• SA Has A 'Right' to Cheap Data

    According to Duncan Alfreds, data cost remains a barrier to many South Africans accessing the Internet and reducing that cost should be the priority, an industry insider insists.

    In his article titled ‘SA has a 'right' to cheap data’, Alfreds echoes Kevin Hurwitza, chief executive officer’s view that, "Access to cost-effective data should be a basic right to consumers, not a luxury."

    He argues that despite South Africa having the potential of six million cable broadband connections, there are only around 800 000 ADSL subscribers, adding that most South Africans who access the Internet, do so on mobile phones.

    To read the article titled, “SA has a 'right' to cheap data,” click here.

    News 24
  • Education 'Key' to Open Wi-Fi Networks

    South African cities are engaged in the process of rolling out public Wi-Fi hotpots in an effort to make high speed mobile data freely available.
    According to a security consultant at Fortinet, Jonas Thulin, states that the new service though, could be used by criminals to entrap users who are unused to the environment.
    "While access for all is a commendable goal, there are security risks in extending free and low-cost Wi-Fi access in public places," explains Thulin.
    The cities of Tshwane and Cape Town are in the process of rolling our Wi-Fi access points for residents, and Thulin said that newbie users had be educated about the risks of an open network.
    To read the article titled, “Education 'key' to open Wi-Fi networks,” click here.

    News 24
  • ICASA Challenged Over Call Rates

    Cellphone network operators, MTN and Vodacom, will continue to challenge the introduction of new asymmetrical call termination rates in the Johannesburg High Court.

    However, Kate Hofmeyer, for Cell C, believed that if MTN and Vodacom were granted interim relief through the court suspending the Independent Communications Authority of South Africa’s (ICASA) 2014 regulations, this would result in the market being unregulated.

    Call termination rates are rates that mobile operators have to pay one another for calls to other networks.

    To read the article titled, “Unregulated cell environment dangerous – ICASA,” click here

    Fin 24
  • Mobile Data on the Increase in SA

    According to a report, mobile data traffic in South Africa is expected to have a compound annual growth of 53 percent in the next five years.

    The Cisco Visual Networking Index Global Mobile Data Traffic Forecast for 2013 to 2018, points out that mobile data traffic will reach an annual run rate of two exabytes (one quintillion bytes) by 2018.

    The report also states that 60 percent of mobile connections in South Africa will be ‘smart’ connections by 2018, up from 20 percent in 2013.

    To read the article titled, “Mobile data in South Africa to boom in next five years,” click here.

    Times Live
  • Vodacom and MTN Put Profits Before People

    I often wonder if certain captains of industries are entirely disconnected from reality. It is the only thing that can explain the breathtaking gall of Vodacom chief executive, Shameel Joosub, who complained publicly that new regulations would cost his company R1 billion in 2015, threatening to sue as a result.

    His threat relates to the upcoming changes in mobile termination rates enforced by the Independent Communications Authority of South Africa (ICASA). These are the fees that our cellphone networks are allowed to charge each other when customers call numbers outside of their own network.

    After years of squabbling, ICASA has finally managed to force the larger operators to gradually reduce these fees from 56 cents per minute in 2012 to 20 cents starting in March this year (2014), and down to 10 cents by 2016.

    Let's be clear: we are not talking about Vodacom or MTN suddenly being unfairly fined or taxed. These termination fees are built into the cost of the phone calls we make. By forcing the operators to lower them, ICASA is acting on behalf of ordinary consumers because lowering these fees will stimulate competition and drive down call charges across the industry.

    So what Joosub is effectively saying is: "Vodacom looked at the numbers and these lower call rates will hurt profits. We like profits, so we are (probably) suing ICASA." Were Vodacom some kind of struggling non-governmental organisation or a scheme to dig wells for the impoverished in South Sudan, say – we might have some sympathy. But Vodacom is a spectacularly profitable giant with over 50 percent of the South African market in its grasp.

    In the year ending December 2013, Vodacom declared over R13.2-billion in pure profit – a rise of nearly 30 percent on the previous year. So the amount Joosub is complaining about does not even equal 10 percent of last year's profits. By 2015, it will probably be closer to five percent. Shame.

    One of the things that is most vexing to Joosub and his compatriots at MTN (who control a healthy 33 percent of the market) is that ICASA has decided to treat the smaller networks – Cell C and Telkom Mobile – differently. They will receive much higher termination fees from Vodacom and MTN than they pay in return. 

    The logic behind this decision is that the larger players, left unchecked, might exercise their market power to squeeze the smaller players out completely. I am normally not a fan of such blatant market manipulation by a regulator, but given the alternative – a predatory duopoly – I am comfortable with the idea.

    It is pleasingly ironic to watch Telkom argue that it needs special treatment to help it defeat mean old Vodacom, in which it owned a 50 percent stake until mid-2009. The spectacle of one rapacious monopolist stabbing another former comrade-in-monopoly in the back is grimly amusing. The fact that consumers may benefit as a result is purely coincidental, but with Telkom's history I suppose we will take what scraps we can get.

    You could argue that Joosub and Zunaid Bulbulia, MTN's chief executive, are just doing their jobs. They are protecting their shareholders, many of them ordinary South Africans, against a regulator that blatantly seeks to make their companies less profitable. 

    But let us look at their profit margins in comparison to international norms. In its last financial year, Vodacom's net profit margin was 22.2 percent and the MTN group's was 17.8 percent. In the previous year, the figures were 17.5 percent and 19.5 percent respectively. International averages for the industry hover around 10 percent, and 15 percent is considered very high.

    Profit margins are meant to reflect risk. Supermarkets make lower margins than many riskier businesses because the chance of people not needing food regularly is zero. But they make up for this in volumes. 

    I would argue that mature telecoms operators are much more like supermarkets than riskier businesses such as software or construction. They have huge, established customer bases and provide a daily service to even the poorest people. They simply do not deserve the large risk premium they are currently extracting from the market. So bitching about giving five percent of your enormous profits back to your customers will only come across as tin-eared and out of touch.

    Oscar Wilde once said: "One should always play fairly when one has the winning cards." If I were Joosub or Bulbulia, I would take that to heart and shut my mouth.

    Alistair is the Mail & Guardian's Chief Technology Officer. This article first appeared on the Mail & Guardian website. 
    Alistair Fairweather
  • Africa Leads Cellular Health Technology Revolution

    Necessity is the mother of invention - and in Africa, where high levels of disease threaten to engulf the continent - the medical profession is having to get creative.

    According to Dr Sam Surka, researcher from the Chronic Disease Initiative for Africa (CDIA), a case in point is the recent advances in cellphone technology and Mobile Health, or M-health, which are showing that an answer to Africa’s medical health needs may come from this most unlikely of sources.

    Africa has one of the highest HIV/AIDS rate in the world, and an increasing incidence of chronic and non-communicable disease and the associated risk factors. Poor living conditions, over-populated living areas, lack of education and inaccessibility to medical information make this situation incredibly hard to manage. Africa carries more than 24 percent of the global burden of disease but has an average of only two doctors per 10 000 people.

    “Healthcare has always been a huge concern in Africa, especially when doctors and hospitals are far from isolated or remote areas where care is often most needed: M-health is potentially the answer to this,” says Surka.

    The M-health applications already available offer a wide range of services across the medical spectrum, contributing to a variety of responses to medical needs and conditions, in many cases opening new areas of preventative action previously impossible. Surka is currently working on a first-time project for the CDIA to develop a mobile phone application that calculates a total cardiovascular disease risk score and to investigate how this impacts on screening for cardiovascular disease by community health workers.

    “While much has been made of the mobile revolution in North America and its impact on the health sector, M-health is even more important in developing countries where phones are sometimes the only way for people to share and receive information. Through M-health projects, we at the CDIA hope to contribute to bringing its potential to light,” says Surka.

    Mobile penetration in Africa is at 65 percent, the second biggest mobile market in the world, with half of all Internet connections in Africa exclusively on mobile technology. South Africa has the second highest smartphone penetration on the continent at 19 percent, after Egypt at 37 percent.

    This accessibility means big things for healthcare - cellphones enable education that is more effective and targeted. “M-health is very much a needs-based innovation. While first world countries are leading in the medical technological sphere, there is certainly a gap between international thinking and what is actually needed on the receiving end. M-health gives us the ability to ensure we’re addressing actual needs,” says Surka.

    This is done primarily through the collection of data: the most important feature of mobile phone medical applications is that they are patient-focused; the patient is the one engaging. And through the data that the patient supplies, it is possible to see what areas are most in need of support, and for healthcare providers to respond accordingly.

    “Importantly, mobile health offers a necessary change to the status quo - for too long the medical sector has been at efforts to switch from doctor centric to patient-focused care. For the last 50 years, this has been happening and the advent of cellphone tech [technology] allows this to an even greater degree,” says Surka.

    Some good examples of M-Health include: TxtAlert - a mobile tool that sends unique automated SMS reminders to patients on chronic medication - reminding them to take their medication or perform other necessary tasks. A special tool, called ‘Please Call Me’ allows patients to call their doctors even if they do not have any airtime available by ‘pinging’ their doctor who then calls back.

    Young Africa Live is a digital forum where African youths can share stories and get information about HIV and AIDS. It also has helpful numbers and contact details for HIV/AIDS-related organisations, in an effort to de-stigmatise the diseases while also providing clear facts and support groups for African youths.

    hiVIVA is an application in early development stages, enabling users to stay motivated and on top of HIV medication adherence, through a smartphone application built on the MIT Media Lab’s online ‘CollaboRythm’ platform. Along with personalised real-time adherence support and reinforcement, users access instant lab results, just-in-time information about HIV, and smartphone-based communication with their provider and support group. One of the developers on this project, Dr Lindi van Niekerk, researcher at the CDIA and the Bertha Centre for Innovation and Social Entrepreneurship at the Graduate School of Business at the University of Cape Town, says that applications such as these represent the groundbreaking potential of M-health.

    “Most of these have never been tried before, through any technology - the ‘reminder’ technology alone could make a significant contribution to combating health issues in Africa. Theoretically, the potential benefit of M-health is enormous,” she says.

    “However many of the M-health possibilities still need to be tested, with many organisations now moving into research to enable policy makers to make the decisions needed for M-health to reach its next step. Fortunately”, says Surka, “That gap between funders and researchers is narrowing.”

    “In Africa in particular, because of the need; we are actually leading in the development of M-health globally. The South African government especially is encouraging M-health development, and putting its money where its mouth is,” he says.

    Surka says that we are entering a world where an increasing number of previously marginalised people have access to a mobile phone – a new state of affairs that has brought with it rapid technology development: importantly, powerful, relatively cheap technology that could provide immense relief to the crippling burden of disease on the continent.

    “The sky is the limit. We are seeing new technologies available every day, and as more health technicians, service providers, and developers start to roll out M-health initiatives, we will see M-health applications become an integral part of life in Africa, and then we will really start to see a positive change to the health of the continent.”

    - Jane Notten is the director at Rothko. For more information contact Zenahrea Damon at or call 021 448 9465.
    Jane Notten
  • UN Warns on Mobile Cyber Security Bugs

    A United Nations group that advises nations on cyber security, International Telecommunications Union, plans has sent out an alert about significant vulnerabilities in mobile phone technology that could potentially enable hackers to remotely attack at least half a billion phones.
    The bug, discovered by German firm, allows hackers to remotely gain control of and also clone certain mobile SIM cards.
    Hackers could use compromised SIMs to commit financial crimes or engage in electronic espionage, according to Berlin's Security Research Labs, which will describe the vulnerabilities at the Black Hat hacking conference that opens in Las Vegas on 31 July 2013.
    To read the article titled, “UN warns on mobile cyber security bugs,” click here.

    News 24
  • Parliament Launches Mobi-site

    Parliament is taking its drive to increase public participation to mobile technology, with the launch of a mobi-site to make itself more accessible to the people.

    South Africa has more than 63 million cellphones registered with the different networks, and the mobi-site will enable these users to access the latest information on what is happening in Parliament.

    Parliament media manager, Letebele Masemola-Jones, points out that with the mobi-site, Parliament “…wants to increase public participation, reach out to the youth. Parliament wants to be accessible to everybody."

    To read the article titled, “Parliament launches mobi-site,” click here.

    SABC News
  • Mobile Phones, a Tool for Pregnant Women

    Mobile Alliance for Maternal Action (MAMA), an initiative that aims to empower women to play their part in the prevention of child and maternal mortality in the country, enables pregnant women to access information about their pregnancies and unborn babies on their mobile phones.

    Global director for MAMA, Kirsten Gagnaire, says: “We work to deliver vital health information to new and expectant moms straight into the palms of their hands via their mobile phones.”

    Gagnaire explains that MAMA’s messages are designed to encourage and remind mothers about the importance of things like eating nutritious foods during pregnancy, going to the clinic, exclusive breastfeeding and immunising their babies.

    To read the article titled, “Mobile phones, a vital tool for pregnant women,” click here.

    SABC News
  • Technology, e-Learning and Education in Africa

    Technology is evolving rapidly and opening doors for a variety of sectors including education. In resource-poor settings and rural communities new technological advances create opportunities where none previously existed. New developments in education are becoming vital in Africa where some countries are finding that their education systems are not meeting community and societal demand, or are becoming too expensive.(2) In some places there is no real guarantee of a quality education and the efficiency and availability of primary, secondary and university level education are not assured.(3)
    To combat these problems throughout continental Africa, countries are embracing information and communications technology (ICT) to increase access to the Internet and expand educational curricula at all levels of schooling.(4) E-learning, as this use of ICT in education is known, is quickly becoming an asset not only to the students but to communities and teachers as well. It provides the means for gaining stronger work skills, allows for global partnerships to develop, and increases the quality of education programmes.(5) Expanding access to and the availability of e-learning programmes for students, teachers and businesses is a key to furthering continental development and growth.
    This paper discusses the broad developments in e-learning technology spreading across continental Africa. It focuses specifically on how ICT, particularly mobile phones and applications, and e-learning are changing and shaping education on the continent. The benefits of e-learning and the challenges to advancement and implementation of new educational opportunities in Africa are also briefly outlined.
    The emergence of information and communications technology in Africa
    Technology and its content are changing communication and publications in schools. Interactive textbooks and educational games are being introduced into schools, creating an environment like an online digital classroom.(6) In Africa, these types of environments are being introduced into both urban and rural settings, especially in areas in which reliable power sources have not previously been readily available.(7)
    The rise of mobile technology was one of the most revolutionary steps in technological growth in recent times and it is particularly interesting in Africa because mobile services are well developed and have grown out of necessity.(8) Some of the most innovative advances in mobile services have occurred in resource-poor settings, and have been used to meet different technological or social needs.(9) Advances in mobile services have also provided the means to expand community knowledge about the Internet and wireless technology.(10) Overall, the use of ICT has grown exponentially across the continent in the past decade. This graph demonstrates the growth (percentage of communications growth in Africa (11))
    Mobile phone subscriptions particularly have increased significantly from 1998 to 2008. In 2011, there was further growth in mobile phone subscribers. In Kenya for example, of a total population of 41.6 million,(12) there are now 25 million mobile phone users.(13) Even though the story in rural areas is changing, the majority of these users are still in urban areas with only about 30 percent of rural Kenyan families presently owning a mobile phone.(14) However, numbers like these and others across Africa are increasing continuously as ICT is rapidly expanding and is considered vital to economic growth.(15) A growing body of evidence shows that old ways of learning across the continent are not getting the desired results, so it has been necessary to introduce new ways of approaching education provision. Businesses, schools and communities are now increasingly focusing on ensuring that people are becoming more literate in ICT.(16)
    E-learning and education opportunities in Africa
    This new focus is changing education all over Africa and it is adapting and changing with the growing use of e-learning and technology. New kinds of content are in development regularly and are being introduced to children and adults. For example, digital textbooks are being introduced, replacing conventional two dimensional publications and books.(17) Due to the generally unreliable nature of electricity provision from national grids across many parts of Africa, new sources of power, such as wind and solar power are also required and training in these technologies is needed.(18) Great strides are being made in this regard all over urban and rural Africa as ICT expansion and provision continues. Classrooms are being powered by solar energy and battery sources that are more easily rechargeable.(19) Very slim, easily manageable computers are available for use and only require a low 3 to 15 watts of power for operation.(20) The growing availability of ICT made possible by these innovations has increased access for millions of students in Africa. In South Africa for example, about 1.5 million students can now access computer classrooms through upgraded computer technology.(21)
    Education through e-learning is becoming vital in opening new doors, not only for children but also for adults. It is slowly allowing women to strengthen their positions in society through increased access to information and opportunities and is providing independence and ICT awareness.(22) It is noted that in order to continue this growth the expansion of education through e-learning must occur and that, in the African context, this is only possible through the increased use of ICT and continued training through large scale-up programmes.(23) In this way education in both urban and rural areas will be improved by access to information through technology, learning and the Internet.(24)
    There are many more examples of ways that African countries are expanding education using e-learning solutions. A report from Accenture shares several ways in which technology is enhancing education and access to it through e-learning by:

    • Providing teachers with digital materials to supplement traditional lectures (via laptops and projectors);
    • Delivering master teacher sessions by video to wide audiences, computer-based games and simulations;
    • Replacing books with electronic devices supporting more engaging and comprehensive content;
    • Enabling collaboration across communities via connected classrooms;
    • Supplementing traditional curricula with additional learning materials covering locally-relevant topics like health and agriculture;
    • Delivering teacher training in local schools during evenings and weekends;
    • Delivering vocational training and adult education via school infrastructure during non-school hours;
    • Offering individual, self-paced training tailored to individual needs and goals; and
    • Extending education beyond the classroom via mobile devices, personal computers or Internet kiosks.(25)
    The cost of tailoring these solutions to all the schools in almost any African country has also been reduced exponentially over the years from the range of billions of dollars to millions.(26) Additionally, schools that could not use computers due to electricity costs may now do so because of the reduction in energy needs. The average operating cost of a single device over three years has decreased from about US$400 to about US$50.(27)
    Examples from South Africa and Malawi demonstrate how ICT innovations and attendant e-learning technologies are being used to change communities. In South Africa, an initiative by Vodacom in partnership with the Eastern Cape Department of Education is creating a new ICT centre in the Lady Frere District that will increase education availability for students and provide training to teachers.(28) The expectation is that more than 1400 teachers with be trained throughout the district while strengthening curricula and teaching aids through cloud computing technology that stores the new content making it easily accessible.(29) These new possibilities provide ways to standardise training and teaching throughout urban and rural schools and allow for students to receive the same educational opportunities no matter where they live.(30)
    In Malawi Microsoft is training teachers and helping them open their own computer labs through the Malawi Learning Partnership network.(31) It is providing students and teachers with access to e-learning resources that will enhance their learning and teaching capabilities and their access to the global community.(32) The network has also increased access for female students allowing girls in rural communities the opportunity to learn information technology skills and potentially pursue careers in technology-based industries.(33) The opportunities presented by e-learning and technology have transformed, and continue to transform, education and access to it across the continent.
    Challenges to e-learning and education
    E-learning and the availability of technology is changing the face of education across the African continent, but even with the aforementioned successes countries still face challenges to implementation and access. They might face many different constraints such as poor infrastructure and availability of resources. Some of the most common and key constraints to e-learning which are present at the national level are listed in the table below.

    Rank Constraining Factor Percentage The Country Most Likely Identify. This is a Constraint The Country Least Likely to identify. This is a Constraint
    1 Bandwidth is limited 17 Zambia Kenya
    2 Financial resources are lacking 1 Zambia Nigeria
    2 Human resource capacity is inadequate 11 South Africa Tanzania
    2 Electricity is limited 11 Nigeria South Africa
    5 Appropriate training is lacking 8 Kenya Uganda
    6 Appropriate hardware is lacking 7 Tanzania Ghana
    7 Lack of trained teachers 6 South Africa Nigeria
    8 Appropriate software is lacking 6 Tanzania Ghana
    8 Political will is lacking 4 Nigeria Uganda
    8 Corruption and theft of resources 4 Uganda Zambia
    11 Lack of good quality educational content 3 Tanzania Nigeria
    12 Pressure of poverty 3 Kenya Uganda
    12 Sustainability is not prioritised 3 Kenya Tanzania
    12 Leadership is lacking 3 Nigeria Uganda
    15 Instability and lack of security 1 South Africa Zambia
    15 Other factors   N/A N/A
    Key constraints to e-learning (34)
    The table demonstrates that some countries may be facing multiple constraints to their ability to provide e-learning solutions to educational needs. The most common problem is still limited bandwidth reducing Internet capability and stability.(35) Additionally, other continuing problems with availability of technology include limitations in access in rural areas and the capacity of the technology owned by many people to support new learning techniques.(36) An example of this is seen through research conducted in Kenya using Graphogame, a game serving as a research tool to study reading acquisition, which is used on a smart phone. Researchers found that most families in rural areas, even those with mobile phones, did not have mobiles with the capability to use the game’s technology.(37) 
    Other longer term and more distal constraints that may limit access to education generally include political instability, as under such conditions the key institutions and infrastructure of good governance, which include those of education, are often corrupted, mismanaged, under-funded and neglected, and brain drain, which has negative consequences for institutional capacity.(38) However, even though these barriers do represent obstacles to moving forward with education upgrades they are not stopping individuals and communities from moving forward. They are working to increase capacity-building and the mitigation of such constraints so that they can limit the effect these have on the expansion of educational opportunities and uptake.(39)
    Concluding remarks
    The availability of e-learning technologies is providing expanded opportunities for countries in Africa to make education available to their whole population. Rural communities are being connected to the rest of the globe and their residents are more able to achieve the same level of education as their urban counterparts. In addition, more and more examples of how different communities are providing e-learning options are highlighted regularly in the media.
    This continued expansion is important for helping to maintain and further social and economic development and to secure future growth. However, there are clearly still barriers to growth and implementation of new technologies and limitations to making e-learning solutions available to everyone. Governments, non-governmental organisations and civil society groups must continue to monitor needs and build capacity to meet those needs, because the strength of a country’s education system may be a clear condition to its positive development and the lack thereof a contributor to its poverty.(40)
    Shannon Rupp (, Consultancy Africa Intelligence’ Africa Watch Unit. This discussion paper first appeared on the Consultancy Africa Intelligence website, a South African-based research and strategy firm with a focus on social, health, political and economic trends and developments in Africa. For more information, see    
    (2) Ekundayo, M.S. and Ekundayo, J.M., ‘Capacity constraints in developing countries: A need for more e-learning space? The case of Nigeria’, 2009,
    (3) Ibid.
    (4) Mpunga, N., ‘EC Education and Vodacom Partner to Empower Teachers’, Province of the Eastern Cape Education, 19 September  2012,
    (5) Sabela, Z., ‘SA & US institutions partner for e-learning,’, 22 August 2012,
    (6) Isaacs, S. and Hollow, D., (eds) 2012. The eLearning Africa 2012 Report. ICWE: Germany,
    (7) Ibid.
    (8) Banks, K., ‘Mobiles offer lifelines in Africa’, BBC News, 15 September 2009,
    (9) Ibid.
    (10) Ibid.
    (11) Ibid.
    (12) ‘Kenya’, The World Bank,
    (13) Isaacs, S. and Hollow, D., (eds) 2012. The eLearning Africa 2012 Report. ICWE: Germany,
    (14) Ibid.
    (15) Ibid.
    (16) Ibid.
    (17) Ibid.
    (18) Abell, T.E. and Long, T., ‘eLearning in Africa – Transforming Education through Enabling Technologies’, Accenture, 21 December 2010,
    (19) Isaacs, S. and Hollow, D., (eds) 2012. The eLearning Africa 2012 Report. ICWE: Germany,
    (20) Ibid.
    (21) Ibid.
    (22) Ibid.
    (23) Ibid.
    (24) Ibid.
    (25) Abell, T.E. and Long, T., ‘eLearning in Africa – Transforming Education through Enabling Technologies’, Accenture, 21 December 2010,
    (26) Ibid.
    (27) Ibid.
    (28) Mpunga, N., ‘EC Education and Vodacom Partner to Empower Teachers’, Province of the Eastern Cape Education, 19 September  2012,
    (29) Ibid.
    (30) Ibid.
    (31) Gondwe, G., ‘Microsoft employees train Malawi school teachers’, Bizcommunity Daily, 4 September 2012,
    (32) Ibid.
    (33) Ibid.
    (34) Isaacs, S. and Hollow, D. (eds.), 2012. The eLearning Africa 2012 Report. ICWE: Germany,
    (35) Ibid.
    (36) Ibid.
    (37) Suzanne, C. and Otieno, A., 2012. “Early reading acquisition using mobile learning in Africa: The case of Graphogame adaptations in Kenya”, in Isaacs, S. and Hollow, D., (eds.). The eLearning Africa 2012 Report. ICWE: Germany,
    (38) Ekundayo, M.S. and Ekundayo, J.M., ‘Capacity constraints in developing countries: A need for more e-learning space? The case of Nigeria’, 2009,
    (39) Ibid.
    (40) Ibid.


    Shannon Rupp
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