Radio Is Adrift On Denial River

Someone recently asked, “Eric, if you could gather all the big publicly owned broadcasters in one room, what are the biggest concerns you would share with them?” Here are my concerns:

Cost-Cutting: In our efforts to cut expenses, we have cut into the bone. We cannot grow the business by more cost-cutting, because there is little left to cut without seriously hampering operations. All efforts should be focused on growing top-line revenues and overall radio spending.

Top-Line Growth: The misconception is that the RAB’s efforts to promote radio to national advertisers will solve this problem, yet national advertising is only a small percentage of radio billing. Though this effort can help, top-line growth will come from investing in our front-line troops locally — the 65,000 people selling radio. Most are ill equipped and poorly trained. Without excellent training, relevant messaging, and an understanding of how radio really works in today’s environment, they will be unable to create growth.

Quality Content: Radio is not investing enough in quality talent and programming. If Hollywood had overly automated, no one would go to the movies anymore. Hollywood may be containing costs elsewhere, but they invest in their product: quality writers, directors and actors. We do not.

Loss of Experienced People: We’re burning out our people with unrealistic expectations, enormous pressures and little job satisfaction. We’ve lost many of our best people to other industries. Others plan to jump ship the second they can sell their stock.

Ability to Attract and Retain Salespeople: Other industries offer six months of in-depth training before the reps’ first sales calls. They also receive perks, company cars, and ample time to learn and perform. We still throw new salespeople the Yellow Pages, giving them 45 days to sink or swim as we churn and burn bodies. Young people are unwilling to work in a negative pressure cooker with limited rewards and an irrelevant 20-year-old audiocassette as training.

Ability to Attract New Listeners (Thinking 10 Years Out): As teenagers, my generation embraced radio as the soundtrack of our life. Today’s teens and young adults do not have the same relationship with radio. Listening is declining as we compete for their time with iPods, cell phones, video games, Internet and more. Radio is not developing talent and programming targeted to teens, because we cannot make money on it today. If we don’t get teens addicted to radio now, they won’t suddenly become addicted when they become a “money” demographic five or 10 years from now.

Spot Loads: Our inability to price our product fairly and command our price (a training and a quarterly earnings issue) has led us to whoring our rates to get business at any cost and has led to increased inventory. Spot sets are unreasonably long, and unfair to paying advertisers whose ad falls in the middle of a long cluster. This produces unhappy advertisers as well as listeners, and we play into the hands of the satellite radio “commercial free” environment.

Quarterly Earnings: By setting aggressive expectations on Wall Street, our performance must continue to improve each quarter. Growth can no longer come from acquisitions and expense cuts; it can come only from investing in new long-term strategies and investment in our product. Wall Street does not give us the time to innovate and reinvent.

New-Generation Thinking: Every 40 years, the baton passes to a new generation and brings changes in thinking, culture, music and media. The last major shift was in 1964. It’s happening today. This shift impacts what we say, how we say it, what we advertise, and how we sell and communicate. What worked a year ago does not work today. The baby-boomer motto was non-conformity. The echo-boomer motto is authenticity. Radio is ignoring the shift and sticking to what we know — which won’t continue to work.

I’m not being negative. These are realities we cannot deny. Pretending that everything is OK is for fools. Cementing a solid future for radio is possible, but the solutions are painfully slow and require investment. Radio can build a solid future as a predominant medium if we are proactive and stop drifting down Denial River.

7/05/04 Radio Ink Magazine. By B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

The Danger Of A Preferred-Vendors List

A famous cartoon has General Custer on the front line, battling Indians with handguns and rifles. Standing in the wings is a salesman with a Gatling gun (early machine gun). The caption reads: “I haven’t got time to see a salesman. What we’re using works just fine.” Of course, he lost the battle.

Infinity recently announced that it had developed a list of preferred vendors to be used by the company. It evidently means a restriction to certain hardware and software vendors. The company also will use only certain consultants, and managers must select from this list.
Picture this: A cluster manager explains to Steve Rivers, head of Infinity programming, that a ratings disaster resulted from using “XYZ Consultants,” who directed the station with the poor results. Rivers might instantly think, “I’m never using those guys again; they screwed up one of our radio stations.”

Maybe he did not have time to gather all the facts. If he were to phone XYZ Consultants, he might hear that the consultants documented that the station followed only 20 percent of XYZ’s advice and that XYZ had many proven successes when the program was followed properly. Maybe the station manager thinks XYZ Consultants were actually to blame. Or maybe the manager knows she did not follow XYZ’s advice, and she wants to avoid censure. Scapegoating research and consultants is an old practice in radio. Meanwhile, Rivers thinks XYZ is a poor company — when they may not be — and XYZ can’t get future Infinity business.

I certainly see the value of knowing which vendors have great track records and which do not, and sticking to the good ones, but here’s at another scenario. Let’s assume that most research for Clear Channel stations is conducted by Critical Mass Media (CMM), a company owned by Clear Channel. Even though the company does not insist on using CMM, managers want to do what is best for the company, so they all use CMM. What if this research company (which has a great track record of success) suddenly makes mistakes or misses valuable information and, as a result, presents flawed research and direction. The company might not recognize that the research is the problem, and placing all its eggs in the one basket could mean company-wide disaster.

A preferred-vendors list is dangerous when it leaves no room for innovation or change and allows vendors to get lazy. Innovators today may not be innovative tomorrow if they get fat, rich and comfortable. We all know that competition is the motivation for innovation. Innovation in big radio companies usually comes when a small-town manager decides to buck company trends and do something new. Maybe it’s using a new piece of equipment. Maybe it’s a new NTR plan or a new research company with a new technique. Its success spreads through the company, and everyone wins. If that manager is allowed to use only pre-specified consultants or companies, innovation isn’t likely.

Historically, big companies do not innovate. Most great new ideas in radio come from small markets and independent broadcasters who have the guts to try something new. They don’t have to “look good” to corporate executives or on a quarterly earnings report.

There is importance in using only one traffic system company-wide for consistency, and doing this for most product categories may seem like a good business practice, but variety in vendors and in people is the key to innovation.

What if, in 1960, Bill Drake had come to Infinity and said, “I’ve reinvented radio”? If he weren’t a preferred vendor, he wouldn’t have been considered, and radio wouldn’t have been revolutionized. We need innovation more than ever, and a preferred-vendor list could end innovation at companies that implement them.

7/26/04 Radio Ink Magazine. By B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

A Standing Ovation For Industry Leadership


When Steve Rivers came to work for me at a high-tech start-up, he told me that one reason he did not take the job as head of programming for Clear Channel when his company AMFM was merged was that he did not want to deal with the spot loads the company was running. He said that if Clear Channel did something, such as increase inventory, AMFM would follow suit, because Wall Street expected it.

Two years ago, when John Hogan took the Clear Channel helm, I told him that he had an awesome responsibility: Not only did he have the company’s future in his hands, he also held the future of radio. As everyone watches and stock analysts track the industry’s largest company, he should assume that his actions and practices would be adopted industry-wide.

Radio is often an industry of copycats. A successful format is copied everywhere. If a major company increases spot loads, everyone else thinks they should do the same. Leadership, therefore, becomes an important responsibility when our industry leaders’ actions usually become industry-wide standards.

I applaud Clear Channel for taking the lead to reduce spot loads and sell premium positions. If they can pull it off across the chain, it will have a positive impact on our industry, though it will require a great deal of training and discipline at the station level. This could be a brilliant PR ruse, or it could be the real thing. Will the industry follow? Let’s hope so.

Leadership is happening in many places. David Field of Entercom has become a brilliant visionary and has gathered other group heads to address our industry issues. Field, Joel Hollander of Infinity, and John Hogan have been pushing the Radio Advertising Bureau toward building radio in the eyes of advertisers. Field also took action by creating and airing radio spots informing listeners of satellite radio downsides. David Kennedy of Susquehanna and Jeff Smulyan of Emmis led by example in creating people-friendly cultures and making their companies desired places to work in radio.

Nothing happens until someone takes a step. Everyone can take a leadership role. You don’t have to be a group head, station owner or GM; you can be a salesperson, an air talent or any other position in the industry. Leadership in your local area can manifest itself industry-wide. For example, you may be a sales rep who sees an area needing change, and you may develop and implement an idea that results in great success. Your station gets attention, your group adopts the idea, and the industry copies it.

Don’t expect someone else to see your vision or take the leadership role, and don’t be discouraged by nay-sayers. Stop complaining, and take action on your own. Leaders must endure criticism and often do not receive recognition, yet your idea can change the industry or even the world. Take action now. We need more great leaders in our industry, and there is a leadership role with your name on it.

8/09/04 Radio Ink Magazine. By B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

Small-Town Voices


Isolated at our summer home in the wilderness of the Adirondack Mountains, our lives instantly change. We have to drive 20 minutes to the gas station to pick up the local newspaper, and the nearest grocery store is 30 minutes away. Pine and birch trees, water and mountains surround us. There are no billboards, and we have no local television. Without inundation by media, we relax and live a slower pace. Radio reception in the mountains is spotty, but here, radio is the lifeline to the community.

One of the first lessons I learned as a radio programmer is that reflecting the community and being a part of the community are keys to success. Today, many stations around the country pretend to be local when they are not. Saying a town’s name when giving the weather is not community involvement, yet often that’s the extent of it. People may listen to your station anyway because they like other elements of the station, but it’s next to impossible to fake localism. Your community listeners know when you are truly one of them.

Here in the woods and small towns, radio is the accessible media. You listen to find out local news, local events, who died, who was born, whose dog is lost and who has an old washing machine for sale. It’s localism at its best.

I’ve chided radio for losing its soul, for being too formulaic, for lacking creativity and for not being local. I’ve changed my mind. This summer, I spent a fair amount of time in the car, driving through a number of towns in the region. What I heard was refreshing.
Indeed I heard McRadio in a number of places, with the same tired, old lines about “biggest hits, better variety, best hits of the ’70s, ’80s. ’90s…” BORING. Would it still work if it were put up against something fresh and innovative?

What was not boring were the small-town voices. Some were 100-percent live, some were automated or satellite operations, yet many of those stations still managed to be the voices of their communities. In some cases, what I used to consider bad radio was refreshingly good. Why? Because it was real: not hype, not contrived. On one station, I heard a kid with a cracking voice. He wasn’t slick or affected, yet he was very funny, and everything he talked about had a local reference. It felt like bygone days, when I would cling to every word, when radio was exciting and fun.

In this hectic world, there is nothing better than a cross-country drive, listening to small-town voices. In those small towns, one can still find vestiges of our radio heritage: local involvement, innovation created by the necessity to survive, and some folks who understand that formulas and hype are not real. These people, forced to be in touch with their communities, have realized that the slick sound on many radio stations is not so appealing to locals. This is where radio is still alive, creative and refreshing. I can’t help but wonder if adopting this homespun, small-town approach would appeal to audiences where every station is over-produced and a little too slick. Is it time for big metropolitan radio stations to become small-town voices?

8/23/04 Radio Ink Magazine. By B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

Wall Street, a.k.a. Mr. Wolfe


Friday morning, Harrison Hill Elementary, Mr. Wolfe’s 6th-grade math class: We had a big test, and I didn’t know the answers. I glanced to my right, I glanced to my left — and copied as many answers as I could. All three of us failed that test. Later, I was paddled in front of the class for copying. The humiliation, the F, and a glowing red behind taught me never to copy again.

Mr. Wolfe is needed desperately at the Radio Advertising Bureau. A recent headline in the RAB daily e-mail reads: “2000 Radio Scripts Now Online.” I cringed when I saw that announcement. Copying other people’s scripts is lazy. Encouraging it is bad for radio. Facilitating it is shameful. (I could almost agree with publishing successful radio scripts if RAB placed a bright-red warning that people should NOT copy the ads, but use them only to stimulate new ideas.)

The spot you copied may be creative, but it probably won’t solve your clients’ marketing challenges. Worse, it probably won’t work for them. For too long, copywriters or AEs have grabbed a spot, changed only the name of the client, put it on the air and watched it fail. How many more advertisers have to say, “I tried radio and it didn’t work,” before Radio finally teaches its people to write?

Today’s busy account executive rushes in on Friday afternoon, bangs out a spot in 10 minutes (or copies one from the RAB database), gives it to Production and then begins planning Monday morning’s explanation to the client of what went wrong. We are fools to think our average account executive is prepared to write radio copy.

We are in the business of words, but we do not study them. Functional illiteracy is the disease that’s killing radio.

Radio groups are spending fortunes on research to refine their programming, yet they spend nothing to learn how to make ads work. Commercials are the life-blood of our business. Doesn’t it make sense for us to study them? The answers are available, but most broadcasters don’t realize the nature of the problem: Closing the sale isn’t the finish line; it’s the start of the race.

Because of pressure to hit goals, today’s account executives sell schedules they know won’t work. In addition, illiteracy is not just a problem with AEs. Most sales managers, GMs, market managers, regional VPs and group heads don’t know how to write ads, either. We hide behind the idea that it’s Someone Else’s job. Hey, maybe when we locate the mysterious Mr. Someone Else, we can have him explain to Wall Street why we’re not hitting our numbers.

Mr. Wolfe slammed my backside with a paddle when he caught me copying because he knew that I would be less effective in life if I were a copycat. Likewise, Radio is getting its behind paddled, and its glowing red rear is its pathetic share of ad dollars in the marketplace. The difference between us is that I knew my beating came as the result of copying, but radio has never quite figured out why it’s being paddled.

9/06/04 Radio Ink Magazine. By B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

What Radio Needs Now


“I’m thinking about getting out of radio altogether and focusing on a new career.”

I said it and I meant it. It happened during a casual moment just a few weeks ago. I was boating across a lake in the Adirondacks with a prominent young executive from one of America’s largest radio groups. The occasion was my 50th birthday. The question had been entirely innocent: “What would you do if you didn’t have Radio Ink?”

My friend was stunned with my answer: “But I thought you loved radio.”

My response was honest: “I do, but I don’t feel I’m making a difference.”

“What about NAB? With Eddie Fritts potentially leaving in a couple of years, wouldn’t you take that job?”

“Unfortunately, I tend to say what’s on my mind often at the expense of my own business. That’s not what NAB needs. I’d be kicked out of Washington within a week.”

“What about RAB? Gary Fries won’t stay forever. Wouldn’t that be a natural place for you?”

“RAB has a big board with differing agendas. Some want it to be a small-market support organization while others want it to support only the big markets. Some want it to be a sales training organization while others think its only purpose should be promoting radio to advertisers. Besides, Fries needs a successor in their late 30s or early 40s, a person who will be perceived as young and vibrant.”

“What about the FCC? They’ll be looking for a new chairman soon.”

“I like to break rules, not make them. If I were chairman of the FCC, I’d probably reorganize it altogether.”

“What about us? Can we hire you?”

“Nothing really happens until a board of directors decides that the pain of staying the same is greater than the pain of change.”
“But radio needs you. You’re the conscience of the industry.”

Though I was flattered, and my ego was overly inflated for a moment, the discussion made me realize what it is that Radio really needs most: Young, passionate, irreverent voices that aren’t concerned about making enemies and are willing to question the status quo.

Are you willing to be one of them?

9/20/04 Radio Ink Magazine. By B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

The Buzz

Unless someone out there has been doing a really good job of keeping a major announcement quiet, I predict the buzz at this year’s NAB convention will be about Clear Channel’s “Less is More” initiative.

Will it catch on? Will it hurt the industry? Is it a Wall Street ploy? Will John Hogan lose his job over it? You’ll probably hear the rumor that Mark and Randall “slipped this one past Lowry while he was in the hospital.” Sadly, much of the buzz will come from radio’s ever-present drones explaining all the reasons “it can’t work.”

Every good thing is met with resistance; Less is More will be no different. The unimaginative, the cowardly, the backward and the small will cry out for solidarity against “the oppression of Cheap Channel, the evil empire.” How they think they’re being oppressed I don’t really know, but they can always spin it somehow.

A number of months ago, I wrote an editorial suggesting that we reinvent they way we sell and place commercials so that we:
1. reduce cluster lengths to keep people listening,
2. give advertisers a more favorable environment,
3. sell premium waterfront real estate by making the first spot in the break the most expensive, and
4. re-evaluate why :30s and :60s are priced the same.

Frankly, I think we should abolish :60s altogether and make most of our inventory :15s, especially if you believe, as I do, that Radio is a branding medium. A cluster of :15s sure beats a cluster of :60s and :30s. But it’s never going to happen if Radio backs away from John Hogan and leaves him to fight this battle alone.

John Hogan founded the “Less is More” initiative, and he had to sell it in every direction. So far, he’s been met with tremendous resistance from his own managers, who understand how hard it will be to do. If the initiative fails and the numbers go in reverse, we’ve probably seen the last of John Hogan. And that would be a shame.

Less is More is bigger than Clear Channel. It needs a commitment from all of radio.

The only issue I take with Clear Channel on this initiative is that it’s expecting too much too soon. Less is More is the right idea. It will work; it will change the industry and will powerfully benefit radio’s advertisers. But can it work in 2005? I doubt it. Clear Channel’s board may or may not see the results they need to see within the timeframe they consider to be reasonable. I hope they will be patient. Less is More will work, but it’s clearly a three-year, not a one-year, initiative.

If someone other than Clear Channel had introduced Less is More, the other groups would have immediately jumped on board, and the buzz at this year’s NAB would have been whether or not Clear Channel would commit to it.

Reader friend, we’ve known each other a long time, so I hope you’ll forgive me for asking what needs to be asked: Are you big enough to get past the fact that “your enemy” was the one who suggested this?

10/04/04 Radio Ink Magazine. , by B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

Have We Seen The Last Better Mousetrap?


The NAB exhibit floor was anemic. Vendors that have been radio-industry leaders for decades are pulling out of radio or going out of business altogether. It appears there soon may come a day when broadcasters are offered only a single choice in some product categories and no choice at all in others. Lack of competition increases prices and makes broadcasters vulnerable to lower-quality products and dismal service. When competitors disappear, bad things happen.

Competitors are disappearing because no one is buying anything. Budgets have been tight for too long.

When vibrant and innovative vendors are inventing new tools that allow stations to improve their quality, radio is on an upswing. When broadcasters try to outdo one another, everyone wins. The station wins. The listener wins. The advertiser wins. The vendor wins.

Right now, nobody is winning. What went wrong? Why is there so little innovation within radio’s vendor community today?

The answer is simple: Innovation is stimulated by incentives and competition. When incentives go away, innovation disappears. Wall Street’s pressure on broadcasters to perform financially has triggered a near-decade of relentless corporate cost-cutting. The result is radio with a look and feel reminiscent of Russian technology near the end of the Cold War.

Managers have been told to “make do, make it last,” until the average station is sending its signal from an exhausted, old studio to an antique transmitter held together with shoestring, baling wire and chewing gum. Traffic and billing are generated from a tired, old software system that sends a monthly invoice that whispers, “We’re out of touch — nothing new happening here. If you want innovation and change, you must look somewhere else.”

Exacerbating the problem is the fact that most big groups have standardized to one supplier in each product category, making group-wide purchases at prices that barely allow the vendor to survive. As a result, suppliers are forced to cut quality and completely ignore research and development. Sadly, they have no choice.

One vendor recently confessed to me that he was selling below his cost because he needed the cash flow to survive. I’m betting the big group that maneuvered him into the deal will soon be calling the company’s tech-support number only to be greeted by a recording that says, “We’re sorry, but you have reached a number that has been disconnected or is no longer in service.”

Hey, I know you have to “hit your numbers.” And I know you’ve been told “maybe next quarter” for the last 27 quarters. Even so, I encourage you — no, I beg you for the sake of our industry — to seriously consider making one or two long-overdue purchases NOW. If possible, spread the purchases to multiple companies to help keep them alive and competing. Increase your budget for capital expenditures in 2005.

If radio’s vendors don’t see an immediate increase in sales opportunities, you and I have seen the last better mousetrap in our industry.

10/18/04 Radio Ink Magazine. , B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

White Gloves And A Magic Baton

Roaring applause shook Symphony Hall as he strode to center stage and leapt to the podium like an Indy car driver hopping into the cockpit. Arms raised heavenward, fingers twitching on his baton like thoroughbreds in the starting gates, then a single down stroke of his white-gloved hand unleashed sounds that echoed through our souls. He was a great conductor.

But what if he suddenly rushed into the woodwind section, shoved the clarinet player aside, grabbed his instrument and began to play the part? Then with clarinet firmly in his teeth, what if he snatched the drumsticks from the percussionist and began thumping the tympani as he scurried to chastise the cello?

I know radio managers who conduct their orchestras that way.

An orchestra conductor would never attempt to play an instrument during a performance or be critical of a player in front of the audience. Conductors audition and hire the best players, rehearse them on the music, add a bit of their own interpretative style, and inspire everyone to do their best. They don’t play an instrument. How do you suppose a great conductor would respond if the concert hall owner suggested the music be played a little faster so he could squeeze a second matinee on the schedule?

Likewise, a manager should be an insulator between owners and employees, not a conduit between them. Good managers protect employees from the sticky, green stress that oozes like mud from the boardroom. They do not transfer it. When a manager begins to reflect the mood of the owner, the music is about to get ugly.

Great managers create great cultures and hire people who will fit into them. Then they quickly step out of the way, giving guidance rather than commands, leading those people rather than driving them. They manage individually, rather than managing everyone alike.

When a musician in an orchestra keeps hitting the wrong notes, a replacement is made quietly but swiftly. Great managers likewise know they can’t keep great employees if they retain weak ones, so they hire slow and fire fast.

The best managers, like great conductors, appear confident, invigorated and passionate throughout the performance. Like great conductors, they make it look effortless, always providing a great experience and a wonderful show.

Here’s a crazy idea: Why not invite the conductor of your local symphony to lunch and ask them to share their secrets of leadership? How do they get the players in step with each other; how do they handle squabbles or raise the bar? I honestly believe it would be a fabulous investment of your time. You up for it?

11/01/04 Radio Ink Magazine. B. Eric Rhoads

By | February 4th, 2005|Radio|0 Comments

How To Become Radio Again


I’m about to make noises like a dinosaur. I hope you’ll forgive me, but hindsight is 20/20, so I like to look backward before going forward.

I was a little kid in Fort Wayne when stereophonic sound began gaining momentum. I remember the day my dad brought home a state-of-the-art “stereophonic system,” along with every stereophonic recording that was available: a big box of beautiful music on clunky, reel-to-reel tapes.

Dad was excited as he gestured toward the left and the right speakers when different sounds emerged from each of them. It was the coolest thing I’d ever heard. A decade later, FM radio stations began broadcasting rock ’n’ roll in stereophonic sound. It was an Indianapolis station — WNAP — which finally gave me Rock in stereo. I’ll never forget those guys. I was excited, the public was excited, and once advertisers saw significant audience shares, they were anxious to hop on board.

Sirius and XM are rapidly gaining subscribers because they’re offering two things that are exciting and new. First, their experimentation with goofy, eclectic formats is repositioning broadcast radio as being “predictable and lacking variety.” Second, like computers and PDAs and MP3 players and cell phones, their signals are digital.

If ever you’ve heard me, hear me now: Every radio station in America must invest in HD radio today, while there’s still some interest among the receiver manufacturers. Remember when AM stereo came out? We delayed so long in adopting it that the receiver manufacturers finally lost interest and drove the last nail into AM stereo’s coffin? We’ll do that again if we’re not careful.

Even though it’s the essential first step, HD broadcasting alone would merely elevate us to the level of our competitors. What can broadcast radio offer as a selling point that would set us apart and energize America? Consider this:
1. Just about everyone has upgraded his or her home stereo system in recent years to include 5.1 Surround Sound.
2. The record labels are dying to find something that will get people to purchase records again.
3. If radio got with the big labels and convinced them to reissue the top songs in 5.1 Surround, and…
4. If leading stations immediately went digital and began a collaborative, nationwide radio campaign to “Surround yourself with 5.1 DVD RADIO,” people would get enthusiastic again.
5. It would be a brand-new experience for them, and we would have taken a giant step above everyone else.
6. There’s no reason we can’t do this. Nothing stands in our way.
7. I believe that if we don’t seize this opportunity, we’re nuts.

“You’re listening to WYOU in High Definition Surround.” Do this, and radio will become RADIO again.

By B. Eric Rhoads. Published in RADIO INK 12/06/04

By | February 4th, 2005|Radio|0 Comments