Final month, we hosted a webinar on federal hashish regulation and coverage in 2026. Whereas issues will not be the place we’d like them to be, it’s wonderful to contemplate all the things that has occurred through the years. From a lawyering perspective, it’s nearly unbelievable.
I’ve labored as a enterprise lawyer within the hashish trade for over 15 years. It’s been a protracted, unusual journey because the poet stated. And I’m grateful for it. Beneath is a long-form piece on the way it all went down.
2011
I used to be a second-year lawyer at a enterprise agency downtown when a medical marijuana dispensary proprietor got here by means of our workplace. (Again then, no person stated “hashish.”) His store was right here in Portland, with a develop within the again, and the proprietor had been handed alongside by two different regulation corporations that felt uncomfortable advising him. This gentleman had acquired a chapter trustee’s discover on his door, advising that his landlord was in a Chapter 7 (I feel). He desperately wished to remain within the constructing. Possibly even purchase it, someway.
We appeared on the lawyer ethics guidelines, known as the state bar affiliation, learn the Ogden memo, and many others., and it was unclear whether or not we might help the shopper—even concerning compliance with state and native legal guidelines. It was unclear whether or not our malpractice insurance coverage prolonged protection. It was unclear whether or not our financial institution would take the deposits. It was unclear if his enterprise even complied with Oregon regulation to start with. Every part was unclear; nobody would opine. The first Cole memo issued that summer season, making issues much more complicated. However, the solutions weren’t clearly “no” and my boss invited me to strive. I had no downside with any of it.
I ended up serving to the shopper attain a deal to pay money lease to the Trustee—which might by no means occur at this level: the cost half is wild; the money protocol, outrageous—after which I began serving to him with enterprise agreements and all the things else. Again then, there have been nearly no legal professionals engaged on non-criminal hashish points. He began sending me trade referrals, one after one other. It was a loopy time—the work was much less subtle but additionally more difficult in some respects than a lot of what we do as we speak.
Looks as if all of these individuals are gone now.
2012
Oregon was not licensing medical marijuana dispensaries, however folks had been boldly opening collective-style storefronts, just like the man I simply talked about, ostensibly underneath the state’s decades-old medical marijuana statute. That regulation was not designed for commerce, in any respect. The coverage concept was to easily to confer an affirmative protection to “sufferers” and “caregivers” from prosecution underneath state regulation for hashish possession and use. That’s so far as it went.
Lots of the companies I handled in these days had self-organized as non-profits and collectives and such, as borrowed from the California mannequin. I couldn’t discover accountants for them, or something actually. It was such a large number.
That fall, Oregon’s Measure 80 narrowly misplaced on the polls, 47% to 53%, whereas Colorado and Washington handed legalization measures. Measure 80 would have legalized hashish for grownup use statewide in Oregon, established a licensing and taxation system, and many others.—which finally occurred a couple of years later underneath Measure 91. Elsewhere, trade pioneers like California’s Harborside dispensary (which might later turn into a shopper; then go public; then fail) had been going at it with the feds. In these days, all the things was a rock struggle.
2013
The Oregon legislature handed a regulation known as HB 3460 that August, directing the Oregon Well being Authority (OHA) to jot down guidelines and launch a registry system for medical marijuana operators. This was an enormous deal! Purchasers appeared nervous: there was no trade foyer to talk of, and all the things coming from Salem appeared reactive.
The second Cole Memo additionally issued that summer season, in response to the pending Washington and Colorado grownup use applications. It felt like issues had been altering fairly quick. My boutique enterprise regulation agency “merged” with a mid-sized regulation agency downtown that catered to monetary establishments and didn’t like hashish. I continued to quietly do the work. Lots of that work was unsupervised; someway all of it labored out.
2014
OHA issued its guidelines, which had been skeletal, unenforced and ass-backwards on sure issues. There have been no hashish testing necessities; no grandfathering protections for present storefront operators; a rule that individuals who had been convicted for “manufacture or supply of [cannabis]” couldn’t be “chargeable for” a hashish retailer (?!); and I can’t even bear in mind what else. However I recall shoppers coming to us with so many questions and issues which had been basically unanswerable, as a result of the framework wasn’t there. That November, Measure 91 handed, legalizing hashish for grownup use in Oregon. Lastly.
On the federal aspect, the Division of the Treasury issued the FinCen Memo on “BSA Expectations Concerning Marijuana-Associated Companies.” This was accompanied by one other DOJ memo titled Guidance Regarding Marijuana Related Financial Crimes, and a DOJ memo on “Marijuana Issues in Indian Country.” The latter two directives had been rescinded four years later by Legal professional Normal Jeff Periods, however the FinCen Memo is someway nonetheless in impact. Greater than a decade later, I’d discover myself advising banks, credit score unions and even the federal authorities on that cumbersome steerage.
2015
The Oregon legislature began messing with Measure 91 nearly instantly in drastic methods (e.g. tax construction, residency requirement). A few of my shoppers began to ramp as much as transition into the OLCC program, however many sat again and waited. Folks had been getting larger and bolder on the medical aspect. We started to see a proliferation of medical marijuana processors and “wholesalers” round this time, though none of this was contemplated within the guidelines. Numerous crazy stories.
The Oregon State Supreme Court docket amended the legal professional ethics guidelines in February, to expressly permit us legal professionals to work with marijuana enterprise “concerning Oregon’s marijuana-related legal guidelines.” Most legal professionals remained on the sidelines, although. I left my previous agency in June, and began the Portland workplace of what would turn into Harris Sliwoski LLP. Lots of people appeared to assume that was a loopy transfer, nevertheless it was actually enjoyable. I began writing intensively right here on the weblog and I wrote the first of 100 columns for the Portland Mercury. I ended litigating completely.
Grownup use and possession grew to become authorized on July 1, which was awkward within the sense that OLCC had not but licensed shops. The state finally capitulated and allowed early gross sales by means of current medical dispensaries on October 1. The entire system was nonetheless vexing from a contracts perspective—the hashish being purchased and bought all got here in by means of the OHA provide chain, which meant it was theoretically the property of medical marijuana sufferers, at the very least to start out.
I labored with one other lawyer in my agency on one of many OLCC guidelines advisory committees, and the first batch of the OLCC program rules dropped in October of 2015. The Fee made a great run at it, however enterprise acumen was missing. The “monetary curiosity” and “residency” guidelines had been terribly complicated, and primary business ideas weren’t addressed, from convertible notes to safety pursuits. The Metropolis of Portland was even worse.
Of us began lining as much as submit OLCC functions on January 1, 2016. I recall organizing and incorporating a dizzying variety of little firms within the months main as much as that date. Again then, a typical setup was somebody with property, a man who knew develop hashish (at all times a man), and perhaps an investor with $200,000 or so. Actually easy stuff. I testified earlier than varied cities and counties with respect to cannabis-related zoning ordinance proposals, and time, place and method guidelines. A few of these hearings had been well-run and respectful; a couple of went off the rails.
2016
We muddled by means of licensing and the system started to launch. I recall considered one of our producer (develop) shoppers being informed they had been the “third licensee within the state.” The legislature started to fiddle with the system additional, together with by means of repeal of the residency requirement (HB 4014). It’s onerous to overstate how essential this was: no different jurisdiction on this planet had a hashish program the place non-residents may very well be house owners. Calls began coming in from all over the place and other people couldn’t appear to get their minds round it. However the guidelines had been clear: you could possibly be from Oregon or California or Israel or Spain. You possibly can be from Mars.
We answered a number of questions on federal regulation enforcement again then, which hardly occurs anymore. The concern issue ticked up considerably once more in November, when Donald Trump was elected President. That very same election night time, California, Nevada, Maine and Massachusetts all went leisure (and Arkansas, Florida and North Dakota all adopted medical applications), making the state/federal dynamic extra dissonant than ever. Regionally, an increasing number of OHA program contributors made their method into the OLCC system, whereas others stayed put or went off the grid altogether.
OHA lastly obtained its act collectively and began licensing medical marijuana processors, though the medical program was clearly on the best way out. The Oregon Division of Agriculture (ODA) handed a key regulation to propel the stalled state hemp program, and we had a couple of shoppers begin in on that. That they had logistical issues you wouldn’t imagine, together with discovering seeds.
2017
Jeff Periods was confirmed as Legal professional Normal to kick off the 12 months. Folks will say that didn’t scare anybody, however I’m right here to let you know that funding slowed a bit. By mid-year, although, the OLCC program started to hit its stride. Issues felt largely “constructed” for the primary time, even when a testing lab bottleneck endured, with different program kinks.
By December 2017, there have been nearly 900 licensed farms in Oregon, and the M&A market began to realize steam. There was a number of press at this level about oversupply, unlicensed cannabis and diversion. The faddish and wasteful RICO lawsuits had been in full swing. Right here on the regulation agency, we had been additionally fielding fewer calls from “medical marijuana growers,” though it was recognized that people had been nonetheless stacking playing cards and all the things else. That stated, all of these 90-plant medical grows had been going the best way of the buffalo.
Elsewhere, lots of the newer companies had been already failing and folk began suing each other in earnest. Reporters nonetheless known as every time lawsuits had been filed. I recall posting adverts for litigators, and questioning if OLCC licensees would work out earn money within the regulated market. I additionally sat for a sequence of lunches with legal professionals in mid-sized and enormous regulation corporations who had been poking across the Oregon house. Lastly, I took a couple of calls from the FBI and U.S. Attorneys on client-related investigations. Not nice.
On the hemp aspect, we noticed an increasing number of shoppers pursuing CBD gross sales, which had been coming into vogue however confusion concerning the 2014 Farm Invoice and all the things else. Below Oregon’s pilot program folks obtained crops within the floor, nonetheless. And with federal dialogue looming, it felt like hemp was lastly on the best way.
Elsewhere, I grew to become an proprietor on the regulation agency on January 1, and we opened workplaces in San Francisco and Los Angeles, which had been extremely productive for a time. That summer season, I used to be cynically sued in circuit court docket for “civil conspiracy” by a poorly supervised colleague at a big regulation agency. The allegations had been based mostly on recommendation he assumed I’d given to a hashish shopper. That declare went nowhere, however I didn’t admire it.
I started educating Hashish Legislation & Coverage at my alma mater, Lewis & Clark Legislation College, which continued over a five-year interval. We had Earl Blumenauer come converse and issues like that. In 2017, it was the second or third such class on provide nationwide. Class was bought out after which some.
2018
Jeff Periods kicked off the 12 months by rescinding the Cole Memo, which obtained folks jittery as soon as once more. The native “oversupply” dialog was coming to a head, such that Oregon U.S. Legal professional Billy Williams felt the necessity to writer a memo of his personal. Instantly thereafter, the OLCC “paused” its consumption of marijuana license functions—probably because of the memo, but additionally as a result of the Fee was simply to date behind.
The Canadian invasion was additionally in full swing at this level. Lots of our native shoppers had been rolling up on the Canadian Inventory Change by means of reverse mergers, or questioning how to do that, or speaking with somebody about doing it. Different shoppers despised the entire thing. And nonetheless different shoppers WERE the Canadians. International {dollars} had been additionally pouring into different western states by this level, largely California and Nevada.
I can’t let you know what number of mergers, reverse mergers, choice agreements, inventory sale agreements, asset buy agreements, convertible debt agreements, and many others. and many others. we papered round this time—whilst costs tanked. It was extremely dynamic and extremely quick. Round this era, we additionally had been employed by a sequence of large-cap, bellwether U.S. firms attempting to know the CBD market and what may very well be completed there. Numerous opinion work, with company campus visits. We did a sequence of superstar collabs, too; a couple of of these are nonetheless going robust.
Outdoors of Oregon, I doubt there was ever an even bigger 12 months for hashish than 2018. California commenced its grownup use market, the U.S. legalized hemp by means of the 2018 Farm Invoice and Michigan grew to become the primary midwestern state to go full rec. Internationally, Canada legalized marijuana federally, Mexico introduced its plan to do the identical, and the U.N. introduced it could revisit hashish scheduling. Oh, and Jeff Periods was sent on down the road. It was superior.
2019
Hemp was most likely the largest story regionally in 2019. Almost 2,000 growers registered to plant over 63,000 acres, an almost 6x acreage enhance from the 12 months prior. Then the issues got here. A lot of the hemp went unharvested because of unhealthy climate and inexperience. Costs additionally fell by means of the ground alongside the provision chain, from seeds to completed merchandise. Our workplace dealt with extra litigation on the hemp aspect than on the THC aspect. And folks began to make use of ODA licenses as cowl for diversion, somewhat than persisting within the OHA (medical marijuana) system.
Federally, USDA appeared to sluggish stroll the foundations, and FDA was as ineffective as ever. The ODA’s adoption of a “total THC” testing customary was additionally onerous for operators. Nationwide, the CBD craze was in full swing. A few of the nation’s largest grocers, distributors and CPG firms employed us and flew us round, after consumers and advertising departments obtained forward of themselves. The excessive level was being employed and flown to D.C. to advise the Nationwide Credit score Union Administration on guidance for hemp banking.
On the THC aspect, the Oregon legislature lastly passed a law to curtail the award of hashish manufacturing licenses, bowing to stress from all sides. It was too late to have a lot affect, though the hassle did create a powerful secondary marketplace for producer license transfers (which we proceed to commerce in as we speak). The legislature handed one other forward-looking regulation to permit hashish exports; the concept right here was to arrange native growers for the top of prohibition. Lastly, vaping got here into the regulatory crosshairs, leading to extra litigation.
2019 was the primary 12 months that the OLCC market appeared to actually settle out and there was much less compliance work than earlier than. We had paralegals masking many of the licensing. Past that, it was simply offers and offers and offers.
2020
This was the primary 12 months that Oregon handed the $1 billion gross sales mark (cresting at $1.1 billion), pushed by COVID-related components. The pool of retail licensees continued to develop, however different license classes remained static. OLCC lastly streamlined its software course of to some extent, a theme the Fee would return to in future years. OLCC additionally adopted a short-lived “fix it or ticket” method to sure guidelines violations, and enacted a ban on sure vape merchandise.
We had been nonetheless doing a number of M&A piece, most memorably for a personal fairness agency that swooped in to purchase and function expansive verticals; and which 5 years later, we put into receivership. Different shoppers plodded alongside; however with costs nonetheless low, it was a quantity proposition up and down the provision chain. General, Oregon hashish M&A very peaked round this time. We additionally noticed renewed curiosity from tribes, together with intergovernmental agreements between the Cow Creek Tribe and Oregon.
Wildfires were terrible within the fall, with one in each 5 licensed marijuana companies (or 408 companies) in evacuation protocols. A lot of producers had been pressured off web site completely. The fires hit the hemp grows onerous too, as they had been closely concentrated within the affected areas. It was a horrible time for a lot of outside hemp and marijuana licensees, lots of whom misplaced crops and gear, and had been un- or underinsured.
In contrast to the THC market, the hemp market continued to sputter. Biomass pricing hovered at $2.50 or much less per pound, versus $40 to $45 simply two years prior. We nonetheless had many litigations within the workplace arising from companies failing and traders dropping cash. A few of the work concerned SBA lending points and chapter proceedings, which was novel within the hashish house.
This was additionally the 12 months that Oregon’s Measure 109 and Measure 110 handed. I used to be considerably essential of Measure 109, which created a cottage psilocybin companies trade, and which we might advise on in coming years. Measure 110 decriminalized possession of all medication in small quantities. That experiment faltered, although, and the legislature rolled it again 4 years later. They did depart in provisions that siphoned off marijuana tax income for habit therapy companies.
Lastly, the United Nations voted in December to take away hashish and hashish resin from Schedule IV of the Single Conference (the place probably the most harmful medication stay), and into Schedule I (acknowledging medical use). I had been writing about worldwide hashish on the weblog for a couple of years, and we had plenty of fascinating issues come by means of the workplace. One among them required us to register with DOJ underneath the International Brokers Registration Act; others concerned battling Customs and Border Patrol on wrongly embargoed shipments. The agency was uniquely suited to all of that, with our international trade lawyers lending a hand. I felt I used to be studying rather a lot.
2021
Pricing and controlled marijuana gross sales plateaued in 2021, though the pool of licensed retailers continued to develop, from 719 to 760. The variety of producers additionally elevated from 1,177 to 1,388—which wasn’t wanted in any respect. However OLCC’s streamlined licensing course of was reducing by means of the backlog, following a really pregnant three-year “pause.” All in all, the trade continued to develop, regardless of a difficult labor market.
Throughout this time, we helped folks purchase and promote producer licenses in the $250K – $300K range. A couple of years later, costs would fall as little as $30K. One among our shoppers liquidated one thing like 6 licenses on adjoining tax tons round this time; and although his timing was impeccable, he was arrested driving weed round Texas shortly thereafter. He went bust completely. Anyway, lots of the license consumers had been Jap European round this time; Chinese language nationals had been one other sizable demographic, and finally took the lead.
“Artificially derived cannabinoids” had been within the regulatory crosshairs, and OLCC was tasked with regulating these compounds. OLCC and ODA additionally obtained extra enforcement funding, and launched Operation Desk Rock. It focused largely southern Oregon grows, and predictably discovered a majority of licensed hemp producers rising marijuana. The legislature then met in a one-day particular session to grant $25 million extra to enforcement. I wrote that it “wouldn’t be enough,” and it wasn’t.
Sure administrative and legal litigation ensued, although we didn’t have any of that right here within the workplace. On the nationwide degree, the enshittification of hemp was nicely underway, with delta-8 and different intoxicating merchandise being shipped nationwide underneath doubtful shade of regulation, and with scant regulation. We determined as a regulation agency to not take that work, which suggests we determined to depart some huge cash on the desk. I’m nonetheless good with that.
I obtained right into a groove of taking over expert witness matters in state and federal court docket, which obtained me again to my litigation roots and was enjoyable. I ended up testifying earlier than a jury in considered one of them, and submitting a report for federal court docket use in one other. All of those had been disputes on the usual of look after legal professionals within the hashish house. Strikes and gutters as they are saying.
Some large names made the information in regionally 2021. Dutchie, the hashish e-commerce platform out of Bend, raised a formidable $350 million in a closed Sequence D, at a $375 billion worth. Curaleaf, which we later represented on worldwide hashish transport, was sued up and down for promoting a THC product in CBD packaging—amongst different issues. And GoldenLeaf, the primary Oregon hashish outfit to roll up onto a Canadian inventory alternate, got here again from the lifeless to amass 5 Residence Grown Oregon shops.
We opened a New York workplace, which was enjoyable and lasted a few years. I felt I used to be spending practically as a lot time “working the regulation agency” as I used to be spending with precise lawyering. I used to be additionally cited by U.S. Senators Cory Booker and Elizabeth Warren in correspondence to U.S. Legal professional Normal Merrick Garland, concerning a plea to decriminalize hashish.
However my favourite lawyering reminiscence, ever, was being invited to talk for NORML down in Key West, Florida that December. After my presentation—however earlier than we went for beers with a choose who had performed himself in The Wire—I sat at a folding desk within the again, subsequent to an older gentleman. He was sporting a tank prime and a Assist the Troops cap. He stated nicely completed and shook my hand, and launched himself as Phil Hirschkop. There was one thing concerning the interplay; I Googled him underneath the desk; I rattling close to blacked out.
2022
The pandemic period tailwinds petered out, and annual Oregon gross sales fell to underneath $1 billion. Our retail shoppers started to report much less demand for marijuana flower particularly, and adjusted to fulfill rising demand within the edible and cartridge classes. Wholesale pricing dipped beneath the 2018 market nadir, which was a shock to many operators.
Home Invoice 4016 handed, enacting a sweeping moratorium on new hashish licenses within the state. This was an enormous deal! There have been grandfathering provisions and such, however HB 4016 was a proper enactment of what OLCC had been attempting to do—and what trade had been clamoring for—for years. Ultimately, OLCC had the statutory authority to drag the plug.
OLCC additionally began talking tough about “unhealthy actors” within the house, and the Fee’s observe of permitting these companies to promote their licenses whereas dealing with revocation proceedings, all however pale to black. In live performance with HB 4016, this coverage change appeared knowledgeable by an underlying aim to cull licenses. That stated, the State additionally rolled out a limited social equity program, the place “certified candidates” might obtain license choice in sure contexts. From what I can inform, it by no means had a lot affect.
OLCC stopped complying with public data requests round this time, pleading organizational and staffing points. After some forwards and backwards, we dragged them earlier than the Oregon DOJ. The system was finally cleaned up, and I’m happy to report that it continues to work because it ought to. The opposite trigger I undertook in 2022 was abuse of service agreements, after seeing a sequence of shoppers broken.
Across the county, a couple of of our legal professionals had been invited to legislative panels in states hashish regulation. We shared our ideas there and on the blog. I began going after President Biden a good bit too, for failing to fulfill his marketing campaign guarantees on hashish. He would finally provoke an ill-fated rescheduling course of, and concern some pardons. None of that squared along with his guarantees (“decriminalization”), and it felt like an enormous probability missed.
Past hashish, we had been working with psilocybin enterprise underneath Oregon’s Measure 109, and writing about psychedelics on the agency’s Psychedelics Law Blog. There was a resident possession requirement there, just like the early days of hashish, so naturally people started gaming it. I used to be additionally invited to jot down a separate piece for a Harvard Legislation journal on-line. They flew me out to talk to the scholars—one other factor I by no means might have imagined doing.
2023
Oregon gross sales fell once more coming off COVID peaks, and the variety of licensees lastly fell too. Monitoring knowledge, I continued to notice a years-long pattern of shoppers migrating away from flower, towards edibles and different merchandise. That pattern continues as we speak.
I began talking up on behalf of smaller companies regionally early within the 12 months—they had been taking it within the shorts from bigger outfits and from OLCC. And I felt so badly for a few of them.
Issues actually got here to mild when the La Mota scandal broke early within the 12 months. That chain wasn’t paying its share of taxes, or its employees or distributors per widespread allegations. OLCC additionally allow them to skate following main compliance citations that will have sunk most anybody else. La Mota did have the Oregon Secretary of State quietly on payroll, we realized, which led to her ouster from public workplace.
Launching off that scandal, I wrote a critical piece concerning OLCC’s disparate therapy of huge and small operators. A lawyer named Amy Margolis known as me on behalf of Nectar, one other chain operator, requesting I pull the piece. I declined. This resulted in a shabby ethics criticism towards yours really. The Bar swatted it away; Nectar appealed; and Nectar misplaced once more.
Lastly, one other bigger operator, Chalice, went stomach up and pursued a coordinated receivership exercise with its associated, Canadian collectors. Native belongings had been finally sold off to company insiders, who began anew. The optics on that one had been additionally horrible, with many small operators getting shafted on funds. Receivership is an equitable treatment, in fact, however the previous saying remains to be apt: “it’s not a court docket of justice, it’s a court docket of regulation.”
For its half, OHA had a tough 12 months, too, after passing a rule to mandate aspergillus testing. The rule was challenged by trade, and it was “stayed” pending judicial overview. Moderately than defend its rule at a listening to, OHA withdrew it, and deserted the hassle. Setting apart any debate on public well being, this was an actual boon for the consolidated Hashish Trade Affiliation of Oregon, the plaintiff in that case.
2024
Gross sales and pricing remained comparatively static, and the trade continued to limp alongside. In that respect, Oregon was just like all the established states, and the western states particularly. Croptober got here in with Oregon’s largest METRC harvest ever at 5,733,288 kilos, which was a full 900,000 kilos greater than the identical month in 2023. Costs predictably suffered, although I’m guessing not all of that weed stayed within the state.
We absorbed a few boutique hashish corporations right now; or components of them. Like operators and different distributors, hashish regulation corporations had been on the decline. The small corporations had been withering and the bigger corporations—which had entered the house late—had been exiting early. On the shopper aspect, we put a few bigger outfits into receivership.
That fall, OLCC despatched enforcement notices to seven of the eleven testing labs concerning THC inflation. This concern was getting a number of protection nationally; the native investigation had been going for some time; and the notices had been no shock. We noticed a few labs shutter in consequence.
A couple of notable guidelines landed in 2024 as nicely. Poll Measure 119 took impact, which required all OLCC retailers, processors and labs to signal a labor peace settlement with a “bona fide labor group.” I used to be relentlessly critical of the Measure on the weblog, calling for a problem. That lastly occurred and BM 119 was declared unconstitutional—that case remains to be up on enchantment. Lastly, we obtained new testing guidelines for hemp, and a invoice making OLCC’s licensing moratorium everlasting.
Federally, we had elections in fact. Elections with penalties. Donald Trump was re-instated as President, and the Republican Occasion claimed majorities in each homes of Congress. This was typically considered as unwelcome information for the hashish trade, and for Biden’s flawed rescheduling effort. Every part came to a head a couple of weeks into 2025, which is the place I’ll depart off.
2025
For those who made it this far, thanks and I applaud you. My 2025 “State of the State” submit on Oregon hashish could be discovered here. It offers a strong overview of how issues went final 12 months, and the place we stand as we speak.
