“Verschärfte Vernehmung” is German for “enhanced interrogation”.
By Mona
Childish rhetoric such as calling the President “Bushitler,” and the like, hasn’t been my style. It may be time to reconsider. Andrew Sullivan, has some historical documents from the Nazi regime:
What I am reporting is a simple empirical fact: the interrogation methods approved and defended by this president are not new. Many have been used in the past. The very phrase used by the president to describe torture-that-isn’t-somehow-torture – “enhanced interrogation techniques” – is a term originally coined by the Nazis. The techniques are indistinguishable. The methods were clearly understood in 1948 as war-crimes. The punishment for them was death.
And as Sully painfully reminds us:
Freezing prisoners to near-death, repeated beatings, long forced-standing, waterboarding, cold showers in air-conditioned rooms, stress positions [Arrest mit Verschaerfung], withholding of medicine and leaving wounded or sick prisoners alone in cells for days on end – all these have occurred at US detention camps under the command of president George W. Bush. Over a hundred documented deaths have occurred in these interrogation sessions. The Pentagon itself has conceded homocide by torture in multiple cases.
I am so very ashamed of my country, and I never, ever thought I’d be forced into such an unwelcome feeling. Read Sullivan’s entire post, but be prepared to scream.Â
Comment by Dave W. —
May 29, 2007 @ 1:32 pm
Go to Canada if you feel that strongly. I did.
Comment by Gsnorgathon —
May 29, 2007 @ 2:06 pm
So even Sully is now shrill and anti-American. How sad.
Comment by moonbiter —
May 29, 2007 @ 3:15 pm
Entweder Gsnorgathon hat sehr ironischer Humor, oder er ist ein echter Troll.
Comment by Steve Barton —
May 29, 2007 @ 3:59 pm
Boo hoo.
Comment by Eric the .5b —
May 29, 2007 @ 5:15 pm
I wish I could believe that the Blues would change this, given the presidency or whatever other positions.
Comment by Davebo —
May 29, 2007 @ 5:19 pm
Sully concentrates too much on the words used and not on the acts themselves.
Call it whatever you want to call it. It’s still torture.
And I too am sad by all the bedwetters willing to defend it.
I wonder what Osama would call it? I suppose we could ask him.
Comment by JP —
May 29, 2007 @ 7:02 pm
The article is tragically convoluted and dishonest. As Sullivan notes, the techniques here aren’t new; if he was honest he’d note that they predate the Nazis. In fact the OSS employed similar methods on high-value Wehrmacht and Schutzstaffeln personnel captured during the war… and suspected German “spies” caught out of uniform. Why doesn’t Sullivan mention this? Because the Nazis (boogity boogity) weren’t involved and the British successfully covered it up without apparently resorting to cumbersome euphemisms. BUT HE’S NOT SAYING BUSH IS ACTING LIKE A NAZI, NO SIR.
Nazi war criminals weren’t hanged for simply torturing people or running a few freaky jailhouses for security purposes. In fact some of the people who did this were employed against Communists during the Cold War (I suppose you’re going to pretend to cry for them, too?). Their executions were also justified by the systematic, industrial murder of whole populations.
Comment by Mona —
May 29, 2007 @ 7:14 pm
JP, you are (purposely, one suspects) missing the point. The Nazis employed the same euphemisms for the same atrocious techniques, which were deemed to be war crimes. And I don’t know what your point about Communists is supposed to be because that sentence made no sense to me. If it matters, I’m somewhat notorious for my disgust with American Stalinists and their apologists, but that, too, is quite beside the point.
That article isn’t the least “convoluted.” You just don’t like what it says, both per se, and I imagine about your President and country.
Davebo: I disagree, the very need to resort to nearly identical euphemisms and “justifications” is quite the indictment.”
Comment by Thoreau —
May 29, 2007 @ 7:35 pm
I think the salient points here are:
1) It was a war crime under international law, and it’s a war crime now. Note that Sullivan discusses people charged with war crimes specifically related to torture of insurgents operating out of uniform. The guys in question weren’t charged with war crimes for the events at Auschwitz or wherever (they were too far away from that). This was about the use of torture.
2) Frighteningly, the exact same euphemisms and excuses were employed. There’s something about the psychology of torture that is sadly universal.
Comment by Gsnorgathon —
May 29, 2007 @ 7:44 pm
Alas, the real lesson here seems to be that the worst crime of the Nazis was losing. So long as we win, whatever we do must therefore be right. The actions of our enemies aren’t evil because of their actions, but because our enemies do them.
Comment by Mona —
May 29, 2007 @ 7:57 pm
What Thoreau said.
Comment by Jon H —
May 29, 2007 @ 8:34 pm
“So long as we win, whatever we do must therefore be right. ”
Winning seems rather unlikely.
At least the Bush administration, AEI, and the Project for a New Arab Caliphate can look forward to their shiny shiny Al Qaeda MVP rings.
Comment by ofom —
May 29, 2007 @ 9:01 pm
props to Moonbiter, but why Humor instead of Witz?
Comment by nabalzbbfr —
May 29, 2007 @ 9:26 pm
You are missing an important distinction. The Gestapo employed these techniques against innocent civilians. President Bush has expressly stipulated that enhanced interrogation techniques can only be employed against unlawful enemy combatants.
Comment by Hesiod —
May 29, 2007 @ 9:39 pm
You are missing an important distinction. The Gestapo employed these techniques against innocent civilians. President Bush has expressly stipulated that enhanced interrogation techniques can only be employed against unlawful enemy combatants.
They used them against anyone they thought could provide them information on enemy or insurgent activities, or actions against the state.
Some of thos people were “innocent” of the crimes the Nazis asserted against thm, yes. But so was that Taxi driver the US tortured in Guantanamo for several years using these techniques.
Beieve it or not, alot of the people the Naiz tortured really WERE with the French resistance, etc.
The point is that torture is an inherent evil. It does not suddenly become OK to do just because the person you are torturing is a bad guy.
Comment by Jim Henley —
May 29, 2007 @ 9:50 pm
Mona, you’re still a blogging noob. I would have titled the item, “Vee Haff Vays of Makink You GODWIN!” But keep at it. You’ll get the hang.
The only thing the torturephiles in the thread have said that interests me at all is JP’s claim that “the OSS employed similar methods on high-value Wehrmacht and Schutzstaffeln personnel captured during the war… and suspected German “spies†caught out of uniform.” Go ahead dude, give me the references.
Comment by Mona —
May 29, 2007 @ 10:03 pm
Oh, I know, and in this context Marty Lederman goes on at some length as to why “Godwin’s Law” is somewhat problematic at times, even if generally useful.
Comment by Jon H —
May 29, 2007 @ 10:25 pm
“Oh, I know, and in this context Marty Lederman goes on at some length as to why “Gdwin’s Law†is somewhat problematic at times, even if generally useful.”
In brief, how can we prevent another Nazi-like regime from rising if we aren’t allowed to point out that a Nazi-like regime is, in fact, rising?
So uncivil, you know. You can’t say that until six million and one Jews have been killed.
Comment by djangone —
May 29, 2007 @ 10:37 pm
Bam, there it is. Finally someone prominent breaks through the unspoken wall and lays out what’s been obvious without scrupling or pearl-clutching over the Hitler comparisons. This post was about the similarities with respect to basic human rights, but after proper pause to mull that horror, more could be written about similarities in Bush vs. Nazi communication style, use of political muscle–in short all things about the Bush Admin that had Orcinus’ Dave Nieuwert within an inch of declaring them fascists but for the lack of widespread overt violence in dealing with domestic enemies.
When a clown like DeLay uses Hitler comparisons against the Left, you know the time has long gone that the elephant in the corner, this creeping proto-fascism, should be brought out and dissected so as to prevent it ever getting near our room again.
Comment by Ultima Ratio —
May 30, 2007 @ 8:15 am
Gsnorgathon has a sad point. War crimes tribunals are convened by the winning states of a war to punish the losing states. And the U.S. has nothing to fear from any state with a carrier group, so don’t count on Rumsfeld, Cheney, Ashcroft or Bush visiting the Hague any time soon.
Comment by Barry —
May 30, 2007 @ 8:51 am
JP: “Nazi war criminals weren’t hanged for simply torturing people or running a few freaky jailhouses for security purposes. In fact some of the people who did this were employed against Communists during the Cold War (I suppose you’re going to pretend to cry for them, too?). Their executions were also justified by the systematic, industrial murder of whole populations. ”
And the USSR employed ex-Nazis in Eastern Europe, immediately after the war; sometimes in former Nazi ‘facilities’. For the same reason – they were useful, and had failed the ethics test.
Comment by ajay —
May 30, 2007 @ 10:01 am
JP: Nazi war criminals weren’t hanged for simply torturing people or running a few freaky jailhouses for security purposes
Well, as the documents quoted make perfectly clear, yes, they were. But since you haven’t shown up again: nice driveby, troll.
Comment by JP —
May 30, 2007 @ 11:13 am
The Nazis employed the same euphemisms for the same atrocious techniques, which were deemed to be war crimes.
–Did they use the same euphemisms? Does Sullivan speak German or do you just take his word for it?
Sullivan says the Nazis were hanged for using such techniques. Some were, but crimes against humanity – as opposed to mere war crimes the torture of a few Resistance members in Hotel Terminus – were the most damning legal justification for their execution.
(Let us not forget that some were shot for simply wearing the wrong uniform at the wrong time.)
Scale and extent of atrocity matter. In the interest of making a larger political point, Sullivan won’t admit that.
And I don’t know what your point about Communists is supposed to be because that sentence made no sense to me.
–Nazis who tortured people were used (hired, actually) by other security services to do the same things to Communists in the postwar era. Does that make French intelligence a pack of fascists? Does the rather aggressive British interrogation of IRA hooligans warrant a Nazi label? I doubt it but by bringing them up the association is fairly clear. Why else does Sullivan bring up the Nazis besides to slur the Bush administration?
You just don’t like what it says, both per se, and I imagine about your President and country.
–Right, since Canadians are known for being so pro-American.
Look, I just think that people overstate Western niceness – and that Sullivan is being sloppy here. I can point to French interrogations in Algeria and say “look, Nazi behaviour!” and important distinctions go out the window. The stronger case against French FFL and Paratroop units, for example, is to be found in large-scale atrocities against Algerian civilians; not the mistreatment of suspected (and actual) terrorists.
Comment by Mona —
May 30, 2007 @ 1:17 pm
Intent of post matters, and you won’t admit that. Thoreau encapsulated it best, so I will recite him verbatim:
(It is immaterial whether Sully speaks German. He has access to researchers who do, and has published to a world full of Internet readers that includes native speakers and other fluent in it as a second or more language. Thus far, I’ve seen no criticism, and your red herrings are quite numerous.)
Comment by Eric the .5b —
May 30, 2007 @ 1:23 pm
The OSS was an American agency, the predecessor to the CIA.
But, who cares? That the history of American torture actually quietly, shamefully predates the Bushies’ public establishment of it isn’t relevant to the point being made.
Comment by Jim Henley —
May 30, 2007 @ 3:17 pm
I’m still waiting for references on the claim that OSS tortured spies and uniformed officers during the war. I’m willing to believe that they did, but not on the basis of an unsourced blog comment.
Comment by JP —
May 30, 2007 @ 3:32 pm
“Intent of post matters, and you won’t admit that.”
–Beg pardon, but what does that mean?
“It is immaterial whether Sully speaks German.”
–What! So because he has a few German internet readers (does he?) at his beck and call that gives him license to flesh out the nuances of a foreign language?
Odd how that is immaterial to analysis of what he’s getting at but my suspected nationality and political sympathies weren’t (since you brought up red herrings). Curious also that Sullivan raises examples of Nazi torture and euphemizations thereof but, oddly, backs away from making the inevitable parallel.
“The guys in question weren’t charged with war crimes for the events at Auschwitz or wherever (they were too far away from that). This was about the use of torture.”
–Nonsense. The fiercest arguments made against Nazi and collaborationist personnel were their participation in mass executions (e.g. Einsatzgruppen aktion) and death camp conduct, things so heinous that new legislation was written to tabulate them. Brutalization of a few sullen partisans was trifling in comparison to, say, the Lidice massacre.
Thoreau brings up Auschwitz but that contradicts his point: Auschwitz’s camp commandant, Rudolf Hoess, wasn’t hanged because he savaged a few people and took nasty photos. That was merely a helpful indication of his sadism and severe character defects. He was executed because he ran the gas chambers.
It is no coincidence that a lot of people involved with low-level bone-breaking weren’t sentenced to death but commandants from Belsen, Majdanek and Jasenovac were (in the latter case in absentia).
The OSS was an American agency, the predecessor to the CIA.
–Yes. But interrogations were done in Britain and also assisted by British intelligence. Without that assistance it’s possible that the information we have now about Latchmere House and other places of ill repute might have been made public long ago.
“That the history of American torture actually quietly, shamefully predates the Bushies’ public establishment of it isn’t relevant to the point being made.”
–It is relevant when Sullivan – again – writes as though this is euphemization and denial are actually new – though as he says in the passage, they’re not. Suffice to say Sully would be shocked – SHOCKED – that the CIC kept the Butcher of Lyon on payroll. Weird, right? Whatever, that was under Truman, who gives a sh!t.
(The sad thing is the Soviets were even worse – they ran gulags. Which are now being compared to Gitmo. Or is it the other way around?)
Bushitler, the “commander” of US detention camps (LOL), has even offered a public apology for the wretched failures of leadership exhibited at Abu Ghraib. This seems a strange precedent for a fascist-ish head of state and counterpoint to Sullivan’s awkward rant.
Comment by BruceR —
May 30, 2007 @ 3:33 pm
JP:
(Let us not forget that some were shot for simply wearing the wrong uniform at the wrong time.)
Goering, for instance. That guy had no sense of style.
Comment by BruceR —
May 30, 2007 @ 3:39 pm
Jim:
You’ll keep waiting, I’m afraid. It’s like the Werwolf thing from a few years back that refused to die. The fact that this occupation is facing an insurgency means the 1945 occupation must have as well, even if all the histories say otherwise.
It’s a truism: since we are torturing now, the OSS must have then. After all, they won the war, didn’t they?
(It should be noted that the OSS/CIA was implicated in profiting from the avails of local torturers during the Greek Civil War a few years later. But I suspect that’s as close as anyone comes… Wild Bill Donovan was not particularly known for his lack of commitment to American values.)
Comment by Jim Henley —
May 30, 2007 @ 4:27 pm
Well, at least the “Latchmere House” reference led me to this:
But, hm, something’s different.
Comment by JP —
May 31, 2007 @ 12:38 am
“Goering, for instance. That guy had no sense of style.”
–I believe Hugo Boss designed uniforms for the SS. Presumably just because you’re fascist doesn’t mean you can’t be fashionable.
Maybe it’s one of the side effects of being a torturephile, but I hadn’t actually noticed Jim Henley’s request for substantiation. I already mentioned Latchmere House (unfortunately the Beeb article doesn’t really do justice to what went on there or elsewhere in the Isles). Much of what exists on this is still classified. Nonetheless there is some info available. For example it’s fairly well known that waterboarding wasn’t copied from the SS; it was used in the interrogation of Filipino rebels during the Philippine Wars. Apropos of the period we’re talking about, here are a few internet references. On the Bad Nenndorf incident (concerning British interrogation of DPs and German prisoners that apparently got out of hand):
http://www.guardian.co.uk/germany/article/0,,1745662,00.html
Assuming you accept the Guardian as a reputable source (a stretch, I know) this isn’t exactly cheery. The numbers aren’t as distressing as those released from the Rheinwiesenlager, but the inmates at Bretzenheim and Bad Kreuznach weren’t actively tortured and intimidated in the same way people were at Nenndorf. The motives behind the interrogations at Nenndorf should bother anyone who thinks the Allies (not including the Soviets for whom it was a natural state of affairs) didn’t use torture during and after WWII.
Benjamin Ferencz, US Army sergeant and later Einsatzgruppen Trial prosecutor (incidentally someone who thinks Bush should be up on charges along with Saddam [an odd sentiment considering what he admits below]), describes the ugly side of postwar evidence-gathering:
“Someone who was not there could never really grasp how unreal the situation was,” he says. “I once saw DPs beat an SS man and then strap him to the steel gurney of a crematorium. They slid him in the oven, turned on the heat and took him back out. Beat him again, and put him back in until he was burnt alive. I did nothing to stop it. I suppose I could have brandished my weapon or shot in the air, but I was not inclined to do so. Does that make me an accomplice to murder?”
“You know how I got witness statements?” he says. “I’d go into a village where, say, an American pilot had parachuted and been beaten to death and line everyone one up against the wall. Then I’d say, ‘Anyone who lies will be shot on the spot.’ It never occurred to me that statements taken under duress would be invalid.”
http://www.washingtonpost.com/wp-dyn/content/article/2005/07/21/AR2005072101680_pf.html
In other words: my hands are clean but only so much. And this from a future ICC advocate after the war. Now, is this not torture? Is someone going to tell me this doesn’t qualify as psychological trauma and mind-fuckery to the nth degree? How well do you think threatening unarmed civilians with summary execution would be received today? Hrm, probably like this:
http://washingtontimes.com/national/20031030-113114-2964r.htm
Returning to WWII, Ferencz’s testimony and references to psychological torture don’t take into account actual extrajudicial executions and atrocities carried out by Allied troops and SOE/OSS operatives, of which there were undoubtedly many during WWII (see here for a general scholarly account: http://hnn.us/roundup/entries/32869.html). Perhaps the most obvious brush the OSS had with torture was its recruitment of ex-Nazis (many of whom failed the ethics test referred to by Barry; think Operation Paperclip and the Gehlen Organization).
Such methods do produce results on occasion (just ask the poor survivors of Lidice how effective Nazi interrogation could be), but they strike me as oafish and unreliable. Rank sadism of the sort seen at Abu Ghraib doesn’t sit well with me any more than most of the commenters here. I’d much prefer that the more sophisticated hands-off interrogation techniques employed by Hans Scharff (yes, a German officer) on USAAF personnel were utilized in Iraq and elsewhere. Frankly the fact that torture occurs is not what bothers me; to some degree it is inevitable. Rather it is the attempt to whitewash its manifestations, past or present, accompanied by wails that “we’ve never done this before!†(Sorry Yanks, you have – and so have we).
I agree with Sullivan (gasp!) that the attempt to downplay torture is sad and disturbing. On the other hand, it’s not new; moreover, I find a few cherry-picked Gestapo papers are hardly indicative of the fascist parallels Sullivan (doesn’t!) draw and his sob sistery over the uncomfortable effects of a war he supported. In contrast to the denial of previous decades, I’m glad we can talk about this openly and without too much name-calling and mud-flinging.
Like BruceR says – and to paraphrase Rumsfeld – “stuff happens.” War is “untidy” and ugly and it’s pretty naive (in my humble opinion at least) to think even the most disciplined Western forces don’t embrace atavism from time to time, particularly during COIN work. It’s good that this tendency is being challenged and debated – unlike during WWII.
P.S. The comment about Joseph Donovan and “American values†is telling. Which values is the writer referring to? American sentiments of the period supported the censorship of negative press material, for example, which helped in terms of winning the war. On the other hand, dated notions of fair play very nearly prevented the formation of what we would recognize as structured extraterritorial information operations and intelligence networks. The emergence of an organized US foreign intelligence apparatus is relatively new; the OCI was ineffective as an intelligence-gathering organization and attitudes like that held by Henry Stimson (“gentlemen don’t read each other’s mailâ€) were sadly commonplace.
Donovan had this to say about the development of the OSS in 1942:
“Espionage is not a nice thing, nor are the methods employed exemplary. Neither are demolition bombs nor poison gas, but our country is a nice thing and our independence is indispensable. We face an enemy who believes one of his chief weapons is that none but he will employ terror. But we will turn terror against him – or we will cease to exist… On the one hand we must freely use stratagem and on the other, we must be frugal in civilized scruple. We are in a nasty business, facing a nastier enemy.â€
As for the recruitment of certain unpleasant Communists, Donovan apparently said: “I’d put Stalin on the OSS payroll if I thought it would help us defeat Hitler.†Not sure what that says about how permissive the OSS was of interrogative brutality, but as it was the NKVD knew far more about the OSS than vice versa and that came back to bite Washington in the ass after the war.
Comment by moonbiter —
May 31, 2007 @ 1:44 am
props to Moonbiter, but why Humor instead of Witz
Because Witz is “joke,” while Humor is, well, “humor.” As in ein Sinn für Humor (”a sense of humor”).
In any event, I just hope that the American people can reign in the sins of their leaders without having to lose 1 in 10 of their citizenry and suffering a devastated infrastructure. It’s too late for us to retain our innocence, but it’s not too late to stop the stupidity and evil.
I have some reason for this hope. Our public seems to be resisting the call to nationalism and fascism better than the Germans did in the 30s. But that doesn’t mean that we are out of the woods yet, or even near the edge of the woods. (I always thought when I was growing up that “The price of freedom is eternal vigilance” meant watch out for foreign invasion. Oh, the naiveté of youth …)
Comment by Mona —
May 31, 2007 @ 8:04 am
Not very. What Donovan meant, and what is true, is that he had American Stalinists working for him. It turns out that in particular former Lincoln Brigade members, bilingual and in other ways well familiar with warfare and intelligence gathering, were some of the best options for him. Not that he was always candid about it — he testified to Congress that he had no known Communists in his staff , which was a lie.
Further, I do not doubt — and in fact readily concede — that the allies, including some U.S. GIs were brutal to captured SS. Some of what was done to Japanese caught in the South pacific was, well, not pretty. In every war, no matter who it is, vicious things happen because warfare brings out the brutal instincts in people, and understandable so.
The difference here is what is formal, codified and officially promulgated. To deal with terror suspects our government has adopted formal standards that parallel those adopted by Nazis. And which are war crimes. At least one U.S. soldier during the Vietnam war was court-martialed for participating in a waterboarding, and waterboarding is one of the methods on display in the Vietnamese Torture Museum. (I had these cites at my old blog, whose archives have disappeared into the ether.)
Comment by JP —
June 1, 2007 @ 11:48 am
What Donovan meant, and what is true, is that he had American Stalinists working for him.
–Yes. That was my point. The OSS-cum-Central Intelligence Agency hired ex-Nazis and, essentially, American traitors. To imply that WWII American intelligence was naive and wide-eyed about torture – or the risks it was running – is sophistry.
The difference here is what is formal, codified and officially promulgated.
–Well it’s also not nearly as well hidden as similar (accepted, officially promulgated) efforts were in WWII. Which I think is another important difference. Instead of holding our noses and acting like “we haven’t done this before,” it’s being opened to the public.
At least one U.S. soldier during the Vietnam war was court-martialed for participating in a waterboarding, and waterboarding is one of the methods on display in the Vietnamese Torture Museum.
–I understand your government has tried a lot of people involved in Abu Ghraib and other inhumane incidents.
Comment by JP —
June 1, 2007 @ 11:49 am
Oops. Scratch “officially promulgated” from the above.
Comment by Mona —
June 1, 2007 @ 4:06 pm
The OSS having domestic Stalinists on its payroll — which it did during WWII — has no bearing on officially sanctioned torture. The Stalinists in the OSS were not involved in extracting information from individuals at the physical level.
This nation has rejected torture in its laws, along with the rest of the civilized West. Until Bush. If we accept torture formally, we slide steeply toward that whihc we are ostensibly fighting.
Comment by JP —
June 1, 2007 @ 6:19 pm
The OSS having domestic Stalinists on its payroll — which it did during WWII — has no bearing on officially sanctioned torture.
–Not just domestic Stalinists. I’m afraid the involvement of particularly brutal Nazi interrogators (Klaus Barbie) and bureaucrats (Alois Brunner) does imply a certain willingness to look the other way when it came to harsher forms of interrogation. That moral ambiguity is comparable to sending some Islamist thug to Jordan or Egypt to get worked over. Rendition (or as I like to call it, “outsourced coercive intelligence operations”) is an old game and will likely continue under the next administration, Democrat or Republican.
This nation has rejected torture in its laws, along with the rest of the civilized West.
–Officially, sure. Most of us have scruples and human rights are relatively respected in the “civilized West.” We expect to be treated decently by our police and military forces and by and large that’s exactly the case. Unofficially, it happens. Fortunately there is an independent judiciary to redress excesses and elected officials to regulate such things.
To the best of my (admittedly limited) knowledge, torture against American citizens is forbidden, though forms of it occur in prisons and jails. Britain has had much less issue with taking particularly noxious IRA characters to task behind closed doors. Ditto the French in relation to the FLN; at the time, Algeria was considered part of France.
When it comes to having other people do dirty work in other places, American laws carry no writ. That is to say international law is a wonderful idea but it’s often a toothless proposition as far as enforcement goes; it ends where state laws begin and those typically end where executive authority dictates otherwise.
Comment by Daniel —
August 2, 2007 @ 6:01 am
I have to say, that I could not agree with you in 100% regarding Unqualified Offerings, but it’s just my opinion, which could be wrong