Brewbound Podcast: How Not to End Up in the TTB’s Penalty Box With Your Sports Sponsorship

[00:00:00] Jessica Infante: Heading to CBC? Kick things off the day before at Brewbound's meetup at Love City Brewing in Philly, Sunday, April 19th from 5 to 7 p.m. Connect with beer industry leaders, grab a drink, and catch up with the Brewbound team. It's free to attend and walking distance from the convention center. Head to Brewbound.com slash lovecity.rsvp. And don't forget to catch the Brewbound team at booth 956 during CBC. What should you do if the TTB comes calling? Find out on the Brewbound Podcast. Hello and welcome to the Brewbound Podcast. My name is Justin Kendall and I am the editor of Brewbound and I am joined by Brewbound managing editor, Jessica Infante. Hi, Jess.

[00:00:53] Trade Bureau: Hi, hi, hi, how are you?

[00:00:55] Jessica Infante: I'm okay. And also Brewbound reporter Zoe Licata. How you doing, Zoe? Great. How are you? Doing well. We're just going to jump into this week. We've got two great guests. We have Alva Mather, head of the McDermott, Will & Emery'The Alcohol Regulatory and Distribution Group. Welcome, Alva. We're glad to have you.

[00:01:17] The Alcohol: Nice to be back.

[00:01:18] Jessica Infante: It's always a pleasure to have you here. And we've also got McDermott, Will and Emery counsel, Nichole Shustack. Welcome back, Nichole.

[00:01:27] Tobacco Tax: Hi, thanks for having me.

[00:01:29] Jessica Infante: So we keep seeing all these fines that come in. Well, they're not fines, they're offers in compromise that are going to the TTB. And a lot of what we've seen recently have dealt with sports sponsorships, things for arenas or venues. And we want to get into, you know, how producers who are going to play in these spaces can avoid this. And before we get started, we've got to do the usual disclaimer. And I'm going to leave that up to Jess because she's better at that than I am.

[00:02:01] Trade Bureau: Oh, yeah. So Alva and Nichole are not offering legal advice. They are here to discuss their opinions. But if you have questions about anything mentioned in the podcast, you should contact your own attorney.

[00:02:11] Jessica Infante: And with that out of the way, we'll get started here. I want to start with what an offer in compromise is. And that is essentially a settlement for any violation of the laws and regulations that the TTB administers. So typically you'll see in these administrative actions, they'll explain it's a violation of the Federal Alcohol Administration Acts prohibitions. And a lot of times they'll say Tidehouse, an exclusive outlet. Am I right on there, Alva? Is this the typical way some of this goes down?

[00:02:42] The Alcohol: Yeah. You can have an offering compromise for many different types of violations, including failure to pay the right excise tax. But the ones that I know that we're focused on and have been coming out more in the industry are the ones more on the trade practice side. So That's going to include Tidehouse. It's going to include Exclusive Outlet. You know, it's just going to include other categories that we know under that general trade practice umbrella, like exclusionary behavior, which is a lot of what, you know, we can get into that discussion that they're looking for and they're trying to clean up, so to speak, in the marketplace through these offers and compromise.

[00:03:25] Jessica Infante: And these offers in compromise have crossed tiers. The most recent ones we've seen on January 18th, the TTB accepted $305,000 from Fifth Generation, which produces Tito's Vodka. On January 10th, it accepted $225,000 from Dahl Distributing in Des Moines, Iowa. On December 16th, it accepted $225,000 from Robert Chick Fritz in Bellevue, Illinois. And all of those listed sponsorship deals definitely differing in each of them. But you can see, if you look at the TTB page, how enforcement has increased in recent years. And that's because they've received, I believe, $5 million to conduct some of these investigations. There were 21 offers in compromise in 2021. That included one for a sponsorship deal of the Iowa State Fair. Iowa Beverage Systems paid that. There were nine in 2020, and that included the $5 million record offer in compromise that Anheuser-Busch paid for sponsorship deals. So we've seen all this enforcement actions in recent months and in recent years, really. And I guess the overarching question I have is, for the companies who want to work out these types of sponsorship deals, how can they do so without running afoul of the TTB at this point?

[00:04:47] The Alcohol: I'll tackle that to a certain extent, and I think it'd be important to get Nichole's buy-in here too. I think from where I sit, because I end up sitting in those trade practice investigations with TTV, and so what they're looking for is they're looking for behavior where through the sponsorship, they're looking for buzzwords and buzz concepts, exclusive. You are the exclusive craft beer sponsor of a particular sports venue or sports team. Anything that uses the word exclusive, even if it's not exclusive in the way that it is excluding other people from participation, which is really what the legal standard is, those are the types of things that TTV is going to be looking for. But also to make their case, on the back end, they're going to also look for that exclusion. If you are the exclusive craft beer sponsor for a particular sports venue, what are the sales of your products versus other products? That's the back end. But I think, Justin, to your question is knowing we've got that back in knowing that we've got this stepped up enforcement. And also I'll just add, this is gonna continue, right? Because we've seen the uptick because of that $5 million allocation, but investigations take a long time, right? So offers and compromise that we're seeing today were the result of investigations that are usually two to three years in the making, right? So there's more and more in the pipeline. to come. But I think the bigger thing for your audience is when you're getting into these sponsorship activities, what should you be thinking about? What can you do in at least trying to mitigate your exposure? So I'm going to turn that over to Nichole because that's what she gets to do for a lot of our clients. I get to be the ax on the back end.

[00:06:52] Tobacco Tax: Yeah, I think particularly with sponsorship agreements and sponsorship arrangements, you really need to kind of take a two-pronged approach to kind of navigating this. And the first is to ensure that from a contractual perspective, you're navigating the complexities both on a federal level, but from a state perspective and a locale perspective, that the arrangement for the sponsorship is compliant with all laws. And so what you have contractually is a guideline to what you also need to keep in mind, which is the practical implementation of the sponsorship arrangement. So you have both what's in writing and not just what's in writing within the contract, but all of the emails and correspondence that goes along with that, but also what's being done practically. So I think one of the things that the TTB highlighted in some of these more recent offers and compromise has been arrangements for things that didn't actually take place. So it's really important to ensure that what you're contractually agreeing to is both compliant, but you're actually carrying through with that. So there isn't a hook for an enforcement officer to say, hey, you agreed to a sampling, for example, that never actually happened. Where are those funds now? So ensuring that what's actually played out is also you know, compliant with all laws. And that can be really tricky to navigate. And, you know, there's absolutely things you can do from a contractual and a practical perspective to kind of navigate that and ensure you're, you know, compliant with.

[00:08:27] The Alcohol: Yeah, and can I actually have sort of another thought on that, which is, there's sort of like the front end, right, which is the contract, there's the back end, right, which is the enforcement, and then there's everything kind of that circles around that, right. And I think, you know, TTV is smart, and they're, they're going to look at a contract, they're gonna say, that's, that's great, like, whatever that says. What I want to know is what in fact happens, right? So in these investigations, they're looking for emails, right? They're going after sales and marketing folks, right? Those are the people they're going to talk to. Those are the emails that they're going to look for. Because, you know, in those roles, they're trying to make something happen, right? They're not going to necessarily you know, have the rigid legal hat that I'm going to have, or Nichole's going to have, or in-house counsel is going to have. And so some of this too goes into the importance of training, right? Knowing that we're in this environment, getting your people internally to understand there are buzzwords like exclusive or otherwise, you know, there are ways in which, you know, you're trying to make a deal and you're trying to do your job. You're trying to do sales, but there's a way in which, you know, sales and the rubber hits the road when you're dealing with some of these more high profile contract because they do think that there is there's a reason that TTB is focused on sponsorship deals at large venues. I don't have a crystal ball, but I will tell you from where I sit, that is absolutely going to continue to be an area of focus for them. So any supplier, right, that is, and wholesalers too, but you know, we represent mostly suppliers in this space, has to sort of do both of those things, right, really sensitize their folks to how they're making these deals and what they're putting in emails and things like that. And in addition, like Nichole said, to actually executing on what that agreement says once it's in place.

[00:10:26] Jessica Infante: Alba, you mentioned those buzzwords. Does official rise to that level as well?

[00:10:31] The Alcohol: You know, it's sort of like shades of gray. I mean, I think, you know, official certainly has that same connotation. Right. So, you know, there's never from an investigation standpoint, it's very rare that you're going to have this silver bullet that has a contract that says. Hey, supplier A is going to pay retail concessionaire B $100,000 if you put our products out there. So those things, most people will understand you can't do that. So TTV is looking to put together a case of all those little pieces. And so I think anything exclusive Officials certainly could be in that category. I don't see it as strong because it doesn't tie into legal concepts coming out of the FAA. Anything about competitive, any restrictions whatsoever in the contracts on competitive products. If, for example, you're putting sponsorship banners or other things on a concessionaire within one of these big sports arenas, those are the types of things they're looking for.

[00:11:41] Tobacco Tax: To feather that out a little bit more, I think when you're approaching a sponsorship agreement, the thing you really need to be worried about is pouring rights. So there's pouring rights and there's advertising rights. And where we're seeing suppliers and wholesalers get tripped up is when those two kind of cross over, right, that the payment for advertising rights, which is compliance, which you're able to do. trickles down and starts to influence the independence of these concessionaires, right? Where purchasing of an advertising space means, for example, that there's a handshake deal that they can't maybe serve a competitor's product, or they're limiting what can be served, or that there's an expectation that your product is served. Pouring rights should never be a part of your contract or your deals, but advertising rights, or if you're an official kind of sponsor of an event is permissible. So finding that space and navigating that both contractually, but also practically kind of where you want to be.

[00:12:41] Trade Bureau: That's really helpful. And that's really interesting. So pouring red should never be a thing. You should not expect to get this. This should not exist. Generally, yeah. Gotcha. So I'm going to cook up a slightly crazy hypothetical so that it can't be mistaken for anything. But let's say, you know, I own Justice Brewery and Justice Brewery is becoming the official craft beer partner of the local... Justin Stadium. Justin's Stadium. And Jess's brewery, our flagship, is a really nice Saison. So Justin wants to put my Saison on top of his stadium, but Zoe's brewery also makes a good Saison. And when Zoe comes to make her sales pitch to Justin, Justin says, oh no, thank you, we've already got a Saison. Now, if we didn't have this deal, he probably could be thinking that same thing because you don't want to duplicate too many styles when you only have so many draft lines. Does a situation like that run afoul of the FAAA?

[00:13:38] The Alcohol: Yeah, I mean, it's sort of like, what is the technical legal answer to that versus what is the TTB endorsement reality we're living in? Because the technical legal answer is that, you know, they have to really prove that because of that deal, there was true exclusion, right? Meaning, you know, that there was kind of like that handshake deal or that understanding on the back end as between Justice Brewery and, you know, Dustin Stadium, that you're absolutely not going to pour that other stays on. And the crux of that, again, is an interference with retailer independence versus what you pointed out, Jess, which is, no, the retailer is still afraid of the side. but the reality having sat in lots of these GTV investigations is that they essentially sort of start from a perspective that like they believe that that is going on regardless of whether it is, right? So they're looking again for sort of indicia and therefore when you have instances that make perfect sense from a marketing perspective, right? Which is if you're branding you know, this particular location for Des's Brewery, of course, consumers are going to have an expectation that your products are going to be there. And maybe you do just independently have the better safe on. But what they're going to go in and they're going to try to prove because they're in the middle of an investigation, is whether or not before that deal was just in selling Zoe's Saison. What do those sales histories look like? And that's where on the back end they can make their case. But it does make it a very tricky space to navigate to try to bridge that gap between what really is lawful behavior, right? And that's what Nichole was pointing out in terms of true advertising rights. And sort of the natural and appropriate impact of that advertising, which is that people recognize your brands and they recognize your products and they want to buy those products. And so retailers independently mirror that and where the gray spaces in these investigations on who's right and who's wrong. It is grace-based, and that's the other thing, right? These are offers and compromises. These are settlements, right? It means that the parties have kind of agreed to disagree about the merits, right? We have not seen cases basically since Fedway in the 1970s, I think, in terms of really pushing what does TTP have to prove, right? What is the actual evidence behind these trade practice investigations as opposed to just, you know, the reality, which is it's not worth litigating with the government. So we don't think we did anything wrong. We think what we did was right, but it's worth it for all different kinds of reasons to enter into this settlement and move on.

[00:16:37] Tobacco Tax: I think the two other areas to kind of build off of what Alva was saying is the utilization from a supplier's perspective and entering these with kind of some gray space. We see this all the time with a supplier maybe providing equipment, right? Or something that is legal to obtain maybe some additional benefits, including maybe some pouring rights, right? And that's where we're seeing suppliers get tripped up in terms of providing things that are not just straight advertisement, right? Like I'm paying for this signage or this banner to be placed. on that field. So, you know, providing of equipment or sponsorship of some tasting, consumer sampling, like things like that, where it becomes very tricky to honestly navigate both on a federal level and on a state level, right, to make sure you're complying with all of these different laws. And then the second big one is the utilization of, you know, third unlicensed parties to kind of pay a third party to, you know, obtain sponsorship rights, right, or some of these. And it becomes very difficult for suppliers to kind of navigate, right, even with these third parties, you know, how that money is being spent. But it is their obligation as a licensee to know when they make a payment for advertising rights, that's being done compliantly, even though it's through a third party, because as we all know, what you can't do indirectly, you can't, or you can't do directly, you can't do indirectly, right? So utilization of a third party doesn't necessarily alleviate your compliance obligations to make sure that your agreement ultimately is compliant with all federal and state laws.

[00:18:18] Alva Mather: So when you have so much gray area, what can companies do to protect themselves when they are still following those lawful things that are in place?

[00:18:28] Tobacco Tax: I think making sure that the four corners of your agreements and the entire deal is compliant on a federal and state level. Watching for buzzwords that Alva pointed out of exclusivity, pouring rights, limiting what can be served or the independence of the retailer. you know, taking a look at your agreements and your sponsorship deals and making sure that, you know, you're retaining the independence of the retailer, you know, is a really good first step. And then something that Alva brought up earlier is making sure that your sales staff is trained on these things, right? That they're aware that there's enforcement action occurring and there's an uptick in it and making sure that they have the tools to kind of navigate and make these deals compliantly. Trainings and materials like, state-specific one-sheets or watch-outs or things to be cognizant of and trainings on how to make these deals holistically, right? Not just what ends up on a finalized contract, but the entire process up to it are just a few things that I think you can do really practically to help mitigate your risks.

[00:19:37] The Alcohol: One thing I'd add to that is just think about sort of trying as best you can to create sort of a culture of compliance within your company. Every company is going to be different in terms of, you know, their risk tolerance for some of these spaces, because it is gray. But I do think that having folks who really are committed to compliance and see compliance as an important part of their job, as opposed to an impediment to what they want to do and sort of interfering with their ability to make, you know, to effectuate their job the way that they want. You know, if you take that from a leadership down, that can really make a difference. I mean, I had an investigation in this last month where there was an employee in the sales and marketing side that was engaging in conduct that he shouldn't have, but it was the other employees that brought that to the company's decision. And a lot of what I found when I looked at it was this person was an outlier because there was that culture of compliance, right? There was this culture that this person was not doing what they should and was therefore putting the company at risk. And they therefore didn't want to keep that risk. And I think to have that type of leadership is ultimately what's going to sort of make the difference, because your contracts can say whatever they want. But if the day-to-day and the people who execute on those relationships don't have that same buy-in, you're going to be vulnerable, which is what we're trying to avoid here.

[00:21:11] Jessica Infante: I think one of the tricky things to wrap my head around is that if I'm sitting in my arena, you know, and Jess's brewery has it, it's, you know, it's across the ribbon, you know, and it's advertising her Saison, you know, and I'm sitting there and I'm very thirsty, you know, in my arena watching my basketball team or whatever. I think that as a consumer, I might even have an expectation that I'm going to be able to get that product at that concessionaire.

[00:21:37] The Alcohol: I think that's right. And that's sort of the practical reality of what marketing is supposed to do. And there's nothing wrong with that, right? It's really, I mean, from a legal framework perspective, there's nothing wrong with saying, again, subject to retailer independence, that if a retailer wants to have your product there, you know, as long as that's their choice, then there shouldn't be an issue with TTV, right? But where it gets thorny and just brought this up earlier is, you know, there may just be a reality that you don't want to have five days on top, right? You're going to pick the one that makes the most sense for your business and tie them, like you said, Dustin, to your consumer expectations. And whether that's wrong, Right, again, we haven't litigated these cases with DTB. We're just sort of seeing what they're coming, you know, through their perspective, you know, how they're coming at it with suppliers and, you know, suppliers deciding that they're not going to challenge the gray because it's a lot to try to go to battle with the agency that completely regulates pretty much every aspect of the business and your ecosystem.

[00:22:43] Jessica Infante: I'm sorry, Zoe, Jess just makes a better saison.

[00:22:47] Alva Mather: it's fine, I mean, I might go to the TTB and, I mean, it seems like they might have my side anyway, so we'll see what happens.

[00:22:56] Trade Bureau: We'll see what happens. I think, you know, like it is, I can see how it's exciting to think about the pouring opportunities that do come with these partnerships, but really the most valuable thing that you have with this venue or the organization is the relationship because, you know, with these official contracts that get done, like that gives you the ability to say, hey, like, Justice Saison is the official beer of the Salem Witch paddleboarding team. And sorry, I'm just trying to make this as weird as possible. Quidditch. Or Quidditch, that's right. Yes. And you need to set aside the fact that, yeah, you probably will be able to have your beer poured at the Quidditch fairgrounds, right?

[00:23:38] The Alcohol: I guess the only other sort of dynamic in here, and this is just sort of a business reality, is that these laws are aimed at suppliers, and they're aimed at wholesalers, right? They're aimed at industry members. They're not aimed at retailers. And so, you know, I do think that there is a reality that, you know, different retailers or other stadium owners can be fairly aggressive in terms of what they're asking for. Because, you know, at the end of the day, when TTB calls, It's not their license that's at issue. It's not their business that's impacted. And, you know, I just, I offer that as just a reality of part of what becomes challenging for folks trying to navigate this space is that, you know, not all partners carry the same amount of risk for the same choices.

[00:24:28] Alva Mather: So when the TTB does come calling, what do you need to do?

[00:24:32] The Alcohol: I mean, you need to cooperate. I get a lawyer. You know, at the end of the day, you have to cooperate. And, you know, there can be ways in which you can, you know, with support of counsel, push back on certain things. But you have to kind of let the investigation run its course. And, you know, some of the other part of it, and this is, you know, what I try to help clients with is Whenever you are under investigation from a government agency, you want to keep it as contained as possible, right? The worst thing is, and this is what happens, is the government gets in there on pouring rights at Justin's stand, and all of a sudden that investigation morphs into three investigations because they found out about what was going on at, you know, Justin's music venue. And, you know, it's a real, Dan to find a way to be responsive, cooperative, but contain in terms of getting through whatever it is that brought them to your door and trying not to let that morph into something else. I mean, that's my advice and folks call me for these things.

[00:25:46] Trade Bureau: Nichole, do you want to add to that?

[00:25:48] Tobacco Tax: I would say just generally, you know, having a solid contract to try and avoid an enforcement altogether. Having a formalized contract, and to Alva's point, you know, it gets really tricky with some retailers or concessionaires that have a lot of leverage, right? Because they try and, you know, force you on their paper. But having a standard sponsorship agreement where you know it's compliant generally, and having some do's and don'ts, right, that you can provide or basic, basic training that you can provide your sales people and your marketing staff is really going to mitigate a lot of this because your hope is to avoid an enforcement action altogether for all of the reasons Alva mentioned. And of course, you know, it's important to seek counsel and, you know, to navigate that carefully. But I think kind of even ahead of hopefully not even having to deal with that, you know, having one of those form agreements and keeping it when possible to your Your form is my biggest recommendation because I think having a solid agreement and an understanding from your sales and marketing staff on what is compliant is key to never even getting to that point.

[00:26:59] Trade Bureau: Alva, you mentioned a really great point about how not all parties in these relationships face the same amount of risk when things go awry. And maybe it's not like a venue situation, but just a regular on-premise account that tries to engage in pay-to-play kind of stuff. And we hear about this all the time. Accounts ask suppliers to pay for coolers or draft systems or whatever. Is there any kind of punishment that they could possibly face? Maybe it doesn't come from the TTB, but is there anything that can happen to those retailers in these situations?

[00:27:33] The Alcohol: Yeah, I mean, again, like everything in alcohol kind of comes down at the state level and the state by state, but there are absolutely states out there that do put the onus equally on retailers, right? That they have responsibilities not to be taking things of value, you know, not to be essentially trying to solicit suppliers from, you know, engaging and trying to induce them into certain things. And, you know, and I think that's more where their risk lies is at those state level ABCs. But, you know, who's going to dime them out, right? I mean, because that's part of the problem, right? You think about you know, the large investigation of pay to play in Massachusetts, that came out, you know, and the wholesale there was, was very much on the hook, but the retailers eventually, you know, had to come to pay too. But that was only because someone essentially sort of blew the whistle, so to speak, on what was happening in the industry. And it was not TCB that came down, but it was rather the state. So I think that's where that retribution is, but it's never going to be equal. I mean, that's just, you know, until the laws change, there's many more top heavy issues and TTB doesn't have jurisdiction over retailers. So, you know, at the federal level, it's always going to be either wholesalers or suppliers.

[00:28:59] Jessica Infante: So maybe a dumb question, but where do these offers and compromise go? Where, where's the money go after it's been accepted?

[00:29:08] The Alcohol: TTB sits in treasury. So, you know, it goes back into the treasury fund and you know, where, where it goes from there. They know we don't, right? But certainly I do think that, you know, from what I, you know, understand in doing these investigations and in talking to TTV investigators themselves, you know, there is a lot of pressure within that department and with sort of what, you know, sort of main treasury, right, which sits kind of on top of TTV. to continue to get big dollar numbers just to add to the fund as opposed to necessarily to clean up the industry. And that's not to say there are not, and I've met them, there are folks within TTB who were in the trade practice unit who are true believers. They really feel that they're trying to clean up the industry and they're trying to create a more level playing field. Because the issue that they should be tackling is that it shouldn't be right that big supplier A is able to squeeze out little supplier B just because they happen to be the bigger player and have the big dollars. at the end of the day, that the money is going back into the general treasury coffers. And that kind of becomes like a self-fulfilling prophecy, right? Like when they have to go back to Congress to say, hey, you gave us this $5 million. Having those numbers shows that they're doing what they're supposed to do with those $5 million so they can get it again or they can get more next year, right? So they have to continue to generate these offers and compromises. and to get them at good numbers to kind of keep that going in terms of these extra funds and the dedication within the broader TTP to putting these resources in this direction.

[00:30:59] Jessica Infante: And your expectation is this is going to continue. This isn't going to slow down.

[00:31:03] The Alcohol: I see absolutely no indication it's gonna slow down. The money is continuing to come in. Like I said, I think they're in a good position to show that they can kind of justify that what they're doing is having the intended impact. That unit has been fairly built out and they've got investigations still in the pipeline that we haven't even seen. So I think this is gonna be an ongoing new enforcement environment or not new, but sort of how it's going to be for suppliers going forward. And so I think the things we've been talking about on this podcast on how to put yourself in the best position are going to continue to be really important for companies going forward.

[00:31:48] Jessica Infante: What other regulatory issues out there should be top of mind for brewers right now that we haven't talked about during this talk on sponsorship deals and enforcement actions?

[00:32:01] The Alcohol: You know, sponsorships are going to continue to be a big one. But, you know, like Nichole highlighted another one like equipment. equipment, giving free things that have value, whether that's at the TTV level or at the state level is going to continue to be important. I think some of the other big pieces that regulators are going to have to grapple with, and as a result, as an industry, we are too, is you know, kind of the third party platform, right? The unlicensed service providers and sort of where they fall into this. But, you know, that's a whole other podcast to talk about. But I think that's, you know, that's an area of development that people should be watching for as well, you know, and that ties into e-commerce, right? If you watched our webinar, that's our big topic on what Nichole and I saw coming in 2022. Yeah.

[00:32:57] Tobacco Tax: I think one of the other things just to note, and I think we talked a lot about sponsorships, right, and how this extrapolates into 2022 in enforcement efforts and to other sponsorship deals and things where you know it's pretty easy for the T. to be proven exclusion right which. It's kind of limiting so sponsorships are really the big one but another area that we haven't seen. That we didn't see a ton in twenty twenty one is expected but maybe something that will see in twenty twenty two is you know. Every focus on on some health claims in advertising. We saw a hand you know the T. to be issued an advisory. On health claims I'm saying that they're going to specifically focus on it. given the direction, all of the innovation in our space, you know, I would expect the TTV to put some focus in that area because there's a lot of things, you know, particularly out there, even in the wine space that, you know, advertising and advertising on social media and, you know, the fact that maybe it's not on your label, but it's used in kind of other forms. I think that's probably going to be scrutinized as well. So just another thing to kind of keep on the radar in terms of watchouts.

[00:34:10] Jessica Infante: Jess, keep that in mind when you're brewing your next Saison.

[00:34:14] Trade Bureau: Oh, Jess' Saison is, you know, full of vitamins, won't give you any hangovers. It's a good thing it's fictional.

[00:34:21] Jessica Infante: Yes, all the electrolytes in that. Well, Nichole and Alva, this has been great. We appreciate you being here, and there are plenty of regulatory issues for us to bring you back for, so I'm sure we'll be talking to you in the near future. But until then, that's our show for this week. Thanks to our one-man audio team, Joe. Thank you to Jess and Zoe for hanging out with me and doing this podcast. Thanks to all of you for listening. Please like, rate, review, subscribe, click that follow bell so you know when new episodes come out. So until then, we'll talk to you next week.