Team Code:

BEFORE THE HONOURABLE

INTERNATIONAL COURT OF JUSTICE

DEMOCRATIC REPUBLIC OF ANTARA

V.

VELAN KINGDOM OF RAVARIA

MEMORIAL FOR THE RESPONDENT

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 TABLE OF Contents

MEMORIAL FOR THE APPLICANT.................................I

TABLE OF CONTENTS.........................................I
INDEX OF AUTHORITIES......................................II
STATEMENT OF JURISDICTION.................................III
STATEMENT OF FACTS.......................................IV
STATEMENT OF ISSUES.......................................IX
SUMMARY OF ARGUMENTS.....................................X
ARGUMENTS ADVANCED.......................................1
PRAYERS FOR RELIEF..........................................8
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 INDEX OF AUTHORITIES

1. Charter of the United Nations

2. Statute of the International Court of Justice

3. International Covenant on Civil and Political Rights (ICCPR)

4. International Covenant on Economic, Social and Cultural Rights (ICESCR)

5. Council of Europe Convention on Cybercrime (the Budapest Convention)

6. Vienna Convention on Diplomatic Relations

7. Vienna Convention on the Law of Treaties.

8. South-West Africa Decolonization Cases (1949-1971) ICJ Reports 1950

9. South West Africa Cases (Ethiopia v. South Africa; Liberia v. South Africa),

(Second Phase), ICJ Reports 1966

10. Legal Consequences for States of the Continued Presence of South Africa in

Namibia (South West Africa) notwithstanding Security Council Resolution

276 (1970) ICJ Reports 1971

11. East Timor (Portugal v. Australia), ICJ Reports 1995

12. Legal Consequences of the Construction of a Wall in the Occupied Palestinian

Territory, ICJ Reports 2004

13. Corfu Channel Case (United Kingdom v. Albania), ICJ Reports 1949

14. Immunities and Criminal Proceedings (Equatorial Guinea v. France), ICJ

Reports 2018

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 STATEMENT OF JURISDICTION

The Democratic Republic of Antara instituted proceedings against the Velan Kingdom

of Ravaria, and in accordance with Article 40(1) of the Statute of the International

Court of Justice, concerning the Suthan Referendum, signed in The Hague, The

Netherlands, on the thirteenth day of September in the year two thousand twenty-one.

In pursuance of the above request the Velan Kingdom of Ravaria is submitting its

submissions.

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 STATEMENT OF FACTS

The democratic Republic of Antara and the Velan Kingdom of Bavaria are two
developed countries located in the Benthamin Peninsula. Antara has a population of
21 million across 152,000 square kilometers. Ravaria lies immediately to the south of
Antara. Its population is 12 million, and Its area is 121,000 kilometers.
The entirety of the Benthamian Peninsula was colonised by the Zemin Empire in the
18th century. During the colonial period, Zemin divided the Peninsula into three
administrative districts, with Antara to the north, Ravaria to the south, and Suthan
between the two. All of the significant population centers were in Antara and Ravaria;
Suthan was sparsely populated.
The population of Suthan began to grow steadily only in the 1920s, when large
deposits of gold, copper, and natural gas were discovered in the region.
In 1949, after the Second World War and the collapse of the Zemin Empire, both
Antara and Ravaria became independent States, with territories corresponding to their
colonial district boundaries: Antara a republic and Ravaria a monarchy Although
Zemin announced its desire to remove itself from the Benthamian Peninsula
altogether, the dispute between the two States was unresolved, and Suthan remained
under Zemin’s colonial control until 1962.
According to census reports from 1955, Velans were a minority in Antara,
representing 24% of the population, while 47% of Suthans and 85% of Ravarians
identified as Velan. Those percentages have not substantially changed to the present
day. On 1 February 1957, Vela was proclaimed the State religion of Ravaria.
The U.N. Secretary-General appointed the respected diplomat Aqeel Noorali to devise
a peaceful solution to what he called “the vexing situation on the Benthamian
Peninsula.” On 29 October 1962, Ambassador Noorali announced a breakthrough: an
agreement among Zemin, Antara, and Ravaria, signed in Singapore, according to
which Sutha would become a province of Antara for at least the next 25 years At the
signing ceremony, Ambassador Noorali described the Treaty as “a testament to the
parties’ respect for the rule of law, and a lantern that may light the way for the

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peaceful resolution of other disputes around the world.” All three parties ratified the
Treaty, and it was duly registered with and published by the U.N. Secretariat.
As required by the Treaty of Singapore, Antara amended Article 119 of its
Constitution to provide for the referendum. Under the amendment, if a majority of
Suthan residents voted for separation, a two-year transition period would commence,
at the end of which Suthan would become independent. Ravaria accepted that
provision as consistent with the Treaty.
Since 1962, relations between Antara and Ravaria have remained friendly. Both
nations became centers of technological innovation and entrepreneurship. By the late
2010s, Antara and Ravaria were both technologically advanced, with over 80% of the
populations of the two countries having Smartphone and access to high-speed
internet.
Pano is an online social media platform that allows internet users to message one
another, post and share content on their feed, live stream videos, and create private
groups of up to 10,000 users. By 2018, Pano was the most popular social network in
the Peninsula.
In April 2017, a series of cyberattacks hit police departments and hospitals across
Antara, resulting in significant losses, delays, and interruptions Professor Liam
Hunland is a citizen of Ravaria and a devout Velan, who has been a legal permanent
resident of Antara since he moved to Suthan Province in the 1980s. A tenured
Professor of Velan Theology at the University of Suthan, Prof. Hunland has for years
been a regular contributor to local and international media. By 2019, Prof. Hunland’s
personal Pano page acquired over nine million followers, the third largest contingent
in the Peninsula.
Prof. Hunland has long been an advocate for Suthan autonomy. In 2009, he became
affiliated with the SIP, and later that year, authored a new manifesto for the Party. It
had 10 of the 130 seats in the Suthan Legislative Council, and 12 of the 250 seats in
the national Parliament. By 2016, it had 55 seats in the Legislative Council, and 41 in
the Parliament.

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Between April and June 2020, Prof. Hunland posted over 600 public messages on his
Pano page. Rather than stressing the cause of Suthan independence, he focused on
dissatisfaction with the Antaran government generally, claiming that the COVID
restrictions were an unjust infringement of the freedoms of religion and assembly,
when some Ravarians attempted to evade the border closure, and local Suthans
gathered at the Shrine in groups of prohibited size, there were several arrests, but no
serious injuries were reported.
On 12 May 2020, the Internet Law and Security Assembly (“ILSA”), a global non-
governmental organization, issued an urgent report citing unusual activity on Pano.
The paper, authored by a team of cyber security experts, reported that over 180,000
new accounts had been registered in Antara in the first two weeks of May, far more
than the previous average of about 2,000 per week. The post was nonetheless shared
by Prof. Hunland with the caption: “Military law??? How far is this regime prepared
to go? Is a massacre in the planning stage?”
In August 2020, Antara held regularly-scheduled parliamentary elections, in which
Prime Minister Goldman’s party lost its majority. SIP’s vote increased nationally, with
the party capturing 52 seats. In his election-night speech, Prof. Hunland remarked that
the vote was “the first step toward true democracy; next comes the vote for a free
Suthan!”
A month later, the SIP put forward resolutions in both the Suthan Legislative Council
and the Antaran Parliament, proposing for the first time a referendum on Suthan
independence in accordance with the Singapore Treaty and Article 119 of the
Constitution. The votes on whether to go forward with the referendum were scheduled
for the week of 11 October 2020. A few days before that, Queen Sonia of Ravaria
attended the dedication of a new Velan house of worship in the Ravarian capital.
The Ravaria Times ran a banner headline on its front page: “Her Majesty Supports the
Velan Separatists in Sutha!” Asked for comment, the Palace spokesman declined to
respond. Shortly after the resolution was passed, SAD launched a grassroots
campaign to mobilize and register voters. The campaign included public posts to

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Pano, some of which portrayed the referendum as a religious fight.

On 11 January 2021, following repeated calls by users and political groups to remove
a number of Prof. Hunland’s posts because they were “spreading misinformation,”
“incendiary,” “inflammatory,” or “incitements to violence”. On 31 January 2021 Prof.
Hunland staged an outdoor rally in Suthan to encourage voters to go to the polls.
Despite early commitments by the organizers to hold the event online in compliance
with COVID-related restrictions, 7,500 people attended. Antaran police arrived to
break up the rally, and there were violent altercations. While it is unclear how the
violence broke out, 225 people were injured, and three people later died of their
injuries.
On 5 February 2021, the content moderation unit within the Antaran DPCA filed an
application for a content takedown and user suspension order to be issued against
Pano with respect to Prof. Hunland’s posts, in accordance with Section 5 of PACA.
The 74-page petition was submitted to the Federal Court of Lower Antara and
included detailed examples of what the DPCA alleged were inaccurate and misleading
statements of fact, both directly and by sharing the posts of others, on Prof. Hunland’s
Pano account. The legal representative of Pano in Antara immediately confirmed that
the company would comply with the order. Prof. Hunland’s account was suspended,
and all of his posts were removed from the platform.
Prof. Hunland filed suit against Pano in Zemin, seeking to have the restrictions set
aside, but the action was summarily dismissed, as under Zemin law social media
platforms are not liable for content moderation decisions. He also applied to an
Antaran federal court for an injunction against the suspension order, but the court
rejected the application for lack of standing.
On 4 April 2021, The Sydney Morning Herald reported that one week before the
referendum, DPCA’s cybercrime prevention unit had sought and received a court
order under Section 8 of PACA for the takedown of what it codenamed “Lunar
Botnet.” During a closed-door ex parte hearing, DPCA provided evidence to a judge

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in the Federal Court of Upper Antara that Lunar Botnet had infected over 30,000
devices over the three months immediately preceding the referendum. Acting on the
court order, DPCA discovered that the command-and-control server at the centre of
the Lunar Botnet was physically located in Antaran territory and was masking its
identity by operating through the “dark web.”
The DPCA proceeded to hack the server remotely, and to launch what it called
“Operation Moonstroke” from the server on 26 February 2021. Operation Moonstroke
disabled the botnet, removing thousands of “web shells” – segments of script
enabling. That day, Ravaria’s Ministry of External Affairs issued a note verbale to its
Antaran counterpart, expressing “dismay at what can only be described as a brazen act
of extraterritorial enforcement in clear violation of international law.” Such an
operation, the note continued, “As rhetoric escalated between the two countries, the
Foreign Minister of Zemin, a personal friend of Ambassador Walters, was able to
broker an ad hoc conciliation meeting between the Attorneys-General of Antara and
Ravaria, to discuss potential resolution of all of the issues that seemed to be in
increasingly heated dispute between the two countries. The recorder had captured the
following exchange between the Attorneys General that took place on 30 May 2021,
during the second day.
On 13 September 2021, the Parties requested that the proceedings before the Court

continue.

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 STATEMENT OF ISSUES

a. Whether the documents obtained in the search of the vehicle driven by Ms.

Walters and the recording from the conciliation meeting of 30 May 2021 are

admissible as evidence in these proceedings;

b. Whether Ravaria’s campaign of financial contributions and the dissemination

of misinformation intending to influence the outcome of the Suthan

referendum were in violation of international law;

c. Whether the Antara’s order suspending Prof. Liam Hunland’s Pano account

was consistent with international law; and

d. Whether Antara’s actions in taking down the Lunar Botnet, and the effects of

those actions on computers and devices in Ravaria, were consistent with

international law.

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 SUMMARY OF ARGUMENTS

1. The documents obtained in the illegal search of Ms. Walter's vehicle and
the 30 May 2021 recordings are inadmissible as evidence in these
proceedings.
Antara has indicated that it intends to rely on the documents contained in Ms. Walter’s
briefcase and the recording of the conversation between the Attorneys General.
Ravaria has objected to the admission of those materials into evidence.
So, it is clear that the Search on Ms. Walters was absolutely illegal and violation of
constitutional law.
Illegally or improperly obtained evidence is evidence obtained in violation of a
person's human rights or obtained in breach of the law or procedure – and it would be
unfair or unjust to use it.
As per fact we can easily understand that, the way Ms. Walter was searched, it was
fully unlawful. So, the documents & recording they got from her bag is no more
admissible evidence here.

2. Ravaria's alleged financial contribution and cyber operations in

connection with the Suthan referendum were consistent with
international law.
The right to self-determination which has been included in the International
Covenants on Human Rights and in the Vienna Declaration and Programme of Action
emphasizes that the right to self-determination is an integral part of human rights law
and it has a universal application. At the same time, the right of self-determination can
be said to be a fundamental right which is necessary for the enjoyment of other human
rights and fundamental freedoms which include their civil, political, economic, social
and cultural rights.
So, Ravaria's alleged financial contribution and cyber operations in connection with
the Suthan referendum were consistent with international law.

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 3. Antara's Order suspending Prof. Liam Hunland's Pano account was
consistent with international law.
On 11 January 2021, following repeated calls by users and political groups to remove
a number of Prof. Hunland’s posts because they were “spreading misinformation,”
“incendiary,” “inflammatory,” or “incitements to violence.” Therefore, Antara's Order
suspending Prof. Liam Hunland's Pano account was consistent with international law.

4. Antara's interference with computers and devices operating on Ravarian

soil, resulting from the decision to take down the Lunar Botnet, was in
violation of international law.

Acting on the court order, DPCA discovered that the command-and-control server at
the centre of the Lunar Botnet was physically located in Antaran territory and was
masking its identity by operating through the “dark web.” The DPCA proceeded to
hack the server remotely, and to launch what it called “Operation Moonstroke” from
the server on 26 February 2021. Operation Moonstroke disabled the botnet, removing
thousands of “web shells” – segments of script enabling remote administration – from
the affected devices. DPCA subsequently notified the affected internet service
providers and confirmed that, although it still could not verify the exact location of
the botmaster, roughly 20,000 of the hacked devices were situated in Antaran territory,
5,000 in Ravaria, and the rest in other countries (or their location could not be
determined).
So, in the end it stands as, Antara's interference with computers and devices operating
on Ravarian soil,resulting from the decision to take down the Lunar Botnet, was in
violation of international law. The Vienna Convention on Diplomatic Relations of
1961 is an international treaty that defines a framework for diplomatic relations
between independent countries. Antara's actions in taking down the Lunar Botnet, and
the effects of those actions on computers and devices in Ravaria, were consistent with
this convention.

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 ARGUMENTS ADVANCED

1. The documents obtained in the illegal search of Ms. Walter's vehicle and the 30 May
2021 recordings are inadmissible as evidence in these proceedings.

1.1 That search was illegal

An unreasonable search and seizure is a search and seizure by a law enforcement officer
without a search warrant and without probable cause to believe that evidence of a crime is
present. An unreasonable search and seizure is unconstitutional as it violates the Fourth
Amendment. Further, evidence obtained from the unlawful search may not be introduced in
court. This evidence is referred to as fruit of the poisonous tree. In Mapp v. Ohio, 347 U.S.
643 (1961), the Supreme Court held that exclusionary rule applies to evidence gained from an
unreasonable search and seizure.
At the invitation of the Zemin Foreign Minister, diplomats from Ravaria and Antara
continued to meet for another month in an attempt to resolve their remaining differences.
Those discussions led to an agreement that the parties would refer all matters in dispute to the
International Court of Justice, and for that purpose they drafted and signed this Special
Agreement.

Antara has indicated that it intends to rely on the documents contained in Ms. Walter’s
briefcase and the recording of the conversation between the Attorneys General. Ravaria has
objected to the admission of those materials into evidence.

So, it is clear that the Search on Ms. Walters was absolutely illegal & violation of
constitutional law.

1.2 The documents & recording is inadmissible evidence in this procedure.

Inadmissible evidence refers to any evidence that cannot be presented before a jury for one or
more reasons. While states often have individual rules regarding what evidence can be
presented in court, the Federal Rules of Evidence established as law in 1975 detail which

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evidence is generally admissible or inadmissible in court. Evidence may be considered
inadmissible in the following situations:

- The evidence was improperly obtained. This is a common reason for evidence to be
tossed out or otherwise considered inadmissible.
- If the evidence used in a criminal case was obtained by means that violated the
defendant’s civil rights, that evidence cannot be used in court. For example, if
evidence was obtained in an illegal search and seizure committed without a warrant,
that evidence cannot be used against them in court. This rule also applies to arrests
that were made without probable cause, as well as confessions that may have been
coerced.

- Illegally or improperly obtained evidence is evidence obtained in violation of a

person's human rights or obtained in breach of the law or procedure – and it would be
unfair or unjust to use it.

As per fact we can easily understand that, the way Ms. Walter was searched, it was fully
unlawful. So, the documents & recording they got from her bag is no more admissible
evidence here.

2. Ravaria's alleged financial contribution and cyber operations in connection with

the Suthan referendum were consistent with international law.

The right to self-determination of the people is also recognized under other international and
regional instruments. The Declaration of Principles of International Law Concerning Friendly
Relations and Co-operation among States adopted by the United Nations General Assembly
in 1970, the Helsinki Final Act adopted by the Conference on Security and Co-operation in
Europe in the year 1975, the African Charter of Human and Peoples Rights of 1981, the
CSCE Charter of Paris for a New Europe adopted in the year 1990, and the Vienna
Declaration and Programme of Action of 1993 also includes the concept of the right to self-
determination. Furthermore, the scope and content of the right to self-determination have
been elaborately explained by the United Nations Human Rights Committee.

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The right to self-determination which has been included in the International Covenants on
Human Rights and in the Vienna Declaration and Programme of Action emphasizes that the
right to self-determination is an integral part of human rights law and it has a universal
application. At the same time, the right of self-determination can be said to be a fundamental
right which is necessary for the enjoyment of other human rights and fundamental freedoms
which include their civil, political, economic, social and cultural rights.

All persons shall be equal before the courts and tribunals. In the determination of any
criminal charge against him, or of his rights and obligations in a suit at law, everyone shall be
entitled to a fair and public hearing by a competent, independent and impartial tribunal
established by law. The press and the public may be excluded from all or part of a trial for
reasons of morals, public order (ordre public) or national security in a democratic society, or
when the interest of the private lives of the parties so requires, or to the extent strictly
necessary in the opinion of the court in special circumstances where publicity would
prejudice the interests of justice; but any judgment rendered in a criminal case or in a suit at
law shall be made public except where the interest of juvenile persons otherwise requires or
the proceedings concern matrimonial disputes or the guardianship of children.

Everyone charged with a criminal offence shall have the right to be presumed innocent until
proved guilty according to law.

In the determination of any criminal charge against him, everyone shall be entitled
to the following minimum guarantees, in full equality:

(a) To be informed promptly and in detail in a language which he understands of the

nature and cause of the charge against him;

(b) To have adequate time and facilities for the preparation of his defence and to
communicate with counsel of his own choosing;

(c) To be tried without undue delay;

(d) To be tried in his presence, and to defend himself in person or through legal

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 assistance of his own choosing; to be informed, if he does not have legal assistance,
of this right; and to have legal assistance assigned to him, in any case where the
interests of justice so require, and without payment by him in any such case if he
does not have sufficient means to pay for it;

(e) To examine, or have examined, the witnesses against him and to obtain the
attendance and examination of witnesses on his behalf under the same conditions as
witnesses against him;

(f) To have the free assistance of an interpreter if he cannot understand or speak the
language used in court;

(g) Not to be compelled to testify against himself or to confess guilt.

4. In the case of juvenile persons, the procedure shall be such as will take account of
their age and the desirability of promoting their rehabilitation.

5. Everyone convicted of a crime shall have the right to his conviction and sentence
being reviewed by a higher tribunal according to law.

6. When a person has by a final decision been convicted of a criminal offence and
when subsequently his conviction has been reversed or he has been pardoned on the
ground that a new or newly discovered fact shows conclusively that there has been a
miscarriage of justice, the person who has suffered punishment as a result of such
conviction shall be compensated according to law, unless it is proved that the non-
disclosure of the unknown fact in time is wholly or partly attributable to him.

7. No one shall be liable to be tried or punished again for an offence for which he
has already been finally convicted or acquitted in accordance with the law and penal
procedure of each country.

So, Ravaria's alleged financial contribution and cyber operations in connection with the
Suthan referendum were consistent with international law.

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 3. Antara's order suspending Prof. Hunland's pano account was in violation of
international law, and Antara must therefore rescind the order.

On 11 January 2021, following repeated calls by users and political groups to remove a
number of Prof. Hunland’s posts because they were “spreading misinformation,”
“incendiary,” “inflammatory,” or “incitements to violence,” Pano released the following
statement: We are aware that certain Pano accounts, including some that seem to be
inauthentic, have been posting false or malicious content on our platform, concerning the
upcoming referendum in Sutha. Some posts shared by political leaders and other high-profile
users violate our terms of service and policies. Starting immediately, relying on user-
generated reporting and algorithmic analysis, our Civic Integrity and Election Team will flag
these posts, requiring users to click on an additional screen to see them. The notice will read:
“The Pano rules about abusive behaviour and deceptive content apply to this post. While it
may be in the public interest for the post to remain available, we advise users to act with
caution before clicking this screen.”Between 11 January and 1 February 2021, 240 of Prof.
Hunland’s posts and re-posts (63% of his total), were flagged by Pano.

On 31 January 2021 Prof. Hunland staged an outdoor rally in Sutha to encourage voters to go
to the polls. Despite early commitments by the organisers to hold the event online in
compliance with COVID-related restrictions, 7,500 people attended. Antaran police arrived to
break up the rally, and there were violent altercations. While it is unclear how the violence
broke out, 225 people were injured, and three people later died of their injuries. The police
response to the rally was broadly condemned in both Antara and Ravaria. Pano pages were
filled with tributes to the injured and deceased, many including calls for Suthan
independence. On his Pano page, Prof. Hunland denounced what he called “another Antaran
campaign to silence the voices of Velans.”He also reposted a photograph alleged to be of a
police officer beating a woman who seemed to be kneeling to pray at the rally, with the
caption “This is the fate that awaits us all. Freedom now!”

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Pano flagged the photograph as inauthentic.

4. Antara's interference with computers and devices operating on Ravarian soil,

resulting from the decision to take down the Lunar Botnet, was in violation of
international law..

The Vienna Convention on Diplomatic Relations (1961) reduced to three the categories of
diplomatic representatives, which are: (1) ambassadors and other heads of mission of
equivalent rank who are accredited to the host heads of state; (2) envoys extraordinary,
ministers plenipotentiary, and other representatives who are…Immunities adopted the Vienna
Convention on Diplomatic Relations to replace the 19th-century rules of Vienna and Aix. It
specifies three classes of heads of mission: (1) ambassadors or nuncios accredited to heads of
state and other heads of missions of equivalent rank, (2) envoys, ministers, and internuncios
accredited…In 1961 the UN Conference on Diplomatic Intercourse and Immunities adopted
the Vienna Convention on Diplomatic Relations to replace the 19th-century rules of Vienna
and Aix. It specifies three classes of heads of mission: (1) ambassadors or nuncios accredited
to heads of state and other heads of missions of equivalent rank, (2) envoys, ministers, and
internuncios accredited to heads of state, and (3) chargés d’affaires accredited to ministers of
foreign affairs. A chargé d’affaires ad interim is a deputy temporarily acting for an absent
head of mission.

Acting on the court order, DPCA discovered that the command-and-control server at the
centre of the Lunar Botnet was physically located in Antaran territory and was masking its
identity by operating through the “dark web.” The DPCA proceeded to hack the server
remotely, and to launch what it called “Operation Moonstroke” from the server on 26
February 2021. Operation Moonstroke disabled the botnet, removing thousands of “web
shells” – segments of script enabling remote administration – from the affected devices.
DPCA subsequently notified the affected internet service providers and confirmed that,
although it still could not verify the exact location of the botmaster, roughly 20,000 of the
hacked devices were situated in Antaran territory, 5,000 in Ravaria, and the rest in other
countries (or their location could not be determined).

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So, in the end it stands as, Antara's interference with computers and devices operating on
Ravarian soil, resulting from the decision to take down the Lunar Botnet, were in violation of
international law.

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 PRAYERS FOR RELIEF

Velan Kingdom of Ravaria requests that the Court adjudge and declare that:

a. The documents obtained in the illegal search of Ms. Walters’s vehicle and the

30 May 2021 recording are inadmissible as evidence in these proceedings;

b. Ravaria’s alleged financial contributions and cyber operations in connection

with the Suthan referendum were consistent with international law;

c. Antara’s order suspending Prof. Hunland’s Pano account was in violation of

international law, and Antara must therefore rescind the order; and

d. Antara’s interference with computers and devices operating on Ravarian soil,

resulting from the decision to take down the Lunar Botnet, was in violation of

international law..

AND/OR

Pass any other order that it deems fit in the interest of Justice, Equity and Good

Conscience.

AND FOR THIS ACT OF KINDNESS, THE APPLICANT AS IN DUTY-BOUND,

SHALL HUMBLY FOREVER PRAY.

Sd/-

(Counsels for Respondent)

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