Can Non-Citizens Be Deported For Their Speech?

>> Eugene Volokh: Welcome to Free Speech Unmuted. I'm Eugene Volokh, Senior Fellow at the Hoover Institution at Stanford and emeritus law professor at UCLA Law School. My cohost, Jane Bambauer, is professor, many decades away from being emeritus, at the University of Florida in the Law School and the Journalism department.

 

And before we get to the substance of our show, I wanted to announce a new feature. It's a mailbag feature. If you have questions about free speech, you can go to Hoover.org/askunmuted, that's Hoover.org/askUunmuted, one word, askunmuted, and leave us your question. And then we'll probably periodically do a answering user questions show.

 

So that's a new feature. Hope you enjoy it. Today we will turn to the question about free speech and aliens, free speech and people who are not US citizens and to what extent they are protected by the First Amendment.

>> Jane Bambauer: Yeah, so, yeah. So we decided to record on this topic today because in the news cycle right now is a controversy involving a former Columbia graduate student named Mahmoud Khalid, Khalil, I'm sorry.

 

And a few days ago, he was arrested by ICE, Immigration and Customs Enforcement. And the announcement from DHS on X, maybe I'll just read part of it, explained that he was arrested because, and here I'm quoting, Khalil led activities aligned to Hamas, a designated terrorist organization. So I think that that wording might be important to us later, aligned to Hamas.

 

The background is that Khalil was frequently in the reporting on, his name was mentioned in a lot of the reporting about the protests going on at Columbia University. He served as the so the student groups that were setting up encampments and making demands about divestment from Israeli companies and whatnot used Khalil as their main negotiator.

 

There was a CNN story around that time where Khalil not only talked about his experience as the negotiator and what they want and why they had turned down some offers that other universities had previously used successfully. But he also said that they would not decamp even after Columbia University gave them an order to.

 

And he had mentioned back last year in 2024 that he was a little bit nervous being on the forefront of the protest movement because at the time he was in the country on a student visa. Now, it's a little confusing. During the time of the arrest, the Trump administration had suggested that he still, at least in some of their tweets and whatnot, had suggested that he still was a visa holder.

 

But it's now clearer at least according to Khalil's lawyers at aclu, that he has become a green card holder. So he graduated, I think, in December of 2024. He's a permanent resident now. He's married, he's expecting a child soon. And so that's his residency status. And so we need to understand, I guess, whether as a statutory matter and then also as a constitutional matter, the Trump administration really can deport someone like Khalil.

 

Who has been working quite actively with protest groups that, in addition to engaging in speech, also engaged in at least some, at least trespass and maybe some other illegal acts as well. So does that set us up well enough or do you wanna add anything?

>> Eugene Volokh: Well, so it sets us up almost too well.

 

So here are these interesting factual disputes about this particular case, or factual, let's say factual accounts with some factual uncertainties. We don't know for sure, for example, as I understand it, whether the federal government is also saying that he was indeed conspiring to commit crimes and if so, what kind of crimes.

 

Yes, they commit trespass, perhaps, or something like that, but maybe even more. So the facts of the case, I think, help illuminate what's going on. But there's a broader question that arises for many more people and in various different kinds of ways. So let's turn briefly to this broader question.

 

Let's start with the statutes. So first of all, the government is generally speaking entitled to deport people, at least constitutionally entitled to deport people if they commit crimes. A citizen, by the way, I used to be an alien. I was born in the then Soviet Union. I am, thankfully, a United States citizen.

 

But back before then, if I had been at the tender age of, I think it was 14 when I got citizenship, the tender age of say 13 if I had committed a crime. And actually, let's, to make it easier, assume that I was an adult when I committed the crime.

 

It's possible I might have been deported, that certainly I had no constitutional right to remain in the US So long as I was not a US Citizen. Now that I am a citizen, if I commit a crime, not that I would, but if I were, I could be punished, but I couldn't be deported.

 

But non citizens can be at least consistent with the Constitution, deported for committing crimes. Of course, there are also statutory limits. Not every single crime, not every time you speed or something like that would you be, be deported. And, of course, there are also various procedures that are required.

 

Procedures perhaps of the sort that are being gone through right now having to do with whether, in fact, you're legally eligible for, whether the government is legally allowed to deport you under the statute. So there's this complicated statutory scheme of immigration law, but as a constitutional matter, people can be deported for committing crimes.

 

Now, what if somebody is deported solely because of their speech? So let's start with the statutory provisions. This is one area where President Trump is not really getting out way ahead of Congress the way he is in some areas where there's a question as to whether he's entitled to.

 

Here there is a federal statute. There's been for quite a while a federal statute which specifically provides that an alien may be excluded or deported for endorsing or espousing terrorist activity or persuading others to endorse or espouse terrorist activity or support a terrorist organization. So this is based on speech.

 

It's not just if you are a terrorist. Of course, if you're a terrorist, you could be excluded and deported. Of course, if you're actually conspiring with a foreign terrorist organization, you could be excluded or deported based on that crime.

>> Jane Bambauer: And likely maybe incitement, too, if you actually within the bounds of incitement.

 

But here, just endorsing is not any of that. Those things.

>> Eugene Volokh: Okay, this is, this is speech that would be constitutionally protected, generally speaking, for American citizens. But the, but the immigration laws say that if you engage in such speech, you are excludable both at the border, you can be not allowed in in the first place, and you can be deported if you engage in such speech.

 

>> Jane Bambauer: Am I correct that this statute, the language from this statute that we're focusing on came out of the Patriot act, which I think is also.

>> Eugene Volokh: So, you know, this is an interesting question. That's my vague recollection. I have not actually looked at.

>> Jane Bambauer: Okay, yeah, no worries.

 

>> Eugene Volokh: So if you look at how terrorist activity is defined, again, and it's enough for this law that you endorse or espouse it. But if, if you look at how it's defined, it's defined very broadly. It's any activity which is unlawful under the laws of the place where it is committed or, or which would have been unlawful in the US if it had been committed in the US and which involves hijacking, sabotage, assassination, violent attacks on chief of state, and a few.

 

Few other things. So technically, if somebody were to say, I think that someone in Russia should shoot Putin, and that's the way to. That the war will be over and things will get better for Russians as well as the Ukrainians, that would be endorsing or espousing terrorist activity, because terrorist activity includes activity that's unlawful.

 

Shooting Putin is unlawful in Russia. I'm quite sure of that. I'm not an expert in Russian law, but I'll. I'm willing to bet on that. And it's an assassination as well as a violent attack on an internationally protected person. So. So this is potentially a broad restriction on the speech of aliens.

 

So as a statutory matter, I can't speak to any particular case because I need to know exactly what the person said, although presumably that will come out in these proceedings that need to happen before someone is deported. But at least in principle, many people who spoke out, say in favor of Hamas or defending Hamas's actions in Israel, Hamas's murder of Israelis, that they would be, in fact, excludable, deportable under this statute.

 

So that's the statute. So President Trump is acting consistently with the statute. Are he and the statute consistent with the Constitution? And, and the answer is, I think the only honest answer is we don't know. You might think, why don't we know? I mean, after all, modern free speech law is about a century old, more or less.

 

These issues have arisen at various times you'd think there would be a clear answer in the precedence. Turns out there's not. A few things are clear. The first thing is that when it comes to criminal punishment and traditional civil liability, and I quote here, freedom of speech and of the press is accorded aliens residing in this country.

 

That's a 1945 decision that was quite early again in modern, modern free speech law. So that actually involved an interesting case involving a labor leader, Harry Bridges, who was being prosecuted under state law and turns out he was an Australian citizen. And the question was, can he be prosecute?

 

Can the government have extra authority to prosecute him for speech because he's a foreign citizen? The Supreme Court said no. When it comes to kind of normal law, normal criminal law and normal civil liability, aliens have the same rights as citizens when they're in the US. By the way, if we're talking about aliens speaking in foreign countries or foreign organizations speaking in foreign countries, the First Amendment doesn't apply.

 

Government, for example, can deny funding in viewpoint based ways to foreign organizations speaking in foreign countries. That's just outside the writ essentially of the First Amendment, the Supreme Court has said. Now what about entry? What about just coming into the United States in the first place, say as a tourist?

 

Well, in a case called Klein Deans to me, Mandel 1972 case involving a Marxist academic who was invited to speak, oddly enough at Stanford University, which is my employer, Hoover is of course a unit of Stanford University. So he was invited. The government said no, no, they had it said it that he was rejected because he'd violated visa conditions in the past.

 

But the Supreme Court basically said that the government can exclude aliens even based on their speech. So it can just say, look, if you were an American saying these things in America, you'd be free to do that. But just because we have to tolerate our own people like that, our own people with views that we think are very bad, Nazis, Communists or whatever else, doesn't mean we have to import them.

 

>> Jane Bambauer: Now can I ask you a question about that one? So Kleindienst came up longtime listeners might recall I was interested in this case when we were thinking about TikTok, because that's an example of where if we think of the algorithm as originating in China.

>> Eugene Volokh: Algorithm just like a Belgian Marxist.

 

>> Jane Bambauer: Yes, just like a Belgian Marxist, but the indicta. The court explained that one reason they felt comfortable allowing the visa to be denied was that the listeners who have the interests, who have First Amendment interests were still getting his message because there was a tell at the Time it was a telephone conference where he could deliver his remarks anyways or something like that.

 

So I, I take it that, you know, I, I guess I take it that, that Mandela's not completely clear or, I don't know, at least, at least some vagueness about. Especially when it comes to the interests of others who might want to hear a message. But I think the territoriality here really matters, right?

 

>> Eugene Volokh: Right. So I think Klein die Mendel is pretty clear in the power to exclude, which is sort of understood an essential attribute of sovereignty. Like we at our borders, we can say to anybody, no, we just don't want you here. But once they're in, are they in?

 

>> Jane Bambauer: Is it like.

>> Eugene Volokh: Well, we'll get to that. Of course, we'll get to that. Okay, okay, but I do think you raise a very important question. What about listener interests, right? That even if you were to say, well, you know, aliens, they're not Americans, they're not protected by the Bill of Rights.

 

Again, the Supreme Court has said they are protected at least as to some things, as to many things. But let's say we say, you know, they shouldn't be protected. Well, there are Americans who may want to hear their views. And the First Amendment protects the rights of listeners as well as of speakers.

 

But inclined deans, the Supreme Court essentially said, yes, yes, it does protect the rights of listeners. That's why we're taking this argument, the First Amendment argument, quite seriously. But it doesn't give anyone the right to come into the US So the rights of listeners are important. They make a difference in various kinds of cases, but they will only take you so far when it comes to immigration.

 

>> Jane Bambauer: Yeah, and there is sort of a parallel there cuz the Supreme Court has also said that people who want to go listen and observe in Cuba don't have a right to travel to that. I think that case and Mendel sort of show that the crossing borders is.

 

Just treated as whether we call it conduct, or in any case, some non-expressive decision that where the First Amendment won't attach.

>> Eugene Volokh: Right. So then we get to this question of what happens if we do let him in, but then we regret it and want to kick them out.

 

Can we do that again, can we do that as a constitutional manner? Federal immigration law may limit the government's power to do that as a statutory matter and may certainly impose certain procedures, but can substantively Congress say, as it has, people who espouse these particular views can indeed be deported?

 

Well, here the rule is unclear. Now this issue did come before the court in a case called Harisiadis Vs Shaughnessy back in 1952. And there the court did speak about basically nearly unlimited congressional power over deportation. But that came in the section dealing with the argument that deportation violated the Due Process Clause.

 

When it came to the First Amendment argument, the Supreme Court said, well, it's okay to deport him because he's an active member in the Communist Party. And at the time, basically I oversimplify here, but at the time that was seen as punishable, at least in many respects, even for citizens.

 

I think the law has changed in considerable measures since then. But Heresiadis therefore could be read two ways. One is the government has unlimited authority in deciding whom to kick out. At least, excuse me, as a matter of fact, the First Amendment does not constrain the government in deciding whom to kick out, just as it doesn't constrain the government in deciding whom to let in.

 

But another possibility is to say no, basically applied the then existing First Amendment rule and said, well, his speech is unprotected, so that's why he can be kicked out. So as a result, things are unclear. And one way of knowing that they're unclear is that lower courts like the federal appellate court, so pretty high, but lower than the Supreme Court, are quite mixed on this.

 

So for example, There was a Ninth Circuit case from 1995, American Arab Anti Discrimination Committee vs Reno, which was reversed by the Supreme Court, but on other grounds. So the Supreme Court did not end up passing judgment on this question. That said, look, read properly. Horisiadis establishes the deportation grounds are to be judged by the same standard applied to other burdens on First Amendment rights.

 

That's a quote. So basically saying rules are the same for aliens as they are for citizens. And there's a Fourth Circuit case from 1985 that ruled the same way. On the other hand, There is a Ninth Circuit case from 1991, which said that the protection afforded resident aliens by the First Amendment may be limited because the court has historically afforded Congress great deference in the area of immigration and naturalization.

 

And here's a particularly relevant quote because it involved the plaintiff who's a lawful permanent resident. Although Price is justified in expecting the greatest degree of constitutional protection afforded a non citizen, again because he was a lawful permanent resident green card holder, certainly not an illegal alien, but also not temporarily visiting student or something like that.

 

So although he has the greatest degree of constitutional protection, the protection afforded him certainly is not greater than that of the citizen plaintiffs in Kleindienst. Remember the case we just talked about, whose claims were rejected? So essentially, he was saying, look, the people who wanted to listen to Mandel were American citizens, they lost inclined Einstein.

 

Price will move here too. And by the way, this raises another question which is neither deportation nor initial admission. What about citizenship? Can the government say, look, maybe we won't deport you, but we don't want you to be voting in our elections. We don't want you to be playing a role in the governance of our nation.

 

And there Price suggests that Congress can deny non citizenship. Excuse me, non-citizen citizenship based on speech that would be protected if said by a citizen. Quote, natural decisions. Let me restart that quote. Naturalization decisions deserve at least as much judicial deference as do decisions about initial admission. And back again to Kleindienst.

 

So the answer is unclear. But there's one last thing which, where the answer is at least clearer, and it may resolve some of these cases alone, not all of them. In Reno, the, the. I'm sorry, in Reno, the American Arab Anti-Discrimination Committee. Remember that ninth Circuit case I said went up to the Supreme Court was resolved on other grounds.

 

The Supreme Court did hold that, basically, generally speaking, maybe with a few exceptions, but generally speaking, one thing that citizens who are being deported can't do is raise a selective prosecution claim. If I'm being prosecuted for some crime, I can say, look, the real reason you're prosecuting me is my speech.

 

And I want the charges dismissed against me because they would not have been filed if it weren't for my political affiliation or things that I've said. It's constitutionally protected speech. You're saying you're prosecuting me for tax evasion or whatever else, but really you're targeting me because of my speech.

 

Those are hard cases for defendants to win, but in principle they can win them. Whereas generally speaking, when it comes to immigration decisions, the Supreme Court can't even be said, you can't raise the selective prosecution. Maybe there's an exception where the government basically admits to selective prosecution.

>> Jane Bambauer: Well, that's what I was just going to ask.

 

>> Eugene Volokh: Might be the case in this case.

>> Jane Bambauer: Truth socials that suggest that. We know what the reasoning is here.

>> Eugene Volokh: Right. So, but at least in many situations where the person says, well, I think think the real reason you're going after me is because I participated in these demonstrations.

 

You're saying it's because I was involved in trespass or some such, but really the reason is you didn't like the message of the demonstration. Well, the Supreme Court's decision makes clear that that argument isn't going to fly. But returning to the broader point, what if the government says no, no, no, we want to stress that the reason we are going after you, in fact the only thing we're going after you, let's assume the government says is you're endorsing or espousing foreign terrorist activity.

 

What the First Amendment rule is about that we just don't know. At least don't know for sure.

>> Jane Bambauer: Very interesting. And just to be clear, we do not know that Khalil specifically said or did anything that actually endorses the Hamas attacks. At least the quotes that I've seen for are ones where he has said that the student protesters should not leave campus until Columbia divests.

 

And you know, I think that's not, that doesn't quite fit the, even the broad definition of, of endorsing or espousing terrorist activity. But, but there, like you said, we will learn more about what he has said and done.

>> Eugene Volokh: Right. By the way, I should mention, though, a part I may have omitted when I read the statute at the outset because it's a little technical but might be relevant here.

 

The statute also makes excludable and deportable people who threaten, attempt or conspire. To endorse or espouse terrorist activity. So if I'm involved in a conspiracy with other people where they're the ones who are endorsing or espousing terrorist activity, but I am deliberately helping them in various ways with the aim of promoting their endorsement or espousal of terrorist activity, that would presumably be conspiracy to do that and would itself be deportable or excludable.

 

Again, if I were an alien, a status that I have thankfully left far in the past, by the way, I should tell people just. Just to acknowledge what a foreign and suspect character I am. Every so often I have to, for bar admission, indicate. Depends on the jurisdiction, but I may have to indicate all the names I have ever been known under.

 

And in addition to Eugene Balak, I have to say Yevgeny Fallach, because on the visa to get into the US, I distinctly remember my Russian. Russian name is Evgeny, which is the Russian version of Eugene, but it was just transliterated rather than translated. Then, thankfully, my parents realized that life in America is better.

 

>> Jane Bambauer: Would be easier as Eugene.

>> Eugene Volokh: If you come up with a name that at least everybody knows roughly how to spell and how to pronounce, more or less. But in any case-

>> Jane Bambauer: This is why my Yakowitz family went by Yorks for a long time.

>> Eugene Volokh: If only my parents had done the same with my last favorite.

 

>> Jane Bambauer: With your last favorite.

>> Eugene Volokh: Although then again, you know, there are advantages to being odd. It sort of becomes a bit of a trademark in any event. So as citizens, we have all of these rights. As an alien, I had some of those rights, many of the free speech rights, but maybe not the most important one of all, which is the right not to be deported for the things that I say.

 

Maybe the most important one of all. But one of the most important rights of all.

>> Jane Bambauer: Well, I think in your case it probably is the most important, given where your career wound up, right?

>> Eugene Volokh: Well, and given where I would have been deported to.

>> Jane Bambauer: That too.

 

Yes. Okay, so I have two follow up questions. One is that I saw in some of the reporting around this controversy, I saw at least one commentary say that it's not clear whether Khalil, through the aclu, will be able to raise First Amendment, a First Amendment challenge before removal proceedings have finished or at least been initiated.

 

Is that correct? I mean, I think this was a matter of standing. That seems to me hard to believe given that there's been an arrest, but.

>> Eugene Volokh: Right. It seems odd to me, but I should say immigration law is a highly, highly technical field.

>> Jane Bambauer: Okay.

>> Eugene Volokh: I'm comfortable that I know the First Amendment rules, such as they are, as we see there.

 

All I may know is we know very little having to do with, with immigration law. Also the, the statute that I read, I'm familiar with, but the exact procedures about what you raise and when. And there are interesting questions about where physically in what district, the federal, in what federal district these claims have to be made.

 

All of these are important questions to which I do not know the answer.

>> Jane Bambauer: Okay, so then the second question is the policy question. So do you think this is a good idea? Even if, even, even if, you know, I think given past episodes, I think we're both on the record of as being, I think, somewhat skeptical of the wisdom of some of these student protest movements.

 

>> Eugene Volokh: Right.

>> Jane Bambauer: Is it a good idea to, whether we're talking about visa holders or green card holders, is it a good idea for the government to selectively revoke the, you know, access to, to American soil based on, based, based on protest activity?

>> Eugene Volokh: No, I do not.

 

I'm a big believer in. Free speech is an important, in fact necessary condition of the search for truth of the marketplace of ideas of democratic self government. Now of course, aliens by definition are not themselves direct participants in democratic self government, but they do talk to American citizens.

 

And American citizens may learn important things from them. Sometimes they may be persuaded by them. Sometimes one of the things they may learn is, wow, these people really hold these ideas, which I think are awful ideas. But this gives me a new perspective on what's happening on campuses, what's happening in the world, what's happening in various kind of political corners of the United States.

 

It's useful information to know. So for all of these reasons, being able to, being able to hear what non citizens have to say is quite important, especially because, you know, what, what about 96% of the world more or less consists of people who are not Americans. It's a big, big world out there.

 

And it's useful to be able to hear what foreigners, people who maybe just very recently lived in foreign country, maybe about to return to a foreign country, or maybe not in the case of lawful permanent residence, but how they see the world, that may help influence our judgment about Americans about what makes sense for our country to do.

 

So I believe in all these things. And the flip side of that is, I think it's important at the university that people free to talk about these things. And when you see your friends and your classmates being chilled in their speech because they say, I don't want to get deported.

 

It creates a chilling effect on everybody. I mean, you might say, well, I don't have to worry about getting deported. But still you're getting, it becomes less a community of people who really are genuinely free to express themselves and free to talk about all sorts of issues like for example, even espousing terrorist activity.

 

I imagine there are people who have, at various times in their lives, especially when they're younger, have been quite open to political violence, especially overseas. Remember this is. We're talking about espousing foreign terrorist activity and violence in foreign countries may have been, yes, absolutely, more revolution, more war, more whatever.

 

And then eventually they realize that was a mistake, and it was useful for me to talk it over with people to recognize them. It's a mistake. So for all these reasons, I generally think that there ought not be these kinds of restrictions on non citizens any more than on citizens.

 

Now, you might try to distinguish situations where people are saying things that suggest that they're actually a hazard to Americans in America. So you can imagine the government coming in and saying, look, this person is saying things that make us think that he's going to try to, to bomb synagogues or bomb mosques or bomb government buildings or whatever else in America.

 

We just want to kick him out just so he's no longer a danger to us. You can imagine possibly having a different kind of argument as to that, although even there I would be quite skeptical of that kind of deportation. But it seems pretty clear that both the statute, which remember, focuses on endorsement of terrorist activity, the great bulk of which is overseas terrorist activity.

 

So it seems to me that both the statute and the administration right now aren't looking at, they're going narrow rationale. Looking at the broader rationale, again, just because we have to allow Americans to say these awful things, doesn't we have to mean we have to import foreigners who are going to say that?

 

But I think ultimately that's counterproductive. I think it's bad for American public debate and I think it's bad for serious, thoughtful discussions at American universities. Because, remember, this doesn't just apply to people chanting slogans in encampments, including often illegal encampments. It also applies to somebody could be deported under the statute for having a serious, thoughtful conversation about.

 

>> Jane Bambauer: Right, exactly.

>> Eugene Volokh: Hope of foreign political violence.

>> Jane Bambauer: Yeah, writing a polite op ed in the student newspaper, that sort of thing. Yeah. I mean, so I agree with all of those things. And I do also want to highlight that in addition to the free speech theory, which you and I both are firmly committed to, it also is very counterproductive, I think is the word you used because, you know, most people were actually pretty annoyed by these student protests and the demands.

 

And now we have, you know, now Khalil is looking quite sympathetic, especially with a baby on the way, and you have a bunch of lawyers coming in trying to parse the difference between supporting terrorism versus being against Israeli government decisions as a policy matter or, you know, and, and so that's just, I think it.

 

Even if you were completely instrumental and were willing to use whatever government power you have to get to achieve the ends you want, which neither of us are, but even if you were, this would be, this would be a really bad call, even on, even to achieve the short term ends that Donald Trump seems to want, so.

 

>> Eugene Volokh: Yeah, I'm inclined to say that that's so, especially given that the Trump administration is billing itself as protecting free speech and faulting Europeans for unduly restricting speech. I mean, I take it that some people from the administration may say, yeah, we mean the speech of Americans. We're about America first.

 

And yeah, sure, we don't care as much about the speech of foreigners, especially who come here as visitors to our country and then violate our rules. So perhaps they could defend themselves this way politically. I've been so poor in my predictions of what's going to play well and what won't politically in American politics, that I can't speak with great confidence.

 

But I'm inclined to tend to agree with you that this is putting people who express these views, many of whom really are, should be condemned for those views. It's making them not quite free speech martyrs, but at least putting them in a more positive light.

>> Jane Bambauer: Absolutely.

>> Eugene Volokh: Again, I just can't say I'm completely certain at how this is going to play in Peoria or how it's going to play in Portugal.

 

>> Jane Bambauer: Very good. All right, well, we'll see how it plays out in the courts of New York City, I guess, first.

>> Eugene Volokh: Well, that's a good question. So, just to be clear, friendly amendment, the federal courts somewhere, maybe in New York. But this is one of the questions, as I understand it, is whether it's going to be in the federal courts in New York, where I've heard talk about in Louisiana.

 

>> Jane Bambauer: Louisiana, that's right, that's right, he was-

>> Eugene Volokh: The one thing that I can say with considerable confidence is if we expect this case to give us the precedent, we can be waiting a long time. Our justice system is generally not super fast, but the immigration system is extra complicated with a lot of layers of review.

 

Maybe at some point the Supreme Court is going to resolve some of these questions, but. But it may take a while. So, Jane, thank you very much as always, such a delightful conversation, and we look forward to talking with the rest of you folks in a few weeks.

 

>> Jane Bambauer: Thanks, Eugene.

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