The Magic of ELS Alums Mentoring Our Current Students

Last week, we invited Sophie Voigt (ELS, Class of 2023), now a transactional lawyer at Freshfields, to speak to our current ELS students about her career trajectory. Having gone straight from her LLB to working for a big firm in Germany, Sophie had a lot of insights, tips, and answers to questions that our current students had: She answered questions ranging from how she got her job, her favorite interview questions, how ELS prepared her for practice (if at all), what kind of profiles big firms are looking for in their applicants, and the path to becoming a solicitor in the UK even as an ELS grad (under their new Solicitor Qualification Exam) with two years of qualifying work experience (i.e. working as a transactional lawyer).

I am so proud to see ELS alums succeeding out in the real world, and I love it even more when they take the time to share their experiences to guide/mentor our current students.

I am not only grateful to Sophie, but last week alone, I reached out to other ELS alums like Kamila Sotomska (ELS, Class of 2017) and Annika Harju (European Studies & Law, Class of 2020) asking if they would be able to mentor a few current students, who are facing similar issues that they themselves expericed as students and they have been incredibly generous and kind in offering to help their juniors. Others like Eve Meurgey (ELS, Class of 2016), now working as an Associate at Herbert Smith Freehills, I’ve pretty much bothered every year, any time an ELS student has a question about qualifying in the UK. Much to my pleasant surprise, she has not blocked or ghosted my communications, allowing me to share her contact info with students so that they can ask her questions directly.

So a big special thank you to Sophie, Kamila, Annika, Eve, and to all the other ELS alums helping out current ELS students!! You are the network that keeps ELS going strong and we cannot thank you enough!!

UWC & UM Mock Trial of Nicholson v. The Chronicle Tides: A Wild Success (A Biased Reflection)

It was September 2022 when Sueli Brodin kindly introduced me to Maria Vatista as I was looking for volunteering opportunities at the United World College Maastricht. An in-person-meeting and a cup of coffee later (of what was once known as The Student Hotel), Maria and I started scheming assortment of ideas together. Later that week, she introduced me to Aidan Hollinger-Miles, a high school Junior at UWC, who was bursting with fireworks full of ideas and infectious energy. Following these introductions, I started visiting UWC frequently to meet up with Maria, Aidan, and his group, colloquially referred to as the Justice Club (although our WhatsApp group was more modestly called “Law Stuff”, but I digress). The Club organized a mock trial at the UWC in 2023, but Aidan - for his Senior year - wanted something even bigger and better. This was when the idea of doing a mock trial with the support of UM students and staff popped up.

Just last week (almost a year and a half after our initial cup of coffee together), we organized the mock trial of Nicholson v. The Chronicle Tides, a manifestation of Aidan’s vision, brought to life by Maria, the extremely competent and dedicated organization team from the Justice Club, other UWC students (serving as judges, jury members, lawyers, witnesses, plaintiffs, etc.), and UM students mentoring, guiding, and organizing the event.

The event, if I may say so myself, was an absolutely success. The UWC students were extremely engaged and very enthusiastic. Behind the scenes, Maria and the UM volunteers were greasing the wheels to make sure that everything went smoothly and accordingly (even running a “dress rehearsal” weeks prior to the main event to perfect - not only the substantive elements of the mock trial - but also the theatrical aspect of it all, from the lighting to the presentation of the exhibits on the big screen). We really couldn’t have asked for any better (even the catering from King George was insanely delicious).

Of course I am extremely grateful to Aidan, Maria, and the organization team as this would not have happened without them, but I would be remised if I did not give a specific shout out to the UM volunteers, who invested a lot of time and effort (even sacrificing their time to draft the IBL memorandum and exam prep) to be a part of this event. Ana, David, George, Leanne, Rozer, Sarah, Sreyas, and Ziya, thank you, thank you, and thank you!

As they say, there is no rest for the wicked, and so we now on to the next event, TEDxUWC Maastricht, where I’m hoping to loop Yama Saraj into this mix. It’s all about connecting good people, building a community together, and making an impact where we can, one small step at a time. I love this part of my job!!

UWC Maastricht and UM Collaborating on the Nicholson v. The Chronicle Tides Mock Trial

The Maastricht University Faculty of Law and the Maastricht Negotiation & Conflict Resolution Clinic are happy to host students from the UWC Maastricht conducting the mock trial of Nicholson v. The Chronicle Tides with guidance and mentoring from our students. Very happy for this collaboration and a special thank you to Maria Vatista for facilitating this joint effort!

Special shout out to our mentors & volunteers: Leilani Radaideh, Leanne Ligtenberg, David Čurilla, Rozer Kleige, Sarah Ennimer, Ziya Sterken💪, George Pliakas, Sreyas Susarla, Ana Dominguez Rodriguez, Reuben Ang, and Marc Bernhard. Grateful of your sense of community and service 🖖

Maastricht Mediation Clinic ➡️ Maastricht Negotiation and Conflict Resolution Clinic

Four years ago, Catalina Goanta and I passed on the duties of managing the Maastricht Mediation Clinic to Nikki van Dijk and Kristien Festjens, who graciously took over the clinic's reigns. As various other engagements have taken up their time more recently, I've agreed to take back the management of the clinic.

With this transition, I've also decided to broaden the scope of the clinic from just focusing on mediation to something a bit broader: The result is the formation of the Maastricht Negotiation & Conflict Resolution Clinic. For our first event as the MNCRC (organized jointly with our International Business Law Course), we are honored to host Eva Chan, who was recently elected as the Co-Chair of the Young International Council for Commercial Arbitration. We are very grateful to have Eva share her experiences, not only as an Associate at Skadden Arps, but as someone who is now leading the immense knowledge network that is the Young ICCA.

The Young ICCA is an organization that is opening doors for early-career-practitioners and students to the world of international commercial arbitration through skills training workshops, mentoring programs, and assortment of other admirable efforts, which we hope many of our students at the Maastricht University Faculty of Law will sign up for (especially after Eva's talk).

The Young ICCA is an organization that is opening doors for early-career-practitioners and students to the world of international commercial arbitration through skills training workshops, mentoring programs, and assortment of other admirable efforts, which we hope many of our students at the Maastricht University Faculty of Law will sign up for (especially after Eva's talk).

Lastly, I would also like to extend my gratitude to Catalina, Nikki, Kristien, Mardoeka Christensen and Monique Benning (formerly with Stichting Trajekt), who made the MMC possible. I am also very thankful to all of the people who have participated in our events and clinical trainings over the last ten years. You know who you are. I hope that as we attempt to grow our MNCRC community, you will continue to be interested in our ongoings. Mahalo nui loa!

Being a Foreigner in The Netherlands Now

The arc of the moral universe is long, but it bends toward justice.
— Martin Luther King Jr.

I remember this doom and gloom feeling from back in 2016, right after Donald Trump won the US Presidency. Having voted for Hilary Clinton that year, I was not only disappointed, but horrified by what Trump’s victory would mean for people like me (i.e., a minority). Reading the news and the dreadful speculations of what Trump would do in office became an agony-inducing, traumatic experience (so much so that I stopped reading the news for about 3 years). I remember asking my PhD supervisor very soon after that election whether I could stick around in Maastricht when I was done with my PhD. Even as a foreigner, I felt more safe and more accepted in The Netherlands than I did back home, or at least I did back then.

Last night’s election in The Netherlands - and PVV’s commanding victory - brought back remnants of this foreboding feeling. So much so that it immediately made me feel less comfortable being a foreigner in The Netherlands. However, having experienced this feeling once before, my despair has been - so far - less apocalyptic. I find some comfort in knowing that politics, more often than not, is a process of perpetual oscillation. At least in most democracies, parties and politicians will rise and fall at the whim of its citizens. While for the time being, many Dutch citizens have opted to support Geert Wilders (it’s either that or they could no longer tolerate what the VVD-led coalitions were peddling), this phase too shall pass. As they say about the weather in New England, if you don’t like it, just wait a few minutes.

Behind this cognitive bravado though, I am actually quite shaken up by the thought of Wilders becoming Prime Minister (even though it would be his democratic right to be one), as I am a foreigner living on foreign soil with a government that is increasingly hostile towards outsiders (Timmermans’ post-election speech, while nice, was not very reassuring). Nevertheless, given that I teach courses that advocate for empathy-building and communicating (even) with people that we disagree with, I am actively trying to do my utmost to rationalize this current situation: For example, I try to see (most) PVV voters’ decision, not as a personal attack on foreigners, but as a manifestation of their frustration for having had their voices slighted for too long by the majority. After years of Mark Rutte and the VVD holding the reigns, a large percentage of the Dutch population wanted something different. Add to that, a relentless increase in their costs of living, a terrible housing crisis, and the perception that their government was putting their interests behind that of others, these voters just wanted the status quo to change. Even if that meant voting for an extreme-right, nationalist party with a leader that wants The Netherlands to ban the Koran and to leave the EU. This was a vote - however myopic - intended for self-preservation, using foreigners and migrants as scapegoats for their woes. As they say in relationship psychology, “hurt people, hurt people” and this, I think, is what we are witnessing.

I also think this situation is a perfect manifestation of what Paul Bloom describes in his book, Against Empathy, as the circle of empathy and the limits thereof: We, as individuals, often exhaust a lot of energy taking care of ourselves and those close to us, but less on those that are outside of our immediate circles of empathy. Wilders’ promise for the Dutch to “get their country back” and to stop the “asylum tsunami” is not only a dog whistle to galvanize an anti-immigration movement, but a misguided move towards making the Dutch circle of empathy smaller. While some may not see the immediate problem with the idea of only looking after their own, Martin Niemöller’s poem, First They Came, serves as a haunting reminder of why this isolationist approach never really works out in the long run.

So this is where I find myself: my rational mind at odds with how I feel. Today, while dropping off my son at school and going to the library with my daughter (both Dutch citizens), I couldn’t help but to wonder which of the people I came across in the city voted for PVV (which in Maastricht is one in every four eligible voter). My rational mind would say that these are not bad people. They are hurt too. They just want self-preservation and protect their loved ones. But my timid heart wanders and whispers into my ears, “they probably don’t like you” - or worse - “they might bully your kids because they look like outsiders” and I find myself scared and worried. So I am hurting. But somehow, I have to make sure that I don’t feed into the cycle of hurt. The problem is, I’m not sure if I can. I don’t know if the weather will change quickly enough. But while I wait for my rational mind and how I feel to be more in alignment, I’ll continue to take my Dutch classes and try to pretend that I am not-so-foreign by humming Sinterklaas songs while I cycle around the city on my bakfiets. Just in case.

Our Career, not as a Ladder, but as a River

Last week, I got to host Prof. dr. Christine Neuhold (the Dean of Maastricht University Faculty of Arts and Social Sciences) for the Maastricht Young Academy’s Growing Up in Science event. She shared with us her story of resilience, finding joy in what she does, and much more. While there were many aspects to her story that I found inspiring (i.e. "color the cow green"), I was particularly moved by her idea, not to see our career in terms of a ladder for us to climb up or down, but as a river. Our career is not something linear. Instead, like a river, it weaves and flows, branching out at times and merging together at other points. Thank you again Christine for all your hard work as a Dean and for sharing your motivational words with us!

Re-defining Masculinity (Again and Again)

“When women are depressed, they eat or go shopping. Men invade another country. It’s a whole different way of thinking.”
— Elayne Boosler

According to the American Psychological Association’s 2018 report, perpetuation of “traditional masculinity” - or toxic masculinity - is harmful, not only to those who are on the receiving end of its manifestations, but to those that display it. No big surprises there. Suppressing one’s emotions, having to be “hard” at all times, and displaying a “tough-guy” behavior (e.g. aggression and violence) when confronted, not only sound antisocial and unpleasant, but quite unhealthy, if not dangerous.

While I would never label myself as being “hard” or a “tough guy”, I never really learned how to express or talk about my feelings very comfortably growing up in Japan. As a kid, I always had to put up a facade of conformity, especially when in public, which meant be quiet, be respectful, and don’t bother anyone with your problems (it’s very cliche, but true nevertheless). It took me until I was in my mid 30s to first see a therapist, who had to (and still is) teach(ing) me, what feelings feel like and how to honestly answer that annoying question of “how are you feeling?” (apparently, “I’m ok” is not a feeling). All of this is to say that I am not an expert on masculinity, but am quite curious about what being masculine means today. 

While it is quite easy to villainize toxic masculinity and call out idiots like Luis Rubiales (unfortunately, his name can easily be replaced by numerous other candidates so feel free to insert your own man here), I am not entirely sure where bad masculinity ends and good masculinity begins. For example, the Bible - in 1 Corinthians 16:13-14 - advises men to “[b]e watchful, stand firm in the faith, act like men, be strong. Let all that you do be done in love”, which feels, perhaps rather obviously, patriarchal and overly religious (not really my cup of tea). For those of us less pious, there are more secular attempts to define masculinity through mnemonics like the “3Ps of masculinity”, which guides males to be providing, protecting, and preparing. Perhaps less antiquated, but still feels slightly awkward due to the lingering sense of paternalism.

Whichever definition one subscribes to, perhaps the discomfort that comes with speaking about masculinity today is due to the unavoidable reality that masculinity has - at least recently - garnered a lot of negative attention (and hardly any good ones): #MeToo or #SeAcabó are obvious movements that shed light on and attempted to thwart the horrific behaviors by men perpetuated against women. Even away from the more salient news articles, masculinity has been attributed as one of the major causes of high crime rates (as men are are more likely to commit violent crimes than women) evidenced by how “men are overrepresented in prisons” or why sustainability initiatives fail (because “men resist green behavior as unmanly”).

Some may feel that as a result of the aforementioned #MeToo movement and various perpetrators being caught and excommunicated from civil society, things have gotten better (although the Rubiales incident would suggest otherwise). Thanks in part to the popularity of authors like Brene Brown and Esther Perel, even men are now talking about being more open and being vulnerable. In other words, it has become more acceptable for men to not be so masculine (at least in the traditional sense) relative to some decades ago. However, this new, more vulnerable and emotional version of masculinity is not without its own problems as well. This can be evidenced by the emergence of “petulant vulnerability”, which is when one “uses the language of vulnerability as a cudgel… feign[ing] emotional fragility as a means of retaining power.” So perhaps in some ways, things are getting better, but in other ways, not. 

This brings us back to the central question of where bad masculinity ends and good masculinity begins. In sum, toxic masculinity is bad. Petulant vulnerability is bad. Patriarchy is bad. Men trying to cling on to power and dominance is bad. All of which begs the question of what is good masculinity then?! And here, I am still not entirely sure and am slightly reluctant to offer a thought of my own for the fear of being entirely wrong. Nevertheless (hello vulnerability), I think masculinity is kindness. It is being able to create a sense of belonging for others without being (overly) paternalistic about it. It’s about trying to help those in need when asked for an assist. It’s about trying to talk to my kids about their feelings and sharing mine with them (even when it is very unflattering). It’s about doing household chores without feeling like I’m entitled to compliments and praise. It’s about knowing that I don’t really know and being open to listening and learning, knowing that things will change tomorrow. Maybe, and just maybe, being masculine could even mean that when we are feeling down, we don’t go invade another country, but we go eat instead? 

Curious what masculinity means to you.

Is There Room for “Unreasonable Hospitality” in Education?

Over the summer, I managed to take small breaks from work, traveling to Belgrade and Rome with friends and going camping with my family in Rheeze (a place up north in The Netherlands, where it rained for most of the time while we were there). I’m slowly getting ready for the upcoming school year by “micro-working” to psych myself up for the bump and grind of another season in academia; and as I do so, one of the books I read over the summer is giving me a lot of food for thought: Will Guidara’s Unreasonable Hospitality.

Full disclosure, I am a huge sucker for food-related books and TV shows. The first book that fish-hooked me into this genre was Anthony Bourdain’s acclaimed autobiography, Kitchen Confidential (may he rest in peace). I remember simply falling in love with how restaurants – especially the high-end ones – operated. The chaos and madness behind the pristine elegance. The fiery passion of the chefs to perfect their craft and their relentless dedication bordering on torment and psychosis. These days, anytime I need a jolt of inspiration or crave examples of explosive creativity, I go through Massimo Bottura’s Never Trust a Skinny Italian Chef. I love watching shows like The Chef’s Table or The Bear and find myself getting immersed in their world and I just can’t get enough of it.

Will Guidara is not a chef, but one of the most renowned restauranteurs in the world, who owned and operated Eleven Madison Park together with the James Beard Award winning chef, Daniel Humm. As such, Guidara’s book is not about cooking, but is about the business of running restaurants, what hospitality is, and how to create a culture and the team to become the best in the world at something. As such, the book is more about management philosophy than it is a cookbook or a chef’s tell-all. Nevertheless, I found his book to be absolutely captivating and thought-provoking.

The book also hit me on a personal level, because I’ve always loved to host and entertain people, to prep meals for hungover friends, or make Christmas dinners for students that couldn’t make it home to their families. I took pleasure in catering to their needs by paying attention to their subtle gestures and listening to what they were saying. I attribute this tendency to me growing up in Japan and being inculcated with practice of omotenashi, a kind of hospitality where the host pays attention to every detail and anticipate the needs of their guests (although admittedly, my sense of omotenashi has become rather dull since moving to the Netherlands as I’ve been told that this kind of hospitality is “too much” for the Dutch, but that is another post all together).

Without mentioning the word, Guidara essentially talks about omotenashi in his book. About how going above and beyond and “caring is cool” and the importance of making people seen and welcomed. As he notes, there is “nobility in service” and in everything that they do, there is intentionality and purpose (i.e. to amaze their customers and to make them feel valued). To create the world’s best restaurant, Guidara had to cultivate a strong and cohesive team and a culture to promote excellence, curiosity, and a sense of purpose and the book details this laborious process.

While restaurants and universities may not have much in common at first glance, I see a lot of overlapping similarities: For example, award-winning restaurants not only offer dishes prepared using quality products and impeccable cooking techniques that fuse together to create mastery of flavors, but call for attentive service and a level of hospitality that makes their customers feel unconditionally welcomed and heard. Similarly, it is not enough for universities to just teach up-to-date materials and impart relevant knowledge that prepares students for employment and society at large (the meal), but how we teach and how we connect with our students (the service) is just as important.

When I see new teachers, I sometimes see them fall into the trap of focusing too much on the meal (i.e. just trying to learn the materials that they have to teach) without paying enough attention on the service-end (i.e. listening to the students, paying attention to their needs, and connecting with them at a more human-to-human level).  

Of course there are stark differences too between a restaurant and a university. The biggest difference being that we – as teachers – are not here to host the students as if they are customers at Michelin-starred restaurant, serving their every wish and whim. At times, we have the duty to impart difficult lessons and give them challenges that help them grow. From time to time, we even have to let them fail. Nevertheless, what I take away from Unreasonable Hospitality is the thought that there must be a way – without over-pampering or coddling the students – to make them feel heard and be offered a learning environment where they feel a sense of belonging. In other words, how can we incorporate various aspects of unreasonable hospitality into our education? In finding a way to do so, I truly believe that we can transform an ordinary classroom experience into an extraordinary one.

Finding Inspiration (in the Usual Places)

I had the great fortune of joining the Sustainable Global Economic (SGEL) Law Summer School this week, where I got to ride on the wonderful Ivana Isailovic's (UvA) generous coattails to present and discuss the Achbita case with a group of inspiring PhDs and early career researchers. The entire event, which included (but definitely not limited to) the likes of Corinne Blalock (Yale) talking about Law & Political Economy or Phillip Paiement (Tilburg) discussing climate litigation, was an incredible learning experience to say the least. What inspired me the most though was witnessing these early career researchers (and soon-to-be-if-not-already star scholars) share their thoughts and insights with one another with such enthusiasm and vigor.

The wonderful participants of the SEGL Summer School. Me in the back standing on two chairs.

For some time now, I’ve been making my research somewhat secondary, prioritizing instead an increasing assortment of “other” tasks (from parenting to teaching and taking on various admin and organizational tasks). While I’ve managed to churn out the bare minimum amount of publications to keep me in the game, I was not attending conferences and interacting with the research community enough (at least not in a very meaningful way). Almost to the point that I felt quite behind on some of the developments that have transpired in the legal/academic world during my hiatus and I felt somewhat insecure about getting back into it.

The kind invitation by Ivana to teach in this summer school, where I got to experience joy and enthusiasm about conducting research and disseminating/hearing theories and legal narratives once again was an utter delight that helped me shed my insecurities. The participants were discussing ideas and exploring sometimes provocative thoughts with the intent to understand and to learn from one another. I am particularly grateful of Debadatta Bose (UvA) and Barbora Hnatova (Charles) for entrusting me with their draft papers for commenting and to Andrea Leiter (UvA) for allowing me to crash her workshop, where I got to hear ideas from João Telésforo (São Paulo) and Nevena Jevremovic (Aberdeen).

As I reluctantly enter the “middle age” stage of my career with all the baggage and pressures that come with it, I felt rejuvenated by the vitality of this wonderful group that joined us from all corners of the world. While I am still not sure whether I will make research the primary part of my job (as I am much better with the other facets of this job), with this renewed sense of purpose and excitement for research and making new discoveries, I hope to spend some time over the summer catching up and reengaging with my research, which I had decided to put on hold some time ago. Thank you Ivana and to all the participants of this wonderful event for your camaraderie and for your inspiration! I am humbled and motivated.

The Dutch Internationalisation Debate, Generative AI Models & English as a Competitive Advantage?

For those in Dutch academia, a divisive topic that has been dragging on for sometime has been the attempts by various Dutch politicians to curb the influx of international students flocking to Dutch universities and to require Dutch to be the main language of education.

The likes of Independent MP, Pieter Omzigt, have staunchly argued that it is the legal obligation of the universities to teach in Dutch and any deviation from that (e.g. to teach in English) is something that is permitted only in “exceptional cases.” As things stand, he resented that there are too many international students and to many programs being taught in English, much to the detriment of Dutch students and taxpayers. Those in support of the curb and those against have been vociferously making their arguments: Minister of Education, Culture and Science, Robbert Dijkgraaf, for example, cited to preventing over crowding the classrooms, reducing the already high workload for the teaching staff, and resolving the congested housing issue as some of the arguments in favor of the curb, while those in opposition like the Dean of University of Amsterdam’s Faculty of Social and Behavioral Sciences, Agneta Fischer, argued that contact with foreign students greatly benefit their research and education.

We are convinced that curbing internationalisation would harm not only the development of universities, but also the social environment in the regions in which they are based. It would also have an impact on the future of Dutch students, many of whom consciously choose an English-medium study programme and an international study experience with a view to their future professional field. To us, all this seems clear and logical.
— Rianne Letschert, President of Maastricht University

On a personal level, I think it makes sense for those that live and work in the Netherlands to learn Dutch and for the Dutch universities to adopt some sort of an admissions framework that limit the student intake and to do some quality control (which is a rather unpopular idea around these parts of the world) to alleviate the problems raised by Minister Dijkgraaf. What I want to introduce into this discussion though is a concern that popped into my head as I’ve been trying to ask ChatGPT the “right prompts” on assortment of tasks (and there are indeed right and wrong ways to do this): How does this issue of curbing internationalization intertwine with the growth of generative AI in education?

Image produced by Dall-E with the prompt “students using laptops in van gogh style”

While ChatGPT (currently) supports more than 85 languages from Awadhi to Vietnamese, the OpenAI website is only available in English and they admit that their “models (e.g., GPT-3, 3.5, and 4) are optimized for use in English.” Many of the models are “robust enough to generate good results for a variety of languages,” but it appears that those using generative AI in English has a (slight?) competitive advantage (at least for the time being). We are still at the nascent stage of all this, where even when promoting ChatGPT in English, there are various limitations: While it is more than capable of drafting a decent - albeit generic - recommendation letter, it still can’t write columns for me even in English (at least at a level that I find convincing or satisfactory). However, I suspect that this will soon improve, and as our use and reliance on generative AI continue to grow, a slight competitive advantage earlier on could grow into giant leaps down the line. So in this context, I respectfully disagree with MP Omziegt, who believes that adhering to Dutch as the operating language of universities (and thus following the law) comes with benefits, sans much costs.

People like saying that generative AI is already changing the way we work and to deny this reality, is to risk being left behind. Given the competitive advantage of knowing how to prompt these models correctly in English (as that is the language these models are optimized for), I worry that for the Dutch politicians to disincentivize Dutch universities from operating in English at this very juncture could be detrimental and short-sighted. This move, which carries similar nationalistic sentiments to Brexit, could potentially bootstrap us in the race to remain academically competitive (both in research and education) relative to institutions that enable programs in English to thrive unhindered. Of course, the debate of curbing internationalisation is a very complicated one and this is just a singular issue. Nevertheless, I believe it to be an important one, worthy of more consideration: perhaps as it always has been, English is our lingua franca, but in a world proliferating with generative AI models, English is potentially more than that, as it could be the key to potentially ensuring our future success as well. To disregard this possibility, may come with heavy costs.