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Revisiting Barlow’s Misplaced Optimism

Revisiting Barlow’s Misplaced Optimism, Symposium for John Perry Barlow, 18 Duke L. & Tech. Rev. 97.

As part of Duke Technology Law Review‘s Symposium for John Perry Barlow, I reflected on the perspective of early Internet luminary John Perry Barlow, the vision he offered, and what I see as the most promising sources of accountability for online behavior. My piece begins:

Barlow’s A Declaration of the Independence of Cyberspace calls for a “civilization of the mind in cyberspace,” and he says it will be “more humane and fair” than what governments have created. Barlow’s vision is unapologetically optimistic, easily embraced by anyone who longs for better times to come.  Yet twenty years later, it’s easy to see some important respects in which reality fell short of his vision.  Alongside the Internet’s many pluses are clickbait, scams, hacks, and all manner of privacy violations.  Ten thousand hours of cat videos may be delightful, but they’re no civilization of the mind.  With a bit of hindsight, Barlow’s techno-utopianism looks as stilted as other utopianism—and equally far removed from reality.

Beyond being overly optimistic about how perfectly the ‘net would unfold, Barlow was also needlessly skeptical of plausible institutions to bring improvements.  He writes: “The only law that all our constituent cultures would generally recognize is the Golden Rule.” But the moral suasion—and practical effectiveness—of the Golden Rule presupposes participants of roughly equal power and status.  It is no small feat to meaningfully consider what Joe User might want from Mega Social Network if the tables were turned and Joe owned the goliath.  As a practical matter, any claim a user has against a goliath requires state institutions to adjudicate and enforce.  When Barlow wrote A Declaration of the Independence of Cyberspace, tech goliaths were much smaller.  Plus, the Internet’s early users were in a certain sense more sophisticated than the mainstream users who eventually joined.  So the gap from little to big was much narrower then, arguably making governments less important in that era.  But as the big get bigger and as the Internet attracts average users who lack the special sophistication of early adopters, governments play key roles—adjudicating disputes, enforcing contracts and beyond.

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Class Action Settlement — Phone Calls and Text Messages Recorded by Twilio updated May 21, 2020

Flowers, et al. v. Twilio, Inc. is a consumer class action alleging that Twilio recorded phone calls and text messages for its customers Handy Technologies and Homejoy and text messages for its customer Trulia, without the consent of all parties to those communications, in violation of California privacy law.

The parties reached a settlement which received final approval by the Court on June 11, 2019. Persons included in the settlement will be eligible to receive a portion of the settlement fund based on whether their recorded communication(s) involved a phone call or only text messages.

Payments to Class Members will be distributed pro rata based on the type of recorded communication. Each Settlement Class Member who had only a text message recorded by Defendant will receive one share, while each Settlement Class Member who had at least one telephone call recorded by Defendant will receive eight shares. The value of one share will be determined by dividing the net settlement fund by the total number of shares allocated to the Settlement Class. The Settlement Administrator estimates that a Class Member with a recorded phone call will receive $64.30 and a Class Member with only a recorded text message will receive $8.04. This is only an estimate and may change as the Settlement awards are finalized. if the Settlement administrator has the correct mailing address for a Class Member, that Class Member will automatically receive his or her share of the Settlement.

Case documents (including Complaint and Class Notice) are available at the settlement website, californiarecordingsettlement.com.

Checks were first mailed out in September 2019 and those expired on December 16, 2019.

In February 2020, the Court approved re-issuing checks to settlement class members who did not cash the first round of settlement checks in 2019.  Those checks were re-issued on March 10, 2020 and will expire on June 8, 2020.

If you received one of these re-issued checks, you must cash it before June 8, 2020 to ensure you get your share of the settlement.  After June 8, 2020, any uncashed settlement checks will be voided and cancelled.

Do not attempt to cash any settlement checks after the void or expiration date listed on the check, or you may be subject to bank fees.  If you still have an uncashed settlement check issued in 2019, you should not attempt to cash it.

If you have any questions about a re-issued settlement check, you can email or call Class Counsel at recordingsettlement@gbdhlegal.com or 1-800-531-4446.  You can also contact the Settlement Administrator at Flowers v. Twilio Settlement Administrator, P.O. Box 404103, Louisville, KY 40233-4103.

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An Introduction to the Competition Law and Economics of “Free” with Damien Geradin

Benjamin Edelman and Damien Geradin. An Introduction to the Competition Law and Economics of ‘Free’.  Antitrust Chronicle, Competition Policy International.  August 2018.

Many of the largest and most successful businesses today rely on providing services at no charge to at least a portion of their users. Consider companies as diverse as Dropbox, Facebook, Google, LinkedIn, The Guardian, Wikipedia, and the Yellow Pages.

For consumers, it is easy to celebrate free service. At least in the short term, free services are often high quality, and users find a zero price virtually irresistible.

But long-term assessments could differ, particularly if the free service reduces quality and consumer choice. In this short paper, we examine these concerns.  Some highlights:

First, “free” service tends to be free only in terms of currency.  Consumers typically pay in other ways, such as seeing advertising and providing data, though these payments tend to be more difficult to measure.

Second, free service sometimes exacerbates market concentration.  Most notably, free service impedes a natural strategy for entrants: offer a similar product or service at a lower price.  Entrants usually can’t pay users to accept their service.  (That would tend to attract undesirable users who might even discard the product without trying it.)  As a result, prices are stuck at zero, entry may be more difficult, effectively shielding incumbents from entry.

In this short paper, we examine the competition economics of “free” — how competition works in affected markets, what role competition policy might have and what approach it should take, and finally how competitors and prospective competitors can compete with “free.” Our bottom line: While free service has undeniable appeal for consumers, it can also impede competition, and especially entry. Competition authorities should be correspondingly attuned to allegations arising out of “free” service and should, at least, enforce existing doctrines strictly in affected markets.

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Class Action Settlement — Refunds for Certain American Airlines Checked Bag Fees

Bazerman v. American Airlines, Inc. is a consumer class action pending in the District of Massachusetts. The plaintiff alleges that American Airlines has charged passengers to check bags that should have been free under American’s contract with customers. On June 22, 2018, U.S. District Court Judge William Young preliminarily approved a settlement. If granted final approval, eligible American Airlines passengers who submit a valid, timely claim will receive either a 75% refund or a full refund plus interest for incorrectly charged bag fees. Awards will range from $18.75 to $200 plus interest per bag. Class members must submit a claim by November 26, 2018 to receive a refund. The final approval hearing is set for February 21, 2019. (Note that these dates were extended by court order.)

The Court has authorized notice to be sent to class members. Class members should receive an email on Saturday, July 21, 2018, with the subject line: “Notice of Class Action Settlement – Refunds for American Airlines Checked Bag Fees.” If you’ve flown on American in the past six years and get this email, you should read it since you may be eligible for a refund. The email includes a class notice and claim form. The case documents (including Claim Form and Class Notice) are available at the settlement website, aabaggagefeesettlement.com.

If you have any questions, you may contact Class Counsel: Linda M. Dardarian, Byron Goldstein, and Raymond Wendell at AAcheckedbags@gbdhlegal.com or 1-866-762-8575, or Benjamin Edelman.

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Updated Research on Discrimination at Airbnb with Jessica Min

In December 2015, Mike Luca, Dan Svirsky, and I posted the results of an experiment in which we created test Airbnb guest accounts, some with black names and some with white names, finding that the latter got favorable responses from hosts more often than the latter. Black users widely reported similar problems — Twitter #AirbnbWhileBlack — and in September 2016 Airbnb responded with a report discussing the problem and Airbnb’s plans for response.

I promptly posted a critique of Airbnb’s plans, broadly arguing that Airbnb’s commitments were minimal and that the company had ignored a simpler and more effective alternative. But ultimately the proof is in the results. Do minority guests still have trouble booking rooms at Airbnb? Available evidence indicates that they do.

Below is a table based on work of Jessica Min (Harvard College ’18) as part of her undergraduate thesis measuring discrimination against Muslim guests. The table summarizes eight studies, with data collected as early as July 2015 (mine) and as late as November-December 2017 (hers), the latter postdating Airbnb’s report by more than a year. Each study finds minority users at a disadvantage, statistically significantly so.

 

Author/title/place and year of publication Dates of data collection Sample size Summary of findings Noteworthy secondary findings
Edelman, Benjamin, Michael Luca, and Dan Svirsky.

Racial Discrimination in the Sharing Economy: Evidence from a Field Experiment.

American Economic Journal: Applied Economics, 2017.

 July 2015 6,400 listings across five U.S. cities Guests with distinctively black names received positive responses 42% of the time, compared to 50% for white guests.

 

 Results were  persistent across type of hosts (i.e. race, gender, experience level, type and neighborhood of listing).

Discrimination was concentrated among hosts with no African American guests in their review history.

Hosts lost $65 to $100 of revenue for each black guest rejected.
Ameri, Mason, Sean Rogers, Lisa Schur, and Douglas Kruse.

No Room At The Inn? Disability Access in The New Sharing Economy.

Working paper, 2017.

 June to November 2016 3,847 listings across 48 U.S. states Guests with disabilities received positive responses less often. Hosts  preapproved 75% of guests without disabilities, but only 61% of guests with dwarfism, 50% of blind guests, 43% of guests with cerebral palsy, and 25% of guests with spinal cord injury. Airbnb’s  non-discrimination policy, which took effect midway through data collection, did not have a significant effect on host responses to guests with disabilities.
Ahuja, Rishi and Ronan C. Lyons.

The Silent Treatment: LGBT Discrimination in the Sharing Economy.

Working paper, 2017.

 June – July 2016 794 listings in Dublin, Ireland Guests in male same-sex relationships were approximately 25 percentage points less likely to be accepted than identical guests in heterosexual relationships or female same-sex relationships. The difference was driven by non-responses from hosts, not outright rejection.

The difference persisted across a variety of host and location characteristics.  Male hosts and hosts with many listings were less likely to discriminate.
Cui, Ruomeng and Li, Jun and Zhang, Dennis J.

Discrimination with Incomplete Information in the Sharing Economy: Evidence from Field Experiments on Airbnb.

Working paper, 2016.

 Three audit studies.  Summarizing the results as to guests without prior reviews:
September 2016 598 listings in Chicago, Boston, and Seattle Guests with distinctively black names received positive responses 29% of the time, compared to 48% for white guests. The authors assess hosts’ apparent reasons for discrimination, including whether hosts were engaged in statistical discrimination and whether reviews reduce the problem of discrimination.
October – November 2016 250 listings in Boston and Seattle Guests with distinctively black names received positive responses 41% of the time, compared to 63% for white guests.
July – August 2017 660 listings in Boston, Seattle, and Austin Guests with distinctively black names received positive responses 42% of the time, compared to 53% for white guests.
Sveriges Radio’s Kaliber show,  Sweden October 2016 200 listings in Stockholm, Gothenburg, and Malmö For hosts who said no to guests with black-sounding names, a second inquiry was then sent from a guest with a white-sounding name. Of hosts who had previously declined the black guest,  many told the  white guest that the listing was available. Methodology follows longstanding testing for discrimination in US housing markets, sending a white applicant after a landlord declines a black prospective tenant.
Min, Jessica

No Room for Muhammad: Evidence of Discrimination from a Field Experiment over Airbnb in Australia.

Undergraduate honors thesis, 2018.

 November – December 2017 813 listings in Sydney, Australia Guests with distinctively Middle Eastern names received positive responses 13.5 percentage points less often, compared to identical guests with white-sounding names. Results were  persistent across all hosts, including hosts with shared properties and those with expensive listings.

Discrimination was most prominent for hosts with highly sought-after listings, where hosts can reject disfavored guests with  confidence of finding replacements.

My bottom line remains as I remarked in fall 2016: Airbnb’s proposed responses are unlikely to solve the problem and indeed have not done so. Truly fixing discrimination at Airbnb will require more far-reaching efforts, likely including preventing hosts from seeing guests’ faces before a booking is confirmed.  Anything less is just distraction and demonstrably insufficient to solve this important, and long-festering, problem.

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On Uber Selling Southeast Asia Business to Grab

Uber and Grab provide much the same service — ride-hailing that lets casual drivers, using their personal cars, transport passengers in on-demand service. In the markets where both operate, in Southeast Asia, they’ve been locked in a price war. Grab has local expertise and, in many countries, useful product customizations to suit local needs. Uber is an international powerhouse. It hasn’t been obvious which would win, and both firms have spent freely to attract drivers and passengers. Today the companies announced that Uber would sell its Southeast Asia assets to Grab.

It’s clear why both companies like the deal. They’d end costly competition with each other — saving billions on incentives to both drivers and passengers. Diving the world market — with Grab dominating Southeast Asia, Didi in China (per a 2016 transaction), and Uber most everywhere else — they can improve their income statements and begin to profit.

But for every dollar of benefit to Grab and Uber, there is corresponding cost to drivers and passengers. Free of competition from each other, neither company will see a need to pay bonuses to drivers who complete a target number of rides at target quality. Nor will they see a reason to offer discounts to passengers who direct their business to the one company rather than the other. And with drivers and passengers increasingly dependent on a single intermediary to connect them, Grab will be able to charge a higher markup — a price increase that harms both sides.

Some will protest that aggrieved passengers can take taxis, buses, bikes, or private cars, or just walk. Indeed. But there’s always a substitute. If Coca Cola and Pepsi merged, customers could still drink water. Antitrust law is, prudently, not so narrow-minded. The relevant question under law is the SSNIP test, assessing customer response to a small but significant and non-transitory increase in price. Facing such an increase, would passengers truly go elsewhere? In my travels in Southeast Asia, I’ve often found Grab and Uber to be 30% cheaper than taxis. There’s plenty of room for them to increase price without me, and other passengers similarly situated, finding it profitable to switch to taxis. That means Grab and Uber are, under the relevant test, in a separate market from taxis. Then they can’t seek shelter from having (maybe) a small market share relative to taxis and other forms of transportation.

Separately, it’s not apparent what alternative is available to Grab and Uber drivers. Facing higher fees from Uber, what exactly are they supposed to do? They certainly can’t become taxi drivers (requiring special licenses, special vehicles, and more). There’s no obvious easy alternative for them. For drivers, ride-hailing is plainly distinct from other forms of transportation and other work.

The short of it is, ride-hailing is different from alternatives. Grab, Uber, passengers, and regulators know this instinctively, and extended economic and legal analysis will confirm it. With Grab and Uber in a distinct market, they jointly have near-complete market share in the markets where both operate. Under antitrust law, they should not and cannot be permitted to merge. No one would seriously contemplate a merger of Lyft and Uber in the US, and sophisticated competition regulators in Southeast Asia should be equally strict.

Additional concerns arise from the special role of SoftBank, the Japanese investment firm that held shares in both Grab and Uber. Owning portions of both companies, SoftBank cared little which one prevailed in the markets where both operated. But more than that, SoftBank specifically sought to broker peace between Grab and Uber: When investing in Uber in December 2017, SoftBank sought a discount exactly because it could influence Uber’s competitors across Asia. Such overlapping ownership — intended to reduce competition — raises particularly clear concerns under competition law. A Grab spokesman tried to allay these concerns by claiming the transaction was “a very independent decision by both companies [Grab and Uber]” — yet in the next sentence noted that Masa [SoftBank CEO Masayoshi Son] was highly supportive of the” transaction (emphasis added).

The Grab-Uber transaction follows Uber’s summer 2016 agreement to cede China to Didi, which led that firm to an unchallenged position in that market. News reports indicate higher prices and inferior service after the Didi-Uber transaction — the same results likely to arise in the Southeast Asia markets where Uber and Grab propose to combine.

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Keeping “Free Law” Free

Who should pay to store and distribute the litigation records in US federal courts? The answer is surprisingly contentious – and, by all indications, getting more so.

When the general public wants to read documents in US federal litigation, the standard method is PACER – the federal courts’ electronic record system. One might think this would be free to access – an efficient information system run from a few web servers with no significant incremental cost per document copied. But PACER dates back to 1989, when information was provided by modem with genuine costs for courts to obtain and provide dial-up hardware, not to mention servers and storage. Thus a tradition of charging — a tradition which has continued, now yielding fees of $0.10 per page. That sounds low, and it is… until a big session, perhaps looking for the proverbial needle in a haystack, requires browsing hundreds or even thousands of documents at corresponding expense. Meanwhile, with a fee for every page, PACER tells users that the meter is always running and browsing should be done lightly if at all – inconsistent with some readers’ preference to explore unfettered. Certain readers are distinctively at risk. For example, journalists often have limited budgets. For some pro se litigants, virtually any expense is unaffordable. Others are conducting research outside the country or are undocumented, unbanked, or for other reasons have no United States debit or credit card to use for payment.

In principle, litigation might put a check on public record expenses. Following up on a 2014 lawsuit, several non-profits sued the United States in 2016 as to PACER fees, alleging that the E-Government Act of 2002 allows only “reasonable” fees and then “only to the extent necessary.” The plaintiffs argue that PACER charges are higher, are not necessary, and indeed yield revenues that courts divert to other projects. For example, Quartz reports the federal courts spending 28% of PACER revenue on other court technology, such as monitors and sound systems — meritorious, no doubt, yet not obviously related to distributing court documents. Litigation is ongoing. But the disposition of the 2014 lawsuit gives reason to doubt the effectiveness of litigation to constrain PACER fees. For one, a sitting federal judge has every reason to defer to colleagues sitting on the Judicial Council (the body of judges that sets the PACER fee schedule). Indeed, any reduction in PACER fees would deprive the judicial branch of one of its primary revenue sources — a particular challenge if judges believe that Congress does not adequately fund the courts.

In the short run, the most promising response to PACER fees is RECAP, a browser plug-in that lets users share what they read on PACER. The idea is simple and elegant: Whenever a RECAP user reads a document on PACER, the RECAP plug-in sends a copy to RECAP’s servers which in turn store it for others to read free of charge. RECAP has used this approach since 2009, when it began as a graduate student project at Princeton University’s Center for Information Technology Policy (CITP). RECAP later grew with funding from non-profits public.resource.org and the Think Computer Foundation, as well as smaller monetary and in-kind donations from a variety of other groups and legal startups. There have been technical glitches, but on the whole the system has worked well.

A surprise development came in November 2017 when the Free Law Project (FLP), the operator of RECAP ever since the original Princeton team graduated and disbanded, announced major changes in how RECAP-collected data will be distributed in the future. Under the new plan, rather than making all RECAP-collected documents available to the public on the Internet Archive (IA) as soon as possible, FLP would hold the documents until the end of each quarter for a batch update to IA. FLP also proposed to upload litigation materials to IA in only machine-readable formats compressed into enormous multi-gigabyte tarballs, ending the human-readable individual HTML files that have for years made it easy for normal users with standard web browsers to see court records.

FLP says these changes are “necessary for RECAP to thrive” which I understand to summarize concern about FLP funding. I’m sensitive to the need to keep RECAP sustainable. But I question whether the November 2017 changes offer the right approach. Four specific concerns:

  • One, I don’t know that RECAP’s expenses need to be particularly high. Open source software development often does not entail paying developers anything at all. With the right motivation including public praise, some people may be inclined to donate their skills. Certainly RECAP needs new features and improvements from time to time, but most such improvements should last indefinitely once built, reducing RECAP’s ongoing expenses.
  • Two, charging for access to documents seems in sharp tension with RECAP’s promise to users. The organization’s very name — “Free Law” — calls for distributing materials not just without charge, but also without restriction. Indeed, FLP filed an amicus brief in the National Veterans Legal case stating that the FLP is a “nonprofit organization established in 2013 to provide free, public, and permanent access to primary legal materials on the internet for educational, charitable, and scientific purposes to the benefit of the general public and the public interest” (emphasis added).
  • Three, there are other promising means to support RECAP. Imagine a service that alerts interested subscribers to new documents in a given docket or referring to a given litigant or subject. Or a premium service that searches or cross-references document contents. Perhaps bulk downloads of hundreds of files en masse. RECAP could do all of this and more. If RECAP stays true to its nonprofit public-interest mission, and if its expenses remain as low as it seems like they could be, RECAP could also rely on further funding through grants, avoiding the need to try to monetize data that FLP itself calls “free” and “public.” These, in my view, are the more natural ways to fund RECAP’s operations. In contrast, charging for the documents themselves may be easier – no need to build new features – but it is too far from RECAP’s prior promises and users’ expectations, not to mention undercutting the public interest in the National Veterans Legal lawsuit.
  • Four, FLP announced the delayed data distribution as a fait accompli, not soliciting input ahead of time from the users who contribute documents and code to the RECAP plug-in. That’s a natural approach for a commercial service, and maybe appropriate for some non-profits, but hard to reconcile with the position of stewardship I had understood RECAP and FLP to aspire to.

More generally, I struggle to reconcile FLP’s changes with the organization’s non-profit status and with its overall position favoring free and unrestricted access to court documents.

A final twist is that FLP has already arranged for only its own CourtListener site to get premium access to RECAP’s documents as they are gathered by users and uploaded by the RECAP plug-in. FLP envisions that other sites and the public will get access only once per quarter unless they pay an undisclosed fee. Indeed, a few sites have sprung up to collect RECAP-gathered court records, repackage them in some way, and distribute them to the interested public. It’s hard to see a principled reason why only CourtListener should get superior and more frequent access to the documents. They’re public documents, gathered by the US courts themselves, and then submitted for public archival by participating users who support the “Free Law” RECAP concept. Nothing in users’ or donors’ understanding or their agreement with RECAP calls for RECAP providing the documents to only one site but not others.

Tensions have been brewing, including a pointed critique from Aaron Greenspan (whose PlainSite service is among the victims if RECAP begins to withhold data from other services), as well as Internet Archive staff questioning the purpose and effect of the proposed changes. But getting this right requires more users speaking up about what they want from RECAP and what they expect of its leadership. For myself, I want a RECAP that lives up to the principles articulated in 2009 — gather court documents and distribute them without charge or restriction.

(Added January 25, 2018) On Github, user @johnhawkinson pointed out the FLP is still posting RECAP data to CourtListener, and indeed indicates that it will continue to do so promptly (even though IA uploads are to be delayed). Indeed. And at present, no CourtListener TOS limits how users access the site; it seems users could download thousands of documents for their own purposes, even scrape the site and its contents if that better matches their requirements. Kudos to CL for not banning (or purporting to ban) those methods. Yet favoring CourtListener, rather than the authoritative and widely-trusted archive.org, seems to me a troubling change. FLP’s stated reason for putting data only on CL, and not promptly on IA, is to make the service “sustainable” which I take to mean an effort to raise funds, which in turn entails withholding features or data (or both) from those who don’t pay. And FLP is already asking for payments from those sites that seek full access to bulk RECAP data. Such restrictions and charges are exactly what RECAP’s historic mission did not contemplate or indeed allow.

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From the Digital to the Physical: Federal Limitations on Regulating Online Marketplaces with Abbey Stemler

Edelman, Benjamin, and Abbey Stemler. “From the Digital to the Physical: Federal Limitations on Regulating Online Marketplaces.” Harvard Journal on Legislation, Volume 56, Number 1, pp. 141-198.

Abstract:

Online marketplaces have transformed how we shop, travel, and interact with the world. Yet, their unique innovations also present a panoply of challenges for communities and states. Surprisingly, federal laws are chief among those challenges despite the fact that online marketplaces facilitate transactions traditionally regulated at the local level. In this paper, we survey the federal laws that frame the situation, especially §230 of the Communications Decency Act (CDA), a 1996 law largely meant to protect online platforms from defamation lawsuits. The CDA has been stretched beyond recognition to prevent all manner of prudent regulation. We offer specific suggestions to correct this misinterpretation to assure that state and local governments can appropriately respond to the digital activities that impact physical realities.

Informal introduction:

Perhaps the most beloved twenty-six words in tech law, §230 of the Communications Decency Act of 1996 has been heralded as a “masterpiece” and the “law that gave us the modern Internet.” It was originally designed to protect online companies from defamation claims for third-party speech (think message boards and AOL chat rooms), but over the years §230 has been used to protect online firms from all kinds of regulation—including civil rights and consumer protection laws. As a result, it is now the first line of defense for online marketplaces seeking to avoid state and local regulation.

In our new working paper, Abbey Stemler and I challenge existing interpretations of §230 and highlight how it and other federal laws interfere with state and local government’s ability to regulate online marketplaces—particularly those that dramatically shape our physical realties, such as Uber and Airbnb. §230 is sacred to many, but as Congress considers revising §230 and Courts continually reassess its interpretation, we hope our paper will encourage a richer discussion about the duties of online marketplaces.

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The Market Design and Policy of Online Review Platforms

Edelman, Benjamin. “The Market Design and Policy of Online Review Platforms.” Oxford Review of Economic Policy 33, no. 4 (Winter 2017): 635-649.

I present the institutions and incentives of online reviews, including attracting initial reviews, assuring truthful reviews of genuine experiences, and avoiding inflated or deceptive reviews. I also explore the competition and consumer protection concerns associated with reviews.