Relying on the development of Internet, social economy, culture and political life are undergoing unprecedented changes, and various cyber crimes pose an all-round challenge to this change. Based on the new characteristics of fraud in e-commerce activities and the standpoint of criminal law, this paper puts forward its own views in order to contribute to judicial practice and criminal law theory.
First, the new features of e-fraud in e-commerce
The crime of e-commerce fraud is an act of fabricating facts or concealing the truth through the network information system for the purpose of illegal possession, and defrauding a large amount of property. In legal form, the crime of e-commerce fraud has surpassed the ordinary fraud and special fraud stipulated in the current criminal law, but in real life, it is only a manifestation of these crimes.
Traditional fraud crimes can be roughly divided into two types by using modern network technology: one is the act of sending false information online to defraud the victim to agree to deliver some property to the perpetrator; One is the act of entering a specific network information system as the other owner, adding and inputting certain information in the network information system, transferring the electronic money owned or occupied by the owner into his own account, and then cashing it. The former behavior is just a renovation of the crime of fraud in the means of behavior. From the perspective of criminal law, the existing criminal law theory can be used to solve the problem. The latter objective behavior is different from ordinary fraud and special fraud in criminal law. In order to distinguish it from the previous behaviors of the scientific community and facilitate discussion, this paper calls it electronic fraud.
The methods of using the network as a tool to commit crimes mainly include: moving skylight, Trojan horse, Italian sausage, data fraud, worm virus, logic bomb, impersonation, opportunity intrusion, instrument scanning, password cracking and information interception. However, the crime of electronic fraud is only a part of these means. In order to obtain electronic money, actors generally do not take the method of destroying information systems, but use the technical weaknesses in the network to achieve their goals.
E- The main steps of fraud crime: The first step is to obtain correct information. Rights information includes access rights, such as the identity of the rights holder, usage rights, keys and passwords. The way to get the correct information can be through asking, listening, collecting, etc. Or by using technology to intercept information. For example, the actor can connect lines on the Internet or telephone network, or install equipment to intercept electromagnetic waves to obtain the transmitted system information. Some even get useful information by analyzing parameters such as information flow direction, flow rate, communication frequency and length. The second step is to change the information. Such as changing the order and direction of information flow, adding, deleting and changing information content. Due to the influence of the network information system, the equipment and facilities it supports run in disorder or send out wrong instructions. Therefore, the electronic money in other people's accounts is transferred to the account opened by the actor through the network. The third step is information cashing, that is, the actor spends or converts electronic money into paper money in consumption. This is because the crime of fraud is a consequential offense.
The network is usually regarded as a virtual society, which is extremely important for understanding cyber crime. We might as well divide the place where cyber crimes occur into virtual space and real space. In this way, the crime of electronic fraud is manifested in three forms in the criminal law: one is the preparatory crime that occurs in the real stage, such as the actor looking for passwords and passes by analyzing the documents and papers abandoned by the victim. Second, the preparatory crime and attempted crime in virtual space. Third, attempted crime and accomplished crime occur in real space.
Second, the object of electronic fraud
Electronic fraud and other types of fraud have different ways to obtain property. In general fraud activities, there is some communication between the actor and a natural person, that is, "people-to-people dialogue"; However, the crime of electronic fraud is not the case, and the actor mostly achieves his original goal through "man-machine dialogue". It is precisely because of the technical characteristics of man-machine dialogue that the actor only obtains digital symbols representing a certain amount, so it is still inconclusive whether the object of this crime is data records or data carriers or cash objects. Some scholars put forward that electronic funds should be the object of theft when studying the use of computers to steal electronic funds, so the object of crime is "electronic data records that exist in the electronic fund transfer system and represent certain asset ownership relations".
. The reasons are as follows: firstly, the content of the object of theft should be continuously expanded with the development and progress of society; Second, electronic funds are different from general knowledge and information. If you want to secretly transfer the funds from someone else's account to your own account through the computer, the funds in the victim's account must be reduced accordingly, otherwise the computer will refuse to operate; Third, electronic funds have the same nature as payment vouchers, securities and negotiable instruments. Since the latter can be the object of crime, there is no reason to refuse to treat the former as the object of crime. Fourth, the criminal law and judicial interpretation have stipulated that electricity, gas, natural gas and telecommunications services are the objects of theft, and electronic funds should also be regarded as the objects of theft; Fifth, listing electronic funds as the target of theft is conducive to protecting financial property.
The essence of these reasons is that intangible things can be the object of crime. Indeed, some scholars believe: "The object of crime is people or things. Material is an objective material that is not transferred by human will; The existing form of things is time and space, and the external expression of things is state; Things include tangible and intangible. "
This seems to prove the above point of view. Because in the final analysis, electronic money is as intangible as electricity, gas, natural gas and telecommunications services.
In the past, the author thought that the object of this crime was the carrier representing electronic money, such as electronic bills, electronic wallets, electronic wallets and so on. But now, after careful consideration, I think it is not appropriate, and I think that money and things are still the targets of this crime. The reasons are as follows: first, the intangible things are arrested at random as the object of crime, and the things in criminal law are almost equal to those in the philosophical category. In this way, the investigation scope of the criminal object is undoubtedly expanded. Intangible assets are also different in legal attributes and value attributes. Take electronic currency symbols and gases as examples. The specific expression of the former's possession is the specific loss or loss of value, while the latter's possession is not enough to show the loss or loss of the value of the corresponding thing. After the owner finds that there is a problem with the funds in his account, he can take the form of notice to block the intention of the actor. It is reasonable to regard the former as the object of crime, but it is difficult to compare the latter with the former and regard it as the object of crime. Secondly, if the electronic currency symbol is taken as the object of crime, it will lead to the opposite conclusion with the general crime of fraud. The traditional criminal law theory holds that "the object of crime refers to the objective and concrete person or thing shown by the criminal acts stipulated in the specific provisions of criminal law."
The object of crime is not only a concrete thing, but also must reflect the damage degree of the object. If we think that electronic money is the object of crime, that is to say, the actor has the symbol of electronic money, it will cause real harm, that is, the crime is accomplished. As mentioned above, the crime of electronic fraud is an isolated crime, and the time and place between the behavior and the actual harmful result may be inconsistent; In addition, crime is consequential crime, and the possession of digital symbols by the actor does not mean that money has been obtained. The key to the accomplished standard of the crime of fraud is that the actor has obtained a large amount of property. Therefore, taking electronic currency symbol as the object of crime will improve the standard of accomplished crime and expand the scope of punishment in criminal law. Thirdly, the author believes that it is necessary to distinguish the object of crime and the object of behavior for electronic fraud. As the object of behavior, it is the initial goal that the actor hopes to achieve when he carries out the behavior, and it is the symbol of the criminal object. The object of this crime is electronic money or digital symbols. There are also differences between electronic money and electronic money payment methods. The common and legally significant electronic money payment methods in the commercial activities of Internet users mainly include the following:
1, electronic ticket. Common electronic tickets include: user opinions and product demand questionnaire, product purchaser information feedback and maintenance or guarantee information feedback form, product (commodity) quotation application form, quotation form and order form. It should be noted that Electronic Data Interchange (EDI) is constantly improving and developing, and its purpose is to completely realize the electronization of bill transmission, which is the so-called paperless trade. At this stage, due to traditional concepts and technical limitations, only electronic tickets and paper tickets can be used at the same time. However, if we focus on the long term, the author can never deny the significance of electronic tickets to crime. As a matter of fact, in many countries and some economically developed places in China, paper tickets have been reduced from the previous only or main position to the secondary or auxiliary position, which is very telling.
2. Electronic wallet. It is issued through the certification center of the network system, including certified credit cards and ID cards. Users can use e-wallet to complete the operation anytime and anywhere, and personal, credit card and password information are directly transmitted to the bank for payment and settlement.
3. Smart card. It can make small cash payments directly in the network and download cash from bank accounts through the Internet, thus ensuring the convenience of using electronic cash. You can also attach a password to ensure safe use. In addition, it also has the functions of identity authentication and government welfare distribution. If smart cards are used in schools, the identities of teachers and students can be verified; It can also be used as electronic money to pay for meals, photocopying, laundry, and even as a dormitory key. In the United States, it is estimated that 80% of financial transactions are paid electronically.
4. Electronic bill. Bills include bills of exchange, promissory notes and checks. Electronic bills are mainly electronic checks. As early as 1995, some big American banks and computer companies jointly developed and publicly demonstrated the electronic check trading system using the Internet, and predicted that "this system may cause a revolution in banking transactions". Singapore has also developed the first electronic check system in Asia in recent years. In China, due to the restriction of the bill law implemented by 1996, electronic bills are still blank. However, the author believes that with the establishment of China Financial Certification Center and the determination of the legal status of digital signature in electronic payment, coupled with the development of network technology and the strengthening of practical needs, electronic bills will surely become an important means of payment in the future.
5. Electronic bank account. E-banking provides information inquiry, monetary payment, savings business, settlement, online investment, financial management and other services for enterprises or individuals. Among them, individuals, companies, enterprises, savings, fund transfer and other online payments must be made through creditors' accounts in electronic banks. The author might as well take the electronic bank account as the basis to realize electronic money transfer.
These means of payment are generally tangible, and they are the carriers of electronic money transfer. In other words, without these carriers, electronic money transfer cannot be realized. In addition, it can be said that the perpetrators rely on these carriers to commit economic crimes of electronic fraud. But they are not the targets of crime. Because they do not directly reflect the property relationship or economic order relationship of the object of the crime of infringement. If the perpetrator steals someone else's smart card, there is a time interval between withdrawal or use, during which the original cardholder can report the loss to avoid property loss; Or the actor did not use the smart card, and the property of the obligee did not suffer losses. Therefore, it is not the carrier of electronic money that determines whether to investigate the criminal responsibility of the actor, but the realistic possibility of his access to or non-use of electronic money and the degree of damage he has caused to the property rights embodied in electronic money.
Third, the unfinished form of electronic fraud.
(a) about the implementation of behavior.
The beginning of a crime is the boundary between criminal preparation and attempted crime. It refers to "the criminal begins to commit a specific crime stipulated in the specific provisions of the criminal law".
So in the field of electronic fraud, when or what link does the behavior start? The author believes that, first of all, we should rule out the actual contact behavior. The reason is:
First, the actual contact behavior does not have the characteristics of the implementation behavior. Proceed with the act, that is, begin to implement the specific elements specified in the specific provisions of the criminal law. When judging it, we should not only consider the specific charges stipulated by law, but also consider the content and form of the act.
In other words, we should make a unified investigation from the formal and substantive characteristics of behavior law. The actual contact behavior does not have the conditions to be close to the criminal object, and it is impossible to cause harm to the criminal object, so it is not harmful to the implementation of the behavior; Moreover, the behavior at this stage is usually to create conditions for the behavior of virtual link, which is more in line with the characteristics of criminal preparation behavior.
Second, it is against the legislative spirit to regard the actual contact behavior as the implementation behavior. The third paragraph of Article 196 of the Criminal Law stipulates: "Whoever steals a credit card and uses it shall be convicted and punished in accordance with the provisions of Article 264 of this Law." That is, it is punished as theft. With this provision, the author can infer that the perpetrator only swiped the credit card and did not use it, so it should not be treated as a crime, at least as a completed crime. At this point, the obligee's property right has not been substantially damaged, but at most it has been threatened, and the threat must be transformed into real harm, and the actor must conduct virtual link behavior. So the provisions of the criminal law are correct. It can be used as a reference for dealing with similar situations. Stealing or defrauding others' electronic signatures, digital passwords, etc. for the same reason. If it is treated as a criminal act, it is against the spirit of criminal law.
Thirdly, taking the actual contact behavior as the implementation behavior will cause the embarrassment of judicial application. If the actual link behavior is regarded as the implementation behavior, there is no doubt that the preparatory behavior of the crime will be considered in advance, and such irrelevant behaviors, such as forging smart cards, are a preparatory behavior. If it is regarded as an implementation act, the previous purchase of materials is regarded as a preparatory act for a crime, and criminal responsibility can also be investigated. This kind of behavior has little legal significance and should not be treated as a crime. In addition, if the implementation behavior is considered in advance, is the behavior in the virtual stage an implementation behavior? If so, there will be two kinds of implementation behaviors, which will naturally explain the criminal law theory and do not conform to the criminal law provisions; If not, it can only be regarded as an act after implementation, and there will be no negative discontinuance. If the perpetrator does not implement the virtual link at all, it will still be regarded as a crime accomplished. This is obviously meaningless.
Secondly, the initial behavior of entering the network system is not the implementation behavior. Although the time from entering the network system to the perpetrator completing the cyber crime is very short, sometimes only a few seconds, it is necessary to correctly understand the nature of this behavior. One of the reasons why it is not an executive behavior is that it does not have the nature of an executive behavior. In order to complete a specific crime in the network, the actor usually has to enter a specific information system. Before that, he may need to log in to other information systems with auxiliary functions. The second reason is that, from the point of view of criminal policy, these acts are not considered to have the nature of implementation, which helps to prevent the perpetrators from further committing criminal acts. If the behavior at this stage is only preparatory, it will undoubtedly give the perpetrator enough time to stop the crime and subjectively promote the intentional incomplete expression of his crime. On the other hand, it is also helpful for the judicial organs to fully identify the subjective mentality of the perpetrator and provide more credible evidence for punishing crimes.
The author believes that only the virtual link behavior implemented after entering a specific information system is the implementation behavior. The reasons are as follows: 1, this behavior has the reality of infringing on the criminal object, and it will be implemented if it is not affected by other factors; 2, the behavior has the characteristics of criminal law, that is, the direct behavior that leads to the result of the constituent elements.
(2) About attempted crime
There are many viewpoints in academic circles about the standard of distinguishing crime accomplished from attempted crime, such as "the realization of criminal purpose", "the occurrence of criminal result" and "the elements of crime completion". At present, although the last viewpoint is temporarily dominant, other different viewpoints still exist.
In order to identify the completed form of crime more accurately, the theory of "complete elements of crime" further distinguishes between consequential crime (including dangerous crime) and behavioral crime (including behavioral crime). When completing the form of electronic fraud crime, we must first distinguish between consequential crime and behavioral crime.
For consequential offense, legal harmful result or legal dangerous state is the standard of accomplished crime. However, does the result happen in virtual space or real space? If electronic money is stolen, is it the result of the transfer of electronic money from one account to another, or is it the result of the reduction of the real property of the obligee? The significance of this question is self-evident. The author advocates taking the result of real space as the standard of accomplished crime. The reason is:
First, it conforms to the spiritual essence of modern criminal law. Modern criminal law is based on the function of protecting society, taking into account the function of protecting human rights, and both cannot be neglected. In order to achieve this goal, there is no one-size-fits-all approach in criminal legislation, but different types of crimes are distinguished. On the accomplished boundary, some require specific harmful results, some require specific dangerous states, some only require certain behaviors, and some even only require certain actions. This is because we can balance the function of criminal law by considering the differences of social interests embodied in various social relations. The object of electronic fraud crime is not beyond the scope of general crime. Therefore, if we deviate from the requirements of other crimes and set up another standard, it will destroy the equilibrium point of the current criminal law and will inevitably conflict with the spirit of modern criminal law.
Second, the transformation from the result of virtual space to reality is still isolated in time and space. The result of the virtual stage is only the literal meaning of the correct record or the change of information data. Whether it is necessary to harm the rights and interests of the obligee depends on the actor's further deepening behavior, resulting in real property infringement on the obligee, thus producing real practical results. The deepening method of behavior can be completed by the actor himself, or by others or tools. Only at this stage, the actor can also make new moves, such as making new moves, canceling the virtual results caused by the previous actions and restoring the original state. In this way, it is difficult for obligees to feel that their rights are threatened, and there is no confusion in the order of legal interests. From the perspective of criminal policy, it also helps the perpetrator to stop committing crimes.
Third, most scholars worry that if we deal with cyber crimes in the above way and do not punish illegal acts in the network system, it will be tantamount to encouraging criminals to commit crimes. There is no need to worry about it. According to the principle of dealing with implicated offense, the author can distinguish the preparatory form of this crime from the crime of destroying computer information system.
As far as behavioral crime is concerned, it is only required that the behavior of the actor meets the conditions stipulated in the specific provisions of criminal law, that is, it constitutes accomplishment. So there is no accomplished crime.
Third, the dividing line between fraud and theft.
According to the traditional criminal law theory, it seems that it is not a big problem to distinguish fraud from theft; However, there have been different views on the nature of the use of stolen credit cards and the behavior of stealing blank invoices, checks and other blank valuable documents before using them. Some provisions made after the promulgation of the new criminal law and related judicial interpretations have clarified some disputes, and the difference between theft and fraud is more clear. For example, Article 196 of the Criminal Law stipulates: "Whoever steals a credit card and uses it shall be convicted and punished in accordance with the provisions of Article 264 of this Law." Only with the progress of science and technology, the original simple problems have become complicated in the field of network finance.
Credit card is the earliest carrier of electronic money. Today, the carriers of electronic money include other electronic wallets, electronic bills and smart cards. Therefore, criminal means are more complex and diverse. For example, in Japan, there are cash automatic teller machines (ATMs) and banks connected to the national network everywhere, and the penetration rate of ATMs and credit cards is very high; Crimes against ATM cards are also quite rampant. From stealing someone else's ATM card, then deciphering the password, then withdrawing cash, to forging the main ATM card, and then directly stealing account funds through the computer information system of the bank through the network.
There is also a common modus operandi used by perpetrators, that is, monitoring the victim for 24 hours in a certain place, taking the opportunity to steal his account number and password, and then using these stolen accounts and passwords to transfer the victim's electronic money to his online account number.
The difficulty lies in the situation that the fraud of virtual link and the theft of real link overlap. Virtual links occur in the network, while real links occur in the real society.
In order to prevent network crime, a set of security technology is generally set in virtual link. The first is the encryption mechanism. Information encryption is the most commonly used means of secure transactions, which can prevent unauthorized disclosure of information during transmission and storage, and resist interception, illegal access to databases and information theft. The second is digital signature technology. This is a set of passwords. When the sender sends a message, he sends out this set of passwords. After receiving the message, the receiver operates according to the rules agreed by both parties, so as to determine the identity of the sender. In essence, it is similar to a paper signature, which can not only confirm that the information was sent by the signer, but also prove that the information has not been modified since it was sent and received. The third is timestamp. The date of signing the document is as important as the signature. In electronic transactions, digital timestamps can provide security protection for the release time of electronic documents. The fourth is the authentication mechanism. Used to confirm the authenticity of counterparty identity. The fifth is the firewall. This is a highly defensive technical measure, the only information channel between different networks or network security domains, and it undertakes the mission of preventing external attacks. However, these security technologies are by no means perfect, and each technology has flaws to follow, which provides an opportunity for online fraud. For example, tampering with the digital signature of other people's electronic bills, or changing the text content of electronic bills, and then defrauding electronic cash from electronic banks.
In order to obtain or steal other people's electronic money, the actor can take two ways in the virtual space: one is to destroy the normal operation of the information system and take the opportunity to achieve the goal; The second is to impersonate other rights holders to cheat the trust of "system administrators", so as to obtain or use electronic money of other rights holders. The possibility of the first way to achieve the goal is almost zero in the network field, so the second way is very common. In this way, you must use deception. In order to make cheating more effective, it is undoubtedly the pursuit of the actor to get the real information such as the password and signature of the obligee as soon as possible. Some actors use technical means to decipher the password of the right holder in the network and obtain relevant information; Some also use traditional stealing methods to obtain these key information. In the latter case, there is a phenomenon of concurrence of theft and fraud.
In this regard, based on the provisions of China's criminal law, combined with the traditional criminal law theory, and fully considering the characteristics of electronic money, to distinguish whether an act belongs to theft or fraud, we must consider the nature of the act that occurs in the real link. Because through the previous analysis, the author can see that most behaviors in virtual space are fraudulent, but it is obviously inconsistent with the law to regard cyber economic crimes as fraud; In addition, from a legal point of view, theft is a felony compared with fraud. When there are two kinds of concurrence, it should be dealt with as implicated offense and should be characterized as theft. Furthermore, if the behavior in the real link is fraud, then the behavior in the virtual link that follows it constitutes fraud; The behavior that happens in the real link is theft, and the behavior that follows the virtual link constitutes theft.
Specifically: 1, the act of using smart cards without passwords or using smart cards with restricted passwords for many times constitutes theft as long as the amount reaches a large amount; 2. If the smart card is used three times in a year, it shall be deemed as "multiple theft" as stipulated in Article 264 of the Criminal Law, which constitutes theft; 3. Stealing other people's public information network accounts and passwords to access the Internet, causing a large number of telecom tariff losses to others, which constitutes theft; 4. Using stolen electronic wallets, such as credit cards, constitutes theft; 5. The use of false or fraudulent identity documents to access the network and use mobile phones, resulting in a large loss of telecom tariffs, constitutes a crime of fraud; 6. The act of defrauding other people's accounts and passwords by various means of payment, and then using these accounts and passwords to obtain electronic money in the network constitutes a crime of fraud; 7. The act of cracking the password of the obligee through technical means on the Internet, obtaining relevant information, and then obtaining electronic money constitutes the crime of fraud. 8. The use of the smart card password after defrauding constitutes fraud; 9. Stealing the smart card password and using it constitutes a crime of fraud.
Four, about the electronic signature
The main means to determine rights and obligations in e-commerce is electronic signature. Sometimes it is the key to enter a specific information system, sometimes it is an obstacle to using the network information system, and sometimes it is a sign of engaging in network activities. An electronic signature is a set of numbers arranged in a special way. The development of electronic signature technology will have a far-reaching impact on the criminal law interpretation of forging and altering traditional content and financial fraud.
In the past, in criminal law theory and judicial practice, forgery was interpreted as imitation, while alteration was to change the real appearance or content. This explanation has obvious defects after the promulgation of China's Negotiable Instruments Law. At that time, the theoretical circle believed that forging bills refers to the behavior of the actor illegally manufacturing the above bills by printing, copying and drawing, imitating the form, pattern, color and format of real bills of exchange, promissory notes and checks; Altering a bill refers to the act that the actor illegally changes the main contents of the bill by means of splicing, digging up, covering up and altering the real bill, promissory note or cheque as evidence or based on the real bill.
However, the proper meaning of forging bills is to imitate others' signatures, forge others' seals and steal others' real seals; Alteration of a negotiable instrument means that a person who has no right to change it according to law changes other items recorded on a valid negotiable instrument except the signature, thus changing the rights and obligations on the negotiable instrument.
It can be concluded that the act of forging or altering bills is only a typical bill fraud, which is not similar to the act of forging or altering currency independent of bill fraud. Therefore, the author thinks that the provisions of the criminal law are inappropriate. However, knowing the crime in the network, even according to the latter's point of view, will lead to difficult questions to answer.
In the past, bill authentication mainly used handwritten signature. The signature is written casually, and Chinese characters are easy to imitate. Stamping is the same, and almost no official seal can't be engraved privately. The system uses computer to automatically identify signatures and seals, which improves work efficiency. However, as long as the proof of the authenticity of the bill is still signed and sealed, there will inevitably be criminals trying to imitate the signature and seal privately, and there will inevitably be criminals trying to transform and erase the bill. In recent years, some lawless elements have adopted computer scanning and computer seal engraving technology, which makes the private seal engraving electronic and automatic, and can completely confuse the fake with the real. Therefore, the automatic seal identification system, like the signature system, is definitely not the future development direction of the bill authentication system. Therefore, the significance of cryptographic mechanism and electronic signature in network activities has been given new content. If the payee prepares the password in advance according to the bill number, it will be transmitted to the drawer through a secure channel. Every time the drawer issues a ticket, he pastes the password according to the bill number. The payee verifies the authenticity of the bill according to the corresponding relationship between the bill number and the password. Prevent third parties from forging bills. In financial institutions, we can develop a code conversion seal system, also known as password payment system, to verify bills. It adopts the traditional single-key cryptosystem. The drawer and the payee agree in advance on a key, which shall be kept by both parties respectively. Every time the drawer issues a bill, the contents of the bill are digitized first, and then the message is encrypted with the saved key and link to obtain an authentication code, which is used as proof of the authenticity of the bill and transmitted to the bill receiver together with the bill. The payee repeats the same calculation process and obtains an authentication code. As long as the two authentication codes are the same, the bill is considered to be genuine. Because the authentication code is a function of the key and the message, any change of the message will change the authentication code, and it is impossible to calculate the authentication code without using the key. Therefore, the traditional explanation has almost no application value. At this point, it will be difficult, perhaps impossible, to forge rights, but it will be difficult to distinguish between altered and traditional forged contents.
The author believes that it is not so much forgery of electronic signature as fraud of electronic signature. Only the electronic signature of the actor and the electronic signature of the obligee must be consistent, will there be practical consequences of infringing on legal interests. In order to achieve this result, the actor must do everything possible to know the electronic signature data of the obligee, and its method can only be characterized as fraud.
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