- Chapter 1 The Smudged Imprint
- Chapter 2 Ash and Staple Wire
- Chapter 3 The Diamond Cartel
- Chapter 4 Microfiche Ghost
- Chapter 5 Xerographic Sins
- Chapter 6 The Longbox Crypt
- Chapter 7 A Postmarked Phantom
- Chapter 8 Bleed Through the Margin
- Chapter 9 Blacklisted in Brooklyn
- Chapter 10 The Zine Fair of 1987
- Chapter 11 The Cottage in the Pines
- Chapter 12 Ink-Stained Fingertips
- Chapter 13 The Refusal to Draw
- Chapter 14 Pulped Manifestos
- Chapter 15 Anatomy of an Erasure
- Chapter 16 The Stolen Plates
- Chapter 17 Bristol Board Memories
- Chapter 18 Shadow on the Lightbox
- Chapter 19 Direct Market Sabotage
- Chapter 20 Crosshatching Truth
- Chapter 21 The Uncut Master
- Chapter 22 The Gutter Space
- Chapter 23 The Boycott Unravels
- Chapter 24 Press Run Midnight
- Chapter 25 Eleanor’s Final Frame
- Chapter 26 Proof of Life
Eleanor Vane's Last Comic
Table of Contents
CHAPTER ONE: The Smudged Imprint
The basement smelled of dead moths and decomposing lignin, the exact bouquet of archival failure. Arthur Finch adjusted his spectacles, wiped an involuntary tear brought on by caustic paper dust, and pulled another heavy corrugated carton from the lower shelf of the flat-file annex. He was thirty-two years old, held a doctorate in American material culture that qualified him exclusively to teach introductory survey courses to disaffected freshmen, and was currently employed on a soft-money contract by the Henderson Comic Art Archive in lower Manhattan. His official mandate was to process the back-room detritus bequeathed to the institute by the late Milton Croft, a comic distributor whose career had spanned four decades of cutthroat monopoly and dubious bookkeeping.
Croft had been a hoarder of spite. While other distributors pitched overstock into dumpsters behind strip-mall retail outlets, Croft kept physical receipts of every small press enterprise he had ever strangled. His warehouse in Bayonne, New Jersey, had been an open grave of indie publishing, and now thirty-eight of Croft’s surviving file boxes sat in Arthur’s subterranean cubicle, awaiting classification, cataloging, and an inevitable re-burial in acid-free mylar sleeves.
Arthur flipped open the cardboard tabs of Box 14. Inside lay hundreds of promotional broadsheets, invoice carbons from 1986, and legal threats typed on onion-skin paper with dying ribbon cartridges. Beneath a yellowed stack of wholesale orders for issue forty-two of The Savage Blade, Arthur’s thumb caught on an irregular edge. It wasn't the standard glossy coated stock of the Direct Market, nor was it the newsprint pulp of Sunday funny sections. It was twenty-pound bond, folded down the center, stapled with standard steel office wire that had begun to blossom into a halo of dark orange oxidation.
He lifted it by the spine, using his gloved forefingers. The cover was stark, rendered in unyielding black india ink that had bled slightly into the cheap fiber of the page, giving the borders an electric, ragged halo. The illustration depicted an enormous, mechanical printing press, its iron rollers fitted with human teeth, chewing through a tangled landscape of telephone wires and domestic kitchens. Caught in the teeth was not a woman in distress, as forty years of superhero comics would have dictated, but an enormous, unblinking eye reflecting the city skyline. Across the top, hand-lettered with an architectural precision that seemed almost cruel in its exactitude, ran the title: The Mirror Line.
Beneath the title, crammed into the lower right corner where a publisher’s logo should have sat, was a smudged colophon. It was a circular stamp, applied by hand in purple mimeograph ink. The imprint showed a broken drafting triangle encircled by text that had blurred in the press of the rubber: Hecate Press / March 1987 / Run: 500 / E. Vane.
Arthur blinked. He lowered his face until the bifocals were an inch from the purple mark. The Mirror Line. The name bounced against a recessed corner of his memory, rattling like an old key in an empty tin. In the mid-nineties, during the golden age of photocopied fanzines that discussed comic history with the solemnity of Talmudic scholars, there had been occasional, fragmented whispers about Eleanor Vane. She was an urban legend whispered over plastic tables at small conventions in damp hotel basements—the woman who had supposedly printed an eight-page comic so incendiary that Croft’s distribution empire had refused to ship it, threatened the specialty shops that ordered it through mail order, and chased her clean out of the five boroughs before the snow had melted in April of that year.
Standard comic scholarship treated Eleanor Vane as an apocryphal collective pseudonym, like Alan Smithee in Hollywood or Luther Blissett in European media pranks. No monograph mentioned her. Her name did not appear in the grand index of the Grand Comics Database, nor was she filed in the Library of Congress’s copyright catalog. The prevailing theory among the half-dozen academic historians who cared about underground feminist comix was that The Mirror Line had never existed as a physical object. It was presumed to be a piece of trade folklore invented by disgruntled graphic artists to dramatize the industry's ruthless consolidation in the late 1980s.
Yet here it was, resting against his white cotton gloves, radiating the dull, sour warmth of sixty-weight offset paper.
Arthur gently turned the first leaf. The interior was drawn with an aggressive, terrifying clarity. Unlike the loose, psychedelic hatching of the San Francisco undergrounds from the decade prior—the sprawling, weed-scented curves of the early seventies pioneers—this work was cold, technical, and brutally modern. The panels were laid out in rigid six-tier grids, but the line work inside them vibrated with controlled fury. A sequence on page two depicted a woman standing at an drafting board under the harsh cone of a desk lamp, slicing her own thumb with an X-Acto blade to use the blood as masking fluid over an illustration of an executive board meeting. The executive faces were rendered with grotesque photographic likenesses; Arthur squinted, his breath hitching as he recognized the young, predatory jawline of Milton Croft himself, flanked by three men who had run the regional distribution syndicates of the mid-Atlantic seaboard.
"Good lord," Arthur murmured to the empty basement.
Attached to the back cover with a rusty paperclip was an uncashed check from Croft Distribution Inc., dated April 4, 1987. It was drawn for zero dollars and zero cents, made out to Eleanor Vane, with a single word typed in the memo field: REJECTED. Below the signature line, in red grease pencil, someone had scrawled a brief, ugly note: Return to source. Do not invoice. Pulp the rest.
Arthur sat back in his steel swivel chair. The springs groaned beneath him. The basement of the Henderson Archive was silent save for the wet drone of the industrial dehumidifier three aisles over. He looked from the comic to the computer terminal on his desk—a beige desktop machine running a local database that linked directly to the university's special collections.
He typed V-A-N-E, comma, E-L-E-A-N-O-R.
The screen flickered, processed the query for four seconds, and returned a blunt, monochromatic verdict: 0 RECORDS FOUND.
He tried The Mirror Line. Nothing. He tried Hecate Press. The only result was a self-published occult chapbook from 1923 that had been cataloged by mistake under religious history.
Arthur looked back at the smudged purple imprint on the back cover of the pamphlet. In the center of the broken drafting triangle, the ink had gathered in a tiny, dark pool, almost obscuring a string of numbers. He reached for a heavy magnifying loupe he kept beside his legal pads. Under ten-times magnification, the purple pool resolved into a tiny, hand-stamped sequence: a six-digit New York City postal box number followed by an alphanumeric string that looked like an internal batch code from a long-defunct copy shop.
He took off his gloves, reached for his notebook, and carefully wrote down the numbers.
Every academic has an obsession they cannot justify on a grant application. For the last five years, Arthur’s had been the missing margins of the Direct Market boom—the bodies crushed under the steel wheels of the comic industry when it transformed from a rack-jobber novelty business into a speculative commodities exchange run by a few regional monopolies. The story everyone told was about the victory of the specialty shop, the triumph of creator rights, the glorious dawn of the adult graphic album. But Arthur had seen the invoices. He knew that for every creator who secured a royalty contract, fifty others had been run out of print shops by distributors who controlled the trucks, the warehouses, and the checkbooks.
Milton Croft had been one of the great gatekeepers of that choke point. If Croft had kept this single copy of The Mirror Line pinned to a zero-dollar check in his personal files, it wasn’t because he thought it was worthless. It was because he wanted proof that he had killed it.
Arthur stood up, walked to the aisle shelf, and pulled down Croft’s shipping logs for the spring of 1987. The logbook was a massive, canvas-bound ledger with marbled endpapers, its pages crowded with columns of purple spirit-duplicator entries and hand-written freight receipts. He turned the heavy leaves until the cold calendar of thirty-five years prior opened before him. March. Late March. Shipments to Philadelphia, Boston, Baltimore, Syracuse.
Then, on the entry for March 28, 1987, the neat bureaucratic lines dissolved. Across three rows of shipping manifests destined for the outer-borough indie co-ops, Croft’s heavy blue fountain pen had slashed a single, violent stroke through an entire pallet shipment. In the margin, written in Croft’s unmistakably crabbed, looping script, were the words: Hecate shipment seized at dock. 480 copies destroyed per settlement. Final balance: $0.
Four hundred and eighty copies destroyed out of an edition of five hundred. That left twenty copies unaccounted for. One was sitting on Arthur’s desk. Where were the other nineteen?
He looked back at the tiny, faded purple imprint. The name Eleanor Vane wasn't just an urban myth, and it wasn't a pseudonym for a collective of male artists playing at agitprop. It belonged to an artist who had drawn Milton Croft’s actual face into the gears of a meat-grinder press, printed the proof on a bootleg duplicator, and had her life's work seized and pulped on a New Jersey freight dock before it could hit the shelves.
Arthur felt the specific, dangerous prickle behind his eyes that signaled the death of his professional caution. His tenure review was eighteen months away. His department chair had made it abundantly clear that he was expected to produce an article on mainstream Silver Age licensing agreements—safe, uncontroversial archival bookkeeping that would upset no living donors. A wild-goose chase after a four-decade-old ghost with a grudge against dead distributors would not secure him an associate professorship. It would not pay his rent in Sunnyside. It would likely get his access privileges to the Croft papers revoked if Croft’s surviving estate executors found out he was rooting through the uncataloged personal boxes for evidence of trade suppression.
He picked up The Mirror Line. The staple wire had stained the centermost gutter with an orange tear that looked almost fresh.
Arthur opened his leather satchel, laid the comic carefully between two thick pieces of archival backing board, secured them with an elastic band, and slipped the package into the interior pocket of his coat. It was a technical violation of the Henderson Archive’s checkout protocol, but he told himself he was merely taking it upstairs to the digitization suite for high-resolution imaging. He would scan the smudged imprint under ultraviolet light. He would see what lay beneath the purple smudge.
He turned off the overhead fluorescent lights of the basement, leaving Croft’s cardboard boxes to their silence, and walked up the concrete stairs into the gray drizzle of a Manhattan afternoon.
CHAPTER TWO: Ash and Staple Wire
The high-resolution imaging lab on the third floor of the Henderson Archive was kept at a brisk sixty-three degrees to appease the digital sensors, an arrangement that invariably made Arthur’s knuckles ache. The room was dominated by an overhead planetary scanner that resembled an industrial drill press refitted for forensic work. It hummed with the steady, mournful baritone of expensive cooling fans.
Arthur locked the heavy wooden door behind him, slid the deadbolt into place, and laid his satchel flat on the laminate workstation. He did not switch on the overhead fluorescents; instead, he worked by the pale perimeter glow of the twin monitors and the articulated halogen task lamp attached to the scanning bed. He unwrapped the archival boards with deliberate slowness. Free of the satchel, the booklet shed a single, microscopic flake of rust from its bottom staple. It drifted down like an iron spore, settling on the white matte surface of the scanning plate.
Under the cold, raking beam of the halogen, The Mirror Line looked less like a forgotten publication and more like a crime scene relic. The paper stock had begun to curl slightly at the outer corners, an involuntary shrug caused by thirty-five years of humidity cycling in Milton Croft’s Bayonne warehouse. Arthur set the glass platen down with featherweight tension, just enough to flatten the cover without cracking the brittle spine, and initiated a pre-scan at twelve hundred dots per inch.
The scanner carriage crawled across the platen, bleeding an icy blue LED stripe across Eleanor Vane’s ink work. On the high-definition monitor, the image bloomed to life pixel by pixel.
Seen at twelve times its physical size, the mechanical printing press on the cover revealed details invisible to the naked eye. The teeth set into the iron rollers were not generic caricatures; they were anatomically distinct molars and bicuspids, complete with fillings, root resorption, and tiny hairline fractures in the enamel. Running along the edges of the iron machinery were microscopic lines of text disguised as crosshatching. Arthur leaned closer, his nose nearly touching the anti-glare screen. The tiny lines, drawn with an impossibly steady hand using a triple-zero technical pen, repeated a single phrase over and over until the words blurred into shading: The paper eats the hand that feeds it.
"Who hurt you, Eleanor?" Arthur whispered to the glass.
He toggled the scanner's light source from visible spectrum to ultraviolet. The blue glow died, replaced by the violet shimmer of three-hundred-and-sixty-five-nanometer radiation. The screen flickered, recalibrating the sensors to read luminescence rather than reflectance.
Instantly, the smudged purple colophon in the corner surrendered its secrets.
Under the ultraviolet wash, the mimeograph ink flamed into a bright, greenish fluorescence, but underneath it—partially masked by the heavy stamping ink—lay an earlier, fainter mark. It was a blind-embossed seal, pressed into the paper stock before the purple ink had touched it. Arthur adjusted the software’s contrast curve, dropping the black level until the purple stamp vanished into gray noise. What remained was a circular depression, stamped by a handheld notary seal: Hudson Graphic Arts Guild / Certified Apprentice / E. V. / Nov 1984.
Arthur reached for his moleskin notebook and scribbled down the guild name. The Hudson Graphic Arts Guild was not a comics organization; it had been an old trade union affiliate representing commercial paste-up artists, typesetters, and photolithographers in lower Manhattan and Jersey City before desktop publishing gutted the trade in the early nineties. Eleanor Vane hadn't come out of the scruffy, drug-addled world of the underground comix scene, nor had she emerged from the fanatical subculture of superhero fanzines. She was a professional tradeswoman. She was someone who understood offset lithography, plate chemistry, and the mechanical tolerances of giant sheet-fed presses.
That explained the technical ferocity of her line work. It also explained why Milton Croft had viewed her as an existential threat rather than a mere annoyance. In 1987, the Direct Market distribution system was built on a fragile bluff: distributors told retailers that independent creators were unreliable, chaotic amateurs who needed the steady hand of middle-tier cartels to manage their production. An artist who actually knew how to run an automated press, shoot half-tones, and strip film negatives was dangerous. She didn't need them, and worse, she could show others how to bypass them entirely.
Arthur zoomed out and panned down to the staple. On the digital monitor, the rusty wire looked like a twisted girder pulled from a collapsed bridge. The rust hadn't just oxidized; it had reacted chemically with the paper fiber, leaving a greasy, circular halo that was suspiciously dark.
He took a pair of surgical tweezers from his tool kit and delicately approached the edge of the lower staple. Using the microscopic magnification of the macro-lens camera mounted beside the scanner, he brought the rusted wire into sharp focus.
It wasn't just iron oxide. Lodged in the inner crimp of the wire was a microscopic shred of burnt matter. It was flat, black, and completely carbonized—a fragment of charred paper, less than two millimeters across, captured and preserved by the staple when the wire had been punched through the folded leaves.
Arthur felt his pulse drum against the collar of his shirt. He knew how saddle-stitched mini-comics were assembled in 1987. You printed the sheets on an office duplicator or an AB Dick tabletop press, folded them by hand with a bone folder, and used a heavy-duty, long-reach stapler to bind the spine. If a fragment of burnt paper had been caught in the staple wire, it had been present on the binding table at the moment the staple was driven home.
Someone had bound this copy of The Mirror Line in a room where other papers were actively being burned.
The phrase in Croft’s shipping ledger flickered through his mind: Seized at dock. 480 copies destroyed per settlement.
Had the destruction not happened in a pulping mill in New Jersey, as the official ledger claimed? Arthur looked at the carbonized fleck. Pulping was a wet process. You threw the newsprint into massive hydrapulpers filled with water and caustic soda, turning thousands of comic books into an unrecognizable gray slurry within minutes. You didn't burn them unless you were in a hurry, or unless you wanted to ensure that no salvageable scrap ever escaped the furnace.
Arthur saved the high-resolution RAW files to an encrypted external drive, ejected the disc, and returned The Mirror Line to its cardboard sandwich. He checked his watch. It was four in the afternoon. The library’s reference desk on the main floor would still be manned by Marlo Chen, the archive’s senior cataloger and the only person in the building who remembered the industry before the collectors took it over.
He slipped the package back into his satchel, exited the imaging suite, and took the service elevator down to the second-floor reading room.
The reading room smelled better than the basement—here, the odor of old paper was tempered by lemon oil and the dry, warm air of the circulating heaters. Marlo Chen sat behind the oak reference counter, flanked by two towering stacks of oversized trade paperback proofs from the mid-2000s. She was sixty-one, wore thick tortoiseshell frames on a silver chain, and had worked in the production bullpen of Marvel in the late seventies before migrating to academic cataloging when the corporate buyouts began.
"Arthur," she said without looking up from her pencil annotations. "You look like you swallowed an overdue notice. Did Croft’s files finally cough up the receipts for his Florida timeshare?"
"Marlo," Arthur said, leaning across the polished wood of the desk. "What do you know about the Hudson Graphic Arts Guild?"
Marlo’s pencil stopped mid-stroke. She looked over the rims of her glasses, her dark eyes narrowing slightly. "I know they ceased to exist around Thanksgiving of 1989. The union merged with the typographers, who then died quietly when QuarkXPress ate their lunch. Why? You working on labor relations in the commercial shops?"
"Did you ever know a member named Eleanor Vane?"
The silence that followed was heavy and deliberate. Marlo set her pencil down in the groove of her oak desk tray. She folded her hands over her cataloging sheets, her fingers interlocked. Outside the tall arched windows, the Manhattan rain was turning into a greasy evening sleet that streaked the glass with gray fingers.
"Where did you hear that name?" she asked.
"Box fourteen," Arthur said. "Milton Croft had a personal copy of The Mirror Line. Kept it filed between a wholesale order for The Savage Blade and an uncashed zero-dollar check."
Marlo let out a short, dry puff of air that might have been a laugh if there had been any humor behind it. "Milton kept it. The miserable bastard. He kept it like a scalp."
Arthur took a half-step closer. "You knew her."
"Everyone who worked on the West Side piers in the eighties knew who she was, even if they didn't know her face," Marlo said. She looked past Arthur toward the empty reading tables. "Eleanor wasn't a comic person. She didn't go to the conventions at the Pennsylvania Hotel to trade back-issues of Spider-Man. She worked third shift at a trade shop on Varick Street, running a massive four-color web press that did financial prospectuses during the day. At night, after the managers went home, she and a couple of other paste-up girls used the darkrooms to shoot plates for small presses, feminist poetry collectives, housing activists, anyone who couldn't afford commercial rates."
"And The Mirror Line?"
"That was hers alone," Marlo said softly. "She spent six months drawing it on forty-ply cold-press illustration board. She didn't use blue line pencil; she laid out the grids with an architect's drafting arm. It was an autopsy of how Croft and his buddies were slicing up the distribution map. Milton Croft, Harry Levinson from New England, and the guys in Chicago—they had formed an informal pool to fix wholesale discounts. If an independent publisher didn't give them exclusive distribution rights and an eighty-percent cut of the cover price, they refused to warehouse the book. If a comic shop tried to buy direct from the creator through the mail, Croft told the shop owner he’d cut off their supply of the big superhero books."
"That's illegal," Arthur said, though he knew the answer before the words left his mouth. "Restraint of trade. Sherman Antitrust."
"This was comic books in 1987, Arthur, not steel or oil," Marlo said, her tone dripping with weary condescension. "Nobody cared about five-dollar pulp magazines sold to teenagers in strip malls. The Department of Justice wasn't looking at longboxes. Croft ran his territory like a dock boss. And then Eleanor drew him into a comic."
"She drew his actual face," Arthur said. "I saw it. Page two."
"She didn't just draw his face. She printed his home address in the credits on the back leaf. Along with the unlisted office phone numbers of every regional distributor in the syndicate. She called it a public registry of cultural gatekeepers. She planned to distribute it at the New York Small Press Expo that April."
Arthur reached into his coat pocket and touched the outline of his notebook. "The ledger said the shipment was seized at the dock. Four hundred and eighty copies destroyed."
"Destroyed isn't the word Milton used," Marlo said. Her voice dropped to a low murmur. "Milton went down to her print cooperative in Hoboken on a Sunday morning with three guys who worked freight for his trucking firm. They didn't just seize the run. They broke her lightbox with an iron pipe. They smashed the glass on her process camera. And then they dragged the cartons of The Mirror Line out to the gravel lot behind the warehouse, poured kerosene over them, and set them on fire."
Arthur’s mind flashed back to the high-magnification image on the third floor: the orange rust of the wire, and the microscopic black fleck of charred wood-pulp trapped inside the steel crimp.
"The staples," Arthur said. "She was binding them while the fire was burning."
"She was inside the shop while they were burning the cartons outside," Marlo confirmed, her gaze steady and cold. "Milton told her that if she ever touched an ink brush again, he’d make sure she never got commercial work in New York, New Jersey, or Pennsylvania. In those days, commercial printing was a closed shop. Milton had connections with the teamsters and the union stewards. One call from him, and you couldn't get a job sweeping paper scraps off a pressroom floor."
"What did she do?"
"She packed her drafting kit into a leather bag, took whatever copies she had managed to staple before they broke the door down, and vanished," Marlo said. "Nobody in the union saw her again. A few people said she went to upstate New York. Some people thought she went to Canada. After a while, people just stopped asking. Milton Croft owned the market, and if you wanted to work in comics, you learned not to talk about the woman who tried to burn his house down."
"There are twenty copies missing from the ledger," Arthur said. "Croft noted four hundred and eighty destroyed. If the print run was five hundred, twenty survived."
Marlo looked at Arthur’s satchel. Her eyes lingered on the leather strap, then moved back to his face. "If you found one in Milton’s boxes, that means nineteen went into the wind with Eleanor. And Milton spent five years checking every comic shop in the northeast to see if any of those nineteen ever showed up in a back-issue bin."
"Did they?"
"Not one," Marlo said. "Whatever she did with those books, she kept them buried."
She reached out and tapped the desk between them with her index finger. "Be careful, Arthur. Milton Croft is dead, but the people who helped him run the syndicate aren't. Some of those old distributors retired into private equity; some of their kids run the media companies that own the comic properties today. They don't want people digging up the skeletons from the Direct Market transition. They like the story where the comic industry was saved by plucky visionaries, not a cartel of warehouse thugs."
Arthur stepped back from the desk. The air in the reading room felt suddenly thin. "Thank you, Marlo."
"I didn't tell you anything," Marlo said, picking up her pencil again. "And if anyone asks, Box fourteen was missing three years before you started working here."
Arthur walked out of the reading room and down the wide marble staircase that led to the archive’s main lobby. The security guard, an elderly man named Frank who had spent thirty years watching students fall asleep over microfiche readers, barely glanced up from his evening tabloid as Arthur tapped his plastic identification badge against the electronic turnstile.
Outside, the rain had settled into a sullen, rhythmic drumming against the asphalt of Mercer Street. The streetlights had flickered on, casting long, greasy amber reflections across the wet pavement. Arthur pulled the collar of his wool overcoat up against his neck, clutching his satchel tightly against his ribs beneath the fabric of the coat.
He walked three blocks west toward the subway entrance at West Fourth Street. The city in the rain felt old, thick with the weight of unseen infrastructure. Beneath his feet, through the iron grates embedded in the sidewalk, steam rose from the municipal conduits, mixing with the cold air to create a low-lying fog that smelled of sulfur, damp brick, and wet coal.
As he reached the tiled entrance of the subway station, Arthur paused under the concrete overhang to shake the rain from his umbrella. He reached into his coat to check the clasp of his satchel, his fingers brushing against the stiff cardboard sandwich containing The Mirror Line.
Under his thumb, through the heavy board, he could feel the faint, distinct ridge of the spine—the tiny, sharp bite of the staple wire that had survived the fire in the Hoboken gravel lot thirty-five years ago.
He pulled his notebook from his pocket and opened it to the page where he had recorded the ultraviolet scan. Beneath the Guild imprint, the scanner had revealed one more detail that he hadn't mentioned to Marlo Chen.
In the margin of page eight, etched into the zinc plate with an engraver’s drypoint needle so lightly that it only showed under ultraviolet shadow, was a series of four coordinates: an old rural delivery route in Columbia County, followed by a three-word phrase scrawled in Eleanor Vane’s cold, architectural hand:
Look for ash.
Arthur tucked the notebook away, swiped his transit card through the turnstile, and descended into the humid roar of the downtown platform.
This is a sample preview. The complete book contains 27 sections.