Evidence of meeting #31 for Access to Information, Privacy and Ethics in the 43rd Parliament, 2nd Session. (The original version is on Parliament’s site, as are the minutes.) The winning word was workers.

A video is available from Parliament.

On the agenda

MPs speaking

Also speaking

Melissa Lukings  Juris Doctor Candidate, Faculty of Law, University of New Brunswick, As an Individual
Jennifer Clamen  National Coordinator, Canadian Alliance for Sex Work Law Reform
Sandra Wesley  Executive Director, Stella, l'amie de Maimie
Clerk of the Committee  Ms. Miriam Burke

11 a.m.

Conservative

The Chair Conservative Chris Warkentin

Colleagues, I call this meeting to order.

This is the 31st meeting of the House of Commons Standing Committee on Access to Information, Privacy and Ethics.

I'd like to remind colleagues that today's meeting will be televised, and it's going to be available via the House of Commons website.

Pursuant to the motion adopted by this committee on Friday, December 11, 2020, the committee is resuming its study on the protection of privacy and reputation on platforms such as Pornhub.

Today we have three witnesses with us. We have Melissa Lukings, who is the juris doctor candidate, Faculty of Law, University of New Brunswick. We have the Canadian Alliance for Sex Work Law Reform, Jennifer Clamen, who is the national director, and we have Sandra Wesley, who is the executive director at Stella.

We'll turn it over to our witnesses. I believe we'll start with Melissa Lukings for an opening statement followed by the others.

Ms. Lukings, the floor is yours.

11 a.m.

Melissa Lukings Juris Doctor Candidate, Faculty of Law, University of New Brunswick, As an Individual

I am Melissa Lukings. I was born in Ontario in 1989—

11 a.m.

Bloc

Marie-Hélène Gaudreau Bloc Laurentides—Labelle, QC

On a point of order, Mr. Chair. There is an issue with interpretation. Since—

11 a.m.

Conservative

The Chair Conservative Chris Warkentin

Pardon me, there's a point of order. There is a problem with static.

We'll just check the translation.

I think it is fine now.

I apologize for the interruption. Please continue.

11 a.m.

Juris Doctor Candidate, Faculty of Law, University of New Brunswick, As an Individual

Melissa Lukings

I moved to Newfoundland in 2007, and then I moved to New Brunswick in 2018.

I have an undergraduate degree from Memorial University of Newfoundland in linguistics and psychology, and I'm working on my law degree, juris doctor, from the University of New Brunswick.

My background includes 13 years of lived experience in sex work. From 2008 to 2013, I was an employee at an adult erotic massage parlour in St. John's, Newfoundland that was called Executifsweet Spa. For four years I managed or operated but also worked at another erotic massage parlour, and that was called Studio Aura. I've also worked independently from 2018 to the present.

If we look at those dates, we'll notice something super-fun, and that is that I had been working in sex work since before the Bedford outcome happened. That started in 2008; the Bedford outcome was in 2013, followed by Bill C-36 in 2014, so there's some interesting overlap there.

Within those years of lived experience, eight years involve a degree of sexual exploitation, so again we're having some overlap here, and the exploitation was very interestingly related to cryptocurrencies, data mining and business development in Newfoundland and Labrador. I feel that my perspective is all the different sides—well, I haven't been trafficked—exploitation, certainly, and sex work as well.

My recent relevant volunteer experience includes Newfoundland and Labrador Sexual Assault Crisis and Prevention Centre; the Community Coalition for Mental Health, NL; the Schizophrenia Society of Newfoundland and Labrador; Safe Harbour Outreach Project; HardOnTheRock.com; Reproductive Justice New Brunswick; Save Clinic 554; SafeSpace London; and the Canadian Alliance for Sex Work Law Reform now.

My current relevant work experience is that I am a cybersecurity law researcher, so I'm particularly interested in dark web content, regulation, cryptocurrency and decentralization, all of that within the law of Canadian perspective sex work legal regulation research, and I've also just finished publication of a 10-piece article series on understanding Canadian cybersecurity laws with IT World Canada.

The perspective that I want to share is obviously one of decriminalization of sex work but also regulation of surface web content, the recognition of the differences between surface, deep and dark web content and the realities that go along with the legal enforcement of those areas.

Thank you.

11:05 a.m.

Conservative

The Chair Conservative Chris Warkentin

Thank you.

We'll turn to Ms. Jennifer Clamen.

11:05 a.m.

Jennifer Clamen National Coordinator, Canadian Alliance for Sex Work Law Reform

Thank you.

I am Jenn Clamen. I'm the national coordinator of the Canadian Alliance for Sex Work Law Reform. We are an alliance of 25 sex worker rights groups across the country, the majority of which are led by sex workers working in the sex industry. The alliance was created in 2012 as the means of getting sex workers' voices to people like you, to Parliament, as a means of building respect and legitimacy for the voices and the experiences of sex workers where we are otherwise ignored and not taken seriously.

Also, the alliance was really created as a mechanism for sex workers to get involved in the policies and practices that affect their everyday lives, and that's the work we do together.

That's where I want to focus my intervention today, on the ways and the duty of parliamentarians to take direction and leadership from sex workers who are really best placed to speak to any policy or practice that may regulate online sex work or online porn.

I'll start by saying that it's important—obviously we all feel that it's really important—to remain really critical of abusive and exploitive practices on the Internet, and more so for people who are targeted for violence. Sex workers understand this. We have been organizing for over 50 years against violence and abuse in the industry. It's why we started organizing. We didn't start organizing for the right to work in the industry. We started organizing against abuse and violence. For this reason, sex workers are the best placed to be at the centre of this discussion. Sex workers are mitigating violence all of the time in the context of criminalization and stigma that is perpetuated against the industry.

I want to talk about meaningful consultation and why it's so important, and also how to do it. We've been involved in so many of these parliamentary discussions, and people talk about consultation, and we get invited at the last minute, on a Friday evening to a meeting on Monday morning. Some people might not know how to do consultation, and that's okay, but we're here to explain how to do that as well. We want to teach you how to do that and hope that you're open to those learnings.

So far, your committee hearings have really promoted a set of values that have been extremely damaging for sex workers to watch across the country and across North America. Our alliance member groups, as well as individual sex workers across Canada and the States, have been pressuring for a seat at this table since day one of these hearings. On day one of these hearings, you all heard from Rape Relief as a means of framing the discussion. They framed it, not surprisingly, as one of exploitation; and that has been really clear to sex workers and really harmful to sex workers across the country.

It is made clear that sex workers are not welcome at this table and are not considered valued participants. We were told outright that this committee didn't concern us, and it hasn't been safe for sex workers to come and publicly testify as a result in this what we consider a hostile setting.

I want to talk about meaningful consultation, and what it means, what you need to do, and I'm happy to send this all in written form. Meaningful consultation is something we consulted our members on years ago, and we wrote it down for exact moments like this. Meaningful consultation means treating sex workers like experts on the impacts of laws related to sex work. Often the only people who are treated as experts in conversations like the ones happening in this committee are lawyers, academics, politicians, social workers and, in the case of this committee, people who don't work in the sex industry. So, sex workers are most affected by any regulation, and sex workers' perspectives need to be at the centre of your discussion.

Meaningful consultation also means proportionately weighing the consultation based on who is affected by the laws. Sex workers currently working in the sex industry are most affected and live the experience of criminalization and regulation every day, so their perspectives should hold more weight for all of you who are considering regulation.

Meaningful consultation also means scrutinizing who is considered an expert on sex work issues. Exodus Cry, Rape Relief, RCMP—it's a hard no on all of that from our end. How can any of these people explain to you how exploitation or violence happens in the industry when they don't work in it? They're merely providing an ideological perspective.

Meaningful consultation also means gathering experts by asking sex workers who their allied organizations and community groups are, where they access services. We've been trying to send you lists and lists of people you can speak to from day one, and unfortunately that's gone ignored—and I'm not just chastising you. Please see this as more than chastising you for what this committee hasn't done. It's really an invitation to open and change the way things are moving forward, so that any regulation or any policy moving forward is actually centring sex workers at its base.

Meaningful consultation also means accounting for structural barriers in consultations. This means considering anonymity for sex workers, who have the right to remain anonymous and have to remain anonymous; considering pseudonyms; or allowing them not to show their face. It means offering in camera or private face-to-face dialogues with sex workers and chosen supporters. It means ensuring that there's sufficient time in the lead-up to the conversations to allow sex workers to prepare for these moments of intervention. It means providing information in advance on the kinds of questions you're asking and the kinds of interrogations you're doing. It means making particular efforts to contact communities of more marginalized sex workers, such as racialized sex workers, indigenous sex workers, Black sex workers and trans sex workers. It means holding informal meetings in these kinds of conversations for sex workers who are marginalized, particularly by poverty, immigration status or indigeneity.

This committee has received briefs and written testimony from sex workers who have experienced violence in the industry, and this testimony outlines how violence happens and makes suggestions for ways to mitigate that violence. Every industry has violations. Industries that are criminalized and stigmatized have more, and we need to work to address them. The most basic premise here would be the inclusion, centring and leadership of people who are experiencing those violations. No other industry would create regulation without the input of workers.

This committee has the challenge of addressing exploitation that some people experience, without infringing on the rights of sex workers. The people on the front lines of this industry—sex workers—are best placed to help shape any existing or proposed regulation. Any approach that fails to consider their needs will harm sex workers. I promise you this. Sex workers are systematically ignored in policy that impacts our lives.

Consultation isn't an easy process. In 2007, the Canadian Alliance for Sex Work Law Reform held a consultation, over a year and a half, with our member groups and sex workers in our member groups to create a series of 54 recommendations for law and policy reform. It was a collective process to write those recommendations, and they are a clear rejection of criminal sanctions and other repressive measures of the industry, not based on ideology but based on the impacts of regulation.

Those recommendations are underscored by a series of principles that I want to share with you, because I think the committee could benefit from this set of principles. Based on the hearings so far and the ways that these conversations have been going—and we've been listening very closely—this committee really needs a dose of neutrality rather than ideology, and a dose of evidence. We want to share with you some of the principles that underscored our recommendations.

Selling or trading sexual services is not inherently immoral, harmful or a public nuisance.

Sex work does not inherently damage the physical or mental health of those who do it, and sex workers do not become unfit employees, parents, tenants, customers, clients or people who can testify at committees.

Stigma towards sex work and against sex workers is real and pervasive, and it's deeply ingrained in Canadian society and around the world. It contributes to harassment, discrimination, violence and abuse. It also contributes to bad policy, as we've been seeing in the discussions at this committee. Laws and policies and their enforcement often reflect and reinforce the stigma, or encourage or tolerate the abuses that flow from it.

Eliminating stigma against sex workers needs to—

11:15 a.m.

Bloc

Marie-Hélène Gaudreau Bloc Laurentides—Labelle, QC

On a point of order, Mr. Chair.

11:15 a.m.

Conservative

The Chair Conservative Chris Warkentin

Pardon me, Ms. Clamen.

We have a point of order.

11:15 a.m.

Bloc

Marie-Hélène Gaudreau Bloc Laurentides—Labelle, QC

I don't want to miss a single sentence of your testimony.

11:15 a.m.

National Coordinator, Canadian Alliance for Sex Work Law Reform

Jennifer Clamen

I understand. I have also sent you my brief.

11:15 a.m.

Bloc

Marie-Hélène Gaudreau Bloc Laurentides—Labelle, QC

The interpretation stopped working a few seconds ago.

11:15 a.m.

National Coordinator, Canadian Alliance for Sex Work Law Reform

Jennifer Clamen

I didn't hear what the member said.

What's not functioning? Is it the headset?

11:15 a.m.

Bloc

Marie-Hélène Gaudreau Bloc Laurentides—Labelle, QC

The interpretation is no longer coming through.

11:15 a.m.

Conservative

The Chair Conservative Chris Warkentin

I think it's not working on the English and the French channels. I was not getting the interpretation as well.

I just want to make sure that everyone's headset is plugged fully into their computer. There seems to be a significant amount of static coming through.

I just want to verify, Ms. Clamen, if your—

11:15 a.m.

National Coordinator, Canadian Alliance for Sex Work Law Reform

Jennifer Clamen

My headset is plugged in.

11:15 a.m.

Conservative

The Chair Conservative Chris Warkentin

Very good.

Mr. Fergus, I see your hand is raised. Do you have a suggestion?

April 19th, 2021 / 11:15 a.m.

Liberal

Greg Fergus Liberal Hull—Aylmer, QC

Mr. Warkentin, when you started talking, I didn't hear that noise, but I hear it now.

Ms. Gaudreau, do you hear the same thing?

When Mr. Warkentin was talking, I couldn't hear anything.

11:15 a.m.

Conservative

The Chair Conservative Chris Warkentin

Thank you. I've asked the technicians to verify where that static is coming from.

Let us try to get through this. Hopefully the technicians are able to identify it and eliminate it.

Ms. Clamen, we'll turn back to you.

11:15 a.m.

National Coordinator, Canadian Alliance for Sex Work Law Reform

Jennifer Clamen

Sure.

Hopefully you can hear me say that the irony of you not being able to hear me while I'm talking about sex workers not being heard is not lost. Hopefully that will give all of you a little smile for the day. Maybe you can't hear that.

Madame Gaudreau, you cannot hear me say it still? You can? You thought my joke was funny, fantastic.

I'll just continue on some of the principles that underscored our recommendations.

The last few are around how singling out sex workers and activities related to sex work for additional prohibitive or additional repression is virtually always harmful for people working in the sex industry. Some of the briefs that you received, particularly the one from West Coast LEAF and other partners, really outlined the evidence around that.

Any legislation or policy or repressive measure that you're thinking of right now should really maximize the autonomy of sex workers to be able to work as safely as possible in keeping with sex workers' human rights to safe working conditions, liberty, privacy, non-discrimination and dignity.

I'll finish up now, but there's been a lot of discussion around youth in this committee as well. There's been a lot of conflation of issues with youth, and exploitation, and sex industry, human trafficking; these words are being bandied about very carelessly. In our recommendations for law reform, we also took the time with the hundreds and hundreds of sex workers to talk about recommendations for youth. I also wanted to share those with you too, because our recommendations really stem from recognizing the agency of people, and that includes people under 18, and by agency meaning the capacity to think, and the capacity to make decisions in a given set of conditions that anybody is living on.

The entire focus on child exploitation and human trafficking in this committee has been completely overblown. That is not to suggest these things don't exist in real space and time, but they have been overblown with respect to the conversations in this committee. The framing of all content online as youth exploitation really undermines sex workers' ability to keep safe and makes it harder to address violence in the industry. When we see everything as violence in the industry, it's hard to understand when sex workers are actually experiencing violence.

The alliance's groups recommend the following principles with respect to understanding youth and any regulations that involves youth: a harm reduction approach that requires authorities to use the least intrusive approach towards youth with the emphasis on preserving community; and a recognition that repression, apprehension, detention and rehabilitation are often experienced as antagonistic and traumatic and often push youth away from supports rather than towards supports.

The alliance's member groups also recommend a reliance on existing laws rather than the creation of new laws, additional regulations and law enforcement measures that move people away from supports rather than towards supports.

I'll conclude by saying that last week we heard Bill Blair say what all sex workers were fearing as a result of this committee. We were assured it had nothing to do with committee, but we heard Bill Blair say that he was thinking of creating a new regulatory body that would be created for online content. We can't stress enough that more regulation is not the answer and that it will just actually harm sex workers and harm the industry in general with respect to sex workers' rights.

There's also the ongoing parallel work of Bill S-203 submitted to the Senate by Julie Miville-Dechêne.

On top of this there's the continual refusal of Parliament to decriminalize sex work, despite the evidence that regulation and criminalization harms sex workers.

Targeting Internet sex work during a pandemic is such an aggressive and violent move on your part and on the part of everybody who's considering regulation right now. The Internet has been a safe haven for so many workers who are unable to face the conditions of COVID like so many sex workers. Some sex workers, but not all, have moved online and have been able to support themselves this way, so it is important, now more than ever, to protect these spaces and to ensure that sex workers can continue to work without violence and exploitation.

If you want to know how to protect people on platforms like Pornhub, create a committee, sit down with people who actually post their content on Pornhub, sit down with sex workers and talk to us.

Thank you.

11:20 a.m.

Conservative

The Chair Conservative Chris Warkentin

Thank you.

Ms. Wesley, we'll turn to you now for your opening statement. You have seven minutes.

11:20 a.m.

Sandra Wesley Executive Director, Stella, l'amie de Maimie

Hi. My name is Sandra Wesley.

Normally, I would testify in French, because we are a Montreal group. However, due to interpretation issues and time constraints, I will do it in English.

I am very sorry; I apologize to Ms. Gaudreau and other francophones.

I'm going to continue in English.

However, I will be very happy to answer questions in French.

Before I begin, I want to be very clear that this committee's hostility toward sex workers will contribute to violence against us. The actions so far of this committee have been hostile and have contributed to harming sex workers. Any further repressive measures against sex workers will absolutely kill many of us. This is the level of seriousness that this has for us. Every demeaning and every dehumanizing thing that is said is heard loud and clear by every aggressor, abuser and exploiter out there.

We saw it recently in Atlanta, with a man who aimed to eradicate all massage parlours, all Asian massage parlours, and went and killed several women in a massage parlour. We see this time and time again. When our governments send out a message that they want to eradicate us, people take that into their own hands and find different ways of carrying out the government's mandate.

Stella is an organization by and for sex workers. We were created in Montreal in 1995. We represent sex workers. We are sex workers ourselves. We do not represent or defend the rights of third parties in the industry. We have no opinion on any specific company or individual who works around sex workers. We are not for or against. Some websites work very well for some people and can be the absolute worst for someone else. However, third parties are necessary for a lot of sex workers. Especially when we're working online, the average sex worker does not have the time, energy and knowledge to create her own entire website in terms of distribution or method of payment and processing. We need to work with other people.

Our community is very diverse and broad. It includes women who work in porn full time and part time; people who perform in videos with other performers; solo videos; videos they produce themselves or with third parties; women who post content on major platforms, such as Pornhub, or on smaller online communities or their own websites; women who do live work on camera versus pre-recorded videos; and people who work through all kinds of different models, including a lot of women who combine some online work with other types of sex work, in person or remotely. It is very important to not have a narrow view of pornography while you're focusing on one single website and to make regulations for one website while ignoring the massive diversity in the sex industry.

In terms of this inquiry, we can't make any assumption about why you decided to investigate Pornhub specifically. However, we can certainly witness the context in which this is happening. In December 2020 an article was published by The New York Times denouncing Pornhub specifically and making all kinds of claims about its content and procedures. To our community of women working in the sex industry, this type of sensational reporting is nothing new. It's been happening consistently over many decades. Anti-porn activists and anti-sex work activists have been active for a long time. This is how they operate. They try to come up with the most sensational, most dramatic stories and put them out into the media to get a reaction out of society. Over time, their overt arguments against porn in general have become less effective. The course has shifted to talking about violence and exploitation, trafficking or about the presence of youth in the sex industry.

These extremely emotional arguments are not necessarily representative of the true objectives of those groups or of the reality of sex work. It creates this big dichotomy where it positions people. You can either be against exploitation, and therefore against sex work and pornography, or you can be in favour of sex workers' rights. Somehow that's being construed as being supportive of that kind of exploitation.

I urge you, in your duties as members of Parliament who are sworn to work within the charter and not on emotion, to take a step back and look in a more objective and non-ideological manner at the situation and what led you to decide to spend so much time on the follow-up of a New York Times article that was written by a journalist with a very long history of exploitative reporting, of sensational reporting not just about sex work but about sexual violence in general.

This particular reporter also has been called out in the past for writing an entirely fabricated story [Technical difficulty—Editor] organization, which raised a lot of money for this completely fake organization. We know that this is not someone with high standards, and we know that this is someone who has been very willing to use his position as a reporter to push an anti-sex-work ideology.

You've also heard about who instigated campaigns against Pornhub, which you've actually heard from. One of those groups has a new name now. It's called the National Center on Sexual Exploitation. This is a recent rebranding of a group known as Morality in Media.

Morality in Media was founded in the early seventies or maybe late sixties. Specifically, their initial mandate was to eradicate all erotica literature from bookstores. They felt that it went against their Christian values. They are well known in the United States for such campaigns as boycotting Disney in the nineties because of their non-Christian content, wanting to eradicate the National Endowment for the Arts because they were worried that some artists might be making some sexual content, and boycotting Madonna and other pop artists. Ultimately, what they want is the eradication of all content from the Internet or society that does not meet their view of heterosexual, Christian, monogamous relationships.

A few years ago, seeing that this message was not getting them anywhere, they rebranded and focus now on this notion of sexual exploitation and human trafficking, because those are the buzzwords that get everyone from every party to stop and listen to them. Who instigated this? Obviously not anyone who has the well-being of women or sex workers at heart.

The other group, Exodus Cry, also rebranding over the past few years, is fundamentally a religious group with very violent views, specifically towards the LGBTQ2S+ community. Their goal is to also eradicate all sex that doesn't meet their Christian standard. They're violently anti-gay, violently anti-trans and violently against sex workers. They despise us and want to eliminate us.

Collectively, those groups obviously are not friends of sex workers. Starting an inquiry based on their assessment of a problem will never lead to anything positive within the community. Their only goal is to eradicate pornography.

You've heard also from some groups who brand themselves as feminists and who also have very ideological views. Instead of maybe a religious argument, they bring forward an argument based on their view of feminism, which is being increasingly marginalized and excluded from mainstream feminism. They're fundamentally anti-trans and anti-sex-workers, and they also share the religious groups' goal of eradicating us. They cannot be listened to when it comes to making our work safer or to tweaking anything in our industry to improve anyone's safety, because their goal is not that.

We've also seen a long history of repressive measures against sex work on the Internet, and repressive measures against the Internet in general, where sex work is the excuse to push that forward. In the nineties, when the Internet became a more common consumer-based thing, in the United States those same groups mobilized, because they wanted to essentially ban the Internet. The United States at that point was able to pass a law that included a section that makes websites not liable for the content on their platforms. This is the reason that we have the Internet as we know it today.

The first time any erosion of those rights happened was in SESTA and FOSTA, again in the United States, a few years ago. This created an exception to section 230, which now makes websites liable for sex work happening on their platforms. This has had devastating impacts. You can look up what sex workers have had to say about SESTA and FOSTA in the United States and elsewhere. It has led to a lot of deaths and a lot of violence. It's opening the door to further and further regulation of the Internet, to the point where all kinds of content gets captured under this increased censorship that we're seeing.

We've seen websites—for example, Tumblr, which had sexual content—simply choose to get rid of all the sexual content, which for the most part had nothing to do with sex work, just in case they were caught up in this. We've seen Facebook ban eggplant emojis and peach emojis. This is kind of funny on one level, but it is also an indication of how this liability for companies leads to a very drastic eradication of sexual content. It's making it harder for queer youths and for young people in general to get sexual education online because that also gets captured under pornographic content that should be eradicated.

I want to address a little bit about what sex workers actually need when it comes to—

11:30 a.m.

Conservative

The Chair Conservative Chris Warkentin

Ms. Wesley, I do apologize. You are now several minutes over the allotted time. I'm wondering if you could move to a conclusion so that we can allow for questions. I don't want to eliminate the members' opportunity to ask questions.

11:30 a.m.

Executive Director, Stella, l'amie de Maimie

Sandra Wesley

Sure. I will quickly go over the needs and the conclusion.

There are four broad categories of needs that we have identified for sex workers who work online and for anyone who uses the Internet for any kind of sexual content.

The first thing is income. We work in the sex industry to make money, so any policy that takes away our source of income is not feminist, is not helpful and is another form of violence against us.

In relation to security, we need to avoid being outed, so any policy that involves putting our legal name forward exposes us to all kinds of violence and is not okay for us.

As for privacy, we need to be able to operate without putting our legal information out there. We have heard from some people who have told you that they wanted, for example, a registry of everyone who owns a porn company, who has performed in porn or who accesses porn. That will eliminate every small porn production company and only leave some major companies that have the money required to hire lawyers and to have other people put their names on the company so that the performers are not outed, so that's extremely problematic for us.

We also need dignity. We need to be treated as valuable human beings. We need to have our work recognized and valued. Government needs to stop acting like we're political pawns to be just used whenever there's a need to rile up the population or to create a moral panic.

As long as this government wants to eradicate sex workers, as this government is doing through the Criminal Code when it comes to sex work, violence will continue, and there will be no solutions to make it safer for anyone, for people who are there willingly and for people who have their videos put online against their consent.

As sex workers, we're not willing to sacrifice our lives for your moral panic or your anti-porn project. We are demanding that our rights be respected, and we want our allies, who normally support sex workers' rights, not to forget everything they have learned over the years the moment we're talking about pornography.

11:35 a.m.

Conservative

The Chair Conservative Chris Warkentin

Thank you.

We will turn to our members' questions now.

We will start with Mr. Viersen for the first questions.

Mr. Viersen.