I actually kinda like talking about insider trading because it's a topic that can have a lot of gray areas in it and requires some legitimate careful thought. Despite having worked on Wall Street for many years, I'm well aware that insider trading questions are frequently not cut and dry, which is why we were usually trained on the maxim "If you have to ask, don't do it." I wrote a few posts on this topic earlier, but it's come back into play with a vengeance this week, with the crackdown on "expert networks."
Uninformed populist ragers will act shocked, and scream "OMG! So wall street takes all of these industry insiders, re-labels them "experts" and then sells inside information?!!! How unfair!" Now, I just want to clarify one thing - the point of expert networks is to allow people who want to do real due diligence to get the information they need by talking to people who know what they are talking about! The vast majority of the information in these sessions is almost certainly perfectly legal to share. It's also entirely possible that there are people who mistakenly disclose information that they should not be disclosing and are guilty of misappropriating material non-public information - but I'd guess that they are a minuscule minority. My point is only that expert networks are positively not inherently evil. In an ideal world, this is how everyone would do research - talk to experts. Instead, we rely on greed, the desire to make a quick buck, penny stock touts, and Cramer. But I digress. (Here's a pretty decent description of Expert Networks)
Let me just give a few quick examples: If you want to know about how ETFs work, you might pay to have a conference call with me, and I would explain it to you. Talking to me, an expert in the field, is a great way for you to quickly get a grasp of a concept or industry in a short amount of time, without the journalist or mutual fund industry bias that you'll get reading white papers on the 'web.
If you want to know about the effect the expiration of Apple's exclusive AT&T contract might have on the mobile phone industry, you might contact Gerson Lehrman (one of the "expert network" pioneers), who would (for a fee) put you in touch with the former VP of sales for Sprint, who could explain the entire process to you. Nowhere in the chain is the goal supposed to be to get the current VP of AT&T to comment on material nonpublic information about his company's subscribers or business plans. The expert you are talking to knows this (or is supposed to know this!) also - and doesn't want to go to jail or get fired just to make you rich and get $200 an hour for himself.
If you want to understand the effect that higher fuel prices might have on Wal-Mart's distribution costs, you might talk to a shipping company about the number of miles they drive each year, and how that might change with economic conditions and higher commodity costs.
If you want to understand the process by which BP will have to close down its leaking well, you contact an expert in the field who could explain to you in an hour what you might otherwise spend 2 weeks researching on your own. (A friend of mine actually mentioned that he talked to some Gerson Lehrman experts on this very subject, and they ended up being wrong about their prognosis!)
Is it possible that one might encounter a policy-ignorant industry insider who shares material non-public information? Of course it's possible - but it's positively not the goal of expert networks. The goal is to allow investors to gain an in depth knowledge of a business from people who understand that business. Increased due diligence is a good thing, and insider trading is a bad thing - but the two are not even close to synonymous.
Amazingly, in the wake of this week's FBI activity on insider trading, the boys at Themis, Sal Arnuk and Joe Saluzzi wrote and absolutely embarrassing article attempting to liken high frequency trading to insider trading. Sal and Joe are not idiots. I don't generally agree with their view of the use of technology in the markets, and view them as victims of the progress in technology, trying desperately to cling to their niche by maligning their opposition - but at least they usually try to make well reasoned, factually sound arguments.
Their piece today, however, was utter nonsense. It's so bad that I hate to call attention to it, but it needs to be corrected, and it touches on insider trading topics I've addressed on this blog previously. Themis writes (emphasis theirs):
"We believe that if the FBI and SEC feel that information that investors are getting from some “expert networks” is defined as inside information, then a case can be made that the data that the exchanges are providing could also be considered an “expert network”. The question becomes is the information that the exchanges provide in their private data feeds considered “material, non-public information”? It is certainly not widely disseminated but is it non-public information? We realize that anybody can subscribe to the data feeds and this is most likely the defense the exchanges will use. But is it realistic for most investors to subscribe to these data feeds and then establish the computing capacity to analyze this information. The fact of the matter is not all investors are looking at the same information. Whether this is technically inside information is not for us to decide."
Readers should have no confusion on this matter: this is not non-public information. In fact, it's quite public - it's available to anyone who wants to subscribe to it - for a fee. Remember from my prior post - "public" doesn't mean you can get it online in 15 seconds via a Google search for free. I've tried to repeatedly make the point that this is another reason why high frequency trading is a better model than the old NYSE specialist model: the specialist model was a tight Old Boys' club - you couldn't become a specialist just because you wanted to and had the ability to - you had to crack the club. It was positively non-public in terms of opportunity. Today, however, the process has become democratized - anyone who has the ability and the means can compete in the world of high frequency trading, using PUBLICLY available data that doesn't cost millions of dollars a month. It's not just the rich, it's not just men, it's not just certain ethnicities - it's democratized.
So when Sal and Joe write "whether this is technically inside information is not for us to decide," I can only hope that they are being intentionally disingenuous and that they in fact are fully aware that this is not anything that can even be intelligently debated as inside information, and are simply trying to write a fear/hype piece to mis-educate the masses. Just because John has access to information that Jane doesn't have does not mean that John's information is non-public, or that he has some unfair advantage. All investors are rarely looking at the same information - the important point is that investors have the opportunity to have access to the same information. If you still don't understand this, please read PeterPeter's comment on Themis's Business Insider post, which reiterates a number of points I've discussed on this blog previously.
-KD
30 comments:
The worst part of high frequency trading is that those who are part of it (HFT) are allowed to trade in subpenny prices, which the rest of us aren't.
Other than that, I personally don't care positively or negatively about HFT.
Anon #1.
KD - your argument is correct. It is no different that me not getting the WSJ and my neighbor did and me seeing that as an unfair trading advantage.
Kid,
I am afraid I must respectfully disagree with the disclosure aspect of your position (Re: Themis Trading), where disclosure needs to apply.
I should disclose off the top that I am not nor have I been a professional equities trader, so my knowledge of these specific data systems is limited. That said, I do have a firm grasp on disclosure requirements for publicly listed entities from both the sell and the buy-side, and it is from this perspective that I comment on public disclosure. For listed entities, while the identification of the materiality of specific information is often a grey-area, and one that dynamically changes with supplemental information, the requirements for disclosure of this information are quite firm. In circumstances of MNPI, public disclosure is not deemed until information has been widely dissemenated in a non-exclusionary manner. This is commonly occurs through public filings with the listed exchange, or through other company notices available to the public (read: either anyone or press can view).
In the instance of indirect MNPI as I'll term it, where exchanges, brokers, or data providers (not insiders to the target firm) possess information deemed MNPI I will concede the situation may differ, but only in the requirement to disclose not the method. I am afraid these situations draw on knowledge of case law and enforcement practice beyond my own experiences.
For reference, please find attached a Q&A provided by the US SEC on the Fair Disclosure regulation: http://www.sec.gov/divisions/corpfin/guidance/regfd-interp.htm
Note that the answer to question 102.05 provides valuable insight.
Great post - you are completely correct.
I could give you lots of examples of "expert" interviews I've done (though not necessarily using networks like these) that were incredibly useful that have nothing to do with inside information. They just represent doing tons of work. Really good buy side analysts (at fundamentally-driven shops) might spend hundreds of hours looking at a single investment from every possible angle.
A real world example that I have done countless times: I'm looking at a new medical drug or device (maybe still in trials, maybe recently approved). I know the company's version of how this is going to be used, but I want to talk to actual physicians and really go into detail about what they do when a patient presents: what's the thought process, what tests are run, how do they decide how to proceed, what reimbursement issues are there, when will they decide to escalate treatment, where might this new option fit in, what would they need to see to use it more/less, etc. I could go on, but these are the types of ways that interviews like this are used all the time in health care, rather than "Hey, did you hear how drug X is doing in its clinical trial?"
Interesting article. My first thoughts on seeing this issue flair up was "Aren't experts the source anyone who is knowledgeable would turn to?"
Also, would it be possible to email you? I work for a similar site and I'd like to discuss a few things.
UA - sorry you might not have seen your comment right away - Google filtered it as SPAM for some reason.
Now, I don't get your point:
"public disclosure is not deemed until information has been widely dissemenated in a non-exclusionary manner"
the information in question IS widely disseminated in a non-exclusionary manner to each and every person who wishes to subscribed to it. It's positively NOT MNPI - seriously - this isn't one where the lawyers need to pull their hair out analyzing it. It would be one thing if the exchange was leaking the data to their buddy in Newark, but no one else - that's not what's happening.
Also note that Reg FD, which you referred to in your link, is something different.
Andrew: kiddynamiteblog yahoo if you want to contact me. I don't check that constantly though
Agree 100%.
I would add that the expert networks, at least the reputable ones, put experts who sign up through a questionnaire designed to make sure they understand what nonpublic information is and that they are not supposed to disclose it.
And the funds that want to stay on the right side of the law kick off every call by asking the expert not to disclose material nonpublic information, since they wouldn't want to be restricted from trading.
There is certainly potential for it to be a slippery slope of error and abuse, but it's not wholesale brokering of inside information.
when a retired physicist at a large computer co told me he got paid thousands a day to advise Wall St firms about potential new machines touted by another firm, it was perfectly clear to me he had no MNPI to share and the firms were doing exactly the right thing. When another physicist casually told me how iPods were selling explosively and Apple couldn't keep up, I knew this was MNPI and didn't trade it.
Kid,
I certainly understand and agree with your point that the evolution of market data from the old boys club to the available to all data-subscription model is an improvement, and a clear step towards reducing incidents of blatant insider trading.
My point was this: I'm uncertain as to how what I've termed indirect MNPI (material non-public information held by a non-corporate insider) is determined and whether certain trading information applies, however assuming it is MNPI and that a) it is still illegal to trade under MNPI indirect or direct, and b) that the only way to unburden oneself of such MNPI liability is to disclose the information publicly (as listed firms do under Reg FD), then I agree with Themis Trading's commentary as a subscription service is by definition not public. As you can see in the SEC Reg FD Q&A link I sent, the authorities are quite particular as to what qualifies as appropriate disclosure, and under such stringent requirements it seems clear to me that only releasing information to a group of the public who had to opt-in and pay anything more than a truly nominal fee for a subscription is not available enough to meet the SEC Reg FD threshold.
Obviously however, if you disagree with either of my assumptions a) or b), then the following point of sufficiency of disclosure is moot because that would imply Reg FD may not be a suitable comparable. I will say though that on the sell-side the by the book practice is that when an analyst learns of MNPI on a coverage entity not only may they not use it directly in publications to clients, but they are obligated to inform the target company that such MNPI exists and urge them to disclose under Reg FD.
So again, I don't know much about the players involved in data streaming or the specifics of subscription services, but in my mind I see parallels with Reg FD where assumptions a) and b) are in force.
UA - Talor's simplification in the second comment of this thread illustrates why confusing and confounding Reg FD and corporate MNPI here (which is what I think you are doing) is misplaced.
for the purposes of MNPI, information in subscription services IS public - again, "public" doesn't mean "freely and easily available on a google search". for the purposes of Reg FD, it may not be - which was your earlier link.
aside, I still don't know why Google thinks you are spam...
Kid,
I hear you on the differences between Reg FD for listed entities/corporate insiders and 'indirect MNPI' or corporate MNPI, and candidly I don't know whether similar treatment would apply. The Reg FD just offers a MNPI disclosure framework, whereas there doesn't appear to be one that exists for indirect insiders, as indicated by this discussion.
Let me illustrate by way of a couple of hyperbolic examples why I would be inclined to lean towards the Reg FD frameworks:
1) Lets say I am the sole owner of a firm that provides market data and I am the sole employee (no fiduciary obligation since it's only me). Despite this, my one man operation sees all the flow from every player in country X at the highest level of detail a full 2 minutes before other data providers do. I then start a subscription service called UA's Minute by Minute (anyone can subscribe, $10MM/acct/yr), where every minute I highlight fresh trades that a reasonable investor would expect to move a stock's price (MNPI) and send this instantly to my subscribers (a full minute before any other providers could know). Is this inside information, or does my subcriber distribution make it public? What if there is only 1 person who subscribes? Does the ability for anyone to subscribe still make it public?
2) (more classically) Lets say I produce an influential weekly publication, in which 1 listed stock is favourably profiled, and this profiling correlates well to a 1 day outperformance in this name controlling for other factors. The article contains no MNPI itself (it IS MNPI). I have a super-subscribers service, where for a fee (again $10MM/acct/yr) available to anyone willing to pay I provide this article 1 day before the newsletter is sold to my other subscribers. Is this inside information, or does my super-subscriber distribution make it public? What if there is only 1 person who subscribes? Does the ability for anyone to subscribe still make it public?
Both examples are hyperbolic because of the clear MNPI and monopolistic nature of the MNPI, and that the threshold for entry to subscription to the MNPI is clearly prohibitive for retail investors. Does this matter? Does the public/non-public threshold perhaps relate to whether a retail investor could reasonably subscribe?
I think we would both agree that if the MNPI was from an insider directly there would be much more clear cut consequences to all parties.
UA:
#1) not MNPI. It's publicly distributed to anyone who wants to pay for it. Your prohibitive fee brings up other "fairness" issues that people would complain about and want changed though. Your extreme example is pretty much what most subscription based research or data is like.
#2) I thought we kinda talked about this one earlier in the prior thread - it's also not MNPI, although outlets that do this, like Barrons, have policies prohibiting their authors from leaking the story data for profit. Actually, it may be MNPI for Barrons for that reason - you're harming BARRONS by releasing the data - that's the violated duty. In your example, you can't violate a fiduciary duty to yourself, so it's not MNPI.
Manipulation, maybe, but that's another story
UA - i should have clarified the main point, which I think you already know, but it's always good to remind others:
material + nonpublic is NOT EQUAL TO material nonpublic. That's the key point.
If I go to WYNN and drop $150mm at the tables, that is material information. It's also non-public information. It's also completely legal for me to buy WYNN stock using that information, and for me to tell my friends that I lost $150mm and that they should buy WYNN stock. it's NOT material nonpublic information from an insider trading perspective, even though it's material and nonpublic.
Kid,
Perhaps I am overweighting a fairness doctrine over minimum disclosure levels. I certainly am concerned about the entry-fee based collusion and potential for market manipulation.
Also, your responses seem to imply that the folklift operator at BusinessWeek who provided the Merrill analyst with advance copies would have been acting legally (though likely against company ethics and non-disclosure guidelines) if he took out an ad in the WSJ and advertized providing that service regularly to anyone with $10MM. Whereas when he released this information privately to the ML analyst on request he was found guilty of conspiracy and insider trading charges. (http://www.reuters.com/article/idUSN0730131820071208)
A telling sign for future enforcement will be the underlying evidence of the current "expert network" investigation. In my opinion it feels like populist sentiment against capital market nepotism and the insider wealth-gap may create policy 'suprises' for many participants going forward (their lobby be damned).
@UA I don't want to rehash a lot of what we discussed in Kid's earlier insider trading thread, but it seems to me that what a lot of your comments are missing is that the information in question must be material, non-public AND obtained through some violation of a duty. That last part is key. In the case of case of a forklift operator, he's has a duty to his employer. He violates that no matter whom he sells his information to. Hence, insider trading.
Here's a real world example of an expensive data source that is not insider trading. IMS tracks prescriptions of drugs in the US. This data is very, very expensive - a lot of hedge funds won't even pay for it, relying instead on sell siders to pass it along in their reports. These numbers will move drug stocks dramatically. There is no way that a subscriber using this information is committing insider trading, however (unless he was leaked the information ahead of time by a disgruntled employee, etc.). And IMS certainly has no obligation, affirmative or otherwise, to share the fruits of their labor for free with the world.
It sounds like you want something to be considered insider trading which isn't, by either statute or regulation. That's fine, but it's a departure from what the law has been to this point and would have some serious consequences.
"dissemenated in a non-exclusionary manner"
How much is the "fee" to access exchange data??
if I am a poor bloke (no "if" needed) wouldn't the fee be considered exclusionary?? and I am guessing it is not cheap...
UA - Rob responded beautifully before I could. We covered this in the previous thread.
Anon about data costs:
HRJ has a good comment here:
http://www.businessinsider.com/high-frequency-traders-may-be-next-on-the-chopping-block-2010-11#comment-4cec1156cadcbb81380e0000
I don't know exactly how much the highest level exchange fees are - someone here will certainly give you the answer - but I think it's in the realm of 10's of thousands of dollars (or much less - maybe $5k?) monthly, not millions of dollars.
PeterPeter - what's the answer?
U.S. insider trading jurisprudence in this context is "all about the duty." Bracketing the issue of materiality (which i find is a losing battleground from a defendant's standpoint), the analysis bottoms out on whether you know, or have reason to know, that the information you have received and are trading on was provided to you in breach of a duty owed to the source. So in the channel checking context, is the info being provided to the research firm by managers, suppliers, etc. who are prohibited from providing that info? If so, there's a problem.
> PeterPeter - what's the answer?
There are too many invariants to give a simple answer. But, suppose you were classified as a "professional trader" (costs would be reduced otherwise) and suppose you only want raw data feeds for quotes rather than trades and had 1 computer processing the data and wanted to get all of the big equity exchanges:
BATS - Free
Direct Edge - Free
Nasdaq - $1576/mo
Nasdaq OMX BX - $520/mo
Nasdaq PSX - Free
ARCA - $30/mo
NYSE - $60/mo
But you also need the consolidated feeds (the ones that Joe and Sal say should be the exclusive data feeds.... except of course for the other proprietary feeds that they do pay for and don't mention....).
CQS: $950/mo
UQDF: $80/mo
You of course need connectivity and a place to put the machine, but anyone who is getting the full consolidated feeds (i.e. CQS and UQDF) likely has already paid those costs.
An account with $25K or more will likely find you a broker dealer who will locate your server in their data center, and you'll pay them a modest monthly fee as well.
Getting trade data will run you additional money, but nothing terribly out of line with the numbers above.
The folks who say this requires millions of dollars or super-computers are talking out of thier asses.
-PeterPeter
Rob,
In your IMS Health example I agree that the firm is of course under no obligation to provide their service to the public.
That aside, does their research involve receiving specific information from company insiders that a reasonable investor would judge to have a material effect on market price (i.e. company shipments of prescription drugs, etc)? If so then IMS itself would be bound by their duty to source under misappropriate theory from trading on this name. Moreover, if this specific information was included in their report (“a company representative said XXX”), such that a reasonable investor should be aware that a) it is material information, and b) that it came in some form from an insider (result of a violation of duty), then a subscriber to this report (assuming its distribution is limited and does not result in it becoming public – despite Kid’s argument against) would also be bound by a duty to source regardless of the indirect connection. In this I agree with Don Gately’s commentary above.
Sell-side analysts get around this issue by way of the mosaic theory of research compilation where pieces of both material public and non-public information are combined together in such a way that the reader should not reasonably expect the information to have come from an insider rather than analyst skill and insight.
Bringing the conversation full circle back to “expert networks” the parallels with the above example are clear. To draw it closer still: if IMS doesn’t distribute a report, but rather has a conference call with a small group of hedge funds, all of whom subscribe to the service for a fee (which anyone can subscribe to), and on this conference call, as above, IMS discloses MNPI that can be reasonably assumed to come from an insider, the hedgies may have a problem trading (and be investigated by the FBI evidently).
The key here is misappropriate theory of insider trading, which as of the US vs. O’Hagan Supreme Court ruling allows a violation of duty to occur indirectly where it is reasonable to assume that one originally occurred in attaining the information (I’ve conferred with a legal mind now clearly!).
Kid,
I agree that my example 2 above was sloppy in construction of the MNPI, but my point was to focus on your definition of public distribution (i.e. super-subscriber vs. subscriber).
I hear your argument against my example 1, and that any subscriber list is public distribution, but as in my response to Rob above, how do you see this differing from “expert network” conference calls? These networks provide a service to a paying ‘subscriber’, to which anyone with the funds can subscribe, but according to the implications of recent raids and arrests this limited distribution doesn’t seem to discharge them of dealing in MNPI. The implication therefore is that “expert network” services are not a public distribution (when dealing in MNPI). How do you interpret this relative to my example 1?
Note that I don’t want to tread on your accurate points above that most “expert networks” don’t trade in MNPI but instead provide industry insight that is not material to a specific company. I’m trying to hone in on the public distribution aspect of MNPI in relation to the implications of these investigations.
After the Cow handywork I was expecting a turkey prepping pictorial today KD!
Have a great holiday.
(sorry if repost, not sure if it didn't publish or was spammed)
Rob,
In your IMS Health example I agree that the firm is of course under no obligation to provide their service to the public.
That aside, does their research involve receiving specific information from company insiders that a reasonable investor would judge to have a material effect on market price (i.e. company shipments of prescription drugs, etc)? If so then IMS itself would be bound by their duty to source under misappropriate theory from trading on this name. Moreover, if this specific information was included in their report (“a company representative said XXX”), such that a reasonable investor should be aware that a) it is material information, and b) that it came in some form from an insider (result of a violation of duty), then a subscriber to this report (assuming its distribution is limited and does not result in it becoming public – despite Kid’s argument against) would also be bound by a duty to source regardless of the indirect connection. In this I agree with Don Gately’s commentary above.
Sell-side analysts get around this issue by way of the mosaic theory of research compilation where pieces of both material public and non-public information are combined together in such a way that the reader should not reasonably expect the information to have come from an insider rather than analyst skill and insight.
Bringing the conversation full circle back to “expert networks” the parallels with the above example are clear. To draw it closer still: if IMS doesn’t distribute a report, but rather has a conference call with a small group of hedge funds, all of whom subscribe to the service for a fee (which anyone can subscribe to), and on this conference call, as above, IMS discloses MNPI that can be reasonably assumed to come from an insider, the hedgies may have a problem trading (and be investigated by the FBI evidently).
The key here is misappropriate theory of insider trading, which as of the US vs. O’Hagan Supreme Court ruling allows a violation of duty to occur indirectly where it is reasonable to assume that one originally occurred in attaining the information (I’ve conferred with a legal mind now clearly!).
UA: re IMS: the point is that their research does NOT involve specific information from insiders, despite the fact that average investors would find the IMS information material.
re: expert networks, you wrote: "These networks provide a service to a paying ‘subscriber’, to which anyone with the funds can subscribe, but according to the implications of recent raids and arrests this limited distribution doesn’t seem to discharge them of dealing in MNPI."
of course not - having subscribers doesn't absolve you. that's not my argument.
the entire market data argument from Themis is ludicrous - the market data IS the data - it's available to anyone who wants it. It's not MNPI, it's not hiding MNPI, it's got nothing to do with company insiders (see Rob's point, again). it's MPI - material, public information.
I also agree with Don Gately's comment - and it illustrates why the market data MNPI accusation is ludicrous and misplaced.
The legal issues don't appear to be this nuanced around the Chu arrest the other day. Humans have a genius for communicating illicit information. For a humorous and relatively obvious form, think the in-court bribery negotiation scene from Scarface. KD, nice job as always presenting the lonely baby-with-the-bathwater sane counterpoint.
TZ
@UA - In your latest comment you seem to agree that a violation of duty is required in addition to the information being material and non-public. I didn't think that was your position in your earlier comments, but it's possible I misread them. If you see that a a duty violation is the necessary third leg of the stool, then I think we're on the same page. Incidentally, one can actually see in the charging documents the other day where the government made sure to specify where they thought a violation of duty was occurring, not just that the information was material and non-public.
This is a bit beyond the scope of this post, but people might find some info on IMS interesting. Far from getting their information from the drug companies, the relationship is the opposite: drug companies get their info from IMS. Whenever you hear a drug company say they have x% share of new prescriptions (in say a presentation, press release, or conference call), that's always IMS data. Drug companies would have no way to know that themselves, so they buy the data just like investors do (I assume in fact that the drug/biotech industry is actually a far greater portion of IMS revenue than financial firms, but I don't know that for a fact).
Drug firms actually sell product (and record revenue) to drug wholesalers, who stock up based on what they think end unit demand will be (plus when they think drug companies will increase prices). Prescriptions written by doctors are obviously the driver of eventual demand, and over time revenue should follow prescriptions. On a quarterly basis though - especially when it comes to smaller/newer drugs/companies - these two trends can differ dramatically. Understanding this dynamic and recognizing when the market overreacts to a quarterly revenue number one way or the other can be very profitable when you invest in health care stocks. And doing this type of analysis requires access to IMS data
Rob,
Sorry for the confusion earlier, I was trying to target Kid's distribution argument and how he perceived public versus private information, muddied the water with a questionable MNPI example.
Thanks for the info on IMS.
I have something to contribute, but it's too long to post as a comment. How do I get it to you? Can I attach it to a comment? Sorry, I'm new to the blog and comment game, but not to the law of insider trading.
Carolyn - I don't know what format you have it in. if it's a website, you can link it. If it's a long comment, you can break it into a few comments. otherwise, you can leave me your email address and I will email you, and you can email it to me.
Sure, it's rubiana33@yahoo.com. I'll send it off tomorrow, after I hear from you. I just found your "world" and enjoy it.
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