(ORLANDO, Fla. – Oct. 6, 2021) — After two long years (although it seemed so much longer), WIA’s Connectivity Expo convention, also known as Connect (X), is back – and a great time is being had by all. Although the cloud of COVID-19 hangs over the conference, the light at the end of the tunnel shines through. Nearly everyone I spoke with was confident in the progress being made and how wireless is moving toward 5G and other wireless technologies.
According to the WIA powers that be, the conference attendance is only down by perhaps 10 percent, compared with 2019. A remarkable showing. Technical sessions abound, and attendance is respectable. The keynotes featured the usual suspects from T-Mobile, SBC, Crown Castle, Vertical Bridge, American Tower and, this year, Dish and Amazon Web Services. Having AWS here is a real indication of how the telecom segment is embracing and integrating technologies of the 21st century, such as the cloud.
There was no shortage of cutting-edge discussions around O-RAN, 5G, mmWave, fiber, neutral host, what the infrastructure bill means and how it will enable our industry. How to get into the loop for funds was an extremely popular session. CBRS, public-private partnerships, the edge, DAS, fixed wireless and fireside chats rounded out the conference.
What was most impressive to me in both the sessions and vendors is the visibility of 5G. Although the carriers receive the most noise when it comes to 5G, there is a quiet revolution going on with many vectors that are coming onto the scene. What I mean by that is the permeation of 5G in the enterprise, the industrial IoT, transportation, city centers and other applications outside of carrier-implemented 5G.
In the end, attending this show gave everyone a great perspective on how not just the wireless infrastructure is evolving, but how other platforms such as software are changing the way infrastructure hardware is evolving and how new verticals such private wireless are gaining some significant traction – it is not about the carriers anymore.
One thing close to my heart at this conference is how WIA supports the Women’s Wireless Leadership Forum. There was a session I attended that featured some real powerhouse panelists. The session was moderated by Susan Au Allen, the national president and CEO of the U.S. Pan-Asian American Chamber of Commerce Education Foundations. Panelists included Deb Mercier, the WWLF executive director for programs; Pamela Prince-Eason, president and CEO of the Women’s Business Enterprise National Council; even a millennial, Ashli Fuselier, secretary of the WWLF executive board.
What impressed me about this panel was the general understanding of not only the challenges faced by women, but also their dedication to educating and supporting small and medium businesses (SMBs) in how to address and understand the issues involving diversity of all types. These individuals are truly power brokers in moving the diversity needle.
This was one of the best panels I attended or moderated. Hats off to these amazing women.
I want to express my appreciation of the involvement of WIA in many segments of not just wireless, but also business and government. It played a pivoting role in helping to shape some of the funding in the recent infrastructure bill, as well as other governmental policies in the wireless ecosystem.
I am elated that this conference is back. Aside from the over-the-top deep dive into the wireless space, it was great to see old friends and make new ones. And, the closing WWLF reception again featuring wireless’ greatest (and only) band the best harmonica player in wireless ecosystem, Johnathan Adelstein. And you thought he is just a mover and shaker with a pretty face. That made all the craziness worth every minute. Awesome job, WIA. Thanks for all you do, and see you in Denver next year.
Ernest Worthman is an executive editor with AGL Media Group.
Speakers gave upbeat assessments of the tower industry on the “View From the Top: Tower Executive Roundtable,” moderated by Jonathan Adelstein, president and CEO of the Wireless Industry Association during its Connectivity Expo earlier this week.
Earlier this week, which has been crowded with wireless news, FCC Chairman Pai announced that to receive approval from the FCC for the Sprint merger, T-Mobile had committed to deploying its 5G network into rural areas, with 85 percent of rural Americans covered within three years and 90 percent covered within six years.
Alex Gellman, Vertical Bridge CEO, said he believed even if the FCC had not required the rural coverage, the New T-Mobile would have done it anyway.
“I always believed that T-Mobile would be aggressive as a standalone wireless company post-merger,” Gellman said. “It will be a positive for the tower industry to have an aggressive, co-equal third carrier, especially one that is focused solely on wireless investment in their network. AT&T and Verizon, on the other hand, have competition from other segments for their capital.”
The previous day at the Connectivity Expo, T-Mobile Chief Technology Officer Neville Ray showed a graphic that depicted a three-layer 5G rollout cake with the bottom, largest layer consisting of 600 MHz spectrum, topped by mid-band spectrum layer with the top, and smallest, layer of millimeter wave spectrum.
David Weisman, president and CEO, InSite Wireless Group, responded to the carrier’s plans, saying he views the T-Mobile 600 MHz rollout as validation for macrocells, but he noted how far the industry still is from understanding what approval of the merger will look like.
“The Department of Justice has not spoken. When they do there will be a whole set of details and concerns as to how it is going to rollout. It may create a three and a half carrier environment. The devil is in the details,” he said.
Jeffrey Stoops, SBA Communications CEO, said T-Mobile’s proposed deployment at 600 hits SBA’s sweet spot, and he sees it resulting in a lot of collocation on existing SBA assets.
“T-Mobile, which is an active services client of SBA’s, will be requiring more services,” Stoops said. “We will help speed the deployment of the network so Neville won’t have to pay any penalties.”
Jay Brown, president and CEO, Crown Castle International, seemed less interested in prognosticating the future of the Sprint/T-Mobile merger. Instead, he noted that fundamentally the tower industry prospers when the carriers are well funded and there is spectrum to deploy, as well as growing data needs.
“The driver is the growth and usage of data. As we progress from a 4G environment toward 5G, we are better off concentrating on the opportunities and the need for infrastructure, regardless of the number of carrier customers in the market,” Brown said.
Speaking of wireless industry growth drivers, the panelists touched on the early stages of 5G development and the ongoing saga of Charlie Ergen, DISH and the deployment of a nationwide IoT network.
The tower industry is barely at the beginnings of what will be a decade long deployment of 5G, according to Steve Vondran, American Tower Executive VP, president, U.S. Tower Division.
“As you see the use cases develop and the usage of the network go up 30 to 40 percent per year, we expect the same evolution of 5G that we saw in 4G,” he said.
Brown pointed to increased number of connections per base station, which will be enabled with the 5G equipment, making Internet of Things applications possible.
“It opens up the business model for lower-use devices, as well as lower revenue devices that should allow the carriers to generate better economic returns for the spectrum that they hold,” he said. “As we see better economic returns, the carriers’ willingness to invest in their networks to improve their networks is a virtuous cycle that we all benefit from.
Stoops noted, and Brown and Weisman later agreed, that since there is little 5G equipment available, the driver for tower growth remains in the future. Weisman has seen some initial demand for supplemental millimeter wave hotspots for venues with heavy demand.
“It is great for our industry in that we are at this very early stage in the evolutionary rollout,” Weisman said. “We are going to see a whole host of rollouts that are going to lead to more utilization of our infrastructure. There is doubt that 5G has the potential to be part of a new industrial revolution.”
Weisman said he is confident that business cases for 5G will eventually be developed, perhaps through using network slicing to provide a premium product with a higher price tag, but until then carriers will need to work on their business model for consumer users. “It will come. There will be an Uber for 5G, but in the meantime carriers will move away from unlimited data. They can’t continue to give data way,” he said.
DISH and other Comm-infra Opportunities
SBA Communications has been doing a lot of business with DISH Network, helping it deploy its nationwide Internet of Things network. Stoops described DISH has appreciative of SBA’s help in its efforts to deploy its technology. Brown called DISH diligent in its buildout efforts, and Weisman referred to the company as a “sleeping giant with an enormous amount of spectrum capacity.”
“One of the things we have been able to help them with is to rely on our roots as a network development company with our services side of the business,” Stoops said. They have a lot at stake. We are working hard with them to see that the [spectrum buildout requirements] get met. There is a lot to be done and we are right in the thick of it.”
Brown said it is important to look beyond the Big Four carriers to find infrastructure opportunities so much spectrum laying fallow and capital flooding in looking for wireless applications.
“I think we are in for a prolonged duration of growth rate. Look at the amount of capital that is looking to convert every type of data into a mobile application. DISH is one of those early players,” he said.
The general trend within the wireless media is to recap conferences and trade show, both as they run and afterwards. That has a great deal of value, both to the attendees, for what they were not able to catch, as well as those that cannot attend. However, rarely do organizations behind such events get recognition for the hard work and maximum effort it takes to, successfully, pull it off. Most of the time this behind the scenes work goes unnoticed. So rather than pen another recap of the today’s happenings at the Connectivity Expo here in sunny Orlando, Florida, I want to take a moment to bring to light more of what the Wireless Infrastructure Association is about and how much they actually do for this industry.
I had the opportunity to have a spot of lunch in the WIA member room while its president, Johnathan Adelstein, talked a bit about all the areas WIA is invested in. I knew about some of them but others I had no idea about.
The fact that WIA has enough esteem to draw speaker from inside and outside of the industry, like Neville Ray and Adam Koeppe of T-Mobile and Verizon, respectively, and Shelly McKinley from Microsoft, speaks volumes. But having Orlando’s mayor, Buddy Dyer show up and speak, is, really, impressive. Orlando’s mayor is one of the more progressive when it comes to issues such as siting. That he recognizes that WIA is the organization that is capable of helping Orlando, as well as other cities, to understand and expedite deployments and smooth over the speedbumps that deploying such new, as well as, expanding existing networks present, speaks for itself.
Tangential to Connect X, WIA events also work at bringing together some of the brightest minds in the industry to move wireless technology forward. One of WIA’s missions is to develop other events, such as the Wireless Hall of Fame to bring people together to generate ideas. Another is to provide platforms, one of which is a new blog, where thought leaders can discuss industry topics and present new or innovative ideas. Another is to provide an information platform to allow industry players to inform other peripheral segments, through white papers, for example, about developments in wireless segments.
There is also their support in forming working groups to further the development of bleeding-edge, evolving industry segments. The smart city working group is a prime example. This group partnered with the Smart Cities Council to bring attention to smart city development though a number of avenues. The idea is to cross pollinate wireless technologies with smart city concepts to come up with a variety of wireless solutions to the challenges of making a city smart.
WIA has also created the Innovation & Technology Council, which focuses creating and disseminating white papers on a variety of issues. Topics include the economic issues that surround broadband wireless network and infrastructure deployment in rural America, for example. As well, they created a report on mobile broadband policy concerns for the 5G buildout. And, this is only the beginning. Such task forces and councils are ideal for tackling the complex issues around wireless deployment.
Peripheral platforms are not forgotten either. A new fiber working group has been formed, chaired by Crown Castle to work on getting transport capabilities for the emerging 5G platforms.
And, WIA has been instrumental in moving heterogeneous networks forward with the creation of the HetNet forums back in 2006, and the small cell forums for a similar number of years. WIA has been a driving force in helping companies deploy small cells by providing a wealth of data pertinent to small cells and HetNets. Without such support, it is unlikely small cells would be where they are today. As well, there are many other directions in which the WIA is moving – too many to mention here.
My motivation for this missive is to let the industry know that there is an organization out there that has its finger on the pulse of wireless and that can only be of benefit to it. I have watched them, over the years, bloom and grow – a credit to Jonathan, Tracy Ford, and the rest of the WIA team, and how hard they have worked to bring the organization to where it is today. I am impressed by the leadership team of WIA and I believe it will be the driving force and a leading organization in the infrastructure space, going forward.
Six weeks ago, few people knew there even was a Mobile Infrastructure Hall of Fame. But as WIA President and CEO Jonathan Adelstein took the stage for the first induction ceremony in a crowded room of 500 of the industry’s leaders, it felt like there has always been one. Or at least there was a pent-up demand for one.
“Today, these five honorees come from companies with a combined market cap of around $200 billion. They employ nearly 100,000 people and growing. And they’re driving the innovation economy with wireless broadband few dreamed possible in the flip phone era,” Adelstein said. “These five leaders are inducted tonight because of their foresight, their vision, and their tenacity. Each faced down challenges — and overcame them all.”
Gathering the top wireless CEOs and others at a ballroom in Washington D.C. on a Wednesday night in mid-November to honor its best had another altruistic goal. It raised $500 thousand for the WIA Foundation in support of training, education and apprenticeships.
“Tonight, the [inductees] lend us their presence because each believes — with us — that another challenge lies ahead for the wireless industry. To build world-class 5G networks — we need a world-class 5G workforce. Together, we’re taking steps to meet that challenge — building a workforce that’s worthy of this great industry,” Adelstein said.
The evening was attended by such notables as FCC Chairman Ajit Pai, Commissioners Michael O’Rielly and Brendan Carr, U.S. Sen. Steve Daines, and other guests from the FCC, Congress and the Administration.
The inaugural class of Hall of Fame inductees included: Neville Ray, CTO, T-Mobile; Steven Bernstein, founder, former CEO and current board member of SBA Communications; Steven Dodge, founder, former CEO, American Tower; John Kelly, former CEO, Crown Castle; and Jose Mas, CEO, MasTec Network Solutions.
John Legere, president and CEO of T-Mobile, lent his star power and sense of humor in a heartfelt tribute to Ray, who has 25 years of wireless experience and has led the carrier through the LTE roll out, from the zero POPs in 2012 to 324 million POPs today. The first 200 million POPs were built in six months. He also pushed new technology into the field, including Wi-Fi calling, VoLTE, License Assisted Access and 4X4 MIMO and 256 QAM.
“Neville Ray is truly a genius,” Legere said. “This is a guy that gets things done. You give him the goal and the resources, and you just know that it will be done. You get out of the way.” He joked that Ray’s budget of $50 billion also played a key role in the success. “Give the guy some cash and he makes it happen.” Ray later clarified that he only got $40 billion.
Jeffrey Stoops, president and CEO, SBA Communications, praised Bernstein’s decision-making ability and leadership qualities.
“He can quickly and incisively distill complex issues down to straightforward decisions has been a critical part of our success,” Stoops said. “More importantly, it’s his entrepreneurial spirit and his values, including honestly, integrity, fair play, quality, customer service and hard work, that Steve instilled in SBA that remains a driver of our continued growth and success.”
Jim Taiclet, chairman, president and CEO, American Tower, said Dodge has been a “true trailblazer” for the tower industry, and has served as innovator throughout his 40-year career, which included banking, media and telecom.
“He founded and took public three pioneering companies. The first was American Cable Systems, which he grew into an industry leading position and sold to Continental Cable. Then he went on to American Radio Systems, which was sold to CBS, and then American Tower Corporation. The only flaw in Steve’s plan was an apparent lack of creativity with company names.”
Ben Moreland, former CEO of Crown Castle, introduced Kelly as the “most wonderful person” he has ever known. Kelly served as a mentor to Moreland and “set a high bar as a humble leader and a really nice guy,” Moreland said. Kelly was CEO of Crown from 2001 to 2008 and remained on the board for a number of years afterward.
“He inspires people to be the best they can be,” Moreland said. “He instilled a very customer-centric focus that required us to always think about a win-win situation with the carriers.”
After Mas became CEO of MasTec, the company grew to 22,000 professionals nationwide, quadrupled its revenues, increased earnings six-fold, and reached a ranking of 428 in the Fortune 500, O’Rielly said in his introduction.
Additionally, Mas diversified MasTec beyond telecom construction into renewable energy, oil & gas and electric transmission, among others.
“Mr. Mas is not just as successful businessman. He is a long-time leader in the Miami-Dade United Way’s Toqueville Society, which donated $15 million to improve lives last year. Most recently Mas and his brother Jorge joined a consortium with David Beckham to raise $25 million to bring a new Major League Soccer team to Miami,” O’Reilly said.
While I, generally leave discussions on keynotes to my contemporaries, the data presented by FCC Chairman Ajit Pai this morning talked to a bit of the technical aspect of the industry as well as the regulatory. Therefore, I thought it might warrant a bit of discussion.
Pai discussed two topics of particular interest; regulation and spectrum. Of course, those are topics constant, general discussion but his presentation was a bit more on the cutting edge. For example, Pai reiterated what seems to be a concern of late, which is that it is important our industry be at the forefront of the 5G movement. That seemed to be what much of the trade press glommed onto, the extreme “if you ain’t first, you’re last” to quote Pai, (taken from the Will Farrell movie, Talladega Nights: the Ballad of Ricky Bobby).
While he stopped short of rabidly championing that we need to be first, he did allude to the fact that the FCC plays a big part in enabling the United States to be at the front of the pack, which, of course, is where we need to be.
A short time ago I penned a missive that I thought the race to worldwide 5G was not as much of a race as it was a march – a cooperative, as opposed to a competitive, movement, IMHO. What I heard was that the FCC recognizes that 5G is a worldwide movement. But he also expressed confidence in the United States, as a highly innovative and competitive player, will have no problem running with the leaders.
In that vein, he noted that being aggressive, in FCC policy decisions, would be one of his priorities to keep us competitive. For that, action not lip service, is the message the FCC is trying to disseminate.
This is good news, since the FCC, in the past has not been known for moving quickly. According to Pai, the FCC’s primary role in the development of next-generation networks is one of enabling vendors to maximize (and capitalize) on their role in the development of these networks to make it easier for vendors to deploy this next-generation infrastructure. And, to make available spectrum to so these networks can be deployed easily and quickly – three key concepts. To that end, Pai was bullish on modernizing and updating the FCC’s rather antiquated infrastructure regulatory environment – from the age of 200-foot towers to an environment that understands and favors the densification that will be a 5G world.
There was more, but to this editor, the modernization of FCC policies and procedures, to support the next generation of wireless networks is paramount, above all else. Kudos to Chairman Pai for his understanding and willingness to support and take on this brave, new world.
Dense Networks – Coming to a Location Near you, but When?
The terms used to define dense networks vary. Some call them ultra-dense networks, others call them hyper-dense networks, even hybrid-dense networks. But regardless of what they are called, they promise to offer ubiquitous wireless coverage, wherever you are.
While there is a lot of chatter about dense networks and they are well covered at Connect (x), the bottom line is that they are still in the petri dish stage. There are some test beds and areas such as sports stadiums that come under the dense coverage umbrella, but they have yet to scale to areas much larger than such venues, with next-generation technology. In fact, according to Greg Najjar, director, business development, Advanced RF Technologies, during the 5G Ultra Dense Networks pane session, “There are innovations, and apps, yet to be developed that are not even on the radar screen yet.” These will be what puts the pedal to the metal in the development and deployment of dense networks.
While the technologies for densification are rapidly reaching the viability stage, technologies are not the real challenge, according to the panel discussion. The real challenge is esthetics. That makes so much sense. While we rush to make it possible, technologically, putting that technology into hardware and deploying it poses a significant challenge. This because hardware is ugly and we just don’t want to see it. And, the hardware cannot be just dropped anywhere. There are many issues with who owns what and if they are willing to be part of this solution.
But that is not all. Even if we overcome the visibility factor, and have the technology, applying it transparently and reliably is also challenging. By that, I mean finding ways to scale network density.
The panel discussed that while it is pretty easy to cover an area, even a large one, with dense coverage. The dynamics of the space are often fluid. For example, take a sports venue. Typically, such a venue sees high traffic only periodically and then it is swamped. And that traffic may be dynamic within the venue as well. It may not be a particularly critical problem with a stadium, but scale that to the enterprise, city centers, or other large development s and it becomes problematic.
The panel addressed that by talking about new technologies such as AI, virtualization and self-optimizing networks. That is likely to resolve many of the issues, but realize that these technologies are in various stages of evolution and not necessarily ready for prime time, today.
And, of course, there is the RoI, which has yet to be proven. The pressure is always on cost containment, but in many cases, the cheapest solution may work under some conditions, and not under others in the same environment.
And finally, there is the issue of integrating all of the technologies currently in existence with new ones on the horizon. The last thing that the industry wants to do, with densification, is reinvent the wheel.
But it ended on an optimistic note. Once all the issues are resolved and densification begins, in earnest, the benefit will be tremendous. You will be able to find a parking space without driving around. You can find out how long your favorited restaurant wait is, even reserving a special table. People management will become possible, such as directing individuals to less crowded exit and entry points at various venues and showing crowd dynamics. And, not to mention autonomous vehicles and smart “x.”
Densification promises a lot. But it will take some time to deploy it, ubiquitously. And don’t forget, it will stratify across not only places but people and things as well. The vision is to up the level of the transparent user experience, across everything.
Autonomous Vehicles are Here – Not!
If one really wants to know where technology sits, ask an engineer. Kudos for Connect X having an autonomous vehicle panel. After all, autonomous vehicles will be a critical component of the future wireless ecosystem.
The panel led off with Kevin Lacy, state traffic engineer, North Carolina Department of Transportation. While this may intimate is has do with the state of North Carolina, the fact is that what is an issue here is an issue everywhere and the solution for one place is the solution for every other place (modified for environmental conditions, of course, but the core solution is the same).
Lacy did an excellent job of pointing out the current state of autonomous vehicles, what exists now, and what it will take to develop an autonomous vehicle infrastructure.
A couple of the platforms that get a lot of attention in this space is sensors and navigation technology. Both of which are in various states of advancements. According to Lacy, the following elements are what will make fully autonomous vehicles possible:
I write a lot about this topic, and much of the above is in various stages of existence and development. However, the last item, the connect AV infrastructure, specifically vehicle to infrastructure (V2X) and its next iteration, vehicle to everything (V2X) is what will put the vehicles in full autonomy. However, much of it is still on the drawing board. The following figure shows where we are presently (courtesy Kevin Lacy).
Still, there is talk that some vehicles are at level 5 (or at least very close), if one listens to those with an agenda. But Lacy’s chart shows that a bit differently. It shows we are now developing level 3 and some level 4. Fully autonomous vehicles, level 5, will not be here until after 2025 or later.
In this editor’s opinion, this is a much more credible scenario. I have said it before and I will say it again –without some sort of two-way smart road infrastructure, I believe fully driver driverless vehicles without driver-accessible control are, likely even further out than 2025.
OK, let us assume, by whatever plausibility theory one wants to assume, that we do develop the necessary V2X, and back, infrastructure. Technology has reached level 5. Now the ecosystem has to deal with the intangibles. Things like cost. Who will pay for both the technology and the ongoing costs of all of the components involved? Not only the vehicle with its complex technology, but building intelligence into the roads and the other objects. Then there is the central and edge management platforms.
And there is more, like the number of lines of code it will take to handle all of this (processing complexity) and the latency from the various elements. According to Lacy, autonomous vehicles may have 300, 400 million, maybe more, lines of code. At present this is a very complex and expensive platform and even as costs scale downward, putting all of this together will be a monumental undertaking.
Next, come legal and liability issues. We all know how long things can take in the judicial and regulatory systems. It will be years before the present lawsuits, and suits yet to be filed, are resolved. There is little in the wheelhouse about liability and responsibility so far.
On the regulatory side, the ecosystem is barely seeing the tip of the iceberg. Autonomous vehicles span all types of governmental agencies, from federal to local. And they vary from municipality to municipality. Need I say more?
Lastly, but not finally, just for this discussion, there is the human factor. We are not all going to wake up the day after full autonomy is reached and give up our vehicles. While there will be an evolutionary process here, some individuals, (like me) enjoy driving. There is something exhilarating about going from zero to sixty in three second. At this point, the last thing I want to do is turn my vehicle into an office, or spend all of my travel time ride sharing (I dig rock and roll music). Other issues include ownership models, transport, vehicle powering options, and the rate of adoption.
To be fair, things are moving at all levels of technology and regulation so all of these will, eventually, be resolved. But the challenges are many and complex. We have some ideas but are far from having our arms around all of the issues within this platform.
This session painted a very realistic picture of the state of, and the issues that face the evolving autonomous vehicle platform. It was good to see cooler heads stepping up.
Executive Editor/Applied Wireless Technology
His 20-plus years of editorial experience includes being the Editorial Director of Wireless Design and Development and Fiber Optic Technology, the Editor of RF Design, the Technical Editor of Communications Magazine, Cellular Business, Global Communications and a Contributing Technical Editor to Mobile Radio Technology, Satellite Communications, as well as computer-related periodicals such as Windows NT. His technical writing practice client list includes RF Industries, GLOBALFOUNDRIES, Agilent Technologies, Advanced Linear Devices, Ceitec, SA, and others. Before becoming exclusive to publishing, he was a computer consultant and regularly taught courses and seminars in applications software, hardware technology, operating systems, and electronics. Ernest’s client list has included Lucent Technologies, Jones Intercable, Qwest, City and County of Denver, TCI, Sandia National Labs, Goldman Sachs, and other businesses. His credentials include a BS, Electronic Engineering Technology; A.A.S, Electronic Digital Technology. He has held a Colorado Post-Secondary/Adult teaching credential, member of IBM’s Software Developers Assistance Program and Independent Vendor League, a Microsoft Solutions Provider Partner, and a life member of the IEEE. He has been certified as an IBM Certified OS2 consultant and trainer; WordPerfect Corporation Developer/Consultant and Lotus Development Corporation Developer/Consultant. He was also a first-class FCC technician in the early days of radio. Ernest Worthman may be contacted at: [email protected]