Let me answer that twofold.
In the past, we had this general criminal prohibition that could encompass any agreements that had an undue lessening of competition. We moved away from that. Those were the 2009 amendments. It was furthered through a very long process, if I may. Three expert reports were commanded by the commissioner at the time to get ideas of what exactly should be per se, with 14 years of jail term attached to that.
When we're saying let's compare to the U.S., the U.S. has been acting against no-poaching and non-solicitation since 2010 under civil actions. In 2016, they provided guidelines for professionals saying that the next time it's going to be criminal. They came up with their first criminal charge in 2020. This committee isn't aware of this, but it is in our letter: In the first trials in the U.S. for criminal no-poach and wage-fixing, they lost.
All we're saying is that it would be—