Presented at the 2009 Sport & Recreation Law Association Conference

1. Analysis of Release Law and
its Growth from the Common
Law
Session 57

2. Disclaimer:
All legal advice by it’s very nature is
subject to change and the laws of
each state. All legal advice requires a
review by your local attorney.

3. Reality
• No matter what we learn here a judge
can change it.
• By the time we get done with the
conference a judge has probably
changed it.
• If you are really bad, you are going to
lose no matter what

4. James H. Moss, J.D.
• OSU Environmental Interpretation
• Capital Law School, J.D.
• 500 Clients in Outdoor Recreation Field
– Individuals to Organizations
– Concessionaires & Permittees
– Manufactures to Retailers

5. Attorney for:
• O.A.R.S.
• International Mountain Guides
• Noah’s Ark
• C.A.M.P. USA & C.A.M.P. SpA (Italy)
• NRS
• American Mountain Guides Association
• G3
• Mountain Trip

6. Trials
• Whitewater
Rafting
Companies
• Snow Mobiles
• Ropes Course
• Canoe Liveries
• Climbing Gyms
• Land owners
• Ski Areas
• Mt. Everest
• Mountaineering

7. Adjunct Instructor
Ski Area Operations Risk Management

8. Editor
Outdoor Recreation Law Review

9. Outdoor Recreation Law Review
Legal News
Editorials describing legal issues that are affecting
your operation and how they need to change
Analysis of groups of cases that are affecting your
business
Specific case analysis with the actual case
hyperlinked to the analysis
Written in English
Legal & Insurance Resources

10. UIAA Safety Committee
• Union Internationale Des Associations
D’Alpinisme (International Mountaineering
and Climbing Federation)
• US Member of the UIAA Safety Committee
• European Product Standards
Governmental Organization

11. James H. Moss, J.D.
– I am the only attorney/person to win an appeal to
the Board of Land Appeals (NPS/BLM)
– I’ve participated in my OR lawsuits than all other
attorneys combined (except for ski area defense
lawyers)
– I’ve dealt with the only US litigation over Mt Everest
– I’ve dealt with Ten Fatalities with no $$ paid
– I’ve dealt with 3 Quadriplegics with no $$ paid
– I have taught outdoor skills for universities
– I have worked as a river, mountain, jungle, cycling
and rock climbing guide and I still guide

12. James H. Moss, J.D.
• I am a recovering Trial Attorney
• Citations & Writing are based on the above

13. Analysis of Release Law and
its Growth from the
Common Law

14. How to Find a Copy of the
Presentation
• Title: Common Law and Releases
• Or go to www.rec-law.blogspot.com and
search for SRLA
• Email me: recreation.law@gmail.com
– If you email me let me know if you want PPT
2003 or PPTX 2007
• Go to Google Docs and Search for Title
• http://docs.google.com/Presentation?
docid=dg2k3n4r_47hs552sss

15. What is the common law
Originated from the way of doing things in
England
Eventually written down and became law of
the US
Basis of the law in 49 states
Exception to the rule:

16. Common law and releases
Common law still controls unless it has
been incorporated into a statute or
constitution
Louisiana: C.C. Art. 2004 (2005)
New York: General Obligation Law § 5-326
Montana: MCA § 27-1-701

17. What does this
mean?

18. Contract v. Release
• If you have any meeting of the minds
• If you have any consideration
• If you have anything like a contract
You have a Contract

19. Contract v. Release
• Unless your release is written within the
strict boundaries set forth by the courts in
the jurisdiction you are arguing the release
You do not have a contract which is a
release

20. Contract v. Release
• Contracts Default to “A Contract”
• Releases Default to no release

21. Releases do not
• Do not stop claims for greater than normal
negligence – ever (*almost)
• Willful and wanton negligence
• Gross negligence
• Intentional Negligence
*Kansas does not recognize W&W or Gross Negligence so a release in
Kansas does work

22. Generally Releases will not
be upheld if
• They are hidden
• The type is too small
• They are a sign in sheet
• They are mislabeled
• They are not signed

23. Releases will be upheld if
they are
• Not read
• Signed with a fake name
• Not understood

24. Some Yes – Some No
• Not given enough time to read the release

25. States Were
Releases are
Void
Based on Statute or State
Constitution

26. Louisiana: C.C. Art. 2004 (2005)
C.C. Art. 2004 (2005). Clause that
excludes or limits liability.
Any clause is null that, in advance,
excludes or limits the liability of one party for intentional
or gross fault that causes damage to the other
party. Any clause is null that, in advance,
excludes or limits the liability of one party for causing
physical injury to the other party.

27. Montana: MCA § 27-1-701
MCA § 27-1-701 Liability for negligence as
well as willful acts.
Except as otherwise provided by law,
everyone is responsible not only for the results
of his willful acts but also for an injury occasioned
to another by his want of ordinary care or skill in the
management of his property or person except
so far as the latter has willfully or by want of
ordinary care brought the injury upon himself.

28. States were
Releases are
Void
Based on State Supreme Court
Decision

29. Virginia
Johnson’s Adm’x v. Richmond and Danville
R.R. Co., 86 Va. 975, 11 S.E. 829 (1890)
Heitt v. Lake Barnroft 418 SE 2d 894 (VA
1992)

30. Connecticut
Hanks v. Powder Ridge Restaurant Corp.,
276 Conn. 314, 885 A.2d 734 (2005)
Reardon v. Windswept Farm, LLC, Et Al.,
280 Conn. 153; 905 A.2d 1156; 2006 Conn.
LEXIS 330

31. Wisconsin
Atkins v. Swimwest Family Fitness Center,
2005 WI 4; 2005 Wisc. LEXIS 2

32. State where
statute modifies
Releases

33. New York: General Obligation Law § 5-326
General Obligation Law § 5-326. Agreements exempting pools,
gymnasiums, places of public amusement or recreation and similar
establishments from liability for negligence void and unenforceable
Every covenant, agreement or understanding in or in connection with,
or collateral to, any contract, membership application, ticket of
admission or similar writing, entered into between the owner or operator
of any pool, gymnasium, place of amusement or recreation, or similar
establishment and the user of such facilities, pursuant to which such owner
or operator receives a fee or other compensation for the use of such
facilities, which exempts the said owner or operator from liability for
damages caused by or resulting from the negligence of the owner,
operator or person in charge of such establishment, or their agents,
servants or employees, shall be deemed to be void as against public
policy and wholly unenforceable.

34. New York
Lemoine v Cornell University, 2 N.Y.3d
701; 810 N.E.2d 912; 778 N.Y.S.2d
459; 2004 N.Y. LEXIS 509 (NY 2003)
Climbing wall Accident were
education not entertainment was the
main focus of the activity

35. New York
Chieco v. Paramarketing, Inc., 228 A.D.2d 462;
643 N.Y.S.2d 668; 1996 N.Y. App. Div. LEXIS
6617 (upheld a release in a product liability
setting)

36. How a state deals with
Releases & Product
Liability Law is a state
by state review – not
here!

37. There are 46 states
where the basis of
release law is the
Common Law

38. Historically the common law
disfavored releases
Releases were found to be
unconscionable
– sense of gross unfairness
– "smell" of unfairness
However this contradicted the common
law freedom to contract

39. Consequently Releases have
always created a schism in the
law
Add to that Courts
that seem to be
more (politically)
biased to a position

40. ExamplesExamples

41. Missouri
Alack v. Vic Tanny International of Missouri, Inc, 923
S.W.2d 330, (MO 1996)
Although exculpatory clauses in contracts releasing
an individual from his or her own future negligence
are disfavored, they are not prohibited as against
public policy.
Release failed because it did not include the proper
language for a release
– exculpatory clause was ambiguous
– exculpatory clause did not use the word “negligence”
or “fault” or their equivalents

42. North Carolina
Del Raso v. United States of America, 2001 U.S.
App. 4115, 244 F.3d 567
North Carolina courts, like those of many other
states, do not favor contracts releasing parties from
liability for their future negligence, but will
nevertheless enforce such clauses unless they
violate a statute, are gained through an inequality of
bargaining power, or contravene public policy.
Defendant won based on the release

43. Maine
Doyle v. College, , 403 A.2d 1206 (1979)
We address, first, the question, whether these
documents may fairly be held to be “releases.” Courts
have traditionally disfavored contractual exclusions of
negligence liability and have exercised a heightened
degree of judicial scrutiny when interpreting
contractual language which allegedly exempts a party
from liability for his own negligence.
Plaintiff won because court determined not a
release and indemnification clause was void

44. Colorado
Heil Valley Ranch v. Simkin, 784 P.2d 781
(Colo. 1989)
Agreements attempting to exculpate a
party from that party's own negligence have
long been disfavored.
Defendant won even though release did
not contain the word negligence

45. Illinois
Pruett v. American Motorcycle Association, 54
F.3d 779 (Table), 1995 WL 302426 (C.A.7 (Ill.))
As a general rule, “Illinois does not
enforce contracts exculpating persons from the
consequences of their willful and wanton acts.
Release failed to stop claim for willful and
wanton negligence

46. Until changed by decision or
statute common law still
holds
Releases are Void as Against
Public Policy

47. Public Policy
• The needs or costs of the public exceed the
needs of the individual
• Individual meaning the person wanting to use
the release
• The public cost is paying for any injury
• The Freedom to Contract is less than the duty
Society has to an individual
• Injured people become a burden upon society

48. Current State
of Affairs

49. States that Do Not allow
the use of a Release

50. Connecticut
Hanks v. Powder Ridge Restaurant Corp.,
276 Conn. 314, 885 A.2d 734 (2005)
Reardon v. Windswept Farm, LLC, Et Al.,
280 Conn. 153; 905 A.2d 1156; 2006 Conn.
LEXIS 330

51. Virginia
Johnson’s Adm’x v. Richmond and Danville
R.R. Co., 86 Va. 975, 11 S.E. 829 (1890
Heitt v. Lake Barnroft, 418 SE 2d 894

52. Wisconsin
Atkins v. Swimwest Family Fitness Center,
2005 WI 4; 2005 Wisc. LEXIS 2

53. Montana
MCA § 27-1-701 Liability for negligence as
well as willful acts.
Except as otherwise provided by law,
everyone is responsible not only for the
results of his willful acts but also for an injury
occasioned to another by his want of
ordinary care or skill in the management of
his property or person except so far as the
latter has willfully or by want of ordinary care
brought the injury upon himself.

54. Louisiana
Louisiana: C.C. Art. 2004 (2005). Clause
that excludes or limits liability.
Any clause is null that, in advance, excludes
or limits the liability of one party for
intentional or gross fault that causes
damage to the other party. Any clause is null
that, in advance, excludes or limits the
liability of one party for causing physical
injury to the other party.

55. General Pocket of
Support for Releases

56. NASCAR/Stock Cars/Racing
If you can drive around a track fast in your
state and it is a big sport, it is difficult to beat
a release.

57. The NASCAR Phenomenon
Clutter v. Karshner, 2001 WL 1006155 (C.A.6
Ohio)
Groves v. Firebird Raceway, Inc, 67 F.3d 306
(Table), 1995 WL 574619 (C.A.9 (Idaho))
Sweat v. Big Time Auto Racing, Inc, 117
Cal.App.4th
1301, 12 Cal.Rptr.3d 678, 4 Cal.
Daily Op. Serv. 3606, 2004 Daily Journal D.A.R.
5037
Winkler v. Charlotte Motor Speedway,
Incorporated, 923 F.2d 850 (Table), 1991 WL
5919 (C.A.4 (N.C.))

58. The NASCAR Phenomenon
To overcome The NASCAR Phenomenon you
have to really write a bad release
Conservatorship of the Estate Link, 158
Cal.App.3d 138, 205 Cal.Rptr. 513 (release
printed in five-and-one-half-point type)

59. Recreation
Becoming a mixed bag
Releases used to be supported for
Recreational Activities

60. Skiing
• Garretson v. United States,
456 F.2d 1017 (9th
Cir.
1972)
• Shephard v. Bear Valley
Ski Company, 2004 WL
2825126 (2004)
• Blau, v. Mammoth
Mountain Ski Area, 2001
Cal. App. 1506, 2001 Cal.
App. LEXIS 1506

61. Although Skiing Has been Taking
a Beating Lately
• Solis v. Kirkwood Resort Company, 2001
Cal. App. 3090, 94 Cal. App. 4th
354, 114 Cal.
Rptr. 2d 265, 2001 Cal. Daily Op. Service
10304
• Dalury v. S-K-I, Ltd, 164 Vt. 329; 670 A.2d
795; 1995 Vt. LEXIS 127 9 (Releases are
against pubic policy in Vermont for skiing)
• Rothstein v. Snowbird Corporation, 2007 UT
96; 2007 Utah LEXIS 219 (Ski Statute is all
ski area’s get)

62. Rothstein v. Snowbird
Corporation
Rothstein was decided less than 45 days of
another Supreme Court decision supporting
a release?
Berry v. Greater Park City Company, 2007
UT 87; 171 P.3d 442; 590 Utah Adv. Rep. 3;
2007 Utah LEXIS 192

63. Is There a Statute Protecting
the Commercial Activity
If so, there is a high likelihood that the court
will find the legislature intended the
statute to be the full remedy available to
the commercial activity
If a statute is being proposed, the language
should include the ability to continue to
use a release

64. Hawaii
• Hawaii Revised Statute § 663-1.54.
Recreational activity liability. Provides
protection from inherent risk of an activity.

65. West Virginia
• Article 3B. Whitewater Responsibility Act.
• Murphy v. North American River Runners, Inc., 186
W. Va. 310; 412 S.E.2d 504; 1991 W. Va. LEXIS
222
• Therefore, to the extent that the anticipatory
release in the present case purports to exempt the
defendant from tort liability to the plaintiff for the
failure of the defendant's guide to conform to the
standard of care expected of members of his
occupation, it is unenforceable.

66. New Mexico
Berlangieri v. Running Elk
Corporation, 132 N.M. 332;2002
NMCA 60;48 P.3d 70;2002 N.M.
App. 39;41 N.M. St. B. Bull. 25
See Release of Liability Found
to Violate Public Policy because
the Legislature created the NM
Equine Liability Act.

67. West Virginia
• Kyriazis v. University of West Virginia; 192
W. Va. 60; 450 S.E.2d 649; 1994 W. Va.
LEXIS 161
• Murphy v. North American River Runners,
Inc., 186 W. Va. 310; 412 S.E.2d 504;
1991 W. Va. LEXIS 222

68. Current Analysis of
State Law Concerning
Releases

69. States that have limited
the use of Releases in
Recreational Settings

70. Hawaii
Revised Statute § 663-1.54 Recreational
activity liability
Enacted in 1997 to help stop lawsuits against
commercial recreational operators

71. Hawaii: H.R.S. § 663-1.54
(a) Any person who owns or operates a
business providing recreational activities to
the public, such as, without limitation, scuba
or skin diving, sky diving, bicycle tours, and
mountain climbing, shall exercise
reasonable care to ensure the safety of
patrons and the public, and shall be liable for
damages resulting from negligent acts or
omissions of the person which cause injury.

72. Hawaii: H.R.S. § 663-1.54
(b) Notwithstanding subsection (a), owners and
operators of recreational activities shall not be liable
for damages for injuries to a patron resulting from
inherent risks associated with the recreational activity
if the patron participating in the recreational activity
voluntarily signs a written release waiving the owner
or operator’s liability for damages for injuries
resulting from the inherent risks. No waiver shall be
valid [**11] unless:
.

73. Hawaii: H.R.S. § 663-1.54
(1) The owner or operator first provides full
disclosure of the inherent risks associated
with the recreational activity; and
(2) The owner or operator takes
reasonable steps to ensure that each patron
is physically able to participate in the activity
and is given the necessary instruction to
participate in the activity safely.

74. Hawaii: H.R.S. § 663-1.54
(c) The determination of whether a risk
is inherent or not is for the trier of fact. As
used in this section an “inherent risk”:
(1) Is a danger that a reasonable person
would understand to be associated with the
activity by the very nature of the activity
engaged in;

75. Hawaii: H.R.S. § 663-1.54
(2) Is a danger that a reasonable person
would understand to exist despite the owner
or operator’s exercise of reasonable care to
eliminate or minimize the danger, and is
generally beyond the control of the owner or
operator; and
(3) Does not result from the negligence,
gross negligence, or wanton act or omission
of the owner or operator

76. Hawaii: However
• Guests from cruise
ship booked horse
back riding trip.
• Guest signed release
• Guest was bitten by
another horse
King v. CJM Country Stables, 315 F. Supp.
2d 1061; 2004 U.S. Dist. LEXIS 7511

77. King v. CJM Country Stables
The Court finds that there are genuine
issues of material fact as to: whether
Defendant was negligent; and the Release
Form’s validity as a waiver of liability, which
depends on whether the horse-biting
incident was an “inherent risk” of the
recreational activity that Defendant provided
to Plaintiffs. Defendant cannot satisfy its
burden and thus, is not entitled to judgment
as a matter of law.

78. King v. CJM Country Stables
The death knell for this case and all recreational
activities in Hawaii is Hawaii Revised Statutes,
Section 663-1.54(c). It requires the trier of fact,
the jury, to decide if a risk is inherent or not.*
Consequently the release has no value in
Hawaii for
* Outdoor recreation Law Reivew: Case Brief: Hawaiian court case demonstrates change in law actually
hinders the recreation businesses it was designed to protect commercial recreational activities.

79. Arizona
Phelps v. Firebird Raceway, Inc., 2005 Ariz.
LEXIS 53
Phelps lost control of his vehicle and
crashed into a wall. Phelps’ vehicle erupted
into flames and he suffered severe burns

80. Phelps v. Firebird Raceway, Inc.
…both parties agree that Firebird raised a
defense of assumption of risk.
…he had assumed the risk of any injuries
resulting from Firebird’s negligence.

81. Phelps v. Firebird Raceway, Inc.
The defense of contributory negligence or of
assumption of risk shall, in all cases
whatsoever, be a question of fact and shall,
at all times, be left to the jury.

82. New Mexico
Berlangieri v. Running Elk Corporation, 132
N.M. 332; 2002 NMCA 60; 48 P.3d 70; 2002
N.M. App. 39; 41 N.M. St. B. Bull. 25
Equine activities

83. New Mexico: The Equine
Liability Act
A. No person, corporation or partnership is
liable for personal injuries to or for the death
of a rider that may occur as a result of the
behavior of equine animals while engaged in
any equine activities.

84. Berlangieri v. Running Elk
Corporation
We decline the invitation to abolish this
doctrine now. Instead, we think that strict
limits on the use of exculpatory agreements
would better serve
the important interests at stake.

85. Berlangieri v. Running Elk
Corporation
We conclude the general rule that liability
releases for personal injury may be enforced in
limited circumstances should be retained. …the
facts of this case fall within the exception to the
general rule arising from public policy. Liability
releases for equine recreational activities
represent another exceptional case where
public policy dictates that they not be enforced.
Several considerations are relevant to this
determination.

86. Berlangieri v. Running Elk
Corporation
We conclude that the release in this case
expressed the intent of the parties that
Berlangieri would not hold Running Elk liable
for its negligent acts.

87. An Aside: Inherent failures of Equine
liability acts
Since the passage of Equine Liability Acts,
not one horse has been sued.
However suits against horse owners have
stayed constant.

88. West Virginia
Murphy v. North American River Runners, Inc.,
186 W. Va. 310; 412 S.E.2d 504; 1991 W. Va.
LEXIS 222
Whitewater Rafting

89. Murphy v. North American River
Runners, Inc
A clause in an agreement exempting a party
from tort liability is, however, unenforceable
on grounds of public policy if, for example,
(1) the clause exempts a party charged with
a duty of public service from tort liability to a
party to whom that duty is owed, or (2) the
injured party is similarly a member of a class
which is protected against the class to which
the party inflicting the harm belongs.

90. Murphy v. North American River
Runners, Inc
An example of the second situation just
mentioned is that when a statute imposes a
standard of conduct, a clause in an
agreement purporting to exempt a party from
tort liability to a member of the
protected [***9] class for the failure to
conform to that statutory standard is
unenforceable.

91. Murphy v. North American River
Runners, Inc
Thus, a plaintiff's express agreement to
assume the risk of a defendant's violation of
a safety statute enacted for the purpose of
protecting the public will not be enforced; the
safety obligation created by the statute for
such purpose is an obligation owed to the
public at large and is not within the power of
any private individual to waive.

92. West Virginia
Kyriazis v. University of West Virginia; 192
W. Va. 60; 450 S.E.2d 649; 1994 W. Va.
LEXIS 161
Student was hurt playing rugby at a West
Virginia University rugby club

93. Kyriazis v. University of West
Virginia
Because we believe the University qualifies
as a "public service," and that it possessed a
decisive bargaining advantage over the
appellant when he executed the Release, we
find the anticipatory Release void as a matter
of West Virginia public policy.

94. Vermont
Dalury v. S-K-I, Ltd, 164 Vt 329; 670 A.2d 795;
1995 Vt. Lexis 127 (VT 1995)

95. Dalury v. S-K-I, Ltd
…defendants’ allocation of responsibility for
skiers’ injuries is at odds with the statute. The
statute places responsibility for the “inherent
risks” of any sport on the participant, insofar
as such risks are obvious and necessary. Id. A
ski area’s own negligence, however, is neither
an inherent risk nor an obvious and
necessary one in the sport of skiing.

96. Idaho
Lee v. Sun Valley Company, 107 Idaho 976; 695
P.2d 361; 1984 Ida. LEXIS 599
Idaho Outfitters and Guides Licensing Act,
Chapter 21 of Title 36, Idaho Code
The court held the defendant Sun Valley
could not use the release as a defense
because it violated public policy as the
outfitter was protected by a statute.

97. Utah
Rothstein v. Snowbird
Corporation, 2007 UT
96; 175 P.3d 560; 593
Utah Adv. Rep. 26;
2007 Utah LEXIS 219

98. States that are
all over the
place and
release law is
akin to a “wack
a mole” game

99. Texas
Akin v. Bally Total Fitness Corporation, 2007
Tex. App. LEXIS 1218

100. Pennsylvania
Chepkevich v. Hidden Valley Resort, L.P., 593
Pa. 420; 931 A.2d 630; 2007 Pa. LEXIS 1773

101. Chepkevich v. Hidden Valley Resort
….where the defendant drafts the
agreement and the plaintiff is merely a
recipient of the document, “it must appear
that the terms were in fact brought home to
him and understood by him, before it can be
found he has accepted them

102. Chepkevich v. Hidden Valley Resort
Significantly, the legal term “negligence” is
not clearly defined or illustrated in any way,
such as with an example of conduct that can
be considered negligent. As such, Appellee’s
Release from Liability arguably amounts to
an adhesion contract which provides no
recourse to one who disagrees with it but to
reject the entire transaction.

103. Chepkevich v. Hidden Valley Resort
…there is an assertion that an agreement
was reached between Lori and the lift
operator which superseded any that might
have been created under the Release from
Liability form; therefore, we cannot conclude
as a matter of law that the disclaimer is
enforceable, as this question of fact remains
as to what the ski lift operator said to
Appellant

104. Savarese, vs.
Camelback Ski Corp,
417 F. Supp. 2d 663;
2005 U.S. Dist.
LEXIS 41389
(release stops suit
over lift accident)

105. Issues
Failure to Negotiate the Release
Turnbough v. Ladner, 754 So. 2d 467; 1999
Miss. LEXIS 375

106. Lease Negotiation
Used to be a requirement that for a release
to be accepted, their had to be negotiation
for the release to be value.
You had to have the opportunity to buy the
activity without a release

107. Ways Releases are Being Defeated
• Legislature Gave Commercial Operator
Statute, Statute is All they Get
• Void as Against Public Policy
• Harm Done far exceeds what the court can
stomach

108. References: Law Review
We, The Parents and Participant, Promise
Not to Sue ... Until There is an Accident. The
Ability of High School Students and their
Parents to Waive Liability for Participation in
School-Sponsored Athletics, 37 Suffolk U. L.
Rev. 439, 2004

109. References: Law Review
Validity and Enforceability of Liability
Waivers on Ski Lift Tickets, 28 Campbell L.
Rev. 107, 2005

110. References: Outdoor Recreation
Law Review
Case Brief: Hawaiian court case
demonstrates change in law actually hinders
the recreation businesses it was designed to
protect
Case Brief: 1985 Idaho Supreme Court finds
releases cannot be used to prevent a lawsuit

111. References: Outdoor Recreation
Law Review
It Takes More Than a Ticket Purchase to
Enforce a Contract and Release
New Jersey Court decision highlights need
to mention heirs when writing a release

112. References: Outdoor Recreation
Law Review
Utah Supreme Court flip flop on releases for
ski areas could have broader consequence
Pennsylvania Supreme Court decision
endangers strength of releases in recent
decision

113. References: Outdoor Recreation
Law Review
New Hawaiian law to minimize liability
exposure may have backfired

114. How to Find a Copy of the
Presentation

115. Thank You