On the Proposal for the CUNY Graduate Center’s Doctoral Students’ Council to Boycott Israeli Academic Institutions (Jadaliyaa)

In April 2013, the Association for Asian American Studies (AAAS) became the first United States academic body to pass a resolution boycotting formal relations with Israeli universities. In December, the American Studies Association (ASA) and the Native American and Indigenous Studies Association (NAISA) also passed boycott resolutions, followed by the Critical Ethnic Studies Association (CESA) in July 2014. These resolutions were adopted in response to the 2004 call from Palestinian civil society to boycott academic institutions in Israel, as part of a wider Boycott, Divestment, and Sanctions (BDS) movement against Israeli occupation of Palestinian people’s land, resources, and cultures. Each resolution pointed out that the boycott does not apply to individual Israeli students, scholars, or disciplines, but Israeli academic institutions that are structurally complicit with the state’s violence against Palestinians.

The response to the resolutions—especially towards the ASA, whose membership contains five thousand scholars, many of them highly distinguished in the academy—was largely characterized by a flurry of reactionary Zionist sentiment buttressed by liberal condemnation of the suppression of “academic freedom.” University administrations across the United States condemned the ASA resolution, including former CUNY Graduate Center President and then-CUNY Interim Chancellor William Kelly, who used the opportunity to announce a new partnership between the Zicklin Business School at Baruch College and the College of Management Academic Studies in Rishon LeZion, an academic institution in Israel that has principally set itself the goal of “creating robot-powered applications particularly for the military and security forces” of both Israel and the United States.

Kristofer Peterson-Overton’s article on “Academic Freedom and the Boycott” in the February 2014 issue of the Graduate Center Advocate eloquently points out the inherent fallacies in attempting to prevent the academic boycott on grounds of the purported suppression of academic freedoms. If anything, pro-Palestinian students and scholars have been restricted in their expressions of academic freedom. This is most saliently evinced by the University of Illinois Urbana-Campaign’s decision to rescind an offer of employment to Steven Salaita, a Palestinian American scholar of Native American literatures, after his tweets criticizing the Israeli state and its supporters this summer during “Operation Protective Edge”—which resulted in 2,143 dead (including 578 children) and 11,100 wounded in Gaza—galvanized anti-Palestinian UIUC donors to press for what was in effect a termination of his employment. Additionally, various chapters of the student organization Students for Justice in Palestine (SJP) have experienced growing repression on campuses across the United States, from routine surveillance of club activities, to background checks on invited speakers, and metal detector checkpoints and heavy security/police presence at their events, as documented by the Center for Constitutional Rights and Palestine Solidarity Legal Support.

A September 2014 resolution for the Doctoral Students Council (DSC) of the CUNY Graduate Center to boycott Israeli academic institutions—proposed by an ad-hoc group of students from several CUNY Graduate Center programs, DSC chartered organizations, and political affiliations—is in fact part of these ongoing expressions of academic freedom and in-depth dialogue in our disciplines and academic associations, not an attempt to squelch the open exchange of information and ideas. The politics behind the resolution had been discussed in a widely publicized, co-sponsored, and attended April 2014 Graduate Center event, “BDS and Academic Freedom,” as well as previously in various events around CUNY, such as a February 2013 Brooklyn College panel featuring Judith Butler and Omar Barghouti on the “BDS Movement for Palestinian Rights” (both of which detractors from inside and outside the university vehemently tried to shut down). An earlier iteration of the resolution had been discussed and widely supported in the May 2014 DSC plenary, although the meeting did not have quorum to conduct a vote. It is a democratic decision, following all of the formally recognized DSC proceedings, which can ultimately demonstrate that the Graduate Center student body stands in solidarity with oppressed peoples in Palestine, and against the atrocities committed by the Israel Defense Forces in particular and the Israeli state in general.

Clarity after the Dust and Bluster Settle

The first DSC plenary of this academic year, in which the resolution was presented, was held on 12 September. Over one hundred people crowded into Graduate Center room 5414 to witness and participate in the debate over the resolution. Haaretz, a liberal Israeli newspaper, sent a journalist to cover the proceedings. That whole week, DSC officers had fielded an avalanche of threatening phone calls, emails, and tweets urging them to abandon the resolution. Members from such varied DSC chartered organizations as the Adjunct Project, AELLA, Africa Research Group, Africana Studies Group, Comp Comm, Critical Palestine Studies Group, CUNY Internationalist Marxist Club, GC Poetics Group, Immigration Working Group, Jewish Connection Group, Middle Eastern Studies Association, Postcolonial Studies Group, Prison Studies Group, QUNY, Space Time Research Collective, and Women of Color Network, and representatives from CUNY for Palestine, Hillel, Stand With Us, Students for Justice in Palestine, and the Israel Campus were also present for the debate.

The plenary was chaired under Robert’s Rules of Order, open to the public, with speaking rights restricted to those with credentials (though DSC representatives could cede their time to members of the audience). Prior to the boycott resolution debate, the plenary heard several concerns about sexual harassment in GC housing and the need for Title IX awareness, a potential pattern of women students of color’s fellowships being revoked because of vague “progress challenges,” graduate student representation in the Professional Staff Congress and in contract negotiations, and NYSHIP’s potentially illegal switch of mental health coverage to the company Value Options.

During the preceding week, opponents of the resolution argued that GC students who observed Shabbat were being left out of democratic participation by the DSC plenary being held on a Friday night. DSC plenaries have been scheduled, for at least the last several years, on Friday nights with no condemnation of the practice until now. When the aforementioned issues were discussed, not once was a concern over democratic representation raised. It was only aired when the boycott resolution was brought to the table. This makes the opponents’ accusations especially disingenuous, as if Sabbath-observing students would only care about the boycott resolution, but not sexual violence, union democracy, or any other aspect of DSC business until now. When the boycott resolution came up for discussion, DSC Co-Chair of Communications and chairperson Dominique Nisperos facilitated the decision to allot twenty minutes of speaking time in support of the boycott, twenty minutes for those opposed, and twenty minutes for undecided representatives.

Those in favor of passing the resolution were randomly selected to speak first. Sean M. Kennedy of the English Program, one of the principal individuals behind the resolution, ceded his time to me, Conor Tomás Reed (also in English), who spoke first on behalf of those who supported the resolution. I pointed out that the resolution was not being put forth in a vacuum. The American Studies Association, Association for Asian American Studies, Native American and Indigenous Studies Association, and Critical Ethnic Studies Association—bodies comprised of thousands of colleagues in the academy—have all voted to support this boycott. Palestinian civil society (including unions, schools, community and legal organizations, religious groups, neighborhood associations, and cultural collectives) has made a broad call for global solidarity to support BDS. Furthermore, I pointed out that the United States government funds the state of Israel, over three billion USD per annum, and Israeli academic institutions provide research, scholarships, funding, personnel, and ideological backing to the Israeli military as well as to occupation and settlement projects. I cited the recent “Operation Protective Edge” Israeli incursion into Gaza in July-August of 2014 as placing the urgency of this issue in stark relief, then reiterated that the boycott does not target specific individuals or disciplines, but academic institutions. I also highlighted that the resolution does not restrict travel into Israel—indeed, one Distinguished CUNY Professor, Sarah Schulman, had honored the boycott call by creating a “solidarity tour” in Israel and Palestine, as detailed in her 2012 book Israel/Palestine and the Queer International.

Robert Bell, the representative for the Middle Eastern Studies Program, spoke next, further stressing that the nature of BDS was not intended to stifle debate, but to target institutions within Israeli society that are complicit with the oppression of Palestinians. Balthazar Becker, an English Program representative, ceded his time to Nirit Ben-Ari, who spoke next. Ben-Ari, an alumna of the Political Science Program, had lived in Israel and worked at Hebrew University in Jerusalem and voiced that many Israelis support the boycott. She reminded the audience not to conflate criticism of Israel with anti-Semitic rhetoric and that conscientious people should support the academic institutions boycott as a “basic act of democracy that is non-violent.” She also acknowledged that anti-occupation Israelis, in such groups as Boycott from Within, have been some of the most ardent and articulate proponents of the boycott. Ben-Ari concluded that support of the DSC resolution was a moral act that students at the Graduate Center could take to support oppressed Palestinians.

Velina Manolova of the English Program then considered the reasons why a body such as the DSC was involved in such a debate. She pointed out that the resolution has no chance in stopping the oppression of Palestinians, but that it was a measure through which bigwigs in government would feel pressure from their constituents to rethink their relationship with the Israeli state. Manolova also pointed to the issue of Palestinian and BDS activists at CUNY being intimidated, as well as being spied upon in recent months. Colin Ashley, of the Sociology Program and former DSC Co-chair for Business, spoke next, again reiterating that the proposed boycott was against structures rather than people. He argued that real lives are at stake and that power between Israelis and Palestinians is grossly asymmetrical. Ashley pointed out that this inequity stifles voices and any modicum of social parity, and that BDS “evens the playing field.” He emphasized that Palestinian lives and voices in this situation, where power is unequal, has real consequences in academic access and processes. Ashley concluded that the resolution was a necessity if the GC student body was in favor of supporting the voices of the oppressed and marginalized.

Sean M. Kennedy then urged the DSC representatives to take a stand on the issue, and mentioned those students not able to attend but were in favor of such a resolution being passed, namely Rayya El Zein, one of the original authors of the resolution. Erik Wallenberg of the History Program spoke last. He suggested utilizing the term “apartheid” to describe the Israeli social, political, and economic subjugation of Palestinians, and likened the contemporary BDS movement to the anti-Apartheid struggle in South Africa in the latter part of the twentieth century. Wallenberg went on to discuss the Steven Salaita case and why it was important now, more than ever before, for the DSC to “stand on the right side of history” and challenge the United States’ facilitation of Israeli aggression against the population of Palestine. He also recognize that Palestinians don’t have “academic freedom” under imposed “apartheid” conditions, are offered only limited mobility, are forced to use bombed-out schools, and have few, if any, academic resources.

Those opposed to the resolution spoke next. Anick Boyd of the Comparative Literature Program ceded her time to Asaf Shamis. Shamis, also an alumnus of the Political Science Program, eschewed the notion that the debate was specific to “pro” versus “anti” Palestinian agendas. Rather, he stressed that the “real issue” is academic freedom. Shamis claimed that the current resolution endorsed the restriction of knowledge based on nationality. Erin McKinney-Prupis of the Public Health Program spoke next. She led with the technological and medical advances achieved by Israeli doctors and how such achievements were ostensibly accomplished in conjunction with support from academic institutions within the United States. McKinney-Prupis went on to mention some sixty ongoing joint-research projects between Palestinian and Israeli scholars. She stated that she found the resolution to be anti-Semitic and felt “targeted as a Jew” and that the resolution, if passed, would drive a wedge between Israeli and Palestinian students. McKinney-Prupis also argued that any sort of BDS legislation would fail to achieve peace and questioned why Israeli institutions are targeted in the resolution when other states also violate human rights.

Yuval Abrams of the Philosophy Program spoke next on behalf of those opposed to the resolution. Abrams criticized BDS in general and the DSC resolution in particular for failing to “foster discussion.” While recognizing that Palestinian students and scholars have their rights violated, he did not see the tactic of boycotting of Israeli universities as a remedy, arguing that Israeli academic institutions are powerful engines for social change and are a powerful arena of left-wing thought. He also mentioned that Israeli academics traveling to the United States need funding from their universities, so communication and fiscal matters should remain open on an institutional level. Abrams questioned whether restricting the movement of people is beneficial in achieving peace. He also pointed to CUNY’s current partnerships with Israeli universities as a way to expand dialogue, rather than severing it.

Cosim Sayid, also in the Philosophy Program, spoke after Abrams. Sayid was “shocked” to receive the resolution, which he sees as opposing academic freedom, citing other problems at CUNY that should be of more immediate concern. He criticized the DSC for allegedly jumping “petitions and other democratic means,” putting the resolution on the plenary agenda. Sayid expressed fears that the success of the resolution would prove deleterious to the DSC’s relationship with the new president, chancellor, as well as with the board of trustees. Citing the University of Haifa, where thirty-three percent of the student body is Arab, Sayid stated that the political situation in the region “doesn’t sound like apartheid.”

Naomi Perley, a Music program representative, spoke briefly, reiterating earlier claims, before ceding her time to Eric Alterman, a professor at Brooklyn College. Alterman began his talk by stating that even if he agreed with the boycott, he would not pass it on Shabbat. He likened the proponents of the resolution to “communists making decision behind closed doors in the middle of the night.” Alterman contested the idea that the boycott does not impact individuals, arguing that scholars need institutional support to attend conferences. He also put forth the idea that any BDS measure was actually “pro-occupation” as it singles out Israel for opprobrium and makes it difficult to find a two-state solution. Alterman summed up the speeches on behalf of the opposition camp by stating that the resolution would foster contempt of free speech, that the proposed resolution, as well as BDS in general, was “about doing away with the state of Israel,” and finally, that it would have been an act of self-disrespect to vote for such a measure.

Undecided representatives spoke to the plenary last. Elyse Steenberg of the Music Program worried as to the professional consequences of endorsing the resolution, principally for research and future career positions. Laurie Hurson of the Environmental Psychology program, while leaning towards supporting the boycott (though with some issues in the wording of the current resolution) pointed out that she was at the plenary to represent her constituents, many of whom are undecided. She went on to request more time to speak with people in her program. Liza Shapiro, David Nagy, and Ian Haberman, representatives from the Comparative Literature, Philosophy, and Economics Programs respectively, went on to echo Hurson’s desire to have more time to discuss the resolution with their constituents.

What followed the speeches of each of the three camps was a general conversation about direct democracy versusliberal representative democracy. This was arguably a tactic for certain DSC representatives to justify tabling the decision until a future meeting without actually talking about the specific issues of the boycott resolution. It seemed that a good share of voting participants in the room didn’t sufficiently gauge themselves and their programs in order to decide on the matter, and were concerned with receiving any backlash that may occur. However, one Anthropology student, who couldn’t speak before the allotted discussion time ended, later explained that their program representative had promptly used the previous week to share the resolution with their fellow students, gather opinions, answer questions, and be prepared to give a fully informed vote at the plenary. It remains unclear why this active representative democratic process wasn’t more widely practiced across the programs.

Soon after a majority vote was made to table the resolution until the next DSC plenary on 24 October, most of the room cleared out, which made the boycott opponents’ accusations regarding democratic participation doubly disingenuous. Those who did remain in the plenary honored the sometimes long, tenuous, often unsung, but exceedingly crucial project of democracy.

Anti-racism, not Anti-Semitism

As ardent supporters of this boycott resolution, we underscore our condemnation of one of the most slanderous and misguided accusations waged thus far—that the resolution targets Jews. For the record, Jews at the Graduate Center—alongside Afro-Americans, Arabs, Caribbeans, Eastern Europeans, Latin Americans, South Asians, and more—contributed to writing the resolution, spoke on its behalf, and aptly identified the historic significance of taking a(nother) concrete stand against a Eurocentric nation-state that espouses a violent nationalist ideology predicated on racial supremacy, hyper-spatial policing, forced expulsions, and ethnic segregation. As Ben-Ari pointed out in the plenary, we should not conflate criticisms of the Israeli state with anti-Semitism. The criticisms put forth in the current resolution, and of BDS movements more generally, do not address some essentialized “Jewish character,”but hold accountable the actions of the state of Israel as a polity. The claims of an ethno-religious bias in the resolution are a misreading, whether intentional or mistaken, and actually elide the poly-ethnic alliances that Graduate Center students are creating in support of BDS.

Furthermore, Alterman’s red-baiting comments about midnight show trials, while not representative thinking of all those who opposed the resolution, willfully obscured an abundant record of Jewish left-wing radicalism, while demonstrating through his most callous attempts at fear-mongering that, to some, this critical debate is more about preserving the status quo in Israel than ameliorating the oppression of Palestinians. Alterman’s selective snapshot of Jewish political history refuses to recognize the communist, socialist, anarchist, anti-fascist, civil rights, and anti-apartheid Jews who led social movements in the United States (including CUNY!) and around the globe. This longer perspective is needed to understand why, in 1914, as Arthur Liebman documents in Jews and the Left, Zionist organizations in the entire United States numbered in total about twelve thousand members—the same number of Jewish members in the Lower East Side branch of the US Socialist Party. To equate Zionism with Judaism erases entire generations of Jewish ideas, actions, and political traditions who oppose(d) the kinds of atrocities that the state of Israel currently conducts and tries to justify.

More recently, a public stand taken by over 350 Holocaust survivors, their descendants, and victims of the Nazi Genocide, in a statement to The New York Times, also offers a crucial alternative reading on the politics espoused by Jewish people. The statement concludes:

We must raise our collective voices and use our collective power to bring about an end to all forms of racism, including the ongoing genocide of Palestinian people. We call for an immediate end to the siege against and blockade of Gaza. We call for the full economic, cultural and academic boycott of Israel. ‘Never again’ must mean NEVER AGAIN FOR ANYONE!

Jews and Israelis represent a growing number of BDS’s most incisive advocates who call for social justice movements to confront all Israeli institutions that perpetuate the suppression of Palestinian (as well as Arab Israeli and asylum-seeking African refugees’) political, social, and economic rights. Anti-occupation Israelis themselves recognize that Israeli citizens reap varying material benefits of these state-sanctioned inequities—that they cannot simply engage in dialogue and collaboration with Palestinians without changing the power structures deeply embedded in the region—and that therefore their participation in tangible solidarity actions is necessary for a viable solution. The BDS movement recognizes that anti-Semitism and anti-Arabism/Islamophobia are two sides of the same violent bigotry, and that a multi-faceted resurgence of radical coalitional unity against racism is necessary to confront all attacks on people’s ethnic, cultural, and religious identities.

As a result of this anti-racist movement work, BDS supporters have been able to highlight a nuanced debate involving whether Israel is a settler-colonial regime that reproduces apartheid policies akin to indigenous genocide in the formation of the United States, Canada, Australia, and New Zealand; United States colonialism in Cuba,Puerto Rico, Guam, the Philippines, and Hawai’i; the long history of European colonization of Africa, India, Latin America, and the Caribbean; and the most noted comparison, the South African apartheid regime. Hafrada (the literal translation from Hebrew being “caused separation”), a state policy of Israel since the 1990s, advocates unilateral separation and segregation of Palestinians from Israelis. This policy provides the ideological as well as the material basis for the subjugation, destruction, and theft of Palestinian land and resources. As well, South African Archbishop and Nobel Peace Prize winner Desmond Tutu stated in 2010, “I have been to the Occupied Palestinian Territory, and I have witnessed the racially segregated roads and housing that reminded me so much of the conditions we experienced in South Africa under the racist system of Apartheid.” The flawed assumption (held by some of the resolution’s opponents) that a two-state solution is necessary for peace, justice, and an equitable society evinces a process that would in fact further segment and box off Palestinian voices, more so than they have already been marginalized. To agitate for a democratic and secular Palestine, a one-state solution, where Jews and Arabs are full and equal citizens with equitable access to resources, employment, suffrage, religious affiliation, and freedom of movement, can advance a unique goal of transformative justice.

Academic Freedom for Whom?

As students and scholars, our relations to academic institutions at home and around the globe, far from being taken for granted, should always be critically examined and (re-)constituted according to how our moral and political views coincide or conflict with these institutions. With this “critical university studies” structural analysis (see insightful explorations here, here, here, and here), we emphasize that the boycott resolution does not abrogate the academic freedom of Israeli students and scholars. In fact, we identify these students and scholars as key interlocutors in a critical appraisal of Israeli academic institutions’ complicity (ranging from silence to jingoistic cheerleading) in the government and military’s almost ceaseless immiseration of Palestinian life. If anything, the boycott resolution represents the DSC’s more amplified capacity for academic freedom, in that it demonstrates a careful thought process of deciding which institutional ties, if any, should be made.

In particular, as the resolution mentions, an urgency to divest the developing institutional ties between the Zicklin Business School at Baruch College and the College of Management Academic Studies in Rishon LeZion moves beyond an ambiguous debate about “dialogue” and actually enters the inter-embedded terrain of moral and financial accountability. The Zicklin Business School’s affairs especially warrants scrutiny, in light of being charged in 2012 with fixing students’ grades so that they could maintain high-profile Wall Street internships. Perhaps instead of creating new academic partnerships, CUNY should more amply fund all of its existing colleges.

But why, we must ask, does prevailing discourse tend to rush to defend the academic freedom of Israelis, while saying nothing of Palestinian students, scholars, disciplines, universities? As Curtis Marez, former president of the American Studies Association, wrote in a widely circulated New Year’s Eve 2013 op-ed in The Chronicle of Higher Education defending the ASA’s academic boycott,

If there is any group whose academic freedom is being denied, it is the Palestinians. The Israeli occupation prevents Palestinian academics from accessing outside institutions of higher learning and professional conferences, hampering their ability to do their work, while Israeli authorities make it difficult for foreign academics to travel to Gaza and the West Bank.

As for Palestinian students, their universities are directly targeted for Israeli military bombing campaigns, as theIslamic University in Gaza endured in 2008 and 2014, which they can’t rebuild because Israel limits the amount of concrete that comes into Gaza. Palestinian students face daily checkpoints that impede movement to and from school, cannot travel from Gaza to the West Bank to attend lectures and conferences, are denied entrance by Israel into the United States on Fulbright scholarships, and hold graduation ceremonies that honor the names of scores of killed classmates. It is time to dramatically reframe the debate: the academic and political freedoms of Israelis—and of ourselves—must never come at the expense, indeed the erasure, of the academic and political freedoms of Palestinians.

To go further, as Graduate Center students who are also contingent academic workers, this debate on academic and political freedoms must be reframed as a labor issue. The precarity of our own positions in a university that ispublic, urban, multi-racial, poor, and increasingly militarized and surveilled, likens our experiences much more to Palestinians than Israelis. We too face checkpoints, harassment, political repression and exploitation, paltry resources, distant wealthy administrators, occupying police and security forces, and the growing names of the dead and dying, albeit on a much less catastrophic scale. When we demand better living, working, and studying conditions, our claims for justice resonate within a broader chorus of the oppressed.

To “strike” against occupation—and what increasing numbers of people characterize as apartheid—with this academic boycott is to join our colleagues in several academic associations that have lucidly recognized their intersectional labor power in this movement, as well as to stand alongside the International Warehouse and Longshore Union (ILWU) that refused in August 2014 to unload Israeli Zim ship goods in Oakland, to embrace the historical actions of the 1955-1956 Montgomery Bus Boycott and 1965 United Farm Workers grape boycott (among so many others), and to join the efforts of such cross-industry coalitions as US Labor for Palestine.

Enact Democracy at the CUNY Graduate Center

In hindsight, we assess that the undecided representatives in the DSC plenary, more than the resolution’s opponents, are the most crucial faction who will determine whether the resolution will pass. Those still undecided have taken the step to become intellectually and politically animated by these debates that will determine not just the future of the Palestine-Israel Conflict, and the United States’ intimately implicated role in it, but our own moral compasses in the academy. Altogether, had a vote been taken, the boycott could potentially have been defeated. So even though DSC members voted to table the resolution until a future meeting that would not conflict with Shabbat (a first in DSC history), this is arguably a positive development for supporters of the resolution.

We now have more time to talk with people in our programs, do informational tablings on campus, write newspaper op-eds, and activate the many students/faculty/staff BDS advocates in the Graduate Center who were not in the room. The question of what kind of democracy we want in the DSC—which represents more than 4,700 masters and doctoral students—is certainly important, and did have a place in the debate, although not at the expense of discussing what stance the boycott intends to enact. We recognize that some of the wording in the resolution warrants further clarification, as should certain provisions and their methods of implementation. In spite of this, the philosophical, political, economic, and moral foundations of the resolution remain exceedingly legitimate.

While BDS measures alone will not liberate Palestinians, the endorsement of this DSC resolution amplifies the wider cause of human rights and dignity in the face of horrific state violence. BDS offers a way for those of us in the United States to directly support the Palestinian struggle against Israeli occupation and repression, as well as to oppose Islamophobia and targeted surveillance of Arabs and Muslims in the United States, and to condemn an essentializing anti-Semitism that would assume all Jews support Israel’s actions. Support of this resolution is a moral decision that addresses multiple levels of the oppressed and ostracized, and it takes a stand on the historically marginalized issue of neocolonialism.

The next time that this boycott resolution comes to a DSC plenary, it should be voted upon and roundly passed. The road to collective liberation is long (sixty-six years since the Nakba, seventy-one years since the Warsaw Ghetto uprising), and so this is one step of many in creating a vibrant political culture that can affirmatively support human life and dignity for everyone, but especially for those who are most oppressed by—and most resilient against—militaries and nation-states guided by ethnic supremacist ideologies like Israel and the United States. We encourage you to reach out to your DSC program representative and tell them what you think of the resolution so that they can knowledgeably—with principle—vote on this important decision.

[A version of this article appeared in the GC Advocate, Volume 26 Issue 1.]