Smith v. Cabot Creamery Cooperative, Inc. et al

Filing 38

Order by Hon. Samuel Conti granting 22 Motion to Dismiss with prejudice.(sclc2, COURT STAFF) (Filed on 2/25/2013)

1
2
3
4
5
6

IN THE UNITED STATES DISTRICT COURT

7

FOR THE NORTHERN DISTRICT OF CALIFORNIA

8
9

United States District Court

For the Northern District of California

10
11
12
13
14
15
16
17

) Case No. 12-4591 SC
)
TIMOTHY SMITH, ROHIT FEDANE,
) ORDER GRANTING
and MISTY JOHNSON, individually ) MOTION TO DISMISS
and on behalf of all others
)
similarly situated,
)
)
Plaintiffs,
)
v.
)
)
CABOT CREAMERY COOPERATIVE, INC. )
and AGRI-MARK, INC.,
)
)
Defendants.
)
)
)

18
19
20

I.

INTRODUCTION
Plaintiffs Timothy Smith, Rohit Fedane, and Misty Johnson

21

("Plaintiffs") filed a putative class action lawsuit against

22

Defendants Cabot Creamery Cooperative, Inc. ("Cabot") and its

23

parent Agri-Mark, Inc. ("Defendants"), asserting a variety of

24

statutory and common law claims.

25

claims are all based on the core allegation that Defendants' yogurt

26

product, which Plaintiffs purchased, was misbranded under federal

27

food regulations.

28

Defendants' motion to dismiss Plaintiffs' FAC.

See id. ¶¶ 1-6.

ECF No. 16 ("FAC").

Plaintiffs'

Now before the Court is
ECF No. 22 ("MTD").

1

The motion is fully briefed,

ECF Nos. 27 ("Opp'n"), 32 ("Reply"),

2

and suitable for decision without oral argument, Civ. L.R. 7-1(b).

3

For the reasons discussed below, Defendants' motion is GRANTED, and

4

Plaintiffs' claims are DISMISSED WITH PREJUDICE.

5
6

II.

BACKGROUND
Yogurt is a dairy product made by combining milk with certain

7
8

food-grade bacteria.

FAC ¶¶ 16-18.

The bacteria ferment the

9

milk's lactose to produce lactic acid.

Id.

This fermentation

United States District Court

For the Northern District of California

10

process causes the milk to coagulate and thicken into a liquid-

11

solid mixture.

12

solid portions of the yogurt manufacturing process, while Greek

13

yogurt keeps only the solid.

14

thicker, higher in protein, and lower in sugar than regular yogurt.

15

Id. ¶ 20.

16

Id. ¶ 5.

Id.

"Regular" yogurt maintains both the liquid and

Id. ¶¶ 19-20.

As a result it is

It also tends to be more expensive than regular yogurt.

Cabot markets "Cabot Greek," the product at issue in the

17
18

instant matter, as "Greek-Style YOGURT."

19

contains whey protein concentrate ("WPC") and milk protein

20

concentrate ("MPC").

21

protein powders that are essentially byproducts of cheese

22

manufacturing.

23

whey protein, it is WPC.

24

proteins in the same proportion as they appear in cow's milk, it is

25

MPC.

26

material" to thicken Cabot Greek and increase its protein content,

27

instead of making Greek yogurt the "authentic" way, which involves

28

filtering the liquid whey byproduct during the manufacturing

Id.

Id. ¶ 26.

Id. ¶ 28.

Id. ¶ 22.

Cabot Greek

WPC and MPC are concentrated

If the protein powder contains mostly
Id. ¶ 29.

If it contains whey and casein

Plaintiffs allege that Cabot uses WPC and MPC as "filler

2

1

process and keeping only the protein-rich solid portion.

2

2, 20-21, 27-29, 32.

3

Id. ¶¶ 1-

Plaintiffs are all consumers who purchased Cabot Greek

4

believing it to be yogurt.

FAC ¶ 6.

5

problem with Cabot Greek's manufacturing process arises from the

6

Food and Drug Administration's ("FDA") strict guidelines, called

7

Standards of Identity ("SOI(s)"), which define what may legally be

8

called "yogurt."

9

is not "yogurt" under FDA regulations and the Food, Drug, and

Id. ¶¶ 37-40.

According to Plaintiffs, the

Plaintiffs allege that Cabot Greek

United States District Court

For the Northern District of California

10

Cosmetic Act ("FDCA"), 21 U.S.C. § 341, because it contains MPC and

11

WPC, which Plaintiffs claims the FDA forbids as ingredients in

12

yogurt.

13

branding misled them into believing that they were purchasing

14

genuine Greek yogurt and thereby paying a premium for it, which

15

they would not have done if it were not so branded.

16

6, 36.

17

Id. ¶¶ 35-36, 43-44.

Plaintiffs allege that Cabot's

See id. ¶¶ 5-

Per these allegations, Plaintiffs bring the following causes

18

of action against Cabot: (1) breach of express warranty; (2) breach

19

of the implied warranty of merchantability; (3) breach of the

20

implied warranty of fitness for a particular purpose; (4) unjust

21

enrichment; (5) violation of California's Consumer Legal Remedies

22

Act ("CLRA"), Cal. Civ. Code sections 1751 et seq.; (6) violation

23

of California's Unfair Competition Law ("UCL"), Cal. Bus. & Prof.

24

Code sections 17200 et seq.; (7) violation of California's False

25

Advertising Law ("FAL"), Cal. Bus. & Prof. Code sections 17500 et

26

seq.; (8) negligent misrepresentation; and (9) fraud.

27
28

Defendants now move to dismiss Plaintiffs' FAC, arguing
primarily that the FDA permits the addition of MPC and WPC to

3

1

yogurt, thereby rendering all of Plaintiffs' claims baseless

2

because they are predicated on the FDA's purported prohibition of

3

those ingredients.

MTD at 6-15.1

4
5

III. LEGAL STANDARD
A motion to dismiss under Federal Rule of Civil Procedure

6

Block, 250 F.3d 729, 732 (9th Cir. 2001).

9

on the lack of a cognizable legal theory or the absence of

10

United States District Court

12(b)(6) "tests the legal sufficiency of a claim."

8

For the Northern District of California

7

Navarro v.

sufficient facts alleged under a cognizable legal theory."

11

Balistreri v. Pacifica Police Dep't, 901 F.2d 696, 699 (9th Cir.

12

1988).

13

should assume their veracity and then determine whether they

14

plausibly give rise to an entitlement to relief."

15

Iqbal, 556 U.S. 662, 679 (2009).

16

must accept as true all of the allegations contained in a complaint

17

is inapplicable to legal conclusions.

18

elements of a cause of action, supported by mere conclusory

19

statements, do not suffice."

20

Twombly, 550 U.S. 544, 555 (2007)).

21

"limited to the complaint, materials incorporated into the

22

complaint by reference, and matters of which the court may take

23

judicial notice."

24

(9th Cir. 2005).

25

///

"Dismissal can be based

"When there are well-pleaded factual allegations, a court

Ashcroft v.

However, "the tenet that a court

Threadbare recitals of the

Id. (citing Bell Atl. Corp. v.
A court's review is generally

See Kourtis v. Cameron, 419 F.3d 989, 994 n.2

26
27
28

1

Defendants assert a variety of other grounds for the FAC's
dismissal, MTD at 15-18, but since the Court resolves the instant
matter on Defendants' main argument, the Court need not and does
not address Defendants' remaining arguments.
4

1

IV.

DISCUSSION
The parties' dispute is ultimately based on one predicate

2
3

issue: whether FDA regulations forbid cultured dairy products

4

containing WPC and MPC from being called "yogurt."

5

they do.

6

all of Plaintiffs' claims are premised on the FDA forbidding the

7

addition of WPC and MPC to yogurt, all of Plaintiffs' claims fail.

8

Defendants say they do not.

A.

Plaintiffs say

Defendants are right.

The Relevant FDA Regulations

The FDA promulgated its first SOIs for yogurt in 1981.

9
10

United States District Court

For the Northern District of California

Since

C.F.R. §§ 131.200 (yogurt), 131.203 (lowfat yogurt), 131.206

11

(nonfat yogurt).

12

Fed. Reg. 9924; 47 Fed. Reg. 41519.

21

46

The yogurt SOI specifies:

Yogurt is the food produced by culturing one
or more of the optional dairy ingredients
specified in paragraph (c) of this section
with a characterizing bacterial culture that
contains the lactic acid-producing bacteria,
Lactobacillus bulgaricus and Streptococcus
thermophilus. One or more of the other
optional ingredients specified in paragraphs
(b) and (d) of this section may also be
added. When one or more of the ingredients
specified
in
paragraph
(d)(1)
of
this
section are used, they shall be included in
the culturing process. All ingredients used
are safe and suitable.

13
14
15
16
17
18
19
20
21

These SOIs became effective July 1, 1983.

21 C.F.R. § 131.200(a).

22

The "optional dairy ingredients" that may be cultured per

23

paragraph (c) of the yogurt SOI are "cream, milk, partially skimmed

24

milk, or skim milk, used alone or in combination."

25

131.200(c).

26

D.

27

optional ingredients," including (1) "[c]oncentrated skim milk,

28

nonfat dry milk, buttermilk, whey, lactose, lactalbumins,

Id. §

Paragraph (b) permits the addition of Vitamins A and

Id. § 131.200(b).

Paragraph (d) permits the addition of "other

5

1

lactoglobulins, or whey modified by partial or complete removal of

2

lactose and/or minerals . . . ," as well as (2) nutritive

3

carbohydrate sweeteners, (3) flavoring ingredients, (4) color

4

additives, and (5) stabilizers.

5

this list of other ingredients does not include MPC or WPC.

6

id. § 131.200(d)(1)-5).

7

(d)(1) of the SOI, and so despite being published that portion is

8

not in effect.

9

Fed. Reg. 41519-01 (Sept. 21, 1982) ("1982 Stay").

Id. § 131.200(d)(1)-(5).

Notably,
See

However, in 1982, the FDA stayed paragraph

Stay of Effective Date of Certain Provisions, 47

United States District Court

For the Northern District of California

10

Plaintiffs allege that the SOI for yogurt, absent the stayed

11

provision, "is an exclusive list of ingredients that may be added

12

to yogurt," and that "if 'yogurt' contains any ingredient not on

13

that list, as a matter of federal law it is not yogurt . . . ."

14

FAC ¶ 43.

15

not include WPC or MPC, those ingredients are prohibited.

16

44.

17

and is misbranded per FDA regulations and the FDCA.

18

36, 43-44.

19

claims.

20

116-120, 123-28, 131-33.

Plaintiffs further claim that since the yogurt SOI does
Id. ¶

Therefore, Plaintiffs aver, Cabot Greek is not yogurt at all
See id. ¶¶ 35-

This allegation is the basis for all of Plaintiffs'

See id. ¶¶ 68-70, 76-83, 86-89, 92-94, 97-102, 109-113,

21

Defendants' primary argument in moving to dismiss the FAC is

22

that Plaintiffs' claims all fail because the FDA actually permits

23

WPC and MPC as optional ingredients in yogurt.

24

argument, Defendants point to several FDA statements, made

25

consistently over the last thirty years, in which the agency has

26

interpreted the effect of the stay and the remaining parts of the

27

yogurt SOI.

28

In support of this

MTD at 6-11.

In 1982, the FDA stated, "[The FDA] is staying the effective

6

1

date of the provision[] of [§ 131.200(d)(1)] that restricts the

2

kinds of safe and suitable milk-derived ingredients that may be

3

used as optional ingredients to increase the nonfat solid contents

4

of [yogurts] . . . ."

5

this was the earliest date on which the FDA explained the effect of

6

the 1982 Stay, which was not -- as Plaintiffs allege -- to render

7

the remaining provisions of the yogurt SOI exclusive lists of

8

ingredients, but rather to remove a restriction on what could be

9

added to yogurt.

United States District Court

For the Northern District of California

Id.; see Reply at 2-3.

website, which included the following question and answer:
Q:
May whey protein concentrate (WPC)
and/or milk protein concentrate (MPC) be
used as ingredients in yogurt to increase
the nonfat solids content?

12
13
14

A:
Yes. 21 C.F.R. 131.200(d), which would
have precluded WPC or MPC use, was one of
several
provisions
of
the
standard
of
identity for yogurt that were stayed in
1982, 47 F.R. 41519, September 21, 1982.

15
16
17

NOTE: If WPC and MPC are used in Grade "A"
yogurt product, they must be Grade "A" and
come from an IMS Listed Source.

18
19
20

Defendants note that

In 2004, the FDA published a Memorandum of Information on its

10
11

1982 Stay at 41519.

ECF No. 33, ("RJN") Ex. A ("2004 Interpretation").2

21

In 2009, the FDA proposed amendments to the yogurt SOI.

22

Proposal to Revoke the Standards for Lowfat and Nonfat Yogurt and

23

to Amend the Standard for Yogurt, 74 Fed. Reg. 2443-02 (Jan. 15,

24

2009) ("2009 Proposal").

25

it had stayed parts of the yogurt SOI that "restricted the type of

In the 2009 Proposal, the FDA noted that

26
27
28

2

Defendants submitted a Request for Judicial Notice ("RJN"), ECF
No. 33, in support of their motion to dismiss. Plaintiffs do not
oppose the request and the documents contained in the RJN are
public records. The Court GRANTS Defendants' request and takes
judicial notice of the documents.
7

1

milk-derived ingredients that may be used to increase the nonfat

2

solids content of cultured milk and yogurts."

3

1982 Stay at 41523).

4

construction -- removal of a restriction rather than the narrowing

5

of an exclusive list -- that the FDA offered in 1982.

6

with 1982 Stay at 41519.

7

competing priorities and limited resources, FDA has not held a

8

public hearing to resolve these issues and the effective date for

9

these provisions remains stayed. Therefore, these provisions were

United States District Court

For the Northern District of California

10

never in effect."

12
13
14
15
16

18

Id.

As Defendants note, this was the same

Compare id.

The FDA elaborated, "To date, due to

Thus, the FDA concluded:

[C]ultured milk and yogurts may deviate from
the relevant standards in the previously
mentioned respects. For example, although
the current standards do not permit the use
of certain ingredients such as preservatives
or a reconstituted dairy ingredient as a
basic ingredient, because of the stayed
provisions, FDA has not taken enforcement
action against the use of these ingredients
in yogurt, lowfat yogurt, or nonfat yogurt.

11

17

Id. at 2444 (citing

Id.
Defendants claim that these express statements are controlling

19

interpretations of the FDA's own regulations, thereby clarifying

20

that WPC and MPC may lawfully be used as optional ingredients to

21

increase the nonfat solid content of yogurt, as Cabot did.

22

at 7-8, 10.

23

cases: PLIVA, Inc. v. Mensing, 131 S. Ct. 2567, 2575, reh'g denied,

24

132 S. Ct. 55 (2011), and Bassiri v. Xerox Corp., 463 F.3d 927, 930

25

(9th Cir. 2006).

26

See MTD

To support this point, Defendants rely mainly on two

In PLIVA, the parties disputed whether and to what extent

27

generic drug manufacturers could change their drugs' labels after

28

FDA approval.

131 S. Ct. at 2575.

8

The defendants argued that FDA

1

regulations allowed them to change their drugs' labels without

2

waiting for preapproval, which is ordinarily necessary when a drug

3

company changes a label, but the FDA interpreted its regulations to

4

bar changes without preapproval.

5

this issue that "[t]he FDA's views are 'controlling unless plainly

6

erroneous or inconsistent with the regulation[s] or there is any

7

other reason to doubt that they reflect the FDA's fair and

8

considered judgment.'"

9

452, 461, 462, (1997)).

United States District Court

For the Northern District of California

10

Id.

Id.

The Supreme Court held on

(quoting Auer v. Robbins, 519 U.S.

In Bassiri, the Ninth Circuit reviewed a district court's

11

decision to give deference to several Department of Labor letters

12

defining the term "normal compensation."

13

district court had given those letters deference under Skidmore v.

14

Swift & Co., 323 U.S. 134, 140 (1944), which sets the standard for

15

courts' deference to agency interpretations of statutes.

16

463 F.3d at 930.

17

Department of Labor was interpreting regulations, not statutes, the

18

district court should have applied the Supreme Court's rule from

19

Auer (the same rule the Supreme Court applied in PLIVA, 132 S. Ct.

20

at 2575), which is that "where an agency interprets its own

21

regulation, even if through an informal process, its interpretation

22

of an ambiguous regulation is controlling under Auer unless

23

'plainly erroneous or inconsistent with the regulation.'"

24

(quoting Auer, 519 U.S. at 461).

25

463 F.3d at 930.

The

Bassiri,

The Ninth Circuit held that because the

Id.

Plaintiffs do not grapple with these cases, but they attempt

26

to dull the effect of the FDA's 2004 Interpretation by arguing that

27

the source of the 2004 Interpretation -- a Q&A session at the 2004

28

Regional Milk Seminar -- renders the 2004 Interpretation merely

9

1

informal and, under Supreme Court precedent, "at most, informal

2

statements of policy," which Plaintiffs claim would not be binding

3

in the way a formal regulation would be.

4

Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc.,

5

467 U.S. 837 (1984)).

6

does not bar the Court from giving the FDA's clarifications

7

deference, and agencies are not bound to limit their pronouncements

8

to formal rulemaking, as the Supreme Court has made clear:

9

"[B]ecause agencies normally address problems in a detailed manner

Opp'n at 12-13 (citing

This distinction is not relevant.

Chevron

United States District Court

For the Northern District of California

10

and can speak through a variety of means, including regulations,

11

preambles, interpretative statements, and responses to comments, we

12

can expect that they will make their intentions clear if they

13

intend for their regulations to be exclusive."

14

v. Automated Med. Labs., 471 U.S. 707, 718 (1984).

15

further guidance: "Where an agency interprets its own regulation,

16

even if through an informal process, its interpretation of an

17

ambiguous regulation is controlling under Auer unless 'plainly

18

erroneous or inconsistent with the regulation.'"

19

2575 (quoting Auer, 519 U.S. at 461).

20

Hillsborough County
PLIVA provides

132 S. Ct. at

Defendants correctly note that the "informal comments" from

21

the meeting Plaintiffs mention were indeed formalized into a

22

Memorandum of Information from the FDA, directed to "All Regional

23

Food and Drug Directors."

24

comments far more compelling than Plaintiffs would suggest.

25

event, the FDA is permitted to clarify its regulations as it did in

26

the 2004 Interpretation, and those clarifications are entitled to

27

deference.

28

guidance from the 2004 Interpretation indicates that the FDA

2004 Interpretation.

See Hillsborough, 471 U.S. at 718.

10

This renders those
In any

Further, the FDA's

1

understands its own guidelines to allow WPC and MPC as optional

2

ingredients in yogurt.

3

Further, per Auer, the FDA's statements in 2004 and 2009 show

4

that it was interpreting its own ambiguous regulation regarding the

5

yogurt SOI.

6

completely unambiguous," Opp'n at 12, is plainly false given the

7

posture of this case.

8

such heated argument over the effects of the yogurt SOIs and the

9

FDA's interpretation of them if the yogurt SOIs on their own were

Plaintiffs' contention that "the regulations are

The parties would likely not be engaged in

United States District Court

For the Northern District of California

10

as easy to interpret as Plaintiffs claim.

11

is ambiguous by definition because the FDA's stay of the "optional

12

ingredients" provision could suggest either that "optional

13

ingredients" are excluded entirely from the yogurt SOI, or

14

potentially included by virtue of the stay.

15

Moreover, the regulation

The FDA clarified in the 2004 Interpretation and the 2009

16

Proposal that though it has not made a definitive ruling on the

17

subject, it considers WPC and MPC acceptable optional ingredients

18

in yogurt.

19

statements from the FDA about its own regulations.

20

therefore finds that MPC and WPC are permissible optional

21

ingredients in yogurt under FDA regulations.

22

all fail because they are premised on the argument that those

23

ingredients are impermissible.

24

GRANTED for these reasons.

25
26

These interpretations are entitled to deference, being

B.

The Court

Plaintiffs' claims

Defendants' motion to dismiss is

Plaintiffs' Other Arguments

Plaintiffs provide four additional arguments for why the FDA

27

regulations do not actually allow WPC or MPC in yogurt.

28

arguments are all unconvincing on their own.

11

These

First, Plaintiffs argue that the FDA has unambiguously stated

1
2

that WPC and MPC are forbidden in yogurt.

3

statements to which Plaintiffs refer actually concern the FDA's

4

clarification that WPC and MPC are not allowed as basic ingredients

5

in yogurt.

6

Defendants' argument is that the FDA permits WPC and MPC as

7

optional ingredients, which is how they are used in Cabot Greek.

8

The two categories of ingredients, basic and optional, are

9

factually and legally different and should not be conflated.3

United States District Court

The

This is irrelevant.

Second, Plaintiffs' argument that the 1982 Stay renders the

10
For the Northern District of California

See 2009 Proposal at 2452-53.

Opp'n at 10-13.

11

yogurt SOI an "exclusive list" of acceptable ingredients fails

12

because the FDA, as discussed in Section IV.A supra, has stated

13

otherwise, and its interpretation of its regulation is binding.

14

Further, Plaintiffs' authority here is inapposite.

15

on the following language from the Supreme Court's decision in

16

Federal Security Administrator v. Quaker Oats Co., 318 U.S. 218,

17

232 (1943): "The announcements promulgating [the SOIs in question]

18

stated that they were so framed as to exclude substances not

19

mentioned in the definition."

20

actually undermines Plaintiffs' position.

21

that substances not mentioned in the yogurt SOIs were excluded from

Opp'n at 6.

Plaintiffs rely

But this language
The FDA never stated

22
23
24
25
26
27
28

3

In support of their argument on this point, Plaintiffs also cite
FDA statements regarding "cheese food" products, in which the FDA
stated clearly that MPC cannot be added to "cheese foods" as an
optional ingredient. FAC ¶ 45. These statements are irrelevant to
the instant matter. Cheese foods and yogurt have different SOIs,
and the FDA's statements on one should not be taken to apply to the
other. Plaintiffs disagree, claiming that the FDA explained that
its findings on WPC and yogurt were "consistent with the agency's
recent tentative decision not to permit [MPC] as a basic ingredient
in standardized cheese," but that quotation concerned basic
ingredients, not optional ingredients, and as the Court has noted,
the two categories are not to be conflated. See Opp'n at 12
(citing 2009 Proposal at 2452-53).
12

1

yogurt.

As discussed in Section IV.A supra, it did the opposite.

2

Further, the SOIs in question in Quaker Oats specifically forbade

3

the food producer in that case from using the certain ingredients

4

in the product it produced.

5

That is not the issue here.

See Quaker Oats, 318 U.S. at 220-23.

Third, Plaintiffs argue that the FDA's failure to enact any

6
7

rules explicitly permitting WPC and MPC in yogurt from the 2009

8

Proposal means that the FDA meant to indicate that WPC and MPC had

9

always been prohibited in yogurt.

See Opp'n at 11.

This is

United States District Court

For the Northern District of California

10

unconvincing.

The FDA had interpreted its regulations to permit

11

WPC and MPC in yogurt in 1982 and 2004, and even in the 2009

12

Proposal itself.

13

supra (discussing the 2009 Proposal).

14

a section of the 2009 Proposal in which the FDA clarifies that WPC

15

and MPC are forbidden as basic ingredients, an argument the Court

16

rejected above.

17

Association] requested that FDA revise the yogurt standards to

18

allow the use of [WPC] as a basic ingredient . . . .") (citing 2009

19

Proposal at 2452-53) (emphasis added).

20

nothing at all about optional ingredients.

See 2009 Proposal at 2444; see also Section IV.A,
Plaintiffs misleadingly cite

See Opp'n at 11 ("[The National Yogurt

But this section says

Finally, Plaintiffs allege that WPC and MPC render Cabot Greek

21
22

"adulterated" because they are food additives, and moreover, are

23

not Generally Recognized as Safe ("GRAS"), thereby violating the

24

FDCA.

25

has stated specifically that MPC and WPC are permissible optional

26

ingredients in yogurt.

27

clearly if that same permissible addition would render the yogurt

28

illegally adulterated.

FAC ¶¶ 46-51.

This argument is also unavailing.

The FDA

It would not have made this statement so

13

1
2

V.

CONCLUSION
For the reasons discussed above, the Court GRANTS Defendants

3

Cabot Creamery Cooperative, Inc. and Agri-Mark, Inc.'s motion to

4

dismiss Plaintiffs Timothy Smith, Rohit Fedane, and Misty Johnson's

5

first amended complaint.

6

PREJUDICE.

Plaintiffs' complaint is DISMISSED WITH

7
8

IT IS SO ORDERED.

9

United States District Court

For the Northern District of California

10

25
Dated: February ___, 2013

11

UNITED STATES DISTRICT JUDGE

12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

14