On the scales: the reasonableness of the offending conduct

38



OFFENSE T O OTHER S



trivial, mindless, arbitrary actions, all fail to satisfy the standard of personal

importance and can be discounted accordingly.

A second standard for judging the "reasonableness" of the offending conduct is its social utility, or as Prosser puts it, "the social value which the law

attaches to its ultimate purpose.'"4 If the conduct that annoys or inconveniences others is part of the activity of moving or demolishing buildings,

repairing ruptured gas or water lines, investigating a crime, pursuing an

escaped felon, or reporting a news story, it has a great deal of public value,

as part of a kind of activity that is socially useful, but if it is valuable only to

the person who engages in it, as for example, hawking a product for sale,

loitering in or near a public place for the purpose of soliciting deivate sexual

relations, purveying offensive materials for the purpose of making a personal profit, and so on, then it contributes little but nuisance to the rest of

the community. Playing a portable radio on a public bus may have some

value to the person who does it and to that extent at least deserves a

legislator's respect, but it is hardly the sort of activity that contributes to

the public good. Conversing freely, easily, and naturally with an acquaintance, on the other hand, whether in a public bus (story 25) or elsewhere, is

a type of activity that is not only vitally important to individuals, but also

productive of far more good than harm to the community on the whole.

Unregulated impromptu communication between individuals is in general a

necessary condition for efficient social functioning.

It is at least partly by virtue of the high social value attached to it that

unfettered expression o f opinion has such a privileged position in American

law.' 5 To be sure, expressing opinions openly in spontaneous conversation,

writing, or through more powerful media of communication is also of great

importance to private individuals themselves, since self-expression is valued

both as an end in itself and as a means of effecting desired changes. But it is

also a necessary condition for the satisfactory functioning of any government that relies heavily on enlightened public opinion in its decision making. It is important to each individual to voice his own opinion about

matters of public policy, but it is also important to him that he have fair

access to the opinions and arguments of all his fellows, and important to the

whole community that all possible roads to truth be left open lest our

leaders become committed to insufficiently examined policies, with disastrous social consequences. It is necessary to emphasize here, as Mill did in

On Liberty,' 6 that unpopular, unorthodox, and extreme opinions, no less

than any others, need their spokesmen, in order that our chances of discovering truths and making wise decisions be increased. There is a social

gain then from constantly reexamining public policies, probing for difficulties and soft spots, bringing to light new and relevant facts, and subjecting



MEDIATING TH E OFFENS E PRINCIPL E 3



9



to doubt hitherto unquestioned first premises. Without these challenges,

nations have a natural tendency to drift complacently into dead ends and

quagmires. For that reason, no amount of offensiveness in an expressed

opinion can counterbalance the vital social value of allowing unfettered

personal expression.

There are two ways, however, in which an expression of opinion can be

offensive. An audience can be offended by the opinion expressed or implied

in an utterance, as, for example, a devout Christian might be offended by

the bare assertion of atheism; or the audience might be offended instead by

the manner in which the opinion itself is expressed, for example as a caption to an obscene poster of Jesus and Mary (see stories 11 and 19). Something other than an opinion itself offends when offending conduct does not

involve language or symbolism, or when it offends by means of an utterance with no clear prepositional content at all (for example, obscene epithets), or when an opinion is expressed but is only incidental to the cause of

offense, which is the manner or context of expression.'7 Utterances that

give offense in the latter ways may have some value to the person who

makes them, and have some weight for that reason, but they derive very

little weight from the standard of social utility, and consequently can be

rightly restricted by law when the offense they cause is sufficiently serious.

In contrast, the offensiveness of the opinion itself is never serious enough to

outweigh the heavy public interest in open discussion and free expression of

opinion. One should be free to shout to a crowd, or carry a sign or words

on one's back, to the effect that we should abandon democracy for Nazism

or Communism, that our troops should invade Cuba or bomb China, that

churches should be nationalized, that homosexual intercourse in public

should be encouraged—offensive as these opinions may be to many people.

A non-offensive utterance of an opinion, even of an offensive opinion, is a

kind of trump card in the application of the offense principle. The standards of personal importance and social utility confer on it an absolute

immunity; no amount of offensiveness can enable it to be overriden.

It should be clear then how the qualified offense principle would apply to

so-called "thematic obscenity." It would permit public advocacy, whether in

hand bills or magazines, on billboards, or from soap boxes, o f an y policies

or values whatever, pertaining to sex, religion, politics, or anything else;

but it would not necessarily permit graphic portrayals of seriously offensive

scenes to unwilling captive audiences, for example lurid paintings of sexual

couplings on billboards in a crowded urban center. So precious is free

speech on questions of public policy, however, that public advocacy of laws

permitting graphically obscene billboards should be permitted. Indeed,

public advocacy even of the legalization of homicide should be permitted



40



OFFENSE TO OTHERS



provided the manner of advocacy itself is not offensive in one of the ways

recognized by the qualified offense principle.

Another factor to be considered in any determination of the reasonableness of conduct that causes offense to others is the degree to which nonoffensive alternatives that are equally satisfactory to the actor are available.

If the offending person, by doing his thing at another place or time, can

avoid causing offense to a captive audience without loss or unreasonable

inconvenience to himself, then his offending conduct is unreasonable if

done in circumstances that permit offense. Very often offensive conduct is

quite unobjectionable in itself and could be performed quite legally in the

privacy of the actor's own abode or some other private place, in which case

he can have no complaint if the law prevents him from doing it right under

the noses of unwilling observers. One can, however, make too much of this

point, for as David Conway points out, "it very often is not true that if an

action is prohibited in public, one is left 'at liberty to do the same thing in

private. . . .' For in many cases it is highly inconvenient or virtually impossible to perform the same action in private, and more importantly, in other

cases, the very point or rationale of the action disappears if one is restricted

to privacy.'"8 As examples of possibly offensive conduct that would be

unreasonably inconvenient or even impossible to restrict to private areas,

Conway cites wearing long hair or a beard. But the point about inconvenience is secondary:

Not only is there inconvenience involved in such cases, but presumably the

very point of having long hair or a beard is to "go about looking that way."

The same is true of a woman wearing a mini-skirt, or a very brief bikini, or

only the bottom half of the bikini, or no bikini at all. One can be nude in

private, but again, the point of so doing (a feeling of freedom in the supermarket, or whatever) may be lost, just as it is if it is demanded that one wear a

beard-cover in public.' 9



The point, then, of behaving or dressing or undressing in a certain way

may be totally lost if the behavior in question is done only in private. In such

cases, it is not unreasonable, by the standard of available alternatives at least,

to perform the offensive conduct in public. But whether this factor is to carry

much weight in the final analysis depends very much on what the "point" of

the conduct is. If the point of being nude is to facilitate one's movements, get

a suntan, keep cool, or "feel free in the supermarket," then the conduct has a

certain amount of reasonableness, despite its tendency to offend (shock, embarrass, inconvenience) others. But if the whole point of nudity is to offend

others, if one goes bare in the supermarket not despite but because of the

known tendency of nudity to offend, then the legislature must, at the very

least, discount the reasonableness of the offending conduct.



MEDIATING THE OFFENSE PRINCIPLE



41



This brings us to the next maxim for determining the reasonableness of

offensive conduct. By and large the offending person's motives are his own

business, and the law should respect them whatever they are. But when the

motive is merely malicious or spiteful it deserves no respect at all. Offending the senses or sensibilities of others simply for the sake of doing so is

hardly less unreasonable than harming the interests of others simply for the

sake of doing so. Conduct cannot be reasonable in the eyes of the law (or on

the scales of the legislator) if its entire motive is malice or spite. Even

abnormal vulnerabilities and super-sensitive, "skittish" sensibilities, which,

as we have seen, have little claim to protection against even minimally

reasonable behavior, can make some claim at least to protection against

persecuting harassment and wholly spiteful flaunting that has no purpose

whatever except to cause offense. Unlike special vulnerabilities to harm,

however, abnormal susceptibilities to offense find more appropriate legal

protection against malicious exploitation through means other than the

criminal law, for example, through injunctions, civil suits, or permitted

private "abatement."

In practice, however, malice and spite may be very hard to distinguish

from another motive that is surely more reasonable, however it must be

treated by the law. The nude housewife in the supermarket may fancy

herself a kind of moral reformer, trying to exercise a modifying influence on

prevailing attitudes that she regards as benighted. She may be trying to do

her share (her duly as she conceives it) to habituate the public to the sight of

nude bodies so that what she takes to be the unreasonable susceptibility to

offense at the sight of nudity may diminish and eventually disappear along

with various unwholesome attitudes towards sex to which it may be connected. She may be aware that her nudity will cause some observers to

experience painful embarrassment, but she acts despite that awareness, not

because of it. Her case is surely to be distinguished from that of the mischievous troublemaker and the spiteful misanthrope. One would hope that she

would not be seriously punished by a court. The question of whether her

conduct could pass the tests of reasonableness required by an enlightened

application of the offense principle, however, is more difficult.

Donald VanDeVeer argues persuasively that it is possible in principle to

distinguish malicious from what he calls "conscientious" offensive conduct.

As an example of the former, he has us consider the following: "Smith, an

eccentric liberal Democrat, paints a swastika on his roof to irritate his

Jewish neighbor, but not with the intention of winning converts to NeoNazism or achieving any further purpose."2" We already have an example of

"conscientious offensivencss" in the dutiful nudist in the supermarket. An

example more parallel to VanDcVeer's eccentric liberal would be a Nazi



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OFFENSE T O OTHER S



who wishes to persuade others to consider the Nazi ideology with less

prejudice by painting a swastika on his roof (assuming that Nazis can have

genuine convictions and hold them conscientiously). VanDeVeer also

points out that political dissidents often cannot "get a hearing" without

media attention, and "cannot achieve that without offensive behavior" like

guerilla theatre performances and shocking symbolic acts. VanDeVeer

would discount purely spiteful motivation, as we too have suggested, while

permitting offensive conduct when conscientious. I am sympathetic with

his view, although I draw back from an absolutist principle that would

make conscientiousness an automatically sufficient condition for permissibility. What conscientiousness in VanDeVeer's sense shows is that the

conduct is genuine political expression and not mere malicious insult without advocacy, or some use of symbolism other than defending a thesis or

making a point. It therefore brings the full weight of free expression as an

important social value down on the side of the scale weighing the reasonableness of the offending conduct. There would be considerably less political value in using a symbol simply to shock a neighbor, or exposing oneself

in the supermarket for sexual self-stimulation, or to solicit sexual relations,

or simply to upset the excessively prudish as an end in itself.

The final consideration relevant to the reasonableness of conduct that

tends to offend has to do with the nature of the neighborhood in which the

offending conduct takes place. The maxim that offensive conduct performed in d e facto restricted areas where it is known to be common is more

reasonable than it would be were it performed in locales where it is uncommon is a corollary of the "available alternatives" standard that deserves

some separate discussion. Homosexual lovers petting and kissing on a public bus are unreasonably offensive, by the present standard, if there is an

area of their city, not unreasonably distant, that is known to be frequented

regularly and primarily by homosexuals who commonly engage in the same

sort of activity on the street corners, in the taverns and night clubs, even in

the local buses. Similarly, sex shops, pornographic cinemas, and dirty book

stores, all with neon identifying signs and lurid advertising posters, create

an irritating and unwanted ambience in residential and most commercial

areas of a city, but can cause very little offense in neighborhoods already

abandoned to them, like 42nd Street and Charing Cross Road. Large cities

might very well tolerate such free zones (while carefully monitoring them

for genuinely harmful effects) as a means of providing "available alternatives" for persons whose deviant practices have some personal value, but are

likely to cause serious offense if engaged in elsewhere. As Prosser reminds

us in his account of the law of private nuisance, "courts are frequently



MEDIATING TH E OFFENS E PRINCIPL E 4



3



called on to determine the paramount use to which a locality is devoted."21

Legislatures might very well permit courts a similar discretion in the process of determining the reasonableness of offensive conduct when this calls

for assessing the paramount character of a neighborhood.

Very likely the balancing tests on the whole would still tell against prohibitions of such natural and spontaneous practices as gestures of affection

even among "deviant" groups. We could not plausibly require any kind of

licensing for the kind of private communications and expressions that we

think of as natural rights in our own cases. Walking hand in hand down the

main street of a town is just as much a right of homosexual as of interracial

couples. On the other hand, residential restrictions might more plausibly be

applied to more overtly erotic behavior, and to acts of solicitation, places of

assignation, houses of prostitution, adult book stores and sex shops, pornographic movie theatres, and the like. In fact, American cities have tried two

different techniques to control such offensive activities short of outright

criminal prohibition. What might be called the Boston technique did not

work well in that New England metropolis. Licenses for adult book stores,

massage parlors, and porno theatres were issued as revocable privileges

(most of which were later revoked in fact) provided the merchants located

their businesses in a narrow strip of blocks in downtown Boston. This area,

which had already largely deteriorated, soon became known to wagsters as

"the combat zone," as it quickly filled up with harlots, pimps, protection

racketeers, gangsters, pickpockets, bullies, runaway children, criminals in

hiding, armed and nervous policemen both in uniform and plain clothes,

and other human landmines. Violence and fraud flourished, the most common victims being high school and college students. The city soon tired of

the experiment and reverted to the status quo ante. By segregating offensiveness the authorities had so increased its magnitude, not to mention danger

and harm, that it had become an intolerable blight on the city.

Detroit took the opposite approach. The city was divided into geographic

areas of roughly equal size and shape, and a very small number of revocable

licenses for "offensive" commercial establishments (hiding behind reasonably decorous fronts) were issued for each district. This number was treated

as an absolute maximum, so that unsavory elements would not tend to

locate in any one place, creating higher concentrations of ugliness and

sordid corruption for the city as a whole. There are obvious difficulties and

dangers in the Detroit system too, but it at least spared the city (in theory)

the presence of any one neighborhood of quite intolerable degeneracy.

Whether the diffusion or concentration of offensiveness works best depends

on many variables that differ from city to city, especially the supply and



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OFFENSE TO OTHERS



demand for "offensive services" already present. In the right circumstances,

however, either is likely to be a more efficient control than outright prohibition, and both are greater respecters of individual liberty.

In summary, the reasonableness of conduct that happens to cause offense

to others is determined by the following standards, each of which can be

understood to be a kind of mediating maxim governing the application of

the offense principle to legislative or judicial deliberations:

1. Personal importance. The more important the offending conduct is to the

actor, as measured by his own preferences and the vitality of those of the

actor's own interests it is meant to advance, the more reasonable that

conduct is.

2. Social value. The greater the social utility of the kind of conduct of which

the actor's is an instance, the more reasonable is the actor's conduct.

3. Free expression. (A corollary of i and 2.) Expressions of opinion, especially

about matters of public policy, but also about matters of empirical fact,

and about historical, scientific, theological, philosophical, political, and

moral questions, must be presumed to have the highest social importance

in virtue of the great social utility of free expression and discussion

generally, as well as the vital personal interest most people have in being

able to speak their minds fearlessly. No degree of offcnsiveness in the

expressed opinion itself is sufficient to override the case for tree expression, although the offcnsiveness of the manner of expression, as opposed

to its substance, may have sufficient weight in some contexts.

4. Alternative opportunities. The greater the availability of alternative times

or places that would be equally satisfactory to the actor and his partners

(if any) but inoffensive to others, the less reasonable is conduct done in

circumstances that render it offensive to others.

5. Malice an d spite. Offensive conduct is unreasonable to the extent that its

impelling motive is spiteful or malicious. Wholly spiteful conduct, done

with the intention of offending and for no other reason, is wholly unreasonable. Especial care is required in the application of this standard, for

spiteful motives are easily confused with conscientious ones.

6. Nature o f th e locality. (A corollary of 4.) Offensive conduct performed in

neighborhoods where it is common, and widely known to be common, is

less unreasonable than it would be in neighborhoods where it is rare and

unexpected.



j. Reading th e balance

Having assessed the reasonableness of the offender's conduct by the application of the above standards, the legislator or judge (when the legislature



MEDIATING THE OFFENSE PRINCIPLE



45



has permitted him discretion) must "balance" it against the seriousness of

the offense caused, as determined by the four standards mentioned earlier.

A legislature does not, of course, concern itself with specific actions and

specific offended states. Rather it must weigh against one another generalized types of conduct and offense. In hard cases this balancing procedure can

be very complex and uncertain, but there are some cases that fall clearly

under one or another standard in such a way as to leave no doubt how they

must be decided. Thus, for example, the Volenti standard preempts all the

rest when it clearly applies. Film exhibitors, for example, cannot reasonably

be charged with criminally offensive conduct when the only people who

witness their films are those who voluntarily purchased tickets to do so,

knowing full well what sort of film they were about to see." One cannot be

wrongly offended by that to which one fully consents. Similarly, books cannot be legitimately banned on the grounds of offensiveness, by virtue of the

standard of reasonable avoidability, nor can inoffensive expressions of offensive political or theological opinions, by virtue of their personal and

social importance. On the other side, purely spiteful motives in the offender

can be a preemptive consideration weighting the balance scale decisively on

the side of unreasonableness.

In some cases, no one standard is preemptive, but nevertheless all applicable standards pull together towards one inevitable decision. The public

eating of feces (coprophagia) fully and unambiguously satisfies the extent of

offense standard. One doesn't have to be abnormally squeamish to be offended by the very sight of it. If it is done (say) on a public bus, it

definitely fails to win the support of the reasonable avoidability and Volenti

standards, which is to say that it causes intense disgust to captive observers.

Hence, by al l the relevant criteria, it is seriously offensive. By all the

criteria for weighing reasonableness, public coprophagia does poorly too. It

cannot be very important to the neurotic person who does it (not as important, for example, as earning a living, or eating fresh food); it has a definitely limited social utility; it is not the expression in language of an opinion, nor does it fall into a recognized genre of aesthetic expression; and it

could as well be done in private. Hence it is both seriously offensive and

unredeemed by independent "reasonableness." Proscription by means of

the criminal law then would be in principle legitimate, even though in

practice it might be unwise, uneconomical, or unnecessary.

In hard cases, however, when standards conflict and none apply in a

preemptive way, where for example a given kind of conduct is offensive to a

moderate degree, and only moderately unreasonable, there will be no automatic mathematical way of coming to a clearly correct decision. The theorist can identify the factors that must be considered and compared, but, in



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OFFENSE TO OTHERS



the end, there is no substitute for judgment. When the facts are all in, and

the standards all duly applied to them, there is no more need for a philosopher; the judge or legislator is entirely on his own. The scales used in the

legislative and judicial balancing act have no dials and pointing arrows like

those on ordinary bathroom scales (which suggests another interpretation of

the saying that justice is blind). When the case is close, and all the relevant

principles have been applied to it by means of all the proper standards, the

legislative or judicial decision may yet be unwise, or properly criticized as

"wrong," but it cannot be "illegitimate," in the sense of applying an inadmissible kind of reason.

Many criminal statutes that have long been part of the penal codes of

American states would not pass the test of our rigorously qualified offense

principle. Laws forbidding mistreatment of a corpse even in the privacy of

one's home fail to pass; so do laws against private sexual conduct of all

kinds, consensual adultery, prostitution (except for rules regulating commerce), private showings of pornographic films, obscene books, and blasphemy, among others. Some statutes, however, do receive a warrant even

from our highly restricted version of the offense principle. Some of these

are worded in such a general and imprecise way that they leave it to the

courts, in effect, to apply the offense principle in their own way, as for

example, Section 415 of the California Penal Code which prohibits "maliciously and willfully disturbing the peace or quiet of any neighborhood or

person . . . by tumultuous or offensive conduct." The statute proceeds to

list various examples including loud and unusual noise, challenging to a

fight, running a horse race for wager or amusement on a public street,

firing a gun, and using "any vulgar language within the presence or hearing

of women or children in a loud and boisterous manner." (The clause about

"women and children" would not do well by the extent of offense standard,

however. See Chap. 16, §i.) Similarly, the Model Penal Code forbids "open

lewdness" defined as "any lewd act which [the actor] . . . knows is likely to

be observed by others who would be affronted or alarmed," 23 leaving it to

the courts to judge which acts are "lewd" and likely to affront. Other

sections of the Code, applying the offense principle directly to a given type

of conduct, are more precise. A model "indecent exposure" statute penalizes

"exposure of the genitals for the purpose of arousing or gratifying sexual

desire in circumstances likely to cause affront or alarm." 24 Solicitation of

deviant sexual relations is made a crime by the Code when the actor "loiters

in or near any public place" for the purpose of such solicitation. 25 As Louis

Schwartz points out, the comments attached to the final draft of the Code

"make it clear that the target of this legislation is not private immorality but



MEDIATING THE OFFENS E PRINCIPL E 47



a kind of public 'nuisance' caused by congregation of homosexuals offensively flaunting their deviance . . .'"6 Even something like "blasphemy" is

prohibited by the Code, not when it occurs before any public audience, or

even an y captive audience, but only when it takes the form of a mischievous

disruption of a "religious meeting or procession with utterances designed to

outrage the sensibilities of the group . . ." 21 A final example is closer to the

borderline of illegitimacy, namely, the Code's prohibition of "desecration of

the national flag or other object of public veneration" but only when "others

are likely to observe or discover."28



^. Cultural change an d th e martyrdom o f th e premature

Even the most cursory survey of cultural variations reveals how diverse are

the things thought to be offensive, how steady are the changes even within

a culture in prevailing sensibility, and how different arc the reactions of

different persons to the same stimuli. The offense principle, therefore, is

dependent on cultural standards that vary greatly from place to place, and

within our own nation "constantly and rapidly change. "29 Even public defacation is common and inoffensive in many parts of the world, and there are

many examples of conduct that was once universally offensive in our country but is now commonplace. One of the more dramatic of these was the

not-so-gradual evolution of the ankle-length bathing suit into the bikini, and

the development now occurring before our very eyes of the bikini into the

topless suit. There is little doubt that nude bathing will be common on

many beaches before many more years. None of these facts, considered

simply as facts, need embarrass the "reluctant" defender of the legitimacy

of the offense principle. One can imagine similar changes in the conditions

for the application of the harm principle, but they don't weaken anyone's

confidence in that principle. Conduct that is banned at a given time because

it spreads disease ought not to be banned at a subsequent time when that

disease is rendered harmless by universal vaccination. Similarly, conduct

that causes universal offense at a given time ought not to be banned at a

later time when many people no longer are offended, whatever the cause of

the change. The two cases seem to me to be precisely on the same footing

in this respect.

Cultural change, however, causes a problem for the defender of an offense principle more serious than any caused for the harm principle by

technological change. The principle as mediated by the extent of offense

standard seems to permit punishment of offenders in the transitional stage

that is unfair and morally unsettling. It is true by definition that the vast



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OFFENSE T O OTHER S



majority of people are "not the first by whom the new is tried, nor yet the

last to cast the old aside." The vast majority, then, have little to fear from

laws derived from the restricted offense principles. Reformers and trendsetters, on the other hand, those in each generation who are responsible for

the movement and direction of the prevailing sensibility, may not be so

fortunate. Mow do the sensibilities of people (as opposed to their moral

judgments and opinions) come to change? Surely one of the more common

causes of such change is a steady increase in the number of offending cases.

What once caused spontaneous horror, revulsion, shame, or wrath, becomes less horrifying and revolting as it becomes more common. We become accustomed to it, and hardened against it, and then invulnerable to it,

and finally (even) tolerant of it. But what of those offending persons who

have the misfortune to engage in a given type of behavior during the transitional period between the time when the qualified offense principle clearly

applies and when it clearly no longer can apply? Some of them, no doubt,

will be punished for what may be done a year later with impunity—and

according to my principle, rightly so. These unfortunate chaps are in a way

like the last soldiers to be killed in a war. They are treated no worse than

their predecessors were in an earlier period, who were punished in the same

way for the same thing, but coming near the end of an earlier stage of

cultural history their punishment is somehow more poignant. To a later

tolerant age, they will appear to be martyrs punished for exercising their

rightful liberties a trifle prematurely. More to the point, their conduct had a

direct causal influence on the attitudes and sensibilities they were punished

for offending. Their punishment was for conduct that helped destroy the

very conditions that rendered that kind of conduct legitimately criminal in

the first place.

Thus, I could be in the uncomfortable position of making a case for the

punishment of anti-war demonstrators in 1965 for parading a Viet-Cong

flag (shocking!) while denouncing the punishment of other protestors in

1970 for doing the same thing (yawn). Rapid cultural change will always

claim some victims in this way, and perhaps I should sadly conclude that

some unfair martyrdom in the transitional stages is simply inevitable, a

tragic fact of life. My discomfort in this position is at least mitigated by the

thought that martyrs to the cause of cultural change, in my view, should

never be subject to more than very minor penalties or coercive pressure. So

the "tragedy" of their punishment is not at all that lamentable. Moreover,

those who are penalized for anticipating rapid changes already in progress

will soon enough be vindicated by the very changes they helped to produce,

which should be ample reward and compensation for most of them.