Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7210 Page 1 of 15
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`FILED
`JUN 1 0 2022
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`1 RANDY S. GROSSMAN
`Acting United States Attorney
`2 MELANIE K. PIERSON
`SABRINA L. FEVE
`3 Assistant U.S. Attorneys
`California Bar No. 112520/226590
`4 Office of the U.S. Attorney
`880 Front Street, Room 6293
`5 San Diego, CA 92101
`Tel:
`(619) 546-7976
`6 Fax:
`(619) 546-0631
`Email:Melanie.Pierson@usdoj.gov/Sabrina.Feve@usdoj.gov
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`CLERK, U.S. DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`B
`DEPUTY
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`CANDINA S. HEATH
`8 Senior Counsel
`Texas Bar No. 09347450
`9 Computer Crime and Intellectual Property Section
`U.S. Department of Justice
`10 Washington, D.C. 20005
`Tel:
`(202) 307-1049
`11 Email: Candina.Heath2@usdoj.gov
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`12 Attorneys for United States of America
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`UNITED STATES DISTRICT COURT
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`SOUTHERN DISTRICT OF CALIFORNIA
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`UNITED STATES OF AMERICA,
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`Case No. 18-CR-4683-GPC
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`Plaintiff,
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`v.
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`JACOB BYCHAK,
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`Defendant.
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`PLEA AGREEMENT
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`IT
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`IS HEREBY AGREED between
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`the plaintiff, UNITED STATES OF
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`AMERICA, through its counsel, Randy S. Grossman, United States Attorney,
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`and Assistant United States Attorneys Melanie K. Pierson and Sabrina L.
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`Feve, and Computer Crime and Intellectual Property Section Senior
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`Counsel Candy Heath, and Defendant JACOB BYCHAK, with the advice and
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`consent of Jessica Munk, counsel for Defendant, as follows:
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`II
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`II
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`Def. Initials lJi__
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`1 0 _r,o_ /IC. 0 'J _f"'D/"'
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7211 Page 2 of 15
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`I
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`THE PLEA
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`Defendant agrees to plead guilty to Count 1 of the Superseding
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`Information charging Defendant with:
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`Conspiring with others to knowingly and falsely represent
`themselves to be the registrant and legitimate successor in
`interest to the registrant of 5 or more Internet Protocol
`addresses, and intentionally initiate the transmission of
`multiple commercial electronic mail messages
`from
`such
`addresses, in and affecting interstate commerce, on or about
`between December 2010 and September 2014, within the Southern
`District of California, in violation of 18 U.S.C. §1037 (a) (5)
`and (b) (3), a misdemeanor.
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`The Government agrees to (1) move to dismiss the remaining charges
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`in
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`the underlying
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`Indictment without prejudice when Defendant
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`is
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`12 sentenced, and (2) not prosecute Defendant thereafter on such dismissed
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`13 charges unless Defendant breaches the plea agreement or the guilty plea
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`14 entered pursuant to this plea agreement is set aside for any reason.
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`15 The defendant agrees to waive the Statute of Limitations and any double
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`jeopardy rights and allow the filing of this Superseding Information.
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`17 If Defendant breaches this agreement or the guilty plea is set aside,
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`18 section XII below shall apply.
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`This plea agreement is part of a "package" disposition as set forth
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`in Section VI.E below
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`II
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`NATURE OF THE OFFENSE
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`A.
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`ELEMENTS EXPLAINED
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`The offense to which Defendant is pleading guilty has the following
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`25 elements:
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`1. Beginning on or about December 2010 and ending on or about
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`27 September 2014 there was an agreement between two or more persons to
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`Def. Initials j Q
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7212 Page 3 of 15
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`1 commit the offense of electronic mail fraud, in violation of Title 18,
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`2 United States Code, Section 1037 (a) (5) and (b) (3);
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`2. The defendant became a member of the conspiracy knowing of
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`4 its object and intending to help accomplish it;
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`3. The defendant or a co-conspirator knowingly and falsely
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`represented himself to be the registrant or the legitimate successor in
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`interest to the registrant of 5 or more Internet Protocol addresses;
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`4. The defendant or a co-conspirator intentionally initiated
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`the
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`transmission of multiple electronic mail messages
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`from
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`such
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`5. The electronic mail messages were
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`transmitted in and
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`12 affecting interstate commerce.
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`B.
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`ELEMENTS UNDERSTOOD AND ADMITTED - FACTUAL BASIS
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`Defendant has fully discussed ~he facts of this case with defense
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`15 counsel. Defendant has committed each element of the crime and admits
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`that there is a factual basis for this guilty plea. The following facts
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`17 are true and undisputed:
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`1.
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`At all relevant times, Defendant worked for a San Diego-
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`19 based internet marketing company called Frontline Direct, then Adconion
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`20 Direct and then Amobee (hereinafter referred to collectively as Company
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`21 A). As part of his duties at Company A, Defendant managed
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`the
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`22 acquisition and announcement of Internet Protocol (IP) addresses. The
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`23 defendant knew and intended these IPs were to be used to send multiple
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`24 commercial electronic mail messages to persons throughout the United
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`25 States.
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`2.
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`During
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`the period of
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`the conspiracy,
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`the defendant
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`27 agreed with other co-conspirators working at Company A to purchase 11
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`Def. Initials _, !1
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7213 Page 4 of 15
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`1 domain names associated with IP addresses from Daniel Dye of GetAds
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`(the "GetAds IPs") and announce these IP addresses via Vincent Tarney
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`3 of the Mata Group and others so that the GetAds IPs could be used by
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`4 Company A to send multiple commercial email messages throughout the
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`5 United States. The GetAds IPs included the IP addresses associated with
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`the domain names ect.net (165.192.0.0/16), Telalink.net (207-234.0.0/17
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`7 and
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`207.152.0.0/18),
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`SierraSemi.com
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`(151.192.0.0/16),
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`8 openbusinesssystems.com
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`(168.129.0.0/16),
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`Moore-Solutions.com
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`(167.87.0.0/16),
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`TrinityMicro.com
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`(63.79.40.0/21),
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`Paxny.com
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`(208.199.68.0/23),
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`Sura.net
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`(163.253.0.0/16),
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`Cdnair.ca
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`(142.147.0.0/16),
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`Mediavis.com
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`(149.118.0.0/16)
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`and
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`Internex.net
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`(various). The domain names associated with the GetAds IPs allowed the
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`13 defendant and his co-conspirators to control the IP addresses although,
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`14 as the defendant was aware, neither he, nor his co-conspirators nor Dye
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`15 nor GetAds were the actual registrants or legitimate successors in
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`interest for these IP addresses.
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`3.
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`To announce some of the GetAds IP netblocks, Dye provided
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`18 defendant and his co-conspirators with Letters of Authorization
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`("LOAs"), which falsely attested that the true registrant of the IP
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`20 addresses had authorized use of the IP addresses. The LOAs provided by
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`21 Dye used the name and a fictitious letterhead of the IP address block's
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`true registrant. Dye provided the defendant and his co-conspirators
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`23 with electronic versions of LOAs created using word processing software.
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`24 This format enabled the defendant and his co-conspirators to edit or
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`25 alter the LOAs.
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`4.
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`The defendant and his co-conspirators (knowing that they
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`27 were not the true registrants, the legitimate successors in interest,
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7214 Page 5 of 15
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`1 or otherwise authorized by the true registrant) provided these LOAs to
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`2 Tarney and other hosting companies,
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`representing
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`that
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`they were
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`3 authorized by the registrant, to enable Company A to use the GetAds IPs
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`to send bulk unsolicited commercial email to individuals throughout the
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`5 United States.
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`5. After the GetAds IPs were announced and under their
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`7 control, defendant and his coconspirators coordinated Company A's use
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`8 of these IP addresses to transmit multiple commercial electronic mail
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`9 messages.
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`6.
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`The parties agree that the amount of loss attributable
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`the offense is $313,700.
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`III
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`PENALTIES
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`The crime
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`to which Defendant is pleading guilty carries
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`the
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`A.
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`B.
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`C.
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`D.
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`a maximum 1 years in prison;
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`a maximum $100,000 fine;
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`a mandatory special assessment of $25 per count;
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`a term of supervised release of one year. Failure to comply
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`with any condition of supervised release may
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`result
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`in
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`revocation of supervised release,
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`requiring Defendant to
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`serve in prison, upon revocation, all or part of the statutory
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`maximum term of supervised release.
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`IV
`DEFENDANT'S WAIVER OF TRIAL RIGHTS AND
`UNDERSTANDING OF CONSEQUENCES
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`This guilty plea waives Defendant's right at trial to:
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7215 Page 6 of 15
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`A.
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`B.
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`C.
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`D.
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`E.
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`F.
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`Continue to plead not guilty and require the Government to
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`prove the elements of the crime beyond a reasonable doubt;
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`A speedy and public trial by jury;
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`The assistance of counsel at all stages;
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`Confront and cross-examine adverse witnesses;
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`Testify and present evidence and to have witnesses testify on
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`behalf of Defendant; and,
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`Not testify or have any adverse inferences drawn from the
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`failure to testify.
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`V
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`DEFENDANT ACKNOWLEDGES NO PRETRIAL RIGHT TO BE
`PROVIDED WITH IMPEACHMENT AND AFFIRMATIVE DEFENSE INFORMATION
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`Any information establishing the factual innocence of Defendant
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`known to the undersigned prosecutor in this case has been turned over
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`to Defendant. The Government will continue to provide such information
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`establishing the factual innocence of Defendant.
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`If this case proceeded to trial, the Government would be required
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`to provide impeachment information for its witnesses. In addition, if
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`Defendant raised an affirmative defense,
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`the Government would be
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`required to provide information in its possession that supports such a
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`defense. By pleading guilty Defendant will not be provided
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`this
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`information, if any, and Defendant waives any right to this information.
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`Defendant will not attempt to withdraw the guilty plea or to file a
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`collateral attack based on the existence of this information.
`VI
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`DEFENDANT'S REPRESENTATION THAT GUILTY
`PLEA IS KNOWING AND VOLUNTARY
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`Defendant represents that:
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7216 Page 7 of 15
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`A.
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`B.
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`C.
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`D.
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`E.
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`Defendant has had a full opportunity to discuss all the facts
`and circumstances of this case with defense Counsel and has
`a clear understanding of the charges and the consequences of
`this plea. By pleading guilty, Defendant may be giving up,
`and
`rendered
`ineligible
`to
`receive, valuable government
`benefits and civic rights, such as the right to vote,
`the
`right to possess a firearm, the right to hold office, and the
`right to serve on a
`jury. The conviction in this case may
`subject Defendant
`to various collateral
`consequences,
`including but not limited to revocation of probation, parole,
`or supervised
`release
`in another case; debarment
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`government contracting; and suspension or revocation of a
`professional license, none of which can serve as grounds to
`withdraw Defendant's guilty plea.
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`No one has made any promises or offered any rewards in return
`for this guilty plea, other than those contained in this
`agreement or otherwise disclosed to the Court.
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`threatened Defendant or Defendant's family to
`No one has
`induce this guilty plea.
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`Defendant is pleading guilty because Defendant is guilty and
`for no other reason.
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`The disposition contemplated by this agreement is part of a
`"package" disposition with codefendant(s) Mark Manoogian,
`Abdul Mohammed Qayyuum and Petr Pacas. If any defendant in
`the package fails to perform or breaches any part of their
`agreement, no defendant can withdraw their guilty plea or
`withdraw from their agreement, but the Government is relieved
`from and not bound by any terms in any agreements in the
`package.
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`VII
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`AGREEMENT LIMITED TO U.S. ATTORNEY'S OFFICE
`SOUTHERN DISTRICT OF CALIFORNIA
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`This plea agreement is limited to the United States Attorney's
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`Office for the Southern District of California and cannot bind any other
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`authorities in any type of matter, although the Government will bring
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`this plea agreement to the attention of other authorities if requested
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`by Defendant.
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7217 Page 8 of 15
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`VIII
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`APPLICABILITY OF SENTENCING GUIDELINES
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`The sentence imposed will be based on the factors set forth in 18
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`4 U.S.C. § 3553(a). In imposing the sentence, the sentencing judge must
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`5 consult the United States Sentencing Guidelines (Guidelines) and take
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`them into account. Defendant has discussed the Guidelines with defense
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`7 counsel and understands that the Guidelines a re only advisory, not
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`8 mandatory. The Court may impose a sentence more severe or less severe
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`than otherwise applicable under the Guidelines, up to the maximum in
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`the statute of conviction. The sentence cannot be determined until a
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`11 presentence report is prepared by the U.S. Probation Office and defense
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`12 counsel and the Government have an opportunity to review and challenge
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`the presentence report. Nothing
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`in this plea agreement limits the
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`14 Government's duty to provide complete and accurate facts to the district
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`15 court and the U.S. Probation Office.
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`SENTENCE IS WITHIN SOLE DISCRETION OF JUDGE
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`IX
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`This plea agreement is made pursuant to Federal Rule of Criminal
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`19 Procedure 11 (c) (1) (B). The sentence is within the sole discretion of
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`the sentencing judge who may impose the maximum sentence provided by
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`21 statute. It is uncertain at this time what Defendant's sentence will
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`22 be. The Government has not made and will not make any representation
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`23 about what sentence Defendant will receive. Any estimate of the probable
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`24 sentence by defense counsel is not a promise and is not binding on the
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`25 Court. Any recommendation by the Government at sentencing also is not
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`26 binding on the Court. If the sentencing judge does not follow any of
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`the parties' sentencing recommendations, Defendant will not withdraw
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`the plea.
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`X
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`PARTIES' SENTENCING RECOMMENDATIONS
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`A.
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`SENTENCING GUIDELINE CALCULATIONS
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`Although the Guidelines are only advisory and just one factor the
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`7 Court will consider under 18 U.S.C. § 3553(a) in imposing a sentence,
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`the parties will jointly recommend the following Base Offense Level,
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`Specific Offense Characteristics, Adjustments, and
`Base Offense Level [§ 2Bl.1]
`1.
`2.
`Amount of Loss [§ 2Bl .1 (b) ( 1) (G)]
`3. Acceptance of Responsibility [§ 3El.1]
`Combination of Factors [§ 5K2.0]
`4.
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`Departures:
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`12 The parties agree that a downward departure of seven levels for a
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`13 combination of circumstances is appropriate, because the offense is a
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`misdemeanor
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`(while
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`the guideline section is
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`typically applied
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`to
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`felonies), and the agreement allows the government to avoid a prolonged
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`trial during a surge in the ongoing pandemic.
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`B.
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`ACCEPTANCE OF RESPONSIBILITY
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`Despite paragraph A above, the Government need not recommend an
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`adjustment for Acceptance of Responsibility if Defendant engages in
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`conduct inconsistent with acceptance of responsibility including, but
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`not limited to, the following:
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`1.
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`Fails to truthfully admit a complete factual basis as
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`stated in the plea at the time the plea is entered, or
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`falsely denies, or makes a statement inconsistent with,
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`the factual basis set forth in this agreement;
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`2.
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`3.
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`Falsely denies prior criminal conduct or convictions;
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`Is untruthful with
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`the Government,
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`the Court or
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`probation officer; or
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`Breaches this plea agreement in any way.
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`C.
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`FURTHER ADJUSTMENTS AND SENTENCE REDUCTIONS INCLUDING THOSE
`UNDER 18 U.S.C. § 3553
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`Defendant may
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`request
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`or
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`recommend
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`additional
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`downward
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`5 adjustments, departures, or variances from the Sentencing Guidelines
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`6 under 18 U.S.C.
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`~ 3553. The Government will oppose any downward
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`7 adjustments, departures, or variances not set forth
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`in Section X,
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`8 paragraph A above.
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`D.
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`NO AGREEMENT AS TO CRIMINAL HISTORY CATEGORY
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`The parties have no agreement as to Defendant's Criminal History
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`11 Category.
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`E.
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`"FACTUAL BASIS" AND "RELEVANT CONDUCT" INFORMATION
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`The facts in the "factual basis" paragraph of this agreement are
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`true and may be considered as "relevant conduct" under USSG § 1B1.3 and
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`15 as
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`the nature and circumstances of
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`the offense under 18 U.S.C.
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`16 § 3553 (a) (1).
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`F.
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`PARTIES' RECOMMENDATIONS REGARDING CUSTODY
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`The Government will recommend that Defendant be sentenced to the
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`low end of the advisory guideline range recommended by the Government
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`20 at sentencing.
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`G.
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`SPECIAL ASSESSMENT/FINE/RESTITUTION/FORFEITURE
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`1.
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`Special Assessment
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`The parties will jointly recommend that Defendant pay a special
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`24 assessment in the amount of $25.00 per misdemeanor count of conviction
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`to be paid forthwith at time of sentencing. Special assessments shall
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`26 be paid through the office of the Clerk of the District Court by bank
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7220 Page 11 of 15
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`1 or cashier's check or money order made payable to the "Clerk, United
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`2 States District Court."
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`2.
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`Fine
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`The parties will jointly recommend that Defendant pay a fine in
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`the amount of $100,000, which the Court shall order payable forthwith.
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`3. Community Service
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`The parties agree that the defendant will perform 100 hours of
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`8 community service during any period of probation or supervised release.
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`H.
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`SUPERVISED RELEASE/PROBATION
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`If the Court imposes a
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`term of supervised release or probation,
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`11 Defendant will not seek to reduce or terminate early the
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`term of
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`12 supervised release or probation until Defendant has served at least 2/3
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`13 of the term and has fully paid and satisfied any special assessments,
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`14 fine, and community service.
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`15
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`16
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`17
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`XI
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`DEFENDANT WAIVES APPEAL AND COLLATERAL ATTACK
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`Defendant waives
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`(gives
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`up) all
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`rights
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`to appeal
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`and
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`to
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`18 collaterally attack every aspect of the conviction and sentence. This
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`19 waiver includes, but is not limited to, any argument that the statute
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`20 of conviction or Defendant's prosecution is unconstitutional and any
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`21 argument that the facts of this case do not constitute the crime
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`22 charged. The only exceptions are 1) Defendant may appeal a custodial
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`23 sentence above the high end of the guideline range recommended by the
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`24 Government at sentencing (if USSG § SGl.l(b) applies, the high end of
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`25
`
`the range will be the statutorily required mandatory minimum sentence),
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`26 and 2) Defendant may collaterally attack the conviction or sentence on
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`27
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`the basis that Defendant received ineffective assistance of counsel. If
`
`28
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`11
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`~ '[)
`Def. Initials ~ 'SJ
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`1 Defendant appeals, the Government may support on appeal the sentence or
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`2 restitution order actually imposed.
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`3
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`4
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`5
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`XII
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`BREACH OF THE PLEA AGREEMENT
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`Defendant and Defendant's attorney know the terms of this agreement
`
`6 and shall raise, before the sentencing hearing is complete, any claim
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`7
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`that the Government has not complied with this agreement. Otherwise,
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`8 such claims shall be deemed waived (that is, deliberately not raised
`
`9 despite awareness that the claim could be raised), cannot later be made
`
`10
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`to any court, and if later made to a court, shall constitute a breach
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`11 of this agreement.
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`12
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`Defendant breaches this agreement if Defendant violates or fails
`
`13
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`to perform any obligation under this agreement. The following are non-
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`14 exhaustive examples of acts constituting a breach:
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`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
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`22
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`23
`
`24
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`25
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`26
`
`1.
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`2.
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`3.
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`4 .
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`5.
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`6.
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`Failing to plead guilty pursuant to this agreement;
`
`Failing to fully accept responsibility as established in
`
`Section X, paragraph B, above;
`
`Failing to appear in court;
`
`Attempting to withdraw the plea;
`
`Failing to abide by any court order related to this case;
`
`Appealing (which occurs if a notice of appeal is filed)
`
`or collaterally attacking the conviction or sentence in
`
`violation of Section XI of this plea agreement; or
`
`7.
`
`Engaging in additional criminal conduct from the time of
`
`arrest until the time of sentencing.
`
`If Defendant breaches this plea agreement, Defendant will not be
`
`27 able to enforce any provisions, and the Government will be relieved of
`
`28
`
`12
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`Def. Initials :f j~
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`1 A-rR-Ll&:;A~-r.::pr
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`

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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7222 Page 13 of 15
`
`1 all its obligations under
`
`this plea agreement. For example,
`
`the
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`2 Government may proceed to sentencing but recommend a different sentence
`
`3
`
`than what it agreed to recommend above. Or the Government may pursue
`
`4 any charges
`
`including
`
`those
`
`that were dismissed, promised
`
`to be
`
`5 dismissed, or not filed as a result of this agreement (Defendant agrees
`
`6
`
`7
`
`that any statute of limitations relating to such charges is tolled
`
`indefinitely as of the date all parties have signed this agreement;
`
`8 Defendant also waives any double jeopardy defense to such charges). In
`
`9 addition, the Government may move to set aside Defendant's guilty plea.
`
`10 Defendant may not withdraw the guilty plea based on the Government's
`
`11 pursuit of remedies for Defendant's breach.
`
`12
`
`Additionally, if Defendant breaches this plea agreement: (i) any
`
`13 statements made by Defendant, under oath, at the guilty plea hearing
`
`14
`
`(before either a Magistrate Judge or a District Judge); (ii) the factual
`
`15 basis statement in Section II .B
`
`in this agreement; and (iii) any
`
`16 evidence derived from such statements, are admissible against Defendant
`
`17
`
`in any prosecution of, or any action against, Defendant. This includes
`
`18
`
`the prosecution of the charge (s)
`
`that is the subject of this plea
`
`19 agreement or any charge {s) that the prosecution agreed to dismiss or
`
`20 not file as part of this agreement, but later pursues because of a
`
`21 breach
`
`by
`
`the Defendant. Additionally, Defendant
`
`knowingly,
`
`22 voluntarily, and intelligently waives any argument that the statements
`
`23 and any evidence derived from the statements should be suppressed,
`
`24 cannot be used by the Government, or are inadmissible under the United
`
`25 States Constitution, any statute, Rule 410 of the Federal Rules of
`
`26 Evidence, Rule ll(f) of the Federal Rules of Criminal Procedure, and
`
`27 any other federal rule.
`
`28
`
`13
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`Def. I n i t i a l s~
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`1 Q_f""D_/IC.O"J_f""nf""
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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7223 Page 14 of 15
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`1
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`2
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`3
`
`XIII
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`CONTENTS AND MODIFICATION OF AGREEMENT
`
`This plea agreement embodies
`
`the entire agreement between the
`
`4 parties and supersedes any other agreement, written or oral. No
`
`5 modification of this plea agreement shall be effective unless in writing
`
`6 signed by all parties.
`
`7
`
`8
`
`9
`
`XIV
`
`DEFENDANT AND COUNSEL FULLY UNDERSTAND AGREEMENT
`
`By signing this agreement, Defendant certifies that Defendant has
`
`10
`
`read it (or that it has been read to Defendant in Defendant's native
`
`11
`
`language) . Defendant has discussed the terms of this agreement with
`
`12 defense counsel and fully understands its meaning and effect.
`
`13
`
`I I
`II
`14
`15 II
`16 II
`17 II
`18 II
`19 II
`II
`20
`21 II
`II
`22
`23 II
`
`24 II
`25 II
`26 II
`II
`
`27
`
`28
`
`14
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`Def. Initials 'J ~
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`

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`Case 3:18-cr-04683-GPC Document 480 Filed 06/10/22 PageID.7224 Page 15 of 15
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`1
`
`2
`
`3
`
`xv
`
`DEFENDANT SATISFIED WITH COUNSEL
`
`Defendant has consulted with counsel and
`
`is satisfied with
`
`4 counsel's representation. This is Defendant's independent opinion, and
`
`5 Defendant's counsel did not advise Defendant about what to say in this
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`regard.
`
`DATED: June 6, 2022
`
`Respectfully submitted,
`
`RANDY S. GROSSMAN
`United States Attorney
`
`Melanie K. Pierson
`Assistant United States Attorney
`
`ls/Sabrina L. Feve
`Assistant United States Attorney
`
`/s/Candy Heath
`Senior Counsel
`Computer Crime and
`
`Intellectual Property
`
`Section J~
`
`6/6/22
`DATED
`
`JESSICA MUNK
`Defense Counsel
`
`19
`
`IN ADDITION TO THE FOREGOING PROVISIONS TO WHICH I AGREE, I SWEAR UNDER
`PENALTY OF PERJURY THAT THE FACTS IN THE "FACTUAL BASIS" SECTION ABOVE
`20 ARE TRUE.
`
`JACOB BYCHAK
`Defendant
`
`DATED
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`15
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`Def. Initials J,B
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`1A-rP-LlhA~-r.:or
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`