Julien Beaulieu, doctoral researcher in environmental policy research at Imperial College London’s Centre for Environmental Policy, returns to the Counterfactual podcast to discuss pending amendments to the Competition Act regarding environmental claims.
In June 2024, the Competition Act was amended to require businesses to have testing or substantiation to support certain environmental claims, and in June 2025, the Competition Tribunal became empowered to grant leave to private parties to bring deceptive marketing cases, including in relation to environmental claims, if the Tribunal is satisfied that it would be in the “public interest.” In November 2025 the Government proposed further amendments to the environmental claims provisions of the Competition Act that would walk back some of the earlier amendments not long after they took effect. Julien Beaulieu, who was our guest in previous episodes about environmental claims that aired in April 2023 and September 2024, returns to share his insights on this important development.
00:30
Ian Macdonald
Hello and welcome to Counterfactual, the podcast produced by the Competition Law and Foreign Investment Review section of the Canadian Bar Association. My name is Ian Macdonald and in this episode, I'll be speaking with Julien Beaulieu about recent and pending developments regarding greenwashing and environmental claims.
00:52
Ian Macdonald
Julien is currently a doctoral researcher in environmental policy research at Imperial College London's Centre for Environmental Policy. He also currently works as a law lecturer at the University of Sherbrooke and collaborates with the Quebec Environmental Law Centre on research projects relating to environmental claims.
01:12
Ian Macdonald
Julien and I have already discussed environmental claims in two previous episodes, which aired in April 2023 and September 2024.
01:23
Ian Macdonald
In those episodes, we defined greenwashing and green hushing, discussed certain specific categories of claims like net zero pledges and the use of voluntary carbon offsets, and discussed significant amendments to the Competition Act relating to environmental claims.
01:39
Ian Macdonald
Today is January 13, 2026, and since our last episode, a lot has happened in this space, including a pending round of amendments to the Competition Act that will walk back some of the earlier amendments not long after they took effect.
02:00
Ian Macdonald
Julien, hello and welcome again to Counterfactual. We're so glad to discuss this important topic with you once more.
02:08
Julien Beaulieu
Hello Ian, very happy to be here as well. Always a pleasure to speak with you. We're breaking a record here with this third episode on greenwashing. So, it's always great. Let's see, maybe we'll have to make a fourth one if the developments keep happening at this pace.
02:23
Julien Beaulieu
Just wanted to make mention, and mentioned it last time, but some of my research on this topic is funded actually by the competition, the Canadian Bar Association's Law for the Future Fund. So, it's really always great to participate in media events or events media activities that are hosted by the CBA. And I would also like to promote, a little bit of self-promotion here. I have a law review article that is going to be published in the next edition of the comment Canadian Competition Law Review to go together with Iris Fairley-Beam and Camille Lemarier. And it is on today's topic. So, it addresses the pre-existing greenwashing rules that existed before C-59, the rules that were proposed as part of C-59,
03:08
Julien Beaulieu
recently proposed amendments in the C-15. So hopefully our listeners will take a look at that as well.
03:17
Ian Macdonald
Well, that's great to know. And you're obviously a big contributor to our section. So, two foundational questions at the outset, primarily for the benefit of listeners who may not have listened to our previous two episodes or who could otherwise benefit from an overview or refresher.
03:34
Ian Macdonald
First, please briefly explain what greenwashing is, what green hushing is and why, from a policy perspective, it is important to strike the right balance between discouraging greenwashing on the one hand without contributing to green hushing on the other.
03:49
Julien Beaulieu
Yeah, these are foundational questions, and I really like the definition that one Canadian scholar with whom I've had the chance to contribute, Ren Montgomery at Ivy Business School, has of the concept of greenwashing. She defines greenwashing as something that takes place whenever an organization makes deceptive claims that convey an overly positive impression of the environmental performance of products, activities, or the business as a whole.
04:18
Julien Beaulieu
Now, there are various forms or tactics that are used to greenwash. Selective disclosure is a popular one; selectively disclosing positive information, making vague or generic statements; also using ambiguous images and logos. So, these are just some of the common practices that have been reported in the literature.
04:39
Julien Beaulieu
But it's very important to know that greenwashing may not always lead to legal action. So, it is a legal phenomenon, but not only a legal phenomenon. First of all, greenwashing may not be detected, so it will remain uncovered. It will just be taking place without anybody noticing. But there's also several cases of greenwashing that don't really result in legal consequences and legal action. So, stakeholders might try to seek accountability through advocacy campaigns, they might be reporting potential cases to the media. So, you will see some accusations of greenwashing in the news. Some of them will translate in legal complaints, but not always. So, consequences can be legal, but reputational consequences are also a very important thing that our listeners should keep in mind.
05:26
Julien Beaulieu
Now, you said greenwashing is an important policy question. Why would we require enforcement against greenwashing? Why do we actually need rules against greenwashing? Does this really matter? Right? Well, you know it's at the core of competition policy. You need adequate and proper information in order to make decisions.
05:45
Julien Beaulieu
And without information that is true, that is substantiated, that is complete, markets cannot really do their job of allocating resources, rewarding innovation, allowing companies that want to improve the quality of their products to be rewarded. And that's true for all products, but that's also true for environmental information. So, you really need accurate information to ensure that there will be free competition in the marketplace.
06:13
Julien Beaulieu
And at the same time, you've um you've mentioned green hushing. So it's important to protect these competitive dynamics. But at the same time, if companies perceive that the legal risks of making a green claim are too significant or too important, then maybe they'll just prefer to avoid sharing information to avoid legal scrutiny. And that's not better, right? Because again, without information, markets cannot work.
06:38
Julien Beaulieu
So green hushing takes place when firms prefer to remain silent and avoid the legal risk of being accused of greenwashing. Now, if firms remain silent instead of lying or instead of making unsubstantiated claims, that's not really a problem, in my opinion. That's not really green hushing. But what you really don't want is honest firms which decide not to speak out.
07:02
Julien
So really striking this balance is super important. You're really right. Managing the protection of the consumers, protection of the marketplace, but at the same time, ensuring that honest firms can speak out.
07:13
Ian Macdonald
Thanks. And with that balance in mind, what are the key amendments relating to environmental claims in Bills C-59 and C-15? And how would the amendments contemplated by C-15 reverse or walk back some of the amendments in C-59?
07:29
Julien Beaulieu
Yeah, so let's maybe, to answer your question, I think we need to think a little bit more about to go back a little bit at what was introduced in C-59 and why was it necessary. And obviously our listeners can go back to our previous episodes where we speak about these things in a little bit of more details, but I'll give a brief overview just to remind everyone of what we're talking about. Bill C-59 introduced two changes to Canada's deceptive marketing framework.
07:56
Julien Beaulieu
The first big change was to introduce a new requirement to substantiate environmental benefit claims about products, businesses, and business activities.
08:06
Julien Beaulieu
So essentially, in a nutshell, now under these new rules under Bill C-59, whenever you make a green claim, you need evidence. You cannot just make claims that are made out of thin air you really need to have evidence to back up what you say. Now the test in terms of evidence evidentiary requirement is a little bit different depending on whether you're making a claim about products or a claim about your business and the activities of your business. For claims about products, you need to rely on an adequate and proper test, which is wording that already existed in the Competition Act with respect to performance claims about products. But this one is very specific about environmental benefit claims for products.
08:48
Julien Beaulieu
And then for claims about businesses and their activities, this means holding adequate and proper substantiation in accordance with internationally recognized methodology. I've said that this very criticized expression, and internationally recognized methodology. That's the type of evidence you need if you make, for example, a net zero pledge about your company or your report on the greenhouse gases emissions of your company.
09:16
Julien Beaulieu
And I'll explain why this expression is controversial in a second. But these changes entered into force in the summer of 2024, a bit more than a year now.
09:26
Julien Beaulieu
And it really just meant that whenever you made claims, you needed to have evidence. It was already illegal to make false or misleading claims under the Act before.
09:37
Julien Beaulieu
And as I said, the law was also requiring substantiation for performance claims about products. But these changes made it just very, very obvious that almost any environmental benefit claim made to the public for commercial purposes had to be substantiated, shifting the onus to the firms making claims.
09:56
Julien Beaulieu
So that's the first big change introduced as part of Bill C-59. And then the second big change was to allow private plaintiffs. So you can think of consumers, civil society groups, but also competitors. And that's important to remind our audience here. Competitors can also bring cases, and I think lawyers advising clients should keep that in mind. These rules are not only there to sue companies, but also allow companies to sue and defend their interests. Actually, we've seen a few cases in Europe where, and one in the US as well, where some companies are there in the construction materials sector, the energy sector and
10:36
Julien Beaulieu
Avocado production in California, I think, three cases where competitors have used deceptive marketing laws to sue competitors. So, yeah, second big change: allowing private plaintiffs to bring deceptive marketing lawsuits, consumers, civil society groups, competitors directly before the competition tribunal without having to go to go through the Competition Bureau,
10:57
Julien Beaulieu
conditional, however, on meeting a public interest test. And this second change, which is a bit more recent, only entered into force a few months ago in June of 2025.
11:10
Julien Beaulieu
Now, these changes, they sparked intense reactions. Some of the members of our audience will have heard about these reactions. Several stakeholders claim that these cases these new provisions were bringing so much legal uncertainty, and that they would reduce firms' incentives to make green claims.
11:28
Julien Beaulieu
The Competition Bureau issued guidelines, but it did not seem to reduce the concerns of the industry. And therefore, in November of last year, so a few months ago, the government decided to introduce a regulatory response and as part of the Budget Implementation Act, so Bill C-15, the government decided to re-amend the deceptive marketing rules of the Competition Act.
11:56
Julien Beaulieu
So now I will provide a little bit of details about these new changes which have not been adopted as we record this episode. We'll see what happens. I think now we're still at the committee stage, so there will be some committee meetings where these provisions will be discussed and eventually it will make its way to Royal Assent, if there's an agreement, obviously, between the different parties.
12:22
Julien Beaulieu
So, what are these re-amendments? Essentially two proposals. The first proposal is to amend the requirement to substantiate environmental claims about business and business activities. The famous requirement to substantiate in accordance with internationally recognized methodology, also known as an IRM.
12:44
Julien Beaulieu
This was a very controversial expression. a lot of people said that this concept of IRM was vague, it created legal uncertainty, it could limit the ability of firms to rely on domestic standards given this internationally recognized requirement. And some people said that this was really disincentivizing firms from disclosing information about their environmental performance. So the new wording that is being proposed is to substantiate with actually to have adequate and proper substantiation. So we are like now we have words that would be very similar to what we have for products, performance claims and environmental benefit claims about products.
13:27
Julien Beaulieu
We're not talking about testing, but we're coming with this adequate and proper concept again. That's the first proposal, so slightly changing the substantiation requirements for claims about businesses and business activities. And then the second proposal is to prevent private plaintiffs from filing lawsuits for a failure to substantiate environmental claims about businesses and business activities.
13:51
Julien
So not only are we proposing to change the evident evidentiary requirement, but also limiting private access to remedies. So it really seems here that we're trying to limit the legal risks for firms making these types of claims, while at the same time preserving the ability of the Bureau to take enforcement action against unsubstantiated firm level claims.
14:16
Julien Beaulieu
So that's it. that's what is on the agenda for the Parliament.
14:20
Ian Macdonald
Great. And in your view, are the proposed changes from C-15 necessary, a net positive and net negative? And in answering that, please comment on both the substance and the timing as some of the C-59 amendments are being walked back only a few months after they came into
14:41
Julien
Yeah, that's a bit tricky. I would say regarding the replacement of the IRM standard, based on what I've seen so far, this seems to be quite consensual. Overall, I would say this is a good thing. It brings us closer to the wording that already existed um at paragraph B, so the requirement to substantiate performance claims for products. There we have case law on this requirement. So, it’s probably easier to draw parallels from that existing case law and therefore I think it is reducing slightly the legal uncertainty. I personally don't think that the IRM standard was so problematic as some have said. There already exists a large array of sustainability reporting methodologies and indicators that firms could use and we do not yet have ah comprehensive and long-term evidence on how disclosure behaviour was affected by C-59. So I think it was still too early to say that the new standard was really causing problems.
15:43
Julien Beaulieu
But it is true that the law did not state who was entitled to recognize the methodology when that recognition had to be obtained. So I really understand the confusion, and I think this is a net positive.
15:55
Julien Beaulieu
Now, the new proposed wording is still general. And I think it does not explicitly list which methods, which standards can be used to substantiate environmental claims about business businesses and business activities.
16:11
Julien Beaulieu
So the uncertainty is not entirely gone. And if the government really wanted to provide full certainty, they could accept, that they could adopt, sorry, regulations under Section 128 of the Act to officially recognize methodologies that are widely accepted to substantiate green claims, such as the GHG protocol or the standards, the disclosure standards by the CSSB for instance. So I think that would be great, there would be great opportunity there to provide even more legal certainty and the government already has the legislative powers to do so.
16:44
Julien Beaulieu
The Competition Bureau could also provide more detail and specific guidance as other jurisdictions have done. I'm thinking of France particularly which has this very, very detailed guide where which lists all the standards that might be used to substantiate green claims. So could we have something similar in Canada that would be quite helpful. And I think we can already expect the current guidance to be updated if the amendments are adopted. So that would be another opportunity to provide more legal certainty.
17:12
Julien Beaulieu
So that's for the first change, the change of the evidentiary standard for firm level claims. Regarding the second change, however, so the repeal of the private right of access for lawsuits for the firm level failure to substantiate firm level claims. This came as a surprise. There's been no private enforcement case since the entry into force of the private right of action. So frivolous litigation does not really seem to be a live issue at the moment. And in addition to that, there are robust safeguards built in the law already.
17:52
Julien Beaulieu
You can think about the requirement to obtain leave from the tribunal by demonstrating that a claim was in the public interest. That's a high bar to meet. There's also the due diligence defense in the Act.
18:04
Julien
And finally, um there was already limited incentive for private plaintiffs to file cases actually under paragraph B.2, this requirement to substantiate firm level claims. Plaintiffs cannot claim class action type damages under this provision. So for me, this was not such a massive problem. On top of that, the risk to be required to pay the defendant's defense costs can be significant for plaintiffs. So that's an additional disincentive to bring cases. And that probably explains
18:33
Julien
why we haven't seen any cases so far, right? So we have not seen this flood of litigation that some were projecting. But that said, despite that, if these amendments do go ahead, we need to keep in mind that private remedies will remain available for violations of paragraphs 74.01(1)(a) and (b) and (b.1). So the prohibition on false or misleading statements, the requirement to substantiate performance claims about products and the requirement to substantiate environmental benefit claims about products.
19:10
Julien Beaulieu
So, there will still be some room for private action under these other provisions.
19:15
Ian Macdonald
Thanks for that that detailed summary. To what extent do you think that political considerations and that political considerations relating to the relationship between the federal government and the government of Alberta in particular may have contributed to the C-15 amendments, noting that some strong criticism of the C-59 amendments came from Alberta-based stakeholders and that the C-15 amendments are referenced in the Memorandum of Understanding between Alberta and the federal government about the future of the two governments' climate and energy policy future.
19:51
Julien Beaulieu
I think this certainly played a role. And this is something that I did not expect. So maybe I don't have good visibility on policy developments in this space, actually. But I was very surprised. I was surprised to see this reference in the MOU. So know we heard about the amendments and then the MOU happened. And I thought this is quite a peripheral issue, right? It's a peripheral issue for Alberta's energy sector, which you know has bigger issues to solve, issues that will be actually quite costly if you think about carbon pricing, investments in emissions reduction, dramatic changes, investments in emissions reductions.
20:32
Julien Beaulieu
These are actually much more significant from a cost perspective, in my mind, than these Competition Act amendments. But it seems like this was actually something that was very important to the industry that was taken very seriously by the Alberta government. So I think it's probably the result of some advocacy by the industry.
20:50
Julien Beaulieu
You might think that potentially the federal government also saw this as a concession that they could give in exchange for other concessions from the other side. So maybe this was seen as a strategy from the federal government. This clearly aligns with a broader push in Alberta to adopt measures that would limit legal risk associated with climate-related claims. So we've seen the Alberta government recently adopt legislation that would allow them to adopt regulation to limit the legal risk associated with climate-related disclosures for reporting issuers. So essentially, they're created creating a new regulatory power under the Securities Act, which was enacted around the same time, which could allow them to limit the risks, the legal risks associated with climate disclosures for reporting issuers. So that's interesting. It seems like there's a lot of concerns in Alberta around legal risks for energy firms that are speaking about climate change, that are speaking about climate risks and climate benefits.
21:52
Julien Beaulieu
One thing that I do find a little bit concerning is the fact that now it's in the MOU and it's in this agreement between the two governments. And I'm just wondering how much that will prevent parliamentarians from doing their job and really looking at potential changes in the wording of the provisions, looking at expanding them, reworking them a little bit to maybe make them even better, even clearer. Knowing that now there is this underlying MOU that the government will be really cautious about.
22:25
Julien Beaulieu
So how will that influence the freedom of the parliamentary debates? That's something that I find a bit concerning.
22:32
Ian Macdonald
That's interesting context. Let's talk a little bit more about private enforcement. As you mentioned, some stakeholders expressed concerns about a potential wave of lawsuits, but there have not yet been any applications to the Tribunal for private remedies under the Act's deceptive marketing provisions related to environmental claims or otherwise.
22:53
Ian Macdonald
However, there have been a few new complaints relating to environmental claims filed with the Bureau since we last spoke. Can you tell us a bit about these complaints and areas of legal risk for the future?
23:04
Ian Macdonald
Where do you see private and public enforcement taking place in the coming years?
23:09
Julien Beaulieu
So, you're right, we we've had three at least three complaints. It's always difficult to know the number of complaints because if the plaintiffs don't, the complainants don't make them public, then we cannot know that they're happening. But at least three.
23:24
Julien Beaulieu
So one of them was filed in January of last year, so one year ago. It was a complaint to the Bureau against Énergir, which is the natural gas distributor in Quebec.
23:35
Julien Beaulieu
And it was a claim about the supply of renewable natural gas to consumers. This was a copycat complaint. A similar complaint had been filed with the provincial consumer protection agency, and essentially, they're saying that
23:49
Julien Beaulieu
the company did not clearly communicate about how consumers could purchase some renewable natural gas to supply their houses. Still underway. Second complaint was filed in July 2025. It's a complaint against EverWind. So EverWind is a developer for a renewable green hydrogen project in Nova Scotia.
24:21
Julien Beaulieu
So this complaint was filed by a group of citizens which were concerned that actually the product project did not have the environmental benefits that were claimed by the promoter. And the third case, again, another one relating to natural gas. It's a complaint against Enbridge. I don't have the precise date, but it was filed sometime this fall. And it's about the claims that the company made regarding the supply of renewable natural gas. So very similar to the Énergir complaint that was filed a year pay prior to that one.
24:53
Julien Beaulieu
I think these complaints highlight a broader global trend where technologies products and services with contested climate benefits are being promoted as being positive for the climate, whether it's natural gas, whether it's green hydrogen. And I think CCUS is another example. Now we're already seen, obviously, a challenge of CCUS in the context of the Pathways Project. We've seen a lot of NGOs, but also academic researchers,
25:22
Julien Beaulieu
challenging the benefits of CCUS, challenging the benefits of LNG as well as climate solutions in terms of technical feasibility, scalability. So they are, these are very live questions. And I think proponents of such solutions, services, products should really make sure that they hold extremely robust scientific evidence before making claims about these technologies' environmental benefits, because I expect that they will be under close scrutiny.
25:49
Ian Macdonald
Great, thanks for that. With respect to other regulatory developments relating to environmental claims, in the last budget, the federal government also announced that it was moving ahead with the adoption of a sustainable finance taxonomy.
26:06
Ian Macdonald
At the same time, proposed regulation by the CSA for mandatory climate-related risks disclosure remains suspended. Outside of the Competition Act, what do you see on the regulatory horizon that could impact greenwashing enforcement?
26:22
Julien Beaulieu
So, I think you're very right. Like securities law is an area that we should be closely watching. I think there's been some enforcement action that people were maybe not expecting. So, I think all the eyes were on the Competition Act and C-59 and the whole summer, people were speaking about the risk associated with these changes. But then action came from somewhere else. In September, the Ontario Securities Commission took action against a fund manager, which had made allegedly deceptive claims about ESG factors, the integration of ESG factors in funds.
26:58
Julien Beaulieu
So that's interesting, right? So securities regulators taking action. And we've also seen another complaint by an NGO against Cenovus and Enbridge, regarding potentially misleading disclosures regarding net-zero in August. So it's an NGO that has been doing a few of these complaints in the past, Investors for Paris Compliance. We haven't seen any response from the Alberta securities regulator yet, but it shows that the Competition Act is not the only source of legal risk.
27:29
Julien Beaulieu
And there's still, even though the Canadian securities administrators, the CSA, has suspended its project to regulate climate related disclosures, there is still this general requirement for reporting issuers, so all these publicly traded companies, to disclose material information to investors.
27:49
Julien Beaulieu
So, all the material climate related risks and opportunities still have to be disclosed to investors if they are deemed material, and I think the fact that the sustainable finance taxonomy is moving ahead is also a net positive. I think you know maybe, I can just clarify what is a sustainable finance taxonomy because maybe our listeners are not familiar with that. It's essentially a dictionary.
28:14
Julien Beaulieu
So a taxonomy provides a clear and standardized rulebook for classifying activities based on their sustainability credentials. So, a let's say you have a different criteria and then you want to decide whether an activity is green or not, then the taxonomy would set out these criteria in very specific, detailed technical terms to ensure that any activity that is labeled under this taxonomy is actually green.
28:43
Julien Beaulieu
So, this could have very potential impacts it could be used to make environmental claims it could reduce the legal risk associated with making environmental claims under the Competition Act because then you would have this official rule book issued by the government that defines what is green what is transition. At the same time there are some risks with the taxonomy from my perspective. The first is the possibility that the criteria are not stringent enough.
29:10
Julien Beaulieu
So if the criteria are not sufficiently robust, then this could lead to something that we called green lighting, which is the official endorsement of controversial activities by governments.
29:24
Julien Beaulieu
So essentially, it's providing some kind of official label or certification to companies, projects, activities, financial products, which are not actually green, and that can be a risk. And we've seen that actually happening in other jurisdictions. So China had included some coal projects in its taxonomy. Europe had included some gas and nuclear projects as well. And there had been some legal challenges in these areas.
29:51
Julien Beaulieu
The second risk associated with the taxonomy is the fact that right now it's really just considered as a voluntary tool. So we're really in the early days at this point, but if it remains just a voluntary rule book that does not really force companies to change their reporting practices and use these rules to issue bonds, to issue loans, to make claims, then maybe it's not going to be that impactful.
30:19
Julien Beaulieu
So, I think that would be a missed opportunity if we develop this very nice, comprehensive taxonomy, but we don't do anything with it.
30:27
Ian Macdonald
Thanks. As we conclude, let's briefly address international developments. Can you give us a brief overview of what you are seeing in other jurisdictions?
30:35
Julien Beaulieu
Yeah, internationally, I think we're seeing mixed signals. We've obviously had some cases internationally that were quite interesting. I'm thinking, for instance, of France, where there was a case brought by NGOs against Total regarding net zero claims. And the court concluded that, yes, some claims that had been targeting consumers were in fact misleading because they were not aligned with the best scientific evidence.
31:06
Julien Beaulieu
And interestingly, in that case, the court clearly stated that environmental issues are material for consumers. We're not in a world where these are secondary, peripheral concerns for consumers. People care about these things. So, these are material aspects of ah consumers' decision making. So, we're seeing some cases, there's been also a case in Germany where the authorities have required Apple to stop marketing the Apple Watch as being carbon neutral because it was relying on dubious offsets, which had no long-term
31:41
Julien Beaulieu
there was like no long-term guarantee that the offsets would be permanent. So, we're seeing some enforcement. There was also a case in Malaysia where actually the case was brought against the government. So, the government in Malaysia is being sued for having failed to adopt sufficient anti-greenwashing measures. So that's quite interesting. Not really the type of case that...
32:02
Julien Beaulieu
We're used to. We're also seeing some jurisdictions that keep tightening the rules, Switzerland, Germany, for instance, but we're also seeing a slowdown in regulatory ambition in other jurisdictions. For example, the EU Green Claims Directive is being suspended. We've also seen the omnibus package in the EU, which has soften some of the reporting requirements regarding sustainability in Europe. So it's hard to tell. It's really mixed signals at this point, but we're certainly seeing more cases. So cases will not stop and NGOs keep bringing cases before the courts.
32:40
Ian Macdonald
Julien, this has been very interesting. There are so many more issues we'd love to discuss and more deeply, but we've taken up enough of your time, I suspect. I'd like to thank you for sharing your knowledge and insights with the Counterfactual podcast.
32:54
Ian Macdonald
We'll look forward to following your ongoing research and publications. Thank you.
33:00
Julien Beaulieu
Thank you so much.