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The Ratcatcher Syllogism: Notes for a Philosophy of Private Security

2013; Taylor & Francis; Volume: 8; Issue: 2 Linguagem: Inglês

10.1080/19361610.2013.765341

1936-1629

H. H. A. Cooper,

Intelligence, Security, War Strategy

Click to increase image sizeClick to decrease image size Notes 1. Dance of the Dwarves, Boston, MA: Little Brown, 1968, p. 33. Cited “Thoughts on the Hiring (And Firing) of Security Directors,” H. H. A. Cooper and Brook E. Penn, Journal of Security Education, Vol. 3, No. 3–4, 2008, pp. 297–323 at p. 320. Yes, dear, diligent readers, you have, indeed, seen this citation, in this very Journal. Had your research extended further, you would also have discovered it aptly cited in Catching Spies, H. H. A. Cooper and Lawrence J. Redlinger, New York, NY: Bantam Books, 1990, pp. 1–33, in a different yet still appropriate context. Sir Terry Pratchett, The Last Continent, London, England: Corgi Books, 1999, p. 127, “All bastards are bastards, but some bastards is bastards.” We are sure Nicole Kidman, would have appreciated the subtle, cultural emphasis. 2. Philosophy is another of those plastic words that lends itself to promiscuous employment in a variety of contexts. Its employment here is encapsulated in a quote from an excellent New Yorker article “We are alive,” by David Remnick on Bruce Springsteen, July 30, 2012, pp. 38–57 at p. 49: He [Jon] Landau, got a call from Springsteen. We talked for hours about music, about philosophy. The core of him then was the same as it is now. And, you know, we've been having that conversation for the rest of our lives; about growth, about thinking big thoughts, about big things. Certainly, this exchange was to have a big impact on both their lives. See, too, “France's Prophet Provocateur [B-HL], Joan Juliet Buck, Vanity Fair, January 2008, pp. 86 et seq., at p. 91.” Philippe Sellers, “Can a philosopher have a direct effect on events? He can if he's Bernard Henri.” Of course, even the most modest talent can shine like the Dog Star if you are obscenely wealthy, are married to a beautiful, talented celebrity and have a powerful politician as a mentor. I am indebted to an excellent former student, Samuel Wilkison III, for a delightful Descartes story. The distinguished, French philosopher (Cogito, ergo sum) called into a bar on his way home. He ordered a white wine. Seeing he had finished it, the barman called out to him to see if he would like another. “I think not,” said Descartes. And disappeared forthwith. 3. “Security is not a subject that lends itself to introductory writings,” Target Terrorism, Providing Protective Services, Richard W. Kobetz, and H. H. A. Cooper, International Association of Chiefs of Police, Gaithersburg, MD, 1978, p. 22. Indeed, the best book I have encountered is in Spanish, La Seguridad Moderna, Guia Completa Para el Oficial, Supervisor o Gerente de Seguridad, Candido Neris Mulero, Drupa Editores, Medellin, Columbia, 1996. This is a fine exposition of the philosophy of private security in Puerto Rico, which has much wider application. 4. Medieval, feudal society had much of the “Warlord” basis about it until the rise and supremacy of the nation state and the assumption of the responsibility for security internal and external by central government. 5. That this process is very far from complete can be seen from the example of Libya following the overthrow of the Gaddafi regime before any sensible alternative could be put in place. 6. This unfortunate situation in Afghanistan is being obscured by the unwillingness of the big powers to face up to the situation their well-intentioned meddling has helped create. Only a powerful, central authority can permit the growth of private, subordinate security services. 7. Uncontrolled by war and like circumstances, this struggle is all about power, who shall gain it, who shall exercise it. The demise of the Cold War did nothing to produce a resolution of the matter, which is really at the heart of the current Eurozone problems. 8. By a legal fiction, time immemorial for the purposes of the common law is expressed as the year 1089. The true philosophy of security as examined here “the thinking of big thoughts about big things” goes back a very great deal farther than that, at least to Sumer (the Biblical Shinar). Much of the Old Testament is permeated with such ideas of rights and duties, social harmony. From but a slightly later age, see the wonderful Code of Hammurabi, http://www.wsu.edu/ ∼dee/MESO/CODE.HTM. Hammurabi, The exalted prince was elevated to bring about the rule of righteousness in the land, with the beautifully enunciated Philosophy in its Prologue, “so that the strong should not harm the weak.” For all his power to guarantee the security of the inhabitants in their homes,” the great King acknowledged his indebtedness to the Divine. [L.W. King translation, 1910]. 9. Morris West, perhaps, articulated it better than anyone. He wrote: “Every city needs a ratcatcher to go down the sewers, but none of the citizens will invite him to dinner.” Proteus, New York, NY: William Morrow, 1979, p. 263. Even with a change of clothes! This article, on other evidence, accepts the premise. It merely seeks to explain it and relate it to those, equally needed, yet are just not the sort you invite to dinner, There is more than simple prejudice at work here, there is a real yet irrational fear of contamination. The late Christopher Hitchens, who could by all accounts be quite obnoxious at times, does not seem to have suffered from the ratcatcher syllogism; at least, he seems to have been a popular enough dinner guest. He was a great admirer of George Orwell (Eric Blair). He writes, in reference to Orwell's WW II service with the UK Ministry of Information: One has to use a certain amount of decoding to identify literary transitions like this as they move from Orwell's private to his public writing, whereas other sources of inspiration and provocation are more blunt and obvious. In 1939 he takes a ‘Miscellaneous’ diary note from the agricultural journal Smallholder. ‘Rat population of G. Britain estimated at 4–5 million.’ Who knows in what part of his cortex he stored away that random finding against the day when it would help form one of the most arresting images of terror in all of his fiction. The Importance of Being Orwell, Vanity Fair, August, 2012, pp. 66­69 at p. 69. A great friend of Hitchens, Salman Rushdie, who has just published a “must read” personal account of arresting interest to all concerned with protecting high risk targets from assassination, excerpted a portion titled The Disappeared for The New Yorker, September 17, 2012, pp. 50–65. Rushdie writes: “The worst thing in the world is different for every individual. For Winston Smith, in Orwell's ‘1984,’ it was rats” 10. Even the best of robots has to have a human handler, somewhere. The robot is really little more than a remote, activated shield protecting its human master from potentially harmful contact with the device to be neutralized or disarmed. 11. A New Yorker cartoon, August 27, 2012, p. 71 captures this with an evocative drawing and a three word caption. An enthusiastic young cavewoman is introducing a somewhat unprepossessing young man to her “family,” “Kip paints caves.” Certain skills have been around since “time immemorial.” “Most people define themselves in large part by their work. I am a shoemaker, I am a gardener, I am a writer, I am an engineer, I am a lawyer,” David Burnham, The Rise of the Computer State, New York, NY: Random House, 1953, p. 222. 12. The “new” social media certainly lends itself to dangerous levels of deception. It can, of course, only go so far. Doctored images and highly exaggerated bios eventually come up against the hard facts of reality as many sexual predators caught by law enforcement “stings” have learned to their cost. 13. See, for example, the Proceedings of the 27th ASET Annual International Round Table Conference, “Thoughts on the Hiring (and Firing) of Security Directors, H. H. A. Cooper and Brooke E. Penn, Journal of Security Education, Vol. 3, No. 3–4, 2008 pp. 297–323, at pp. 299–300. 14. Ibid. This author was President of ASET at that time. 15. What is called “pure Science” is characterized by its rigorous methodology. It is that adaptation and application of what is discovered by these means that, as in the case of security, give it relevance in solving the problems of real life. Computer programming offers the perfect example of what is meant here. 16. For an interesting slant on this, see “Words on Trial,” Jack Hitt, The New Yorker, July 23, 2012, pp. 24–29 at p. 27. “Like all linguists, [Rob] Leonard starts from the position that meaning is delicately contingent and that the most common way we compensate for this frailty is redundancy. We say the same thing more than once, or in more than one way.” 17. In the teaching of legal subjects, academically, the science of law tends to be bound up with its underpinning philosophy. This is somewhat obscured where the subject is treated of as legal theory or, in the UK, as Jurisprudence. Strictly speaking, what is brought into these necessary studies is a good deal of received learning from other, discrete disciplines. This is especially the case with respect to meaning. See Lies!Lies!Lies, The Psychology of Deceit, Charles V. Ford, Washington, DC: American Psychiatric Press (1996), especially Chapter 9 on memory. False memories, false accusations, and false confessions all have in common the alteration of objective reality. This is very important for the evaluation of evidence. 18. Whether we are talking about terrorism or health care, there is always a paymaster. We are constantly reminded, at every turn, “there is no free lunch.” There is nothing inherently demeaning in getting paid for what you do; even the President of the United States receives a salary for his (or her [?]) labors. Business merely determines how you expect to be paid. 19. Business, as the term is employed here is essentially a matter of organization of transactions, of the provision of goods and services desired by one party in exchange for an agreed value placed upon them by the provider. It is in the nature of what passes from one to the other that the real appreciation of the transaction is founded. To be able to conduct a business in law or medicine takes many years of study and practice as well as capital investment. It is no less a business for all that. “Bezos is a businessman, but, like the founders of Google and Facebook he frames his business as a force for social good,” Popes Trail, Ken Auletta, The New Yorker, June 25, 2012, pp. 36–41 at p. 38. 20. People may, in a broad sense, be said to be respected less for who or what they are than how difficult, expensive, worthy is that which they do. With no disrespect, how difficult is it for a relatively fit person to bag groceries in a supermarket? You don't need four years of college education to do that kind of a job. What we tend to respect, in terms of status, is the cost of the endeavor to acquire the recognition of the capability to do particular kinds of work. Someone, somewhere certifies you, and as a result, you enjoy an enhanced status, you are defined (a) by what you do, and (b) individually, by how well you do it. A cautionary tale, here. A distinguished professor of criminology (her books have gone into double digits in their editions) lived in a very upscale community, but being a somewhat private person, she was not widely known for such by those among whom she lived. One day she received a misdirected item by mail courtesy of USPS. She was wearing an unprepossessing garb, but without thinking and with the very best of intentions she hastened to take the package to its proper intended destination. At the front door of the premises to which she had gone to deliver the item, this person of considerable status was greeted by a “common” maid servant, who ordered her rudely to the rear entrance. Respect, like beauty is often in the eye of the beholder! 21. Whether we are talking Walsingham, Talleyrand, Thurloe, Trepper or a host of others, all are distinguished, and appreciated for the quality of their product. Institutions per se do not deliver unique, usable intelligence for decision-makers. The product is the work of singularly gifted (and devoted) human beings. Israeli politicians have long employed their own, private Mossad. Sometimes, as with medical conditions, you just feel it advisable to seek a second opinion. 22. Americans hold curious, but in the main, sustainable beliefs about the efficiency of private enterprise versus that which is run by government. Curious, because the whole edifice rests upon what one believes offers the greatest incentives to those engaged in the endeavor. Some institutions cannot, sensibly, be privatized, while others can and should be; USPS offers a prime example. Aviation security was not noticeably improved by being taken over at U.S. airports by a Federal government service. The objectives could by different methods have been more efficiently attained and in less costly fashion. But could you, sensibly, envisage a private IRS—yes, you_Mr. Paul? Corruption can affect any government service, given certain conditions, for example, Prohibition. You don't need to see Lawless to fathom why. 23. See, on this, the fascinating account by Nick Paumgarten, “The World of Surveillance: Here's Looking at You,” The New Yorker, May 14, 2012, pp. 40–59. Another cute New Yorker cartoon shows two kids by a park lake; one is controlling a model yacht electronically and looking with shocked amazement at the other, controlling an overflying, huge drone, September 10, 2012, p. 84. You can't beat that for topicality. 24. An interesting security versus privacy issue arose out of the Monica Lewinsky–Bill Clinton “affair,” the full implications of which have never been resolved or even explored in satisfactory depth. See, “… even Presidents have private lives,” H. H. A. (Tony) Cooper, Intersec, Vol. 8, Issue 7, September 1998, pp. 354–355. 25. The unalienable rights emphatically spelled out in the Second Paragraph of the United States of America Declaration of Independence, July 4, 1776. 26. Technological applications of science are making it ever easier to steal information, some of it of great consequence for the regular workings of modern society. As in all forms of warfare, there is a constant struggle to devise more powerful and efficient weapons and the construction and emplacement of defensive devices to secure from harm that which is at risk. This would be a much more uneven struggle were it not for the efforts of private security from which even those who are not direct contributors benefit. 27. See, on this generally, Business Intelligence: A Primer, H. H. A. Cooper, Executive Protection Institute, Berryville, VA, 1996. 28. For many years conventional private security agencies have been far too slow to get into the business of protecting the virtual environment. The “hacking community” was generationally and technologically far ahead. The gap is now closing, but the two cultures are still, on careful appraisal, far apart. Thus the protection of information has developed more as a separate discipline than as a component of the old-line security industry. This is not healthy and gives distinct advantages to the “bad guys.” See, on this “Machine Politics,” The New Yorker, May 7, 2012, David Kushner, pp. 24–30 regarding the hacking of Sony, and its “thought to have been impregnable defenses.” 29. This was even the case with some proprietary security departments where security directors often enough lacked the technical expertise of their IT specialist counterparts. This was most pronounced in businesses specializing in, at one time, the arcane area of information technology. A professional made an interesting point in his time. “Crooks, just like people in finance and entertainment, transact their business via phone and Telex. They travel by jet and use computers to do their bookkeeping whereas most cops still have to count on their fingers.” Fric-Frac, Albert Spaggiari, Boston, MA: Houghton Mifflin, 1979, p. 214. Only a slight change of wording is needed. 30. “Any man who has to ask about the upkeep of a yacht can't afford one,” attributed to J. P. Morgan. There are many who could not, realistically, afford the expense of even a relatively small yacht who, nevertheless spend a great deal on private security, especially if they can shunt the cost on to someone else, the taxpayer. Security is a deductible, business expense if it is found at law to be necessary. 31. The author was responsible for the very carefully calibrated entry in the Encyclopedia Americana, Grolier, 1972 at “Self-Defense at Law.” At her confirmation hearing, Justice Sotomayor was asked, point blank by Senator Coburn, R. OK, if there was a general right of self-defense. She gave what this author considered a rather unsatisfactory reply, thereby missing an excellent opportunity to confound her interrogator. 32. This officer maintains a symbolic presence, riding ahead of the Monarch at Coronation. The office has long been held and exercised by the Dymoke family on ceremonial occasions. 33. Much that has found its way into this article is the product of the author's many years of experience conducting evaluations and surveys of private security entities. Client confidentiality prevents the use of more specific identification, but there are still those around who may recognize themselves, and the service in question from the reference given. 34. Ostensibly, the NATO powers, though not all are participating, or doing so with particular enthusiasm. Future generations, left to bear the costs may well wonder whether from a security perspective the expense, as incurred, was worthwhile, or even necessary. See previous note 30. 35. Hamid Karzai was the puppet Pashtun, hand picked by the United States to serve as president during the long difficult years of the occupation. Corruption flourished under his rule, though it is difficult reviewing the choices to suggest anyone better suited to have served the interests of the United States and its allies. 36. It is to be devoutly hoped that the obvious business opportunity afforded by the hoped for 2014 exit will be firmly eschewed by any responsible U.S. private security entity. Rudyard Kipling, who knew that part of the world very well, wrote, “Let us admit it fairly, as a business people should, We have had no end of a lesson; it will do us no end of good.” Rudyard Kipling's Verse, New York, NY: Doubleday, 1940, p. 297. 37. Modern aviation security methods were the brainchild of the Third Reich. On this, see “The Aviation Security Business, U.S. Style,” H. H. A. (Tony) Cooper, INTERSEC, Vol. 8, Issue 11–12, November–December, 1998, pp. 457–460 at p. 459. The Hindenburg disaster, would certainly, after all these years, pay revisiting. It was the classic “inside job,” though on whose orders has never been clarified. This author's suspicion falls heavily on Air Marshal Goering, who saw the Zeppelin as a threat to the Luftwaffe. 38. In some cases, the reason for this was geography, while in others political factors, having to do with problems in the Islamic world predominated. Athens, Greece became a notorious hot spot. Yet, it is significant, in measuring the threat to note that carriers, including the more vulnerable continued to use these airports. 39. This was usually at the insistence of the nation state involved. Both Belgium and the Netherlands may be singled out for mention in this regard. This had, however, little unfavorable impact on the programs introduced by the most concerned carriers. 40. On his last trip to this UK airport in 2010, this author found certain security aspects unsatisfactory and was not in the least surprised to find an 11-year-old boy, unaccompanied, and apparently without ticketing or identity documents had evaded Continental-United security and been conveyed to foreign parts. This was clearly a predictable failure of supervision. Moreover, this airport has more than “one” final barrier to overcome. This is very disturbing in terms of lessons not learned. Incidentally, no one encountered by the author, including the airport police, had ever read INTERSEC. 41. See “Airport Insecurity,” Vanity Fair, June, 1997, referred to in “The Tale of the Little Grey Suitcase,” H. H. A. (Tony) Cooper, INTERSEC, Vol. 7, Issue 10, October, 1997, pp. 336–338 at p. 336. 42. The very fine American Airlines International Security program, developed, in-house, from a basis of the Israeli ICTS training did, indeed, provide specifically for such enquiry. Unfortunately, following the departure of Robert Crandall, the program was shortsightedly (over the strenuous objections of the director of security) allowed to go into decline, a trend that has never since been reversed. 43. In his testimony before the subcommittee on Criminal Laws and Procedures of the Committee on the Judiciary of the United States Senate 95th Congress, “The Terrorist and His Victim,” July 21, 1977, p. 12, this author made the point: “Terrorism is a clandestine activity. In the preparation stage none of this is revealed.” It is, accordingly, up to those engaged, at all levels, in the work of counter terrorism, to seek out in the most effective ways possible, those machinations that have not yet come to fruition. 44. For an amusing, revealing account by a professional journalist of just such an encounter, see Baghdad Without a Map and Other Misadventures in Arabia, Tony Horwitz, New York, NY: Dutton, 1991, pp. 212–213. “Anyone who flies the Israeli carrier, El Al, is subjected to interrogation by a corps of fingernail pullers in training, a kind of farm team for Mossad.” This is from a friend; heaven knows what someone less kindly disposed might write! 45. Or some three and a half trillion dollars if the far from exaggerated estimates of the distinguished economist, Joseph Stiglitz, are preferred. 46. The author is aware that he is, here, preaching to the choir. He does not expect to reach the indifferent general public through this Journal. It is the profession, the industry itself that must set about offering its correctives in the PR field. 47. See, on this, the charming The ABCs of Public Relations, Scriptographic Booklet by Channing L. Bete Co., South Deerfield, MA 01373, 1972–1982: “If you understand yourself better … it will help you understand others better,” p. 11. 48. A classic film about a failed bank robbery, a negotiation, and the denouement, from the late 1970s when the United States was plagued with a number of such occurrences. 49. A vocation is a calling, a strong, irresistible almost, impulse to seek and follow out a special career path and to devote one's entire energies and aspirations to that end. 50. See, “A Code Explodes,” Security, amid intense speculation over its source, the worm that has attacked Iran's nuclear facilities raises fears that we are in a dangerous new era of cyber-warfare, write James Blitz, Joseph Menn, and Daniel Domley, Financial Times, October 2–3, 2010, p. 7. 51. See, “Beware of the Dogs,” Burkhard Bilger, The New Yorker, February 27, 2012, pp. 47–57. 52. In the days and weeks following 9/11, a number of U.S. airports adopted this stratagem, the “final barrier” being the aircraft boarding door. It is difficult to judge how effective a deterrent this might have been, but it was most certainly a major passenger inconvenience. 53. The effective heads of departments of security are not uniformly titled. “Director” carries with it a certain prestige that is sometimes deliberately denied the office holder. Manager of security, as a title tells its own story. How people and entities are designated is important. In some states the police entity is called, simply, State Police, in others it is the Department of Public Safety, while in others the same functions are vested in the Highway Patrol. The Chief of Police of one department may well be the Superintendent or Commissioner of another. 54. “Getting pleasure from the fear of others is something most of us cannot relate to,” The Gift of Fear, Gavin De Becker, Boston, MA, Little Brown, 1997, p. 81. A good friend served as director of security for a major North American bank during a very trying time. He was A VP and did sterling work on behalf of his colleagues at all levels. Yet, when he attended management meetings, his arrival was invariably greeted, sotto voce with, “Watch out, here comes the Gestapo.” The efforts of the Gestapo saved many of those self-same executives from being kidnapped. 55. There is a divergence of opinions on the derivation of COP as referring to a police officer. For some it is thought to have derived from Chief of Police while others assert its provenance as Constable on Patrol. Others see a relationship, somewhat more removed, with the expression to cop a plea and its variants. 56. Before 9/11, this frequent traveler always carried a Damascus bladed knife that he employed during long hours aboard various aircraft doing surgery on many magazines and newspapers he would collect en route. His classes benefited from these exertions. Tearing out the materials with the bare hands and trimming them later did not give quite the same satisfaction. 57. Safety razors and nail clippers were among the items so often rudely seized (and purloined). These searches and seizures did little to enhance the image of private security for those exposed to them. Most passengers were soon resigned to the indignities rather than risk missing their flights. Yet, for all this, dangerous items still got on board aircraft. First class passengers, that is, those closest to the cockpit were usually still served with metallic tableware even at the height of the 9/11 crisis. 58. Many years ago, this author, already deeply engaged in the “new” security problems posed by terrorism, frequently traveled the air ways, accompanied by his cat, Farley (until that feline went off to live at North Mountain Pines—there's a name to conjure up security memories for some). The author, being too “chintzy” to purchase a regular cat carrier, always availed himself of that furnished by the carrier. On the occasion to which this tale is germane, he (with his burden) was greeted by a charming, elderly lady screener who politely asked to be allowed to examine the package. She opened the box and faced down this rather fearsome feline, who was accustomed to being mistaken for Morris, of the then popular commercial. “May I move him to one side?” she enquired. She then repeated the maneuver. In an almost confidential whisper, she said, “I have to do this to make sure there isn't a weapon in there, he is lying on.” I said to her, “You take your job very seriously, so permit me to show you something that may help you in the future.” I removed Farley (who probably thought that was a very short flight!) and showed her the false bottom of the box (hygiene!) and demonstrated how easily a large handgun might have been concealed there. Make of this what you will, it is of universal application. 59. This author was always punctilious about placing his knife in the receptacle provided. Sometimes its manifest quality evoked admiring comment on the part of the screener, but there was never an inquiry as to the purpose of this sharp instrument being carried on board. The purpose (see note 56), was hardly so obvious that enquiry would have been otiose. 60. This focus was brought about, in the main, as a result of the downing of Pan Am 103, The Maid of the Seas. That disaster was simply a wake-up call and as the disaster was of the Hindenburg variety (see note 37), this redirection would not have caught the offending artifact. On Pan Am 103, see Terrorism and Espionage in the Middle East. Deception, Displacement and Denial, H. H. A. Cooper and Lawrence J. Redlinger, Lewiston, NY: The Edwin Mellen Press, 2005, p. 773, and pp. 479–597. See, too, “The Unasked Questions about Pan Am 103,” H. H. A. Cooper, Vol. 5, Tactical Response, No. 2 Spring–Summer 1993, pp. 19–38. 61. See, on this A Short Typology of Skyjackers, H. H. A. Cooper, Gaithersburg, MD; International Association of Chiefs of Police, 1981, at p. 5 Dynamics: The Why of Skyjacking, “Thus aircraft are seized, in the air or on the ground … (IV) for use as a missile.” Active countermeasures were initiated by Israel as early as 1973, when a Libyan aircraft suspected of being used as a missile was shot down, as a precaution, over the Sinai. In 1974, also a scheme titled Operation Pandora's Box was hatched by a failed U.S. businessman, who had conceived a singular hatred for Richard M. Nixon. He seized an aircraft on the ground at BWI after killing an airport police office and wounding the copilot. He intended to crash the aircraft on the White House. See, Murderpedia.org and various other sources. 62. See, Perfect Soldiers, the 9/11 Hijackers, Who They Were, Why They Did It, Terry McDermott, New York, NY: Harper Collins, 2005. 63. Perhaps the most valuable account is by that versatile, talented scholar, Judge Richard A. Posner, Preventing Surprise Attacks: Intelligence Reform in the Wake of 9/11, New York, NY: Rowman and Littlefield, Inc., 2005. 64. The excellent, groundbreaking (for an American carrier) security program was initiated by Robert Crandall, when American Airlines began to expand internationally. Directed by Homer Boynton and managed by David Divan, the program was very expensive and was essentially restricted to international routes, for largely logistical reasons. This weakness was observed and exploited by those who conceived the 9/11 plot. It is for this reason that domestic, long-haul flights were targeted rather than the international with their more stringent security provisions. See, too, H. H. A. (Tony) Cooper, Aviation Security Post 9/11: Perceptions of the Frequent Flyer, INTERSEC, Vol. 13, Issue 4, 2003, pp. 132–133 at p. 132: It is indisputa