Oversigning.com
4Jun/1120

The Day After The Day

Before we get started, we highly recommend that you consider using Twitter to follow this topic, it is the best place to go to get links to articles on oversigning as they come out.  It is really amazing how information flows through Twitter.  We'll try to retweet as many articles as possible so they will show up in the sidebar here so those of you not on twitter can read them.  On to the good stuff...

Now that the dust is settling on the SEC's new "roster management" legislation, the general consensus appears to be that the media is not buy what the SEC is selling.  As we mentioned yesterday, this was strictly a PR move by the conference to try and appease the media while at the same time not get on board with REAL legislation that completely eradicates the exploitation and abuse that takes place in oversigning.  Was it better than nothing, sure, but let's be honest, could they really do nothing?

Our biggest criticism is that if the SEC wants to move to national legislation on oversigning, why didn't they invite their colleagues to the table for discussion before creating what they want as the national legislation?  Why is the SEC pushing so hard for THEIR rules to be national rules?  The answer is simple, this was never about being ethical or doing the right thing, this is about competitive advantages, something coaches made very clear in their 12-0 vote to not change the rules and something SEC fans have been accusing Big 10 fans of whining about ever since this topic came up.  For SEC fans, the only reason this is even an issue is because Big 10 fans think they are at a competitive disadvantage.  Irconically, when forced to do something about oversigning, it was the SEC that showed its hand and revealed that oversigning is about a competitive advantage and if they have to give it up then the rest of the country MUST follow suit.  For months and months we heard that there is no competitive advantage in oversigning, that myth has been busted.

Could you imagine if the roles were reversed and it was the Big 10 doing what the SEC is doing? 

What if the Big 10 announced that they were going to go back to their pre-2002 rules were there was absolutely ZERO oversigning and they EXPECTED the NCAA to make it a national rule?  The outrage would destroy the sport.  Just to make sure we have this right, the conference that was the worst abuser of the unethical practice of oversigning declares that it is doing something about it and, by God, the rest of the country is going to follow along.  The funny part is that the new rules they are touting are not as restrictive as the B1G rules when you consider that if a school has 16 openings the new SEC rule still allows for 25 signees; that's oversigning by 9.  The B1G rule would only allow that school to sign 19, which is only 3 over.  If you are a self-respecting college football fan you should be insulted, especially if you are an SEC fan that really cares about the conference and the sport.

But here's the good news, and it really is good for sport of college football and all of college athletics.  The door is now open.  There is a very real chance that we will get everyone to sit down at the table and draft real meaningful rules on oversigning that addresses the problem at its root, the number 85, and yet still provides competitive equality with regards to the number of players each school is signing each year.

The NCAA has an obligation to create national rules on oversigning that make it clear that hoarding players and playing games with the numbers to gain a competitive advantage through highly unethical behavior has no place in the sport they regulate, that every recruit and current player IN EVERY CONFERENCE will be protected from forced attrition, and that every conference competing for BCS bowl spots and the money that comes with it will be on equal footing when it comes to the number of players they can recruit and sign. 

Quick Links:

Sports Blog, Get the Picture, which has been following this topic for a long time, has a nice post up on the days events and points out that Chris Low sees the shortcomings of the new legislation.  Highly recommended reading.

http://blutarsky.wordpress.com/2011/06/04/the-oversigning-is-dead-long-live-the-oversigning/

For a much stronger take, from a Northwestern perspective, check out Lake the Post's latest piece on the new SEC legislation.

Math. Basic math.  Per NCAA rules a team is limited to having 85 scholarship players on its roster. The biggest bullshit is the PR spin term they’re using – “roster management”.  If you follow the backchannel talk on this type of stuff you’ll know this is a direct response to the heat the conference is getting for oversigning.  Yet, somehow they’re using the scholarship cap per season as some sort of veiled attempt to be ethical. 

Finally, we stand up loud and proud for our friends at Oversigning.com who make my obsession with Northwestern football look like a mainstream action. The entire site is dedicated, passionately, to this issue.  Yesterday was the equivalent of NU going to the Rose Bowl in terms of frequency of posts and “OMG” moments.  I can’t do the blog justice as there are so many damn good points on the SEC reaction including the absolutely insane totalitarian Nick Saban stance...

http://www.laketheposts.com/index.php/2011/06/tressel-gate-zero-impact-on-sec/

The ShreveportTimes.com has a piece up on the SEC coaches losing to the SEC presidents.  Interesting comments from Les Miles and LSU AD, Joe Alleva.  Our advice to them is that oversigning college football recruits is not how you solve the problem of poor elementary and secondary education systems, in fact, by oversigning you are enabling those systems, to the degree that they play a role in preparing a kid for a scholarship in college football, to continue to fail kids instead of forcing them to improve. 

"I think there are academic risks in the SEC recruiting pool," Miles said. "And I think at times you take some of those risks with the idea that you'll have a plan B for him. Then you'll be able to direct him comfortably and delay enrollment. I think that those things are certainly healthy.

LSU athletic director Joe Alleva, a former Duke athletic director, has noticed the difference in recruiting in the Deep South as opposed to recruiting the state of North Carolina at Duke, where academic risks are usually not taken.

“You’ve got to understand, the elementary education and secondary education in the state of Louisiana is not the best in the world,” said Alleva, who wanted the limit to remain 28. “So we have kids coming out, and we don’t know if they are going to qualify or not. We don’t know if they’re going to get through the NCAA Clearinghouse and be eligible.

http://www.shreveporttimes.com/article/20110604/SPORTS0202/110603024/SEC-coaches-suffer-oversigning-loss-presidents?odyssey=mod|newswell|text|FRONTPAGE|s

Filed under: NCAA 20 Comments
2Jun/1117

Red Herring Alert!!! It’s Not About 28 or 25, It’s About 85!!!!!

The last two days of quotes and responses from SEC coaches, athletic directors, and now university presidents and the president of the NCAA Mark Emmert, have made one thing crystal clear, they either do not fully understand the issue of oversigning or they are using the hard cap of 25 as a red herring to divert the average fan's attention away from the real number that counts, 85

University of South Carolina President, Harris Pastides said today that he hopes that whatever the SEC does that the NCAA will force the rest of the country to follow along.  First off, his comments indicate that the competitive advantage aspect of the oversigning issue is much more important than the ethical treatment of players.  Secondly, Harris Patides obivously knows nothing about how the Big 10 Conference handles oversigning, because if he did he would realize that they have been 50+ years ahead of the curve on this issue.

"We'd love the SEC to play a lead role in doing the right thing," Pastides said. "We would hope the NCAA would adopt whatever we would do. That's where our ADs and coaches are. They don't want us to be so far out in front that we're the only league that clamps down on that."

NCAA President Mark Emmert, who met with SEC presidents and chancellors today, said it's possible the league's position on oversigning could become national legislation.

"It's certainly an issue that's more important to the SEC right now than other conferences," Emmert said. "So if they come out with a good position, it may well be one that could become a national standard."

"We certainly know that our football advocates would prefer there's a so-called level playing field," Pastides said. "I think the challenge is do we go first and hope (the nation) will follow? And what if we go first and they don't follow? Do we go back to 28? Nobody sees that happening."

http://www.al.com/sports/index.ssf/2011/06/south_carolina_president_on_ov.html

The lead role???  Are you kidding.  The Big 10 Conference banned the practice of oversigning in 1956 and only relaxed its rules slightly in 2002 to allow for 3 over a school's limit with tons of transparency.  The SEC is not taking the lead role here folks, they are playing catch up ball.

The key element that is lost on so many involved in this topic is that you have to address this at the 85 total limit, not the annual 25 limit.  If a Big 10 school has 16 roster openings to get to 85 on national signing day then they can sign up to 19 new recruits, provided there is proper documentation and approval from the conference office.  That's it, they can go three over the limit of 85.   

If the NCAA tried to force a hard cap at 25, a school with 16 openings could still sign 9 over the 85 limit by signing a class of 25.  How does that address or even curb oversigning?  It doesn't.

Setting a hard cap that remains static every year is not the answer, and it will never be the answer because the number of openings each year fluctuates.  Schools are allowed to have 85 scholarship players every year; some years schools will have 16 openings some years schools will have 25.  Therefore the limit needs to fluctuate with the amount of legitimate openings at national signing day and it should be based on getting to 85, not 25.

But what about attrition after national signing day?  The vast majority of that can be mitigated, as rules tighten on oversigning so will the recruiting practices.  Fewer borderline kids will be recruited because the expectation on STUDENT-athletes will be that they have to be prepared for college, remain eligible academically while in college, and not just gifted athletically.  A lot of the attrition that we see post national signing day is forced attrition due to oversigning, so all of that will be gone.  The rest, coaches will just have to deal with.  They can award a 1 year scholarship to a deserving walk-on and fill the slot next year with a new recruit they expect to have for 4-5 years.  This is a perfectly workable solution that eliminates the exploitation of players through the oversigning loophole.

When you demand excellence from student-athletes you will get it (just ask schools that are already doing it: ND, NW, PSU, Vandy, etc), but when you have a system that says to the student-athlete that they don't have to be prepared for college when they come in, they don't have to take classwork seriously when they get there and they don't have to keep their nose clean because they can easily be replaced via oversigning, you have a system that goes against everything college athletics is supposed to be about, which is the enrichment of the educational experience through competition in athletics.  We didn't make that up by the way, that is supposed to be part of the mission of the NCAA.

As fans and alumni, we should demand more from university presidents, they should demand more from athletic directors, they should demand more from coaches, and coaches should demand more from student-athletes.  To do otherwise by exploiting a loophole such as oversigning in order to run through kids in search of the best football talent is what is really hurting kids.

Filed under: NCAA, SEC 17 Comments
6Mar/1116

More on NCAA Football Issues Committee Monitoring Oversigning

We posted a quick link on this earlier in the week but would like to drill into it a little more here.  In the discussions lately in the comments section, there have been a few readers that have made the point that eliminating oversigning will only lead to abuses to players further upstream, meaning that instead of cutting players after signing day players would be cut in December and January.   It appears the NCAA is thinking along the same lines, which to be honest is very troubling because in order to subscribe to the notion that a rules change would only result in abuse further upstream you have to accept that player abuse is currently taking place with the use of oversigning, something many of you who have tried to defend oversigning have denied. 

Because the effect of the new rule may not be apparent immediately, the Football Issues Committee decided to remain diligent about monitoring it.

“This rule has only been in effect for one year, and we want to take some time to see if that’s the perfect number,” said committee chair Nick Carparelli. “Certainly, the committee will continue to monitor it, and we can re-evaluate to see if there is a more appropriate number if necessary.”

http://www.ncaa.org/wps/wcm/connect/public/ncaa/resources/latest+news/2011/march/football+issues+committee+to+monitor+oversigning

The rule change that they are monitoring, in case you are unaware, is the recent additions of 13.9.2.3 and 15.5.1.1 from proposal 2009-48 which only limit the number of NLI's to 28 between NSD and May 31st.  Rules that Andy Staples said were not worth the paper they were written on.

We don't believe this is about finding the right number.  This is about a shift in the cultural mindset of the schools that abuse oversigning the most.  As we have mentioned a few times, the Big 10 Conference established its rules on oversigning back in the 1950's and it is our belief that over time the mindset of the member institutions has been shaped by those rules resulting in oversigning not being an issue in that conference.  As you can see by analyzing the numbers, the type of attrition that many think will be moved upstream by today's oversigners, such as this example from Huston Nutt, is not an issue in the Big 10; if it were you would see that the Big 10 would have a much higher number of players signed each year, and yet, of all the BCS schools the Big 10 ranks last in the average number of players signed.

So what is the solution?  Leadership.  When the SEC university presidents meet in June for their annual conference meetings, they absolutely must demand that their athletic departments stop oversigning and they must create a culture that does not accept the kind of roster attrition we see from the oversigning schools.  Maybe they find that in a number or in a set of rules, or maybe they find that by hiring coaches that are more known for their ethical treatment of players and ability to develop them instead of their ability to recruit or find loopholes in the NCAA by-laws. 

Grayshirting

Another area covered in the NCAA press release was the practice of grayshirting, which the NCAA is also going to start monitoring.  This too has become a controversial topic with Florida's President calling it morally reprehensible.

Susan Peal, who administers the National Letter of Intent program, said the Collegiate Commissioners Association (the program’s governing body) doesn’t support grayshirting. The program has a policy that nullifies the National Letter of Intent if an institution or coach asks the student-athlete to grayshirt. However, if a student-athlete decides to delay enrollment, the national letter remains valid. Determining the instigator of the decision can be difficult.

http://www.ncaa.org/wps/wcm/connect/public/ncaa/resources/latest+news/2011/march/football+issues+committee+to+monitor+oversigning

According to the press release, Susan Peal appears to agree with Florida's president, and although she doesn't call it morally reprehensible, it is clear that she does not support grayshirting due to the fact that it can nullify the NLI.  One area where this is a concern is that some coaches are purposely oversigning and telling many of the kids they recruit that there is a possibility that they MIGHT have to take a grayshirt if the numbers don't work out.  As August rolls around and the numbers begin to shake out, the coaches that have oversigned and told recruits that they MIGHT have to take a grayshirt can play their ace in the hole and attempt to avoid public backlash by stating that they told the recruit up front that a grayshirt might be POSSIBLE.  Our question is, did they also tell them that they are offering something that the NLI program does not support because of the risk it poses to the recruit or are they telling them that grayshirting is normal and there is nothing to worry about?  Based on the comments of the players and parents that have found themselves in a grayshirt situation it is clear that everyone is not on the same page.

Our position is that we are against coaches telling a handful of recruits that they MIGHT have to grayshirt if the numbers don't work out and we are against coaches oversigning knowing they have a handful of players they can push back if they need to via the grayshirt.  Grayshirt offers should only come after a school has filled all of their available openings, it should be petitioned for with transparency at the conference or NCAA level, and there should be something in writing that guarantees the recruit that they will have spot in the following class.  Grayshirt offers, if any, should be the last offers given out because all of the current openings in the class are taken.  It is unethical to go around giving out offers that come with a grayshirt clause.  NLI doesn't support the grayshirt practice and recruits that are being told by a football coach that they MIGHT have to take a greyshirt should be very cautious when considering that kind of offer.  Hopefully we will see some reform here and the grayshirt process with either go away or become heavily regulated.  We would hate to throw the baby out with the bath water just because you have a handful of coaches out there offering kids conditional grayshirt offers simply to keep them away from other schools.

Filed under: NCAA 16 Comments
24Jan/11118

Oversigning Making the Rounds – Andy Staples with a Great Article

Andy Staples is not new to the topic of oversigning.  In his latest article on the topic, he calls into question the teeth, or lack thereof, behind the NCAA rules for signing players.  As Staples points out, the NCAA has now placed a limit on the number of players that can be signed at 28, however, what good is a limit of 28 when a school only has room for 15-18?  They still have the opportunity to go over the 85 limit, drastically.

So now that a nationwide rule governs signee totals, the morally shaky practice of oversigning should end. Shouldn't it?

Not even close. The rule isn't worth the paper on which it's printed, and everyone in college football knows it.

The NCAA rule was sponsored by the SEC, home to some of the nation's most notorious oversigners. The SEC passed its own rule in 2009, and that rule was in place last year when Auburn signed 32 players and LSU signed 29. Thanks to a lingering numbers drought in the Loveliest Village on the Plains following coach Tommy Tuberville's 2008 ouster, Auburn managed to squeeze every academically qualified player onto the roster. That wasn't the case at LSU, where coach Les Miles already had tried to clear the decks by cutting quarterback Chris Garrett. Miles misjudged how many of his academically shaky signees would qualify, and by summer's end, Miles had two more qualified newcomers than he had available scholarships.

Tommy Tuberville sheds some major light on the competitive advantage aspect of oversigning with his comments:

Tuberville, now the coach at Texas Tech, doesn't need to see any numbers to know oversigning offers a competitive advantage. "Sure it is," he said. "But hey, nobody told [the Big Ten] they had to do that."

Tuberville, who coached at Ole Miss before Auburn, believes oversigning can benefit certain players. It's no coincidence that most of the schools that engage in oversigning are either in states or border states that allow junior college football. A coach will sign players he knows have no chance of qualifying academically and then place those players in junior colleges. In return, the junior college coaches will feed the best of their players back to the FBS programs when those players are ready to transfer. Tuberville believes the practice allowed some players to reach college when they might have otherwise slipped through the cracks.

"I always liked to oversign seven or eight just to sign kids, to motivate them, and then we're going to put you in junior college," Tuberville said. "Once you sign, then we can continue to call you and motivate you to go to class, get your grades higher. Then you go to junior college, and you'll be in a lot better shape. Now, you're not going to be able to do that."

One of the signees Tuberville's Auburn staff placed in a junior college was defensive tackle Nick Fairley. After a stint at Copiah-Lincoln Junior College in Wesson, Miss., Fairley went to Auburn, where he helped the Tigers win a national title. He now is considered the top prospect in the 2011 NFL draft by many analysts.

Memo to Tommy Tuberville, you're right, no one had to tell the Big 10 that they had to ban oversigning, they already knew it was bad for the student-athletes and decided to be proactive instead of reactive.  Being that the Big 10 banned oversigning in 1956, 8 years before Georgia Tech decided to leave the SEC because of oversigning, you would think that the SEC would have figured out that this was bad for student-athletes and not worth the human expense to allow it to continue.  Nonetheless, here we are 55 years later and still trying to get the SEC to come to its senses and put some real teeth into its oversigning rules.

One of the major contributing factors to the oversigning issue, and why it is so prevalent in the SEC, is the academic aspect of recruiting a student-athlete and the JUCO farm system the resides in the Southeastern portion of the country.  As Tuberville mentions, when he was at Auburn, he would sign 7-8 extra and place them in JUCO in hopes that maybe one day a guy like Nick Fairley would come back. 

Here's a news bulletin, Nick Fairley is not going to Notre Dame, Michigan, USC, Penn State, Stanford, Vanderbilt, Northwestern, etc., etc.  Academically he would have not been admitted into Notre Dame - Notre Dame has never had a JUCO player, ever.   Yet the BCS wants everyone to believe that their National Championship is legitimate and that everyone is competing for it on a level playing field - guess what, they are not, and oversigning along with the JUCO farm systems of the south play a major role in explaining why the playing field is not level.

Go read the rest of Andy's article; it's a great piece of work done by a true professional.  This might be the site that is at the epicenter of the oversigning topic, but it takes guys like Andy Staples, Stewart Mandel, Bruce Feldman, Bob Ley, and the countless others with real mainstream media pull to move the needle, and right now it is really moving.  Now we need the local beat writers to really hound the coaches to explain their numbers when signing day comes around.

Filed under: Big 10, NCAA, SEC 118 Comments
2Jan/1175

OTL Video

21Aug/1039

NCAA Gives Alfy Hill the Les Miles Treatment

The sole purpose of this site has been to expose the oversigning loophole in the NCAA rule book to the masses, identify the coaches that abuse it the most, and follow the stories of the kids that get screwed in the process.  As we near 3 million hits since this site was created in February, it is pretty clear to anyone who can type the word "oversigning" into a google search box that we have delivered on those three objectives. 

For the last several months, we have closely followed Alabama and LSU as they were both identified as teams guilty of gross oversigning of their rosters.  During that time we were able to predict with a reasonable amount of certainty the number of players LSU and Alabama would have to lose in order to remain under the 85 scholarship limit by the August 1st deadline.   The main problem we have with LSU and Alabama oversigning is that nearly all of the attrition and roster movement below took place after they already accepted over 25 signed letters of intent from new recruits.  When schools accept those signed letters of intent the recruits that sign them are bound to the school but the school is not bound to the recruit.  As we saw with Elliott Porter, LSU screwed up the signing process so badly that they had to just pull the rug out from underneath Porter, who was already on campus, and send him packing because they didn't have scholarship room for him.  Simply put when you accept more signed letters of intent than you have room for when you accept them it's inevitable that someone is going to get screwed.

2010 The March to 85 - Alabama

Player Position Reason for leaving after NSD
Terry Grant Running Back Scholarship not renewed
Travis Sikes Wide Receiver Scholarship not renewed
Rod Woodson Safety Scholarship not renewed
Star Jackson Quarterback Transfer, Georgia State Div 1AA.
Deion Belue Defensive Back Academically Ineligible; headed to JUCO
Alfy Hill Linebacker Academically Ineligible; future unknown
Taylor Pharr Offensive Lineman Medical Hardship
Milton Talbert Linebacker Medical Hardship
Darius McKeller Offensive Lineman Medical Hardship
Ronnie Carswell Wide Receiver Greyshirt
Wilson Love Defensive End Greyshirt


With Alfy Hill's departure it opens a scholarship spot for Harrison Jones who just a couple of weeks ago was on the short end of the stick with regards to the scholarship numbers.  Jones was going to accept being greyshirted until January because due to Nick Saban's oversigning and the unknown status of so many of the players on Alabama's roster it appeared that there wasn't going to be room for Jones.   We'll have more on Alfy Hill in a minute.

The March to 85 - LSU

Player Position Reason for Leaving
Akiem Hicks Defensive Tackle Removed from the team - was involved in NCAA investigation
Kyle Prater Linebacker Transfer
Jhyryn Taylor Wide Receiver Transfer
Thomas Parsons Fullback Medical Hardship Scholarship
John Williams Wide Receiver Medical Hardship Scholarship
Clay Spencer Offensive Lineman Medical Hardship Scholarship
Chris Garrett QB Cut - Scholarship Not Renewed
Houston Bates Defensive End Released from LOI in April; refused Greyshirt
Elliott Porter Offensive Lineman Asked to Greyshirt in AUGUST; refused Greyshirt; released


This is in sharp contrast to how a lot of other schools manage their scholarship numbers and the signing process.  As we have mentioned several times, the Big 10 Conference does not allow oversigning, even by 1, much less 8-10 every year.  The practice has not been banned by the ACC but in looking at their numbers it is clear that the coaches and schools in the ACC exercise constraint with the regards to the signing process and outside of North Carolina (Butch Davis) and Miami (Randy Shannon), the ACC has some of the lowest number of signed players in the country.  Same with the Pac 10+2, their numbers are consistently low. 

Outside of looking to get a competitive advantage by moving out lesser players for new recruits, fans of schools that oversign often site that one of the reasons for oversigning is that coaches often don't know who is going to be eligible and they use oversigning as a way to hedge their bets against the NCAA clearinghouse, after all the loophole in the NCAA rule book allows them to do so.

Case and point, Alfy Hill.  Hill was part of Alabama's oversigned class of 2010.  He was cleared by the NCAA clearinghouse, admitted onto campus, completed 3 courses of work, and is now being told that he is not eligible because after reviewing his high school transcript a second time, the NCAA has determined that a couple of his high school courses did not meet their requirements for eligibility.  Hill has now been released from his scholarship at Alabama and will have to go to JUCO or pay his own way. 

This is one of the most bizarre situations we have seen since we really started following oversigning.  Alfy Hill is getting screwed, as is Alabama, and it is completely the NCAA's fault.  The level of ineptitude and the lackadaisical nature of the NCAA is sickening.  The entire signing and scholarship management process that is under the care of the NCAA needs to be thrown out the window and there needs to be drastic reform in order to prevent more kids like Elliott Porter and Alfy Hill from getting screwed over.  The NCAA has managed to create a system so flawed and screwed up that potential student-athletes can get screwed from either side of the equation (Porter by LSU and Les Miles and Alfy Hill by the NCAA clearinghouse).

Between coaches like Les Miles and the NCAA does anyone know what the **** they are doing?  You have coaches signing more players than they have room for and then having to cut players in order to make room and you have a governing body who cannot accurately determine if a player is academically eligible in a timely manner and leaves a loophole in their bylaws that allows coaches to hedge their bets against their ineptitude.   It is almost like the NCAA is telling coaches, "since we are not efficient enough to tell you who is academically eligible in a timely manner so you know exactly how many players to sign or who to sign, just go ahead and sign as many as you want and sort it out later."  WTF???

The combination of coaches willing to oversign and ineptitude of the NCAA is a lethal combination that results in guys like Porter and Hill getting screwed.

This by no means excuses coaches that oversign.  They know the deal and they should at least keep their side of the street clean and some do - shame on the others that don't (Les Miles, Nick Saban, Houston Nutt, Randy Shannon, Butch Davis).  After all, it is these coaches and not the NCAA that are in the living rooms of recruits promising them and their parents that they will take care of them for the next 4 years. 

The bottom line is that the entire recruiting and signing process needs to be thrown out the window and replaced with a system that permanently closes the oversigning loophole and determines academic eligibility in an accurate and timely manner.   The new system should provide coaches with the exact number of players they can sign without going over their limit (which means the number for each team will be different every year based on who each team has graduating and leaving for the NFL early) and it should provide them with a list of players cleared to be signed.  They also need to make the letter of intent a two-way binding agreement, not a one-way agreement that only binds the recruit to the school.

Filed under: NCAA, SEC 39 Comments