“I am Joseph, your brother” (Bereishit 45:4). These are the words spoken by Pope John XXIII to an American delegation of Rabbis in October 1960, just one month after he instructed that a draft outlining the relations between the Church and the Jews be prepared.[i] This draft – later to be known as Nostra Aetate – rejects the traditional accusation that the Jews killed Jesus, and it condemned antisemitism thereby recognizing the legitimacy of Judaism.[ii] These five words, drawn from the common text between Jews and Christians, effectively illustrate the attitude of the Pope towards his relationship with the Jews. The Pope did not want to be a simple friend to the Jews; rather, he thought of himself as one of our brethren. The Second Vatican Council, initiated by Pope John XXIII and continued by Pope Paul VI, started a reformation of the Church’s relations with other religions. Notably, it extended a hand to the Jews in order to mend relations with them by enacting documents such as the Nostra Aetate and by inviting Rabbinic delegations to the Vatican and to churches throughout America for interfaith dialogues. Two Orthodox Rabbinic leaders—Rabbi Moshe Feinstein and Rabbi Joseph B. Soloveitchik—responded to this call of brotherhood by the Pope. These rabbinic authorities had to grapple with the question: Do we, Orthodox Jews, encourage interfaith encounters meant to create pluralistic relationships?
This article will discuss two types of interfaith encounters through the lens of Orthodox Judaism: interfaith dialogue and interfaith cooperation. Before delving into whether or not interfaith dialogue and interfaith cooperation can be encouraged among Orthodox Judaism, we must first define the nature of both relationships and explain what sets them apart.
The difference between the goals of interfaith dialogue and interfaith cooperation is stark. The goal of interfaith dialogue is to create religious unity, which is accomplished by engaging people of diverse beliefs in a conversation about faith, through which thoughts about theology, ritual, and values will be brought to the forefront. Oftentimes, interfaith dialogue is criticized for being too focused on attempting to proselytize members of other faiths,[iii] as well as trying to highlight specific common values for the sake of molding all religions into one standard and essential message.[iv] On the other hand, interfaith cooperation shifts focus from dialogue to common action for the sake of civic concern: building stronger communities and creating social cohesion.[v] Common action builds bridges of cooperation, which requires mutually inspiring relationships between people of different backgrounds, basic knowledge of other traditions and their values, and a positive attitude towards other religions.[vi] This triangle of relationships, knowledge, and attitude contributes to the creation of a pluralistic environment where all members of the community can respect each other’s unique belief system. While interfaith dialogue tries to create religious unity by proselytizing or creating a common thread, interfaith cooperation hopes to stamp out prejudice and negative attitudes towards other faiths by having people of diverse background come together to make the world better for all people of all faiths.
Rabbi Moshe Feinstein and Rabbi Joseph B. Soloveitchik, leading Orthodox Rabbinic leaders whose words continue to impact Judaism to this day, both recorded their opinions in regard to interfaith encounters. Rabbi Moshe Feinstein[vii] argued against interfaith encounters based on the Torah prohibition of inciting others to worship idols. There are three steps necessary for understanding how this prohibition applies to interfaith dialogue: First, an interfaith relations conference run by a member of a different faith is really a means of converting Jews to the other faith. Second, the image that appears in the worldwide news of Christian clergy and Jewish rabbis praying together in a church or a synagogue brings down the barrier of difference between the two religions. Third, and finally, other Jews, who are more susceptible to accepting the values of other faith, will be encouraged by the example of these rabbis to engage members of other faith communities in dialogue; and, the openness of the Jews to discuss religion will give the Christian clergy the opportunity to convert them. Therefore, according to Rabbi Moshe Feinstein, rabbis should avoid setting an example of engaging in interfaith dialogue.
Rabbi Joseph B. Soloveitchik’s article, “Confrontation,” set policy guidelines for the Modern Orthodox community to follow, guidelines the RCA adopted. It is therefore important to note that his guidelines never utilize formal Halakhic terminology to forbid or permit such encounters, rather his guidelines offer historically and philosophically based parameters for such relationships.[viii] Rabbi Soloveitchik believed that “we are summoned by God, who revealed himself at both the level of universal creation and that of the private covenant, to undertake a double mission—the universal human and the exclusive covenantal confrontation.”[ix] From the moment of creation, Adam 1 was charged to be a dignified human being through his mastery of nature and ability to create, while Adam 2 was charged with the knowledge of the cosmos and his relationship to a higher being. The universal confrontation of Adam 1 belongs to all of humankind; however, the covenantal confrontation of Adam 2 belongs only to the Jewish people from the revelation at Sinai to this very day. Rabbi Soloveitchik explains that this covenantal confrontation requires us to interact with the divine separate from other faith communities due to its uniqueness in the very nature and origin of the confrontation.[x]
Therefore, in the event that interfaith dialogue was going to occur, Rabbi Soloveitchik stipulated four conditions to interfaith dialogue in order to “safeguard our individuality and freedom of action.”[xi] First is the issue of our uniqueness; Rabbi Soloveitchik argues, “We are a totally independent faith community. We do not revolve as a satellite in any orbit. Nor are we related to any other faith community as ‘brethren’ even though ‘separated.’”[xii] Rabbi Soloveitchik explains that there is legitimacy to acknowledging the historical relationship between Christianity and Judaism, since the former grew out of the latter. Furthermore, it is also legitimate to claim that there is a cultural relationship between the two communities, since both faith communities have contributed their cultural values to Western society and, thereby, to each other. However, Rabbi Soloveitchik argues against legitimizing the sense of brotherhood for which Pope John XXIII advocates. He feels that acknowledging such a relationship only affirms the belief of the Church that Judaism’s sole purpose was to pave the way for Christianity. As such, it is imperative for Jews partaking in interfaith dialogues to uphold the fact that Judaism is a distinct and unique faith community that exists in and of itself within the realm of religion and theology.
Second, perhaps in response to the nature of interfaith dialogue itself, Rabbi Soloveitchik insists, “the logos, the word, in which the multifarious religious experience is expressed does not lend itself to standardization or universalization.”[xiii] Rabbi Soloveitchik believes that to create a common thread between all religions for the sake of unity is to water-down the intimate relationship each faith community experiences in its relationship to the divine spirit. Certainly in connection with his view of the nature of Judaism’s confrontation with God, it would be absurd for Jews to adopt the language of another faith community to explain to others how they relate to God in a unique manner. The very fact that an outsider to the Jewish faith community may not be able to understand our relationship to God attests to the fact that our faith is a private affair between us and God. This aspect leads us to the third stipulation: Jews engaged in interfaith dialogue will “refrain from suggesting to [Christians]…changes in ritual or emendations of its texts.”[xiv] Just as we hope to be viewed as an independent religion, so too we should respect the rituals, beliefs, and texts of other religions. They should not interfere in our faith, and we will not interfere in theirs.
Finally, Rabbi Soloveitchik stipulates his last condition that “we certainly have not been authorized by our history, sanctified by the martyrdom of millions, to even hint to another faith community that we are mentally ready to revise historical attitudes, to trade favors pertaining to fundamental matters of faith, and to reconcile ‘some’ differences.”[xv] According to Rabbi Soloveitchik, there will never be a time when we can forgive another faith community for the oppression and persecution it enacted against us. While the religious leaders of our time might not be responsible for those crimes, it does not negate the severe impact those historical moments has had on our identity as Jews. Holding onto the memories of those killed by members of another faith community drives a wedge between us and other faith communities necessary for upholding a distinctly unique identity as the Jewish people. Only if all four of these conditions are met are we safe to engage in interfaith relations with other faith communities without fear of proselytization or standardization of beliefs.
Is there room for interfaith encounters within Orthodox Judaism? From the Teshuvah of Rabbi Moshe Feinstein it seems that interfaith dialogue is halakhically prohibited based on the concern that Jews might be seduced by the faith and values of other religions. Though the Teshuvah only discusses interfaith dialogue with the Catholic clergy, it seems clear that the prohibition includes similar dialogue with members of any faith community based on a concern of putting Jews into a situation where they will be influenced by any foreign value. Furthermore, Rabbi Moshe Feinstein does not limit this prohibition solely to interfaith dialogue; rather, any form of encounter with members of other faith communities is similarly prohibited, even if the encounter is centered on social issues and not religion. Interestingly, it could be argued that the prohibition that Rabbi Moshe Feinstein enforces only prohibits the unintended consequence of all interfaith encounters—leading others to convert to, or accept the values of, other religions—while fundamentally there might not be a problem with interfaith encounters if it can be guaranteed that no one will be converted out of Judaism. However, it is clear from the Teshuvah that Rabbi Moshe Feinstein believes that trying to convert Jews to the another religion is an inherent part in interfaith encounters; why else would the Christians engage the Jews in conversation if not to convert them?
In contrast, according to Rabbi Joseph B. Soloveitchik, there are four conditions that must be met in order for interfaith encounters to be considered safe for engagement. These four conditions all work with the underlying necessity that, while interfaith dialogue might smooth the tension between Jews and other communities, there needs to be an understanding that the Jewish faith community is unique based on the nature of our covenantal confrontation with God. Interestingly, it is possible to assert that interfaith cooperation would be more acceptable to Rabbi Soloveitchik than interfaith dialogue. Interfaith cooperation, by its very design, puts less emphasis on the theological ideas and stresses more the need to simply respect the beliefs of other communities. Diversity is key to the pluralistic community that interfaith cooperation serves to create and, therefore, everyone would acknowledge the right for each faith to intimately confront the divine in their own unique manner. Furthermore, the civic cooperation and common action that the diverse members of interfaith cooperation take part in will build a community of trust and decrease prejudice while still being able to acknowledge the historical moments of oppression that some communities have imposed on others.
Despite the difficulty that the Teshuvah of Rabbi Moshe Feinstein poses in the Halakhic discussion, Rabbi Soloveitchik presents an opening for Orthodox Jews to engage in interfaith encounters based on a universal confrontation that every person in the world shares. Whether or not we, students of Yeshiva University where Rabbi Soloveitchik dedicated his life to teaching the future members of Jewish community, choose to partake in interfaith dialogue, interfaith cooperation, or avoid such programs entirely, I think that there is an important message that can be taken away from this conversation by all. Interfaith encounters, to me, express the importance of making the world a better place for all members of the world, a place in which we must all live. While many are not inclined to taking part in that responsibility, we must all feel compelled to making our own community—Orthodox Jewish community—a better place for all of its members. If the Jewish faith community is really a unique confrontation with God that cannot be had in any other faith, then it is our responsibility to help fellow Jews—our brothers—find their place in the Jewish community in order to take part in the special, day-by-day relationship with God that we may take for granted. We should all feel compelled to take on the mission of approaching fellow Jews and saying, “I am Joseph, your brother.”
Daniel Abboudi is a staff writer for Kol Hamevaser. His interest in the relationship between interfaith encounters and Judaism was sparked by the sociology of religion courses he has participated in during his studies in Yeshiva College.
[i] Romano, L’Osservatore. http://www.ccjr.us/dialogika-resources/documents-and-statements/roman-catholic/second-vatican-council/naprecursors/1259-j231960oct19. Council of Centers on Jewish-Christian Relations, Web. 9 Dec. 2014.
[ii] http://www.britannica.com/EBchecked/topic/507284/Roman-Catholicism/43709/The-church-since-Vatican-II. Encyclopædia Britannica Inc., 27 Jan. 2014. Web. 9 Dec. 2014
[iii] Aamir Hussain. http://berkleycenter.georgetown.edu/posts/the-challenges-of-interfaith-dialogue. Berkeley Center for Religion, Peace & World Affairs, 10 Jan. 2014. Web. 1 Dec. 2014.
[iv] Kunin, David A. “Multifaith: New Directions.” Journal of Ecumenical Studies. 47.1 (2012): 101-112. Web.
[v] Patel, Eboo and Cassie Meyer. “The Civic Relevance of Interfaith Cooperation for Colleges and Universities.” Journal of College and Character. 12.1 (2011): 1-9. Web.
[vi] Patel, Eboo. Sacred Ground: Pluralism, Prejudice, and the Promise of America. Boston: Beacon Press, 2012. Print.
[vii] Igrot Moshe, Yoreh Deah 3:43
[viii] Korn, Eugene. “The Man of Faith and Religious Dialogue: Revisiting ‘Confrontation’.” Modern Judaism. 25.3 (2005): 290-315.
[ix] Soloveitchik, Joseph B. “Confrontation.” Tradition: A Journal of Orthodox Thought. 6.2 (1964). Web.
[x] Ibid.
[xi] Ibid.
[xii] Ibid.
[xiii] Ibid.
[xiv] Ibid.
[xv] Ibid.
Orthodox Perspectives on Interfaith Dialogue
“I am Joseph, your brother” (Bereishit 45:4). These are the words spoken by Pope John XXIII to an American delegation of Rabbis in October 1960, just one month after he instructed that a draft outlining the relations between the Church and the Jews be prepared.[i] This draft – later to be known as Nostra Aetate – rejects the traditional accusation that the Jews killed Jesus, and it condemned antisemitism thereby recognizing the legitimacy of Judaism.[ii] These five words, drawn from the common text between Jews and Christians, effectively illustrate the attitude of the Pope towards his relationship with the Jews. The Pope did not want to be a simple friend to the Jews; rather, he thought of himself as one of our brethren. The Second Vatican Council, initiated by Pope John XXIII and continued by Pope Paul VI, started a reformation of the Church’s relations with other religions. Notably, it extended a hand to the Jews in order to mend relations with them by enacting documents such as the Nostra Aetate and by inviting Rabbinic delegations to the Vatican and to churches throughout America for interfaith dialogues. Two Orthodox Rabbinic leaders—Rabbi Moshe Feinstein and Rabbi Joseph B. Soloveitchik—responded to this call of brotherhood by the Pope. These rabbinic authorities had to grapple with the question: Do we, Orthodox Jews, encourage interfaith encounters meant to create pluralistic relationships?
This article will discuss two types of interfaith encounters through the lens of Orthodox Judaism: interfaith dialogue and interfaith cooperation. Before delving into whether or not interfaith dialogue and interfaith cooperation can be encouraged among Orthodox Judaism, we must first define the nature of both relationships and explain what sets them apart.
The difference between the goals of interfaith dialogue and interfaith cooperation is stark. The goal of interfaith dialogue is to create religious unity, which is accomplished by engaging people of diverse beliefs in a conversation about faith, through which thoughts about theology, ritual, and values will be brought to the forefront. Oftentimes, interfaith dialogue is criticized for being too focused on attempting to proselytize members of other faiths,[iii] as well as trying to highlight specific common values for the sake of molding all religions into one standard and essential message.[iv] On the other hand, interfaith cooperation shifts focus from dialogue to common action for the sake of civic concern: building stronger communities and creating social cohesion.[v] Common action builds bridges of cooperation, which requires mutually inspiring relationships between people of different backgrounds, basic knowledge of other traditions and their values, and a positive attitude towards other religions.[vi] This triangle of relationships, knowledge, and attitude contributes to the creation of a pluralistic environment where all members of the community can respect each other’s unique belief system. While interfaith dialogue tries to create religious unity by proselytizing or creating a common thread, interfaith cooperation hopes to stamp out prejudice and negative attitudes towards other faiths by having people of diverse background come together to make the world better for all people of all faiths.
Rabbi Moshe Feinstein and Rabbi Joseph B. Soloveitchik, leading Orthodox Rabbinic leaders whose words continue to impact Judaism to this day, both recorded their opinions in regard to interfaith encounters. Rabbi Moshe Feinstein[vii] argued against interfaith encounters based on the Torah prohibition of inciting others to worship idols. There are three steps necessary for understanding how this prohibition applies to interfaith dialogue: First, an interfaith relations conference run by a member of a different faith is really a means of converting Jews to the other faith. Second, the image that appears in the worldwide news of Christian clergy and Jewish rabbis praying together in a church or a synagogue brings down the barrier of difference between the two religions. Third, and finally, other Jews, who are more susceptible to accepting the values of other faith, will be encouraged by the example of these rabbis to engage members of other faith communities in dialogue; and, the openness of the Jews to discuss religion will give the Christian clergy the opportunity to convert them. Therefore, according to Rabbi Moshe Feinstein, rabbis should avoid setting an example of engaging in interfaith dialogue.
Rabbi Joseph B. Soloveitchik’s article, “Confrontation,” set policy guidelines for the Modern Orthodox community to follow, guidelines the RCA adopted. It is therefore important to note that his guidelines never utilize formal Halakhic terminology to forbid or permit such encounters, rather his guidelines offer historically and philosophically based parameters for such relationships.[viii] Rabbi Soloveitchik believed that “we are summoned by God, who revealed himself at both the level of universal creation and that of the private covenant, to undertake a double mission—the universal human and the exclusive covenantal confrontation.”[ix] From the moment of creation, Adam 1 was charged to be a dignified human being through his mastery of nature and ability to create, while Adam 2 was charged with the knowledge of the cosmos and his relationship to a higher being. The universal confrontation of Adam 1 belongs to all of humankind; however, the covenantal confrontation of Adam 2 belongs only to the Jewish people from the revelation at Sinai to this very day. Rabbi Soloveitchik explains that this covenantal confrontation requires us to interact with the divine separate from other faith communities due to its uniqueness in the very nature and origin of the confrontation.[x]
Therefore, in the event that interfaith dialogue was going to occur, Rabbi Soloveitchik stipulated four conditions to interfaith dialogue in order to “safeguard our individuality and freedom of action.”[xi] First is the issue of our uniqueness; Rabbi Soloveitchik argues, “We are a totally independent faith community. We do not revolve as a satellite in any orbit. Nor are we related to any other faith community as ‘brethren’ even though ‘separated.’”[xii] Rabbi Soloveitchik explains that there is legitimacy to acknowledging the historical relationship between Christianity and Judaism, since the former grew out of the latter. Furthermore, it is also legitimate to claim that there is a cultural relationship between the two communities, since both faith communities have contributed their cultural values to Western society and, thereby, to each other. However, Rabbi Soloveitchik argues against legitimizing the sense of brotherhood for which Pope John XXIII advocates. He feels that acknowledging such a relationship only affirms the belief of the Church that Judaism’s sole purpose was to pave the way for Christianity. As such, it is imperative for Jews partaking in interfaith dialogues to uphold the fact that Judaism is a distinct and unique faith community that exists in and of itself within the realm of religion and theology.
Second, perhaps in response to the nature of interfaith dialogue itself, Rabbi Soloveitchik insists, “the logos, the word, in which the multifarious religious experience is expressed does not lend itself to standardization or universalization.”[xiii] Rabbi Soloveitchik believes that to create a common thread between all religions for the sake of unity is to water-down the intimate relationship each faith community experiences in its relationship to the divine spirit. Certainly in connection with his view of the nature of Judaism’s confrontation with God, it would be absurd for Jews to adopt the language of another faith community to explain to others how they relate to God in a unique manner. The very fact that an outsider to the Jewish faith community may not be able to understand our relationship to God attests to the fact that our faith is a private affair between us and God. This aspect leads us to the third stipulation: Jews engaged in interfaith dialogue will “refrain from suggesting to [Christians]…changes in ritual or emendations of its texts.”[xiv] Just as we hope to be viewed as an independent religion, so too we should respect the rituals, beliefs, and texts of other religions. They should not interfere in our faith, and we will not interfere in theirs.
Finally, Rabbi Soloveitchik stipulates his last condition that “we certainly have not been authorized by our history, sanctified by the martyrdom of millions, to even hint to another faith community that we are mentally ready to revise historical attitudes, to trade favors pertaining to fundamental matters of faith, and to reconcile ‘some’ differences.”[xv] According to Rabbi Soloveitchik, there will never be a time when we can forgive another faith community for the oppression and persecution it enacted against us. While the religious leaders of our time might not be responsible for those crimes, it does not negate the severe impact those historical moments has had on our identity as Jews. Holding onto the memories of those killed by members of another faith community drives a wedge between us and other faith communities necessary for upholding a distinctly unique identity as the Jewish people. Only if all four of these conditions are met are we safe to engage in interfaith relations with other faith communities without fear of proselytization or standardization of beliefs.
Is there room for interfaith encounters within Orthodox Judaism? From the Teshuvah of Rabbi Moshe Feinstein it seems that interfaith dialogue is halakhically prohibited based on the concern that Jews might be seduced by the faith and values of other religions. Though the Teshuvah only discusses interfaith dialogue with the Catholic clergy, it seems clear that the prohibition includes similar dialogue with members of any faith community based on a concern of putting Jews into a situation where they will be influenced by any foreign value. Furthermore, Rabbi Moshe Feinstein does not limit this prohibition solely to interfaith dialogue; rather, any form of encounter with members of other faith communities is similarly prohibited, even if the encounter is centered on social issues and not religion. Interestingly, it could be argued that the prohibition that Rabbi Moshe Feinstein enforces only prohibits the unintended consequence of all interfaith encounters—leading others to convert to, or accept the values of, other religions—while fundamentally there might not be a problem with interfaith encounters if it can be guaranteed that no one will be converted out of Judaism. However, it is clear from the Teshuvah that Rabbi Moshe Feinstein believes that trying to convert Jews to the another religion is an inherent part in interfaith encounters; why else would the Christians engage the Jews in conversation if not to convert them?
In contrast, according to Rabbi Joseph B. Soloveitchik, there are four conditions that must be met in order for interfaith encounters to be considered safe for engagement. These four conditions all work with the underlying necessity that, while interfaith dialogue might smooth the tension between Jews and other communities, there needs to be an understanding that the Jewish faith community is unique based on the nature of our covenantal confrontation with God. Interestingly, it is possible to assert that interfaith cooperation would be more acceptable to Rabbi Soloveitchik than interfaith dialogue. Interfaith cooperation, by its very design, puts less emphasis on the theological ideas and stresses more the need to simply respect the beliefs of other communities. Diversity is key to the pluralistic community that interfaith cooperation serves to create and, therefore, everyone would acknowledge the right for each faith to intimately confront the divine in their own unique manner. Furthermore, the civic cooperation and common action that the diverse members of interfaith cooperation take part in will build a community of trust and decrease prejudice while still being able to acknowledge the historical moments of oppression that some communities have imposed on others.
Despite the difficulty that the Teshuvah of Rabbi Moshe Feinstein poses in the Halakhic discussion, Rabbi Soloveitchik presents an opening for Orthodox Jews to engage in interfaith encounters based on a universal confrontation that every person in the world shares. Whether or not we, students of Yeshiva University where Rabbi Soloveitchik dedicated his life to teaching the future members of Jewish community, choose to partake in interfaith dialogue, interfaith cooperation, or avoid such programs entirely, I think that there is an important message that can be taken away from this conversation by all. Interfaith encounters, to me, express the importance of making the world a better place for all members of the world, a place in which we must all live. While many are not inclined to taking part in that responsibility, we must all feel compelled to making our own community—Orthodox Jewish community—a better place for all of its members. If the Jewish faith community is really a unique confrontation with God that cannot be had in any other faith, then it is our responsibility to help fellow Jews—our brothers—find their place in the Jewish community in order to take part in the special, day-by-day relationship with God that we may take for granted. We should all feel compelled to take on the mission of approaching fellow Jews and saying, “I am Joseph, your brother.”
Daniel Abboudi is a staff writer for Kol Hamevaser. His interest in the relationship between interfaith encounters and Judaism was sparked by the sociology of religion courses he has participated in during his studies in Yeshiva College.
[i] Romano, L’Osservatore. http://www.ccjr.us/dialogika-resources/documents-and-statements/roman-catholic/second-vatican-council/naprecursors/1259-j231960oct19. Council of Centers on Jewish-Christian Relations, Web. 9 Dec. 2014.
[ii] http://www.britannica.com/EBchecked/topic/507284/Roman-Catholicism/43709/The-church-since-Vatican-II. Encyclopædia Britannica Inc., 27 Jan. 2014. Web. 9 Dec. 2014
[iii] Aamir Hussain. http://berkleycenter.georgetown.edu/posts/the-challenges-of-interfaith-dialogue. Berkeley Center for Religion, Peace & World Affairs, 10 Jan. 2014. Web. 1 Dec. 2014.
[iv] Kunin, David A. “Multifaith: New Directions.” Journal of Ecumenical Studies. 47.1 (2012): 101-112. Web.
[v] Patel, Eboo and Cassie Meyer. “The Civic Relevance of Interfaith Cooperation for Colleges and Universities.” Journal of College and Character. 12.1 (2011): 1-9. Web.
[vi] Patel, Eboo. Sacred Ground: Pluralism, Prejudice, and the Promise of America. Boston: Beacon Press, 2012. Print.
[vii] Igrot Moshe, Yoreh Deah 3:43
[viii] Korn, Eugene. “The Man of Faith and Religious Dialogue: Revisiting ‘Confrontation’.” Modern Judaism. 25.3 (2005): 290-315.
[ix] Soloveitchik, Joseph B. “Confrontation.” Tradition: A Journal of Orthodox Thought. 6.2 (1964). Web.
[x] Ibid.
[xi] Ibid.
[xii] Ibid.
[xiii] Ibid.
[xiv] Ibid.
[xv] Ibid.