In this video, Board Certified International attorney Jen Diaz talks about customs and trade, and how that has been impacted by COVID-19 and how the trade war makes matters even more complicated.

Transcript:

Hi everybody, Jeff Kostick with Flying Chimp for one of these another one of these video chats. I am joined today by Jennifer Diaz of Diaz Trade Law. She is a board-certified International Attorney specialize in customs International Trade. She helps companies deal with the federal laws associated with you know, importing and exporting, hi Jen, welcome. Hi there. Thanks for having me so just because I know think a lot of people are familiar with what a customs and international trade law attorney does quickly give us a you know, the elevator pitch on what that is sure and as an FYI, I wasn’t sure what we did at first when I first started either so that’s perfectly reasonable. Took me a long time. I actually grew up overlooking the Port of Miami, right? I had no idea what actually happened there, you know, everybody drives and you see these awesome big trucks in your way who you want to yell at and get really mad at when you’re on the wait, because they’re taking up the roads and taking up some space and driving really slowly and you’re trying to pass them. Well, that’s all part of who we need to appreciate especially nowadays with coronavirus. They’re the guys getting our stuff to local Walmart’s and charges that’s a big portion of what we do ideas trade law. The idea is one of two realms. So, for all the attorneys, you obviously know people want you need you when they don’t have a choice there in an emergency situation. So, the emergency in my world is I tried to import X item even let’s say waters masks whatever the items are, and US Customs stop them at the border. Now, I’ve paid my supplier. My customers are yelling at me. I’m in a state of emergency because I can’t get my goods and I need you to help me now. Now that’s the typical scenario of when somebody needs a customs and trade attorney like myself where I wish people would call me a lot more. I can get that guy who is in trouble to then say wait a minute. That wasn’t really fun. I didn’t love that process. It took many months, maybe a year, a couple months, couple weeks. Whatever the time frame was to resolve that problem, but don’t want that to happen again. So, what do I have to do if I want to import whatever item so I can actually import smoothly and seamlessly, and life could be great pay my supplier? My customer pays me, and I get the goods my customer on time. So we call that at pre-compliance now, here’s the fun part and the US Jeff how many US federal government agencies do you think regulate International Trade regulate imports and exports we deal with more than one and you would be right. It’s like you’re playing what’s the game? When you want to guess the number that’s under, but you don’t want to bring over. There you go. You’re playing The Price is Right now 47 agencies and how many border crossings do you think we have in the US How many ways to enter? Goods, and people all throughout the US I too will go with more than one and you Price is Right. Again. It’s Jeff is always going win Price is Right. Not a fair contestant 323. So now you’ve got three hundred twenty-three different ways. You’ve got 60,000 plus US Customs and Border Protection employees. So when you think of US Customs and Border Protection, you usually think about them stopping illegal immigrants from coming in but that’s not the Terry role when it comes to trade there’s a separate function for goods as there is for people so when it comes to Goods the Customs job the US Customs and Border Protection Officer job is to facilitate legitimate trade and to stop a legitimate trade. So, Customs has what are called priority trade initiatives, like what are the big things we care about that? We’re going to look out for at those 323 ports of Entry. Now, here’s the fun part Customs is always at the center. For anything coming into the US Anything leaving the US They are the agency that’s responsible to enforce all those 47 other agency rules. Now imagine they have to know Alcohol Tobacco tax and trade Bureau Federal Maritime commission Transportation Security Administration Hazmat Goods FDA Food and Drug Administration. One of the most common regulatory agencies that when you think about imported Foods is the FDA almost 70 percent of our Seafood is imported. That’s a lot. So, there’s a there’s a big consumption in the US for imported food products. So now you have not only Customs but FDA. So, in reality to sum up that long fun, when did story is what is somebody like me do on an everyday basis? I can be dealing with food aluminum structures apparel Electronics cosmetics. On the same day for different tasks for different emergencies or different compliance related matters. So, we’re ecstatic to review and some clients have had for 15 years where they have new products and they want the expertise of is this compliant before I start imported? Perfect. We love you; you know you we review the product we review the labeling is it? Okay is it does it meet us standards? Can it come into the US? Does it need registrations in advance? And then it’s the oh no, I’m in trouble which is the bulk of the practice itself. And that’s what happily Keeps Us in business. So, we’re not complaining about that either. Gotcha. Okay, that was a great answer and I’m guessing now that you kind of briefly mentioned, you know kind of covid-19 and coronavirus which is obviously all anybody can talk about. Oh, yeah. How obviously that’s impacted your business and your clients in a very meaningful way kind of explain about how that has impacted it and what that means to kind of lay person like myself and your friends and people who don’t pass import-export. I absolutely I think every Law Firm period is impact in every business in the US and every business in the world is impacted in different way law firms are considered essential offices thankfully now. So, we’re all still open. So that’s the good news. The bad news is we all have to come up with contingency plans. So, it was about five weeks ago for us where maybe four weeks ago where my assistant was coming back from Italy and she had this great vacation. She loved it and next thing, you know, she was trying to come home and couldn’t her flight was kids and then she had to come up with contingency plans and then I had to really quickly learn that Nineteen was a real reality. Although it really hadn’t hit the us yet. We had to come up with a covid-19 plan before anybody else because we had somebody living eating and breathing it and then we needed to make sure office was safe and quarantined. Right sure and we have others in the office that have young children and we’ve got people that are older and our office as well that we have to worry about. So, every office has had to come up with their COVID-19 contingency plans and whatever that may be, so we’ve had to set up our remote. Items and thankfully those work and our great we’re to deal with business continuity. So, on the law firm side, like everyone else we stopped in person meetings. We made sure that we’re still running everybody has access to our systems remotely in her documents remotely females remotely. So, any essential function can still be performed regardless of your physical location that I’m ecstatic about which is not easy in any way shape or form, but thankfully works. On a side note. We were also in the process of doing a webinar Series. So, we were at the part where we were doing a three-part webinar series on intellectual property rights, the third part of that series was intellectual property rights and protecting your intellectual property rights in China. We decided to add covid-19 to that webinar because it made sense. It was so timely at that time as well. So we were going to talk about the trade war and relations with China anyways, so then we added what’s going on with us China relations as it relates to intellectual property rights and period as a related to trade and it’s a big deal. I mean China closes every year for Chinese New Year, and that’s usually a month. This year it was three months, you know, four months and in some parts of factories, they’re still closed. So, imagine you have an order to a Chinese Factory. You expect them to be closed for Chinese New Year, but you don’t expect them to be closed for a quarter of the year. Right. So now when you start seeing some of the operations opening you got problems because you have workers that can’t go to work. You still have quarantine and hometowns where there’s no bus, there’s no anywhere. There’s no there’s no way for these employees to physically get to work to begin with that’s a huge issue. So, although your opening about two-thirds of capacity. If you don’t have workers to work in those factories, it’s for not that’s a huge issue. Then you have busloads of workers that are allowed to leave a specific Province where the out Burke where the outbreak first came in which were interested to see so now you’re going to start seeing Flows of goods come from China more and more. Then you’re seeing more and more cargo planes being used where passenger planes would have been used prior, but you don’t have passenger planes going to and from China now and from the US. So now you have empties where now you’re filling them with cargo as well. So, you’re going to see more are shipments than see shipments as well, which also gets the goods faster used to be a much higher expense, but now everybody’s kind of lobbying, you know, everybody wants the business. Imagine how many container ships are empty and how many aren’t actually going where they need to go. So, it’s a really crazy time where you want to see the manufacturing start back up again. You want to see the import start back up again. And then at the same time, we are actually still in the middle of a trade war and it’s a nasty trade War. So, a lot going on with that trade War to begin with and we are still knee-deep in it. So, you have one side of the trade realm where there was a letter that went to POTUS. Stating that they wanted an end to the China tariffs the China trade War. So, we’ve got millions and billions of items that are listed on this trade War. It’s all segregated into four lists. So, the group says I want all of it to end. I want to be able to import whatever from China and not be subject to 25% or 7.5% duties. Whatever list you’re on and now the response we’re seeing is that’s not going to happen. That’s not going to be a realistic output as a result of The Crow. Virus as a result where we have a phase one deal that was negotiated with in that phase one deal. China has to meet certain metrics and certain buying metrics. The fun part is they’re not going to tell possible now at the end of the day to meet that Phase 1 metrics. They would have to buy a hell of a lot of agricultural goods. And now they’re not necessarily in the position to do that. So, it’s going to be really interesting to see because there is some wiggle room on both sides, especially with a global pandemic now like the legal Community is all talking about Force majority. You know, that’s the hot word now the hot term that’s floating and it’s impractical for both sides to be able to commit to such a large Hefty deal now when the world is in the middle of a pandemic, so I don’t my personal opinion is I think we are going to get to our Phase 2 portion of the deal. I think that will flow as even if phase one isn’t perfectly met. I think we’re still going to be at the negotiating table and we’re still going to have trade with China which is necessary. I do think that others are starting to look more and more seriously for Alternatives, which is a long time coming. We do have issues with China that necessitated the trade War to begin with and that’s part of why we started the intellectual property rights series because a big chunk of that was intellectual property rights counterfeits, you know taking ownership of it. Information that wasn’t yours to begin with and nobody can deny that that was an issue in China. Now, we have health safety and sanitary issues on top of that that started the spread of this really nasty virus as well to talk about but so I’m going to go to stop really quick. So, let’s talk about how the Imports specifically either from Italy or China or the other kind hot beds from other areas it how the travel ban. Has impacted the ability to get certain supplies that we otherwise would have expected. It’s a reality at the end of the day. Now you see some us companies stepping up which is so cool. My husband belongs to some of these distilleries and get some of these cool news for the Bourbons that he loves some of these bourbon guys are now turning into making hand sanitizer that’s phenomenal like you want to hear more and more vodka just found out that today a lot of local US based offers certainly don’t answer love it and why not? Not you’re at a stage where Ingenuity has to come to play and these us companies have to step up as well because we’re so Reliant upon Imports for so many things and we’re not the manufacturing Hub of the world that we used to be back in the day. So, we had an over Reliance upon China and don’t get me wrong. I’m guilty. Everybody’s guilty. We love Amazon We Love convenience. We love cheap prices. That’s where this all imaginated. Let’s be realistic if you have something for a dollar or something. For five dollars, you know the likelihood is you’re really excited about the dollar. It’s hard to get you to care about the $5. So bottom line is now you see more and more people saying all right. What can I shift? Is it possible for me to shift production somewhere else? If so at what cost at what timeline? What location how is this all going to play out? And how is this going to work because trade with some countries now for a certain block of time. It’s just not going to be possible or not possible. Possible for the time and for the cost that you were excited about good luck with that now from a financial perspective. How is that input impacting your import companies that were previously kind of expecting that as their primary and like I don’t know how to ask exactly. the question It’s crap. I look let’s be realistic you place an order with the Chinese Factory and they can’t fulfill it for four months and you thought it was because I thought it was going to take one how happy are you how happy are your customers? How happy are you with all It is maybe you don’t have any maybe you do? I mean if people are flustered and it’s tough because you’re not getting the flow of goods that you’re accustomed to getting but nobody is if they’re from the same country of origin if they’re from China. It’s like it’s just an issue. So, you’re going to see fewer particular products of some on the shelves when it comes to specific Commodities. I mean, this isn’t the same as everybody hoarding toilet paper. That’s a whole nother argument, but you know it there is A case for it. So now at the end of the day is can we finally get some production outside of China as well or is China going step up and now we’re seeing them step up and starting to open up those factories and start to increase production. So, we’re going to see more and more of those goods physically coming they come by air. We get them nice and quickly they come by see it takes a month. So, question for you are there specific? goods and services that are being led through easier at point as a result from a kind of an internal a specific need based and what are they? Yeah for sure. So, going back what’s interesting in regard to the trade war is goods are separated into these four lists. So, you got list 1 2 4 4 a 4 B within those lists are Commodities that are part of the trade War. So, it was the escalation of now after each list. We have a little cheat sheet if anybody wants to see it. It’s also on our website. And on our blog as well that I’ll share with you, but within our cheat sheet for the list. What’s interesting is you have the option to petition to say I want my product excluded from this bad guy list from this 25% or 7.5% duties, right? So, we just saw a flash round of a decent chunk of products that were excluded that are all medical supplies and medical equipment. So makes a lot of sense now, right? So, this went straight from the top. Stop saying we need to start getting these products approved away because they’re all medical supplies and equipment. So why should that be part of this trade War when we actually need them in our own country, right? So now you’re seeing more and more exceptions when it’s something that really benefits the US like the medical supplies and equipment. So that’s common sense. And then you’re seeing FDA lacks rules in regard to medical supplies and equipment which is interesting as well because how would these distilleries and anyone else be able to make a drug which is a hand sanitizer without FDA compliance. Otherwise, you know and how would masks and ventilators and all these things that we need. We need FDA and everybody on board to get to This Global pandemic solution because you don’t have the products then what serve the US population then what so the but then I also have red and I don’t know the legitimacy of that is that we’ve seen a bunch of counterfeit type of items specifically health Care items coming into the country what can be done and what have you seen? What have you heard and what can be done to stop such a good question and it’s true? So that’s actually one of Customs priority trade initiatives. So, going back to US Customs. There are pretty amazing at the border and they’ve got a really big job at the border. So, we’ve seen fake test. So imagine how many people are in line to take the test to find out whether or not they have This nasty virus or don’t have this nasty virus, you know, so now there were counterfeits that came in and they were manifested. Basically, whoever was shipping them told Customs. Oh, don’t worry about it’s just a water test. It’s a water vile like a water whatever. Yeah, that’s nice. Well custom is for whatever reason because they’re really smart. They have their own targeting systems. They figure out what they’re going to pull over and inspect and what they’re not they opened it up and there really covid-19 test. Are fakely manifested as water vials or water tests like not. Okay who tested them? How do we know that? They’re safe? How do we know that? They’re not safe? Like how we know they’re reliable or not reliable. What’s the deal with that? It’s not. Okay. Unfortunately, with every catastrophe and every pandemic and every emergency you’re going to see Schmucks trying to take advantage of the system and trying to rip off whatever they possibly can. But thankfully we have US Customs and Border Protection protecting our Borders a lot of people don’t give them enough credit because you have trillions and trillions of line items of things coming into the US every year. You how it is to Candy pick what it is you’re going pull to the side and what you’re not going to pull to the side to inspect to figure out who’s full of it. Who’s not who’s illegitimate who’s not what’s counterfeit what’s not but they have such great sophisticated software that allows them to tell the difference between what they should and shouldn’t pull over and it helps them with different algorithms and a lot won’t share with us because why would they want us to know the system so that anybody could try to screw with it? Right? I know so much. Google doesn’t tell us the rules either because otherwise we can game the system even more than we already do. So, are you concerned that that the restrictions and rules are going to get more tight as a result of these sorts of counterfeits that are out there the rules themselves as they are in Play Now cover these Scenarios they’re just enforced and that’s the reality is you don’t need new rules to catch these bad guys. You just need the enforcement of the rules we have on the system today and that’s what’s happening. And it’s okay. The expectation is always that we’re going to have bad guys try to do bad things and that’s part of the law and part of the rules. So, we’ve got great statutes great regulations that talk about the detention process the seizure process. What Customs does to facilitate the legal stuff what? Some does to punish the bad guys in the counterfeiters. So imagine if you’re a counterfeiter, you can go through a detention custom stops your goods and specs them then Customs physically seizes your goods you go through the seizure process and thereafter dependent upon what it is and what law you violated and what trademark for example you counterfeited. You could have a penalty after the fact that the value of your importation sometimes that could be millions of dollars and it’s the value of your MSRP not the value of your $2, you know. Taguchi. It’s how much this Fendi Gucci really, you know in the stores as they sell it. So, the laws that we have in place catch these bad guys. It’s interesting. I was at a different conference in front of lawmakers in Europe and they were the counterparts to the US and I was talking to them about the US System for catching the bad guys counterfeiters and in the intellectual property rights rules and I was spitting off stat stats to them that was saying in Thousand eighteen, you know, we had about 34,000 seizures in the US for intellectual property, counterfeit violations, and they said really that’s all and I said, that’s all I was like, what is it like in your country? They were like, oh hundreds of thousands. I was like what that’s interesting. It’s like there’s a lot of lost opportunities. So, I learned that I need to be a practitioner in Europe at the end of this lot more opportunity a lot more cases, but it’s interesting because no matter what you do is never going to be enough. But it wealthy the end of the day. The real question is do we have less of an issue do we have more that actually gets by that doesn’t get by because a lot of what we see in the stats that we are looking at our mail facilities and those smaller shipments, you know e-commerce has picked up to such a huge degree now. It’s like when’s the last time especially nowadays who’s going to the mall now, you’re buying off of Amazon like everybody else. You’ve got these small snail shipments. Those have to be Checked and vetted and then you still have the opioid crisis as well in the middle of all of this, you know, and what’s the majority of the pathway for that type of medicine to go through and those drugs to go through and that’s going to be through the mail facilities as well. So that’s the majority of the enforcement that you’re going to see as well. So bottom line is we have rules we have laws in place. The whole point is when they work, they work really well. There’s no need to change the laws, but we are going to see the enforcement the same because it is a priority for Customs to catch those bad guys to make sure that the health safety and Welfare of the American people is covered at the border and that’s the job to facilitate the good stuff and get rid of the bad stuff and catch bad guys. you know absolutely Currently you kind of touched upon the trade war with China and how the this because of our specific needs. It’s impacting what were allowed. Threw in a little more of an expedition back expeditious fashion what other provocations will COVID have on the trade War? In your community, I think they’re the reality is we’ve been so Knee Deep and like the exclusion process for tariffs and to find out who’s on the good list who’s on the bad list what can come into the country without 25% Duty, you know, what has what doesn’t have we’ve been going through what we call mitigation of the trade War. So, you’ve got five main options of things to do. So, this is like what everybody’s been knee-deep in. It’s like What can I do about it. If my goods are subject to these China trade Wars? The first thing to do is to move your country of origin not everybody can just do that. I’ve talked to a lot of people that have really expensive facilities set up. They’ve got great quality control systems. They’ve got a whole lot of machinery and know-how and warehouses and Manufacturing facilities completely set up and it would cost them a hell of a lot of money to just up and move that to another location and to try to create those relationships elsewhere. You’re talking a couple of years. So now everybody’s kind of playing the lotto Long is this going to last versus? How long is going to take me to move elsewhere? So, this is what everybody’s thinking about now, and now even more so in the middle of covid-19 because if they would have started when the trade War started almost a year ago, you know, could they have been already there? Could they already have a different facility set up that maybe has less of an impact. There other options like foreign trade zones and bonded warehouses. That’s huge in Miami the deal with a foreign trade zone is your technically outside the jurisdiction of the US even though you’re physically in the US which is quite cool because when you think about Miami, we got a lot of goods that come from China come to Miami and then are going to Latin America. Well, technically they’re not for the US Consumption. They’re not for us customers. So why would you want to pay a trade War duties, you know those extra China tariffs plus your regular duties when it’s not an American Consumer that actually is going To utilize the product there’s an exception and fur that you can use what’s called a Bonded Warehouse or a foreign trade zone. So, we have been setting up foreign trade zones and bonded warehouses like up to here because that’s a great opportunity for anyone who Imports for export. It’s a great way to bypass the rules and a legal way to do. So why would you want to pay when you don’t have to right? It’s an easy one. And for those that do wind up paying there’s a system called Duty drawback where you can get nice. Ninety-nine percent refund of what you paid. So now how happy is Publix and Costco and anyone to give you a refund of that toilet paper that you hoarded right. Now, they’re not going to do it. Well Customs on the other hand. You paid them these a lot of money and duties they collected over 48 trillion dollars duties. I think it’s no billion dollars in duties just for the China Terrace now billions. That’s a hell of lot of money for a year plus that this has been going on. That’s not a long time. That’s you know, it’s a decent chunk of change. So yes, Customs has the money but are they happy to give it back to you? They’re going to make you prove it and nickel and dime you and check every item make sure every T is crossed every I is dotted everything that came in to the US had to be exported in the same Condition. It’s very nitty-gritty to process. A lot of people are in ecstatic about because it’s not easy. No, never easy to get a refund. So, there are options like that in a couple more like first sale and tariff engineering Lee changing the items condition that you import. For example, we worked with a client where if they imported an item in one type of Packaging it was a different classification that another type of packaging and one set them in a completely different classification and a completely different Duty rate makes a big difference. Sometimes you just have to look at your code how your goods are classified and maybe it can take you out of the madness. Another thing not a lot of people are doing is seeing how exclusions are going for competitors. So, the fight itself to get off of the 25% list for one two, and three for those Illusions is classification product specific. So, imagine if you and I import the same item and you we both fought I lost my fight, but your fight is still pending, and you win your fight. I may be able to use to my advantage as well. It might not just be for your product. So, it’s important for me to check the status of your fight as well as anyone else who is another competitor of ours because maybe I can take advantage of that do not pay the duties and You can also request refunds going backwards. So, these are opposed my head. It’s like its version of like case law in your situation. Yeah, it’s there’s a whole lot of craziness going on at the same time. So, you’ve got organized chaos and then just chaos at times as well. So, we’ve got a lot of people trying to take advantage of New Opportunities. We’re hearing a lot of I can get masks and I can get ventilators and I can get hand sanitizer and how do I do this? How do I do this quickly? I need this quickly. Versus I’m still dealing with the trade War. How’s our case doing? How’s our competitors case doing what’s going on with that or let’s get our act easy setup. What’s the status of that or the government is also doing a lot of enforcement on a side note with anti-dumping and countervailing duties? That’s a hot-button term now. So, when it comes to enforcement there are different ways to tell on bad guys or to tell on potential bad guys. So, for example, if I think you Jeff for importing counterfeit, Merchandise, I can tell Customs to get after you and I can give them information about you. So that Customs tracks you down finds you and tries to get your Imports and it’s not like they would tell me the status of it. I wouldn’t be notified. But I would have a play and knowing that my information led to your seizures, at least it would hopefully make me feel good. Hopefully at the end of the day if you’re a competitor, I couldn’t get into a Walmart for example, because you offered them a lower. The me, obviously, it’s a whole simplification because Walmart does a whole lot of betting to begin with but let’s say you were able to get past that if Customs was to stop you. That’s fine on the flip side. There’s a separate process called HEPA the enforce and protect act. This is a big new thing. Where imagine if I’m telling on you Jeff because you’re a competitor you make an item and you’re telling the world that the item is made in Vietnam, but I think it’s really made in China and I think you’re trying to avoid anti-dumping. So, I tell Customs this is my suspicions for Jeff. This is what I think he’s bringing in where he’s bringing it in why I think he really is coming from China why he’s a bad guy and trying to avoid paying duties and its public you find out that I’m the one that title told against you we go through a public proceeding. It’s a whole like a public trial, you know, it starts off as administrative and we’re seeing more and more. Of these tattle-tale cases. This is a big deal now in the Customs realm because Customs when it comes to those priority trade initiatives anti-dumping counterfeiting. That’s all top of the list. This is all a really big deal now. So now you have a new pathway for people that hate you or that are competing with you to tell on you and whether the info is or wrong is a whole nother story, but now you have a presumption because Customs is going to think that you’re a bad guy after they read all this then it’s You to prove you’re not a bad guy. That’s a really hard presumption so far 99% of people lose that case really hard to win. So, we’re knee-deep in some of those as well. So, you’ve got so many different facets of international trade going on at the same time where you still have the enforcement heavy side. Now, you’ve got a whole bunch of people from Customs working remotely and you still have people on the front line, but have to go to the, you know to the front lines that are there every day. It’s a whole new realm. So, I’m talking to people from Customs that are working from home that are still emailing that are now having to give out their cell phone number if they want to be in touch, which is really hard right? It’s a little bit of unknown for all of us. We don’t know what the future is going to hold now. It’s I don’t I don’t really see that Customs is going to enforce less as a result. I think we’re going to see the same number of seizures that we’ve always seen but I think for example the audits that are in Anything that takes place in person. We’re going to see a hell of lot less of because that’s going to make sense. Nobody wants to be in contact with one another, right? It can’t happen because umm, it’s not happening. Right we’re doing this interview because oops there we go. Alright I all I can think of is as you were saying that about the kind of the tattletale sort of situation that you’ve got is apparently stitches don’t get stitches apparently that you know, and fascinating I think it’s that there’s not a mechanism in place to sort of prevent those sort of what I would say like a This kind of case or a frivolous lawsuit kind of situation. So, it’s kind of fascinating to hear that that doesn’t appear to be that mechanisms in place. So, it’s almost you’re almost incentivized to mess with your competition in that way. Especially when you said 99% the time you lose those cases. It seems like it’s something that almost from a strategic standpoint. You should be doing a hundred percent. The only caveat to that that I will say is once you file your allegation, it doesn’t mean that Customs is going to That allegation and go forward with it. So they don’t give us the stats on how many frivolous ones were filed that weren’t taken to the next level the ones that Customs vetted and took to the next level if Customs believe that there was enough Merit in the case itself to take it to the next level publicly and issue a notice of initiation. That’s where you know, everybody is pretty much losing at the grand scheme of things until there’s a real resolution versus What’s out there and how much has been filed who knows interesting of well, thank you so much for joining me today. This has been fascinating. Um, I obviously we’ve known each other for many years, and we’ve gone into detail about certain things but never quite the in-depth with regard to the trade stuff. So, I thought those you haven’t read the 70 pages of my website that you put together. I have not read all 70 pages of the website that we put together. I read the charges that were relevant that you know, the last thing for you so and your messaging as an FYI, Jeff puts together a badass website. I am super proud of ours its diaztradelaw.com he does a really phenomenal job. So, if anybody’s considering Jeff for website/SCO/making your content look fabulous and blog maintenance and all that other fun stuff. He’s phenomenal great. Thank you very much for the plug. I appreciate it. Have a wonderful day and thank you again. And I’ll put your own old will put up with Jennifer’s contact information in the in the YouTube information down there as well everybody. This has been Jennifer Diaz of Diaz Trade Law the board-certified expert in international customs and trade law and we’ll see you next time. Sounds great. Take care.