The Brief

California regulators have failed to compel the state’s worst cited wage theft offender to pay the millions of dollars his companies stole from workers, a KQED investigation found.

The California Labor Commissioner’s Office ordered Rafael Rivas’ RDV Construction Inc. and RVR General Construction Inc. to pay $16.2 million for defrauding more than 1,100 workers in Southern California. But the agency, which issued the citations for back wages and penalties in 2018 and 2019, had recovered just 2% as of last month, according to a department spokesman.

KQED reviewed hundreds of pages of state documents and court records, knocked on doors of properties linked to Rivas and interviewed workers the construction contractor cheated to piece together an accounting of the stunning labor violations — and how an understaffed agency was unsuccessful in collecting most of what Rivas and his companies owe.

California has some of the nation’s strongest employee protections on the books, including against wage theft. Yet, Rivas’ case signals that the state is not prioritizing restitution for workers when their earnings are withheld, according to workers’ rights advocates and employment attorneys.

“It’s outrageous. It’s infuriating,” said Benjamin Wood, a former organizer with the Pomona Economic Opportunity Center who has helped dozens of workers file wage complaints with regulators, including against RDV. “The state has so much power to enforce laws. But when it comes to massive wage theft, it seems like they’re powerless.”

The California Labor Commissioner’s Office ordered Rafael Rivas’ RDV Construction Inc. and RVR General Construction Inc. to pay $16.2 million for defrauding more than 1,100 workers in Southern California.

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Darren Tu

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From 2017 through 2023, the labor commissioner’s Bureau of Field Enforcement assessed $450.6 million in unpaid wages and penalties against thousands of employers statewide, including Rivas’ companies. The agency recovered as little as 16%, or $74.5 million, according to records it provided to KQED last month.

The database, however, may contain errors and omissions, according to a department statement. A state employee familiar with the bureau’s case management system said that’s because staff don’t consistently update it.

Beth Ross, an employment attorney, said the omissions point to a dysfunction at the Labor Commissioner’s Office, which has a critical role in protecting vulnerable workers from abuses and helping to level the playing field for law-abiding employers.

“If the agency is not capable of keeping the database updated, then what else is the agency not able to get to?” said Ross, an adjunct professor at UC Law San Francisco. “We know the agency has a very difficult time keeping up with the onslaught of complaints and tips it receives about wage theft and labor law abuse in the state.”

The job vacancy rate at the Labor Commissioner’s Office reached 42% last year, according to an analysis of staffing documents kept by the state Department of Finance. Dozens of wage theft investigators, attorneys and others at the agency implored state lawmakers in July to address a hemorrhaging of employees leaving for better-paid positions elsewhere.

The Labor Commissioner’s Office, also known as the Division of Labor Standards Enforcement, declined interview requests but said in a statement that collection efforts in Rivas’ case are ongoing.

“The Labor Commissioner’s Office will continue to explore all avenues towards restitution that are available to our agency,” said a department spokesperson in a March 14 email.

Rivas did not respond to requests for comment by email, phone and messages left in person with an employee at his office in Los Angeles County and on a note at his residential property in San Bernardino County.

Two family business associates named as co-defendants in one of the wage citations — his brother, Juan Rivas, and cousin, Nicolas Del Villar — also declined interview requests.

The state Attorney General’s Office, which can criminally prosecute wage theft cases, declined to answer whether it had taken any action against the employer.

“To protect its integrity, we’re unable to comment on, even to confirm or deny, a potential or ongoing investigation,” a spokesperson for the attorney general wrote in an email.

Spokespeople for district attorneys in San Bernardino and Orange counties said they had no records of cases against Rivas or his companies. The Los Angeles County District Attorney’s Office did not return requests for comment.

Victims struggle to pay rent, buy food

When Saul Pedroza is not working he finds solace gardening in his home in Anaheim. March 7, 2024.

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Javier Gonzalez and Saul Pedroza installed steel rods and wooden frames for RDV Construction in 2016 at an apartment complex in Glendale, north of Los Angeles. The crewmates, both Mexican immigrants, said the company never paid them for about a month of full-time work.

Supervisors “started telling us that the paychecks were coming next week, and then next week,” Pedroza, 51, said in Spanish. “That’s how they strung us along.”

The carpenters were given paychecks that bounced due to insufficient funds. After they quit, Pedroza and Gonzalez said they went to the worksite and RDV’s offices to demand their earnings, and they both filed wage claims with the Labor Commissioner’s Office.

The agency determined RDV owes $11,000 to Gonzalez and $12,500 to Pedroza.

“I see it as a mockery of all the people they defrauded and of the government,” Gonzalez, 61, said. “It was a robbery in broad daylight what they did to us.”

Pedroza said the theft of his salary meant he couldn’t buy enough food for his four children or pay rent for the family’s mobile home in Anaheim. He said he borrowed money from friends and desperately scrambled for other jobs to avoid eviction.

“It was a long time that we were doing badly, without any money,” Pedroza told KQED. “It was wrong.”

Rivas’ companies underpaid workers at dozens of construction sites from 2014 through 2017, according to investigations by the Bureau of Field Enforcement. In 2018, the labor commissioner cited RDV for nearly $12 million in unpaid wages and penalties. It was the largest citation the agency ever issued. The following year, RVR was hit with a $4.3 million citation.

“Stealing earned wages from workers’ pockets is illegal in California, and this case shows that employers who steal from their workers will end up paying for it,” said California Labor Secretary Julie Su at the time, who now heads the U.S. Department of Labor.

Delays gave Rivas time to minimize payments

Rivas appealed the citations. Disruptions during the pandemic further delayed attempts to recover any funds, providing Rivas years to take steps that would limit the labor commissioner’s ability to collect the fines.

By the time the agency dismissed Rivas’ appeals in May 2022, he had filed for federal bankruptcy protection for RVR. He also closed down RDV, with the company’s contractor license expiring in April 2022.

That meant state claims against RVR, which continues to operate, could not legally be collected outside of bankruptcy court, and obtaining funds from RDV would be very difficult, according to several legal experts.

“It’s next to impossible to collect from a company that’s closed unless they have real estate or other assets, which would be very rare, particularly for a small construction contractor,” said Greg Groeneveld, an attorney in San Francisco who specializes in enforcing wage judgments. “But you can sometimes pursue the owners of that company.”

The labor commissioner may still choose to target individual defendants cited, including Rivas.

When an employer doesn’t pay a wage fine that’s deemed final, the agency requests a state court to order payment. The civil judgment generally allows a creditor to use tools such as liens and levies to try to recover what is owed.

Many employers agree to settle before a court issues a judgment against them. But others don’t have the money or try to dodge payments, including by closing their companies or transferring ownership of real estate as a way to hide assets.

The Orange County Superior Court awarded the labor commissioner a judgment against Rivas, Juan Rivas, Del Villar and RDV last year. However, investigating a debtor’s true ability to pay can be time-consuming and difficult, and it’s unclear what of the individuals’ personal assets the department has tracked as eligible for collections. The labor commissioner’s Judgment Enforcement Unit, tasked with recovering funds in thousands of unpaid judgments, had 16 out of 28 positions filled last year, according to the Department of Finance.

San Bernardino County Assessor’s records show Rivas transferred at least one commercial property in Fontana, which is listed as RVR’s official business address, to a family member, Rosa Rivas, months after filing for the company’s bankruptcy. Rivas also owns an adjacent vacant plot of land.

The commercial property, with a Zillow estimated market value of $1.4 million, has a barber shop and hair salon facing the street and a one-story home standing in the back. A woman who told KQED she was eating lunch at the home identified herself only as Rivas’ ex, adding that they no longer spoke to each other. She declined to give more information.

“I don’t want to hear anything else about him,” she said before closing the door.

Three miles away, no one opened the door at a residential property owned by Rivas. A reporter observed a luxury Maserati Grecale purchased last spring, according to a document taped to its windshield, and a Ford F-550 flatbed truck were parked on the driveway. KQED could not confirm that Rivas owns the vehicles.

Who is Rafael Rivas?

Rivas started working in construction as a teenager more than 45 years ago, according to documents filed by his attorney in the U.S. Bankruptcy Court in Riverside.

The former day laborer went on to grow businesses that earned millions of dollars per year, building private hotels, mixed-use buildings, luxury apartments and at least one affordable housing project near downtown Los Angeles.

Rivas, 61, co-founded RDV Construction in 2010 with Juan Rivas and Del Villar. The following year, Rivas launched RVR General Construction.

Years later, Rivas blamed his family business partners for the wage theft violations.

“Rivas was certain he had not violated any such regulations and later learned that the family partners were the source of problems,” according to filings by attorney Michael Jones, who represented RVR.

“Realizing that he was not compatible with the family partners as business associates, Rivas did venture out on his own and began doing business by himself through RVR,” Jones added. “However, a significant amount of damage had already been done.”

In a separate case, the labor commissioner determined RDV owed $314,500 for underpaying more than a dozen carpenters employed at a Los Angeles public housing project in 2015 and 2016. Rivas settled for an undisclosed amount after the Contractors State License Board suspended his companies’ licenses to operate until the judgment was resolved, said Katherine White, chief of public affairs at the license board.

Rivas’ companies repeatedly violated workplace standards, paying about $37,000 in back wages and damages to the U.S. Department of Labor in 2017, and additional fines to other regulators. The California Division of Occupational Safety and Health penalized RDV and RVR, including for safety violations related to the 2015 death of an employee who fell 40 feet from a roof opening.

How much is the labor commissioner set to recover in Rivas’ case?

So far, the labor commissioner has collected $277,000 towards the two multi-million citations, including through a mechanics lien and a payment plan for RVR to emerge from Chapter 11 bankruptcy, said Peter Melton, a spokesperson with the Department of Industrial Relations.

“We can confirm the Labor Commissioner’s Office (LCO) has received over $164,000 from Chapter 11 bankruptcy payments as part of our judgment enforcement efforts in this case,” said Melton in an email. “LCO also collected and disbursed $100,000 on a mechanics lien lawsuit against this employer.”

The bankruptcy payments appear to be the only restitution the agency is currently receiving.

RVR agreed to pay at least 10% of its total income until it fully covers or settles the labor commissioner’s $7.6 million claim, according to bankruptcy documents. The company projects installments of about $150,000 per year.

At that rate, it would take RVR 50 years to settle the debt.

“It’s really a shame,” said Ross, the employment attorney. “These workers are so unlikely to see any amounts of money that could remedy the wrong that they suffered. And that’s if you can find them. As time goes on, fewer and fewer of these workers will be found.”

Daniel Reiss, a bankruptcy lawyer who reviewed RVR’s case for KQED, said an important question now is how the labor commissioner is monitoring the company’s income to ensure their payments comply with the agreement.

Depending on RVR’s financial picture, the agency could still push for a shorter-term deal through a court mediation panel, he added.

“You can make a negotiation with respect to getting money now while everybody’s still alive, as opposed to having no idea if it will ever be paid off,” said Reiss, who is also a bankruptcy mediator for the Central District of California.

Monopoly lovers can now buy up the Queen Mary, collect rent on Belmont Shore and park their token at a storied tattoo shop, Outer Limits.

The Long Beach landmarks line the spaces of a new Monopoly edition themed around L.A. County’s second biggest city, released just this month.

The Long Beach edition is part of an expanding series of Monopoly games featuring dozens of American cities, which Hasbro licensee Top Trumps started to produce about five years ago when interest in board games surged during the pandemic.

What it takes to make the cut

How does a city land on one of the world's most popular board games? Turns out, it’s not just a roll of the dice.

“We’re looking for places with strong community pride, places where people will really love seeing their city on a Monopoly board,” said Jennifer Tripsea, a partnership sales executive with Top Trumps.

Long Beach fit the bill and got to join a list of SoCal cities on Monopoly boards including Huntington Beach, Riverside and Palm Springs.

Tripsea said in some instances, a city will pitch themselves to the company — she didn’t disclose which have — but not every place makes the cut.

There has to be enough population — or local enthusiasm — to support a run of thousands of games.

Top Trumps sells the games online and through local businesses, sometimes the same ones featured on the board. That creates a built-in customer base: residents, tourists and collectors hunting for their next addition.

And while some businesses may offer to sponsor their way into consideration, their inclusion isn’t a given.

Tripsea said when deciding who earns a spot, the company weighs cultural relevance, brand standards and community input.

The community gets a turn

Once a city is selected, residents are invited to help shape the board.

That means emailing suggested landmarks and drafting potential Chance and Community Chest cards. For Long Beach, one Community Chest card directs players to collect $100 if they "attend a beach cleanup at Alamitos Beach."

Hundreds of submissions flooded in over the last year, many pointing to the same top attractions, Tripsea said. The Queen Mary and Aquarium of the Pacific take up the same spots on the board that are occupied by Park Place and Boardwalk in the original game.

Of course the Queen Mary historic ocean liner landed a plum spot on the Long Beach version of Monopoly.

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Patrick T. Fallon

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Others featured on the board are lesser known to outsiders, like Rosie’s Dog Beach and the Arts Council for Long Beach.

The arts nonprofit was “surprised and excited” to hear from Top Trumps last year that they were being included in a version all about Long Beach, said interim executive director Lisa DeSmidt.

“I describe Long Beach as a big city that's run like a small town, and that everybody kind of knows each other to some degree,” DeSmidt said. “Long Beach has a sense of community in that Long Beach takes care of Long Beach people.”

An intern for the Arts Council for Long Beach designed its space on the Monopoly board.

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Arts Council for Long Beach

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An intern for the arts council, Peyton Smith, designed its space on the board, featuring small, intricate renderings of landmarks like the Long Beach Airport and the pyramid arena at Cal State Long Beach.

For DeSmidt, the game serves as a kind of cultural snapshot highlighting the city’s mix of arts, neighborhoods and institutions. It’s reminiscent of the council’s own project mapping the city’s cultural assets.

“This ties into uplifting what makes Long Beach unique and what people love about it,” DeSmidt said.

Monopoly's lasting pull

Outer Limits Tattoo was also invited to be part of the game, where it now appears next to VIP Records on the board.

Recognized as the country’s oldest continuously working tattoo shop, Outer Limits’ history dates back to 1927, when it opened in the waterfront amusement district known as The Pike, now home to the Pike Outlets.

Outer Limits' general manager Matt Hand said once word got out that the shop was stocking the game, customers started showing up just to buy it.

“It’s just a cool thing,” Hand said. “Especially when it’s like, ‘The business where I get tattooed’ is on the board.”

A big reason Hand thinks these editions are catching on is nostalgia. Seeing your own city in a board game that you played as a kid — and may be now playing with your own kids — is thrilling.

“You're basically like a part of the game now,” Hand said.

You might have noticed a little more purple on your commute in Los Angeles recently. Turns out the jacarandas are putting on their annual show of blooms a little early this year.

Originally from the tropics, jacarandas respond to changes in temperature. They typically flower in our region from late April to mid-June.

But remember that sweltering heat wave we got in March?

“They got the clear sign: ‘It’s over 90 [degrees], it’s hot out. Even though you weren’t quite prepared, it’s time to put out some flowers,'” Loral Hall, community forestry senior program manager at environmental nonprofit TreePeople, told LAist.

Hall said not only do jacarandas grace us every year with thick canopies and carpets of purple, they’re relatively drought tolerant, pest resistant and able to grow in urban areas (like in a small square patch of dirt surrounded by concrete).

“They’re attention-grabbers here in Southern California,” said Hall, who grew up in Hollywood and has childhood memories of playing with the fallen purple blooms at a local park. “In a place where we don’t have really obvious seasons, [jacaranda blooms] are a sign that warmer weather is on the way.”

Hall also shared a lesser-known fact about jacarandas: There’s a white cultivar, too. The white version is much more rare in L.A., though with some of the trees rumored to be in a non-public area of the L.A. County Arboretum, Hall said.

A jacaranda at the LA Arboretum.

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Katherine Garrova

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How’d they get here? 

The jacaranda is native to the tropical and subtropical regions of Argentina and Brazil.

While we don’t know exactly when the jacaranda first arrived in our area, we do know they were brought to Southern California in the late 19th century and proliferated thanks to a local horticulturist named Kate Sessions.

Where are the purple hot spots? 

A couple years ago, a local data graphics editor even created an interactive map so you can find the purple hot spots.

They’re... everywhere, so it shouldn’t be too hard to stumble upon a jacaranda show.

The number of immigrants who have died while in Immigration and Customs Enforcement custody has reached an all-time high this fiscal year.

Twenty-nine people have died in ICE custody since October, the start of the federal government's fiscal year, already surpassing 2004's toll of 28, the previous record, according to government data.

The most recent death was of 27-year-old Aled Damien Carbonell-Betancourt, a Cuban man held in ICE custody in Miami. According to an initial report released by ICE on the evening of April 16, Carbonell-Betancourt was found unresponsive in his cell on the morning of April 12. The report lists the cause of death as a "presumed suicide," but the official cause remains under investigation.

The report said Carbonell-Betancourt entered the United States in 2024 without valid documents and later released into the U.S. via a program known as parole, which allows noncitizens to enter the country without a formal visa, often for humanitarian reasons.

He was arrested for resisting an officer with violence in 2025, and then transferred into ICE custody earlier this year, according to the ICE release.

The rise in deaths comes as detention numbers have skyrocketed during the Trump administration. Detentions are up more than 70% under President Donald Trump compared to the first year of the Biden administration. The Trump administration has carried out an unprecedented crackdown on immigration. Immigration officers have arrested and detained criminals in the country illegally, as well as many people without a criminal record and some migrants who are in the country with temporary protections from deportation.

There are about 60,000 people currently in immigration detention.

In a statement to NPR, DHS denied there's been a spike in deaths and attributed the increase to the large number of people in detention. DHS said as of April 16, "death rates in custody under the Trump administration are 0.009% of the detained population."

The agency added that ICE provides migrants with access to medical care.

"For many illegal aliens this is the best healthcare they have received their entire lives," the statement said. The statement went on to encourage detainees to self-deport. "Being in detention is a choice. We encourage all illegal aliens to take control of their departure with the CBP Home App," the statement said.

During a congressional hearing also on Thursday, acting ICE Director Todd Lyons said there are a high number of deaths this fiscal year "because we do have the highest amount in detention that ICE has ever had since its inception in 2003." Lyons added that the agency spent "almost half a billion dollars last fiscal year … to ensure that people have proper care."

He reiterated details noted by other DHS officials: that detainees get a complete physical within 14 days and are seen by a medical professional within 24 hours of being admitted.

"No death is what we want. We don't want anyone to die in custody," Lyons, who handed in his resignation hours after testifying, said. "I hope that's a policy of anyone that has to be tasked with detaining someone."

When asked how many people were still working in the Office of Detention Oversight, he was not able to provide a number.

Lyons was also asked about the delay in public reporting and tracking detainee deaths. On April 13, Georgia Democratic Sens. Jon Ossoff and Raphael Warnock sent a letter to Lyons and DHS Secretary Markwayne Mullin raising concern over the rising number of detainee deaths and noted that of the 49 deaths in custody at the time since January 2025, "ICE has issued an interim death notice within 48 hours in only 15 cases" and argued that reports contained less details.

"We are reporting. We are working on that timeline," Lyons said during the House hearing, agreeing that the detainee death reports were considered essential work even during the agency's funding lapse.

Facilities in Texas and California are the deadliest

Adelanto ICE Processing Center in Adelanto, Calif., and Camp East Montana in El Paso, Texas have each reported the deaths of three detainees, the most out of ICE's sprawling detention operation. 

According to ICE's initial reports, the deaths of the six immigrant detainees were attributed to a number of causes, including suicide, alcohol withdrawal, liver failure and kidney failure. Other detainees displayed symptoms like shortness of breath.

One of the deaths at Camp East Montana was ruled a homicide by the El Paso County Medical Examiner's Office.

Initially, DHS said that Geraldo Lunas Campos had died in Camp East Montana after experiencing "medical distress." It also claimed Lunas Campos had become "disruptive while in line for medication" and was placed in segregation. But later, the El Paso Medical Examiner's Office ruled his death a homicide due to "asphyxia due to neck and torso compression." The FBI is now investigating the death.Chris Benoit, an attorney representing the family, told NPR Lunas Campos came to the U.S. in the mid-1990s as part of a wave of Cubans immigrants during the balsero crisis after the fall of the Soviet Union.

"For all sense and purposes he is an American," Benoit said. "He's lived here for decades and raised his family here and his kids love him and miss him."

According to DHS, Lunas Campos had been convicted of multiple crimes, including petty larceny, unlawful possession of a weapon during a robbery and sexual contact with a child under 11.

In a court petition seeking eyewitness testimony, Lunas Campos' three children said they planned to file a wrongful death lawsuit.

Rahul Mukherjee contributed to this report.
Copyright 2026 NPR

Combatting bacterial and viral infections is getting tougher because of their growing resistance to drugs. Antibiotic drugs can no longer be counted on to conquer nasty bacteria. Antivirals don't always overpower the viruses. This is a huge problem but it is one that widely acknowledged and researched.

There's an additional medical challenge though, that matters a lot. Namely, drug-resistant fungi.

Yep, fungi.

It's a topic that doesn't get discussed much — and that worries Paul Verweij, professor of clinical mycology at Radboud University Medical Center in Nijmegen, the Netherlands. He says there's a "silence surge" in drug-resistant fungi and that it's mostly happening under-the-radar.

This is a particular challenge in lower-income countries.

"Look at, for instance, Candida auris [a type of yeast that can cause severe infections and is often drug-resistant] -- you need very, very strict infection control measures in hospitals, you need good diagnostics, good infection control, you have to follow-up with patients and that's just not available in these lower- middle-income countries," he says. "People will die, and you won't know they have a fungal infection. You wouldn't know if it was resistant."

Verweij teamed up with 50 scientists around the world – from Brazil to Nigeria to China — to call for action against drug‑resistant fungi in Nature Medicine this week.

NPR spoke with Verweij, who's been working on this issue for more than 20 years. His interview has been edited for length and clarity.

What's the link between agriculture and drug-resistant fungi?

Fungicides are used to protect plants against fungal disease. Everything — watermelons, maize, wheat, flowers — use lots of fungicides. If we didn't use the fungicides, you'd probably have a yield loss maybe of 30% or 40%.

The problem is that the fungicides are quite similar to the drugs we give to patients. So the fungus becomes resistant to the fungicide and, at the same time, our medical azoles [a class of antifungal drugs] do not work as well anymore.

The fungi which cause disease in humans are not causing disease in plants. So this is an unintended effect.

How does the resistance get from farms to hospitals? 

So the molds – the hairy fungi – have spores which are released into the air. These spores travel long distances. It's not really well-understood but the idea is that they go right up to these jet streams, very high into the atmosphere and then can travel for continents. We inhale the spores all the time.

How serious are fungal infections?

With fungi you have two types of infections. First, we have very severe infections, and they usually occur in [hospitalized] patients who have some kind of defect in their immunity. So, yeast found in the bloodstream or mold in the lungs. Second, we have infections of the skin, the hair and the nails, which are irritating but are not life threatening.

In the past 10 to 20 years, we see more and more resistance in fungi in both those categories.

There are very few studies looking at the clinical impact. We did a study in the Netherlands, and we found that if you compare an infection [where azole antifungal drugs work] and where it's resistant. There's about a 20% difference in mortality — you're 20% more likely to die. So that's a significant impact. And there's the new skin disease [Trichophyton indotineae] where you don't have mortality but we've had patients who have been on treatment for four years and are still suffering from the infection.

Why is it hard to create new antifungals?

The main challenge is that fungi, if you look at the cell structure — how they are built up — it's very similar to the human cell. This is different from bacteria, because bacteria are much simpler. And viruses are even more simple because they don't even have a cell.

For fungi, because they're similar to human cells, it's quite difficult to find a drug which kills the fungus but does not harm the human cell. So in the past 75 years, we have developed only five classes of antifungals. The azoles are, by far, the most important.

The problem is that if you can't use one of these classes then maybe you'll have one alternative left. It's already causing problems. For instance, if the fungus is in the brain, you have a very few drugs which actually get into the brain.

What can be done?

At a mycology meeting we found a global community who wanted to collaborate [on this issue].

For example, you really want to know what people are using [on crops] and see if you can reduce that or if there's any unnecessary use. Another important factor is: If you introduce new fungicides, they [should] undergo an assessment to see their impact on human fungal pathogens. It's important to establish if there's a risk for cross resistance.

Are you optimistic? 

I've worked in this field for a long time, and I think that it is changing.

WHO published a fungal pathogen list in 2022 for the first time — that had a major impact. A decade ago, when the World Health Organization came out with its global action plan against antimicrobial resistance, fungi were only mentioned twice. Now, after 10 years, it is being revised. And as a mycology community, we feel it is really important now that fungi are addressed.

The problem is, in fungi, we need to do the basic stuff: Develop the tools. Do the surveillance. Set up the [laboratory] networks. And it's sometimes difficult to get these basic things funded.

But overall, I think it's really changing. People are realizing this is not a local problem — it's really global.