Transcript: 

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Geraldine  0:14  
Hello, everyone, and welcome to the New Earth lawyer podcast. I'm Geraldine Johns-Putra. I'm your host. I'm a lawyer based in Melbourne, Australia. Today I'm speaking with David Cameron. He is the principal of David Cameron Law Office based in Hong Kong. David started his own law firm in order to better serve clients and he provides advice on corporate transactions and financial law at a fixed fee. He's dual qualified in Hong Kong and New York. He's been based out of Hong Kong for 12 years and he has worked for multiple UK 'magic circle' law firms, in addition to being a partner at an AmLaw 100 US law firm. David, welcome to the podcast.

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David  1:00  
Thank you, Geraldine. It's nice to be here and I'm looking forward to our discussion.

 

Geraldine  1:04  
So am I. As we were talking, just before we started recording, I was saying to you, I'm really interested in speaking to you because I did work in Hong Kong for a number of years. So I have a familiarity with the market there, the legal market. So I really wanted to hear from you what it's like being innovative law professional in the Hong Kong market.

 

David  1:29  
So again, thank you for your time, I think that's a great question to start out with. And I think Hong Kong, and when I reference Hong Kong, I think it's also applicable to Singapore, are pretty unique legal markets, in that you have the very large US and UK firms that have had a presence here for a very long time, on one end of the spectrum, and then on the other end of the spectrum, you have kind of the local firms, the Hong Kong firms that are more fragmented, and maybe don't have that much international experience. And then you have this kind of big void in the middle, in terms of lack of boutique, international law firms in Hong Kong. And it's very interesting, because, you know, this market is just not conducive to someone like me, you know, if you have a seasoned practitioner, chances are that he or she goes from one big firm to another big firm, or they go home to their home jurisdiction, you don't have somebody effectively starting a law firm in their garage, which is what I've done, I'm not in my garage, but to the expression.

 

And then at the same time, there are barriers to entry here. You need to be a Hong Kong solicitor, and I just happened to take that test four years ago, no tangible benefits at the time, it's obviously paying dividends now. You need to have your own physical office, you can't do a virtual law firm, you can't have a service office like WeWork, so you do need to sign up for a proper office. So there's some capital outlay. And then other things like you need to buy insurance, that's statutorily required, so you need to invest. And then at the same time, kind of have the wherewithal to know you'll have clients that will will come to you. But as a result of all this, the fact that I'm in this unique space there, there are a lot of smaller financial firms, and I put those in the categories of asset managers, family offices, companies that are maybe five years old, that don't that have international legal needs, but aren't big enough to have their own in-house counsel. And they're, that's the boutique law firm market that would normally be served, and I think you have that in Australia. And I know you have that in the UK. And I know you have that in the States, but it's really lacking here. So I've kind of found myself in this market position where there's a lot of a lot of demand out there.

 

Geraldine  4:13  
Are there any other regulatory impacts on you? So I'm thinking it's quite a traditional market, as you've described, in some ways, they are restrictions on things like advertising and whether you can enter into a multidisciplinary partnership with non lawyers, so that would hamper innovation, I would have thought, are you finding that that's a challenge or are you just not proceeding there yet?

 

David  4:42  
It's a conservative market, I would say, yes, but there's still ways within those limitations, to be innovative. And I don't think we've necessarily seen that yet here in Hong Kong because of these two ends of the spectrum. And you know, having recently, my firm is only five months old, having recently entered into this space, I think a lot of the innovation is actually coming out of Australia, the UK, and the US. And it's there. And people are coming up with these ideas and pricing and business models. And it's just who here in Hong Kong is going to take up those ideas and implement them. It's very hard to change if you're an older or larger institution. And, you know, for reasons I mentioned, there just aren't that many New Law firms in the city.

 

Geraldine  5:46  
Yeah, so it's a gap. It's waiting to be filled. You could be an early mover into it. I suppose that's the spot that you're finding yourself in? Is that why you decided to leave partnership and get into a New Law practice? 

 

David  6:02  
No, that's that's a good question. And I would like to say this is all part of the vision and I had some sort of eureka moment. That's, I'll just say, that's not the case. But I think, at different stages, I think it's always helpful to pause and ask yourself, why are you doing the things the way you're doing? You know, if the answer is that's because the way they've always been done, I think you need to dive a little bit deeper into that. And if you don't know, the original reason, let's stress test it a little bit, are there alternatives available? So I think I've done that along the way. And my career has progressed. And I think this last jump is really because even if you're at a big law firm, and maybe this is unique to my experience in Hong Kong, is even if you're at a big law firm with a brand and a platform, and you have the resources, it's still very limiting in terms of how you can service your clients and what you can do. Because, you know, if I hear of a good idea, you know, out of Australia or elsewhere, then I can really think about implementing it and and see if it better serves serves my clients.

 

Geraldine  7:17  
Yeah, I think that's probably true of Big Law firms, in other cities I've worked in, so I've also worked in London, and Melbourne and Sydney. But I think you're right, there is something about the Hong Kong structure where the competition is so sort of fragmented, well, it's not fragmented, so much as segmented. So you've got the big law firms, the American and UK law firms competing with each other. And then, like you said, the local law firms and now lately, the Chinese law firms coming in and setting up, and everyone sort of knows their place. And so no one really wants to break out of it, it seems to me, whereas in places like Australia, and the UK, because of the New Law start-ups, being more mature, really, and I spoke to someone last week, Mel Lyon from Hive Legal, they've been going for seven years, so that's relatively mature, and the sorts of innovations they're bringing to the market, Big Law has to respond. So I think that that's a little bit of a privileged situation that the big end of town in Hong Kong have had, but you could see it, you know, in a couple, three years' time really progressing to a point where they have to. They're going to have to take note of what you're doing and what other New Law firms are doing. Do you see - what's the competition that you see in your space, then? Are there a lot more like you're setting up?

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David  8:54  
No, there aren't a lot like me. So what I see in this client base, so put aside the global banks and institutions, if you have smaller sized firms or companies in Hong Kong, I think they're really struggling to find a good fit in terms of somebody who could provide legal services.

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Geraldine  9:16  
Yeah. Okay. 

 

David  9:18  
I mean, and to your point to innovation, um, it doesn't have to be anything that big. It can be pretty small, simple concepts, and you apply them and it's the way to differentiate yourself and better serve your clients. And, you know, some easy examples of what I've done is I have a Board of external advisors. That's something that any law firm can do. And I think it's very uncommon. And working on my set of core values or core principles. Again, I think maybe that's more widespread, but I'm happy to talk about it. In terms of really implementing and living them, I don't think other law firms are doing that. And then I've also a third example, just very simple things, and this is based on listening to your clients is I've come up with a set of client commitments that I sent to my clients at the opening of each engagement. So this is just me, I'm just a one man band. And I think innovation, you don't it's not necessarily thinking about, is it constrained by, you know, regulations? And are these difficult or capital intensive things to do? They're really not. And I think, you know, I'm trying, I need to do what I can to differentiate myself. So I'm looking to innovation. And it's some of the bit it's very easy to implement. But firms aren't doing it.

 

Geraldine  10:52  
This is very consistent what you're talking about, with your values, very consistent with the conversations I've been having with people who have left large law firms and either set up with others boutique or niche practices or set up on their own. And it's something that I've experienced myself, because I left partnership in a law firm last November, and I've set up my own small practice, also on my own. So we're in a similar boat. And I know how I want to run my matters. And I know the conversations what I want to have with clients. I haven't gone so far, and I think it's a wonderful idea, to tell my clients what my commitments are. But it's true alignment, in my experience, and it's actually deeply fulfilling, would you agree and how, I suppose the next question I would go to, once you've told me what you think about what I've said about that alignment, is what's the reaction you're getting from your clients?

 

David  11:52  
Yeah, so I agree with what you said, Geraldine about alignment. And for me at the outset of my firm and similar to you, perhaps it's not only about attracting the right clients, it's also about being able to say no, to certain type of work at certain clients as well, because that's how you get focused. And I think a lot of the, you know, other law firms, it's very difficult to say no, and then you don't end up with clients who are aligned with what you want to accomplish, or your skill sets. So I think it's important to get your messaging clear and consistent. And it's very hard to specialise, not in terms of attracting, you know, that target work that you're going after, but it's actually saying no to other work that may come in, in the door. So yeah, I think each firm, that the more you can get your client commitments up there and their core values, then you really start to define yourself. And then you really start to end up with clients who are on the same page as you. And I think that's a win-win.

 

Geraldine  13:12  
And when you say to your clients, these are my commitments to you. And I imagine that that's around pricing, that you're going to listen to them, availability, responsiveness, and so on. And I imagine that it's not, you didn't work shop it with a big consulting firm and pay them lots of money to come up with it, you actually looked deep into yourself to decide what you'd be comfortable with saying.

 

David  13:39  
So just to describe, client commitments and then core values, two separate buckets. So the client commitments I came up with are really not, I want to say superficial, but very simple things, and I won't read them to you, but they're 12 commitments. Starts out, number one, I will be on time for meetings, which really, really means I do have to be on time for meetings, you know. Another one is I will test my equipment, so you can hear me clearly at the start of meetings. And the last one is from John Chisholm, who you've had on your show.

 

Geraldine  14:16  
Yeah, yeah, fantastic inspiration. 

 

David  14:18  
And that gets into more substance in terms of, you won't receive a bill from me that you haven't pre-authorised. But these are very common things. And with innovation, it doesn't necessarily need to be something brand new, but you're listening to feedback and what clients want. And if things are slipping in a certain direction, then you know, clients really appreciate you reaffirming these basic things. So instead of taking traffic into account for client meetings, you need to take into account getting your equipment up and running. And what the people who may kind of think these are light hearted things the public announcement I have for, through your show is, these are actually things that I hear from consumers of legal services. Because I do this as a habit of mine, if it's a friendly environment or whatever, I ask the person , what do you think of your lawyers these days? And so this list is based on that.

 

And I hear stories about how, to meet up with my lawyer, you know, he or she was five minutes late, another five minutes to get the audio up or running, another five minutes to get the video and then all of a sudden, he's there. And it's, he's on his couch. And it seems like George Costanza from Seinfeld. And especially if you're billing by the hour, I mean, it's just, you know, so those are my client commitments, I came up with them. I get an engagement letter signed and returned to me. And just proactively I say, to clients, here are my commitments, these are for your record. It's something I don't need to do. And it's one way, I think. So I'm just kind of filed away, and others really have a positive reaction to it.

 

And then for my core values and core commitments, that goes into a book by Michael Morse called Fire Proof. And he started his law firm. And at the time of publishing that book, it was up to $116 million business in revenue. And he talks a lot about, a lot of things in terms of hiring and firing and putting teams together properly. And what he says about core values is, this is really the essence of your firm. So you can't just sit down and write what your core values are, you know, start with number one, which is integrity. But this is something that you need to cultivate over time. So this is something my, you know, my firm is new. So I've been thinking about these, but I haven't really put pen to paper yet, I think it's worth taking your time to get these right, the only one I've kind of settled on is we only take on work that we're genuinely excited about. 

 

Geraldine  15:15  
Yeah. 

 

David  15:18  
And I'm sure all these big firms that I've been at, you've been that they have core values or core principles somewhere. But the difference is, the fact that I don't remember them means that they weren't truly implementing them. Because if it, every turn, you should reference these. So you know, you're staying the course. And am I hiring these, these people pursuant to these principles? In my letting them go? And by forming these teams... 

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Geraldine  17:36  
Who am I promoting to partner? When I promote the partner, am I actually testing them against these principles?

 

David  17:42  
So those are the two but I get just examples of innovation. That's it's very easy to implement. And it makes a lot of sense. Same for my Board of advisors, and we can talk about pricing, pricing too. But yeah, it takes an open mind to innovate, it doesn't necessarily take a lot of resources or capital. That's where I've ended up.

 

Geraldine  18:12  
What I, what really fascinates me about what you were talking about with, you're coming up with your core values and taking your time about it is that I'm a big believer in values work, and, and how that feeds into purpose. So I did my own values work three, four years ago, maybe three years ago, with the lady I had on the show, Kim Wright was my coach through it. And it wasn't an easy process. And I go back every now and again and I look at those values. And I think are these still my values? But you know, it actually guides me when I have tough decisions to make, or when I feel like I'm in an ethical dilemma. I actually go back and I think about the principles, the values. And I think well, which what am I really emphasising here and I may, there may be a trade off between them. But I'll know why I'm making that trade off. And it makes my decisions clear. It also makes me comfortable that I'm still being true to myself that I'm not making one of those decisions where I'm just sort of closing one eye and going, well, you know, I think this is what I feel like doing even though I don't think it's right. And I think that same thing, because you're working in a sole practice, would apply to your law firm. And I think it means that you know, everything you do, even outside of commitments you make to your clients, but how you run your entire practice from the day you, from the moment you kind of walk in the door so to speak, to when you clock off. You'll be testing yourself against those values and I think it just will create this incredibly integral sense. I would love to catch up with you in a year's time and say, hey, David, have you got your values together and see how it's going? I think it's a standard that could be set for many law firms what you're doing.

 

David  20:19  
Yeah, I agree. And I think it's an important aspect of running a business. And you know, I'm a solo practice right now, I hope to not be a solo practice for for too much longer. And, you know, it's a matter of the people you bring on board. You know, are they are they the same wavelength? Because if they're not, it's just, it's not sustainable in the long run.

 

Geraldine  20:43  
So let's get into the pricing conversation. Because there have been a number of people I've heard on now I had John, obviously, I had Matthew Burgess, who runs a virtual law firm in Brisbane. And we've been talking about value pricing and how that goes. So I'd love to hear your experience. talking to clients about it, and the reception that clients have had, and any quirks that you've seen come out of it.

 

David  21:13  
Yeah, so value pricing, and I just mentioned how I got in this space. And I don't want to talk about the billable hours as its own topic, but I didn't, so when I started my firm, you know, I was, I had the luxury of asking, what do I not want to do? And can I just do the things that I want to do? And obviously, there's some things by necessity, you need to keep but I decided the billable hour was not something I was going to adopt, right? And that was, you know, people talk about efficiencies and incentives. But this was purely me not wanting to keep track of every six minutes of my working day. And I think that is not given enough emphasis that for the lawyers, it's not something that I think any lawyer really wants to do. So anyway, so I got rid of that. So then you get rid of that. And then you need to find an alternative. And that goes into fixed value pricing. And there's so many reasons why that makes sense.

 

And then here in Hong Kong, I think it's a little bit easier, you know, now that I've described the structure is, you think about it versus the alternatives, that, you know, the client thinking about pricing versus the alternative, one is the big law firms, right, and then they kind of have an idea of those prices. Another alternative is hiring their own in-house counsel. And a third alternative that you may not think of which is, kind of scary, is it's so expensive, and not worthwhile, that they don't reach out to legal counsel for that particular piece of work, or they end up trying to review it themselves. And there, it's kind of the two costs. One is the potential liability. And the other is the opportunity costs of business people reading legal documents when they should be running the business. So from a value pricing perspective, it's not that, and my cost basis is completely different than the big law firms, so it's not that hard to price it in terms of transactional work. And what I'm doing and what's been interesting, in terms of how this has naturally progressed, and this goes into, where I am, you know, today and decisions that are being made this week, is you quickly go from value pricing, on a transactional basis to really start understanding how the subscription model starts making sense. 

 

Geraldine  23:57  
Yeah. 

 

David  23:58  
Because, again, these companies, they genuinely need help, legal help. And if you think about reaching out to counsel, if they're reaching out when there's already a problem that's too late. And if they're reaching out for a specific transaction, a lot of the time cost is getting up to speed, understanding the situation, understanding the background. So if you have somebody who is available to to you, and it's not tied to ours, I think that opens up all sorts of efficiencies and meaningful client relationships that aren't transaction based.

 

Geraldine  24:40  
Yeah, that makes sense. And I wonder that there's something in what you said, it's, if you're not tied to the billable hour, you also free up your time to make investments that may not be so obvious. So I'm thinking here, around marketing right? When I was in the Hong Kong market, there seemed to be a very standard way of going about marketing, which was to identify who you want it to speak to. And then you'd go and set up meetings, you like to go to the offices or you'd meet one of the cafes or whatever, right? And there were just a lot of meetings that I remember being set up for business development, as well as the usual networking things that happen, AmCham, AusCham and so on, right? But if you decided to innovate, marketing wise, make an investment, for example, like this podcast I'm doing, it's not an obvious form of marketing for me, you know, it's certainly I wouldn't be able to sell it to a partnership if I was a partner and so on. I set up a podcast talking to lawyers about changing the legal practice. But it's actually paying off for me in different ways. It's making relationships for me, and I'm getting opportunities elsewhere, that could have a long term effect. Are you seeing something like that in the way that you go about marketing? Because you're not tethered to the billable hour?

 

David  26:11  
Yeah, I think so. It's, I mean, marketing, from my perspective, is you still need that personal touch and that personal engagement, but you can utilise technology to facilitate that. You know, that this, the mass marketing in terms of putting client updates out there, I'm just not in that space, because the big law firms have entire departments that put it out. So I'm, my marketing is more why my law firm and its profile is different than the bigger firms. So it kind of takes on a unique nature in that respect.

 

Geraldine  26:58  
Yeah. And it's more authentic as well, going back to the conversation we were having about values. And you can be yourself as well as, as you're thinking through things like your client commitments. I was gonna ask you about the advent of the China law firms into your market, and whether that's going to have any changes around new law offerings.

 

David  27:27  
It will definitely change the market and it is changing the market. I'm not sure. You know, I never thought about it before in terms of changing the New Law market, I think, the more variety and and the more competition, the better. And the Chinese law firms have definitely made inroads and they're getting a big presence. And they can offer capabilities in a variety of different jurisdictions. It's not just PRC. So they they are making inroads, that at least at the start, is very China focused. But in terms of real disruptors? I don't know if they're necessarily in that category versus an alternative to the US or UK firms.

 

Geraldine  28:19  
Yeah, yeah. I suppose they are disrupting a different segment of the market. It was that segment that the Big Law firms were trying to get into through their China practices, and then the Chinese law firm sort of arrived in Hong Kong? So it's probably a different segment. But a shake up all the same. And there was also. there's another trend that's been, that I've been observing as I talk to New Law firms, based in Australia, mainly. And that is the response of young lawyers, law students coming through. So I'm, I'd be interested to know what you're seeing, especially given in Hong Kong the last two, three years, we've had so much going on with the university campuses, with the protests, what's the feeling of young lawyers? And the traditional law model?

 

David  29:12  
Yeah, that's a great question. And it's very pertinent because I've been looking into starting the hiring process, and that would be somebody junior, I've been talking to a lot of people in the industry. And I think it's unique, and I think, you know, their kind of, their needs, and what they want is really going to drive change in this industry. Because older people can refer to them as millennials, and, you know, they don't know how to work hard, but I think they're actually quite smart about things. And interlaid on top of all of this is COVID and flexible working and people realising that you can do a lot remotely and who knows how this is going to look once the pandemic, this is over. But I think look, people going through law school and coming into this industry, I think they're very smart, I think they're going to see through a lot of the things that don't necessarily need to be there. 

 

Geraldine  30:15  
Yeah. 

 

David  30:17  
So in terms of attracting them, I think the intangibles and what you have to offer, and I'm not just talking about work life balance, but in terms of career progression investment in them, I think that's going to be very important. And, you know, law firms, if they want to attract the best people, it's not going to be about the highest pay necessarily moving forward. So they're going to need to rebalance what they have to offer to people coming into this industry.

 

Geraldine  30:52  
Yeah, my observation of the Hong Kong market when I was there was, obviously if you're working with a magic circle law firm, similar, the hours are extremely long, whether you're working in Hong Kong, or Shanghai, or London or New York. But in Hong Kong, there was an, my observation was that it wasn't just the big end of town where the hours were just horrendous. All through the Hong Kong culture, there is a perception that you will work as hard as it takes. Are you seeing that people, like we talked about work life balance, are you seeing that that's really starting to shift?

 

David  31:35  
Yeah, I think that's starting to shift. And I don't know if it's, I can't say for certain whether it's the law firms being proactive, or if it's them being reactive, but I think, you know, okay, so you work a lot of hours, and people say, that's fine, because that's what I signed up to, I want to make a lot of money, and I want to work at a good firm and do the headline transactions, but I think you can, that starts to lose a little bit of its basis when you can, when you realise that things can be done a lot more efficiently.

 

Geraldine  32:16  
Yeah. 

 

David  32:17  
And a lot of the traditional things in terms of going into the physical office. A lot of inefficiencies, they just kind of fall to the to the wayside. So I think, whether they're thinking about the billable hour or not, I think people coming into this industry are realising that they have other things to trade, and they're time, and they're very smart about it. I think law firms are going to be in a pinch where you kind of need to offer top dollar just to attract them, and then offer the intangibles to retain them.

 

Geraldine  32:56  
Yes. 

 

David  32:56  
This is what I've been learning in the past couple of weeks. 

 

Geraldine  33:01  
So if I could ask you then, with your experience, having worked with large law firms, having been a partner at a large law firm, and now being a sole practitioner, what would be your advice to a young lawyer just starting out and thinking, well, maybe I could do things differently?

 

David  33:23  
Yeah, so not that I'm in a position to give anyone advice, but...

 

Geraldine  33:29  
I think you are very, very experienced. I think particularly given that you're in a market that isn't traditionally thought of and conventionally thought of as being very innovative.

 

David  33:42  
Yeah, I think just some practical things before getting into more innovative things, but I think, be mindful to the amount of debt you're taking on to get an education. Because that's a trap that a lot of students get into very quickly. And then you need to go into a high paying profession. And anything beyond that, that you had in mind is kind of eliminated. Other practical things is, you know, think about what industry you're going into, and whether there's longevity, and whether there's a lot of competition, kind of find your niche. And then on the innovative aspect. I mean, it's hard to say that because this industry, I think is going to change so rapidly, but I think just evaluate your options because it's fun. You know, working at David Cameron Law Office is not going to be for everyone. But you know, do you want to work with a partner level person who will invest time in you and think through the different business models out there because you working at my firm are going to be fixed costs, and your time spent on things is not going to matter to me so I'm going to train you to be as efficient and as good as possible, because I want you to produce things of high quality in a short amount of time, if possible. I think that ties into, I need you to be well rested every day, right? Get your sleep. So I would, hopefully the industry provides enough alternatives for people coming into in this industry to have more to choose from, right. It's not just one big UK firm versus another big firm, but it's, you know, Chinese firms that you mentioned, you know, local Hong Kong firms that are getting more, international start-up firms, I think just the more choices available to people, the better because it's going to be a different fit for each person.

 

Geraldine  35:54  
Yep, that diversification is needed. So that's what's happened in Australia, I'm sure it's happened to the UK. And Hong Kong really is just ripe for it. The whole ecosystem needs to have more variation within it. Because like you said, the law students coming out, the young lawyers, they're looking for that variation or that variety, and they won't put up with with the old model for much longer, I don't think.

 

David  36:19  
Yep. And if law firms don't kind of lead this change, you're going to have consulting firms coming into legal space, you're going to see companies that do fund formation or company formation, and all of a sudden they have legal teams associated with them. 

 

Geraldine  36:38  
Yeah. 

 

David  36:38  
So it's not just in the law firm space, is there, if we don't kind of drive this change, there's going to be competitors that are already here and looking to expand.

 

Geraldine  36:49  
Yep. But I like what you're saying about your model, which is something that I've been thinking on as well, when I was pondering on what's the role for large law firms. Apart from being the provider of large scale projects, expertise in that space, I was thinking that they actually provide a great training ground. But then I turned that around. And I thought, well, yes, and no, because the training that you're offering is the master apprentice type of training, which you don't really get at large law firms anymore. And I think that that's a really unique offering for law students coming in, and that would be very interesting.

 

David  37:33  
Yeah, so I mean, they're just, there are holes in this, but if you imagine, take any law firm, even the biggest law firm, and they had teams of free people, and the whole firm was made up of teams of three people. And that was a partner, senior associate and junior associate, and a timeless firm, because you can't do this on the billable hour, but you know, you're hired with the expectation that you will, the junior will replace the mid level, the mid level will replace the partner. And then, you know, tie bonuses to each other and the performance, the revenue performance of the partner. And then you're getting into really aligned incentives in terms of training and investing in people below you. So, yeah, I think it is Big Law firms, or you're leveraging, you know, the fact that there're eight associates for every partner, for example, then, you know, just look at that, look at those numbers, and not everyone is going to be partner and then, you know, are you investing the same amount in each person? 

 

Geraldine  38:44  
Yeah. 

 

David  38:45  
If they were, at least the intention was for them to rise up the ranks.

 

Geraldine  38:52  
Excellent point. Well, David, I really appreciate you finishing that on that point, because that's giving me food for thought. I want to congratulate you on setting up David Cameron Law Office. And I really, like I said, I hope to speak to you in a year's time and hear of your continuing success. Thank you for being on the show. 

 

David  39:15  
Okay, thank you for your time.