©2001 A. Paul Mahaffy. All rights reserved.

Introduction

Despite the many predictions for phenomenal growth in online commerce, just as many excuses have been given for why online commerce is being held back. Fears of consumer privacy being invaded and credit card numbers stolen, and difficulties in filling orders and handling returns and complaints may be the most widely publicized. But concerns over whether online contracts are just as enforceable as paper contracts continue to deter many businesses from engaging in true e-commerce.

Whether the clicking of "I agree" is a valid acceptance of an online offer, whether the parties to an online contract are actually who they purport to be, and whether their online communications have actually been sent by them and arrive unaltered, are often difficult issues to resolve.

Many issues which arise in connection with paper contracts delivered in person are just more difficult to resolve in the context of electronic contracts transmitted over the Internet. Determining if a prospective buyer or seller is of the age of majority, has the mental capacity to contract, or is willingly entering into the contract, is obviously more difficult when communications take place online rather than face-to-face. The same difficulty can exist when attempting to determine whether an online party has the actual authority to contractually bind his firm or corporation.

While some of these issues will continue to be more difficult to resolve in the online context, others are now unaffected by any offline/online distinction. Recent case law and legislation have taken away some of the differences between offline and online contracts. Even prior to the passage of enabling legislation, appropriately worded website terms of use and electronic trading agreements have helped to remove some of the disadvantages of contracting online.

This paper will attempt to review some of these contract issues where the offline/online distinction is disappearing, if it hasn't disappeared already. The issues to be reviewed will generally apply to all contracts which are negotiated, confirmed or entered into online, whether they apply to business-to-business transactions such as share purchases, financings, supply agreements or joint ventures, or business-to-consumer transactions for the purchase of books, music and software, or the subscription for access to databases and encyclopedias. While such issues apply in the context of private networks which may have been originally established for inter-corporate electronic data interchange, this paper will focus on contracts formed over the Internet.

Contract formation

Online offer

The legal requirements for a binding online contract aren't any different from the requirements for other contracts. There must at least be communication of an offer and an acceptance, along with valuable consideration and enough certainty of the essential terms to indicate a meeting of minds. Offers may be communicated online by being placed on a website, posted to an electronic bulletin board, conveyed through a chat group, or simply sent by e-mail.

While websites usually serve as online advertisements and invitations, not all communicate offers capable of acceptance. Yet many do. And just as any party making an offer has the right to determine to whom the offer is to be directed and how the offer is to be accepted, a website may circumscribe the class of persons entitled to accept the offer. This is particularly necessary in the case of those online businesses, such as stock brokers and insurers, which are highly regulated and licensed to carry on their business only in certain jurisdictions or only with certain types of customers.

Online acceptance

Acceptance of an online offer may generally be communicated in the same way as the offer. For example, an e-mailed offer can be accepted by return e-mail. For website-based purchase contracts, a buyer is often requested to scroll through the terms of the seller's offer and accept by clicking on a particular button or link, or entering a specific word or symbol. The terms of these "click-wrap" contracts ordinarily aren't capable of being amended by the buyer and therefore, unlike paper contracts, don't allow for a counter-offer instead of an acceptance to be made.

Usually the buyer just clicks on an "I Agree" button on the website. But there has been some doubt if mere clicking is the same as legally accepting. Since legal acceptance of an offer can be evidenced not only in writing or orally, but also by conduct, it has been argued that clicking can be sufficient conduct to evidence acceptance. However, the seller has to make a reasonable attempt to bring the terms of the offer to the attention of the buyer, and the buyer has to have a reasonable opportunity to read them in order to be bound by them.

Mail box rule

When the means for giving offers and acceptances involve a time delay, such as the use of postal services in the offline world, offers capable of being accepted by mail are deemed accepted from the moment an acceptance is deposited in the mail box regardless of how long, if ever, the acceptance takes to be delivered to the offeror. Should an offeror wish to revoke the offer before actually receiving the acceptance, he will be too late to do so in the event that the acceptance has already been mailed, even though he hasn't yet received it. However, this mail box rule doesn't apply where there is no such time delay, as is the case for offers given over the telephone or in person.

It is not entirely clear whether this mail box rule applies to online communications, given that they are not always instantaneous. All too often e-mail messages can be delayed for hours. For offers which are communicated by or through a website, the terms of use of the website often prescribe when and how a contract is entered into, including the deeming of acceptance only when received by the offeror, in an effort to avoid the application of the mail box rule.

Rudder v. Microsoft Corp.

Some of the doubt surrounding "clicked" acceptances has been removed with the recent Ontario case of Rudder v. Microsoft Corp. [1999] O.J. No. 3778 (S.C.J.) which held that two law school graduates who clicked on the "I Agree" button appearing after the terms of an online Microsoft Network membership agreement were bound by them. In holding that the online agreement "must be afforded the sanctity that must be given to any agreement in writing", Mr. Justice Winkler enforced the agreement's choice of Washington state as the applicable forum for dealing with any disputes arising from it, and declined to allow the plaintiff's class action against Microsoft based upon a breach of the agreement to proceed in Ontario. Before this decision, practitioners questioning the enforceability of click-wrap contracts relied upon by analogy, with some caution, certain American cases such as ProCD, Inc. v. Zeidenberg, 86 F.3d 1447 (7^th Cir. 1996) which held that a shrink-wrap license agreement, enclosed in a software package not requiring any signature, is enforceable in appropriate circumstances.

The plaintiffs in Rudder had argued that they hadn't read the agreement's choice of forum clause, it being buried in the "fine print" of the agreement which was not adequately brought to their attention. In rejecting their claim, Justice Winkler found that the Microsoft sign-up procedure presented prospective members with the terms of the agreement twice, and required them to signify their acceptance both times. He held there were "... no physical differences which make a particular term of the agreement more difficult to read than any other term", and that while admittedly "the entire agreement cannot be displayed at once on the computer screen, ... this is not materially different from a multi-page written document which requires a party to turn the pages". To give effect to the plaintiffs' claims, he reasoned, "... would lead to chaos in the marketplace, render ineffectual electronic commerce and undermine the integrity of any agreement entered into through this medium".

Formal requirements

Although contracts generally don't have to be in writing or be signed by the parties to them in order to be legally enforceable, some do in order to meet statutory requirements. As for most other contracts, it is certainly preferable that they be in writing and signed, not only for evidentiary purposes but also for authentication of the parties and the terms and to reduce the risk of possible repudiation. But given that global commerce tends to discourage the costs and delays associated with traditional face-to-face meetings of all the contracting parties together at the same time to sign, or to each attend before notaries to sign, alternative ways to contract "in writing" are constantly being sought.

However, writing requirements are still imposed on certain contracts by a number of statutes and regulations. For example, contracts dealing with the sale of land or containing a guarantee should be in writing pursuant to section 4 of the Ontario Statute of Frauds. "Executory" contracts for the sale of goods or services where the purchase price exceeds $50 and which are to be delivered or performed after the contract is entered into must be in writing pursuant to section 19 of the Ontario Consumer Protection Act. Contracts providing for the assignment of copyright must be in writing pursuant to subsection 13 (4) of the federal Copyright Act.

The "in writing" requirements of the Ontario Consumer Protection Act represent somewhat of a deterrent to business-to-consumer e-commerce. It can be argued that most consumer online transactions are essentially executory contracts and are technically in violation of the formal "in writing" and signature requirements of that Act, or at least as the term "writing" is defined in the Ontario Interpretation Act. It can also be argued that a computer print-out of an online contract is inadequate to satisfy the requirement to provide the consumer with an original duplicate copy of an executory contract pursuant to subsection 19 (2) of the Ontario Consumer Protection Act. For those online contracts which fit within the meanings of direct sales contracts and credit contracts under that Act, there is also the requirement under it to provide the consumer with appropriate notification of various rescission rights, cost of borrowing, and other mandatory disclosure items, again all "in writing".

Identity of the parties

Even if clicking "I Agree" can amount to acceptance of an online offer and give rise to a valid contract between the parties, there can still be concern over the identity of the parties and whether they are indeed who they purport to be.

While verifying the identity and good standing of a party in an offline transaction is important, it can certainly be a challenge in an online transaction. Most parties are identified to each other by their respective e-mail or website address, and not by a street address or physical location. Although an online "WHOIS" inquiry of a domain name owner can be easily performed, a post office box may be all that is revealed as the owner's address.

Although a party may have a real address, he can still use a fake identity to carry out his online contracting. Having him enter his name in a particular box or click on a button may be sufficient to show he intended to "sign" an online contract, but such a practice isn't very reliable if he's a bit of a rogue. Ordinarily confidential passwords, personal identification numbers and access codes are assigned to parties who intend to engage in repeat online business and want to ensure that a signature rightfully belongs to a particular contracting party. But for complete strangers with only an isolated transaction in mind, these forms of protection aren't very practical.

Integrity and confidentiality of the communication

Unlike most offline contracts, online contracts can't be read by human beings, at least not without the aid of a computer. And while parties to offline contracts are often able to analyze their contracts for tampering, parties to online contracts may not have the same confidence that the electronic files being exchanged between them, or retrieved later on, haven't been tampered with.

Therefore, in addition to ascertaining the actual identity of a party sending an online communication, the receiving party generally wants to know whether the communication has been tampered with during transmission, whether the communication received can be denied as having been sent by the sender, and whether the communication, once filed or stored, can be retrieved later on in an unaltered form. In other words, he wants "authentication" not only of the sender but also of the message in order to protect against the message being repudiated later on.

And both parties generally want their online communications with each other to be kept confidential, unavailable to others to see and use.

Electronic trading agreements

Dealing with these issues over the need for agreements to be in writing, the identity of the contracting parties, and the integrity and confidentiality of contractual communications has often called for a more traditional, offline solution. Before commencing online commercial relations, some contracting parties have resorted to paper-based master electronic trading agreements. These agreements can be traced back nearly 20 years when electronic data interchange or EDI was being introduced by large corporations to reduce the human labour component in order entry systems. Corporations with stable trading partner relationships would sign traditional paper agreements governing the exchange of electronic communications between them. However, problems arose when such parties were not involved in long term trading partner relationships, since the cost of negotiating, drafting and signing such traditional agreements was often prohibitive. Such agreements are still not very practical for those parties who prefer to meet and deal with each other strictly online, especially for an isolated transaction.

However, many parties having, or intending to have, an ongoing online contractual relationship today put in place offline master electronic supply or trading agreements to cover a series of future individual online transactions. In the absence of clear statutory and case law authority making online contracts just as enforceable as offline contracts, these electronic trading agreements usually deem electronic communications between the parties to constitute signed, written communications so long as certain criteria are met and so long as the communications can be stored in a form which allows for a paper copy to be produced later on. Purchase orders containing the basic terms of individual purchase contracts can then be entered into directly online. The American Bar Association has a Model Electronic Data Interchange Trading Partner Agreement, which can be found at http://www.abanet.org/buslaw/catalogue/5070258.html.

Escrow services

While offline electronic trading agreements may provide the parties sufficient comfort to subsequently deal online with each other in the absence of enabling legislation, such agreements aren't particularly suitable for the small business or consumer markets when the expected number of online transactions or monetary amounts involved are relatively low.

However, another practical but only partial solution to addressing some of the concerns parties have about the identity of each other and the possible failure to receive goods and services bought through online contracts has been provided by various escrow services. For a fee, an escrow holder acts as an intermediary between an online buyer and seller. Money is placed in an escrow account until the buyer approves payment to the seller, normally when the goods are finally delivered or service performed.

Such services are obviously not an ideal solution, especially for those sellers who want their money immediately instead of risking that they may not receive payment if the buyer is not completely satisfied. Furthermore, whether or not payment is obtained prior to or upon the delivery of goods or services, both parties to even an isolated online transaction might still prefer to have an enforceable contract in place covering post-delivery warranties, if nothing else.

Encryption

In the absence of an offline electronic trading agreement, online contracting parties can still address some of their concerns about the identity of each other, and the integrity and confidentiality of their contractual communications, through the use of encryption technology.

Encryption generally involves the scrambling of a message in order to make its unscrambling by an unauthorized party too time consuming or difficult. A limited form of encryption security has generally been made available in electronic commerce, commonly used in electronic banking transactions to protect account information from being intercepted in transit. This limited form, based upon symmetrical encryption, uses a single secret key which is known by both parties to a message for encrypting and decrypting the message. Both parties must agree on the secret key without anyone else finding it out; if they are in separate locations, they must be confident that the courier or phone system won't disclose the key to third parties. This limited form obviously requires a certain amount of trust between the parties not to disclose the secret key to others, or not to repudiate a message by claiming it was forged by a third party.

These limitations with symmetrical encryption can be overcome through the use of asymmetrical encryption by means of public key infrastructure. Under this system, each party to an online contract has a public key which is shared with the other party (and with the online public generally) and which can be used to decrypt or encrypt messages, along with a private key which is not shared. To send a confidential message, the sender encrypts the message using the recipient's public key, and on receiving the message, the recipient uses his private key to decrypt it. In order to provide the recipient with a means to authenticate the origin of the message, the sender applies his private key to the message before sending, by what some call a "digital signature". The recipient, on receiving the message, will apply the sender's public key to authenticate the signature.

A digital signature is not a digital version of an actual signature but instead a process which transforms an electronic message in a manner that is unique to each user. A digital signature generally does not resemble an individual's signature and is ordinarily just a numeric sequence or some other means to identify the individual. However, though not commonly used, "electronic pen signatures" are available to replicate an individual's normal manual signature.

The use of the digital signature is designed to ensure (i) signer authentication (verification of the identity of the sender), (ii) non-alteration (that the document or message was not altered after it was "signed"), and (iii) non-repudiation (that the signer has indicated the intention to be legally bound by the terms in the document, like traditional written signatures).

However, there is the possibility that an imposter could secretly substitute his own public key for the public key of another while having the same private key. To guard against this, certain institutions can be selected as "certification authorities" to certify that a named user actually owns a public key or confirm that a public key is no longer valid because its paired private key has been compromised.

Whether or not parties consider adopting some form of public key cryptography when entering into online contracts, they are still well advised to use other techniques to confirm the identities of the other parties with whom they are dealing. Confidential passwords, personal identification numbers or access codes may still be assigned to individual users, and certain personal identification queries asked of message senders.

Recent legislative changes

While online contracting parties may derive certain comfort through the combined use of public key encryption, certificates and digital signatures, recently enacted legislation not only reinforces what encryption has attempted to do in ensuring the enforceability of online contracts, but also ensures the compliance with the "in writing" and "signed" requirements imposed by other legislation such as the Ontario Statue of Frauds and the Consumer Protection Act. In the absence of this new legislation, these requirements restrict transactions to paper and deter the transmission of contractual documents electronically.

This new legislation provides a way to adapt existing statutes and regulations so that they are compatible with an electronic environment and ensures that there is an electronic alternative to transmitting information. It allows electronic documents to be used as evidence in court proceedings, facilitates electronic data interchange, and generally attempts to boost trust in the electronic commerce system. Described below, the Ontario Electronic Commerce Act, 2000 is based upon the Uniform Electronic Commerce Act, and the recent amendments to the Ontario and Canada Evidence Acts are based upon the Uniform Electronic Evidence Act. Both of these uniform acts were initially adopted and promoted by the Uniform Law Conference of Canada.

Electronic Commerce Act, 2000

Dealing mainly with online contracts, the Electronic Commerce Act, 2000 S.O. 2000, c. 17 (formerly Bill 88) addresses issues such as the formation and enforceability of online contracts, the use of electronic agents in the contracting process, and when and where an online contract is deemed to be sent and received. It's founded on the notion of electronic and paper equivalence and attempts to ensure that online contracts won't be unenforceable just because they are in electronic form.

It doesn't, however, guarantee that an online contract will always be enforceable, since there are still lots of reasons for a contract in whatever form to be unenforceable. And it doesn't require the use of any particular technology, or require a person to use or accept electronic communications without his consent. However, section 3 of the Act provides that his consent may be inferred from his conduct, which may well be interpreted to mean not only his previous online conduct such as placing an order through a website, but other indicia such as his e-mail address appearing on his business card.

Other sections of the Act deserve special mention. If a document is legally required to be in writing, section 5 states that its electronic equivalent will be acceptable if it can be accessed for use at a later time. If a document is legally required to be provided to someone in writing, section 6 states that the intended recipient must be able to access as well as retain it. Where there is a legal requirement that an original document be produced, section 8 states that an electronic document will be acceptable if there exists reliable assurance that information contained in the electronic document has remained complete and unaltered from the time it was first created in its final form, apart from any changes that arise in the normal course of communication, storage and display.

If the person providing the document inhibits its storage or printing, or if the document isn't actually provided but is just passively available for review, perhaps by merely putting it on a website, sections 9 and 10 provide that such a document is not effectively provided for the purposes of the Act. In other words, the intended recipient must be able to control what becomes of the document.

If a document is legally required to be signed, section 11 states that an electronic signature may be used, although Regulations may be passed to determine the reliability of such a signature or set other applicable rules. An electronic signature is defined in the Act as electronic information that a person creates or adopts in order to sign a document. This information must be in, attached to, or associated with the document.

If a document is legally required to be retained, section 12 provides that an original electronic document must be retained in the same format in which it was created, sent or received, or in a format that accurately represents the original information, and that the information must be accessible for later use by the relevant parties. If the electronic document was transmitted, information identifying its origin, destination, and the time and date of its transmission must also be retained.

Section 19 of the Act specifically recognizes online acceptance of an offer by clicking or touching on an icon on a computer screen. Section 20 states that a valid contract can be formed even if the electronic communications are automated at either or both ends of the exchange, through what the Act calls "electronic agents". However, such a contract is nonetheless voidable pursuant to section 21 if a material error has occurred in the communications, there is no opportunity to prevent or correct the error, and the party making the error notifies the other and either returns or destroys the consideration received according to the instructions from the other.

Section 22 of the Act provides the rules for determining when and where electronic communications are sent and received, and attempts to clear up some of the confusion created by the mail box rule, discussed above. An electronic communication is deemed to be sent once it enters an information system outside the control of the sender. If the sender and recipient use the same system, it is deemed to be sent when it is capable of being retrieved by the recipient. An electronic communication is deemed to be received when it enters the recipient's previously designated information system and is capable of being retrieved, whether or not the recipient thereafter actually retrieves it. This presumably will prevent those making offers from refusing to open up valid acceptances. An electronic communication is deemed to be sent from the sender's place of business and received at the recipient's place of business.

Section 26 confirms that the purpose of the Act is to supplement but not replace existing laws affecting electronic communications, and that it is not intended to displace the legal requirements governing the method of displaying or delivering information. Furthermore, section 28 provides that Regulations may be passed to exempt certain kinds of legal requirements from the Act, and section 31 provides that certain kinds of documents, including wills, powers of attorney covering an individual's personal care and financial affairs, land transfers, negotiable instruments and other documents prescribed by Regulation, are to be exempt as well.

Amendments to the Ontario Evidence Act

By section 7 to Schedule B of the Red Tape Reduction Act, 1999, S.O. 1999, c.12, subsections 34 (3) and (4) of the Ontario Evidence Act dealing with a court's discretion to refuse to admit into evidence photographic film prints of destroyed documents were repealed, and a new section 34.1 was added. This new section addresses such matters as authentication, the presumption of integrity, industry standards with respect to the creation and storage of electronic records, and the "best evidence rule", but provides at subsection 34.1 (2) that it does not otherwise modify any common law or statutory rule relating to the admissibility of records.

Prior to the amendments, proving an electronic document to be an original under the "best evidence rule" was a challenge. The "best evidence rule" generally requires that the party attempting to introduce a document into evidence should produce the original document or the closest thing available to an original. Even though an electronic document can be saved and re-saved, changed, e-mailed or printed many times over, it can still appear to be an original and you can't tell if it has been altered by merely looking at it.

In light of the amendments, you can now look at the electronic document system, and not the document itself, to determine admissibility. Instead of questioning the integrity of the document, you question the integrity of the computer system that produced the document. Who had access to the computer system, were passwords required, and was there a system in place to log any changes made to the document, all should be asked.

Certain subsections within the new section 34.1 deserve special mention. Pursuant to subsection (5), the "best evidence rule" is satisfied on proof of the integrity of the electronic records system by or in which the electronic information was recorded or stored. Under subsection (6), an electronic record in the form of a printout that has been consistently acted on or relied upon is the record for the purpose of the "best evidence rule".

The integrity of the electronic storage system is presumed under subsection (7) upon evidence that the system was operating properly at all material times, or that the electronic record was recorded or stored by a party to the proceeding who is adverse in interest to the party seeking to introduce it, or that the electronic record was recorded or stored in the usual and ordinary course of business by a person who is not a party to the proceeding and who did not record or store it under the control of the party seeking to introduce it.

In determining whether an electronic record is admissible under any rule of law, subsection (8) provides that evidence may be presented in respect of any standard, procedure, usage or practice on how electronic records are to be recorded or stored, having regard to the type of business or endeavour that used, recorded or stored the electronic record and the nature and purpose of the electronic record.

Amendments to the Canada Evidence Act

In Part 3 of the Personal Information Protection and Electronic Documents Act S.C. 2000, c.5 (formerly Bill C-6), the Canada Evidence Act is amended to facilitate the admissibility of electronic documents, to establish evidentiary presumptions related to secure electronic signatures, and to provide for the recognition as evidence of notices, acts and other documents published electronically by the Queen's Printer. Like the above amendments to the Ontario Evidence Act, these amendments to the Canada Evidence Act provide that in order to show that an electronic document is the "best evidence" of a contract, the party trying to enforce the contract will have to prove that the system which received and stored the document functions properly and has appropriate back-up, that it stores and archives documents consistently, and that such documents are stored in hard copy as well as electronically.

Contained in new sections 31.1 to 31.8 are provisions generally comparable to those in new section 34.1 of the Ontario Evidence Act described above, although new section 31.4 of the Canada Evidence Act sets out an additional provision dealing with electronic signatures. In that new section, regulations may be made with respect to the association of secure electronic signatures with persons, and with respect to the integrity of information contained in electronic documents signed with secure electronic signatures.

Other statutory requirements

But even with the Electronic Commerce Act, 2000 and these amendments to the Canada and Ontario Evidence Acts, there will continue to be problems in enforcing online contracts which are due to other laws. Although beyond the scope of this paper, a number of other "consumer protection laws" must also be considered when determining the enforceability of any particular online contract.

A number of terms and conditions affecting contract enforceability are implied by such laws into all consumer contracts, whether online or not. Warranties as to product quality, mandatory "cooling off periods" and rights of cancellation, restrictions on disclaimer clauses, even the font size to be used, are imposed. While far from an exhaustive list of such laws, the Business Practices Act, Consumer Protection Act, Loan Brokers Act, Motor Vehicle Repair Act and Prepaid Services Act are all examples of Ontario statutes which affect contracts with consumers.

Furthermore, the laws governing specific industries and sectors affect contracting practices. Securities, insurance, real estate sales, automobile sales, residential tenancies and travel services represent just some of the regulated industries whose governing statutes have to be considered when determining the enforceabilty of online contracts involving their members.

Depending upon how many separate jurisdictions govern the parties to an online contract and the contract itself, the various terms and conditions imposed by a number of different statutes could well be inconsistent or in conflict with each other, though nonetheless applicable to the parties involved.

Recommended online contracting practices

So until all of these laws are amended and harmonized to facilitate online contracting, what can online parties do to increase the likelihood of a court finding their online contracts to be enforceable? In short, they should do everything they can to bring the terms of their online contracts to the attention of the other contracting party. They should also attempt to narrow down the number of jurisdictions which might have a rightful claim over their online contracting.

For sales contracts entered into through a website, the terms should be placed on or linked to all pages on the seller's website and not just on the order entry screen. After each online sale, the terms should be sent to the buyer by e-mail or fax with the request that the sold product or service not be used if the terms are not acceptable.

It's also wise to use a dialogue box to get the buyer to first scroll through the terms and agree to them before proceeding, and preferably again at the end before finalizing the order. In any event, the buyer should always be able to reject the terms and terminate the sale at any time while online. And any other contact with the buyer, whether through online or telephone customer support efforts, or online or written marketing materials, should be consistent with the contract terms expressed on the website.

Reducing the number of jurisdictions which may impose their own legal requirements upon a website-based contract is often attempted by reducing the potential range of eligible contracting parties. Access to the site can be restricted to the residents of certain jurisdictions by means of blocking software, and notice of such restriction can be posted on the site. The particular laws and courts intended to govern site activity can be specified in the online contract and in the terms of use to the site itself. However, reducing the number of jurisdictions and laws which may have application to a party's online activities can reduce the number of potential customers, and thereby remove one of the main advantages for doing business on the Internet in the first place.

Conclusion

Although the encryption technology and recent legislative changes discussed above won't necessarily guarantee an online contract's enforceability, they appear to have removed to a large extent the differences between contracting "on paper" and contracting online. Or at least they have helped to remove an excuse for not trying to do business online.

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