by this court.

[00:21:50] Speaker 01:
I agree.

[00:21:51] Speaker 01:
The court should not consider it because it was not outside the scope of what the district court considered in the order that we are appealing.

[00:21:58] Speaker 02:
Well, considered necessarily rote, but I just want to make sure that I understand your argument in that regard.

[00:22:05] Speaker 03:
Yes.

[00:22:05] Speaker 03:
Well, what about their other argument?

[00:22:07] Speaker 03:
And there's something sort of real about it, which is, in their view, there's all of these violations.

[00:22:16] Speaker 03:
There's this, there's that, there's all of these things.

[00:22:19] Speaker 03:
How are they supposed to be policing all of the different things when, in their view, there continues to be a number of violations?

[00:22:28] Speaker 01:
I'm glad you brought that up, Your Honor.

[00:22:30] Speaker 01:
Certainly, I understand the position that they should not be counted on to exhaustively bring up every issue, but this issue

[00:22:40] Speaker 01:
was replete in the things that even they submitted into the court.

[00:22:45] Speaker 01:
So they knew, they saw, but did not challenge.

[00:22:49] Speaker 01:
And that's the main difference.

[00:22:50] Speaker 03:
So you agree that it's not necessarily their onus to just go after every single little thing.

[00:22:59] Speaker 03:
Maybe if they didn't know about it, it's your position, correct?

[00:23:02] Speaker 01:
Sure, exactly.

[00:23:03] Speaker 01:
But they did.

[00:23:05] Speaker 01:
And even if they claim they didn't, they ought to be charged with knowing because it was everywhere.

[00:23:11] Speaker 01:
The use of just say was everywhere within their, even their submissions.

[00:23:14] Speaker 03:
So they can't say.

[00:23:16] Speaker 03:
Your time seems to be up.

[00:23:17] Speaker 03:
Are there any additional questions?

[00:23:19] Speaker 03:
They're not for me.

[00:23:21] Speaker 03:
No questions.

[00:23:21] Speaker 03:
Very well.

[00:23:22] Speaker 03:
Thank you so much for your presentation to both of you.

[00:23:26] Speaker 03:
I appreciate it.

[00:23:28] Speaker 03:
But with that, we will be in recess.

[00:23:31] Speaker 03:
Thank you very much.

[00:23:35] Speaker 01:
Rise.