Hoping for other companies to bring anti trust suits against Apple and a judge forcing it to change. Apple shouldn’t be able to hold on to their iphone customers on their purchase of other Apple products. AirPod or beats approach is fairer. Apple Watch not so.
Beautiful is that we will be able to see how harmful is for Consumers!
next step: right to repair & etc ! I want to be able to change the battery on my iPhone, the memory on my Mac Mini and etc. !
you mean like I buy a car from Mercedes Benz but I have the freedom to put whatever has and repair it wherever I like? I’ve never understood why everyone thinks that Apple still owns the device you purchased?
Not the device. Apple stills owns iOS, the app store, AKA the ecosystem that the device utilizes.
Allowing links to external developer stores is fine. I would bet most mainstream users will opt for Apple's App store for convenience sake rather than saving 10-30% on an App. I wonder, will the AppStore auto update system be supported on external purchases? Or will the purchaser have to revisit the external site to get updates. Also surely the unsubscribe process for third party purchases will super simple <sarcasm> Time will tell if store security, price and convenience will have a material impact on Apple's bottom line.
Problem is, some developers won’t give customers the option to pay via the App Store. They might take all in-app payments only via their external payment gateway. And there will be an opportunity for someone to be that gateway outside the App Store for all iOS developers who want to take advantage. A third-party payment gateway could slide in under the 30 or 15% Apple commission with a 10%, or 5% commission for handling transactions. This will be great for developers, but will leave Apple with nothing for its work creating and maintaining the App Store, it’s work testing apps, it’s costs to host and provide bandwidth to download apps, and it’s efforts to design, develop and maintain the 150,000 APIs and associated developer tools. Well, except the $99 developer fees. Not sufficient to cover costs I’d guess.
Apple could always charge developers for bandwidth required to distribute their apps. If nothing else it would solve the issue of app size bloat.
I'm not sure this ruling will hold up under appeal. If the App Store isn't really a monopoly, why would Apple be disallowed from anti-steering clauses that are standard practice for web retailers and online sellers?
There was no ruling on whether the AppStore was a monopoly, or having any other antitrust/anti-competitive issues. This judge's ruling very narrowly addressed only a very narrow segment "the mobile gaming transactions market" which she defined as the relevant market. The headline infers a whole lot more to it.
Nice spin. The mobile gaming transactions market is the single largest portion of The App Store. If you can’t prove Apple is a monopolist in their biggest and most profitable segment you’re never going to convince anyone they are a monopolist in any other area.
This ruling might as well have said the entire App Store isn’t a monopoly.
Typical for what? Calling out your usual BS posts? The more pertinent text from Judge Rogers was:
“Given the trial record, the Court cannot ultimately conclude that Apple is a monopolist under either federal or state antitrust laws. While the Court finds that Apple enjoys considerable market share of over 55% and extraordinarily high profit margins, these factors alone do not show antitrust conduct. Success is not illegal.”
Which is exactly what I’ve said all along. Being big and successful (and even a monopoly) isn’t illegal. So even IF Apple was declared a monopoly, it’s still not illegal. Apple can’t be punished for being wildly successful. They have to do something illegal, and there’s only two choices regarding antitrust law in the US:
- Doing something illegal to get to your market position. Buying up competitors or undercutting them on prices until they go under are two classic examples. - Doing something illegal after you gain market power. Like increasing prices or adding onerous terms to you customers knowing they have no other choices in the market.
Apple has done neither. Although they were found to be in violation regarding anti-steering, it’s irrelevant to the discussion of being a monopoly simply because Apple has always had these rules in place, long before they became as large as they are. So it’s an infraction, but nothing to do with Apples market position. Had Apple tried to add these rules AFTER becoming so successful they’d be in a lot more trouble. Like Google is, for starting out open and now trying to tighten things up and add restrictions to the use of Android (like their crackdown on IAP) now that Android has become the #1 mobile OS.
I’m curious in what area do you think Apple can be found a monopolist? Instead of just disagreeing with everyone, why don’t you offer your opinion with some examples and reasons why?
You won’t, because that’s not your MO. If you never actually take a stand on anything you don’t have to defend yourself, right?
The judge's own words are all you need Eric. I was not arguing for either position. To quote from the ruling itself, page 180 of 185 in the section "Conclusions": "Thus, and in summary, the Court does not find that Apple is an antitrust monopolist in the submarket for mobile gaming transactions"
BTW, from her comments you didn't mention: “The court does not find that it is impossible (that Apple is an antitrust monopolist); only that Epic Games failed in its burden to demonstrate Apple is an illegal monopolist”
Well duh!!! Seeing as Epic is the plaintiff the burden is on them. Or did you want the court to bring evidence against Apple too?
Since you came into the conversation late you can be forgiven for missing what it's about and the points being discussed
Without developers the App store would have to sell pictures of Tim Cook to make a profit. But developers need the app store to introduce the world to their product (although this is not a requirement), so this is clearly a complex issue.
However, if a real estate agent charged me 15% annual rent to find me an apartment and then tried to charge me 15% every single month thereafter, then yeah, I would be upset too.
Without developers the App store would have to sell pictures of Tim Cook to make a profit. But developers need the app store to introduce the world to their product (although this is not a requirement), so this is clearly a complex issue.
However, if a real estate agent charged me 15% annual rent to find me an apartment and then tried to charge me 15% every single month thereafter, then yeah, I would be upset too.
Your analogy fails because Realtors do not provide services in subsequent years. Apple provides a list of about 20 services that are free for users and developers. Those free services come out of Apple's 15% fee. Apple's main benefit is how it simplifies user experiences, and the 15% App Store fee is deigned to simplify the developer's experience. Developers are users too, don't you know? A person like Tim Sweeney doesn't need Apple to help them out. But most developers are small groups of people who appreciate the assistance from Apple. But since you sound like someone who hates small groups of people and loves big corporations, I can understand your point of view. I don't hate you just because you love big corporations.
I'm not sure this ruling will hold up under appeal. If the App Store isn't really a monopoly, why would Apple be disallowed from anti-steering clauses that are standard practice for web retailers and online sellers?
There was no ruling on whether the AppStore was a monopoly, or having any other antitrust/anti-competitive issues. This judge's ruling very narrowly addressed only a very narrow segment "the mobile gaming transactions market" which she defined as the relevant market. The headline infers a whole lot more to it.
Nice spin. The mobile gaming transactions market is the single largest portion of The App Store. If you can’t prove Apple is a monopolist in their biggest and most profitable segment you’re never going to convince anyone they are a monopolist in any other area.
This ruling might as well have said the entire App Store isn’t a monopoly.
Typical for what? Calling out your usual BS posts? The more pertinent text from Judge Rogers was:
“Given the trial record, the Court cannot ultimately conclude that Apple is a monopolist under either federal or state antitrust laws. While the Court finds that Apple enjoys considerable market share of over 55% and extraordinarily high profit margins, these factors alone do not show antitrust conduct. Success is not illegal.”
Which is exactly what I’ve said all along. Being big and successful (and even a monopoly) isn’t illegal. So even IF Apple was declared a monopoly, it’s still not illegal. Apple can’t be punished for being wildly successful. They have to do something illegal, and there’s only two choices regarding antitrust law in the US:
- Doing something illegal to get to your market position. Buying up competitors or undercutting them on prices until they go under are two classic examples. - Doing something illegal after you gain market power. Like increasing prices or adding onerous terms to you customers knowing they have no other choices in the market.
Apple has done neither. Although they were found to be in violation regarding anti-steering, it’s irrelevant to the discussion of being a monopoly simply because Apple has always had these rules in place, long before they became as large as they are. So it’s an infraction, but nothing to do with Apples market position. Had Apple tried to add these rules AFTER becoming so successful they’d be in a lot more trouble. Like Google is, for starting out open and now trying to tighten things up and add restrictions to the use of Android (like their crackdown on IAP) now that Android has become the #1 mobile OS.
I’m curious in what area do you think Apple can be found a monopolist? Instead of just disagreeing with everyone, why don’t you offer your opinion with some examples and reasons why?
You won’t, because that’s not your MO. If you never actually take a stand on anything you don’t have to defend yourself, right?
The judge's own words are all you need Eric. I was not arguing for either position. To quote from the ruling itself, page 180 of 185 in the section "Conclusions": "Thus, and in summary, the Court does not find that Apple is an antitrust monopolist in the submarket for mobile gaming transactions"
BTW, from her comments you didn't mention: “The court does not find that it is impossible (that Apple is an antitrust monopolist); only that Epic Games failed in its burden to demonstrate Apple is an illegal monopolist”
As usual you refuse to take a stand.
Why don’t you list areas in which Apple could be found guilty of being a monopolist? Surely you can come up with at least one example.
From actual legal experts, which I am not, nor are you AFAIK.
"The question of whether Apple abused monopoly power "remains very much unsettled," said Joshua Paul Davis, a professor of antitrust law at the University of San Francisco School of Law.
"Given how controversial these issues are right now, I would expect this not to be the final say," he said.
"As a consequence, the trial record was not as fulsome with respect to antitrust conduct in the relevant market as it could have been," Gonzalez Rogers said."
And this one:
Valarie Williams, a partner at law firm Alston & Bird, called Gonzalez Rogers' decision a "road map" to future plaintiffs pursuing monopoly claims against Apple.
Future plaintiffs could bring a case that adopts Gonzalez Rogers's market definition and introduces additional evidence, Williams said.
and this one:
Sam Weinstein, a professor of antitrust law at Cardozo School of Law, agreed the judge's ruling could encourage other market participants to learn from Epic's case and try to launch a stronger blow against Apple.
Language in the ruling could even signal that the judge thinks "it's only a matter of time" before Apple becomes a monopoly, Weinstein said.
And this one:
"This is only one particular piece of litigation framed in one particular way," said Davis. "The court was pretty explicit that different litigants could come forward with different evidence...and that could potentially change the result."
I'm not sure this ruling will hold up under appeal. If the App Store isn't really a monopoly, why would Apple be disallowed from anti-steering clauses that are standard practice for web retailers and online sellers?
There was no ruling on whether the AppStore was a monopoly, or having any other antitrust/anti-competitive issues. This judge's ruling very narrowly addressed only a very narrow segment "the mobile gaming transactions market" which she defined as the relevant market. The headline infers a whole lot more to it.
Nice spin. The mobile gaming transactions market is the single largest portion of The App Store. If you can’t prove Apple is a monopolist in their biggest and most profitable segment you’re never going to convince anyone they are a monopolist in any other area.
This ruling might as well have said the entire App Store isn’t a monopoly.
I'm not sure this ruling will hold up under appeal. If the App Store isn't really a monopoly, why would Apple be disallowed from anti-steering clauses that are standard practice for web retailers and online sellers?
There was no ruling on whether the AppStore was a monopoly, or having any other antitrust/anti-competitive issues. This judge's ruling very narrowly addressed only a very narrow segment "the mobile gaming transactions market" which she defined as the relevant market. The headline infers a whole lot more to it.
Nice spin. The mobile gaming transactions market is the single largest portion of The App Store. If you can’t prove Apple is a monopolist in their biggest and most profitable segment you’re never going to convince anyone they are a monopolist in any other area.
This ruling might as well have said the entire App Store isn’t a monopoly.
Typical for what? Calling out your usual BS posts? The more pertinent text from Judge Rogers was:
“Given the trial record, the Court cannot ultimately conclude that Apple is a monopolist under either federal or state antitrust laws. While the Court finds that Apple enjoys considerable market share of over 55% and extraordinarily high profit margins, these factors alone do not show antitrust conduct. Success is not illegal.”
Which is exactly what I’ve said all along. Being big and successful (and even a monopoly) isn’t illegal. So even IF Apple was declared a monopoly, it’s still not illegal. Apple can’t be punished for being wildly successful. They have to do something illegal, and there’s only two choices regarding antitrust law in the US:
- Doing something illegal to get to your market position. Buying up competitors or undercutting them on prices until they go under are two classic examples. - Doing something illegal after you gain market power. Like increasing prices or adding onerous terms to you customers knowing they have no other choices in the market.
Apple has done neither. Although they were found to be in violation regarding anti-steering, it’s irrelevant to the discussion of being a monopoly simply because Apple has always had these rules in place, long before they became as large as they are. So it’s an infraction, but nothing to do with Apples market position. Had Apple tried to add these rules AFTER becoming so successful they’d be in a lot more trouble. Like Google is, for starting out open and now trying to tighten things up and add restrictions to the use of Android (like their crackdown on IAP) now that Android has become the #1 mobile OS.
I’m curious in what area do you think Apple can be found a monopolist? Instead of just disagreeing with everyone, why don’t you offer your opinion with some examples and reasons why?
You won’t, because that’s not your MO. If you never actually take a stand on anything you don’t have to defend yourself, right?
The judge's own words are all you need Eric. I was not arguing for either position. To quote from the ruling itself, page 180 of 185 in the section "Conclusions": "Thus, and in summary, the Court does not find that Apple is an antitrust monopolist in the submarket for mobile gaming transactions"
BTW, from her comments you didn't mention: “The court does not find that it is impossible (that Apple is an antitrust monopolist); only that Epic Games failed in its burden to demonstrate Apple is an illegal monopolist”
Well duh!!! Seeing as Epic is the plaintiff the burden is on them. Or did you want the court to bring evidence against Apple too?
Apple isn’t a Monopoly far from it, there is choice Android (market leader world wide 80%?) and others, not long ago there were five other companies in the market outside of Chinese market, it isn’t Apple’s problem so many companies have quit the field.
Note: the same applies to Mac OS with the A series CPU’s soon to be the best PC/OS combo in the world, certainly the most profitable.
I noticed those points in the ruling too. I also noticed that 70% of apps are games, so by corollary 98% of the revenue comes from 70% of the apps.
But the really interesting statistic was that virtually ALL of the game revenue came from only 10% of the total iOS user base! There’s quite a bit to unpack there, but the questions that I’d like to get answered are: 1. How popular are games really? Yes they make lots of revenue but it’s only from a tiny minority of platform users. 2. Do the other 90% have any games on their devices? I would guess so but they are likely free, ad-funded, or they just play the big games for free without buying the in game credits and stop when they have to start paying. 3. Is Apple Arcade included in this revenue figure? If not, then subscription based gaming may actually increase the overall “paying” market size. 4. Are games actually too expensive to play given only 10% (I assume those who can afford to drop 1,000’s on in game credits) actually pay to play them?
Epic seem to think they can expand their market by offering a 20% discount on in-game credits, but I suspect the growth opportunity with their current business model is not actually as big as they think it is.
1. What do you mean by popular? Games are the most downloaded apps in the smartphone App Stores, but they are 10% of total usage minutes for smartphones. The dominant usage minutes are social media, video and comms. Not only that, Android has about 2x the worldwide downloads than iOS. So in terms of units, Android has the most players. It's just that iOS has the most players who actually pay. Really, if Apple wanted to, they can attack the Court's market definition on appeal and be effective at it imo.
2. Yes, I agree with your guess. The Court did not have data on how much money is in ad-supported games. I would bet a lot that the vast majority of time spent on games are ad-supported games, and on IAP games that people don't buy any IAPs. How much money in ads do those games make? Who knows.
3. There wasn't an itemized list of what made the overall $100m dollar market. The 100m were all estimates. Everything was an estimate. So, you are asking a too specific question. Given how the Court's market analysis was done, it doesn't matter. Here's how they computed revenue share, what they called market share. The court took Apple's self stated revenue share of the entire gaming market (consoles, PCs, et al), which they believed to be about ~25%, and divided that number by the estimated fraction of the estimated mobile gaming revenue of the total gaming market, 44%. 0.25/0.44 = 57%. That's it. There wasn't any independent market analysis nor telemetry. Arcade subscription revenue might be already built into the number, as it is Apple's estimated revenue share number. The Court wouldn't know unless they asked.
4. No. The games aren't expensive enough. They need to be more expensive to fund the industry. The current App Store's agency model (all of app stores) and hyper-aggregation has driven down all app prices to as low as they possibly can go. Traditional monetization methods can't survive the App Store. If people were willing to spend $20 to $40 on a game, there'd be more pay-once games and some portion of the market could avoid IAP games, and a lot of developers would be happier. However, it won't stop IAP style games or ad-supported games. Nothing would have stopped the trend, because free is impossible to fight. This monetization model by assumption requires big spenders (10% of users) to support all the non-spenders (the remaining 90%).
This is why I'm quite skeptical of the Courts rationale for anti-steering decisions, both here and in the e-books decision. The stated rationale for their decisions was Apple's practices limited price competition, and prices could be cheaper there was. I think they are wrong. The agency model and aggregation in app stores mean developers are in a cut-throat price competition with every other developer, from places all over the world with different costs of living, in competition with everything else that occupies a user's time. This has driven prices down to ridiculous $1, $2, $5 levels. And it's $1 because that's the lowest price tier. If there is a 50¢ tier, prices will be driven down to there. These court decisions are now saying that if this or that rule is changed, it will drive prices down ever lower? No way. Prices will not be going down.
“Jefferies analyst Kyle McNealy calls the decision largely a win for Apple… [and] sees the exodus as limited by most developers lacking the scale and brand recognition to build an independent payment workflow and ‘consumer aversion to entering payment details for a high volume of apps separately.’ The firm maintains a Buy rating and $175 price target.”
IOW how many people really want to bother with creating a separate account for payment with each vendor, thereby creating multiple opportunities for a company to expose their information with careless or insufficient security? It’s barely a bump in the road for Apple.
“Jefferies analyst Kyle McNealy calls the decision largely a win for Apple… [and] sees the exodus as limited by most developers lacking the scale and brand recognition to build an independent payment workflow and ‘consumer aversion to entering payment details for a high volume of apps separately.’ The firm maintains a Buy rating and $175 price target.”
IOW how many people really want to bother with creating a separate account for payment with each vendor, thereby creating multiple opportunities for a company to expose their information with careless or insufficient security? It’s barely a bump in the road for Apple.
Probably very few, but we may see payment integrators like PayPal or Square offering easily implementable frameworks so that a button can push information through the integrators platform for payment in a WebFrame. That could be more of a threat to Apple.
From the user perspective, once they have an account with the integrator they'd just need to authenticate their password from iOS keychain via TouchId and they're done. It's always going to be a couple extra taps, but not that much of a hurdle than Apple's IAP, and users may see other advantages from using those services, e.g. PayPal do their own credit lines.
“Jefferies analyst Kyle McNealy calls the decision largely a win for Apple… [and] sees the exodus as limited by most developers lacking the scale and brand recognition to build an independent payment workflow and ‘consumer aversion to entering payment details for a high volume of apps separately.’ The firm maintains a Buy rating and $175 price target.”
IOW how many people really want to bother with creating a separate account for payment with each vendor, thereby creating multiple opportunities for a company to expose their information with careless or insufficient security? It’s barely a bump in the road for Apple.
Probably very few, but we may see payment integrators like PayPal or Square offering easily implementable frameworks so that a button can push information through the integrators platform for payment in a WebFrame. That could be more of a threat to Apple.
From the user perspective, once they have an account with the integrator they'd just need to authenticate their password from iOS keychain via TouchId and they're done. It's always going to be a couple extra taps, but not that much of a hurdle than Apple's IAP, and users may see other advantages from using those services, e.g. PayPal do their own credit lines.
The thing is that Apple is not require to allow or support, the developer payment system, inside their app. Apple is only require to allow developers to inform their users, with in the app, that they can pay for their purchases outside of the app and/or supply a link to where they can pay for their purchase, that is outside of the app. Most likely logging into their account at the developer website, using a browser.
Apple do not have to allow the developer to have a "PayPal" button inside their app, that will finalize the purchase. The payment must be made outside the app. That's where the developer can have a "PayPal" button or some other choices, that the purchaser can use to pay.
The ruling is not requiring Apple to support a developer's payment system inside their app or iOS. Nor requiring Apple to provide developers with an alternative payment system, other that iTunes. But you can bet that if Apple were forced to support a developer payment system inside an app, Apple will have an easier time keeping track of purchases, in order to send the developers the bill for the commission. Which the court still allows Apple to charge and collect.
What Epic really wanted was to be able to have their game playing customers pay for their IAP, without leaving the app. That's not going to happen with this ruling.
Apple today filed a motion asking Judge Rogers to stay the injunction she issued. Apple also filed notice that it had appealed her decision. I don't think either of those things is a surprise.
Comments
However, if a real estate agent charged me 15% annual rent to find me an apartment and then tried to charge me 15% every single month thereafter, then yeah, I would be upset too.
"The question of whether Apple abused monopoly power "remains very much unsettled," said Joshua Paul Davis, a professor of antitrust law at the University of San Francisco School of Law.
"Given how controversial these issues are right now, I would expect this not to be the final say," he said.
"As a consequence, the trial record was not as fulsome with respect to antitrust conduct in the relevant market as it could have been," Gonzalez Rogers said."
And this one:
Valarie Williams, a partner at law firm Alston & Bird, called Gonzalez Rogers' decision a "road map" to future plaintiffs pursuing monopoly claims against Apple.
Future plaintiffs could bring a case that adopts Gonzalez Rogers's market definition and introduces additional evidence, Williams said.
and this one:
Sam Weinstein, a professor of antitrust law at Cardozo School of Law, agreed the judge's ruling could encourage other market participants to learn from Epic's case and try to launch a stronger blow against Apple.
Language in the ruling could even signal that the judge thinks "it's only a matter of time" before Apple becomes a monopoly, Weinstein said.
And this one:
"This is only one particular piece of litigation framed in one particular way," said Davis. "The court was pretty explicit that different litigants could come forward with different evidence...and that could potentially change the result."
Apple isn’t a Monopoly far from it, there is choice Android (market leader world wide 80%?) and others, not long ago there were five other companies in the market outside of Chinese market, it isn’t Apple’s problem so many companies have quit the field.
Note: the same applies to Mac OS with the A series CPU’s soon to be the best PC/OS combo in the world, certainly the most profitable.
2. Yes, I agree with your guess. The Court did not have data on how much money is in ad-supported games. I would bet a lot that the vast majority of time spent on games are ad-supported games, and on IAP games that people don't buy any IAPs. How much money in ads do those games make? Who knows.
3. There wasn't an itemized list of what made the overall $100m dollar market. The 100m were all estimates. Everything was an estimate. So, you are asking a too specific question. Given how the Court's market analysis was done, it doesn't matter. Here's how they computed revenue share, what they called market share. The court took Apple's self stated revenue share of the entire gaming market (consoles, PCs, et al), which they believed to be about ~25%, and divided that number by the estimated fraction of the estimated mobile gaming revenue of the total gaming market, 44%. 0.25/0.44 = 57%. That's it. There wasn't any independent market analysis nor telemetry. Arcade subscription revenue might be already built into the number, as it is Apple's estimated revenue share number. The Court wouldn't know unless they asked.
4. No. The games aren't expensive enough. They need to be more expensive to fund the industry. The current App Store's agency model (all of app stores) and hyper-aggregation has driven down all app prices to as low as they possibly can go. Traditional monetization methods can't survive the App Store. If people were willing to spend $20 to $40 on a game, there'd be more pay-once games and some portion of the market could avoid IAP games, and a lot of developers would be happier. However, it won't stop IAP style games or ad-supported games. Nothing would have stopped the trend, because free is impossible to fight. This monetization model by assumption requires big spenders (10% of users) to support all the non-spenders (the remaining 90%).
This is why I'm quite skeptical of the Courts rationale for anti-steering decisions, both here and in the e-books decision. The stated rationale for their decisions was Apple's practices limited price competition, and prices could be cheaper there was. I think they are wrong. The agency model and aggregation in app stores mean developers are in a cut-throat price competition with every other developer, from places all over the world with different costs of living, in competition with everything else that occupies a user's time. This has driven prices down to ridiculous $1, $2, $5 levels. And it's $1 because that's the lowest price tier. If there is a 50¢ tier, prices will be driven down to there. These court decisions are now saying that if this or that rule is changed, it will drive prices down ever lower? No way. Prices will not be going down.
From the user perspective, once they have an account with the integrator they'd just need to authenticate their password from iOS keychain via TouchId and they're done. It's always going to be a couple extra taps, but not that much of a hurdle than Apple's IAP, and users may see other advantages from using those services, e.g. PayPal do their own credit lines.
Apple do not have to allow the developer to have a "PayPal" button inside their app, that will finalize the purchase. The payment must be made outside the app. That's where the developer can have a "PayPal" button or some other choices, that the purchaser can use to pay.
The ruling is not requiring Apple to support a developer's payment system inside their app or iOS. Nor requiring Apple to provide developers with an alternative payment system, other that iTunes. But you can bet that if Apple were forced to support a developer payment system inside an app, Apple will have an easier time keeping track of purchases, in order to send the developers the bill for the commission. Which the court still allows Apple to charge and collect.
What Epic really wanted was to be able to have their game playing customers pay for their IAP, without leaving the app. That's not going to happen with this ruling.
https://storage.courtlistener.com/recap/gov.uscourts.cand.364265/gov.uscourts.cand.364265.821.0_1.pdf
https://storage.courtlistener.com/recap/gov.uscourts.cand.364265/gov.uscourts.cand.364265.820.0.pdf