Agency & PartnershipAgency & PartnershipProfessor Donald J. KochanProfessor Donald J. Kochan

Class 16Class 16

Today’s MaterialsToday’s Materials

Pages 393-417Pages 393-417

Liability of Agents Liability of Agents to Third Partiesto Third Parties

IntroductionIntroduction If you are an aggrieved third party,If you are an aggrieved third party,

Who can you sue?Who can you sue? Who should you sue? – Agent or principal?Who should you sue? – Agent or principal?

What can you sue for?What can you sue for? What must you prove?What must you prove?

What is yje difference between actual, apparent, actual, What is yje difference between actual, apparent, actual, and non authority?and non authority?

Always analyze next steps – if an agent is held liable to a Always analyze next steps – if an agent is held liable to a third party can he sue for indemnification from the third party can he sue for indemnification from the

principal or join the principal? If the principal is held liable principal or join the principal? If the principal is held liable can he sue the agent or join the agent in the third party can he sue the agent or join the agent in the third party

lawsuitlawsuit??

Introduction (cont.)Introduction (cont.)

When it Comes to Liability, Always When it Comes to Liability, Always Remember “How Would I Argue This Remember “How Would I Argue This if I Reprented X? How would I Argue if I Reprented X? How would I Argue for Y? How Might I Argue for Z?” And for Y? How Might I Argue for Z?” And

on an Exam, Tell Me All – Wear All on an Exam, Tell Me All – Wear All the Hats. Then tell me who should the Hats. Then tell me who should

win and why.win and why.

Liability When Unintentionally Liability When Unintentionally Undisclosed PrincipalUndisclosed Principal

Unwitting failures to disclose; why Unwitting failures to disclose; why does that matter versus . . .does that matter versus . . .

Intentional failures to discloseIntentional failures to disclose 1) At the direction of the principal1) At the direction of the principal 2) Unilateral decision by the agent2) Unilateral decision by the agent

Why does the distinction between 1&2 Why does the distinction between 1&2 above matter in the end?above matter in the end?

Liability When Unintentionally Liability When Unintentionally Undisclosed PrincipalUndisclosed Principal

From the Text: From the Text: “[A]n agent for an undisclosed “[A]n agent for an undisclosed

principal is liable as a party to the principal is liable as a party to the contract in recognition of the contract in recognition of the expectationsexpectations of of the person of of the person

contracting with the agent. This is true contracting with the agent. This is true even when the agent did not intend even when the agent did not intend such liability and had unintentionally such liability and had unintentionally failed to to disclose the principal.”failed to to disclose the principal.”

(emphasis added, at p. 396 Note 1)(emphasis added, at p. 396 Note 1)

Jensen v. Alaska Valuation ServiceJensen v. Alaska Valuation Service Appraisal CaseAppraisal Case

““Ordinarily, the question of whether a Ordinarily, the question of whether a corporate agents acts for a disclosed or an corporate agents acts for a disclosed or an

undiclosed principal is one of fact.”undiclosed principal is one of fact.” Use of corporate checks and notice – is that Use of corporate checks and notice – is that

sufficient disclosure?; “only one factor” and sufficient disclosure?; “only one factor” and “not necessarily determinative” in an “not necessarily determinative” in an

inherently factual inquiryinherently factual inquiry Focuses on notice and knowledge of the Focuses on notice and knowledge of the

party and duty to informparty and duty to inform

Restatement on Principal Restatement on Principal DisclosureDisclosure

§ 4. Disclosed Principal; Partially § 4. Disclosed Principal; Partially Disclosed Principal; Undisclosed PrincipalDisclosed Principal; Undisclosed Principal

(1) If, at the time of a transaction conducted by an agent, the (1) If, at the time of a transaction conducted by an agent, the other party thereto has notice that the agent is acting for a other party thereto has notice that the agent is acting for a

principal and of the principal's identity, the principal is a principal and of the principal's identity, the principal is a disclosed principal.disclosed principal.

(2) If the other party has notice that the agent is or may be (2) If the other party has notice that the agent is or may be acting for a principal but has no notice of the principal's acting for a principal but has no notice of the principal's

identity, the principal for whom the agent is acting is a partially identity, the principal for whom the agent is acting is a partially disclosed principal.disclosed principal.

(3) If the other party has no notice that the agent is acting for a (3) If the other party has no notice that the agent is acting for a

principal, the one for whom he acts is an undisclosed principal.principal, the one for whom he acts is an undisclosed principal.  

Restatement sec. 4 Comment cRestatement sec. 4 Comment c

““Whether a principal is a disclosed principal, Whether a principal is a disclosed principal, a partially disclosed principal or an a partially disclosed principal or an

undisclosed principal depends upon the undisclosed principal depends upon the manifestations of the principal or agent manifestations of the principal or agent and the knowledge of the other party and the knowledge of the other party at at

the time of the transaction.the time of the transaction. The disclosure The disclosure of the existence or identity of the principal of the existence or identity of the principal

subsequently has no bearing upon the subsequently has no bearing upon the relations created at the time of the relations created at the time of the

transaction.” [Emphasis added].transaction.” [Emphasis added].

Restatement on Undisclosed Restatement on Undisclosed PrincipalsPrincipals

§ 322. Principal Undisclosed§ 322. Principal Undisclosed An agent purporting to act upon his own account, but in fact An agent purporting to act upon his own account, but in fact

making a contract on account of an undisclosed principal, is a making a contract on account of an undisclosed principal, is a party to the contract.party to the contract.  

Comment:Comment: a.a. As stated in Section As stated in Section 186, an undisclosed principal as well as the agent, is , an undisclosed principal as well as the agent, is

liable upon a contract made on his account by an agent acting within his liable upon a contract made on his account by an agent acting within his powers, unless the contract is negotiable or sealed; hence, with the same powers, unless the contract is negotiable or sealed; hence, with the same

exceptions, the other party to the contract has the option of holding the agent exceptions, the other party to the contract has the option of holding the agent or the principal. The effect upon the agent's liability if the other party, after the or the principal. The effect upon the agent's liability if the other party, after the

discovery of the principal, deals with the principal, looks to his credit or gets discovery of the principal, deals with the principal, looks to his credit or gets judgment against him is stated in Sections judgment against him is stated in Sections 335, , 337..

b.b. If an agent purports to act for another but intends to act for himself in a If an agent purports to act for another but intends to act for himself in a transaction in which he is authorized by the other so to do, he becomes a party transaction in which he is authorized by the other so to do, he becomes a party as the undisclosed principal of the other. If he has no power to bind the other, as the undisclosed principal of the other. If he has no power to bind the other, the “agent” is normally liable on his warranty of authority (see the “agent” is normally liable on his warranty of authority (see § 329), unless ), unless the other ratifies (see the other ratifies (see § 87, Comment , Comment bb), in which case the agent is no longer ), in which case the agent is no longer liable (see liable (see § 100) and is not a party, unless the purported principal is willing.) and is not a party, unless the purported principal is willing.

Restatement on Principal Restatement on Principal Partially DisclosedPartially Disclosed

§ 321. Principal Partially Disclosed§ 321. Principal Partially Disclosed

““Unless otherwise agreed, a Unless otherwise agreed, a person purporting to make a person purporting to make a contract with another for a contract with another for a

partially disclosed principal is a partially disclosed principal is a party to the contract.”party to the contract.”

Restatement on Notice Restatement on Notice of A/P Relationshipof A/P Relationship

§ 9. Notice§ 9. Notice

   (1) A person has notice of a fact if he knows the fact, has reason (1) A person has notice of a fact if he knows the fact, has reason

to know it, should know it, or has been given notification of it.to know it, should know it, or has been given notification of it. (2) A person is given notification of a fact by another if the latter(2) A person is given notification of a fact by another if the latter (a) informs him of the fact by adequate or specified means or of (a) informs him of the fact by adequate or specified means or of

other facts from which he has reason to know or should know other facts from which he has reason to know or should know the facts: orthe facts: or

(b) does an act which, under the rules applicable to the (b) does an act which, under the rules applicable to the transaction, has the same effect on the legal relations of the transaction, has the same effect on the legal relations of the parties as the acquisition of knowledge or reason to know.parties as the acquisition of knowledge or reason to know.

(3) A person has notice of a fact if his agent has knowledge of (3) A person has notice of a fact if his agent has knowledge of the fact, reason to know it or should know it, or has been given a the fact, reason to know it or should know it, or has been given a

notification of it, under circumstances coming within the rules notification of it, under circumstances coming within the rules applying to the liability of a principal because of notice to his applying to the liability of a principal because of notice to his

agent.agent.

From Jensen:From Jensen:

““Although officers of a corporation will not Although officers of a corporation will not ordinarily be held personally liable for contracts ordinarily be held personally liable for contracts

they make as agents of the corporation, they must they make as agents of the corporation, they must disclose their agency and the existence of the disclose their agency and the existence of the corporation before they will be absolved from corporation before they will be absolved from

liability.. An agent who makes a contract for an liability.. An agent who makes a contract for an undisclosed or partially disclosed principal will be undisclosed or partially disclosed principal will be

liable as a party to the contract. liable as a party to the contract. Restatement (Second) of Agency, §§ 321, ,

322 (1958). Thus, Jensen can avoid liability only if . Thus, Jensen can avoid liability only if his use of corporate checks disclosed the existence his use of corporate checks disclosed the existence

of Arthur Jensen, Inc. and Jensen's intention to of Arthur Jensen, Inc. and Jensen's intention to contract on its behalf.”contract on its behalf.”

From Jensen:From Jensen:

““An agent who attempts to avoid liability on a An agent who attempts to avoid liability on a contract has the burden of proving that the contract has the burden of proving that the agency relationship and the identity of the agency relationship and the identity of the

principal were in fact disclosed. A third party with principal were in fact disclosed. A third party with whom the agent deals is not required to inquire whom the agent deals is not required to inquire

whether the agent is acting for another. The third whether the agent is acting for another. The third party will be held to have notice of the agency party will be held to have notice of the agency

relationship, however, “if he knows [about it], has relationship, however, “if he knows [about it], has reason to know [about] it, should know [about] it, reason to know [about] it, should know [about] it,

or has been given notification of it.” or has been given notification of it.” Restatement (Second) of Agency § 9 (1958).”.”

From the Text: Disclosure and From the Text: Disclosure and Binding the PrincipalBinding the Principal

““In general, an agent for a disclosed In general, an agent for a disclosed principal is not liable on the contract principal is not liable on the contract

arranged by the agent.”arranged by the agent.”Page 397Page 397

“’“’There is a presumption that it was There is a presumption that it was the agent’s intention to bind his the agent’s intention to bind his

principal and not to incur personal principal and not to incur personal liability . . .’”liability . . .’”

Page 397Page 397

Copp v. BreskinCopp v. Breskin

Attorney/Expert Witness CaseAttorney/Expert Witness Case

Proof of Custom IssuesProof of Custom Issues

Reliance/Reasonable Expectations IssuesReliance/Reasonable Expectations Issues

Intention IssuesIntention Issues

Disclaimer IssuesDisclaimer Issues

Copp v. Breskin (cont.)Copp v. Breskin (cont.)

““Justification for the disclosed agency Justification for the disclosed agency rule is the probable intention of the rule is the probable intention of the

parties, objectively manifested. parties, objectively manifested. Restatement (Second) of Agency § 320, Comments a-c; § 321, Comment a; § , Comments a-c; § 321, Comment a; §

328, Comment a (1958).”328, Comment a (1958).”

Copp v. Breskin (cont.)Copp v. Breskin (cont.)

““We hold that in these circumstances an attorney owes We hold that in these circumstances an attorney owes an expert or other litigation service provider an express an expert or other litigation service provider an express disclaimer of responsibility if the attorney intends not disclaimer of responsibility if the attorney intends not to be bound by a contract for litigation services. This to be bound by a contract for litigation services. This

reflects the modern trend, which is to hold the attorney reflects the modern trend, which is to hold the attorney liable in the absence of an express disclaimer or other liable in the absence of an express disclaimer or other clear indication not to be bound. Putting the burden on clear indication not to be bound. Putting the burden on the attorney promotes public trust and confidence in the attorney promotes public trust and confidence in the legal profession, the supervision of which is the the legal profession, the supervision of which is the

exclusive province and responsibility of the courts. . . . exclusive province and responsibility of the courts. . . . 3 (1984). Public trust in the profession and the courts . Public trust in the profession and the courts would be “greatly endangered and jeopardized” by a would be “greatly endangered and jeopardized” by a

technical defense of disclosed agency.”technical defense of disclosed agency.”

Notes Following Notes Following CoppCopp

Consider Restatement sec 6.01 Comment c Consider Restatement sec 6.01 Comment c regarding knowledge and reliance and regarding knowledge and reliance and

disclaimersdisclaimers Understanding such, how would you draft the Understanding such, how would you draft the

contract?contract? Focus on the importance of the drafting and Focus on the importance of the drafting and

signature issue on page 401signature issue on page 401 Focus on why the agent should avoid “personal Focus on why the agent should avoid “personal

gurantees”gurantees” When must an agent identify himself as an When must an agent identify himself as an

agent and for whoagent and for who

Van D. Costas, Inc. v. RosenbergVan D. Costas, Inc. v. Rosenberg

Mechanics Lien, Foreclosure, and Breach of Contract Case – Also Mechanics Lien, Foreclosure, and Breach of Contract Case – Also focus on monthly rental issuesfocus on monthly rental issues

What does purporting to act mean?What does purporting to act mean? What is the consequence of a “knew or should have known” What is the consequence of a “knew or should have known”

standard?standard? Regarding Liability, Why Does Awareness Go Both Ways?Regarding Liability, Why Does Awareness Go Both Ways?

Look at the notes following the case regarding the concept of Look at the notes following the case regarding the concept of “awareness”“awareness”

Look at the Notes after the case regarding drafting and Look at the Notes after the case regarding drafting and avoidance of personal liabilityavoidance of personal liability

Custom and Usage issues affect the definitions of authority and Custom and Usage issues affect the definitions of authority and liabilityliability

Is there an affirmative duty to disclose the identity of a principal?Is there an affirmative duty to disclose the identity of a principal?

Van D. Costas, Inc. v. Rosenberg (cont.)Van D. Costas, Inc. v. Rosenberg (cont.)

““The extent to which an agent must make disclosure of his principal in order The extent to which an agent must make disclosure of his principal in order to avoid personal liability is explained in to avoid personal liability is explained in 3 Am.Jur.2d Agency

§ 320” (1962)::

In order for an agent to avoid personal liability on a contract negotiated in In order for an agent to avoid personal liability on a contract negotiated in his principal's behalf, he must disclose not only that he is an agent but his principal's behalf, he must disclose not only that he is an agent but also the identity of his principal, regardless of whether the third person also the identity of his principal, regardless of whether the third person

might have known that the agent was acting in a representative might have known that the agent was acting in a representative capacity. It is not the third person's duty to seek out the identity of the capacity. It is not the third person's duty to seek out the identity of the principal; rather, the duty to disclose the identity of the principal is on principal; rather, the duty to disclose the identity of the principal is on

the agent. The disclosure of an agency is not complete for the purpose of the agent. The disclosure of an agency is not complete for the purpose of relieving the agent from personal liability unless it embraces the name of relieving the agent from personal liability unless it embraces the name of

the principal; without that, the party dealing with the agent may the principal; without that, the party dealing with the agent may understand that he intended to pledge his personal liability and understand that he intended to pledge his personal liability and responsibility in support of the contract and for its performance. responsibility in support of the contract and for its performance.

Furthermore, the use of a tradename is not necessarily a sufficient Furthermore, the use of a tradename is not necessarily a sufficient disclosure of the identity of the principal and the fact of agency so as to disclosure of the identity of the principal and the fact of agency so as to

protect the agent against personal liability.”protect the agent against personal liability.”

Van D. Costas, Inc. v. Rosenberg (cont.)Van D. Costas, Inc. v. Rosenberg (cont.)

““Section 321 of the Restatement (Second) of the Law of Agency Section 321 of the Restatement (Second) of the Law of Agency (1957) discusses the liability of the agent under circumstances in (1957) discusses the liability of the agent under circumstances in

which it appears that he is acting for someone else but the which it appears that he is acting for someone else but the identity of his principal is unknown to the other party.”identity of his principal is unknown to the other party.”

§ 321. Principal Partially Disclosed§ 321. Principal Partially Disclosed

‘‘Unless otherwise agreed, a person purporting to make a contract Unless otherwise agreed, a person purporting to make a contract with another for a partially disclosed principal is a party to the with another for a partially disclosed principal is a party to the

contract.contract.  Comment: Comment: 

a. A principal is a partially disclosed principal when, at the time of making the contract in question, the other a. A principal is a partially disclosed principal when, at the time of making the contract in question, the other party thereto has notice that the agent is acting for a principal but has no notice of the principal's identity. party thereto has notice that the agent is acting for a principal but has no notice of the principal's identity.

See § 4. The fact that, to the knowledge of the agent, the other party does not know the identity of the See § 4. The fact that, to the knowledge of the agent, the other party does not know the identity of the principal is of great weight in ascribing to the other party the intention to hold the agent liable either solely, or principal is of great weight in ascribing to the other party the intention to hold the agent liable either solely, or

as a surety or co-promisor with the principal. The inference of an understanding that the agent is a party to as a surety or co-promisor with the principal. The inference of an understanding that the agent is a party to the contract exists unless the agent gives such complete information concerning his principal's identity that the contract exists unless the agent gives such complete information concerning his principal's identity that he can be readily distinguished. If the other party has no reasonable means of ascertaining the principal, the he can be readily distinguished. If the other party has no reasonable means of ascertaining the principal, the

inference is almost irresistible and prevails in the absence of an agreement to the contrary.inference is almost irresistible and prevails in the absence of an agreement to the contrary.Restatement (Second) of Agency § 321, at 70.’”, at 70.’”

Van D. Costas, Inc. v. Rosenberg (cont.)Van D. Costas, Inc. v. Rosenberg (cont.)

““. . . Of course, if the contracting party knows . . . Of course, if the contracting party knows the identity of the principal for whom the the identity of the principal for whom the

agent purports to act, the principal is deemed agent purports to act, the principal is deemed to be disclosed. to be disclosed. Potter v. Chaney,

290 S.W.2d 44 (Ky.App.1956). A dispute . A dispute concerning such knowledge presents an issue concerning such knowledge presents an issue

of fact. of fact. Myers-Leiber Sign Co. v. Weirich, 2 Ariz.App. 534, 410 P.2d 491 (1966).”.”

What Consequence?What Consequence?

Husky Industries v. Craig Husky Industries v. Craig IndustriesIndustries

Charcoal Manufacturer CaseCharcoal Manufacturer Case Misrepresentation of Authority CaseMisrepresentation of Authority Case

Attorney Involvement CaseAttorney Involvement Case Representation IssuesRepresentation Issues

Reliance/Purporting to Act – Reliance/Purporting to Act – See Note 1 on Page 410See Note 1 on Page 410

Principal Monitoring Responsibilities IssuesPrincipal Monitoring Responsibilities Issues Principal Intervention ResponsibiltiesPrincipal Intervention Responsibilties

Husky Industries v. Craig Husky Industries v. Craig Industries (cont.)Industries (cont.)

““Having represented himself as an agent of a disclosed Having represented himself as an agent of a disclosed principal, an individual who purports to contract in the name principal, an individual who purports to contract in the name of his principal without or in excess of his authority to do so, of his principal without or in excess of his authority to do so,

becomes personally subject to liability to the other becomes personally subject to liability to the other contracting party. Unless the agreement also expressly binds contracting party. Unless the agreement also expressly binds

him personally, the liability of the agent is not predicated him personally, the liability of the agent is not predicated upon the contract itself, but rather upon the agent's breach upon the contract itself, but rather upon the agent's breach of the express or implied covenant or warranty of authority. of the express or implied covenant or warranty of authority.

The individual liability of the agent is fixed unless he The individual liability of the agent is fixed unless he manifests that he does not make such a warranty or the manifests that he does not make such a warranty or the

other contracting party knows the agent is not so authorized. other contracting party knows the agent is not so authorized. Griswold v. Haas, 277 Mo. 255, 261, 210 S.W. 356, 357(1) (1919)

; II ; II Restatement of the Law of Agency, s 329, p. 725; ; 3 Am.Jur.2d, Agency, s 298, pp. 657-658; 3 C.J.S. Agency ss ; 3 C.J.S. Agency ss

372 and 373, pp. 194-197. “372 and 373, pp. 194-197. “

Husky Industries v. Craig Husky Industries v. Craig Industries (cont.)Industries (cont.)

   ““The agent is personally liable even if he acts in the utmost good faith and honestly The agent is personally liable even if he acts in the utmost good faith and honestly

believes he was authorized and regardless of whether he has falsely represented his believes he was authorized and regardless of whether he has falsely represented his authority with intent to deceive. Robinson v. Pattee, 359 Mo. 584, 588, 222 S.W.2d 786, authority with intent to deceive. Robinson v. Pattee, 359 Mo. 584, 588, 222 S.W.2d 786, 788(5) (1949); 3 C.J.S. Agency s 374, p. 197. Although it may not be unlawful for a person 788(5) (1949); 3 C.J.S. Agency s 374, p. 197. Although it may not be unlawful for a person to agree to convey and sell property he does not presently own but expects to acquire, to agree to convey and sell property he does not presently own but expects to acquire, yet if he unqualifiedly undertakes to perform that which he later finds he cannot do, he is yet if he unqualifiedly undertakes to perform that which he later finds he cannot do, he is held to the liability which the law imposes upon the contract breaker.   Silliman v. held to the liability which the law imposes upon the contract breaker.   Silliman v. Chrisman, 584 S.W.2d 441, 447 (Mo.App.1979). As stated in the Restatement, supra, Chrisman, 584 S.W.2d 441, 447 (Mo.App.1979). As stated in the Restatement, supra, Comment a., p. 726: Comment a., p. 726:

‘‘Where an agent purports to make a contract ... for a principal, the other party Where an agent purports to make a contract ... for a principal, the other party thereto may reasonably assume from such conduct that the agent represents that he thereto may reasonably assume from such conduct that the agent represents that he has power so to bind the principal. Hence, the rule stated in this Section (i.e., 329) has power so to bind the principal. Hence, the rule stated in this Section (i.e., 329) results from the mere fact that the agent purports to act as such, although he makes results from the mere fact that the agent purports to act as such, although he makes no express representation as to his authority.” Though the agent acts bona fide, yet if no express representation as to his authority.” Though the agent acts bona fide, yet if he has no authority he still does a wrong to the other party. If that wrong produces he has no authority he still does a wrong to the other party. If that wrong produces damage to the other party, owing to his confidence in the truth of an express or damage to the other party, owing to his confidence in the truth of an express or implied assertion of authority by the agent, it is deemed just and proper that the implied assertion of authority by the agent, it is deemed just and proper that the agent who makes such an assertion should be personally liable for the consequences, agent who makes such an assertion should be personally liable for the consequences, rather than that the damage should be borne by the other party who has been misled. rather than that the damage should be borne by the other party who has been misled. 3 Am.Jur.2d, Agency, s 299, pp. 658-659.’”3 Am.Jur.2d, Agency, s 299, pp. 658-659.’”

From the Notes Following From the Notes Following HuskyHusky

Reliance ReminderReliance Reminder ““Such liability does not come into Such liability does not come into

effect where the third party knows effect where the third party knows that the agent lacks authority that the agent lacks authority

although having reason to know of although having reason to know of the agent’s lack of authority will not the agent’s lack of authority will not

prevent a claim based on warranty of prevent a claim based on warranty of authority.” What does this mean and authority.” What does this mean and

how does it affect the parties?how does it affect the parties?

From the Notes Following From the Notes Following HuskyHusky

““An agent can avoid personal liability An agent can avoid personal liability by expressly disclaiming it or by fylly by expressly disclaiming it or by fylly

laying all the facts concerning his laying all the facts concerning his authoritybefore the other partyand authoritybefore the other partyand letting the other party decide for letting the other party decide for

itself whether the transaction should itself whether the transaction should go forward.”go forward.”

Coker v. DollarCoker v. Dollar

Harm to the Economic Interests of Others – When Harm to the Economic Interests of Others – When is that Actionableis that Actionable

Apartments converted to Condominiums CaseApartments converted to Condominiums Case Escrow Accounts CaseEscrow Accounts Case

Negligence IssuesNegligence Issues ““It is of course a basic principle of tort law that It is of course a basic principle of tort law that

one cannot be held liable for negligence unless one cannot be held liable for negligence unless one is deemed to have breached some legal duty one is deemed to have breached some legal duty

owed to the injured party.”owed to the injured party.” Note fact-specific language on page 415Note fact-specific language on page 415

Note reliance issues discussed on page 415Note reliance issues discussed on page 415

Concluding ThoughtsConcluding Thoughts

Do the Problems on Page 416Do the Problems on Page 416

Revisit the Introductory Comments – Revisit the Introductory Comments – They Highlight the Themes for this They Highlight the Themes for this

ReadingReading