Overview
The transition between presidential administrations is typically accompanied by a change in federal enforcement priorities, and the world of higher education is no exception. President-elect Trump has already promised to implement significant changes to the sector. Some of his more high-profile ideas have captured the news cycle, such as the proposal to eliminate the Department of Education altogether,1 but other areas will likely see major changes as well. This includes antitrust litigation, foreign relations (and a potential China Initiative 2.0), the implementation and revision of education regulations, and increased congressional scrutiny. Below, we discuss some of these areas and how the changes could impact colleges and universities.
Antitrust
President Trump’s return to the White House will likely bring a noticeable shift in US antitrust regulation and enforcement priorities.2Two potential areas of concern for higher education are the cost of tuition and the structure of the NCAA.3
The ongoing settlement negotiations in House v. NCAA, three joined cases involving antitrust allegations for the uncompensated use of athletes' names, images, and likenesses, will play a significant role in shaping the structure of college sports in the future.4The current settlement in House would not only pay former college athletes approximately $2.78 billion in damages but would also allow colleges to begin sharing revenue with current and future college athletes.5Beyond House, the NCAA has indicated that it will continue to seek some form of a limited antitrust exemption from Congress to support the NCAA’s rulemaking authority.6A GOP congressional majority may be sympathetic to these requests7; for example, Senator Ted Cruz (R-Tex.) recently announced that structuring the "future and viability of college athletics" will be "a priority" for Congress.8 Even if no legislative solution is reached, it is plausible that the Department of Justice (DOJ) under President-elect Trump will dial back its involvement in NCAA litigation. This would be a significant contrast from the Biden administration’s less-than-friendly stance towards the NCAA. In recent years, the DOJ has supported athletes by filing amicus briefs and Statements of Interest in lawsuits challenging NCAA rules, as it did in the lawsuit that overturned the NCAA’s transfer restriction rules.9
The DOJ under the Biden administration also applied antitrust law against colleges and universities in an attempt to combat the rising cost of higher education.10 In a 2022 case, the DOJ filed a Statement of Interest supporting plaintiffs who alleged that a group of defendant universities had entered into an agreement to calculate need-based financial aid that was not exempt under the 568 Exemption because the colleges' consideration of family income in its student admissions process rendered them ineligible.11It remains to be seen how the DOJ under President-elect Trump will prioritize participation in antitrust suits against the price-setting behavior of colleges and universities. (Such suits show no sign of abating; two college students filed a lawsuit with proposed class antitrust claims against 40 universities in October 2024.12) One factor that may play a role in the DOJ's involvement in such suits is the identity of defendant universities in any such actions. Conservative lawmakers have expressed increasing hostility against "elite" universities, and it is not difficult to imagine a Republican-led DOJ continuing to take positions—in antitrust lawsuits and otherwise—that are against the interests of such institutions.
China Initiative 2.0
The DOJ's much-maligned "China Initiative," which ran from 2018 to 2022,13was a focused effort to improve national security by cracking down on economic espionage and trade theft conducted by the Chinese government.14 Under the China Initiative, the DOJ prosecuted several academics for allegedly failing to properly disclose their ties with China when applying for federal research funding.15 After multiple prosecutions ended unsuccessfully, either with acquittals or dismissals, the DOJ officially ended the China Initiative in 2022.16 (Steptoe defended a professor from Southern Illinois University-Carbondale in a China Initiative prosecution in federal court, obtaining dismissal of two counts of wire fraud against him and a jury acquittal on a related count of making false statements, acquitting him of all grant fraud charges. He was convicted on technical foreign bank account reporting violations and received probation.17)
Reports of the China Initiative's demise, however, may be greatly exaggerated, as it is entirely possible that the China Initiative will return in some form under President-elect Trump. In September 2024, House Republicans passed a bill that would revive the China Initiative.18 And a hostile attitude toward China is not limited to Republicans—members of both political parties have taken a strong stance against China in recent months.19Given these sentiments, it is not unreasonable to think that the executive branch under President-elect Trump may implement a new round of the China Initiative, even if under a different name, and given the incoming administration's disdain for elite higher education institutions, the initiative may this time take aim at institutions, and not just Chinese-origin academics. If this occurs, it will be critical for researchers and institutions to ensure they are properly disclosing all ties with China when applying for federal funding, closely vetting relationships with Chinese institutions and organizations, and performing heightened due diligence where appropriate.
Title IV of the Higher Education Act
Title IV provides students with federal financial aid for higher education.20 President Trump's 2018 proposed budget (titled "A New Foundation for American Greatness")21included drastic cuts to federal student aid programs, one of which would have cut Pell grants by $3.9 billion, a move that surprised many in higher education.22 These sweeping cuts to student financial aid did not make it into the final Congressional budget.23 Education grants and aid are broadly popular and seem unlikely to be repealed, but the Trump administration may nonetheless propose and/or implement cuts that could impact the availability of aid. Education funding could also fall within the crosshairs of President-elect Trump's newly created Department of Governmental Efficiency (DOGE) commission, to be headed by Elon Musk and Vivek Ramaswamy, which has been tasked with slashing federal spending.24
Title VI of the Civil Rights Act – Religious Discrimination
Title VI, which the Department of Education has interpreted to prohibit religious discrimination against Jewish and Muslim students,25 could play a critical role in how President-elect Trump’s executive branch handles campus protests surrounding the Israel-Hamas conflict. President-elect Trump has made strong public statements supporting Israel, both during his first presidency26and on the campaign trail, when he promised to “defend our American Jewish population."27He encouraged the Biden administration to revoke the visas of individuals supporting Hamas,28 and he may attempt to do this upon taking office. Since Hamas' October 7, 2023 attacks on Israel, "the Department of Education’s Office for Civil Rights (OCR) has opened dozens of investigations into allegations of antisemitism at colleges and K-12 schools, a dramatic increase from previous years."29 This trend will likely continue under the Trump presidency, with OCR continuing to focus on investigating antisemitic conduct as well as (though likely to a lesser extent) anti-Arab and anti-Muslim harassment and violence,30 all of which is on the rise on college campuses.31
Title VI of the Civil Rights Act – Racial Discrimination
Title VI enforcement actions regarding racial discrimination also bear monitoring. Last year, the Supreme Court ruled that affirmative action programs in higher education were unconstitutional, a decision that President Trump and Republican lawmakers praised.32 Despite this decision, the Biden administration promoted recommendations to increase diversity on campuses that some considered to be impermissible workarounds.33 The Trump administration is expected to discontinue such practices and take steps to limit diversity, equity, and inclusion (DEI) initiatives on campuses.34 For example, President-elect Trump has promised to "cut federal funding for any school or program pushing Critical Race Theory."35 In anticipation of his next presidency, some commentators have recommended preemptively curtailing DEI offices and initiatives at universities.36 Others have recommended holding fast to DEI initiatives in the face of President-elect Trump's threats to cut funding.37 For example, Wesleyan University’s president has publicly taken the latter stance, pledging more, not fewer, DEI initiatives to come.38 Whichever route colleges and universities take, they should be thoughtful about the steps they take and cognizant of the risks and potential legal implications of those actions.
Title IX of the Civil Rights Act – Gender Discrimination
The Biden administration bolstered Title IX's protections for transgender students and pregnant individuals through new DOE guidance.39Republican state attorneys general have challenged these protections, suing the Department of Education and securing injunctions preventing the new guidance's enforcement in several states.40 President-elect Trump's administration is expected to replace President Biden's more victim-friendly regulations and reinstate its previous stances on Title IX,41including strengthening protections for those accused of sexual assault and decreasing federal protections for transgender students. As a practical matter, this may leave universities in limbo for some period of time, with uncertainty around what the current Title IX regime is (which may vary state to state, based on the injunctions referenced above) and what it will be in the future.
Potential Leniency toward For-Profit Schools
The Biden administration made a concerted effort to crack down on for-profit schools, some of which have saddled their students with high amounts of debt and no degree after promising employability upon graduation.42 President-elect Trump, who himself previously ran a now-shuttered for-profit institution, Trump University,43 will likely favor for-profit institutions and discontinue the Biden administration's crackdown. During President-elect Trump's first term in office, then-Secretary of Education Betsy DeVos closed multiple investigations into allegedly predatory for-profit institutions.44 President-elect Trump will likely "loosen the reins" on for-profits, decreasing oversight and investigations into such institutions.45
Congressional Investigations
Congressional oversight of universities—other than for-profits—is likely to increase during the next Congressional session. Even before the election, Congressional hostility toward higher education was on the rise, notably highlighted by the December 5, 2023, hearing on campus antisemitism at which the presidents of Harvard University, Massachusetts Institute of Technology, and the University of Pennsylvania were questioned for their handling of antisemitic incidents and campus protests.46 The testimony led to the resignations of the presidents of both Harvard and the University of Pennsylvania.47 Similar investigations and hearings are likely to occur.
Congressional investigations and oversight will likely extend beyond protests and antisemitic incidents. President-elect Trump's allies in Congress have already proposed several pieces of legislation aimed at taxing the endowments of “elite” and private institutions at higher rates48 and curtailing the availability of DEI initiatives on campuses.49 So far, Congressional focus has primarily honed in on a small number of private institutions, notably Ivy League and elite institutions. This focus is likely to continue.
Potential Overhaul of the Department of Education
President-elect Trump has repeatedly vowed to eliminate the Department of Education altogether.50 Uncertainty as to what may happen to the Department increased with President-elect Trump's announcement that he would nominate Linda McMahon as the Secretary of Education. She is the former head of the Small Business Administration, but better known as the former president and CEO of World Wrestling Entertainment, Inc. (WWE).51 President-elect Trump's announcement promised to "send education back to the states."52
In late November 2024, Senator Mike Rounds (R-S.D.) introduced legislation that may give a preview of future Department policy.53 The bill aims to dismantle the Department of Education, but includes language that would redirect certain Department programs—including federal loan programs, special education, and Native American education initiatives—to other federal agencies.54 Most commentators think it is unlikely that the Department of Education will be entirely dissolved. But McMahon’s nomination seems to indicate that President-elect Trump intends to curtail a significant portion of the Department's activities in the name of efficiency and state determination. As noted above, it also seems likely that, to the extent OCR continues to exist in its current form, its enforcement priorities may shift to focus more on incidents involving antisemitism, anti-Israel sentiment, and perhaps anti-conservative and anti-white bias.55
The Department of Education is not the only agency that may experience significant changes that could impact the higher education sector. In early December, Jay Bhattacharya, President-elect Trump's nominee to direct the National Institutes of Health, told the media that he is developing "a plan to link a university’s likelihood of receiving research grants to some ranking or measure of academic freedom on campus."56 Any such change could potentially impact how billions of dollars of research grants are allocated.57
Conclusion
As the country enters the second Trump presidency, colleges and universities should stay informed and be proactive in responding to the new administration’s policy shifts that may impact institutions' operations, funding, and compliance. Steptoe will be closely monitoring these developments, writing on them regularly, and advising its institutional clients on risks, compliance, and related issues.
1 See Sara Randazzo and Matt Barnum, Trump to Nominate Linda McMahon to Lead Education Department, Wall St. J. (Nov. 19, 2024), https://www.wsj.com/politics/policy/trump-to-nominate-linda-mcmahon-to-lead-education-department-33e3e095.
2 Trump 2.0: Potential Shifts and Key Considerations in US Antitrust Policy, Steptoe LLP (Nov. 19, 2024), https://www.steptoe.com/en/news-publications/antitrust-and-competition-blog/trump-20-potential-shifts-and-key-considerations-in-us-antitrust-policy.html.
3 Juan Perez Jr., Antitrust Comes to Campus, Politico (Aug. 5, 2024), https://www.politico.com/newsletters/weekly-education/2024/08/05/antitrust-comes-to-campus-00172567.
4 Justin Williams, House v. NCAA Settlement Granted Preliminary Approval, Bringing New Financial Model Closer, The Athletic (Oct. 7, 2024), https://www.nytimes.com/athletic/5826004/2024/10/07/house-ncaa-settlement-approval-claudia-wilken/.
5 Id.
6 Steve Berkowitz, NCAA President Charlie Baker Addresses Future of Federal Legislation, Antitrust Exemption, USA Today (Feb. 23, 2024), https://www.usatoday.com/story/sports/college/2024/02/23/ncaa-president-charlie-baker-federal-legislation-future/72718646007/.
7 Miranda Nazzaro, Republicans Unveil Legislation Protecting NCAA, Conferences from Legal Challenges, The Hill (May 8, 2024), https://thehill.com/homenews/house/4651977-republicans-unveil-legislation-protecting-conferences-ncaa-legal-challenges/.
8 Verdict with Ted Cruz, Inside the Senate Vote on the New Majority Leader, at 20:10 (Nov. 15, 2024), https://omny.fm/shows/verdict-with-ted-cruz-1/inside-the-senate-vote-on-the-new-majority-leader.
9 Josh Sisco and Juan Perez Jr., DOJ Joins Suit Targeting NCAA Athlete Transfer Restrictions, Politico (Jan. 18, 2024), https://www.politico.com/news/2024/01/18/doj-joins-suit-targeting-ncaa-athlete-transfer-restrictions-00136441; Mike Scarcella, NCAA Settles US, States’ Antitrust Lawsuit Over Athlete Transfer Rules, Reuters (May 30, 2024), https://www.reuters.com/legal/government/ncaa-settles-us-states-antitrust-lawsuit-over-athlete-transfer-rules-2024-05-30/.
10 Juan Perez Jr., Antitrust Comes to Campus, Politico (Aug. 5, 2024), https://www.politico.com/newsletters/weekly-education/2024/08/05/antitrust-comes-to-campus-00172567.
11 Statement of Interest of the United States at 1, Carbone v. Brown University, No. 1:22-cv-00125, Dkt. 167-1 (N.D. Ill. Jul. 7, 2022), https://www.justice.gov/atr/case-document/file/1518171/dl.
12 Lauraann Wood, 40 Private Schools Hit with Aid-Fixing Conspiracy Claims, Law360 (Oct. 8, 2024), https://www.law360.com/articles/1888018/40-private-schools-hit-with-aid-fixing-conspiracy-claims.
13 Ryan Lucas, The Justice Department is Ending Its Controversial China Initiative, NPR (Feb. 23, 2022), https://www.npr.org/2022/02/23/1082593735/justice-department-china-initiative.
14 Information About the Department of Justice’s China Initiative and a Compilation of China-Related Prosecutions Since 2018, Department of Justice (last updated Nov. 19, 2021), https://www.justice.gov/archives/nsd/information-about-department-justice-s-china-initiative-and-compilation-china-related.
15 Aruna Viswanatha, Justice Department Shifts Approach to Chinese National-Security Threats, Wall St. J. (Feb. 23, 2022), https://www.wsj.com/articles/justice-department-shifts-approach-to-chinese-national-security-threats-11645646452.
16 Id.
17 Steptoe Secures Favorable Decision for Professor MingQing Xiao, Steptoe LLP (May 9, 2022), https://www.steptoe.com/en/news-publications/steptoe-secures-favorable-decision-for-professor-mingqing-xiao.html; Jeffrey Mervis, U.S. Math Professor Gets Probation, Not Prison, in China Initiative Case, Science (Sept. 19, 2022), https://www.science.org/content/article/u-s-math-professor-gets-probation-not-prison-china-initiative-case.
18 H.R. 1398, Protect America’s Innovation and Economic Security from CCP Act of 2024, (118th Congress, 2023–2024), https://www.congress.gov/bill/118th-congress/house-bill/1398; Jessica Blake, Republicans Seek to Revive China Initiative, Inside Higher Ed (Sept. 11, 2024), https://www.insidehighered.com/news/government/science-research-policy/2024/09/11/house-republicans-seek-revive-china-initiative.
19 Caitlin Yilek, Trump and Harris' Views on China, According to Their Records and What They’ve Said, CBS News (Sept. 13, 2024), https://www.cbsnews.com/news/trump-harris-china-2024/.
20 Congressional Research Service, The Higher Education Act (HEA): A Primer, Congressional Research Service, 1, 9 (April 10, 2023), https://crsreports.congress.gov/product/pdf/R/R43351.
21 See https://www.govinfo.gov/content/pkg/BUDGET-2018-BUD/pdf/BUDGET-2018-BUD-3.pdf.
22 See Statement on “A New Foundation for American Greatness,” President Trump’s FY2018 Budget Proposal, Institute for Higher Education Policy (May 23, 2017), https://www.ihep.org/press/statement-on-a-new-foundation-for-american-greatness-president-trumps-fy18-budget-proposal/.
23 See Department of Education Appropriations Act, 2018 Pub. L. No. 115-141, 132 Stat. 746 (Mar. 23, 2018).
24 Lindsey Choo, Elon Musk’s DOGE Takes Aim At Federal Agencies—Here’s Where Cuts Could Be Made, Forbes (Nov. 22, 2024), https://www.forbes.com/sites/lindseychoo/2024/11/22/elon-musk-doge-takes-aim-federal-agencies-where-cuts-can-be-made/.
25 Abigail A. Graber, Religious Discrimination at School: Application of Title VI of the Civil Rights Act of 1964, Congressional Research Service, 3 (Sept. 17, 2024), https://crsreports.congress.gov/product/pdf/LSB/LSB11129.
26 Liam Stack, Trump Has History of Strong Support for Israel, N.Y. Times (Nov. 6, 2024), https://www.nytimes.com/2024/11/06/world/middleeast/trump-israel-support.html.
27 Roll Call, Remarks: Donald Trump Speaks at October 7th Remembrance Event in Miami, at 17:51 (Oct. 7, 2024), https://rollcall.com/factbase/trump/transcript/donald-trump-remarks-terrorist-attack-anniversary-israel-october-7-2024/.
28 Simone Weichselbaum, Trump’s Plan to Quell Protests: ‘Deport Pro-Hamas Radicals’, NBC News (Aug. 13, 2024), https://www.nbcnews.com/news/trumps-plan-quell-protests-deport-hamas-radicals-rcna166168.
29 Vimal Patel, The Man Who Helped Redefine Campus Antisemitism, N.Y. Times (Mar. 24, 2024), https://www.nytimes.com/2024/03/24/us/politics/kenneth-marcus-college-antisemitism-complaints.html.
30 E.g. Press Release, Office of Communications and Outreach, Department of Education, U.S. Department of Education’s Office for Civil Rights Announces Resolution of a Complaint Against the University of Illinois – Urbana Champaign (Sept. 3, 2024), https://www.ed.gov/about/news/press-release/us-department-of-educations-office-civil-rights-announces-resolution-of-0.
31 Lexi Lonas Cochran, Fears Rise on Campuses After Attack on Palestinian College Students, The Hill (Nov. 30, 2023); Holly Honderich, Antisemitic Incidents in US Surge to Record High – Report, BBC (Oct. 6, 2024), https://www.bbc.com/news/articles/c9wkxv9d99vo.
32 Sara Dorn, Trump Cheers ‘Amazing’ Affirmative Action Ruling: ‘What a Wonderful Day’, Forbes (June 29, 2023), https://www.forbes.com/sites/saradorn/2023/06/29/trump-cheers-amazing-affirmative-action-ruling-what-a-wonderful-day/; US Supreme Court Holds Race-Based University Admissions Programs Unconstitutional, Steptoe LLP (June 30, 2023), https://www.steptoe.com/en/news-publications/us-supreme-court-holds-race-based-university-admissions-programs-unconstitutional.html.
33 See Kaanita Iyer, Biden Administration Releases New Recommendations for Colleges to Promote Diversity, CNN (Sept. 28, 2023), https://www.cnn.com/2023/09/28/politics/biden-administration-recommendations-education-diversity/index.html.
34 Alice Speri, US universities brace for education policies overhaul under Trump, Al Jazeera (Nov. 24, 2024), https://www.aljazeera.com/news/2024/11/24/us-universities-brace-for-education-policies-overhaul-under-trump.
35 President Trump’s Plan to Save American Education and Give Power Back to Parents, Trump Vance: Make America Great Again (July 25, 2024), https://www.donaldjtrump.com/news/da7f3c42-76b5-42c0-9beb-475d649030ae.
36 The Campus in the Second Age of Trump, The Chronicle of Higher Education (Nov. 18, 2024), https://www.chronicle.com/article/the-campus-in-the-second-age-of-trump.
37 Id.
38 Vimal Patel and Sharon Otterman, Colleges Wonder if They Will Be ‘the Enemy’ Under Trump, New York Times (Nov. 12, 2024), https://www.nytimes.com/2024/11/12/us/trump-higher-education-policy-universities.html
39 Id.; see also Michael S. Roth, I’m a College President, and I Hope My Campus Is Even More Political This Year, New York Times (Sept. 2, 2024), https://www.nytimes.com/2024/09/02/opinion/college-president-campus-political.html.
40 See Collin Binkley, More Republican states challenge new Title IX rules protecting LGBTQ+ students, AP News (April 30, 2024), https://apnews.com/article/title-ix-lawsuit-transgender-sports-f47922529d12b68580a4fb5bc5981ba5.
41 See PRESIDENT DONALD J. TRUMP IS WORKING TO PROTECT STUDENTS FROM SEXUAL MISCONDUCT AND RESTORE FAIRNESS AND DUE PROCESS TO OUR CAMPUSES (white paper), U.S. Department of Education, https://www.ed.gov/sites/ed/files/about/offices/list/ocr/docs/titleix-fact-sheet.pdf.
42 Elissa Nadworny, Feds Offer Students New Protections Against Programs That Lead to High Debt, Low Pay, NPR (Sept. 28, 2023), https://www.npr.org/2023/09/28/1202291883/for-profit-colleges-student-loans-affordable.
43 Students Charge Donald Trump with Racketeering in “University” Scheme, The National Trial Lawyers, https://thenationaltriallawyers.org/article/trump-racketeering/.
44 Danielle Ivory, Erica L. Green, Steve Eder, Education Department Unwinds Unit Investigating Fraud at For-Profits, New York Times (May 13, 2018), https://www.nytimes.com/2018/05/13/business/education-department-for-profit-colleges.html.
45 The fate of America’s for-profit colleges hinges on the election, The Economist (Aug. 29, 2024), https://www.economist.com/united-states/2024/08/29/the-education-business.
46 College Presidents to Answer for Mishandling of Antisemitic, Violent Protests, Committee on Education & the Workforce (Nov. 28, 2023), https://edworkforce.house.gov/news/documentsingle.aspx?DocumentID=409778#:~:text=On%20Tuesday%2C%20December%205%2C%20at,Leaders%20Accountable%20and%20Confronting%20Antisemitism.%E2%80%9D.
47 Stephanie Saul et al., Penn’s Leadership Resigns Amid Controversies Over Antisemitism, New York Times (Dec. 9, 2023), https://www.nytimes.com/2023/12/09/us/university-of-pennsylvania-president-resigns.html.
48 See Tim Shaw, Republican Bill Would Raise Tax on University Endowments, Thomson Reuters (Sept. 23, 2022), https://tax.thomsonreuters.com/news/republican-bill-would-raise-tax-on-university-endowments/.
49 See H.R. 8707, Dismantle DEI Act of 2024, https://www.congress.gov/bill/118th-congress/house-bill/8706.
50 Mary Whitfill Roeloffs, Will Trump Eliminate the Department of Education? What to Know as Linda McMahon Picked to Lead Agency, Forbes (Nov. 20, 2024), https://www.forbes.com/sites/maryroeloffs/2024/11/20/will-trump-eliminate-the-department-of-education-what-to-know-as-linda-mcmahon-picked-to-lead-agency/.
51 Sara Randazzo and Matt Barnum, Trump to Nominate Linda McMahon to Lead Education Department, Wall St. J. (Nov. 19, 2024), https://www.wsj.com/politics/policy/trump-to-nominate-linda-mcmahon-to-lead-education-department-33e3e095.
52 See Mary Whitfill Roeloffs, Will Trump Eliminate the Department of Education? What to Know as Linda McMahon Picked to Lead Agency, Forbes (Nov. 20, 2024), https://www.forbes.com/sites/maryroeloffs/2024/11/20/will-trump-eliminate-the-department-of-education-what-to-know-as-linda-mcmahon-picked-to-lead-agency/.
53 Rounds Introduces Legislation to Eliminate U.S. Department of Education¸ Mike Rounds: US Senator for South Dakota (Nov. 21, 2024), https://www.rounds.senate.gov/newsroom/press-releases/rounds-introduces-legislation-to-eliminate-us-department-of-education.
54 Id.
55 Anti-white bias on college campuses was the topic of a sharply divided Fifth Circuit en banc opinion in November 2024. https://www.law360.com/articles/2261000/split-5th-circ-axes-student-s-bias-suit-over-right-wing-beliefs
56 Liz Essley Whyte, The Trump NIH Pick Who Wants to Take on ‘Cancel Culture’ Colleges, Wall St. J. (Dec. 6, 2024), https://www.wsj.com/health/healthcare/jay-bhattacharya-national-institute-health-grants-cancel-culture-645101f5?st=hJb6HX.
57 Id.
