If you’re a foreign seller with US sales tax exposure you didn’t know about — Amazon FBA inventory in a state, economic nexus crossed two years ago, a Shopify store quietly accumulating liability — a Voluntary Disclosure Agreement (VDA) is almost always the cheapest, cleanest exit. A VDA is a contract between you and a state’s Department of Revenue: you come forward voluntarily, pay the back tax plus interest, and in exchange the state waives penalties (often 25–50% of the tax) and limits how far back you have to pay. Without a VDA, the statute of limitations doesn’t run for non-filers — your exposure is, in effect, unlimited.
This guide is written specifically for foreign sellers — operators based in the UK, EU, Australia, New Zealand, South Africa, Canada, Singapore, and elsewhere — who don’t have a US EIN, don’t have a US bank account, don’t have an SSN, and are looking at a stack of states wondering where to start. Every generic VDA article on the internet was written for US-domiciled CPAs serving US-domiciled clients. None of it tells you what to do when the state portal demands an SSN you don’t have.
We’ll cover what a VDA actually does, who qualifies, lookback periods state-by-state, the alternatives (some of which will hurt you), the step-by-step process for a non-US seller, real costs, common mistakes that blow up the deal, and how our done-for-you service handles all of this end-to-end for one fixed fee.
What Is a Voluntary Disclosure Agreement (VDA) and Why Foreign Sellers Need One
A VDA is a negotiated settlement contract between an unregistered taxpayer and a state revenue department: you disclose past liability, the state agrees to a limited lookback period and waives most penalties. It is the single most powerful tool in the sales tax compliance toolkit for sellers who have years of accumulated exposure.
Plain-English definition of a VDA
In simple terms:
– You (the seller): admit you should have been collecting and remitting sales tax for some period, calculate the back liability, and pay it.
– The state: caps the lookback (typically 3 or 4 years instead of “forever”), waives penalties, and agrees not to audit you for periods before the agreement.
– Result: a clean slate, ongoing registration, and predictable forward-looking compliance.
The mechanic that makes VDAs valuable is simple: In most states, the statute of limitations on sales tax assessments is tied to return filing, and the clock generally does not start until a return is actually filed — meaning unfiled periods can remain open indefinitely. If you have unfiled returns in any state, contact us for a current review of your exposure window.. That means if you’ve never filed in a state where you had nexus, the state can theoretically come after you for every year you had a presence — five, eight, ten years back. A VDA puts a hard cap on that exposure.
Why foreign sellers are disproportionately exposed
Three structural reasons:
- FBA inventory creates physical nexus on day one. The moment Amazon allocates your inventory to a fulfillment center in California, Texas, or Pennsylvania, you have physical-presence nexus in that state. Storing inventory in Texas — including through third-party fulfillment programs like Amazon FBA — can create a registration obligation even where a marketplace collects on your sales, but the analysis depends on your specific facts and current Comptroller guidance. If you have FBA or 3PL inventory in Texas, contact us for a current review. Foreign sellers rarely understand this until years in.
- Economic nexus thresholds creep up unnoticed. A successful Shopify store hits California’s $500,000 economic nexus threshold or Texas’s $500,000 threshold in the second or third year of operation. Most states have $100,000 thresholds. The seller never registered, never collected — the liability stacks up.
- No one in the US is watching the seller’s books. A US-domiciled seller usually has a CPA who eventually flags the issue. A foreign seller running operations from Auckland or London often discovers the problem when applying for a US bank account, evaluating an exit, or being threatened with a marketplace suspension.
What a VDA gets you
| Without VDA | With VDA |
|---|---|
| Lookback: unlimited (no SOL until return filed) | Lookback: typically 3 or 4 years |
| Penalty: 10–50% of tax due | Penalty: waived |
| Interest: full statutory rate | Interest: full rate (almost never waived) |
| Audit risk: high once detected | Audit risk: closed for prior periods |
| Disclosure: forced (audit notice / discovery) | Disclosure: anonymous initial phase |
The single thing a VDA does not fix is interest. States universally take the position that interest is the time value of money owed to the public fisc — they waive penalty as a goodwill gesture for coming forward, but they don’t waive interest. Plan accordingly.
Who Qualifies: VDA Eligibility for Non-US Sellers
The single most important VDA eligibility rule: you must come forward before the state finds you. Once a state’s discovery unit makes contact — even a soft nexus questionnaire — the VDA window slams shut in most jurisdictions.
The “no prior contact” rule
Almost every state VDA program requires that the taxpayer:
– Has not previously registered for sales tax in that state.
– Has not been contacted by the state’s audit, collections, or discovery division.
– Is not currently under audit.
– Has not filed sales tax returns in the state (even zero returns).
California’s CDTFA operates both an In-State and Out-of-State Voluntary Disclosure Program, with eligibility conditioned on the taxpayer not having been contacted by CDTFA prior to applying.
For foreign sellers, this creates an unusual urgency. The states have automated discovery tools that scrape Amazon, eBay, and Shopify. If you wait, you may lose the option.
Why being on a marketplace doesn’t disqualify you
A common misconception: “Amazon collects sales tax for me now, so I don’t need a VDA.” Wrong, in two ways:
- Pre-marketplace-facilitator periods are still on you. Marketplace facilitator laws kicked in at different dates state-by-state — California’s Marketplace Facilitator Act became effective October 1, 2019, Texas marketplace provider collection obligations apply to sales made on or after January 1, 2019 (see Texas Comptroller — Marketplace Providers and Marketplace Sellers).. Sales before those dates are your liability, not Amazon’s.
- Direct (off-marketplace) sales are always your liability. If you also sell via Shopify, your own website, or any non-marketplace channel, those sales were never covered by Amazon’s collection.
- FBA inventory still requires registration. Per the CDTFA Marketplace Facilitator Act Tax Guide, a marketplace seller is not required to register in California if all of its retail sales are facilitated exclusively through a registered marketplace facilitator — registration is triggered only when the seller has direct sales or sales not facilitated by a registered marketplace facilitator.
States where foreign entity status is a complicating factor
Foreign sellers face additional friction in several states:
- EIN required. Most states require a Federal Employer Identification Number before VDA execution. Foreign entities without an SSN must apply via paper Form SS-4 by fax, which historically takes 4–6 weeks.
- Registered agent. Several states require a designated US registered agent for service of process, especially for foreign LLCs and corporations registering as foreign entities.
- ID friction. California’s online registration explicitly requires SSN/ITIN for individual applicants. Texas’s online application is unusable for officers without SSNs — Texas requires foreign applicants without SSNs to submit a paper Form AP-201 to the Comptroller.
- Bond requirements. Some states impose a security bond on foreign or remote sellers at the registrar’s discretion. The amount varies by projected liability.
Lookback Periods: How Far Back Do You Have to Pay?
The core economic value of a VDA is lookback compression: instead of paying tax on every period you had nexus, you pay only on a defined window — typically 3 or 4 years. Marketplace facilitator effective dates further compress your exposure if your sales were primarily through Amazon, eBay, or Etsy.
Standard lookback by state
Most states settle on either a 3-year or 4-year lookback under VDA, measured from the date of agreement (or sometimes the date of registration). A representative sample:
| State | VDA Lookback | Notes |
|---|---|---|
| California | 3 years standard under CDTFA’s VDA programs | Penalties waived, interest reduced (typical) |
| Texas | 4 years typical under Comptroller VDA program | Penalty waiver, interest not waived |
Lookback periods vary across the other 43 sales-tax states, and the exact terms turn on the fact pattern (whether you collected and didn’t remit, whether you ever registered, whether the state has had prior contact). If you need a state-specific lookback estimate, contact us for a current review — we maintain a working file across all 45 sales-tax states.
How marketplace facilitator effective dates cap your exposure
For pure FBA / marketplace sellers, your VDA exposure is bracketed by:
- Earliest date: when you first had nexus (FBA inventory placement, or economic nexus crossed).
- Latest date for direct liability: the marketplace facilitator effective date in that state — after which the marketplace is responsible for collection on facilitated sales.
For example, a foreign Amazon-only seller whose FBA inventory was first placed in California in 2018 has VDA exposure roughly from 2018 to October 1, 2019. After that, Amazon is the responsible retailer for facilitated sales — though, critically, the seller still has the registration obligation in California because of the FBA inventory.
This is a structural arbitrage VDA process can capture: the actual back tax for a marketplace-only foreign seller is often much smaller than the seller fears, because the window of personal liability is narrow.
For sellers with significant direct (off-marketplace) channels, the lookback runs the full 3–4 years on those sales.
When states extend lookback
The lookback compression is conditional on good faith. States can — and do — extend lookback or void VDAs when:
– The taxpayer materially understated liability in the disclosure schedules.
– Fraud or willful evasion is later discovered.
– The taxpayer collected tax from customers but didn’t remit it (this is treated more harshly than failure to collect).
The last point is critical. If you charged customers sales tax on your Shopify checkout in 2022 and pocketed it, you have trust-fund tax liability — and that liability is treated as theft in some states, with personal liability extending to officers. VDAs typically do not eliminate trust-fund tax exposure on collected-but-not-remitted amounts.
VDA vs. Alternatives: A Decision Framework for Foreign Sellers
Five paths exist for resolving back sales tax exposure. Three are reasonable, two are traps.
Option 1: Multistate Tax Commission (MTC) National Nexus Program
The MTC’s National Nexus Program (NNP) lets you submit a single application that covers multiple participating states. Pros:
– Single application, single representative, single set of disclosure schedules.
– Some economy of scale on professional fees.
– Anonymous initial phase.
Cons:
– Not all states participate. Major omissions vary year to year — California and several large states often run their own programs and don’t participate, or impose additional terms.
– Foreign sellers face extra vetting (some states want to confirm registered agent, EIN, and US representation before agreeing to standard MTC terms).
– Lookback terms are sometimes less favorable than direct VDAs in specific states (e.g., California’s direct program is often as good as or better than MTC for CA).
Option 2: Direct state-by-state VDAs
Apply directly to each state’s DOR. Pros:
– Often better terms in large states (CA, TX, NY).
– Greater flexibility on payment terms and lookback negotiation.
– Direct line to the state’s settlement officer.
Cons:
– More administrative overhead — 14 states means 14 applications, 14 sets of schedules, 14 negotiation tracks.
– Each state has its own forms, portals, and procedural quirks.
– Foreign sellers struggle with state-specific portal access (no SSN, no US address).
Option 3: Quiet disclosure (DON’T)
“Quiet disclosure” = just register going forward and start filing, without addressing the past. Don’t do this. Three reasons:
- You don’t get penalty waiver. When the state eventually notices the gap (and many do, when comparing registration dates against marketplace data), you’ll owe full back tax + full penalty + full interest.
- Registration signals nexus. Once you register, the state has your name on file — and they will eventually run discovery against historical periods.
- You lose VDA eligibility forever. Once registered, you cannot enter a VDA in that state.
Option 4: Register prospectively only
Appropriate when:
– Your back exposure is genuinely small (under a few thousand dollars per state).
– You’ve recently crossed nexus and the historical window is short.
– The cost of a VDA process exceeds the back-tax exposure.
For foreign sellers with multi-year accumulated FBA exposure across 10+ states, this is rarely the right answer — you typically have meaningful liability, and the VDA economics work in your favor.
Option 5: State amnesty programs (when available)
States occasionally announce amnesty programs — typically broader than VDAs (sometimes even waiving interest), but with narrow time windows. Active amnesty programs change year to year. If you’d like us to check whether any current 2026 amnesty programs apply to your facts, book a consultation — we monitor this on a rolling basis.
Decision tree summary
Have you been contacted by the state DOR?
YES → Get representation immediately; VDA likely off the table; negotiate with audit/collections.
NO → Continue.
Is your back exposure across all states under ~$5K total?
YES → Register prospectively only; clean up forward.
NO → Continue.
Is your exposure mostly Amazon FBA (post-MF date)?
YES → Narrow VDA scope; focus on registration + minimal back tax.
NO → Continue.
Are you in 5+ states?
YES → Bundled VDA program (MTC NNP or done-for-you direct).
NO → State-by-state direct VDAs.
The VDA Process Step-by-Step (For a Foreign Seller With No US Presence)
The sequence matters. Doing steps out of order — for example, registering before approaching the state — can permanently kill your VDA eligibility.
Step 1: Nexus study — establishing exposure across all 50 states
Before approaching any state, you need a defensible nexus map:
– All states where you have ever held FBA inventory (Amazon’s inventory event detail report).
– All states where you crossed economic nexus thresholds (year-by-year sales by state).
– All states where you have other physical-presence triggers (employees, contractors, trade shows).
Output: a state-by-state matrix showing nexus start date, cumulative direct sales, cumulative marketplace sales, and estimated back tax. This is the input to every subsequent step.
Step 2: Obtain EIN (Form SS-4)
Foreign entities without an SSN apply via paper Form SS-4 to the IRS:
– Line 7b (“SSN, ITIN, or EIN of responsible party”) — leave blank if you have no US tax ID.
– Submit by fax to the IRS international fax line.
– Processing typically takes 4–6 weeks, sometimes longer.
The EIN is required by virtually every state DOR portal before they’ll process a registration or settle a VDA. We cover the EIN process in detail in our guide on EINs for foreign sellers.
Step 3: Anonymous approach to state DOR (representative-led)
Most state VDA programs allow an initial anonymous phase, where a representative (CPA, tax attorney, or our firm) contacts the state on behalf of an unidentified taxpayer to:
– Confirm VDA eligibility under the stated facts.
– Negotiate the lookback period.
– Negotiate penalty waiver and interest treatment.
– Confirm payment mechanics and post-VDA registration timing.
This phase is critical for foreign sellers because:
– You do not yet expose your identity to the state.
– If terms aren’t acceptable, you can walk away (in most states) without disclosure.
– The representative speaks directly to the state’s voluntary disclosure officer, bypassing general intake channels.
Step 4: Disclosure of identity and submission of schedules
Once anonymous terms are agreed, you sign a draft VDA, disclose your entity name and EIN, and submit:
– Detailed schedules of taxable sales by period.
– Documentation of marketplace facilitator coverage (for FBA sellers).
– Calculation of back tax owed.
– Calculation of statutory interest.
Step 5: Negotiation of lookback and payment terms
Some states allow installment payments. Most require lump-sum settlement within a defined window after agreement execution. For foreign sellers, this is often the moment a US banking workaround is needed.
Step 6: Execution of agreement and back-tax payment
You sign the final VDA. The state issues an executed counterparty copy. You wire the agreed back tax + interest. The state issues an acknowledgment.
Step 7: Registration and ongoing compliance
Almost every VDA requires you to:
– Register for ongoing sales tax collection (state portal).
– Begin filing returns immediately on the assigned cadence.
– Maintain compliance for a defined period (typically 3 years) — failure can void the VDA retroactively.
This is where many foreign sellers stumble: the VDA is signed, back tax paid, and then they miss the second monthly filing because no one warned them about the 20-of-the-month deadline. The agreement gets revoked, and the state comes back for the originally waived penalties.
Real Numbers: What a Multi-State VDA Costs a Foreign Seller
The total cost of a multi-state VDA is the sum of (1) back tax + interest, (2) professional fees, and (3) ancillary costs. The back tax is what it is. The professional fees vary wildly between hourly billing and bundled flat-fee service.
Back tax + interest
Back tax is straightforward: taxable sales × applicable rate. Interest accrues from the original due date. State interest rates vary — typically in the range of 0.5% to 1% per month, compounded or simple depending on state.
States universally refuse to waive interest. Penalty is the negotiable lever; interest is not.
Professional fees: piecemeal vs. bundled
Two market models exist for VDA professional services:
Piecemeal CPA / law firm engagement:
– $1,500 to $3,000 per state for VDA representation.
– Plus hourly billing for the nexus study, EIN application, schedule preparation.
– Plus separate fees for ongoing registration and filings.
– A 14-state VDA at this rate is easily $30,000–$50,000 in fees alone.
Bundled done-for-you service (our model):
– Single flat fee covering the entire program.
– Includes: nexus study, EIN application (foreign entity), all VDAs across all triggered states, anonymous negotiation, schedule prep, payment coordination, registrations, and ongoing filings.
– Predictable for founders without US accounting infrastructure.
Anonymized case study: foreign Shopify seller
- Profile: EU-domiciled e-commerce business, GmbH structure.
- Cumulative US sales 2021–2025: $2.4M.
- Channels: 70% Shopify direct, 30% Amazon FBA.
- States triggered: 14 (FBA inventory in 6 states + economic nexus crossed in 8 additional states from Shopify volume).
Back tax exposure breakdown:
– Pre-MF Amazon sales (narrow window): ~$8,000.
– Post-MF Amazon sales: $0 (Amazon’s responsibility).
– Direct Shopify sales (full lookback in each state): ~$182,000 in tax + ~$24,000 in interest.
Outcome under bundled VDA program:
– Penalties (would have been ~$45,000–$90,000): waived.
– Interest: paid in full.
– Lookback: averaged 3.5 years across the 14 states (vs. unlimited without VDA).
– Professional fees: single bundled flat fee, fixed in advance.
– Total all-in cost: substantially less than a single state audit settlement would have been.
This is the typical economics. Foreign sellers consistently overestimate the back tax exposure (because they assume Amazon liability is theirs) and underestimate the value of penalty waiver.
Common Foreign-Seller VDA Mistakes That Blow Up the Deal
Four mistakes routinely destroy what should have been clean VDA outcomes. All four are avoidable with disciplined process.
Mistake 1: Filing a registration first
A panicked foreign seller, suddenly aware of nexus, registers for a sales tax permit in California. Two weeks later, they engage a CPA to “clean up the past.” The CPA explains: California’s VDA requires no prior registration. The window is closed.
Order of operations: nexus study → VDA approach (anonymous) → terms agreed → THEN register. Never register first.
Mistake 2: Ignoring the questionnaire that already arrived
State discovery units send “nexus questionnaires” or “information requests.” These look soft — just a few questions about your business activities. They are not soft. Responding (or even ignoring without strategy) typically disqualifies VDA eligibility.
If a questionnaire has arrived, immediately get representation. Sometimes a strategic response can preserve VDA eligibility; sometimes it can’t, but the alternative path (negotiated resolution with the audit division) is materially different from a VDA and requires different positioning.
Mistake 3: Underreporting in the disclosure schedules
Tempting to “round down” the back tax. Don’t. State VDA agreements universally include a clause that voids the agreement if the taxpayer materially understates liability. The state then proceeds with full audit, full penalty, full interest — and your prior good-faith disclosure is now used as evidence of underreporting.
The discipline: report accurately. The penalty waiver is worth more than any rounding-down savings.
Mistake 4: Missing the post-VDA filing deadlines
VDAs are conditional. The state expects you to file the next return on the assigned cadence — and the next, and the next, for a defined compliance period. Foreign sellers often sign the VDA, pay the back tax, and then miss the very next filing because they don’t have a system in place.
The fix: have your ongoing compliance infrastructure ready before you sign the VDA, not after. This is exactly the gap our service is built to close — the VDA settlement and the ongoing filings are one continuous engagement, not two separate vendors.
Done-For-You: How Sales Tax Compliance USA Handles Your VDAs End-to-End
Don’t want to figure this out yourself? Sales Tax Compliance USA handles your entire US sales tax compliance — VDAs through ongoing filings — for a single fee.
We are not a software platform. We are not asking you to learn another portal, upload your transactions to a dashboard, or interpret state DOR notices yourself. We do the work.
What’s included in our foreign-seller VDA service
- Nexus study across all 50 states: we pull your Amazon inventory event reports, your Shopify transaction data, and any other channel data, and produce a defensible nexus map.
- EIN application for your foreign entity: we prepare and submit Form SS-4 by fax, track the assignment, and provide you with the EIN.
- VDA strategy: MTC NNP vs. direct state-by-state, optimized for your facts.
- Anonymous approach to each state DOR: our practitioners contact the state’s voluntary disclosure officer and negotiate terms before exposing your identity.
- Schedule preparation: we calculate back tax, interest, and assemble disclosure schedules in the state’s required format.
- Negotiation: lookback, penalty waiver, payment terms.
- Identity disclosure and execution: we sign the VDA on your behalf as authorized representative.
- Payment coordination: we coordinate the back tax payment, including helping foreign sellers without US bank accounts work through wire and ACH alternatives.
- State registration: we register your entity in each state, obtain portal credentials, and configure your seller’s permit.
- Ongoing filings: we file every return on every cadence in every state — monthly, quarterly, annual — so the post-VDA compliance period is bulletproof.
One flat fee, all 50 states, one point of contact
Single engagement, single fee, single email thread. No per-state hourly billing. No surprise invoices when a state has a follow-up question.
What we need from you
- Your transaction data (Amazon inventory event reports, Shopify export, etc.).
- Your entity formation documents.
- Authorization to represent you (Power of Attorney).
That’s it. No US bank account required to start. No SSN required. No registered agent already in place — we coordinate all of it.
Book a free exposure assessment and we’ll tell you, in plain numbers, what your back tax exposure looks like and what a clean VDA program costs. Or learn more about our full sales tax compliance service.
Frequently Asked Questions
Can a foreign company without a US EIN apply for a sales tax VDA?
You’ll need an EIN before the VDA can be executed in most states, but you can begin the anonymous nexus and approach phase before the EIN is issued. We typically file Form SS-4 in parallel with the nexus study so the EIN arrives in time for VDA execution.
How far back will a state make me pay sales tax under a VDA?
Most states cap VDA lookback at 3 or 4 years. Without a VDA, lookback is effectively unlimited because the statute of limitations doesn’t begin until a return is filed. The exact lookback in your state depends on the facts — contact us for a state-specific estimate.
Do I need a US bank account to settle a VDA?
You’ll need a way to wire USD to the state DOR. A US bank account is the cleanest path, but foreign sellers can use international wires from their home-country bank in many cases. We coordinate the payment mechanics as part of our service.
Will entering a sales tax VDA trigger income tax or franchise tax exposure?
Sometimes. A state DOR that establishes you have sales tax nexus may share the information with the income tax / franchise tax division, who may then assess separate liability. This is a real risk for foreign sellers, especially in states with low franchise tax thresholds (e.g., California’s $800 minimum franchise tax). The risk is fact-specific — for a current review of how your VDA program might interact with income / franchise tax, contact us.
Can I do a VDA if I’ve already received a nexus questionnaire from the state?
Usually not — most states’ VDA programs disqualify taxpayers who have been contacted. But the timing and content of the contact matter. If a questionnaire has arrived, get representation immediately; sometimes the contact can be addressed in a way that preserves voluntary disclosure options.
Does Amazon FBA inventory create VDA-worthy exposure even after marketplace facilitator laws?
Yes — for two reasons. First, pre-MF-effective-date FBA sales are your direct liability. Second, FBA inventory creates a registration obligation in many states even after MF laws kicked in, and failure to register can itself trigger penalty exposure. Texas guidance indicates that marketplace sellers with inventory stored in Texas (including FBA stock) may still have a permit and registration obligation independent of marketplace collection, though application turns on the specific facts. If you hold FBA inventory in Texas, contact us for a current review of your permit obligations.
Is the MTC National Nexus Program better than state-by-state VDAs for foreign sellers?
It depends on the state mix. MTC NNP is efficient when most of your exposure states participate and the standard MTC terms are competitive. For foreign sellers with significant California or Texas exposure, direct state VDAs often produce better outcomes. We evaluate both paths as part of every engagement.
What happens if I just register and start filing without doing a VDA?
You lose VDA eligibility, you owe full back tax + penalty + interest on the periods before registration, and the state has your contact information for future discovery. Quiet disclosure is the most expensive option dressed up as the cheapest.
How long does a multi-state VDA process take from start to finish?
Typically 4–9 months end to end: nexus study (3–4 weeks), EIN (4–6 weeks, parallel), anonymous approach and negotiation (4–8 weeks per state, parallel), execution and payment (2–4 weeks), registration (2–4 weeks). Foreign sellers without an EIN at the start of the process should add 4–6 weeks to the front of the timeline.
Do VDAs cover sales tax only, or also use tax and seller’s use tax?
Most state VDAs cover the full sales/use tax framework — including consumer use tax on out-of-state purchases brought into the state and seller’s use tax on remote sales. Confirm scope when negotiating each VDA; the standard programs include all three.
Can my disclosure stay anonymous if the state rejects the VDA?
In most states with a true anonymous-approach VDA program, yes — if the state declines to offer acceptable terms during the anonymous phase, you can walk away without identity disclosure. This is one of the structural protections that makes VDAs valuable. A handful of states require identity disclosure earlier in the process; we flag those during strategy.
What if I underestimated my back tax — can the VDA be amended?
Material understatement is a serious problem and can void the agreement. Minor good-faith adjustments after execution are sometimes negotiable, but the discipline is to get the schedules right before signing. This is why the nexus study and back-tax calculation phase is the most important part of the work.
Last verified: 2026-05-10
This article is for informational purposes only and does not constitute tax advice. Consult a licensed tax professional before acting on any of this content.
