Hal Halpin is the founder of the Entertainment Consumer Association (ECA), a non-profit advocacy group dedicated to giving a political voice to gamers across the United States. Gamasutra Features Editor Frank Cifaldi, along with Game Developer Managing Editor Jill Duffy and Features Editor Brandon Sheffield, recently sat with Halpin to get a broader scope on his vision, the legal challenges the organization is likely to face, and the need for consumer awareness in the face of legislative ignorance.

Gamasutra: So tell us briefly about the ECA. We've had time to poke around the site a bit, but tell us in your own words.

Hal Halpin: ECA is a 501(c)(4) [non-profit agency], so that's a membership organization that's different than a (c)(4), which is pure charity, or (c)(6), which is trade association. There aren't any other similar membership organization for movies, music, or games, so we're sort of inventing the wheel. And that's probably as many good things as bad.

What we sort of parallel ourselves against, in terms of modeling, is AAA or AARP or moveon.org, because they're also membership organizations. They're also involved in advocacy, which is sort of the root of our business, and then they also provide lots of services to the members, especially AAA and AARP, where you subscribe or you become a member for a fee, and you get many times the value in terms of other things that they're supportive of with their services.

Even during interviews, Hal Halpin takes
time out to enjoy the latest issue of
Game Developer magazine!

So that was sort of the genesis of it. It came about as a result of an IEMA board meeting, the organization I used to run. We had a board meeting, and came out of it, and I realized that a lot of the conversation that we were having had sort of stopped being about the retailers and what they could accomplish inside the industry, and started becoming about the consumers, and what their wants and needs are.

That's when I realized that it's unusual that there are all these trade associations representing all these other parts of the industry, but no one's out there representing consumers and gamers.

GS: "Used to run?" Are you done working with retailers entirely now?

HH: Well, technically I'm still president emeritus of the IEMA [the Interactive Entertainment Merchants Association, which earlier this year merged with the Video Software Dealers Association (VSDA) to become the Entertainment Merchants Association (EMA)], although I don't have any day-to-day interaction with the new organization.

GS: So it looks like the primary mission…actually, I have a printout right here, I'll just read it! "The primary mission of the ECA is to give gaming consumers a voice and ensure that state and local politicians hear their concerns and appreciate their demographic power." How are they, theoretically I guess since the ECA just started, being heard? What kind of channels are we talking about here?

HH: We're a web-based organization, so hopefully all of it will be digital advocacy. And – a lot like MoveOn.org, actually – a lot of what we're going to try to do is motivate people to sort of express to us their wishes and their opinions, and then we'll be doing advocacy through our government relations team at the state and federal level, and my sort of fondest wish is to motivate people at the local level to go and actually testify, to present petitions, and to be able to sort of show that gamers as a group are not pimply-faced little kids. They're adults, and they can speak up for themselves, and I would love to get people testifying before committees.

GS: So you're talking about web-based, sort of idea gathering, and then from there there's a lot of actual ramifications in the physical world?

HH: I think both things would happen in parallel. The GI team is going to be actively out there and sort of fighting on behalf of consumers and all that stuff anyway. And it's more a matter of, how do you change a course to adapt to what your consumer members want, as opposed to cutting the course.

GS: So is it mostly politically geared?

HH: In terms of advocacy, yeah, almost all that we do in terms of advocacy is politically driven. As a (c)(4) we're not allowed to, by law and by our IRS designation, back any party or any political person running for office. What we can do is fight on behalf of consumers and do a lot of the similar things that the IGDA and the ESA and the EMA do.

GS: What kind of output will you have? You mentioned AARP and AAA and obviously they have magazines and newsletters and things like that. What are people going to get to know that they are part of the organization?

HH: We have a few initiatives internally, none of which have been announced yet, but one is that we're going to be doing a monthly newsletter that will just keep them abreast on everything that's going on, both legislatively as well as what's going on in the business, via partner websites.

I'm not sure if we're going to be generating a lot of our own content, I don't know if that falls in line with what we do. We're not really a media company, unless it involves legislative and advocacy issues, in which case, by all means. In terms of magazine, AARP's magazine is the largest in the world. It's not something that frankly I've given a lot of thought to. Eventually it could be, but I see more of our constituents as sort of digitally driven, and I'm not sure that a print magazine would fit in with that.

GS: What if anything is the ECA a direct response to? Is there one incident that really inspired you, that made you say, 'You know what, there's a need for this?'

HH: To me there is. I'm not sure that it's there yet for consumers, so we might be out ahead of the curve in terms of them being aware of the legislation or the impending doom from legislators. From our perspective, at least from mine, I noticed last year that the state-level guys started moving away from targeting retailers, and trying to haul them off for selling M-rated games, to targeting consumers. And, you know, kids being hauled off at 17 years of age for buying an M-rated game, especially when the industry is doing so much to inhibit that process, it's going from a misdemeanor to a formal felony to going on their record and inhibiting their ability to get loans or scholarships or any of those sorts of things. It's just insane. And so, to me, that was the call.

GS: When I interviewed you back in November, I asked you what the major opponents were for the retail industry. And you said, with no hesitation, the state of California, the state of Michigan, and the state of Illinois. What would you say are the three major opponents to consumers right now?

HH: It's a more difficult question to answer now, because of the timing, because we're not in session in most states, and so the election hasn't happened, and people aren't really posturing, other than generally saying, "I'm for kids!" and "I'm for," you know, "everyone being happy!" That doesn't necessarily translate into "I'm going to introduce this bill." So we're in a good position, because while we're launching and while we're new, it gives us some time to sort of get our feet underneath us. And when they do come back into session and the posturing starts more in earnest, then we'll know.

GS: Let's talk about the actual membership benefits. The benefits you are considering, according to the website, include credit cards and…health care plans? I don't really understand the relevance…

HH: It's actually kind of difficult to get your head around, especially from my old gig. With the IEMA, our mission was very focused, and what the retailers needed out of us, especially the top thirty retailers, was very specific. So we didn't need to look at affinity benefits for them, because we weren't going to be able to get the guys at Wal Mart or Target or any of these guys better health care than they could already get themselves, where with consumers, it's sort of a whole new landscape that we're out there pioneering.

I was actually half complaining to Jason [Andersen, ONE PR, also present at the interview] here on the way over, that it's sort of hard to keep my brain wrapped around where we need to be at the moment, because one minute I'll be on the phone with Chase talking about affinity credit cards, and the next minute I'll be on the phone with MetLife talking about healthcare and that sort of benefit, and then the next minute I'll be on Instant Messenger with him [pointing to Andersen] talking about very games-specific stuff.

So those are the things that are challenges that AARP and AAA have. Again, those are great models for us, not just because they're successful, but also because they sort of have core missions about which they stay true, and yet the also find time to make sure that they're taking care of their members in all sorts of different ways.

GS: Are you talking about recommended healthcare, or included healthcare?

HH: Including healthcare is an option. One of the modules, the essential business, is that everything you see on the website now is essentially the front-end, and then all of the back-end stuff, which will be the more robust part, is all ASP and modular based, and we'll be rolling out starting Q1 or Q2 one module at a time. And so in the insurance module, hopefully we'll be providing that kind of access to that kind of insurance that they wouldn't be able to get on their own.

GS: Like group benefits, basically?

HH: Yeah. Right now I think I've got pretty good healthcare for my family, and we usually go to the doctor when we want to, and it's still nowhere near as competitive as we've been hearing back from the three majors that we're talking about. So it could be huge. It could be really beneficial to the average gamer who may or may not have their own benefits, this could be a real opportunity.

GS: This is kind of a silly question, but have you talked about those specific areas that would need to be targeted for gamers, like eyesight, or chiropractic stuff?

HH: When I met with the brokers, I told them to try to get us the most robust package that they could get. Usually you can get a better package the more defined you get, but since we don't know who are consumer is and who our members are going to be, for the next three to five years we'll be experiencing that as it happens. So I said to go out and get the best you can get for everyone. So as much as we can get, as deep as we can get, and at the cheapest we can provide.

GS: This may be premature, but what kind of demographic are you expecting now and in the future?

HH: I think that my initial anticipation was that we were going to get, you know, GameStop employee kind of people, who are hardcore console, but not necessarily online gamers or casual gamers. And it ended up being a lot more online people, and even more hardcore people; over the course of the first week, anyway. And I think that may be to the credit of Jason here, because there were so many online stories, and the print books haven't hit yet. Every time a story hit, we saw a spike in membership.

GS: What kind of numbers are you expecting?

HH: So far we've been seeing one per hour which, when I talk to my advertising brethren, they say it's a pretty good rate. So…I don't know. It's sort of the 100 million dollar question for us internally as we try to plan both financially as well as in terms of organizationally. We're trying to figure out, because there's nothing similar to this, again, anywhere else in the entertainment industry, where…where do we go? How quick is this growth going to happen? What I can tell you is that a lot of the marketing that we're doing will be in Q1, so we'll probably have a much better idea in Q2 – March, April, May – about how well we're penetrating into our market.

GS: How are you going to make sure that you're actually advocating what your members are wanting? Like, are you going to be able to support specific initiatives that will be voted on, or…?

HH: It may end up getting that specific. I'm not sure that we'll be there for a while, mainly because we're going so broad that pretty much any anti-gamer or anti-games legislation, we're going to be out in front of. And hopefully before our members know about it we'll be out there already fighting against it. But certainly there could be issues that crop up in the future that they either bring to our attention or we realize is sort of a parallel issue that we wouldn't have thought was inside of our scope.

GS: And are you thinking at all of partnering, or have you partnered with the ESA or ESRB-type people to present some kind of unified front of game-related organizations?

HH: Absolutely. In my last role at the IEMA I worked very closely with the ESA, with the ESRB and with IGDA, and I think we work most effectively when we work together. The ECA isn't really "industry" anymore, but going forward with sort of common goals and common initiatives is really impactful. I can see it work at the state level, I've seen it work in the media, where a journalist – in the mass media, especially – will call up and say "Oh, I'm just following up on a story on how you people try to murder everyone, and you make this insane stuff that influences our children." And they spend time on the phone with me, and Jason [Della Rocca, IGDA] and Pat [Patricia Vance, ESRB], and when they're done with the story it isn't as sensational. We probably didn't turn them around 100 percent, but the story wasn't anymore about the sensationalism. That coalition building is really important for us throughout.

GS: And how are you anticipating teaming with the parent side of things, because it seems that with a consumer organization, you might be in a better position to inform parents. That seems like a big deal, parents versus evil video games. What are your thoughts about how to deal with that?

HH: Funny that you mention that! We have a press release that we're dropping Wednesday. We got called early on when we were deciding to the sort of initial building of the ECA, and publishers in general were trying to find out how they could be helpful, because they were excited about the fact that consumers were in power to get in the fight. And my response to them generally was, I'm not sure how we can receive any of your funding. All of our funding comes 100% from our members. But what I did say with them is that we'd love to partner with you in ways that we're working together, in ways that you can communicate to your consumers who are our prospective members that we're here and what we're about, and one of the really good feedbacks I got was from NCSoft, who said they had just launched this initiative called PlaySmart.

PlaySmart was this two-sided card. On one side it had information about kids and how they could be safe online and how they could share and what information to share, and on the other side was information for parents about how to be careful with what their kids are playing, what they should and shouldn't be sharing in terms of information online. And I looked at that and said, this is the most responsible piece of literature I've ever seen a company create, inside our industry anyway, and they were doing it purely on their own. And it wasn't like they were out there seeking the PR or for any other reason. And so we partnered with them. There's going to be one card inside every retail NCSoft game, so that every piece that goes out will have the card in it, and the ECA will be distributing it at every conference that we go to.

So hopefully we'll get some attraction with parents that way. The other way is I want to try to embrace parents that are casual gamers. There are a tremendous amount of casual gamers that are from the top end of our demographic that we inside the industry debate whether or not they should be included, whether we skew the demographics or not, and to me those are all prospective ECA members or parents of ECA members.

GS: On the entirely opposite end of the spectrum, or maybe not: last time we spoke, we talked about the difficulty of selling AO [ESRB rated "Adults-Only"] games, particularly on the retail level. I was wondering what sort of benefits the ECA could offer for that audience?

HH: Well, in terms of the retail landscape, I think that that's probably changed with the merger of the IEMA and the SDA. The SDA is much more open to adult content. They're partnering with the Adult Entertainment Expo, and they have a lot of members who buy and sell and rent adult content.

That said, I'm not sure. I just don't know, in terms of the ECA, whether that would be something that we might want to tackle, that our members feel strongly about, above and beyond talking about it. But I do think it's important to inform our members about what's going on.

GS: As far as staff goes, how many people on a sort of full-time basis do you envision being dedicated to the ECA.

HH: I actually gave this a little bit of thought! I’m not sure, because I'm not sure how many full-time internal people are going to be required. I have warned our IT department that there's going to be this need that's going to be expanding, and I was really pleasantly surprised by some of the early members wanting to be involved. "What can we do? How can we do more?" And I was thinking actually of copying the CMP model of sort of empowering them by employing them through volunteerism, and people who have proven themselves as leaders on other forums online, and other communities, or proving themselves through us over time, could be empowered to help on a volunteer basis. So it would put less strain on our internal staff, and allow us to focus on new initiatives, and also leave people who are best at it to do it, rather than us training and developing guidelines.

GS: Are there funding models beyond the $19.99 annual subscription fees?

HH: There are. There are a few other initiatives that we've been working on, including the newsletter and other things that we haven't fully developed yet. However, for financial modeling purposes, we only use the membership at present.

GS: Now, you're talking about distributing these cards in game packages, and placing ads in enthusiast magazines, but these are people who are already, for lack of a better word, "hardcore" gamers. Are there plans in place to reach out to a more general audience?

HH: Yes, though there's nothing in place yet. We have had internal discussions about partnering with parenting magazines and other media that could reach them. One of the conversations I had just within the last hour or two with our PR firm is perhaps us creating documentation that we could give away to media, that they would be able to reproduce, so it wouldn't be a burden on them editorially, and we'd be able to get a) some branding for us, b) a place for parents to go, rather than come to us and to other sources that might not be so fruitful, and c) it gives that readership empowerment and knowledge about what's going on and the issues. So that's one of the new things that we've just recently talked about, actually. We're only a week in! [laughs]

GS: And we're grilling you! [laughs] How has the response been from the development community?

HH: I've noticed some developers whose company names I noticed in the URL from when they joined, but generally speaking I've heard really nice, resounding supportive reaction from both publishers and developers. I've come to know a handful of developers from having gone to GDC and speaking on panels, and just sort of walking with my eyes open, because my fifteen year career is pretty much on the opposite end of the industry from them.

So every year I go to GDC just trying to learn more and trying to understand more. That leads to me knowing very few people on the development side, and so the ones I know I try to look regularly to for feedback. So…so far, so good! I think probably the whole industry, regardless of where you are, is in this sort of wait and see mode. Like, oh, this is really interesting, this has a lot of potential, this could be great…now, let's see you do some stuff!

GS: Was there much of a change fundamentally in your responsibilities in switching from the IEMA to the ESA? It seems like a logical progression in many ways but at the same time it's, you know, an entirely different group you're representing here.

HH: Well, the two organizations are as different as night and day. And every day is unique; not just topically when conversation changes, but also how you approach it. I was warning my staff last week that we've had anywhere between 29 and 39 bosses before, because that's how many retailers there are in the business, and we're going to have…a few more than that now! [laughs] And all of those people are potentially our boss, so we have to be careful that we're taking all these opinions from this broad spectrum of consumers, from hardcore online gamers to hardcore console gamers, to people who do both, to people who play casually online, like the demographic we were talking about earlier. So it's going to be a challenge to try to be sure that we're staying true to our core mission, but at the same time servicing all those people, and that's sort of the big difference between the IEMA and the ESA.

GS: You're talking about the potential of attracting this casual crowd. Um…how? [laughs] I mean, it doesn't seem like there are any political issues that these particular gamers have to worry about. Why would they want to join?

HH: Well, it's another one of the challenges of educating them. We were testing some internal ads, the ones we'll be dropping in January, and even at our ad agency – which is one of the bigger ad industries inside the games industry, very well branded, they do other work for other game publishers – as they were printing out the ads, one ad that we're going to be using kept resounding internally, because people would walk over to the designer and be like, "Is this true?" It speaks about the legislation, and exactly what's going on and how much they spent against it, and I don't think even people who work inside the business understand that there were last year one hundred pieces of legislation that we had to defend against.

It's unbelievable when you think about it! One hundred pieces? Don't they have anything better to spend their time and money on than trying to nail Johnny who is buying a game at 17 that he's only supposed to have six months later when he's 18? So that sort of educational process I think would resound with anyone. So if you're a gamer, regardless of how you're classified or how passionate you play or how often, making sure that that word gets out about the truth about what's going on, and not politicizing it, and sort of deemphasizing it and demystifying it, that's our challenge.

GS: Well, with casual gamers, I think a lot of them may not really consider themselves gamers. Do you think there's anything you can do about that?

HH: I do. One of the three ads that we were testing actually has exactly that sort of messaging to it. The thing I like about the ads is that it's really a slap across the face. You're reading through your favorite consumer magazine, your favorite enthusiast magazine, and all of a sudden there's this ad that strikes you because it steps out away from everything else that we're doing in the industry, and doesn't look like everything else, and all of a sudden you're shocked because you look at it and you read the facts. And the facts make you stop. So with the casual gamer the challenge is harder, but the messaging is the same. So we're trying to partner with outlets like Yahoo! Games, or places where you find all of those audiences, and use that same messaging to the same degree, but do a different audience.

GS: You mentioned print ads in the enthusiast press, are you going beyond gaming publications? In print, I mean.

HH: Initially it will just be the endemic media, mainly because those are the people that we've partnered with over the last few months, and trying to take out ads in some of the bigger, broader magazines, where impactful. I think it needs to be a strategic decision.

GS: And where would be impactful?

HH: It depends. Again, if we're talking about parents that are also casual gamers, then it's probably one set of outlets. If it's parents that we're just trying to educate about the issues, it's probably another whole set of outlets, and we're not going to be able to move as quickly as this holiday season. Right now, we're really just focused on building the membership, and getting awareness out, so this is probably something that will be a long-term process. And in terms of editorial, I think that's something we can start sooner than later. In terms of advertising, we probably have to be more particular, we have to be really careful about how we're spending our members' money.

GS: I'm assuming that the initial advertising is to gain membership, and then subsequent advertising would be advocacy and awareness?

HH: Actually, the initial round of advertising does both. So I'm hoping to build awareness about the association, but at the same time, build awareness about the advocacy, and the importance of those issues.

GS: Has the weekly editorial content started yet?

HH: It has not. And hopefully it will be daily!

GS: That's a lot.

HH: That is a lot. I'm hoping to build it in a way that a lot of content will come from partner websites, and so we'll just be pushing back out information that we feel is important for our members to be aware of, and that will be driving back to our partners.

GS: Well…I haven't gotten a call yet, I…[laughs]

HH: I'll make a note!

GS: I don't know a whole lot about your background, but can you brief me on political interactions you've had?

HH: Sure! I've been in the industry for about fifteen years. The first half of that was approximately in the publishing side. I used to run Game Week magazine, which became IE, and then while I was doing that I founded the IEMA, the Interactive Entertainment Merchants Association, a retail group that represented all the major retailers in the channel, and has over the course of the past, oh, seven to nine years. That spanned a lot of the advocacy we did was in the last three or four years.

Prior to that, the focus really was on the ratings system and the publishers, and when the spotlight started moving towards the retailers is when I personally became more involved in testifying for state legislatures and the FTC and working with the senators. I think it was four or five years ago that I was first beckoned by Senator Lieberman up to Hartford and called in for a meeting. So that's probably my first one on one with a politician, and ever since it's been a real education.

GS: Is that where a lot of your personal motivation lies?

HH: In terms of this new organization?

GS: Well, sure, but also in terms of what you want to do withit for yourself and for the community. Is that really the kind of heart of what you're interested in?

HH: Again, from my perspective, I see it as a much more urgent matter probably than the average member that we have now or could get in the future, maybe more than the average person in the industry, because it was what I used to do. And so having been on the front lines, I can see that when you're up against a hundred bills a year, all doing the same thing, and people are copying each other from state to state, and then all of a sudden the target starts shifting from publishers to retailers, and then all of a sudden the first bill came out last year that was anti-gamer; you don't need a crystal ball in order to realize that this year, the issue is not going away. The anti-gaming groups are out there in force, and if this continues to head toward anti-gamer legislation instead of just anti-games, that someone needs to be on the front lines.

GS: Why do you think that shift happened?

HH: Because they were being unsuccessful against the First Amendment argument being made. Essentially the ESA and the IEMA and the VSDA and IGDA and ESRB were continuing to go up against them, and saying, "Here are all the great reasons why this is illegal, and you're not going to be able to enforce any of this." And often times we find that legislators were just pushing it through anyway, knowing as we were going in that it wasn't going to pass muster. But as that failure rate increased, we started getting more vocal as an industry about how you're wasting time and taxpayers' dollars, and here they are in Louisiana fighting against anti-games legislation when they have Katrina to worry about.

That could be one of the reasons they looked to a new target, it could be that they were just running up against too many walls. They have probably as many attorneys if not more on their side than we do on our side, and so people are getting creative. And if no one is out there defending consumers, and consumers are kids who don't vote, from their perspective, it's a win-win. So that's what I was saying earlier, that we need to change the perception, we need to enlighten them about the fact that the average gamer is 30 years old or 33 or 27. We're still talking about a voting-age person who is an adult, and who is well-educated, who is not a pimply-faced kid who needs protection.

GS: We talk about who the average gamer is in so many different ways, depending on what games we're talking about or who we're talking to, and I definitely believe in that theory that change happens because old people die and young people grow up. [laughs] And that's the reality. We say that the average gamer is 30, and we're in that mindset that things are changing because young people are growing up, and sometimes the average gamer is 55 and female, or, you know. So it seems really murky for those of us who do know what's going on, and somehow crystal clear for the average people who read Newsweek or whatever.

HH: An interesting statistic I read in AARP magazine recently is that the average age of a U.S. senator is 60, the oldest it's ever been in our nation's history. And the first thing that came to my mind is, "Wow, the average age of a gamer is 30!" There is a disparity, and so it wasn't crystal clear for me before – and I was knee-deep in it – until I read that. You know, you're out there seeing all sorts of different politicians, and you don't know how old they are, and the ones that get the most spotlight are usually younger than 60. And so you don't think about it in those terms.

One of the more interesting things I think we'll be able to bring to the table is a tremendous amount of research. I'm really excited about our research division being developed internally, both in what we can provide to the industry in terms of factual feedback, as well as to understand the consumer better, and who the consumer actually is. I know that it's a little bit threatening to some companies, I got a call from one the other day that seemed very concerned about the research that they provide to the industry, because it's going to be on a significantly smaller basis than what we would be able to provide. And I'm not sure if media outlets might be concerned that we're going to start an enthusiast magazine. That's not our business, and we're not really interested in starting whole new ventures that are going to be apart from our core. But we are interested in making sure that people are serving the demographic correctly. And so, if it's being honest and it's being pure, then to me it's worthwhile.

GS: That brings up an interesting question, though. If you do have the power to do all this research, and you're a consumer advocacy group, most likely that information should be released for free, right?

HH: I don't see any reason why it shouldn't. That said, we're ahead of even establishing a division.

GS: Right. But if you do, that would, I think, be useful for a wide range of people.

HH: In theory, the way it normally works, as I understand it – and this is brand new eyes on it – is that we would do a tremendous amount of research internally sort of looking inward into our own membership, and then release publicly the top line information that we thought would be the most useful for everyone, and then release privately to the industry or to other advocacy groups or empowerment organizations more detailed information. It would actually be our own members that would get the most. Now, you could argue that with 250,000 people employed by the industry, a lot of them should be accredited ECA members, and would therefore get access to the same information.

GS: Let's talk about the ECA's acquisition of Game Politics. You said that you weren't advocating or decrying any particular politicians, is this going to be an issue?

HH: Dennis [McCauley] will still be allowed to have all of his own views, and we'll express on the bottom of the page in all the legalese that need be that his opinions are his own. He's not a full-time staffer, so he's allowed to have his own opinions, and frankly the success he's enjoyed over the last few years with enthusiast magazines and sites regularly using him as sort of a conduit, we wouldn't want to stymie any of that. So that all remains the same. And frankly the forums that he has going, and all of the people and that discussion and that interaction, we want to encourage them.

GS: Are there issues with avoiding a political stance? It seems like a potentially powerful tool for changing politicians' minds via the ECA would be, "Here are the people that are in favor of you, vote for them." Or, "These people have helped pass pro-game initiatives, and these people are working against it."

HH: You sort of touched on a much bigger, long-term thing we'll be talking about. And with MoveOn.org as an example I mentioned earlier, they actually have a PAC which is a separate organization that they fund. So the political action committee can run around and do much more educational stuff. And that's entirely possible in the future. To have a PAC you really have to be successful and really grow your organization. The ESA doesn't have a PAC. But there is strength in numbers.

There are 30 million in the U.S. alone that meet ECA's potential universe. We get three million of them, and all of a sudden we have pretty big coffers to do that sort of thing.