[Ip-health] JAPAN G8 PAPER FROM GLAXOSMITHKLINE

[Peter Chowla]

Dear ip-health,

In July, 2008, the G8 will meet in Japan.  The following is the paper
distributed by GSK to governments. I thought it might be of some interest
to people on this list.

Best regards,

Peter Chowla


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JAPAN G8 PAPER FROM GLAXOSMITHKLINE

GSK welcomes the focus the Government of Japan has put on the key themes
of the World Economy and Development and Africa as part of its
chairmanship of the G8 during 2008. The research-based pharmaceutical
and bioscience industry has a key role to play in supporting progress on
these two vital themes and GSK looks forward to working in partnership
with the international community in helping deliver concrete progress on
both issues.

This paper sets out a number of areas where the G8 can make a difference
in both the developed and developing world.  It is split into two
sections reflecting Japan=92s key themes and focuses on issues that could
be usefully addressed by the G8.

The main points of this paper are:

On the World Economy, the G8 can:

Mitigate the economic cost of an influenza pandemic to the world economy
by putting in place a global pandemic plan which ensures adequate
medical provisions are in place each G8 country and undertakes not to
close borders automatically in the event of a pandemic. The benefit, if
any, of closing borders would be massively outweighed by the cost. Such
a pandemic plan and corresponding open-border agreement will strengthen
business confidence and ensure global supply chains remain open which in
turn will reduce the likely economic impact of a pandemic.

Ensure a strong and vibrant economic environment which encourages
innovation by (1) supporting harmonisation of Data Exclusivity periods
to 10 years and ensuring that, even after the period of exclusivity, the
data remains confidential, even though other companies can refer to it
(2) ensuring that discussions on the Convention of Biological Diversity
(CBD) and the WHO Intergovernmental Working Group (IGWG) on Public
Health, Innovation and Intellectual Property do not reduce incentives to
carry out research and development and (3) preserving effective minimum
international standards of IP protection by ensuring appropriate use of
TRIPs flexibilities.

Continue to ensure that the threats from counterfeiting, in all parts of
the world, are recognised and that appropriate early warning mechanisms
and enforcement programmes are put in place in both =93source=94 and
=93recipient=94 countries, that they are adequately funded, and that
counterfeiters face penalties which act as real disincentives.

On Development and Africa, the G8 can:

Ensure that an holistic approach to managing the challenges of HIV/AIDS
is adopted by all partners.

Ensure that the world=92s poorest countries are able to respond to the
challenges of a potential influenza pandemic by putting in place a
global pandemic plan which addresses their needs and vulnerabilities.

Look at ways of ensuring the long-term sustainable funding of promising
Public-Private Partnerships (PPPs) that have been established for R&D
into diseases that disproportionately affect developing countries.

Look at creative ways of financing vaccines for the developing world, in
particular making sure that Advanced Market Commitments (AMCs) are
designed in such a way that provides appropriate risk sharing, greater
clarity and greater sustainability, especially with respect to demand.

Design and put in place an Advanced Purchase Agreement (APA) for malaria
vaccine so that as soon as vaccines are licensed (potentially from 2011)
vaccination can start without delay.

Establish a programme of technical assistance to build clinical
expertise in developing countries.

Ensure that local taxes and tariffs on medicines in developing countries
are removed, thereby increasing affordability.


SECTION 1: THE WORLD ECONOMY


1.1  MITIGATING THE ECONOMIC COST OF A POTENTIAL INFLUENZA PANDEMIC

Using the evidence from SARS, in which there was an immediate economic
loss of around 2% of East Asian GDP, the World Bank has estimated that
an influenza pandemic could result in a downturn in the world economy of
$800 billion in one year. This estimate could be very conservative, as a
pandemic would lead to a downturn in world trade more severe than that
caused by SARS, which was concentrated in one region. According to
Oxford Economic Forecasting, taking the downturn in world trade into
account, a pandemic could result in the loss of 4-5% of world GDP,
equivalent to $1,500 to $2,000 billion.

One of the biggest risks will be if governments start to close borders.
This will severely hamper global supply chains. Not only will this mean
that the production and distribution of medicines and vaccines will be
severely compromised; it will also undermine business confidence and
therefore increase significantly the likelihood of greater economic
damage.

The G8 could:

Mitigate the economic cost of an influenza pandemic to the world economy
by ensuring adequate medical provisions are in place in each G8 country
and by putting in place an international agreement which ensures that
during a pandemic governments will not close borders automatically since
the benefit, if any, will be massively outweighed by the cost. Such an
agreement will strengthen business confidence and ensure global supply
chains remain open which in turn will reduce the likely economic impact
of a pandemic.


1.2  A STRONG AND VIBRANT ECONOMIC ENVIRONMENT WHICH ENCOURAGES
INNOVATION

Research and development into new medicines and vaccines is an essential
response to unmet medical need and to the challenge of increasing
resistance to some products.  Innovative medicines contribute enormous
social benefits and reassurance for individual citizens through improved
healthcare - as seen in increased life expectancy and the treatment of
cancer, diabetes, asthma and other diseases. Pharmaceuticals also
contribute to economic efficiency and competitiveness for society.
Innovative medicines deliver healthy working populations able to work
longer and healthier elderly populations making fewer demands upon
social security systems; and they enable more efficient use of
healthcare budgets. The pharmaceuticals sector provides substantial
investment in research and development, leading to high quality jobs for
science graduates, unrivalled job multiplier benefits, and support for
the academic research community.

A strong IP system is necessary to provide incentives for the high risk
and high cost of developing new medicines and vaccines. It creates the
conditions under which industry can generate the returns needed to fund
R&D, including for diseases that disproportionately affect the
developing world. Strong global IP rights drive innovation and
investment and ensure a level playing field between developed and
developing countries, to the benefit of economies and patients around
the world.

It is therefore important that the G8 promotes and protects a balanced
IP framework.




Data Exclusivity

The research-based pharmaceutical industry is virtually unique in being
required to provide significant amounts of confidential test data (such
as preclinical and clinical data) to regulatory authorities as part of
the product registration process. Data Exclusivity recognises the
proprietary nature of this data by ensuring that it is not referred to
by other companies (for a defined period) when they are registering
their products and, even after that defined period, it remains
confidential. This protection provides incentives for the substantial
financial investment involved in generating the data in the first
instance. Data Exclusivity is of particular significance where patent
protection for a particular product or indication may not be available
or where the patent has been eroded by a long development phase. The
level of Data Exclusivity varies greatly across the G8 and other
countries, and GSK believes that a more harmonised approach, in which
all G8 countries have 10 years of Data Exclusivity, would further
incentivise R&D.


Convention on Biological Diversity (CBD)

GSK supports the CBD=92s role in providing a framework for the
conservation of biological diversity and the sustainable use of its
components. GSK also supports the CBD objective =93to provide fair and
equitable sharing of the benefits arising from the use of genetic
resources=94.

However, given the diversity of biological materials and the many ways
in which they are used in research and development, it is not possible
to generalise as to the role they play in biomedical research or the
fundamental value of any particular material to any particular project
or product.

A careful balance therefore needs to be struck in seeking to define,
implement and monitor appropriate access to genetic resources and the
sharing of benefits arising from their use. Go too far one way, and
society risks damaging the search for medicines and vaccines to treat
and cure diseases like HIV/AIDS, cancer, malaria and pandemic influenza.
Go too far the other way, and the legitimate interests of countries and
communities from where the genetic resources were sourced can be
undermined.

In GSK=92s opinion, the best way of achieving the CBD=92s access and
benefit-sharing (ABS) objectives is for countries to introduce national
laws governing access to their genetic resources and for mutually agreed
contracts to define how any benefits arising from their use should be
shared.  This approach allows national governments the flexibility to
determine what guidelines will best serve their national interests, and
gives users the opportunity to reach agreements which are appropriate to
each particular case.

In this respect, GSK broadly supports the Bonn Guidelines of 2002, which
advise governments on how to set fair and practical ABS conditions (we
do not, however, share the Bonn Guidelines support for disclosure
obligations in patents). We believe that once countries have adopted
local laws reflecting this advice, they will receive the protection and
compensation envisaged under the CBD.

Notwithstanding GSK=92s support for national legislation and contracts
based on the Bonn Guidelines, we recognise the CBD=92s mandate to
=93elaborate and negotiate an International Regime on access and
benefit-sharing=94. However, we do not accept the need to use patent law,
in the form of a disclosure requirement in patent applications, to help
facilitate access and benefit-sharing. The legal and commercial
uncertainties associated with a disclosure requirement would
significantly reduce incentives to develop products which in any way
involve =93genetic resources=94.  This could lead to a reduction in
innovation (and the societal benefits that arise from it) as well as the
benefits to be shared (ie. a key objective of the CBD).

GSK also believes that pathogens and their derivatives, such as
influenza viruses, should be excluded from the International Regime
under discussion. The CBD was designed to preserve biodiversity.
Pathogens are organisms which the world would be better off without.


The Intergovernmental Working Group on Public Health, Innovation and
Intellectual Property

In May 2006 the World Health Assembly (WHA) asked the WHO to establish
an Intergovernmental Working Group on Public Health, Innovation and
Intellectual Property (IGWG).  The Working Group's mandate was to
prepare a global strategy and plan of action related to =93the growing
burden of diseases and conditions that disproportionately affect the
developing countries, and particularly women and children=94. The
resulting global strategy and plan of action is due to be presented to
the WHA in May 2008.

GSK supports efforts to stimulate increased research into diseases of
the developing world. However the discussion within IGWG is being
largely driven by ideological positions whose primary motive appears to
be to weaken intellectual property rather than to develop concrete
proposals to increase research for the developing world. A number of
commentators are promoting unproven and possibly counterproductive
proposals such as patent pools and prize based mechanisms. Such
proposals should be treated with extreme caution as they could
significantly reduce the incentives to carry out research and
development and hence the total amount invested in R&D when more, not
less, research is needed.

GSK supports the focus of the IGWG on diseases that disproportionately
affect developing countries. Going beyond this mandate and looking at
other diseases is unnecessary, a waste of scarce WHO resources, and
detrimental to moving this process forward. GSK would therefore urge the
G8 to work to ensure that implementation of the IGWG strategy and plan
of action focuses on diseases that disproportionately affect developing
countries and do not reduce incentives to carry out research and
development. New initiatives must complement the existing IP-based
system and must be voluntary.


Preserving effective minimum international standards of IP protection

The international IP system has become a touchstone for concerns about
the impact of globalisation. Some of those concerns are
well-intentioned; others are deliberately aimed at undermining the
system of global free trade.  The net result is that global IP is under
threat in a number of fora.

However, international standards of IP protection are not just tools for
developed world businesses. If appropriately tailored, they are good for
development as well. IP protection encourages local businesses in the
developing world to invest in innovation without fear of free riding by
competitors. It also encourages developed world businesses to enter into
partnerships and collaborations with local businesses elsewhere and to
invest in their markets.

Within the context of the access to medicines debate, patents should not
be condemned as key barrier to access to medicines. The World Health
Organisation compiles and regularly updates an Essential Medicines List
as a guide for countries developing their own essential medicines lists
according to their priority health needs. 95% of the medicines on the
WHO=92s list are not subject to patents and can be manufactured by generic
companies: most are. However, according to the WHO, a third of the
world=92s population still does not have access to these essential
medicines. In India, which until recently had no intellectual property
protection for pharmaceutical products, and has the most developed
generics industry in the world including many companies manufacturing
AIDS medicines, it might be expected that AIDS treatments would be
widely available. However, WHO estimates suggest that the proportion of
HIV/AIDS patients that need antiretrovirals, to those actually receiving
them, is no higher than in Africa.

GSK fully recognises the right to grant compulsory licenses (both import
and export) as a flexibility of TRIPS. Some commentators have criticised
the WTO decision of August 2003 to amend TRIPS with respect to
compulsory licensing for export as being too complex and ineffective.
However, in August 2007 the process was successfully used by the
Government of Rwanda. This enabled the Canadian generics company Apotex
to manufacture a generic fixed dose combination (FDC) antiretroviral
(ARV), containing two molecules over which GSK has patent rights
(zidovudine and lamivudine) for the treatment of HIV/AIDS. This shows
that the solution is both workable and effective.

However, we would not expect to see widespread use of this mechanism not
least since it does not fundamentally address the key barriers to
access, which have nothing to do with IP. The main constraint is local
capacity to absorb and effectively use the drugs being offered, and lack
of demand. In some cases, insufficient political will is a problem. As
Dr. Kevin de Cock, WHO Head of HIV, said in July 2006, "If you work in
these countries it is very obvious, very quickly, that the elephant in
the room is not the current price of drugs. The real obstacle is the
fragility of the health systems, particularly in Africa." Compulsory
licensing would do nothing to address these challenges - but injudicious
use of compulsory licensing would have a negative impact on investment
in R&D in certain disease areas.

The G8 recently recognised that the benefits of innovation for economic
growth and development are increasingly threatened by infringements of
intellectual property rights worldwide. These benefits would equally be
threatened by the overuse of the flexibilities in TRIPs.


The G8 should:

Strengthen and harmonise on a period of Data Exclusivity of 10 years and
ensure that even after the period of exclusivity, the data remains
confidential, even though other companies can refer to it.

Support the Convention on Biological Diversity=92s access and
benefit-sharing (ABS) objectives through national laws governing access
to the genetic resources and for mutually agreed contracts to define how
any benefits arising from their use should be shared.

Ensure that any International Regime on Access and Benefit-Sharing
emerging from current discussions within the Convention on Biological
Diversity faithfully reflects the CBD and excludes pathogens (such as
influenza viruses) and derivatives.

Oppose attempts to introduce a disclosure of origin obligation in patent
applications (especially through an amendment to TRIPs or inclusion in
the CBD International Regime).

Ensure that the development of the strategy and action plan of the WHO
Intergovernmental Working Group on Public Health, Innovation and
Intellectual Property (IGWG) and its implementation focuses on diseases
that disproportionately affect developing countries and does not reduce
incentives to carry out research and development. New initiatives must
complement the existing IP-based system and must be voluntary.

Preserve effective minimum international standards of IP protection by
ensuring appropriate use of TRIPs flexibilities.
1.3 COMBATING COUNTERFEIT MEDICINES

Strong copyright and trade mark protection, and efficient enforcement
systems, not only protect the investment in the innovation they
represent, but protect consumers as well. Counterfeit and sub-standard
medicines represent a major public health risk. At best, fake medicines
waste scarce resources, at worst they kill people. The G8 must therefore
take the necessary steps to ensure that appropriate early warning
mechanisms and enforcement programmes are put in place in both =93source=94
and =93recipient=94 countries; that they are adequately funded; and that
counterfeiters face penalties which act as real disincentives.


The G8 should:

Continue to ensure that the threats from counterfeiting, in all parts of
the world, are recognised and that appropriate early warning mechanisms
and enforcement programmes are put in place in both =93source=94 and
=93recipient=94 countries, that they are adequately funded, and that
counterfeiters face penalties which act as real disincentives.
SECTION 2: DEVELOPMENT AND AFRICA

Recent years have seen significant efforts by all sectors of global
society to work together to address the challenge of developing world
healthcare. The G8 has been at the forefront of these efforts, and much
progress has been made.  However, significant challenges remain.  WHO
recommends a minimum spend on health of =A317 per person per year to
provide the most basic health services. Yet the average spend in
sub-Saharan Africa is just =A35. The African region of WHO suffers 24
percent of the global burden of disease, but has only 3 percent of the
world=92s health workers. This chronic under-investment means that
healthcare infrastructure in many countries is woefully inadequate.


2.1 HIV/AIDS

GSK supports the Gleneagles target of achieving as close as possible to
universal access to antiretroviral therapy by 2010. For this target to
be reached, an holistic approach is needed.

GSK believes that to make progress towards the 2010 target the G8 should
commit itself to a series of actions which incorporate the following key
elements.

1.  Identify and commit additional funding

Effective and well-established funding mechanisms, such as the Global
Fund, PEPFAR and GAVI, now exist to help ensure that medicines are made
available, and the increased focus on innovative financing mechanisms is
warmly welcomed. However, funding remains inadequate.

The Global Fund to Fight AIDS TB and Malaria, PEPFAR, GAVI and other
funding mechanisms must be adequately and predictably resourced over the
long-term. Therefore:

Wealthy nations should make achieving the target allocation of 0.7% of
GNP for overseas aid a key priority.
African governments should plan towards the Abuja Declaration target of
allocating at least 15% of their annual budget to health.

2. Develop an holistic approach to fighting the epidemic by ensuring
that prevention measures, and action against stigma and discrimination,
are fully incorporated into national strategies.

Developing countries should be encouraged to:

Increase efforts at education and prevention, including condom use, harm
reduction measures for drugs users and sex workers, and Mother-to-Child
Transmission prevention for pregnant women.
Address gender inequality and discrimination against women.
Scale up treatment of children: improve diagnosis, standardise
treatment, and develop improved paediatric formulations.
Establish proactive national HIV testing programmes. In all cases,
testing must be combined with effective counselling and treatment
programmes. Legislation to prevent discrimination on the basis of HIV
status should be implemented and enforced, as should the African Charter
on Human and People=92s Rights.
Integrate people living with HIV/AIDS into AIDS policy development and
programme activity.



3.  Create a favourable environment to support R&D

The development of new antiretrovirals, including improved paediatric
formulations, is crucial to fight the development of resistance.
Therefore:

A framework must be built to set up ethical clinical studies on the
prevention of HIV infection, using ARVs.
Local registration requirements should be harmonised and registration
facilitated if drugs are already approved by a stringent regulatory
agency (FDA, EMEA, etc.).
International IP treaties should be respected in tenders and all
procurement processes.
As endorsed at Gleneagles, new R&D Public-Private Partnerships (PPPs) on
vaccines and microbicides, in addition to the G8 Global HIV/AIDS vaccine
enterprise, should be encouraged.

4. Continue to build a framework that encourages voluntary preferential
pricing for ARVs, testing and other commodities

To ensure that the poorest countries can still get access to the lowest
prices (i.e. not-for-profit prices) other developing countries,
procurement agencies and other organisations should not seek a single
price for all developing countries.
Developed and developing countries should act to prevent product
diversion of preferentially-priced products.
As agreed at the G8 Evian meeting in 2003, developed countries should
not benchmark against preferential prices offered to the developing
countries and should not use these discounted prices in reference
pricing systems.

Taken together, these actions could play a major part in ensuring
significant progress towards the 2010 target.


2.2 PANDEMIC INFLUENZA

Governments in developing countries, including those in Africa, are
understandably concerned about securing access to pandemic influenza
vaccines for their citizens.  Under WHO=92s leadership a number of steps
have been taken to address these concerns, but more needs to be done.

Last year WHO agreed to establish a stockpile of 150 million doses of
H5N1 vaccine with one third of the doses reserved to help contain an
initial human outbreak, should H5N1 attain the ability to transmit from
human to human. The remainder would be reserved to help low and middle
income countries fight a pandemic should it be caused by H5N1.

GSK fully supports the creation of a H5N1 stockpile and in June of last
year we announced our intention to donate 50 million doses of vaccine to
WHO=92s stockpile. What is needed now is for new funding to be identified
to ensure the stockpile is financed on a sustainable basis. GSK has
stated its intention to supply additional doses of vaccine to the
stockpile, over and above our donation, at a highly preferential price
to WHO.

In addition to this GSK is committed to selling vaccine direct to
developing country governments at tiered prices which reflect a
country=92s Gross National Income (GNI) as defined by the World Bank for
both pre-pandemic H5N1 vaccine and for pandemic vaccine.

As well as stockpiling H5N1 vaccine developing countries will want to
have access to the actual pandemic vaccine, once it becomes available.
Many developed countries have secured their supply of pandemic vaccines
through Advanced Purchase Agreements (APAs). The poorest and most
vulnerable developing countries lack the resources to enter into such
agreements by themselves. GSK believes that these countries could be
helped by creating a APA operated by WHO working in partnership with
donors and industry, with donors providing funding and industry
committing to tiered pricing principles. Creating such a mechanism
requires partnership and political leadership which is why the G8 could
have a key role in addressing these issues.

The G8 should also work to ensure that the long-established WHO Global
Influenza Surveillance Network is protected and maintained. This unique
system, in existence for 50 years, is a vital mechanism for ensuring
that the world responds quickly to the threat of new viruses. It allows
all parties to share and analyse influenza viruses for research and
vaccine development. The Network=92s success, and the consequent benefits
for healthcare across the world, has been based on all parties sharing
and analysing influenza viruses. If governments desist from freely
sharing information on viruses circulating in their countries, as has
been threatened, the implications for global healthcare could be
significant. The development and supply of both seasonal and pandemic
influenza vaccines, and of other vaccines, would be impacted.

The G8 can:

Work with WHO to identify new sustainable funding to support the WHO=92s
stockpile of H5N1 vaccine.

Work with WHO and industry to develop an APA for pandemic vaccine for
the poorest and most vulnerable developing countries, guaranteeing them
access to vaccine in the event of a pandemic.

Work together to protect the WHO=92s Global Influenza Surveillance
Network, which facilitates the research and production of new vaccines
against influenza and ensure that countries continue to share viruses
freely.


2.3 SUPPORTING R&D INTO DISEASE OF THE DEVELOPING WORLD

The return on investment on R&D for diseases of the developing world is
often too low to justify an adequate allocation of resources.
Public-Private Partnerships (PPPs) are therefore needed. Companies
provide the technology that they have invested in for decades, as well
as their development and distribution expertise, to the partnership.
Public sector partners help fund the development costs while also
helping to ensure that the medicines and vaccines developed get to the
people that need them. This has the double benefit of encouraging R&D
and accelerating the product=92s uptake in the developing world. A number
of these PPPs have been established and have transformed the pipeline of
R&D projects for diseases of the developing world.

Increased funding for existing products and partnerships has undoubtedly
already helped progress research in many disease areas by helping to
share the financial risk involved. However, the vast majority of this
funding has come from Private Foundations, such as the Bill and Melinda
Gates Foundation.

Recognising the early successes of PPPs, and as a follow up to the
commitment at Gleneagles for increased investment, the G8 should
intensify its support for PPPs.


Building up R&D and regulatory capacity in developing countries

As successful PPPs start to bring new medicines and vaccines into late
stage development it is becoming increasingly clear that there is a need
to develop and strengthen the ability of developing countries to conduct
clinical research. Clinical trials require suitable sites with trained
personnel, sufficient resources and infrastructure, and appropriate
regulatory and ethical oversight. As the pipelines of the product
development Public Private Partnerships, such as MMV and GATB, mature
the capacity of the few suitable clinical facilities, especially in
Africa, will be dangerously over-stretched.

PPPs, Advanced Market Commitments (AMCs) and Malaria

GSK believes that AMCs can offer a powerful and cost-effective
market-based mechanism to accelerate the development and availability of
priority new vaccines against diseases that currently kill millions of
people in developing countries. Early, guaranteed commitments that
create a viable market could encourage vaccine manufacturers to invest
in research and development and production capacity to serve developing
countries, which would otherwise be commercially unviable. The result of
this will be more vaccines available to developing countries in a
shorter time frame at an affordable price. GSK strongly supports the
launch of the Pneumo AMC in 2007.

The Malaria Vaccine Initiative (MVI), a PPP in which GSK is a partner,
is making significant progress in developing a vaccine. The current
timetable is to file in 2011, just three years from now. The G8 should
start now on creating an Advanced Purchase Agreement (APA) for malaria
vaccine now, ensuring healthcare systems, manufacturers and others have
time to prepare and invest in the necessary capacity, so that as soon as
the vaccine is available widespread vaccination can be started without
delay.

The G8 should:

Establish a programme of technical assistance to build clinical
expertise in developing countries.

Establish a working group to evaluate and recommend appropriate
financial mechanisms to strengthen R&D through PPPs and ensure that the
products developed through PPPs get to the people who need them as
quickly as possible.

Start work now on an APA for Malaria vaccine, working on the assumption
that a vaccine could be available from 2011.


2.4 REDUCING TAXES AND TARIFFS ON MEDICINES

Local taxes and tariffs are a factor in reducing access to affordable
medicines, as acknowledged in the recent report of the WHO Commission on
Intellectual Property Rights, Innovation and Public Health. The impact
of tariffs tends to be greatest in those developing and least developed
countries that have the greatest public health needs, and their removal
would help in addressing those needs. Every dollar that a pharmaceutical
company has to pay in tariff duties raises the cost of medicines in
importing countries. The removal of tariffs on both finished medicines
and on pharmaceutical intermediates would also be a powerful
demonstration of the political will needed to address the issue of
access to medicines. GSK welcomes the moves at the WTO by the US,
Switzerland and Singapore to eliminate tariffs imposed on the trade of
medicines and medical devices.

The G8 should:

Support moves to eliminate tariffs on medicines and vaccines in the WTO.




*************************************
Peter Chowla
peter@chowla.org
http://www.chowla.org
Skype ID: pchowla
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