Letters of Intent

Pankaj Raval (00:03)
Well, hello everybody and welcome back to another episode of Letters of Intent. I am Pankaj Rabel, the founder of Carbon Law Group. And today our co-host Sahil Chaudhry is on vacation. So you have me and a wonderful guest who I've gotten the pleasure of knowing over the years and who works with Carbon Law Group as our IP litigation counsel and is a wonderful attorney who you're going to learn more about. that's Sarah Gold. Sarah, welcome to the podcast. Thank you for being here.

Sara Gold (00:31)
Thanks, it's a pleasure to be here.

Pankaj Raval (00:32)
So Sarah, you and I have been getting to know each other for the last year, year, maybe year and a half on a variety of different IP matters. I'd love to maybe jump in and have you tell us a little bit more about your background and what made you become an IP attorney and what does that mean? What kind of cases do you work What's exciting about this world of intellectual property to you?

Sara Gold (00:53)
I've been in IP ever since I became a lawyer. After working at a law firm for a few years, I started my own solo practice that now works in collaboration with Carbon Law Group, which has been a pleasure and a joy. I focus primarily on trademark and copyright cases. On the infringement side, trademarks are...

logos, slogans, images, anything that is used to identify the name or identity of a business. McDonald's Arches, know, Nike Swoosh, all those great things. Those fall within the category of trademarks. The other side of the coin are copyrights, which protect artistic products and creations. Think books, movies, plays, and

There can be infringement considerations both as a plaintiff pursuing a claim as well as if you're on the defense side and you've received a demand letter and need assistance on that end.

Pankaj Raval (01:45)
Fascinating. really, really cool. And I'd love to hear a little bit more about your background too. You it's always fun, you know, learning more about people before they became lawyers. So could you share with us a little bit about like, you know, where you went to school, led you to this, to the field of law? then also, yeah, specifically what led you to intellectual property? has that been so interesting to you?

Sara Gold (02:07)
I've always been a writer. I've always loved to write. I was a news journalist before going into law. always been drawn toward the inquisitiveness and the investigative nature of news. So turning that into a career in law seemed to be a very natural lawyers were trained to be inquisitive, were trained to look for answers, were trained to seek truth and to serve our communities, all of which I enjoy doing as an intellectual property lawyer.

Pankaj Raval (02:34)
Fascinating. Did you always know you wanted to become a lawyer, even as a journalist?

Sara Gold (02:40)
No, actually, I was always a writer and initially I thought that I was going to work in news and my dad actually was the one to suggest, hey, if these are your skill sets, a career in law might be a good fit for you. So I really took a leap of faith, applied to law school. I graduated from California Western School of Law in San Diego and

Pursuing intellectual property specifically did seem like a natural byproduct of my writing background. In the field of news, you are constantly creating products, which are, of course, the subject of copyrights. And also have to consider First Amendment considerations, free speech, all of those factors that also play a large role in trademark and copyright cases.

Pankaj Raval (03:24)
Yes, interesting. Okay, so this makes more sense now as to why, okay, why copyright and trademark even are so interesting to you because of your background in journalism and now the use of copyrighted material, especially news material is a hot topic in the world of AI. So there's a few things that I think we're going to discuss today, but I would love to jump into that. You know, just the...

the use of copyrighted material in the world of AI that we live in today, what are your thoughts on some of these cases now that are going through the courts and even in general, how these AI companies have been using news material, copyrighted material? Do you feel like it is a violation of the law? how do you think this might play out going forward?

Sara Gold (04:09)
So far, there haven't been a lot of definitive decisions from the courts. There are a number of high profile lawsuits filed by a wide variety of plaintiffs from journalism, from music production, entertainment, all of whom allege that these AI models are using these copyrighted characters and products to mold their machine learning in order to give the end user

answers or content. It's a very interesting question of whether these kinds of end products might be protected by fair use. Generally, fair use is designed to give people the free speech ability to adapt copyrighted material in a way that adds new expression. Copyright and trademark law are both designed to be protective of IP but also

not restrictive of the right to free speech. So there's an interesting balance there. But because fair use is such a fundamentally policy driven doctrine, it is a very new question of whether our society should allow or want AI companies to use copyrighted material. is no bright line answer on whether something is considered fair use. That really is.

a value judgment, although the statute prescribes certain factors, judges and courts are the ones weighing those factors and those judges and courts apply their own concepts of what is considered fair, what is considered exploitative, what is or is not considered necessary to achieve an end product. So ultimately, we as a society and as a judicial system will have to make that value judgment as to whether we think that the benefits

of allowing copyrighted material in AI products outweighs the harms.

Pankaj Raval (05:53)
Very interesting. so right. This is new subject, something going to be some time now. And we're already seeing going through the courts. I know the New York Times has sued, I believe, OpenAI, a variety of other companies, Just I read yesterday that are some suits, I think, being brought by media MidJourney.

over their use of copyrighted images. I think this is probably tip of the iceberg of probably what we're going to see going forward in terms issues. love to kind of maybe back up a little bit too, and just for listener who maybe is not familiar with fair use and even of copyright law, can you tell us a little bit about what fair use is what creates law in the US?

And does that apply globally? Because I think today we live in a very global world too. So what does that mean in the context being the U S and the U S also does that mean in terms IP globally? Like what if you're trying your rights around the Does someone in India or China have the ability to take your copyrighted work if it's copyrighted in the U S? So I know those are kind of big questions, but maybe we can start with just.

copyright law in general? Where does it come from? And then maybe talk a little bit about fair use and then talk about kind of what the global implications as well.

Sara Gold (07:04)
Copyright law protects artists and creators, people who create books, films, plays, photography, artwork. All of that is subject to copyright protection given that there's at least a modicum of originality, which is usually fairly easy to satisfy. You get copyright protection as soon as the work is created.

However, if you want to enforce those rights, you do need a US copyright registration if you want to prosecute infringements that are occurring within the US. If there are out of country actors that are infringing, those infringements would only be actionable under US law if those infringements are occurring in the US. And there have been a few fringe cases testing the limits of whether out of

country conduct is sufficiently connected to the U.S. for U.S. law to apply. That said, there are other countries that have their own copyright systems and if any particular copyright owner a particular concern about infringement in a particular country, they might want to consider obtaining copyright protection in that particular company, perhaps in addition to U.S. protection. But because a lot of sales of products

Pankaj Raval (07:56)
Hmm.

Sara Gold (08:16)
do tend to happen in the US. And because so much commerce nowadays is international, a lot of times there can be a US nexus to link to in order to invoke US copyright law.

Pankaj Raval (08:29)
And I would imagine it gets even more complicated nowadays with internet, where the internet is everywhere, right? Like what if your website, it's viewable around the world. So, you what does that mean in the context of copyright law as well? Is that right?

Sara Gold (08:41)
That is right. And there are a number of factors that would play into that threshold determination. You'd have to make sure that the website is accessible in the US. If some kind of product is being sold, you'd want to ask whether that product is being sold to people in the US. But US copyright protection generally is valuable. And it also is not all that expensive. Even factoring in attorney's fees, the cost registration.

is designed to be accessible and affordable.

Pankaj Raval (09:10)
speaking of and registration, so it sounds like you can file a copyright application to register a copyright. There's also certain rights you have if you don't register a copyright but you're limited in terms your remedies. Let's say you have a copyright now and you find someone's infringing on What are your options? And tell us a little bit about some recent developments of

new methods of enforcing your copyright.

Sara Gold (09:36)
Historically, in order to qualify for enhanced damages under the U.S. Copyright Act, the owner would have needed to have a registered copyright in hand at the time of the infringement. Unfortunately, that's not always the case, especially with newer artists or artists that don't have legal teams. They might find that their work has been infringed and they didn't already have that copyright in place. So to address that problem,

The U.S. Copyright Office developed a new program called the Copyright Claims Board. It's fairly new. It was developed a little over two years ago and it is an alternative dispute forum to federal court where litigants can prosecute these types of infringements at lower cost and without having had that original registration so long as you apply for one concurrently when you file with the CCB.

Pankaj Raval (10:27)
Interesting, interesting. as long as you have applied, so let's say I have an image, I took a photograph of something, put it online, and I found someone else using it for commercial purposes, taking into consideration the fair use analysis, let's say it's pretty clear to use infringement. But I don't want to spend a bunch of money litigating in federal So now essentially, if I didn't registration, could file for registration.

I, there a time limit on when like, let's say I took this one two years ago. Does that matter in terms of filing the registration application for registration now?

Sara Gold (10:58)
There is no time limit on when you can register a copyrighted work, but when there's an infringement involved, you do have to sue either in federal court or at the CCB within three years of either when the infringement happened or when you knew that the infringement happened in the event that you found out about the infringement after the fact.

Pankaj Raval (11:19)
Interesting, interesting. And, and again, what's the word the remedies like what kind of remedies does the the CCB provide?

Sara Gold (11:27)
The CCB is designed to be a small claims type court. So you can't earn as much money as you would if you were prepared with that registration have standing in federal court. it's better than not having any remedy at In the small claims court, you are eligible for up to $15,000 per infringed work.

Pankaj Raval (11:47)
another issue that comes up a lot, think, and people even listening to this if you're a business owner, may with this or be dealing with it is, there's a lot of these enforcement law firms out there, will send out letters

think you've infringed on a copyright, represent these large companies that massive copyright Let's say you receive one those letters. What do you suggest to do? What does a small business owner they get a demand from one of these law saying, oh, you owe us $100,000 or whatever, let's say even $50,000 because copyrighted works on your

What does one do in that

Sara Gold (12:22)
The first thing you'll want to do is hire a qualified copyright attorney. Carbon works on these types of matters. The first question that you and your attorney will want to explore is whether or not the asserted is actually something that you've used. Sometimes the letters may not match up with your actual activity. So you want to make sure that they're alleging a photo that you've actually used in some shape or form, usually online.

And the second question would be whether or not that photograph is actually protected by a copyright registration. You'd be surprised to see how many times plaintiffs will try to prosecute infringements and there wasn't a copyright registration. if that's the case, can't even sue unless and until there is a copyright So that would be the second initial question.

After that, your counsel and you could explore options of if there is a viable claim, how that might be approached in terms of settlement or litigation defense.

Pankaj Raval (13:10)
I'm sure.

those are great tips because I deal with a lot of clients, as you said, come to us with these concerns, they used an image and, oftentimes, more often than not, we see those letters overstating the rights of the claimant, right? Of, the party that is making this demand. and they're making some usually kind of egregious demand, like some kind of

very high number that they throw out there thinking that, okay, they'll probably negotiate it for much lower numbers. So I think it's good for just any listeners who have dealt with this with this or concerned about it, just recognize that it's good to have a lawyer, good to have an experienced who's dealt with this advise to best navigate this issue not necessarily...

get to have a heart attack when you get that letter, because a lot that can be done to ideally reduce your exposure.

Sara Gold (14:03)
Absolutely. And I think that also speaks to the importance of having systems in place when you post content online or anywhere else to make sure you're not stealing random photos from the I think in our digital age, there's more of an expectation of free access to everything, whether it's movies, media, photos. there are still copyright laws. And just because you can find something online,

and post it doesn't mean that it's necessarily free or yours to use. it's important to make sure that if you are posting photos online that using licensed photos from or some other repository.

Pankaj Raval (14:41)
Absolutely. Absolutely. That's such a good point and a very important one to to get licensed material nowadays is pretty Canbook, Subscription, Envato, Artlist, services out there that you can pay pretty nominal amount, especially compared to a copyright lawsuit, to get licensed music, licensed images, video you can use freely.

Again, you do probably have to look at the license itself it's good to also maybe consult with an attorney to make sure you can use it in all contexts because some licenses are limited. You may have a license to use it in certain countries or you just have to make sure you look at what that license actually gives you. we've advised clients on that before because it's become an issue when they have a larger scale production with a network of sorts and they aren't sure whether they can use

those, the music or the images there. really, really good insight you've provided. now I want to maybe shift a little bit, Sarah, to of just understanding in general. You talked a little bit about the difference in, you know, there's trademarks, copyrights, patents, but know, we do a lot of trademark work here too at Carbon and you've been, you know, such a instrumental, consultant insight, you know, providing such great insight on some of these trademark cases that we've dealt

Can tell me a little bit about the difference between trademark and copyright and what is the purpose of registering a trademark? Why is it important to register a trademark copyright and is there any kind of overlap?

Sara Gold (16:00)
Just like you want to register your copyrights, you also want to make sure to register your trademarks. one difference there is that you are not required to have a trademark registration order to sue for infringement. it can prove extremely helpful it provides a legal presumption that you are in fact the rightful owner of the mark. Another important reason to register as soon as you can is because you don't want someone else using the same mark or something really close to it.

to swoop in and register first. And if you started using the trademark and you try to assert that right against someone else and you don't have a registration, when the other party receives that letter, they're going to try to beat you to the trademark office. So certainly before sending any kind of demand or complaint letter an election fringer, you absolutely want to make sure that you have the trademark registration at least pending. great part about the trademark office

is that you get priority of use the minute you click the file It can take upwards of a year to actually get a registered trademark, but once you submit the application, your application then has priority over anything else that might be filed to the day after you do.

Pankaj Raval (17:11)
Interesting, What if I have used my name for five years but never decided to register the trademark? Do I have any rights in that situation?

Sara Gold (17:21)
It depends on whether you're the true first user of the mark. If you truly are the first person to use this mark in your particular industry, then there is a good chance that you will have trademark rights. There are some other requirements to get a setting those aside, if you're the true first user, then you should be able to get a trademark registration, assuming that all other requirements are met.

Pankaj Raval (17:45)
Is there any value to registering at a state level versus the federal level for a trademark?

Sara Gold (17:50)
A federal trademark is the most appropriate if you are a business doing business in multiple states. One of the key requirements of federal trademark registration is that you do have to be doing commerce interstates. It doesn't have to be incredibly frequent. If you run a restaurant in cool area of town where tourists might come from out of state.

sufficient. You don't have to be doing regular interstate commerce, but you do have to be able to show that at least someone from outside of your home state has used your business and that should be enough to qualify for interstate commerce. Most trademarks that we've dealt with typically qualify for interstate commerce. Estate trademarks are more appropriate when it really is a local business. Like one time I worked with a local swap meet.

and they don't tend to have people come in from other places. So if that's the case, then you might qualify for state protection, which would your exclusive right to the mark within your geographic state.

Pankaj Raval (18:55)
when it comes to trademarking, is there a benefit of using a lawyer versus going online with an online filing service? Are there any risks with using an online service?

Sara Gold (19:05)
all for reducing business costs where possible. problem with the online do-it-yourself trademarks is that they don't have the nuanced understanding of how the system works and how to avoid pitfalls and how to avoid rejections from the trademark office. They don't understand truly what your services are and what you provide. So I've seen applications filed through online systems where the stated services

weren't even what the clients were doing in practice. That provides risks when you're trying to enforce your trademark if there's a mismatch between what you actually do and what the trademark says that you do. A lot of these applications done through online systems also get rejected for a variety of reasons. And I've received a lot of those clients from people who needed their trademarks corrected in some way, and some of them couldn't be corrected.

Pankaj Raval (19:43)
That's a great point.

Sara Gold (19:57)
So although it might be a cost saving at the beginning, it can incur much more cost if you have to fix the application with an attorney or if you have to start the process over with an attorney.

Pankaj Raval (20:08)
a good point. had several people come to us too over the years, dozens of clients who have filed online and now are dealing with some, it especially gets hairy when you have some enforcement issue or someone's suing you and there's maybe a question about first use date. I think that's where things get really hairy because can really dissect each and every trademark application and question whether it was done right. Is that first use date right?

Um, because lot of ways as trademark attorneys, can try to attack a trademark application. maybe you can talk to us a little bit about like, are ways filed a trademark application and someone says, Hey, well, actually I was the first user and this person, saw my brand and they're just trying to almost like squat on my name by filing a trademark But I was actually been using this for a Are there ways we can actually.

try to invalidate that application that was filed.

Sara Gold (20:58)
Yes. In order to invalidate a registered trademark that you think you have superior rights to, you would need to either go through federal court or go through the trademark office to challenge those Ideally, you would want to file the trademark when you start using the mark to prevent other people from swooping in later, but life isn't perfect and if that didn't happen and someone else registered first, there are avenues to challenge that.

and you'd want to consult a qualified attorney to help you do that.

Pankaj Raval (21:26)
Okay, so all hope's not lost if a brand owner has a trademark, they've been using it, just neglected to file and someone beat them to it, there's still options for them in terms of obtaining a commission.

Sara Gold (21:36)
There are still options, but you do

want to act quickly you discover that someone is using that mark, because there are statutes of limitations. In the trademark context, it is a little less and it does vary from state to state trademark statutes of limitations. But if a few years passed when you knew about that other mark and you didn't do anything, you could lose your right to contest.

Pankaj Raval (22:00)
That's a great point. So we to act quickly. you do find out about very good to know. In talking a little bit more about the trademark process, though, Let's say you file an application for your trademark. What happens next? And can you walk us through some of the scenarios brand owners after the application's filed?

Sara Gold (22:16)
I key is that you want to have an attorney that you trust representing you because all of the communications from the trademark office will be sent to that attorney. if they don't send it to you or don't act promptly, that could prejudice your rights. So you want to make sure you're working with a firm that you like and trust. After you file the application, potentially with the help of an attorney, it takes around six months for the trademark office to respond.

Many times they will approve the trademark and then the trademark goes into what's called an opposition window. That gives potential opposers 30 days within which to file any objections to your trademark. That could happen if there's another person that's using a similar mark. A lot of times those things might be flagged by the examiner, in which case you might get an initial refusal.

But if the examiner clears it but someone else has a different opinion, you might hear about that in opposition. Many times there are no challenges during opposition. And at that point, if you've submitted an acceptable evidence or statement of use, once that's submitted, then your mark would proceed to register.

Pankaj Raval (23:22)
And how long does that whole process generally take?

Sara Gold (23:24)
It takes about six months to get an initial response from the trademark office. If they approve of it at that point, it takes another couple months to clear through opposition. And then it could take another couple months after that to finally get the registration. If you file the original application without the evidence of use, which you are allowed to do, allowed to do that on an intent use basis if you're preparing to launch a trademark but haven't done so yet.

And that's actually an advisable strategy if you're preparing to launch a then you get your application in the queue faster. you're able to set that priority date above anyone else who might try to use your mark later. So if you did not submit that evidence of use upfront, then you would have the ability to do so after the mark clears through opposition. And if you're filing the evidence of use at that later point, it might take a little longer.

to get the you file the evidence of use upfront because you're already using the mark at the time that you you could have a registered trademark within about a would be probably the quickest time span.

Pankaj Raval (24:25)
Interesting. And what if you get a rejection or the examining attorney looks at your mark and issues an office action? do you have to do then? Like, how do you deal with an office action?

Sara Gold (24:35)
If you file the mark on your own or through a web service and you do get a rejection, that's where you would really experienced attorney to help you not something that can be done through formula or necessarily through really need someone who understands the of trademark law to evaluate whether or not it is a rebuttable office action. Sometimes there are problems with trademarks that can't be fixed.

Consulting with an attorney in advance of filing can also help weed out some of those problems because if there are some obvious reasons why your mark cannot be registered, you may not want to go through the process of applying. But there are also times where an attorney could help you attempt to rebut those issues. And ultimately the decision is made by a person. It's made by a person who works at the trademark office.

Pankaj Raval (25:13)
Hmm.

Sara Gold (25:25)
So you can never guarantee whether or not the examiner might change their mind, but in some instances they could change their mind. And if they don't, then there could be avenues to reconsider it or to appeal it to a higher board.

Pankaj Raval (25:39)
Interesting. Can you tell us what would that next step be? Let's say they arguments. is the next step to kind of final action examining attorney?

Sara Gold (25:49)
The most common refusal is called a likelihood of confusion refusal. That's what happens when the trademark examiner believes that there is another trademark that precedes yours that is close enough to your industry and that looks close enough to your trademark to be too close of a match.

And for that type of rejection or any other, the next step would be either to request reconsideration. asking the same examiner to look at it again. In my experience, that doesn't always make a difference, but you can. it's free. Alternatively, or in addition, you can pay a fee to institute an appeal with the Trademark Appeals Board.

And that's when you get a new group of judges to look at your trademark application and see whether or not the trademark should register.

Pankaj Raval (26:35)
Interesting, And is there anything beyond the trademark appeal board? Like, what if they say no?

Sara Gold (26:41)
At that point, you would really want to work with your counsel to see whether or not there is a reasonable basis to register. And if there is, you can appeal the appeals decision to a federal court.

Pankaj Raval (26:53)
That's fascinating. let's say, you know, there's the process of registering a trademark does seems like it takes about a year. Is there any way to fast track it or any ways you could expedite the review?

Sara Gold (27:04)
What really expedites review is working with an attorney in advance to make sure that obvious errors are not included in the application.

Pankaj Raval (27:12)
know there's this process of registering a trademark and take a long time and also wanted users aware of there are...

unique circumstances in which you can maybe expedite or fast track a application review and potential registration. And that's something to consider and consult counsel about. But we've done this for certain clients when there's impending litigation, when they need to enforce a maybe they didn't even register it someone else is using their name. I we had this issue come up with a service provider client where someone copied their name, almost copied their website. And we had to expedite the

trademark registration so we could actually sue in federal court. and there's situations where okay maybe for marketing you're putting major marketing campaign together. The USPTO may consider that also in expediting trademark. There's very nuanced and very specific reasons that will happen. It doesn't happen often. I think 20, 30 that are done a year but they will do it on specific circumstances. So just something to keep in mind.

Sara Gold (28:09)
That's great information. Absence, circumstances, if you're just trying to get a trademark and you do want the process to go faster, the best way to do that is by working with qualified counsel to make sure that there in the application that could slow down the process.

Pankaj Raval (28:26)
Absolutely. So Sarah, you this has all been really, really insightful. You provided a wealth of knowledge on and trademarks. And also we talked a little bit about love to get, you maybe just your kind of looks like owners in terms of registering IP, using IP, leveraging IP the world of AI. Any issues you think that they should maybe be looking out for or consider?

as they try to build their IP portfolio going forward.

Sara Gold (28:52)
Especially in the trademark context, it's important a name search before you build your brand. All too often, companies will just kind of pick a name and go with it and build it up and then find out years down the line that it's a potential infringement. So especially with the growing number of registered trademarks, you want to make sure that whatever name you're using and investing in isn't infringing on someone else's rights.

In terms of copyright, if you are a business owner that's just posting content, you do, like we discussed before, want to make sure that any images you're using are licensed. It's all too easy to assume that just because content is available that it's OK to use. That's not necessarily the case. And a lot of people have an incorrect idea of fair use. And they might be too optimistic that their planned use would

count as fair Contrary to popular belief, fair use is not necessarily a catch-all for anything that you're using on your own or in some kind of creative fashion. It's a more narrow doctrine that is really reserved for when you're using someone else's in order to rely on that work and the message of that work to add meaning. If you're taking a photo from somewhere and

using it just to show the photo, even if you're using it on your own site or your own blog, not enough to elevate it to fair use. I think that's where lot of people and business owners are a little misinformed on that topic.

Pankaj Raval (30:24)
I think we could probably have a whole talking about just fair use and maybe we'll do that in the future if people are interested because it's a very topic that goes through rigorous analysis in many different cases. If you read any kind of copyright case, the amount of time and effort spent on analyzing fair use is significant. So I appreciate you raising that and reminding people of that analysis.

and also I just wanted to make sure people understand and Sarah, can, you can also add comment too, but there's I think, out there that says, well, you can use 30 % or maybe 70 % of a work. As long as you change it by okay. and that's not true. Is that, is that right? Sarah, from my understanding 30 % number is really made up.

Sara Gold (31:05)
There is no quantitative threshold under copyright law. The courts will ask whether or not there's substantial similarity between the two works. And that can really depend on size of the original work and the size of the infringing work. There are a number of considerations that go into that. So there's no standard you can objectively compare against.

So if you are quoting from other material, you want to make sure that it's done in a way that elevates that material and for which the use of that material is essential because you're perhaps critiquing or commenting on it. can't just take things and try to them on your website and think just because, it's my website and it's in a little bit of a different context that now it's fair use. Fair use is a bit more of a restricted doctrine.

and want to exercise caution. And if you're ever in doubt, hire counsel to assist you.

Pankaj Raval (32:01)
Well, this has been super interesting and Sarah. I want to really thank you again your time experience and expertise and also collegiality over the years. a great help with a lot of our many disputes and settlement matters that have come up over the years and enforcement issues. know, we're really the team of

of lawyers and professionals that we have working with us here at Carbon Law Group. any listeners are looking for advice or additional insight on intellectual property matters, business matters, corporate matters, we're here to help. And you all for listening today. And Sarah, again, thank you so much for your time and insight and help and support over these years. So with that, thank you so much, Have a wonderful and hope to do this again.

Sara Gold (32:46)
Thanks for having me. Have a great day.

Pankaj Raval (32:48)
Thank you.