Comment

We have little faith in the fairness and appropriateness of the US's laws and processes around copyright and intellectual property. The US government is continually strengthening its copyright laws at the behest of the entertainment industry (see SOPA and PIPA) and is trying to pass laws that we would not like to see copied in NZ.

Will this NZ police cooperation lead to New Zealanders being arrested and handed over to the US for doing things that may not be serious offences in New Zealand? Which other countries' laws do New Zealanders have to obey when using the internet?

Whether this case is an example of good international cooperation or the US demanding other countries help enforce bad law is yet to be determined. We will be monitoring this issue closely and hope to publish more information as it is available.

Media Links

• FBI charges seven with online piracy (Wall Street Journal)
• Megaupload's Kim Schmitz arrested in Auckland, site shut down (3news)
• File-sharing website Megaupload shut down, NZ-based founder arrested (PC World NZ)
• File-sharing kingpin arrested in New Zealand at US officials' request (NBR)
• 'We're not pirates, we're just providing shipping services to pirates' (Wall Street Journal Law Blog).
• Why the feds smashed Megaupload (Ars Technica).
• Megaupload attempting to get back online (Stuff NZ)

Useful Links

• The FBI press release.
• The indictment.
• Statement from the NZ Police.
• The NZ extradition treaty (PDF) with the US.
• Ministry of Foreign Affairs and Trade's information about extradition from New Zealand
• Yes, copyright infringement can be criminal in New Zealand with imprisonment up to five years.
• Damning quotes from the MegaUpload owner's email.

The omissions are significant and make it harder for the accounts holder to challenge the notice on the facts, but we believe there are excellent grounds for challenging the notice because the notice itself is invalid. The rights holders may or may not accept this but ultimately it will be up to the Copyright Tribunal to make the final decision.

Notice Requirements

So, what are the requirements for a valid infringement notice? They're spelt out in two places - the Copyright Act (mainly section 122) and the associated Copyright (Infringing File Sharing) Regulations. We'll only be looking at the requirements for the notices from the ISP (internet service provider) to the account holder (the person paying for the internet connection).

A detection notice must include:

1. The name of the rights owner (or their agent).
2. The name of the owner of the copyright of the work.
3. The name of the work that is alleged to be infringed.
4. The type of work it is (from the list at section 14(1) of the Copyright Act). This is one of literary, dramatic, musical or artistic works; sound recordings; films; communication works; or a typographical arrangement of a published edition.
5. What they're accusing you of doing to infringe copyright (from the list at section 16(1) of the Copyright Act). This includes copying, issuing copies, performing, playing or showing it in public, making an adaptation, or authorising someone else to do any of those).
6. The date of the infringement down to the hour, minute and second.
7. The internet IP address where the infringing is alleged to have occurred.
8. Identify the file sharing application or network used in the alleged infringement.
9. The date of the notice.
10. Explain the consequences if further infringing occurs.
11. Explain how to challenge the notice and give either a form to fill out or a link to an online form.
12. Include an infringement number. This number must be unique, indicate whether it is a detection, warning or enforcement notice, and identify the ISP sending the notice.
13. Include the ISP's contact details.
14. Include links to the relevant section of the Ministry of Economic Development's website.

A warning notice (the second notice after a detection notice) must include all of that information as well as:

1. Identify the relevant detection notice that this is the follow up to.
2. List any other alleged infringements that the account holder has detected since the detection notice.

An enforcement notice (the third notice) must include all of that information as well as:

1. Explain the enforcement action may now be taken against the account holder.
2. Explain that no further infringement notices can be issued by that rights holder until the end of the quarantine period (35 days from the date of the enforcement notice).

Challenging a Notice

When you receive a notice you have 14 days to challenge it before it is regarded as being accepted.

If you receive a notice, we suggest that you check it very carefully. If it is incorrect or omits required information you should challenge it. It will be up to the rights holder to decide whether to accept your challenge, but any challenges can also be used in your defence if you appear before the Copyright Tribunal. The notice will include instructions on how to challenge it.

The first few issued notices are starting to leak out and it appears that they do not comply.

An Orcon user posted to the 3strikes forum copies of the notices they received. Comparing the information provided on those notices to the law and regulations, we noted the following problems:

• There is no description of the type of work as per 14(1) of the Copyright Act. (Regulations 4(2)c(iii).)
• The nature of the breach (as described by 15(1) of the Copyright Act) is not specified. (Regulations 4(2)c(iv).) The notice only says a breach has taken place, not the nature of it.
• The date and time given on the first notice is not specified to the second. (Regulations, 4(2)c(v).)
• The file sharing application or network is not specified. (Regulations, 4(2)c(vi).)
• The notice number does not include information that identifies the type of notice or the IPAP that sent it. (Regulations 5(2)(b) & (c).)

These details matter because the account holder needs to understand what they are accused of so that they can properly defend themselves.

Account suspension

We are also deeply concerned that the notice makes the claim that your Internet connection can be suspended by the District Court for up to six months. This part of the law has not yet been activated, and it is alarming that notices are already misleading users on possible penalties. Orcon should not be making such claims.

Concluding questions

The notices as posted do not comply with the requirements of the law and regulations.

Does this mean that they are invalid and can be challenged (or ignored) as such?

Will the Copyright Tribunal accept them as valid or not?

Does this mean that all notices sent through Orcon are invalid?

We wanted to know whether New Zealand telecommunications companies are installing this sort of software on the phones they sell to us.

Telecom deny that they used anything of the sort:

No, we do not use Carrier IQ. Our devices do not come loaded with this type of software and we don’t have an agreement with Carrier IQ or any other company that implements tools like this.

Vodafone also deny using such software and make a good point about it contravening the Privacy Act:

Vodafone would never knowingly contravene the privacy act and to the best of our knowledge this software is not on any of the devices we sell.

Telstraclear have also denied it (brevity due to denial being via Twitter):

@TelstraClearNZ No, our devices do not keylog. ^TN

2 Degrees joins the rest:

No, we haven’t. The only customer information 2degrees records is for billing purposes. We don’t monitor our customers’ handset activity or request that any software to do so is installed on devices.

Thanks to @nzkarit on Twitter for his assistance with this article.

This is the transcript of a speech given by Thomas Beagle at Kiwicon in Wellington on November 6th, 2011.

Hi everybody. I'm Thomas Beagle from Tech Liberty. We're a lobby group dedicated to protecting civil liberties in the digital age.

I'm going to talk about how the government is protecting us by using technology to make us safer and happier people – while possibly not caring so much about our freedom.

Now, in the tech field we often laugh about the government and the law being one step behind - I bet more than one of you has looked at the new copyright law and thought "Ha, they're cracking down on torrenting but these days I get all my content via usenet!"

The problem is that this goes both ways. Sometimes it's the government that is using the new technology and the it's the laws we use to protect ourselves that haven't caught up with it yet.

Automated Number Plate Recognition

I'm going to start with automated number plate recognition because there's a good chance many of you won't have heard of it and it provides a good example of the way digital technology is changing things. But what is it?

It's pretty simple really - it's a camera that gets installed in a police car. It recognises the number plates of passing cars and checks them against a central database. Get a match to a "vehicle of interest" and the police can pull over the car and have a little chat with the driver.

Now you might think that sounds pretty innocuous, it's just automating an existing manual process. And it means that the police will spend less time and money catching more bad guys. How could anyone have a problem with that?

Of course, you lot have probably already worked out the problem. It's more than just a simple database lookup - it also includes the date, the time and the place. And it’s doing it for every car. And it’ll end up being installed in every police car. So the police are going to end up with an ever-growing database of car sightings that will let them know where you have been.

Tracking someone used to be hard.

Automated number plate recognition is going to make tracking easy. You don't need a whole team of people, you don't need to install a GP tracking device, you don't need to get a court order to access mobile phone data - you just install ANPR devices everywhere and then you can ask the database whatever you like. Because you're storing historical data, you can even go back in time - "Where did car X go on the night of May 5th?"

It's the sort of information that a totalitarian regime would love to have. It's the sort of information that an over-zealous police force obsessed with green or brown terrorism would use. But is it the sort of information that we want our government to have about everyone?

At one time the answer would have been no. When tracking devices became practical, the law was changed to make the police have to have a warrant before they could use them. Of course, the law change was partly to enable police to trespass to install the devices, but us civil liberties types have to take what we can get. This new automated number plate recognition system could be implemented without the need for any law changes or any oversight - and the NZ police are trialling it at the moment.

Search warrants

Another example of how the government’s use of tech is outpacing the laws we use to protect ourselves - the common or garden search warrant. Let's say that you're suspected of embezzling funds, or armchairs, from the company you work for. A complaint is made, the police investigate, they get a search warrant and kick down your door.

In the old days you'd expect them to take any sort of financial papers, documents, etc, etc. But would they take your old love letters or the family photo album? Of course they wouldn't, and the terms of the search warrant wouldn't let them.

Things are different now - sure they'll take any papers they find but they're also going to take your computer and any other digital storage on the premises. And, well I don't know about you, but my entire life is on that computer. My business files, my letters, my medical records, my family photos, ... my not so family photos... all in the hands of the police. All available to be indexed and searched with the police able to keep a copy indefinitely.

Once again, the law hasn't changed but the digitisation of information means that the effect of the law is much more oppressive.

Customs

And while I'm on the subject of searching computers, did you know that Customs have the power to seize any digital device or storage coming into the country and examine the contents? They can even take copies of the device for review later.

This is not just theoretical – they have been doing it. We got a complaint from someone about them taking his netbook as he returned from holiday in Samoa, and of course there were the Switched on Gardening people who had their phones and laptops taken every time they crossed the border.

In theory Customs can only do this to look for contraband or censored works, but it seems very likely that they are using this power at the behest of the police to do the searches that the police legally can't. You might want to bear this in mind the next time you cross the border.

Civil liberties

The question has to be - do we want to live in a society where our movements and secrets are open to the authorities? It's traditional to mention Orwell's 1984 at this point - not least because it is such a terrifying view of the surveillance state that we're rapidly developing the ability to implement.

How do we decide what is acceptable and what isn't Trying to come up with answers to this question is one of the reasons we founded Tech Liberty. We saw that one of the best ways to look at this is through some rather old rights such as freedom of speech, the right to due process, the freedom from unreasonable search, and the recent addition of the right to privacy. And some of our new laws are stomping all over them.

But I promise this isn't a recruitment session! Instead let's start running through some of the things happening at the moment in New Zealand.

Control of the internet

The big one is control of the internet. Over the past 7 years there has been a three way legal combo attack that, as far as I'm concerned, means that the government has largely won.

The first part of this combo is the Telecommunications Interception Capability Act of 2004, known as TICA. It simply says that communications companies - telcos and ISPs - must provide facilities for law enforcement and intelligence agencies to be able to intercept communications - phone calls, data, etc. Sure, they have to have a warrant, but as our judges have declined just 1 of the hundreds of applications for interception warrants in the last three years, I think we can assume that that isn't too difficult to get.

Second is the internet filter implemented by the Department of Internal Affairs. There is no law enabling this and therefore use of the system is "voluntary" by the ISPs - but I note that in the UK they made moves to make a similar system mandatory after some of the smaller ISPs failed to realise they were meant to volunteer. Right now over 90% of New Zealanders get their internet through a connection that is censored by the government and, unlike the rest of our censorship laws, they refuse to tell us what has been blocked.

Finally, our new copyright law to stop the evils of infringing file sharing has two interesting provisions. The first is that ISPs are obliged to keep records of which account had which IP address at any one time. Secondly the government has decided to skip all that messy having to prove you actually did something bad, and has decided that they can penalise the account owner for anything done through their internet account.

So, this three way combo means that the government has established that it has the right to control where we can go on the internet, it has the right to monitor what we do, and if someone does anything it doesn't like, the government has someone it can punish.

Now this is currently being done with a fairly light hand - they only filter "the really bad stuff", they have to get a warrant to monitor or intercept, and no account holders have been fined yet (although the first notices have just gone out) - but it means that the tools are in place and ready to be extended as required.

For example, currently it's the Department of Internal Affairs who choose what to censor and I believe them when they say that they want to limit the use of the filter to child pornography... but they're not the only ones with influence. How about the courts - a judge in the UK has just ordered British Telecom to use their "really bad stuff" filter to block access to a file sharing site - because the tech is available. Or what happens if there's another media scandal about bomb-making instructions on the internet and some politician thinks that the government must come up with a solution - again, the technology is there and ready to be used.

Of course, you're all sitting here thinking "haha, I am elite masterhacker and I use encryption and VPNs, they'll never catch me!". And to a certain extent you're right - the careful and technically savvy person can avoid some of these things to a greater or lesser extent (although of course, your VPN has to come out in a legal jurisdiction somewhere...). But while this is all right for you and me, what about everyone else in New Zealand? Don't they deserve some freedom and privacy as well? When governments oppress people, it affects all of society.

Cameras

What else is happening? I think we can safely assume that the number of surveillance cameras, both govt and private, continues to rise. At some point the promise of facial recognition might even live up to its marketing claims.

But there are also special cameras. Customs have been trialling the naked body scanners even though the Aviation Crimes Act expressly forbids use of technology that shows the naked form. Customs claims that the law only applies to the use of scanners to detect weapons and other threats, whereas they're using them to detect contraband. In other words, either they're lying - or they're willing to invade your privacy by taking naked pictures of you to find counterfeit Rolex watches.

Privacy Act

Of course, we do have the Privacy Act. People and companies can't just give your private info away, right? Well, first you have to worry about the jurisdiction that your data is in - services based overseas may not have the protections we do.

But even in New Zealand the act includes a provision that you're allowed to release information "to avoid prejudice to the maintenance of the law". You may think that the police would need a warrant or court order to get Trademe to release information about you, but they're happy to admit that they will give the police any assistance that they request. Do you know whether the NZ companies you deal with will stick up for your privacy?

The Law Commission has just finished the review of the Privacy Act and we're expecting to see a bill to modify the law soon. The good news is that they intend to make the Privacy Commissioner a little less toothless. More interestingly, they've recommended making it a responsibility to notify people if security is breached and personal data is stolen. I think this is a good idea and, for any black-hats out there, it's going to make cracking the right targets just that much more satisfying when they're obliged to put out a press release telling everyone about it.

TICA and Search & Surveillance

Speaking of reviews, earlier I mentioned TICA, the Telecommunications Interception Capability Act. There's a general perception that the law doesn't work well, with both law enforcement and comms companies struggling with the lack of specifics. The Ministry of Economic Development is planning a review of the law next year. I think it's going to be one to keep a sharp eye on as law enforcement is never shy about asking for more powers.

The best example of that is undoubtedly the Search & Surveillance Bill. The Law Commission was asked to review and revise our rather chaotic laws around search & surveillance. Now, they could have had a serious look at what sort of invasive powers we let the government have in a free and democratic society - but instead they just gave the police and everyone else whatever they asked for. I still find it hard to believe that they thought it appropriate that even the local city council could apply for a search warrant to put a hidden video camera in your bedroom.

The original version was so over the top, and so badly drafted that it got sent back to be rewritten somewhat, and you can tell it’s still bad because then the govt chickened out and put the rewritten version on hold until after the election. Some of the things I'm particularly unhappy about are the lack of notifications - how can you challenge the government for doing an illegal search if you never find out that it was done? There’s also further erosion of the right to silence through the extension of production and examination orders to more types of crimes.

But one part you should all be aware of is related to searching computer systems. If you have "relevant knowledge" of the system being searched, you can be compelled to assist in the execution of a search. Refuse? You could be jailed for up to three months.

Now this could be unpleasant for a number of reasons - who wants to be caught up in someone else's drama just because you're a sysadmin or work at an ISP? But what if the assistance you're asked to provide is "Crack the encryption on these files"? How well do you think the average judge will understand that cracking a well designed encryption system isn't exactly trivial? After all, they watch TV, they know hackers can get into anything with few minutes work.

Why do we get these laws and why are they often so bad?

The final thing I want to talk about is - where do these laws come from and why are they often so bad?

Wikileaks very clearly showed that our new copyright laws are a result pressure from the US. And they’re still going – now it's the promise of a free trade treaty, the Trans Pacific Partnership, where the cost of joining and getting better access for our agricultural products will be gutting Pharmac and implementing stronger IP laws.

Then there's our local politicians who need to be seen to be doing something and are always happy to pander to the law and order trolls to get votes. Don't you trust our brave boys in blue? Of course they need more powers to stop these evil islamic Greenpeace terrorists!

Unfortunately "something" is often ineffective or has undesirable consequences. We end up with King Canute laws - someone is standing on the beach and ordering the tide to stop coming in, and it's not doing a lot of good.

Will our new copyright laws stop file sharing? No, but they have undermined our right to a fair trial.

Will the internet filter stop children being abused? Of course not, but it has given the government a new system designed for mass censorship.

Will naked body scanners stop terrorist attacks? Well, we don't have any terrorists so maybe this one will be effective!

Political solutions

Kiwicon is a very technical conference but these aren't technical problems with technical solutions. Instead they're political problems and the solutions also have to be political. The good news is that in New Zealand we do have, no matter how much people sneer at it, a working democracy.

You can get involved, you can give an opinion, you can help educate our politicians, you can influence our laws.

And this is the point where I say that Tech Liberty needs more people who want to be involved in that political process, that we have a website at techliberty.org.nz, and thanks very much for listening.

These talks have included meetings with representatives from IPSafe (www.ipsafe.co.nz) and Datacom (www.datacom.co.nz). IP Safe's website is rather minimal and they have not responded to our queries. Their record at the Companies Office lists three directors, Chris Riddell, Wared Seger and Adel Shahin.

They also note that the Telecommunications Carriers Forum (TCF) submission about the law suggested that a centralised system run by the government would be the best approach, but this was not picked up by the Select Committee.

The MED goes on to say that they are not in the process of considering such a system and "that specific arrangements for the implementation of the Act are a matter for Internet Service Providers to agree on between themselves."

The questions have to be: why is Datacom involved and who are they working on behalf of? Who are IP Safe and what is their involvement?

What inspired you to offer the service?

People will always choose the easiest way to get the latest movies and TV shows and downloading off the internet is it. Unfortunately options are now limited to VPN tunnels not only for p2p but also for using an American IP address to get access to TV sites like www.hulu.com.

Are you getting many customers and what do they want it for?

Yes I am. VPN tunnels have a number of uses that include getting an American IP address to watch tv sites such as hulu.com, encrypt internet traffic when they are using a public WiFi point and of course hiding their real IP address.

How do you feel about the fact that some of your customers will probably be using your service to break NZ law?

No Comment.

What sort of information do you keep about your customers?

We only keep the email address.

What sort of information do you keep about your customers connections? (Such as when they connect, how long they connect for, anything they do through the service.)

We do not log what the user does or transfers over our network but we do log the time of connection and disconnection. We use this data to strategically deploy network resources. We also log the country the user is logging in from, this helps us to detect hijacked accounts and abuse. We do not log IP addresses.

Do you think your business has an obligation under the Telecommunications (Interception Capability) Act to allow the NZ police or other enforcement agencies to monitor traffic?

No, I am not a network operator. A network operator means a person who owns, controls, or operates a public telecommunications network or a person who supplies (whether by wholesale or retail) another person with the capability to provide a telecommunications service. CyberDodge does not provide anyone else with the capability to provide a service and CyberDodge is not a public telecommunications network. Public telecommunications network means a public switched telephone network and a public data network. CyberDodge is not a public switched telephone network nor a public data network. A public data network means a data network used, or intended for use, in whole or in part, by the public and includes, without limitation, the following facilities: Internet access and email access. CyberDodge requires that you have internet and email access already. This law applies to ISPs, which CyberDodge is not.

Do you think your business has an obligation under the Copyright (Infringing File Sharing) Act to store customer IP addresses so that you can pass on notices?

No, I am not a IPAP. IPAP, or Internet protocol address provider, means a person that operates a business that, other than as an incidental feature of its main business activities, offers the transmission, routing, and providing of connections for digital online communications, between or among points specified by a user, of material of the user's choosing and allocates IP addresses to its account holders and charges its account holders for its services and is not primarily operated to cater for transient users. CyberDodge does not offer the transmission nor providing of connections for digital online communications. CyberDodge only routes digital online communications. This law applies to ISPs and CyberDodge is not a ISP.

"Taking photographs around Cuba Mall and a police officer approached and said 'Would you like me to break that?' indicating the camera. He was exceedingly hostile and it turned out it was because the officer thought he had been photographed by us."

"Have to wonder why they confiscate cameras and tapes then. We were told we could pick the tapes up from the station... at which point any knowledge of the tapes was denied."

The legal situation in New Zealand

Firstly, it is generally accepted that anyone can photograph or video anyone else as long as the subject wouldn't have a reasonable expectation of privacy. There are a range of exceptions, but are the police one of them?

We wrote to both the Police Commissioner and the Minister of Police and asked them "Is it against the law in New Zealand to take photos of video of the police at work?"

The Police responded first: "No, not if the photos of video of police at work are taken in a public place, or with the landowner's consent if on private property."

Judith Collins, the Minister of Police, backed up the Police's position in her response, going on to say that she saw no need to change the law and was not aware of any plans to do so.

Conclusion

It seems clear that in New Zealand the police can't stop you from documenting what they are doing. They have no power to stop you, seize your camera or force you to delete images or video.

We believe that this is a good thing and is part of having a police force that is accountable to the people they serve. The police hold most of the cards when it comes to dealing with the public, and the prospect of being recorded should provide a brake on any temptation to abuse those powers.

However one concern remains. Police training does not cover this issue and it seems that some officers feel free to make up their own powers as they go. We recommend that the NZ Police should make sure that this is included in initial and continuing training.

Finally, we remind anyone taking photos of police at incidents to make sure that you do not get in their way or you could be arrested for obstruction.

Liability under the new copyright law

One of the issues that we and many others have with the new copyright law is that it unfairly penalises people for the actions of others. You're either an IPAP (a very tight definition of ISP) or an account holder, and if you're an account holder you're liable for the actions of anyone using that internet account.

This means that hotels will be liable for the actions of their guests, universities for the actions of students, the person paying the bill will be liable for their flatmates, and you'd be better be careful about which of your guests you let use your internet while they visit your house.

Ministry of Economic Development advises differently

However, it seems that the Ministry of Economic Development has a different interpretation of the law. The owner of a homestay, concerned that as the account holder he would be liable for his guests, recently contacted the Ministry of Development.

The advice he received from the Ministry was that if he is providing internet services but does not meet the requirements to be an IPAP under section 122, then he must be an ISP and would be safe from liability according to section 92B.

Furthermore, if he received an infringement notice he just had to respond and say that he ran a homestay and that would be the end of it. As he observed, "What's to stop anyone claiming that their house is a homestay?"

Our interpretation

We don't find this interpretation particularly convincing (nor did we find it convincing when the NZCS made a very similar argument in their submission (PDF) to the MED).

The intent of the Copyright (Infringing File Sharing) Act seems to be to catch everyone. If we accept the MED interpretation, the definition of ISP in the Copyright Act is so wide that anyone who shared their internet connection with another would thereby be able to claim immunity under it. The law would be fatally undermined.

While we think that this wouldn't be a bad thing, as it would remove liability from account holders who shared their internet and thus avoid the problem of punishing people for the actions of others, it seems clear that this is not the intention of the law makers.

Ultimately this argument will be tested at the Copyright Tribunal and possibly in court, but for now we caution against relying on this advice from the Ministry of Economic Dvelopment. This means that you should assume that the account holder will be liable for any infringing file sharing performed over their internet connection.

[Correction: The article as originally posted said that the advice was from the Ministry of Justice. The MoJ contacted us to deny giving advice to anyone. We followed up with our original source and managed to establish that the advice was actually from the Ministry of Economic Development. We apologise for the error.]

Where are the notices?

We've not received one notice in response to our request for copies of copyright infringement notices sent under the new law. From speaking to ISPs, it seems that very, very few notices have been received at all.

What are the rights holders doing?

Secondly, we heard some very interesting rumours about what the major rights holders organisations are doing. (Please note that this is rumour - but from a source that we trust.)

No one will be surprised to hear that the rights holders were very unhappy about the $25 per notice fee set in the regulations. NZFACT (NZ branch of the US MPAA) believes that they should be "just a matter of cents".

Indeed, we've been told that they're not going to be sending out any notices even though they heralded the law as a vital protection for their NZ$2.5 billion industry.

Instead they are talking to ISPs and offering to fund a centralised system for the management of the infringement notice process. This is obviously with the aim of making it much cheaper for the ISPs, so that they can go back to the Ministry of Economic Development to get the per notice fee reduced at the six-monthly review.

Some questions

This raises a number of questions:

• How will the centralised notice system work?
• Who will have access to the system and under what terms? Is it just for the major rights holders or will it be open to everyone?
• It will be necessary for any system to have some account holder details included (for matching purposes) - who will have access to this information? Won't this circumvent the law's careful approach to maintaining account holder privacy?
• And finally, what's in it for the ISPs?

Contact us

If you know anything about this proposal we'd love to hear more.