DEFINITIONS
A
Alternative Business Structure
Alternative Business Structure (ABS) is an alternate model for providing legal services through businesses/entities that are not the traditional law firm environment. There is a variety of ABS models, including: (1) business entities providing both legal and nonlegal services with identified restrictions on licensure and ownership; (2) business entities providing both legal and nonlegal services without restrictions on licensure and ownerships; (3) business entities providing only legal services with identified restrictions on licensure and ownership; and (4) business entities providing only legal services without identified restrictions on licensure and ownership.
Alternative Dispute Resolution
Alternative Dispute Resolution (ADR) is a process designed to resolve a legal dispute without court adjudication. See also MCR 2.410, p 100.
Alternative Fee Arrangements
Alternative Fee Arrangements (AFAs) are mutual agreements between law firms and clients in which the billing for legal services does not rely solely on traditional hourly billing. AFAs include fixed, contingent, hybrid, and other creative fee arrangements. They are intended to reflect what is fair and reasonable to both the client and lawyer based on the value the client receives from the legal services and how the client perceives the value.
Alternative Legal Services Providers
Alternative Legal Services Providers (ALSPs) refers to individuals who are not attorneys, and businesses other than law firms, providing some type of legal service to the public. Washington's LLLTs are an example of regulated ALSPs. LegalZoom and Rocket Lawyer are examples of unregulated ALSPs. The Relevant Lawyer, ABA Center for Professional Responsibility, Chapter 3, p 63.
American Bar Association
The American Bar Association (ABA), founded in 1878, is a voluntary professional organization committed to supporting the legal profession with practical resources for legal professionals, improving the administration of justice, accrediting law schools, establishing model ethics codes, enhancing diversity, and advancing the rule of law throughout the United States and around the world. Membership is open to lawyers, law students, and others interested in the law and the legal profession.
Artificial Intelligence
Artificial intelligence (AI) is the use of technology to automate systems to limit the direct ongoing involvement of humans in certain steps of a matter. Uses for AI in the law include automated intake forms, data-mining in e-discovery, legal research, predictive coding, online dispute resolution, e-mediation, document review, evidence management, trial organization, and case and law analysis. How Automation is Changing the Legal Profession, Monahan, Your ABA, 2015.
Alternative Licensure
Alternative Licensure is a regulatory system that provides a license to practice law to persons who are not lawyers. Washington's LLLT regulatory scheme exemplifies an alternative licensure regulatory system. See also the NOBC summary table of status of alternative licensure programs.
B
Big Data
Big Data is defined as data of sufficient volume, complexity, or velocity that exceeds the capability of conventional current technology or methodology to process or analyze conventionally. To help meet the challenges, a multi-disciplinary area of data science has been tapped to pick up where conventional methods leave off. ABA Section of Science & Technology Law: Big Data.
Business Process Analysis
Business Process Analysis (BPA) is the review and assessment of business processes and procedures to identify inefficiencies and obstacles for delivery of high quality and affordable services. "The seven basic business processes in a law office are production, marketing, personnel, finance, systems and technology, communication, and managing." The Seven Basic Business Processes in a Law Office, McLaughlin, ABA GPSOLO, 2002.
C
Client-Centric
Client-Centric describes providing legal services with a focus on clients' needs.
Collaborative Practice or Collaborative Law
Collaborative Practice or Collaborative Law, presently used primarily in family law cases, is a voluntary dispute resolution process enabling parties to settle matters without resort to litigation. A team of professionals that includes lawyers, mental health counselors, financial advisors, coaches, realtors, and others professionals as needed, work collaboratively to assist the parties in reaching an agreement that meets their needs. See also International Academy of Collaborative Professionals; Collaborative Practice Institute of Michigan.
Commoditization of Legal Services
Commoditization of Legal Services describes the delivery of legal work that has a relatively steady volume (such as patent filings or employment litigation) at a fixed rate over a fixed period of time. See also The Three-Dimensional Transformation in the Business of Law, Poll, ABA Law Practice Today, January 2012.
Continuing Legal Education
Continuing Legal Education (CLE) refers to educational programs designed to maintain or sharpen the skills and knowledge of licensed attorneys and judges. Accredited courses typically provide updates on changes in the law, examine new areas of the law, or review basic practice and trial principles. Continuing legal education programs are sponsored by state, local, and federal bar associations, law firms, law schools, and groups such as the American Bar Association and the American Law Institute.
Convergence
Convergence is reducing a company's network of law firms and legal service providers from the possible hundreds that are currently on the company's roster to a selected set of preferred legal advisers. The client guarantees a certain volume of work, and in return the panel members provide increased value through a variety of means, including fixed or other alternative fee arrangements, discounts, secondees (see secondee), and other "free" value-added services. See also Panel Management, Codd, ABA Law Pracice Today, June 2013.
Co-Pay Clinic
A Co-Pay Clinic is a nonprofit clinic that delivers legal services on a sliding-scale fee to low- and moderate-income populations.
D
Digital Immigrant
A Digital Immigrant is a person born before the beginning of digital technology who was instrumental in the invention of digital technologies, such as the Internet, microchips, and cloud-based applications. They achieve goals quickly, use focused resources to build things to scale, and revitalize or repurpose existing institutions. See also Digital Natives vs. Digital Immigrants, DeGraff, Huffpost Business, September 2014.
Digital Native
A Digital Native is a person born during or after the beginning of digital technology who routinely and effortlessly uses digital technology. Digital natives are said to exhibit a willingness to collaborate across boundaries and to build "horizontal" solutions (low capital investment, reduced complexity, and smaller scaled projects). See also Digital Natives vs. Digital Immigrants, DeGraff, Huffpost Business, September 2014.
Digital Transaction Management
Digital Transaction Management (DTM) is the use of technology to manage business transactions by improving the process, increasing efficiency, and reducing cost. Electronic signature, the most common use of DTM, eliminates the need for scanning originals, obtaining ink signatures, and storing paper documents. See also What the Jobs Are, Henderson, ABA Journal, October 2015.
Discrete Task Representation
Discrete Task Representation refers to a lawyer performing specific, limited tasks, instead of handling all aspects of a matter. Discrete task representation is often referred to as the "unbundling" of legal services. "Depending upon the context, the availability of unbundled legal services allows clients to limit their legal costs by coming to a lawyer for specific advice and paying for only that, without having to pay the lawyer the added expense of drafting an agreement, conducting negotiations, filing an appearance, going to court, or preparing additional pleadings." SBM informal ethics opinion RI-347.
Disruptive Innovation in the Law
Disruptive Innovation in the Law refers to the changes rapidly reshaping the legal profession. The changes most commonly cited are globalization of economic activity, the rise in information technology, and the blurring of traditional boundaries defining the professions. To be drivers of positive change, rather the unconscious victims of disruptive innovation, law firms are encouraged to experiment in three areas: (1) structure—accommodate experiments in new models for delivering legal services; (2) attorney-client relationship—provide greater value to clients through AFAs, new work flow systems that deliver legal services efficiently and consistently, and the use of emerging technologies; and (3) collaboration—connection and collaboration within the law firm and externally to detect the need for change. See also Conference Examines 'Distrupions' in the Law, Rice, Harvard Law Today, March 2014.
Document Assembly
Document Assembly is software used to automate preparation of legal documents to reduce preparation time and increase efficiencies.
Drivers of Change
Drivers of Change consists of the "more for less" challenge, liberalization of legal services, and information technology. The "more for less" challenge refers to delivering more legal services at less cost; liberalization permits nonlawyers to provide legal services; and disruptive technologies challenge and change legal work. See also Tomorrow's Lawyers, Susskind, ABA Law Practice Magazine, July/August 2013.
E
E-Filing
E-Filing, short for "electronic filing," describes the submission of legal documents to the court in electronic form.
E-Learning
E-Learning is the use of simulated legal practice and virtual legal learning environments.
Electronic Legal Marketplace
Electronic Legal Marketplace refers to three types of online systems used by clients and lawyers. "Online reputation systems" allow clients to share their views on the performance and levels of service of their lawyers. "Price comparison systems" put the prices and rates of different legal advisers and law firms online. "Online legal auctions" market legal services in a manner made familiar through e-Bay.
Enhanced Member Directory
An Enhanced Member Directory is one in which the member can provide additional professional information, such as practice areas, a biography, links to publications, and awards. The State Bar of Michigan enhanced directory, powered by Zeekbeek, is an online legal marketplace where consumers can find lawyers, and lawyers, legal professionals, and law students can connect with each other. Developed in partnership with the State Bar of Michigan, Zeekbeek is the first online, bar-centric site created to improve consumer access to legal services and also address the needs of practicing lawyers.
Entity Regulation
Entity Regulation describes the regulation of entities that provide legal services, rather than the traditional regulatory scheme that only regulates attorneys. The regulated entity (law firm) must run the business and employees must carry out their role in the business effectively and in accordance with proper governance, including clear reporting lines, as defined by the regulator. The regulator can refuse to authorize an entity if it is not satisfied that the governance arrangements are adequate to safeguard the regulatory objectives. The U.K. has adopted entity regulation as part of the changes initiated by the Legal Services Act of 2007. Australia, Canada, England, and Wales presently use some form of entity regulation.
F
Fee Shifting
Fee Shifting laws require a party to pay the attorney's fees incurred by the opposing party in a litigation matter. Fee shifting is designed to attract lawyers to public interest cases. Michigan follows the American Rule, which allows an award of attorney's fees if expressly authorized by statute, court rule, or a recognized court-made exception. Examples include Michigan's offer of judgment rule, MCR 2.405; case evaluation sanctions, MCR 2.403; fee awards in domestic relations cases, MCR 3.206(C); and the Michigan Civil Rights Act, MCL 37.2801.
G
Gamification
Gamification is the use of digital game mechanics and techniques in nongame applications. In the context of the law, gamification would take a process such as filling out an online client intake form and add entertaining game elements that would motivate the client to complete the form. See also The Relevant Lawyer, ABA, Ch 7, p 126.
Gatekeeper
A Gatekeeper assists unrepresented persons with their legal needs by directing them through the process and assisting with the completion of pre-printed standard forms approved for use in the legal court system. See also Lay Navigator.
H
Holistic Defense
Holistic Defense is an innovative model of public defense pioneered by the Bronx Defenders that combines aggressive legal advocacy with a broader recognition that for most poor people arrested and charged with a crime, the criminal case is not the only issue with which they struggle.
I
In Pro Per
A person proceeding "In Pro Per" is someone who is attempting to resolve a legal matter without the assistance of a lawyer. See also Pro Se and Self-Represented Litigant.
Indigent Defense
Indigent Defense refers to the right to legal representation afforded under the Sixth Amendment of the United States Constitution, and is deemed a primary safeguard of a defendant's rights within the criminal justice system.
Insourcing
Insourcing describes a trend by corporate legal departments to control budgets and cut costs, including limiting the use of outside counsel/law firms. General counsel and other inside lawyers are used directly to address legal, ethics, public policy, corporate citizenship, and other concerns, relying on technology to improve their internal infrastructure to support insourcing. Insourcing advocates cite the benefits of the inside counsel's exclusive service orientation to the company and deeper understanding of the corporate business. See also Insourcing by Corporate Legal Departments, Jillson, Managing Law Firm Transition, October 2014.
K
Kaizen Event
A Kaizen Event is a one-week improvement blitz aimed at overhauling a core work process to increase efficiency, improve customer satisfaction, and cut costs. The term kaizen is Japanese, meaning to change (kai) for the better (zen).
Knowledge Management for Law Firms
Knowledge Management for Law Firms (KM) is the process of connecting people to tacit and explicit knowledge they need to do their job. Factors driving the adoption of KM are found here. KM is who and what we know and how we operate. KM can involve a wide array of activities, including document management, records management, precedent development, legal research, business or competitive intelligence, CLE and professional development, Intranet deployment, e-discovery support, project management, client support (virtual deal rooms), document automation, and the creation of smart systems for clients. The KM tools needed by a lawyer vary depending on responsibilities.
L
Latent Market for Legal Services
A Latent Market for Legal Services is an untapped market for legal services with ready consumers, often estimated in the U.S. at $45B annually. Data indicate that 50% of the middle income households in the U.S. experience one legal problem per year, but only 20% seek legal assistance from an attorney, while 26% do nothing.
Lay Navigator
A Lay Navigator is a person or entity trained to assist unrepresented litigants through the legal maze of their particular legal issue and integrates them into a triage system, such as currently operating legal assistance centers and Michigan Legal Help. New York State has recently implemented a lay navigator program on a trial basis.
Lean Law
The objective of Lean Law is the removal of waste to focus on processes that add value to consumers of legal services. Lean law requires creative thinking about the delivery of legal services to generate greater value with fewer resources by optimizing the use of technologies to improve processes to deliver legal services faster, more reliably, and less expensively. See also What is Lean Law?, Reisenwitz, Capterra Legal Software Blog, June 2015.
Legal Aid
Legal Aid refers to nonprofit organizations that provide free legal services to low-income persons.
Legal Health Checkup
A Legal Health Checkup is a system to help people identify everyday legal problems that may be harmful to healthy living and to get help for them. Examples of such programs include Ontario's programs funded through legal aid and the California Bar's Legal Health Checklist.
Legal Incubator
A Legal Incubator is a post-graduate program to support and assist law school graduates in starting their own solo, small firm, or nonprofit practices. Incubator participants receive the infrastructure and basic training needed to get their practices up and running, and serve the local community's legal needs at an affordable cost. Incubator Guide, California Commission on Access to Justice, p 3.
Legal Operations
Legal Operations describes a multidisciplinary field of professionals collaborating to design and build systems to manage legal problems. The intended result of the collaboration is to accomplish the legal goal better, faster, and cheaper.
Legal Process Outsourcing
Legal Process Outsourcing (LPO) is the use of a third party to complete tasks which have traditionally been completed by an attorney or staff person in the firm. Often these tasks include document review, contract management, and due diligence. See also The Impact of Legal Process Outsourcing, Friedmann, Law Practice Today, January 2012.
Legal Project Management
Legal Project Management (LPM) describes a deliberate system for improving efficiency in the delivery of legal services. LPM techniques are intended to identify best practices for determining the scope of a matter, effectively communicating across the team handling the matter, managing a budget, and monitoring progress.
LegalRnD
LegalRnD is a curriculum at Michigan State University College of Law dedicated to improving legal-service delivery and access across the legal industry through research and development of efficient, high-quality legal service delivery tools and systems. The LegalRnD curriculum teaches students various elements of lean thinking.
Legal Services Act of 2007
The Legal Services Act of 2007 was enacted by the Parliament of the U.K. to liberalize and transform the regulation of the market for legal services in England and Wales, to encourage more competition, and to provide a new route for consumer complaints.
Legal Service Provider
A Legal Services Provider (LSP) typically refers to a nonprofit organization that provides free legal services to low-income persons.
Legal Triage
Legal Triage is a process for sorting through the legal needs of consumers to identify the specific legal services needed, establish a priority and system for addressing them, and refer consumers to legal services and nonlegal services providers for assistance based on the triage assessment.
Limited License Legal Technician (TRIPLE LT)
A Limited License Legal Technician (LLLT or Triple LT) is a nonlawyer authorized through a license to deliver legal services to clients in a limited manner. The LLLT model was first developed and implemented in the state of Washington to provide more affordable legal services to persons of low or moderate income. The Washington State Bar administers the program. See also Restore Access to Justice Through Limited License Legal Technicians, Crossland, ABA GPSOLO, May/June 2014.
Limited Scope Representation
Limited Scope Representation (LSR), also "unbundling," refers to attorneys providing only discrete legal services that are agreed upon in advance, rather than full representation. LSR often involves providing legal advice, coaching, and document preparation for parties representing themselves without the use of a lawyer. LSR attorneys are also used to mediate conflicts, negotiate settlements, or make limited appearances in court on behalf of clients who otherwise represent themselves in their case. See also Limited Scope Representation Helps Lawyers Expand Practice, Your ABA, April 2015.
Low Bono
Low Bono refers to legal services provided at a regular lower rate for services, not a discount for work performed, generally to under-represented communities. See Encouraging the Development of Low Bono Law Practices, Herrera, University of Maryland Law Journal, Vol 14 Iss 1, 2014.
M
Mandatory Continuing Legal Education
Mandatory Continuing Legal Education (MCLE) is a compulsory system of continuing the professional education of lawyers in order to maintain or sharpen their professional competence. Continued licensure is conditioned on compliance with the MCLE requirements.
Massive Open Online Course
Massive Open Online Course (MOOC) is an online educational course with unlimited participation and open access via the Internet. In addition to traditional course materials such as filmed lectures, readings, and problem sets, many MOOCs provide interactive user forums to support community interactions between students, professors, and teaching assistants. MOOCs are a widely researched development in distance education first introduced in 2008.
Multijurisdictional Practice
Multijurisdictional Practice (MJP) describes legal services provided by a lawyer licensed to practice law in a U.S. jurisdiction, who is not disbarred or suspended in any jurisdiction, providing legal services in another jurisdiction where the lawyer is not licensed to practice law. MRPC 5.5; ABA Model Rule 5.5.
Modest Means
Modest Means, used interchangeably with moderate means, generally refers to the economic status of individuals who do not qualify for free legal services but cannot afford the expertise of attorneys at the standard rate. To qualify for many modest means programs, individuals must have incomes less than or equal to 200% to 250% of the federal poverty guidelines, depending on the program. Individuals meeting the income criteria pay a significantly reduced hourly fee for legal services. The ABA has a comprehensive list of modest means programs offered nationally.
More for Less Challenge
The More for Less Challenge, refers to the need for attorneys to deliver more legal services at less cost in the face of increased competition and efficiencies enabled by technology. See also Tomorrow's Lawyers, Susskind, Jams ADR Blog, August 2014.
N
National Organization of Bar Counsel
The National Organization of Bar Counsel (NOBC) is a nonprofit organization of legal professionals whose members enforce ethics rules that regulate the professional conduct of lawyers who practice law in the United States, Canada, and Australia.
O
Online Dispute Resolution
Online Dispute Resolution (ODR) uses Internet technology to facilitate the resolution of disputes between parties regarding legal matters rather than court adjudication. It primarily involves negotiation, mediation, or arbitration, or a combination of all three. Benefits claimed for ODR include cost savings, speed of resolution, convenience, and individually-tailored processes. Other terms used for ODR are Internet Dispute Resolution (iDR), Electronic Dispute Resolution (eDR), Electronic ADR (eADR), and Online ADR (oADR).
P
Poverty Measure
Poverty Measure is the method used by the federal government to measure poverty.
Practice Management & Case Management Software
Practice and Case Management Software automates the management of client and case information, including contacts, calendaring, and documents, as well as billing. Many programs link with personal digital assistants (PDAs). The software is increasingly Internet-based, providing access to all features at any time and anywhere. View ABA software comparison chart.
Practice Management Software
Legal Practice Management Software automates all the relevant information about a case or matter—calendaring, task management, people management, and case/matter management—so that litigation and transactions can be easily accessed.
Predictive Coding
Predictive Coding is the use of keyword search, filtering, and sampling to automate portions of an e-discovery document review. The goal is to reduce the number of irrelevant and nonresponsive documents that need to be reviewed manually. See also Predictive Coding, Rouse, Enterprise Records Management Trends Guide, 2013.
Pricing Professional
A Pricing Professional is part of the law firm leadership whose areas of responsibilities include alternative fee arrangements (AFAs), profitability analysis, RFPs, budgeting, client fee discussions, and pricing training. See also A Day in the Life of a Pricing Professional, Gianakos, Legal Solutions, October 2015.
Proactive Management Based Regulation
Proactive Management Based Regulation (PMBR) refers to software programs designed to promote ethical law practice by assisting lawyers with practice management. PMBR programs typically have three features: (1) proactive programs to complement traditional professional discipline; (2) emphasis on responsibility of law firm management to implement policies, programs, and systems designed to prevent misconduct and unsatisfactory service, referred to as an "ethical infrastructure;" and (3) the goal of improving legal services and reducing problems by establishing information-sharing and collaborative relationships between regulators and service providers.
Pro Bono Publico Service
Pro Bono Publico Service is the provision of "professional legal services at no fee or a reduced fee to persons of limited means, or to the public service or charitable groups or organizations. A lawyer may also discharge this responsibility by service in activities for improving the law, the legal system, or the legal profession, and by financial support for organizations that provide legal services to persons of limited means." MRPC 6.1.
Pro Se
Pro Se litigant, or person proceeding pro se, refers to someone who is attempting to resolve a legal matter without the assistance of a lawyer. See also In Pro Per and Self-Represented Litigant.
S
Search Engine Optimization
Search Engine Optimization (SEO) is the process of maximizing the number of visitors to a particular website by ensuring that the site appears high on the list of results returned by a search engine.
Secondee
Secondee is a law firm lawyer hired by a corporation for a set period of time on a full-time, fixed-price basis. A secondee works in the corporation's offices and is integrated into the corporation's business and legal teams during the secondment. See also Partnering with Outside Law Firms for a Successful Secondment, Perkins & Barth, ACC Docket, October 2014.
Secondment
Secondment is the hiring by a corporation of a law firm lawyer for a set period of time on a full-time, fixed-price basis. The law firm lawyer providing the legal services to the corporation is called a secondee. See also Partnering with Outside Law Firms for a Successful Secondment, Perkins & Barth, ACC Docket, October 2014.
Secure Client Portal
A Secure Client Portal is an online storage area that offers an alternative to e-mail for communicating and collaborating with clients. See also E-Lawyering in the Age of Accelerating Technology, Seyle, ABA GPSOLO eReport, January 2013.
Self-Help Legal Center
A Self-Help Legal Center is a court-based center that provides a variety of legal information and resources, e.g., court forms and glossary of legal terms, to assist self-represented litigants who wish to resolve their legal matters without the assistance of a lawyer. The self-help legal center is usually free, however, there may be a charge for some forms to cover copy charges. Persons staffing a self-help legal center are trained to only provide legal information and not legal advice.
Self-Regulation—Legal Profession
Self-Regulation in the legal profession is the exclusive authority by the legal profession to determine who is licensed to practice law, to set the professional standards that lawyers in the profession must adhere to, and discipline lawyers who fail to meet the required professional standards. In Michigan, the Michigan Supreme Court has the exclusive, inherent power to regulate lawyers and the practice of law, promulgate rules for admission and discipline of lawyers practicing before the state courts of Michigan, and to promulgate rules regarding the operations of the State Bar of Michigan. Ayres v. Hadaway, 303 Mich 589 (1942).
Self-Represented Litigant
A Self-Represented Litigant (SRL) is a person who represents himself/herself in a legal dispute. A SRL may also be referred to as "pro se" or "in pro per." See also Pro Se and In Pro Per.
Service Delivery Framework
Service Delivery Framework (SDF) is a standard method for developing and delivering reliable solutions and services quickly and collaboratively, industrializing delivery to support high performance and consistent, predictable, and reliable solutions.
Specialty Certification for Lawyers
Specialty Certification for Lawyers refers to voluntary programs that are consistent with the ethical requirements of a particular licensing jurisdiction, permitting lawyers in that jurisdiction to claim achievement of a certain level of skill and expertise in a particular practice area, as evidenced by established criteria such as examinations, peer references, experience, continuing legal education, etc.
Standardization
Standardization is the process of developing and implementing systematic procedures to ensure a consistent and high quality process.
Systematization
Systematization is standardizing a method to accomplish desired outcomes to improve processes.
T
Technology-Assisted Dispute Resolution Systems/Services
Technology-Assisted Dispute Resolution Systems/Services (TADRS) refers to the use of technology to augment alternate dispute resolution processes that exist independently of the technology.
Technology-Based Dispute Resolution Systems/Services
Technology-Based Dispute Resolution Systems/Services (TBDRS) refers to those systems where technology plays an active role in conducting the dispute resolution.
U
Unbundling
Unbundling, also Limited Scope Representation (LSR), refers to attorneys' providing only discrete legal services that are agreed upon in advance, rather than full representation. LSR often involves providing legal advice, coaching, and document preparation for parties representing themselves without the use of a lawyer. LSR attorneys are also used to mediate conflicts, negotiate settlements, or make limited appearances in court on behalf of clients who otherwise represent themselves in the case. See also informal ethics opinion RI-347.
Unauthorized Practice of Law
Unauthorized Practice of Law (UPL) describes the conduct of persons or entities providing legal services or representing/designating themselves as lawyers or law firms without authority to do so. See also MCL 600.916; MCL 450.681; MRPC 5.5; ABA Model Rule 5.5.
V
Virtual Law Office
A Virtual Law Office (VLO), also referred to as a virtual law practice, is a method used by lawyers to deliver legal services to clients using a secure, online portal. This delivery method is intended to be convenient for clients because the technology typically allows clients to access information and documents and to obtain status updates regarding their matters at their convenience. This method of delivering legal services is also referred to as e-lawering. See also Lawyers' Definitions of Virtual Practice Vary, Filisko, ABA Journal, April 2014.