Legal Business Environment

 Federal Trade Commission (FTC) is the primary regulatory agency. It enforces statutes which prohibit unfair and deceptive trade practices, various credit abuses, and misleading warranties for keeping competition free and fair. Fair Debt Collection Practices Act which prevents debt-collection agencies from using abusive or deceptive collection practices. Fines of violating FTC may be assessed in three distinct situations: 1) for violation of consent or cease and desist order, 2) for a violation of a trade regulation rule, and 3) for a knowing violation of prior FTC orders against others.

There are other laws that regulate consumer protection but in different methods such as Fair Packaging and Labeling Act which prohibits deceptive labeling of certain consumer products and requires disclosure of certain important information, Equal Credit Opportunity Act prevents discrimination in credit extension based on sex, age, race, religion, national origin, marital status, and receipt of welfare payments. Magnuson-Moss Warranty Act is to require the FTC to issue rules concerning consumer product warranties.

The unfair and deceptive practices are as follow:

a.       Price mispresentation -  such as Bait-And-Switch promotion which seller intends to use a product advertised at a low price only as bait to capture the interest of consumers and then switch their attention from it to products which the baiter really has desired to sell from the beginning.

b.      Performance mispresentation – such as False representations of the composition, quality, character or source of products by misbranding or otherwise, have been barred as deceptively misleading. And disparaging the goods of others in an attempt to promote the sale of one’s own is also an unfair practice.

c.       Truthful yet deceptive Advertisements – such as using a word while having a hidden or unusual interpretation in mind for the purpose of promoting sales and intend to mislead. Using product-name simulation (e.g. using the same name of other or one that is deceptively similar to another product of another producer which has acquired consumer acceptance) is also unfair. Also silence of seller may result in deception of consumers (e.g. nondisclosure that books published were abridged or condensed was rules as deceptive. And distributing secondhand or rebuilt goods without indicating them as such and selling foreign goods without disclosing their origin have been considered as deceptive)

d.      Giving impression that pain relievers are something other than aspirin when they are not is deceptive.

e.      Making unsubstantiated claims about gasoline additives improving fuel mileage unless an appreciable number of consumers can achieve that performance under normal conditions.

f.        Advertising for diet pills that would induce weight loss while sleeping and without exercise or dieting and the manufacturer could not substantiate the ads it considered as deceptive.

g.       Mispresentation of value and investment potential of coins sold is deceptive.

The seller or manufacturer is considered FTC violator if they advertise about the product which they cannot prove. The FTC has said that it will use three tests to determine whether to take action against trade practices. 1) FTC must conclude that the ad is likely to mislead consumers; 2) misled consumers must be acting reasonably in the circumstances; 3) the practice must be material.

Truth-In-Lending Act is to assure the necessary disclosure whenever a buyer pays in four installments or more and require more disclosure for financing statement that must be given to the borrower before credit is extended and must contain, in addition to the finance charge and annual percentage rate, the following information:

1.       Any default or delinquency charges that may result from a late payment

2.       Description of any property used as security

3.       The total amount to be financed, including a separation of the original debt from finance charges.



Warranty makes a statement about a product or a promise about its performances and must be available to buyers prior to purchase. Congress pass Magnuson-Moss Warranty Act to help warranty problems with consumer products, that requires disclosure on the terms of warranty in simple and readily understood language which warranty must be labeled “full” or “limited”. The products covered by the full warranty must be repaired or replaced by the seller without charge and within a reasonable time in the event there is a defect. Manufacturers cannot impose requirements on buyers to obtain the repairs or replacements unless the requirements are reasonable. Means, the law does not require manufacturer to give any warranty. The products covered by the limited warranty, the limited information must be conspicuously displayed in associate with warranted product so that the buyers are not misled.

The remedies of Unfair and Deceptive Acts and Practices (UDAP) are as follow:

1.       Restitutions for victims by fraudulent merchants

                                                   i.      Victim can recover the actual loss; triple damage; or minimum amount

                                                 ii.      Assessment of punitive damages and attorney’s fees and costs

2.       Civil penalties which must be paid to the state if they are related to public.

3.       Criminal fines and/or imprisonment if it is related to public

4.       Revocation of license and other forms of permission to do business within a state if it is related to public UDAP

Under implied warranty of merchantability, it is the seller’s duty to provide the buyer with a product which is fit for the ordinary purposes for which such goods are used. If product is not fit for its ordinary use, the seller is strictly liable for injury to person, property, or the product itself. Under UCC section 2-315, if a purchaser relies upon a seller’s skill and judgment to select a product to serve a particular mentioned purpose, the seller is liable if the product fails the purpose.

Section 2-313 of UCC creates an Express warranty for any promises the seller makes about a product’s performance, such as: “The transmission of this tractor is guaranteed against mechanical defect for five years.” It establishes an express warranty for any factual statements describing the product. (“All moving parts are made of stainless steel”) similarly, the seller is held to warrant expressly that final shipment of goods will conform to any sample or model that has been furnished that buyer. Non of these express warranties need use the words “warranty” or “guarantee”.

Express warranty places upon the seller an absolute duty of performance, that seller has acted reasonably or that the product is fit for its ordinary use and is not defective does not protect the maker of an express warranty. If the product is not as described or if it does not perform as promised, the seller is liable. A duty of performance which overlaps that of express warranty places tort liability on anyone who mispresents to the public a material fact about the character or quality of a product through advertising or labeling.

Legal requirements of warranties cases are varied between plaintiff’s and defendant’s as follow:

 In plaintiff’s legal side

Plaintiff must prove the below four necessary elements whether the case involves negligence, strict tort liability, or the implied warranty of merchantability.

1.       Defect must be in production or design

If there is an absolute duty of performance (such as in express warranty), the plaintiff must establish that the product causing injury is defective before recovery is permitted. Product becomes defective when it does not meet the standard of safety society expects.

Production defects are generally easy to identify. The product does not meet the manufacturer’s own internal production standards. Although the manufacturer may not be negligent simply because there is a production defect, such a defect usually allows the plaintiff to rely upon strict tort or implied warranty of merchantability.

Design defect does not involve a deviation from the manufacturer’s own standards. The issue of whether product breakdown after long use means the product is defective is presently of primary concern to manufacturers. Manufacturers can often protect themselves in cases involving the performance life of products by issuing appropriate warnings should cover both the expected duration of product use and proper maintenance procedures.

2.       Defect must be in hands of the defendant

Just because a product user has been injured by a defect in the product does not mean that the manufacturer, or any particular party in the chain of distribution, is liable. A vital fact which the plaintiff must prove to win a products liability case is that the defect occurred or existed while in the hands of the defendant. As we previously mentioned. Engineering consultants and other expert witnesses can frequently provide testimony which will fix at what point the product became defective.

3.       Defect must have caused the harm

Plaintiff must do more than establish merely that a defect in the product existed at the time of the accident. Plaintiff must show a causal link between the defect and the harm. An inability to do so will usually defeat the claim.

4.       Defect must make the product unreasonably dangerous

The defectively produced product is unreasonably dangerous if the defect causes injury. Since the injury-causing item contains no production defect, it will create liability for the manufacturer only if the court determines that the design is unreasonably dangerous.

Proper warnings which accompany a potentially dangerous product can go far toward reducing the possibility that a court might find the product unreasonably dangerous.

The likelihood of a product being called unreasonably dangerous is, of course substantially less when the product meets relevant government standards and industry practices than when it does not.

In defendant’s legal side

Defendant bears complete responsibility for the manufacture, distribution, and sale of product to different number of parties, and defendant can raise some defenses to win the case,

1.       Parties that are effected in product liability

When someone’s person or property is injured through use of defective product, the damage will usually create potential liability for the following parties

a)      Occasional sellers

Liable only in negligence or for express warranties

b)      Retailers, wholesalers and manufacturers

Usually not liable for negligence; may seek indemnification from preceeding seller; some states do not permit products liability

c)       Raw Materials suppliers, component parts manufacturers, parts assemblers, and packagers

Liable only when the product defect is caused by the parts and materials supplied or the work performed by these parties

d)      Lessors

Using the rules of strict tort and warranties of merchantability of fitness fora particular purpose, lessors are stand in a far  better financial and technical position than lessees to insure against, prevent, or spread the costs of product-related injuries.

e)      Franchisors

Franchisors have become the target of products liability suits based on theories of strict tort and implied warranty. Although franchisors may not manufacture, handle, design, or require the use of a product, they frequently do retain the right to control or approve the design, and they may specify quality-control standards and conduct advertising for the trademark.

f)       Sellers of used products

Sellers of used products are liable for negligence when they fail to use reasonable care in selling defective products that cause injury. Sellers of such products will quickly be held liable if a used product does not live up to an express warrarnty.

The plaintiff in these cases usually sues all such parties to increase the chances of recovery against a guilty party that is financially able to pay the judgment. It becomes important, then, to know who may be defendant in a products liability lawsuit.

2.       Defendant’s defenses

As it was mentioned previously that some defenses can be raised by defendant as follow

a)      Contributory Negligence

The second major field of tort liability involves behavior which causes an unreasonably great risk of injury. Complain for negligence show four elements as follow:

                                                                                                                           i.      Existence of a duty of care owed by the defendant to the plaintiff. The conduct of sellers must fulfill the duty of “ordinary and reasonable” care. Otherwise, sellers must answer in damages for negligence to those injured by their conduct.

                                                                                                                         ii.      Unreasonable behavior which breaches the duty. Res ipsa loquitur applies when Plaintiff can show the item which caused the injury was within the sole control of the defendant and the injury typically would not have occurred unless the defendant were negligent.

                                                                                                                        iii.      Causation of the plaintiff’s injury by the defendant’s behavior:

1.       Cause in fact. Plaintiff must prove that the defendant actually caused the injury.

2.       Proximate causation. It represents the proposition that those engaged in activity are legally only for the foreseeable risk which they cause. Proximate cause doctrine requires the injury to be caused directly by the defendant’s negligence.

                                                                                                                       iv.      An actual injury

Contributory and comparative negligence defense absolutely barred the plaintiff from recovery if the plaintiff’s own fault contributed to the injury in any degree. In the great majority of states is to offset the harsh rule of contributory negligence with the doctrine of comparative responsibility. It merely compares the plaintiff’s fault with the defendant’s and reduces the damage award proporplantiff’s fault with the defendant’s and reduces the damage award proportionally.

b)      Assumption of risk

For the defense of assumption of risk to succeed, the defendant must show that the plaintiff understood the nature of the risk and voluntarily and unreasonably assumed it.

c)       State-Of-Art

Product manufacturers frequently find themselves sued for injuries which occur during the use of a product, the state of technological art may have progressed until it is now possible to manufacture a product considerably safer than the older product. The state-of-art defense requires that juries judge defendants by the technology feasible at the time the defendants manufactured the products in question.

d)      Misuse

The defendant may also avoid liability by showing that the plaintiff deliberately misused the product. When misuse is foreseeable, some states permit the defendant to raise it as an absolute defense.

3.       Defendant may seek identification

The plaintiff must be able to prove that the defect existed while the product was in the hands of a particular seller. Because several sellers in the chain of distribution may be liable to the plaintiff, if one seller pay the entire claim can that seller seek recovery from other sellers in the distribution chain, this principle permits any seller who is compelled to pay the injured plaintiff to obtain full recovery from the party that sold the defective product to him or her.

4.       Product Liability Prevention

Company can prevent the product liability and reduce the risk of product liability to the minimum point if the following preventive procedures are applied:

·         Management involvement at all levels of planning and production

·         Formal product-safety policies

·         Product-safety officers or committees

·         Preproduction safety testing

·         Production quality controls and safety audits

·         Thorough legal review of product documents, such as labeling, warranties, and advertising

·         Product monitoring of actual consumer use

·         Product recall plans

Not merely there is product liability; there is service liability and malpractice for accounting professional. The accounting malpractice toward a client can arise, for instance, when accountants present a negligently prepared financial statement to the client, and the client relies on it and is injured. Malpractice also results during an audit when accountants fail to pursue evidence that a client’s employee is defrauding the client.

 Recession cause many debtors to be unable to repay their debts on time. Several laws protect debtors when this happens to balance fairness to individual debtors against the benefits produced by an efficient market system. Debtor protection covers four things 1) limit the interest a creditor may charge to a debtor via usury law; 2) regulate the methods of legitimate debt collection through Fair Debt Collection Practices Act (FDCPA); 3) discharge debtors from their debts via federal bankruptcy law and 4) allow debtors to assert certain defense against third parties.

1. Usury Law:

The law has traditionally attempted to protect debtors by limiting the amount of interest that may be charged upon borrowed money or for the extension of the maturity of a debt. Contracts by which the lender is to receive more than the maximum legal rate of interest are usurious. Usury laws usually provide for criminal penalties and, in addition, may deny a lender the right to collect any usurious interest.

A seller of goods may also add a finance or carrying charge on long-term credit transactions in addition to the maximum interest rate. A different means of avoiding usury is to have a “credit price” that differs from the “cash price”. Another is to charge extra interest for delinquent payments otherwise legal limit.

2. Debt Collection

Congress in 1978 passed the Fair Debt Collection Practices Act (FDCPA) which covers only consumer debt collections. One of the first actions of debt a collector will usually be to locate the debtor. This action , known as “skip-tracing” may require that the collector contact third parties who know of the debtor’s whereabouts. FDCPA permits the collector to contact third parties, such as neighbors or employers, but it limits the way in which this contact may be carried out. FDCPA restricts methods that can be used in the collection process that collector cannot:

-          Physically threaten the debtor

-          Use obscene language

-          Represent himself or herself as an attorney unless it is true

-          Threaten debtor with arrest or garnishment unless the collector can legally take such action and intends to do so.

-          Fail to disclose his or her identity as a collector

-          Telephone before 8:00 am or after 9:00 pm in most instances

-          Telephone repeatedly with intent to annoy

-          Place collect calls to the debtor

-          Use any “unfair or unconscionable means” to collect the debt

Violations of the FDCPA entitle the debtor to sue the debt collector for actual damage, including damages for invasion of privacy and infliction of mental distress, plus court costs and attorney’s fees. In the absence of actual damages, the court may still order the collector to pay the debtor up to $1,000 for violations.

3. Bankruptcy

Bankruptcy proceedings begin upon the filing of either a voluntary or involuntary petition to the court. A voluntary petition is one filed by the debtor; an involuntary petition is filed by one or more creditors of the debtor. The creditors who sign the involuntary proceeding that the debtor is unable to pay his or her debts as they mature; the court will order relief against the debtor. Relief may also be ordered if someone has been appointed to control the debtor’s property (for example, a receiver) within the previous 120 days for the purpose of satisfying a judgment of other lien.

Corporations and partnerships can also have all their assets liquidated and distributed to creditors. However, especially for large businesses, an alternative to liquidation is reorganization. A main part of the reorganization is a plan that is proposed by the business and considered by committee of creditors prior to court approval. The plan rearranges the business’s liabilities and equities (ownership assets). Parts of business may be sold, and always the existing ownership interests in the business are reduced. In effect, the creditors often become owners in the business. The number of bankruptcy reorganizations nearly tripled between 1980 and 1987.

Under bankruptcy laws, certain creditors receive priority over others in the distribution of debtor’s assets. Secured creditors who hold mortgage or article 9 security interests in the debtor’s property usually have priority over the bankruptcy creditor classes. The priority of bankruptcy creditors are as follow:

1.       Creditors with claims that arise from the costs of preserving and administering the debtor’s estate (such as the fee of an accountant who performs as audit of the debtor’s books for the trustee)

2.       Creditors with claims that occur in the ordinary course of the debtor’s business after a bankruptcy petition has been filed.

3.       Employees who are owed wages earned within ninety days, or employee benefits earned within 90 or employee benefits earned within 180 days of the bankruptcy petition (limited to $2,000 per employee)

4.       Consumers who have paid deposits or prepayments for undelivered goods or services (Limited to $900 per consumer)

5.       Government (for tax claims)

6.       Creditors who have other claims (general creditors)

The purpose of bankruptcy is to secure a discharge of further obligation to the creditor, but certain debts cannot be discharged in bankruptcy. They include those arising from taxes, alimony and child support, international torts (including fraud), breach of fiduciary duty, liabilities arising from drunken driving, government fines, and debts not submitted to the trustee because the creditor has lacked knowledge of the proceedings. In addition to having certain debts denied discharge, the debtor may fail to receive a discharge from any of his or her debts if the courts find that the debtor has concealed property.

For additional protection for consumer-debtors, most credit contracts contained clauses which stated that consumers agreed not to assert to assert any contractual defenses against third parties. These clauses meant that if seller sold the consumer’s credit contract to collection agency, the agency could legally collect the contract price form the consumer in spite of the fact that the seller had breached the contract, or had even defrauded the consumer. In addition to a credit agreement, many times the consumer had also signed a promissory note (A promissory note is an easily transferrable, specially type of commercial instrument or paper)

 Society can be protected by antitrust law which preventing some business practices that may lessen competition via the following Acts

a.       Sherman Act

b.      Clayton Act

c.       Robinson-Patman Act

d.      Celler-Kefauver Act

e.      Antitrust improvements Act

There are number of laws must be concerned by Companies which providing criminal sanctions such as Foreign Corrupt Practices Act.


Acts (Law)



More detailed Prohibition

Sherman Act of 1890 prohibits;

Price Fixing

Agree with other specific manufacturers or sellers to sell in specific price



Division of markets

Agree with other specific manufacturers or sellers to where to sell



Group boycotts

Agree with other specific manufacturers, sellers, or buyers not to deal with another



Resale price maintenance

Manufacturers may enter into contracts with one or more retailers, setting the minimum price for products

Resale price maintenance is prohibited except for consignment contract

Clayton Act 1914 prohibits;

Horizontal, Vertical and Conglomerate merger

Horizontal merger is between competitors, vertical merger is between supplier and purchaser and Conglomerate merger involves different industries or different areas of business.



Tying or tie-in sales

Sales in which a buyer must take other products in order to buy the first product

The per se rule for tying contracts does allow defendant to justify undertaking the tie. A tie-in may be justified if it is implemented for a legitimate purpose and if a no less restrictive alternative is available.

Reciprocity cases are quite similar to tying cases, and courts treat them in a similar manner.


Exclusive dealing

Seller requires a buyer to purchase only the seller’s products and not buy, any products from the seller’s competitors

Exclusive-dealing contract contains a provision that one party or the other (buyer or seller) will deal with other party.

Franchise contracts often require that the franchisee purchase all of its equipment and inventory from the franchiser as a condition of the agreement. These provisions are commonly inserted because of the value of the franchiser’s trademark and the desire for quality control to protect it. Such agreement, while anticompetitive, are legal, because the legitimate purpose outweighs the anticompetitive aspects

Franchisor is not able to license its trademark in such a manner that it can coerce franchisees to give up all alternate supply sources because such agreements are unreasonable restraints of trade. The quality-control aspect is not present for items such as packaging materials and food items in which special ingredients or secret formulas are not involved; thus, the purpose of the “exclusive source of supply” provision is only to limit competition.


Price Discrimination

Sell the same product but at different price to different buyers



Interlocking directorate

It prohibits person being a member of the board of directors of two or more corporations at the same time, when one of them has capital, surplus, and undivided profits which total more than $1mm.


Robinson-Patman Act of 1936 prohibits;

Predatory Pricing

To sell at lower prices in one geographic area than elsewhere in the United States to eliminate competition or a competitor, then to increase the price after driving out the competitors

Predatory pricing means pricing below marginal cost by a company willing and able to sustain losses for a prolonged period to drive out competition. Predatory pricing also involves charging higher prices on some products to subsidize below-cost sales of other products or cutting prices below cost on a product in just one area to wipe out a small local competitor.

Price-cutting was generally deemed predatory when price was below total costs, including long-term fixed costs. However, some economists have argued that pricing is predatory only if companies slash prices below average variable costs – the short-run expenditures such as labor and materials – needed to produce some more units of product. With long-term fixed costs excluded, prices legally can be cut to a much lower level without the price-cutter being guilty of predatory conduct.

Predatory pricing is established by proof that a price is below average variable costs unless evidence of justification is admitted to show some other reason for the low price. Only when prices are below average variable costs is prima facie case established.


Price Discrimination


Robinson-Patman amendment forbids discrimination in price when the goods involved are for resale. It does not apply to sale by a retail to consumers. The term “commerce” is defined as “trade…among the several states and with foreign nations…”

Plaintiff seeking triple damages because of price discrimination must prove that the effect of the discrimination is to injure, destroy, or prevent competition with any person who grants or knowingly receives the benefit of the discrimination, or with customers of either of them.

The statute recognizes certain exceptions or defenses:

1. Price differentials based on differences in the cost of manufacture, sale, or delivery of commodities are permitted

2. Sellers may select their own customers in bona fide transactions and not in restraint of trade.

3. Price changes may be made in response to changing conditions, such as actual or imminent deterioration of perishable goods, obsolescence of seasonal goods, distress sales under court process.

4. A seller in good faith may meet the equally low price of a competitor (good-faith meeting-of-competition defense). The act permits a defendant to demonstrate that a given price discrimination was not unlawful by “showing that his lower price or the furnishing of services or facilities to any purchaser or purchasers was made in good faith to meet an equally low price of competitor, or the services or facilities furnished by a competitor.

Celler-Kefauver Act of 1950 prohibits

Acquisition of assets of another corporation


Determining the relevant product or geographic market is considered by courts that is affected by the merger in question. The more narrowly the product line or geographic area is defined, the greater the impact a merger or acquisition will have on competition.

In addition to determining the relevant market affected by a given merger, courts must also find that within that market the effect of the merger “may be substantially to lessen competition, or to tend to create a monopoly” before a violation is established. The degree of market concentration prior to the merger and the relative position of the merged parties are important factors in such cases.

Antitrust improvements Act 1950 requires

Premerger Notification


Premerger Notification Rule requires that prior notice be given to the Justice Department and to the FTC of all pending mergers subject to the rule.

The application of the premerger notification rules are determined by the size of the firms involved and the size of the transaction. The rules cover transactions involving at least 15% of either the assets or the voting securities of the firm to be acquired when the value of the purchase exceeds $15mm. The value of the assets is determined by fair market value, not by book value.

Under new guidelines, the legality of vertical and conglomerate mergers is judged solely on their impact on future direct competition. Horizontal mergers are examined for the post-merger market concentration and the increase in concentration resulting from the merger. Herfindahl-Hirschman Index is used to test the legality of horizontal acquisitions.1

Foreign Corrupt Practice Act of 1977

Prevent Secret Payments

Giving significant gift such as expensive brand new car or lump sum big money to officials in any country to retain a business

The act prohibits foreign concern, including any person acting on its behalf, whether or not doing business overseas and whether or not registered with the SEC, from offering or authorizing corrupt payments to any

1) Foreign official;

2) Foreign political party or official thereof;

3) Candidate for political office in a foreign country.

Corrupt payments include payments for purpose of inducing the recipient to act or refrain from acting so that domestic concern might obtain or retain business. Therefore, FCPA prohibits the following

1) a mere offer or promise of bribe

2) payment anything of value, Deminimis gifts and tokens of hospitality are acceptable.

3) person making them knew or should have known that some or all of them would be used to influence a governmental official.

Payments made to governmental clerk or ministerial employee to expedite the processing the formalities are not be prohibited as long as the payments are not significant.

Public Companies must make and keep books, records, and accounts in reasonable detail that accurately and fairly reflect transactions and dispositions of assets.



 1 An index known as the Herfindahl-Hirschman Index (HHI) is computed as follows:

  HHI = ∑ (Market Share of each firm)2

a)        If the result is ≤ 1000, the merger probably will not be challenged, as the market is considered to be unconcentrated, having the equivalent of at least ten equally sized firms.

b)       If the result is between 1000 and 1800, a careful examination of moderately concentrated market will be determine if acquisition is likely to harm competition. Harm will likely be found if the merger adds 100 points to the index. If < 50 points are added, the Justice Department is unlikely to challenge the merger.

 If The liquidity ratios such as current ratio for Company’s have been steadily increasing during the three of five-year period analyzed and the median current ratios is higher than comparable Companies within the industry, it appears the company is a much stronger financial position to meet is current obligation as compared to its industry peers and it also indicates that Company’s is less leveraged than its peer group.

The activity ratios should be considered too. If the accounts receivables turnover has declined from last period and followed by increase in the average collection period of accounts receivables may indicate to management of this asset has slipping considerably during the analyzing period. Also, if the median of the accounts receivables turnover and inventory turnover are fallen below its industry peers in its management of major working capital components. If this trend continues, the company’s working capital could become significantly strained and become an obstacle to future growth.

For Business valuation there are various approaches such as cost, market, asset and income approaches. As long as accounts receivables are current assets. Therefore, the asset approach is used for determining the value of accounts receivables. Trade receivables should be examined for collectability. The allowance for doubtful accounts should be reasonable and be reviewed for adequacy and uncollectable amounts should be reviewed and expensed at the date of evaluation.

Templates and Forms