BAHR Dispute Resolution Insight No. 2/2022
BAHR2 <<< CONTENTS Opening statement 3 How and why artificial intelligence (AI) represents a competitive advantage in large disputes ................................................................... 4 Recognition of foreign restructuring plans in Norway 8 Norwegian arbitration trends to keep in mind when choosing a dispute resolution mechanism ............................................................................ 14 Contact us................................................................................................................................................ 19 BAHR Dispute Resolution Group
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OPENING STATEMENT
It has been a hectic quarter for BAHR’s Dispute Resolution group. The corona virus restrictions having eased, we are now back to arguing cases in person before courts and tribunals. Whilst digital hearings have worked surprisingly well over these past two years, there is nothing quite like being present. This quarter also brought encouraging results in the annual Prospera-survey on legal services where BAHR was ranked #1 in Dispute Resolution. We are particularly pleased with the ranking because it is based on feedback from clients alone. We take this to mean that the client centred work ethos of our Dispute Resolution group is noticed and valued by our Aclients.surprising finding of the wider Prospera-survey, however, was that clients – when considering which law firm to employ – rank digital capability dead last on the list of priorities. We beg to differ. In this Dispute Resolution Insight we explore how there is currently a significant competitive advantage, particularly in large cases, in choosing a law firm skilled in the use of advanced software and artificial intelligence when preparing the case. We hope the article may serve as an eye-opener.
Another important focus area for the Dispute Resolution group is supporting BAHR’s restructuring team in litigation matters. A central part of this work is securing the enforcement and recognition of foreign restructuring plans in Norway. In this Dispute Resolution Insight we provide an update on the Norwegian law position on cross-border restructuring following the enactment of the new Restructuring Act in 2020 and the later amendments to the Bankruptcy Act in Lastly,2021.wesee an increased use of arbitration in Norway. We have included an overview of the key trends in Norwegian arbitration that parties to a contract should bear in mind when considering arbitration as the dispute resolution mechanism. We hope this Dispute Resolution Insight provides an interesting read!
Atle J. Skaldebø-Rød Partner / Head of Dispute Resolution
How and why artificial intelligence (AI) represents a competitive advantage in large disputes
Today’s matters are evidentially larger Over the past three decades commerce has undergone a silent but radical change. More or less everything is now being done digitally and have been for quite some time. This means that most things are traceable. If a dispute arises, there will be a large number of emails and other forms of digital communication (SMS, WhatsApp-messages etc.) as well as presentations, memos, logs, manuals, guides and often several draft versions of the same document – all potentially shedding light on the dispute and all retrievable with relative ease from digital Despitearchives.thegreater volume of documents to consider, it is still important, and also an expectation, that dispute resolution is carried out as swiftly and cost-efficiently as possible. Stringent deadlines are usually imposed on the parties to a commercial dispute. At the same time, there is an expectation on the part of courts and arbitral tribunals that the parties are able to focus the presentation of evidence on what really matters for the dispute at hand. In other words, there are three constraints put on parties to a dispute; (i) there will be a large volume of evidence to consider in (ii) a relatively short amount of time whilst (iii) the presentation of facts has to be Overfocused.the last couple of years, BAHR has tested advanced software from several providers. Our current conclusion is that only a very few of the available advanced software provides the required functionality in order to be capable to fulfil the task described above. During the extensive testing and use of advanced software in dispute resolution work we have experienced great benefits of using such tools, and for us, advanced software has become an indispensable tool when preparing cases. Relatively simple capabilities, dramatically improves efficiency Anyone faced with a large dataset of for instance emails face a daunting task. Datasets are most often (if not always) unorganised in terms of chronology, sender/receiver, subject, attachments etc. and always consist of a large number of duplicates. Software can however assist in “tidying up” such datasets in a matter of minutes, removing duplicates, organising documents chronologically, marking sender/ receiver etc.
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Much has been said about the use of artificial intelligence (AI) in the legal sector, whether it is AI writing contracts, setting bail or carrying out due diligence or discovery processes. Most of these discussions focus on the future; how AI someday may or may not revolutionise the business. In this article we want to focus on what benefits the BAHR Dispute Resolution group get from using advanced software and AI in its work today and why clients should care about the digital capabilities and experience of the law firm they trust with their disputes.
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Assistance in these relatively simple tasks provides substantial savings in time, so that we as lawyers can better spend our times on the individual documents (undisturbed by duplicates) and focus on the key points in time and the involvement of persons central to the Morecase.advanced software assists not just in tidying up datasets, but also in analysis of the documentation, i.e. by providing lawyers with graphic overviews of who is discussing what, when and with whom. The benefit of the advanced software is not limited to the case preparations but can also be useful during the hearing if new documents are presented and there is a need to consider the relevance and context of the new document in order to respond quickly. In other words, advanced software immediately provides us with a more comprehensive understanding of the facts, almost irrespective of the size of the dataset involved.
Today, this represents an opportunity and pitfall for clients. Clients opting for a law firm with greater digital capabilities will have the upper hand, particularly in large cases involving extensive datasets. Similarly, choosing a law firm that is less digitally equipped and capable, will leave a party disadvantaged.
Artificial intelligence Whilst tasks like tidying up datasets may be seen as a form of AI; AI is typically ascribed to forms of machine learning. In addition to the processes of “tidying up” datasets, software provides for the use of AI in the more typically manner of machine learning to assist lawyers in the document review. Our experience is that machine learning, if used correctly, can be a powerful tool in discovering relevant documents and evidence.
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The greater amount of work the lawyer has in the dataset, the better the precision of the AI.
At last, it is important to note that there are normally substantial cost savings involved. In larger cases we have seen examples of counterparties spending literally millions of Norwegian kroners more than our client on reviewing evidence, either manually or by engaging third parties to assist with the sorting and analysis of large datasets.
By monitoring how a reviewing lawyer considers and classifies a dataset, algorithms will try to similarly consider and classify the remainder of the dataset. Based on the lawyer’s findings the algorithms will suggest other documents of a similar nature.
There is a competitive advantage today This description of our current experience with advanced software and AI may in the future be regarded as stating the absolute obvious – like reading today an article from the early 90’s on the use of emails and the Itinternet.remains a fact however, that even large law firms are currently neglecting the use of advanced software in dispute resolution.
That said, in our dispute resolution work, we have seen a number of examples of key evidence being discovered through the use of advanced analytic software involving AI.
Currently, our opinion after having used advanced software in several cases over the last five years is that machine learning algorithms still have a long way to go. For the algorithms to work effectively, the reviewing lawyer needs to have a good understanding of how the algorithm is constructed and works, to avoid “confusing” the AI.
Simen Skjold Søgaard Partner E SimenMsss@bahr.no+4790021287isadmittedto the Supreme Court and rejoined BAHR as partner after six years at the Office of the Attorney General (Civil Affairs) in April 2022. Simen represents clients in all forms of commercial disputes, including insurance matters, tax/VAT litigation and matters involving public authorities.
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Sondre Nobel Skalleberg Senior Associate E SondreMsonsk@bahr.no+4747860360leadstheefforts of the BAHR Dispute Resolution group on the use of digital tools in large disputes. Sondre’s practice is focused on company law and commercial contracts, particularly within the energy sector. He recently formed a key part of the BAHR team securing a USD 74 million award for our client in a case concerning the Wistingdiscovery and the development of an oil and gas field in the Barents Sea being one of the largest industrial projects in Norway this decade. The case received particular attention in the Norwegian financial press for the BAHR team’s use of artificial intelligence in preparing the case.
Recognition of foreign restructuring plans in Norway
When planning and executing cross-border reconstruction processes, a key question is whether the process and the prospective outcome of the process (the reconstruction plan) will have legal effect in all relevant jurisdictions. A recent example is SAS’ reconstruction process under Chapter 11 of the US Bankruptcy Code. To have the desired effect, SAS is inter alia reliant upon the reconstruction process and the prospective court-sanctioned plan to be respected by all creditors regardless of jurisdiction and governing law.
BAHR is commonly assisting clients with planning reconstruction processes and ensuring recognition. In this article we discuss the legal basis for recognition of foreign restructuring proceedings and court-sanctioned reconstruction plans in Norway.
temporary Reconstruction Act (Norw.: “Rekonstruksjonsloven”) and amended the Bankruptcy Act to cater for crossborder restructurings. Based on the new legislation, BAHR has recently successfully assisted clients with ensuring recognition of cross-border restructurings in Norway.
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A successful NorwayInuncommon.processesofthelegalreconstructionhighlyConventionNorwaywhichprocessesreciprocalcross-borderCross-BordertoimplementedNorwayInsolvencyDespitenegotiations.choosetreatmentprocess,suchinthatthatreconstructioncross-borderprocesspresupposesallstakeholdersareconfidenttheoutcomewillhavelegaleffectallrelevantjurisdictions.LackofconfidencewillcomplicatetheastherewillberiskofunequalandsomecreditorsmaytopursuepaymentduringthenotbeingboundbytheEURegulation(2015/848),haduntilrecentlynotanylegislationsimilartheUNCITRALModelLawonInsolvencyregardinginsolvencyprocessesandeffects.ExceptinsolvencyinotherNordiccountries,isautomaticallyrecognisedinduetotheNordicBankruptcy(1933),itwasthusuncertainwhetheraforeignplanwouldhaveeffectinNorway.Thisispartofreasonwhyseekingrecognitionforeignin-courtreconstructioninNorwayhasbeen2020and2021respectively,howeverintroduceda
Recognition under the Dispute Act Section 19-16 Formerly, the Dispute Act (Norw.: “Tvisteloven”) Section 19-16 was the usual starting point when seeking recognition of foreign courtsanctioned restructuring plans in Norway. However, the provision only provides basis for recognising the ruling sanctioning a reconstruction plan, not the process leading up to the reconstruction plan as such. Accordingly, recognition under this provision will not provide protection against creditors pursuing their claim in Norway during the foreign process. Also, recognition of the ruling sanctioning the reconstruction plan – and thus (indirectly) the plan itself –depends on several conditions being met. Firstly, it must be provided by statute, bilateral agreements, or agreement between the parties that a ruling shall have legal effect in Norway.
As Norway only has a limited number of agreements with other states regulating recognition of rulings in civil matters – and the Lugano convention has a wide-ranging bankruptcy exception in Article 1 – this condition excludes recognition of most foreign rulings in insolvency matters. There are however some exceptions. For instance, Article 1 (2) in the convention between Norway and the United Kingdom providing for the reciprocal recognition and enforcement of judgments in civil matters of 12 June 1961, which was re-asserted on 13 October 2020, sets out that “any decision of a court” shall be recognised. It could thus be argued that a decision sanctioning for instance an English reconstruction plan should be recognised and have full legal force in Norway – possibly also without basis in the Dispute Act Section 19-16 – provided that the convention is applicable. To our knowledge, this question has however never been tried in Norwegian courts.
Furthermore, bilateral agreements between the parties pursuant to Section 4-6 of the Dispute Act will be sufficient to meet the first condition for recognition. As complex restructurings normally encompass a broad mass of creditors, including non-consenting creditors, this alternative is however normally unapplicable. Even if there is an agreement between either Norway and the relevant state or between the parties, the following three conditions must be met for a ruling to be recognised under the Dispute Act Section 19-16; (i) it decides a civil claim, (ii) it is final and enforceable and (iii) it is not contrary to mandatory Norwegian
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Recognition under the Bankruptcy Act
Section 163 of the Bankruptcy Act regulates recognition of foreign main insolvency proceedings. If the following six conditions are met, both the foreign proceedings as such (Section 164) and the ruling sanctioning the reconstruction plan (Section 167) will have legal effect in Norway:
In 2016, Norway passed rules regulating cross-border insolvency matters based on the UNICITRAL Model Law. However, the rules did not enter into force until 1 July 2021, when they were implemented as part 4 to the Bankruptcy Act.
Accordingly, recognition under the Bankruptcy Act depends on the nature of the foreign proceedings and whether the relevant state recognise Norwegian proceedings. Unlike the Dispute Act Section 19-16 it is however not a condition that a bilateral agreement on recognition is in place – it is sufficient that the relevant state, based on national law, recognise similar Norwegian processes. For instance, as a Norwegian reconstruction plan can be recognised under Chapter 15 of the U.S. Bankruptcy Code, U.S. bankruptcy proceedings can be recognised in Norway.
An alternative to consider: Parallel process under the Reconstruction Act As recognition of a foreign reconstruction process and/or the result of the process (i.e., a court sanctioned reconstruction plan) depend/-s on several discretionary conditions that have yet to be tried in Norwegian courts, seeking recognition in Norway based on the Dispute Act or the Bankruptcy Act is associated with uncertainty. In previous matters, BAHR has therefore advised, and successfully assisted clients with, running a Norwegian reconstruction process in parallel with a foreign proceeding. Unlike the two other alternatives, this approach reduces uncertainty regarding recognition and whether the debtor has protection against creditors during the proceedings. Before opening a parallel process in Norway, it must be thoroughly assessed whether the desired restructuring plan can be implemented under Norwegian insolvency legislation. As long as the debtor ensures that the creditor mass as such is treated fairly, our experience
BAHR10 <<< law or ordre public. Due to condition (iii), recognition is dependent on the foreign ruling – and thus the relevant reconstruction plan – is in accordance with Norwegian insolvency regulation. Depending on the nature of the foreign process, it could also be necessary to assess whether it is in line with Norwegian company law. Depending on the desired outcome of the reconstruction process, this could entail a significant challenge. Also, if condition (iii) is met, it could instead be opened a parallel restructuring process in Norway, as this alleviates uncertainty regarding recognition. This alternative is described below.
(i) The process is opened where the debtor has its main interests (COMI), (ii) it is collective, (iii) it entails that the debtor at least in part loses control of its assets, (iv) an insolvency manager is appointed, (v) the debtor is a legal person, and (vi) the state in which the relevant insolvency proceeding has been opened recognises similar insolvency proceedings opened in Norway (reciprocity).
Supreme Court and has extensive experience across a broad range of complex commercial disputes. His practice includes post-M&A, directors’ liability, shareholder disputes, company law, financial reporting and marine insurance as well as special forms of judicial proceedings, such as enforcement proceedings, preliminary injunctions and securing of evidence.
Atle J. Skaldebø-Rød Partner / Head of Dispute Resolution
E ChristopherMchjer@bahr.no+4745664410adviseon a broad field of complex and international disputes regarding, inter alia, company law, commercial contracts, tort and post M&A. In addition to ordinary court cases, he works with enforcement, securing of evidence, interim measures, seizure and arbitration. He also has experience with complex and cross-border restructurings and has advised on several reconstructions under the Norwegian Reconstruction Act (2020).
E AtleMatska@bahr.no+4792287727isadmittedtothe
11BAHR>>>is however that the Reconstruction Act offers significant flexibility. However, it is important to note that compared to similar legislation in many other jurisdictions, the Reconstruction Act has strict voting rules. For the reconstruction plan to be passed, at least 50 % of the voting-eligible debt must actively vote in favour of the plan. This entails an enhanced risk of non-approval in Norway compared to most foreign jurisdictions. Still, depending on the legislation in the other jurisdiction(s), this uncertainty can be alleviated by giving the foreign reconstruction officer a proxy and instruction to vote “yes” to the proposed restructuring plan in Norway on behalf of all creditors. If the processes are sequenced correctly, such mechanism will ensure the outcome of the vote in the Norwegian process, and thus that the reconstruction plan is identical in all the involved Accordingly,jurisdictions. an alternative approach is to run a court ordered restructuring process in Norway in parallel with the foreign restructuring process with an objective to mirror the foreign restructuring plan. This would also entail an automatic stay in Norway against bankruptcy petitions and enforcement of certain types of asset security/mortgages for at least three months.
Christopher Thue Jerving Senior Associate
The current Norwegian Arbitration Act was enacted in 2004 and is based on the UNCITRAL Model Law. Some attempts have been made over the years to have awards set aside, which the courts have largely declined. The few examples of Norwegian courts holding arbitration awards as invalid have primarily been based on due process considerations. It is safe to say that the threshold for setting aside arbitration awards, or otherwise not enforcing arbitration agreements, in Norway is very high and Norway can rightly be labelled “arbitration friendly”.
A key clause in any commercial contract is the dispute resolution clause.
This means that by choosing arbitration in Norway, parties can normally expect an arbitration procedure in line with international best practice rather than a procedure replicating that of the ordinary Norwegian courts. Ad hoc-arbitration remains the first choice Arbitrations in Norway are primarily conducted ad-hoc, without the use of arbitral institutions. In terms of Norwegian institutional arbitration, the only choice is the Oslo Chamber of Commerce (OCC). Conversely, the OCC has in our experience a good, lean, ruleset which also provides for fast-track arbitration and a competent secretariat.
When choosing between litigation and arbitration in Norway there are, however, several trends and developments in Norwegian arbitration worth keeping in mind. Norwegian arbitration is international The strongest and most significant trend in Norwegian arbitration over the past decade has been the shift from a Norwegian civil procedurebased procedure to international best practice. This shift was in many ways cemented by the 2017 decision of the Norwegian Supreme Court in I.M. Skaugen (HR-2017-1932-A).
Norwegian arbitration trends to keep in mind when choosing a dispute resolution mechanism
Professional parties face a choice: litigation before the ordinary courts or arbitration? In this article we identify the main trends in Norwegian arbitration and how they may inform parties’ choice of dispute resolution mechanism. Arbitration in Norway?
The Swedish Chamber of Commerce (SCC) in Stockholm also remains popular in arbitrations concerning contracts with a Norwegian nexus. ICC is also used to a certain extent, particularly within construction. An alternative to “pure” ad-hoc arbitration and institutional arbitration, is a hybrid solution whereby the arbitral tribunal is set up ad-hoc, but the parties agree to follow a given ruleset or guidelines. This form of arbitration is gaining traction in Norway following the creation of Nordic Offshore and Maritime Arbitration (NOMA) Rules and Guidelines. The NOMA Rules were
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Whilst the NOMA Rules and Guidelines were originally drafted based on maritime and offshore arbitrations, in practice they are of relevance and used in commercial arbitrations in Norway also outside the maritime and offshore sectors.
A previous concern of foreign clients when considering (ad hoc) arbitration in Norway has been that the absence of detailed procedural rules entails uncertainty related to what the actual process will be like. This has often been referred to as the “black box”Asproblem.mentioned, Norwegian arbitration, when properly conducted is today based on international best practice. This best practice has also been codified, as set out above, in the NOMA Best Practice Guidelines.
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A further consequence of the reliance on international best practice is the increased use of procedural orders (POs) in Norwegian arbitrations. The POs typically considers and clarifies any initial procedural issues as well as setting out a schedule for the case preparation up until the hearing. It is also not unusual that an arbitral tribunal gives further POs as the case preparation proceeds. This means that ad hoc proceedings in Norway are more predictable and transparent than what they may have
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been perceived as only a few years Recentlyago.we have seen examples of this transparency being helpful in terms of enforcement of Norwegian arbitration awards abroad. The available guidelines codifying Norwegian arbitration practice and the use of POs makes it easier to alleviate any due process concerns a foreign court may have at the enforcement stage.
The use of so-called multitiered clauses (also referred to as escalation clauses) is increasing. These are arbitration clauses that stipulate certain steps to be taken before commencing arbitration.
Multi-tiered dispute resolution clauses
Fast-track arbitration is primarily an option with institutional arbitration. For example, the OCC Arbitration Rules include a separate chapter on fast-track arbitration (applicable where the parties have agreed to fast-track arbitration in the arbitration clause, typically for disputes valued under a certain amount, or subsequent to the dispute Inarising).2021, NOMA also introduced fast-track rules to facilitate an ad hoc alternative. By default, the fast-track rules apply to arbitration with a dispute value of less than USD 250 000, unless another sum has been specified in the arbitration clause. Our experiences with fasttrack arbitrations have only been positive. Excepting the largest and most complex cases, more disputes can in our view be decided by a single (experienced) arbitrator. At the same time, the constraints put on the proceedings provide more certainty in terms of time and costs and force the parties to focus on the key issues in dispute.
Drafting trends for arbitration clauses
In drafting a multi-tiered arbitration clause it is important that any requirementspre-arbitrationarewritten in a clear manner using obligatory terms and avoiding unclear or ambiguous wording.
Fast-track arbitration
A classic example is prearbitration negotiations. The idea is to provide for a “cooling-off” period in which the parties can explore an amicable Multi-tieredsolution.clauses can be effective in bringing the parties together. At the same time, they can add uncertainty and complexity to the dispute if the clause is not carefully drafted.
Recent examples also show that where a party commences arbitration under a multitiered arbitration, without the pre-arbitration requirements being met, the counterparty
Fast-track arbitration has become a popular means by which to handle smaller disputes more efficiently or disputes where expedience is important. Typically, fast-track arbitration is based on the appointment of a sole arbitrator and proceedings limited in terms of both time and costs.
BAHR16 <<< should react immediately (if it wants to conduct and complete the agreed pre-arbitration steps) and raise the issue before the arbitral tribunal. The courts will not later interfere or set aside an award for breach of prearbitration requirements. This is well illustrated by the recent case before the Hong Kong courts in C v D. In that case the High Court of Hong Kong found that non-compliance with pre-arbitration require-ments only affects the admissibility of a claim (which is for the arbitral tribunal alone to determine) but not the arbitral tribunal’s jurisdiction (for which recourse may be sought in the courts; see for instance article 34 of the UNCITRAL Model Law). We discussed the mentioned decision in a newsletter on escalation clauses last summer which can be found here. The decision was confirmed in a judgment by the Hong Kong Court of Appeal last month. Norwegian courts would likely approach the matter similarly.
Choice of law in arbitration clauses
During the past two years, foreign courts have also considered the governing law applicable to arbitration Theclauses.issue primarily arises out of the separability doctrine in arbitration law whereby an arbitration clause is considered an agreement separate from the main contract within which it is contained. The purpose of this doctrine is to ensure that even if contracts including an arbitration clause is void, a dispute concerning the contract will still be subject to Thisarbitration.doctrine may cause uncertainty as to the law governing the arbitration where no choice of law has been made in the arbitration clause itself.
Becausearbitration.arbitration is a consensual dispute resolution mechanism it is notoriously difficult to join a party to an arbitration or consolidate proceedings without the consent of the third party. The Norwegian Arbitration Act has no provision for joinder or consolidation. For this reason, we see an increased use of multi-party arbitration clauses. There are alternative ways of structuring arbitration clauses to achieve multi-party arbitration depending on the nature of the contract(s) involved. Examples include the use of a free-standing arbitration agreement or protocol signed by all parties involved or the use of so-called “umbrella” clauses. In other types of contracts, the conclusion of such clauses may not be practical. An example being charter party chains in the shipping sector, where back-to-back arbitration clauses is used to facilitate (but rarely guarantee) consolidated arbitration
Multi-party arbitration clauses Today, high value commercial contracts will often concern many parties in different jurisdictions. If a dispute arises under such contracts the matter may involve more than two parties. In the interest of both cost efficiency and the avoidance of conflicting awards, it may be beneficial to conduct a multi-party arbitration either by consolidating arbitration proceedings or joining one or more parties to an
Asproceedings.theincreased use of multiarbitration clauses show, these clauses should be chosen and drafted with care. In particular attention should be given to the terms obligating parties to consolidate or join proceedings and also the rules relating to the formation of the arbitral tribunal.
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Jan B. Jansen Partner E JanMjbj@bahr.no+4793494306isadmittedtothe Supreme Court with a practice focused on tax litigation (in particular matters under the Petroleum Tax Act), oil and gas disputes, insurance and professional liability matters.
Mads Schjølberg Senior Associate E MadsMmasch@bahr.no+4795882085hasawide-ranging practice in commercial arbitration and litigation focusing in particular on marine insurance as well as shipping and offshore related matters. Mads has acted as counsel in numerous international arbitral proceedings under the Norwegian Arbitration Act, both ad hoc and under institutional rulesets (i.a. ICC, OCC and NOMA).
This issue has been considered by the UK Supreme Court in the two recent decisions of Enka v Chubb (see our newsletter here) and Kabab-Ji SAL Kout Food Group (see our newsletter here).
It follows from the decisions that a two-step approach is taken: i. if the contract containing the arbitration agreement (the main contract) contains a choice of law (expressly or implicitly), the choice of law of the main contract will usually apply; ii . if the main contract contains no choice of law; then the system of law most closely connected to the arbitration agreement will apply. However, there have been differing approaches to this issue internationally. For example, French courts have put greater emphasis on the law of the seat of the arbitration (which pursuant to the English decisions are primarily of relevance to the second step in the approach above). Accordingly, the only hard and fast rule is to include a choice of law in the arbitration clause. And we recommend doing so, particularly where the parties intend to subject the arbitration agreement to a different system of law than that of the main contract or the seat of arbitration.
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19 >>> Atle J. Skaldebø-Rød Partner / Head of Dispute Resolution E Matska@bahr.no+4792287727 Jan B. Jansen Partner E Mjbj@bahr.no+4793494306 Contact us
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