This Webinar is part of the 13th edition of the EOLE conference which is held online this year due to the worldwide pandemic.
Initiative born in 2008 the European Open Source & Free Software Law Event (EOLE) aims to promote the share and dissemination of legal knowledge related to free software, as well as the development and promotion of good practices.
For this firth webinar, which focuses on Free software acquisition by public administration, the speakers responded to the questions : How can public administrations acquire free software? What means are available? What would be the main obstacles? The Speakers take into account past experiences and recent legal development to highlight the important aspects that need to be considered when public entities decide to acquire free and open source software.
This webinar is divided into the four following parts:
- 1. Guidelines for Software Procurement and Reuse by Italian Public Administrations - Italo Vignoli (00:04:55)
- 2. Software reuse through free and open source:Developers Italia and the Italian strategy - Leonardo Favario (00:23:30)
- 3. Free software acquisition by public administration. What does Open Source change? - Benjamin Jean (00:49:17)
- 4. Question time (01:13:37)
Free software acquisition by public administration
The European Open source & Law Event aims to promote the sharing and dissemination of legal knowledge on free and open source software. This is an annual event and is usually held in different European cities each year. If you want any additional information about previous editions do not hesitate to consult the website of the event.
Today starts the 13th edition of EOLE which focuses on legal aspects of free software in public administrations. It was originally scheduled in April in Turin (Italy) but like many other projects EOLE has been postponed due to the worldwide COVID pandemic. We thus decided to make it a virtual conference divided into 5 webinars.
Today is the first one and we will focus on the acquisition of free software by public administrations.
1. Guidelines for Software Procurement and Reuse by Italian Public Administrations - Italo Vignoli
Italo Vignoli (IVI) is a member of the Association Libre Italia, he is also an open source initiative board member, co-chair of the ODF advocacy, he co-leads Libre office marketing public relation team. He has a lot of experience in this field and can thus share with us some key points and best practices about public administrations and open source.
This presentation focuses on the Italian situation, but of course there are many similarities with other European countries. In Italy we have one of the most advanced laws in terms of Open Source adoption by Public Administration (PA). We have the CAD (Codice Amministrazione Digitale) which has been approved several years ago. There has been a couple of guidelines for the deployment of the law. Currently “Before acquiring any software, administrations must develop a comparative evaluation of available solutions” and they should give the priority to the reuse and to open source solutions. If the final decision is to purchase a proprietary software or to develop new ones, it has to be technically and economically justified. Moreover, every developed software has to be released with an OSI compliant open source license and there is a preference for European licenses. But most licenses compliant with the open Source (OS) definition could apply.
Law about reuse
Since 2005 Public Administrations (PA) must provide their software to other PA which is a direct reuse. Since 2012 PA must adopt available Open Source software rather than proprietary software and since 2016 software have to be released as Open Source. So reuse is through the use of OS, not only through direct reuse of proprietary software.
Advantages of this reuse: This reuse brings improvement in the quality of software but also better access to knowledge, good security and opportunities for small and medium companies and software houses.
Obstacles: But there are of course some obstacles to the use of OS software : the lack of specific open source software for PA which have very peculiar needs, the lack of open source software lists and catalogs for PA. A major effort has been made and the team Digitale has done a very good job but knowing and getting control of all available software is very difficult. There are also some fears about security and the lack of documentation, and this is unfortunately very typical of people who received an education based on proprietary software.
The comparative evaluation could be a complex methodology. For this reason a group led by AGID (Agenzia per l’Italia Digitale), CSI Piemonte and other public administrations or related organizations has been created. They managed to define a procedure - although complex - which facilitates the understanding and production of a comparative evaluation.
This progress has been made possible thanks to the dynamic of the open source software project and the integration of several criteria :
- Regarding compliance, which are: Interoperability, data protection, safety, accessibility
- Regarding quality, which are: Requirements, maintenance, support, dependencies, PA skills, etc.
The adoption of the evaluation criteria is unfortunately limited. There are groups of PA which are producing evaluation criteria on a regular basis and there are some areas where the evaluation is completely ignored even if the law is sufficiently clear. One major issue is the lack of sanctions which leaves people free to simply ignore the law and this issue is verified with the quote : “No one has ever been criticized for having ignored a comparative evaluation and chosen Microsoft”. Moreover, the innovation manager of the city of Milan is a Microsoft employee assumed to be on sabbatical leave but his LinkedIn profile does not mention it. If a large public administration like Milan (Milan is one of the largest cities in Italy) appoints a former Microsoft employee as the city’s innovation manager, which is the department that should control the choice of software, you can understand that we are going in the wrong direction.
I have been a free software advocate for 16 years and before that I have been working in information technology in marketing since 1981 in large US companies and European consultancies. I went into open source without any education, I completely changed my point of view. Unfortunately, public administrations are very slow to understand the benefits of open source and there is still some form of resistance. From my point of view, the law exists but we still need someone to enforce the law because they understand the benefits. Otherwise, the law is completely ignored and nothing positive will come out of it.
LGA: Italo’s point of view is quite sad to hear but it is important to share his experience, and he’s right, so we have to face it. To recontextualize : Italo, you refer to the lack of sanctions from the Digital administration code, but article 12 of the code says that "the public manager is responsible for the observation and implementation of provisions which is also relevant for measuring evaluation organization and individual performances. It could be a way to obtain more attention from them to stress these points. My personal opinion is that open source could be a resource for public administration - not because it is provided by law, but because it works, it is cheaper and it brings a lot of advantages. So, Italo, as a marketing expert, what can be done without going through law ? Why are we so “lazy” about open source ?
IVI: This is difficult to answer. I manage a consulting team with various organizations to migrate from proprietary to open source software - especially Libre office, but also other software and open standard formats. I can tell you that I talked with managers from many European organizations - in Italy especially - and when we discuss the advantages of open source, the level of understanding is extremely limited. We need better education on these subjects. For example, the number of people understanding the issues of open standards is about 10%. Everyone uses the Microsoft format which is proprietary while they are not formally allowed by law (at least in UK, France, Portugal, Italy, and Sweden) according to the latest guidelines. Sweden is the only country enforcing the open standards because it is written in the procurement law. In all the other countries, the majority of the population uses Microsoft as the main format for exchanging documents, because they simply ignore or don’t know the advantages of open source - security, cost, interoperability, etc - and they do not think about alternatives. Moreover, for the majority open source means free and they do not try to see behind that. That is the tragedy and the only people starting to use free software are people who are beginning to ask themselves questions, such as: ‘Is it better because it is free ? Or is it better because it is more solid, more respectful, etc. ?’. Yes it is less expensive, but this is not the only advantage, and people need to understand that. The marketing answer is : we should educate people but it is not easy because the majority does not see the need to be educated on these subjects.
LGA : I want to find hope in your presentation because it seems clear that ignorance is the first obstacle to the spread of open source within public administrations. Open source already has a significant presence in the private sector which means there is still hope. We should really start using Open Office in school but I think it is better not to start talking about educational issues because we are saddened by what has already been said and this would bring us to another fundamental subject.
2. Software reuse through free and open source: Developers Italia and the Italian Strategy - Leonardo Favario
Leonardo Favario (LFA) is an open source project leader of the digital transformation department at the Italian government and is responsible for the open source strategy. His responsibilities involve : Developers Italia, the public code certification, the new national guidelines and the catalog of open source software created for public administration. He has also been a free and open source advocate from a very young age.
LGA: Leonardo, we have already discussed some points of the Italian situation, but I am sure you have something to say about it.
LFA: It is always a difficult task to speak after Italo. As Laura said, I will be very brief today since many topics have already been depicted by Italo who shared his point of view with us. I will try to explain what Developers Italia is doing, what it is and what it will possibly be in the near future.
Since we have already seen everything about Italian law, I would like to talk a bit more about the new guidelines. In 2017 - 2018, a working group led by the AGID (Agenzia per l’Italia Digitale) and the Digital transformation team - which no longer exists and has been replaced by the digital transformation department - begins to question the situation. We have the main primary law that is written in the digital administration code, articles 68 and 69, but this code also says that it is possible for the AGID to define some technical guidelines and documentation in order to explain more clearly what the primary norm says and to help public administration in this digital transformation process.
The guidelines are available online since May 2019, and I think the working group has done a good job in drafting these guidelines. As Italo previously said, public administrations have frequently failed to follow these provisions because they did not really know how to do it. We can call it ignorance, or not being able to understand but the department is now trying to understand how to educate them, and how to share and spread as much information as possible about free and open source software, standards, procedures and methodologies. In short, the guidelines say that, Public administration must make a comparative assessment and if they want to use some proprietary components or a full proprietary software they must explain their motivations on an official document and digitally sign it. Then, one of the most important parts is that everything a public administration does, write and commission - in terms of software - must be released as open source. This, I think, is an enabler in starting a good virtue circle when using the catalog.
I will now show you two quick examples to explain how the development phase and the reuse phase work
The development phase
The PA “A” decides to develop an "Imago " software. As they don’t have the capacity to develop it themselves, they commission developers. The developers assign the ownership of everything that has been produced, so the PA owns the code.
The public administration or private developer has to publish the code as free and open source with an open source compliant license and publish the code on a code hosting repository. That is where Developers Italia comes into play.
The Reuse phase
Public administration B tare looking for a software that has been published by someone else. If they find something that maybe can cover their requirements they (or third party developer connected to PA “B”), can clone the code (download it and test it, see if what is written inside) and see if it fits their needs. They are free to use it and reuse it without any issue. But if it needs customization, PA "B "can also appoint a third party developer. Those modifications will be assigned back to public administration B. So here we see whether it is made from scratch or just modified, everything created will be assigned back to the public administration.
Developers Italia was created in 2017/2018 by the agency and digital transformation team. In January 2020, the team ceased to exist, so a new digital and transformation department is following, curating and maintaining it. It is a community of nearly 500 people, not everybody is a developer. There ate private citizens, public administration entities, … They provide tools, chat channels, forums to have a melting pot of people so that Public administrations can understand what is needed from the other side ( the citizen side and/or the private sector side), in order to share ideas and share software. Since 2019 and the publishing of the guidelines it is the epicenter of the reuse approach.
They have 3 main sections: API, software and platforms. Inside the software section , you can see the “reuse catalog”. One of the issues is that when Free and Open Source Software (FOSS) is introduced most of the time PAs mention that it is interesting but don’t fully understand or can’t find documentation. They are often left with many questions unanswered regarding the Open source world which is still new and to be discovered for many people. Developers Italia realized that and decided to create a catalog PAs could look into. One of the issues was to not recreate yet another central platform, as the code is already somewhere to be found most of the time. Developers Italia wanted public administrations to look for that code in a decentralized fashion, which is how they designed the architecture of the catalog. There are a lot of interesting information that are listed: features, screenshots,… that are available to be discovered.
The way it works is that, every night, a crawler looks through the different repositories for a specific file containing information about a piece of software. The only thing to do in order to be seen by this crawler is to put a file called “publiccode.yml” in the code, to help the crawler find the software. The software is then verified and the information is published on a dedicated page in the catalog.
Beyond “just release”
It’s a big leap forward, but in my opinion still a little step towards an ultimate goal. If we just tell the administration to take the code and publish it, it is not really an open source approach, it is a step, but another important aspect of open source is to build a community in order to build a better software, fix any issue.The goal would be to make the administrations aware that we have to start an “open by design approach” where we design and develop in a collaborative fashion.
LGA: Thank you, it is pleasing to know that a lot has been done already. What about local public entities? As Italo said, there is very good law and clear guidelines regarding procurement and use of software in open source. The problem is that little public entities with no resources or competence may have a hard time applying those guidelines. Is there something that the teams are preparing to get in touch with those local entities, in order to create a community in this sense? It is not only an Italian problem I think.
LFA: Most of them are small entities and don’t have the in-house skills. I think it is crucial, and it is something we have been working on with the Agency for digital Italy, we have to understand how to create the aggregation of not just people but also of PA. This would increase the possibilities of getting better maintenance. They have examples in public administration where this aggregation has been done and it is a good study case. There were many little entities creating a little block, which grew in the procurement phase, which increases the possibility of building better software and getting better maintenance. Currently we are trying to make PA understand that their needs are also the needs of someone else, and that they don’t have to recreate things over and over again. This meeting of needs must happen somewhere so they are trying to provide the tools so that this communication happens faster. But there is also work to be done on the procurement side and with the providers of services, in order to understand what is really needed from the point of view of Public administrations. They are currently communicating with the European community on this subject and they are experimenting with this idea. They are trying to see if this works or not but I think that what we are doing in Italy for the competence center is going in that direction. Decentralizing this law and putting the competence centers as close to the Public administrations as they can be, a good government is a government that teaches people how to govern themselves not the one telling people what to do from start to finish. we need to take little steps and explain to people how to do it. We, as citizens, need to organize also at the local level. We’re on a good path.
LGA: Thank you , there is another question from the chat, it is very specific to your presentation: Which public code has been harvested by developers Italia?
When we designed Developers Italia we had PAs in mind, they had to do what the PA code is telling them to do. Hence, they created a catalog of free and open source software, and created a new section called " third party FOSS" where they can index any software that has an OSI compliant license on top of it. A software, even if it is not used, can be of interest to a PA, so it can be potentially anything. So I’d like to add: if you have a piece of software that could be useful, put the .yml file in the software so that it can appear in the catalog for other people to use.
3. Free software acquisition by public administration. What does Open Source change? - Benjamin Jean
Benjamin Jean (BJE) is currently the Inno3 company CEO, an open innovation consulting firm focused on digital transformation, intellectual property management and strategies around open source and open data. He is also the president and co-founder of Open Law, a french non-profit organization focused transformation of the legal sector through digital cooperation programs. He is also a professor of Intellectual Property for Science Po Paris. He is also one of the co-founder and co-organizers of EOLE.
BJE: Thank you, Today I’d like to share France’s plans on this particular question about including open source in PA, and about how the administration can acquire open source software. In France, and other countries, nowadays open source is quite close to open data regarding the administration. All administrative entities have to share the source code of every software they are producing for their mission as they have to share all data they produce. Open source is part of what France calls "open data by default " which means, that the PA has to publish the source code before anyone asks them to do so. In France we also have a policy to use and contribute to free software, this policy is produced as a template to be reused by others, which makes the software sharing process way easier. The end of the year mission for the government is the Mission Bothorel, about the value of open source and open data. What is interesting to see is that even if open source is today the default status, people need to understand why it is. The reason why open source is not as significant as it could, is because people do not understand why they need to open their code. Another call of the Bothorel mission is to understand and bring a broad view of the value of sharing code. Open source is open data but at the same time it is a way of building digital commons. There is a good dynamic of PA trying to join existing digital communities and join efforts. It’s something which is done at a local level, a lot of PA are trying to do things with local players and to share with other local authorities. Just to cite a french resource, we have an “outil commun” live resource on how to contribute and produce commons.
One other thing I wanted to share which is quite close to what Leonardo just shared, is "code sources du secteur public ". Which is a webpage that gathers all PA repositories, posted on GitHub, Gitlab or any other platform. It’s not technically done in the same way as Developers Italia , but it would be interesting to share practices, to see how to do it efficiently.
I will talk about how to think about acquiring an open source software, what needs to be done when acquiring a FOSS, what needs to be done for the production of the services after, but also needs to be thought out from a community and contribution standpoint. Another aspect which I think is important when discussing public administrations, is how to lower the risks of doing open source. People usually know how to acquire a commercial software, but it’s much more complex for them to think about acquiring a FOSS, so we need to lower the risk and explain the benefits. All the steps need to be anticipated at the time of the writing of the tender. This presentation is divided into the 3 main phases of a project: before, during and after.
Mutualizing : When thinking about acquiring an open source software, the first step is to think about:
- What other free software which might fit the need of the PA exits
- Who are the other PA or stakeholders who might be interested in acquiring the same software.
This first step which is not something PAs have to do when just acquiring a traditional software is really important when it comes to FOSS. It’s a way of mutualizing with other PAs, but also a way of being sure that if you are using a FOSS, it will be beneficial from a competition perspective.
The judges explain that because of the open source nature of the software you can choose a specific one, as it is open source and good for competition.
Licensing: When funding a supplier, and asking to develop a new software, PAs need to choose the right license for the software they are building. This choice of license might be very specific to the software they want and the community they want to build around it. In France the amount of open source licenses that PAs can use is limited. It’s not the same to think about reusing open source components or producing new resources and this step might be really important when trying to gather a community around a specific software which doesn’t exist yet.
Evaluating: Another point that needs to be thought out at the beginning of the acquisition is how to evaluate each actor. They are asking people to answer their needs but if they don’t evaluate the answers with some criteria dedicated to evaluating what open source is, you won’t be able to choose a good actor.
To demonstrate this, I want to share some feedback from RTE (Réseau de Transport d’énergie), who included a specific provision in the tender about wanting an open source only software. They expected to have fewer answers and actually a lot of suppliers complied with the requirement, even if they needed more time to explain what kind of open source software or license they needed, in order to help the supplier understand and accept every aspect of what open source means. We already published a document on the best practices to adopt which is available on the website of LFenergy
If the PA wants to build an open software, they need to think about the three parts that constitute a digital common: Resource, Community and Governance.
Suppliers: The Decidim project from Barcelona city is a good example, they had a very interesting way of thinking. In order to make sure that they won’t rely on one player only (and remain free and inclusive). From the very beginning, they asked several suppliers to work on the answer together to be make that they will have the choice between all of them when continuing the development of the specific project.
Communities: We can use the example of Decidim, they made a very interesting choice to ask the community that emerged from that project, to also take part in the governance of the project. That way, even if the original roadmap was fixed by Barcelona, other cities, future members could join and benefit from what was done from the beginning.
Resource: What can be added to the tender and the contract is the need to make sure that the source code be made publicly available in a continuous way. It’s another kind of requirement that can be expected when asking people to produce an open source software. Putting the lines of code being produced on Github or Gitlab is a good way of ensuring that the software remains free and accessible.
Governance : PAs have to think about which aspects they might want to integrate from the beginning of the project. There is always a talk about the license, they could also think about what kind of contributor agreement they will add, in order to integrate other contributions from other participants. It’s not something that needs to be done as soon as the tender is published but it is something to keep in mind as it’s part of the process of acquiring an open source software and being part of a broader project.
PAs need to think about how to maintain the specific contribution, and how to maintain the benefit of the contribution from other public and private members.
In another project also funded by a PA, 5 years after the beginning of the project and using the OS software, they did not benefit in any way from the collaborative approach.Another thing to think about is the exit of the PA. In some cases, the PA which funded the project becomes the leader and when it tries to exit the project disappears. It would be better to anticipate the exit in order to make sure that the project remains sustainable after the leave of the PA.
I am a bit more optimistic than Italo. There is a good dynamic in France and Europe even if there is still a lot of work to do. There are a lot of elements to share between PAs from France, Italy and other countries. Even if these states are not working on digital commons together, public administration can work with others in other countries, it is a good way to collaborate from a horizontal perspective.
IVI: I would like to ask a question to Benjamin: Is there a party that is supporting Microsoft in the adoption of software everywhere in France? Do you have a city executive who is a Microsoft employee? I think France is the European country where the government is using open source the most.
BJE: I know, what is interesting is that it is done at a higher level, and a lot of local authorities don’t want to work with Microsoft.
IVI: Yes I think the attitude is completely different in Italy. No one has ever been fired for using Microsoft but a lot of people have been strongly criticized for using open source. For example, when the Ministry of defense decided to switch to LibreOffice, the highest level of the Military were greatly pressured directly and indirectly by Microsoft. So unfortunately, the two countries are very similar but the situation and cultural independence of people, especially at a lower level is completely different. Actually the law in France helps in some way, French law requires software to be translated into French otherwise it cannot be used in another language. These are small details but unfortunately we are not in a good situation, even if Leonardo and the team are doing a very good job. It’s a very big challenge, education is a challenge because it doesn’t come for free. In some cases the feeling is that you have a “rubber world” in front of you. You may go forward but you will bounce back, to the difference of bricks that you could break.
4. Question time and discussion
LGA: I believe that open source will work in Italy because open source works. I agree with the point from Italo about driving the change through education, and to bring this idea through procedure, which in my opinion is not just bureaucratic homework. Making a procedure that imposes a motivation of proprietary choices, is a way to better understand the alternatives that are available when acquiring a software. Benjamin , you focused your presentation on the cultural point, because in a procurement procedure driven by PA, being able to translate the effective needs in criteria requirements, written down in procedure, which can allow PAs to evaluate open source projects for what they can offer is important. The problem is that, from my point of view, what an open source project can offer to a public administration and the way this project can offer its advantage are different from proprietary software. We need to be able to evaluate and be capable of reevaluating open source software and projects, as not all the projects are the same, OS needs to be really connected with interoperability, open data, and open standard. That’s a point because we need to write down procedure respecting the competition and so on, but probably we need to be braver and believe in OS as an advantage. We will start the round table with this idea, I believe Leonardo you want to answer.
LFA: I want to believe, not really in the final outcome, so not just publishing somewhere a piece of software, but want to believe in the community that open source software is always offering as, we all probably participated in communities around FOSS. That is really what I’m looking for, this is what we have to achieve in the long term, in some way I understand what Italo said, however, the guidelines have been published just one year ago and we’re starting to see an evolution. Those are the people and administrations that are using on a daily basis the catalog from Developers Italia they are the only adopters and they are a small percentage if we take into account all the sphere of PAs in Italy. But we are trying to understand what is needed from different perspectives. This is a very long process, we’re interviewing them, we’re trying to make it as painless as possible for PA to use the catalog especially in the acquisition phase. We have to go and try to aggregate the needs, the administrators and make them understand that they have similar needs and that they don’t have to duplicate efforts every time. It’s the most efficient way to build for everyone, because in the end you only build once and don’t need to replicate. We are on a good path , and we still have to provide a lot of efforts, I’m really happy that the department for digital transformation is trying to push forward in this direction, so we are pushing forward and having more resources .
LGA: It’s funny because two years ago we were already talking about switching from open by default to community by default. I think the key point of Open Source is the community. Some Public administrations think that they cannot engage in Open Source because they cannot rely on the community for assistance and that they need to get a team as Open source cannot offer them certainty and guarantees that they need. Where are they wrong?
IVI: There are companies working on every project that can support an Open Source software with any kind of support level from service level agreement if needed to other agreements. I think that if the French government,if the military in Italy (which has 100,000 users), can use the software and use the support, the question is just an excuse it’s not a real question. Of course you have to adapt yourself to a different way of being supported. For example, if you want a phone number, that may not work in all cases, but we have online chats, we have a lot of different resources. At the moment I am working with a very large organization based in Geneva, you can understand which one it is. If they are able to work with support based in Italy, Germany or France, I think that any organization can really work with support from Open Source projects. It’s an excuse, of course people are looking for excuses in many cases.
LGA: Another question in the chat for Leonardo, about again the Open source program office. I think you have already read it, you can give us some feedback?
LFA: The idea is to again, try not to be the center of government telling everyone what to do but trying to catch the real needs from the local perspective and put it into aggregation. In Italy we have the three years ICT plans, which, in some way, local and central governments want to achieve. In this plan, we have a little bit of a focus on this aggregation, what I call “competence centers”, they may say SPOs even if it’s not really an SPO. The idea is to support PA in this procurement phases. The phases that are the challenging for the PA, the comparative evaluation, this assessment, they have to do before starting the real acquisition phase are really delicate. I think if we somehow concentrate on the knowledge, a small PA could simply go meet the local competence center which has the same aim that we have but can help you in a very practical way. So I think this could be a very important point that the competence centers have to tackle and help the PA to achieve. But again it’s a way, in my personal point of view, to spot the knowledge. For example, if you know someone who is very skilled, you can create a little group, make a competence center and help others. It is a good way of decentralizing but also empowering the local governments in going towards the national strategy.
LGA: Of course, I agree, for example, a region is going to create a competence center on open source, in order to support not only the region itself but also other local entities in better knowing and understanding open source. Unfortunately time is running, my question about SaaS remains in the air.
LFA: I can answer it quickly, I mainly think that lately, when talking about SaaS (Software as a service), we often forget about the first S (which is software) people are always worried about the service without taking into consideration software. I think that the guidelines are rather clear about it, they talk about software on one side (the development phase and the licenses) and then the deployment (how you distribute your software as a service). I think it is a pretty clear guideline, I think we will work from our side in order to clarify better and better, to help administrations and service providers to understand what to do and when to do it. I think we have tools, we have licenses that somehow with the network effect are covering some parts of it, we have ways to work with it. I think that software as a service idea is important in order to understand how to build better software, software that can be distributed over different modes, that can be replicated over and over again… I think we need to have this idea in mind when building software, separating several services into micro-services and having a more agile and flexible architecture then we can deploy some cloud providers and we can make it available.
LGAa: Yes, let’s say that in Italy but probably not only here, we have two strategies open source first and SaaS first. We probably need to clarify better the relationship and try to impose Open SaaS first. Time is running, Thank you everyone, this discussion brought a lot of interesting points. Thank you EOLE and see you on the next webinar, and think Open!