Undercover police activity has become a standard feature of the contemporary political terrain. Disclosures in recent years indicate that environmentalist, anti-nuclear and animal rights groups are likely to be targeted for surreptitious investigation. This can take many forms, from an inconspicuous stranger who turns up to help at a demonstration, to a trained “deep cover” operative who may spend years working inside a target organization. These operations can be launched locally by a police or sheriff’s department, or by any of a number of federal agencies.
Another major source of inside information for investigators is the “CI” or “confidential informant.” These informers can be private citizens recruited to infiltrate a group, or fearful members who turn on their friends (usually to save themselves). WIthout the existence of the CI, or “snitch,” there would in fact be very few arrests made for major crimes. However, CIs do have major short-comings from a police perspective, including their general unreliability, questionable status as testifying witnesses, and frequent refusal to testify in open court. Therefore, the information garnered from a CI must be backed up by the testimony of undercover police officers or supplemented by an intensive police investigation (which may involve surveillance and the use of search warrants) to build a case without putting the informer on the witness stand. In fact, the use of a CI in an arrest is usually not revealed, so the investigation may appear to be nothing more than competent police work.
Any monkeywrencher who suspects surveillance, should examine associates, study who has access to information now believed to be in the hands of the police, notice anyone who suddenly attempts to distance themselves, and be alert to any other indication that investigators are receiving inside information.
The Undercover Infiltrator
Both government agencies and private companies are routinely involved in running undercover operations. Small police departments and private firms (ranging from the large agencies like Pinkerton and Burns down to the security divisions maintained by large corporations and often staffed by former law enforcement agents) typically rely on the solitary agent to ferret out information which is then passed on to the agent’s supervisors. Larger state and federal agencies have the resources to mount far more extensive infiltration efforts. Major efforts entail a team approach, with extensive backup equipment and personnel to exploit the information provided by the undercover cop. The team’s job is to protect the undercover agent and assemble a mass of evidence so that a subsequent prosecution doesn’t rely entirely on the testimony of one officer.
The increasing sophistication of undercover operations has made it more difficult to spot these people. Today’s undercover officer can look and sound like anyone. Many years ago, an undercover cop might be exposed when suspicious associates pilfered his phone bill from a mailbox and found that it listed numerous calls to a recognizable police phone number. Those days are gone as the quality and training of undercover operatives has improved. Only the crudest attempts to infiltrate, such as those occurring at demonstrations or other well-publicized events, are likely to be obvious due to the appearance or demeanor of the plainclothes officer.
There are two broad categories of undercover operative: deep cover and light cover.
A deep cover infiltrator “lives” the role. It may be someone with extensive experience in undercover work, or a young person selected from an academy training class. Novices are actually preferred sometimes because they have not acquired the typical authoritarian habits that might give them away as cops, and also because they are less likely to be recognized by regular cops in the field who might unknowingly reveal their identity in a chance encounter.
Deep cover operations are tightly compartmentalized within the investigating agency to prevent breaches of security or leaks by employees sympathetic to the group being infiltrated. These operations may be coordinated from isolated offices at training facilities like the FBI’s Quanitco Academy or the federal law enforcement training academy.
A deep cover agent is equipped with false ID (usually retaining the real first name so he/she doesn’t forget to respond to their name), and a skeleton of personal history, such as a business owner who will verify that so-and-so worked for them (and who will later notify the police that someone was inquiring). The agent’s background may be kept close to the truth to prevent slip-ups. Finally a deep cover agent may work a real job, rent a house or apartment, and live the role 24 hours a day.
An undercover cop working under “light” cover may also have a false ID, but will most likely go home to his family and “real” life (usually in another city). Sometimes narcotics officers and other specially trained agents will be called on for these assignments.
Most undercover infiltrations begin when the operative presents themself as a willing volunteer and joins the targeted organization. Often a confidential informant is used to introduce the infiltrator into a group so that she will be more readily accepted. The CI may then discreetly drop from the scene.
A high priority target organization may have a number of CIs and undercover operatives working at once, usually unknown to each other. Such multiple infiltration is used to test the veracity of the information provided.
Undercover agents may also assume roles outside the target organization but designed to provide inside access. A favorite is to pass themselves off as “writers” or members of the news media, or even as someone hoping to produce a documentary for public access television (note: the rise in “independent” media in recent years has allowed infiltrators to pose as friendly or activist media). A phony photographer or video camera crew will enhance the look of authenticity and make a record of people and actions for later use in identification and prosecution. This approach, when used at public gatherings provides better quality information and photos than the old method of concealing surveillance cameras inside nearby buildings or parked vans. These undercover officers may also use this role to seek “confidential” interviews with underground activists.
Another widely used undercover role is that of a utility worker or phone company repair person. This approach is valuable for obtaining access to a suspect’s living quarters or workplace. While inside, the officer can plant listening devices, size up the security measures for a later “break-in,” or look for evidence of illegality that can be used to obtain a search warrant. If the suspect is a renter, the landlord’s cooperation may be sought to obtain legal access without a warrant, to provide nearby facilities for surveillance, or to provide cover for an undercover officer who may act as a handyman or building superintendent. If you rent, you should go out of your way to remain on good terms with your landlord. Even if your landlord doesn’t tip you off to police inquiries, a sudden change in her behavior around you could alert you that something has happened to change her opinion of you, and that “something” just might be sudden police interest in you. The same rule applies to neighbors, employers, and co-workers. The people around you every day can provide the first warning of danger.
If utility company employees come to your door seeking access and you didn’t request service, you should request some ID first, and then call their office to verify their identity and their reasons for requesting entry. Look up the phone number yourself, since the number they provide could be as phony as their ID card. However, remember also that acting unduly suspicious might c cause a bona fide repair person to wonder just what you might have to hide.
Yet another undercover role is that of the phony “lawyer” who contacts a suspect before the shock of arrest wears off in an effort to elicit information. This person may claim to be a lawyer, or may just user subterfuge to create that impression. You can, of course, ask for some ID such as a state bar membership card. The period immediately after arrest is a dangerous time. Even after you take on an authentic lawyer to represent you, you may want time to think about your situation before deciding how straightforward you want to be with your attorney. Contrary to the old adage, it is not necessarily essential that your lawyer know everything. For instance, your lawyer may not need to know that you’re guilty, just that you intend to plead innocent.
Similar to the phony lawyer approach is that of the fake court official. This person may ask you for a statement or ask you to fill out a form (to be used for handwriting comparison). If someone like this approaches you, verify the person’s identity before doing anything else.
If you are in jail, the prisoner sharing your cell may be an undercover operative, usually a “jail-house snitch” who routinely seeks information for the authorities from talkative prisoners. Finally, the prosecution may attempt to place an informant in your legal defense committee.
The first task of an undercover infiltrator is to gain unquestioning acceptance within the group. Often she will play it cool, do volunteer work, and bide her time awaiting opportunity.
The goal of undercover cops is to identify suspects and gather evidence for prosecution. They may volunteer for any job, just to widen their access to information. Often they seek clerical or leadership roles to extend their influence and gain access to membership and contribution records. When the FBI was working to suppress the American Indian Movement, they had an undercover agent working as AIM’s head of security.
Sometimes, undercover agents may go beyond the identification of suspects and the gathering of evidence: they may actually encourage someone to participate in an illegal act, and then help the police set up the arrest of that person or persons (the classic “agent provocateur”). Don’t make the mistake of thinking that this sort of thing is only found in spy novels, or went out of style with the demise of the Czarist secret police. There is a good deal of evidence to suggest that the decline of a number of radical groups in the US in the 1960s and early ’70s was speeded up by the judicious use of agent provocateurs (as well as simple informants) by both Federal and local police agencies.
One way these agents try to spot potential monkeywrenchers they can set up for arrest is to act especially radical and “talk tough” when around other members of the group. If someone responds, the agent will then provide ideas, information, or equipment to the monkeywrencher(s) to encourage specific illegal acts which can later result in arrests. Such agents may brag of having participated in numerous illegal acts, in order to attract recruits. In early 1989, a story unfolded about the infiltration of animal rights and environmental organizations by several undercover operatives. In this case, the agents were apparently employed by a private security company whose clients included corporations under attack by animal rights activists for their abuse of laboratory animals. In one incident, these agents appear to have helped engineer an attempting bombing in which an animal rights activist was arrested. According to Ecomedia Bulletin, a Toronto anarchist publication, one agent (Mary Lou Sapone) was on the mailing lists of numerous animal rights and environmental groups, including Earth First!
The most valuable information an undercover agent can obtain includes admissions of guilt and plans for future raids. The agent will often seek to record this information for later presentation in court. The basic way to do this is to “wear a wire,” either a small transmitter or a recording device concealed on her person. If this is deemed too risky, the agent may try to arrange an incriminating conversation in a car or room that has been bugged in advance. Any such recording is completely legal, requiring no warrant, as long as one party present (the undercover cop) consents to allow the recording. When pre-selected locations are used to stage an incriminating session, hidden video cameras using tiny “pinhole” lenses which are nearly impossible to spot may be used to make a record of non-verbal, but possibly incriminating evidence, such as the node of a head, or the passing of a written communication.
Electronic recording has become so common that often police agents questioning suspects openly will wear small recording devices.
If a suspect makes an incriminating statement in the presence of an agent when not under electronic surveillance, the undercover agent may then try to arrange a second incriminating conversation at a time and place when it can be recorded. Note: contrary to popular myth, an undercover cop does not have to admit being a cop if confronted with the accusation.
Undercover operatives enjoy logistical support that greatly expands their ability to gather evidence. In addition to sophisticated electronics, they often use a wide variety of vehicles (usually confiscated) to allow unobtrusive surveillance.
Measures taken against suspects fingered by an undercover operative include the following:
- Physical surveillance of a suspect and her residence, which will continue during nighttime and other times when illegal actions are more likely to occur.
- Video surveillance of a residence by cameras hidden in parked vehicles or nearby buildings. Remote video surveillance has become especially popular in rural areas where the physical presence of officers may stand out. Cameras may be hidden in brush and trees, with coaxial cables run to a monitoring post (perhaps in a neighbor’s house).
- Trash may be searched for incriminating items, names, and addresses of associates, financial records, records of travel, etc. Trash may be either directly retrieved from the suspect’s trash can, or retrieved later from the trash truck after normal pickup.
- A “pen register” may be installed on the suspect’s phone line. This device makes a record of all phone numbers dialed but does not record conversations. Such a record may be useful in establishing a pattern of calling associated with illegal actions, and in establishing a suspect’s associates. Undercover agents, wanting to frame a leader with whom they have limited contact, will encourage an individual against whom they have incriminating recordings to phone the leader merely to establish evidence of contact in an effort to support conspiracy charges against the leader.
- Bank records may be scrutinized for signs of travel or incriminating purchases. These records sometimes may be secured unofficially, through the “good-old-boy” network, since many former law enforcement personnel end up in bank security posts.
- Utility company records may be checked. These might show valuable information, such as a drop in power usage which might indicate a prolonged absence at a key time.
- Authority to conduct “mail cover” may be secured from postal authorities. This involves the recording of all the information on the outside of letters and packages (without opening them to check the contents).
- A “bumper beeper” may be secured to the underside of a suspect’s vehicle with wire or magnets. Such a device allows surveillance vehicles to track the suspect’s movements from a safe distance so as not to betray the agents presence.
Note that none of the above investigative methods requires a warrant. If the police can develop sufficient information (usually just a “pattern” of suspicious behavior) they can then obtain warrants for more invasive methods, such as success at getting permission from federal judges to install phone taps and room bugs based on elaborate and often fanicful conspiracy theories.
Private Undercover Operations
When private investigative agencies infiltrate a radical group, they usually assign operatives with little training, sent out on a fishing expedition to pass along any and all information on the activities of the target group. More experienced operatives may have a background in employee investigations and are generally “hired” by an established business to pose as an average employee while actually seeking information about theft, drug use, union activity, or anything else of interest to management.
Private operatives may use their real identities or fabricated ones. They routinely provide written reports to their employers to justify their job. Because they are not law enforcement officers, they are more likely to instigate or provoke others to commit illegal acts, conduct illegal searches and surveillance, and generally engage in the kinds of actions whose evidence would not be admissible in court. Private operatives also typically lack the costly support systems of police undercover agents and can be more readily exposed.
These private undercover operatives have been repeatedly used against the environmental , anti-nuclear, and animal rights movements.
The confidential informant, or “CI, is possibly the most valuable tool used in law enforcement. CIs are obtained by a number of means:
- Walk-in. These are disgruntled or disenchanted members of a target organization who volunteer their services, for a variety of reasons. They may have joined a group with good intentions only to become offended by what they see as overly radical tactics. Or they may be ambitious people who have been passed over for leadership roles and decide to seek revenge against those they think slighted them. Or they may be wackos who seek revenge against someone in the group for personal reasons, including romantic ones.
- Tip-offs. The future CI is indiscreet in talking of illegal exploits, and is overheard by someone not of the group, who in turn informs police. The police approach the future CI, and are able to persuade her to roll over.
- Deal-makers. Someone who is arrested on a serious charge may try to avoid prosecution or obtain a lighter sentence by agreeing to infiltrate a group to obtain information about other illegal activities. This often occurs with drug busts.
- Recruits. Known members of a target group may be targeted for recruitment by the police. The effort usually begins with a background check for signs of vulnerability. An individual who appears “weak” might simply be interviewed repeatedly by a persuasive officer until he agrees to cooperate. A conservative employer, perhaps one with a law enforcement or military background might be enlisted to help in pressuring the prospective recruit. In the past, for instance, the FBI has used interviews with employers to intimidate members of political groups.
Similarly, a spouse may be approached to aid in the recruitment. Veiled threats to children or to one’s job security have often proved effective. Also, the parents of the would-be informer may be approached to secure their help. This approach may be particularly effective if the subject is, say, a college student receiving financial support from their parents.
- People who have never been arrested, or young people heavily influenced by their families, are often more susceptible to becoming CIs than those with more experience.
Be especially cautious when dealing with people who volunteer inside information from their position in the offending company, agency, or the like. Such people may be sincerely on your side, and if so, their information can be extremely valuable. But it is also possible that such people, particularly if they approach you first, are double agents. A double agent will, under the pretext of helping your group, actually give you misleading information that can be harmful. Such a person may even try to set the group up for an arrest.
If you have such a “volunteer” and you think he or she might be useful to you, reduce the risk to any actual monkeywrenchers by dealing with them through an intermediary who serves as contact person. The contact should be someone you know well and are sure is on your side, but who has never participated in illegal actions, and who has no intention of ever doing so. The contact serves as a “cut-out”, passing on information from the volunteer informant and providing a protective layer between the informant and the action group.
It is important that information only flow in one direction, from the informant to the action group. The informant, no matter how helpful, should never be told of plans or actions by the action group. This also protects the informant, in case of investigation by police or company officials. For this reason, you never make any written record of the informant’s identity, lest this fall into the authorities’ hands.
Because your contact person is exposed to the threat of arrest (especially if the informant really is a double agent planning a set-up), she or he must be mature and emotionally stable enough to stand up under interrogation to protect the identity of the action group.
If you have reason to suspect that your informant is a double agent planning a set-up, arrange to secretly tape-record meetings between your contact and the informer, in which the informant can be caught making provocative statements designed to incite illegal action. Such a recording could be quite valuable in the defense of anyone charged with a monkeywrenching offense. However, any such tapes (or other evidence) should never be kept at home where police could use a warrant to seize and destroy the. Remote rural burial is perhaps the most secure option, so long as you encase the tapes in several layers of water tight plastic bags.
Your contact should have solid alibis at the time of any action. Being in a public place where others will be able to provide later verification is a good way; being verifiably out of town is even better.
The contact should be very careful when passing information on to the action group. A pay phone to pay phone call, arranged at the last minute, is generally secure (there are very few payphones these days that accept incoming calls, making this route increasinly difficult). Face-to-face meetings in open areas like parks are also usually secure from electronic eavesdropping. Pass information on verbally, making no written notes that can be seized as evidence, and on a strictly one-to-one basis. If confronted, denials will be more convincing if the content of a conversation hinges on one person’s word against another’s. Another precaution is for the contact to pass on information as if it were idle conversation or gossip. If no illegal activity is actually discussed, it will be harder to provide that a crime has been committed.
Exposing Undercover Agents
When dealing with a suspected undercover agent, be patient. Undercover operations can be very costly and if they don’t produce results, they may be discontinued or moved elsewhere. If an undercover agent fails to elicit any useful information after a considerable time, they may move on. Incidentally , beware of the person who moves constantly from one area to another. They could be an undercover agent fishing for opportunities.
Baiting is one way to expose an undercover agent. The “suspect” is provided (seemingly inadvertently) with a bit of information so enticing that the authorities cannot resist acting on it. This could be the time, date , and place of a future action, or the location of some highly incriminating item. Of course, the action does not take place as planned, or the incriminating items are totally innocuous. If the suspected undercover agent is the only one provided with this information, and the police make the appropriate response, you have reasonable proof that the suspect is indeed an agent. If you have tipped the suspected informer to the details of a bogus action, you will need to have some method of spotting the resultant police surveillance or ambush without compromising anyone; perhaps you could have someone just walk by as an innocent pedestrian or hiker.
The baiting method can be used with more than one person at a time by providing each one with a slightly different information (different locations, times, etc.) The response will indicate which person is passing information. Keep it simple!
Remember that undercover agents usually wear a wire to record conversations. If you really suspect someone of being an agent, and there is no way to keep the person out of a key meeting, you might consider “frisking” the people attending the meeting. Another method of detecting recording devices would be to use a small metal detector (such as those used by treasure hunters and sold by companies like Radio Shack). However, in most situations this option is probably not feasible, since most people would highly resent such an invasive procedure, or consider it an affront to their loyalty.
A better option would be to come up with an excuse for postponing the meeting, until you can check out the suspected agent by other means. Often an agent will haver their recorder or a backup recorder in a day pack, purse or briefcase. As long as the conversation takes place nearby (in the same room or vehicle, say) the recording is apt to be intelligible. In situations where undercover agents expect close personal or extended contact, such as a camping trip, exercise or soaking in a hot tub, they may forego using a recording device lest they be discovered. If anything incriminating is discussed while they are unwired, they will refer back to the conversation later when they are recording, hoping to get the incriminating information on tape. Of if they suspect they are suspected, they might manufacture a situation which “proves” they are not wired for sound.
Here are a few ways u undercover agents may tip their hands:
- Seeking information they do not need under “need to know” rules.
- Trying to get people to repeat incriminating statements made at an earlier meeting (so they can be recorded). If you are suspicious, say you were just joking when you made the earlier remark.
- Repeatedly casting suspicion on others without basis. This may be a smoke screen to keep suspicion off themselves.
- Showing an extremely shallow understanding of the issues. An undercover cop may know only what they have been briefed on. Some, however, are good talkers and can sound knowledgeable without really knowing an issue in depth.
- Making boisterous demands for action and belittling more timid members of the group. Because many cops have authoritarian, even violent personalities, they may reveal this inadvertently.
- Showing extreme nervousness, such as looking around constantly during an action. (They may be looking for the surveillance or backup team.)
- Slipping away to phone or meet supervisors or control agents. Such meetings may be brief , in a car at a public parking lot, for instance, or in a department store. Longer meetings, such as “debriefings” might be held in motel rooms.
- Constantly “managing” the conversation to guide it in direction they wish.
- Mentioning another person’s name when you refer obliquely to that person.
- Working the time, date, or location into conversations.
- Explicitly stating incriminating things in response to vague comments from you or others.
- Manipulating conversations to try to get some kind of affirmation from you in response to their incriminating statements.
- Regularly asking about other individuals (particularly supposed leaders).
- Initiating conversations about monkeywrenching.
- Steering a conversation back to illegal acts or conspiracies when the conversation moves on to legal and unrelated matters.
- Claiming to be a recovering alcoholic. This gives them excuses not to drink with you and possibly slip on their cover while under the influence.
- Playing different roles with different people calculated to appeal specifically to each individual’s vulnerabilities or strengths. An infiltrator may play the role of just the kind of person you need in your current mental state.
- Setting up a phony “hit” to enhance their credibility. They may arrange to attack heavy equipment, surveyor stakes, or other targets while witnessed by people they with to entrap or whose confidence they want.
Remember that a typical way for a professional undercover agent to initially contact a suspect (group or individual) is to be introduced by a non-professional informer already known but not suspected by the suspects.
Background Check on Suspected Infiltrators
A background investigation may uncover undercover operatives. Even the deep cover operative typically has only a rudimentary personal history to back up the false IDs. A basic background check through government records (a stock-in-trade process for private investigators) will usually expose the fabricated persona of the undercover cop.
Every normal person (including you) leaves a substantial paper trail as they move through life. To check someone. you need to gain access to such records.
Begin by using casual conversation to elicit details about the past of the potential recruit or suspected undercover infiltrator. Be wary of anyone who seems reluctant to discuss his or her past, family or job history. Most undercover operatives will not want to reveal their real families to persons suspected of criminal activity (for good reason!). The key period in an agent’s personal history may be the most recent years, which might be the years in which they have worked for the police department, Forest Service, Pinkerton Agency, etc. But even the earlier years in life may provide leads to friends and relatives who know about the agent’s true current employment. The “investigator” needs to be subtle in talking with such people (casual conversation), patient (gather a lot of information over time), and thorough (your freedom may be on the line).
Once you have elicited some background on the potential recruit, search public records for confirmation. You will have to violate the basic security axiom of “no written notes,” but be cautious in your handling and concealment of the information you gather. If your background investigation convinces you of the person’s legitimacy, destroy the accumulated notes in the proper method (burning and crumbling the ashes).
As you begin the background check, you will find that laws vary from state to state with regards to what is, or is not, public record – the only uniformity in accessibility (or inaccessibility) is with federal records.
Dealing with bureaucratic records clerks can be frustrating, but be patient and friendly. Don’t volunteer information. Some clerks will demand to know why you want the information. Tell such people that the records are public (if you know they are) and tell them you would prefer to work with their supervisor. This usually changes their attitude. If such clerks insist that the information you want is not public record, verify this by talking to someone else in the office, or call a similar office (county clerk) in another county.
Have a cover story. You could say you are doing genealogical research, or that you are working for a Realtor. Or you might pose as a writer or researcher.
You can find out a great deal at the public library. Become familiar with city directories. Libraries may keep files of high school and college yearbooks. The county courthouse is a veritable gold mine, and includes tax and property ownership records. State government officers keep records on businesses, auto registration, driver’s licenses and driving records. Driver’s licenses are probably the last thing you should check, since if an undercover agent has a phony license, they may have set it up so that if anyone checks on her license, it will trigger a warning to the appropriate police agency.
Remember that a record search entails looking not just at the one person, but at family, friends and neighbors. Later on, you may find it necessary to approach these people in person or by phone to elicit information about the person whose background you are checking. For this approach (with a name pulled off an old high school annual, say; this is risky in a small town) or a fellow member of some club or service organization, or an old Army buddy. You might pose as a business person verifying a job application or a request for credit. Use your imagination, and be friendly, not pushy or demanding. If you’ve verified a former job by talking to the boss, you might pose as a former co-worker when approaching neighbors or family members.
A deep cover undercover agent may have a sketchy history, such as a business owner who’ll tell you the subject worked for them. Because of this, you must take the time to dig deep. Beware of discrepancies and mysterious gaps. Don’t be in a hurry, as a thorough check of someone’s background may take months, and it may be necessary to travel to a distant city or state.
Private undercover operatives may use their real history, in which case you will need to ask around to find out about their current employment. If all else fails, you can ask something like, “Did he/she ever get that government job they wanted?”
For detailed information on how to conduct a records search, check a large public library for a copy of Where’s What, the bible for such work. Or check for books on the subject in the Loompanics Unlimited catalog (http://www.loompanics.com).
You can also hire a private investigator to run a background records check, while you pose as a prospective yet suspicious business partner, would-be spouse, or the like. Get a cost for a basic records check first and make it clear to the investigator that you don’t want word of it getting back to the target. Keep in the back of your mind, however, that if law enforcement becomes aware of the PI’s inquiry, they may compel her to join their scheme. This is most likely to occur when a records background check delves into government maintained files like auto registrations and driver’s licenses.
If all this seems like too much trouble, consider this: Undercover operatives are working right now within groups you are associated with. You can’t be too careful. Of course, because of the risk inherent in such background checks and the time and possible expense involved, it may be best to simply avoid any individual who elicits your suspicion to the extent that you feel a background check is called for.
Finally, the most certain ways to avoid being busted because of an informant or undercover agent is to work only with long-time trusted friends or to work along and give no one any hint that you are a monkeywrencher.
(This material was produced by enemies of our Movement. We’ve only edited it very slightly. Here our interest is effective security methods NOT the ideology of the author(s), which we may or may not be in agreement with. Either way we wish the author(s) the best and thank them for such quality work. Our interest in security measures should also NOT be misread to imply we are engaged in illegality in any way shape or form.)