Depending on the plastic deformation capacity required, structural steel design under the current codes can be classified into three categories: elastic, plastic, and seismic design. Most of the current steel codes explicitly forbid the use of a steel material with a yield strength higher than 450 MPa in the plastic design because of the concerns about its low plastic deformation capacity as well as the lack of test data on local and lateral torsional buckling behavior. In this study, flexural tests on full-scale H-shape members built with SM490A (ordinary steel or benchmark material) and HSB800 (high-strength steel) were carried out. The primary objective was to investigate the appropriateness of extrapolating the local buckling criterion of the current codes, which was originally developed for normal-strength steel, to the case of high-strength steel. All the SM490A specimens performed consistently with the current code criteria and exhibited sufficient strength and ductility. The performance of the HSB800 specimens was also very satisfactory from the strength perspective; even the specimens with a noncompact and slender flange developed the plastic moment capacity. The HSB800 specimens, however, showed an inferior plastic rotation capacity due to the premature tensile fracture of the beam bottom flange beneath the vertical stiffener at the loading point. The plastic rotation capacity that was achieved was less than 3 (or the minimum level required for a plastic design). Although the test results in this study indicate that the extrapolation of the current flange local-buckling criterion to the case of high-strength steel is conservative from the elastic design perspective, further testing together with an associated analytical study is required to identify the causes of the tensile fracture and to establish a flange slenderness criterion that is more appropriate for high-strength steel.
Centering around ruins recognized of being relatively early stage related to flat tile and brick, excavated in Silla capital area, the study attempted elementary approach to seek the appearance time of every remain through comparing them from the excavated cases and production methods of Short beating, Medium beating plate, Long beating plate and Stamped-roof tile. Gyeongju began to use the short beating plate made of tile-less plates or tile plate and increased its quantity. That is deemed to be due to efficiency of beating plate making methods, and moreover to be limited only for use in the palace castle and offices. That is, making short beating plates is presumed to be made merely under some definite objectives. Medium beating plate has been spread to the whole country since Silla and Baekje united. Differently from Koguryo and Baekje, Silla had its unique Beating-plates making technology available for mass-production, which was spread to the whole country and resulted in disappearing of Koguryo and Baekje technology. Long beating plate was not nearly founded in Gyeongju area, but flat tile and common tile excavated in Sachunwang Temple site and Samrang Temple 3rd remains are known. In the outskirts of Gyeongju, long beating plate appeared between the latter half of 8C and the beginning of 9C. Until now, different views have raised to appearance of long beating plate of Unified Silla, which is expected to be clarified under the situation excavated by position relations. Stamped-roof title in Gyeongju is estimated as used after the datum point year 679. While in Baekje area, five stems and branches were involved, in Silla area, code or sign was shown much. The difference between two areas would be due to each other factory, and especially the marked contents werenot letters, which means it had been changed from Baekje s existing-methods. That is, it says the production environment changed owing to Silla's merging. And stamped-roof tile was temporarily used in Gyeongju but soon disappeared, which was because Silla beating plates made under cylinder-shaped tile barrel(圓筒瓦桶) and hitting-pressing of Medium beating plate had beenspread to the whole country, so the production technology of Koguryo and Baekje was naturally dismissed. In consequence, the mergence by Silla brought about unification of each nation's special technology.
The cultural contents industries have moved closer to the centre of the economic action in many countries and across much of the world. For this reason, the concern with the development of glocal cultural contents has also been growing. According to Goldman Sock's BRICs report, Indian economy will be the engine of global economy with China. In addition, India will be a new blue chip country for large consumer market of cultual contents. The most important point for the development of glocal cultural contents is a systematic and in-depth analysis of other culture. India is a complex and multicultural country compared with Korea which is a nation-state. Therefore, this paper is intended as an understanding about India appropriately and suggestion for a strategy to enter cultural industry in India. As the purpose of this paper is concerned, we will take a close look at 9 Indian culture codes which can be classified into three main groups: 1) political, social and cultural codes 2) economic codes 3) cultural contents codes. Firstly, political, social and cultural codes are i) consistent democracy and saving common people, ii) authoritarianism which appears an innate respect for authority of India, iii) Collective-individualism which represents collectivist and individualistic tendency, iv) life-religion, v) carpe diem. Secondly, economic culture codes are vi) 1.2billion Indian people's God which represents money and vii) practical purchase which stands for a reasonable choice of buying products. Lastly, viii) Masala movie and ix) happy ending that is the most popular theme of Masala movies are explained in the context of cultural content codes. In conclusion, 3 interesting cases
Green or an environmental consciousness has been a major issue for businesses and government offices, as well as consumers, worldwide. In response to this movement, the Korean government announced, in the early 2000s, the era of "Green Growth" as a way to encourage green-related business activities. The Korean fashion industry, in various levels of involvement, presents diverse eco-friendly products as a part of the green movement. These apparel products include organic products and recycled clothing. For these companies to be successful, they need information about who are the consumers who consider green issues (e.g., environmental sustainability) as part of their personal values when making a decision for product purchase, use, and disposal. These consumers can be considered as eco-sumers. Previous studies have examined consumers' purchase intention for or with eco-friendly products. In addition, studies have examined influential factors used to identify the eco-sumers or green consumers. However, limited attention was paid to eco-sumers' disposal or recycling behavior of clothes in comparison with their green product purchases. Clothing disposal behaviors are ways that consumer can get rid of unused clothing and in clue temporarily lending the item or permanently eliminating the item by "handing down" (e.g., giving it to a younger sibling), donating, exchanging, selling, or simply throwing it away. Accordingly, examining purchasing behaviors of eco-friendly fashion items in conjunction with clothing disposal behaviors should improve understanding of a consumer's clothing consumption behavior from the environmental perspective. The purpose of this exploratory study is to provide descriptive information about Korean eco-sumers who have ecologically-favorable lifestyles and behaviors when buying and disposing of clothes. The objectives of this study are to (a) categorize Koreans on the basis of clothing disposal behaviors; (b) investigate the differences in demographics, lifestyles, and clothing consumption values among segments; and (c) compare the purchase intention of eco-friendly fashion items and influential factors among segments. A self-administered questionnaire was developed based on previous studies. The questionnaire included 10 items of clothing disposal behavior, 22 items of LOHAS (Lifestyles of Health and Sustainability) characteristics, and 19 items of consumption values, measured by five-point Likert-type scales. In addition, the purchase intention of two eco-friendly fashion items and 11 attributes of each item were measured by seven-point Likert type scales. Two polyester fleece pullovers, made from fabric created from recycled bottles with the PET identification code, were selected from one Korean brand and one US imported brand among outdoor sportswear brands. A brief description of each product with a color picture was provided in the survey. Demographic variables (i.e., gender, age, marital status, education level, income, occupation) were also included. The data were collected through a professional web survey agency during May 2009. A total of 600 final usable questionnaires were analyzed. The age of respondents ranged from 20 to 49 years old with a mean age of 34 years. Fifty percent of the respondents were males and about 58% were married, and 62% reported having earned university degrees. Principal components factor analysis with varimax rotation was used to identify the underlying dimensions of the clothing disposal behavior scale, and three factors were generated (i.e., reselling behavior, donating behavior, non-recycling behavior). To categorize the respondents on the basis of clothing disposal behaviors, k-mean cluster analysis was used, and three segments were obtained. These consumer segments were labeled as 'Resale Group', 'Donation Group', and 'Non-Recycling Group.' The classification results indicated approximately 98 percent of the original cases were correctly classified. With respect to demographic characteristics among the three segments, significant differences were found in gender, marital status, occupation, and age. LOHAS characteristics were reduced into the following five factors: self-satisfaction, family orientation, health concern, environmental concern, and voluntary service. Significant differences were found in the LOHAS factors among the three clusters. Resale Group and Donation Group showed a similar predisposition to LOHAS issues while the Non-Recycling Group presented the lowest mean scores on the LOHAS factors compared to the other segments. The Resale and Donation Groups described themselves as enjoying or being satisfied with their lives and spending spare-time with family. In addition, these two groups cared about health and organic foods, and tried to conserve energy and resources. Principal components factor analysis generated clothing consumption values into the following three factors: personal values, social value, and practical value. The ANOVA test with the factors showed differences primarily between the Resale Group and the other two groups. The Resale Group was more concerned about personal value and social value than the other segments. In contrast, the Non-Recycling Group presented the higher level of social value than did Donation Group. In a comparison of the intention to purchase eco-friendly products, the Resale Group showed the highest mean score on intent to purchase Product A. On the other hand, the Donation Group presented the highest intention to purchase for Product B among segments. In addition, the mean scores indicated that the Korean product (Product B) was more preferable for purchase than the U.S. product (Product A). Stepwise regression analysis was used to identify the influence of product attributes on the purchase intention of eco product. With respect to Product A, design, price and contribution to environmental preservation were significant to predict purchase intention for the Resale Group, while price and compatibility with my image factors were significant for the Donation Group. For the Non-Recycling Group, design, price compatibility with the factors of my image, participation to eco campaign, and contribution to environmental preservation were significant. Price appropriateness was significant for each of the three clusters. With respect to Product B, design, price and compatibility with my image factors were important, but different attributes were associated significantly with purchase intention for each of the three groups. The influence of LOHAS characteristics and clothing consumption values on intention to purchase Products A and B were also examined. The LOHAS factor of health concern and the personal value factor were significant in the relationships with the purchase intention; however, the explanatory powers were low in the three segments. Findings showed that each group as classified by clothing disposal behaviors showed differences in the attributes of a product, personal values, and the LOHAS characteristics that influenced their purchase intention of eco-friendly products. Findings would enable organizations to understand eco-friendly behavior and to design appropriate strategic decisions to appeal eco-sumers.
The concentration of economic power takes the form of one or a few firms controlling a substantial portion of the economic resources and means in a certain economic area. At the same time, to the extent that these firms are owned by a few individuals, resource allocation can be manipulated by them rather than by the impersonal market mechanism. This will impair allocative efficiency, run counter to a decentralized market system and hamper the equitable distribution of wealth. Viewed from the historical evolution of Western capitalism in general, the concentration of economic power is a paradox in that it is a product of the free market system itself. The economic principle of natural discrimination works so that a few big firms preempt scarce resources and market opportunities. Prominent historical examples include trusts in America, Konzern in Germany and Zaibatsu in Japan in the early twentieth century. In other words, the concentration of economic power is the outcome as well as the antithesis of free competition. As long as judgment of the economic system at large depends upon the value systems of individuals, therefore, the issue of how to evaluate the concentration of economic power will inevitably be tinged with ideology. We have witnessed several different approaches to this problem such as communism, fascism and revised capitalism, and the last one seems to be the only surviving alternative. The concentration of economic power in Korea can be summarily represented by the "jaebol," namely, the conglomerate business group, the majority of whose member firms are monopolistic or oligopolistic in their respective markets and are owned by particular individuals. The jaebol has many dimensions in its size, but to sketch its magnitude, the share of the jaebol in the manufacturing sector reached 37.3% in shipment and 17.6% in employment as of 1989. The concentration of economic power can be ascribed to a number of causes. In the early stages of economic development, when the market system is immature, entrepreneurship must fill the gap inherent in the market in addition to performing its customary managerial function. Entrepreneurship of this sort is a scarce resource and becomes even more valuable as the target rate of economic growth gets higher. Entrepreneurship can neither be readily obtained in the market nor exhausted despite repeated use. Because of these peculiarities, economic power is bound to be concentrated in the hands of a few entrepreneurs and their business groups. It goes without saying, however, that the issue of whether the full exercise of money-making entrepreneurship is compatible with social mores is a different matter entirely. The rapidity of the concentration of economic power can also be traced to the diversification of business groups. The transplantation of advanced technology oriented toward mass production tends to saturate the small domestic market quite early and allows a firm to expand into new markets by making use of excess capacity and of monopoly profits. One of the reasons why the jaebol issue has become so acute in Korea lies in the nature of the government-business relationship. The Korean government has set economic development as its foremost national goal and, since then, has intervened profoundly in the private sector. Since most strategic industries promoted by the government required a huge capacity in technology, capital and manpower, big firms were favored over smaller firms, and the benefits of industrial policy naturally accrued to large business groups. The concentration of economic power which occured along the way was, therefore, not necessarily a product of the market system. At the same time, the concentration of ownership in business groups has been left largely intact as they have customarily met capital requirements by means of debt. The real advantage enjoyed by large business groups lies in synergy due to multiplant and multiproduct production. Even these effects, however, cannot always be considered socially optimal, as they offer disadvantages to other independent firms-for example, by foreclosing their markets. Moreover their fictitious or artificial advantages only aggravate the popular perception that most business groups have accumulated their wealth at the expense of the general public and under the behest of the government. Since Korea stands now at the threshold of establishing a full-fledged market economy along with political democracy, the phenomenon called the concentration of economic power must be correctly understood and the roles of business groups must be accordingly redefined. In doing so, we would do better to take a closer look at Japan which has experienced a demise of family-controlled Zaibatsu and a success with business groups(Kigyoshudan) whose ownership is dispersed among many firms and ultimately among the general public. The Japanese case cannot be an ideal model, but at least it gives us a good point of departure in that the issue of ownership is at the heart of the matter. In setting the basic direction of public policy aimed at controlling the concentration of economic power, one must harmonize efficiency and equity. Firm size in itself is not a problem, if it is dictated by efficiency considerations and if the firm behaves competitively in the market. As long as entrepreneurship is required for continuous economic growth and there is a discrepancy in entrepreneurial capacity among individuals, a concentration of economic power is bound to take place to some degree. Hence, the most effective way of reducing the inefficiency of business groups may be to impose competitive pressure on their activities. Concurrently, unless the concentration of ownership in business groups is scaled down, the seed of social discontent will still remain. Nevertheless, the dispersion of ownership requires a number of preconditions and, consequently, we must make consistent, long-term efforts on many fronts. We can suggest a long list of policy measures specifically designed to control the concentration of economic power. Whatever the policy may be, however, its intended effects will not be fully realized unless business groups abide by the moral code expected of socially responsible entrepreneurs. This is especially true, since the root of the problem of the excessive concentration of economic power lies outside the issue of efficiency, in problems concerning distribution, equity, and social justice.
Land was originally communized by a community in the primitive society of Korea, and in the age of the ancient society SAM KUK-SILLA, KOKURYOE and PAEK JE-it was distributed under the principle of land-nationalization. But by the occupation of the lands which were permitted to transmit from generation to generation as Royal Grant Lands and newly cleared lands, the private occupation had already begun to be formed. Thus the private ownership of land originated by chiefs of the tribes had a trend to be gradually pervaded to the communal members. After the, SILLA Kingdom unified SAM KUK in 668 A.D., JEONG JEON System and KWAN RYO JEON System, which were the distribution systems of farmlands originated from the TANG Dynasty in China, were enforced to established the basis of an absolute monarchy. Even in this age the forest area was jointly controlled and commonly used by village communities because of the abundance of area and stocked volume, and the private ownership of the forest land was prohibited by law under the influence of the TANG Dynasty system. Toward the end of the SILLA Dynasty, however, as its centralism become weak, the tendency of the private occupancy of farmland by influential persons was expanded, and at the same time the occupancy of the forest land by the aristocrats and Buddhist temples began to come out. In the ensuing KORYO Dynasty (519 to 1391 A.D.) JEON SI KWA System under the principle of land-nationalization was strengthened and the privilege of tax collection was transferred to the bureaucrats and the aristocrats as a means of material compensation for them. Taking this opportunity the influential persons began to expand their lands for the tax collection on a large scale. Therefore, about in the middle of 11th century the farmlands and the forest lands were annexed not only around the vicinity of the capital but also in the border area by influential persons. Toward the end of the KORYO Dynasty the royal families, the bureaucrats and the local lords all possessed manors and occupied the forest lands on a large scale as a part of their farmlands. In the KORYO Dynasty, where national economic foundation was based upon the lands, the disorder of the land system threatened the fall of the Dynasty and so the land reform carried out by General YI SEONG-GYE had led to the creation of ensuing YI Dynasty. All systems of the YI Dynasty were substantially adopted from those of the KORYO Dynasty and thereby KWA JEON System was enforced under the principle of land-nationalization, while the occupancy or the forest land was strictly prohibited, except the national or royal uses, by the forbidden item in KYEONG JE YUK JEON SOK JEON, one of codes provided by the successive kings in the YI Dynasty. Thus the basis of the forest land system through the YI Dynasty had been established, while the private forest area possessed by influential persons since the previous KORYO Dynasty was preserved continuously under the influence of their authorities. Therefore, this principle of the prohibition was nothing but a legal fiction for the security of sovereign powers. Consequently the private occupancy of the forest area was gradually enlarged and finally toward the end of YI Dynasty the privately possessed forest lands were to be officially authorized. The forest administration systems in the YI Dynasty are summarized as follows: a) KEUM SAN and BONG SAN. Under the principle of land-nationalization by a powerful centralism KWA JEON System was established at the beginning of the YI Dynasty and its government expropriated all the forests and prohibited strictly the private occupation. In order to maintain the dignity of the royal capital, the forests surounding capital areas were instituted as KEUM SAN (the reserved forests) and the well-stocked natural forest lands were chosen throughout the nation by the government as BONG SAN(national forests for timber production), where the government nominated SAN JIK(forest rangers) and gave them duties to protect and afforest the forests. This forest reservation system exacted statute labors from the people of mountainious districts and yet their commons of the forest were restricted rigidly. This consequently aroused their strong aversion against such forest reservation, therefore those forest lands were radically spoiled by them. To settle this difficult problem successive kings emphasized the preservation of the forests repeatedly, and in KYEONG KUK DAI JOEN, the written constitution of the YI Dynasty, a regulation for the forest preservation was provided but the desired results could not be obtained. Subsequently the split of bureaucrats with incessant feuds among politicians and scholars weakened the centralism and moreover, the foreign invasions since 1592 made the national land devasted and the rural communities impoverished. It happned that many wandering peasants from rural areas moved into the deep forest lands, where they cultivated burnt fields recklessly in the reserved forest resulting in the severe damage of the national forests. And it was inevitable for the government to increase the number of BONG SAN in order to solve the problem of the timber shortage. The increase of its number accelerated illegal and reckless cutting inevitably by the people living mountainuos districts and so the government issued excessive laws and ordinances to reserve the forests. In the middle of the 18th century the severe feuds among the politicians being brought under control, the excessive laws and ordinances were put in good order and the political situation became temporarily stabilized. But in spite of those endeavors evil habitudes of forest devastation, which had been inveterate since the KORYO Dynasty, continued to become greater in degree. After the conclusion of "the Treaty of KANG WHA with Japan" in 1876 western administration system began to be adopted, and thereafter through the promulgation of the Forest Law in 1908 the Imperial Forests were separated from the National Forests and the modern forest ownership system was fixed. b) KANG MU JANG. After the reorganization of the military system, attaching importance to the Royal Guard Corps, the founder of the YI Dynasty, TAI JO (1392 to 1398 A.D.) instituted the royal preserves-KANG MU JANG-to attain the purposes for military training and royal hunting, prohibiting strictly private hunting, felling and clearing by the rural inhabitants. Moreover, the tyrant, YEON SAN (1495 to 1506 A.D.), expanded widely the preserves at random and strengthened its prohibition, so KANG MU JANG had become the focus of the public antipathy. Since the invasion of Japanese in 1592, however, the innovation of military training methods had to be made because of the changes of arms and tactics, and the royal preserves were laid aside consequently and finally they had become the private forests of influential persons since 17th century. c) Forests for official use. All the forests for official use occupied by government officies since the KORYO Dynasty were expropriated by the YI Dynasty in 1392, and afterwards the forests were allotted on a fixed standard area to the government officies in need of firewoods, and as the forest resources became exhausted due to the depredated forest yield, each office gradually enlarged the allotted area. In the 17th century the national land had been almost devastated by the Japanese invasion and therefore each office was in the difficulty with severe deficit in revenue, thereafter waste lands and forest lands were allotted to government offices inorder to promote the land clearing and the increase in the collections of taxes. And an abuse of wide occupation of the forests by them was derived and there appeared a cause of disorder in the forest land system. So a provision prohibiting to allot the forests newly official use was enacted in 1672, nevertheless the government offices were trying to enlarge their occupied area by encroaching the boundary and this abuse continued up to the end of the YI Dynasty. d) Private forests. The government, at the bigninning of the YI Dynasty, expropriated the forests all over the country under the principle of prohibition of private occupancy of forest lands except for the national uses, while it could not expropriate completely all of the forest lands privately occupied and inherited successively by bureaucrats, and even local governors could not control them because of their strong influences. Accordingly the King, TAI JONG (1401 to 1418 A.D.), legislated the prohibition of private forest occupancy in his code, KYEONG JE YUK JEON (1413), and furthermore he repeatedly emphasized to observe the law. But The private occupancy of forest lands was not yet ceased up at the age of the King, SE JO (1455 to 1468 A.D.), so he prescribed the provision in KYEONG KUK DAI JEON (1474), an immutable law as a written constitution in the YI Dynasty: "Anyone who privately occupy the forest land shall be inflicted 80 floggings" and he prohibited the private possession of forest area even by princes and princesses. But, it seemed to be almost impossible for only one provsion in a code to obstruct the historical growing tendecy of private forest occupancy, for example, the King, SEONG JONG (1470 to 1494 A.D.), himself granted the forests to his royal families in defiance of the prohibition and thereafter such precedents were successively expanded, and besides, taking advantage of these facts, the influential persons openly acquired their private forest lands. After tyrannical rule of the King, YEON SAN (1945 to 1506 A.D.), the political disorder due to the splits to bureaucrats with successional feuds and the usurpations of thrones accelerated the private forest occupancy in all parts of the country, thus the forbidden clause on the private forest occupancy in the law had become merely a legal fiction since the establishment of the Dynasty. As above mentioned, after the invasion of Japanese in 1592, the courts of princes (KUNG BANGG) fell into the financial difficulties, and successive kings transferred the right of tax collection from fisherys and saltfarms to each KUNG BANG and at the same time they allotted the forest areas in attempt to promote the clearing. Availing themselves of this opportunity, royal families and bureaucrats intended to occupy the forests on large scale. Besides a privilege of free selection of grave yard, which had been conventionalized from the era of the KORYO Dynasty, created an abuse of occuping too wide area for grave yards in any forest at their random, so the King, TAI JONG, restricted the area of grave yard and homestead of each family. Under the policy of suppresion of Buddhism in the YI Dynasty a privilege of taxexemption for Buddhist temples was deprived and temple forests had to follow the same course as private forests did. In the middle of 18th century the King, YEONG JO (1725 to 1776 A.D.), took an impartial policy for political parties and promoted the spirit of observing laws by putting royal orders and regulations in good order excessively issued before, thus the confused political situation was saved, meanwhile the government officially permittd the private forest ownership which substantially had already been permitted tacitly and at the same time the private afforestation areas around the grave yards was authorized as private forests at least within YONG HO (a boundary of grave yard). Consequently by the enforcement of above mentioned policies the forbidden clause of private forest ownership which had been a basic principle of forest system in the YI Dynasty entireely remained as only a historical document. Under the rule of the King, SUN JO (1801 to 1834 A.D.), the political situation again got into confusion and as the result of the exploitation from farmers by bureaucrats, the extremely impoverished rural communities created successively wandering peasants who cleared burnt fields and deforested recklessly. In this way the devastation of forests come to the peak regardless of being private forests or national forests, moreover, the influential persons extorted private forests or reserved forests and their expansion of grave yards became also excessive. In 1894 a regulation was issued that the extorted private forests shall be returned to the initial propriators and besides taking wide area of the grave yards was prohibited. And after a reform of the administrative structure following western style, a modern forest possession system was prepared in 1908 by the forest law including a regulation of the return system of forest land ownership. At this point a forbidden clause of private occupancy of forest land got abolished which had been kept even in fictitious state since the foundation of the YI Dynasty. e) Common forests. As above mentioned, the forest system in the YI Dynasty was on the ground of public ownership principle but there was a high restriction to the forest profits of farmers according to the progressive private possession of forest area. And the farmers realized the necessity of possessing common forest. They organized village associations, SONGE or KEUM SONGE, to take the ownerless forests remained around the village as the common forest in opposition to influential persons and on the other hand, they prepared the self-punishment system for the common management of their forests. They made a contribution to the forest protection by preserving the common forests in the late YI Dynasty. It is generally known that the absolute monarchy expr opriates the widespread common forests all over the country in the process of chainging from thefeudal society to the capitalistic one. At this turning point in Korea, Japanese colonialists made public that the ratio of national and private forest lands was 8 to 2 in the late YI Dynasty, but this was merely a distorted statistics with the intention of rationalizing of their dispossession of forests from Korean owners, and they took advantage of dead forbidden clause on the private occupancy of forests for their colonization. They were pretending as if all forests had been in ownerless state, but, in truth, almost all the forest lands in the late YI Dynasty except national forests were in the state of private ownership or private occupancy regardless of their lawfulness.