Welcome And What Changed This Week

Meet Eric Berlin And His Role

SPEAKER_03 0:10

Welcome to this week in Cannabis Live. I am Jay Rosenthal. That is Jeremy Burke. That is Mark Hauser. And over there is Anna Ray Grabstein. There wasn't much going on this week, so I didn't even know if we wanted to have a show. Just kidding. Clearly, I think we'll look back on this week as a seminal moment in sort of cannabis in the U.S. At least I hope that's the case because it was a big week. There's lots of scuttle butt. We are going to bring on an expert lawyer, an expert and a lawyer, an expert lawyer, Eric Berlin from Dentons in a Sec to talk all about what the Department of Justice direction means, what it means. There's also IRS interaction or something at play. And a hemp, Truth Social, which doesn't probably carry the weight of law, I would guess. So we'll talk about all of those things today. Eric Berlin, welcome.

SPEAKER_01 1:05

Welcome. Nice to see all of you. And thank you for having me.

SPEAKER_03 1:09

Great.

SPEAKER_01 1:10

I see my video is a little wonky, so I apologize to you and your audience. And I'm excited to be here. Just uh for background for your audience, I have been a lawyer now for over 30 years and involved in the cannabis space for 18. I was the lawyer who helped craft and get past the Illinois medical cannabis law. And then I rewrote and helped get past the Ohio medical cannabis law. And I now lead the U.S. and global cannabis sector group at Denton's, the largest firm in the world. I spend 100% of my time for clients in the cannabis space and also advocating for safe, legal, affordable access. So what happened over the last 48 hours is a watershed moment for that. And I'm excited to be here with you.

SPEAKER_02 2:02

I'm going to check that Eric is is is underselling himself himself there. And has done more for um you know professionalizing this industry and getting it forward and you know move working with every company in this industry to to make it better. So uh, you know, this industry is a lot to thank Eric for.

SPEAKER_01 2:35

Well Mark, you're very kind. It is it is it takes the village, as they say. So I think we're all working on it. Yeah, but I appreciate it. Thank you.

unknown 2:43

Yeah.

SPEAKER_03 2:43

Well, with that all said, and as a prelude, give us your take, Eric, what has happened over the past 48 hours and maybe top line what it means, and then we're gonna pepper you with questions, all of us.

280E Tax Chaos And Mixed Businesses

SPEAKER_01 2:55

So the top line to me is that the federal government has provided a pathway for the full legalization of medical cannabis, and defining medical cannabis as both uh the previously approved DEA pathway and also state legal cannabis, and allowing state legal operators to apply for the DEA registration, and that would be considered legal medical cannabis. And so that part is more than just rescheduling, and it's very significant for those of us who care about safe, legal, affordable access. Um, the other top line is that the government has not yet, at least, rescheduled non-medical use of cannabis. And I will comment that that is um you know, that we haven't seen that before, where the government divides based on use. But what the final order, what President Trump's final order says is that first part on medical cannabis, but also that there will be an additional hearing to determine whether adult use cannabis will be pulled into Schedule Three as well. And since it's the same substance, right, there are very good arguments that it that it should be as well. But the top line is that not only has uh medical cannabis been rescheduled, but the federal government hasn't provided a pathway for full legalization. And I know that not everyone is reading it that way, but that that certainly is is Denton's reading of this. Um the other top line I want to mention, so I'm sorry, is is just um this creates a lot of uh work for accountants with section 280e. And uh the government has also provided guidance, or rather, it's provided notice that it will provide guidance on allocating for section 280e when you have a business that is both medical cannabis and adult use cannabis, and medical cannabis has been rescheduled to three, but adult use has not yet been. It's kind of a funky situation that accountants are going to spend a lot of time on, and we lawyers as well.

SPEAKER_03 5:25

Well, don't sound so upset by that. Well, and it's you know what?

SPEAKER_01 5:30

So, so I'll tell you like uh having I've been at this now for almost two decades, and I would much favor clean legalization over work for lawyers at this point. My kids have already gone to college, so you know I'm just speaking, no, but truly, not just as personally, but as as someone who cares a lot about this. Um, this is this was a great advancement yesterday, but the fact that it's going to need so much lawyering and accounting is um is not great and is in some ways disappointing, but we'll see what comes of that.

AnnaRae Grabstein 6:12

Eric, uh this process started formally in 2022 under the Biden administration, and the industry has been talking about rescheduling um since then, regularly, predicting if it's going to come tomorrow, next week, or next year. And uh throughout all of that, never once have I heard someone um suggest that there would be a bifurcation um of the market in the way that this order yesterday created. And I'm wondering if you have any insight into why that happened and how that happened that you can shed some light on for us.

SPEAKER_01 6:51

Well, um, I'm a legal realist, you know? Like I've been through the political process enough that like I know that it's not formed on sitting back and saying, what's the best public policy? It has a lot to do with who has access and who is advocating. And I think in this instance, um that was really the case. And I'll say because clients were involved in that, I want to be careful, right? But um, I I think that's uh uh when you when you look at it, it's a great thing, right? I mean, it's not a great thing to have it bifurcated, but it's a great thing that medical has advanced not just to rescheduling but to a legalization, full legalization pathway. And I think there was just the feeling that you know that needed to get accomplished, but the government and and President Trump was not yet fully comfortable on doing that for adult use cannabis. And the focus has always within his administration been on the medical value. And I want to say President Trump um, you know, uh President Biden asked a question and asked folks to go and answer that question, and he was equivocal. President Trump was unequivocal. President Trump said in his executive order marijuana has uh medicinal uses. Marijuana is accepted to have currently accepted medical value in treatment in the United States, and he has focused on that along with Howard Kessler, that cannabis has significant medical value and it has been a healthcare injustice that the American people have not had access to cannabis for medical uses. So that is really consistent with what President Trump wants. President Trump um is not necessarily, I think he recognizes the inevitability of full legalization, but it's not what he personally is that interested in. So I think looking at kind of the legal realism of how this got done, that explains the bifurcation. And I do uh you know, um, it's and uh Ray, it's absolutely correct that we were not talking about that. Like some folks had suggested that as a possibility, and it pretty much got dismissed. And it's just another lesson in in politics, I think. And I I get surprised, but I shouldn't be because I've been at it so long that I just know that that's how it happens, but yet you get a result like this. And I'm not I'm not criticizing the result, it's a little bit unexpected, but it's a good result. And I also think it's partly based on the desire to continue to follow international treaties. And so I thought there was a possibility that the Trump administration would say, like, we don't really care about the single convention, or at least how it's treating marijuana. We'll just we'll just move forward. So I think a lot of what they did was uh driven from the interest of maintaining compliance with the international treaties and doing something that was airtight so that when Sam files its lawsuit, it would not be successful.

SPEAKER_02 10:28

Yeah. I want to um oh go ahead. Sorry, go ahead. Oh, yeah, I was just gonna say, I mean, that that, you know, I didn't really write this in my musings yesterday, but that was what really surprised me a lot was the the the that so much of it was framed around fitting within the single convention in a way that Canada, when Canada legalized, they didn't really seem to care as much about.

SPEAKER_01 10:50

Right.

SPEAKER_02 10:50

And give it, you know, on the one hand, given the Trump administration's general attitude towards the UN, um, you know, it it in that regard, it's it's kind of like really, but you know, but it when you put it in the framework of wanting to make sure that it gets, you know, it's forestalling arguments that others may make to challenge it, it makes perfect sense.

SPEAKER_01 11:15

Yeah.

SPEAKER_02 11:16

From that legal realism perspective. Sorry, go ahead, Charlie.

SPEAKER_04 11:21

No, I I was gonna ask Eric, um, you know, you you talked about inevitability, um, but also, you know, mentioned the fact that you've been at this for 20 years, right? Um, and I think I think there is an interesting notion in there because, you know, while this does apply to medical, the way it's bifurcated, we are headed for a DEA hearing in June. Uh and, you know, business leaders I've talked to, like, still people are confused. They're said, well, we've sort of been here before. Now this is a different administration, uh, this is a new setup for a hearing. But hearings were supposed to start, they didn't happen. So, Eric, in your mind, like, what are the mechanics of this? And is there a risk that these hearings do fall apart when it comes to the adult use or recreational side of the industry?

SPEAKER_01 12:07

Yeah, thanks for that question, Jeremy. And let me clarify my comment about inevitability. It was with respect to the legalization of cannabis writ large, as opposed to that that hearing result in that. Um, and so uh I don't know what's going to happen in that hearing. No, I think there is there's sort of uh uh there was uh an intent behind the scenes to to put that in and bring adult use into schedule three. But you make an excellent point, and I'm well aware about of it, right? I mean, just to put a point on it, I started to work on this uh the year after the iPhone hit the market, right? Like compared to the iPhone, terrible, terrible problem. I appreciate your comments, Mark, but like I kind of suck.

SPEAKER_04 13:00

Um I don't think so.

SPEAKER_01 13:02

So it's one of the reasons I don't want to take all the responsibilities because then it's just terrible. I'm ineffectual. No, but like uh I am fully aware of that, and I'm fully like I started reading that final order. When I started reading the final, and I do apologize for my video, it's terrible. Yeah, we got you on, Claire. When I when I started reading that order and the first thing said about FDA approved, and then you had some digging, I absolutely had the response of like nothing good can ever happen at cannabis. You know, I mean I did have that. I did like the DA is never gonna let anything good happen. I had that little bit like when I saw that Bondi was fired, honestly. My first reaction was like, oh God, this is gonna derail this. But that hasn't happened, right? Um and and who who is the um cultivator? Have has anyone produced a uh Todd Blanche strain yet? Because that seems inevitable. Um but that in fact happened, and in fact, uh, you know, despite cynicism, skepticism, President Trump has legalized medical cannabis. And so what happens in in the hearing, I truly don't know. And I'm a I'm a grown-up. I understand that a possibility is that golly, that the hearing falls apart, problems happen, there are lawsuits, who knows what happens. And I'm not sitting here to suggest that I'm confident that the hearing will result in um adult use being rescheduled, but I'm confident that it should be, and I'm confident that if you look at the standards and now and and and and and these don't normally get divided by use. So the question is does cannabis have uh uh currently accepted medical uses in treatment in the United States, and is it less dangerous than Schedule One or two drugs? And it doesn't really matter how someone is using it, right? It matters whether those whether a substance meets those standards or not. So, I mean, the government has made the biggest admission ever of rescheduling part of cannabis to schedule three. So it would follow that the rest of it should go, but I'm with you 100%. I I can't sit and guarantee that because Lord only knows.

Can States Expand Medical Access Fast

SPEAKER_03 15:41

Well, Eric, can I ask you a question about that in particular? Uh we, Jeremy and I, uh in our program talked to a lot of regulators in states, uh, most notably, most recently California. Many want to help the industry or claim to want to help the industry in some way. Like, what would stop a state now to say um all of our cannabis that we sell is medical, right? And we write rules to that effect. And and you know, just like aspirin is legal in lots of you know different places to buy it, just make everything medical in a state and loosen the rules so significantly that everything is medical in California or New York. Um, like it doesn't I I don't know if they've thought of that scenario or I don't know if regularly agree, but like but let's do it.

SPEAKER_01 16:25

Hey, Jay, I can say that I've been thinking of nothing else over the last like 24 hours. So um let's talk about that a little bit.

SPEAKER_02 16:34

Like amazing.

Interstate Commerce And State Barriers

SPEAKER_01 16:36

Let's let's first of all um I'm gonna answer that question, but I think this is an important point that I want to make is let's not take for granted our our state regulators. And they're they're really going to be important in all this, and they're important conduit to the legislators, and we're gonna need we're gonna need the support of legislators because it what needs to happen now. So every state that is legalized legalization basically eats medical cannabis, um uh not entirely because there are lots of tax benefits from going in and and and being a medical cannabis patient, but in general, a lot of people purchase adult use and use that medically, right? And so and and and and in states that have only medical, it is a thriving industry. And so what I would work towards states to do now is uh open the doors for medical, right? I mean, what they it can't be it can't be like non-doctors and it can't be self-certification because that's not gonna work necessarily. I have to think about that more, but I don't know that's gonna work in this scenario. But the way that this can be broadened is um any doctor can certify any patient for any condition, right? And so we've been this has been forever like folks criticize Colorado because so many people were registered for pain and anxiety. Well, it turns out so many people were registered for that. Yeah, some people registered for it because it's broad, but lots of people registered for it because cannabis works for pain and anxiety and sleep and and appetite. Like it works for those, so it's not surprising that people register under those broad categories. And we need to get back to that as opposed to having very specific particular conditions to have broad qualifying conditions. Uh, we need to take away all the, you know, physicians need to jump through all sorts of hoops and certify to all sorts of different statements to let patients use. It can be much more broad than that, and any patient can, excuse me, any physician can certify for for any um any condition. And that would uh push a lot of folks back into medical cannabis and maintain the tax um beneficial treatments for medical cannabis patients. Um and uh I think that's going to be really helpful. The other thing that is being talked about is what does this mean for interstate commerce? And my view, my view is that um you have the state compacts, and I'm not quite sure whether this necessarily triggers what's in each of the state compacts. I haven't gone back and done that for like California and Oregon, but other states can jump on that now. I mean, this is fully legal, right? So let's just take an example. Let's just say I'm a medical cannabis patient for Crohn's disease, and I have cannabis that I use for that treatment. And I now am traveling from Illinois to California. It was never a problem to begin with, right? I mean, TSA was never stopping folks for that. Not never, but like not within the last 10 years. But the point being that that cannabis that I now have is legal, it's fully legal. The fact that I'm crossing state lines or showing up in another place where it's legal or in a plane with it, it's it's all legal. If you're a legal medical cannabis patient and purchased legal medical cannabis, that is then all legal. So there's nothing stopping the interstate movement of that product, either as a consumer or as um as operators. What's stopping that are the state laws. The state laws expressly said nothing can leave the state. Many of them do, and in fact, most of them do, in order to comply with what was then the coal memorandum. The coal memorandum had its own priorities, and one of its priorities is none of this should leave the state. So many of the states we wrote into the state laws, that in particular, to kind of ward off federal enforcement. But the bottom line is legislators, general assemblies can change that language. Uh, they can delete that language and make it legal for the cannabis to to leave the state. And and and several states can arrange for interstate commerce of medical cannabis, although not adult use cannabis at this point.

SPEAKER_02 21:50

I I I I agree with you wholeheartedly. I think the interesting thing, though, will be that you know, I think the states generally like You know, from a protectionist perspective, uh, having these things. Um, and you know, it it would whereas states like California will definitely benefit from being an exporter, you know, other states, I think, you know, from what I've heard and talked to people, they generally will, you know, they want to have that protectionism while they still can get away with it. And they do have some of the protection based upon what some of the appellate courts have said, which is that there is no, there is no commerce clause protection for an illegal product, which you know, which is illegal. But now that it's no longer legal, that argument, you know, I think that there is now potentially a new challenge to these laws. Um, so that you may we may not see it that the states necessarily, you know, themselves break down their, you know, their barriers, but we may, you know, eventually see those barriers breaking up. Of course. You know, this it's creating this really interesting legal intellectual argument.

SPEAKER_03 23:06

Or, I mean, can I I I'm not a lawyer, but I do know Mark Hauser. So that's that makes me close to a lawyer, I guess.

SPEAKER_02 23:13

You know a lawyer.

SPEAKER_03 23:14

I know a lawyer.

SPEAKER_02 23:15

You know two lawyers on the city. I know many lawyers.

SPEAKER_03 23:18

My my my world is filled with lawyers. Uh most of them, most of them love weed, but not as much as you guys like the cannabis industry. Um but what it what what stops, I mean, aside from the um the state rules, but what what stops a grower in California, a great licensed grower, from growing medical cannabis and and soon being able to ship it to patients in other legal cannabis states?

SPEAKER_02 23:39

Well, I think right now it's the state law. Right. Right now, a lot of this they would be violating their own state's laws. But they could they could arguably challenge that. That's the pro you know, that's the issue. But they but right now the law on the books says they can't do it.

SPEAKER_03 23:57

Right, but that's a state law. But also imagine you're a California grower growing quantities that patients in Florida and they're only patients in Florida, like will will California, I mean, you can imagine a scenario, Eric. I I could think that if California changes rules to help their growers to find markets outside of California, that a California grower would find common cause with uh dispensary owners and operators in Florida, because although their rules would also have to change.

AnnaRae Grabstein 24:27

Um but like and and Florida's a great example. I mean, the the existing medical operators can't even sell to each other right now.

SPEAKER_01 24:36

So yeah, so there yeah, let me address, let me try to address all that. That's a really interesting point. And this just for the legal geeks out there has to do with the dormant commerce clause. And to be clear, we in the United States, and this is not just a geeky point, I want to get the foundation. We in the United States have interstate commerce, and it's one of the things that makes the United States great. We have climates and different climates and different abilities all over the country, and the fact that in the middle of the winter, I can go downstairs and get a glass of orange juice, right? I mean, like you can't do that in Chicago other than for interstate commerce. And um and uh so number one, I want to get that foundational commerce clause issue. And the Dormer Commerce Clause basically says you can't you can't um uh disadvantage uh uh folks in interstate commerce based on like an individual state. You can't say only residents of the state can supply lumber to the state. That's a simplification of those. Um to Mark's point uh the uh intrastate commerce has been a pretty good interim solution. It's worked well with states that are learning to regulate cannabis and it's regulated solely within the state through sea-to-sale tracking. Um and it works very well for many of the uh uh licensed operators um who can produce in Maine or other places without having to compete against the California producers or Florida producers or you know, places that have climates that you can produce in in great amounts with lower energy costs. And I respect that business point, but here's the deal I in uh Illinois am eventually going to be able to uh uh use the best cannabis that's grown anywhere in the United States because that's what makes America great, and we don't limit uh legal products in that way, and so to go back to the original question, medical cannabis has become federally legal. And if if you are a producer in uh if let's say you have a license in California and Florida, and you want to start bringing in your product from California into Florida, and it's all for legal medical canvas purposes, and every entity in there is properly licensed under state law and registered with the DEA pursuant to this new final order. Um I think that I think that um state laws barring that are very susceptible to dormant commerce clause challenges. And I don't want to I don't want to state a result, and I want to be a little careful here in my wording to not be definitive because I need to think about it more, and I don't want to say something that you know gets taken out of context. But like from the notion of how this country works, we don't limit the interstate flow of legal products, and medical cannabis is becoming a fully legal product. So I would think, yeah, go ahead, Aina Ray. Sorry.

AnnaRae Grabstein 28:17

No, yeah, I just I'm just making sure I'm on the stack because I know we all have lots of questions. Um, this is such a big deal, uh, what you're talking about, and and a huge element of it is this DEA registration and um and the way that that process flows. This order basically created a regulatory framework or or the or the auspices of one because of the way that it described how the DEA will uh purchase the cannabis um for a nominal fee. And one of the things that I have always thought was slightly questionable when I thought about cannabis being rescheduled or legalized at the federal level was was that the government was going to be giving up a lot of the 280e penalties that has been its way of taxing the industry for a long time and that they wouldn't give that up without inserting something else. And it appears that the that the DEA is inserting itself in the middle of cannabis transactions in a way that it could be benefiting um with revenue generation through this transaction. Uh I'd love it if you could just dive in for us to what has been proposed as the DEA's involvement and um and why that ultimately means legalization and and how it might be kind of like a licensing fee or taxation in some ways, if you see it that way.

SPEAKER_01 29:49

Anna Ray, your view that the federal government might want a piece of this is well founded. And I know that President Trump at one point said something like, look at all the money the states are making, we should get a cut of that. Yet I don't think that the DEA insertion is that. Uh, the DEA has been inserted for compliance with international law. And as as we said, there was a possibility, we thought, that the government wouldn't want to do that, but apparently they do, and they're hewing very close to that. Not very close, they're complying with federal law by doing it this way. And federal law, the single convention on narcotics and the follow-on treaty require the DEA have control of all this, which gives them um inspection and audit rights as well that folks haven't really been talking about. But um that sale to the DEA is not like the DEA is gonna come and take possession of it and then distribute it itself. It's sort of a legal fiction, right? I mean, they're they're not gonna take physical possession as I understand it. There will be, they're taking uh control because they have enough control over the facility, and they're going to take a fee so that it's formally a sale to them and a sale to someone else. But I don't while your your hypothesis is correct, I don't see this as the area where the government is trying to take its cut. It could be, but I think uh, you know, we may eventually see an excise tax, but that's really for Congress uh to pass, not for the president doesn't have the power just to do that.

State Compacts And Legal Precedent

SPEAKER_04 31:39

Eric, I've got a relatively simple question. Um I'm obviously not a lawyer, so you know, bear with me with my lack of knowledge, but is there is there a precedent for multiple states entering in a compact to transport goods across state borders that still have federal restrictions? Say, for example, California, Washington, Oregon, New York, Massachusetts, Connecticut, allowing cannabis to cross the state lines, however defined.

SPEAKER_01 32:17

Um so there's not a ton of precedent on this, but it can be done, right? I mean, I think that's I have to I'll I'll refresh myself on this, but I think it's constitutional. Like states constitutionally are permitted to enter those compacts. So there's not a ton of history on that as I know, but it it it it unequivocally is permitted. Most of the compacts now, the the states are saying like when legal, right? I mean, they've sort of hedged on it, but it's legal. That's the point that I'm making, right? Like that when legal, that has occurred. By the way, there are all sorts of provisions in contracts that say the trigger for a warrant or conversion is based on federal legalization of cannabis. I mean, I think. Well, I think cannabis acreage. Many of the well, many. There are a ton. And and we started drafting them differently later on. But the fact that there's so many out there, that those were drafted in a time when, quite frankly, it was not envisioned that the federal government would buy for cake cannabis in this way. And now we have like I the intent of those would was that cannabis was fully legal, and some of them were drafted that way, but some of them early on were just like when the federal government legalizes cannabis. And in fact, that's happened in part. So um I I I didn't I I I regret, I mean, I just want to be clear I'm a lawyer, but I I do regret how much lawyering is going to be required for it. Well, so I know we're laughing, but like I mean, I know people are looking at this and being like, it is the lawyer and accountant employment act.

SPEAKER_02 33:59

Um, yeah, and I guess I called it the federally sponsored lawyer and accountant pension plan. Well, I oh, go ahead, Anna.

Hemp, CBD Policy, And Four Categories

AnnaRae Grabstein 34:08

I want to make a little bit of a segue. You talked about this bifurcation. So I think what we're talking about now is not just a bifurcation of medical and adult use. There's actually now four categories of cannabis. There is FDA-approved cannabinoid medicines, there is medical cannabis, there is adult use cannabis, and there is hemp um also cannabis. And um I think that there has been a lot of talk about hemp for months and months and months since the November language came out. And um when this was announced yesterday, one of my thoughts was well, maybe this actually is going to open the door for more clarity on the hemp policy or maybe more action on change, because the cannabis industry has been working so long on rescheduling. The administration can't move on hemp policy without actually doing something substantive on rescheduling. And then by the end of the day, we had a um tweet, or I don't know what it's called on Truth Social from Donald Trump um talking about the executive order uh from from the winter time and calling for action around hemp derived CBD. Um what are what are we thinking about about that on the back of rescheduling? Are they connected? Are they totally two different paths? It seems like similar people. You talked about Howard Kessler and and and medical, and he's very much a part of the CBD effort as well.

SPEAKER_03 35:41

Can I just say before you start, Eric, that we're having like two or three minutes, and then we're gonna have to wrap. Apologies.

SPEAKER_01 35:46

I'll be really quick. My my understanding of what Trump is driving at there is a change to the definition of hemp to fully permit what he envisioned with the CBD reimbursement program. And so the problem is hemp was redefined, it's defined so narrowly that many of the broad spectrum CBD products that Trump wanted to include in the CMMI program and have reimbursed with Medicare are off the market. So he wants Congress to fix the definition of hemp so that it permits uh his products. What I envision from this is at at the end of this, I'm not sure what's gonna happen with adult use, and maybe it'll be rescheduled. But in terms of your categories, you'll have a DEA supply, you'll have state legal medical, you'll have state legal adult use, you're gonna have hemp, which is gonna be substantially narrowed to basically just CBD products. And of course, we have the fully listed market, which is like as large as all those put together. And I think that's a really important point. And if is that you know, we're we're doing all this work, but we don't exist in the universe where we have a choice of cannabis versus no cannabis. We have a ton of cannabis out there, and it depends how we want to regulate, tax, and enforce.

SPEAKER_03 37:17

That is a good place, I think, to pause, because this conversation is going to go on for months and months and months. But for today, this I think has been a very good thank you, Eric, and all, um, conversation about sort of what did happen over the past 48 hours, the questions that are still outstanding, and how the industry will discuss it uh over time. But I super appreciate your time, uh, always, Jeremy, Mark, and Anna Ray. But today, specifically with Eric, uh, because this has been a great conversation. We super appreciate it. So thanks so much.

SPEAKER_01 37:48

Thank you guys. Really great talking to you.

SPEAKER_03 37:50

Thanks, everybody. We'll be back with lots more of this conversation next week on cultivated.news. Get our newsletter and all that jazz. Uh, thanks, everybody.