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Many today are angry at our justice system, and many of them have good cause to be angry!
But, some are too angry! Their anger will hurt you! They are out of control! They teach falsehoods! They’re that angry! That’s how you know them. They are not your friend! Their “legal theories” fail. They are blinded by rage. Believe them at your peril. Angry people can rarely be trusted, and that is never more true than when they try to get you to join them in their angry legal theories that run contrary to the rules that control our courts. #1 For example, a nice fellow called me the other day and ended up screaming at me because I refused to go along with his idea that our birth certificates are some kind of “contract”. In the first place, the most fundamental truth about contracts is that no “contract” can bind a party who doesn’t understand the agreement. Even if we were able to understand the alleged binding nature of our birth certificate at the moment of our birth, we didn’t sign the thing! Some doctor did, probably. We cannot be bound by a contract we don’t understand, and certainly not one we didn’t enter into. Yet, this nice man screamed at me for refusing to help him storm the hated walls of justice for him and take up his cause to fight the dragons! #2 Another strange legal myth that’s come around in the last few months is that one can “copyright” his or her own name and thereby prevent the courts from using their name on any court papers. Duh! Anger does twist the mind in strange ways! But, to think one can prevent others from using his or her name by “copyrighting” the name is utter nonsense. I want you to win. You cannot win relying on nonsense! #3 A few are absolutely convinced that our courts are “sitting in admiralty” and therefore cannot rule in common law or statute. But, the fact is that pretty much any court can rule in admiralty cases, if the issue before them is one that involves navigation or the rights of seagoing workers or dockside stevedores. Contract disputes, negligence cases, foreclosure, and other matters are absolutely notadmiralty cases, and the courts that hear such cases are not “sitting in admiralty” … no matter whether there’s a yellow fringe on the flag in the corner or not. #4 More than a few seem to have made a “religion” out of believing such things. Many claim to be “patriots”, yet do all they can to evade the Rule of Law and refuse to do much of anything toward learning the principles of due process so many gave their lives to protect in past and present wars! This group of people get together to talk about how horrible things are but spend very little effort learning how to make things better by learning the rules! I know people are hurting. I’ve been helping thousands upon thousands of good people get justice in the courts since 1997 when I first put Jurisdictionary on the internet. It wasn’t much back then, but I’ve been doing all I can to make it better each year and will do the best I can to continue in the months and years to come. But! If you choose to believe the lies, God help you! Lies are what we’re fighting to overcome. Overcoming lies is what the rules are all about! Please don’t get me wrong. I want to help those who are angry, as well as those who are being destroyed by crooked bankers, corrupt judges, lying lawyers, and the hosts of darkness that never seem to give up in their quest to destroy all that’s good and wholesome in this world we live in. But! YOU … that’s right … YOU cannot afford to believe the lies if you want to get justice in our courts! Your birth certificate is not a contract. You are who you are, no matter whether your name is spelled in ALL CAPITAL LETTERS or all small letters or written out in script with a ball-point pen! And, as far as our courts go, nobody (and I do mean nobody) knows better than I do about the corruption of some judges or the stealth and trickery that lawyers use to twist the truth to their own advantage. But, being angry won’t help. The only thing that will help is learning how to use the rules that control the courts, rules that stop corruption, rules that require judges to grant justice, rules that were paid for by far too much innocent blood already. Please join Jurisdictionary in our effort to uplift the hopes and determination of the American People and even people in other nations around the world where justice is for sale to the highest bidder and good, honest people are sacrificed on the altar of money! Someone once said, “The truth will set you free!” If YOU believe that … if you really believe it … then you will join the work of Jurisdictionary to reach people who are being destroyed all too often simply because they are believing the legal mythology so rampant on the internet, in our daily emails, and even in weekend seminars a few amateurs here and there are putting on for those foolish enough to pay. There’s never been but one way to win any contest! Either you cheat … or you use the rules to your own advantage. Cheaters don’t win all that often. Food for thought? – – – – – – – – Winning is EASY once you know the rules and how to use them effectively! Help Your Friends! Don’t let anyone intimidate you into thinking lawsuits are too complicated for mere mortals to grasp or deceive you into thinking all lawyers are smarter than the rest of the human race … ’cause it ain’t so! Anyone can learn the rules required to win! Anyone! You simply need to start with a clear view of the field of play, the object of the game, and the rules that control all the players … including judges and lawyers! It IS simple … as many thousands have learned! In the 13 years since I launched Jurisdictionary I’ve found the most debilitating factor that infects good people with hopelessness is the fear that comes from lack of knowing how the game of litigation is played to win! Not knowing creates fear. Knowledge displaces fear with the confidence! Take any apparently complicated thing apart to examine its component parts and you quickly see how they all fit together. When you first begin, it seems impossible. But! If someone shows you how each separate part works with each of the other parts, even the most complicated things are suddenly easy-to-understand. The mystery my profession has woven disappears! Every one of you has great legal power! Sadly, many good people never discover the power that is theirs … so people who know how to use the rules of court and the law of the case take advantage of them! Jurisdictionary wants to turn the tables on crooked lawyers and biased judges and protect the “little guys and gals” that are being taken advantage of simply because no one has ever come out with a course like this. No one has ever cared enough to tell you the truth. No one has ever made it this easy-to-understand! It is easy-to-understand how to win in court once you see things the way I teach them! The full details you need to know are in my affordable step-by-step Jurisdictionary course. To learn more, go to: www.Jurisdictionary.com Click this link to watch a FREE VIDEO. ============================
My affordable 24-hour step-by-step lawsuit self-help course includes:
Still Only $249 (plus $7.50 for Priority Mail S&H) Control judges! Save legal fees! Defeat crooked lawyers! Ask anyone who has it: Jurisdictionary Works! Call Toll Free for details: 866-Law-Easy Get your competitive edge before the price increase. Force judges to enforce the rules, instead of allowing the lawyer on the other side twist the law against you! You cannot win if you don’t know how to control the judge and all the lawyers (including your own lawyer, if you can afford to pay one to go to court for you)! You’ve heard the horror stories from others. Don’t let it happen to you! Order my course now, if you don’t already have it. Know the rules and how to force everyone to obey! Know how to draft proper pleadings, how to get your own evidence in the court’s record, how to keep the other side from getting their evidence in, how to move the court to enter orders favorable to your cause, and how to use your Jurisdictionary legal know-how and case-winning strategies to control the judge and win your case! My self-help course is presented in such an easy format people tell us an 8th grader can learn it in just 24 hours! Know what you must know to win! Stop courtroom corruption! I’ll show you how in just 24-hours … step-by-step! Control judges and lawyers – or lose! My “Tips & Tactics” newsletters are only introductions to the complete course you need to win. If you don’t already have my 24-hour step-by-step self-help course, go to my website and order now!
As Woody Guthrie used to sing, “This Land is our Land,” and that includes every courtroom and every courthouse from San Diego to Bangor, Maine. Why let lawyers control our lives with trickery? Why let judges destroy our lives by letting lawyers get away with their trickery? YOU CAN WIN! Forward this article to ALL YOUR FRIENDS! If you aren’t involved in a lawsuit or threatened with one today, learn what my course teaches and help others who will be destroyed by all-too-common courtroom corruption if YOU don’t help them learn what it takes to win! There are more than 150 lawsuits filed every minute in the United States – nearly 100 million each year. Try to imagine how many thousands of good, honest people will be destroyed in the next 7 days just because they have no idea how to protect themselves and have nobody they can trust (or afford) to help them win! Urge everyone to get my affordable 24-hour course! Do it for your nation … and for your children! Dr. Frederick David Graves, JD
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Archive for the ‘software’ Category
Is Legal Software Conduct? True or False?
On August 2, 2011, Federal District Judge Nanette K. Laughrey, for the Western District of Missouri, the Judge presiding over the class action case against LegalZoom for unauthorized practice of law, released an opinion denying, in part, Defendant’s Motion of Summary Judgment. The Court held that document preparation by non-lawyers, under Missouri Law, is conduct, and not entitled to First Amendment protection. ( See full opinion here ).
This is consistent with my own view, expressed in a previous post. (Is LegalZoom just a self help legal software company?).
The court’s opinion rejects the logic in an article authored by Professor Catherine J. Lanctot, titled, "Does LegalZoom Have First Amendment Rights: Some Thoughts About Freedom of Speech and the Unauthorized Practice of Law." , which doesn’t surprise me, as it is hard to characterize LegalZoom’s activities as "speech", when they have 500 employees working on customer’s documents.
One paragraph in the Court’s opinion is troubling. On Page 21, the Opinion states as follows:
"Furthermore, LegalZoom’s branching computer program is created by a LegalZoom employee using Missouri law. It is that human input that creates the legal document. A computer sitting at a desk in California cannot prepare a legal document without a human programming it to fill in the document using legal principles derived from Missouri law that are selected for the customer based on the information provided by the customer. There is little or no difference between this and a lawyer in Missouri asking a client a series of questions and then preparing a legal document based on the answers provided and applicable Missouri law. That the Missouri lawyer may also give legal advice does not undermine the analogy because legal advice and document preparation are two different ways in which a person engages in the practice of law. "
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"The Missouri Supreme Court cases which specifically address the issue of document preparation, First Escrow, Mid-America and Eisel, make it clear that this is the unauthorized practice of law. The fact that the customer communicates via computer rather than face to face or that the document prepared using a computer program rather than a pen and paper does not change the essence of the transaction."
This Opinion could be interpreted to mean that all legal software programs are a form of conduct, and not entitled to First Amendment protection. I would argue that the Court comes to this conclusion because the legal software is used in the context of a document preparation service, and is not a stand alone program. As the Court further explains that:
As in Hulse, First Escrow, Mid-America, and Eisel, LegalZoom’s customers are rendered passive bystanders after providing the information necessary to complete the form. Yet LegalZoom charges a fee for its legal document preparation service. …..The customer merely provides information and "Legal takes over."
The facts of this case make a difference, I would argue, in understanding the scope of the Court’s Opinion.
If we define a legal software program as a "product", where there is no service element and no conduct whatever, then it is hard for me to believe that the Court intended to ban legal software programs from distribution directly to consumers, whether on-line or off-line.
If that was the Court’s intent, then companies like Nolo and Intuit, would have to pull their products off the shelves of Barnes & Noble and Staples and Amazon, programs like LawHelp Interactive, supported by the US Legal Services Corporation, would have to be terminated, and the many web sites that offer interactive forms, without any service component would have to be abandoned. Courts that are experimenting with distributing interactive forms from their web sites, would have to consider whether this activity is the "unauthorized practice of law", a strange result.
Law Schools like Chicago-Kent Law School that are experimenting with new legal software interfaces that connect citizens directly with legal help through software, might reconsider their efforts.
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The only way that such legal software could be used, would be by attorneys in the context of delivering of legal service through their law firms. I think this would be an unfortunate result.
Other possible negative consequences of such an interpretation would be:
- The legal profession would be further attacked for attempts to restrict commerce and maintain higher legal pricing by the consuming public causing further damage to the profession’s already declining reputation;
- Pro se litigants would not have access to tools that enable them to represent themselves, further restricting access to the legal system;
It would be helpful, if the Missouri District Court clarified its language on page 21 of the Court Order to distinguish between fact situations where interactive legal software is used as part of a document preparation service business and situations where the programs are distributed as stand alone programs — products– like a book or other publication. What do you think?
Is LegalZoom Just a Self-Help Legal Software Company?
In a Fortune Magazine blog post by Roger Parloff just last week, entitled Can Software Practice Law?, writing about the class action suit against LegalZoom in Missouri for violating Missouri’s UPL statute, Parloff argues that LegalZoom is no more than a self-help legal software company, and therefore entitled to the same protections as a self-help legal software publisher. The question of whether legal software constitutes the practice of law is a controversial one. When the Texas Bar won a suit against Nolo Press on the grounds that its WillMaker program constituted the practice of law, the Texas Legislature amended the UPL statute and further defined the practice of law as follows:
Texas Code, 81.101 (c) the "practice of law" does not include the design, creation, publication, distribution, display, or sale, including publication, distribution, display, or sale by means of an Internet Web site, of written materials, books, forms, computer software, or similar products if the products clearly and conspicuously state that the products are not a substitute for the advice of an attorney. This subsection does not authorize the use of the products or similar media in violation of Chapter 83 and does not affect the applicability or enforceability of that chapter.
No other state has passed such an exemption, but there is a well-established line of cases that supports the position that the publication of information about the law, as well as self-help legal books, divorce forms with instructions, and do-it-yourself kits is not the practice of law and protected by the First Amendment of the U.S. Constitution and may be protected by state constitutions as well. See, e.g., New York County Lawyers’ Ass’n v. Dacey, 21 N.Y.2d 694, 234 N.E.2d 459 (N.Y. 1967), aff’ing on grounds in dissenting opinion, 283 N.Y.S.2d 984 (N.Y. App. 1967); Oregon State Bar v. Gilchrist, 538 P.2d 913 (Or. 1975); State Bar of Michigan v. Cramer, 249 N.W.2d 1 (Mich. 1976); The Florida Bar v. Brumbaugh, 355 So.2d 1186 (Fla. 1978); People v. Landlords Professional Services, 215 Cal. App.3d 1599, 264 Cal. Rptr. 548 (Cal. 1989).
LegalZoom takes the position that it is no more than a self-help legal publisher and seeks to fall within this classification, as Roger Parloff argues in his blog post. This is also the position that Legal Zoom takes on its Web site and in its answer to the Missouri Complaint:
From the LegalZoom Web site:
"Is LegalZoom engaged in the practice of law?"
"No. LegalZoom is the latest and natural evolution of the centuries-old legal self-help industry."
"No jurisdiction prohibits the sale of software that generates a legal document based on a customer’s unique input. LegalZoom has never been prohibited from operating in any state."
"Should consumers be concerned about LegalZoom losing this case?"
"No. If LegalZoom is found to be engaged in the unauthorized practice of law in Missouri, then every guide and legal formbook in libraries and bookstores in the state would also be engaging in the unauthorized practice of law. These days, nearly all such books are packaged with computer software that works in a similar manner to LegalZoom. Just like with a Nolo Press® book or a preprinted form, LegalZoom customers have the ability to review and consider their legal form before committing to their purchase."
It is not possible to know how LegalZoom’s document technology actually works without further evidence. However, one can state with certainty that it doesn’t work like a true Web-enabled document automation technology which generates a document instantly from data entered into an on-line questionnaire that is presented through the Web browser.
Vendors of true Web-enabled document automation solutions, such as HotDocs, Exari, DealBuilder, WhichDraft and Rapidocs (our company) have document automation technologies that generate a document instantly after the user clicks on the submit button. Because LegalZoom’s technology seems to require a separate step that is executed off-line, it does not in my opinion, fit into the category of a Web-enabled document automation technology. [ For a more extensive discussion of Web-Enabled Document Automation as a Disruptive Technology, click here to download our white paper on the subject. ]
Instead, in the LegalZoom business model, as described by LegalZoom, a data file is created, reviewed by a legal technician, and then imported into their – document assembly application utilizing some form of import mechanism. It is not clear whether the document is fully-assembled until this second step takes place, and it’s a distinction that makes a difference.
If LegalZoom were just a legal software company, it is hard to understand why it needs over 400 employees to provide services to its customers, other than the fact that these employees are conducting professional reviews and providing real service support. For these services, LegalZoom receives a substantially higher price than if they were just selling a self-help legal form. See for example on the LegalZoom Web site, the 30-point review of wills conducted by LegalZoom’s "professional legal document assistants."
These more labor intensive, personal services makes LegalZoom a "service business" and not just a "legal software publisher" entitled to the First Amendment protections that are afforded to publishers.
Andrea Riccio, a Canadian lawyer who has commented about this subject, responds to some of the arguments that LegalZoom makes in its defense:
LegalZoom’s argument: "Typically, there is no interaction between the customer and the person reviewing the file."
Riccio’s response:
“The mere fact that the employee is granted access to the customer’s response is an interaction between the employee and customer.”
LegalZoom’s argument: "If there is an inconsistency, it is NOT corrected by the employee – instead, it is brought to the attention of the customer."
Riccio’s response:
“Whether it is the customer or the LegalZooM employee that physically changes the document is irrelevant. What is important is that it is the LegalZoom employee that has identified the inconsistency. That, in my opinion, goes beyond "self-help" and is an act of legal draftsmanship.”
LegalZoom’s argument: "no employee revises or corrects any portion of the customer’s self-created document."
Riccio’s response:
“Identifying inconsistencies or errors in another person’s document is in my opinion an act of revision and correction. Who physically makes the changes is irrelevant.”
It is for these reasons that LegalZoom was required to be licensed under California law as a registered and bonded legal document assistant (see footer LegalZoom Web site).
What is a Legal Document Assistant?
A "Legal Document Assistant", as defined by the California Business & Professions Code (Section 6400 (c)) is:
"Any person who is otherwise not exempted and who provides, or assists in providing, or offers to provide, or offers to assist in providing, for compensation, any self-help service to a member of the public who is representing himself or herself in a legal matter, or who holds himself or herself out as someone who offers that service or has that authority, or a corporation, partnership, association, or other entity that employs or contracts with any person who is not otherwise exempted who, as part of his or her responsibilities, provides, or assists in providing, or offers to provide, or offers to assist in providing, for compensation, any self-help service to a member of the public who is representing himself or herself in a legal matter or holds himself or herself out as someone who offers that service or has that authority."
This California statutory scheme is based on the idea that a non-lawyer can perform clerical support functions without violating the unauthorized practice of law statute in California. Only a few states have carved out this exception by statute (e.g., California, Florida, Arizona). Missouri is not one of them.
Could LegalZoom operate in California, where it is headquartered, without being registered with the state as a Legal Document Assistant? I think not.
This is the category that LegalZoom fits into, not “self-help” software.
Otherwise, I suppose Nolo, a California-based self-help legal software publisher, and other California-based legal software publishers that sell directly to the public, would have to be licensed in California as Legal Document Assistants!!! (See generally – http://en.wikipedia.org/wiki/Legal_document_assistant, for a more extensive discussion of what a Legal Document Assistant is, and is not.)
Just to be clear, I am personally in favor of both self-help legal software and paralegal-assisted document preparation services as a way of providing access to the legal system, and personally think there should be more choices for consumers. But my personal opinions are not the issue. The issue is:
“What does the law in the different states now require, and what can we do to change it if we don’t like it?”
It is becoming clear that LegalZoom’s defense strategy in the Missouri case is to associate itself with “self-help software”. I am sure that its well-financed publicity machine is already approaching bloggers and the business press to write stories about whether “legal software” should be prohibited or regulated, when the real issue is whether and under what conditions a legal document preparation service should be regulated, or immune from regulation.
Definitions of what is “legal self-help software”, and what is not, are critical for carving out safe harbors for innovation, particularly as legal software applications that are distributed over the Internet have potential for great impact and for providing access to the legal system for those who cannot afford full service legal representation.
For example, LawHelpInteractive, a non-profit pro bono support organization, with grants from the US Legal Service Corporation, has assisted in the creation of true Web-based document assembly Web sites in many states that provides free legal forms directly to consumers that can be assembled directly on-line.
LawHelpInteractive has generated thousands of legal forms during the past few years that are instantly available and free to consumers throughout the United States. No one is arguing that these Web sites constitute the practice of law.
Because of the wider reach of the Internet, Web-enabled legal software applications are actually more of a threat to the legal profession, than desktop software, and the opportunity for over-regulation remains ever present. I would regret the day that courts prohibit the sale of self-help legal software because it is the unauthorized practice of law.
However, stronger arguments can be made for protecting from regulation the distribution of legal software applications, than there are for exempting from regulation a "service business", so I maintain that confusing one category with another is dangerous and takes us down a slippery slope.
Whether or not LegalZoom provides a valuable service; whether or not consumers have been harmed by LegalZoom; and whether or not the company provides some form of legal advice are questions of fact for the Missouri jury, and beyond the scope of this post.
The question for the U.S. District Court in Missouri is whether, as a matter of Missouri law, LegalZoom’s document preparation service business constitutes the practice of law in Missouri, under the terms of the Missouri UPL statute.
I think it does. What do you think?
LegalZoom is Considering an IPO
Apparently LegalZoom is in the early stages of planning an IPO, (going public), according to an unnamed source at VentureBeat. Employing more that 500 employees, and having raised over $45 million in venture capital over the last few years, LegalZoom is clearly the leading non-lawyer legal document preparation web site. This is a good example of a disruptive innovation in the delivery of legal solutions by a non-lawyer provider that continues to eat away at the market share of solo practitioners and small law firms.
Focusing on a market that is not served well by the legal profession, in the same way that Southwest Airlines first targeted people who traveled by bus, rather than by air because air travel was too expensive, LegalZoom is will undoubtedly figure out a way to move up the value chain, capturing even more complex business from law firms, without actually giving legal advice.
In the United States, because the definition of what constitutes the "unauthorized practice of law" is so vague. (perhaps unconstitutionally vague), it would seem that even though LegalZoom does not actually provide legal advice, it would be prohibited from assembling legal documents, even when the document assembly is purely software-driven.
The reality is that bar associations have a tough case to make against a non-lawyer provider when no actual legal advice is given. UPL statutes haven’t been truly tested on the issue of whether a non-lawyer can assemble legal documents without actually giving legal advice. In Florida, when the issue came up, there was a compromise between the bar and non-lawyer providers and non-lawyers can help a consumer complete court forms as long as no legal advice is provided. It gets murky when you move beyond courts forms, to more complex transactional documents such as a will, a living trust, or a marital separation agreement, even if the user is making the selection through a software driven questionnaire. Some UPL advocates, have argued that the selection of alternative clauses is still UPL, because a person had to "program" the clauses. There is some precedent for this position, but the State of Texas on the other hand, specifically excludes software driven document assembly from the "unauthorized practice of law., provided there there are disclaimers which state "clearly and conspicuously that the products are not the substitute for the advice of an attorney."
I think the risk portion of the prospectus will make for fascinating reading, particularly since in many states UPL is a felony. I can just visualize this language: "Investors should be aware that the company may be violating unauthorized practice of law statutes in many states, and as a result, if convicted, one or more executive officers may be required to serve time in the pokey."
In the interest of full disclosure, Epoq US, of which I am President, and which is the parent company of DirectLaw, also provides legal document preparation services over the web directly to consumers through a network of legal web sites So perhaps I should be worried as well.
Venture Capital Flowing Into Legal Enterprises: Total Attorneys Receives Infusion of Capital
Private capital is beginning to flow into companies that are operating at the intersection of the delivery of legal services and the Internet.
Total Attorneys, a Chicago-based company, just announced that they received a multimillion dollar investment from BIA Digital Partners, a Virginia-based venture capital firm. Total Attorneys is most known for the marketing services that it provides to law firms and the recent ethical controversy in some states surrounding the use of pay-per-click advertising on behalf of law firms. (Apparently this controversy has been resolved in favor of Total Attorneys in every state where it was considered by bar ethics committees.)
The company plans to extend its technology assisted services to law firms by expanding its virtual law firm Software as a Service offerings (SaaS). Total Attorneys mission is to become a leading provider of elawyering Services to solos and small law firms by providing a comprehensive suite of outsourced technology services, from marketing to web-based practice management tools to a robust client portal.
The company licenses virtual law office technology to solos and small law firms as a subscription service, that now consists primarily of a robust suite of "back-office" practice management tools. The pan is to expand the service into a more comprehensive "front-office" client portal, providing a total solution to solos and small law firms.
This expansion would entitle the company to claim that it is a leading provider in the eLawyering space and it would compete more directly with our own DirectLaw virtual law firm platform service and other web-based companies moving in the same direction. [ See: Legal Vendors Cloud Computing Association ] .
The concept of "technology-assisted service" is an interesting category for the legal industry for it describes a form of outsourcing which combines both a digitally-based service combined with human service. Thus Total Attorneys also provides "virtual receptionist services", and at one point virtual support services to bankruptcy law firms. One management solution for solos and small law firms it to out source to independent specialized companies functions which can be done more effectively and at less cost than the law firm can do itself using internal resources.
It is good to see competition heating up in the eLawyering space, which has been moribund for a long period of time. The eLawyering Task Force of the Law Practice Management Section of the ABA was created in 2000, more than a decade ago. For many years there was not much to report in terms of the innovative delivery of on-line legal services by law firms. The last 2 years has witnessed an explosion in elawyering industry developments as lawyers adapt to change — caused by a severe recession, widespread unemployment of recent law school graduates, and the challenges created by consumers who are seeking lower-cost and "good enough" alternatives to lawyers, [such as LegalZoom.]
Competition among a variety of vendors provides choices to law firms. Competition focuses attention on the fact that delivering legal applications as a SaaS is emerging as a new paradigm for enabling solos and small law firms to access complex Internet technologies at a fraction of the capital cost of developing these applications internally. Private capital moving into the legal industry will create more choices for law firms, and as a consequence more choices for consumers.
Creative legal outsourcing will enable solos and small law firms to become more productive and survive in an increasingly competitive environment.
