Studie: Mehrzahl der Terrorakte vom FBI organisiert
Eine Studie kommt zu dem Ergebnis, dass die FBI für über 90 Prozent der misslungenen Terrorakte in den USA mitverantwortlich ist. Die Untersuchung wurde vom Project SALAM in Auftrag gegeben, die sich für muslimische Angeklagte einsetzt.
Die Methode der Terrorbekämpfung ist in den USA schon länger bekannt.
FBI plant Terroranschläge, um sie dann zu vereiteln
Die Methode der US-Behörden ist seit längerem bekannt
The Lawfare of Preemptive Prosecution
A study by
National Coalition to Protect Civil Freedoms
Written by Stephen Downs, Esq. and Kathy Manley, Esq.
Lynne Jackson, database designer
Jeanne Finley, editor
© 2014 by Project SALAM and National Coalition to Protect Civil Freedoms. This work is licensed under the Creative Commons Attribution 4.0 International License. To view a copy of this license, visit http://creativecommons.org/licenses/by/4.0/. This license includes the section of the Project SALAM database contained herein as Appendix A, but the license does not include the entire Project SALAM database (aka Database of Cases), which is presently restricted as to use.
Downs, Esq., Stephen, and Kathy Manley, Esq. Inventing Terrorists: The Lawfare of Preemptive Prosecution. Albany, NY: Project SALAM and National Coalition to Protect Civil Freedoms (NCPCF), May 2014. http://www.projectsalam.org/Inventing-Terrorists-study.pdf
E-mail the authors at: study[at]projectsalam.org
About the Authors, Preparers, and Sponsors of This Study
Stephen Downs, Esq. graduated from Amherst College (1964) and Cornell Law School (1969) after serving in the U.S. Peace Corps in India (1964–66). He was chief attorney of the New York State Commission on Judicial Conduct from 1974–2003, part of the defense team in U.S. v. Yassin Aref (2006–2007), and a founder of Project SALAM (2008). He became executive director of the National Coalition to Protect Civil Freedoms in 2012.
Kathy Manley, Esq. is a criminal defense attorney and one of the attorneys for Yassin Aref. She is legal director of the National Coalition to Protect Civil Freedoms, a founder of Project SALAM, and vice president of the Capital Region Chapter of the New York Civil Liberties Union.
Lynne Jackson is a professional computer consultant who specializes in database design. She is a founder of Project SALAM and serves as its president.
Jeanne Finley is a professional editor and writer and media director of Project SALAM.
Project SALAM (Support And Legal Advocacy for Muslims), www.projectsalam.org, was founded and incorporated in 2008 after a conference at Albany (New York) Law School that focused on preemptive prosecution. The conference was convened by groups and other interested people who supported Yassin Aref, Dr. Rafil Dhafir, and Fahad Hashmi, and featured attorney Lynne Stewart as keynote speaker. Project SALAM’s mission is to advocate for prisoners who have been preemptively prosecuted, assist their families, create and maintain a database to study the phenomenon of preemptive prosecution, and publish on the issue.
National Coalition to Protect Civil Freedoms (NCPCF), www.civilfreedoms.org, was founded and incorporated in 2010 as a coalition of Muslim, civil rights, and peace groups to oppose profiling, preemptive prosecution, and prisoner abuse. Current member organizations include: American Muslim Alliance (AMA), Bill of Rights Defense Committee (BORDC), Center for Constitutional Rights (CCR), Creating Law Enforcement Accountability and Responsibility (CLEAR), Committee to Stop FBI Repression (CSFR), Defending Dissent Foundation (DDF), Desis Rising Up and Moving (DRUM), Friends of Human Rights (FHR), International Action Center (IAC), Islamic Circle of North America (ICNA), Muslim Civil Liberties Union (MCLU), Muslim Legal Fund of America (MLFA), National Lawyers Guild (NLG), National Liberty Fund (NLF), Peace Thru Justice Foundation (PTJF), Project SALAM (Support And Legal Advocacy for Muslims), United National Antiwar Coalition (UNAC), and Universal Justice Foundation (UJF).
To see specific details on any of the preemptive prosecution cases mentioned in this study and its appendices, readers can access the Project SALAM database at http://www.projectsalam.org/database.html and sign in as a guest account; search for each defendant by name.
Lawfare: the use of the law as a weapon of war.
–– “Law and Military Interventions: Preserving Humanitarian Values in 21st-Century Conflicts” by Brigadier General (S) Charles J. Dunlap, Jr., USAF. In Humanitarian Challenges for Military Intervention, Harvard University, John F. Kennedy School of Government, The Carr Center for Human Rights Policy, November 2001.
This study, sponsored by two national organizations, Project SALAM (Support And Legal Advocacy for Muslims) and the National Coalition to Protect Civil Freedoms (NCPCF), focuses on post-9/11 claims by the U.S. government that it keeps the country safe from terrorism by arresting hundreds of so-called “terrorists” who were about to strike the U.S. until the FBI foiled their plots. In fact, this study shows that there have been remarkably few actual terrorism threats to this country in the last decade.
The vast majority of arrests in the war on terror have consisted of
the FBI foiling its own entrapment plots; or
the government arresting people on material support for terrorism
charges that effectively criminalize innocent conduct, such as charitable giving and management, free speech, free association, peace-making, and social hospitality; or
inflation of minor or technical incidents into terrorism events, such as immigration application inaccuracies, old weapons charges, or inaccurate statements to governmental officials
The study shows that the war on terror has been largely a charade designed to make the American public believe that a terrorist army is loose in the U.S., when the truth is that most of the people convicted of terrorism- related crimes posed no danger to the U.S. and were entrapped by a preventive strategy known as preemptive prosecution. The theme of the study links preemptive prosecution to the metaphor of “lawfare,” the use of the law as a weapon of war, in this case the war on terror.
Statistically, the study asks how many of the individuals who appear on the Department of Justice (DOJ) 2001–2010 list of “terrorism and terrorism-related convictions” (Appendix A) represented real terrorism threats, and how many were cases of preemptive prosecutions. The study then categorizes the cases of the individuals on the DOJ list as one of three types of cases: preemptive prosecutions, cases that contained elements of preemptive prosecution, or cases that were not preemptive prosecutions/represented real terrorism threats.
The statistical analysis shows that 72.4% of convictions on the DOJ list represent cases of preemptive prosecution that were based on suspicion of the defendant’s perceived ideology and not on his/her criminal activity. Another 21.8% of convictions on the DOJ list represent people who began on their own to engage in minor, non-terrorist criminal activity but whose cases were manipulated and inflated by the government to appear as though they were “terrorists”; these cases are referred to in the study as “elements of preemptive prosecution” or “elements.” Overall, 94.2% of all the terrorism-related convictions on the DOJ list have been either preemptive prosecution cases or cases that involved elements of preemptive prosecution.
The study defines preemptive prosecution, gives background on the origin of the concept, discusses the tactical patterns that characterize its use by the government, and provides a methodology for determining the categorization of a case. The study then shows, for cases on the DOJ list, the percentages for each categorization of a case, as well as percentages for the tactical patterns used in each categorization. The study concludes that the government has used preemptive prosecution to exaggerate the threat of Muslim extremism to the security of the country, and presents some hypotheses as to why the government has done this, without taking a position on which possibilities may be correct. The study also makes recommendations to change the present unfair terrorism laws.
The following appendices are included: Appendix A is the DOJ list of terrorism/terrorism-related convictions with each individual’s case designated as preemptive prosecution, elements of preemptive prosecution, or no preemptive prosecution used/real security threat. Appendix B contains descriptions of all preemptively prosecuted individuals and cases referenced in this study. Appendix C is a bibliography of sources.
DEFINITION OF PREEMPTIVE PROSECUTION
Preemptive prosecution (also called preventive, predatory, proactive, pretextual, or manufactured prosecution) is a law enforcement strategy, adopted after 9/11, to target and prosecute individuals or organizations whose beliefs, ideology, or religious affiliations raise security concerns for the government.1 The actual criminal charges are pretexts, manufactured by the government to incarcerate the targets for their beliefs. These pretexts include:
Using material support for terrorism laws to criminalize activities that are not otherwise considered criminal, such as free speech, free association, charity, peace-making and social hospitality.
Using conspiracy laws to treat friendships and organizations as criminal conspiracies, and their members as guilty by association, even when most members of the group have not been involved in criminal activity and may not even be aware of it.
Using agents provocateur to actively entrap targets in criminal plots manufactured and controlled by the government.
Using minor “technical” crimes, which otherwise would not have been prosecuted or even discovered, in order to incarcerate individuals for their ideology (for example, making a minor error on an immigration form, which is technically a crime; lying to government officials about minor matters; gun possession based on a prior felony many years earlier; minor tax and business finance matters).
Journalist Chris Hedges has written that “the concept of pre-emptive
prosecution mocks domestic law as egregiously as pre-emptive war mocks the foundations of international law.”2 Preemptive prosecution is similar to earlier methods of political repression in the U.S. whereby ideology, beliefs, and thoughts were targeted for prosecution: the Palmer Raids of the 1920s, the Japanese internments during World War II, the Communist witch hunts of the 1950s, and COINTELPRO during the 1960s and 1970s, which targeted progressives and particularly the Black Liberation movement for infiltration, disruption, frame-ups, and even assassination, i.e., Black Panthers Fred Hampton and Mark Clark.
The Senate Select Committee to Study Governmental Operations with Respect to Intelligence Activities (known as the “Church Committee” because it was chaired by Senator Frank Church) issued a report in 1976 on the COINTELPRO program that stated in part:
Many of the techniques used would be intolerable in a democratic society even if all of the targets had been involved in violent activity, but COINTELPRO went far beyond that...the Bureau conducted a sophisticated vigilante operation aimed squarely at preventing the exercise of First Amendment rights of speech and association, on the theory that preventing the growth of dangerous groups and the propagation of dangerous ideas would protect the national security and deter violence...nonviolent organizations and individuals were targeted because the Bureau believed they represented a “potential” for violence.3
Targeting non-violent individuals because the government believes that they represent a potential for violence is precisely what preemptive prosecution is all about. In preemptive prosecution, the targets are prosecuted with fake, manufactured, or pretext charges to preempt them from developing their “potential for violence,” as the Church Committee report puts it.
In 2010, the Department of Justice (DOJ) published a list of individuals that it claimed represented all of the terrorism and terrorism- related convictions in the U.S. from September 11, 2001 to March 18, 2010 (http://web.archive.org/web/20100530015008/http://www.justice.gov/cjs/d ocs/terrorism-convictions-statistics.pdf). Via the Project SALAM database, this study uses the DOJ list as a basis to categorize and analyze cases of preemptive prosecution. The DOJ list is unfortunately incomplete. It is both over-inclusive and under-inclusive: it omits “terrorism” cases decided after March 18, 2010, it omits some “terrorism” cases that were decided prior to that date, and it includes some cases that do not appear to be terrorism cases at all (see below under “No Preemptive Prosecution”). This probably reflects a lack of clear standards for inclusion on the DOJ list.
Project SALAM has built and maintained a much more comprehensive database that contains significantly more cases than the DOJ list, including more preemptive prosecution cases and additional cases that reflect a real security threat. However, the statistical analysis of this study considers, in Appendix A, only those cases that appear on the DOJ list. (Project SALAM’s database includes more complete information on each case than does the DOJ list, and thus Appendix A includes this information, but only with regard to those cases that appear on the DOJ list.) This study will refer later on to other cases that are not on the DOJ list, but which are found in the Project SALAM database, as examples of issues the study has identified, but these additional cases not on the DOJ list are not included in the statistical analysis.
For purposes of terminology, this study refers interchangeably to the convicted individuals on the DOJ list as both “individuals” and “cases,” the latter term encompassing all the charges and tactics used to bring the prosecution against that individual, although a single case often had more than one defendant, especially those cases designated by their popular names, such as the Newburgh Four or the Virginia Paintball Network. The original DOJ list did not group such individuals by case, but the Project SALAM database has done this.
Appendix A lists all of the convicted individuals included on the DOJ list, and this study places each of those individuals’ cases in one of three categories: 1) preemptive prosecution, 2) “elements of preemptive prosecution” (a prosecution based on an initial decision by the defendants to engage in non-terrorism-related and often minor crime, but which the government then inflated into a terrorist charge), or 3) a terrorism-related charge that does not have the characteristics of preemptive prosecution. Using these categories, it is possible to quantify what percentage of the government’s terrorism and terrorism-related convictions represents preemptive prosecution cases, what percentage represents elements of preemptive prosecution cases, and what percentage represents cases that do not qualify as preemptive prosecution and thus were actual threats to national security.
Based on the above-mentioned classifications, the study made the following assumptions in designating cases.
Tactics Used in Prosecution Sorted by
Preemptive Prosecution Used, Elements of Preemptive Prosecution Present, or
No Preemptive Prosecution Used
Based on U.S. Department of Justice list, “National Security Division Statistics on Unsealed International Terrorism and Terrorism-Related Convictions 9/11/01–3/18/10” http://web.archive.org/web/20100530015008/http://www.j ustice.gov/cjs/docs/terrorism-convictions-statistics.pdf
Preemptive Prosecution Cases Mentioned in the Study
Aaronson, Trevor. The Terror Factory: Inside the FBI’s Manufactured War on Terrorism. Brooklyn: Ig Publishing, 2013.
Ahmad, Shamshad. Rounded Up: Artificial Terrorists and Muslim Entrapment After 9/11. Troy, NY: Troy Book Makers, 2009.
Aref, Yassin. Son of Mountains: My Life as a Kurd and a Terror Suspect. Troy, NY: Troy Book Makers, 2008.
Brittain, Victoria. Shadow Lives: The Forgotten Women of the War on Terror. London: Pluto Press, 2013.
Cole, David, and Jules Lobel. Less Safe, Less Free: Why America Is Losing the War on Terror. New York: New Press, 2007.
Greenwald, Glenn. No Place to Hide: Edward Snowden, the NSA, and the U.S. Surveillance State. New York: Metropolitan Books, 2014.
Haas, Michael. George W. Bush, War Criminal: The Bush Administration’s Liability for 269 War Crimes. Westport, CT: Praeger Publishers, 2009.
Kundnani, Arun. The Muslims Are Coming! Islamophobia, Extremism, and the Domestic War on Terror. London and New York: Verso Books, 2014.
Kurnaz, Murat. Five Years of My Life: An Innocent Man in Guantanamo. New York: Palgrave MacMillan, 2008.
Mayer, Jane. The Dark Side: The Inside Story of How the War on Terror Turned into a War on American Ideals. New York: Doubleday, 2008.
Risen, James. State of War: The Secret History of the CIA and the Bush Administration. New York: Free Press, 2006.
Salisbury, Stephen. Mohamed’s Ghosts: An American Story of Love and Fear in the Homeland. New York: Nation Books, 2010.
Scahill, Jeremy. Dirty Wars: The World as a Battlefield. New York: Nation Books, 2013.
Temple-Raston, Dina. The Jihad Next Door: The Lackawanna Six and Rough Justice in the Age of Terror. Philadelphia: Public Affairs Books, 2007.
Prisoner Support Websites
of defendants mentioned in the study
“Free Sami Al-Arian,” http://www.freesamialarian.com “Free Ali Al-Timimi,” http://freeali.wordpress.com/
[Aref-Hossain case] “Muslim Solidarity Committee,”
“Justice for Yassin Aref,” http://www.yassinaref.com/indexnew.php “Dhafir Trial, Information About Dr. Rafil Dhafir,”
[Syed Fahad Hashmi] “Free Fahad,” http://freefahad.wordpress.com/ and
“Free the Holy Land Five,” http://freedomtogive.com/
[Tarek Mehanna] “Free Tarek,” http://www.freetarek.com/
[Shifa Sadequee] “Free Shifa,” http://www.freeshifa.com/
“Justice for Lynne Stewart,” http://lynnestewart.org/
“Free Ziyad Yaghi: How Can the Oppressed Become the Oppressors?”,
“Free Ziyad Yaghi Info,” http://www.freeziyadyaghi.info/
Reports and Studies
Aaronson, Trevor. “The Informants.” Mother Jones (September-October 2011).
Accompanied by “Terror Trials by the Numbers.” http://www.motherjones.com/politics/2011/08/terror-trials-numbers Accompanied by “Profiles in Terror,” searchable database. http://www.motherjones.com/fbi-terrorist
American Civil Liberties Union. Blocking Faith, Freezing Charity. New York: ACLU, June 2009.
Aziz, Sahar. Countering Religion or Terrorism: Selective Enforcement of Material Support Laws Against Muslim Charities. Policy Brief #47. Washington, D.C.: Institute for Social Policy and Understanding, September 2011. http://www.ispu.org/Getpolicy/34/2276/Publications.aspx
Bergen, Peter et al. Do NSA’s Bulk Surveillance Programs Stop Terrorists? Washington, D.C.: New America Foundation, January 2014. http://www.newamerica.net/publications/policy/do_nsas_bulk_surve illance_programs_stop_terrorists
Bjelopera, Jerome P. American Jihadist Terrorism: Combating a Complex Threat. Washington, D.C.: Congressional Research Service, January 23, 2013.
–––––. The Federal Bureau of Investigation and Terrorism Investigations. Washington, D.C.: Congressional Research Service, April 24, 2013. http://www.fas.org/sgp/crs/terror/R41780.pdf
Bjelopera, Jerome P., and Mark A. Randol. American Jihadist Terrorism: Combating a Complex Threat. Washington, D.C.: Congressional Research Service, September 20, 2010. http://www.law.umaryland.edu/marshall/crsreports/crsdocuments/R4 1416_09202010.pdf
Center for Human Rights and Global Justice. Targeted and Entrapped: Manufacturing the “Homegrown Threat” in the United States. New York: New York University School of Law, 2011. http://chrgj.org/wp- content/uploads/2012/07/targetedandentrapped.pdf
Chishti, Muzaffar, et al. America's Challenge: Domestic Security, Civil Liberties, and National Unity After September 11. Washington, D.C.: Migration Policy Institute, [March] 2003. http://www.migrationpolicy.org/research/americas-challenge- domestic-security-civil-liberties-and-national-unity-after-september- 11
Cincotta, Thomas. Manufacturing the Muslim Menace. Somerville, MA: Political Research Associates, 2011. http://www.publiceye.org/liberty/training/Muslim_Menace_Complet e.pdf
Geneva Convention (III). Article 90, Relative to the Treatment of Prisoners of War, 1949.
Greenberg, Karen J., et al. Terrorist Trials: A Report Card. New York: Center on Law and Security, New York University School of Law, February 2005. http://www.lawandsecurity.org/Portals/0/documents/12_terroristtrial reportcard.pdf
–––––. Terrorist Trial Report Card: US Edition, September 11, 2001– September 11, 2006, September 2006. http://www.lawandsecurity.org/Portals/0/documents/09_TTRCComp lete.pdf
Accompanied by Appendix B: Chronologic Table of Cases. http://www.lawandsecurity.org/Portals/0/documents/11_TTRC_US_ 2006_Appendix_B.pdf
_____. Terrorist Trials, 2001–2007: Lessons Learned, October 2007. http://www.lawandsecurity.org/Portals/0/documents/08_TTRC2007 Update1.pdf
–––––. Terrorist Trial Report Card: Update January 1, 2008, January 2008.
–––––. Findings of the Terrorist Trial Report Card Update, September 11, 2006–January 1, 2008, January 2008. http://www.lawandsecurity.org/Portals/0/documents/07_TTRCFindi ngsJan08.pdf
–––––. Terrorist Trials, September 11, 2001–April 1, 2008, April 2008. http://www.lawandsecurity.org/Portals/0/documents/04_TTRCApril 08Final1.pdf
–––––. Terrorist Trial Report Card: Terror Financing Through Charities, April 2008
–––––. Terrorist Trial Report Card: September 11, 2008, September 2008. http://www.lawandsecurity.org/Portals/0/documents/03_Sept08TTR CFinal1.pdf
–––––. Terrorist Trial Report Card: September 11, 2001–September 11, 2009, January 2010.
–––––. Terrorist Trial Report Card: September 11, 2001–September 11, 2010, September 2010.
–––––. Terrorist Trial Report Card: September 11, 2001–September 11, 2011, September 2011.
Greenberg, Karen J., ed. “Prosecuting Terrorism: The Legal Challenge.” The NYU Review of Law and Security 7. New York: Center on Law and Security, New York University School of Law, April 2006. http://www.lawandsecurity.org/Portals/0/Documents/no7_Prosecutin g-Terrorism-the-Legal-Challenge.pdf
Kurzman, Charles. Muslim-American Terrorism Since 9/11: An Accounting. Durham, NC: Triangle Center on Terrorism and Homeland Security, February 2, 2011. http://sites.duke.edu/tcths/files/2013/06/Kurzman_Muslim- American_Terrorism_Since_911_An_Accounting_Feb2_2011.pdf
–––––. Muslim-American Terrorism in the Decade Since 9/11, February 8, 2012.
–––––. Muslim-American Terrorism: Declining Further, February 1, 2013. http://sites.duke.edu/tcths/files/2013/06/Kurzman_Muslim- American_Terrorism_February_1_2013.pdf
–––––. Muslim-American Terrorism in 2013, February 5, 2014. http://sites.duke.edu/tcths/files/2013/06/Kurzman_Muslim- American_Terrorism_in_20131.pdf
Méndez, Juan E. Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment. New York: United Nations Human Rights Council, March 4, 2014. http://www.refworld.org/docid/53185c254.html
Mueller, John, ed. Terrorism Since 9/11: The American Cases. Columbus: Mershon Center, Ohio State University, 2012. http://polisci.osu.edu/faculty/jmueller/since.html
Muslim Advocates. Losing Liberty: The State of Freedom 10 Years After the PATRIOT Act. San Francisco: Muslim Advocates, October 2011. http://d3n8a8pro7vhmx.cloudfront.net/muslimadvocates/pages/47/att achments/original/Losing_Liberty_The_State_of_Freedom_10_Year s_After_the_PATRIOT_Act.pdf?1330650785
National Counterterrorism Center. Office of the Director of National Intelligence. 2011 Report on Terrorism, [June] 2011. http://www.fas.org/irp/threat/nctc2011.pdf
Offices of the Inspectors General (Department of Defense, Department of Justice, Central Intelligence Agency, National Security Agency, Office of the Director of National Intelligence). (U) Unclassified Report on the President’s Surveillance Program. Report No. 2009- 0013-AS, July 10, 2009. http://s3.amazonaws.com/nytdocs/docs/108/108.pdf
Schanzer, David. The Way Forward on Combating al-Qa’ida-Inspired Violent Extremism in the United States: Suggestions for the Next Administration. Policy Brief. Durham, NC: Institute for Social Policy and Understanding, Duke Islamic Studies Center, ISLAMiCommentary, and Triangle Center on Terrorism and Homeland Security, October 18, 2012. http://www.ispu.org/Getpolicy/34/2567/Publications.aspx
Schanzer, David, Charles Kurzman, and Ebrahim Moosa. Anti-Terror Lessons of Muslim-Americans. Durham, NC: Triangle Center on Terrorism and Homeland Security, January 6, 2010. http://sites.duke.edu/tcths/files/2013/06/Schanzer_Kurzman_Moosa_ Anti-Terror_Lessons1.pdf
Stahl, Aviva. Guantanamo Begins at Home: Systematic discrimination faced by Muslim “War on Terror” suspects in the US. London: CagePrisoners, April 2012. https://privacysos.org/sites/all/files/GITMOathome.pdf
United States Congress. House. Committee on Foreign Affairs, Committee on the Judiciary. Subcommittee on Crime, Terrorism, Homeland Security, and Investigations. Humanitarian Assistance Facilitation Act of 2013 (HAFA). H.R. 3526. 113th Cong., 1st sess. http://beta.congress.gov/bill/113th-congress/house-bill/3526/text
United States Congress. Senate. Committee on Homeland Security and Governmental Affairs, Permanent Subcommittee on Investigations. Majority and Minority Staff Report. Federal Support for and Involvement in State and Local Fusion Centers. 112th Cong., 2nd sess. October 3, 2012. http://cdn.govexec.com/media/gbc/docs/pdfs_edit/100312cc1.pdf
United States Department of Justice. National Security Division Statistics on Unsealed International Terrorism and Terrorism-Related Convictions 9/11/01–3/18/10. n.d. . http://web.archive.org/web/20100530015008/http://www.justice.gov /cjs/docs/terrorism-convictions-statistics.pdf
_____. Office of the Inspector General. Audit Division. Follow-up Audit of the Department of Justice’s Internal Controls over Reporting of Terrorism-Related Statistics: The Executive Office for United States Attorneys. Audit Report 13-34, September 2013. https://www.documentcloud.org/documents/791778-a1334.html
mentioned in the study
National Jericho Movement, http://www.thejerichomovement.com No Separate Justice, http://no-separate-justice.org/
All links checked May 1, 2014.