Troops of 5 Battalion operating under 16 Brigade, Nigerian Army, in a raid operation on Sunday, June 25, 2023 at Azuzuama Community in Ijaw South Local Government Area of Bayelsa State, have captured an armoury located in a camp from where suspected unrepentant militants and illegal oil bunkerers carried out their nefarious activities.

During the operation, the highly motivated troops subdued the suspected militants with superior firepower, compelling them to abandon their camp in disarray.

A statement on Monday issued and signed by Brigadier General Onyema Nwachukwu, Director of Army Public Relations, said the well-conducted raid operation led to the recovery of five AK47 Rifles, two Rocket Propelled Grenade Bombs, four Rocket Grenade Bomb Chargers, seven 7.62mm Special ammunition, 14 AK47 Rifle Magazines and one pumping machine.

“Other items recovered include two 16-inch anchored verve, one mallet hammer, one pipe range spinner and one axe. The illicit camp has been destroyed by the troops.

The Abuja Electricity Distribution Company (AEDC) has appealed to its customers to disregard the planned tariff increase as approval for such an increment had not been received.

AEDC management made the appeal in a statement on Monday in Abuja.

“Please disregard the circulating communication, regarding the review of electricity tariffs.

“Be informed that no approval for such increments has been received. We regret any inconvenience.”

However, AEDC had earlier in a statement, said there would be an upward review of electricity tariffs from July 1.

According to the statement, the tariff increase is influenced by the fluctuating exchange rate.

“Effective July 1, 2023, please be informed that there will be an upward review of the electricity tariff influenced by the fluctuating exchange rate.

“Under the MYTO 2022 guidelines, the previously set exchange rate of N441/1 dollar may now be revised to approximately N750/1 dollar which will have an impact on the tariffs associated with your electricity consumption.

“For customers within bands B and C, with supply hours ranging from 12 to 16 per day, the new base tariff is expected to be N100 per Kilowatts per hour (KWh).

“While Bands A with (20 hours and above) and B (16 to 20 hours) will experience comparatively higher tariffs,‘’ it said.

In the statement, AEDC encouraged customers with prepaid meters to consider purchasing bulk energy units before the end of June as this would allow them to take advantage of the current rates and make savings before the new tariffs came into effect.

AEDC said that for those on post-paid (estimated) billing, a significant increment is imminent in their monthly billing, starting from August.

The Mult Year Tariff Order (MYTO) is the methodology for regulating electricity prices.

It provided a 15-year tariff path for the Nigerian electricity industry with limited ‘minor’ reviews each year in the light of changes in a number of parameters.

These included inflation and gas prices and ‘major’ reviews every five years when all of the inputs were reviewed with stakeholders.

(NAN)

Two lawyers who unwittingly submitted fake cases generated by ChatGPT to support their claim have been fined by a New York court because they “abandoned their responsibilities”.

As well as being fined $5,000 each, the lawyers and their firm have been ordered to inform their client and the judges whose names were wrongfully invoked in the case of the sanctions imposed on them.

Peter LoDuca, Steven A Schwartz and the firm of Levidow Levidow & Oberman attracted international attention after the brief in a personal injury claim prepared by Mr Schwartz contained six cases that ChatGPT had simply made up – the system later insisted they were real when Mr Schwartz asked it.

US District Judge P Kevin Castell in the Southern District of New York said: “In researching and drafting court submissions, good lawyers appropriately obtain assistance from junior lawyers, law students, contract lawyers, legal encyclopedias and databases such as Westlaw and LexisNexis.

“Technological advances are commonplace and there is nothing inherently improper about using a reliable artificial intelligence tool for assistance. But existing rules impose a gatekeeping role on attorneys to ensure the accuracy of their filings.”

He continued that here the lawyers “abandoned their responsibilities when they submitted non-existent judicial opinions with fake quotes and citations created by the artificial intelligence tool ChatGPT, then continued to stand by the fake opinions after judicial orders called their existence into question”.

Among the “many harms” that flowed from the submission of fake opinions was that it promoted “cynicism about the legal profession and the American judicial system”, while “a future litigant may be tempted to defy a judicial ruling by disingenuously claiming doubt about its authenticity”.

The law firm primarily practises in New York state courts. It uses a legal research service called Fastcase and does not have access to Westlaw or LexisNexis.

But the case involved the Montreal Convention and was in federal court, and the firm’s Fastcase account had limited access to federal cases. Mr Schwartz said this was why he turned to ChatGPT.

Judge Castell said the outcome of the matter would have been “quite different” had the lawyers come clean after the defendant first questioned the existence of the cases, or after the court had required them to produce them.

Instead, they “doubled down and did not begin to dribble out the truth” until the court issued an order to show cause why they ought not be sanctioned.

This was evidence of bad faith on their parts, as was Mr Schwartz’s statement to the court that ChatGPT had “supplemented” his research, when in fact it was the only source of his substantive arguments.

Mr Schwartz testified at the sanctions hearing that he was “operating under the false perception” that ChatGPT “could not possibly be fabricating cases on its own”.

He said: “My reaction was, ChatGPT is finding that case somewhere. Maybe it’s unpublished. Maybe it was appealed. Maybe access is difficult to get. I just never thought it could be made up.”

The law firm told the court that it has arranged for outside counsel to conduct mandatory training on technological competence and artificial intelligence.

Judge Castell credited “the sincerity of the respondents when they described their embarrassment and remorse”. The fines were “sufficient but not more than necessary to advance the goals of specific and general deterrence”.

Earlier this month, the Master of the Rolls, Sir Geoffrey Vos, cited the case as a reason why legal regulators and the courts may need to control “whether and in what circumstances and for what purposes” lawyers can use systems like ChatGPT in litigation.

There are indications that banks are ignoring the Central Bank of Nigeria, CBN, directive that they should grant their customers unfettered withdrawal of foreign currencies from domiciliary accounts, vanguardngr reports.

Meanwhile, Nigeria’s foreign exchange market has recorded a drastic change following the market reforms introduced by the CBN, previous week.

Financial Vanguard findings show that the banks are still restricting the amount of foreign currency that customers can withdraw from their accounts saying the currencies are still scarce.

Dealers and the customers who spoke to Financial Vanguard lamented that the situation has impeded supply of foreign currency to the market.

But the drastic change in both structure and operations of the foreign exchange market, according to the Financial Vanguard findings has resulted in exchange rate convergence by default as the US dollar traded within narrow band across the three segments of the market, namely, the Investors and Exporters (I&E) window, the Bureau De Changes (BDCs) and the black market.

However, for the first time, the exchange rate in the official market (I&E) surpassed what obtained in the black market.

Meanwhile, dealers across all the segments are facing acute scarcity of the US dollars while CBN resumed supply of the foreign currency last week, though at a very low volume.

Findings by Financial Vanguard show that Naira last week depreciated further to N770.17 per dollar in the I&E window, with currency dealers projecting further deterioration of the dollar scarcity, a situation which may propel further depreciation of the local currency this week.

According to data from FMDQ, the I&E window exchange rate closed at N770.17 per dollar on Friday. This represents 16.2 per cent week-on-week, WoW, depreciation of the Naira when compared with the closing rate of N663.04 per dollar the previous week.

The Naira also depreciated in the parallel market, where the dollar traded within the range of N765 and N770 per dollar, at the close of business, up from N759 per dollar the previous week.

The Naira has been on the downward trend in both the official market and parallel market, since the Central Bank of Nigeria, CBN announced, “Operational Changes to the Foreign Exchange Market,” including elimination of multiple exchange rates/segments and re-introduction of willing seller, willing buyer model in the I&E window.

Since the changes were announced the previous week, the Naira has depreciated by 63 per cent in the I&E window, from N471.67 per dollar on Tuesday June 13th.

During the same period, the Naira also depreciated by 20 per cent in the parallel market from N755 per dollar.

Dollar scarcity

Findings from currency dealers showed that the depreciation is driven by acute dollar scarcity in both I&E and the parallel market.

A banker and forex market analyst who spoke on condition of anonymity told Financial Vanguard, “Though the CBN intervened in the I&E window on Thursday, the market is still very short, in terms of supply. The volume of sales by the CBN was not much. The highest volume sold per buyer was $5 million dollars. Some others got $2.5 million while others got between $250,000 and $1 million.

“They, however, sold only to people that bided at an exchange rate above $761 per dollar.

“After the CBN’s sales, some international organisations also sold but the volume was small compared to the demand, especially given the backlog of matured obligations. I will say the market is still evolving and going through a price discovery process. The volatility will continue with the Naira further depreciating, depending on dollar supply coming into the I&E window.

“The true exchange rate will only emerge when all the backlog of dollar demand has been satisfied.”

Operators react

Bureaux De Change, BDC, operators and parallel market operators who spoke to Financial Vanguard lamented the dollar scarcity in the market, noting that banks are yet to comply with the directive of the CBN that they should allow customers have unfettered access to funds in their domiciliary accounts.

Mallam Ahmed Yunusa, a black market trader in Lagos, said: “The market has been very busy since last week after the CBN eased its restrictions on forex trading in banks.

“A dollar was sold for N770 today (last Friday) because I bought a dollar for N765 making just N5 profit. However, over the week, the dollar has been traded at N745 to N770.

“The reason for this is because most of our customers who visited the banks complained the demand for dollars is higher than the supply and that the banks don’t have enough dollars to go round hence the rise in the price for the willing buyers.

“Most traders at the parallel market decided to sell a bit less or higher within the price range of banks to keep our customers as the competition becomes tougher.

“I see a continuous rise in the volume of demand for the dollar as we approach the end of the year and an appreciation of the Naira to N500 or N600 per dollar in the near term if dollar supply increases.”

On his part, Mallam Umoru Mohammed, another black market trader in Lagos, said: “The dollar has been trading since last week from N740 to N770. Today the dollar was traded at N750.

“Here in Ikorodu, businesses have been dull as not many sold dollars to us hence I was not able to get supply of dollars due to the higher demand of dollars than supply.

“I see the Naira depreciating to N800 per dollar due to the inability of traders to meet the demands of buyers as we approach the remaining half of the year but if there is more forex inflows the reverse will be the case.”

Similarly, Garuba Hassan, a parallel market operator also in Lagos, said: “Today (last Friday) we are buying at N750 per dollar, but yesterday the rate was between N760 and N770 per dollar. If you go to the banks, they will tell you no dollars. You will have to visit about three banks before you can get the dollars, and this is affecting the market and the rate.”

Speaking on condition of anonymity, a Bureaux De Change, BDC, operator, and executive member of Association of Bureaux De Change Operators of Nigeria, ABCON, said: “There is nothing like BDC exchange rate because the CBN is not selling dollars to BDCs. We all compete with the parallel market operators for dollars and as such we have to ensure our rates match theirs.

“The situation in the market now is that demand is high but dollars are still scarce because there is no supply.

“People that want to withdraw dollars from their domiciliary account are not able to do so. The banks keep telling them there are no dollars.

“But I believe the Naira will appreciate in the coming weeks. The sharp depreciation of the Naira in the I&E window, I believe, is to encourage investors and Nigerians in Diaspora to bring in their dollars.

“Once this happens, the exchange rate in both I&E and the parallel market will gradually go down.”

Vehicles Duties Up By 40%

The Central Bank of Nigeria and the Nigeria Customs Service have taken the ongoing foreign exchange reforms to the maritime sector with a 40 per cent increase in the exchange rate used for calculating import duty.

The NCS on Saturday raised the exchange rate used for the calculation of import duty from N422.30/dollar to N589/dollar.

The development, which has led to a corresponding 40 per cent increase in import duty on imported cargoes including vehicles, has angered operators in the maritime sector with clearing agents, freight forwarders, and importers calling for an immediate reversal of the policy.

Stakeholders said the policy would lead to job losses in the maritime sector and a drastic fall in the number of imported vehicles.

This, they said, could affect business and economic growth. Economists also said the government was insensitive, saying the policy was capable of affecting Nigerians negatively.

The development came barely one month after the Federal Government removed fuel subsidy and floated the naira. It also came at a time Discos began a gradual increase of their tariff.

The National Public Relations Officer, NCS, Abdullahi Maiwada, who confirmed the new exchange rate on its portal, said the agency was only implementing a CBN policy.

He said, “Whatever you see in our system is what has been communicated to us. It is determined by the Central Bank of Nigeria. So whatever we are using is what is obtainable as communicated to us. It is a monetary policy, we only implement what is given to us. It is a monetary policy and anything monetary is not determined by us, it is determined by the CBN. We only use what is communicated to us.”

Also confirming the development, the Youth Leader of the Association of Nigerian Licensed Customs Agents, at Tin Can Island, Remilekun Sikiru, said that the new rate had been effected on the Customs portal.

Our correspondent also confirmed the new rate on the Customs portal on Sunday.

Sikiru, also the CEO of Siktemstar Logistics, said that the customs duty payable on vehicles had increased astronomically.

He said, “For instance, the total duty payable on a Toyota Camry was N901,000 before now; but it has been increased to N1,270m; duty payable on Venza was N1.632m before now, but it has been increased to N2.278m. In the same vein, Toyota Corolla was N786,000, but now it has been increased to N1.097m while Lexus Rx which used to cost N1,828,000 now costs N2,550,447.”

He added, “It’s pathetic. We woke up to see this in the early hour on Saturday 24th of June 2022. The Federal Government needs to reverse this.”

According to him, this development may lead to cargo including vehicles being trapped at the terminals.

“The customs duty has been increased and it will lead to a heavy increment in duty payment on general goods/cargo. This will bring hardship on importers”

Also speaking, a freight forwarder and Chief Executive Officer, 2B Frank Nigeria Limited, Nwegbe Frankypaul, said, “Freight forwarders woke up on Saturday to realise that dollar rate has been increased from about N423 per dollar to about N590 per dollar.”

Nwegbe pleaded with the President to ensure depreciation on the value of older vehicles.

Reacting to this, the Chief Executive Officer of the Center for the Promotion of Private Enterprises, Dr Muda Yusuf, said the government needed to reverse the policy due to its effect on Nigerians and the economy.

“This has nothing to with either supporting or negating the unification of the exchange rate. What I think is that this will translate to an additional burden on the citizens and businesses. The bottom line is that import duties have increased. The citizens have not recovered from the fuel subsidy removal, they are still expecting palliatives which have not come. Now, the Discos are talking about increasing the electricity tariff. How will the citizens feel? I don’t think the Federal Government is being sensitive to the plight of the people. Whoever gave the directive is not being sensitive; they should be talking about reducing some of these tariffs so that transportation costs can be reduced. The palliative is not only for salary earners, the government should do a palliative scheme that will affect everybody.

Also speaking, the Founder of the National Council of Managing Directors of Licensed Customs Agents, Mr Lucky Amiwero, said, “The moment you allow the naira to float freely in terms of exchange, that is what you get. And it is going to affect the prices of goods. It is going to take a lot of licensed Customs agents out of work because most of them are going to lose their customers.”

The Vice President of the National Association of Government Approved Freight Forwarders, Nnadi Ugochukwu, while remarking, said, “It will affect businesses, there is a container I have for someone, before now, we used to clear that container for N4.3m. With the new exchange rate, the clearing cost is now N6.5m.”

Also speaking, the Secretary General of NCMDLCA, Mr Festus Ugu, “Even if the Federal Government wants to do exchange rate harmonisation, they should know how to go about it. This increase is a very big one.”

However, an economist, Mr Ibrahim Tajudeen, said the policy “is in line with the overall reform of the foreign exchange market by the government. Also, it is not the first time that we are seeing such a thing. A few years ago when the currency was devalued, the exchange rate for clearing goods also increased. So it is consistent with the development or reforms going on in the foreign exchange market. Nevertheless, I recognise that Nigerians are going to feel the negative impact. And I think the government has to do something to help the masses at some point.”

Recall that CBN directed Deposit Money Banks to remove the rate cap on the naira at the official Investors’ and Exporters’ Windows of the foreign exchange market.

This came barely a few weeks after President Bola Tinubu promised to unify the nation’s multiple exchange rates and less than a week before the suspension and detention of CBN Governor Godwin Emefiele, whose unorthodox monetary policies had become a stumbling block to investors and the economy.

The CBN’s decision to float the currency was hailed by the organised private sector and economists who said the move would unify the country’s multiple exchange rates and bring sanitise the FX market

The development means buyers and sellers of foreign currency in the official FX markets are now allowed to quote rates they find comfortable in the FX market, as against the previous practice where rates were dictated by the Central Bank of Nigeria.

Following the development, the naira has been on a free fall, weakening to 770.19/dollar at the close of trading at the I&E Window on Thursday, according to data from the FMDQ Securities Exchange

Former aide to former President Muhammadu Buhari, Garba Shehu, has given reasons his principal did not remove fuel subsidy during his administration from 2015 to 2023.

Below are his reasons:

Former president Buhari didn’t remove fuel subsidy because his party, All Progressives Congress, APC had an election to win.

Secondly, Buhari did not remove petrol subsidy because he removed every other budget-busting, egregious, economic-growth-crushing subsidy along the way.

Thirdly, Buhari kept the decision for a better time.

Fourthly, Buhari did not want to distract the onerous tasks facing Tinubu/Shettima.

Finally, Buhari tried not to remove it at a time when tensions were high in the country and no responsible leader would have added fuel to the fire.

Nuhu Ribadu has assumed duties as the National Security Adviser (NSA).

Speaking when he took over from former his predecessor, Maj.-Gen. Babagana Monguno (Rtd), Ribadu said he would use all in his capacity to subdue insecurity and stabilize Nigeria.

He said the administration of President Bola Tinubu had enormous responsibility of securing Nigeria and ensuring peace in all parts of the country.

According to him, this is a work for Nigerians and he intends to continue with what has been done.

“We will stabilize this country, we will secure our country and we will make Nigeria peaceful because we believe time has come for this country to enjoy peace, restore order and rule of law just like any other country in the world.”

“Securing the nation is a continuous process. We will look at what has been done and build on it. We will count on your support in the course of discharging our responsibilities.

“Mr. President has a huge commitment to securing every inch of our country. We will work with all stakeholders to deliver on this vision.

“This enormous task of securing our country is that of all Nigerians, and all friends of Nigeria,” he said.

Ribadu solicited the full cooperation of all servicemen and women, and by extension all Nigerians.

He said there was need to unite to accomplish the present administration’s quest for a more stable, peaceful and prosperous Nigeria.

Earlier, the former NSA, Monguno, said Rubadu was well-equipped, qualified, educated and has a very deep understanding of the complexity of the security challenges confronting the country.

He said that the new NSA had the capacity to tackle whatever challenges that he might encounter having served in the various positions.

“For me, I have been able to handover a comprehensive note to him and also brief him extensively.”

“For me, I want to give gratitude to the Almighty God for giving the grace to serve for such a long time and also allowing me to depart in good health and enjoy the rest of my life in an atmosphere that is bereft of the type of pressure that are associated with this all important office.

“I am also wishing in the same vein that Mallam Nuhu Ribadu will have a very successful tenure and depart in good health when the time comes for him to depart, he stated.”

Monguno said the ever-changing 21st security environment demands complex approach.

According to him, “Today we are dealing with a situation in which we have terrorists and insurrectionists. The way and manner you will deal with the situation is such that you will have to rely on collection of competent staff.”

He urged the staff to extend the same support and cooperation he enjoyed to his successor to achieve the desired national objective.

The Nigerian Army has successfully raided a ‘baby-making’ factory and human trafficking camp in Adamawa State, resulting in the arrest of seven suspects.

The Brigade Commander 23 Armour Brigade, Yola, Brigadier General Mohammed Gambo, disclosed this to newsmen at the Command.

He explained that the troops of the Brigade were on a special operation on the border area between Nigeria and Cameroon when they received credible information about the operations of the suspected criminals.

According to him, the camp was reportedly holding seventeen young girls aged between 19-21 years, who had been in the custody of the suspects for about 2-3 years without the knowledge of their families.

He observed that the discovery of the camp has raised concerns about the prevalence of human trafficking in Nigeria.

Gambo commended the Nigerian Army’s swift action in the operation and hoped that this will be a significant step towards eradicating human trafficking in Nigeria.

“The suspects have been paraded alongside their victims at the Brigade Headquarters in Yola, the Adamawa State capital,” he stated.

Kano State Governor, Abba Kabir Yusuf, has ordered the State’s Accountant General to stop the salaries of 10,800 workers employed by his predecessor, Abdullahi Umar Ganduje.

Recall that the new administration had accused Ganduje of illegally employing over 10,000 workers when it was about leaving office.

The Accountant General, Abdulkadir Abdusalam, announced the governor’s directive on Monday while addressing journalists in Kano.

Abdusalam said the governor ordered his office to remove the affected workers from the state’s payroll.

He further stated his office would carry out an investigation to find out the genuineness of their engagement and procedures so as to remove those illegally recruited.

Concerning local government workers in the state, Abdusalam disclosed that those who were converted to state workers by the former administration would continue receiving their salaries.

However, he said it would be based on local government levels, asking them to continue working in their new state’s MDAs until the investigation is concluded.

President Bola Tinubu would have lost the 2023 presidential election if his predecessor had removed fuel subsidy, according to Garb Shehu, spokesman of ex-President Muhammadu Buhari.

The incumbent president removed subsidy on his first day in office, an action that has fetched him commendations far and wide.

Addressing some Nigerians based in France during his recent trip to Paris for a summit, Tinubu had said lack of courage allowed the subsidy regime linger.

“I have achieved my aim. Making just a few smugglers rich. Some countries were bleeding us. Courage was missing. sometimes, I became an advocate of it. Remove this thing but God gave me the opportunity when I danced around, strategize with my team, we won the presidency.”

“I brought it. I won. We must achieve with it. We must change Nigeria with it. And then Wale Edun and co, we started debating, putting my speech together without the question on subsidy. I got to the podium, I was possessed with courage and I said subsidy is gone,” Tinubu had said.

But in a statement on Monday, Shehu defended Buhari’s action, saying he did not toe that path in order to avoid the All Progressives Congress (APC) losing the February 25 election.

Shehu said there were multiple subsidies that the Buhari administration inherited in 2015, but they were gone before he handed over power.

“Why did it take the new Tinubu/ Shettima presidency weeks to remove the petrol subsidy when Buhari didn’t do so for years fails to ask the right question. The massive electricity subsidy. The fraudulent fertilizer subsidy. Hajj/Christian Pilgrim subsidies. Remember them?”

“The diesel subsidy. The aviation fuel subsidy. LPFO. Kerosene. Cooking gas and the other subsidy policies we found in place, and put them firmly on the ground. Remember them?

“For those with short memories, many of those subsides were all in place when president Buhari was elected to office in 2015: all those in place were gone by May 2023 – including the annual fertilizer subsidy that weighed 60-100 billion Naira (that’s trillion naira in about 10 years – yes you read that right) heavy on the federal budget each year.

“So no, Buhari didn’t remove the petrol subsidy – but in vitally important stages he removed every other budget-busting, egregious, economic-growth-crushing subsidy along the way.

“So far I have refrained from answering these repeated questions on the removal in Nigeria of subsidies on Premium Motor Spirit, PMS and that arising from the dual rates of the Naira in the Central Bank and the parallel market: Why did Buhari “fail” to do these?

“First of all, my thinking is that instead of the former President answering this question, it is the Party, the All Progressives Congress, APC that is best suited to speak and failing to do this, we are forced to say what will follow here.

“Secondly, we are mindful of the fact that with a Tinubu/Shettima presidency now in place and for which there is a “New Sheriff in Town.”

“We do not want to distract them from the onerous tasks facing them and the nation. Neither is it our wish to take the spotlight away from them in any way.

“In terms of the timings of the decisions to remove fuel subsidy and unify the currency, the Tinubu/Shettima administration has done overwhelmingly well. Even more importantly, they have been most dexterous in managing the aftermath of the decisions by successfully avoiding any crisis.

“To this extent, our wish and prayers are that fellow countrymen will continue to support the new leadership in these very laudable decisions and, in particular, for the Labour leadership and civil society to work with them to ensure that the palliative efforts as promised are successfully implemented.

“The decision to remove subsidies, as in our case – and we believe in all situations – was not for the President to take all by himself.

“That’s why it’s important to remind ourselves – and all those who have conveniently forgotten – that Buhari administration had been on this pathway from the very beginning in 2015.

“Removing subsidies for the Naira and PMS was cued and put on hold. Look for example in the Petroleum Industry Act. The important decision was kept for a better time.

“It could not have come at a time when tensions were high in the country and no responsible leader would have added fuel to the fire.

“In the view of many-including those in the security circles- only a new administration with a goodwill that fills a warehouse can attempt this, and here now comes in the wit and grit of the Tinubu government.

“Finally, we must be politically honest with ourselves. TheBuhari administration in its last days could not have gone the whole way because the APC had an election to win. And that would have been the case with any political party that was seeking election for another term with a new principal at its head. Poll after polls showed that the party would have been thrown out of office if the decision as envisaged by the new Petroleum Industry Act was made.”