ETHICS
PRESENTED BY
WESTERN UNION IN 2008:
SEND ME THE MONEY!
Disclaimer: This case was prepared by Armand Gilinsky, Jr., Professor of Business at Sonoma State University,
from published sources, as a basis for class discussion, not to illustrate either effective or ineffective handling of an
administrative situation.
PRESENTED BY:
WESTERN UNION IN 2008: SEND ME THE MONEY!
When Jorge Ochoa, Vice President of Finance, and Raul Duany, Director of Corporate
Communications joined The Western Union Company (WU) in November 2008, both were
cautiously optimistic about the company’s future prospects in the global money transfer market.
The primary customers for global money transfers, immigrants, flowed from poorer to wealthier
countries, seeking better opportunities. When immigrants left their home countries, they often
left behind family members who depended upon them for financial support. To send money back
home, immigrants most often used money transmitters like WU.
Founded in 1851, WU had formerly enjoyed a long history as a telegraph and wire
services company, but by 2006 it had discontinued its telegraph services to focus exclusively on
money transfers. Its money transfer business had grown 13 percent during the third quarter of
2008, despite slowing growth in certain areas of the world. Declining growth in China, parts of
Europe, and the critical U.S.-Mexico corridor offset rising transaction volumes in India and the
Philippines.
On November 10, 2008, Ochoa and Duany were summoned to WU company
headquarters in Englewood, Colorado for a breakfast meeting with company President and CEO,
Christina Gold. Her new executives’ first assignment was to help develop a strategy for WU that
would mitigate any impact of further erosion of its primary money transfer business, while
remaining mindful of the need to address company’s critics regarding its commitment to social
responsibility. Before joining WU, Ochoa and Duany were well aware that government
regulators and shareholder activists were actively scrutinizing the operations and fee-charging
practices of money transfer businesses. A shareholder initiative calling on WU to become a
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PRESENTED BY:
better corporate citizen and donor was released to the press on April 25, 2008, prior to Western
Union’s annual shareholder meeting in June (see Exhibit 1 for the transcript of the shareholder
initiative). From summer 2007 to summer 2008, a consumer activist organization known as the
Transnational Institute for Grassroots Research and Action (TIGRA) coordinated boycotts
against WU in order to compel the company to decrease fees. TIGRA, based in Oakland,
California, also called upon WU and other global money transfer companies to reinvest more
into local communities, at the tune of $1 dollar per every $100 in money transfer transaction
revenues.
A STORIED PAST
Prior to the boycotts in 2007 and 2008, WU had a chequered history. Fourteen years after
its founders set out to build the first U.S. telegraph giant, WU’s shares began trading on the New
York Stock Exchange (NYSE) in 1865. In 1884, WU became one of the original 11 companies
included in the Dow Jones Industrial Average. Over the years WU was featured in a Zane Grey
novel and a movie depicting the company’s creation of an inaugural U.S. transcontinental
telecommunications link. Innovation was WU’s hallmark: it had created the universal stock
ticker, introduced the first consumer-to-consumer money transfer service, and launched the first
U.S. commercial communications satellite service. However in 1992, WU went bankrupt, as
telegraphs reached obsolescence, a victim of airmail and faxes, and the company was delisted
from the NYSE.
WU re-emerged in 1994 solely as a money transfer company. Owing to a surge in
migration, money transfers were at that time growing at 20 percent per year. In 1998, Chicago
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PRESENTED BY:
lawyer Matthew Piers represented plaintiffs in a class-actions suit against WU and rival money
transfer company MoneyGram, alleging that these firms had deceived customers with
advertisements like, “Send $300 to Mexico for $15,” when, in fact, the companies derived even
higher profits (about 80% more) from settling foreign exchange rates from money transfers into
local currencies to their advantage. The case was settled without either company admitting any
wrongdoing.
After settling its share of the lawsuit for $375 million, a portion of which included the
creation of a fund for immigrants’ organizations, WU set out to recast its image. An internal
marketing memo asserted that that WU appeared “money-oriented” and “cold,” so the goal was
modified to capture a “share of mind” and a “share of heart” in addition to a “share of wallet.” i
WU spent more than $1 billion on marketing, selectively dropped money transfer fees, donated
to immigrants’ rights groups and advocated a path to legalization for illegal immigrants. In sum,
WU sought to portray itself as the migrants’ “trusted friend.”ii Matthew Piers, the lawyer who
had brought the suit against WU later told a New York Times reporter: “Western Union has
become a company that values and protects its customers. No one was more surprised at the
change than me, as I was Western Union critic Numero Uno.”iii
First Financial Management Corporation purchased WU in 1994, and a year later the
combined entity merged with First Data Corporation in Colorado. In the ensuing ten years, WU
grew its leading share of the consumer money transfer services market from 10 to over 17
percent, with an average transaction size of $350. By then, WU far exceeded other franchise
businesses in terms of number of outlets worldwide – over 300,000 – compared with
McDonald’s at 31,000 outlets, and processed nearly five times as many transactions as its closest
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PRESENTED BY:
rival, MoneyGram. WU offered services through a network of agents in more than 200 countries
and territories, under the “Western Union” as well as its subsidiary brands, Orlandi Valuta
(acquired in 1999 and based in Los Angeles, California) and Vigo Remittance Company
(acquired in 2005 and based in Florida).
WU was again listed on the NYSE on January 26, 2006. In fiscal year 2007, WU
continued to derive the majority of its $4.9 billion revenues from fees that consumers paid when
they sent money. WU’s primary segments included consumer-to-consumer (C2C: 83 percent of
2007 revenues) and consumer-to-business (C2B: 15 percent).
Led by the same core group of executives that had managed it under First Data, in 2008
WU continued to carry $3.5 billion in residual debt on its balance sheet as a result of the spin-off
from First Data. CEO Christina Gold, who had joined WU in September 2006, after serving as
executive vice president of global development at Avon Products, was seen by many industry
observers to have been primarily responsible for WU’s makeover. In 2007, Gold reflected upon
her role to a reporter in Singapore:
I look at running a company as stewardship for a period of time…I’m not the
company — I try to keep that perspective because I think the brand stands for
Western Union [and] I’m not the brand. I’m just a representative of the company
and my organization and all of the people who work for it. As part of my stamp I
hope to develop a positioning to be really recognized as a brand that stands for
its consumers and it gives back to the community and it does things that are
meaningful and make a difference. However, when I do leave, I want to leave
behind a company that is more diverse in its revenue streams and has a human
face.iv
Jack Greenberg, former Chairman and CEO of McDonald’s and a member of First Data’s
board of directors, had also moved over in 2006 to become chairman of WU. Together, Gold and
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PRESENTED BY:
Greenberg pursued growth of the WU brand through international expansion. WU’s revenues
increased at a compound annual growth rate (CAGR) of 11.4 percent from 2004 to 2007, driven
by foreign exchange revenues that increased at a 19.7 percent CAGR, comprising 13 to 16
percent of total revenues during that period. See Exhibits 2-4 for WU’s 2005-2007 financial
statements.
CUSTOMERS AND MARKETS
According to Morningstar, about 200 million people lived outside their country of origin
in 2008.v The ongoing growth in the worldwide immigration population was concomitantly
driving growth in the money transfer business. See Exhibit 5 for data on worldwide money
transfers from 1990-2007.
Most money transmitters had relationships with networks of agents that could collect and
distribute cash across the globe — for a fee (see Exhibit 6 for estimated industry profits per
transaction). Money transfers sent by immigrants back to their home countries typically were not
discretionary, but covered the subsistence needs of their families. For instance, money transfers
sent to El Salvador equaled more than 15% of that country’s GDP, according to Morningstar.
COMPETITION
WU competed with Global Payments Inc., Euromet Worldwide, and MoneyGram
International. Exhibit 7 presents comparative financial information on these three direct
competitors. However, indirect competitors in the money transfer industry included financial
services businesses such as: credit unions, ATM operators, card associations, card-based
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PRESENTED BY:
payment providers, informal remittance systems, Web-based services, telephone payment
systems, postal organizations, retailers, check cashing services, and currency exchange
providers. Banks, mass retailers like Wal-Mart, and cell phones also emerged as alternative
channels for immigrants seeking money transfers. By the year 2013, 100 millions of cell phone
users were expected to transfer money via their mobile phones, according to Juniper Research.vi
Many of these rivals were specialists in their industries or regions. Among the factors that
gave certain rivals competitive advantages were local brand reputation, convenience, speed,
varying payments, reliability, and price points. Pricing remained competitive in the money
transfer business. Increasing price competition and regulatory burdens were driving out smaller
rivals, leading to higher market shares for the remaining industry leaders.
CORPORATE STRATEGY OR ECONOMIC JUSTICE?
As increasing numbers of money-transfer companies and banks moved into the field, WU
felt increasing pressure to lower prices and compete for customers. Some critics, like TIGRA,
advocated that WU heighten its commitment to community development.vii Others, such as
Efrain Jimenez, a community organizer in California who was spearheading a joint venture with
WU for a Mexican community development project, were not so certain: “Yes, Western Union
has a social responsibility, but they have the right as a company to make money too. They aren’t
a charity.”viii WU officials proclaimed that about $40 million in aid had been donated by the
company’s foundation to groups in 70 countries since 2000. These officials also maintained that
the company had been aggressive in its philanthropy, while acknowledging that theirs was a
corporate strategy also aimed at defending its business against the emergence of banks and other
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PRESENTED BY:
rivals in wire transfers.ix In late spring 2008, WU publicly committed $50 million in donations to
charitable organizations for the next five years.x
In July 2008, the Arizona Court of Appeals overturned a trial court’s ruling in WU’s
favor regarding the authority of the Arizona Attorney General to seize money transfers
originating in states other than Arizona and intended for payment in Mexico. WU subsequently
asked the Arizona Supreme Court to reconsider this matter. Meanwhile, Arizona’s Attorney
General did not attempt to resume the type of seizures at issue in this litigation, and WU did not
experience any immediate measurable impact to its Americas money transfer business as a result
of this decision. The legal situation in Arizona remained unresolved as of November 2008.
Future Prospects
By late autumn of 2008, several forces had converged that could severely dampen WU’s
future prospects. A weak global employment market had prompted many money transfer
customers — immigrants — to remain in their home countries. The global financial services
industry was in free-fall after the failures of Bear Stearns, Lehman Brothers, and AIG, among
other large financial services providers. Steep declines in the U.S. construction industry as well
as the ongoing immigration debate in various state legislatures and the U.S. Congress slowed
money transfer growth in the U.S.-Mexico corridor, WU’s most profitable segment.
Standard & Poor’s analysts at that time nevertheless remained bullish on WU’s
prospects, targeting compound annual revenue growth at 8 percent out to 2012.xi A reason for
analysts’ optimism was that WU had generated $800 million of free cash flow during the first
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PRESENTED BY:
nine months of 2008, that is, for the first three fiscal quarters ending September 30, 2008.
Exhibit 8 presents operating segment data for third quarter 2008 and for the first nine months of
fiscal 2008. WU repurchased 17 million shares (at a total cost of $385 million) in the second
quarter; and another 20 million shares (at a total cost of $523 million) in the third quarter of
fiscal 2008.
CEO Gold had recently stated WU’s intention to devote free cash to stock repurchases
and acquisitions of rival money transfer firms.xii Yet at the November 10, 2008 meeting with
executives Ochoa and Duany, among the competing options on the table were: development of
innovative financial services products that could be sold through the growing network of 335,000
WU agents worldwide, or perhaps even the creation of a micro-lending or small business
development grant program for customers in developing nations.
Endnotes
i
DeParle, J. (November 22, 2007). "A Western Union Empire Moves Migrant Cash Home," The New
York Times, A1.
ii
Ibid.
iii
Ibid.
iv
Choudhury, A.R. (November 24, 2007). “Christina Gold, the high-flying head of remittance firm
Western Union, has her feet firmly planted on the ground,” Business Times Singapore.
v
“Western Union,” (October 13, 2008). Morningstar Reports.
vi
Juniper Research (October 7, 2008). “100 Million Mobile Users to Make International Money Transfers
by 2013.” Wireless News.
vii
Thompson, G. (2007, May 11). “Immigrants push Western Union to Share the Wealth,” The Nation,
http://www.thenation.com/doc/2070528/thompson/print.
viii
Avila, O. and Olivo, A. (October 21, 2007). “Western Union Boycott Divides,” Chicago Tribune.
ix
Ibid.
x
See http://www.transnationalaction.org/research/index.html#more, accessed December 12, 2008.
xi
“Western Union,” ((November 8, 2008). Standard & Poor’s.
xii
See July 22, 2008 Bloomberg TV interview with CEO Christina Gold at:
http://www.clipsyndicate.com/publish/video/649933/spotlight_western_union
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PRESENTED BY:
Exhibit 1: Western Union Shareholder Resolution, 2008
The federal law known as the Community Reinvestment Act (CRA) obligates federally insured banks and
depository institutions to help meet the needs of communities in which they operate. No such law exists
for money transfer agencies like Western Union.
In March 2007, Federal Reserve Chairman Ben Bernanke stated, "the CRA reaffirmed the long-standing
principle that financial institutions must serve the convenience and needs...of the communities in which
they are chartered.”(1)
Western Union serves many of the financial needs of immigrant populations, as a bank might, with a
major presence in poor and racially diverse neighborhoods.(2)
Western Union's customers are mostly urban and poor. The typical user of its remittance services is a
low-wage immigrant worker who lives in urban America, makes $15,600 annually and sends home $293
a month, almost 30% of his or her net monthly income.(3) These remitters spend up to $300 a year on
costly transaction fees and disadvantageous exchange rates, which equals one week's salary for the
remitter or at least sixty days' salary for their kin in cities such as San Salvador, Mexico City, and
Manila.(4)
Remittances contribute about 80% to a recipient household's total income.
Almost half of Philippine households who receive remittances depend solely on this source of income.
The highest monthly allocations for expenses from remittances are for food, rent, and education.(5)
We believe onerous charges in the multi-billion dollar money transfer industry place an undue economic
burden on low-income immigrant families in the United States and in their communities of origin while
creating an increased reputational risk for our Company.
Western Union has faced numerous lawsuits based on predatory fees and unfair exchange rates. These
suits have resulted in millions of shareholder dollars being spent on settlements. These practices, along
with our Company's relatively low degree of community reinvestment, increase the risk our Company
faces in the competitive consumer market.
BE IT RESOLVED THAT: the Company develop and implement a written policy for community
reinvestment.
SUPPORTING STATEMENT: In our view, community investment goes beyond charitable donations
and corporate volunteering. We believe a policy and strategy to build social capital in communities is
essential. Such a policy is best created by engaging community organizers to identify community needs
to develop long-term programs that reflect those needs.
(1) The Community Reinvestment Act: Its Evolution and New Challenges, Federal Reserve Chairman Ben S. Bernanke, 3/30/07.
(2) Analysis of Alternative Financial Service Providers, Urban Institute, 2004.
(3) Distributing Prepaid Cards through Worker Centers: A Gateway to Asset Building for Low-Income Households, The Center
for Financial Services Innovation, October 2006.
(4) Transnational Institute for Grassroots Research and Action Research, April, 2007.
(5) Enhancing the Efficiency of Overseas Workers Remittance, Asian Development Bank, July 2004.
Source: Responsible Wealth, Boston, MA, http://www.faireconomy.org/news/western_union_shareholder_resolution_2008, accessed June 14, 2009.
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PRESENTED BY:
Exhibit 2: WESTERN UNION CO — Income Statements, 2005-2007
($ Millions except per share amounts)
Transaction Fees
Foreign Exchange Revenue
Commission & Other Revenues
Total Revenues
Cost of Services
Selling, General & Administrative Expense
Total Expenses
Operating Income
Interest Income
Interest Expense
Other Income (Expenses), net
Income before Income Taxes - Domestic
Income before Income Taxes - Foreign
Income before Taxes
Provision for Income Taxes
Net Income
12/31/05
$3,354.8
531.0
102.1
$3,987.9
2,118.9
599.8
2,718.7
1,269.2
0.0
0.0
74.9
801.9
542.2
1,344.1
416.7
$927.4
Weighted average shares outstanding-basic (millions of shares)
Weighted average shares outstanding-diluted (millions of shares)
Year end shares outstanding (millions of shares)
Earnings per share - basic
Earnings per share - diluted
Total number of employees
Number of stockholders
12/31/06
$3,696.6
653.9
119.7
$4,470.2
2,430.5
728.3
3,158.8
1,311.4
40.1
(53.4)
37.0
707.1
628.0
1,335.1
421.1
$914.0
12/31/07
$3,989.8
771.3
139.1
$4,900.2
2,808.4
769.8
3,578.2
1,322.0
79.4
(189.0)
10.0
529.3
693.1
1,222.4
365.1
$857.3
764.5
768.6
771.1
$1.20
$1.19
5,900
4,513
760.2
772.9
749.8
$1.13
$1.11
6,100
4,542
Sources: Mergent Online, accessed November 14, 2008, and company SEC filings.
Exhibit 3: WESTERN UNION CO — Balance Sheets, 2005-2007
($ Millions)
ASSETS
Cash & Cash Equivalents
Accounts Receivable
Other Current Assets
Total Current Assets
Property, Plant & Equipment, net
Goodwill and Other Intangible Assets, net
TOTAL ASSETS
12/31/05
$510.2
2,215.4
2,725.6
82.4
1,798.4
$4,606.4
LIABILITIES AND SHAREHOLDERS’ EQUITY
Accounts Payable & Accrued Liabilities
$238.6
Other Current Liabilities
5,054.8
Total Current Liabilities
5,293.4
Long Term Debt
Borrowings
Stockholders’ Equity
(687.0)
$4,606.4
TOTAL LIABILITIES AND STOCKHOLDERS’ EQUITY
Sources: Mergent Online, accessed November 14, 2008, and company SEC filings.
12/31/06
12/31/07
$1,421.7
24.3
1,763.3
3,209.3
176.1
1,935.7
$5,321.1
$1,793.1
22.5
1,794.7
3,610.3
200.3
1,973.6
$5,784.2
$554.8
2,085.2
2,640.0
2,995.9
3,323.5
(314.8)
$5,321.1
$350.1
2,883.6
3,233.7
2,499.8
3,338.0
50.7
$5,784.2
10 | P a g e
PRESENTED BY:
Exhibit 4: WESTERN UNION CO — Statements of Cash Flow, 2005-2007
($ Millions)
Net Income
Depreciation & Amortization
Other Assets, net
Other Liabilities, net
Net Cash Flows from Operating Activities
Capitalization of Contract Costs
Capitalization of Purchased & Developed Software
Capitalization of Software Development Costs
Purchases of Property & Equipment
Notes Receivable Issued to Agents
Repayments of Notes Receivable Issued to Agents
Acquisition of Businesses, Net of Cash Acquired, & Contingent
Purchase Consideration Paid
Cash Received (Paid) on Maturity of Foreign Currency Forwards
Purchase of Equity Method Investments
Net Cash Flows from Investing Activities
Net Proceeds from Commercial Paper
Net Proceeds from/(Repayments of) Net Borrowings under Credit
Facilities
Proceeds from Exercise of Options
Cash Dividends to Public Stockholders
Common Stock Repurchased
Advances From/(To) Affiliates of First Data
Capital Contributed by First Data in Connection with Acquisitions
Notes Payable Issued to First Data
Repayments of Notes Payable to First Data
Additions to Notes Receivable from First Data
Proceeds from Repayments of Notes Receivable from First Data
Dividends to First Data
Proceeds from Issuance of Debt
Principal Payments on Borrowings
Purchase of Treasury Shares
Net Cash Flows from Financing Activities
12/31/05
$927.4
79.5
42.4
(46.5)
$1,002.8
12/31/06
$914.0
103.5
(4.3)
95.7
$1,108.9
12/31/07
$857.3
123.9
85.2
37.1
$1,103.5
(22.5)
(124.1)
(80.9)
(27.7)
(7.7)
(34.8)
(8.4)
(14.4)
(63.8)
(140.0)
20.0
(83.5)
(6.1)
32.0
(349.1)
(0.5)
(5.4)
($428.4)
(66.5)
4.1
0.0
($384.7)
(35.8)
($202.0)
0.0
324.6
13.6
0.0
0.0
0.0
0.0
(153.2)
369.2
400.1
(246.5)
(504.7)
18.4
(417.2)
3.0
80.8
(7.7)
0.0
160.2
(3.0)
216.1
(30.0)
(726.8)
0.0
($533.9)
Net Change in Cash & Cash Equivalents
$40.5
Cash & Cash Equivalents at Beginning of Year
469.7
Cash & Cash Equivalents at End of Year
$510.2
Sources: Mergent Online, accessed November 14, 2008, and company SEC filings.
(154.5)
(7.5)
776.2
(2,953.9)
4,386.0
(2,400.0)
(19.9)
$187.3
0.0
($530.1)
$911.5
510.2
$1,421.7
$371.4
1,421.7
$1,793.1
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PRESENTED BY:
Exhibit 5: Global Remittances (total $ billions sent home by migrants around the world),
1990-2007
$350
$300
$300
$269
$232
$250
$200
$132
$150
$100
$ billions
$102
$67
$50
$0
1990
1995
2000
2005
2006 2007 est.
Sources: DeParle, J. (2007, November 22) "A Western Union Empire Moves Migrant Cash Home," The New York
Times,
A1;
Transnational
Institute
for
Grassroots
Research
and
Action
(TIGRA)
http://www.boycottwesternunion.net/En/about.htm; Khakimov, S. (2008, February 29), "Can One Build a House
Without A Base?" Results from The UN Forum on Remittances, http://www.scribd.com/doc/12911117/Resultsfrom-the-UN-International-Forum-on-Remittances-20071.
Exhibit 6: Estimated Industry Profit per Transaction ($), 2007
$20.00
$18.00
$16.00
$14.00
$12.00
$10.00
$8.00
$6.00
$4.00
$2.00
$0.00
$16.01
$15.71
$14.28
Average profit per transaction
Average cost per transaction
$2.94
$2.94
$2.94
Western Union
Dolex
MoneyGram
Sources: DeParle, J. (2007, November 22) "A Western Union Empire Moves Migrant Cash Home," The New York
Times,
A1;
Transnational
Institute
for
Grassroots
Research
and
Action
(TIGRA)
http://www.boycottwesternunion.net/En/about.htm.
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PRESENTED BY:
Exhibit 7: Comparative Financial Data — Payment Processing and Services (as of November 1, 2008)
52 Week
Price Range
11/1/07 – 11/1/08
Company
Western Union
Global Payments
Euronet Worldwide
MoneyGram International
Stock
Symbol
WU
EEFT
GPN
MGI
Market
Cap.
$ million
$ 11,084.0
$ 3,294.0
$ 487.0
$
81.0
TTM
Sales
$ million
$5,179.0
$1,369.0
$1,026.0
$ 470.0
TTM
Operating
Income
$ million
$1,340.0
278.0
81.0
nil
TTM
Net
Income
$ million
$ 898.0
177.0
37.0
(1,480.0)
Beta
1.00
0.74
1.59
1.94
Dividend
Yield %
0.30%
0.02%
nil
20.83%
High
$28.62
$49.87
$33.25
$19.21
Low
$12.28
$35.05
$7.79
$0.80
P/E
Ratio
(x)
10.97
16.81
16.69
NMF
TTM = Trailing Twelve Months
NMF = Not Meaningful Figure
Sources: Standard & Poor’s Stock Report: Western Union Co, November 8, 2008; Google Finance, accessed November 14, 2008.
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PRESENTED BY:
Exhibit 8: Operating Segment Data for Western Union, First Nine Months of FY 2008 v. FY 2007
Operating Segment
Consumer-to-Consumer Revenue
EMEASA (A)
APAC (B)
AMERICAS (C)
Total Consumer-to-Consumer (D)
Consumer-to-Business
Other
TOTAL
Three
Months
Ended
9/30/08
45%
33%
7%
85%
13%
2%
100%
Three
Months
Ended
9/30/07
41%
36%
7%
84%
14%
2%
100%
Three
Months
Revenue
Growth %
Three
Months
Transaction
Growth %
20%
0%
23%
27%
1%
30%
Nine
Months
Ended
9/30/08
44%
34%
7%
85%
14%
1%
100%
Nine
Months
Ended
9/30/07
40%
37%
6%
83%
15%
2%
100%
Nine
Months
Revenue
Growth %
Nine
Months
Transaction
Growth %
22%
0%
28%
26%
3%
26%
(A)
EMEASA = Europe, Middle East, Africa and South Asia.
(B)
APAC = Asia/Pacific
(C)
AMERICAS = North America, Latin America, the Caribbean, and South America.
(D)
The geographic split was determined based upon the region where the money transfer was initiated and the region where the money transfer
was paid, with each transaction and the related revenue split 50% between the two regions. For those money transfer transactions that were
initiated and paid in the same region, 100% of the revenue and transactions were attributed to that region.
Source: Western Union Form 10-Q, Quarterly Report, SEC filing November 3, 2008, 34-37.
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