SUMMARY

This is a report from the Community Media Producers Association (CMPA), formerly the Community Television Producers Association (CTPA) Hawaii's oldest and only statewide community producers association, a 501(c)3 nonprofit organization. For 17 years CMPA has advocated for "first-come, nondiscriminatory" access by community producers to public access television, production equipment, and channels.

CMPA has concluded that the Education and Government sectors (E & G) are in fact one sector as Education in this context is a sub-sector of Government. CMPA has also concluded that the state created and controlled non-profit PEG entities have violated state procurement and other state and federal laws for 17 years. These entities have engaged in structural, institutional and systemic practices to divert resources and access away from the public producer to the E & G sectors and favored non-profits.

CMPA has concluded that the historical and current PEG disfunctionality in providing first-come, nondiscriminatory access to production and cablecasting resources to the public producer is primarily due to the State of Hawaii acting through the State Department of Commerce and Consumer Affairs (DCCA), the agency responsible for PEG accountability and oversight.

CMPA also found DCCA's reporting requirements for PEGs consisted of ever-changing data points which defy coherent analysis and obscure how and on what sectors the state-mandated public monies are being spent. This makes accountability and oversight of these public monies impossible.

The current sole-source Government-originated PEGS appear to have colluded with the state government to disenfranchise the community producer and divert monies to Government agencies. PEG opposition to State government policy occurred around the issue of transparency and complying with State procurement law, which would have allowed other non-profits to compete for the opportunity to provide PEG services through an open competitive bidding process.

CMPA found that historically Hawai'i PEGs have yet to designate a single "Public Access Channel," or provide "first-come, nondiscriminatory" access to community producers on such a channel. PEGs have diverted resources intended for the public producer and used those resources to bid against other non-profits (as well as for-profit video production companies).

CMPA has found that the PEGs colluded with the State of Hawaii to deny "first-come, nondiscriminatory" access to community producers, while diverting resources to government and favored nonprofits.

Although CMPA primarily uses`Olelo on the island of Oahu as an exemplar of poor service to the community producers, the PEG entities on the other islands (Ho`ike, Akaku, and Naleo) have performed no better.

OVERVIEW
The PEGs were created in Hawaii supposedly to provide the public with a "soapbox" as intended by the FCC, and to give government and education funds for programming on their designated channels. From the beginning the public sector had grave concerns regarding the level of Government control, inequitable treatment of Public vs. Government sectors (E & G), and especially the failure to memorialize in State Law that the purpose of public access is for the exercise of first amendment rights. This should be the first concern when creating any legislation concerning the PEGs. The public's concerns are ignored by the PEG boards, DCCA, the Legislature, and the Ombudsman. As a result, over time those wishing the soapbox access have seen it methodically diminished, to be replaced by those with less "edgy" messages. A check of new local programming on all islands produced by the clients themselves will verify this assertion.

Only when legal infractions by the PEGs and DCCA were uncovered was there any government reaction. Unfortunately the reaction has been to make legal what had been illegal without attention to consequences. Ironically, 'Olelo and the other PEGs now assert that they had been giving the excellent service they were created to give and DCCA and the Legislature appear to agree, ignoring documented history to the contrary. Their assertions are enthusiastically supported by staff, newcomers, and those who receive services not available to others. Unfortunately that cannot be refuted by the thousands of once-eager former volunteers and staff that suffered at the hands of the PEG monopolies, since they have given up in disgust and are no longer in contact with 'Olelo, Akaku, Ho'ike or Na Leo. CMPA has documents dating back over a decade that dispute the PEG assertions of equitable provision of appropriate services are not true and that CATV (the Cable Television Division, a department of DCCA) has not been providing the "stringent" oversight that it should. This letter from DCCA acknowledges problems, but DCCA never follows up to make sure the problems were corrected.  http://hpam.hi808.net/dcca/dccapublic.gif

Following are categorized examples highlighting seventeen years of unresolved problems and failure to provide the public with "first-come, nondiscriminatory access".

BOARD
Board composition and designation has been an ongoing source of problems. The following indicates the chief ones.

• The boards are not made up of democratically elected "public" members or users. As a result they have never been responsive to client needs and wants except for the sector they represented (self-serving "E, G" and nonprofits)
• The reason given for not appointing a user member in the past was that that person would have an "agenda." Instead, early on Olelo's Board was filled with persons from Education. During those times a disproportionate amount of support was given to Education. Later boards were filled with persons from non-profits, resulting in disproportionate support and facilitation to nonprofits.
• At present there is one elected "public" member. However, DCCA allowed students to vote (although they weren't allowed to run). Predictably, students voted for the person put up by 'Olelo (a teacher); as their teachers advocated to those students for him. That that person wasn't a legitimate representative is proven by the fact that he has attended few committee or board meetings.
• Board constraints on Board meeting testimonies: The Public has three minutes to comment on all agenda items to the Board before the meeting begins. Since agendas are vague at best, and handouts minimal, it is not possible for the public to comment knowledgeably or sufficiently on matters before the Board. For the last two years the public has had no opportunity to comment at all on budgets as the brief form (2-page) budgets were approved in Executive Session and requests for those minutes have been denied.
• The one Board election on Kauai to allow a single "public" Board member allowed no third-party observation of the ballots counted and did not follow standard fair elections practices.
• Board members and DCCA "shall have the right to inspect and obtain copies of the Corporation's books and records", but 'Olelo has gone to great lengths (including suing the state) to insure that the public does not obtain this information.


COMPLAINTS
• To respond to complaints, from its earliest days various kinds of meeting, fora, and committees were formed. Eventually we became aware that they were all for window dressing as there were never any thorough follow-ups to suggestions, or solutions to complaints. Whenever clients caught on to that tactic, that particular form of client feedback was disbanded.
• That the same complaints and solutions continued to be raised reveals that the resolutions were never implemented.
The promises listed in these reports from various fora were never implemented.
http://hpam.hi808.net/olelo/
http://hpam.hi808.net/olelo/forums/ClientforumtablePAGE3.gif
http://hpam.hi808.net/olelo/ProducerForumGrids/index.html

•  As recently as 2001 the Access Services Advisory Committee (ASAC)  http://hpam.hi808.net/asac/  was put into place to increase communication between the 'Olelo administration, their board of directors, and the producers to resolve problems. 'Olelo limited its effectiveness from the beginning by controlling its meetings and direction, miring it in administrative minutia. It disbanded 3 years later in frustration.

• At one point Community Television Producers Association (CTPA) entered into mediation with 'Olelo. 'Olelo refused to discuss the Board's 25 specific bylaw and policy violations brought to them and never complied with the few concessions it made... in essence all openness and accountability related. The mediators, who were represented by 'Olelo administrators and Board directors to CTPA as impartial, were later found to have direct connections to two 'Olelo board directors and an ex-DCCA Director.
• Persons are afraid to complain to 'Olelo or testify to DCCA or the Legislature because of fear of retaliation. In the past, people who have done so have had privileges suspended, have had unjustified fines levied against them, received late or limited air times, had series time slots taken away, and reserved equipment given to someone else... all punative actions not visited upon the more favored producers.


BYLAWS

• Olelo has consistently violated its own bylaws. The most flagrant is that of its mission, which, in 'Olelo's present bylaws and original articles of incorporation state:
"The specific and primary purpose of the corporation is to promote the creation, production and cablecasting of programs by, for and about Hawaii."
Instead, Olelo has been following what it represented in its most recent Strategic Plan:
" ...'Olelo's mission, which is to:
- promote lifelong learning through the creation, production and cablecasting of programs that are aimed at the preservation, development and enhancement of the diversity of thought, culture and heritage on O'ahu"
Note the difference: the bylaw mission enables the public to create its own programming. In the strategic plan, Olelo does the creation, thus violating its own bylaws.

• Bylaw changes:
Every change of bylaws limited transparency further. At present no stringent oversight is possible according to bylaw constraints.
Sect.12.8.a. "Members of the Board, the Director of DCCA, the President of Oceanic and their authorized agents shall have the right to inspect and obtain copies of the Corporation’s books and records during reasonable business hours upon the express condition that information and documents obtained as a result of these inspections shall not be used in any manner detrimental to the Corporation. In the event a member of the Board, the Director of the DCCA or the President of Oceanic, or their respective employer, is involved in any activity or possesses an interest which is adverse to the Corporation, the Corporation, through its President/CEO, shall have the right to withhold from inspection any books, records or other materials which the President/CEO feels, in his/her reasonable discretion, are related to the dispute or interest which is adverse to the Corporation, provided the President/CEO’s decision to withhold such records or materials is ratified at the next meeting of the Board. Members of the Board shall not disclose any confidential or proprietary information of the Corporation without the consent of the Board, the Corporation’s legal counsel or by law."
• On Kauai, the Ho'ike Kauai Community Television, Inc. bylaws were changed many times during the late 1990's to reduce transparency and sunshine. Current bylaws allow this board to go into executive session "for any reason deemed necessary." This is not a transparent organization.

FIRST AMENDMENT VIOLATIONS
• First amendment rights and nondiscriminatory access are infringed upon by:
• block programming
• creating its own programming
• facilitation of certain groups
• filling up slots with out-of-state programming
• looping 20-minute (or less) community bulletin boards (Island Info) for 8 hours.
• PEGs discriminates against certain messages and their producers by providing certain services to groups it favors and withholding it from others. This facilitation includes staff:
• shooting for them
• editing for them
• giving them immediate and favorable air times
• scheduling channel time in advance for unfinished programs (counter to operating policy)
• The revised Purpose in the Articles of Incorporation no longer provides for the First Amendment.
"This Corporation is organized exclusively for charitable, religious, educational, and scientific purposes, including, for such purposes, the making of distributions to organizations that qualify as exempt organizations under Section 105(c)3 of the Internal Revenue code... "
• After 17 years no "Public Access Channel" has been created to be "available on a first-come, nondiscriminatory basis" as called for in  (HAR 16-131-32)
•  Although some (the Government and favored non-profits sectors) get more than fair support, other community producers are unable to get the access. All have access to equipment and airtime but some may find their requests superseded when they arrive at the facility. Due to favoritism and block programming (which ties up hours of air time for program types of Olelo's choosing), some programs get better or sooner air times than others. Nonprofits may receive free training, some individuals must pay, but there is no written documentation of the process or criteria to obtain a fee waiver. The result of these activities is that Olelo controls broadcast content.
•  One way 'Olelo has dealt with its inadequate service is to take over the creation of programs for certain clients of its choosing, thus controlling which messages/viewpoints get aired most often.
•  'Olelo was put into place to train people to create and put their own programs on the air. This is an equitable and fiscally effective approach. However, very soon volunteers realize that if 'Olelo doesn't like them or the message of their program, they will find roadblocks. If 'Olelo does like them, they will receive exemptions from the 66-page Operating Procedures and receive free staff to do their programs for them, which costs 'Olelo considerably more -- meaning it will have less funds for services and equipment, eg. This may be appropriate for a truly independent nonprofit, but not one supported by a Legislature-mandated surcharge on all cable subscribers for an entity established to provide for first amendment purposes.

OLELO FISCAL QUESTIONS

• The page and a half 2008 budget is down from 36 pages of earlier years' versions. It does not show how much is spent for each sector and does not define them.
• Annual Activity reports do not indicate how much funds or staff time Olelo spends on facilitated and in-house productions.
• DOE and UH receive 25% of the funds through HENC and are not permitted to request more per HENC agreement. However, DOE receives further support through monopolizing satellite site use until 3 pm or so, and through additional 'Olelo resources earmarked for "Youth Xchange." It would appear that 'Olelo categorizes this as public and does not classify it as additional Educational sector funding and facilitation.
• It appears that government receives more than its fair share through financing for neighborhood board coverage and then by categorizing it as public.
• More than $247,000 has been used to fight sunshine and procurement under the guise of protecting free speech.
• Attorneys fees in excess of $100,000 per year were paid in 2004 – 2006:

        •  2004, $181,763.00

        •  2005, $147,112.00

        •  2006, $207,895.00 (from 990 income tax returns).

A total of more than a half a million dollars in 3 years! ($536,770.00).
• Approximately $150,000 per year were expended for promotions. ($147,000.00 in 2004) Requests to learn the breakdown of how much was paid to whom and for what services have been denied,

DELETE:  but contracts were obtained under Hawaii's Freedom of Information act (HRS 92f).
• Annual activity reports have gone from over 30 pages to 10 or less, raising the question of whether this represents less activity or less activity that Olelo wants known.
• 'Olelo has provided streaming pilot projects to city council, neighborhood boards, and proposed it to the Senate, and the House without revealing the costs and benchmarks.
• Once there were grants awarded to community producers, "P," with criteria spelled out. Now only E & G are awarded grants, without written criteria.
• There is no record available to the public of hours spent on lobbying (including attorneys drafting legislation, PEG request to introduce & schedule, user outreach, private in-office lobbying, and testimony).
• IRS requirement in 990 to compile lobbying expenses has never been done. (Akaku registered a lobbyist this year for the first time, 'Olelo never has.)
• Despite repeated requests, no third-party management and financial audit has ever been done of 'Olelo.

DCCA
• The original proposal for establishing PEGs was developed by CTPA in 1987. During the next 3 years DCCA's director, Robbie Alm, reworked the proposal so that the public was excluded from management and no strict definitions or guidelines for the 3 sectors were indicated (both problems to this day).
• Director Matayoshi was notified in 2001 that there are no rules for selection of PEGs, which were to have been in place prior to designating all current PEGs. Yet to this day there still are no rules. All contracts, therefore, should be considered illegal.
• Although Senator Fukunaga characterized DCCA's oversight of the PEGs as stringent, any complaints to DCCA have simply been turned over to the PEGs with no follow-up unless strongly requested.
• Required reports are repeatedly late and more often than not DCCA does not request them until requested to do so by the public.
• Many records requested from DCCA are responded to with "DCCA does not maintain that record". DCCA does not retain PEG records because it has never established any rules that obligate it to.  
• DCCA has not required the PEGs to follow the guidelines established by them in its 2004 PEG Plan. This is especially true with regard to its statement, "DCCA believes that openness and accountability are crucial."
• The Honorable 2nd Circuit Court Judge Joel August characterized DCCA oversight as "standardless discretion" and "catch-all criteria". See transcript at http://hpam.hi808.net/akaku/Akaku_v_DCCA.html., or video at http://www.archive.org/details/Akaku_V_State
• Prior to the signing of D&O 261 in August 2000, ex DCCA Director Alm & ex DCCA CATV administrator (and ex deputy director) Doyle negotiated as DCCA appointed 'Olelo board directors with the present CATV administrator Sonobe for PEG benefits. This resulted in:
• a loss of one million dollars annually to the PEGs
• a reduction of the owed 8 channels to 5
• an increase in franchise fees to Educational institutions
• 2 channels specifically designated as "Educational Access Channels" while still not designating "at least one specially designated, noncommercial public access channel available on a first-come, nondiscriminatory basis."  (HAR 16-131-32)
• 'Olelo funds being capped. All funds in excess of the cap were funneled to the State's INET, already valued at 10 times the amount of the total annual statewide franchise fees.

ILLEGAL CONTRACTS
Contracts have had no expiration dates. The current PEG contracts were signed in 1998 and 1999 and were automatically renewed annually until December 2003. (Signed in violation of the state procurement code, the legality of those and all subsequent agreements are in question). DCCA then began renegotiating these contracts and has been extending them in approximately three-month intervals with "supplemental agreements."

While reviewing the PEG contracts, DCCA asked the Department of the Attorney General and the State’s Procurement Office (SPO) whether DCCA's contracts with these PEG access organizations are subject to the State Procurement Code. After much discussion, DCCA was informed by the Attorney General's office that these PEG access contracts are subject to the State Procurement Code and that none of the exemptions in HRS § 103D-102(b) appear to apply"  (the exact date of the DCCA request for an AG opinion is unknown as Public inspection is denied on the basis of client-attorney privilege).

CMPA's understanding is that the sticking point in the negotiations has to do with transparency. 'Olelo, who was requested by all state PEGs to represent them, has been unwilling to allow for open records and meetings and DCCA seems to be powerless or reluctant to assert its authority.

TIMELINE
The following details some of the twists and turns of the recent contract developments.

    * 1995 - CMPA began questioning the process of PEG designation.
    * 1998 - CMPA asked OIP for an opinion as to if PEGs could be considered agencies for the purposes of open records (UIPA HRS Chapter 92f) and sunshine law (HRS Chapter 92)
    * 2001 - CMPA asked DCCA director Matayoshi and CATV administrator Sonobe what the process was to designate the PEG entity. "Is DCCA required to post a public notice or Request for Proposal?" She sent the query to Sonobe, who said it was in the contract. It was not. http://hpam.hi808.net/RFP4PEG/#jg2cs
    * Aug 2002 - OIP opined that the PEGs were "agencies" for the purposes of open records, UIPA Chapter 92f
    * Dec 2002 - CMPA raised the question of designation (as well as other issues) with the new DCCA director.
    * 2003 - The DCCA Director commenced the PEG access plan hearings and, about the same time, negotiation with the PEGs on their contracts. He would not tell CMPA what the negotiations were about or why he commenced them. Until Dec 2003 the contracts were automatically renewed annually. After that, extended by repeated supplemental agreements.
    * 2004 - Neighbor island PEGs gave 'Olelo the power to negotiate contracts for them with DCCA due to its location, deep pockets and powerful attorneys.
    * Aug 2004 -  'Olelo sued OIP contesting its opinion that 'Olelo is a "agency" under UIPA.   http://hpam.hi808.net/OLELOvOIP/
    * Jun 2005 - 'Olelo won in Circuit Court with Judge Victoria Marks presiding.
    * DELETE THIS OR REWRITE (wife of DCCA Director Alm's assigned deputy attorney general Robert Marks who assited in the creation of 'Olelo)
    * Aug 2005 -  OIP appealed to Supreme Court.
    * NOV 2005 - CATV Administrator Sonobe posted a Request for Exemption from Chapter 103d HRS regarding PEG contracts on an out-of-the-way bulletin board (and not on their website) for a procurement exemption for PEG access services. (This was the first time DCCA acknowledged anything relating the PEGs with an RFP process.) The State Procurement Office (SPO) granted the exemption. (see: http://hpam.htohananet.com/PEGdocs/03_form07252_11-21_approval.pdf ) CMPA complained about technical violations and intent to obscure the request from the public.  
    * 2006 - The exemption request process is repeated. DCCA and the Procurement Policy Board provided opportunities for public input. At these hearings DCCA sought much the same information it requested from the public during its 2003 hearings for its Plan. This time the DCCA Request for Exemption was denied by SPO.  (see:  http://hpam.hi808.net/RFP4PEG/form07256.pdf)
    * 2007 - Judge Duffy ruled to uphold Judge Mark's 2005 decision that 'Olelo was not an "agency" under UIPA.
    * 2008 - PEGs draft legislation to exempt Hawai'i PEGs from state procurement law. They lobby for it without disclosing its nature or cost.

This URL link  http://hpam.hi808.net/RFP4PEG/ provides a complete timeline from 2001 through July 2006. Since then the PEGs have used numerous tactics to get out from the procurement code including appealing to the Procurement Policy Board and the Legislature. We understand that this is the longest procurement process in the history of Hawaii.

AKAKU: Maui Community TV
http://www.archive.org/details/Akaku_V_State
Akaku sued DCCA in order not be be obligated to comply with the state-mandated procurement process. The result was that the Judge dismissed the suit without prejudice until:

         1. DCCA returns with appropriate rules regarding PEG designation that acknowledge that PEG Access is established to provide for first amendment purposes or
         2. the Legislature puts this into statute.

HO`IKE: Kauai Community TV

   1. The most secretive of all the PEGs, Ho`ike, deleted "sunshine" from the bylaws during the 1990's and currently according to their bylaws may enter into executive session for "Any issues deemed best to be kept confidential."
   2. Predatory practices against other nonprofits attempting to compete to provide government services to the County of Kauai. When another non-profit, The Benefit Network, was awarded the County of Kauai contract to document government meetings Ho`ike refused to allow use of the the video production equipment that Ho`ike itself granted itself the right to use for tht purpose.
   3. Refused to allow the Kauai League of Women Voters access to studio time for voter education instead subsumed the LWV role of voter education by producing their own program "Teledemocracy."
   4. "Terminated" community producer rights (refused to allow use of production equipment or enter Ho`ike property without being arrested for trespassing) stating vague "bylaw violations" without due process. After eight years of attempting to determine reason for termination Ho`ike refused to specify which bylaw was violated.
   5. Predated and nearly bankrupted another non-profit, The Garden Island Arts Council (GAIC), in a land deal gone bad. GAIC was left with $70 in the bank and lost $39,000 collected through years of fundraising efforts.


Na Leo O Hawai'i

   1. It is difficult to determine the actual status of the Big Island's access organization as they still have yet to create a website, and their reporting requirements are not posted on DCCA's website with the explanation of: "Due to the size and format of these PDF documents, please contact the Cable Television Division (CATV) directly to schedule an appointment to view these documents at its office during business hours."    http://hawaii.gov/dcca/areas/catv/peg_access_center/naleo2006

PEG LANDLORDS

    * `Olelo and Akaku have used public monies to purchase land and buildings with state mandated monies and gone into the landloard business. Ho`ike spent tens of thousands of State mandated public monies attempting to become landlords.
    * Akaku is currently being sued by one of it's tenants.

RECENT TESTIMONY
With regard to the testimony for the current PEGs, it is important to keep in mind that because there are no rigorous definitions for Public, Education, and Government, much of the testimony was a plea for children's programming that was was presented as Public access, but was actually Educational institution access whose content must be controlled

Many of the adult testifiers had undisclosed connections. Some are access employees (but don't say so) and others have programs that receive special facilitation &/or guaranteed airslots from 'Olelo. Compromised, understandably they resist change.

SOLUTIONS

    * Establish that Access Organizations are for first amendment purposes in statute (440g)
    * Define "Access Organization" as member-based nonprofit corporations in HRS 440g-3
    * Amend HAR 16-131-32 by replacing "cable operator" with "access organization," thus ensuring at least one specially designated, noncommercial public access channel (shall be made) available (by access organizations) on a first-come, nondiscriminatory basis. Each "access organization" shall maintain and have available for public use at least the minimal equipment and facilities necessary for the production of programming for such a channel."
    * Prohibit program blocks on "Public Access Channels"

    *  Require a comprehensive management and financial audit of DCCA Cable Television division (CATV) and the PEGs (with great attention given to DCCA PEG oversight). This is the only way under the current system for the public to learn exactly what the PEGs have been doing, what they have spent the public's money on, and how much new programming is really produced by the public sector locally -- the soapbox programming that was the original intent of PEG creation.
    * Separate the P,G, and E sectors by issuing separate RFPs. If the sectors are not separated, they should be separately accounted for by contractual reporting requirements.
    * RFP(s) must contain all reporting requirements expected to be in access organization contracts
    * RFP must state very specifically the services to be required
    * Access organization contracts should be required to provide an opportunity to be reviewed and commented on by the public at a hearing in compliance with chapter 91 prior to signing by DCCA and the awardee.
    * The insertion of "(among other things)" or the like must be prohibited in any access organization contract to prevent "mission drift".
    * Require PEGs to abide by HRS Chapter 92 (sunshine) 92f  UIPA (open records)


CMPA doubts the above suggestions will be implemented as lawmakers, unlike the community producers, have received more than their fair share of the cable subscriber-funded PEG pie. After seventeen years, with the express consent and support of the Legislature and the State Department of Commerce and Consumer Affairs, Hawaii PEGs have failed in their mission to empower citizens to use the channels to freely communicate with their fellow citizens.

CONCLUSION:
This has been an analysis supported by primary documents that reveals how a state bureaucracy under the guise of public access have used federal regulation to expand its own state-interest while claiming to be providing free speech opportunities to the public.  

After seventeen years of PEG failure to serve even one percent of the cable subscribers (if you define service as the number of viewers turned into speakers and provided "first-come, nondiscriminatory" access to the medium of television). CMPA believes it is time for the state of Hawaii to consider either letting the cable subscribers keep the franchise fee mandated by the state, or use those fees as intended and provide the public with first-come nondiscriminatory access to the medium of television. If education and government services need support, use the general fund. If the general fund is inadequate raise taxes through the standard legislative process.

No Derivative WorksNo Derivative Works. 2008 Community Media Producers Association
This document may be copied, distributed, displayed, and performed only verbatim. No derivative works are permitted.

Excellent piece of work. I just uploaded a video that will help expand on your story:

                         "PEG without Free Speech ?? ..."

It is a compilation of court cases in which circuit court judge Joel August recognizes that nowhere in Hawai'i stat law does it recognize that PEG Access was intended for Free Speech purposes. In other words, for 20 years Hawai'i has not only violated their own statutes, but the U.S. & Hawai'i Constitutions as well!

The video is just shy of 8 minutes, and just under 41 megs.

Video URL:    http://digitaleye.users.theuptake.org/en/videogalleryView/id/69/