Nanotechnology Lawyer & Attorney : Porter Wright Morris & Arthur : Nanotechnology Law Report - Germanium nanobead image provided by UT-Battelle, which manages Oak Ridge National Laboratory for the Department of Energy

In recent weeks, Health care reform and financial regulatory reform efforts by the Obama administration have been getting the majority of the media and public's attention, but at the same time reform and updating of the Toxic Substances Control Act (TSCA) has been in the background.

Yesterday, during a speech to the Commonwealth Club of San Francisco EPA Administrator Lisa Jackson announced the administration's "Essential Principles for Reform of Chemicals Management Legislation". Some of the principles that Ms. Jackson highlighted in her speech are:

First, we need to review all chemicals against safety standards that are based solely on considerations of risk – not economics or other factors – and we must set these standards at levels that are protective of human health and the environment.

Second, safety standards cannot be applied without adequate information, and responsibility for providing that information should rest on industry. Manufacturers must develop and submit the hazard, use, and exposure data demonstrating that new and existing chemicals are safe. If industry doesn’t provide the information, EPA should have the tools to quickly and efficiently require testing, without the delays and procedural obstacles currently in place.

Third, both EPA and industry must include special consideration for exposures and effects on groups with higher vulnerabilities – particularly children. Children ingest chemicals at a higher ratio to their body weight than adults, and are more susceptible to long-term damage and developmental problems. Our new principles offer them much stronger protections.

Fourth, when chemicals fall short of the safety standard, EPA must have clear authority to take action. We need flexibility to consider a range of factors – but must also have the ability to move quickly. In all cases, EPA and chemical producers must act on priority chemicals in a timely manner, with firm deadlines to maintain accountability. This will not only assure prompt protection of health and the environment, but provide business with the certainly that it needs for planning and investment.

Fifth, we must encourage innovation in green chemistry, and support research, education, recognition, and other strategies that will lead us down the road to safer and more sustainable chemicals and processes. All of this must happen with the utmost transparency and concern for the public’s right to know.

Finally, we need to make sure that EPA’s safety assessments are properly resourced, with industry contributing its fair share of the costs of implementing new requirements.

 

Its been expected for some time that new legislation to update the TSCA will be introduced by Senators Frank Lautenberg, Barbara Boxer, Representatives  Henry Waxman and Bobby Rush before the end of the 111th Congress 1st Session. We'll keep an eye out for when the legislation is introduced and it's course through Congress.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

 Friday's Federal Register carried two notices of public meetings sponsored by the National Nanotechnology Coordination Office. The notices may be accessed here and here.

The first meeting, a "Nanotechnology Primer" pre-meeting, will be held October 5th from 7-8:30PM at the Holiday Inn Rosslyn-Key Bridge in Arlington, VA and will focus on providing background information about nanotechnology and Federal nanotechnology research and development projects. The Primer meeting will serve as a preparatory meeting for a workshop and public meetings on (1) nanomaterials and the environment and (2) instrumentation, metrology and analytical methods, also to be held at the Holiday Inn Rosslyn-Key Bridge on October 6th and 7th, from 8AM-5:30 PM and 8AM-4PM respectively. Considering the starting time for these meetings, one hopes that they have plenty of coffee available.

Pre-registration for both the Primer meeting and the workshops and public meetings is required. The main sessions of the workshop and public meetings will be webcast.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Inside the EPA published an article today entitled: "EPA Developing Strict Approaches for Overseeing Nanomaterials."

The article summarizes recent comments by Steve Owens -- Assistant Administrator for the EPA's Office of Prevention, Pesticides and Toxic Substances -- at a recent conference held in London which was sponsored by the London School of Economics, ELI, and WWI PEN.

Owens apparently criticized EPA's past "distinct molecular identity" approach to determining whether nanoscale materials are considered New Chemical Substances requiring premanufacturing notice and approval under the Toxic Substances Control Act (TSCA). That approach examines nanoscale materials on a case-by-case basis to determine whether they have a separate and unique molecular identity from chemical substances already on the TSCA inventory. If the material's molecular identity is not distinct, then it is not considered a New Chemical Substance requiring TSCA premanufacturing registration and approval (assuming it is not a significant new use of an existing chemical substance). This approach was first formalized in a 2008 EPA document which you will find here.

Regarding EPA's current approach, Owens stated, "I cannot say what the outcome of that review will be, but I can tell you that we will be taking a fresh look at this issue and at the basis and reasoning for the decision made by the EPA last year."

Our prediction: Reversal of the current approach sometime in 2010. Stay tuned.
 

• Email This
• Print
• Comments
• Trackbacks
• Share Link

In this article, we note a couple of recent EPA enforcement actions against manufacturers allegedly making unsubstantiated antimicrobial claims for their products – much like occurred in the IOGEAR computer keyboard/mice episode in 2008.  Although these products do not purport to use nanoscale materials, the alleged claims for these products are similar to those made by manufacturers for certain nano-based antimicrobial products. Thus, our readers may be interested in EPA’s actions.

The EPA issued a press release today stating that the parent company of North Face camping and outdoor gear faces up to $1,000,000 in fines for allegedly making unsubstantiated health-related claims for almost 70 of its shoe products using Agion silver ion technology. The EPA press release states:

“At issue were more than 70 styles of footwear that incorporated an AgION silver treated footbed. The company sold the products making unsubstantiated claims that the footwear would prevent disease-causing bacteria. Specifically, The North Face made the following public health claims about the footwear on-line and on product packaging:  • ‘AgION antimicrobial silver agent inhibits the growth of disease-causing bacteria’ • ‘Prevents bacterial and fungal growth’ • Continuous release of antimicrobial agents”

The fines are being sought by EPA under the Federal Insecticide Fungicide and Rodenticide Act which prohibits unsubstantiated public health claims regarding unregistered products.

From Agion’s website: “Agion technology operates at the surface of a product through the controlled release of silver ions which attack microbes and inhibit their growth in three different ways. We offer a variety of silver-based technologies to suit various manufacturing and product requirements.” 

In another press release, EPA publicized a complaint it filed “against Peoria, Ariz.-based Granite Marketing, Inc. for the alleged sale and distribution of an unregistered pesticide in violation of the Federal Insecticide, Fungicide and Rodenticide Act. The EPA is seeking up to $5,200 in civil penalties from Granite Marketing, Inc., located at 8190 W. Deer Valley Road, for offering for sale the unregistered antimicrobial pesticide known as Titania Antibacterial System.”

• Email This
• Print
• Comments
• Trackbacks
• Share Link

There are often developments in the nano legal world that do not fit into our traditional Nanotechnology Law Report format, yet might be of interest to some of our readers. You can now find these short postings and other musings on twitter.com/nanolaw  .

Additionally, you can find me on linkedin under "John Monica," as well as on our new "Nano EHS Forum".  Please feel free to link in or to join our new discussion group.

Happy networking!

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Earlier this month, the Reuters news service (now part of Thomson Reuters) carried an article by Richard A. Liroff, "Nanomaterials: Why Your Company Should Sweat the Small Stuff", primarily aimed at management executives at companies using or contemplating using nanomaterials in their products or manufacturing processes.

Noting that nanomaterials present "the potential to yield extraordinary health, environmental, and other global social benefits", Liroff also notes, as with asbestos, the potential for nanomaterials to have "novel toxicity risks". Pointing out that regulatory agencies in Canada, California, and the EU are basically at the beginning stages of issuing regulations;  EPA is noted for having initiated "a handful of regulatory actions" but since most of these actions featured voluntary compliance rather than mandatory, their success rate is noted as "poor".

Mr. Liroff points out that corporate management will

need to exercise especially demanding due diligence to make sure you're not taking on liabilities that you and your shareholders will come to regret.

With that in mind, Mr. Liroff poses several questions, largely focusing on suppliers of nanomaterials, that management should keep in mind while performing their due diligence and long term planning, including planning for the worst case scenario.

It's important that management and shareholders ask these questions and heed the warnings

about the unknown and under-researched hazards of nanomaterials . . . . If these misgivings go unheeded, that would be tragic on multiple counts. Not only because the potential benefits from the burgeoning forms of nanotechnologies will founder and be lost on the shoals of public mistrust and rejection, but also because companies and their shareholders will see corporate financial values vaporize in the face of closed markets and possible litigation.

Liroff raised the specter of asbestos in this article and it's important to learn from what happened - and is still happening, since litigation over the effects of asbestosis is still being filed, decades after asbestos was used in factories and consumer products - to avoid exposure to possible litigation and the lose of their investment by shareholders.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

A much valued contributor from CyberRegs provided us with the following information from the Federal Register that may be of interest to readers:

There will be a 4-day consultation meeting of the Federal Insecticide, Fungicide, and Rodenticide Act Scientific Advisory Panel (FIFRA SAP) to consider and review a set of scientific issues related to the assessment of hazard and exposure associated with nanosilver and other nanometal pesticide products.

DATES: The consultation meeting will be held on November 3 - 6, 2009, from approximately 8:30 a.m. to 5:00 p.m. The consultation meeting will be held at the Environmental Protection Agency, Conference Center, Lobby Level, One Potomac Yard (South Bldg.), 2777 S. Crystal Dr., Arlington, VA 22202.

Comments. The Agency encourages that written comments be submitted by October 20, 2009 and requests for oral comments be submitted by October 27, 2009. Mail: Office of Pesticide Programs (OPP) Regulatory Public Docket (7502P), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001.

FOR FURTHER INFORMATION CONTACT: Joseph E. Bailey, DFO, Office of Science Coordination and Policy (7201M), Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460-0001; telephone number: (202) 564-2045; fax number: (202) 564-8382; e-mail address:
bailey.joseph@epa.gov.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

A few months ago, ACS Nanotation Nanotube announced their second video contest contest, "How Will Nano Change the World?"

The winner of the contest has been announced. This year, the Oscar for best motion picture goes to - woops, sorry, wrong contest. The winner of the 2009 ACS Nanotation Nanotube video contest is :

NanoGirls

The first runner up:

Nano Story

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Yesterday, in Part I, we examined the status and provisions of bills in the House affecting nanotechnology, nanoindustries, or nanobusiness. Today in Part II, we turn to the Senate.

S. 596, the "Nanotechnology Innovation and Prize Competition Act of 2009", was introduced by Senator Ron Wyden (Dem-OR) on 03/16/2009. The bill directs the Secretary of Commerce to establish a program to award prizes for achievement in one or more applications of nanotechnology, (environmental, development of alternative energy sources and fuels, health, and development of consumer products). A board would be established to administer the prizes.

The bill was refered to the Senate Committee on Commerce, Science and Transportation; to date, no hearings have been held and none are scheduled in the near future. The bill remains in committee.

S. 1233, the "SBIR/STTR Reauthorization Act of 2009", was introduced by Senator Mary Landrieu (Dem - LA) on 06/10/2009 and was refered to the Senate Committee on Small Business and Entrepreneurship, which reported it out of committee with an amendment in the nature of a substitute on 07/02/2009. For a further discussion of S. 1233, please see the discussion of HR 2965 in Part I.

S. 1482, the "National Nanotechnology Initiative Amendments Act of 2009", was introduced by Senator John Kerry (Dem - MA) on 07/21/2009 and was refered to the Senate Committee on Commerce, Science and Transportation. No hearings have been held and none are scheduled. S. 1482 would reauthorize and amend the 21st Century Nanotechnology Research and Development Act.  Significant amendments to the 21st Century Nanotechnology Research and Development Act include:

Sponsorship by the National Nanotechnology Program (NNP) of Nanotechnology Education and workforce development programs

Support by the NNP of the development of standardized reference materials, instruments, and computational tools

Participation in national and international organizations developing commercialization and regulatory guidelines and standards

Coordination of research to determine what health, safety and environmental risks nanoparticles and nanomaterials may pose

The Director of the National Nanotechnology Coordination Office would be charged with developing and maintaining a publicly accessible and keyword seachable database of projects funded by the Nanoscale  Science, Engineering and Technology subcommittee of the National Science and Technology Council. This is somewhat similar to the database proposed in HR 554 which was discussed in Part I.

Establish a sub panel on societal, ethical, legal, environmental and workforce concerns.

As with HR 820, an associate Director of the Office of Science and Technology Policy would be designated as the Coordinator for Societal Dimensions of Nanotechnology. The Coordinator's duties would include ensuring that a research plan is developed, updated annually, implemented and responsive to the recommendations of the sub panel mentioned above. The Coordinator, within sixty days of S. 1482's enactment date, would be required to convene a panel to create a research plan for the environmental, health and safety program. This plan would include a description of how the NNP would insure the development of the standards and standardized reference materials also refered to above.

The Director of the National Nanotechnology Coordination Office, no later than six months following enactment, would convene national discussions to encourage both stakeholders and non-stakeholders to express their concerns and priorities regarding nanoproducts, research and development and regulatory policy affecting nanotechnology. The Director would be required to submit a report summarizing these discussions to the Congressional committees that have oversight responsibilities in this area, namely the Senate Committee on Commerce, Science and Transportation and the House Committee on Science and Technology.

SA (Senate Amendment) 1472 was part of a bloc of amendments offered by Senator Carl Levin (Dem-MI) to amend S. 1390, "The National Defense Authorization Act of 2010", and amended the reporting requirements for the Defense Nanotechnology Research and Development Program. The complete text of the amendment is below:

AMENDMENT NO. 1472

    At the end of subtitle D of title II, add the following:

   SEC. 252. MODIFICATION OF REPORTING REQUIREMENT FOR DEFENSE NANOTECHNOLOGY RESEARCH AND DEVELOPMENT PROGRAM.

    Section 246 of the Bob Stump National Defense Authorization Act for Fiscal Year 2003 (Public Law 107-314; 10 U.S.C. 2358 note) is amended by striking subsection (e) and inserting the following new subsection (e):

    ``(e) Reports.--The Under Secretary of Defense for Acquisition, Technology, and Logistics shall submit to the National Science and Technology Council information on the program that covers the information described in paragraphs (1) through (5) of section 2(d) of the 21st Century Nanotechnology Research and Development Act (15 U.S.C. 7501(d)) to be included in the annual report submitted by the Council under that section.''

As with the majority of the House bills, the Senate bills remain in committee. Considering the focus of Congress on health care reform, financial regulatory reform, and various appropriations bills that need to be passed before the end of the 1st Session, when and if these bills are reported out and voted on is unknown. We'll continue to track these bills and others affecting nanotechnology that may be introduced in the future. At the end of the 1st Session of the 111th Congress, two more articles updating these will be posted to this site.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Congress returned from it's August recess this week, so it seems like a good moment to review legislation affecting nanotechnology that has been  introduced so far in the 111th Congress. Today in Part I we'll examine legislation introduced in the House of Representatives.  Thursday, in Part II, we'll examine legislation introduced in the Senate.

HR 554, the "National Nanotechnology Initiatives Amendments Act of 2009", was introduced by Rep. Bart Gordon (Dem - TN - 6th Dist) on 01/15/2009 and was passed by the House under suspension of the rules on 02/11/2009. Received in the Senate on 02/12/2009, it was referred to the Senate Committee on Commerce, Science and Transportation; it has not been reported out of committee and no hearings are currently scheduled.

Major amendments to the 21st Century Nanotechnology Research and Development Act ( P.L. 108-153 15 USC 7501 et seq) include:

Requiring the National Nanotechnology Coordination Office to " develop and maintain a database accessible by the public of projects funded under the Environmental, Health, and Safety, the Education and Societal Dimensions, and the Nanomanufacturing program component areas, or any successor program component areas, including a description of each project, its source of funding by agency, and its funding history. "

Requires the designation of an Associate Director of the Office of Science and Technology Policy as the Coordinator for Societal Dimensions of Nanotechnology. The Coordinator would be tasked with insuring that ethical, legal, environmental and other social concerns with nanotechnology are considered. The Coordinator would also be responsible for convening a panel to develop a research plan for the environmental, health and safety program areas; the plan would be updated on annually.

The Director of the National Science Foundation (NSF) would be required to provide grants to establish Nanotechnology Education Partnerships. Nanobusinesses would be part of these Partnerships. The Partnerships would help to prepare secondary school students to pursue college courses in nanotechnology.

The bill would also provide for the establishment of  “Industry Liaison Groups”  for all industrial sectors that would benefit from nanotechnology applications.

The National Nanotechnology Coordination Office would be required to sponsor a public meeting to (1) solicit views on the relevance and value of nanomanufacturing  research, (2) receive recommendations on ways to strengthen research supported by the Nanomanufacturing program and (3) receive recommendations on improving nanomanufacturing facilities.

HR 820, the “Nanotechnology Advancement and New Opportunities Act”, was introduced by Rep. Michael Honda (Dem – CA – 15^th Dist) on 02/03/2009 and was referred to the House Committees on Science and Technology, Energy and Commerce, Ways and Means, and Homeland Security.  No hearings have been held by any of these committees on this bill and no hearings are currently scheduled. It has not been reported out of any of the committees.

The bill would require the Secretary of Commerce to establish a “Nanomanufacturing Investment Partnership”, but only after and contingent upon the private sector raising $100 million within two years after the bill’s enactment. The Partnership would  provide funds, via direct investment, loans or loan guarantees or other unspecified mechanisms, to nanocompanies for pre-commercial research and development that would not be funded by either the private sector or under the 21^st Century Nanotechnology Research and Development Act. Any such funds provided would have to be paid back.

The Secretary of Commerce would also be directed to establish an Advisory Board to assist in determining which nanocompanies would receive funding. The Advisory Board membership would consist of two groups, (1) representatives of those investors who had provided more than $10 million to the Nanomanufacturing Investment Partnership (in short, the stakeholders) and (2) Presidential appointees drawn from government agencies, industry, and academia. This second group would control 60% of the votes on the Advisory Board and thus would really be the ones deciding where the money goes. This would seem to be a flaw in the bill; as we have seen in the recent past and may see again under future administrations, it is possible to politicize government agencies and as currently written, this section of the bill opens up that possibility here. It is possible that the bill may be amended in one of the committees before it is reported out or an amendment  may be adopted during floor debates.

The tax code would also be amended by creating tax credits to encourage the purchase of stock in qualified nanotechnology developers, as defined by the bill. Tax credits would also be available to cover up to 50% of the cost of nanotechnology education and training courses and programs.

The Secretary of Commerce would be directed to establish the “Nanotechnology Start Up Advisory Council” with membership drawn from industry, marketing, venture capitalist firms, attorneys, and nanotechnology researchers. The Council’s duty would be to review the business plans of nanotech start up companies, to insure that they were really viable plans.

Other sections of the bill would establish competitive grants to encourage the application of nanotechnologies to solving environmental problems, renewable energy sources,  health related uses, and homeland security programs.

The Secretary of Energy would be directed, six months following enactment, to deliver to Congress a report containing a plan to increase interaction on nanotech issues between scientists and engineers at DOE’s national laboratories and informal science education communities with the goal of developing exhibitions for school age children and the general public.

HR 2769, the “Commercializing Small Business Research and Development Act” introduced by Rep. Bobby Bright (Dem – AL -2^nd Dist) on 06/09/2009, is not primarily a nanotechnology focused bill. It’s aim is to amend the Small Business Act . Section 4 of the bill is titled “Nanotechnology related research topics and is reprinted in it’s entirety below:

SEC. 4. NANOTECHNOLOGY-RELATED RESEARCH TOPICS.

(a) SBIR- Section 9(g)(3) of the Small Business Act (15 U.S.C. 638(g)(3)), as amended, is further amended--

(1) at the end of subparagraph (D) by striking `or';

(2) at the end of subparagraph (E) by adding `or'; and

(3) by adding at the end the following:

`(F) the national nanotechnology strategic plan required under section 2(c)(4) of the 21st Century Nanotechnology Research and Development Act (15 U.S.C. 7501(c)(4)) and in subsequent reports issued by the National Science and Technology Council Committee on Technology, focusing on areas of nanotechnology identified in such plan;'.

(b) STTR- Section 9(o)(3) of the Small Business Act (15 U.S.C. 638(o)(3)) is amended--

(1) at the end of subparagraph (A) by striking `or';

(2) at the end of subparagraph (B) by adding `or'; and

(3) by adding at the end the following:

`(C) by the national nanotechnology strategic plan required under section 2(c)(4) of the 21st Century Nanotechnology Research and Development Act (15 U.S.C. 7501(c)(4)) and in subsequent reports issued by the National Science and Technology Council Committee on Technology, focusing on areas of nanotechnology identified in such plan;'.

 

HR 2965, the “Enhancing Small Business Research and Innovation Act of 2009”, was introduced by Rep. Jason Altmire (Dem –PA – 4^th Dist) on 06/19/2009. The bill would have amended and extended the Small Business Act sections on the  Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, which include nanobusinesses. HR 2965 was assigned to the House Committees on Small Business and Science and Technology. Both Committees reported the bill with amendments (H. Rept. 111-190 Pt. 1 and H. Rept. 111-190 Pt. 2).

S. 1233, the Senate version of the bill. The amended bill was then passed by unanimous consent. The amended bill does have a section (Sec. 206) that briefly treats nanotechnology:

 

(a) In General- Section 9 of the Small Business Act (15 U.S.C. 638), as amended by this Act, is amended by adding at the end the following:

`(ff) Nanotechnology Initiative- Each Federal agency participating in the SBIR or STTR program shall encourage the submission of applications for support of nanotechnology related projects to such program.'.

(b) Sunset- Effective October 1, 2014, subsection (ff) of the Small Business Act, as added by subsection (a) of this section, is repealed.

The bill was then returned to the calendar.

Thursday, we'll examine the Senate bills.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Our friends at NanoReg are working with the Keller Heckman law firm and the Institute of Food Technologists to present the upcoming webinar "Nanotechnology, Food and Food Packaging" on September 10, 2009. 

From the webinar's website:

"Food and food packaging have been at the forefront of nanotechnology innovation. Nanotechnology advancements in food additives and packaging are increasing shelf-life, improving flavor, and detecting pathogens in a wide variety of foods. Packaging enhancements are even extended to the marketability of products through color-changing inks, printable RFIDs and printable active displays. This webinar will explore these advancements and the impact of regulatory policy."

I will be attending.  Please consider participating in this very valuable and timely webinar.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

For anyone interested, I am presenting my recently approved Virginia CLE presentation "Insurance, Nanotechnology, and Risk" in mid-September to a national intellectual property law firm based here in D.C.  The presentation covers issues related to the alleged environmental, health, and safety (EHS) risks accompanying certain nanoscale materials from the perspective of both the insured and insurer. Particular emphasis is placed on (i) insurer approaches to EHS risk and uncertainty, (ii) the first commercial insurance exclusion for nanotechnology in the US, (iii) industry reaction to certain recent adverse EHS studies concerning carbon nanotubes, and (iv) three initial steps nano-related businesses should consider when dealing with these issues. The PowerPoint was originally presented at the Nanotechnology Health and Safety Forum in Seattle in June 2009, and the National Nanotechnology Initiative also asked for it to be presented at the opening plenary for its October 2009 workshop on "Nanomaterials and the Environment & Instrumentation."  I anticipate additional presentations of the CLE in D.C. and Virginia over the upcoming months.  Please let me know if you have any interest in attending one of the future sessions and I will try to hook you up for some free CLE credit.

• Email This
• Print
• Comments
• Trackbacks
• Share Link

Earlier today, the Guardian printed a letter from the Soil Association criticizing the paper's nanotechnology supplement appearing last Thursday.  The letter cites the Song study from China as more evidence supporting its call for a moratorium on nanoscale materials along with "nano-free" standards, which we have previously covered.  Key statements from the letter follow:

"Seven women working in a factory [in China] where nanoparticles were used in paint fell ill with serious lung disease and two died. Researchers . . . found nanoparticles deep in the lungs of the women . . . A chemical in the paint, the patients' lung tissue and the liquid surrounding the lungs were all found to contain nanoparticles."

"There should be an immediate freeze on the commercial release of nanomaterials until there is a sound body of scientific research into all the health impacts."

The letter does not attempt to explain any of the severe criticism the Song article has received by most main stream scientists, and is a good example of bad science put to a questionable use.

• Email This
• Print
• Comments
• Trackbacks
• Share Link