Benefit corporation
>From Wikipedia.
In the _United States_ (https://en.wikipedia.org/wiki/United_States) , a
benefit corporation or B-corporation is a type of for-profit _corporate
entity_ (https://en.wikipedia.org/wiki/Corporate_entity) , legislated in 28
U.S.
states, that includes positive impact on society and the environment in
addition to profit as its legally defined goals. B corps differ from
traditional American corporations in purpose, accountability, and
transparency, but
not in taxation.
The purpose of a benefit corporation includes creating general public
benefit, which is defined as a material positive impact on society and the
environment. A benefit corporation’s directors and officers operate the
business
with the same authority as in a traditional corporation but are required
to consider the impact of their decisions not only on shareholders but also
on society and the environment. In a traditional corporation, shareholders
judge the company's financial performance; with a B-corporation,
shareholders judge performance based on how a corporation's goals benefit
society and
the environment. Shareholders determine whether the corporation has made a
material positive impact. Transparency provisions require benefit
corporations to publish annual benefit reports of their social and
environmental
performance using a comprehensive, credible, independent, and transparent
third-party standard. In some states, the corporation must also submit the
reports to the _Secretary of State_
(https://en.wikipedia.org/wiki/Secretary_of_State_(U.S._state_government)) ,
although the Secretary of State has no
governance over the report's content. Shareholders have a private right of
action, called a benefit enforcement proceeding, to enforce the company’s
mission when the business has failed to pursue or create general public
benefit. Disputes about the material positive impact are decided by the
courts.
There are around 12 third-party standards that meet the requirements of the
legislation. Benefit corporations need not be certified or audited by the
third-party standard. Instead, they use third-party standards solely as a
_rubric_ (https://en.wikipedia.org/wiki/Rubric) a company uses to measure
performance.
History
In April 2010, Maryland became the first U.S. state to pass benefit
corporation legislation. As of October 2014, 28 states have passed legislation
allowing for the creation of benefit corporations:
* Arizona's legislation became effective on December 31, 2014._[1]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#
cite_note-BenefitCorpStates-1)
* Arkansas’s legislation was signed by Governor _Mike Beebe_
(https://en.wikipedia.org/wiki/Mike_Beebe) on April 19, 2013 and became
effective
90 days later. _sine die_ (https://en.wikipedia.org/wiki/Sine_die) .
* California’s legislation was signed into law on October 9, 2011 and
became effective on January 1, 2012._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not
in citation given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability)
]
* Colorado's legislation was signed by Governor _John Hickenlooper_
(https://en.wikipedia.org/wiki/John_Hickenlooper) on May 15, 2013 and
became effective April 1, 2014._[3]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-3)
* Connecticut's law came in to effect October 1, 2014. It is the
first to allow "preservation clauses," which allow the corporation's founders
to prevent it from reverting to a 'For Profit' entity at the will of their
shareholders._[4]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-4)
* Delaware's legislation became effective on August 1, 2013.
* Florida's legislation became effective on July 1, 2014._[5]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_
note-5)
* Hawaii’s legislation was signed into law on July 8, 2011 and became
effective upon signing._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not in citation
given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Illinois’s legislation was signed into law on August 2, 2012 and
went into effect on January 1, 2013._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not
in citation given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Louisiana’s legislation became law on May 31, 2012 and went into
effect on August 1, 2012._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not in citation
given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Maryland’s legislation was signed into law on April 13, 2010 and
became effective on October 1, 2010._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not
in citation given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Massachusetts’ benefit corporation legislation became law on August
7, 2012 and became effective on December 1, 2012._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-Benefi
tCorp-2) [_not in citation given_
(https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Minnesota's legislation passed April 10, 2014 and became effective
January 1, 2015._[6]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-6)
* Nebraska's legislation became effective on July 18, 2014._[1]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cit
e_note-BenefitCorpStates-1)
* Nevada's legislation became effective on January 1, 2014._[1]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cit
e_note-BenefitCorpStates-1)
* New Hampshire's legislation became effective on January 1,
2015._[1]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorpStates-1)
* New Jersey’s legislation passed on January 10, 2011 and became
effective when it was signed into law on March 1, 2011._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-Benefit
Corp-2) [_not in citation given_
(https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* New York’s legislation was signed into law on December 12, 2011 and
became effective on February 10, 2012._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not in citation given_
(https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Oregon's legislation became law on June 18, 2013_[7]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-7)
and went into effect on January 1, 2014._[8]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-8)
* Pennsylvania’s legislation became law on October 24 and became
effective on January 22, 2013._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not in
citation given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Rhode Island 's legislation became effective on January 1,
2014._[1]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorpStates-1)
* South Carolina’s legislation became law on June 6, 2012 and became
effective June 14, 2012.<S.C Code of Laws Section 33-38-110
http://www.scstatehouse.gov/code/t33c038.php />
* Utah's legislation became effective on May 13, 2014._[1]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_not
e-BenefitCorpStates-1)
* Vermont’s legislation was signed into law on May 19, 2010 and
became effective on July 1, 2011._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not in
citation given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Virginia’s legislation was signed into law on March 26, 2011 and
became effective on July 1, 2011._[2]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-BenefitCorp-2)
[_not in
citation given_ (https://en.wikipedia.org/wiki/Wikipedia:Verifiability) ]
* Washington State’s legislation to create _Social Purpose
Corporations_ (https://en.wikipedia.org/wiki/Social_purpose_corporation)
instead of
a Benefit Corporations became law on March 30, 2012 and went into effect on
July 6, 2012._[9]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-9)
* Washington, D.C. legislation was signed by the _Mayor_
(https://en.wikipedia.org/wiki/Mayor_of_the_District_of_Columbia) on February
8, 2013
and went into effect after 30 days of congressional review, as the United
States Constitution gives Congress ultimate jurisdiction over the District
"in all instances whatsover".
* West Virginia legislation became effective July 1, 2014._[1]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite
_note-BenefitCorpStates-1)
Benefit corporation legislation has been introduced in Indiana and
Kentucky. In Illinois, legislation is pending that establishes a new type of
entity
called the “benefit LLC,” making the state the first to allow _limited
liability companies_
(https://en.wikipedia.org/wiki/Limited_liability_company) the same
opportunities afforded to Illinois corporations under the state’
s Benefit Corporation Law._[10]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-10)
_[11]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-11)
Differences from traditional corporations
Historically, United States corporate law has not been structured or
tailored to address the situation of for-profit companies who wish to pursue a
social or environmental mission._[12]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-12)
While corporations
generally have the ability to pursue a broad range of activities, corporate
decision-making is usually justified in terms of creating long-term
shareholder value. A commitment to pursuing a goal other than profit as an end
for
itself may be viewed in many states as inconsistent with the traditional
perspective that a corporation’s purpose is to maximize profits for the
benefit of its shareholders.
The idea that a corporation has as its purpose to maximize financial gain
for its shareholders was first articulated in _Dodge v. Ford Motor Company_
(https://en.wikipedia.org/wiki/Dodge_v._Ford_Motor_Company) in 1919. Over
time, through both law and custom, the concept of “shareholder primacy”
has come to be widely accepted. This point was recently reaffirmed by the
case eBay Domestic Holdings, Inc. v. Newmark, in which the Delaware Chancery
Court stated that a non-financial mission that “seeks not to maximize the
economic value of a for-profit Delaware corporation for the benefit of its
stockholders” is inconsistent with directors’ fiduciary duties.
In the ordinary course of business, decisions made by a corporation’s
directors are generally protected by the business judgment rule, under which
courts are reluctant to second-guess operating decisions made by directors. In
a takeover or change of control situation, however, courts give less
deference to directors’ decisions and require that directors obtain the
highest
price in order to maximize shareholder value in the transaction. Thus a
corporation may be unable to maintain its focus on social and environmental
factors in a change of control situation because of the pressure to maximize
shareholder value. Of course, if a company does change ownership and the
result is no longer in adherence to its initially described benefit goals,
the sale could be challenged in court.
Mission-driven businesses, impact investors, and social entrepreneurs are
constrained by this legal framework, which is not equipped to accommodate
for-profit entities whose mission is central to their existence.
Even in states that have passed “constituency” statutes, which permit
directors and officers of ordinary corporations to consider non-financial
interests when making decisions, legal uncertainties make it difficult for
mission-driven businesses to know when they are allowed to consider additional
interests. Without clear case law, directors may still fear civil claims if
they stray from their fiduciary duties to the owners of the business to
maximize profit.
By contrast, benefit corporations expand the fiduciary duty of directors to
require them to consider non-financial stakeholders as well as the
financial interests of shareholders._[13]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-13)
This gives directors
and officers of mission-driven businesses the legal protection to pursue an
additional mission and consider additional stakeholders besides
profit._[14]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-14)
_[15]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-15)
The enacting state's benefit
corporation statutes are placed within existing state corporation codes so
that it applies to benefit corporations in every respect except those explicit
provisions unique to the benefit corporation form.
In the rest of the world, the corporate law position is sometimes very
different. In the UK, for example, the _Community Interest Company_
(https://en.wikipedia.org/wiki/Community_Interest_Company) ensures profit and
purpose
can both be prioritised._[16]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-16)
Provisions
Typical major provisions of a benefit corporation are:
Purpose
* Shall create general _public benefit_
(https://en.wikipedia.org/wiki/Common_good) .
* Shall have right to name specific public benefit purposes (e.g. 50%
profits to charity).
* The creation of public benefit is in the best interests of the
benefit corporation.
Accountability
* Directors' duties are to make decisions in the best interests of
the corporation
* Directors and officers shall consider effect of decisions on
shareholders and employees, suppliers, customers, community, environment
(together the "stakeholders")
Transparency
* Shall publish annual Benefit Report in accordance with recognized
third party standards for defining, reporting, and assessing social and
environmental performance
* Benefit Report delivered to: 1) all shareholders; and 2) public
website with exclusion of proprietary data
Right of Action
* Only shareholders and directors have right of action
* Right of Action can be for 1) violation of or failure to pursue
general or specific public benefit; 2) violation of duty or standard of conduct
Change of Control/Purpose/Structure
* Shall require a minimum status vote which is a 2/3 vote in most
states, but slightly higher in a few states
Benefit corporations are treated like all other corporations for tax
purposes._[17]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-maryland-17)
Benefits
Benefit corporation laws address concerns held by _entrepreneurs_
(https://en.wikipedia.org/wiki/Entrepreneurs) who wish to raise growth
capital but
fear losing control of the social or environmental mission of their
business. In addition, the laws provide companies the ability to consider
factors
other than the highest purchase offer at the time of sale, in spite of the
ruling on _Revlon, Inc. v. MacAndrews & Forbes Holdings, Inc._
(https://en.wikipedia.org/wiki/Revlon,_Inc._v._MacAndrews_&_Forbes_Holdings,_Inc.)
Chartering as a benefit corporation also allows companies to distinguish
themselves as businesses with a social conscience, and as one that aspires to
a
standard they consider higher than _profit-maximization_
(https://en.wikipedia.org/wiki/Profit_maximization) for shareholders._[18]_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_note-18)
See also
* _Community interest company_
(https://en.wikipedia.org/wiki/Community_interest_company)
* _Impact investing_
(https://en.wikipedia.org/wiki/Impact_investing)
* _Public-benefit corporation_ (https://en.wikipedia.org/wiki/Public
-benefit_corporation)
* _Socially responsible investing_
(https://en.wikipedia.org/wiki/Socially_responsible_investing)
* _Stakeholder theory_
(https://en.wikipedia.org/wiki/Stakeholder_theory)
* _Social Purpose Corporation_
(https://en.wikipedia.org/wiki/Social_Purpose_Corporation)
References
1. ^ _Jump up to: a_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorpStates_1-0)
_b_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-
BenefitCorpStates_1-1) _c_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorpStates_1-2)
_d_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_re
f-BenefitCorpStates_1-3) _e_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorpStates_1-4)
_f_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_
ref-BenefitCorpStates_1-5) _g_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorpStates_1-6)
_Benefit
Corp: State by State Legislative Status_
(http://www.benefitcorp.net/state-by-state-legislative-status)
2. ^ _Jump up to: a_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2-0)
_b_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-Benefi
tCorp_2-1) _c_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2-2)
_d_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2-3)
_e_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2-4)
_f_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2-5)
_g_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#ci
te_ref-BenefitCorp_2-6) _h_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2-7)
_i_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-Ben
efitCorp_2-8) _j_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2-9)
_k_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-BenefitCorp_2
-10) William H. Clark, Jr., Drinker Biddle & Reath LLP; Larry Vranka,
Canonchet Group LLC; et. al. (January 18, 2013). _"White Paper the Need and
Rationale for the Benefit Corporation: Why It Is the Legal Form That Best
Addresses the Needs of Social Entrepreneurs, Investors, and, Ultimately, the
Public"_
(http://benefitcorp.net/storage/documents/Benecit_Corporation_White_Paper_1_18_2013.pdf)
(PDF). Legislation establishing the benefit
corporation as a new type of corporate entity has already been passed and
signed into
law in California, Hawaii, Illinois, Louisiana, Massachusetts, Maryland,
New Jersey, New York, Pennsylvania, South Carolina, Vermont, and Virginia,
and has been introduced in several other states.
3. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-3)
_"Session Laws of Colorado 2013: First
Regular Session, 69th General Assembly"_
(http://tornado.state.co.us/gov_dir/leg_dir/olls/sl2013a/sl_230.htm) . State of
Colorado. May 15, 2013.
Retrieved 2013-11-09.
4. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-4)
http://www.ctnewsjunkie.com/archives/entry/social_entrepreneurs_celebrate_new_corporate_structure,http://ctbenefitcor
p.com/become-benefit-corp//
5. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-5)
http://www.flsenate.gov/Session/Bill/2014/685
6. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-6)
https://www.revisor.mn.gov/bills/bill.php?b=house&f=HF2582&ssn=0&y=2014
7. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-7)
http://oregonsosblog.us/2013/06/benefit-company-bill-signed-into-law/
8. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-8)
http://republic3-0.com/state-rep-tobias-read-oregons-new-benefit-company-law-lets-business-owners-bring-values-work/
9. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-9)
Washington State Legislature _H.B. 2239
2011-12_ (http://apps.leg.wa.gov/billinfo/summary.aspx?bill=2239&year=2012)
10. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-10)
S.B. 2358, 98th Gen. Assem. (Ill.
2013).
11. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-11)
_Six Month Report_
(http://illinoistaskforce.files.wordpress.com/2013/04/task-force-six-month-report_4-22-13.pdf)
(PDF) (Report). Governor’s Task Force on Social Innovation,
Entrepreneurship, and Enterprise. April 2013.
12. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-12)
_"Balancing purpose and profit: Legal
mechanisms to lock in social mission for "profit with purpose" businesses
across the G8"_
(http://www.trust.org/contentAsset/raw-data/1d3b4f99-2a65-49f9-9bc0-39585bc52cac/file)
. Trust Law. Retrieved 3 September 2015.
13. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-13)
Marc J. Lane (March 11, 2014).
_"Emerging Legal Forms Allow Social Entrepreneurs to Blend Mission And
Profits"_
(http://www.triplepundit.com/2014/03/emerging-legal-forms-allow-social-entrepr
eneurs-blend-mission-profits/) . Triple Pundit.
14. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-14)
Marc J. Lane. _"Representing Corporate
Officers and Directors"_
(http://www.aspenpublishers.com/product.asp?catalog_name=Aspen&category_name=&product_id=0735598088&promoID=EM95&cookie_test=1)
. Aspen Publishers: Wolters Kluwer Law & Business. Retrieved 8 August
2012.
15. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-15)
Marc J. Lane. _"Social Enterprises: A
New Business Form Driving Social Change"_
(http://www.americanbar.org/publications/young_lawyer/2011-12/december_2011/social_enterprises_new_business_for
m_driving_social_change.html) . The Young Lawyer. Retrieved 18 November
2014.
16. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-16)
_"What is a B Corp and how is it
different to a CIC?"_
(https://www.clearlyso.com/what-is-a-b-corp-how-is-it-different-to-a-cic/) .
ClearlySo. Retrieved 3 September 2015.
17. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-maryland_17-0)
_"Maryland First State in
Union to Pass Benefit Corporation Legislation"_
(http://www.csrwire.com/press_releases/29332-Maryland-First-State-in-Union-to-Pass-Benefit-Corporation-Leg
islation) . _CSRWire USA_ (https://en.wikipedia.org/wiki/CSRWire_USA) . 14
April 2010.
18. _Jump up ^_
(https://en.wikipedia.org/w/index.php?title=Benefit_corporation&printable=yes#cite_ref-18)
_New-Economy Movement_
(http://neweconomicsinstitute.org/publications/new-economy-movement) article
by Gar
Alperovitz, also appeared in the June 13, 2011 edition of _The Nation_
(https://en.wikipedia.org/wiki/The_Nation)
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