ESignature Software: The Complete Guide to Digital Signing in 2026

Electronic signatures have moved from novelty to necessity. Whether you're closing a sales contract, onboarding a new hire, or collecting patient consent, eSignature software is now the default — not the exception. But with dozens of platforms competing for your budget, understanding what actually matters takes more than reading a feature list.

This guide covers everything: how eSignature software works, what makes it legally binding, which security standards matter, how pricing models compare, and how to calculate the real ROI for your organization. If you're evaluating options in 2026, start here.

What Is eSignature Software and How Does It Work?

eSignature software is a digital tool that allows individuals and organizations to sign, send, and manage documents electronically — without printing, scanning, or mailing anything. At its core, it replaces the physical act of signing with a legally recognized digital equivalent.

The software handles the entire signing lifecycle: document preparation, signer authentication, signature capture, record-keeping, and delivery of the completed document. Most platforms operate through a web browser or mobile app, with no software installation required for signers.

How Electronic Signatures Are Created and Validated

When you sign a document electronically, the software captures your intent to sign — typically through a typed name, drawn signature, uploaded image, or click-to-sign action. That intent is then bound to the document using cryptographic technology.

Here's what happens behind the scenes:

1. Document hashing — The software generates a unique cryptographic hash of the document at the moment of signing. Think of it as a digital fingerprint.
2. Signature binding — Your signature data is attached to that hash, creating a tamper-evident record.
3. Timestamping — A trusted timestamp is applied, recording exactly when the signature occurred.
4. Certificate issuance — For advanced and qualified signatures, a digital certificate from a trusted Certificate Authority (CA) is issued to verify the signer's identity.

Validation works in reverse: any party can verify that the document hasn't been altered since signing by checking the hash against the current document state. If even a single character has changed, the hash won't match — and the tampering is immediately detectable.

The Difference Between eSignatures and Digital Signatures

These terms are often used interchangeably, but they mean different things.

An electronic signature is the broad legal concept — any electronic symbol, sound, or process attached to a document with the intent to sign. This includes typed names, drawn signatures, and checkbox agreements.

A digital signature is a specific technical implementation of an electronic signature. It uses Public Key Infrastructure (PKI) cryptography to mathematically bind the signer's identity to the document. Digital signatures are the underlying technology that makes advanced and qualified eSignatures verifiable and tamper-evident.

In practical terms: all digital signatures are electronic signatures, but not all electronic signatures are digital signatures. Simple eSignatures (like a typed name) may not use PKI at all. Qualified electronic signatures (QES) always do.

How eSignature Software Fits Into Your Document Workflow

eSignature software doesn't just replace the signature step — it restructures the entire document workflow around it.

A typical workflow looks like this:

• Prepare — Upload a document or use a pre-built template. Add signature fields, date fields, initials, and form inputs.
• Send — Specify signers by email, set signing order if needed, and dispatch the document.
• Sign — Signers receive a link, authenticate their identity, and complete the signature in their browser or mobile app.
• Track — The sender monitors real-time status: opened, viewed, signed, declined.
• Store — The completed document and its audit trail are stored securely and made available for download or integration into your document management system.

This replaces a process that previously involved printing, physically signing, scanning, emailing, and manually filing — often taking days — with one that can be completed in minutes.

Is eSignature Software Legally Binding?

Yes — in most countries and for most document types, electronic signatures carry the same legal weight as handwritten signatures. But the legal framework varies by jurisdiction, and there are specific exceptions worth knowing.

ESIGN Act and UETA: US Legal Standards

In the United States, two federal laws establish the legal validity of electronic signatures:

The Electronic Signatures in Global and National Commerce Act (ESIGN Act), enacted in 2000, gives electronic signatures the same legal standing as handwritten signatures for transactions in interstate and foreign commerce. It applies at the federal level.

The Uniform Electronic Transactions Act (UETA), adopted by 49 states plus Washington D.C., provides the same protections at the state level. Together, ESIGN and UETA create a consistent legal foundation across the US.

For an eSignature to be legally valid under these laws, four conditions must be met:

1. All parties must intend to sign electronically.
2. All parties must consent to conduct the transaction electronically.
3. The signature must be associated with the signed record.
4. Records must be retained and reproducible.

Reputable eSignature software is built to satisfy all four conditions automatically.

EIDAS Regulation: European Compliance

In the European Union, the eIDAS Regulation (Electronic Identification, Authentication and Trust Services), effective since 2016, governs electronic signatures across all EU member states. It defines three tiers of electronic signatures:

• Simple Electronic Signature (SES) — Basic electronic signature with no specific technical requirements. Legally valid but offers minimal identity verification.
• Advanced Electronic Signature (AES) — Uniquely linked to the signer, capable of identifying the signer, created using data under the signer's sole control, and linked to the signed data so any change is detectable.
• Qualified Electronic Signature (QES) — The highest tier. Created using a qualified electronic signature creation device and based on a qualified certificate issued by a trust service provider. QES has the equivalent legal effect of a handwritten signature across all EU member states.

For most business transactions in Europe, AES is sufficient. QES is required for specific high-stakes documents.

Industries and Document Types Where eSignatures Are Accepted

eSignatures are accepted across a wide range of industries and document types, including:

• Sales and commercial contracts — Purchase agreements, service contracts, vendor agreements
• HR documents — Offer letters, employment contracts, NDAs, policy acknowledgments
• Real estate — Lease agreements, purchase offers, disclosure forms
• Finance — Loan applications, account opening forms, investment agreements
• Healthcare — Patient intake forms, consent forms, HIPAA authorizations
• Legal — Settlement agreements, retainer agreements, licensing contracts
• Government — Permit applications, regulatory filings (jurisdiction-dependent)

When a Wet Signature Is Still Required

Despite broad acceptance, there are document categories where wet (handwritten) signatures are still legally required in many jurisdictions:

Wills and testamentary documents

• Adoption and family law documents (in some states)

Court orders and certain legal filings

• Notarized documents (though remote online notarization is expanding)
• Certain real estate deeds (jurisdiction-specific)
• Negotiable instruments under specific circumstances

Always verify requirements with legal counsel for high-stakes or jurisdiction-specific documents.

Key Features to Look for in eSignature Software

Not all eSignature platforms are built the same. Here's what separates capable software from tools that will create friction at scale.

Signature Types: Simple, Advanced, and Qualified

Your platform should support the signature type appropriate for your use case and jurisdiction. Most business workflows are well-served by simple or advanced electronic signatures. If you operate in regulated European markets or handle high-value legal documents, you may need qualified electronic signature support.

Look for platforms that clearly document which signature types they support and under which regulatory frameworks. Ambiguity here is a red flag.

Audit Trails and Tamper-Evident Records

A complete audit trail is non-negotiable. Every signing event should be logged with:

• Signer identity and email address
• IP address and geolocation at time of signing
• Timestamp of each action (opened, viewed, signed)
• Document hash before and after signing
• Authentication method used

This record is your legal evidence if a signature is ever disputed. Ensure the audit trail is embedded in the completed document or stored in a format that can be independently verified — not just accessible through the vendor's dashboard.

Template Management and Bulk Sending

If you're sending the same document type repeatedly — offer letters, NDAs, lease agreements — templates save significant time. Look for:

• Reusable templates with pre-placed signature fields
• Bulk sending — the ability to send one document to hundreds of signers simultaneously, each receiving their own unique signing instance
• Template sharing across teams and departments
• Version control to manage template updates

Bulk sending is particularly valuable for HR teams rolling out policy updates or sales teams sending standardized agreements at volume.

Integrations With CRM, ERP, and Productivity Tools

eSignature software that lives in isolation creates manual work. The best platforms integrate directly with the tools your team already uses:

• CRM — Salesforce, HubSpot, Pipedrive (trigger document sends from deal stages)
• ERP — SAP, NetSuite (connect contracts to financial records)

- HR platforms — Workday, BambooHR, Greenhouse

- Productivity suites — Google Workspace, Microsoft 365

- Storage — Dropbox, Box, SharePoint, Google Drive

• APIs — For custom integrations and embedded signing experiences

Evaluate integrations based on your actual tech stack, not the length of the vendor's integration list.

Mobile Signing and Offline Capabilities

Signers don't always have access to a desktop. Mobile signing — through a responsive web experience or dedicated app — is essential for field teams, remote workers, and external parties signing on their own devices.

Key mobile considerations:

• Does the signing experience work cleanly on iOS and Android?
• Can signers complete the process without downloading an app?
• Does the platform support offline signing with sync when connectivity is restored?

For industries like real estate, construction, and field services, offline capability can be the difference between closing a deal on-site and losing momentum.

ESignature Software Security and Compliance

Security isn't a feature — it's a prerequisite. Here's what to verify before trusting a platform with your documents.

Encryption Standards: TLS and AES-256

Documents in transit should be protected by TLS (Transport Layer Security) — the same encryption standard used by banks and financial institutions. Documents at rest should be encrypted using AES-256, the current industry standard for symmetric encryption.

Any platform that doesn't explicitly confirm both standards should be disqualified from enterprise consideration.

SOC 2 Type II, ISO 27001, and HIPAA Compliance

Third-party compliance certifications tell you that an independent auditor has verified the vendor's security controls — not just that the vendor claims to be secure.

• SOC 2 Type II — Confirms that security controls have been in place and operating effectively over a sustained period (typically 6–12 months). More rigorous than SOC 2 Type I.
• ISO 27001 — International standard for information security management systems. Particularly relevant for global operations.
• HIPAA compliance — Required if you're handling protected health information (PHI). The platform must sign a Business Associate Agreement (BAA) with your organization.

Ask vendors for their current compliance certifications and the date of their most recent audit. Certifications expire and need renewal.

Multi-Factor Authentication and Role-Based Access

Authentication controls protect both the signing process and your administrative environment.

For signers, look for:

• Email verification links
• SMS one-time passcodes
• Knowledge-based authentication (KBA)
• Government ID verification for high-assurance use cases

For your internal team, look for:

• Multi-factor authentication (MFA) for admin access
• Role-based access control (RBAC) — limiting who can create templates, send documents, access reports, or manage billing
• Single Sign-On (SSO) integration with your identity provider

Data Residency and GDPR Considerations

If you operate in the EU or handle data from EU residents, GDPR compliance is mandatory. Key questions to ask vendors:

• Where is data stored? Can you choose your data residency region (EU, US, etc.)?
• Does the vendor act as a data processor under GDPR? Do they provide a Data Processing Agreement (DPA)?
• What is their data retention policy? Can you delete records on demand?
• Do they use sub-processors, and are those sub-processors disclosed?

Data residency is increasingly important for regulated industries and multinational organizations. Don't assume — verify.

Top Use Cases for eSignature Software Across Industries

eSignature software delivers value across virtually every industry, but the specific workflows and requirements vary. Here's how it plays out in practice.

Real Estate: Contracts and Lease Agreements

Real estate is one of the highest-volume use cases for eSignatures. Agents, brokers, landlords, and property managers deal with a constant flow of time-sensitive documents: purchase offers, counteroffers, lease agreements, disclosure forms, and addenda.

eSignature software eliminates the need for in-person signings, allows multiple parties to sign in sequence, and creates a clear audit trail for every transaction. In competitive markets, the ability to get a signed offer back in minutes — rather than hours — can be the difference between winning and losing a deal.

HR and Recruiting: Offer Letters and NDAs

HR teams send high volumes of standardized documents: offer letters, employment agreements, NDAs, benefits enrollment forms, and policy acknowledgments. eSignature software with template management and bulk sending capabilities dramatically reduces the administrative burden.

For recruiting, faster offer letter turnaround reduces the risk of losing candidates to competing offers. For compliance, digital records with timestamps and audit trails are easier to manage and retrieve than paper files.

Legal and Finance: Client Agreements and Loan Documents

Law firms and financial institutions handle documents where accuracy, security, and legal defensibility are paramount. eSignature software with advanced authentication, tamper-evident records, and qualified signature support meets the bar for most legal and financial use cases.

Loan origination, in particular, benefits from eSignature integration with loan origination systems (LOS) — reducing processing time and eliminating manual data entry errors.

Healthcare: Patient Consent Forms

Healthcare providers collect consent forms, HIPAA authorizations, intake questionnaires, and treatment agreements at every patient interaction. Paper-based processes create administrative bottlenecks and storage challenges.

eSignature software built for healthcare must be HIPAA-compliant, support BAA execution, and integrate with Electronic Health Record (EHR) systems. The result is faster patient intake, reduced administrative overhead, and cleaner compliance records.

Sales: Proposals and Order Forms

Sales teams live and die by deal velocity. Every hour a contract sits unsigned is an hour a deal can fall apart. eSignature software integrated with your CRM allows reps to send proposals directly from the deal record, track when prospects open and view documents, and receive instant notifications when signatures are complete.

Platforms with built-in document creation (like PandaDoc) go further, combining proposal building, pricing tables, and eSignature into a single workflow.

ESignature Software Pricing: What to Expect in 2026

Pricing models vary significantly across platforms, and the sticker price rarely tells the full story. Here's how to evaluate what you're actually paying for.

Free vs. Paid eSignature Plans: What You Actually Get

Several platforms offer free tiers, but they come with meaningful limitations:

• Dropbox Sign — Free plan limited to 3 documents per month
• Xodo Sign — Free plan limited to 3 documents per month
• PandaDoc — Free eSign plan available, but document automation features require paid tiers
• BoldSign — Free Essentials plan with limited envelopes
• SignWell — Free plan capped at 3 documents per month

Free plans are useful for individuals or very low-volume use cases. For any team sending more than a handful of documents per month, a paid plan is necessary.

Per-User vs. Per-Envelope Pricing Models

The two dominant pricing models are:

Per-user pricing — You pay a monthly or annual fee per seat, regardless of how many documents you send. This model is predictable and scales well for high-volume teams. Examples: DocuSign Standard at $25/user/month, Adobe Sign Team from $14.99–$24.99/user/month.

Per-envelope pricing — You pay per document sent (an "envelope" typically contains one or more documents sent to one or more signers). This model can be cost-effective for low-volume users but becomes expensive at scale.

Some platforms blend both models — charging per user with caps on monthly envelopes, then charging overage fees beyond the cap. This is where hidden costs emerge.

Enterprise Licensing and Volume Discounts

Enterprise plans typically offer:

• Unlimited or high-volume document sending
• Advanced security and compliance features (SSO, RBAC, audit logs)
• Dedicated account management and SLAs
• Custom integrations and API access
• Volume discounts negotiated directly with the vendor

Enterprise pricing is almost always custom-quoted. If you're evaluating at enterprise scale, request a formal proposal and negotiate on total contract value, not just per-seat price.

Hidden Costs to Watch Out For

Before signing a contract, scrutinize these potential add-ons:

• Overage fees — Charges for exceeding monthly envelope or document limits
• API access fees — Some platforms charge separately for API usage
• Advanced authentication — SMS verification, KBA, or ID verification may cost extra per transaction
• Template limits — Lower tiers may cap the number of reusable templates
• Storage fees — Long-term document storage beyond a certain retention period
• Onboarding and implementation fees — Enterprise deployments sometimes carry setup costs
• Annual commitment penalties — Early termination fees if you need to exit a contract

Always request a complete pricing breakdown, including all potential add-ons, before committing.

How GoSign Compares to Other eSignature Software

GoSign is built for organizations that need reliable, secure eSignature software without the complexity and cost overhead of legacy platforms. Here's how it stacks up against the major alternatives.

GoSign vs. DocuSign

DocuSign is the market incumbent — widely recognized, broadly integrated, and trusted by enterprises. But that recognition comes at a price. DocuSign's Business Pro plan runs $40/user/month, and essential features like bulk sending and advanced fields are locked behind higher tiers. Teams that need straightforward signing workflows often find themselves paying for capabilities they don't use.

GoSign delivers the core functionality that most organizations actually need — templates, audit trails, multi-party signing, and integrations — at a price point that doesn't require a procurement committee to approve.

GoSign vs. Adobe Acrobat Sign

Adobe Acrobat Sign integrates seamlessly with the Adobe ecosystem, which is a genuine advantage if your team lives in Acrobat. But the pricing structure is complex: Individual plans start at $12.99/month, Team plans range from $14.99 to $24.99/user/month, and Business plans reach $39.99/user/month — with transaction limits on lower tiers that can trigger unexpected overage costs.

GoSign offers transparent, predictable pricing without transaction caps that penalize growth.

GoSign vs. HelloSign (Dropbox Sign)

Dropbox Sign (formerly HelloSign) is a clean, well-designed product with a loyal user base among Dropbox users. Its free tier is limited to 3 documents per month, and paid plans start at $15/user/month for Essentials. The platform's tight Dropbox integration is a strength — but also a limitation if Dropbox isn't central to your workflow.

GoSign integrates with a broader range of storage and productivity tools, making it a better fit for organizations not anchored to the Dropbox ecosystem.

GoSign vs. PandaDoc

PandaDoc is a strong choice for sales teams that need document creation, proposal building, and eSignature in one platform. Its Business plan at $49/user/month reflects that broader scope. But for organizations that already have document creation handled and simply need reliable signing, PandaDoc's pricing includes capabilities you may not need.

GoSign focuses on the signing workflow itself — delivering speed, security, and compliance without the overhead of a full document automation suite for teams that don't require it.

Feature Comparison Table

How to Implement eSignature Software in Your Organization

A successful rollout isn't just about picking the right platform — it's about deploying it in a way that drives adoption and delivers measurable results.

Step 1: Audit Your Current Document Processes

Before you configure anything, map your existing workflows. Identify:

• Which document types are signed most frequently
• How many signers are typically involved per document
• Where delays currently occur (preparation, routing, follow-up)
• Which teams or departments have the highest signing volume
• What systems currently store or manage signed documents

This audit gives you a clear picture of where eSignature software will deliver the most immediate value — and helps you prioritize which workflows to migrate first.

Step 2: Choose the Right Plan and Integrations

Based on your audit, select a plan that matches your volume and feature requirements. Avoid over-buying features you won't use in the first six months — you can upgrade as adoption grows.

Identify the two or three integrations that will have the most impact: typically your CRM, your HR platform, and your document storage system. Confirm that native integrations exist or that the API supports your custom requirements before committing.

Step 3: Set Up Templates and Signing Workflows

Templates are the highest-leverage configuration task. Start with your five most frequently sent document types and build templates for each:

• Place signature, initials, date, and form fields precisely
• Set signing order for multi-party documents
• Configure automated reminders for unsigned documents
• Set expiration dates for time-sensitive agreements

Well-built templates eliminate the manual field-placement step for every document send — which is where most time savings are realized.

Step 4: Train Your Team and Roll Out Gradually

Resist the urge to flip the switch for your entire organization at once. A phased rollout reduces disruption and allows you to identify friction points before they affect critical workflows.

Recommended approach:

1. Pilot with a single team — Choose a team with high document volume and a willingness to provide feedback (sales or HR are good candidates).
2. Collect feedback and refine — Adjust templates, workflows, and integrations based on real usage.
3. Expand department by department — Roll out to additional teams with the lessons learned from the pilot.
4. Provide role-specific training — Senders need more training than signers. Focus your training investment accordingly.

Step 5: Monitor Adoption With Analytics and Reporting

Most eSignature platforms provide usage analytics. Track:

• Documents sent per user — Identifies who is and isn't using the platform
• Average time to completion — Measures the impact on document cycle time
• Decline and void rates — Flags workflow or document design issues
• Reminder frequency — High reminder rates suggest friction in the signing experience

Use this data to identify adoption gaps, optimize workflows, and build the business case for expanding usage across the organization.

ESignature Software ROI: Time and Cost Savings by the Numbers

The business case for eSignature software is straightforward — but quantifying it for your specific organization requires looking at the right variables.

Average Time Saved Per Document Cycle

Traditional paper-based document cycles — print, sign, scan, email, file — routinely take 24 to 72 hours per document, and longer when physical mail is involved. eSignature software compresses that cycle to minutes for simple documents and hours for complex multi-party agreements.

For organizations processing hundreds of documents per month, the cumulative time savings translate directly into staff hours recovered for higher-value work.

Cost Reduction: Paper, Printing, and Courier Elimination

The direct cost savings from eliminating paper-based processes include:

• Paper and printing costs — Ink, paper, printer maintenance, and supplies
• Courier and postage — Overnight shipping for time-sensitive documents can run $20–$50 per package
• Physical storage — Filing cabinets, offsite storage facilities, and the staff time to manage them
• Administrative labor — Time spent printing, scanning, filing, and tracking paper documents

For organizations with significant document volume, these costs add up quickly. A team sending 200 documents per month via courier at $30 per shipment is spending $6,000 per month — $72,000 per year — on logistics alone.

Faster Deal Closure and Revenue Impact

For sales organizations, the revenue impact of faster contract execution is the most compelling ROI driver. Every day a contract sits unsigned is a day revenue is at risk. Prospects change their minds. Competitors make counter-offers. Budgets get frozen.

eSignature software that integrates with your CRM and sends instant completion notifications allows sales teams to follow up at exactly the right moment — reinforcing the decision and accelerating cash collection.

How to Calculate Your Own eSignature ROI

Use this framework to build your own ROI calculation:

1. Volume — How many documents does your organization sign per month?
2. Current cycle time — What is the average time from document preparation to completed signature today?
3. Target cycle time — What is the realistic target with eSignature software?
4. Labor cost — What is the fully-loaded hourly cost of the staff involved in document processing?
5. Direct costs eliminated — Printing, courier, storage
6. Revenue impact — For sales documents, what is the average deal value and what percentage improvement in close rate or cycle time is realistic?

Multiply the time saved per document by your volume and labor cost, add direct cost savings, and compare to the annual platform cost. For most organizations processing more than 50 documents per month, the payback period is measured in weeks, not months.

Get Started With GoSign eSignature Software Today

GoSign is built for organizations that need eSignature software that works — without the complexity, hidden costs, or enterprise sales cycles of legacy platforms.

Start Your Free GoSign Trial in Under 5 Minutes

You don't need a credit card, a demo call, or a procurement process to see GoSign in action. Sign up, upload a document, add signature fields, and send it — all in under five minutes. The trial gives you full access to GoSign's core features so you can evaluate it against your real workflows, not a curated demo environment.

Available Support: Live Chat, Help Center, and Onboarding Calls

GoSign provides live chat support for immediate questions, a comprehensive help center with step-by-step guides and video walkthroughs, and onboarding calls for teams that want a structured setup experience. You're not handed a knowledge base and left to figure it out.

GoSign for Teams and Enterprise: Talk to Sales

If you're evaluating GoSign for a team of ten or a company of ten thousand, the sales team can walk you through volume pricing, enterprise security configurations, custom integrations, and SLA options. There's no pressure and no minimum commitment required to have the conversation.

FAQ

What is the best eSignature software for small businesses in 2026?

The best eSignature software for small businesses depends on your volume and workflow complexity. For very low volume (under 3 documents per month), free tiers from platforms like Dropbox Sign or Xodo Sign may be sufficient. For growing businesses that need unlimited signing, template management, and integrations without paying enterprise prices, GoSign offers a strong combination of capability and value. The key is to match the platform to your actual document volume and integration requirements — not to pay for features you won't use.

Is eSignature software safe and secure to use?

Yes — reputable eSignature software is built on the same encryption standards used by financial institutions. Look for platforms that use TLS for data in transit and AES-256 for data at rest, hold SOC 2 Type II certification, and provide complete audit trails for every signing event. The security of a well-built eSignature platform typically exceeds that of paper-based processes, which have no equivalent audit trail or tamper detection.

Can I use eSignature software for free?

Several platforms offer free tiers, including Dropbox Sign, Xodo Sign, PandaDoc, BoldSign, and SignWell — though most cap free usage at 3 documents per month. Free plans are suitable for individuals or very occasional use. Any team with regular document volume will need a paid plan to avoid hitting limits at inconvenient moments.

How long does it take to set up eSignature software?

For basic use — uploading a document, adding signature fields, and sending — setup takes minutes. For a full organizational deployment with templates, integrations, and team permissions, a realistic timeline is one to two weeks for a small team and four to eight weeks for a larger organization with complex workflows. The phased rollout approach described in this guide helps manage that timeline effectively.

Does eSignature software work on mobile devices?

Yes. All major eSignature platforms support mobile signing through responsive web browsers, and most offer dedicated iOS and Android apps. Signers can complete the entire signing process on a smartphone without downloading anything. For senders and administrators, mobile apps vary in capability — some platforms offer full document management on mobile, while others are more limited. If mobile administration is important to your workflow, test it specifically during your trial.

What types of documents can be signed with eSignature software?

eSignature software supports a wide range of document types, including PDFs, Word documents, and most common file formats. Accepted document categories include sales contracts, employment agreements, NDAs, lease agreements, loan documents, patient consent forms, vendor agreements, purchase orders, and policy acknowledgments. The primary exceptions — where wet signatures may still be required — include wills, certain court filings, and some notarized documents, depending on jurisdiction. When in doubt about a specific document type, consult legal counsel.