States, the President of the United States

Justices, the commissioner does not take a position on whether the appeal ought to be allowed or dismissed.

I have four principal submissions to make in my oral submissions, which are intended to assist the court.

First, PIPA does not grant the discretion to refuse an individual disclosure of their own personal information on charter grounds.

And because the disclosure obligation in Section 23 is mandatory, That provision is necessarily the proper object of charter review.

Second, it is essential that the commissioner have robust powers to order the production of documents in order to perform the task that the legislature gave him when it enacted Section 23 of PIPA.

Third, it is the ordinary techniques of statutory interpretation, the modern approach, and not the necessarily implied test from slate communications.

If we're into that debate, is that an indication of ambiguity? And if it's an issue of ambiguity, of course, then we have to wrestle with the presumption of conformity with the Charter.

If we're into that debate, is that an indication of ambiguity? And if it's an issue of ambiguity, of course, then we have to wrestle with the presumption of conformity with the Charter.

Justice Morrow, to start with Section 23-1A, there's no may in Section 23-1A.

It's must.

Same with Section 52-2B.

The language is must.

Those are both mandatory obligations.

Focusing on the point about the word authorized and the Court of Appeals interpretation of that It is not sufficient in my submission, and the case law supports this, that different decision makers can disagree about the meaning of a word or that some interpretive process is required in order to come to the meaning of a word.

We're in the second part,