Be S.M.A.R.T. With Goal Setting

By Leah Teague

In our last post we encouraged our readers to make time for setting and evaluating goals and to help law students (and young lawyers) do the same. In this post we provide resources for use with the SMART technique (Specific, Measurable, Achievable, Realistic, Timely) for goal setting. We include the SMART technique in our textbook, Fundamental of Lawyer Leadership. In fact, we included it twice. We introduce students to the SMART goal-setting method in Chapter 9, Setting Goals, and we return to it in Chapter 20, How Leaders Manage Effectively, when discussing the importance of delegating and offering suggestions for how to delegate successfully.

Searching for goal setting advice offered to lawyers led to articles also recommending the SMART technique. I particularly liked Lawyer Personal and Career Goals because it starts with the question,

“’[W]hat’s your why?’ What kind of life do you want? … What impact do you want your work to have? Behind all those questions is your ‘why.’ It’s what gets you up in the morning and propels you through your day.”

The “why” should be the basis for setting goals and the control for evaluating actions. 

Other recent articles written for lawyers:

Since the SMART technique is mentioned in all, I did some digging to learn more about its origin. Some sources suggest the renowned Peter Drucker should be credited with its creation based upon his 1954 book “The Practice of Management.” Drucker, credited as the father of modern business management, believed management involved creating systems to set objectives and evaluate performance as part of a wholistic approach to building effective and responsible organizations and institutions. Drucker, born in Austria and raised in Germany, earned a Ph.D. in International Law in 1932 and moved to America two years after some of his work was banned and burned by the Nazi. As with all of us, Drucker’s teachings were influenced by his life experiences. He believed “[m]anagement, practiced well,” was necessary not only for the successful functioning of a company but also as the “bulwark against evil” he witnessed in society. I think Drucker would approve of our efforts to equip law students to be ethical lawyers who own their obligation to be the guardians of democracy.

Works recognizing the benefits of adopting “specific and measurable” goals and objectives can be traced back to Drucker and others in the 1940s and 1950s. Particularly interesting to those of us at Baylor who knew Paul J. Meyer, a report on the History of SMART Objectives credits Meyer with use of the SMART acronym in his work “Personal Success Planner” in 1965. Meyer, a long-time resident of Waco and generous benefactor to Baylor University, was “a pioneer of the personal development industry.” Through his companies, Success Motivation Institute and Leadership Management Institute, Meyer’s programs were produced in more than 70 countries and 27 languages and influenced other renowned leadership authors (such as John C. Maxwell).

The first published article using the SMART acronym appears to have been written by George Doran, Arthur Miller, and James Cunningham for the November 1981 issue of Management Review, titled, “There’s a S.M.A.R.T. way to write management’s goals and objectives.” Written for business managers to assist with being more thoughtful about setting out a plan to accomplish an objective, they encourage these 5 considerations for each goal:

  • Specific – target a specific area for improvement.
  • Measurable – quantify or at least suggest an indicator of progress.
  • Attainable – specify who will do it.
  • Relevant – state what results can realistically be achieved, given available resources.
  • Time-related – specify when the result(s) can be achieved.

We hope you will share with us the ways in which you incorporate the SMART technique into your work to better prepare law students and lawyers for leadership.



Setting Goals

By Leah Teague

Here is to a new year that bring less disruption and more togetherness!

January is a time when lots of people contemplate resolutions for the new year – a goal setting exercise of sorts. For those of us whose work calendar is tied to the academic year we have two additional times to routinely consider our goals and set objectives and action steps. We spend time each summer to construct plans for the fall or perhaps the entire academic year. In early winter we plan for the upcoming spring term. We are devoting this month to tips for effective goal setting practices.

Some of us are already regimented goal setters. Using daily planners, some gain a sense of security in the process of organizing daily tasks to be allocated across the precious few waking hours each day. Others prefer to view the weeks and months ahead as milestones to measure progress in the near future. This time of year, some think about last year’s New Year’s resolutions (i.e., whether met or still outstanding) before deciding the focus of efforts for this year. Still others engage in a retreat-like phenomenon to consider their next big direction in life. All these processes are goal-setting exercises, whether recognized as such or not. If any of these describe you, we hope what we offer will provide new resources to consider and a reason to assess your own goal setting routine.

For those who believe life is best lived by embracing spontaneity, we will offer advice for strategic engagement that is comfortable and productive. Dreams of great works without a plan of action can strand you in a state of unfulfilled potential and leave you longing for answer to the question of what if I had done this or that differently. Whatever our personality, we all benefit from setting aside some time periodically to consider our priorities and imagine great accomplishments and meaningful impacts that allow us to leave a desired legacy.

The same is true of our law students. Students commonly and falsely believe that their life will never be busier than their challenging-to-overwhelming time in law school. We know there is little truth in this assumption. As we seek to provide a more holistic approach to preparing our students for success and impact, we should make time to address the benefits of goal setting and offer suggestions for practices.

We already use goal setting techniques when we counsel students. For example, if a student seeks advice about how to make a good grade in a particular class (or a better grade than before), then they have stated a goal. We then help them to create a plan of action to accomplish the objectives that must be met in order to achieve the goal (i.e., sufficiently preparing for each class, reviewing and outlining material, studying for the exam, etc.). Many of our students come to law school with an understanding of the importance of the process and how to do it. Some do not and need additional assistance.

Whether the goal is passing a class, graduating summa cum laude, making a mock trial team, or winning an election as student body officer, providing students with instruction on goal setting is beneficial to them now. They will better manage their time and achieve more success in law school. If we help students develop the habit of setting goals and periodically assessing their progress while in law school, we give them one more tool to use on their journey to success and satisfaction in life after law school.

Stay tuned for practical tips next week!



AALS Annual Meeting – Session Invite

Leah Teague, Patricia Wilson, and Stephen Rispoli are presenting about “Developing Law Students and Faculty Who Can Lead Diversity, Inclusion, and Equity Efforts” in today’s AALS Associate Deans for Academic Affairs and Research Section session. We will be discussing how leadership development programs can help prepare students for their role as leaders in society. If the proposed amendment to ABA Standard 303 (b) is adopted, all law schools will be required to “provide substantial opportunities to students for … (3) the development of a professional identity.” Lawyers’ role as leaders in society IS a fundamental part of lawyers’ professional identity and leadership programs and courses help with that training.   

A well-developed leadership program also addresses important societal issues. The session today will focus upon the need for law schools to address issues of diversity, equity, inclusion, and antiracism. As part of our presentation, we will discuss proposed amendments to the ABA’s Standards that, if adopted, will require all law schools to provide education to law students on bias, cross cultural competency, and racism.

The virtual session, which includes several panel discussions, takes place today, January 5th, from 3:10-6:00 p.m. ET, and we’re up first! Log in to the AALS 2022 Annual Meeting to join us.


Happy Holidays…

We wish you the happiest of holidays and look forward to ‘seeing’ all of you at the
AALS Annual Meeting in January!

Sessions Sponsored or Co-Sponsored by the Section on Leadership:

Wed. January 5th – 12:35 – 1:50 PM ET – The Deborah Rhode Award Presentation

Wed. January 5th – 12:35 – 1:50 PM ET – Advancing Equality for Clinical Faculty of Color:
Recruitment, Retention, and Support

Wed. January 5th – 3:10 PM ‐ 4:25 PM ET – AALS Open Source Program: The Impact of Deborah Rhode

Fri. January 7th – 11:00 AM ‐ 12:15 PM ET – What Can Research Tell Us About How Law Schools, Lawyers, and
Leaders Can Nourish Democracy?

Fri. January 7th – 3:10 PM ‐ 4:25 PM ET – From Watergate to Insurrection: Fifty Years of Legal Ethics in the U.S.

Fri. January 7th – 4:45 PM ‐ 6:00 PM ET – Anti‐Racism and Clinic Design Choices

Sat. January 8th – 12:35 PM ‐ 1:50 ET – Prioritizing Public Service in Your Role as the Dean: Why it Matters

Sat. January 8th – 3:10 PM ‐ 4:25 ET – Leadership Education as a Component of Anti‐Racist Education in Law Schools



Reflection: Essential Practice for Growth

By Leah Teague

What happens when we repeat the same behavior or action over and over again?

Nothing new! The outcome is the same.

We know that, and yet sometimes we find ourselves stuck in a rut and have to learn that lesson again. What are we missing? Adopting a regular practice of reflection can help us learn and move forward to make the difference we seek. Reflective practice, like Aristotle’s practical wisdom, is built on the process of assessing an experience for the purpose of learning from it.

Some law school programs, such as legal clinics, routinely incorporate reflective practice into their training. As Professors Jodi Balsam, Susan Brooks, and Margaret Reuter noted in Assessing Law Students as Reflective Practitioners:

Clinical law teachers widely view reflective practice as fundamental to effective lawyering and the professional identity formation of lawyers, including the pursuit of core values, social justice, and personal growth. Indeed, most professional disciplines, including those related to medicine, mental health, and teaching, recognize reflective practice as a core competency.

Reflective Practice: Thinking About the Way You Do Things offers a further explanation and this visual approach to a reflective practice:

For a more detailed explanation of the steps in a reflective practice, and a helpful worksheet for your use, go to Reflective-Practice-in-the-Workplace.pdf (duke.edu).

The end of any period (such as the end of fall classes or the end of 2021) is an ideal time to be thoughtful and reflective before embarking on your next round of activities and duties. The challenge is finding time in the busyness of life to put that into practice. We encourage you to set aside the time to reflect, analyze, and plan for your future.

Challenge for December:

  1. Pick one activity in your life you wish were better/stronger/different and set aside one hour to reflect, analyze and plan.
  2. Building upon our gratitude focus last month, December provides an ideal time to send a holiday message to one of your groups (students from your fall class, colleagues, family or friend group). Before sending the message, reflect on your relationship with that group and then write a message that feels most appropriate. Your message could be sharing your appreciation for that group because of the significant role they play in your life and then suggesting your next interaction with them. You might use the message as an opportunity to reach out to heal a past hurt or clear up a misunderstanding. The possibilities are many! The message should be whatever your think best after thoughtful contemplation about the relationship.

We wish you the Happiest of Holidays!



Gratefulness takes reflection… and reflection spurs gratefulness.

By Stephen Rispoli

One of the characteristics of successful and effective leadership that we attempt to instill in our law students is the need to be self-aware. Effective leadership requires intentional reflection and introspection.

As we are in the midst of the holiday season, I thought I’d share a great collection of gratefulness articles. Gratefulness takes reflection, and reflection spurs gratefulness:




Leading in the Present

Guest Post Bridget M. Fuselier
Professor of Law, Baylor University School of Law

Leading by example.  We often use that phrase, but what does it mean?  In my experience, we most often think if we model practices and traits we want to see in our students or young lawyers we mentor, then we can lead them to adopt those behaviors.  When it comes to professionalism, civility, ethics, and hard work, most of us do a good job of leading by example.  But what about when it comes to mental health? 

In February 2016, The Journal of Addiction Medicine published a study conducted by Hazelden Betty Ford Foundation and the American Bar Association Commission on Lawyer Assistance Programs.  The study reported that 21 percent of licensed, employed attorneys qualified as problem drinkers, 28 percent struggled with some level of depression, and 19 percent demonstrated symptoms of anxiety. The study found that younger attorneys in the first 10 years of practice exhibited the highest incidence of these problems.  

In a 2018 Legal Trends Report prepared by Clio, 75% of lawyers reported frequently or always working outside of regular business hours, and that 39% of lawyers say these long hours negatively affected their personal lives.  Additionally, according to the Dave Nee Foundation, new law school students exhibit rates of depression around 8-9%—but after three years in law school, 40% of students are depressed. 

During the past 18 months plus, we have all had a lot of time with our thoughts, both positive and negative.  The isolation, anxiety, confusion, and fear has left us all mentally exhausted.  It has also helped us to refocus on our own physical and mental health and the importance of self-care.  As we have been gradually going back to “normal,” are we leading by example?  Taking time for our mental health is just as important as our physical health.  And our mental health does actually impact physical health. According to one article, “mental health plays a huge role in your general well-being. Being in a good mental state can keep you healthy and help prevent serious health conditions. A study found that positive psychological well-being can reduce the risks of heart attacks and strokes.  On the other hand, poor mental health can lead to poor physical health or harmful behaviors.”  Depression has been linked to diabetes, asthma, cancer, cardiovascular disease, and arthritis. Mental health conditions also contribute to sleep disorders like insomnia. 

As leaders, we have to model good habits of self-care and prioritizing mental health.  If we are open to talking about mental health, it will open up a dialogue for those who look to us as examples.  I have found that when I open up about my own challenges, others feel more comfortable about taking care of themselves and seeking the care they need.  However, if you are not comfortable sharing your own experiences, there are still ways to meaningfully connect and engage.  Here are some examples that I have used and received positive feedback from students:

  1. Sharing relevant articles regarding mental health can provide information to students and open the door for conversation.  The ABA often has great articles like the one found at this link, https://www.lawpracticetoday.org/article/managing-depression/, that can be used as a resource.   
  1. On Mondays, start class with a “Motivation Monday” power point slide.  I find a funny meme or inspirational quote to get the week started.  It is a fun way to not only show a human side but to maybe brighten someone’s day that isn’t going so well.
  1. At final exam time, share prayers, scriptures, inspirational quotes, or words of encouragement to let students know they are not alone, and we understand the stress. 
  1. Communicate with students that you are a safe person to turn to if they need to talk about mental health challenges and get help finding resources.

If we want to be good leaders today, and cultivate good leaders for tomorrow, let’s prioritize mental health and end the stigma. 

– Bridget Fuselier


Cultivating wellness in those who lead and those who are led

Guest Post By R. Lisle Baker
Professor of Law, Suffolk University Law School, Boston, MA

How can we cultivate wellness in those who lead and those who are led?

Lead from our strengths and draw on the strengths of those being led.

The late Dr. Christopher Peterson was a psychologist who offered this prescription for wellness in his Positive Psychology Primer: “if you want to be healthier, you should eat a balanced diet, exercise regularly and not smoke. You should have good relationships with other people and pursue activities that are fulfilling.”

Most of us think we understand diet, exercise and smoking – even if we don’t always follow the behaviors they reference. But how about having good relationships and finding fulfillment? They are general principles with less clear content.

One way I have found helpful with my students is to help them understand their unique set of character strengths, which can help them pursue activities that are fulfilling. Then they can use their awareness of their own strengths to perceive those strengths in those with whom they might interact – helping them have better relationships with those they lead. But how do they learn what those strengths might be?

Many law teachers are aware of the Diagnostic and Statistical Manual of Mental Disorders, or DSM, used by psychologists to classify and treat various kinds of behavioral health concerns. What is less well known is that the same Dr. Christopher Peterson directed and co-authored with Dr. Martin Seligman a treatise they referred to as a “manual of the sanities.” Their joint work, Character Strengths and Virtues: A Handbook and Classification, examined 24 strengths of character which have been valued across time and cultures. They are:

List of 24 strenghts of character: Creativity	Curiosity	Judgment
Love of Learning	Perspective	Bravery
Perseverance	Honesty	Zest
Love	Kindness	Social Intelligence
Teamwork	Fairness	Leadership
Forgiveness	Humility	Prudence
Self-regulation	Appreciation of Beauty and Excellence	Gratitude
Hope	Humor	Spirituality

But what makes their work most helpful is a questionnaire which allows anyone, without charge from the nonprofit VIA Institute on Character, to see what particular pattern of such strengths they have. The ones we rely on most often feel so natural to us that we may be unaware of them, like using a dominant hand, unless asked to reflect on what it would be like if we could not use them for an extended period. But people who become aware of their strengths, and use them appropriately in a chosen role, can lead more fulfilling lives. That is one way to meet part of what Dr. Peterson recommended for wellness.

As for good relationships with other people, when we become aware of our own strengths, we can also begin to notice strengths in other people. Mark Twain once wrote, “I can live for two months on a good compliment.” Often, however, for want of something better, our compliments may oftenfocus on something obvious, like how we dress. But what if instead we tell them what good they have done and how they have done it?

Part of the challenge is that we may not have a large enough vocabulary to do so. But if you notice and comment on other people’s perseverance or bravery or kindness, and say how you saw it expressed, you are honoring some of their 24 character strengths. A bonus is that because their top strengths are aspects of who they are, they may also take them for granted and not be as aware of them as we might be as observers of their behavior. When, however, they find them pointed out, they feel appreciated – perhaps even if a little bashful, as accepting a compliment is sometimes harder than giving one. Doing so, however, honors the giver as well as the recipient.

Leadership, however, extends beyond compliments. When we notice and call upon the strengths of those we lead for action, we can combine theirs with ours to enhance chances for success in a chosen task, just as a team can do more on the playing field than an individual can alone.

Looking for opportunities to compliment – and complement – character strengths in other people also provides us opportunities to honor others’ diversity. We often rely on visible signs of our differences rather than also looking for those invisible distinctions that can add additional value. Spotting and calling on their strengths offer us a means to that end which can further deepen our relationships. We, as law professors, have a role to play in teaching students how to be well themselves and lift up others. Understanding and appreciating our strengths and that of others can be helpful ways for aspiring leaders – as well as those of us who teach them – to have good relationships with other people and pursue leadership activities they find fulfilling – with greater wellness for all involved.  

– R. Lisle Baker


Cultivating an Attitude of Gratitude Beyond Thanksgiving

By Leah Teague

“Gratitude is not only the greatest of virtues,
but the parent of all others.”

– Cicero

Some practice a Thanksgiving tradition in which they share something (or someone) for which they are thankful. As we focus on well-being and celebrate Thanksgiving next week, it seems fitting to focus on the benefits of practicing gratitude. Rather than relegating thankfulness or gratitude to once a year, studies show tremendous benefits to practicing gratitude as part of our daily routine.

A gratitude practice may be especially beneficial for students experiencing the stress of law school. Students naively believe that life will magically be better/easier after law school, but we know such is not the case. The practice of law, and life, can grind up and wear down the best of us. Gratitude positively effects the well-being of both the person showing appreciation and the receiver.

This week before Thanksgiving is a perfect time to encourage our students, as well as our colleagues and loved ones, to practice gratitude regularly and offer suggestions on incorporating a gratitude practice.

Benefits of Gratefulness

The value of a gratitude practice is well established. In The Secret to Happiness (Part 2) – Gratitude, a blog post for the Massachusetts Lawyer Assistance Program, Dr. Shawn Healy noted:

Gratitude helps you put things in perspective. Specifically, it helps prevent your view of your situation from becoming overly negative. We have a tendency to see our situations in reference to the predominate emotional evaluation we experience. In other words, if our day seems more than 50% negative, we experience our entire day as negative. Likewise, if our day seems more than 50% positive, we have a better chance of experiencing our day as positive. Since everyday has both positive and negative aspects, it all depends on what you focus on. A day with one significant negative event can taint the entire day if that negative event is the focus on our attention.

Gratitude has a physiologic effect on us, and the benefits can be demonstrated scientifically, as Travis Whitsitt noted in a recent blog post, The Value of A Gratitude Practice for Lawyers and Law Students (And Tips For Starting One):

The regular practice of gratitude has been shown to decrease the body’s stress response, which in turn boosts immune performance. Studies have suggested it lowers the risk of heart disease, and studies consistently demonstrate that it reduces the symptoms of anxiety and depression while linking it to an overall improved mood. It can also improve relationships, both romantic and otherwise, with studies showing that partners who demonstrate gratitude toward each other experience improved happiness and relationship satisfaction. Studies also demonstrate that optimistic people suffer less from the negative effects of aging, and a gratitude practice has actually been shown to shift one’s outlook toward optimism when employed over time. In a profession rife with stress, anxiety, depression, and burnout, the above benefits sound pretty good to me.

Make the Easy Choice

From the repository of the “Pendleton Judicial Training Updates,” Retired Judge Pendleton from Minnesota reminds lawyers that we have an easy choice each day “between two possible daily mindsets:

1. A mindset where you are grateful for the opportunity to excel in a challenging field and happy just to be involved, or

2. A mindset of struggling and griping about every inch of gained ground, never satisfied with the outcome.

When you read those two choices, no one would consciously pick the second one. Yet when the bell rings and your day begins, many attorneys (and judges) allow themselves to revert to an adversarial mental state (choice #2). Besides the negative affect on the quality of your own life, a non-grateful daily attitude also has a profound impact on how you are perceived by others, including your friends and colleagues. Of course, most of you already know which local attorneys and judges fall into that second category. Don’t be one of them.”

Gratitude Exercise

We offer this gratitude exercise in Chapter 11 of the Teacher’s Manual for Fundamentals of Lawyer Leadership:

Gratitude Wall

Gratitude exercises allow for reflection on influential people and the milestones they made possible. A gratitude wall will enable students to show their recognition in a public way. The instructions for this exercise are simple. Have the students take 1-3 post-it notes and write down one thing they are grateful for on the note. Then have the students or lawyers place the post-it notes on the wall of the classroom or meeting room or a large poster board.

A variation on the gratitude wall is gratitude cards. For these, pass out note cards and have them write down one thing they are grateful for on each card and review these cards every day. In a following class or meeting, discuss how this exercise impacted their daily lives.

“When it comes to life, the critical thing is whether you take things for granted or take them with gratitude.” -G.K. Chesterton

We wish you a happy and healthy Thanksgiving!



Chop Wood, Carry Water – Book Review

Guest Post by Baylor Law Student Samantha Chaiken

The following post is a book review written by Samantha Chaiken, a student in our summer 2021 Leadership Class. As I reflect on Samantha’s thoughts below, two points seem particularly relevant to our discussion this month on the importance of wellness:

  • The author states that the training of our law students becomes their baseline to which they will revert when under pressure. What if we do not address the need to prioritize wellness? Shouldn’t we model and teach them how to do so? We know our students will have challenging times ahead. Let’s help them develop healthy coping mechanisms to be better prepared to weather their storms in law school and beyond.

  • A favorite lesson from the book was about the danger of ‘comparison left unchecked.’ Comparison, which is built into the fabric of law school, is often necessary and constructive; yet an environment of constant comparison can be taken too far and lead to unhealthy feelings about one’s self-worth or abilities and can rob us of our joy. Leadership development programming can help our students learn to cope as we emphasize developing grit, resilience, and a growth mindset to encourage students to view feedback constructively and failure as a normal aspect of their progression.

I hope you enjoy this book review as much as I did. – Leah

Chop Wood, Carry Water by Joshua Medcalf, is exactly as advertised. The book truly takes you through, chapter by chapter, how to fall in love with the process of becoming great. This leadership book is a quick read with each chapter providing a powerful lesson.

The book follows the story of John, a boy who dreamed of becoming a samurai warrior, specifically, an archer. John traveled to Japan where he enrolled as an apprentice to a small community of samurais. It is there that John meets a friendly old sensei by the name of Akira. Much like the Karate Kid, rather than “wax on, wax off,” Akira taught John how to “chop wood, carry water.” In each chapter of the book, Akira teaches John an important lesson that brings John closer to his goal of becoming a samurai warrior.

Lessons Learned

 Although there are many, one of my favorite lessons from the book is that “comparison is the thief of all joy.” One day as John was struggling, he was jealous of how easy things seemingly came to his peers while he had to work so hard and still not do as well as his peers. Akira pulled John aside and told him that he must focus on his journey and his alone. Otherwise, he would run the risk of not only losing his joy, but also losing any chance of true success in the long run.

One of my favorite quotes was Akira telling John, “There is nothing noble in being superior to your fellow man; true nobility is being superior to your former self.” This lesson truly resonated with me. As law students, we are constantly placed in positions of comparison.  We are constantly comparing grades, class performance, titles, positions on Law Review or in student organizations, and in many other aspects of our law school experience. With so much comparison, we lose our joy. We forget our prior successes that led us to law school in the first place. We diminish our accomplishments while in law school because there is seemingly always another classmate who did better than us. We fail to put our experiences in perspective.

This same phenomenon happens to lawyers in the real world as well. Only the subject matter of the comparison changes. That is why it is so important to take a minute to reflect on your own personal journey and the progress YOU have made. Otherwise, comparison is going to steal all your joy.

The book also teaches that “under pressure, you don’t rise to the occasion, you sink to the level of your training.” As I read through the chapter, I had to take a moment to be thankful that I attend Baylor Law. Though the training may be rigorous, and perhaps feels impossible at times, I know that under pressure I will be able to perform at an extremely high level.


I highly recommend this book – to law students, lawyers, or to anyone for that matter. This book will teach you, test you, and bring you to tears. Each lesson truly packs a punch. I had the opportunity to read this book during my time in Practice Court. I think it helped me to keep my journey in perspective. There were so many days when I would start reading and could not help but cry because the lesson was so applicable to what I was going through at the time.

If you are seeking to improve your leadership abilities, you must first look within yourself. This book will assist you along your journey of becoming great. However, even the book itself provides a warning that it is not enough to simply read the book and learn the principles, you must apply them in your everyday life no matter how challenging it may be.