Podcast: A Conversation with Attorney General William Tong
In this episode of our Public Policy & Regulation Group's "Conversations with State Attorneys General" podcast series, attorney Stephen Cobb talks with Connecticut Attorney General William Tong about his work in the office and the growing role of state AGs in recent years, both in Connecticut and nationwide. Their conversation highlights a number of efforts being led by state AGs across the country, including actions related to consumer protection, data privacy and the opioid crisis. Mr. Tong also provides helpful tips and guidance for folks looking to engage with their attorney general’s office.
Stephen Cobb: Welcome to Holland & Knight's Eyes on Washington podcast, State Attorneys General Edition. My name is Stephen Cobb, I'm a partner in our Washington, D.C. office, co-chair of our State Attorneys General practice and former deputy attorney general of the Commonwealth of Virginia. I'm so excited to have with us on this episode of the podcast, the Attorney General from the Great State of Connecticut, General Tong. Welcome to the podcast.
William Tong: Stephen, thank you.
Growing Role of State AGs Over the Years
Stephen Cobb: Thanks so much for being here and, General, as one of the things that you and I have chatted about before were things that I brought up on this podcast before is really the growing role that State Attorneys General play across a variety of areas. And this can be not just policy leaders, but regulatory enforcement. I've often made the argument that I think state attorney generals are really second to none when it comes to being on the front foot of both policy formulation and regulatory enforcement. And the, I think industry, the private sector and national politics continue to recognize that as we see state attorneys general take a large role in the president's cabinet and also in setting the national agenda. What do you attribute the growing role of state attorneys general over the last five, ten, fifteen-ish years?
William Tong: So, that's a great question. There are a million ways to answer it. I think a lot of people ask that question. You know, why are AGs so engaged on so many issues? I think it's a structural one, and I think what you're seeing not because of us, but because of current events is sort of a masterclass in federalism. And what I mean by that, if I may nerd out for a second on the law and constitutional structure, people sometimes forget, I think, their seventh grade physics or maybe their 11th grade U.S. History. You know, we're still a federation of 50 sovereign states, and the territories and the district. And we have retained our sovereignty, each of us. That's why Connecticut has a governor and a legislature and its own criminal laws and then an elected attorney general. And so, because of that, we have delegated limited authority to the federal government to act on our collective behalf. But when the federal government fails to act, you know, when Congress is broken. And in many respects, I think all of us can agree that it is, and it fails to discharge its basic obligations and duties, like passing a budget, you know, funding the government. If it can't act, then the responsibility naturally devolves to the states and rests with the original building blocks of this country. And that is each and every state acting through its attorney general. And so, I think what happened, I wasn't around when this happened. I might have been in high school or grade school, when it happened, and I hope Senator Blumenthal doesn't take this the wrong way. But when Senator Blumenthal was our attorney general, you know, nearly a generation ago when he started out as AG, he was part of the team of attorneys general that brokered the national tobacco settlement after years and years of investigation and negotiation. And it is commonly referred to as, you know, Stephen, as the Big Bang of attorney general coordination and multistate work. And that's when AGs across the aisle looked at each other and said, "Hey, wait a second. If I team up with Florida in Connecticut or New York or California or Tennessee, we can do a lot together." And once we figured that out, because there wasn't enough action in Washington on protecting kids from marketing by the major tobacco companies and because of the epidemic of youth smoking, State AGs said, "Hey, let's do this ourselves. We retain this authority. We're sovereign, we have the power to take this on," and they did.
Stephen Cobb: No, that's an excellent point. When I taught a class on state AGs for law students, I used that exact moment when we're talking about the national tobacco settlement and asked them to discuss, and I'm taking it slightly far off-field here, but whether it was the growth and advent of technology that allowed AGs to better coordinate, or a change in laws which allowed them to have a greater enforcement authority, which was a larger impetus in the ability of State AGs to start to work together. It's an interesting conversation because some can say, well, you know, you weren't exactly faxing each other briefs and having read line and circulating them again. And so in one sense, being able to email allowed for that coordination. On the other hand, it was different laws expanding Consumer Protection Acts, which also fostered that strength.
William Tong: Well, you know, I think it was a breakdown in Washington. You know, when we grow up as kids, we look to D.C. and say, "Hey, the president or Congress are going to do this and take care of us, right?" So, I'll give it a couple of really important examples. There's a huge debate right now about Section 230 of the Communications Decency Act, and basically Section 230 by most people's reckoning provides a broad shield of liability for the technology industry, for big technology companies. And we can debate whether that supercharged a golden age of innovation, and whether it came at the cost of consumers and consumer safety. And that's the debate happening now around Section 230. The feeling about Congress, though, in Washington, is that they're unable to address the issues around Big Tech companies, around consumer safety, around kids, right, on social media platforms. And that's why AGs are now having this conversation. That's why we have a nearly 50 state investigation of Instagram. Why? Because if Congress isn't going to act on it, then our constituents look to us and say, "Hey, rediscover your roots as a sovereign entity, right, as an agent of the sovereign state of Connecticut and the people of Connecticut and assert that authority to protect all of us." I think that's writ large what's happening.
The feeling about Congress, though, in Washington, is that they're unable to address the issues around Big Tech companies, around consumer safety, around kids, right, on social media platforms. And that's why AGs are now having this conversation.
A Look-Back at 2021: State-Specific and Multistate Work
Stephen Cobb: So, let's break this down a little bit because sometimes you're functioning for the citizens of Connecticut solely on issues affecting the citizens of your state. There's other times, as we've alluded to, when you're teaming up shoulder to shoulder with other state attorneys general from across the country. So, kind of let's look back on 2021. Can you tell me some of the work that you've done? First, in Connecticut and then also that you've taken a national scope for and worked with some of your colleagues.
William Tong: I've already mentioned one. There's a lot of action around technology broadly that breaks down into a number of areas. I think the area that is most active and recognizable to people is state attorney general work in the area of consumer data privacy and protecting everybody from data breaches. And so, I doubt anybody listening on this call or very few of you listening to this podcast were spared in the Equifax data breach, for example. That was a huge one. And as a consumer affected by the Equifax data breach, you know, that was a huge wakeup call that one of our nation's principal credit reporting agencies could have a massive data breach. And so, you see state AGs there. Connecticut is frequently a leader in that work because my predecessor started the very first privacy department in the State Attorney General's office anywhere. And then beyond that, there are other data breaches like Home Depot and Target large corporate data breaches. And then, of course, things like Cambridge Analytica, which I guess isn't technically a data breach, but it was a mass compromise of consumer personal data and information. And so there's that bucket. There's the consumer issues around social media and misinformation and disinformation around elections, around vaccines. You know, the harms that young people experience from the content online. And so, you've seen a lot of action around Instagram, Facebook, TikTok. I've been particularly vocal about TikTok. And so, we're all working together on those issues. I mentioned the Section 230 issues. And then there are antitrust issues and there's a case pending now against Google. There was a case against Facebook that the FTC is still maintaining and that we are re-initiating as a community of states. A lot of this is done largely by all of us acting together. All of these cases that I've described, or investigations, have a majority of states involved and on a nonpartisan, bipartisan basis.
I'm particularly active in leading a number of initiatives around medicine, pharmaceuticals, drugs and drug pricing. I am leading the national generic drug price fixing case, which is more or less 50 state territories and the district coalition taking on the generic drug industry for what we believe was brazen and overt price fixing. And violations of our antitrust laws, that's been going on for a number of years. That predates me as attorney general, and I've been very privileged to pick up the ball from Attorney General Jefferson. The other area that inside attorney general community watchers know about is our work, Connecticut's work on opioids. And I've been particularly active first in the settlement with the three major drug distributors AmerisourceBergen, Cardinal and McKesson and Johnson and Johnson, a settlement that was originally announced at eighteen billion. And then with the intervention of Connecticut and a number of other states, that settlement then swelled to twenty-six billion. And then apart from that, I've been very active as part of a greater community of AGs, who have sued Purdue Pharma and the Sackler's. I'm sure there's hardly any listener who hasn't either seen Dopesick or read Empire of Pain or know what's going on around lawsuits and the bankruptcy of Purdue Pharma. And the Sackler family that owns Purdue Pharma. But I am part of the leadership of a group of nine dissenters who voted against the plan of reorganization in the Bankruptcy Court of Purdue Pharma. We appealed that plan and that plan was vacated. And so now we have been compelled to mediation. I can't say anything more than that, but the nine of us were able to stop that plan from being confirmed, and hopefully that will lead to a more just result. As you know, Stephen, in cases like this, particularly when there is widespread loss of life and the damage cannot be measured, both in terms of the cost to human beings and their families, but the financial cost, there's never enough money. You know, to compensate or to address the toll that a crisis like this takes on states like Connecticut and Virginia and across the country, and there's not enough justice that can bring back a lost daughter, son, father, mother. And so you do the best you can. People often ask you, "Well, how much is enough?" Well, there's no book, right? There's no formula about what's enough. Keep pushing until you think you've delivered as much justice as you can produce for victims and families and their survivors.
Stephen Cobb: I would be remiss, since you mentioned Dopesick, that it also includes a portrayal of one of my current law partners, John Brownlee, the good works that he did in this space while he was U.S. Attorney for the Western District of Virginia.
William Tong: Yeah, and you'll see a little cameo in the last minute with Michael Keaton.
Developments in Data Privacy
Stephen Cobb: Well, we touched on a few different subject matter areas, I want to unpack those just a little bit. First, when we talked about data privacy. One of the debates going around, not just in the state AG community, but data privacy in general and in Washington D.C., is the standards that are used in data privacy, both for reporting and both at the best efforts and prevention. We keep seeing new Data Privacy Acts pop up. First it's California, Virginia, Vermont. Where do you see this space going? Do you see national standards coming into play here in the future? And if not, what's the best way to reconcile so many different standards coming up from state to state?
William Tong: Not to be so flip, but if only we could expect national standards. That might make life a little more straightforward for most of us, not simple. It'll never get simple. This will never be simple, but it's the absence of national standards that's so difficult to contend with. So for listeners, right, I've had to learn so much about not just data privacy, but approaches to privacy, broadly. There's the European approach, which basically regards personal data as property and, you know, something that people can have a property right in, which I think is the philosophical underpinning of the GDPR, which is the European construct legal structure for data privacy. And then the opposite view, I guess you would say, in the U.S., which treats data and personal information in many cases as a commodity. And there's a huge debate about what is the right approach and how it impacts growth and innovation and technology and our economy. And it's very challenging because you've got these two seemingly opposing views of the world. And then you've got California doing its thing with the CCPA, and then people outside of California say, we need to do something, but we don't want to do California. So this is because the standards have not been set, and I don't have any confidence that Congress will do that. And so what's the answer? I suppose there will be a period in Connecticut as part of this where we'll do our own thing and we'll continue to strengthen our own data privacy laws here at home. And then, there may be some uniform laws or some conventions among the states that arise out of that, but we're not there yet.
Not to be so flip, but if only we could expect national standards. That might make life a little more straightforward for most of us, not simple. It'll never get simple. This will never be simple, but it's the absence of national standards that's so difficult to contend with.
Stephen Cobb: How much of this do you think, I hate to use the term tail wagging the dog, but I mean, are we headed to a place where the state with the most stringent data privacy laws is just going to end up setting national standards for anyone? Is doing, you know, national or cross state work?
William Tong: That's part of it. And that could happen. I think even though it is hard to conceive of the bigger data breach than, say, a data breach of one of the largest credit reporting bureaus in our country. You and I both know from a policymaking lawmaking perspective, often something really bad has to happen, right, before real substantive action is taken. Either congressional level or, you know, in state legislatures. And so maybe we're not at that point yet. There hasn't been an event that catalyzed that work. But until then, we're going to continue to bump along ,right, and drift, I think you're right, towards one pull or the other. When I say pull, I mean a magnetic pull. Like, maybe one extreme or the other.
Stephen Cobb: Right. So, commodity versus individual leadership.
William Tong: Yeah. If there were easy answers, we wouldn't have even asked the question, right?
Stephen Cobb: One of the things that you alluded to when you were talking about some of the different areas over the last year that you've been involved, some you've categorized as areas that you were taking a leadership role in. Some you've talked about things that every state was involved in. To the extent you can answer, what are some of the things that go into the calculus of when you decide of, OK, this is something that I want to be on the leadership committee with, this something that I want to lead, versus others where it's "I'm going to be part of a team, but I'm going to step back and let so-and-so, this team of three or five other states take the lead."
William Tong: That's easy. The number one objective, criteria, lodestar for me is this is important to the people of my state. You know, and if it's important to Connecticut, if it either originates in Connecticut, arises from Connecticut or has a disparate impact on people in my state, that compels me to action. So, I'll give you a good example. People ask me "Attorney General Tong, Purdue Pharma is based in your home city of Stamford, Connecticut, and the Sackler's live in and around your community. What does that mean to you?" And I say "I believe that it means I have a special obligation to be aggressive," which people don't expect. They expect maybe I'd be a home-stater and not be as aggressive. I think it means I have to be extra aggressive, number one. And number two is we're a small, hard hit state by this crisis. And so, there are other states that are there on a mission have not had the same challenges that we, or New Hampshire, right, or Vermont have had with the opioid addiction crisis. And so, this is really important to us and to families in Connecticut. We have lost so many people and frankly, the economic impact is staggering. So, that's number one. A close number two is you have to pick your spots to really make an impact in the multistate world. So, when you become attorney general today, I became attorney general in 2019, you walk into a totally different landscape than Dick Blumenthal or Joe Lieberman, right? Joe Lieberman was Connecticut's first full time attorney general, believe it or not. And, you know, back then you didn't walk into a multistate environment like this where everybody is contributing and is expected to contribute. And there really aren't any limits on what we can focus on. I mean, there are jurisdictional substantive limits on what causes of action we can bring, where we can bring them. But basically, very few people conceive of our jurisdiction or ambit as being limited or circumscribed. I think people think that AGs can look at and address every problem. Now, I don't think that.
If it's important to Connecticut, if it either originates in Connecticut, arises from Connecticut or has a disparate impact on people in my state, that compels me to action.
Stephen Cobb: In my experience, most AGs think they can.
William Tong: Yeah, I was just about to hang a caveat. I don't believe that because I know that our authority is in each state, either clearly prescribed or circumscribed, right, and limited. And so it is in Connecticut. I don't have criminal jurisdiction, for example. That's a big one. But some AGs do. Peter Neronha of Rhode Island has both civil and criminal jurisdiction. So there's this expectation that we can do everything and anything. And so, you have to be judicious about where you weigh in, because otherwise it's overwhelming, you can't possibly do everything. So one of the things I look to is, has Connecticut established itself as a leader in this "x" area, right? Is it seen as a traditional resource or leader on a particular subject? So, I think if you think about Connecticut, we're known to be very strong in privacy, data privacy. We're known to be very strong in antitrust matters. We're now, you know, recognized as a leader in pharmaceutical related litigation, including the opioid and addiction crisis. So, for example, why did I weigh in so forcefully on the distributor settlement with AmerisourceBergen, Cardinal and McKesson? And the reason why is because George Jepson, as attorney general, my predecessor was the one who said we ought to look at the distributors. And, you know, with all due respect to my colleagues, some people have a different recollection of how it all went down. But I know that George came up with it, and it's my job as the Connecticut attorney general to continue his work, which was very effective, and to take on that responsibility, which I did. So, Connecticut, I am very proud to say we're not big. Three million people, we're, you know, a coastal state in New England. So, you know, some would say not broadly reflective of other parts of the country, but I would quarrel with that, number one. We have a very diverse state that does reflect other parts of the country. But we are often seen in AG world as punching well above our weight. And I take that responsibility very seriously. That's what people look to Connecticut AGs for. Dick Blumenthal? A legend. Joe Lieberman? A legend. George Jepson? Not quite as vocal as those two, but a co-chair of DAGA, the Democratic Attorneys General Association and the president of the National Association of Attorneys General. And so, you know, George is a force among AGs. And so, frankly, that that's a lot to carry sometimes. But I guess that's why I get up in the morning.
The Future of State AGs
Stephen Cobb: There you go. So, we're looking ahead to the rest of 2022. We've talked about some of the big issues from 2021, but looking into your crystal ball, where do you see this year going with State AGs? Any particular issues and industries, or more of an expansion of some of the stuff we already hit on?
William Tong: So, like a lot of your listeners and a lot of your colleagues, Connecticut needs to figure out how to emerge from the pandemic stronger than it entered the pandemic. And one of the challenges is how do we put our economy and our workplaces back together again? And I am very proud to lead the largest law firm in Connecticut. And trying to navigate a world in which people, you and I are doing it right now, you know, we interact by Zoom. We build relationships over Zoom. We collaborate over Zoom. We work together over Zoom. And yet, it's not perfect. We lose something by not being together, so how do you get people back together while retaining some of what we have discovered during the pandemic? And I must tell you, that takes up a lot of my time and it takes up, I think, a lot of the administrative time of my colleagues, if they're honest about what they need to focus on. You know, beyond that, I know that's not terribly sexy, there are some really interesting things happening in Connecticut that are happening across the country. The question about health care provider consolidation, i.e. hospital mergers, right, is increasingly a challenge in Connecticut and across the country. There's an antitrust suit that has been filed by St. Francis Hospital, a Catholic hospital in Connecticut, venerable institution. It has sued Hartford Health Care, which runs Hartford Hospital and has become a large behemoth in the health care space. And there are allegations of anti-competitive conduct. And again, Rhode Island Attorney General Peter Neronha just refused to approve a hospital merger in Rhode Island. And so, you're seeing this happen across at least our two states and I think across the country this question of what do you do about the increased concentration of power in health care providers, hospital systems, some of which are nonprofits, right? And what do you do about potential or allegations of prejudice to individual doctors and nurses and practices? And what is the impact on patients? I expect that to be a huge issue going forward in Connecticut and across the country as people try to figure that out.
I think across the country this question of what do you do about the increased concentration of power in healthcare providers, hospital systems, some of which are nonprofits, right? And what do you do about potential or allegations of prejudice to individual doctors and nurses and practices? And what is the impact on patients? I expect that to be a huge issue going forward in Connecticut and across the country as people try to figure that out.
Stephen Cobb: Is that something that you foresee working in tandem with your federal counterparts or do you see some of that being more of an issue?
William Tong: I think it is more of an AG led issue because there obviously are systems that operate across states in larger hospitals and health care entities. These are largely local questions because hospitals are the quintessential brick and mortar boots on the ground institutions, right? And so, what do you do in Connecticut about, you know, Windham Hospital or Sharon Hospital? We're having a big debate about maternity care at those two hospitals or Yale New Haven Health. And their announced acquisition of Waterbury Hospital. And so, I think these are local issues. I do think that there will be multistate, at least cooperation among state attorneys general because the issues replicate themselves in other states, although every state's regulatory regime is different. The issues are largely the same. So, I just it's one of those things that I think is just not going to go away.
Best Practices: Working with State AG Office
Stephen Cobb: One of the things that I try to ask guests who have been so kind to spend their time on the podcast is what are some tips for folks who want or need to engage with your office? Either from the citizen side who want to reach out about something that's a going concern or on, you know, the corporate private sector side who might find their business or business model under the ambit of the regulatory oversight and enforcement from state AGs. Any suggestions?
William Tong: So, from the citizen perspective, that's easy. You know, know how to get in touch with your attorney general. Know what their authority is. And I don't mean read the statute books. I mean, just generally understanding in Connecticut, if I have a criminal complaint, I shouldn't call William, right? Because William doesn't have that power, I should call my local police or the state's attorneys. But you know, if you are concerned about an issue I just talked about, health care consolidation. Well, you can know I'm working on it and if you have something to share you should reach out and it's easy enough to go on a website and send an email or a complaint or a complaint form. And we look at every single one, you know, and if there's something there, we will definitely take action and take a look at it. I think to folks who are wondering about state attorneys general and you have a business or you have an initiative or you're part of an industry and you're wondering whether to engage with state attorneys general. The answer is yes, yes and yes. Do engage, and don't think that if you don't engage that somehow problems are going to go away, they won't. And the reason why is because, as I said earlier, our constituents, the people to whom we are accountable, the people that vote for me and the people that don't vote for me, by the way, they expect that I'm going to take strong and aggressive action to protect them and their families. And it is hard to conceive of an industry in which there's not some issue that people are concerned about, right? Some public safety issues, some health and security issue, some consumer protection issue. You know, if you're a wedding venue in Connecticut, you could not have thought that well, when the pandemic rolled around, you would get a call from the state attorney general's office. But you did. Why? Because people's weddings got canceled, right? And they put down five, ten, twenty grand or more as a deposit on their wedding. And then when they couldn't hold their wedding because of COVID restrictions, they were out all that money and they called the Attorney General's Office. And that is barebones, you know, basic blocking and tackling for an attorney general, right? And consumer protection. So there are some industries, some companies, big ones that have decided I'm just not going to engage because a bunch of AGs have said bad things about us and we don't like that and we're going to take our ball and go home. Good luck with that. You know, because state AGs are not going anywhere. If it's not me, it'll be somebody else and they'll have the same authority and have the same constituents saying, "Are you going to do something about that?" And the answer is always, yeah, I am going to think about that. It's hardly ever no.
State AGs are not going anywhere. If it's not me, it'll be somebody else and they'll have the same authority and have the same constituents saying, "Are you going to do something about that?" And the answer is always, yeah, I am going to think about that. It's hardly ever no.
Stephen Cobb: So, engage early and often.
William Tong: Yeah, even if there are a number of big companies, for example, in the pharmaceutical space, with whom I have active pending litigation investigations. That doesn't mean we don't talk, that doesn't mean we don't have a relationship.
Stephen Cobb: You know, as we start to kind of wind down our chat a bit. I always, when I have the opportunity to have an attorney general on the podcast, I always like to ask from a couple of things that come up on their Twitter feed. And so, when General Ford was on, I talked to him about his caning display. His fraternity does, kind of, a dance that involves a cane and he was challenging General Raul to do the same dance. When General Nessel was on, I asked her about so many things on Twitter - she was a good sport in answering.
William Tong: I'm only laughing for the listeners because General Nessel is a prodigy.
Stephen Cobb: Oh, yeah. I mean, her PSA skits are informative and hilarious.
William Tong: Yeah.
Stephen Cobb: So can you tell our listeners about what is a Tong Tasting?
William Tong: A Tong Tasting is when the attorney general gets hungry and he's crisscrossing the great state of Connecticut, and he sees he sees a sign, right? For example, and the sign is a big cartoon drawing, slash billboard of a pig's head. And it says Noack's Meat Products. And, you know, it's like the heavens open up and the seas part. And I look at it and was like, I got to go check out Noack's Meat Products. And sure enough, Noack's Meat Products is one of my favorite places in Connecticut. It's a butcher with fresh made sausage products, mostly Polish and German sausage. So, my favorite is half veal, half pork bratwurst. Eat it all summer long. You know, their hot dogs, their Italian sausage, hot and sweet. Amazing. And so, that's what I do often. I'm driving around Connecticut because that's what the attorney general does. I go to this event or that event and have this meeting or speak at, you know, that group. This school. And then in between, I got to eat because, you know, it takes a lot to power this train. And so, I will stop in a Noack's Meat Products or a road food place. Or, you know, my specialty, of course, is ethnic food, especially Asian food. And when I get there, sometimes I'm with some local leader or personality and we'll highlight, you know, for example, the Glenwood. One of my favorite road food places in Hamden, Connecticut. Or New Haven Pizza, best pizza on earth.
Stephen Cobb: I don't want to get back into the what state has the best pizza.
William Tong: Not even close.
Stephen Cobb: General Nessel weighed in on Detroit style as well. It's a bit of a thing. I've also noticed some home culinary editions to Tong Tastings, but it is one of your Twitter staples. And so, I just wanted to ask.
William Tong: Got to be well nourished to do this job.
Stephen Cobb: There you go. General, you've been so incredibly generous with your time, but before I sign off, I wanted to give you a chance if there's something that you wanted to highlight that your office is up to or that's going on in Connecticut? I wanted to make sure you have that opportunity.
William Tong: I just want to say this is an incredible, for anybody wondering, it's an incredible opportunity/honor to be an attorney general. I can hardly think of five lawyer jobs I'd rather have in the world. And I bet if you ask my colleagues, they would say the same thing. And so, I'm very grateful for the people of our state, the people of Connecticut who have given me the opportunity to serve them in the state in which I was born, the first American in my family. It means the world to me.
It's an incredible opportunity/honor to be an attorney general. I can hardly think of five lawyer jobs I'd rather have in the world. And I bet if you ask my colleagues, they would say the same thing. And so, I'm very grateful for the people of our state, the people of Connecticut who have given me the opportunity to serve them in the state in which I was born, the first American in my family. It means the world to me.
Stephen Cobb: That's fantastic, and thank you so much for your time and for your service. My name is Stephen Cobb. This has been Holland & Knight's Eyes on Washington podcast series, our State Attorneys General edition. Thanks so much for listening!