ROMAN v. LEGGETT AND PLATT INC

Filing 46

ORDER granting 25 Motion for Summary Judgment. Ordered by US DISTRICT JUDGE CLAY D LAND on 11/03/2015. (CGC)

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF GEORGIA
ATHENS DIVISION
JOSE ROMAN,

*

Plaintiff,

*

vs.

*

LEGGETT AND PLATT, INC.,

*

Defendant.

CASE NO. 3:14-CV-20 (CDL)

*
O R D E R

Plaintiff
during

a

Jose

random

Roman

drug

tested

screening

positive

for

conducted

Defendant Leggett and Platt, Inc.

phenobarbital

by

his

employer,

Upon confirming the positive

result, Leggett terminated Roman’s employment consistent with
its policy.

Roman does not seriously dispute that his test

showed a positive result, but he argues that it was likely a
false positive or due to some reason other than his ingestion of
non-prescription
may

quarrel

drugs containing phenobarbital.

with

the

test

results

and

While Roman

his

subsequent

termination, he points to no evidence to support his claim under
the

Americans

with

Disabilities

because of his epilepsy.

Act

that

he

was

discharged

Specifically, he fails to create a

genuine factual dispute on the issue of whether Leggett’s stated
reason

for

terminating

him,

the

positive

drug

test,

was

a

pretext for disability discrimination.

Accordingly, Leggett’s

motion for summary judgment (ECF No. 25) is granted.
SUMMARY JUDGMENT STANDARD
Summary judgment may be granted only “if the movant shows
that there is no genuine dispute as to any material fact and the
movant is entitled to judgment as a matter of law.”
Civ. P. 56(a).

In determining whether a

genuine

Fed. R.

dispute of

material fact exists to defeat a motion for summary judgment,
the evidence is viewed in the light most favorable to the party
opposing summary judgment, drawing all justifiable inferences in
the opposing party’s favor.
477 U.S. 242, 255 (1986).

Anderson v. Liberty Lobby, Inc.,
A fact is material if it is relevant

or necessary to the outcome of the suit.

Id. at 248.

A factual

dispute is genuine if the evidence would allow a reasonable jury
to return a verdict for the nonmoving party.

Id.

FACTUAL BACKGROUND
Viewed in the light most favorable to Roman, the record
reveals the following.

Roman worked on the production floor of

Leggett’s mattress innerspring manufacturing facility in Monroe,
Georgia.

Leggett had a substance abuse policy that prohibited

employees from working with “unacceptable levels of drugs or
alcohol in their systems”

because “[t]he

abuse of drugs and

alcohol can cause a serious threat to a safe and productive work
environment.”

Roman Dep. Ex. 6, Substance Abuse Policy, ECF No.

2

28-1 at 68.

The policy also prohibits “abuse or improper use of

prescription or over-the-counter drugs.”

Id.

An employee who

violates the substance abuse policy is “subject to immediate and
severe disciplinary action, up to and including termination of
employment for the first offense.”

Id.

Roman was aware of the

substance abuse policy and knew that failing a drug test could
result in his termination.
Leggett considered Roman’s position to be safety sensitive.
Employees working safety sensitive positions were subjected to
random drug screenings “to determine the possible presence of
substances

of

abuse.”

Id.

Clinical

Reference

Laboratory

analyzes the random drug screen samples of Leggett employees and
reports the results to Leggett.

Clinical’s analysis is designed

to test for the presence of substances in the employee’s body in
an amount above a “cutoff level.”
were

tested

detectable
ingestion.

for
in

a

the

presence

person’s

of

system

In 2011, Leggett employees
barbiturates,
for

at

least

which
a

remains

week

after

The cutoff level used by Clinical for barbiturates

in oral fluid samples is twenty nanograms per milliliter (20
ng/mL).

Irving Dep. 20:3-13, ECF No. 36.

That is the level

Clinical and several other major testing laboratories usually
set as the cutoff level for barbiturates unless the employer
requests a different cutoff level.
If

Id. at 17:1-12, 54:19-55:3.

Clinical’s first test of an employee’s

3

oral

fluid sample

detects a substance in an amount above the cutoff level, then
Clinical runs a secondary confirmation test on the sample.

If

the confirmation test detects a substance in an amount above the
cutoff level, then Clinical reports a positive test result to
the employer.
Clinical
employees

reports

to

Jenny

coordinator.

any

positive

Madsen,

test

results

Leggett’s

for

employee

Leggett

relations

Madsen then contacts the human resource manager at

the employee’s branch to report the positive result.

In 2011,

the human resource manager at Leggett’s Monroe facility was Mick
Crain.

When Crain is notified of a positive test result, he

removes the employee from the production floor and notifies the
employee

of

the

test

results.

The

employee

is

given

an

opportunity to show Leggett that the result should be excused by
producing

information

medication.
result
caused

the

employee’s

prescription

If the employee cannot convince Leggett that the

should
by

about

be

a

excused

(for

medication

for

example,
which

as
the

a

false

employee

prescription), then the employee is terminated.

positive
has

a

Altman Dep.

134:19-135:18, ECF No. 34.
Roman

and

other

employees

working

in

safety

sensitive

positions of Leggett’s Monroe facility were subjected to random
drug screenings.

Each month, a random sample of employees was

tested for drugs.

Roman was selected for the random drug screen

4

in January 2011.
based

on

cutoff

an

oral

level

negative.

The drug test, conducted by Clinical, was

of

swab
20

and

tested

ng/mL.

for

Roman’s

barbituates
January

above

the

test

was

2011

Roman was selected for the random drug screen on

September 7, 2011.

Again, Clinical conducted the drug test,

which was based on an oral swab.

This time, however, Roman’s

sample tested positive for phenobarbital, a barbiturate, with a
concentration of 44 ng/mL.

During the timeframe relevant to

this action—in both January 2011 and September 2011—Roman took
Dilantin to treat his epilepsy, and his dosage did not change.
He also took methotrexate to treat rheumatoid arthritis.
Clinical reported Roman’s positive test result to Madsen,
who reported the result to Crain.

She told Crain that if Roman

contested the positive result, Crain should collect information
regarding Roman’s prescription medications.

When Roman reported

to work on September 14, 2011, Crain told him that his drug test
had come back positive and that he could not work that day.
Roman requested a copy of his test results and told Crain that
he would come back the next day with his prescription medication
information.
Roman returned to Crain on September 15, 2011 and showed
him several prescription bottles.
down

the

medication

name

of

each

Dilantin,

and

Crain or his assistant wrote

prescription,
faxed

5

the

including

list

to

the

Madsen.

epilepsy
It

is

undisputed that no one at Leggett knew that Roman had epilepsy
until Roman disclosed that he took Dilantin.

Madsen sent the

list to Clinical, whose certifying scientists were not able to
verify that any of Roman’s medications could have caused the
positive test result.1

Madsen Decl. ¶ 18, ECF No. 31-1.

Madsen

relayed the information to Michael Altman, Leggett’s director of
labor relations.
Roman

was

possible.

a

Altman spoke with Crain, who told Altman that

valuable

employee

who

should

be

retained

if

Altman told Crain that none of Roman’s prescription

medications explained the positive result, and Altman said that
if

Roman

could

not

provide

an

adequate

explanation

positive drug test, he would be terminated.
13.

for

the

Altman Dep. 73:6-

Crain, in turn, told Roman that none of his prescription

medications explained the positive result.

Roman said he had

additional information and would give it to Crain.
Roman’s

daughter

found

information

on

the

internet

suggesting that Roman’s epilepsy medication, Dilantin, may cause
false positives in drug tests, and Roman contacted his primary
care

physician,

Dr.

Suzanne

Lester,

1

to

investigate

the

Roman contends that this fact is disputed by pointing to a
communication between Madsen and Clinical’s toxicology director, who
stated that he did not see “any medications in [Roman’s] record that
will cause a positive phenobarbital” and that “Dilantin will not cause
a positive for phenobarbital.” Pl.’s Mot. for Summ. J. Ex. 25, Email
from John Irving to Jenny Madsen (Sept. 27, 2011), ECF No. 32-21.
This evidence does not refute Madsen’s statement that Clinical’s
certifying scientists could not verify that Dilantin could cause a
false positive for barbiturates.

6

possibility that one of his medications caused a false positive.
Dr. Lester wrote a letter stating: “It is my understanding that
in

some

cases

Dilantin

or

of

drug

Phenytoin

screening
may

give

that
a

Barbiturates and Phenobarbital.”

the

False

prescription

Positive

result

drug
for

Crain Dep. Ex. 18, Letter from

Dr. Suzanne Lester (Sept. 27, 2011), ECF No. 35-18.

She also

stated that Roman was taking Dilantin and suggested “further
testing

to

differentiate

Phenytoin/Dilantin.”2

Id.

between

Phenobarbital

and

Roman presented the letter to Crain

on September 27, 2011—nearly three weeks after his original drug
test.

Crain sent the letter to Altman.

At

that

point,

Madsen

sought

toxicology director, John Irving.

input

from

Clinical’s

She provided Irving with a

list of Roman’s medications—including Dilantin and methotrexate—
as well as a note from Roman’s doctor.

Madsen Decl. ¶¶ 20-21.

Irving responded that he did “not see any medications in the
donor’[s]
Pl.’s

record

Resp.

Ex.

that
25,

will
Email

cause
from

a

John

positive
Irving

(Sept. 27, 2011 at 3:57 PM), ECF No. 32-21.

phenobarbital.”
to

Jenny

He further stated,

“Dilantin will not cause a positive for phenobarbital.”
On

September

29,

2011—more

than

three

weeks

original drug test—Roman took two more drug tests.
2

Madsen

Id.
after

the

One of the

Roman admitted that he did not understand this issue; Dr. Lester
later told him that Dilantin would not cause a false positive for
barbiturates. Roman Dep. 110:4-19, ECF No. 28.

7

tests was negative for barbituates.

The other was positive for

barbiturates, although Dr. Jan Bennett, the doctor who reviewed
that drug screen and Roman’s medications, wrote that she was
“strongly convinced that a false positive could be obtained from
Keppra or methotrexate.”

Pl.’s Resp. Ex. 15, Note from Jan M.

Bennett,

2011,

D.O.,

Oct.

14,

ECF

No.

32-16.

There

is

no

evidence in the present record that Roman was taking Keppra at
the time of any of his drug screens.

See Pl.’s Resp. Ex. 6 at

LP 00038, Memo from Eric M. Pitts, M.D., Aug. 29, 2011, ECF No.
32-7 at 3 (noting that Roman “was unable to tolerate Keppra and
has

returned

to

Dilantin,

no

further

problems”).

evidence that Roman was taking methotrexate.

There

is

Pl.’s Resp. Ex.

25, Email from Jenny Madsen to John Irving (Sept. 27, 2011 at
2:21

PM),

ECF

No.

32-21.

Methotrexate

was

on

the

list

of

medications that Madsen initially gave to Irving, which Irving
reviewed and said that he did “not see any medications in the
donor’[s]
Pl.’s

record

Resp.

Ex.

that
25,

will
Email

cause
from

a

John

positive
Irving

phenobarbital.”
to

Jenny

Madsen

(Sept. 27, 2011 at 3:57 PM), ECF No. 32-21.
Altman did not consider the two additional drug tests and
did not send the results to Clinical because Altman was only
concerned about the results of the first drug test, which had
taken place more than three weeks earlier.
64:1.

Altman Dep. 63:12-

Altman also did not give any weight to Dr. Bennett’s

8

letter because “she is a medical doctor, not a clinical-drugtest analyst trained in the fingerprinting of drugs.”
67:22-68:3.
the field.

Id. at

Instead, Altman relied on Clinical’s expertise in
Id. at 68:3-6.

Roman did not provide any additional

documentation to explain the positive result from the September
7 drug test, and Leggett terminated him on October 18, 2011.
DISCUSSION
The
employers

Americans
from

with

Disabilities

discriminating

basis of disability.

against

Act
their

prohibits
employees

42 U.S.C. § 12112(a).

covered
on

the

To establish a

discrimination claim under the ADA, a plaintiff must prove that
he suffers from a disability, he is a qualified individual able
to perform the essential functions of his job, and his employer
unlawfully
disability.

discriminated

against

him

because

of

his

known

Earl v. Mervyns, Inc., 207 F.3d 1361, 1365 (11th

Cir. 2000) (per curiam).

Where, as here, there is no direct

evidence that the employer discriminated against the employee
because of his disability, the courts use the burden-shifting
framework established in McDonnell Douglas Corp. v. Green, 411
U.S. 792 (1973) and Texas Department of Community Affairs v.
Burdine, 450 U.S. 248 (1981).3

Earl, 207 F.3d at 1365.

3

Under

Roman suggests in a footnote of his brief that there is direct
evidence of disability discrimination in this case because Leggett
learned of Roman’s disability and terminated him even though Roman
contended that the September drug test result was a false positive.
Under Eleventh Circuit precedent, “‘only the most blatant remarks,

9

that framework, a plaintiff must establish a prima facie case of
disability

discrimination

by

showing

that

(1)

he

has

a

disability within the meaning of the ADA, (2) he is a qualified
individual, and (3) he was subjected to unlawful discrimination
because of his disability.
prima

facie

case,

nondiscriminatory

Id.

the

reason

If the plaintiff establishes a

employer
for

its

may

offer

decision.

a

legitimate

Chapman

Transp., 229 F.3d 1012, 1024 (11th Cir. 2000) (en banc).

v.

AI

If the

employer offers a legitimate nondiscriminatory reason for its
decision, the plaintiff must show that the proffered explanation
is pretext for discrimination.
proffer

sufficient

evidence

Id.
to

“If the plaintiff does not

create

a

genuine

issue

of

material fact regarding whether each of the defendant employer’s
articulated reasons is pretextual, the employer is entitled to
summary judgment on the plaintiff’s claim.”

Id. at 1024-25.

The Court assumes for purposes of summary judgment that
Roman

has

established

discrimination.

a

prima

facie

case

of

disability

It is undisputed that Roman has epilepsy, and

Leggett does not contest for purposes of the present motion that
epilepsy is considered a disability under the current version of

whose intent could be nothing other than to discriminate on the basis
of age’ will constitute direct evidence of discrimination.” Damon v.
Fleming Supermarkets of Fla., Inc., 196 F.3d 1354, 1359 (11th Cir.
1999) (quoting Earley v. Champion Int’l Corp., 907 F.2d 1077, 1081-82
(11th Cir. 1990)).
If there were evidence that Altman said, “Fire
Roman because he has epilepsy,” that would be direct evidence of
disability discrimination. But Roman pointed to no such evidence.

10

the

ADA.

“epilepsy

See

29

C.F.R. §

substantially

1630.2(j)(3)(iii)

limits”

“neurological function”).

the

major

life

(noting

that

activity

of

Leggett does not dispute that at the

time of his termination, Roman was adequately performing the
essential functions of his job.

And Leggett cannot seriously

dispute that it terminated Roman soon after learning that he was
taking prescription medication for epilepsy.
Leggett proffered a legitimate nondiscriminatory reason for
terminating Roman: Roman failed a random drug screen and tested
positive for phenobarbital.

So the dispositive issue is whether

Roman pointed to sufficient evidence to establish pretext by
showing that Leggett’s proffered “reason was false, and that
discrimination was the real reason.”
Hicks, 509 U.S. 502, 515 (1993).

St. Mary’s Honor Ctr. v.

“Provided that the proffered

reason is one that might motivate a reasonable employer, an
employee must meet that reason head on and rebut it, and the
employee cannot succeed by simply quarreling with the wisdom of
that reason.”
not

sit

as

Chapman, 229 F.3d at 1030.
a

super-personnel

department

Federal courts “do
that

reexamines

an

entity’s business decisions.” Elrod v. Sears, Roebuck & Co., 939
F.2d 1466, 1470 (11th Cir. 1991)

(quoting

Mechnig v. Sears,

Roebuck & Co., 864 F.2d 1359, 1365 (7th Cir. 1988)).

The key

question is “whether the employer gave an honest explanation of
its behavior.”

Id. (quoting Mechnig, 864 F.2d at 1365).

11

“The

inquiry into pretext centers upon the employer’s beliefs, and
not

the

employee’s

own

perceptions

of

his

performance.”

Holifield v. Reno, 115 F.3d 1555, 1565 (11th Cir. 1997) (per
curiam).
Roman
because

contends

he

did

that

not

Leggett’s

actually

fail

proffered

reason

his

test.

drug

is

false

But

the

undisputed evidence is that the drug test did come back with a
positive result for phenobarbital.
result was a false positive.4

Roman argues that the test

But, the relevant question for the

pretext inquiry is whether there is enough evidence to suggest
that Altman, the decisionmaker, did not honestly believe that
Roman

failed

to

provide

an

adequate

justification

for

his

positive September 7, 2011 drug test.
In determining whether he believed that Dilantin could have
caused

a

false

positive,

Altman

knew

that

(1)

Clinical’s

toxicology director unequivocally stated that Dilantin would not
cause

a

certifying

false

positive

scientists

for

could

phenobarbital,

not

verify

that

(2)
any

Clinical’s
of

Roman’s

medications (including Dilantin) could have caused the positive
test result, and (3) while Dr. Lester understood that Dilantin
might give a false positive for phenobarbital in some cases, Dr.
Bennett did not list Dilantin as a possible cause of Roman’s
4

The fact that he had a negative test result in January 2011 but a
positive test result in September despite taking the same medications
undercuts this argument.

12

positive test result.

And in determining whether he believed

that methotrexate could have caused a false positive, Altman
knew

that

(1)

Clinical’s

toxicology

director

unequivocally

stated that none of Roman’s medications (including methotrexate)
would cause a false positive for phenobarbital, (2) Clinical’s
certifying
medications

scientists

could

(including

not

verify

methotrexate)

that

could

any
have

of

Roman’s

caused

the

positive test result, and 3) Dr. Bennett listed methotrexate as
a possible cause of Roman’s positive test result (though Dr.
Lester did not).
In

summary,

Altman

received

conflicting

information

on

whether two of Roman’s medications could have caused a false
positive.
perform

The

scientists

Leggett’s

drug

at

tests

the

company

explicitly

Altman

stated

trusted

that

to

Roman’s

medications would not cause a false positive for barbiturates.
On the other hand, Altman received letters from two doctors,
each of whom suggested that one of Roman’s medications might
cause a false positive.

But the two doctors did not point to

the same medication as the culprit—so Roman’s own submissions to
Leggett were in conflict.

Based on this evidence, it was not

unreasonable for Altman to conclude that Roman did not present
sufficient information to excuse the September 7 positive drug
test.

Moreover, the present record does not support a finding

that Altman’s conclusion was pretext for discriminatory animus.

13

Roman pointed to no evidence that Leggett retained any other
employee where Leggett’s drug tester stated that the employee’s
prescriptions would not cause a false positive.
not

point

to

any

evidence

that

Leggett

Roman also did

retained

employee with an unexcused positive drug test.

any

other

For all of these

reasons, the Court finds that Roman has not met his burden of
establishing that Leggett’s proffered reason—the positive drug
test

result—was

false

and

that

discrimination

was

the

real

reason for his termination.
Roman

makes

several

other

arguments

that

Altman’s

investigation of the drug test result was unreasonable.

First,

Roman appears to argue that the drug tests he took in late
September should have influenced Altman’s decision.

But it is

undisputed that the concentration of a substance in the body
decreases from the time of ingestion to the time of testing, so
the Court cannot find that it was unreasonable for Altman to
focus solely on the September 7 drug test results.

Second,

Roman contends that the amount of barbiturates Clinical found in
Roman’s saliva would not have a discernable effect on Roman at
the time of the test.

Roman pointed to no evidence that he or

anyone else submitted any information on this point to Altman.
Plus, it is undisputed that the point of the drug test is not
just to determine whether an employee is under the influence of
drugs at the time of the test but to determine whether the

14

employee has any drugs in his system—which may suggest abuse or
improper use.

Third, Roman contends that the concentration of

barbiturates in Roman’s saliva was likely due to contamination
on the production line in the facility that manufactured Roman’s
Dilantin.

In other words, Roman argues that phenobarbital may

have been in his system due to contamination and not drug usage.
Roman did not point to any evidence that he or anyone else
submitted
Fourth,

information
Roman

points

to

Altman

to

a

regarding

publication

this

by

a

possibility.
drug

testing

laboratory that lists Dilantin as a drug known to cause a false
positive for barbiturates in urine and blood tests.

Roman did

not explain how the publication relates to saliva tests, and he
did not point to any evidence that he or anyone else submitted
the

publication

to

Altman.

Roman

faults

Irving,

Clinical’s

toxicology director, for not considering the publication or the
possibility of production line contamination, but Roman did not
point

to

withheld

any
such

evidence

to

information

suggest
from

that
Altman

Irving
because

intentionally
he

had

a

discriminatory animus toward Roman.5

5

Roman pointed to the expert testimony of Dr. Ilo Leppik in support of
several of his arguments. Dr. Leppik opines that (1) the results of
the drug screen do not indicate drug abuse because the testing method
was too sensitive, (2) the test results were likely due to
contamination, and (3) Roman’s work performance would not be affected
by the low levels reported. Again, the pretext inquiry centers on the
employer’s beliefs, and there is no evidence in the present record
that Roman or anyone else made Altman aware of these potential issues
when Altman investigated Roman’s drug test results.

15

Roman also argues that Altman’s response to the drug test
was

unreasonable.

Roman

contends

that

even

if

he

did

test

positive for barbiturates, Leggett’s substance abuse policy did
not require his termination, so it is reasonable to infer that
his

termination

was

discriminatory.

It

is

true

that

the

substance abuse policy does not state that employees who violate
the

policy

violators

must
are

be

terminated.

“subject

to

But

immediate

the
and

policy

states

that

severe

disciplinary

action, up to and including termination of employment for the
first offense.”

Roman Dep. Ex. 6, Substance Abuse Policy, ECF

No. 28-1 at 68.

Roman did not point to any evidence that the

substance abuse policy was enforced in a way that discriminated
against him because of a disability.
Finally,

Roman

contends

that

Leggett’s

unreasonable for three main reasons.

drug

policy

was

All three reasons require

the Court to second-guess the wisdom of Leggett’s drug policy,
which the Court may not do as long as the policy was not enacted
or enforced in a discriminatory way.
1030

(noting

that

an

employee

See Chapman, 229 F.3d at

cannot

prevail

“by

simply

quarreling with the wisdom of” the employers’ decisions as long
as the decisions are not motivated by a discriminatory animus).
First, Roman contends that he should not have been classified as
a

safety

sensitive

employee

and

subjected to random drug tests.

thus

should

not

have

been

But Roman presented no evidence

16

on this point.

In any event, he was classified as a safety

sensitive

employee

epilepsy,

so

he

before

was

not

anyone

at

classified

Leggett
as

a

knew

safety

he

had

sensitive

employee subject to random drug tests because of his epilepsy.
Second, Roman argues that barbiturates are not a substance of
abuse so Leggett should not have tested for them in the first
place.

The stated point of the substance abuse policy is to

detect abuse or improper use of drugs, which may cause a threat
to a safe and productive work environment.

Roman pointed to no

evidence that it is unreasonable for a manufacturer to prohibit
its

production

floor

employees

from

phenobarbital without a prescription.

working

after

taking

And even if he had, there

is no evidence suggesting that Leggett adopted its policy of
testing

for

barbiturates

with

a

discriminatory

screening employees with disabilities.

purpose

of

It is undisputed that

Leggett began testing for barbiturates months before learning
that

Roman

had

epilepsy.

And

third,

Roman

argues

that

the

cutoff level for barbiturates in Clinical’s screening was too
low because that small an amount of barbiturates in a worker’s
system

would

performance.

have

no

discernable

effect

on

a

worker’s

Again, the point of the drug test is not just to

determine whether an employee is under the influence of drugs at
the time of the test but to determine whether the employee has
any drugs in his system—which may suggest improper use or abuse.

17

The

Court

may

not

second-guess

the

validity

of

a

workplace

policy that prohibits employees from working with minor amounts
of phenobarbital in their system unless that policy is enacted
or

enforced

in

a

discriminatory

way.

Roman

pointed

to

no

evidence that Leggett adopted the cutoff level for barbiturate
testing

with

a

discriminatory

purpose.

For

all

of

these

reasons, the Court concludes that Roman has not established that
the policy was discriminatory.
In sum, the Court finds that Roman has not met his burden
of

providing

sufficient

dispute on pretext.

evidence

to

create

a

genuine

fact

Leggett is therefore entitled to summary

judgment.
CONCLUSION
For

the

reasons

set

forth

above,

Leggett’s

Motion

for

Summary Judgment (ECF No. 25) is granted.

IT IS SO ORDERED, this 3rd day of November, 2015.
S/Clay D. Land
CLAY D. LAND
CHIEF U.S. DISTRICT COURT JUDGE
MIDDLE DISTRICT OF GEORGIA

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