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The Remedy Testimony - Bill #36-0105 - October 9th, 2025 October 6, 2025 Honorable Carla J. Joseph Chairwoman, Committee on Rules and Judiciary 36th Legislature of the Virgin Islands Dear Senator Joseph: Thank you for your letter inviting Lindsey Rithamel and Ryan Kohrig, owners of The Remedy, to provide testimony on Bill No. 36-0105. Please be advised we will unfortunately be unable to attend this hearing in person but submit the following written testimony. We would like to be clear that we are in full support of amending Virgin Islands law to include restrictions and regulations on hemp-derived products. However, as drafted, this bill functions as prohibition rather than regulation, an approach that has historically failed to achieve public health goals. The bill purports to “ensure equitable regulation, enforcement, and reduce ambiguity for businesses, law enforcement, and regulators, while keeping the Virgin Islands competitive in the hemp industry and spur economic development.” It is our position that this bill would do the opposite, creating confusion and economic harm. Proposed §200a of the bill is contradictory and nearly impossible to enforce. Instead of reducing ambiguity, the language ensures constant uncertainty for regulators and lawful businesses alike. Far from keeping the territory competitive, this measure would decimate the local industry, driving commerce off-island, halting investment, and erasing the very economic development opportunities the bill claims to promote. Even if enforcement were possible, the measure would not meaningfully reduce access. Under the Dormant Commerce Clause and the Revised Organic Act of 1954, the Virgin Islands cannot discriminate against federally lawful hemp in interstate commerce, as affirmed in The Remedy Testimony - Bill #36-0105 - October 9th, 2025 Federal courts. This means that consumers will simply buy these products online, beyond the reach of local regulation. Additionally, this would drive consumers to black-market, homemade alternatives which are the very products identified in the September 4th hearing on this bill as the source of harm behind the health incidents in the territory, confirmed by Director of Enforcement of the Department of Licensing and Consumer Affairs, Wilber Francis, and Department of Health Commissioner, Justa Encarnacion. It was suggested at this same hearing that “no bill is perfect” and amendments can follow. Respectfully, the inaccuracies and contradictions in this bill are not minor details and go to the heart of enforceability and interpretation. Passing a flawed measure will create immediate confusion for agencies and compliant businesses. Clarifications regarding delta-8 tetrahydrocannabinol (Δ⁸-THC) statements in the bill ⎯ It is true that these products have not been evaluated or approved by the U.S. Food and Drug Administration (FDA), but this is also true for many lawful consumer products (dietary supplements, essential oils, energy drinks) that are regulated through labeling and manufacturing standards. ⎯ The bill states that the chemical process to produce the concentrations of Δ⁸-THC needed for commercial products “may result in harmful byproducts or contaminants….” Reputable manufacturers already provide third-party lab reports demonstrating products are free of residual solvents, heavy metals, pesticides, microbials, and other byproducts. Requiring these additional tests for ingestibles would easily combat this issue and ensure safety. ⎯ Although irresponsible manufacturers that market products with youth-appealing packaging do exist, reputable companies already follow strict labeling standards and child-resistant packaging. Mandating clear labeling, warnings, physical access controls, and age The Remedy Testimony - Bill #36-0105 - October 9th, 2025 restrictions for products sold in the territory would directly address this issue while keeping hemp-derived products out of the hands of minors. ⎯ The FDA has received reports of short-term adverse reactions (including dizziness, nausea, confusion, hallucinations) in connection with Δ⁸-THC products. Meanwhile, comparative risk assessments place alcohol and tobacco much higher in long-term harm categories. In other words, while isolated short-term effects are documented for hemp-derived cannabinoids, the evidence base supports regulating access and quality, not a sweeping ban, given alcohol and cigarettes’ well-documented, severe chronic harms. A smarter, evidence-based approach What we are asking for is not to maintain the status quo, but to implement balanced regulation. We have included bills from three states that show how other legislatures have addressed or are looking to address youth access and safety without destroying their hemp industries (attachments 1-3). We encourage the Legislature to look to these examples as models for balanced regulation that safeguards consumers. Requested revisions to the bill We fully support section §200a(1) of this bill, as it appropriately addresses cannabinoids that do not occur naturally in the plant in any quantity. We recommend that subsection §200a(2) that would ban cannabinoids capable of being naturally produced by the plant that were isomerized by, synthesized, chemically altered or manufactured outside of the plant be stricken from the bill. There is currently no laboratory method used in commerce that can determine whether cannabinoids were produced in the plant or converted synthetically, making compliance impractical to verify. Additional easily enforceable regulations and safeguards can be written to require ingestible products to have The Remedy Testimony - Bill #36-0105 - October 9th, 2025 third-party lab reports from the manufacturer demonstrating they are free of harmful byproducts that could remain from these processes, as mentioned earlier. If the Legislature’s intent is to keep §200a(2) that prohibits these naturally occurring cannabinoids that exist in hemp products only through chemical conversion or semi-synthetic processes rather than regulate them, we respectfully urge this body to strike all references to tetrahydrocannabinolic acid (THCA), remove subsection §200a(3), and delete subsection §200a(4) of amendment 36-527. THCA in hemp-derived products are produced from naturally occurring THCA within the plant, not through chemical or biotechnological synthesis from CBD or other cannabinoids as they are not practical or cost effective for commercial hemp manufacturing. THCA should therefore not be grouped with chemically converted cannabinoids in §200a(2) as it would contradict scientific evidence and effectively criminalize lawful hemp flower and many unintended, full- spectrum products. Removing subsections §200a(3) and §200a(4) from Amendment 36-527 is appropriate because, with §200a(1) already prohibiting fully synthetic, non-naturally occurring cannabinoids and added language expressly covering cannabinoids produced by chemical conversion, the remaining provisions would otherwise reach only naturally occurring cannabinoids. This revision eliminates enforcement gray areas and avoids reliance on subjective phrases such as “cannabinoids that have similar effects or are marketed to have similar effects”. We humbly recommend the legislature adopt the following additional regulations: 1. Age limits (21+ for sales and possession) 2. Point-of-sale controls (reduce youth access & confusion) a. Behind-the-counter / locked storage for all consumables The Remedy Testimony - Bill #36-0105 - October 9th, 2025 b. Mandatory youth-warning placards 3. Labeling, disclosures & packaging a. Comprehensive labels on ingestible products (ex: serving size, 21+ only, impairment warning, FDA disclaimer) b. QR code to lab reports c. Tamper-evident and child-resistant packaging for consumables d. Restrictions on packaging against trademarked foods, animal/cartoon imagery, or youth-appealing branding 4. Taxation (funding enforcement and education) a. Retail excise tax on hemp product sales (e.g., 2–5% of gross sales) 5. Limitations on combined business licenses a. Restrict “hemp retailer” licenses from being combined with other categories (ex: gasoline stations) These solutions provide genuine safeguards without destroying the hemp industry or creating contradictions in law. The Remedy remains dedicated to supporting the Legislature’s efforts to create a responsible, transparent, and a well-regulated hemp industry. We appreciate the opportunity to contribute and look forward to continued collaboration on sensible and effective policy. Sincerely, Lindsey Rithamel & Ryan Kohrig Owners – The Remedy Page 1 - 132LR1662(04) STATE OF MAINE _____ IN THE YEAR OF OUR LORD TWO THOUSAND TWENTY-FIVE _____ H.P. 1281 - L.D. 1920 An Act to Prohibit the Sale of Potentially Intoxicating Hemp Products to a Person Under 21 Years of Age Emergency preamble. Whereas, acts and resolves of the Legislature do not become effective until 90 days after adjournment unless enacted as emergencies; and Whereas, there are currently intoxicating hemp products for sale in this State for which there is no legal restriction preventing sale to minor children; and Whereas, some of those products may be designed or packaged in a manner that a person, including a child, could potentially be led to confuse the intoxicating products for nonintoxicating products typically marketed to children, such as gummies or similar products; and Whereas, ingestion of intoxicating hemp products by a child can cause harm to the child; and Whereas, it is in the interest of child safety for the restrictions directed by this legislation to go into effect as soon as possible; and Whereas, in the judgment of the Legislature, these facts create an emergency within the meaning of the Constitution of Maine and require the following legislation as immediately necessary for the preservation of the public peace, health and safety; now, therefore, Be it enacted by the People of the State of Maine as follows: Sec. 1. 7 MRSA §2231, sub-§1-A, ¶F is enacted to read: F. "Nonintoxicating cannabinoid" means: (1) Cannabidiol, also known as "CBD"; (2) Tetrahydrocannabivarin, also known as "THCV"; (3) Cannabichromene, also known as "CBC"; (4) Cannabicitran, also known as "CBTC"; (5) Cannabicyclol, also known as "CBL"; LAW WITHOUT GOVERNOR'S SIGNATURE JUNE 24, 2025 CHAPTER 416 PUBLIC LAW ATTACHMENT 1 MAINE BILL HP 1281 (LD 1920) SIGNED INTO LAW JUNE 24, 2025 Page 2 - 132LR1662(04) (6) Cannabielsoin, also known as "CBE"; (7) Cannabigerol, also known as "CBG"; (8) Cannabidivarin, also known as "CBDV"; and (9) Cannabinol, also known as "CBN." Sec. 2. 7 MRSA §2231, sub-§1-A, ¶G is enacted to read: G. "Potentially intoxicating cannabinoids" include the following: (1) Delta-10-tetrahydrocannabinol and its isomers; (2) Delta-9-tetrahydrocannabinol and its isomers; (3) Delta-8-tetrahydrocannabinol and its isomers; (4) Delta-7-tetrahydrocannabinol and its isomers; (5) Delta-6a,10a-tetrahydrocannabinol and its isomers; (6) Exo-tetrahydrocannabinol; (7) Metabolites of tetrahydrocannabinol, including 11-hydroxy- tetrahydrocannabinol, 3'-hydroxy-tetrahydrocannabinol and 7-hydroxy-delta- tetrahydrocannabinol; (8) Hydrogenated forms of tetrahydrocannabinol, including hexahydrocannabinol, hexahydrocannabiphorol and hexahydrocannabihexol; (9) Synthetic forms of tetrahydrocannabinol, including dronabinol; (10) Ester forms of tetrahydrocannabinol, including delta-8-tetrahydrocannabinol- O-acetate, delta-9-tetrahydrocannabinol-O-acetate and hexahydrocannabinol-O- acetate; (11) Varin forms of tetrahydrocannabinol, including delta-8- tetrahydrocannabivarin but excluding delta-9-tetrahydrocannabivarin; and (12) Analogs of tetrahydrocannabinols with an alkyl chain of 4 or more carbon atoms, including tetrahydrocannabiphorols, tetrahydrocannabioctyls, tetrahydrocannabihexols and tetrahydrocannabutols. Sec. 3. 7 MRSA §2231, sub-§1-A, ¶H is enacted to read: H. "Potentially intoxicating hemp product" means any products derived from hemp and ingestible consumer products, including food, food additives, food products and beverages derived from hemp, that in their final forms do not contain: (1) A concentration of less than 0.3% potentially intoxicating cannabinoids; and (2) A ratio of more than 10:1 of nonintoxicating cannabinoids to potentially intoxicating cannabinoids. Sec. 4. 7 MRSA §2231, sub-§12 is enacted to read: 12. Potentially intoxicating hemp products; prohibited sales. A potentially intoxicating hemp product may not be sold to a person who has not attained 21 years of age. Sec. 5. 7 MRSA §2231, sub-§13 is enacted to read: Page 3 - 132LR1662(04) 13. Packaging and labeling requirements. This subsection governs packaging and labeling requirements for hemp products. A. A potentially intoxicating hemp product that is not a beverage, salve or topical product must be packaged in child-resistant and tamper-evident packaging. B. A hemp product may not be labeled or packaged in violation of a federal trademark law or regulation or in a manner that would cause a reasonable consumer confusion as to whether the item was a different trademarked product. Emergency clause. In view of the emergency cited in the preamble, this legislation takes effect when approved.                                                 ATTACHMENT 2 SOUTH CAROLINA BILL 3924 PASSED HOUSE VOTE & MOVED TO SENATE APRIL 10, 2025                                                                                          104TH GENERAL ASSEMBLY State of Illinois 2025 and 2026 HB0064 Introduced 1/9/2025, by Rep. Sonya M. Harper SYNOPSIS AS INTRODUCED: 410 ILCS 620/21 from Ch. 56 1/2, par. 521 505 ILCS 89/5 505 ILCS 89/10 505 ILCS 89/15 505 ILCS 89/20 Amends the Illinois Food, Drug and Cosmetic Act. Provides that, notwithstanding any other provision of law, a food, food ingredient, dietary supplement, cosmetic, or other consumer product shall not be considered adulterated solely because it contains hemp, hemp-derived cannabinoids, including, but not limited to, Delta-9 tetrahydrocannabinol (THC), Delta-8 THC, tetrahydrocannabinolic acid (THCa), or any hemp product, provided that the hemp used in the product complies with the definition of "hemp" as specified in federal law. Amends the Industrial Hemp Act. Conforms several provisions in the Act to federal regulations under the Domestic Hemp Production Program, including (i) definitions, (ii) requirements for the application for a license to cultivate hemp, and (iii) rulemaking requirements for the Department of Agriculture. Provides that the Department of Agriculture shall adopt rules for the distribution and retail sale of hemp products under conditions in specified provisions of the Act. Provides that hemp products that contain cannabinoids, that are intended for human consumption, and that are designated for retail sale within Illinois (i) must meet specified requirements, including federal requirements and rules adopted by the Department of Public Health, and (ii) must be distributed or sold in a container that includes specified information. Provides that hemp products that are intended for inhalation or ingestion and contain detectable amounts of hemp cannabinoids may not be sold in this State to a person who is under 21 years of age. Provides that hemp products distributed or sold in violation of specified provisions in the Act shall be considered adulterated or misbranded pursuant to the Illinois Food, Drug and Cosmetic Act and all other applicable State laws. Defines terms. Makes technical changes. LRB104 03035 BDA 13053 b A BILL FOR *LRB10403035BDA13053b* HB0064 ATTACHMENT 3 ILLINOIS BILL HB0064 REFERRED TO HOUSE RULE COMMITTEE JANUARY 9, 2025 AN ACT concerning hemp. Be it enacted by the People of the State of Illinois, represented in the General Assembly: Section 5. The Illinois Food, Drug and Cosmetic Act is amended by changing Section 21 as follows: (410 ILCS 620/21) (from Ch. 56 1/2, par. 521) Sec. 21. Rulemaking; enforcement; federal regulations. (a) The authority to adopt rules promulgate regulations for the efficient enforcement of this Act is vested in the Director. The Director is authorized to make the rules adopted regulations promulgated under this Act conform, in so far as practicable, with those promulgated under the Federal Act. (b) Hearings authorized or required by this Act shall be conducted by the Director or an officer, agent, or employee designated by the Director him. (c) All pesticide chemical regulations and supplements thereto or revisions to those regulations that are thereof adopted under authority of the Federal Food, Drug and Cosmetic Act are the pesticide chemical regulations in this State, except insofar as modified or rejected by rules regulations for finished foods adopted promulgated by the Director. (d) All food additive regulations and supplements thereto or revisions to those regulations that are thereof adopted 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 HB0064 LRB104 03035 BDA 13053 b under authority of the Federal Food, Drug and Cosmetic Act are the food additive regulations in this State, except insofar as modified or rejected by rules adopted regulations promulgated by the Director. (e) All color additive regulations and supplements thereto or revisions to those regulations that are thereof adopted under authority of the Federal Food, Drug and Cosmetic Act are the color additive regulations in this State, except insofar as modified or rejected by rules adopted regulations promulgated by the Director. (f) All special dietary use regulations and supplements thereto or revisions to those regulations that are thereof adopted under authority of the Federal Food, Drug and Cosmetic Act are the special dietary use regulations in this State, except insofar as modified or rejected by rules adopted regulations promulgated by the Director. (g) All bottled water and vended water device regulations and supplements thereto or revisions to those regulations that are thereof adopted under the authority of the Federal Food, Drug and Cosmetic Act are the bottled water and vended water device regulations in this State, except insofar as modified or rejected by rules adopted regulations promulgated by the Director. (h) All infant formula regulations and supplements thereto or revisions to those regulations that are thereof adopted under the authority of the Federal Food, Drug and Cosmetic Act 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 - 2 - HB0064 LRB104 03035 BDA 13053 b are the infant formula regulations in this State, except insofar as modified or rejected by rules adopted regulations promulgated by the Director. (i) All food, drug, device, and cosmetic Good Manufacturing Practices Regulations and supplements thereto or revisions to those regulations that are thereof adopted under the authority of Federal Food, Drug and Cosmetic Act are the food, drug, device and cosmetic Good Manufacturing Practices Regulations in this State, except insofar as modified or rejected by rules adopted regulations promulgated by the Director. (j) A federal regulation automatically adopted pursuant to this Act takes effect in this State on the date it becomes effective as a Federal regulation. No publication or hearing is required. The Director shall adopt promulgate all other proposed rules regulations in compliance with the requirements of the The Illinois Administrative Procedure Act. (k) Notwithstanding any other provision of law, a food, food ingredient, dietary supplement, cosmetic, or other consumer product shall not be considered adulterated solely because it contains hemp, hemp-derived cannabinoids, including, but not limited to, Delta-9 tetrahydrocannabinol (THC), Delta-8 THC, tetrahydrocannabinolic acid (THCa), or any hemp product, provided that the hemp used in the product complies with the definition of "hemp" as specified in 7 U.S.C. 1639o. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 - 3 - HB0064 LRB104 03035 BDA 13053 b (Source: P.A. 84-891.) Section 10. The Industrial Hemp Act is amended by changing Sections 5, 10, 15, and 20 as follows: (505 ILCS 89/5) Sec. 5. Definitions. In this Act: "Department" means the Department of Agriculture. "Director" means the Director of Agriculture. "Hemp" or "industrial hemp" means the plant Cannabis sativa L. and any part of that plant, including the seeds thereof and all derivatives, extracts, cannabinoids, isomers, acids, salts, and salts of isomers, whether growing or not, with a delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis and includes any intermediate or finished product made or derived from industrial hemp. "Hemp product" means a product that contains hemp. "Hemp production plan" means a plan submitted by the Department to the Secretary of the United States Department of Agriculture pursuant to the federal Agriculture Improvement Act of 2018, Public Law 115-334, and consistent with the Domestic Hemp Production Program pursuant to 7 CFR Part 990 wherein the Department establishes its desire to have primary regulatory authority over the production of hemp. "Industrial hemp" means hemp or any intermediate or 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 - 4 - HB0064 LRB104 03035 BDA 13053 b finished product made or derived from hemp. "Lot" has the meaning ascribed to that term in 7 CFR 990.1. "Land area" means a farm as defined in Section 1-60 of the Property Tax Code in this State or land or facilities under the control of an institution of higher education. "Person" means any individual, partnership, firm, corporation, company, society, association, the State or any department, agency, or subdivision thereof, or any other entity. "Process" means the conversion of raw industrial hemp plant material into a form that is presently legal to import from outside the United States under federal law. "THC" means delta-9 tetrahydrocannabinol. (Source: P.A. 102-690, eff. 12-17-21.) (505 ILCS 89/10) Sec. 10. Licenses and registration. (a) No person shall cultivate industrial hemp in this State without a license issued by the Department. (b) The application for a license shall include: (1) the name and address of the applicant; (2) a legal description of the land that contains the lots where hemp is to be produced, including, to the extent practicable, any geospatial locations consistent with the Domestic Hemp Production Program under 7 CFR Part 990 the legal description of the land area, including 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 - 5 - HB0064 LRB104 03035 BDA 13053 b Global Positioning System coordinates, to be used to cultivate industrial hemp; and (3) if federal law requires a research purpose for the cultivation of industrial hemp, a description of one or more research purposes planned for the cultivation of industrial hemp which may include the study of the growth, cultivation, or marketing of industrial hemp; however, the research purpose requirement shall not be construed to limit the commercial sale of industrial hemp. (b-5) A person shall not process industrial hemp in this State without registering with the Department on a form prescribed by the Department. (c) The Department may determine, by rule, the duration of a license or registration; application, registration, and license fees; and the requirements for license or registration renewal. (Source: P.A. 102-690, eff. 12-17-21.) (505 ILCS 89/15) Sec. 15. Rules. (a) The Department shall submit to the Secretary of the United States Department of Agriculture a hemp production plan under which the Department monitors and regulates the production of industrial hemp in this State. The Department shall adopt rules incorporating the hemp production plan, including application and licensing requirements. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 - 6 - HB0064 LRB104 03035 BDA 13053 b (b) The rules adopted set by the Department shall include annual inspections of, at a minimum, a random group of producers to verify that hemp is produced in compliance with this Act and the Domestic Hemp Production Program established under 7 CFR Part 990 one yearly inspection of a licensed industrial hemp cultivation operation and allow for additional unannounced inspections of a licensed industrial hemp cultivation operation at the Department's discretion. (c) The Department shall adopt rules necessary for the administration and enforcement of this Act in accordance with all applicable State and federal laws and regulations, including rules concerning standards and criteria for licensure and registration, for the payment of applicable fees, signage, and for forms required for the administration of this Act. (d) The Department shall adopt rules for the testing of the industrial hemp THC levels and for remediation or the disposal of plant matter exceeding lawful THC levels, including an option for a cultivator to retest for a minor violation consistent with the Domestic Hemp Production Program under 7 CFR Part 990. , with the retest threshold determined by the Department and set in rule. Those rules may provide for the use of seed certified to meet the THC levels mandated by this Act as an alternative to testing (e) The Department shall adopt rules for the distribution and retail sale of hemp products that meet all conditions 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 - 7 - HB0064 LRB104 03035 BDA 13053 b specified in Section 20 of this Act. (Source: P.A. 102-690, eff. 12-17-21.) (505 ILCS 89/20) Sec. 20. Hemp products. (a) Nothing in this Act shall alter the legality of hemp or hemp products that are presently legal to possess or own, except as otherwise provided in this Section. (b) Hemp products that contain cannabinoids, that are intended for human consumption, and that are designated for retail sale within Illinois must meet the following requirements: (1) The hemp used in the hemp products must comply with the definition of "hemp" specified in 7 U.S.C. 1639o. (2) The hemp products must not contain contaminants unsafe for human consumption, including, but not limited to, any microbe, fungus, yeast, mildew, herbicide, pesticide, fungicide, residual solvent, metal, or other contaminant found in any amount that exceeds any of the accepted limitations as determined by rules adopted by the Department of Public Health for a food, food ingredient, dietary supplement, cosmetic, or other consumer product, or other limitation pursuant to the laws of this State, whichever amount is less. (c) Hemp products that contain cannabinoids, that are intended for human consumption, and that are designated for 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 - 8 - HB0064 LRB104 03035 BDA 13053 b retail sale within Illinois must be distributed or sold in a container that includes: (1) a scannable barcode or quick response code linked to a certificate of analysis prepared by an approved testing laboratory prominently displaying the concentration of all detectable cannabinoids in the product as well as any detectable contaminants under paragraph (2) of subsection (b) of this Section or rules adopted under that paragraph; (2) the expiration date of the product; (3) the number of milligrams of each marketed cannabinoid per serving; and (4) a disclaimer, which shall state: "These statements have not been evaluated by the United States Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.". (d) Hemp products that are intended for inhalation or ingestion and contain detectable amounts of hemp cannabinoids may not be sold in this State to a person who is under 21 years of age. (e) Hemp products distributed or sold in violation of this Section shall be considered adulterated or misbranded under the Illinois Food, Drug and Cosmetic Act and all other applicable State laws. (Source: P.A. 100-1091, eff. 8-26-18.) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 - 9 - HB0064 LRB104 03035 BDA 13053 b