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R&D and firm performance: evidence

from the Indian pharmaceutical
industry
a
Chandan Sharma
a
National Institute of Financial Management , Faridabad ,
Haryana , India
Published online: 29 Mar 2012.

To cite this article: Chandan Sharma (2012) R&D and firm performance: evidence from the
Indian pharmaceutical industry, Journal of the Asia Pacific Economy, 17:2, 332-342, DOI:
10.1080/13547860.2012.668094

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 Journal of the Asia Pacific Economy
Vol. 17, No. 2, May 2012, 332–342

R&D and firm performance: evidence from the Indian

pharmaceutical industry
Chandan Sharma∗
National Institute of Financial Management, Faridabad, Haryana, India

This paper examines the impact of research and development (R&D) activities on firms’
performance for the Indian pharmaceutical industry by utilizing the data of the postre-
form period (1994–2006). For this purpose, we construct two empirical frameworks,
namely growth accounting and production function. Estimation results based on the
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growth-accounting framework suggest that R&D intensity has a positive and significant
effect (15%) on total factor productivity. The results also confirm that the performance
of foreign firms operating in the industry is more sensitive toward R&D than the local
firms. Furthermore, the estimation results of the production function approach indicate
that the output elasticity to R&D capital varies from 10% to 13%. In view of these find-
ings, we propose further encouragement and incentives for doing in-house innovative
activities in the Indian pharmaceutical industry.
Keywords: productivity; R&D; Indian pharmaceutical
JEL classifications: O30, D24

1. Introduction
The pharmaceutical industry in India has completely transformed itself since the mid-1990s
when Trade-Related Aspects of Intellectual Property Rights (TRIPs) came into effect. This
has not only led to a substantial increase in the amount of research and development
(R&D) expenditure, but also transformed the approach, structure and dynamics of R&D
activities. In the past, the firms mainly focused on development of new processes for
manufacturing drugs, but now they are also engaging aggressively in R&D for new chemical
entities (NCEs) and modification of existing chemical entities to develop new formulations
and compositions. Furthermore, the fiscal incentives for doing R&D have also grown
significantly in the recent years. In this context, this study attempts to answer a question that
how and to what extent firms’ in-house R&D affects their performance indirectly through
total factor productivity (TFP) and directly through output in the Indian pharmaceutical
manufacturing. This is an important and relevant question for a policy standpoint and one
would like to have an answer for.
In a pioneer study, Solow (1957) recognized that technological change is one of the
key driving factors of productivity growth. Proponents of recently developed endogenous
growth theories have also recognized its role; however, they considered it endogenous which
is driven by the deliberate investment of resources by profit-seeking firms (Grossman and
Helpman 1990, 1991, Smolny 2000). The theory also accepts the fact that a firm’s innovation

∗
Email: [email protected]
ISSN: 1354-7860 print / 1469-9648 online
C 2012 Taylor & Francis
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 Journal of the Asia Pacific Economy 333

activity is crucial to its technological progress and productivity growth. Klette and Griliches
(1996) extended the edogenous growth theory for R&D and productivity linkage in the
context of firm and presented the quality ladder model in a partial equilibrium framework.
The model explains that R&D investment and innovation activities are the engine of growth.
Thus, the theortical linkage between R&D activities and productivity of firms is well
established in the literature.
In the empirical literature too, there is no dearth of study on R&D and firm’s or
plant’s performance. Most of these studies are invariably found to have a significant and
positive effect of R&D on the performance of a firm. However, the estimated elasticity
of productivity or output with respect to R&D varies widely in these studies (e.g. see
Griliches 1979, 1986, Jaffe 1986, Griliches and Mairesse 1990, Griffith et al. 2006).1 A
closer look on the empirical literature reveals several reasons for a wide variation in the
elasticity estimation. First, it is observed that these results vary according to the type of
industry in consideration. For instance, in R&D-intensive industries, by and large, elasticity
is found to be larger. Second, the choice of the estimation technique is another source of the
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divergence. In several studies, application of different econometric techniques has yielded

wide variation in the results with the same data (e.g. see O’Mahony and Vecchi 2009). Third,
it is also observed that a vast variation exists in results between firm-level and industry-level
data.2 Finally, the size of elasticity also depends heavily on the choice of the indicator of
firm’s performance (on the dependent variable), that is output, labor productivity, TFP and
profit.
Against this backdrop, we are set to investigate the role of R&D on the performance
of firms in the Indian pharmaceutical industry. We take up the issue in an innovative way
and attempt to investigate the relationship for the very recent period (1994–2006). We take
into consideration two important indicators of firms’ performance, namely output and TFP,
for the empirical analysis. This investigation is very relevant from a policy perspective,
mainly, because contrary to the general perception that pharmaceutical industry in general
is very sensitive to R&D activities, the Indian pharmaceutical industry is known for its low
research intensity. Nevertheless, the recent data indicate that at least some large firms in
this industry have started taking R&D activities a bit more seriously than earlier.
The remainder of this paper is structured methodically in sections, which are as follows:
Section 2 discusses policy reforms and innovation activities in the Indian pharmaceutical
industry. Section 3 explains data-related issues and estimates TFP of the sample firms. Sec-
tion 4 constructs empirical models and estimates the effects of R&D on firms’ performance.
The final section lays out concluding remarks and policy suggestions.

2. Policy reforms and innovation activities in Indian pharmaceutical industry

Since independence (1947), India had remained a net user, rather than developer, of R&D-
intensive pharmaceutical products. This was due to obvious reasons such as inadequate
investment resources, lack of sufficient skill in medicinal chemistry and high risk due to
uncertain nature of such investments and embryonic R&D infrastructure in the country.
Furthermore, India had always been considered very soft on the issue of intellectual property
rights.3 However, fact of the matter is that the country had a product patent regime and most
of multinational corporations (MNCs) operating through their subsidiaries were enjoying
this regime and charging relatively high price. On the argument of nonaffordability of drugs
to a large section of the population, the government abolished product patent protection in
1972 and drugs price control was introduced. Due to this, domestic firms were left with very
little incentives to invest in capital-intensive new drug development and no incentives what
 334 C. Sharma

so ever for the MNCs to introduce new drugs into the Indian market (Saranga and Banker
2010). Indian companies (along with MNCs subsidiaries) responded to this situation by
developing generics drugs.
A major policy shift was witnessed in the industry when an agreement on TRIPs came
in to the picture.4 This made mandatory product/process patent protection for the World
Trade Organization (WTO) member countries including India. This development coupled
with modification in the Drug Policy in 1994 and with economic liberalization (since 1991)
has significantly increased the competition in the industry, as MNCs, which were both
technologically advanced and had access to new products through their parent companies,
were allowed to operate in the market. In this new product patent regime, Indian firms
have started looking for new sources of growth in future and the biggest source will be
productive R&D, which can deliver patentable innovations. Therefore, ever since the product
patent regime was launched on 1 January 2005, domestic pharmaceutical companies have
increased their allocation for R&D and their structure of R&D activities. At present, the
Indian drug and pharmaceutical industry is ranked as the fourth largest in terms of volume
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and thirteenth in terms of value in the world. The industry accounts for about 8% of the total
world’s drug production (OPPI [Organisation of Pharmaceutical Producers of India] 2008).
However, the Indian industry’s forte remained in generic product market, and this has been
propelled by reverse engineering skills and also low-cost advantage. The pharmaceutical
products price is ruled at relatively low level, both in the domestic as well as in export
markets. Currently, Indian companies on an average spend about 5% of turnover on R&D,
which is much lower as compared with companies of most of the developed countries
where this percentage varies between 15% and 20% (OPPI 2008). Why Indian companies
have hitherto invested very little in R&D for new drug discovery and NCEs? The industry
circle possibly explains this phenomenon by two important factors. First, the industry lacks
product patent protection regime, massive investment requirement and high-risk nature of
such investment. Second, Indian price control regime also tended to squeeze the profit
margin which served as a disincentive to spend on R&D. Nevertheless, in the recent years,
the outlook of the industry has changed considerably and firms in India have started taking
R&D activities more seriously and more funds are being invested now in these activities
(see Figure 1). There can be at least two reasons behind this change in the attitude of Indian
firms related to the R&D activities. First, fiscal incentives and government support have
encouraged firms for R&D. Recently the government has started many new tax exemptions
schemes and extended most of such old schemes.5 Second, the new patent regime has also
forced Indian firms to take up the R&D activities more seriously, if they have to survive in
the market.

3. Data and TFP estimation technique

3.1. Data
Firms’ data of the Indian Drug and Pharmaceutical industry are mainly obtained from
the Prowess6 database provided by the Center for Monitoring Indian Economy (CMIE).
The analysis includes 89 firms which have consistent data in the study period 1994–2006.
Details of variables, their definitions and sources are discussed in Table 1.7

3.2. TFP estimation

In order to examine the role of R&D on firms’ productivity performance, first, we need to
estimate TFP of our sample firms. In this process, the ordinary least squares (OLS) approach
 Journal of the Asia Pacific Economy 335

60

50

40

30

20

10

0
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007
-10

%Sales Growth % R&D Expendtire Growth

Figure 1. Growth in sales and R&D expenditure in the Indian pharmaceutical industry. (Source:
Prowess Database, CMIE, 2008)
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of measuring TFP of firms as the difference between actual and predicted output may lead
to omitted variable bias since the firm’s choice of inputs is potentially correlated with
unobserved productivity shocks. To overcome this problem, we use the Levinsohn–Petrin
(2003) technique. This technique explicitly recognizes and overcomes the endogeneity,
which occurs because at least a part of the TFP is observed by the profit-maximizing firms
early enough so as to allow the factor input decisions to be changed. This procedure utilizes
firms’ intermediate inputs as proxies to correct the part of the unobserved productivity
shock correlated with firms’ inputs. Following this approach, we estimate a Cobb–Douglas

Table 1. Variables definition and their source(s), 1994–2006.

Variables Definition Data source

Output (Y ) Gross value added Prowess

Labor input (N) Number of workers Prowess and
Annual Survey
of Industries
(ASI)
Physical capital (K) Computed as follows: Kt = (1 − δ)Kt−1 + It , Prowess
where K is the capital stock, I is deflated
gross investment and δ is the rate of
depreciation taken at 7%.
R&D intensity (R&D int) R&D expenditure of firms divided by their Prowess
sales
R&D capital (R&Dcap) Annual expenditure on R&D Prowess
Export intensity (Export) Export of firms divided by their sales Prowess
Import intensity (Import) Total import (raw material and finished goods) Prowess
of firms divided by their sales.
Raw materials Expenditure on raw materials Prowess
Power&fuel Expenditure on power and fuel Prowess
Size Value of sales of firms Prowess

Note: All series are deflated with appropriate deflator before any econometrics treatment.
 336 C. Sharma

Table 2. Cobb–Douglas production function estimation using Levinsohn–Petrin productivity esti-

mator. (dependent variable: LY ).

Variables Coefficient Z value

Ln(K) 0.26801∗ 2.50

Ln(N) 0.60809∗ 13.33
Wald test (p value) .1667

Notes: Wald test of constant returns to scale. Proxy variables: power and fuel expenses and raw material expenses.
∗ Statistical significance at 5%.

production function in the following form:

Ln(Yit ) = α0 + α1 Ln(Nit ) + α2 Ln(Kit ) + ωit + ηit , (1)

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where Y , N and K denote value added, labor and capital, respectively, of firm i in year t.
Ln indicates that series are transformed in logarithm before any econometric treatment. In
this model (Equation 1), the error has two parts: first is ω, which represents the transmitted
productivity component, while second is η, which is an error term that is not correlated with
inputs; ω is affected by firms’ policy, and it is unobserved (for details of this methodology,
see Levinsohn and Petrin 2003, Sharma 2010). Results of the estimated production function
are reported in Table 2, which suggest that both inputs have significant impact on output of
firms. On the basis of this estimation, TFP of our sample firms is computed for the further
analysis.

4. Estimating the effects of R&D on firms’ performance

Now we intend to investigate the impact of R&D on TFP and output of the sample firms.
Our study constructs two frameworks. The first is the growth-accounting framework, which
allows an indirect impact of R&D on productivity through TFP, within the endogenous
growth framework. The second is the production function framework, in which R&D
capital directly enters in the aggregate production function as an input.

4.1. Effects of R&D on TFP

We start our empirical analysis with the growth-accounting framework. Under this approach,
we broadly follow Coe and Helpman (1995) and Atella and Quintieri (2001) and test R&D
intensity (R&D int) on the estimated TFP of firms. Therefore, our baseline empirical model
to be estimated is as follows:

TFPit = α + γ Ln(R&D intit ) + βXit + uit , (2)

where TFP and R&D int are the level of TFP and R&D intensity, respectively, of firm i
in period t. R&D intensity is measured by the ratio of R&D expenditure to sales of firms.
In the equation, X is a vector of firm characteristics; u is error term; and α, γ and β are
parameters to be estimated. Ln indicates for logarithm transformation of the variables.
We estimate Equation (2) in four alternative ways and their results are reported in Table 3.
Column 1 of the table presents results of the model in which only R&D intensity is the
explanatory variable. Columns 2, 3 and 4 include firm-specific characteristics (control
 Journal of the Asia Pacific Economy 337

Table 3. Effects of R&D on TFP, 1994–2006.

Variables 1 2 3 4

Ln(R&D int) 0.1925∗ (1.943) 0.1516∗ (1.983) 0.1542∗ (1.994)

Ln(Export) −0.0093 (−0.999) −0.3742 (−0.374) −0.0034 (−0.384)
Ln(Import) −0.0070 (−0.483) −0.004 (−0.291) −0.0096 (−0.673)
Ln(size) 0.1289∗ (13.391) 0.0096∗ (13.324) 0.1292∗ (13.401)
Foreign firm 0.0157∗ (3.347)
dummy (FD)
TFP(−1) −0.1857∗ (−9.719) 0.0196∗ (−10.228) −0.1814∗ (−9.691)
Ln(R&D int)∗ 0.3632∗ (1.955)
FD
Constant 0.3512 (41.33) 0.0601∗ (9.1159) 0.0617∗ (9.329) 0.0592∗ (9.018)
R2 0.1630 0.34932 0.35838 0.3489

Notes: t values are in parentheses. Estimation technique is random GLS (generalized least squares).
∗ Statistical significance at 5% level.
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variables), that is size, export intensity (export) and import intensity (import).8 Column
3 also includes a dummy for foreign firms (FD) (if foreign firm, FD = 1, otherwise 0),
while column 4 includes an interaction variable of foreign firm dummy and R&D intensity.
One previous year’s lag of the dependent variable is included in columns 2, 3 and 4, to
tackle the potential endogeneity. The results show that the R&D intensity elasticity to the
productivity is positive and varies from 0.15 to 0.19. This implies that 1% increase in R&D
intensity leads to 0.15%–0.19% increase in TFP. This estimate is relatively lower than the
findings for France (Cuneo and Mairesse 1984, Hall and Mairesse 1995) and for Taiwan
(Wang and Tsai 2003). However, it is larger than that of the US (Mairesse and Hall 1996),
the UK (Kafouros 2005). The impact of foreign firm dummy is also found to be significant
and positive on TFP (see column 3 of Table 3), which suggests that foreign firms are more
productive than the local firms in the industry. Surprisingly, the estimated coefficient of
the interaction variable of R&D to foreign firm dummy is found to be sizably large (0.36)
(see column 3 of Table 3). This can be interpreted as 1% increase in R&D intensity of
foreign firms leads to 0.36% increase in their TFP, which is one of the largest findings
in comparison with that of the related literature. Further, the results regarding the trade
variables, that is export and import intensities, are not found to have any significant effects
on the productivity. However, size of firms (which measures economies of scale) seems
to be crucial as coefficient of this variable is found to be sizable, positive and statistically
significant on the productivity.

4.2. Effects of R&D on output

Next we shift our attention to estimate the impact of R&D capital on output of our sam-
ple firms. In doing so, a production function approach is utilized, a la Griliches (1980),
Schankerman (1981) and Branstetter and Chen (2006). Here our baseline specification is

Ln(Yit ) = α0 + α1 Ln(Kit ) + α2 Ln(Nit ) + α3 Ln(R&Dcapit ) + εit , (3)

where Y , N, K and R&Dcap represent value added, labor, physical capital and R&D capital,
respectively. R&D capital is a measurement of the stock of knowledge possessed by a firm
 338 C. Sharma

Table 4. Effects of R&D on output of firms, 1994–2006.

Variables (1) FE (2) RE (3) System GMM

Ln(K) 0.243∗ (5.74) 0.257∗ (7.71) 0.147∗ (2.58)

Ln(N) 0.489∗ (11.75) 0.553∗ (16.44) 0.381∗ (8.14)
Ln(R&Dcap) 0.117∗ (5.34) 0.132∗ (6.57) 0.101∗ (3.53)
Sargan 0.171
R2 0.9141 0.9147

Notes: t values are in parentheses. Sargan is the p value from the Sargan (1958) test of over-identifying restrictions,
which test the overall validity of instruments for the GMM estimators. FE and RE denote fixed effect and random
GLS (generalized least squares) estimator, respectively.
∗ Statistical significance at 5% level.

at a given point of time.9 Ln, i and t denote logarithms of the variables, firm and year,
respectively; α1 , α2 and α3 are parameters to be estimated. We are especially interested in
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α3 , because this is the measure of output elasticity to R&D capital.

We estimate Equation (3) by three estimators: fixed effect, random effect and system
generalized method of moments (GMM). Estimating the model using OLS with fixed
or random effect usually provides estimates that are generally consistent with a priori
knowledge of factor shares and constant returns to scale (Griliches and Mairesse 1995).
However, the procedure may produce biased and inconsistent estimates in the presence
of endogeneity (Griliches 1979). Therefore, following O’Mahony and Vecchi (2009), we
also apply GMM technique for the estimation developed by Arellano and Bover (1995)
and Blundell and Bond (1998). The Blundell and Bond estimator, also called the system
GMM estimator, combines the regression expressed in first differences (lagged values of
the variables in levels are used as instruments) with the original equation expressed in levels
(this equation is instrumented with lagged differences of the variables) and allows us to
include some additional instrument variables. The technique significantly reduces the weak
correlation problem, and has been proved to give more reasonable and reliable results in
the context of production function estimation (Blundell and Bond 2000).
The estimated result of Equation (3) is presented in Table 4. The system GMM estimator
significantly reduces the size of parameters of labor and capital in comparison with estimate
of fixed effect and random effect. However, the coefficient of our prime interest, R&D
capital, is almost invariant to the use of the estimators. Results of the estimations suggest
that the output elasticity to R&D capital varies from 10% to 13%, which implies that 1%
increase in R&D capital leads from 0.10 to 0.13% growth in firms’ output. This estimate
is broadly in accordance with the estimates of Griliches (1979, 1986) for the US, larger
however than that of Branstetter and Chen (2006) for Taiwan and lower than three European
countries (O’Mahony and Vecchi 2009). Also, our estimated elasticity is substantially larger
than that of Raut (1995) for India, who finds it significant, however, small of the magnitude
(0.016%).

5. Conclusion and policy suggestions

Findings of this study suggest that in-house R&D activities of firms are crucial determinates
of productivity and output of the Indian pharmaceutical firms. In this study, we have tested
the effects in two frameworks: growth accounting and production function. Results of the
growth-accounting analysis suggest that R&D intensity has a strong, positive and significant
 Journal of the Asia Pacific Economy 339

effect (15%) on TFP growth. This estimate is slightly larger than the findings of the
international studies. The results also confirm that foreign firms operating in the industry
are more sensitive toward R&D activities than the local firms, as interaction of their dummy
with the R&D variable yields elasticity to 0.36, which means that 1% increase in R&D
intensity of foreign firms leads to 0.36% growth in their TFP. Furthermore, we investigate
the effects of R&D capital on firms’ output under the production function framework. The
results indicate that the output elasticity to R&D capital varies from 0.10 to 0.13, which
implies that 1% increase in R&D capital leads from 0.10% to 0.13% growth in firms’ output.
This finding is moderate in comparison with the estimated elasticity for other countries.
Considering the findings of this study on the crucial role of R&D in stimulating output
and productivity, it is a worrying factor that the Indian pharmaceutical industry is charac-
terized by low R&D intensity. Thus, there is a straightforward policy suggestion that the
government should encourage firms for R&D activities through different ways which may
include fiscal incentives, training and institutional collaboration. It is also noteworthy that
only allocating fiscal incentives cannot help firms, but its implementation at the ground
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level is also equally important. This is vital in the case of India because of the bureaucratic
hurdles often slow the pace of execution of the policies.10 Therefore, there is an urgent
need to overcome from such attitude. Moreover, foreign firms are found to be proactive in
R&D activities, which may have a positive spillover effects for the other firms in the long
run therefore flows of foreign direct investment in the industry should also be encouraged.
Finally, considering the findings in this study regarding the important role of in-house
innovation activities of firms, we propose for further research in this area especially in
developing countries using micro-level data.

Notes
1. Considering the example from firm-level studies, Griliches (1979, 1986) found that the elasticity
to R&D in the US manufacturing was around 0.07. In France, it was found that the elasticity
was larger than that in the US and it ranged between 0.09 and 0.33 (Cuneo and Mairesse
1984). For USA, Jaffe (1986) estimated the elasticity around 0.20. For the same country,
Griliches and Mairesse (1990) found it is ranging from 0.25 to 0.45, while in the same study, for
Japanese manufacturing, it was found to be ranging from 0.20 to 0.50. However, for Taiwanese
manufacturing firms, Wang and Tsai’s (2003) estimation suggested it as 0.19. In a recent paper,
Griffith et al. (2006) for the UK manufacturing firms found the size of the elasticity too low
(ranging from 0.012 to 0.029). In the case of India, the elasticity with respect to value added
was calculated to be 0.064 in the heavy industries, 0.357 in the light industries and 0.101 in the
overall industries (Raut 1995).
2. Firm-based studies generally indicated for a greater role of R&D investment in production than
industry-level studies.
3. However, it can be counter-argued that developing countries lose by granting patent protection
since the costs of patent protection outweigh its benefits (see, e.g., Penrose 1951, Vaitsos 1972,
Greer 1973).
4. India signed TRIPs in 1994; however, only since 1 January 2005, it was implemented in the
country.
5. Some of the important fiscal benefits are as follows:
(a) The benefit of weighted exemption on the income tax has been till 31 March 2015. (b)
Deduction is given on tax to depreciation on investment made in land and building for dedicated
research facilities, expenditure incurred on clinical trials and expenditure incurred for obtaining
regulatory approvals. (c) Reference Standard (sample under test) is exempted from import
duty. (e) Reference books to be imported for R&D are exempted from import duty. (f) On the
basis of recommendations of the Pharmaceutical Research and Development Committee, the
government provides some extra fiscal incentives to R&D-Intensive Companies (Gold Standard
Companies). (g) To fund the R&D initiatives of institutions and industry, the Pharmaceutical
 340 C. Sharma

Research and Development Support Fund (PRDSF) has a corpus of Indian rupee (INR) 1500
million to utilize.
6. Prowess database is an online database provided by the Centre for Monitoring Indian Economy
(CMIE). The database covers financial data for over 23,000 companies operating in India. Most
of the companies covered in the database are listed on stock exchanges, and the financial data
include all those information that operating companies require to disclose in their annual reports.
The accepted disclosure norms under the Indian Companies Act, 1956, make compulsory for
companies to report all heads of income and expenditure, which account for more than 1% of
their turnover.
7. Detailed discussion on dataset and transformation of variables can be seen in Sharma and Mishra
(Forthcoming).
8. To capture the export intensity of firms, we use ratio of export to value of sales of firms.
Theoretically exporting firms make themselves more productive and efficient to compete in
foreign markets, therefore we expect a positive impact of this variable. On the other side, the
import intensity of firms is captured by total import (imports of both raw material and finished
goods) to value of sales of firms (for detailed discussion on this issue, see Ben-David 1993,
Sachs and Warner 1995, Aw et al. 2000, Wagner 2002, Bernard and Bradford 2004). Importing
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firms may receive technologies as well as better inputs, which can potentially help firms to
enhance their productivity performance. Size of firms is accommodated in the model by using
logged value of sales of firms. Theoretically, because of economies of scale, a larger size and
increasing output should have a positive influence on the productivity of firms. Therefore, we
expect positive sign of this variable as well.
9. It’s important to note that two measures of R&D are used in the analysis. We have tested the R&D
impact on TFP by using R&D intensity (a ratio of R&D expenditure to sale). It is important to
note that two measures of R&D are used in the analysis. First, we test the R&D impact on TFP
by using R&D intensity (a ratio of R&D expenditure to sale). Second, R&D capital (deflated
expenditure on R&D activities) is used as an input in the output function (Equation 3).
10. It is also widely observed that in India, the general goal set by politicians consists of vague
statements and bureaucrats are left with considerable choice in translating the policy objective
into concrete decision rules.

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