National Affairs-[Continued] pelled to pay for the things they buy." At Kansas City. After speaking at Topeka, John W. Davis went to Kansas City. There he stopped at the Hotel Muehlebach. He left his room and went to another room in the hotel. There he called on Senator James A. Reed of Missouri, who is invaliding from a recent illness. Senator Reed not long ago announced himself as a supporter of Mr. Davis. So the two are on good terms, although Mr. Davis is a proponent of the League of Nations and Mr. Reed a violent opponent. At Milwaukee, Charles G. Dawes went to the lair of La Follettism to attack, not because the Republicans hope for success there, but rather because of the compelling interest which comes to those who attack the lion in his den. He declared that the La Follette plank, which would permit Congress to override a decision of the Supreme Court that a law is unconstitutional, would destroy the authority of the Constitution which guarantees the civil and political rights of the individual, which reserves certain rights to the states. He said: Of popular government: "That government whose policy is determined by the ultimate judgment of the people will permanently survive. The government whose actions are determined by the passing phases of popular opinion, as distinguished from ultimate opinion, will perish. The Constitution of the United States establishes the rule of the people, as distinguished from the rule of the mob." Of LaFollettism: It "represents the quintessence of demagogism animated by the vicious purpose of undermining the constitutional foundation of the Republic." Of LaFollette's Labor Day speech: "A violent and unsupported affirmation. Never in the history of the United States has the commonsense of the average individual received a greater affront." Of the Convention which adopted the LaFollette Platform: "The heterogeneous collection of the representatives of organized minorities which endorsed the candidacy of Robert M. LaFollette could never have evolved a platform of their own, so diverse were their doctrines and so impracticable and impossible their scattered viewpoints. It seems that there was but one man in the U. S., who could impose platform upon them; and he only could do it because the cardinal principle of his platform was an attack upon the courts and the Constitution of the U. S. . . That is why the Socialist Party a is standing behind LaFollette; and, in the words of Eugene V. Debs, telegraphing his endorsement in this campaign 'is adhering rigidly to its principles and keeping the red flag flying.'" At Washington, one William Meuser and a committee from the Steuben Society addressed Mr. LaFollette, promising him the support of six million U. S. citizens of German blood. Said Mr. Meuser: "The notification which we convey to you is the expression of the mature judgment of 90% of the most loyal, modest and conservative element in the American complex, which recognizes in you the shining qualities of conservative statesmanship and unbending devotion to the principles of constitutional government." Answered Mr. LaFollette: "From my heart I thank you for your stirring message and welcome the support you pledge. . . .We are hearing much in this campaign of the Constitution and of Americanism. I am content to have it so. But I insist that the best friends of the Constitution are those who dared to voice their protest when that instrument, ordained to give perpetuity to the immortal declaration 'conceived in liberty and dedicated to the proposition that all men are created equal,' is invoked as a shield for corrupt and lawless wealth and for the oppression of the liberties of the people in the exercise of their inalienable rights. "I maintain that the real enemies of the Constitution and the real menace to American Government are those unpunished agents of corruption who have despoiled the public domain and betrayed the people, who have written the blackest page in the history of our Government from their high Cabinet positions, and who, it must be said to the shame of the country, have gone to this hour without Executive rebuke. "To trace the progress of this malignant disease, which threatens the very foundation of Constitutional Government, we need only survey the wide chasm which separates Carl Schurz, Secretary of the Interior in Garfield's Cabinet, from Albert B. Fall, Harry M. Daugherty and others of intimate and daily association with this Administration." Where the Money Goes Donald MacGregor, correspondent, recently wrote an article on campaign management. As a specific statement of what the Parties are doing and will do in the present campaign, it was of little value; but it rehearsed, in a general manner, the way money is spent in campaigns something which is not too W known by the public. Mr. MacGregor laid out a typic campaign budget: 25% for headquarters expenses 20% for speakers and radiocastin 20% for campaign books, button posters 15% for miscellaneous and eme gency costs 10% for advertising e The 25% for headquarters penses is devoted to rent and ma agement, to scores of clerks and ste ographers and other assistants, su as are necessary in the business spending several million dollars effe tively in two or three months. possible, the headquarters are usual made expensively elaborate, becau visitors like feeling that they ha been to call on a successful organ zation. The 20% devoted to speakers go mostly for railroad fare and hot bills, since most of the speakers giv their time free. Radiocasting will c down some of the traveling expense but will add instead another costthe use of telephone wires for carry ing speeches to distant radiocastin stations. Every radio speech no costs several thousand dollars. The 20% for campaign trinket goes into a number of things. Th most elaborate is the campaign tex books giving the party platform, ac ceptance speeches of the candidate and other good party propaganda These are distributed to local cam paigners, to editors, to correspond ents, etc. wherever they may do good-and they cost perhaps $50,00 There are also many thousands of pamphlets, much cheaper to get out but much more numerous. There are posters and lithographs of the candidates which cost about four cents apiece. In 1920, the Republi cans distributed 5,000,000 of these in crucial states. There are also campaign buttons costing from three cents apiece up, depending on their elaborateness. A shipping depart ment must handle the distribution of all this stuff. In 1920, the Republi cans spent $680,000 on shipping. Billboard advertising is more flexible than other means of expenditure, is more likely to be practiced by those with well-filled campaign chests than by those who are cramped in their funds. Even in the gigantic year of 1920, the Republicans spent only $400.000 in this way. The 15% for miscellaneous items covers telegraph and long distance National Affairs-[Continued] lephone calls, everything extraorinary. Usually, the traveling expenses of the Presidential and Vice Presidential candidates come out of his fund rather than out of the general speakers fund. These traveling Expenses frequently come to 5% of The entire cost of the campaign. The reason for this is that candidates ravel on special trains so that they can stop by the wayside to make speeches and thus facilitate their usiness. Special trains are expensive. Cars are rented by the day and 100 full-fare railroad tickets are required also. James M. Cox spent his $100,000 on expensive stumpSpeaking in 1920. The 10% spent on press bureaus and news service, chiefly to small dailies and weeklies, is well spent; good writers, good cartoonists are hired to turn out news-propaganda. This is shipped out free to the small papers, sometimes as "mats" or "plates"—that is, with the typesetting already done. The little press gobbles this up greedily. In general, it is by far the most ably written stuff that such papers print and it has a deadly political effect. This is the manner in which $10 million or so will be spent this year. Bob Jr. vs. Butler Republican Chairman William M. Butler counter-attacked Senator LaFollette on the question of combinations and monopolies : "He reiterates the conviction that there are gigantic conspiracies in American industry and trade by which the 'system' is sucking the blood, morals and the pocketbooks of people. American "As a matter of fact, in the bituminous coal industry, which comprises 85% of all coal, there is no single corporation or group selling commercial coal which controls more than 5% of the output. There are 8,000 independent operators busy at the present time cutting each other's throats in competition and fully one-half of them are now selling coal for less than cost. "The price of sugar in the United States since the tariff has averaged a little over six cents a pound for wholesale refined sugar at New York. The average for the three years before the War was a little over four and onehalf cents per pound, making an increase in price now of between 30 and 35%, while the increase in wages in the United States has been 100% and the average increase in the price of all other commodities has been about 45%. It must be obvious that, if this industry were under monopoly, it would surely try to get the average price of commodities. "Competition in the oil industry has resulted in tremendous overproduction and low prices. Senator LaFollette, with his usual knowledge of industrial conditions, prophesied a year ago that we would have $1 gasoline." To this, Bob LaFollette, son of Senator, retorted: "There is no coal trust, no sugar trust, no oil trust, no beef trust, or any other kind of trust, so far as Mr. Butler has ever heard. All the trusts are gone. Harry Daugherty smashed them. "Coal, according to Mr. Butler, is selling for less than cost, Standard Oil is a philanthropic institution, and the 'Big Five' packers are dead broke. Only the tariff, says Mr. Butler, is protecting the innocent beet sugar trust from the terrible Cuban cane sugar trust, when everybody knows that both are controlled by the same bunch of American financiers. "I challenge Mr. Butler to go anywhere west of the Mississippi and recite his farm prosperity statistics to an audience of bankrupt farmers." Protestants The following is an extract from a 'document given to the press and published in many Republican papers: The undersigned, who were supporters of Theodore Roosevelt and the Progressive Party, hereby express resentment at the attempt to arrogate the name of "Progressive" for the radical movement represented by the candidacy of Senator Robert M. LaFollette, and join in this statement of reasons why his candidacy is not entitled to Progressive support. The movement in which we united with Theodore Roosevelt and millions of other Americans, under the historic name of "Progressive," was not radical. Its purpose was to improve American institutions, not to substitute others for them. It stood for political and social justice, not economic revolution. It believed in democracy, not socialism. The only political party of which Senator La Follette is the avowed candidate is the Socialist Party. The rest consists of incongruous groups invited as class blocks rather than as citizens holding common views, who agree only in their disagreement. The Republican Party, which he now repudiates, was satisfactory to him when it had shrunk to a minority fragment dominated exclusively by its conservative element. He said in 1912: "If they [the leaders] are recreant to their trust, the party may suffer the temporary defeat of its purposes. But what abject folly to seek upon such a basis to destroy a great political party. with a clear progressive majority in its ranks, within which there has been builded up a progressive movement that promises to make the Republican Party the instrument through which the government will be restored to the people.. And upon that fact in recent political history, I appealed to progressive Republicans everywhere to maintain their organization within the Republican Party." What Senator La Follette would not do for a sound progressive movement because he was not the candidate, he now does for a destructive, radical one because he is a candidate. Of him Roosevelt said: "He is acting in such fashion as to make him one of the most potent enemies of this country and a most sinister enemy of democracy. We are to stand against men of the stamp of LaFollette. We had this type in the Civil War. Then we called them "Copperheads." We regard it as a supreme challenge to vindicate the memory of Theodore Roosevelt by repudiating this attempt of frustrated ambition to promote the class cleavage in class politics, which Roosevelt spent his life to prevent. L. F. Abbott. N. Y. Frank Knox N. H. George Ade. Ind. A. Lambert....... Henry J. Allen.... Kan. M. F. Lawrence.... Pa. Chas. S. Bird.. Mass. S. McC. Lindsay, Mrs. A. C. Bird, Mass. N. Y. N. Y. Calif. Percy Long. W. P. Bloodgood..Wis. R. H. McCormick Ill. W. C. Bobbs...... Ind. J. S. Mason. N. Y. S. J. Duncan-Clark, J. C. O'Laughlin, 111. D. C. F. P. Corrick..... Neb. J. M. Parker. La, Mrs. William Curtis G. D. Pope. Mich. Demorest N. Y. F. C. Porter.......Calif. C. P. Dodge.. .Col. G. F. Porter. M. H. Elliot.. .R. I. G. C. Priestley....Okla. Lewis Emory Jr... Pa. Raymond Robins.....Ill. H. D. W. English. Pa. Charles Ringer..... Ill. J. R. Garfield......Ohio C. R. Robinson....N. Y. A. L. Garford. .Ohio C. H. Rowell......Calif. Conn. Benjamin Griffith. Col. H. K. Smith. H. Hagedorn. P. S. Stephenson. Va. A. B. Hart. Oscar Straus... N. Y. E. H. Hooker. Julian Street. A. M. Hyde. F. Kellor.... I. Kirkwood N. Y. Mass. N. Y. Mo. N. Y. Mo. L. N. Kirkwood....Mo. E. A. Van Valkenburg E. D. Vincent. H. E. Vittum. FARMERS What They Want N. J. Pa. .Col. Ill. Gray Silver, "the Legislature representative" (i. e., head lobbyist) of the American Farm Bureau Federation, gave out last week a list of some of the things that farmers want from the next session of Congress: CA bill to develop Muscle Shoals for cheap fertilizer. Mr. Silver spoke repeatedly of the Ford bid, but did not specify that it was the only one acceptable to farmers. He argued that more power must be applied to agricultural processes and showed the effect of increased power; that in 1850, with 1.5 horsepower per farmer, nine farmers were able to feed themselves and one other man; that today, with 4.6 horsepower per farmer, one farmer is able to feed himself and three other men. But, he added, "the value of agricultural products per worker is about $2,000; the value of the manufacturer's nearly $6,000; the miner's, $3,000; the railroader's, $2,500." This is in spite of the fact that the investment in agriculture is twice that in manufacturing, four times that in railroads and ten times that in mining. He admitted that horsepower applied to agriculture does not produce as great an increase in the value of the product per worker as in other lines of activity. If this be true, it means not only that power will be turned to other more profitable uses than farming, but also that there is no legitimate reason why the community as a whole should develop its power for agriculture rather than for more productive enterprises. A bill to permit the Department of Agriculture to dye all imported field seeds which it finds not adaptable to this country. The object of this bill National Affairs-[Continued] "The War Department has received, during the evening, dispatches from all corps area headquarters 'describing the results of the defense test. These reports show that more than 16,792,781 person have particpated, and that there have been 6,535 demonstrations." If 16,792,781 persons did not take part in Defense Day exercises (one person in every seven), at any rate a large number had a hand. The official bulletin compiled from the reports of corps area commanders may have contained some pardonable exaggerations. But the idea was simple-to get the people accustomed to the initial steps which must be gone through in a national emergency. Parades, sham battles, demonstrations were an incidental means of dramatizing the idea. In Washington, General Pershing and President Coolidge reviewed a parade of 30,000 people. Secretaries Hughes and Weeks looked on. Major General John L. Hines, the new Chief of Staff and successor of Pershing, Admiral Edward W. Eberle were part of the group. In 6,534 other communities, lesser officials did the job. General Pershing issued a farewell statement in honor of the day which was coincident with his retirement: "To participate in ceremonies attendant upon the retirement of officers and enlisted men, as I have done numberles times, gives one no adequate idea of his feelings when his own turn comes. But even in severing an association that has lasted as long as mine, there are some compensations. I can look back over the period and see the evolution of the Army from a small body of highly specialized Indian fighters, for the most from the great mass of their fellow-citizens, into the Army of today-Regulars, National Guard and Reserves-two thirds of which are civilians participating in the business, political and social Paul Thompson JUDGE GARY lives of their various communities, but none the less integral factors in the national scheme of defense." In the evening he talked by telephone, with Major General Robert L. Bullard, at New York; Major General Harry C. Hale, at Chicago; Major General George B. Duncan, at Omaha; Major General Charles G. Morton, at San Francisco.* Connections were made so that all five heard what the others said, and radiocasting stations spread all their remarks far and wide. Pershing: "Hello, General Bullard Please don't sing for us this evening." Bullard (warbling old West Point song): "Faint heart never won fair lady." Pershing: "How did Defense Day go in the Second Corps Area?" Bullard: "Bully! Bully!" Pershing: "How many citizens turned out in New York?" Bullard: "About a million." Pershing congratulated Bullard, switched over to General Hale at Chicago. Pershing: "What success or lack of success?" Hale: "No lack. . . . We put over *General Bullard was Pershing's classmate at West Point (1885). General Duncan was a plebe when Pershing and Bullard were yearlings. Generals Morton and Hale were part remote physically and mentally in the Class of 1883. a powerful peace demonstration in the Chicago area today." Pershing: "Most gratifying." General Pershing then told General Hale that there had been "a wonderful turnout" at Washington, that President Coolidge had reviewed. Said he: "Just one word more before I terminate my active service at 12 o'clock tomorrow. I don't know anybody who wants to turn the hands of the clock back and it doesn't make much difference." Hale: "I, too, will soon follow in your footsteps. . . . Success and happiness. Goodnight, General." Omaha answered the next switch of signals: "This is Duncan talking." Pershing: "Is that you, George? Did you hear what Hale and Bullard just said?" Duncan: "Yes, I listened. . . . They only echoed what happened in this corps area. . . . We regret to hear you say goodbye to the Army." Pershing thanked him, reminisced briefly, hung up. Coincident with the military tests, which brought National Guardsmen and reservists to the colors, which provided for the temporary enrollment of Red Cross nurses and civilians everywhere (even in Paris 250 men registered for service), the captains of industry rallied around their desks for the national defense. It was a great game. In the Engineering Societies Building in Manhattan, Judge Elbert H. Gary, Chairman of the U. S. Steel Corporation, received a hypothetically frantic order for railway equipment. "Crowley," he cried, "See to that!" "At once," exclaimed the President of the New York Central, and began to execute orders right and left, which went humming out in code over imaginary telegraph lines. Came an order for untold wealth. McRoberts," shouted Judge Gary, "Attend to this!" "Aye, aye, sir," called the Head of the Metropolitan Trust Company, jumping forward. As the myriad demands were made, so they were met by a ten-myriad of orders. It was a great game whether or not it all happened as reported. In the end, the captains of industry were rewarded for their labors. A telegram arrived: "JUDGE ELBERT H. GARY: "Please be good enough to communicate my good wishes and the assurance of my deep interest in the purposes of the gathering which is being held today by the leaders of the industrial and en gineering activities of the country. The national power in these departments is one of our firmest reliances for pros perity and security. (Signed) "CALVIN COOLIDGE." SHIPPING Wood and Flames National Affairs-[Continued] One of the great stories of the Trojan War was the wooden horse. One of the best stories of the World War was the wooden ships. Now their weather-worn hulks are lying in profitless decay. The Shipping Board wanted to dispose of them on any terms. The Western Marine and Salvage Co. came forward with an offer. On the I calm waters of the River James, lay 218 ships, the pride of U. S. wooden navy, built at a cost of $235 million. The Salvage Co. has taken an option on the entire lot. Ten are to be burned. If the iron and copper salvaged from the ashes repay the effort, the whole fleet will be bought for $262,000. The ships are being towed to the Potomac, off Tidewater Virginia. When practical, they will be drawn up on shore; when not, they will be left afloat. Oil, $25,000 worth, will drench their frames. And the flames, leaping and licking, will devour their oaken bodies in the last great lustration of a war gone by. TAXATION Refunds The Treasury Department reported that, without the filing of claims, 1,723,000 refunds, totaling $12,989,000, have been made to those who paid their full income tax on Mar. 15 and subsequently became entitled to a 25% reduction. As Government efficiency goes, this is a good record. The only point of the refunding procedure which seems to be involved in red tape is in securing credit and refunds for a 25% deduction on taxes "paid at source." To secure this deduction, one must massage the tax machinery. TARIFF Tariff and the Sweets There are six members of the U. S. Tariff Commission, who serve for 12 years each, one retiring at the end of every two years. It happens that, on Sept. 30, the term of David J. Lewis, of Maryland, expires. President Coolidge announced last week that he would give Mr. Lewis an interim appointment; and it was intimated that the latter would be nominated for the full term when Con gress reassembles. By Mr. Lewis' reappointment hangs a tale. The Tariff Commission has been Clinedinst Studios "Bully! Bully!" said General Bullard (See opposite page) badly divided against itself. It was divided three to three on the question of whether a member should sit on a hearing in regard to a commodity in which he was financially interested. Congress settled that question by saying "No!" The latest division was on the question of the sugar tariff. The Commission submitted two reports to Mr. Coolidge. One said: "Employ the power of the flexible provision of the tariff law to raise the sugar tariff." The other said: "Employ that power to lower the sugar tariff." The President is still meditating on this advice. But Mr. LaFollette, quicker to express himself, cried out that the tariff should be lowered, adding that the beet-sugar, high-tariff group were out to prevent the reappointment of Commissioner Lewis, who voted for a lower tariff. The reappointment of Mr. Lewis was President Coolidge's reply-in part. His decision on the tariff itself is still in abeyance. The politics of the situation is curious. The high sugar-tariff group consists principally of the beet-sugar farmers of the West; their advocate par excellence is Senator Smoot, of Utah. Their argument is that we must have a high sugar tariff; if not, the sugar importers from Cuba will cut prices, drive the beet sugar industry out of existence, and then hold up the U. S. consumer at will. As may be expected, the regular Republicans, with their high-tariff proclivities, usually rally round this standard. The high-tariffers have had most of their own way. The low sugar-tariff group is composed principally of the importing refiners and a number of large financial interests who have great investments in the Cuban sugar industry. Certain Democrats are with them, except those who come from sugar-producing states, and Senator La Follette. They argue that, since by far the greater share of our sugar is imported, and since it is estimated that sugar makes up as much as 25% of the nourishment taken by this country, it is unjust to tax the great consuming public for the benefit of a few sugar farmers. Here one finds Senator Smoot and his regular cohorts taking the side of the sugar farmers; and Senator LaFollette aligned, in regard to one issue at least, against a group of farmers and on the same side as the great financial interests which he attacks. THE CONGRESS Primary Season The last week saw the making of a number of important nominations in widely scattered states. Some of the most significant include: In South Carolina, ex-Governor Cole Livingstone Blease was nominated over Representative J. F. Byrnes after the present incumbent Senator N. B. Dial had been eliminated in a previous primary. Some of the feeling which Governor Blease can rouse may be gathered from a coruscating editorial in the London (Ky.) Mirror: "CRAZY AGAIN "People familiar with South Carolina say the State goes stark, staring, raving crazy about every thirty years. In 1801 it voted solidly and persistently for Aaron Burr for president. In 1830 it undertook to nullify the tariff laws of the United States and was called to order sternly by Andrew Jackson. In 1860-61 it first seceded and then fired on Fort Sumpter and forced the rest of us into a hopeless civil war. In 1891 it threw out of the United States Senate Wade Hampton, the greatest soldier it ever has produced, and the man whose magnificent and daring leadership de National Affairs-[Continued] livered it from the horrors and oppressions of reconstruction, replacing him with a very ordinary politician. "We rather hope the people will make their job complete by nominating and electing Cole Blease. "On the other hand, Blease, unless awed to silence and helplessness by the traditions and dignity of the Senate, would be a continuing scream, a clown without cleverness, the most perfect specimen of the cheapest kind of crossroads orator, such as we see in the comic strips, the Senate ever has known, an endless delight to the humorous section of the press gallery. He would draw on the State abundantly the shame and ridicule it has earned justly." President Wilson remarked that Governor Blease did not require "any extended comment or commendation." Blease began his career at the State University. He won a gold medal in an oratorical contest in which he spoke on the life of Robert E. Lee. He was then charged with having plagiarized part of his remarks; and the gold medal was taken back. He was expelled from the scholarly precincts. But his friends gave him a gold watch and chain and elected him to the Legislature. It was as Governor (1910-14) that he first got his great reputation. He pardoned convicted criminals by the score, 2,704 of them altogether. He bitterly opposed President Wilson and the War, although he changed his ground somewhat after War was declared. Finally he resigned from office five days before the expiration of his term, in the midst of a political fracas. At one time he was quoted as saying "To Hell with the Constitution" while defending the prohibition of divorce in South Carolina. He corrected this quotation: "Seventy-five thousand white men of my State indorsed it as I said it, and here is what I said: 'If the Constitution of my State causes my State to blush and allows her women to be forsaken, then I say to Hell with the Constitution.' We stand alone on this proposition and we are proud of it and we have no apology to make to any one." Besides having been great in turning men out of prison, he has also been great at keeping them from getting in a very successful criminal lawyer. Ever since leaving the Governorship he has been trying to enter the Senate. In 1914 he lost the nomination to Senator Smith. In 1918 he lost it to Senator Dial; in 1920 to Senator Smith again. In 1924 he won. The Senate has another fire-eater to look forward to. In Massachusetts, Frederick H. Gil Keystone THE GOVERNOR OF SOUTH CAROLINA "An endless delight" lett, Speaker of the House, 73, carried off the Republican nomination for Senator. He took it from three opponents by a good margin with the support of William M. Butler, Chairman of the Republican National Committee. Nine years ago, at 64, Mr. Gillett married. Five years ago, at 68, he was elected Speaker. He said then: "I have reached the goal of my ambition." Not so. At 73, he is running for the Senate. When one of his opponents in the primary, a man 20 years younger, objected that Mr. Gillett was too old, the Speaker answered simply: "I'm still the second best golfer in Congress." In November, Mr. Gillett will contest with Senator David I. Walsh. In Michigan, Senator James Couzens was nominated by the Republicans to succeed himself. Because he has frequently been insurgent, the Administration did not back him in his campaign. He won by good margin, when Detroit, his home town, of which he was formerly Mayor, backed him with a large majority. In Manhattan, Gifford Pinchot, Pennsylvania's famed Governor, underwent an operation for the removal of an obstruction to the duct of one of his salivary glands. Said he: "The obstruction had to be removed . . . it makes talking difficult for a few days. ... Meanwhile, the less I say the sooner the cut in the side of my neck will heal." In Terre Haute, it was reported that Warren T. McCray, onetime Governor of Indiana, who was sentenced to Atlanta penitentiary for using mails to defraud (TIME, May 12), is now functioning as a teacher in the prison Sunday School. In Manhattan, A. Mitchell Palmer, Pennsylvanian, Attorney General in the Wilson Cabinet, commented on a report that President Coolidge would make a campaign tour of the country: "I hope he will. It would be a splendid thing for the Democratic Party. The people would get a chance to see him and learn his limitations." |