JAMES ROBERT DEAL ATTORNEY PLLC
January 2, 2018
Revised January 9, 2018
To read the latest version of this letter and follow links, go to:
Snohomish County PUD
Attention: Commissioners Kathleen Vaughn, Sidney Logan, Tanya Olson
2320 California Street
Everett WA 98201
Sent by email only to: email@example.com
Copy sent to
John Gregory, Distribution Services manager
Sent by email only to: firstname.lastname@example.org
Copy sent to
Mike Kreidler, Insurance Commissioner
5000 Capitol Blvd SE Tumwater WA 98501
PO Box 40257 Olympia WA 98504-0257
Sent by email only to: email@example.com
Dear PUD Commissioners,
A&R Solar has just completed installation of solar panels on my roof here at my residence in Lynnwood along with supporting electrical equipment. The city of Lynnwood has inspected the installation and given its approval. The next step is for the system to be connected to the grid for net-metering.
John Gregory in your office has informed me that Snohomish County PUD intends to install a new GE digital non-communicating electronic meter on our home to measure power produced by the solar panels.
Mr. Gregory has also notified me that PUD intends to remove my existing electromechanical analog meter and replace it with another GE digital non-communicating electronic meter. So according to Snohomish County PUD I will have two new GE digital electronic meters.
I should clarify that these new meters are not the same as the so-called broadcasting advanced meters, also known as AMI meters or more generally as smart meters. With broadcasting advanced meters, the broadcasting function can be turned off, although it can be turned back on from a remote location. The GE digital meter completely lacks the ability to broadcast.
The GE digital meter and the advanced meters together are called electronic meters, and they all suffer from defects which I will outline herein.
The additional defects of the broadcasting electronic meters include the fact that they flood homes and neighborhoods with additional radiation and that the broadcasting function creates gaping holes in security inherent in their design.
Both kinds of electronic meters are inferior to the reliable, all-metal, accurate, safe analog meter currently affixed to my home, and I refuse to accept any electronic meters.
I will list the many ways that GE digital meters are defective and are not meters in the sense that current analog meters are meters. All these defects are true of the electronic broadcasting advanced meters.
1. PUD bills us for the kilowatt hours of electricity we consume, but the GE digital meters do not measure kilowatt hours. They measure voltage and amperage peaks and use an unknown algorithm to make an estimated conversion of the peaks into watt hours. These calculations can be wrong, especially when the customer has various machines which turn on and off frequently and make big voltage draws when motors turn on. This can result in artificially high watt hour reports and higher billings. Electronic meters perform differently in hotter, colder, dryer, and wetter conditions.
On the other hand, analog meters measure watt hour consumption very accurately, regardless of high current draws or changing weather conditions.
2. I asked Mr. Gregory for information regarding these GE meters. He sent me the following:
None of the meters the District owns provide grounding or surge protect[tion] for the customers equipment.
Mr. Gregory confirms what I already knew about the GE digital meters. They are not grounded.
3. A meter which is not grounded is more prone allow voltage surges to enter the building and damage electrical equipment. Current analog meters, because they are well connected to ground and have reasonably good surge protection build in protect electrical equipment to a much greater extent than electronic meters.
Some surge protectors absorb voltage spikes, while others are connected to ground and pass surges to ground. The analog meter is valuable because it provides that path to ground that common power strips and three-pronged plugged equipment can access.
Circuit breakers, power strips, and three-pronged plugged appliances all need a path to ground, which the grounded analog meter provides. Circuit breakers are designed to limit total amperage, while surge protectors are designed to protect against excess voltage.
Mr. Gregory says that the GE digital meter does not include surge protection. Actually, this statement is incorrect. In fact, the GE digital meter does include a lame attempt at surge protection, a varistor, also known as a metal oxide varistor or VOM. Varistors were added to electronic meters to remedy the fact that they lack a path to ground, and to cut down on the fires which electronic meters were causing.
The varistor is an absorption surge protector. It does not pass current to ground. It provides protection only up to 300 volts AC. Many smaller surges will occur, and the surges have a cumulative effect on the varistor. Small surges happen frequently due to substation switching and other utility operations.
Manufacturers of the varistors typically used in digital meters advise that they can survive only a certain number of small surges before they break down. A customer would never know when the varistor in his or her electronic meter would break down.
A surge can occur, for example, when there is a lightning strike. If a meter lacks a path to ground, high voltage surges can enter the home and damage or destroy wiring and appliances – and my solar panels. For an electrical system to survive a direct lightning strike or one within around 100 feet, a lightning rod and expensive, specialized surge protection is required. For lightning strikes which strike the ground further away, an analog meter with its spark-gap protection will survive lightning strikes which the electronic meter will not.
Lightning is not as common in the Northwest as it is in Florida, but it does happen, and we should not be left unprotected from lightning if an analog meter will provide protection.
Line surges are common. They occur when a pole or tree branch falls on two lines and they cross each other. When lines cross, they can send more than the rated voltage to the transformer that feeds the building circuit.
The line voltage at the poles can be from 7,200 to 36,000 volts, depending on the substation and the utility. The most common is 7,200 volts. The transformer on the pole is a simple conversion device. There may be a ratio of 50 turns on the high voltage side to one turn on the stepped down side. If the input is doubled, the output is doubled. So, voltage will double from a normal 240 volts to 480 volts or more in an instant.
When the varistor in an electronic meter, which is rated for 300 volts, meets 480 volts, it cannot handle it. So, the substrate separates from the circuit board and explodes. When this happens, it creates a bridge of 240 or more volts across the remaining circuit board, because these boards are only rated for 12 volts DC. The circuit melts and catches fire and the surge passes into the home and into all electrical equipment.
A circuit board does not belong inside an electric meter. It is too fragile.
Surges also occur when power has gone down and comes back up. There is a system-wide draw by many motors starting up all at once. This drops system voltage. The system might over-react and increases voltage too much, creating a system wide surge. Electronic meters explode and catch fire.
In my case such a surge would go right to my appliances, my copy machine, my computers, and to my new inverters, and then all the way to my solar panels. All would be damaged. Snohomish County PUD will have been negligent in insisting on the placement of a defective, non-grounded device on my home.
When a digital meter blows, there is a loud bang and popping noises, followed by flickering lights and then a fire. There is a massive amount of current that that comes into the circuit, up to 2,000 amps.
Utility people sometimes say that the main breaker on the home protects the meter, but this is false. A circuit breaker is a one-way device. It only protects the downstream circuit. The main breaker does not protect the meter at all. Yes, there is a main circuit breaker, but it takes a full 50 seconds to trip at 2,000 amps. The circuit breaker typically does not see the full 2,000 amps, and so it typically never trips.
4. The analog meter is all metal with a rugged Bakelite back plate. It does not catch fire. Because GE digital meters and are not grounded and because their varistor surge protector is good only to 300 volts, they are more likely to catch fire and in turn catch a building on fire. Google for “smart meter fires”.
5. The GE digital meter and electronic meters in general are defective in design. The National Electrical Code requires a properly sized circuit breaker in front of all electronic devices. In prior times, when all meters were analog meters, utility companies obtained an exemption from having analog meters comply with NEC Code 240.4. This waiver was acceptable because of the surge and ground protection inherent in the design of analog meters. However, digital meters do not comply with NEC Code 240.4, and manufacturers of digital meters never applied for nor received a waiver.
Electronic meters lack basic safety features that are required for other electronic devices. They contain fragile computerized electronic circuit boards that are prone to igniting and exploding when exposed to utility-side electrical surge events.
Electronic meters are not meters in the sense that analog meters are meters. They are computers. As such, they are subject to NFPA 70: National Electrical Code (NEC), Article 240 – Overcurrent Protection – 240.4 Protection of Conductors). For an electronic meter to comply with NEC, a properly sized electric circuit 200-amp breaker would have to be placed between the incoming service wire and the electronic meter. None of these electronic devices were deployed with these conditions met. The utilities ignored this and just swapped one device for another in total disregard to the enormous risks to consumers.
Had the utilities complied with NEC requirements and put a grounded breaker in front of electric meters, the numerous fires, explosions, melting of devices, extensive property damage and in some cases deaths could have been avoided. The worst that could have happened would have been a popped circuit breaker. Of course, adding a circuit breaker to the installation would have increased the cost of building these electronic meters by around $200, and would have changed the profit maximization calculation.
Washington law requires compliance with the National Electrical Code. See WAC 296-46B-010 which incorporates the entire NEC by reference. Because digital meters do not comply with the National Electrical Code, they are illegal. Failure to comply with statutory law is per se negligence on the part of Snohomish County PUD. This means that no proof of negligence is required.
Just because the federal Department of Energy is encouraging and even subsidizing the installation of electronic meters does not make them legal. There are many laws which are routinely ignored.
6. GE digital meters include a switched mode power supply to regulate voltage. The SMPS turns power on and off 20,000 times per second to cut off voltage peaks. The SMPS produces dirty electricity, also known as DE for short, technically known as “High Frequency Voltage Transients”, also known as HFVT or “Conducted Emissions” or CE. Dirty electricity is the rapid, erratic and violent change in voltage that happens thousands of times per second instead of the normal 60 cycles per second electricity we are used to here in the USA.
Thus, electronic meters introduce conductive emissions in excess of required FCC Class B specifications and are not compatible with consumers’ existing electrical systems and appliances. This leads to early appliance failures.
These electrical transients propagate through the electrical system of a building, turning it into an antenna which broadcasts unwanted electromagnetic radiation and dirty electricity upon occupants. Current analog meters do not do this.
7. There is mounting evidence that such electromagnetic radiation causes cancer. The World Health Organization ruled in 2011 the electromagnetic radiation is a class 2B possible carcinogen. Other authorities such as the National Institutes of Health National Toxicology Program in 2016 showed a strong correlation, meaning that the causal connection is probable instead of possible.
The NIH points out that the connection is dose related. The harms caused by electromagnetic radiation are cumulative over time. Researchers refer to the harms from electromagnetic radiation as being dose-response dependent or exposure dependent. As the dose goes up, the harm goes up in a linear manner. As our total lifetime dose of electromagnetic radiation increases, the incidence of cancer increases at a parallel rate. It is hard to prove cancer causation in humans because you cannot put them in cages and expose them to X hours of microwave radiation per day. However, the case is approaching the conclusive. To ignore this possible or probable or proven link is reckless.
8. Because the GE digital meters subject us to an increased risk of fire and to an increased risk of surges and conductive emissions, insurance companies will either exclude coverage for harms caused by electronic meters or charge more for an endorsement to cover the risk. My insurance company wants to increase my insurance rates if it is to cover electrical surges.
You can criticize insurance companies for their conservative approach, but that conservative approach communicates accurately how much risk is present. For example, insurance companies do not insure nuclear power plants or floods. Those markets are too risky and are left to the federal government. I am hoping that the insurance companies will force the discontinuance of ungrounded electronic meters.
For this reason, I am sending a copy of this letter to the Insurance Commissioner, Michael Kreidler.
9. The GE digital meter is an electrical device. It consumes electricity constantly in order to operate. The amount used is not known, but it is not zero. There are estimates that the extra electrical consumption costs homeowners around $10 per month. In this way GE meters will raise my electrical bill unnecessarily. They will increase system-wide consumption of electricity, which is contrary to our goal of consuming less power in order to reduce carbon emissions.
10. The reliable, fireproof, completely accurate analog meter is being phased out in favor of unreliable, fire prone, inaccurate electronic meters. Apparently, new analog meters are not being built in the United States. Reconditioned standard analog meters of the type now on my house, which are as good as new, are readily available for $50 or less. New analog meters are available for the same general price, however, like so much other equipment, they are made in China and are not recommended.
GE digital meters may cost much more according to my current information. If such meters are installed throughout the PUD service area, and if they in fact do cost more, general PUD costs will be increased, and this will increase the electric bills for all consumers.
11. While analog meters of the type now on my house last 40 years and more, electronic meters such as the GE digital meters have a much shorter life expectancy. It is the display which tends to fail first. The cost of replacing meters more frequently will raise general PUD costs and in turn increase the electric bills of all of us.
To summarize, compare our trusted analog meters. They provide the path to ground that electrical equipment can take advantage of. They contain spark-gap surge protection. They do not catch fire. They do not turn the entire home electrical system into an antenna and thus do not expose occupants to unwanted electromagnetic radiation. They consume only a minute amount of electricity to turn the wheels as they very accurately measure watt hours used. They cost less than electronic meters and last longer than digital meters and thus keep costs down.
To summarize, electronic meters lack a path to ground. They contain an inferior surge protection in the form of a varistor, which is protective only up to 300 volts. They catch fire. Due to their switched mode power supply they emit dirty electricity and turn the entire home electrical system into an antenna and thus expose occupants to unwanted electromagnetic radiation. They consume more electricity to operate their computers and the display. They do not measure watt hours used but estimate them based on average voltage and amperage. They cost more. They have a shorter life expectancy.
Thus, in eleven ways, the GE digital meters which Mr. Gregory wants to install on my home are inferior.
Newer is not always better, and this is especially true in the case of electronic meters. The fact that electronic meters are so thoroughly inferior indicates that vendors have failed to fully inform Snohomish County PUD and misled the PUD into buying them. The PUD should make inquiry into the representations made by the vendor of these meters and consider bringing a Consumer Protection suit against that vendor.
When my Lynnwood home was built in 2006, the builder gave an easement to Snohomish County PUD for installation of an electric meter and for access to it for reading the meter and maintaining it. This following easement language appears on the face of the plat:
An easement is hereby reserved for and granted to all utilities serving the subject plat and their respective successors and assigns, under and upon the exterior 10 feet parallel with and adjoining the street frontage of all lots, tracts and common areas in which to install, lay, construct, renew, operate and maintain underground conduits, cables, pipe and wires with necessary facilities and other equipment for the purpose of serving this subdivision and other property with electric, gas, water, telephone, television cable and other utility services together with the right to enter upon the lots, tracts and common areas at all times for the purposes herein stated.
No additional “purposes” are listed “herein”, that is in that document. The wording is standard and customary. At the time the easement was given a standard, trusted, safe, and accurate analog meter was installed.
According to the Washington courts, easements have limits. The general rule regarding limitations on the extent of an easement is as follows:
A servient owner is entitled to impose reasonable restraints on a right of way to avoid a greater burden on the servient owner’s estate than that originally contemplated in the easement grant, so long as such restraints do not unreasonably interfere with the dominant owner’s use. (Green v. Lupo, 32 Wn. App. 318, 647 P.2d 51 (1982).
We believe the servient owner is entitled to impose reasonable restraints on the right-of-way to avoid a greater burden on the servient owner’s estate than that originally contemplated in the easement grant, so long as such restraints do not unreasonably interfere with the dominant owner’s use”…. Rupert v. Gunter, 31 Wn. App. 27, 640 P.2d 36 (1982)”.
The GE electronic digital meters which Mr. Gregory proposes to install would therefore, for the eleven reasons listed above, impose “a greater burden on the servient other’s estate than that originally contemplated in the easement grant”.
The original grant of utility easement contemplated the installation of a high quality, accurate, safe electric meter, one not prone to surges, one which would not emit dirty electricity. It did not contemplate the installation of an inferior, ungrounded, inadequately surge protected, dirty electricity producing meter, one which would expose us to greater electromagnet radiation and fail to provide the same protection against home fires and against damage and destruction to home wiring and appliances. The installation of such inferior meters would exceed the scope of the utility easement which the builder of my home granted to Snohomish County PUD.
The PUD is a governmental entity and as such is subject to the restrictions of the US Constitution. The 14th Amendment prohibits the “deprivation of … liberty or property without due process of law”. It prohibits the denial “to any person” of “the equal protection of the laws”. The 5th Amendment prohibits a taking of “private property” “for public use without just compensation”. There is no compensation which the PUD could give us which would justly compensate us for accepting the additional risks posed by electronic meters.
If Snohomish County PUD were to install GE digital meters on my home, it would be violating the scope of the easement it holds. Thus, I do not need to apply to opt out of having a GE digital meter. Snohomish County PUD needs to obtain a new easement from me which would authorize the eleven additional intrusions upon my property listed above.
If Snohomish County PUD were to install GE digital meters on my home, it would be committing a trespass not authorized by its easement unless it were to obtain a broader easement authorizing the eleven intrusions listed above,
If Snohomish County PUD were to install GE digital meters on my home, without obtaining a broader easement authorizing the eleven intrusions listed above, it would be committing a taking of my property without just compensation.
If Snohomish County PUD were to install GE digital meters on my home, without obtaining a broader easement authorizing the eleven intrusions listed above, it would be violating my liberty right to be free of unwanted electromagnetic radiation.
Nor may Snohomish County PUD threaten to cut off my electrical service if I refuse to submit to the unsafe and inferior GE digital meters. The PUD has a duty to make electricity to all and may not deny service solely because a customer objects to the placement on his home of an unsafe, inferior, and illegal meter. For Snohomish County PUD to make such a threat would be an attempt to deny me the equal protection of the laws.
Mr. Gregory says that these GE digital meters are ANSI approved, as if this were some kind of proof of their safety and accuracy. To the contrary, ANSI does not certify safety or accuracy. ANSI is a trade association governed by officials appointed by companies which build electronic devices such as GE digital meters. ANSI certification only certifies that an item has been built according to the specifications produced by the manufacturer. It only certifies that the item passes the tests which the manufacturer creates. ANSI approvals are not the equivalent of federal agency approvals.
Mr. Gregory says that these GE digital meters are more accurate, but that is not true. They can be accurate when metering 120 amps but not when metering 240 amps. Analog meters strictly measure watt hours used, while the digital meters measure an average of voltage and amperage peaks and use an algorithm to make an estimated conversion into watt hours. An analog meter is a totalizing meter, whereas a digital meter is not.
Snohomish County PUD should look down the road and consider its potential liability for harms which may be caused by these GE digital meters.
Therefore, you may not install GE digital meter on our home. If you violate my instruction, I will file suit.
I demand that you leave my current analog meter in place to measure total consumption. I demand that you install another analog meter to measure power produced by the solar panels. I will buy an analog meter and make it available to your installer.
If you are unwilling to comply with this demand, you are to do nothing, meaning that you should leave my current meter in place and install no meter for measuring production from my solar panels, and you should make no changes in my current meter setup until we have resolved this issue by mediation or lawsuit.
My current meter and the base where a new meter is to be installed are on the exterior of my home. I am expressly demanding that PUD not sneak up to my home against my instructions and attach GE digital meters to my home, as utility providers in other areas have done. Such behavior would be unprofessional and would set off an immediate lawsuit.
I am the president of the Coalition Against So-Called Advanced Meters, a Washington non-profit corporation, which is dedicated to informing the public regarding the dangers of electronic meters and financing litigation to halt their installation.
Therefore, on behalf of the Coalition Against So-Called Advanced Meters, I demand that Snohomish County PUD completely terminate its installation of GE digital meters throughout its service area and that it offer to replace GE digital meters with analog meters.
I also demand that that Snohomish County PUD terminate its plans to install so-called advanced meters, also known as “smart meters” or “AMI meters”. All the negative points made against GE digital meters apply to so-called advanced meters. In addition, said advanced meters collect data which details the personal and private behavior of customers and create a broadcasting mesh network which bathes homes, buildings, and entire cities in a fog of constant electromagnetic radiation.
Seattle is currently installing so-called advanced meters, and in Seattle there are no legal restrictions on the sale of information collected to third party marketing companies. So-called advanced meters run on a mesh network which pulses out microwaves every few seconds, turning the electrical system in homes into broadcasting antennas, and bathing homes, schools, businesses, and the people in them with constant radiation.
Each so-called advanced meter is equipped with a socket into which a meter person can insert an optical probe, which will make available complete access to the specific meter and to the entire mesh network, bypassing encryption, and anyone who obtains such a probe can hack into homes and the entire network. There are more negative aspects of these so-called advanced meters, and I will supply this information later.
I am attaching Request for Production of Documents Pursuant to RCW 42.56. If Snohomish County PUD does not already have research reports or other items responsive to the attached requests, this is proof that Snohomish County PUD, in deciding to purchase and install GE digital meters, did so without doing its due diligence. This would be proof of its negligence.
Likewise, if Snohomish County PUD fails to develop research reports on all of the items contained in the attached Request for Production of Documents, this will be proof of its reckless disregard for public health and safety.
I reserve the right to revise this letter as more issues become apparent.
While I may update the content of this letter, I will not modify the attached Requests for Production of Documents. I reserve the right to submit additional requests.
In order to read the latest version of this letter, which will be upgraded as more relevant facts are obtained, and in order to be able to follow links, the reader should surf the web to www.JamesRobertDeal.org/avoid-GE-digital-electronic-meter.
James Robert Deal, Attorney
WSBA Number 8103
Request for Production of Documents Pursuant to RCW 42.56
When I ask for “items”, I am asking for any correspondence, letters, research, studies reports, writings, emails, recordings, memos, notes, or documents of any kind, whether in printed or electronic form, and whether in your possession or under your control.
When I refer to “you” I am referring to all executive and staff of the Snohomish County PUD.
When I refer to “GE digital meter”, I am referring to the meters which Snohomish County PUD proposes to attach to our home.
When I refer to “agents” or “your agents”, I am referring to all agents of Snohomish County PUD, including those vendors, resellers, contractors, sub-contractors, and installers of the meters referred to herein, from which you have the contractual right to obtain documents. I am referring to any sub-contractors which install said GE digital meters.
1. Please send me all items which describe or in any way relate to the GE digital meters which Snohomish County PUD proposes to install on my home, including their cost.
2. Please send me all items which describe the current analog meters now on my home, including their cost.
3. Please send me all items which the vendor of said GE digital meters gave to Snohomish County PUD when that vendor was marketing said meters to the PUD or which were pointed out or made available to the PUD on the vendor’s web site.
4. Please send me all items which discuss the how the GE digital meters measure kilowatt hours, including whether they measure an average of voltage peaks and amperage and use an algorithm to make an estimated conversion of voltage peaks into watt hours.
5. Please send me all items which discuss the algorithm which GE digital meters use to make an estimated conversion of voltage peaks into watt hours.
6. Please send me all items which discuss the fact that calculations converting voltage peaks can be wrong especially when the customer has various machines which turn on and off frequently.
7. Please send me all items which discuss whether or not analog meters are or are not grounded and whether or not they have surge protection.
8. Please send me all items which discuss whether GE digital meters are or are not grounded and whether they have surge protection.
9. Please send me all items which discuss whether GE digital meters are or are not more prone to catch fire than analog meters.
10. Please send me all items which discuss whether a surge, such as one resulting from lightning strike or when a pole or tree branch falls on the lines and they cross one another, and whether this can result in GE digital meters propagating high voltage surges through the building, damaging or destroying wiring and appliances.
11. Please send me all items which discuss the varistor built into GE digital meters.
12. Please send me all items which discuss whether GE digital meters can cause or allow voltage surges to propagate into buildings and into all electrical wiring and appliances and can damage them.
13. Please send me all items which discuss whether conventional analog meters can cause voltage surges to propagate into the home and into all electrical wiring and appliances and can damage them.
14. Please send me all items which discuss whether GE digital meters can propagate transient voltages throughout the electrical system of a house and turn it into an antenna which broadcasts additional unwanted electromagnetic radiation upon those occupying the structure.
15. Please send me all items which discuss whether conventional analog meters can propagate transient voltages throughout the electrical system of a house and turn it into an antenna which broadcasts additional unwanted electromagnetic radiation upon those occupying the structure.
16. Please send me all items which discuss whether exposure to electromagnetic radiation should be kept at the lowest levels possible and whether electromagnetic radiation is a class 2B carcinogen.
17. Please send me all items which discuss whether as our total lifetime dose of electromagnetic radiation increases, the incidence of cancer increases at a parallel rate, that is whether the carcinogenic effect of electromagnetic radiation is dose dependent.
18. Please send me all items which discuss whether GE digital meters, because they subject us to an increased risk of fire, may in the future cause insurance companies to charge higher insurance rates against homes and other buildings which use GE digital meters or whether insurance companies are already doing this.
19. Please send me all items which discuss whether GE digital meters consume electricity constantly in order to operate and how much electricity they consume in doing as they operate.
20. Please send me all items which discuss the life expectancy of analog meters of the type currently in use is up to 40 years and if not what their life expectancy is.
21. Please send me all items which discuss how long GE digital meters are expected to last.
22. Please send me all items which discuss how much the shorter life expectancy of GE digital meters will raise general PUD costs and in turn increase electric bills in general.
23. Please send me all items which pertain to the policy of Snohomish County PUD regarding responsibility for damage occurring before and after the weather head.
24. Please send me all items which relate to plans being made by Snohomish County PUD to install so-called advanced meters, also known as AMI meters, and referred to incorrectly by some as “smart meters”.
James Robert Deal , Attorney & Broker
PO Box 2276 Lynnwood WA 98036
Direct Telephone Line: 425-771-1110
Toll-Free Line: 888-999-2022
AgencyOne Realty LLC