UPDATED: April 6, 2020 – Major operational changes continue at trade-related U.S. government agencies and courts  due to personnel and public safety concerns over the COVID-19 outbreak in the United States. Below is currently available information on their status. Overall, the Office of Personnel Management has announced that as of March 16, 2020, and until further notice, federal offices nationwide are open but “maximum telework flexibilities” are in place for all eligible employees “pursuant to direction from agency heads.”

U.S. Department of Commerce – While Commerce has published no formal notice of its operating status, it is known that the main Commerce building was closed on March 31 until further notice.  Access to the Herbert C. hoover building is now restricted to only necessary security and maintenance staff, and “mission critical” employees are in contact with their supervisors. The International Trade Administration (ITA) has temporarily modified its antidumping and countervailing duty (AD/CVD) cases to facilitate the serving of documents through electronic means.  Effective March 24, 2020 and until May 19, 2020, documents containing business proprietary information (BPI) may be served on opposing counsel via ITA’s online ACCESS data portal instead of the normal requirement for hard copy “in-person” service. Further, the Bureau of Industry and Security (BIS) has canceled its export control forums scheduled for April 2020.

U.S. Department of the Treasury – While Treasury has published no formal notice of its operating status, the “public engagement” schedule remains empty, indicating that all outside meetings and events have been canceled. The Office of Foreign Assets Control (OFAC) has not indicated yet whether its operations have been affected.

U.S. Department of State – The Directorate of Defense Trade Controls (DDTC) has posted that its core activities across its Licensing, Compliance, Policy, and Management continue to function within the parameters and adjustments that have been made as the agency follows OPM guidance.

  • Licensing activities: All electronic application systems are currently in normal operational mode, and new licenses continue to be accepted for processing; however, a longer than normal processing time should be expected.
  • Registration, CJ Requests and General Correspondence: These filings via the DECCS system continue and are being processed as they are submitted; responses may be delayed by the current operational environment.

DDTC states that it has established a new option for industry to submit disclosures and related information (e.g., exhibits, extension requests, responses to DTCC inquires) by allowing submissions via email to DTCC-CaseStatus@state.gov. In the event that a disclosure cannot be submitted via email, DDTC indicates that the continued use of regular U.S. mail is acceptable.

U.S. Trade Representative (USTR) – The Office of the U.S. Trade Representative has still offered no update on its operating status within the Executive Office of the President.

U.S. International Trade Commission (ITC) – The ITC stated that it is open for business while it continues to monitor the situation. Since March 17, all ITC employees have been teleworking full-time.  The secretary’s office will accept only electronic filings during this time. Filings must be made through the ITC’s Electronic Document Information System (EDIS) at https://edis.usitc.gov. No in-person, paper-based filings or paper copies of any electronic filings will be accepted until further notice. The ITC building is now closed to the public entirely through at least April 24, 2020.

  • Section 337 Hearings – Administrative law judges (ALJs) have been ordered to postpone any hearings until after May 12, 2020. All discovery will continue and any essential outside participation by staff will be decided on a case-by-case basis.
  • Title VII Matters –Until further notice, no in-person preliminary phase Title VII (antidumping and countervailing duty) staff conferences will be held for new and ongoing investigations. Instead, interested parties will have the opportunity to provide opening remarks, witness testimony, and responses to staff questions through written submissions, in addition to post conference briefs. Information and guidance will be provided to parties by the investigative staff in each affected investigation. All ITC Title VII votes will be conducted by notation; there will be no in-person vote for the next 60 days. Until further notice, no in-person hearings will be held for final phase Title VII investigations, five-year (sunset) reviews, and those held under Section 332 and Section 131. In lieu of in-person hearings, the Commission staff will provide specific information and guidance to parties in each affected investigation on alternative means of providing information to the Commission. Interested parties will be invited to provide opening remarks, written testimony, and responses to questions issued by the Commission with certified written responses; parties may also be invited to participate in virtual or telephonic closing and/or rebuttal statements. The ITC has prepared a COVID-19 related set of FAQs.
  • Electronic service of documents has temporarily been implemented for most ITC issuances. Public documents will continue to be made available via the ITC’s electronic record, EDIS.  In addition, temporarily, confidential documents will be made available to authorized parties via Box (www.box.com). Service of confidential documents will be considered effected upon notification via email to other parties/counsel in ongoing investigations that the documents are available for download.
  • Agency Meetings, Seminars and Briefings – All scheduled in-person meetings with outside persons have been cancelled or postponed.

U.S. Customs and Border Protection (CBP) – CBP refers users to DHS.gov/coronavirus for information related to the COVID-19 pandemic, where it states that “all air, land and sea Ports of Entry (POEs), CBP Officers (CBPOs) and Border Patrol Agents (BPAs) continue to identify and refer individuals with symptoms of COVID-19 or a travel history to China, Iran, or certain European countries in the past 14 days to CDC or local public health officials for enhanced health screening.”

In order to streamline communications and support the trade community, CBP launched the CBP COVID-19 Updates and Announcements webpage specifically dedicated to the most recent trade-related information and messaging on the impacts of COVID-19. Information found on the web page includes Federal Register Notices and Cargo Systems Messaging Service communications related to COVID-19, as well as updates and announcements in trade programs and cargo security.

DHS continues to state that the “routing of all flights with passengers who have recently been in China, Iran, and certain European countries through select airports with established resources, procedures and personnel is an important, prudent step DHS is taking actively to decrease the strain on public health officials screening incoming travelers and protecting the American public.”

U.S. Census Bureau – Many U.S. Census Bureau employees are operating remotely via telework. During this time, call centers and email inboxes will remain open to assist customers’ daily trade needs. However, the agency will have limited access to physical mail.  For those companies that are submitting a Voluntary Self-Disclosure (VSD) or data request, please make the submission electronically to the Trade Regulations Branch (TRB) in a password-protected file to emd.askregs@census.gov (for VSDs) or Data User & Trade Outreach Branch (DUTOB) to tmd.outreach@census.gov (for data requests). Additionally, such submissions may be sent to Census’ secure fax at 301-763-8835.

U.S. Court of International Trade (CIT) – According to CIT’s statement of April 2, 2020, courthouse access has been temporarily restricted until further notice.  The staff of the Office of the Clerk is available by telephone and email. The Court’s CM/ECF system continues to be operational during this time and unless otherwise ordered, all filing deadlines will remain in effect.

Any filings that are permitted by the Rules of the Court to be made by mail or delivery should be addressed to:

Office of the Clerk – Case Management
U.S. Court of International Trade
One Federal Plaza
New York, NY 10278

Any filings that are permitted by the Rules of the Court to be made in person should be brought to the Court Security Officers at the courthouse.  The Court notes “that there will be delays in processing documents that are mailed or delivered to the courthouse.”

U.S. Court of Appeals for the Federal Circuit – Per a public advisory notice and an administrative order, the Federal Circuit began restricting public access to the National Courts Building complex on March 16, 2020. On March 19, the Court issued an updated public advisory stating that all cases scheduled for argument during the April 2020 sitting will now be conducted by telephone conference and no in-person hearings will be held.

The Clerk’s Office has issued new guidance on how counsel may accomplish service outside of CM/ECF, which is most frequently required when serving pro se parties or confidential materials. Individuals, including pro se litigants and couriers wishing to deliver or to file case documents, must submit these items either by mail or by deposit in the court’s night box. Mail and third-party commercial deliveries will be limited to the lobby. Any other deliveries must be coordinated ahead of time with relevant court staff.

As the novel coronavirus pandemic alters our daily lives, how we interact with each other and how we conduct business, Thompson Hine’s Trump and Trade editors are providing these web links to helpful government and international organization resources. We will update this post as additional websites focused on the global COVID-19 response become available.

The U.S. government has established multiple websites to assist the public:

U.S. government international trade-related websites:

International resources:

Thompson Hine has also launched a multidisciplinary COVID-19 Task Force to monitor the latest developments and guidance from public health officials and assess the potential impacts on our clients and their businesses. The COVID-19 Task Force page on our website provides a centralized location for recent publications, webinars, articles and resources that you may find helpful.

The U.S. Trade Representative (USTR) issued Friday Federal Register notices exempting Section 301 tariffs for certain List 3 (imports from China with an annual trade value of $200 billion) and List 4 (imports from China with an annual trade value of $300 billion) products.  While the Items on List 3 include several non-medical supply related exclusions, the exemptions for the medical supplies on Lists 3 and 4 are an attempt to address items that could be in short supply as the United States focuses on curbing the spread of the coronavirus. The exemptions cover five entire 10-digit Harmonized Tariff System (HTS) subheadings and 19 specially-prepared product descriptions – a total of 114 separate exclusion requests.

The 19 specially-prepared product description exemptions for List 4 all cover medical supplies:  certain bowls of molded plastics, with clips for retaining guide wires during surgical procedures; certain disposable graduated medicine dispensing cups; certain pads of foam plastics of a kind used for positioning patients during medical procedures; certain single-use sterile drapes and covers of plastics of a kind used to protect the sterile field in surgical operating rooms; certain sterile decanters of polystyrene plastics of a kind used to transfer aseptic fluids or medication to and from sterile bags, vials or glass containers; certain cold packs consisting of a single-use, instant, endothermic chemical reaction cold pack; certain disposable shoe and boot covers; certain eye compresses; certain face masks for single-use; certain gel pads; certain single-use hot packs; certain laparotomy sponges of cotton; certain patient restraint or safety straps; certain single-use blood pressure cuff sleeves; certain single-use medical masks; certain single-use stethoscope covers; certain woven gauze sponges of cotton; certain electromechanical shoe cover dispensers of steel; and certain protective articles.

These exclusions will apply from September 1, 2019, through September 1, 2020.

The five excluded HTS subheadings for List 3 include both medical and non-medical items:

Medical Supplies:

  • 3926.20.9050 – Articles of apparel and clothing accessories (including gloves, mittens and mitts): Gloves, mittens and mitts: Other: Other
  • 4015.19.1010 – Articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanized rubber other than hard rubber: Gloves, mittens, mitts: Other: Seamless: Disposable

Non-Medical Items:

  • 3923.21.0030 – Sacks and bags (including cones): Of polymers of ethylene: Reclosable, with integral extruded closure: Other
  • 3923.21.0095 – Sacks and bags (including cones): Of polymers of ethylene: Reclosable, with integral extruded closure: Other: Other
  • 5603.12.0090 – Nonwovens, whether or not impregnated, coated, covered or laminated: Of man-made filaments: Weighing more than 25 g/m2 but not more than 70 g/m2: Other

These exclusions will apply from September 24, 2018, through August 7, 2020.

These exclusions apply to any product that satisfies the description in the annex of the Federal Register notice, regardless of whether the company using the exclusion filed the request. Each exclusion is governed by the scope of the HTS heading and the product description appearing in the annex of the exclusion notice; it is not governed by the product description set out in any particular exclusion request. U.S. Customs and Border Protection will soon issue instructions on entry guidance and implementation. The USTR will continue to issue determinations on pending requests on a periodic basis.

On March 13, 2020, the Canadian House of Commons and the Canadian Senate each approved Bill C-4, an “Act to implement the Agreement between Canada, the United States of America and the United Mexican States.” Shortly after that, Canadian Governor General Julie Payette gave her royal assent, ratifying the United States-Mexico-Canada Agreement (USMCA) on Canada’s behalf. Now, all three countries have ratified the agreement.

Before the USMCA can enter into force, however, all three must prepare uniform regulations for certain new provisions in the agreement (e.g., automotive rules of origin and labor reforms). President Donald Trump continues to push for the USMCA’s implementation by June 1, 2020.

On March 12, 2020, President Donald Trump signed into law H.R. 4998, the “Secure and Trusted Communications Networks  Act of 2019,” which prohibits the use of certain federal funds and subsidies to purchase communications equipment or services posing national security risks. The Act, passed by both the House of Representatives and the Senate by voice vote and now Public Law No. 116-124, also creates a reimbursement program to assist with the removal and replacement of current equipment in use that was manufactured by entities posing unacceptable national security risks. The Act establishes a $1 billion fund to reimburse carriers during this ongoing Federal Communications Commission (FCC) national security-focused effort.

While never referenced in the Act, the legislation as introduced and passed by Congress is intended to assist in the Trump administration’s efforts to remove the equipment and technology of Chinese companies Huawei Technologies Co. and ZTE Corp. from U.S. telecommunication networks. The White House in a fact sheet noted that the “stakes could not be higher—America’s citizens and our foreign partners must be able to trust that our 5G networks are reliable, private, and secure” and that the Trump administration “will not risk subjecting America’s critical telecommunications infrastructure to companies that are controlled by authoritarian governments or foreign adversaries.” In a November 22, 2019 Report and Order, the FCC designated Huawei and ZTE as companies that pose a threat to U.S. national security.

The Department of Commerce’s Bureau of Industry and Security (BIS) has issued a Federal Register notice again renewing the temporary general license for Huawei Technologies Co., Ltd. and 114 of its non-U.S. affiliates on the Entity List until May 15, 2020. The expiration date for the license had been April 1, 2020. As published on May 22, 2019, this temporary general license authorizes certain activities, including those necessary for the continued operations of existing networks and equipment, the support of existing mobile services, and cybersecurity research critical to maintaining the integrity and reliability of existing and fully operational networks and equipment (see Trump and Trade Update of May 21, 2019). This renewal is the fourth extension BIS has granted since Huawei was placed on the Entity List.

BIS continues to remind exporters, reexporters and transferors subject to the notice that they are required to maintain certifications and other records, to be made available when requested by BIS, regarding their use of the temporary general license. This temporary general license does not relieve parties of their Export Administration Regulations (EAR) obligations as to other licensing requirements for exports to the People’s Republic of China. When not covered by the scope of the temporary general license, exports to listed Huawei entities will require a license and “license applications will continue to be reviewed under a presumption of denial.”

Recently, the U.S. Trade Representative (USTR) issued its annual reports to Congress assessing how the People’s Republic of China (China) and the Russian Federation (Russia) have been complying with their World Trade Organization (WTO) accession agreements, including both their multilateral commitments and bilateral commitments with the United States.  China became a member of the WTO in 2001 (see 2019 China WTO Compliance Report); and Russia joined the WTO in 2012 (see 2019 Russia WTO Compliance Report).

China Report

As with recent reports, the USTR in its 2019 report continues to rate China’s compliance with WTO rules as “poor” and highlights the country’s “continued embrace of a state-led, mercantilist approach to the economy and trade, despite WTO members’ expectations – and China’s own representations – that China would transform its economy and pursue the open, market-oriented policies endorsed by the WTO.” According to the report, China’s trade regime generates many WTO compliance concerns and WTO members too often must resort to the WTO’s dispute settlement regime to seek changes to China’s policies and practices. Despite many years of high-level dialogues and U.S. efforts to urge China to pursue market-based policies, “these efforts largely failed because the Chinese government and the Chinese Communist Party were not sufficiently committed to adopting a true market economy or taking on a more responsible role at the WTO.”  Instead, the report explains, China’s non-market economic system and industrial policies “have systematically distorted critical sectors of the global economy such as steel and aluminum, devastating markets in the United States and other industrialized countries.” As a result, “[u]ntil China transforms its approach to the economy and trade, the United States will take all appropriate actions to ensure that the costs of China’s non-market economic system are borne by China, not by the United States.” The report highlights and summarizes U.S. actions over the past three years to address China’s behavior, including domestic trade remedies, bilateral negotiations, WTO litigation, and strategic engagement with like-minded trading partners.

The report notes the signing of the “Phase One” trade agreement in January 2020 as a first step in structural reforms and other changes to China’s economic and trade regime in the areas of intellectual property, technology transfer, agriculture, financial services, and currency and foreign exchange. The report adds that the United States in “Phase Two” of trade negotiations with China will further focus on intellectual property and technology transfer concerns, as well as trade-in-services market access issues not addressed in the Phase One agreement. Other critical issues to be addressed, the report states, include “excess capacity, subsidies, state-owned enterprises, cybersecurity, data localization and cross-border data transfers, pharmaceuticals and medical devices, competition law enforcement, regulatory transparency, and standards.” The USTR hopes that China will continue to seriously address the concerns of the United States and other WTO members and “engage with us on a productive basis.”

Russia Report

This report notes that U.S. trade in goods with Russia has fluctuated since it joined the WTO in 2012.  For the first nine months of 2019, the report notes, imports from Russia were at the same level as for the same time period in 2018, and exports to Russia for the same period continued to fall. According to the report, “Russia has implemented nearly all of its final tariff bindings.” Russia has also updated its legislation on customs valuation, implemented a ceiling on trade-distorting domestic support payments, and, consistent with WTO transparency rules, notified certain measures to the relevant WTO committees. “Aside from these few positive steps, however, Russia appears to have done little to foster an open market based on WTO disciplines.” Instead, Russia has imposed tariffs ranging from 25 to 40 percent on various U.S. products in retaliation for the U.S. government’s Section 232 tariffs on steel and aluminum products. The report states that most of Russia’s trade restrictions are the result of non-tariff trade barriers, referencing once again a “cumbersome and opaque” customs and licensing regime. The USTR found that Russia continues to protect its markets through a variety of restrictive measures, technical regulations and burdensome reporting requirements. Regarding the protection and enforcement of intellectual property (IP) rights, the United States continues to question Russia’s implementation of its WTO commitments on data exclusivity and patent protection, noting that Russia’s IP enforcement efforts remain weak.  Ultimately, while the United States and other members welcomed Russia into the WTO in 2012 with hopes of expanded open and competitive markets there, the report acknowledges that “those hopes remain unrealized.” With text almost identical to last year’s report, the USTR concludes that Russia in 2019 continued to raise barriers to imports and exports and maintained policies that limit its economic growth: “Despite Russia’s continued reliance on inward-looking, protectionist economic policies, the United States will continue to press Russia to comply with its WTO commitments and pursue market-based principles. At the end of the day, Russia must decide its future and take responsibility for its actions and the impact of those actions on its citizens.”

To compare these annual reports against last year’s USTR reports, please see our Trump and Trade Update of February 6, 2019.

In a rare move, President Donald Trump has issued an Executive Order that the Committee on Foreign Investment in the United States (CFIUS) direct the foreign parties involved in the acquisition of StayNTouch, Inc., a U.S. company, to divest their interests in the company. President Trump found credible evidence that Beijing Shiji Information Technology Co., Ltd., a Chinese company, and its wholly-owned subsidiary Shiji (Hong Kong) Ltd., a Hong Kong limited company (the “foreign purchasers”), “might take action that threatens to impair the national security of the United States.” StayNTouch, founded in 2013, is a mobile hotel property management system. The Shiji group made an initial investment in the company in 2016 and fully acquired StayNTouch in September 2018.

CFIUS is an interagency committee authorized to review certain transactions involving foreign investment in the United States and certain real estate transactions by foreign persons in order to determine the effect of such transactions on the national security of the United States. Because the process is highly confidential for the involved parties, it is unclear whether the foreign purchasers and StayNTouch originally notified CFIUS of the 2018 transaction. It would appear that such notification was not made and that upon learning of the acquisition, CFIUS directed a national security review. Ordering a full divestment of a foreign acquisition is rare because CFIUS and the involved parties are often able to negotiate and enter into a mitigation agreement that establishes certain safeguards and security procedures to prevent access to any sensitive commercial or personal data. In this instance, it appears that CFIUS and President Trump were concerned over the personal data and credit card information StayNTouch’s software and database system collects on hotel guests.

The executive order allows the foreign purchasers 120 days to divest all interests in StayNTouch, including all intellectual property, technology and data (i.e., customer data managed and stored in the company’s systems). Until the time of full divestiture, the foreign parties must refrain from accessing any hotel guest data and confirm that controls and procedures are in place to prevent any such foreign access to such data. In divesting their holdings, the foreign purchasers must notify CFIUS of the new buyer. CFIUS also has the authority to access certain corporate accounts and documents of StayNTouch in order to verify compliance with the president’s executive order.

The U.S. Trade Representative (USTR) has issued a Federal Register notice exempting from List 4 (imported Chinese products with an annual trade value of $300 billion) of the Section 301 tariffs targeting China eight entire 10-digit Harmonized Tariff System (HTS) subheadings that cover 59 separate exclusion requests. While there is no reference in the notice, the scope of these exclusions covers medical supplies and items to help curb the spread of the coronavirus that may be in short supply. Products covered by these exclusions include soaps, sanitary wipes, medical gloves, disposable hospital linens, gowns and surgical masks. The eight excluded HTS subheadings are:

  • 3401.19.0000 – Soap; organic surface-active products and preparations for use as soap, in the form of bars, cakes, molded pieces or shapes, whether or not containing soap; organic surface-active products and preparations for washing the skin, in the form of liquid or cream and put up for retail sale, whether or not containing soap; paper, wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent: Soap and organic surface-active products and preparations, in the form of bars, cakes, molded pieces or shapes, and paper, wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent: Other.
  • 3926.90.9910 – Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Laboratory Ware.
  • 4015.19.0510 – Articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanized rubber other than hard rubber: Other: Medical, of natural rubber.
  • 4015.19.0550 – Articles of apparel and clothing accessories (including gloves, mittens and mitts), for all purposes, of vulcanized rubber other than hard rubber: Other: Medical: Other.
  • 4818.90.0000 – Toilet paper and similar paper, cellulose wadding or webs of cellulose fibers, of a kind used for household or sanitary purposes, in rolls of a width not exceeding 36 cm, or cut to size or shape; handkerchiefs, cleansing tissues, towels, tablecloths, table napkins, bed sheets and similar household, sanitary or hospital articles, articles of apparel and clothing accessories, of paper pulp, paper, cellulose wadding or webs of cellulose fibers: Other.
  • 6210.10.5000 – Garments, made up of fabrics of heading 5602, 5603, 5903, 5906 or 5907: Of fabrics of heading 5602 or 5603: Nonwoven disposable apparel designed for use in hospitals, clinics, laboratories or contaminated areas.
  • 6307.90.6090 – Other made up articles, including dress patterns: Other: Surgical drapes: Other.
  • 6307.90.6800 – Other made up articles, including dress patterns: Other: Spunlaced or bonded fiber fabric disposable surgical drapes of man-made fibers.

These product exclusions apply retroactively to September 1, 2019 and will remain in effect until September 1, 2020. These exclusions apply to any product that satisfies the description in the annex of the Federal Register notice, regardless of whether the company using the exclusion filed the request. Each exclusion is governed by the scope of the HTS heading and the product description appearing in the annex of the exclusion notice; it is not governed by the product description set out in any particular exclusion request. U.S. Customs and Border Protection will soon issue instructions on entry guidance and implementation. The USTR will continue to issue determinations on pending requests on a periodic basis.

On March 5, 2020, Secretary Wilbur Ross testified before a Senate Appropriations subcommittee to discuss President Donald Trump’s fiscal year (FY) 2021 budget request for the Department of Commerce. In laying out the funding requests for each agency within the department, Ross requested $137.7 million for the Bureau of Industry and Security (BIS) in order to continue “efforts to curtail illegal exports while facilitating secure trade of sensitive technologies in coordination with U.S. allies and close partners.” He also stated that the FY 2021 budget would continue to fund BIS activities “necessary for the timely review of exclusion requests from Section 232 trade actions.”

In response to questions from Chairman Jerry Moran, R-Kan., Ross stated that BIS had addressed the key concerns raised by a recent Department of Commerce inspector general’s report (see Trump and Trade Update of October 31, 2019). He provided an update on the status of the Section 232 steel/aluminum product exclusion request process. According to Ross, 171,742 exclusion requests have been filed, with 138,243 posted for review and comment, and 31,381 objections have been filed. Overall, 112,819 exclusion requests have been processed. From this total, 87,808 requests have been granted, 25,011 have been denied, and 31,553 have been returned to the submitter as incomplete or incorrect. BIS has 27,322 exclusion requests that remain active and under review.

With the move in 2019 to a new portal for filing Section 232 product exclusion requests and objections, Ross noted that the process has become more streamlined. He indicated there has been a 79 percent decrease in the time it takes to post a new request on the portal, with new requests posted, on average, within three days. For exclusion requests that receive no objections, Ross stated that the average time for a decision is 59 days. For requests with objections, he noted that such filings take more time to determine due to the objection and reply process. He emphasized that this Section 232 process will help guarantee that “the U.S. steel and aluminum industries are given a level playing field to offset global overproduction to ensure our domestic industry can produce materials that are critical for U.S. national security.”

Ross’s written testimony is available on the Appropriations Committee’s website. You can also view a recording of Ross’s testimony; the portion of his testimony on the Section 232 process begins approximately at the 32-minute, 30-second mark.