More False Claims about Lobbying on Antiquities Issues

David Gill has recently addressed claims made by Peter Tompa that appear to have little basis in fact. Tompa is a lobbyist who represents commercial trade interests. He has alleged that the Cyprus American Archaeological Research Institute (CAARI) “was involved in behind-the-scenes lobbying on behalf of the Cypriot Department of Antiquities, the Cypriot government body that issues excavation permits that allow CAARI affiliated archaeologists to excavate on the Island.” The assertions are not substantiated further.

Ellen Herscher, the vice president of CAARI and an independent scholar, responded to Tompa’s claims after they were posted to the Museum Security Network. She stated:

CAARI’s Director and several trustees publicly submitted statements in support of the agreement. This position is in accordance with CAARI’s Code of Ethics, which states that the organization “is dedicated to the protection and preservation of archaeological sites in Cyprus and the information they contain.” There was no “behind-the-scenes lobbying” involved.

Secondly, “CAARI-affiliation” has nothing to do with the granting of excavation permits in Cyprus. Permits are the sole responsibility of the Department of Antiquities of the Republic of Cyprus.

It is unfortunate that the ACCG continues to publish these erroneous statements, despite the fact that CAARI has responded and refuted them in the past.

Gill asks the question:

Are “false claims” being deliberately planted by some of the North American coin-collecting community as part of the background to the test case over the coins seized in Baltimore? (For some more discussion of the “test case”, see Gill’s “The Baltimore Coin Test Case“).

The question is a provocative one, especially in the context of other false claims recently made by one group Tompa is involved with, the Ancient Coin Collectors Guild (ACCG).

On November 13, 2009 The Cultural Property Advisory Committee (CPAC) convened for an interim review of the bilateral agreement with Italy and asked for public comment to be restricted to Article II. Among other things under Article II, which covers Italy’s obligations, Italy would allow long-term loans to American institutions, access to scholars, and prosecute antiquities traffickers within its own borders. Evidently, the CPAC asked that public comment be confined to Article II due to the concerns of many members of the Association of Art Museum Directors (AAMD) who felt that Italy was favoring institutions that had returned objects to Italy and that more longer term loans ought to be made. Indeed, there were several AAMD members at the interim review who gave presentations to the CPAC (their written comments have been posted online).

Immediately after the interim review, Tompa insinuated that archaeologists departed from Article II and raised the specter of coins and their potential inclusion in the upcoming renewal with Italy (see Tompa’s “Interim Review of the Italian MOU“). He later claimed, innacurately, that Stefano De Caro, who spoke on behalf of Italy’s Culture Ministry, argued that all coins made within the borders of what is now modern Italy should belong to Italy (see Tompa’s “Is the Italian Cultural Bureaucracy the Best Steward for Coins?“). However, after being challenged, he conceded that he may have misunderstood.

The ACCG’s founder, who was not even present at the interim review, then authored a press release alleging that archaeologists opportunistically raised the issue of coins; he also portrayed the AIA representative’s comments as radical (see Sayles’ “Archaeologists Plead for Import Restrictions on Common Coins“; for a more balanced view, see the AIA representative’s reflections on the interim review). While Sayles pretended as if there is not near universal agreement among the archaeological community that looting and indiscriminate sourcing for the antiquities trade is detrimental to archaeology, he failed to note that many collectors have themselves voiced concerns that the status quo, which the ACCG seeks to protect, requires some internal reforms in the trade. Some have even gone so far as to observe that the ACCG is oriented more towards the concerns of commercial dealers rather than to collectors or the interests of preservation.

Wetterstrom, president-elect of the ACCG and its representative at the interim review, then authored an editorial in the Celator (a collector magazine that he operates) claiming that archaeologists at the meeting received special treatment and were not limited in the length of their presentations. He also writes that he was cut off early while reading his written comments that the CPAC already had in front of them (Tompa has reproduced Wetterstrom’s text in his “Another Perspective on CPAC and the Interim Review of the Italian MOU“).

Sayles then solicited another online press release, prompted by Wetterstrom’s editorial (“Collectors Claim Bias Epitomizes State Department Committee Management“). Here, Sayles falsely reports that “Other speakers, who advocate import restrictions on coins, were reportedly allowed to exceed the published time limit with comments ranging up to 30 minutes.”

In spite of the repetition of the claims by ACCG leadership, they have no basis in fact.

1) Archaeologists (note the ACCG’s use of the plural) were not afforded any special treatment. All speakers were allowed only five minutes and were told to finish if they reached their time limit. Wetterstrom, like all other presenters, received a full five minutes and was cut off only after exhausting his time while reading his letter verbatim. All other speakers made “off-the-cuff” presentations. The only individual who made a longer presentation was Stefano De Caro who had traveled from Rome for the meeting, and who spoke approximately 20 minutes. Although it is implied he was improperly given excess time, the ACCG fails to note that foreign dignitaries are customarily not limited in the length of their presentation. This is proper since they represent the countries who have petitioned for an agreement with the U.S. government. As regular attendees of CPAC meetings, the ACCG is well aware of this fact.

2) Archaeologists did not raise the specter of coins. The order of presentation clearly demonstrates this since Tompa and Wetterstrom spoke before any archaeologist. Both individuals urged the committee not to consider coins any future renewal of the agreement and both made reference to the “test case.” Archaeologists and numismatists who addressed the issue of coins during their presentations were simply responding to arguments made by Tompa and Wetterstrom that coins were not worth protecting because they are “common” or “cheap” on the market. But if one requires further proof, compare the written comments of Kerry Wetterstrom and Wayne Sayles, submitted to the CPAC in advance of the interim review, with the letter submitted by Sebastian Heath, the AIA representative. It is clear from the letters that, contrary to the ACCG’s portrayal of events, the ACCG were focused on arguing that coins not be considered in the future. On the other hand, the AIA representative made no suggestion that coins be included in a renewal and instead had prepared to focus on Article II of the MOU as requested. It was only in oral comments that archaeologists and numismatists were forced to respond to issues beyond Article II that were raised by representatives of commercial interests.

Gill’s question about whether or not false claims are being deliberately fabricated is penetrating, especially in the context of the misrepresentation of events at CPAC’s interim review. Is it indeed hoped that the spin put on these events will construct a reality that is more conducive to their litigious activities? In this regard, it is worth noting that one of the points in the ACCG’s 37 page complaint about the seizure, which they staged, states that archaeologists argued that the agreement with Italy be extended to coins, while failing to note that they brought up the question of coins in the first place (pdf here, see point 80).

Gill considers the current legal action pending against the US Department of State regarding the import of antiquities

From “Why are ancient coins from Cyprus featured in a suit against the US Department of State?,” PR Newswire, 26 June 2009:

 

SWANSEA, Wales,June 26/PRNewswire/ –David Gill, archaeologist, considers the recent Freedom of Information Act (FOIA) suit on the US Department of State.

The FOIA suit was served in November 2007by three numismatic organizations; one of the three is based in Brussels, Belgium. The alliance objected to the US Cultural Property Advisory Committee (CPAC) restricting the import of ancient coins minted in Cyprus as part of a wider memorandum of understanding (MOU). CPAC was responding to concerns by the Government of Cyprus that the illicit searching for ancient objects (including coins) was destroying the archaeological heritage of the Mediterranean island. CPAC states, “The MOU offers the opportunity for the U.S. and Cyprus to cooperate in reducing the incentive for further pillage thereby protecting the context of intact sites for scientific study.”

Coin collectors were also concerned about the 2009 MOU with China. This agreement also restricted the import of certain categories of coins.

As a result, one of the three numismatic organizations decided to test the resolve of the US Department of State in April 2009by attempting to import a small number of coins from Cyprus and China in defiance of the newly established laws. These items were detained when their flight from London touched down in Baltimore.

Are these aggressive legal tactics really for the benefit of collectors, or are there other factors at work?

Read the full discussion:

http://lootingmatters.blogspot.com/2009/06/antiquities-ancient-coins-and-changing.html

Unrecorded Ancient Coins from Britain for Sale in the United States: Grumblings and a Positive Response

On May 18, I called attention to two different mass suppliers of ancient coins in the United States who regularly sell bulk lots of “uncleaned ancient coins” from all over Europe and the Middle East (“Having Cake and Eating it too: Unrecorded and Freshly Dug British Coins Sold in the USA,” Numismatics and Archaeology). These two sellers had recently offered bulk lots of coins from Britain, which apparently were not imported into the U.S. with an export license from the UK and, perhaps more importantly, were not recorded in Britain’s Portable Antiquities Scheme (PAS) designed to recorded finds made by metal detectorists. Ten days later, I provided an update following an inquiry, launched by the PAS, to the two sellers in question and the Ancient Coin Collectors Guild (ACCG) (“Update: Unrecorded and Freshly Dug British Coins Sold in the USA“).

The ACCG was queried because it claims to be the voice for ancient coin collectors in the United States and is headed by several ancient coin dealers. The group has often touted the PAS as a solution to the “looting problem,” though there seems to be little self-regulation in the market itself that deals with illicitly exported coins.

Several dealers and ACCG members initially felt threatened by the attention that these two discussions gave them and, in fact, one ACCG intransigent tirelessly continues to make excuses for the lack of recording and to make personal attacks on the commentators who called attention to it and talked about it (see discussions of the attacks/excuses by Paul Barford here, here, here, here, and here).

In spite of the bluster from the one individual, some good has come of the incidents and the attention brought to it. After the PAS inquiry, former ACCG President, Peter Tompa, posted on his blog some links to export guidelines pertinent to coins and antiquities from Britain, which was followed some days later (one day after my update) by a post on the ACCG website: “UK Authorities Post Helpful Advice for Export of Coins.”

I applaud the ACCG for highlighting this information. I do hope this reflects a growing sensitivity within the trade community and that the ACCG leadership will, in the future, be more proactive in addressing the looting problem directly rather than simply lobbying against and challenging protective legislation. Knowledge will only be preserved if all stakeholders, including dealers and collectors, start to value it over purely commercial and self-interests. The preservation of information is something we should all be concerned about and something which we all ought to work towards, especially for those of us who study the past or buy and sell pieces of it.

Response to “Cultural Property Observer” July 9 2008 blog post

On July 9 2008, a post entitled “Saving Antiquities for Everyone: Grassroots or Astro Turf?” appeared on the blog “Cultural Property Observer” which raised questions about SAFE’s membership, funding sources, position on the Ancient Coin Collectors Guild and coin collecting, as well as SAFECORNER’s support “for Iraqi Government control over Jewish holy books” and “SAFE members’ kudos for China’s treatment of Tibet’s cultural heritage at the CPAC hearing on the Chinese request for import restrictions.”

We think that this is a good opportunity for SAFE, who runs SAFECORNER, to bring our readers’ attention to the information on the SAFE website, which also answer these questions raised by “Cultural Property Observer”.

SAFE’s membership:
Please read “Who is SAFE?” to learn about the people who keep SAFE going.

Funding sources:
Please see here. Additional funding comes from fundraising activities listed here We also solicit private donations via the website.

To date, SAFE has not received government funds.

Position on the Ancient Coin Collectors Guild and coin trade:
Please read paragraph 3 of SAFE’s Statement of Principles:
SAFE encourages legal and ethical behavior among collectors, dealers, and museums to stop the trade in illicit antiquities. SAFE recognizes the ability of individuals and institutions to lawfully acquire and properly retain or transfer title of antiquities where authorized by law. However, antiquities are more than just aesthetic objects of beauty; they serve as historical evidence of the past. Because principles of supply and demand influence illegal antiquities trafficking, purchasers of antiquities should recognize that high demand can entice others to illegally excavate archaeological sites, smuggle illicit antiquities, and sell stolen objects. Such unlawful and unethical behavior permanently destroys information about the past.

SAFE has made no statement about the Ancient Coin Collectors Guild.

SAFECORNER’s support “for Iraqi Government control over Jewish holy books”:
Please see paragraph 2 of SAFE’s Statement of Principles and Import Restrictions Imposed on Archaeological and Ethnological Material of Iraq sections III.G.1, IX.F and X.D.

SAFE promotes respect for the laws and treaties that protect cultural heritage and property. SAFE favors accountability for those who violate United States laws and/or tolerate the violation of other countries’ laws in pursuit of cultural artifacts. SAFE supports the enforcement of international and bilateral cultural property agreements.

“SAFE members’ kudos for China’s treatment of Tibet’s cultural heritage at the CPAC hearing on the Chinese request for import restrictions”:
The word “Tibet” doesn’t even appear in any of the 3 statements supplied by SAFE members to the CPAC committee.
_______

Finally, we would like to point out that while SAFECORNER invites members of the SAFE community and other experts and opinion leaders in the field of cultural heritage protection to post on the blog, it does not necessarily mean that the opinions of the authors represent those of SAFECORNER, or the organization SAFE. SAFECORNER provides an open forum for discussion where dialogs begin, ideas exchange, and concrete solutions emerge concerning looting and the illicit antiquities trade. Please also read Blogging on SAFECORNER.

For further information, please review the SAFE’s Terms and Conditions of Use, specifically sections 5.1, 5.2 and 5.3.

Thank you for visiting our blog and participating in our discussions.

SAFECORNER

The ACCG "Benefit Auction"

I have critiqued the goals, motives, and tactics of the Ancient Coin Collectors Guild (ACCG) several times (those unfamiliar with the ACCG are urged to consult a list of some relevant web-postings at the end of this discussion). For those who do not know, the ACCG is a 501 (c) 4 organization to which financial contributions are not normally tax deductible since up to 100% of its funds can be used for the purposes of political lobbying. According to its website, the goal of of the ACCG is to maintain a “free-market” in all coins. It has lobbied against legislative measures designed to protect archaeological and historical sites from destruction. A possible financial motive for its activities may be apparent in the fact that its founder and most of its officers are ancient coin dealers, and the majority of its financial contributors (especially the larger contributors) are ancient coin and antiquities dealers and auction houses.

In November of last year, the ACCG announced it was suing the U.S. Department of State under the Freedom of Information Act (FOIA) for more transparency on the process under which it decided to impose import restrictions, at the request of Cyprus, on certain ancient coins of Cypriot type. Many who are familiar with the “blogstorm” last fall about these issues will recall that several vocal ACCG members and dealers were alleging various conspiracies between archaeologists and State Department officials( links here and here to relevant posts, some of which reference dealer accusations). A “benefit auction” for which the ACCG has been soliciting donations, which it will auction on August 17, 2008, has now sparked my interest.

…Read the rest of the post at Numismatics and Archaeology: “The ‘ACCG Benefit Auction’ and Intrinsic Interests.”

Towards a Forum for Constructive Dialogue

Although I have critically examined the trade in ancient coins, I have never proclaimed an “anti-collecting” position; instead, I have been concerned with destruction and the problems caused by indiscriminate collecting. Over the past several months it has become clear that our viewpoints diverge on philosophical and statistical elements, e.g. the relative value of contexts and scale of the flow of ‘fresh’ materials into the marketplace. Although we differ on these issues I hope we can agree that there are valid points that emerge from the concerns of both ‘sides': e.g. collectors have a genuine interest in and passion for the ancient world; collectors can make (and have made) important contributions to serious numismatic research; the destruction of sites and information is deplorable; and the market at large is supplied by freshly dug material to some degree, as multiple collectors and dealers have acknowledged on various discussion lists.

I think if we can agree on such points we can perhaps move forward with a more constructive dialogue that goes beyond our electronic exchanges and works towards addressing the concerns of academics, cultural heritage preservation advocates, collectors, and dealers in a way that may lead towards solutions that are amenable to all concerned parties. Collectors and dealers wish to trade in ancient coins as they have done; others believe that a controlled market will contribute to curbing the destruction of sites and information. Perhaps we can come together and have a meeting of minds. For example, I have seen proposed models of databases, which might curb the flow of recently dug material into the market if they were used as registries and universal market guidelines were adopted concerning the sell of unregistered material; several weeks ago some of these were discussed on the Unidroit list. I note that one active ACCG member, Jim McGarigle, was the author of one interesting suggestion/model. One thing that I discussed with a colleague several weeks ago was the prospect of a sort of conference or panel that would explore solutions and discuss various methods of implementation.

Such a conference or panel would be hosted by some mutually agreed upon organization, which has no special interest in one ‘side’ or the other and a mutually agreed upon moderator could be chosen as well. Different groups could, perhaps, send a certain number of delegates/presenters to discuss some models that would both work toward establishing greater transparency of market activity in an attempt to diminish the role market demand plays in active looting and facilitate cooperation between academics and members of the trade community at large and establish an atmosphere of greater trust. After the conference, a panel or committee consisting of members from different groups could explore the feasibility and implementation of such models. If it is agreed some event like this would be beneficial, I would look forward to working with interested parties towards that end.

Archaeologists don’t care about ancient coins?

The notion that classical archaeologists do not care about ancient coins, or are ignorant of the utility of their study, is a myth repeatedly perpetuated by vocal members of the coin dealer lobby. One evident example is on the FAQ page of the Ancient Coin Collectors Guild (ACCG):

“Aren’t archaeologists good custodians of ancient coins?

While a few dedicated archaeologist-numismatists do care about coins and have used them to make important contributions to the study of numismatics, many, if not most, archaeologists view coins as just one means to date archaeological sites. Most well preserved specimens that numismatists prize do not even originate from archaeological sites. That is because most large hoards rarely come to light at archaeological sites; the ancients typically sought to hide their savings away from the prying eyes of neighbors. Instead of large hoards of well preserved coins, archaeologists typically find large numbers of ancient “small change” that was lost over time. Such coins are often so corroded by direct exposure to the soil as to be deemed uncollectible. Archaeologists tend not to treat such coins as important historical objects in themselves. Instead, after they serve a limited purpose as but one means to date archaeological sites, coins are all too often dumped into plastic bags and left to deteriorate in storage that usually lacks proper environmental controls.”

While there are some small grains of truth in aspects of this statement (e.g. some archaeologists and numismatists are slow to publish and make finds available for study), the claim that is made (essentially that archaeologists are not competent enough to study coins) is unsubstantiated and false; furthermore, the absolute contrary is demonstrable (see, for example, “Why Coins Matter,” “Misunderstanding the Portable Antiquities Scheme.” The Intellectual Consequences of Collecting Classical Coins,” “It’s All the Same: the Looting of ‘High Art’ vs. the Looting of the Minor Arts,” “Coins, Contexts and Collecting,” and “Can Cultural Property Legislation Kill an Academic Discipline?“).

The falsehood that archaeologists are too incompetent to advocate for the the protection of ancient coins from archaeological sites, even though they are important archaeological objects routinely found at archaeological sites, is evidently perpetuated by vocal members of the dealer lobby in order to present themselves as more appropriate custodians of ancient coins, in an attempt to lend credence to their arguments that ancient coins should be freely traded without a concern for the circumstances concerning their origin and journey to the market and to protect “trade secrets.” The latest unsubstantiated assertion of this idea was posted yesterday by one of the lobby’s top leaders, Wayne Sayles, who is the founder and Executive Director of the Ancient Coin Collectors Guild (ACCG). In the blog entry “Intrinsic Interests,” he attempts to contextualize the interest of the Archaeological Institute of America (AIA) in cultural property issues relating to ancient coins as “sudden” and as an assault on private collectors, referencing the AIA’s post on Archaeology Watch about “Coins and Archaeology”. Mr. Sayles has routinely criticized classical archaeology in general terms and the AIA more specifically for its concerns relating to the protection of cultural heritage and archaeological sites (see for example “Hijacked by Zealots” and “Archaeology: a Wolf in Sheep’s Clothing?“).

In his latest post, Mr. Sayles disparages the AIA and classical archaeologists in general by saying:

“The more that archaeologists learn about coins from antiquity, the more they will realize that the context within which they are found is merely one aspect, and a small one at that, of the tremendous historical resource that coins present.”

He continues:

“Unfortunately, the AIA’s motives for this blossoming interest are suspect. Having virtually ignored coins for scores of years, why is the AIA disposed now to highlight the value of coins to archaeology? The answer is really quite basic. The numismatic community, comprised primarily of independent scholars, has argued effectively that archaeologists do not have a preeminent claim to the acquisition or study of ancient coins, much less to the dissemination of knowledge about them and about the past from whence they came. If the AIA were to acknowledge this simple fact, it would expose a chink in the armor of their perceived supremacy. So, be prepared to see a lot more ink spilled by the AIA and other archaeological support groups regarding the “importance” of coins. Oddly, collectors have always known that coins are important. This awakening by archaeologists is probably a good thing if they really consider the issues rather than just fill the web and print media with institutional propaganda.”

These comments reflect either a lack of knowledge regarding both classical archaeology and academic contributions to numismatics or a desire to gloss over them. Instead of responding to sweeping generalizations and unsubstantiated assertions with the same, I shall respond with some facts:

Fact 1. Contrary to the assertions, classical archaeologists have always cared about ancient coins and DO study them (the Archaeology Watch webpage in question addressed the value of coins in archaeology); additionally, numismatists regularly participate in AIA activities and are an integral part of that organization. Please do not take my word for it, but take the evidence into account. A keyword search of “coins” from the online abstract archive for the 2004, 2005, 2006, and 2007 AIA meetings returned 57 papers directly addressing or relating to numismatic topics; I include the full list of results:

Abstracts from the 2007 Meeting

-The Philaïd Coinage of the Thracian Chersonesus, Sarah Bolmarcich, University of Michigan

-Symbolic Rivalry on the Imperial Coinage of the Island of Lesbos, Matthew F. Notarian, University at Buffalo-SUNY

-Icaria: History and Coins, Evangelia Georgiou, University of Ioannina

-Political Ideology and Roman Architectural Coin Types of the Republic and Empire, Nathan T. Elkins, University of Missouri-Columbia

-Roman War and Republican Coin Types, Rosemarie Trentinella, New York University

-Cistophori and Identity in Roman Asia Minor, Marsha B. McCoy, Austin College

-Research at the Castle of Marko in the Republic of Macedonia, Michael Fuller and Neathery Batsell Fuller, St. Louis Community College

-Excavations at Sarhoyok-Dorylaion in Phrygia Epictetos/Turkey, Taciser Tufekci Sivas, Anadolu Universitesi

-Discovery of the Roman Forum of Buthrotum (Butrint): Current Excavations, David R. Hernandez, University of Cincinnati

-Spectator Galleries on Honorary Arches: An Overlooked Function of Roman State Architecture, Martin Beckmann, Wilfrid Laurier University

-Maxentius and the Temple of Roma, Elisha Ann Dumser, Ursuline College

-Hellenistic and Roman Coins from Gordion: A Case for Monetization, Kenneth Harl, Tulane University

-Traces of Hellenistic Petra: Excavations on the Temenos of the Qasr al-Bint, Petra, Jordan, Andreas J.M. Kropp, University of Nottingham

Abstracts from the 2006 Meeting

-Starry Heroes in Late Ancient Rome, Dennis Trout, University of Missouri-Columbia

-Dharma or Diplomacy? A Reassessment of Cultural Policy in the Indo-Greek Kingdom, Jed M. Thorn, University of Cincinnati

-The Heroon at Messene: New Observations on Order, Style, and Date, Pieter B. F. J. Broucke, Middlebury College

-New Glass Finds from Cyprus: Evidence for Ritual, Dating, and Trade, Danielle A. Parks, Brock University

-Images of the Illustrious and the Reconstruction of the Past on Titus’s Restored Coins, Sarah E. Cox, Columbia University

-Monumental Messages: The Meaning of Changes in the Representation of Architecture on Roman Coins in the Early Empire, Martin Beckmann, University of Heidelberg

-Determining the Function of the So-Called Temple of Romulus in Rome, Elisha Dumser, University of Pennsylvania

-The Intensive Urban Survey Project at Kastro Kallithea, Greece: First Results, Margriet J. Haagsma and Sean Gouglas, University of Alberta, Athanasios Tziafalias and Sophia Karapanou, 15th Ephorate of Prehistoric and Classical Antiquities

-The Last of the Scythians, Nancy T. de Grummond, Florida State University

-Presenting the King: Herod the Great and Political Self-Presentation, Adam Kolman Marshak, Yale University, and Rebecca Donahue, Boston Society of the AIA

-Italian Bronze Age Pottery and Twenty-First-Century Scholarly Communication, Susan S. Lukesh, Hofstra University, and R. Ross Holloway, Brown University

-Harboring Fantasies in Roman Crete, George W. M. Harrison, AIA Member at Large

-Numismatic Paronomasia and the Case of Caesar’s Elephant, Edward Zarrow, Yale University

-Augustus’s Altar-ed State: The Altars of the Lares Augusti on Augustan Quadrantes, Lea Cline, The University of Texas at Austin

-The Origins of the Commemoration of Women on Roman Coinage, Tracene Harvey, University of Alberta, Edmonton

-The Function and Distribution of the Flavian Colosseum Sestertii: Currency or Largess? (Results of a Die Study), Nathan T. Elkins, University of Missouri-Columbia

Abstracts from the 2005 Meeting

-The “Numismatic Habit”? Roman Coins and Roman Inscriptions from Augustus, Edward Zarrow, Yale University

-Stone Offering Boxes (Thesauroi) in the Ritual and Administration of Greek Sanctuaries, Isabelle Pafford, UC Berkeley

-The Bust-Crown, the Panhellenion, and Eleusis: A New Portrait from the Athenian Agora, Lee Ann Riccardi, The College of New Jersey

-The “Skyphos Sanctuary” on the North Slope of the Acropolis, Kevin T. Glowacki, Indiana University, and Susan I. Rotroff, Washington University in St. Louis

-Imperial Cult in the Colosseum, Nathan T. Elkins, The University of Missouri, Columbia

-The Use of Die Studies as a Corrective to Late Seleucid History, Oliver D. Hoover, The American Numismatic Society

-Royal Women in Nabataea: The Case of Rabbel and Shuqailat, Bjorn Anderson, University of Michigan

-Conceptions of Rome: The Meta Sudans on Roman Imperial and Provincial Coinage, Brenda Longfellow, University of Michigan

-Under the Gaze of the Empress: Succession and Political Participation in Severan Coinage, Julie Langford-Johnson, Indiana University, Bloomington

-Communicating Royal Power in the Bosporan Kingdom, Patric-Alexander Kreuz, Freie Universität Berlin

-Keeping Up with the Seleucids and the Ptolemies, Olga Palagia, University of Athens

-Hellenistic Geronthrai: Archaeological Evidence for the Changing Life of a Perioikic Community at the Foot of the Parnon, Mieke Prent and Joost H. Crouwel, University of Amsterdam, and Elizabeth Langridge-Noti, The American College of Greece

-The Origins of Pompeian Domestic Architecture: New Evidence from the House of the Surgeon, Rick Jones and Damian Robinson, University of Bradford, and Steven J.R. Ellis, The University of Sydney

Abstracts from the 2004 Meeting

-False Fronts: Separating the Imperial Cult from the Aediculated Facade in the Roman Near East, Barbara Burrell, University of Cincinnati

-A Late Roman Settlement “Explosion”? The Continuity and Reuse of Sites in the Eastern Corinthia, David K. Pettegrew, The Ohio State University

-A Sample of Bullae from Zeugma, Sharon Herbert, University of Michigan

-Embellishing the Garden: A Glimpse of Private Life in Julio-Claudian Cosa, Jacquelyn Collins-Clinton, Cornell University

-The Apadana Coin Hoards, Darius I, and the West, Antigoni Zournatzi, The National Hellenic Research Foundation, Athens

-Ponēra Khalkia: Towards the Contextualization of Archaic/Classical Plated Coinage, Peter van Alfen, American Numismatic Society

-Regional Economy and Reconstruction: The Stymphalos Hoard of 1999, Robert G.A. Weir, University of Windsor

-Beyond Payment: Alternate Uses of Coins in the Ancient World, Sebastian Heath, American Numismatic Society

-Excavations in the Athenian Agora, John McK. Camp II, American School of Classical Studies at Athens and Randolph-Macon College

-Preliminary Report on the Hellenistic Material from the Dutch Excavations at Geraki (Geronthrai) in Laconia, Elizabeth Langridge-Noti, American College of Greece, and Mieke Prent, University of Amsterdam

-The Emperor, the Sun, and the Son: The Arch and the Colossus in Constantine’s Rome, Elizabeth Marlowe, Columbia University and American Academy in Rome

The 2008 meeting’s preliminary program is also online and includes several papers and panels directly addressing numismatics.

Fact 2. In addition to scholarly numismatic journals, such as the Numismatic Chronicle or the American Journal of Numismatics, other journals frequently host articles on numismatic topics, especially archaeological journals. Since July 2005, the American Journal of Archaeology(AJA), a publication of the AIA, has hosted at least four articles that address numismatic topics:

The Date of the Sardis Synagogue in Light of the Numismatic Evidence
Author: Jodi Magness
Volume: 109.3, Pages: 443-475

New Archaic Coin Finds at Sardis
Author: Nicholas Cahill and John H. Kroll
Volume: 109.4, Pages: 589-

Archaeology of Empire: Athens and Crete in the Fifth Century B.C.
Author: Brice Erickson
Volume: 109.4, Pages: 619-

Visualizing Ceremony: The Design and Audience of the Ludi Saeculares Coinage of Domitian
Author: Melanie Grunow Sobocinski
Volume: 110.4, Pages: 581-602

The AJA is a quarterly academic journal, which typically hosts between 3 and 5 articles per journal; and thus, numismatic topics can comprise a rather significant part of intrinsically related disciplines represented in the journal (e.g. ceramics, numismatics, topography, etc.), considering the journal addresses classical archaeology as a whole. For our readers that have JSTOR access or live in proximity to a good library, one can see that back issues of the AJA contain a plethora of numismatic articles and that the AJA is an important resource for numismatic research (more specifically see Sebastian Heath’s recent comments, on Sayles’ blog entry, about the history of the AJA and its long association with numismatists and numismatic publication). Other archaeological journals, which may be unfamiliar to many collectors and dealers, such as the Journal of Roman Archaeology, frequently host numismatic topics.

Fact 3. Contrary to what some members of the dealer lobby would have the general public and their constituents believe, the AIA has a strong relationship with numismatists. For example, the current AIA president is an alumnus of the American Numismatic Society graduate seminar on Greek and Roman numismatics, has taught graduate seminars on numismatics, and also has published books and articles that incorporate numismatic evidence. There is also a numismatist currently on the AIA’s Board of Academic Trustees. Additionally, one of the AIA’s largest “interest groups” is the “Friends of Numismatics,” which is comprised of alumni of the American Numismatic Society graduate seminar and other numismatists; the Friends of Numismatics meet annually at the AIA meeting. (Note: the “Friends of Numismatics,” associated with the AIA, should not be confused with the ACCG’s “Friend of Numismatics” award, which the lobby uses to honor individuals who “advance” or “protect” ancient coin collecting).

Fact 4. Unlike the AIA, the ACCG is a new organization, founded within the past few years, which arose in response to cultural property advocacy efforts that conflict with the interests of ancient coin collectors and especially dealers, who comprise most of the organization’s officers, all of its “benefactors,” and the majority of its “patrons.” The ACCG’s goals are highlighted on its “objectives” page. One of the ACCG’s primary aims is “to fight for the continued existence of a free market for all collector coins.”

Mr. Sayles pretends as if archaeologists know nothing about coins, objects which are commonly excavated at classical archaeological sites, and attempts to portray advocacy efforts to protect the contextual study of ancient coins and archaeological sites as misguided, since (in his mind) archaeologists should know nothing about coins. In my view, the AIA’s Archaeology Watch page, which Mr. Sayles rails against, reflects a concern many archaeologists have had for decades about looting and the role of the antiquities trade – which includes the trade in ancient coins – in the destruction of archaeological sites and historical information.

Why was the Archaeology Watch page on “Coins and Archaeology” posted this year? Anyone who has been following the discussions on ancient coins and cultural property (for example, on Looting Matters, SAFECORNER, or elsewhere) knows that Cyprus’ request for import restrictions on ancient coins and the U.S. State Department’s subsequent recognition of that request has caused an outcry from the coin dealer lobby, a lobby that attempts to thwart any legislation or protective measures designed to protect archaeological sites and cultural heritage should that legislation include anything that may hinder a completely unregulated and “free market” in ancient coins. Although I am not privy to the immediate circumstances regarding the AIA’s decision to post the “Coins and Archaeology” page, I suspect the ACCG’s outspoken activities, its unceasing assaults against the AIA and classical archaeology in general, and its gross oversimplification of the issues might have contributed to it.

The unregulated trade in ancient coins is responsible for some systematic looting and is forever destroying an important avenue into critical historical inquiry. These issues have already been examined in “Why Coins Matter” and a more substantial work is in preparation. The dealer lobby consistently downplays the value of context and asserts that collectors and dealers are the only people able to produce “scholarship” on ancient coins (see “Can Cultural Property Legislation Kill an Academic Discipline?”). Indeed, context is not the only aspect of numismatic or scholarly inquiry, but it is an important one and one that is essential to serious economic, circulation, and even iconographic studies. Context is an highly important aspect of any archaeological object or historical document and this aspect of an object should not be destroyed or ignored if at all possible. What if the Reka Devnia hoard had been found by a looter or metal detectorist and sold on the market with no record of its find spot or context? (The Reka Devnia hoard is one of the largest, if not the largest, ancient coin hoards ever discovered and contained c. 350 kg of silver Roman coins; it was excavated at Marcianopolis (see David Gill’s blog entry “Misunderstanding the Portable Antiquities Scheme” and comments there)).

In his newest blog post, Mr. Sayles betrays his misunderstanding of archaeology and has again drawn a distinction between “collectible” coins and “worthless” coins that are on the market. Another numismatist has commented that what Mr. Sayles has egregiously labeled “junk” and “trash” are invaluable historical sources. To an archaeologist and field numismatist, all coins are essential to understanding our history and the conditions under which our ancestors lived.

It is constantly claimed by vocal members of the ancient coin dealer lobby that classical archaeologists and cultural property advocates are driving a wedge between numismatists and the academic community. The facts do not support this spurious claim; as was related above, the AIA, for example, is an organization that embraces numismatists and numismatic research. In fact, it is the ancient coin dealer lobby painting a picture of discord, perhaps to rouse action from collectors and lawmakers in Washington to protect their ability to import and trade in “fresh” material indiscriminately, regardless of that material’s origin or the conditions regarding its acquisition (see again “Why Coins Matter” on the source of much of the new material presently on the market; also cf. Hall, J.L. 2007. “The Fig and the Spade: Countering the Deceptions of Treasure Hunters.” Archaeology Watch. 15 Aug., on how groups with a financial interest in trading in antiquities attempt to win public approval by portraying themselves as practicing serious scientific and scholarly activities). If ACCG leaders seriously want a “constructive dialogue,” let us stick to the facts and avoid the reactionary emotional responses and unsubstantiated generalizations and assertions that lack veracity.

*Since I am responding to criticisms leveled against the AIA specifically, but also classical archaeology as a whole, I should note that although I am a member of the AIA, the views presented here do not necessarily reflect the individual views of the AIA’s leadership, the general membership, or its institutional stances. Instead, I respond here in my capacity as a classical archaeologist and a numismatist sensitive to issues relating to looting and the widespread destruction of archaeological and historical information, and as an individual concerned about the future our ability to critically examine and understand humanity’s past – the forbearers of modern civilization – through disciplines that incorporate the study of material culture via the application of a scientific methodology.

Coins, ethics and scheduled monuments

Nathan Elkins has raised some important issues in “Codes of Ethics vs. the Financial Interest“. It has drawn my attention to the code of ethics published by the ACCG.

Appended to the rather brief list is this statement:

“The ACCG Board of Directors also agreed that the standards of conduct of museum professionals and archaeologists ought to include certain issues like conservation, publishing responsibilites, respect for private ownership and public access. These concerns will be communicated to the appropriate organizations or associations in the form of an ACCG petition for consideration.”

In the interest of dialogue, can I take the opportunity to give some feedback on ACCG point 1?

“Coin Collectors and Sellers will not knowingly purchase coins illegally removed from scheduled archaeological sites or stolen from museum or personal collections, and will comply with all cultural property laws of their own country.”

Elkins has already commented on the clause “comply with all cultural property laws of their own country”. But we have seen with the return of antiquities from North American collections to Italy that objects apparently purchased or donated and in compliance with US laws were still deemed to have left their country of origin illegally. (See observations by Gill and Chippindale on the Boston return.) There were good ethical (and professional) reasons for distinguished institutions like the Metropolitan Museum of Art in New York, the Museum of Fine Arts in Boston, and the J. Paul Getty Museum to co-operate with the Italian authorities.

But what about the first section, “coins illegally removed from scheduled archaeological sites”? In the UK “scheduled” has a distinct meaning. But I presume that this part of the code suggests that it is unacceptable to remove coins from known, listed (“scheduled”) archaeological sites. But what about the archaeological sites that have yet to be discovered? Is it acceptable to destroy undisturbed archaeological contexts because by “chance” the site is unknown to archaeological science?

Then there is the phrase “will not knowingly purchase coins”. Elkins has commented on the “Don’t Ask, Don’t Tell” policy. So an ethical policy needs to ask questions. A purchasing strategy needs to be rigorous.

So can I presume to make a humble stab at rephrasing code 1? (And can I suggest three clauses?)

a. Coin Collectors and Sellers will seek to be rigorous in establishing the collecting history (“provenance”) of the coins that they acquire.

b. Coin Collectors and Sellers will not buy coins that they know or reasonably suspect were removed from archaeological sites or stolen from museum or personal collections.

c. Coin Collectors and Sellers will comply with all cultural property laws of the countries associated with the material that they aspire to acquire.

Codes of Ethics vs. the Financial Interest

It is curious that some groups of antiquities dealers have adopted “Codes of Ethics,” which do not seem to be rigorously enforced or acknowledged in practice. One group of ancient coin dealers that claims to advocate for cultural preservation, while opposing any legislative efforts designed to curb looting and the trade in illicit antiquities that also affect the unregulated trade ancient coins (routinely found in archaeological contexts), has adopted such a code. The Ancient Coin Collectors Guild (ACCG) has adopted a “Code of Ethics” for its members, which states: “Coin Collectors and Sellers will not knowingly purchase coins illegally removed from scheduled archaeological sites or stolen from museum or personal collections, and will comply with all cultural property laws of their own country.” VCoins, an online “coin show” hosting multiple dealer inventories, also has a similar statement in its “Code of Ethics.” The careful wording of the ACCG “Code of Ethics” seemingly allows the dealer lobby and its members to skirt the actual problem of provenance by stating that they will not trade in coins that come from “scheduled archaeological sites.” Does this mean they can feel free to trade in coins robbed from historical sites that are not currently being excavated?

The vast majority of ancient coins imported by dealers and subsequently sold have no recorded find spot or an old pedigree, so where do they come from anyway? Who knows! Additionally, the statement that the ACCG “will comply with all cultural property laws of their own country,” along with the relative lack of enforcement, allows for the potential to import illegally excavated and exported material with a clean conscience since the U.S. does not have import restrictions on ancient coins with many foreign nations (except Iraq and, recently, Cyprus), although it is illegal prospect for or to export coins from most source countries without a permit – especially important source countries like those in the Balkans.

Generally, among the North American ancient coin dealing community, there appears to be a “Don’t Ask, Don’t Tell” policy in effect regarding their participation in the trade of undocumented and potentially illegally excavated/exported material: import and sell the material, just “don’t ask and don’t tell” where it came from (for example see some dealer suggestions to circumvent legal issues with illicitly imported coins in David Gill’s blog entry, “Cyprus, eBay and the Coin Lobby”). Should American citizens and coin collectors expect or even accept such unscrupulous activity from sellers? It is documented that similar practices amongst dealers of other sorts of antiquities exist (see Cook 1991, 533-534; cf. Karich 2006). Dealers of uncleaned ancient coins have also adopted a “Code of Ethics,” which deals only with selling practices and does not make any presumption to prohibit the import of coins that were illegally exported or excavated.

A number of the ACCG’s donating ‘patrons’ actively import ancient coins in bulk and often sell them in bulk without any record of provenance. In fact, one ancient coin dealer and patron of the ACCG is also, curiously, the president of a customs clearing company in New York and is one of the more important suppliers of bulk lots of uncleaned coins in the U.S. This individual also deals in other types of antiquities, many of which appear to be of Balkan origin and has online storefronts on VCoins.

Despite the rhetoric and token “Codes of Ethics” subscribed to by some groups of antiquities dealers, it is clear that antiquities and ancient coins are being systematically looted from historical and archaeological sites at an alarming rate in order to supply for market demand. This activity is destroying valuable contextual and historical information in the process, harming not only archaeological and historical inquiry, but also – in the case of ancient coins – the “science of numismatics” (for further discussion see the article “Why Coins Matter…,” which should be made available on the SAFE website within a week).

REFS:

Cook, B.F. 1991. “The Archaeologist and the Art Market: Policies and Practice,” Antiquity 65.248: 533-537.

Karich, S. 2006. “Der Bundesverband Deutscher Kunstversteigerer hat einen neuen Verhaltenskodex für seine Mitglieder aufgestellt. Transparenz ist bisher nicht immer vorhande,” Frankfurter Allgemeine Zeitung 180 (05 Aug.): 47.

Can Cultural Property Legislation Kill an Academic Discipline?

To those of us who advocate for cultural property protection, it is impossible to think that such efforts would have anything but positive effects on the preservation of information and cultural heritage. However, one lobby, the Ancient Coin Collectors Guild (ACCG), opposes such protective measures as they relate to the uncontrolled trade in ancient coins and assert that if cultural property legislation were to affect the trade in ancient coins it would kill numismatics (the study of coins) as a science. (This is a common theme, among others, in the blogs of ACCG officers and activists such as Wayne Sayles and Dave Welsh). In so doing, members of this lobby (the majority of its officers and leadership being dealers as well as all of its benefactors and most of its patrons) assert that they are protecting the interests of “numismatic scholarship.” Does this claim have any validity to it? Can cultural property legislation kill numismatics as an academic discipline?

In short, my point of view is the quite contrary; ancient coins must be considered by cultural preservationists no differently than any other ancient object and that protective efforts can only preserve valuable numismatic information (for the value of coins studied in context and the need for greater awareness of and attention to the unregulated trade see, in general, Beckmann 1998, von Kaenel 1994; 1995; 2007). When ancient coins are found in archaeological contexts they provide a wealth of information that does not come with undocumented coins that appear on the market, lacking any context or provenance. Additionally, the majority of ancient coins enter the market the same way that most antiquities enter the market – through suspect means (see Kersel 2006 for one of the most recent discussions of the way ancient objects make it to the antiquities market – she discusses ancient coins in particular). Archaeological sites throughout Europe and the Middle East are systematically looted in order to provide ancient coins for the market, which are frequently smuggled in large quantities to destination countries. One published account records the interception of approximately 20,000 ancient coins (originating from Bulgaria) at Frankfurt airport, a shipment bound to the U.S.; customs officials determined this one shipment comprised just one of many others which had previously gone through the airport recently and the total smuggled out was in the area of a ton (c. 340,000 ancient coins; see Dietrich 2002). This quantity represented only the actions of a single smuggler in a relatively short period of time.

Perhaps just behind pottery sherds, ancient coins are the most common archaeological finds. This is certainly the case at Yotvata, a remote auxiliary fortress on the Roman Empire’s borders, where I work as the site’s numismatist. In addition to dates, coins in archaeological contexts provide information that can help numismatists and archaeologists to understand the expansion and contraction of settlements, areas of importance and the movement of peoples within a specific settlement. Additionally, coins in context are invaluable to studies of the ancient economy and circulation studies. In fact, contextual study of ancient coins is an increasingly important aspect of serious numismatic and archaeological research. Entire research centers can be devoted the study of ancient coins in archaeological contexts as at Frankfurt University, where one department publishes the inventories of coin finds from archaeological contexts in Germany, Fundmünzen der römischen Zeit in Deutschland – a project which has inspired similar projects in other countries. Additionally, this department sponsors a very important numismatic monograph series that publishes contributions in English, French, Italian, and German that study ancient coins in archaeological contexts (Studien zu Fundmünzen der Antike). From October 25-27, this department is also hosting a three day conference on “Coins in Context.” (For additional information on the scientific value of coins in archaeological contexts, see the AIA’s page and my forthcoming article on the SAFE website).

One vocal lobby member and officer recently proclaimed:

“Numismatics is a much older science than archaeology, which has made many important contributions to the historical record and whose teachings (to which archaeology has contributed very little)are used by archaeologists as a stratigraphic dating tool. It is ironic that this venerable and beneficial field of study is now threatened by a discipline that could hardly be said to exist until the twentieth century, and really began to take shape only after the end of WWII. There are very few (if any) archaeologists who have any knowledge of numismatics, its accomplishments or its importance.”

In my view, the lobby’s rhetoric and assertions that archaeologists know nothing about numismatics are simple fabrications that have no basis in fact and are easily disproved. Dozens of archaeologists are also numismatic experts and some of the leading authorities on ancient coins are archaeologists employed by museums and universities (http://msn-list.te.verweg.com/2007-August/007945.html; for other lobby tactics see David Gill’s blog entries: “Coins, Cabals…and Huff and Puff,” and “Coins and Cyprus: Listening to the Coin Forum”). Familiarity with serious numismatic research also indicates the contrary. Numismatics contributes to archaeology and archaeology contributes to numismatics. One of the best examples of how contextual archaeological study has contributed to the study of ancient coins is from Morgantina, where stratigraphic excavation allowed archaeologists and numismatists to establish a date for the introduction of the Roman denarius.

I am well aware that coin collectors have often contributed to serious numismatic research, but is the continued “free market in ancient coins” necessary for good “numismatic scholarship” and is the fact that some collectors have contributed to such scholarship an excuse for indiscriminate collecting? Perhaps the question is best answered by framing the question in terms of other disciplines. Is it necessary for archaeologists to collect ancient objects to produce scholarship on archaeology? No, the vast majority of archaeologists today do not privately collect objects and view the practice as detrimental to scientific study. Is it necessary for anthropologists to collect arrowheads and old pots to study prehistoric and primitive civilizations and human society? No. Is it necessary for zoologists to trade in endangered species to study them? No. Ancient coins are no different. In fact, when coins enter the market through suspect means – without provenance, without archaeological context – all useful information regarding its find circumstances are lost and part of history is irrecoverably destroyed.

What is to be done? Currently the unchecked trade in undocumented ancient coins is a severe problem and requires increased activism on the part of cultural preservationists. However, direct dialogue with the dealer lobby seems unlikely given its inherent financial interest in maintaining a completely unregulated and unchecked trade and the willingness of some of its members and officers to act irresponsibly and untruthfully in their writings no doubt engenders a great degree of distrust.

In my view, we can only hope to be successful in preserving the future of numismatic research by activism that specifically addresses the trade in ancient coins and public education. Without a doubt we share a passion with ancient coin collectors about ancient history and the ancient world. I believe most ancient coin collectors are either unaware of the way in which ancient coins are procured and the damage that the demand for them causes, or buy into the lobby’s rhetoric since they are hearing only one distorted perspective (Lobby officers control the most popular ancient coin collecting magazine, the Celator, and sympathetic coin dealers own and moderate most every online ancient coin collecting discussion forum including the most popular one, Moneta-L). I, myself, actively collected ancient coins until I educated myself about the issues and the facts. It is the collector to whom we must reach out and educate.

Most ancient coin collectors in the U.S. enter that hobby by first collecting American coins and as a result make little distinction between the two forms of collecting, even though the sources of the objects are very different and are at the heart of the debate. We must highlight the differences between source of coins for collectors of U.S. coins (family collections, directly from circulation) and the source of coins for ancient coin collectors (the ground, very few on the market come from pre-UNESCO collections, most are looted, illicitly excavated and illicitly exported and are openly sold without documentation or appropriate pedigrees). Many excavations do not have academic numismatists in the field because many are employed at museums and many are overburdened with material. I recognize that many collectors have great expertise and capability in attributing ancient coins. It is my opinion that it would be useful to invite such competent individuals to participate in field excavations as site numismatists. The archaeologist would benefit from a specialist to provide dates for the coin finds and, with some training in contextual numismatic research, who could also prepare them for scholarly publication. The collector would benefit from seeing firsthand where ancient coins come from and how invaluable they are to archaeological and contextual research; the thrill of discovery would also be much greater and interesting than the simple acquisition of a coin from an auction or a batch of uncleaned coins. This is one simple suggestion and clearly further discussion on the complex issues currently dividing the academic and collecting community regarding ancient coins is needed. At this point, however, the opinion of the collector – not the dealer – is the most crucial.

Refs:

Beckmann, M. 1998. “Numismatics and the Antiquities Trade,” The Celator (May): 25-28.

Dietrich, R. 2002. “Cultural Property on the Move – Legally, Illegally,” International Journal of Cultural Property 11.2: 294-304.

Kersel, M.M. 2006. “From the Ground to the Buyer: A Market Analysis of the Trade in Illegal Antiquities,” in N. Brodie, M.M. Kersel, C. Luke, and K.W. Tubb (eds.) Archaeology, Cultural Heritage, and the Antiquities Trade. Gainesville: University Press of Florida: 188-205.

von Kaenel, H.-M. 1994. “Die antike Numismatik und ihr Material,” SchMbll 44.173: 1-12.

von Kaenel, H-M. 1995. “La numismatica antica e il suo materiale,” Bollettino di Numismatica 13.1: 213-223.

von Kaenel, H-M. 2007. “Gauner, Gräber und Gelehrte. Antikenraub und Archäologie im Lichte der aktuelle Gesetzeslage,” Paper read at the symposium, Gauner, Gräber und Gelehrte at the Johann Wolfgang Goethe Universität, 4 May, Frankfurt am Main.