Withdrawal of an academic degree
The legal basis in Germany is the respective examination regulations of the universities , in the case of doctoral achievements the doctoral regulations of the respective faculty in connection with the corresponding regulations in the administrative procedural laws of the federal states (§§ 48 ff. VwVfG).
A withdrawal can take place if the applicant is guilty of deception in the examination procedure to obtain the academic degree , for example plagiarism , but also if a person later turns out to be unworthy of the doctoral degree or a certain deliberate crime through subsequent academic misconduct commits.
An administrative act that was illegal when it was issued can be withdrawn ; an administrative act that was lawful when it was issued and only later became illegal for certain reasons can be revoked .
The but-knowing administrative act is regularly connected to the coercive payments reinforced obligation to hand over the award certificate.
Revocation of a grant that was illegal from the start
If it turns out after the award that the title was acquired through deception or that essential prerequisites for the award were not met, an academic degree awarded can be withdrawn.
Depending on the specific regulations in the individual state university laws and examination regulations of the universities, a regulation corresponding to VwVfG in the state administrative procedure law can also apply.
The award is usually canceled with effect for the past, whereby the person concerned can only invoke the protection of legitimate expectations under certain conditions . Trust worthy of protection is excluded in any case in the case of fraudulent deception or bribery.
Cancellation is at the university's discretion . In doing so, it must weigh up trust in science against the professional and social consequences for the person concerned. On March 9, 2016, the Hannover Medical School came to the conclusion in the case of Ursula von der Leyen's work that it was a less serious case. The University Investigation Commission found that 20% of the work was incorrect, but that “serious errors” could only be proven in three places.
Withdrawal based on facts that occurred afterwards
In particular, the doctoral degree can also be withdrawn through misconduct after it has been awarded.
According toVwVfG, a lawful beneficial administrative act may be revoked in whole or in part with effect for the future, even after it has become incontestable, if the authority would be entitled not to issue the administrative act on the basis of subsequent facts, and if without the revocation the public interest would be jeopardized. A criminal conviction can also be considered as such a subsequent fact if, in mirror image of the offense, a provision in the relevant doctoral degree regulations stipulates that admission to the examination can be refused if there is a criminal conviction for an intentional criminal offense to imprisonment of at least one year .
However, a university may only attach relevance to criminal conduct on the part of the doctoral candidate to the extent that science-related criminal offenses are involved. The same applies to subsequent "unworthiness", which is a reason for withdrawal in Baden-Württemberg, Bavaria, Berlin, Rhineland-Palatinate, Saxony-Anhalt and Thuringia.
The case of Jan Hendrik Schön is an example : he received his doctorate in 1998 at the University of Konstanz . In his later publications, but not in his dissertation, Schön was then repeatedly proven that he had manipulated it; In 2004 the University of Konstanz then tried to withdraw his doctorate from him. Schön appealed. In September 2010, the Freiburg Administrative Court ruled that Schön was allowed to continue to use the degree because the university's justification was insufficient for such a measure. The university then appealed, and the Mannheim Administrative Court found that in the “interest of a well-functioning science” the revocation was rightly done. Now Schön appealed; However, the judgment was confirmed by the Federal Constitutional Court in 2014 and the physicist finally lost his doctorate.
In North Rhine-Westphalia, the law on the use of academic degrees remained in force from 1939 to 1987, on the basis of which the degree can be withdrawn if the holder "later behavior has shown himself to be unworthy of the use of an academic degree".
Withdrawal for plagiarism
In the case of scientific plagiarism, the applicant consciously assumes third-party authorship for the thesis. A scientific plagiarism presupposes that it is science and not just pure observations without any independent evaluations, which can be observed by everyone - albeit only in special specialist circles. According to German jurisprudence, at least a “commentary statement” (Hessischer VGH, 1989), “an own dispute” (Hessischer VGH, 1989) or an “evaluation” (VG Berlin, 2009) must be made to the mere observation. "Thoughts and conclusions (...) have to be issued as one's own" (VG Darmstadt, 2011), it must be one's own "thought and mental achievement" (VG Frankfurt, 2007), "train of thought" (VG Frankfurt, 2007) or act a “line of thought” (Hessischer VGH, 1989), which have a “scientific depth” (VG Berlin, 2009). For example, the pure, non-judgmental presentation of the content of a court judgment, law, contract, etc. is not yet a "science", since only a systematic compilation of different court judgments and literary voices in relation to a set of topics can represent an intellectual achievement (Hessischer VGH, 1989). If there are scientific plagiarisms according to these criteria, a second step must be assessed as to whether the violations are significant. A distinction must be made between the quality and the quantity of possible plagiarism.
Plagiarism can also result in criminal prosecution at the instigation of the original author. If the degree was used to obtain a position that would not have been possible without the degree or if the authors are suing, the submission of a false affidavit can result in criminal penalties in the public interest.
The Austrian media scientist Stefan Weber is one of the experts in identifying plagiarism in dissertations . He is co-founder of the Transparent Science Initiative , on whose side dissertations can be discussed collaboratively.
Caused a sensation in the 1970s the case of Friedrich Wilhelm Prince of Prussia , the great-grandson of Kaiser Wilhelm II. The University of Erlangen-Nuremberg decided in 1973, Prince of Prussia the academic degree of "Dr. phil. ”, which he had acquired in 1971.
In 1981 he submitted another thesis to the Ludwig Maximilians University in Munich and was again awarded a Dr. phil. PhD.
In the case of the CDU politician Andreas Kasper in June 2009, due to particular public interest, in addition to the withdrawal, there were also criminal consequences amounting to 9,000 euros, and another 10,000 euros for further plagiarism.
The Guttenberg affair began in February 2011 . The Internet platform GuttenPlag Wiki had initiated an investigation into the doctoral thesis of the then Defense Minister Karl-Theodor zu Guttenberg (CSU). Zu Guttenberg resigned from his offices in March 2011, and the University of Bayreuth revoked his degree in May 2011. There was also a fine.
In the following months, further doctoral theses were checked for plagiarism on the VroniPlag Wiki platform . This led, for example, to the revocation of the doctoral degree of the FDP member of the Bundestag Georgios Chatzimarkakis , the FDP European member and former Vice President of the European Parliament Silvana Koch-Mehrin and the CDU politician Matthias Pröfrock . Other cases are Bijan Djir-Sarai (FDP) and Margarita Mathiopoulos (FDP), who were defeated before the Administrative Court in Cologne and on appeal before the Higher Administrative Court of North Rhine-Westphalia in Münster.
Withdrawal for non-compliance with "minimum scientific standards"
In May 2011 there were allegations against Gundolf Keil that he had run a “university doctor factory” at the University of Würzburg . The University of Würzburg initiated a review of the doctoral theses supervised by Keil and offered the prospect of revoking doctoral degrees because they did not meet “minimum scientific standards”. In November 2012, doctoral degrees were revoked in two cases.
Disqualification for racial or political reasons
According to the law on the revocation of naturalizations and the deprivation of German citizenship of July 14, 1933, "Reich citizens who are abroad could be declared forfeited of German citizenship if they acted contrary to the duty of loyalty Reich and people offend who have harmed German interests. " Forced to emigrate through aryanization policy and "forced emigration", many Jewish academics and political opponents of the Nazi regime lost their German citizenship.
The German universities took the law as an occasion for a far-reaching change in their doctoral regulations on the grounds that the “emigrated traitors” were not worthy of a German doctorate.
Another provision of the since 1934 through various decrees conformist doctoral regulations stipulated that the doctorate was revoked by the university if their vehicle had been convicted of a criminal offense. These criminal acts included, in particular, crimes that can be clearly classified as political and ideological, such as high treason , violations of the treachery law , so-called racial disgrace or the wiretapping of enemy broadcasters. For other crimes that were punishable before 1933, such as homosexuality or abortion , the sentence was drastically increased in certain cases for ideological reasons. Between 1933 and 1945 there were eighteen withdrawals at Munich University for this reason. For the period after 1933, however, it is difficult to determine in retrospect whether a criminal conviction had been made in individual cases for political reasons, which also made rehabilitation more difficult in the Federal Republic of Germany.
The doctorate could also be withdrawn because of "unworthiness" if a court ruling against a doctoral candidate provided for the loss of civil rights as a side effect .
After the Reich Citizenship Act of September 15, 1935 had excluded so-called non-Aryans from Reich citizenship, the academic degree awarded by a German state university could be withdrawn again in accordance with Section 4 of the Law on the Use of Academic Degrees of June 7, 1939 on the basis of Reich law if it subsequently turned out that the holder of the award was unworthy .
By 1945, around 2,000 predominantly Jewish doctors were stripped of their doctorate degree from a German university.
The restitution policy after the Second World War aimed primarily at material compensation. The rehabilitation of the deprived as an immaterial act therefore played a subordinate role in the post-war period . In addition, there was an unclear legal situation with no statutory or at least ministerial regulations, as well as the fact that the university bodies responsible for re- awarding academic degrees ( Consilium decanale ) were mostly still staffed by the same people who had issued the withdrawals. At the German universities, too, the question of individual or institutional guilt was "not articulated or only articulated in a generally non-binding form".
Some universities did not officially rehabilitate those affected until later, including Hamburg 1991, Frankfurt am Main 1995, the University of Bonn 1998, the Humboldt University Berlin, Münster 2000, Marburg 2002, Gießen 2006.
The number of depromotions at the University of Leipzig comprised at least 73 people affected in the period from 1933 to 1944, as Burkhard Boemke declared in a ceremony on April 30, 2007 about the repeal.
The University of Würzburg recognized from the doctorate between 1933 and 1945 a total of 184 scientists. Above all, scientists of Jewish origin should be degraded. In individual cases, the withdrawal was revoked at the request of those affected after the National Socialist era. After a long-term work-up on these depromotions by a commission in 2010, the university reassigned all those affected, to a large extent posthumously , to their academic dignity in a ceremony on May 30, 2011.
At the University of Vienna , the project “Academic 'Dignity' - Withdrawal and reassignment of academic degrees at the University of Vienna” dealt with the withdrawals and reassignments of academic degrees between 1845 and 2005. It emerged from a study that had dealt with the "annulment of withdrawals" from the time of National Socialism from 2003 to 2004 . As part of a commemorative event at the University of Vienna in March 2004, 31 withdrawals from the time of National Socialism were declared null and void: for example those from Otto Abeles , Bruno Bettelheim , Paul Stefan , Otto Stern and Stefan Zweig .
Academic degrees obtained in the GDR
According to Unification Treaty , the right to use state-recognized or awarded academic professional titles, degrees and titles acquired in the GDR remained unaffected by the establishment of German unity in 1989/1990. Contrary to political demands, this also applies to the doctoral degrees awarded by the University of the Ministry for State Security . In addition, the university was dissolved in 1990, so that since then there has no longer been a competent university body for revocation.(1) of the
The University Act (UG) provides for graduates to be awarded the specified academic degree ex officio after they have successfully passed the final examination (Section 87 UG). According to § 89 UG, the award notification is to be revoked and withdrawn if it subsequently emerges that the academic degree was obtained by fraudulently, in particular through falsified certificates or by pretending to be scientific or artistic achievements.
According to § 46 UG, the university bodies have to apply the General Administrative Procedure Act (AVG) in all official matters . According to the case law of the Administrative Court, several requirements are necessary for the fact of fraud within the meaning of Section 69 AVG : Intentional misleading, objectively incorrect information of essential importance must have been provided by the party to the authority on which the authority based the decision. In the case of scientific work, it can be assumed that a significant part of the work has been copied with intent to deceive and the work would have been rated worse (i.e. negative or with a less favorable positive grade) had these circumstances been known. If there is justified suspicion, the thesis supervisor must examine the documents.
Criminal law sanctions for fraudulent achievements in examinations and academic work no longer exist since the Criminal Law Amendment Act 1987. Section 108 of the Criminal Code (deception) was restricted accordingly by excluding deception of state organs with regard to the exercise of sovereign rights.
The universities and their faculties or departments have issued various regulations based on the corresponding cantonal university laws, which include the acquisition and use of an academic title as well as sanctions for violations of the principles of academic integrity and ethically correct behavior.
For example, Section 38 of the Doctoral Degree Ordinance at the Law Faculty of the University of Zurich regulates the revocation of an academic degree by the faculty assembly. If it turns out after the award that admission to the doctorate has been obtained by fraud or that there is unfair behavior, the awarded degree will be revoked by the faculty assembly; any documents will be withdrawn. In particular, the more or less literal adoption of texts from the writings of other authors without reference to the source (plagiarism) and the use of unauthorized aids when providing evidence of performance are unfair.
A prominent example is the national councilor Doris Fiala .
- Volker Rieble : The science plagiarism . The failure of a system. Verlag Vittorio Klostermann, Frankfurt am Main 2010, ISBN 978-3-465-04101-6 .
- Stefanie Harrecker: Graduated doctors. The revocation of the doctorate at the Ludwig Maximilians University in Munich during the National Socialist era (= contributions to the history of the Ludwig Maximilians University in Munich , Volume 2) Utz, Munich 2007, ISBN 978-3-8316-0691-7 . ( limited preview in Google Book search)
- Thomas Henne (Ed.): The revocation of doctoral degrees at the law faculty of the University of Leipzig 1933 - 1945 . Leipzig: Leipziger Universitätsverlag, Leipzig 2007, ISBN 978-3-86583-194-1 .
- Ulf Morgenstern: Collective review: withdrawal of doctoral degrees H-Soz-Kult , September 2, 2008
- Julian Krüper : The thing, not the shadow - The Guttenberg case, jurisprudence as a science and the requirements for legal examination papers ZJS 2011, pp. 198–206
- Doctoral degree regulations for the Law and Economics Faculty of the University of Bayreuth of November 27, 1979 in the version of the fifth amendment of March 30, 2000. §16 Paragraph 1 and Paragraph 3. In: uni-bayreuth.de. March 30, 2000, archived from the original on July 29, 2003 ; accessed on February 1, 2019 .
- cf. for example Section 17 (5) of the Ruhr-Universität Bochum (Hrsg.): Doctoral regulations for the Faculty of Philosophy and Educational Science at the Ruhr-Universität Bochum . Bochum July 26, 2016, p. 14–15 ( ruhr-uni-bochum.de [PDF; 247 kB ]).
- Christian von Coelln: The withdrawal of the doctoral degree - academics. In: academics.de. April 2011, accessed February 1, 2019 .
- cf. For example, Section 16, Paragraph 4 of the Doctoral Degree Regulations for the Law and Economics Faculty of the University of Bayreuth from November 27, 1979 in the version of the fifth amendment from March 30, 2000, University of Bayreuth ( Memento from August 17, 2012 in the Internet Archive ) (PDF ; 62 kB)
- VG Berlin, judgment of 25.06.2009 - 3 A 319/05 - openJur. In: openjur.de. Retrieved February 1, 2019 (paragraphs 20, 65).
- cf. For example, Section 34, Paragraph 7, No. 1 of the Law on Universities in the State of Berlin (Berlin Higher Education Act - BerlHG) in the version dated July 26, 2011
- cf. VG Berlin, judgment of June 25, 2009 - Az. 3 A 319/05 para. 35
- Armin von Weschpfennig: Plagiarism, data falsification and no end - legal sanctions for scientific misconduct HFR 2012, no. 67
- Armin von Weschpfennig: Plagiarism, data falsification and no end - legal sanctions for scientific misconduct HFR 2012, no. 64
- Dpa : Von der Leyen is allowed to keep his doctorate Leipziger Volkszeitung , March 9, 2016
- Armin von Weschpfennig: Plagiarism, data falsification and no end - legal sanctions for scientific misconduct HFR 2012, no. 55
- VG Köln, judgment of October 27, 2011 - Az. 6 K 3445/10 para. 57
- BVerwG, judgment of September 30, 2015 - 6 C 45.14
- Christoph Smets: BVerwG on the withdrawal of academic titles: Doctorate or doctoral degree? LTO , September 30, 2015
- Withdrawal of the doctoral degree due to "unworthiness" only in the case of scientific misconduct. Press release no. 85/2014 of October 1, 2014 on the decision of the Federal Constitutional Court of September 3, 2014 - 1 BvR 3353/13
- Christian von Coelln: The withdrawal of the doctoral degree. In: academics.de. Zeit Verlagsgruppe , April 2011, accessed on January 31, 2019 .
- Press release No. 163 University of Konstanz ( online )
- Counterfeit scandal: physicist's title is revoked. In: ORF ( online )
- Controversy over doctorate: Physics. In: welt.de . September 29, 2010, accessed December 31, 2016 .
- Verdict: Ex-top researcher remains "unworthy" for a doctorate. In: Spiegel Online . September 14, 2011, accessed December 31, 2016 .
- Constitutional Court: University may take away researcher doctorate as a punishment. In: Spiegel Online . October 1, 2014, accessed December 31, 2016 .
- Hermann Horstkotte: Doctorate: How honor is lost. In: Spiegel Online . November 23, 2009, accessed December 31, 2016 .
- Hessian Administrative Court, ruling of June 20, 1989, Az. 6 UE 2779/88, Juris marginal note 16 = DVBl. 1989, p. 1277 ff.
- Berlin Administrative Court, judgment of June 25, 2009, Az. 3 A 319.05, Juris marginal note 42.
- Darmstadt Administrative Court, judgment of April 14, 2011, Az. 3 K 899/10, Juris marginal number 38, reasons for the judgment
- Frankfurt Administrative Court, judgment of 23 May 2007, file number 12 E 2262/05, Juris marginal number 14 = WissR 2007, p. 448 ( online )
- Hermann Horstkotte: Stefan Weber: The lonely plagiarism hunter. In: zeit.de . September 13, 2011, accessed December 31, 2016 .
- Initiative Transparent Science Wiki. In: de.antiplagaustria.wikia.com. May 14, 2001, accessed December 31, 2016 .
- AFFAIRS: Treated silently . In: Der Spiegel . No. 31 , 1973 ( online ).
- Peter Mühlbauer: The nobility and scientific work. February 21, 2011, accessed January 14, 2017 .
- Andreas Kasper: The crash of a high-flyer ( Memento from September 3, 2014 in the Internet Archive )
- Another fine for the ex-office manager in: Hessische / Niedersächsische Allgemeine from June 28, 2010. Accessed on July 6, 2011.
- Defense: Uni Bayreuth recognizes Guttenberg doctorate. In: zeit.de . February 24, 2011, accessed December 31, 2016 .
- Scientific misconduct - Philosophical Faculty revokes Georgios Chatzimarkakis' doctorate. University of Bonn , July 13, 2011, accessed on July 13, 2011 .
- Former FDP politician: Chatzimarkakis has lost his doctorate forever. In: Spiegel Online . March 24, 2015, accessed December 31, 2016 .
- Silvana Koch-Mehrin - University of Heidelberg decides to withdraw the doctorate. Heidelberg University , June 15, 2011, accessed June 15, 2011 .
- University of Tübingen withdraws Matthias Christoph Pröfrock's doctoral degree: Press release by the dean Prof. Dr. Barbara Remmert, Eberhard-Karls-Universität Tübingen. (accessed August 23, 2019)
- A critical examination of the dissertation by Matthias Pröfrock: Energy security in the law of the European Union / European Communities Website VroniPlag - Dissertation Matthias Pröfrock. Retrieved July 13, 2011.
- Pröfrock has lost his doctorate. Stuttgarter Zeitung , July 6, 2011, accessed on July 6, 2011 .
- Cicero ( online )
- Plagiarism: Mathiopoulos fails with appointment - doctorate should go. In: Spiegel Online . December 10, 2015, accessed December 31, 2016 .
- Heike Schmoll: Schavan's doctorate revoked. In: FAZ.net . February 5, 2013, accessed December 31, 2016 .
- news: the doctoral title Kölner-Stadt-Anzeiger was withdrawn ( Memento from March 10, 2014 in the Internet Archive )
- Press release from Heinrich Heine University Düsseldorf ( Memento from February 8, 2013 in the Internet Archive )
- Plagiarism allegation: State Secretary Dippel loses doctorate. In: Spiegel Online . February 17, 2015, accessed December 31, 2016 .
- Olaf Przybilla: Allegations against the University of Würzburg - Die Doktorfabrik. In: sueddeutsche.de . May 27, 2011, accessed December 31, 2016 .
- Hermann Horstkotte: junk goods Dr. med. In: FAZ.net . October 26, 2011, accessed December 31, 2016 .
- Daniel Müller: PhDs: Würzburger Doktorfabrik. In: zeit.de . August 14, 2013, accessed December 31, 2016 .
- University takes two doctoral degrees. 20 Work in medicine under suspicion of plagiarism - lawyer calls for an omission. In: Mainpost , November 7, 2012 ( ( Page no longer available , search in web archives: online ))
- Plagiarism affair continues to circulate - Two doctors are now to lose their titles. In: Südwest Presse , November 9, 2012 Plagiarism affair continues to circulate - two doctors are now about to lose their titles ( memento from April 12, 2013 in the web archive archive.today )
- Renate Wittern-Sterzel : Background to the revocation of the doctorate at the Erlangen medical faculty in the "Third Reich" in: Thomas AH Schöck (Ed.): Removal of the doctorate at the University of Erlangen in the time of National Socialism. Documentation of the memorial files of the Medical Faculty and the Faculty of Law and withdrawals from the Theological and Natural Sciences Faculties , 2010, p. 12
- cf. Dieter Speck: withdrawn doctorates at the Albert-Ludwigs-University Freiburg i.Br. 1933-1945 University archive of the Albert Ludwig University, 2014
- Bernd Weisbrod : "... unworthy of having a German academic degree". The withdrawal of doctoral degrees at the Georg-August University in the “Third Reich” Opening speech for the exhibition of the same name, Oct. 29, 2004
- Stefanie Harrecker: Degradierte Do Doctors , Munich 2007, p. 110 f.
- Stefanie Harrecker: Degradierte Do Doctors , Munich 2007, p. 112 f.
- Katharina Becker: Academic death: The withdrawal of the doctorate. On the Difficulty of Righting National Socialist Injustice Research Frankfurt 2014, pp. 134–137
- Law on the use of academic degrees of June 7, 1939, RGBl. I 985
- Thomas Röbke: Abandoned and forgotten Die Zeit , July 27, 2006
- Gelsenzentrum ( online )
- Bernd Mertens, Margareta Feketitsch-Weber: The withdrawal of doctoral degrees from the law faculty of the University of Erlangen during National Socialism . Erlangen research, special series Volume 15, Erlangen 2010, p. 52 ff.
- Eike Wolgast : terms with the past in the immediate post-war period, Heidelberg University, 1997
- Ineffectiveness of the revocation of doctoral degrees 1933–1945 Speech by the Dean of the Faculty of Law at the University of Leipzig Prof. Dr. Burkhard Boemke on April 30, 2007 on the occasion of the ceremony for the lifting of the withdrawal of doctorates from Jewish academics by the Law Faculty of the University of Leipzig from 1933 to 1945 as part of the 17th annual meeting of the DIJV / IDJV in the Federal Administrative Court of Leipzig. University of Leipzig, 2007 ( online ; PDF; 51 kB)
- The stolen dignity. ( online ( Memento from June 3, 2015 in the Internet Archive ))
- Title robbery by the Nazis: "It was the absolute perversion". In: Spiegel Online . May 31, 2011, accessed December 31, 2016 .
- Herbert Posch: Academic 'dignity' - withdrawals and reassignments of academic degrees at the University of Vienna. Abstract. University of Vienna, undated ( online ( memento from November 19, 2008 in the Internet Archive ); PDF; 135 kB)
- Jan Kixmüller: Secret promotions PNN , July 24, 2013
- Uwe Müller: When the Stasi awards a doctorate Die Welt , November 17, 2013
- Federal Act on the Organization of Universities and their Studies (Universities Act 2002 - UG) RIS , accessed on January 2, 2018
- Florian Taus: Plagiarism in theses from a study law perspective TU Wien, 2011, p. 6
- Hermann Horstkotte: Professor is considered a plagiarist and nobody cares Die Zeit , May 7, 2013
- Lto: handling of allegations of plagiarism in Austria. In: lto.de. June 22, 2015, accessed December 31, 2016 .
- § 108 StGB deception jusline.at, accessed on January 2, 2018
- Report of the Judicial Committee, Reprint 359 of the supplements to the stenographic minutes of the National Council XVII.GP, p. 4
- Florian Taus: Plagiarism in theses from a study law perspective TU Wien, 2011, p. 5
- Title protection postulate of September 14, 2011, website of the Swiss Federal Assembly , accessed on January 2, 2018
- Ordinance on the doctorate in law (Dr. iur.) At the Law Faculty of the University of Zurich (doctorate ordinance) of 25 May 2009
- cf. Judgment of the Administrative Court of St. Gallen from August 29, 2011 - B 2011/102
- Fialas master’s course abolished - denied work not yet made up January 26, 2016
- Edgar Schuler: Plagiarism affair: ETH wants to learn from the Fiala case, Tages-Anzeiger , July 13, 2013