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Sometimes in life, it is the little things that make the biggest difference, the simple things that provide the most satisfaction. Just ask Alex Cooley.
Cooley is the co-founder of the cannabis cultivation company Solstice in Seattle, Wash. In 2014, Solstice finished construction of a state-of-the-art, indoor production facility, complete with new LED technology, a hydrocarbon extraction lab and remote access to grow room controls. It was a technophile’s dream. But Cooley’s favorite part? “I really love that we have parking now. And I love our new conference table.”
This is Cooley’s practical nature on display. Solstice may be a three-time DOPE Magazine Washington Grower of the Year award-winner, but Cooley isn’t resting on his laurels. If he sees something that needs doing, he does it. For example, when zoning restrictions prevented Solstice from making Seattle’s SoDo neighborhood its home in 2011, Cooley worked with Seattle lawmakers to rezone the district to allow for cannabis businesses instead of looking to a new city.
In this interview, Cooley, along with Solstice Director of Operations Max Salinger, explain how to fight zoning restrictions, why Solstice is working with the state to create an organic cannabis certification and how the company’s internal product rating program works.
Scott Guthrie: Alex, in 2011 you worked with the City of Seattle to create new zoning for cannabis businesses. What advice would you give to other businesses looking to rezone their communities?
Alex Cooley: You can go help create the legislation, code and ordinances in a place that doesn’t want you, but it’s not sustainable. Eventually the pendulum will swing back. So, the biggest tip is working with people who want to work with you. We made our home in Seattle, particularly SoDo, where we worked on the zoning for the last six years. I think I’ve helped to write almost a dozen ordinances in Seattle. We are grateful to the city of Seattle for being a partner. It makes it much more sustainable to have that support.
In addition, it’s good to be on the right side of things. We’re in SoDo because it’s the right fit. It’s an industrial district. It’s where our type of businesses occur, where odor occurs, where trucks are moving around. It is important to do it where it makes sense.
This is a bit of the problem with our current system of government. The fact is, if you do the work for them, you get a lot of what you want. I had little to no understanding of zoning, and I’ve worked hard to become educated about that. Then I worked hard to write ordinances for them, and we got what we wanted. That’s how we ended up building the first-ever fully permitted cultivation facility in the state of Washington—we became educated, we worked with people who wanted us and we did the work for them.
Guthrie: In 2014 Solstice built a new, state-of-the-art facility. What are your favorite parts about the facility?
Max Salinger: There are two parts to this. The first being cool, new technology. In that sense, one of my absolute favorites would be the LED technology that we’ve been testing. We do all our vegetative production under LEDs. The speed at which LED technology has been advancing, and the way that we’re able to manipulate not only spectrum, but photoperiod and intensity at different levels is exciting for me.
But some of my favorite equipment that we use is standard agricultural equipment that isn’t necessarily applied specifically to cannabis. For one, our nutrient injection systems. We are currently using a hydroponic system that has the capacity to run acres of greenhouse, but we scaled it down to where we can do individual zoning irrigation within our indoor grow and make larger batches of fertilizer that we can customize for individual strains. Seeing a lot of the technology that I’m familiar with from my background in the tomato industry and lettuce industry being applied to cannabis is awesome.
Cooley: I love all the cool stuff that we have, but to Max’s point, some of the luster fades because it’s not new and incredibly inventive. We make distillate and do fractionalized distillation. That’s super cool, but that wears off quickly once you realize, “Oh, that’s technology from the 1890s, and it’s not really new and novel.”
Salinger: We also have a lot of remote-access stuff. My fiancée gets sick of it. I can’t tell you the times I’ll be lying in bed, scrolling through all the grow room environmental control data. It’s not new technology, but it’s fun and very useful.
Guthrie: Solstice has been asked to join the Organic Certification Board, which will help the Washington State Department of Agriculture create an organic certification program for cannabis. Why is it important to have this program and what needs to happen for it be successful?
Salinger: In normalizing cannabis, we have to start treating it like an agricultural crop. That’s what it is. We are farmers. We’re trying to make this a crop. Our goal is to make this a crop that is a standard, not something that is treated differently solely because it’s cannabis.
When you look at organic certification, it’s one of the No. 1 ways—whether it’s a small farmer or a farmer looking to diversify—to differentiate their products and create an identity around the type of farming that they do. One of the things that was important when we were talking about the barriers and the legislation revolving around this type of program was: How do we align the organic cannabis certifications to the food industry certifications in a way that epitomizes the term “organic”? That is, reduced pesticide usage, reducing environmental impact and a generally safer product. Being able to get that certification is a huge step in cannabis. It’s what needs to happen for cannabis to be taken seriously.
Guthrie: Every batch goes through your internal rating program and receives a score. How was this program designed, and what types of scores are you giving out?
Salinger: The IR [internal rating] program is a dynamic rating scale that’s based on visual, olfactory and aesthetic appeal of each batch. We have a team that will rotate through every single strain of cannabis that is going to market. We’re grading every single product and using that to help us determine the appropriate brand to place it in, and to catalog how this plant performed in this environment, how this plant performed under certain conditions. It shapes a lot of what we grow.
The team is between 10 and 15 people. Everyone will look at the product under a microscope. They give the products fairly subjective scores based on questions such as: How does this look to you? How is this trimmed? Are you seeing anything in here that you like? What’s the color appeal? We combine that with the state-mandated testing, as well as some secondary testing that we’ll do for terpene profile, potency and moisture content. That gives us a numerical score of zero to 100.
We have a scoring standard for four particular brands we supply. Swamp Boys and Solstice are the top tiers. Nothing below that is going to get into those brands. ... If the material doesn’t reach our lowest scoring threshold, it is turned into extract or wholesaled.
Guthrie: Solstice works with some externally sourced genetics. How do you determine what external genetics make it into your facility and how do you find them?
Cooley: We’ve always run an R&D program where we’re essentially looking for a varietal of cannabis that doesn’t cover things that we currently offer. We’re trying to identify what’s popular and what we don’t have. That’s why we partnered with Swamp Boys for “Nookies”: a Nigerian and Animal Cookies cross. We didn’t have a landrace sativa—let alone an African landrace sativa—that had been crossed with an incredibly popular strain. We started working on it in 2015 and completed it in 2018. So, we overlay those Venn diagrams of what we’re missing, and then we move forward.
I’d always spent a lot of time collecting varietals and seed collecting. I scoured the earth to get original Durban Poison seeds that are non-feminized. We’ve got three different Skunk No. 1’s. We put money into tissue culture and pollen saving. So, we’ve got a pretty extensive library that we can use to create what’s popular.
Salinger: That’s the fun part from my standpoint. Alex put in all this work at the beginning, and it got our stock established early. Now, it’s really experimentation into: What is going to produce well, what is going to perform well in our unique environment and what is that end score going to be?
Guthrie: You have a hydrocarbon extraction lab. What was the most challenging part of designing the lab?
Salinger: We are within Seattle city limits, so there were a lot of regulations set by the Liquor and Cannabis Board (LCB), our governing body. We went through multiple inspections with the fire marshal, and we tried to model our extraction lab off standards set by Washington State University for this type of extraction.
The biggest thing was finding the right people who knew the particulars about cannabis extraction, but at the same time were able to investigate and learn about city constraints when it comes to using this type of facility—everything from alarms that are testing the air volatiles to the crazy evacuation systems that rip all the air out of the extraction area with the flip of switch.
It took a lot of research. It wasn’t just, “What’s the best way to extract cannabis material?” but, “How do we do this safely, and how do we do this so when the LCB does start to ask for more constraints around these types of facilities, we don’t have to redesign?”
Guthrie: You produce live resin in limited availability. For such a low-yielding product, how do you justify the work and the expenses it takes to produce?
Cooley: We really like it. That’s where it all starts. Then we find ways to make it profitable. Marketing and branding play into what we can sell it for. We work to get our costs down so that we have a strong margin.
Salinger: With the live resin, it takes a lot of coordination between the garden staff and the extraction staff and making sure that as soon as that harvest is either scheduled or ready, we’re getting the material out and into the freezer as quickly as possible. Like Alex said, it’s a good live resin and it’s something that we all enjoy. The cannabinoid profile is incredibly unique. The terpene profile is incredibly unique. The drying process selectively off-gasses certain terpenes. By extracting the raw flower, we catch those terpenes and preserve them in the live resin. The same goes with cannabinoids, except instead of off-gassing, the cannabinoids convert into different forms (THCA, THC). By freezing the flower at harvest, we are basically taking a snapshot of the flower pre-dry.
Guthrie: Solstice is a three-time Washington Grower of the Year winner. Why is that?
Cooley: It’s our commitment to transparency. It’s our commitment to furthering things. It’s our commitment to making products that we like. It’s our stewardship with the industry and searching out new genetics. It’s working in partnership with other breeders and growers.
Salinger: We’re all here because we all have some sort of affinity to cannabis. For me, it’s making cannabis a generally accepted agronomic crop. For Alex, he’s got a different reason, and for everybody else here, they’ve got a different reason why they want to be here. But collectively, we all have a passion for cannabis and a passion for this industry.
Guthrie: Has Washington’s product oversupply caused Solstice to rethink which strains it grows and when, perhaps forcing you to not grow strains you enjoy?
Salinger: Most of the time, if it’s a strain that we like, it’s going to do well on the market. But we can’t rely on that. In order to make sure that the strain is going to move, I’ll often grow things that I don’t necessarily like.
For example, personally, even the best, most well-manicured, perfectly-grown Durban Poison, I just don’t like it. But I’m not every consumer in the state. So, it’s getting that feedback from sales and understanding what heritage strains, regardless of what brand it goes into or how it’s grown, will have some trajectory, and then making sure that we’re matching those market demands.
Guthrie: You are currently expanding your indoor facility. What will this expansion add to the facility?
Salinger: We’re adding an additional three flowering rooms and some additional vegetative rooms. We are building that all out to continue hitting that premium indoor flower market and really start to look at other types of lighting, other areas where we can create value. We’ve got the space, we’ve got the warehouse already established, we’ve got the staff and we’ve got the people trained.
Cooley: We’re about to finish this second phase. Once that’s up and running, we may explore going to a farm. We do believe, ultimately, high-quality cannabis ends up in a greenhouse. We will eventually build one of those, but it’s not necessary at this point.
Editor’s note: This interview was edited for length, style and clarity.
Scott Guthrie is senior editor for Cannabis Business Times and Cannabis Dispensary magazines.
Cannabis culture, until recent years, has thrived off a tongue-in-cheek, alternative vibe, and there’s no better example of that than the industry’s long history of outlandish strain names. Some are fairly innocuous (Grand Daddy Purp sounds like a friendly, old neighbor); others are a bit more in-your-face (some Chernobyl, anyone?); and a few wink at other famous brands (may the force be with you if you choose Skywalker OG).
But recent history has shown that parodying other well-known companies can land you in hot water. Just ask the team at GG Strains, the creators of GG4 (formerly known as Gorilla Glue #4). In 2017, GG Strains received a letter from the Gorilla Glue adhesive company summoning the cannabis company to federal court for trademark violations. (For more on this lawsuit, and its outcome, read "Gorilla Glue vs. Gorilla Glue" in the November 2017 issue of Cannabis Business Times.)
“Our attorney fees we’ll be paying off probably until our grandchildren are born,” says Catherine Franklin, GG Strains’ director of marketing, chief digital officer and cultivator liaison. She estimates the costs in the tens of thousands, and rising. “People don’t realize that a federal lawyer is more than $500 an hour. Each email is minimum of one hour.”
GG Strains is in the middle of a large-scale rebranding and education effort to inform its partners and consumers about the strain renaming. Since the lawsuit, Franklin says she has spent the bulk of her time building a social media campaign and calling dispensaries directly to make sure they know about the new name—and how the dispensary (and GG Strains) could face another federal lawsuit should it continue to flout the terms of the settlement reached between GG Strains and the adhesive company.
While training budtenders can be a hassle thanks to the high turnover rate in that position, all of GG Strains’ partners have been responsive to the notice.
“We haven’t gotten any pushback from our partners,” says Ross Johnson, GG Strains’ co-founder and the co-creator of GG4. “But just the other day we posted something that said ‘GG4/Original Glue’ and someone came in and said, ‘I’ll always call it Gorilla Glue.’ So you have those people that are aware of the name change, but want to buck the system.”
Johnson and Franklin have heard reports and received calls from businesses that have continued to use the old moniker or are not carriers of the certified GG4 strain (but rather carry unofficial strains from other breeders) about receiving cease-and-desist letters from the adhesive company. But companies aren’t obligated to send cease-and-desist letters warning cannabis companies about the trademark violation; instead, they can move the matter directly into federal court, as in GG Strains’ case. When that happens, cannabis breeders basically lose control over their business decisions.
“The moment you get hit with that cease-and-desist, or in our case that straight federal lawsuit … you don’t have an option to rename,” Franklin explains. “Whoever is suing you or is asking you to cease-and-desist, they now have to partake in your renaming and your rebranding, and you don’t want that because they don’t want the best interests for you.”
For this reason, cannabis entertainment and education website Leafly decided to review its cannabis strain database and rename the varieties that could be potential targets for a trademark violation suit. The company announced the decision in a May 4 article titled, “Trademarks in Cannabis: Where Did All the ‘Star Wars’ Strains Go?” Leafly has rebranded strains like Skywalker OG and Ewok to Mazar x Blueberry OG and Alien Walker, respectively, on its website.
“We know that there’s been issues with trademarks in the past with strains like Gorilla Glue and Girl Scout Cookies,” says Bailey Rahn, a Leafly editor, in an interview with CBT. “We took a preventative approach with some names that could cause the same situation.”
Deserae Weitmann, Leafly’s corporate counsel, added that the company also reviewed its database for names that could appeal to children. “We want to be the best actors in the space,” she says.
But Leafly is taking a more direct role in the retail side of the industry, adding a more robust shopping layer to its website. Leafly now offers “Leafly Pickup,” allowing customers to make reservations of products online, skip the line, and quickly pay for and pick up their reservations at partnering dispensaries.
“With that kind of change to monetization of product in the website, the risk profile definitely changes a bit from just a publisher of information to a more commercial use of that information,” Weitmann explains.
Friend Turned Foe
Renaming strains is a good way to avoid a trademark lawsuit, but it’s also important that all products are named correctly to avoid a lawsuit from the consumer, Franklin warns. That’s because selling a product under a different or false name is the textbook definition of consumer fraud. She predicts the industry is about to see a flurry of such lawsuits, especially as genetic testing services become more popular.
“Somebody could say, ‘I can make a quick million dollars by walking in that dispensary tomorrow and getting something that is not real.’ It costs them $199 to test it, and they can turn that into a million-dollar lawsuit. Consumers like those lawsuits. And that’s what this industry doesn’t think [about],” Franklin says.
David G. Evans, a New Jersey-based personal injury attorney, is one litigator who is examining the cannabis industry for a list of potential lawsuits, including consumer fraud, he tells Cannabis Business Times. At press time, Evans was scheduled to participate in a webinar for lawyers titled, “Effectively Suing the Cannabis & Marijuana Industry” in late June. He says consumer fraud lawsuits can see plaintiffs awarded hundreds of thousands, if not millions of dollars, with the biggest judgments coming in cases involving medical patients. Simple mistakes such as selling a mislabeled product could qualify as consumer fraud, depending on state consumer protection laws.
“There’s also some federal laws regarding that, particularly with medicine,” Evans says. “The Federal Food and Drug Act has laws about misbranding and things like that, where if you make false statements about a product, or misrepresent a product, you can be sued for consumer fraud, for misrepresentation.”
Unscrupulous cultivators will sometimes rename strains to benefit from regional trends, Johnson says. For example, if OG Kush is popular in one city, consumers can expect dispensaries to be flooded with OG Kush or other renamed OG varieties looking to cash in on the rush.
Evans says those cases could easily qualify as consumer fraud, among various other charges that could be brought. “That could be a misrepresentation. It could be a breach of contract, a breach of warranty. It could be considered a failure to warn because you’re not warning the person about the accurate picture of that particular strain of marijuana,” he says.
“People are sue-happy in California,” Johnson warns. “They’re figuring it out, and the dispensaries are going to be caught with their pants down because they didn’t do the simple certification through the cultivators they’re buying product from before putting it on the shelves.”
While lawsuits can come from both consumers and corporations, cannabis businesses can minimize the damages. That said, options are limited once you receive a cease-and-desist letter, Johnson says. “You either abide by what the letter says, or the attorneys work out a deal, or you go to a lawsuit.”
Franklin explains that, typically, cease-and-desist letters will ask that you immediately stop violating the trademark and show proof that you have done so. The best course of action when you receive a cease-and-desist letter is to simply “fix it, call them, say you’re sorry and move on,” she says, adding that, “if you need to get an attorney, get an attorney and call them and find out what’s the time frame [they are] giving to change this without having a lawsuit.”
To create new names when it underwent its internal strain-rebranding process, Leafly reached out to the original breeders to “give them an opportunity to change it on their end so it could be unanimous across the industry,” Rahn says. When breeder information was not known, she notes, “we made our best judgment call of what the new name should be,” often falling back on parent combinations when a suitable alternative wasn’t available (such as with Skywalker OG becoming Mazar x Blueberry OG).
Standardization is the industry’s best line of defense, and while genetic testing can be used against the industry in consumer fraud lawsuits, requiring testing would add a layer of protection to the entire industry, according to Franklin. She says all products need to have their genetic makeup tested to confirm what strain it is “before it ever gets labeled and before it gets put on a shelf for a consumer to pay a price and pay taxes on it, period.” Breeders should register their genetics with Phylos Bioscience or Tru-Breed, and dispensary owners should require paperwork proving their orders’ genetics, she advises.
If you’re going to create a strain, think ahead and check for trademarks and intellectual property, Johnson says. “When GG4 was named as a parody, we never thought it would be as popular as it was. Never in our wildest dreams did we think this was going to be in the top-3 strains in the world. We would have never named it that.”
Ultimately, an ounce of prevention is worth a pound of cure because, as Johnson rightly summarizes, “if I got a letter from Disney, I’d be shaking in my boots.”
Brian MacIver is the associate editor for Cannabis Business Times.
Ideally, cannabis should be harvested at peak cannabinoid and terpene levels, and then properly dried and cured; however, that can often be easier said than done.
How do you know when it’s time to harvest?
With harvesting, there are few hard and fast rules. Even in today’s mature adult-use markets, cannabis is harvested based solely on observations of a handful of factors, including:
1. 60-day flower period: It’s common industry knowledge that cannabis plants complete the flowering stage in approximately 60 days. Some cultivars require less time and some require more time to reach full maturity, but this rule of thumb is typically the first indicator of when to harvest.
2. Stigma/stigmata color/drying out: A popular belief and observation-based indicator is that once roughly 40 percent of stigmata dry out and turn brown—leaving 60 percent of the stigmata with a white color—your plant is mature and ready to harvest.
3. Gland color: Ranging from clear to milky, and amber to reddish, most discerning growers use gland color as a ripeness indicator. As resin glands form, they typically will be translucent (although some express color). As the plant and the glands mature, the resin glands’ composition changes as cannabinoid and terpene percentages increase. As the plant matures, the clear resin glands typically become opaque. The glands will begin to turn colors, ranging from amber to dark red, as the plant reaches the end of its life cycle. If you wait too long or over-expose those resin glands to light, they can oxidize. Oxidization can darken the color of and degrade cannabinoids.
The objective is to estimate when to harvest based on maturity of a given percentage of resin glands. Some growers harvest when they see 70-percent clear resin glands, 20-percent opaque glands and 10-percent amber/red glands. Some prefer different ratios, seeking desired or preferred cannabinoid content. Those growers might harvest later in the plant’s development, when a larger percentage of glands have become amber or taken on a darker, more mature color. In essence, these growers are altering cannabinoid ratios to suit their specific needs or to elicit a desired effect.
Extractors discovered years ago that if they harvested before the resin glands turned amber or red, the resulting extract had a lighter color without a major compromise in overall THC percentages or noticeably reduced terpene content. Many extractors began to purposely harvest early to avoid darker-colored extracts tainted with colorants (pigments and flavonoids) combined with the dark-colored cannabinoids in the resin gland.
These methods of determining when to harvest cannabis are highly subjective and may be inaccurate. Ideally, cannabis should be harvested only when a chemical analysis reveals that the desired levels of cannabinoids and terpenes have been achieved. Take vintners, for example. Grape growers utilize a Brix meter to analyze grapes’ sugar content, which determines when he picks the them. He is aiming for a targeted sugar percentage. Too much or too little, and he will change the wine’s flavor profile.
Cannabis should be harvested similarly, in that it should only be harvested when production of desired compounds has peaked. As of now, an apparatus to determine cannabinoid or terpene levels in a bud on the plant does not exist. However, given the financial reward such a device would bring to its creator, I suspect we will have one someday.
What is the point of diminishing return with respect to cannabis destined to be extracted, not sold as raw cannabis buds? In other words, at what point in a cultivar’s flowering cycle does that plant slow down cannabinoid and terpene production? At what point is it more advantageous and profitable to harvest because desirable compound production has presumably peaked? Does a cannabis variety only produce lower amounts of compounds in later stages of life? Are the stages for cannabinoid development different or similar for all cultivars?
The implications of these unanswered questions are many. I ask them to illustrate that if the cannabis is destined for extracts, and that THC or CBD production and terpene production is minimized in the late flowering stages, then there is a point at which there are more resources going into the plant in the form of labor, space, electricity, nutrients and water, than compounds being produced. As such, when growing for extraction, it could be advantageous and profitable to harvest (for example) 2 acres of cannabis two weeks early, even if harvesting early resulted in (hypothetically) 10-percent fewer available compounds, if it would facilitate one extra harvest per year. (If a grower is currently getting four cycles per year utilizing an eight-week flowering cycle and cuts each harvest by two weeks, then there is enough time for another six-week flowering cycle in the same calendar year.) Again, the focus of this harvest would be compound production (cannabinoids and terpenes), not biomass (flower/bud).
(Editor’s note: Read more about “Workflow, Turns and Yields” in CBT’s May 2018 Hort How-To Column.)
To verify whether such a practice would be worth the cost, growers must calculate the production cost increases that come from that extra cycle, in addition to calculating the amounts (or diminished amounts) of compounds in relation to a plant’s harvest time. Calculating diminishing return rates turns THC, CBD and all other cannabinoids and terpenes into nothing more than commodities, and that is exactly how they will be viewed by corporations of the future.
Both cannabinoids and terpenes will be viewed as starting material or active ingredients. Many emerging corporations want active ingredients. They do not want to cultivate, extract or process cannabis. They want those active ingredients in an exact percentage or form. Recent market projections in Canada indicate that manufacturers desire to put cannabis into anything that can be ingested, ranging from water to edibles (starting in 2019) to capsules. Manufacturers want active ingredients—not trim, flower nor kief. They do not care what cultivar it is nor which cultivation method was used.
Growers who understand this may view cultivation, harvest and crude extract production from a slightly different perspective. They may choose to produce cultivars that rapidly generate cannabinoids. This would allow them to harvest at week six, seven or whenever production has peaked, allowing them to focus on harvesting the active ingredient through resin-gland separation to efficiently produce crude extract. These resin glands can then be refined and super-refined via distillation into a form desired by manufacturers. The obvious goal would be maximum production of a desired compound with the lowest possible production cost. (Editor’s note: For more on extraction refinement, read the CBT November 2018 print edition's Tomorrow in Cannabis column, “A Crude Awakening.")
Many corporations have recently divulged their intent or interests in entering the legal cannabis market, including household names like Anheuser-Busch InBev SA/NV, PepsiCo and Corona (Constellation Brands)—the latter of which invested US$4 billion in Canada’s Canopy Growth Corporation. Global corporations are establishing themselves primarily in the legal Canadian market with the intent to develop their brands and products for future production and sales to not only Canada, but any market that allows importation. Many are also likely preparing for the emerging legal adult-use market in the U.S.
To produce their intended products, we can assume these corporations will demand the lowest price possible for ingredients, which encourages foreign sourcing. Some corporations intend on sourcing active ingredients from countries such as Colombia, Australia, South Africa, Lesotho, Mexico, Portugal and Uruguay. Odds are, they will source from anywhere they are legally allowed to import with the lowest cost of production.
Some companies will choose to source CBD from hemp cultivated by American farmers to be refined in an industrial or pharmaceutical setting. But in a free- market economy that treats cannabis and its derivatives as agricultural commodities, I suspect it unlikely that corporations would source active ingredients from either Canada or the U.S. The increased labor, power and other costs of North American cannabis production would not compete with those countries mentioned (a semi-skilled worker in Colombia can expect to make $20 per 8-hour workday), which means prices for active ingredients may someday become quite competitive. Once that happens, some producers will be forced to examine how and what they produce.
Kenneth Morrow is an author, consultant and owner of Trichome Technologies™. Facebook: TrichomeTechnologies Instagram: Trichome Technologies firstname.lastname@example.org
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