Austerity Strikes Sweep Across Europe (WSJ) Unions in Spain, Portugal and Greece went on strike Wednesday to protest government austerity plans amid a wide economic contraction across Europe's periphery, but questions remained about the unions' ability to influence economic policy. The general strike led to minor violent incidents in Spain, even though morning business activity seemed to remain relatively normal. Spain's government said 32 people had been arrested since midnight, and national TV showed small clashes with police, as well as rallies held by union members in transportation hubs like train and subway stations. The Spanish unions are protesting austerity cuts and an unemployment rate at 25% of the workforce. Geithner Warns Against Delaying Solution to US Fiscal Crisis (Reuters) With lawmakers and the White House bickering over how to put the country on a sustainable fiscal path, a number of lawmakers and think tanks have argued for more time. "That will leave all the uncertainty you don't like on the table," Geithner said at an event sponsored by the Wall Street Journal in his first public comments on the looming fiscal crisis since President Barack Obama won re-election last week. Facebook Investors Brace For Big Round Of Unlocked Shares (Bloomberg) Restrictions lift today on 804 million shares held by former employees and those who sold at the initial public offering, almost doubling the total available for trading, according to a regulatory filing. Geithner’s Money Fund Overhaul Push Sparks New Opposition (Bloomberg) Geithner, heading a Washington meeting of the Financial Stability Oversight Council, a group formed by the Dodd-Frank Act to address systemic financial risks, won unanimous approval for a draft recommendation to the SEC spelling out three ways to overhaul the $2.6 trillion industry. A new option would require capital buffers of as much as 3 percent of assets, while two other solutions he offered were opposed earlier by the fund industry and rejected in August by an SEC majority. Representatives for the fund industry, who last month put forth their own plan, immediately denounced the proposals as stale and unhelpful. While Geithner has said the SEC is best positioned to address money funds, he has also said that the regulators’ panel, often referred to as FSOC, might intervene and subject funds to oversight by the Federal Reserve if the SEC fails to act. SEC Expands Knight Probe (WSJ) The Securities and Exchange Commission has deepened its probe into whetherKnight Capital Group Inc. did enough to police its trading systems before computer errors nearly destroyed the brokerage. The inquiry, which began after Knight's errant Aug. 1 trades saddled it with more than $450 million in losses, initially focused more narrowly on what caused the errors. The probe has broadened to look further at the company's risk-control procedures and Knight's compliance with a rule implemented last year—called the market-access rule—that requires brokerages to guard against these sorts of problems, say people familiar with the investigation. Blankfein Warns Over Cuts (FT) The financial industry should not go “overboard” in cutting costs in reaction to current market conditions, the chief executive of Goldman Sachs said yesterday. “Our industry has a long history of letting too many people go at the bottom of the cycle and hiring too many at the top,” Mr. Blankfein told an industry conference in New York. Pepsi's New Fat Blocking Soda Unleashed On Japanese Consumers (Forbes) Up until recently, soda manufacturers have at least tacitly acknowledged that their carbonated swills aren’t healthy options. Up until recently. [Then] yesterday, Pepsi-Cola in Japan launched a fiber-infused iteration of its cola drink. According to Suntory, the sole distributor of Pepsi in Japan, the beverage contains “indigestible dextrin,” more commonly known as dietary fiber. This magic ingredient, Suntory’s website claims, helps reduce the amount of fat that’s absorbed into the body, hence the tagline of the new drink as a “fat-blocking soda.” Suntory also proffers that the drink quells the rise in triglycerides in the blood that normally follows a meal. Rochdale May Be At The End Of Its Rope (NYP) Stamford, Conn.-based Rochdale Securities is struggling to secure a deep-pocketed buyer three weeks after a former trader, identified as David Miller, saddled the firm with $1 billion in “unauthorized” Apple trades that it wasn’t able to cover. CEO Dan Crowley has been working around the clock to identify a “white knight” willing to save the 55-person broker dealer, according to sources. But staffers of the 37-year old firm worry ongoing investigations will turn off suitors and impede the firm’s ability to operate as a broker dealer. BNY Mellon Unit Settles Madoff Suits (WSJ) The Ivy Asset Management unit will pay $210 million to resolve a series of lawsuits claiming that it concealed doubts about the business operated by convicted Ponzi schemer Bernard L. Madoff. Shareholders To Citi: Break This Company Up (AP) Trillium Asset Management, a shareholder advisory firm with more than $1 billion in assets under management, effectively renewed call made recently by Sandy Weill, Citigroup’s former CEO and one of the founding fathers of the “financial supermarket” concept that helped turn Citi into a global banking behemoth. Siewert In Line For Goldman Partnership (NYP) Hired only last March, Richard “Jake” Siewert, the head of corporate communications, could be among the 70 or so new partners the 144-year-old bank is set to announce this morning...Siewert’s predecessor, Lucas Van Praag, made partner in 2006 — five years after joining the firm. Paula Broadwell Warned Gen. Allen Against "Seductress" Jill Kelley (CBS) A senior official has told CBS News correspondent David Martin the vast majority of the emails between Allen and Tampa socialite Jill Kelley were "completely innocuous," and the general believes many of the 20-30,000 pages under scrutiny are duplicates. The official said that in some of the emails, Kelley would say things like, "saw you on television and you were terrific," and Allen would write back with "thanks, sweetheart." The official said the two never discussed sex and that Allen had never been alone with Kelley. Nonetheless, CBS News correspondent Bob Orr says Pentagon and FBI sources describe the communications as "potentially inappropriate" and "flirtatious," and another source says they were likely more than just innocent exchanges -- noting that the Pentagon's Inspector General is involved for a reason. Among the hundreds of emails exchanged between Allen and Kelly - Orr reports that investigators are focusing on one from several months ago. In it, Allen told Kelley he'd just received an anonymous email warning him to stay away from her. Sources say that the anonymous email came from Broadwell, Petraeus' mistress, who allegedly warned Gen. Allen that Kelley was "a seductress." Broadwell allegedly sent similar warnings to other military officers at the U.S. Central Command, located near Kelley's Tampa home. Broadwell, who had been out of sight since the scandal emerged on Friday, was spotted Tuesday night preparing dinner and drinking a glass of wine inside her brother's Washington home.

Barney Frank cries foul in government's lawsuit against JPMorgan (Reuters) Democratic Congressman Barney Frank defended the largest U.S. bank on Monday, saying in a statement that the government was wrong to go after JPMorgan Chase & Co for the alleged misdeeds of Bear Stearns. Frank, who served as chairman of the House Financial Services Committee during the Bear Stearns acquisition, said federal and state officials should reconsider holding financial firms liable for the wrongdoing of institutions they absorbed at the government's urging. "The decision now to prosecute J.P. Morgan Chase because of activities undertaken by Bear Stearns before the takeover unfortunately fits the description of allowing no good deed to go unpunished," said Frank, who was also the co-author of the 2010 Dodd-Frank financial reform law. New York Attorney General Eric Schneiderman sued JPMorgan, the nation's largest bank by assets, on October 1 over mortgage-backed securities packaged and sold by Bear Stearns. Hedge Funds Hot For Ailing Greece's Debt (WSJ) Ever since Greece completed a debt restructuring in March that turned €200 billion in bonds into about €60 billion, distressed-debt investors—many at U.S. hedge funds—have been picking them over. Hedge-fund analysts have flooded Greek finance officials with requests for information. Prices have climbed. Third Point LLC, based in New York, crowed about Greece in its investor letter earlier this month, citing the resilience of the bonds of fellow bailout-recipient Portugal. "We expected Greece to keep its head up and undergo a similar metamorphosis," the letter said. Ever since Greece completed a debt restructuring in March that turned €200 billion in bonds into about €60 billion, distressed-debt investors—many at U.S. hedge funds—have been picking them over. Hedge-fund analysts have flooded Greek finance officials with requests for information. Prices have climbed. Third Point LLC, based in New York, crowed about Greece in its investor letter earlier this month, citing the resilience of the bonds of fellow bailout-recipient Portugal. "We expected Greece to keep its head up and undergo a similar metamorphosis," the letter said. Billionaire Wilbur Ross Interested In Buying Spanish Bank Assets (Bloomberg) Ross’s WL Ross & Co., which holds about 10 percent of Bank of Ireland and teamed up with Richard Branson to buy part of Northern Rock Plc, is in talks “almost every week” with representatives of the large Spanish banks, he said in an interview in Abu Dhabi, without naming potential targets. “Maybe next year will be the year for Spain,” he said. “We’ve been doing a lot of work in Spain. We’ve put a lot of time and effort into Spain but haven’t put any money in yet.” Doom Heralded at Hayman by Widening Trade Deficit (Bloomberg) Japan’s worsening trade gap will make it harder to service the world’s largest debt, fulfilling part of the doomsday scenario that Hayman Capital Management LP is betting on. The nation’s 10-year note yield may rise toward 10 percent from the world’s third-lowest of 0.79 percent, while the yen weakens, said Richard Howard, who oversees Dallas, Texas-based Hayman’s Japan-focused fund with J. Kyle Bass. That would represent the developed world’s second-highest borrowing costs after Greece, and a surge to that level by the end of 2013 would cause losses of 42 percent for investors purchasing the securities now, data compiled by Bloomberg show. Regulators Crash Over Volcker Definitions (WSJ) The SEC and a trio of banking regulators are butting heads over how to define the buying and selling of securities on behalf of clients, known as market-making, as well as over banks' ability to invest in outside investment vehicles such as hedge funds, according to officials close to the discussions. Since brokers, which are overseen by the SEC, conduct market-making activities, the SEC is pushing for more influence over the issue, these people said. Police: Woman fakes her own kidnapping to get day off work (WOAI) An officer on patrol went to check out a car parked near Ray Ellison and Five Palms around 6:30 p.m. on October 10th. When the officer looked inside the car, he spotted 48-year-old Sheila Bailey Eubank bound with rope. An arrest warrant affidavit states Eubank told police a man jumped into her car around 6:15 a.m. while she was at a Security Service Federal Credit Union ATM near Loop 1604 and Bandera Road. Eubank said the man held her an knife point and forced her to drive him to various locations for what she believed were drug deals. She told officers he then assaulted her, tried to choke her with a rope, and then tied her up and left her in her car. However, officers discovered a lottery ticket in Eubank's purse that was purchased that day during the hours she claimed she was being held. Investigators reviewed surveillance video from the store where the lottery ticket was purchased and found out she had entered the store by herself and appeared "healthy, unhurried, and pleasant with the clerk." Investigators then reviewed video from the Security Service Federal Credit Union where Eubank claimed she was abducted. The video showed withdrawing money from the motor ATM, but there were no signs that anyone else was with her. Police say when Eubank was confronted by investigators, she eventually admitted her story was false and that she simply wanted a day off from work and wanted attention. BofA CEO Moynihan Declares Victory Over Capital Doubters (Bloomberg) Bank of America now has the “top capital” among peers and is capable of paying a bigger dividend, said Chief Executive Officer Brian T. Moynihan. The bank has fulfilled a goal Moynihan drilled into subordinates since his first day on the job: building a “fortress balance sheet,” he said in an Oct. 17 staff meeting at the company’s Charlotte, North Carolina headquarters. “We’re going to officially declare victory on one of those operating principles,” Moynihan said in the town-hall style meeting. “The reason why is, we have the top capital in the industry, the top liquidity in the industry.” People have stopped asking if the bank needs more funds to absorb losses and now want to know when investors will get the excess, he said. Word-Smith: Greg's Book Has 0 Sachs Appeal (NYP) Among the mistakes in the book, sources noted, was Smith’s description of a town-hall meeting last year hosted by Goldman’s co-heads of investment banking — South African Richard Gnodde and Michael “Woody” Sherwood...Smith said one question from a Goldman employee during the 2011 meeting was: “What is the firm doing to address the fact that the culture is dying and our reputation is deteriorating?” According to Goldman, a female referenced in Smith’s book as a “power-hungry” managing director — identified as “Georgette” — was the individual who posed the question about culture. Georgette presented the question as: How is the firm addressing “the perception of the deteriorating culture,” according to a recording of the event, reviewed yesterday by The Post. Smith also writes about a follow-up question demanding “what specifically” the bank was doing — and that it was followed with uncomfortable laughter before some fumbling about over which executive should field the query. There was no follow-up question in the recording of the meeting. Smith embellished that aspect of the book and omitted that “Georgette” — a woman whom Smith worked with and dubbed the “Black Widow” for her cutthroat manner — was the source of the question about values because it undermined his narrative, a source inside the company said. Low Rates Pummel Bank Profits (WSJ) "The longer the Fed stays down at these levels the more it will hurt banks," said Scott Lied, the chief financial officer of ENB Financial Corp, an Ephrata, Pa., institution that has eight branches and 225 employees. "It's painful." Gupta Sentencing Set For Tomorrow (NYP) Prosecutors say Gupta, convicted by a jury in June, deserves as long as 10 years in prison. Gupta seeks probation. Gary Naftalis, a lawyer for Gupta, argued his client’s crime was an “aberrational” event in a “lifetime of good works” that merited a punishment for a man who has suffered an extraordinary fall from grace. He asked Rakoff to impose a term of community service, suggesting Gupta work with troubled youth in New York or with the poor in Rwanda. Theater Thief Costs Movie-Goers Tens of Thousands In Credit Card Fraud (Courant) A man who may have stolen as much as $70,000 a week by slithering beneath theater seats while movies were playing and lifting credit cards from women's' pocketbooks was convicted Monday of fraud and identity theft crimes. Anthony Johnson, 49, and a string of accomplices used the stolen cards to collect thousands of dollars in cash advances from Connecticut's gambling casinos and to make tens of thousands of dollars more in retail purchases in Connecticut and elsewhere, authorities said. On a "good" weekend, Johnson collected $50,000 to $70,000 from the scheme, one of his accomplices testified last week at his trial at U.S. District Court in Hartford. He had to settle for $30,000 or $40,000 on a bad weekend, the accomplice said. The accomplice, who agreed to cooperate with authorities, said Johnson, of Philadelphia, typically worked with women accomplices. They bought tickets to motion pictures likely to be popular with female audiences and chose seats from which they could watch how women in the audience stored their pocketbooks. "Once the movie started, Johnson crawled on the floor, removed credit cards from the stored purses, and returned the wallet to the purses," according to an FBI affidavit. "Johnson crawled in this manner around the theater until he was done…"

JPMorgan Rankled By Risk (WSJ) JPMorgan is seeking to reduce its risks in a business that provides crucial plumbing for Wall Street's money flows. The nation's largest bank by assets, a major player in providing clearing and settlement services to other financial firms, is reviewing its dealings with dozens of brokerages that use the bank to settle trades, according to people familiar with the bank. Clearing and settlement involves standing between buyers and sellers of securities to help manage financial commitments backing hundreds of billions of dollars in transactions daily. J.P. Morgan's review, which started more than six months ago amid increased regulations, effectively seeks to assess the profits clients generate for the bank versus risks they pose, the people say. Spain Unveils Financial Reforms (WSJ) This reform fulfills the commitments made by Spain as part of a €100 billion European Union bailout for Spanish banks agreed in July. As anticipated in the bailout deal, Spain is creating an asset management company, or "bad bank," that will buy property assets from banks starting later this year at prices below book value. Euro Faces Judgment Days (WSJ) The euro zone has seen many pivotal moments since its debt crisis emerged in Greece in early 2010. But there are reasons to think this fall's events are especially vital. With Spain and Greece on the ropes, European officials face stark choices. Nomura Plans $1 Billion In Cost Cuts (WSJ) The cost cuts were unveiled Friday by Nomura's new chief executive, Koji Nagai, when he presented the blueprint for a revamped business strategy at a meeting of 450 senior branch managers, according to Nomura executives who briefed reporters on what was said. They follow another $1 billion in wholesale cost reductions the broker just finished implementing earlier this year. Shia LaBeouf 'Sent Director Sex Tapes To Get New Film Role' (Entertainment) When Shia LaBeouf took a role in Lars von Trier's latest movie 'Nymphomaniac' eyebrows were raised due to the director's previous experimentation with putting real sex on film. Until now it seemed that LaBeouf took an occupational risk in joining the movie, but if the actor's to be believed then he actively looked out for a sexed up role, and involved girlfriend Karolyn Pho...The 'Lawless' actor told Handler: "I sent him [von Trier] videotapes of me and my girlfriend having sex and that's how I got the job." French Minister: No Contradiction in 75% Tax Rate and Attracting Business (CNBC) Responding to claims that the introduction of higher tax rate could be an obstacle to business and investment in France, Moscovici echoed the French President and Prime Minister who have said that the tax was part of a “shared effort” to lead France back to positive growth. ECB Said To Use Greek Myth For Security On New Euro Banknotes (Bloomberg) The European Central Bank is using an image from Greek mythology to improve security on new euro banknotes, four people familiar with the design said, even as Greece’s near bankruptcy fuels a debt crisis that’s threatening the future of the common currency. Europa, the Phoenician princess abducted by Zeus who gave the continent its name, will replace architectural images as the watermark on the new notes, which the ECB wants to start rolling out next year, said the people, who spoke on condition of anonymity because the plans aren’t public yet. Barclays Marathon Man CEO Everything Bob Diamond Was Not (Bloomberg) “In Jenkins you’ve got the archetypal English CEO who is seen as rather safe, compared with the typically aggressive U.S. investment banker that was Bob Diamond,” said Alan Beaney, who helps manage 200 million pounds ($315 million), including Barclays shares, at RC Brown Investment Management Plc in Bristol, England. “His appointment signals that the bank is not going to be as brazen as it has been in the past.” Garlic knot beating in Vero Beach sends man with 'Fat Boy' tattoo to slammer, report shows (TCP) A man on Aug. 19 told Indian River County Sheriff's deputies he was a pizza delivery person and was taking pizza to an address in the 400 block of 9th Street Southwest in Vero Beach. The pizza deliverer said when he got there, Robert Wheeler, 48, was waiting for him outside. The pizza deliverer said that when he lowered his window, Wheeler asked him who he spoke with on the phone before punching him in the face. The pizza deliverer said Wheeler punched him "because he forgot the garlic knots." Wheeler then instructed him to "give that to the person working on the phone back at the restaurant." Wheeler, who has the word "fat" tattooed on his left arm and "boy" on his right, told investigators he hit the pizza delivery person in the face. But, he said the issue was money he said the restaurant owed him -- not forgotten garlic knots.

Fed Governor: Put Cap On Big Financial Firms (WSJ) In a Philadelphia speech, Fed governor Daniel Tarullo recommended curbing banks' growth by putting a limit on their nondeposit liabilities, which are sources of funding for operations that go beyond consumer deposits. The idea takes direct aim at the biggest U.S. banks, including J.P. Morgan, Bank of America, Goldman Sachs, and Citigroup, all of which rely heavily on such funding. Firms outside of this tier make much greater use of regular deposits. With Tapes, Authorities Build Criminal Case Over JPMorgan Loss (Dealbook) Federal authorities are using taped phone conversations to build criminal cases related to the multibillion-dollar trading loss at JPMorgan Chase, focusing on calls in which employees openly discussed how to value the troubled bets in a favorable way. Investigators are looking into the actions of four people who previously worked for the team based in London responsible for the $6 billion loss, according to officials briefed on the case. The Federal Bureau of Investigation could make some arrests in the next several months, said one person who spoke on the condition of anonymity because the inquiry was ongoing. The phone recordings, which were turned over to authorities by JPMorgan, have helped focus the investigation, the officials said. Authorities are poring over thousands of conversations, in English and French. They are also relying on notes that employees took during staff meetings, instant messages circulated among traders and e-mails sent within the group. Cyber Slips Boost Facebook's Ad Clicks (NYP) Facebook is suffering from fat-finger syndrome. That’s the opinion of one influential Wall Street analyst — bolstered by a growing body of research — who believes that some of the company’s recently touted mobile ad performance can be chalked up to accidental or fraudulent clicks. “Fat fingers” — when people click on an ad as they’re trying to click on something else — is an issue across the mobile Web as users try to navigate smaller screens, according to BTIG analyst Richard Greenfield. “People don’t have trouble with a mouse or touch pads,” Greenfield said yesterday. “But on mobile, when you’re gliding through on a touch screen, everything is touchable, and a lot of mistakes are happening.” JPMorgan CFO To Exit Post (WSJ) JPMorgan's chief financial officer is expected to step down over the next two quarters and is likely to move into a different job at the bank, people close to the company say. Douglas Braunstein, 51 years old, has been finance chief at the largest U.S. bank, by assets, since 2010. Before that, the longtime deal maker ran J.P. Morgan's investment-banking operations in North and South America and was heavily involved in the bank's acquisitions of securities firm Bear Stearns Cos. and the failed banking operations of Washington Mutual. Mr. Braunstein's status was diminished as part of an executive shake-up in July. Since then, he has reported to Matt Zames, 41, the company's co-chief operating officer, rather than Chairman and Chief Executive James Dimon. It isn't clear where Mr. Braunstein will decide to go within the bank, but the possibilities include J.P. Morgan's recently combined corporate and investment bank, these people said. He is expected to make his decision over the next quarter or two. Spain Lowers Rating On S&P (WSJ) The ratings company warned Wednesday that Spain's creditworthiness might continue to deteriorate as Madrid struggles to close a yawning budget gap, and said the Spanish government's "hesitation" to request a bailout from the European Union is "potentially raising the downside risks to Spain's rating." Brazil Cuts Rate for Tenth Straight Time to Bolster Recovery (Reuters) Brazil cut its benchmark interest rate for the tenth straight time to 7.25 percent on Wednesday, injecting extra stimulus into a languid recovery threatened by a worsening global economy. TSA screener accused of intentionally slapping flier's testicles (DJ) "A bulky young TSA agent came over to pat me down," Steven DeForest told the Huffington Post. "He told me to turn around. He was using his command voice, barking orders. I told him that I wasn't comfortable turning away from my luggage, which had already been screened, and wanted to keep it in my sight." According to deForest, the screener knelt down to begin the pat-down procedure before making a shocking move. "As he raised his hands he was looking at me. Then he gave a quick flick and smacked me in one of my testicles," deForest said. The episode left deForest in a state of "humiliation, rage, and frustration," according to the report. DeForest believes the agent slapped his gentials as punishment for refusing to enter the backscatter x-ray machine. "I was deliberately assaulted by someone who knew that he could get away with it," he stated. While the motives of the TSA screener cannot be confirmed, other agents have already admitted to performing invasive pat downs in order to force air travelers to choose the body scanners instead. JPMorgan's Dimon hits back at government over Bear Stearns suit (Bloomberg) During a wide-ranging hour-long discussion that went from the "fiscal cliff" to the impact of regulations, Dimon bristled when a member of the audience asked him if he now regretted participating with the government to rescue Bear Stearns in light of the lawsuit. "We didn't participate with the Federal Reserve, OK?" he said. "Let's get this one exactly right. We were asked to do it. We did it at great risk to ourselves ... Would I have done Bear Stearns again knowing what I know today? It's real close." Dimon went on to recount how he warned a senior regulator at the time of the deal to "please take into consideration when you want to come after us down the road for something that Bear Stearns did, that JPMorgan was asked to do this by the federal government." He added that JPMorgan, which will report its third-quarter earnings on Friday, will come out fine in the end. But if he is ever put in a similar position again, he said he "wouldn't do it." "I'm a big boy. I'll survive," he said. "But I think the government should think twice before they punish business every single time things go wrong." Australians World’s Wealthiest on Housing, Credit Suisse Says (Bloomberg) Australians have the world’s highest median worth and the Asia-Pacific topped Europe as the largest wealth-holding region, according to Credit Suisse. Australians have a median wealth per adult of $193,653, the Credit Suisse global wealth report showed, the highest of 216 countries surveyed. With plentiful land, sparse population, natural resources and high home prices, Australia’s proportion of individuals with wealth above $100,000 is the most of any country and eight times the world average, the report said. USADA says Lance Armstrong's Postal Service cycling team 'ran the most sophisticated, professionalized and successful doping program that sport has ever seen' (NYDN) The report describes an underground network of support staff -- smugglers, dope doctors, drug runners -- who kept Armstrong's illicit program in business. “The evidence is overwhelming that Lance Armstrong did not just use performance-enhancing drugs, he supplied them to his teammates,” USADA says of the embattled cyclist and cancer survivor. “He did not merely go alone to Dr. Michele Ferrari for doping advice, he expected that others would follow,” the report continued, referring to the physician who was banned by USADA for his role in cycling’s steroid scandal. Eleven former Armstrong teammates provided testimony against Armstrong, including respected veteran cyclist George Hincapie, whom Armstrong has described as his "best bro" in the peloton and competed with Armstrong during each of his Tour de France victories. “It was not enough that his teammates give maximum effort on the bike, he also required that they adhere to the doping program outlined for them or be replaced. He was not just part of the doping culture of his team, he enforced it and re-enforced it. Armstrong’s use of drugs was extensive, and the doping program on his team, designed in large part to benefit Armstrong, was massive and pervasive.”