Kansas: Democrats want to take stab at amending proof-of-citizenship voter registration law | Wichita Eagle

As the state Legislature prepares for a special session to rewrite an unconstitutional criminal-sentencing law, Wichita Democrats are planning to reopen the debate over a voter proof-of-citizenship law they maintain is equally unconstitutional. Secretary of State Kris Kobach, who wrote the law requiring new voters to provide citizenship documents, said he thinks it would withstand court scrutiny, unlike an Arizona law that recently was overturned by the Supreme Court. And even if it didn’t, Kansas could create two classes of voters: those who provide the proof required by state law and could vote in all elections and those who don’t and who would be limited to voting only in congressional and presidential elections, Kobach said.

New York: New York City Vows to Provide Bengali Ballots after Lawsuit Filed | India West

The New York City Board of Elections said it would translate ballots in Queens, New York, into Bengali for the Sept. 10 primary election. It is the first new language added in more than a decade, election officials said. The addition of Bengali-language ballots at 60 polling sites in Queens comes nearly two years after the federal government ordered the city to provide language assistance to South Asian minorities under a provision of the 1965 Voting Rights Act. The federal government had ordered the city’s English ballots to be translated into Spanish, and more recently Chinese, in 1993 and Korean in 2001, The New York Times reported.  The move by election officials comes after the New York-based Asian American Legal Defense and Education Fund filed a lawsuit July 2 against the board for failing to comply with the language assistance provisions of the federal Voting Rights Act.

Pennsylvania: Lawyers Spar Over Voter ID Law In Court | Associated Press

The judge in Pennsylvania’s voter-identification law trial cleared the courtroom Tuesday so lawyers could spar in private over how many voters may have been unable to obtain an acceptable photo IDs before last year’s election. Lawyers planned to make closing arguments before Commonwealth Court Judge Bernard McGinley on Wednesday, the 11th day of the trial on the constitutionality of the yet-to-be-enforced law. The closed hearing involved 144 voters who were on a Pennsylvania Department of State spreadsheet of about 600 who applied for an ID at PennDOT licensing centers but did not obtain a free, voting-only license designed by the Department of State. Those IDs, under rules streamlined in late September, are supposed to be readily available to registered voters.

Pennsylvania: Closing arguments postponed in voter ID trial | Associated Press

A judge extended the trial over Pennsylvania’s voter-identification law Wednesday into a 12th day after lawyers called a truce in a behind-the-scenes battle and the state filed a motion seeking to dismiss the lawsuit. Commonwealth Court Judge Bernard McGinley scheduled closing arguments, which lawyers on both sides had expected as early as Wednesday, for Thursday. The March 2012 law was passed by the Republican-controlled Legislature without any Democratic votes and signed by GOP Gov. Tom Corbett, but court orders have prevented it from being enforced. Democrats charged that it was a cynical attempt in a presidential election year to discourage voting by minorities, young adults and other groups that tend to vote Democratic. Republicans said it bolsters the security of Pennsylvania’s elections, though state officials have conceded that they are not aware of any cases of voter impersonation.

Pennsylvania: State ends testimony in voter ID case | Philadelphia Inquirer

The battle over Pennsylvania’s voter identification law touched on familiar themes Tuesday as the state concluded its case after almost three weeks of testimony. Witnesses for the Department of State testified for several hours detailing the extent to which they worked to make information about the law widely known – including reaching out to the elderly, veterans groups, the homeless, and immigrant communities – to ensure residents without ID would understand the steps needed to get it. Attorneys for the plaintiffs questioned the same officials about the wide range of difficulties voters encountered and the disparity in estimates on how many remain without proper ID. Closing arguments are expected Wednesday.

Washington: County dumps controversial ballot-tracker system | Journal of the San Juan Islands

The ballot bar code lawsuit, White v. Reed, is now eight years old and does not appear to be ending any time soon. The lawsuit claims that bar codes on the ballot envelope and on the ballot itself violate the Washington law that states, “No paper ballot or ballot card may be marked in any way that would permit the identification of the person who voted that ballot.” Multiple motions have been filed, briefed and argued, but the only clear result is that San Juan County is likely to save money by abandoning the Mail-in Ballot Tracking system previously used here. County Auditor Milene Henley said that after Superior Court Judge Don Eaton decided that the tracking system violated a state law that requires any voting system to obtain federal certification, she decided not to appeal that decision, but instead to abandon the MIBT system, even though Henley insists that the MIBT system did not in any way compromise ballot secrecy.

Cambodia: Prime Minister offers talks with opposition over election complaints, would support probe | The Washington Post

Cambodia’s long-serving prime minister said Wednesday that his party was willing to talk with the opposition to resolve complaints that last weekend’s general election was unfair. The gesture, from a leader not usually given to compromise, represents an acknowledgement that his opponents’ strong showing in the polls could threaten his grip on power. Prime Minister Hun Sen’s ruling party has claimed that it won 68 parliamentary seats to the opposition’s 55 in Sunday’s election according to provisional official results. However, the opposition, which increased its number of seats from 29 in the last National Assembly, could boycott the opening of parliament, leaving the lawmaking body short of a quorum and stymieing the formation of a new government.

Norway: Election campaign cranks into gear | NewsinEnglish.no

Norway’s national parliamentary election is less than six weeks away, but only now are politicians returning from their summer holidays and getting into campaign mode. Many voters seem to assume that Norway’s non-socialist parties will win this time, leading to worries that voter turnout may be low. Public opinion polls have for months showed the non-socialist (borgerlig) parties in the lead, with the Conservatives (Høyre) keen to head a coalition government that’s likely, for the first time, to include the even more conservative Progress Party (Fremskrittspartiet, Frp). A recent study by three researchers at statistics firm Norsk Regnesentral indicated there’s a 91.5 percent probability for a Høyre-Frp majority, and less than a 5 percent chance that Norway’s current left-center government coalition led by Labour will win a third term. Despite the polls and prognoses that Høyre and Frp look set to win a majority in Parliament (Storting) alone, Høyre leader Erna Solberg wants to include the much smaller Christian Democrats (Kristelig Folkeparti, KrF) and the Liberals (Venstre) in the government. That will make it tougher to agree on a common platform, but may make it easier for Solberg to temper some of Frp’s more hard-line stands on, for example, use of oil revenues and limits on immigration.

Zimbabwe: Voters’ roll ‘in shambles’, thousands fail to cast ballots | Mail & Guardian

The chaos in the voting process has strengthened allegations that Zanu-PF, with the help of the Zimbabwe Electoral Commission (ZEC), wants to steal the polls by disenfranchising people in urban areas which are perceived to be MDC strongholds. Several police officers who failed to cast their ballots during the special vote also failed to vote on Wednesday after finding their names crossed off the roll, an indication that they had voted. ZEC chairperson Justice Rita Makarau told journalists the commission did not have an idea of how to deal with the police officers who were turned away other than investigating. “We are investigating cases in which such officers didn’t vote because the register indicated they voted as their names were crossed out,” she said. Only names of those who had successfully cast their ballots were supposed to be crossed off the voters’ roll. Makarau confirmed some voters had been turned away despite producing registration slips as evidence. She said the registration slips of those who failed to vote did not indicate the wards in which they were supposed to cast their ballots.

Editorials: North Carolina: First in Voter Suppression | New York Times

Gov. Pat McCrory of North Carolina didn’t like our recent editorial that criticized the state for abandoning its traditions of racial equality, strong public schools, and economic fairness. He wrote a letter to the editor saying he was leading the state to a “powerful comeback.” That’s demonstrably untrue when it comes to the economy and the schools. But as yesterday’s events in the state capital showed, one thing is making a comeback: an old habit of suppressing the votes of minorities, young people and the poor, all in the hopes of preserving Republican power. Freed of federal election supervision by the Supreme Court, the North Carolina legislature passed a bill that combines every idea for suppressing voter turnout that Republicans have advanced in other states. Rick Hasen, an election-law expert at the University of California, Irvine, called it “the most sweeping anti-voter law in at least decades.”

Pennsylvania: Voter ID’s fate now in judge’s hands | Philadelphia Inquirer

The fate of Pennsylvania’s 16-month-old voter identification law is in the hands of a Commonwealth Court judge after closing arguments in the landmark voting-rights case Thursday. The state argued that it had done its part to ensure that all registered voters had access to mandatory ID, while petitioners countered that those efforts were not enough. Jennifer Clarke, executive director of the Public Interest Law Center of Philadelphia, said the law placed a “fundamental burden” on a right “enshrined in the Constitution.” “It is time to put an end to this and enjoin this law,” Clarke told Judge Bernard McGinley. Attorneys for the state offered no evidence of voter fraud in the commonwealth but defended the law as needed to protect the integrity of the vote. Alicia Hickok, an attorney with Drinker Biddle representing the state, said officials had done “whatever is possible, whatever is necessary, and whatever is legal” to ensure that voters know about the new law and how to go about applying for a free, voting-only card if they lack any other acceptable forms of ID.

Canada: Online voting: the ultimate hackers’ challenge | Toronto Star

“Be careful what you wish for, because you just might get it.” So goes the famous quote. Without very careful study, you might get the wish of Internet voting — and live to regret it. Your birth certificate and passport are “foundation” documents. You have to show up to get them. You have to show up to get married, and you should have to show up to cast a ballot, both “foundation” activities. Internet voting advocates assume away the large risks — and certainty of abuse — of online voting, not to mention the difficulty and expense of developing the system. There is no audit trail in an online vote. Physical ballot boxes are sealed in the presence of human witnesses. The individual ballots can be recounted to determine by sight the voter’s intention. The sheer number of human beings physically watching voters makes the integrity of the ballot box difficult to breach, though people try to cheat in every election. Online voting would be used just once every four years. There is no opportunity to properly debug the system when it goes awry on election day, or between elections, or stress-test the system to determine if it stands up to the server traffic. Enersource’s web servers went down during the July rain storm power outage in the GTA. People got their information from Facebook and Twitter. Hackers thrive in the years of dark time between scheduled elections. Proponents of online voting point to the ubiquitous use of online banking and other daily Internet transactions. The critical difference is that those other systems are used, debugged, watched and stress-tested each and every day by scores of experts who know them inside out. Gaining access to the software’s root directory enables a hacker to control the system on election day, and corrupt the outcome. By the time voters see the damage, it is too late.

National: Obama Reassures Leaders on Enforcing Voting Rights | New York Times

Days after his administration filed suit against Texas to protect minority voters, President Obama told civil rights leaders and local officials on Monday that the federal government would vigorously enforce voting rights in the country despite a Supreme Court ruling against a core section of a landmark 1965 law, several participants said after a White House meeting. “The president said that the Voting Rights Act is not dead, it’s not even critical, it’s just wounded,” said the Rev. Al Sharpton, the civil rights activist and MSNBC talk show host. “He was very reassuring,” Mr. Sharpton added. Mr. Obama met with the group for about 40 minutes, and administration officials led by the attorney general, Eric H. Holder Jr., met with the group for a bit longer. The administration was addressing what Mr. Sharpton described as the civil rights community’s “alarm” over the court’s 5-to-4 vote last month. In that case, Shelby County v. Holder, the majority struck down as outdated and unnecessary the law’s language requiring that the federal government review and clear any changes in election laws in nine states, most of them in the South.

National: Obama vows fight on voting rights | Washington Times

President Obama told a gathering of civil rights leaders at the White House on Monday that his administration is committed to restoring legal protections for minority voting, and a Florida legislator who attended the meeting said his colleagues are motivated by the knowledge that slain black Florida teen Trayvon Martin would have been eligible to vote next year. The president and Attorney General Eric H. Holder Jr. assured the group that they will work on a legislative response to the Supreme Court’s decision in June that struck down Section 4 of the Voting Rights Act, a key section that the administration said was needed to combat discrimination in targeted states and districts. That provision required states with a history of voting discrimination to submit any changes on election law to the Justice Department for approval.

National: Obama pledges to strengthen Voting Rights Act | USAToday

President Obama told civil rights leaders Monday that his administration would work to strengthen the Voting Rights Act in light of a Supreme Court decision striking down a key provision. After a White House meeting with more than a dozen attorneys, state lawmakers and civil rights activists, Obama senior adviser Valerie Jarrett tweeted that the administration wants “to ensure every eligible American has the right to vote.” The meeting came a month after the Supreme Court struck down the provision that required the federal government to pre-clear changes to voting systems in states that have a history of racial discrimination, mostly in the South.

National: Holder sees defense of civil rights as his legacy | The Washington Post

Attorney General Eric H. Holder Jr. was getting ready to give a speech at the Lyndon B. Johnson Presidential Library in Austin when he glanced up at a giant video screen where old photographs of Johnson were being displayed. He was taken aback by what he saw. In an image that captured the historic day the president signed the 1965 Voting Rights Act, a young woman was standing nearby whose face Holder recognized immediately: his late sister-in-law, Vivian Malone, one of two young students who had walked past Gov. George Wallace in 1963 to integrate the University of Alabama.

National: New war begins: Beating voting rights bigots | Salon.com

With North Carolina GOP Gov. Patrick McCrory ready to sign the most restrictive voting rights bill in generations (though he may not know what’s in it), one influential Republican is backing Attorney General Eric Holder’s decision to use a creaky but powerful section of the Voting Rights Act to challenge a similar law in Texas. “The [Justice] department’s actions are consistent with the Voting Rights Act,” Rep. James Sensenbrenner, a VRA reauthorization co-sponsor in 2007, told The Hill last week. “Increased litigation will be one of the major consequences of the court’s decision as courts will have to litigate more allegations of voter discrimination.” Here’s hoping Holder makes North Carolina his next target, if and when McCrory signs the bill. There’s almost no chance he won’t. He’s promised to – although he then had to admit he didn’t know exactly what was in it. McCrory denied it restricted voter registration – although it eliminates same-day voter registration and pre-registration by 17-year-olds who’ll turn 18 by Election Day – insisting “there is plenty of opportunity for voter registration — online, offline, through many methods.”

Illinois: Online voter registration to be in place next July | QuincyJournal.com

In a step supporters hope will propel more young people to the polls, Gov. Pat Quinn signed legislation Saturday to make Illinois the 18th state to allow online voter registration. The system, which must be in place by July of next year, is aimed at increasing the number of people taking the first step to voting while cutting the administrative costs of processing registrations on paper. Backers are confident the system will be secure and will not lead to an increase in voter fraud. “I can shop, watch movies, sign legal documents (and) even open my garage door online. There’s no good reason I should have to wait in line at a government office that’s only open during work hours to register to vote,” the bill’s Senate sponsor, Don Harmon, said in arguing for its passage. The Oak Park Democrat hopes the system will be popular with young people more inclined to use their laptops and smart phones to get things done.

Indiana: Former Secretary of State Charlie White sues Carl Brizzi | Indianapolis Star

Former Secretary of State Charlie White has sued former Marion County Prosecutor Carl Brizzi, alleging legal malpractice and other professional malfeasance in the handling of a criminal case that resulted in White being convicted of voter fraud, perjury and theft. The felony convictions forced White to resign in February 2012 from the state post he won election to in 2010. White is seeking a new trial. He said Brizzi, a former friend and political associate, didn’t provide an adequate defense at his 2012 trial. That request is pending in Hamilton Superior Court. White also is pressing that point in the lawsuit filed last week in Marion Superior Court. In the 31-page complaint, White makes numerous complaints about Brizzi’s work as his defense attorney, alleging legal malpractice, breach of contract, negligent or reckless infliction of emotional distress, fraud and unjust enrichment.

Indiana: Ex-secretary of state sues defense lawyer, claiming voter fraud trial was mishandled | Associated Press

Former Indiana Secretary of State Charlie White alleges in a lawsuit that he was the victim of legal malpractice by his defense attorney leading up to the voter fraud conviction that forced him from office. White’s lawsuit against former Marion County Prosecutor Carl Brizzi contends that Brizzi wasn’t adequately versed in the complexities of election, property and residency laws at White’s February 2012 trial. Brizzi “rendered legal services that fell below the reasonable standard of criminal defense attorneys because he was ignorant of the law, criminal trial procedure and ignorant of the facts in critical phases of (White’s) case during the jury trial,” White contends in the filed last week in Marion County court. A Hamilton County jury convicted White on voter fraud and other charges after Brizzi did not call any witnesses and immediately rested the defense after the prosecution wrapped up its case. White was sentenced to one year of home detention and was automatically removed from office.

North Carolina: McCrory says it all: ‘I don’t know enough’ | The CLog

At a Friday press conference, “Governor” Pat McCrory announced that he will sign the controversial “voter ID” bill into law, even though he hadn’t even read one of the bill’s crucial components – and showed a pretty weak grasp of state policy on voter registration. By the time the bill finished snaking its way through the General Assembly, it had morphed from a mere voter ID law into an all-purpose vote-suppression campaign, making far-reaching changes to the way North Carolinians may or may not vote, and earning nationwide notice as the country’s most suppressive voting law. McCrory praised the bill to reporters as just the perfect thing to “restore faith in elections.” However, when an AP reporter asked the guv how three specific parts of the bill would help prevent voter fraud, McCrory scrambled for answers. In addition to requiring a government-issued photo-ID card, the bill also ends same-day voter registration, cuts early voting by a week, and abolishes a program that let high school students register to vote in advance of their 18th birthdays.

Editorials: North Carolina Voter ID Law Targets College Students

Legislation that North Carolina Gov. Pat McCrory (R) plans to sign into law — despite not reading the entire bill — will make it more difficult for college students to vote in the Tar Heel state. The GOP-backed bill, H.B. 589, will require voters to display specific types of government-issued IDs at the polls, and it doesn’t recognize college ID as valid identification. The measure also removes preregistration for high school students, cuts early voting time and eliminates same-day registration. “It’s clearly targeting student voters,” Diana Kasdan, senior counsel at the New York University School of Law’s Brennan Center for Justice, told the Chronicle of Higher Education. “They tend to vote Democratic, and it’s a Republican-controlled state legislature that passed it.” Although former Massachusetts Gov. Mitt Romney (R) won North Carolina in 2012, two-thirds of voters under age 30 voted Democratic. U.S. Supreme Court precedent allows out-of-state students to vote where they attend college, but few students seek to obtain a driver’s license in the state where they attend school. For this reason, critics contend that voter ID laws that do not allow college-issued cards create an extra hurdle for young voters.

Wisconsin: Federal ruling highlights Wisconsin voter ID debate | The Badger Herald

After the recent U.S. Supreme Court ruling on voting rights, Wisconsin activists are waiting to see how the decision could affect ongoing legal disputes on voter ID laws in the state. In its June 25 decision in the Shelby County v. Holder case, the Supreme Court redacted Section IV regarding the federal oversight of states with historic issues with voting rights and disenfranchisement of voters, of the Voting Rights Act of 1965 in a 5-4 decision. While this decision is monumental for the mostly southern states subject to federal approval to change voter laws, Wisconsin is waiting to see the effect it will have on its own voter ID law. Wisconsin’s voter ID law, which requires voters to have specific photo identification to vote, was ruled constitutional by the 4th District Court of Appeals on May 30, despite a challenge by the League of Women Voters of Wisconsin that it violated the state Constitution. “In sum, the League has presented no basis to conclude that it has met its heavy burden in this facial constitutional challenge,” according to the court’s opinion.

Cambodia: Government rejects election inquiry creating unrest amid fraud accusations | NY Daily News

Cambodia’s government rejected on Tuesday calls by the opposition for an international inquiry into allegations it used massive fraud to win re-election, and said it wanted parliament to approve a new cabinet quickly. The United States and European Union expressed concern about irregularities in Sunday’s election but both said an investigation should be conducted by Cambodian electoral authorities, failing to endorse the opposition’s call for an inquiry involving the United Nations. The government announced on Sunday that the Cambodian People’s Party (CPP) of long-serving Prime Minister Hun Sen had won 68 seats in the 123-seat parliament, a sharp fall from its previous tally of 90. The opposition Cambodia National Rescue Party (CNRP) nearly doubled its seat total to 55, in a major surprise and a setback for Hun Sen.

Maldives: Elections Commission rejects PPM’s calls for “lenient” voter registration | Minivan News

The Elections Commission (EC) has denied receiving any formal complaints over its capability to ensure a fair election in September this year, after rejecting requests by the Progressive Party of Maldives (PPM) to make voter registration more “lenient”. EC President Fuwad Thowfeek told Minivan News no “official complaints” had been filed with the commission over its ability to capably oversee the upcoming presidential election, despite the PPM alleging in local media that it was incapable of ensuring a fair vote. Thowfeek said the PPM have previously requested the EC not to reject voter registration forms missing details such as the name of a voter’s parents or a phone number, that could not be verified during random checks.

Mali: Elections Held After Year of Turmoil | New York Times

Under pressure from France and other Western powers, Mali held a presidential election on Sunday that some observers said the country was not ready for and that risked excluding thousands of its citizens. Voting went off peacefully, nonetheless, in an election that Mali’s numerous donors deemed crucial to restoring the country’s stability after more than a year of turmoil: an Islamist takeover in the desert north in the spring of 2012; a military coup in the capital; French military intervention to forestall Islamist advances in January; and the flight of nearly 200,000 inhabitants beyond Mali’s borders. Mali, a poor West African desert nation, has been ruled by a makeshift, unelected government since March 2012, with no parliament, few functioning state institutions and a weak, military junta-approved president. Billions of dollars in aid have been promised by international donors but only if the country has at least the appearance of democracy. That meant proceeding to a hasty election that some of the country’s politicians, research institutes like International Crisis Group, and even the country’s electoral commission warned might be premature.

Zimbabwe: Crisis looms in Zimbabwe over election results | Los Angeles Times

The first official results from Zimbabwe’s election and unofficial tallies indicated Thursday that President Robert Mugabe’s party was headed for a landslide win. But Mugabe’s main rival, Prime Minister Morgan Tsvangirai, rejected Wednesday’s poll as a sham and warned that the country was headed for a crisis. A number of observers and civil society groups said Mugabe’s ZANU-PF party made huge gains in areas that were strongholds for Tsvangirai’s Movement for Democratic Change, including Matebeleland South, Manicaland and Masvingo. The party had an overwhelming lead in early parliamentary results announced by the Zimbabwe Electoral Commission. ZANU-PF made no official victory claim over Tsvangirai and his Movement for Democratic Change, withdrawing what it described as an unauthorized tweet from the party account that had claimed a resounding win. But a senior ZANU-PF figure told Reuters news agency that his party had crushed the opposition.

Zimbabwe: Robert Mugabe vows to ‘surrender’ if he loses as voters go to polls | ABC News

Zimbabwean president Robert Mugabe says he will quit after 33 years in power if he loses the country’s election, as rivals claimed they had evidence of vote-rigging. Voters go to the polls today with heavily armed riot police deployed in potential flashpoints across the capital Harare. After a violent run-up to the last election five years ago saw then opposition leader Morgan Tsvangirai withdraw, this poll has mostly been free of bloodshed. A power-sharing agreement was established after that last failed election, an acrimonious arrangement with Mr Mugabe remaining as president and Mr Tsvangirai as prime minister. Mr Mugabe’s party is accused of doctoring the roll for this election, while prime minister Mr Tsvangirai’s finance minister is in turn being blamed for failing to release funds to allow it to be revised.

National: Eric Holder Decides to Mess With Texas | Bloomberg

U.S. Attorney General Eric Holder has declared that, at least when it comes to voting rights, the U.S. Supreme Court is guilty of wishful thinking. He is also showing both how difficult and how important it is to overcome that kind of thinking. It was just last month that a closely divided court, reasoning that voter discrimination in the South wasn’t the problem it used to be, neutered the requirement that certain states and counties with a history of such discrimination submit proposed voting changes to the federal government for approval. Last week, Holder said the Justice Department would use “every tool at our disposal to stand against discrimination.” Meanwhile, in Texas, officials said they will proceed with a redistricting plan that dilutes Hispanic voting power, and an aggressive voter-identification law besides. And in North Carolina, the Republican-controlled Legislature passed a bill of such brazenness that it can be more aptly described as an attempt to restrict voting procedures rather than reform them. In 2013 alone, more than 80 bills restricting voting rights have been introduced in 31 states. Meanwhile, the incidence of actual voter fraud hovers near zero. (Kansas, site of one of the first coordinated crackdowns on voting rights, has had more documented cases of UFO sightings than of voter fraud.)

National: GOP lawmaker chides FEC for two-year delay in creating enforcement manual | Washington Post

The House Administration committee’s top Republican last week scolded the Federal Election Commission for failing to approve an enforcement manual two years after lawmakers asked the panel to complete the task. “When a federal agency keeps its enforcement policies and procedures secret or makes them difficult to understand, it increases the opportunity for abuse by its employees — abuse that has very real consequences for the Americans subject to its power,” Committee Chairman Candice Miller (Mich.) said in a statement on Friday. In a letter to Miller on Thursday, FEC Chairman Ellen Weintraub raised concerns about dealing with enforcement guidelines while the Senate is considering two new nominees for the commission.