|Virginia Court Affirms
Denial of Motion to Quash Subpoena for AOL
Records on Anonymous Poster
11/1. The Virginia
issued its opinion
[MS Word] in AOL
v. Nam Tai Electronics,
affirming a Virginia trial court order refusing an ISP's (AOL) motion to quash
a subpoena duces
tecum based upon an electronics company's (Nam Tai) California
action against anonymous persons who allegedly published false and defamatory
messages about it on a Yahoo message board. See also, opinion
[TXT] without footnotes. Bottom line: AOL cannot protect the anonymity of its
subscriber in this case.
Background. Nam Tai is a Hong
Kong based company that makes telecommunication products, palm sized PCs,
personal digital assistants (PDAs), linguistic products, calculators and various
components including LCD modules and RF modules for mobile phones, transformers
and LCD panels. Its stock is traded on the NASDAQ exchange.
Yahoo, an Internet portal, maintains a
message board for discussion of Nam
Tai stock. America Online (AOL) is, among
other things, an Internet service provider based in Loudon County, Virginia.
Nam Tai asserts that numerous anonymous individuals posted defamatory
messages about Nam Tai to the Yahoo message board. It further asserts that one
such person used the email address email@example.com. "Scovey" received notice
of, but did not participate in, the court proceedings described below.
California Action. Nam Tai first filed a complaint in California Superior
Court (Los Angeles County) against 51 unnamed individuals alleging violation of
the California unfair business practices statutes in connection with their
publishing allegedly "false, defamatory, and otherwise unlawful messages" on
Yahoo message board devoted to a discussion of Nam Tai stock.
Nam Tai obtained a subpoena duces tecum from the California Superior Court
directing Yahoo to disclose its subscriber data on "scovey2". Yahoo complied.
The information that it disclosed revealed that "scovey2" obtained his Internet
access through AOL, that "scovey2" used IP address 126.96.36.199 which is
registered to AOL, and that "scovey2" provided to Yahoo the alternate email
address of "firstname.lastname@example.org".
Nam Tai then obtained a commission for out of state
discovery from the California Superior Court to depose AOL's custodian of
records in the state of Virginia.
Virginia Action. Nam Tai then filed a praecipe in the
Circuit Court of Loudoun County, Virginia, for a foreign subpoena duces tecum. The
clerk of the trial court issued the subpoena directing AOL's custodian of
records to produce records related to "email@example.com". Rather than comply, AOL
filed a motion to quash the subpoena duces tecum, asserting the First Amendment
right to speak anonymously. AOL also argued that its motion should be granted,
based upon principles of comity. After receiving further guidance from the California
Superior Court, the Virginia Circuit denied AOL's motion to quash and directed
AOL to comply with the subpoena duces tecum. AOL appealed.
Virginia Supreme Court. The Supreme Court affirmed the trial court
order pursuant to principles of comity, and its application of the Uniform
Foreign Depositions Act (Virginia Code §§ 8.01-411 through –412.1).
Section 411 provides that "Whenever any mandate, writ or commission is issued
out of any court of record in any other state . . . witnesses may be compelled
to appear and testify and to produce and permit inspection or copying of
documents in the same manner and by the same process and proceeding as may be
employed for the purpose of taking testimony or producing documents in
proceedings pending in this Commonwealth."
The Virginia Supreme Court, relying on its previously decided case,
AOL v. APTC,
stated the Virginia will afford comity to an order issued by a court of another
state, if certain conditions are met. "First, the foreign court must have
personal and subject matter jurisdiction to enforce its order within its own
judicatory domain. Second, the procedural and substantive law applied by the
foreign court must be reasonably comparable to that of Virginia. Third, the
foreign court's order must not have been falsely or fraudulently obtained. And,
fourth, enforcement of the foreign court's order must not be contrary to the
public policy of Virginia, or prejudice the rights of Virginia or her citizens."
The Court addressed each of these four conditions in its analysis of AOL's
challenge to enforcement of the subpoena. It found that the California subpoena
satisfied all found conditions.
|Commerce Department Official Addresses IT
|10/28. Deputy Secretary of Commerce
Samuel Bodman gave a
speech on cyber security at a US EU Information Security Forum in Brussels,
Belgium. Bodman also gave a broader
speech on electronic commerce, information security, protection of digital
intellectual property, broadband deployment, and spectrum management.
Information Security. He stated in his speech on security that "Information security is a critical component of the homeland security
equation. As the world is increasingly connected by the Internet, we
are also more vulnerable from different directions ... the
cyber world has no borders. Just last week, this vulnerability was
evidenced by the ``distributed denial of service´´ attack launched
against the Internet root servers. While this attack did not
significantly impact Internet users, it does remind us of the constant
threat that cyber attacks pose."
He continued that "we must strike the right balance between private sector
leadership and government involvement. President Bush has consistently advocated
a policy agenda that promotes market based solutions and encourages competition
... and which regulates, when absolutely necessary, in a transparent and
He also stated that "Information security is -- and should be -- incorporated
into the fabric of doing business ... it must be an integral part of a company's
strategic planning and operations, just like marketing or product development.
Companies must institutionalize the process of identifying critical assets,
assessing their vulnerabilities, and managing the risks associated with these
E-Commerce. In his broader speech, Bodman reiterated President Bush's commitment to
"to pursue an e-commerce agenda that promotes market based solutions".
He stated that "the private and public sectors must communicate and collaborate to remove
barriers to e-commerce and to strengthen the security of our information and
Intellectual Property. He said that "Respecting and enforcing IP rights is necessary
for innovation to flourish. The digital marketplace presents us with difficult
challenges, however. The same avenues that provide unprecedented opportunities
to distribute content also enable widespread piracy. And, we've seen that
technological solutions that promise protection for digital content raise
legitimate concerns for innovators and consumers."
He continued that "I understand the complexities of a digital rights
management system, but I don't see how not developing a solution, or delaying
implementation benefits anyone in the long run ... I know that some of you are
legitimately concerned that efforts to ``fix´´ these new vulnerabilities will
eviscerate consumers' fair use rights, curtail innovation in other areas, or
inappropriately prevent business model evolution. In other words, that the cure
could be worse than the disease ... these issues are valid, but I would also
counter that not taking action entails substantial risks and could be extremely
costly in the long-run."
He concluded that "Government should continue to do its part ... enforcing the law
to make piracy an elusive and ineffective competitor to legitimate digital
content, facilitating industry progress, and engaging and educating consumers.
But, I have confidence that the market has the wisdom to deliver an effective
solution to digital rights management ..."
Broadband. Bodman stated that "Governments need to create the right
environment for further investment in broadband and enabling technologies by
supporting research and development, promoting e-government, promoting
innovative approaches like broadband demand aggregation, and educating
Spectrum. He briefly touched on spectrum management. He said that
"will be making available 90 megahertz of radio spectrum for advance wireless
telecommunications services. Making additional spectrum available will allow
industry to meet the anticipated demand for 3G wireless services while spurring
the development of innovative new wireless applications."
|PFF Releases Report Ranking States in Use of IT
|11/4. The Progress & Freedom Foundation (PFF)
released a report
[62 pages in PDF] titled "The Digital State 2002: How State Governments Use
Digital Technologies". The report ranks the fifty states according to how well
their governments use, deploy and manage information
The PFF used a questionaire to collect information from the states in eight
areas. First, "The use of the Internet and Intranets to locate, file and store
paperwork as well as for procurement and intra-governmental projects." Second,
"The use of the Internet for tax information, forms and filing as well as for
digital record keeping." Third, "The use of the Internet for program
information, eligibility requirements and processing applications for
administrative purposes. In addition, the security of access to client records
was measured." Fourth, " The use of the Internet and two-way, digital multimedia
applications for law enforcement, judicial and corrections officials as well as
to provide public information."
Fifth, "Measures for online or digital access to, and promotion of,
information about state government and the electoral process and the use of the
Internet as an information management tool for the legislature." Sixth,
"Measures of institutional arrangements for digital policy decision making and
long-term infrastructure management." Seventh, "The use of digital technologies
for education, including functions in the areas of administration, instruction
and reporting." And eighth, "The use of geographic information systems and data
-- in intra-governmental and in transportation policy -- as well as
institutional arrangements for collecting and making GIS available to the
The PFF ranked states in each of these eight categories, and overall. The top ranked state was Arizona. The next nine states were Michigan,
Washington, Illinois, Wisconsin, Virginia, Utah, Indiana, South Dakota, and
Maryland. The report contains the overall ranking of only the top 25 states.
California was not in the top 25.
The report was written by Kent Lassman of the PFF.
|GAO Reports on Federal Agency Transfer of Intellectual
|11/1. The General Accounting Office (GAO)
released a report [102
pages in PDF] titled "Intellectual Property: Federal Agency Efforts in
Transferring and Reporting New Technology".
The 1980 Bayh Dole Act and the Technology Transfer Commercialization Act of
2000 (TTCA) require that the GAO issue a report to Congress on the
implementation of these acts at least every 5 years. (The Bayh Dole Act was
titled the "The Patent and Trademark Law Amendments Act"; it is Public Law No.
96-517; it is codified at
§ 200, et seq. The TTCA was
HR 209 in
the 106th Congress; it is Public Law No. 106-404.)
The Bayh Dole Act provides that inventions created under
government contracts and grants may become the property of the contractors and
grantees. The TTCA pertains to the licensing of inventions created in federal
facilities. It requires, among other things, that federal agencies with
laboratories and technology transfer functions to provide the
Management and Budget (OMB) with reports on their technology transfer programs.
This GAO report provides "information on how federal agencies had identified,
patented, and licensed inventions created in their own facilities during fiscal
years 1997-2001." It addresses "(1) the extent to which the agencies complied
with the [TTCA] requirement to submit
reports on their technology transfer activities to OMB and the Department of
Commerce at the time they submit their fiscal
year 2003 budget requests and (2) what the agencies have done -- since the
issuance of our 1999 report on the issue -- to improve compliance with reporting
requirements under the Bayh Dole Act for inventions created under contracts and
grants." (Brackets inserted by TLJ.)
This report states that "These acts generally have been
considered a success, because the federal agencies and their funding recipients
now can profit from their inventions and thus have a greater incentive to
produce new technology. In addition, the technology created is more likely to be
made available to those who can use it."
The report found that "Federal agencies did not fully comply with the
requirement of the [TTCA] that they submit reports on their technology
transfer activities to the [OMB] and the Department of
Commerce ..." (Brackets added.) Moreover, it found that contractors and
grantees are not complying with their reporting obligations under the Bayh Dole
The report was prepared for Sen.
Patrick Leahy (D-VT) and Sen. Orrin Hatch (R-UT), the Chairman and ranking
Republican on the Senate Judiciary Committee, Sen. Ron Wyden (D-OR) and Sen.
George Allen (R-VA), the Chairman and ranking Republican on the Senate Commerce
Committee's Subcommittee on Subcommittee on Science, Technology, and Space, Rep.
Howard Coble (R-NC) and Rep. Howard Berman (D-CA), the Chairman and ranking
Democrat on the House Judiciary Committee's Subcommittee on Courts, the
Internet, and Intellectual Property, and Rep. Vernon Ehlers (R-MI) and Rep. James Barcia
(D-MI), the Chairman and ranking Democrat on the House Science Committee's Subcommittee on
the Environment, Technology, and Standards. The report was signed by John Stephenson, Director, Natural Resources and Environment,
at the GAO.
There is also another GAO
pages in PDF] titled "Intellectual Property: Industry and Agency Concerns Over
Intellectual Property Rights". It was prepared as testimony for a hearing of the
House Government Reform Committee's
Subcommittee on Technology and Procurement Policy on May 10, 2002. It too took
the position that "the framework for
promoting and protecting intellectual property rights in the government has been
considered a success." However, others at the hearing said otherwise.
Rep. Tom Davis (R-VA), who
presided at the hearing, said in his
opening statement that most leading information technology companies refuse
to do research for the government because of intellectual property and red tape
He stated in his prepared testimony that "In an environment where private
sector R&D spending accounts for almost three fourths of the total spent in the
United States, the Government's role has changed to become a partner in
innovation, rather than the sole driving force. Because IP right are the most
valued assets of companies, the Government must ensure that its policies and
procedures reflect this partnership for innovation."
Richard Carroll, of the Small Business Technology Coalition, said in his
prepared testimony that the prevailing attitude of the government is "We
paid for it. We own it." Carroll said that "for small high tech companies in
particular, the government culture of ``we pay for it, we own it´´ has a
chilling effect on their interest in innovating for the government. Understand,
that these companies are the most likely to bring forth the innovations needed
to transform our defense systems, and to meet the needs of homeland defense with
rapid, innovative, and affordable solutions. These new ideas represent the heart
of their company's assets, and their ability to offer strong competitive
alternatives to the status quo is clearly predicated on some level of
intellectual property protection. If they lose that intellectual property
because the government provides it to their competitors, the very survival of
the company is threatened." See, list of witnesses,
with links to prepared testimony.
|Supreme Court News
|11/4. The Supreme Court of the U.S. returned from a two week recess. It
issued three opinions. None were technology related. All three were on writ of
certiorari to the U.S. Court of Appeals (9thCir). The Supreme Court reversed the
Ninth Circuit in all cases.
The Supreme Court granted certiorari in Illinois v. Telemarketing Associates,
No. 01-1806, a case involving regulation of charity telemarketing. See,
List [13 pages in PDF] at page 2. The Supreme Court denied certiorari in Sprint v. William Gagnon, a race
discrimination case. See,
List [13 pages in PDF] at page 3.
The Court also announced that it will take a recess from Monday, November 18,
2002, until Monday, December 2, 2002.
|Tuesday, November 5
|9:30 AM. The U.S. Court of Appeals
(DCCir) will hear oral argument in 21st Century Telesis v. FCC, No.
01-1435. Judges Randolph, Rogers and Williams will preside. Location:
Courtroom 20, 333 Constitution Ave., NW.
Deadline to submit applications to the Agriculture Department's
Rural Utilities Service for grants
under its pilot program for the provision of broadband transmission service in
rural America for fiscal year 2002. See,
notice in the
|Wednesday, November 6
|9:00 AM. FTC
Commissioner Orson Swindle will give a speech titled "Promoting a Culture of
Security" at a Cross Sectoral Industry Association meeting regarding
the role of business in promoting a culture of security. At 11:15 AM, Swindle,
Thomas Niles (U.S. Council for International
Business), Joseph Alhadeff (VP/CPO of
Oracle), Sandra Wilson (OECD) will hold
a media briefing. RSVP is required for media briefing. See,
contact: Jonathon Huneke (USCIB) at 212 703-5043 or
Morrison & Foerster, 2000
Pennsylvania Ave., NW, Suite 5500.
9:30 - 11:30 AM and 2:00 - 4:00 PM. The
Antitrust Division will hold the final
workshops in their joint series titled "Competition and Intellectual Property
Law and Policy in the Knowledge Based Economy" on October 25 and 30 and
November 6. The November 6 event is titled "Antitrust Law and Patent
Landscapes". The 9:30 AM program is titled "Standard Setting Organizations:
Evaluating the Anticompetitive Risks Of Negotiating IP Licensing Terms and
Conditions Before A Standard Is Set". The 2:00 PM program is titled
"Relationships Among Competitors and Incentives to Compete: Cross Licensing of
Patent Portfolios, Grantbacks, Reach Through Royalties, and Non- Assertion
Clauses". Location: FTC Room 432, 600 Pennsylvania Ave., NW.
10:00 - 11:30 AM. Media Security
and Reliability Council (MSRC) will hold a meeting.
Chairman Michael Powell
will participate. The MSRC is a federal advisory committee formed after the
terrorist attacks of September 11, 2001, to study ways to secure and maintain
broadcast and multichannel video programming distribution (MVPD) in the face
of terrorist attacks, natural disasters and other threats. See,
FCC release [PDF]. Location: FCC, Commission Meeting Room (TW-C305), 445
12th Street, SW.
12:15 PM. The
FCBA's Global Telecommunications Development Committee and International
Practice Committee will host an event titled "What Happened in Marrakesh? A
Debriefing on the 2002 ITU Plenipot". The speakers will be David Gross,
Coordinator of International Communications and Information Policy at the
State Department. RSVP to jhindin @wrf.com.
Location: Wiley Rein & Fielding, 1750 K St,
|Thursday, November 7
|The Senate will meet at 10:30 AM in pro forma session only.
Day one of a two day conference hosted by the American Bar Association's Section of
Antitrust Law. See, program.
The basic price to attend is $875.
Location: National Press Club, 529 14th St NW.
9:30 AM. The FCC will hold a meeting. The agenda includes a number of
spectrum related items. The
Spectrum Policy Task Force will report on its findings and recommendations.
The FCC's International Bureau will report
on the outcome of the International Telecommunication Union Plenipotentiary
Conference. The FCC will consider a Second Report and Order that would
allocate spectrum in the 1.7 and 2.1 GHz bands that can be used to provide
advanced wireless services (AWS), such as 3G or IMT-2000. The FCC will
consider a Notice of Proposed Rulemaking (NPRM) concerning service rules for (AWS)
in the 1.7 GHz and 2.1 GHz bands. And, the FCC will consider a NPRM and Order
concerning allocation and service rules for the Dedicated Short Range
Communication Services in the 5.850-5.925 GHz band. Location: FCC, 445 12th Street, SW,
Room TW-C05 (Commission Meeting Room).
RESCHEDULED FOR DECEMBER 2.
10:00 AM. The U.S. Court of Appeals (FedCir)
will hear oral argument in Altiris v. Symantec, No. 02-1137. This is a
patent infringement case involving technology for remotely controlling the
boot process of a computer.
Location: 717 Madison Place, NW.
|Friday, November 8
|The Senate will meet at 10:30 AM in pro forma session only.
Day two of a two day conference hosted by the American Bar Association's Section of
Antitrust Law. See, program.
The basic price to attend is $875. Location: National Press Club, 529 14th St NW.
8:30 - 10:00 AM. The American Enterprise
Institute (AEI) will host an event titled "Post Election Review of
Telecommunications Policy". The speakers will be former FCC Commissioner
Harold Furchtgott Roth and Greg Sidak. RSVP to Veronique Rodman at 202
862-4871 or vrodman @aei.org. Location:
AEI, 11th Floor, Conference Room, 1150 17th Street, NW.
9:00 AM - 4:45 PM. The FCC's Consumer / Disability
Telecommunications Advisory Committee will meet. Location: FCC, 445 12th
Street, SW, Room TW-C305 (Commission Meeting
9:30 AM. The U.S. Court of Appeals
(DCCir) will hear oral argument in AT&T v. FCC, No. 01-1511. Judges
Ginsburg, Edwards and Garland will preside. Location: 333 Constitution Ave., NW.
10:00 AM. The U.S. Court of Appeals (FedCir)
will hear oral argument in Cygnus Telecommunications Technology v.
Totalaxcess.com, No. 02-1325. This is a consolidated patent case appealed
from the U.S. District Court (NDCal). Location:
717 Madison Place, NW.
|Monday, November 11
|Veterans Day. The FCC will be closed.
Deadline to submit comments to the National Institute of
Standards and Technology (NIST) regarding its draft publication
[62 pages in PDF] titled "Guide to Selecting Information Technology
Security Products". This is NIST Special Publication 800-36 (draft). It was written by
Timothy Grance, Marissa Myers and Marc Stevens in the NIST's Information Technology Laboratory's
Computer Security Division.
Send comments to firstname.lastname@example.org.
Deadline to submit comments to the National
Institute of Standards and Technology (NIST) regarding its
publication [78 pages in PDF] titled "Guide to IT Security Services".
This is NIST Special Publication 800-35 (draft). It was written by
Tim Grance, Joan Hash, Marc Stevens, Kristofor O’Neal, Nadya Bartol and Robert
Young in the NIST's Information Technology Laboratory's
Computer Security Division. Send comments to email@example.com.
Deadline to submit comments to the National Institute of
Standards and Technology (NIST) regarding its
[66 pages in PDF] titled "Security Considerations in Federal Information
Technology Procurements A Guide for Procurement Initiators, Contracting
Officers, and IT Security Officials". This is NIST Special Publication
800-4A (draft). It was written by Tim Grance, Joan Hash and Marc Stevens
in the NIST's Information Technology Laboratory's Computer Security Division.
Send comments to firstname.lastname@example.org.
|Tuesday, November 12
|TIME? Day one of a two day conference titled "W3C Workshop on the Future
of P3P". The topic is the the World Wide Web
Consortium's (W3C) Platform for Privacy
Preferences Project (P3P). The W3C has a web site for the event, but all
of the material information, such as a the agenda, participants, and papers,
is all either password protected, or not provided. Location: Dulles, Virginia
campus of America Online, Seriff Auditorium, Creative Center 2, America Online
Dulles campus; enter the campus at Creative Center 3 (CC3), 22110 Pacific
Blvd, Dulles, VA.
9:30 AM. The U.S. Court of Appeals
(DCCir) will hear oral argument in Z Tel Communications v. FCC, No.
01-1461. This is a challenge to the FCC's order approving Verizon's Section
271 application to provide in region interLATA service in the state of
Pennsylvania. Judges Ginsburg, Edwards and Garland will preside. Location: 333
Constitution Ave., NW.
3:30 - 4:30 PM. The Heritage Foundation will host an address by
Rep. Jim Ryun (R-KS)
titled "Reforming Congress for a Safer Homeland: The Need for Congressional
Committee Reorganization". Location: 214 Massachusetts Ave., NE.
6:00 - 8:00 PM. The
FCBA will host a CLE seminar titled "FCC Winter Preview". The panelists
will include Donald Abelson (Chief of the FCC's International Bureau), Thomas
Sugrue (Chief of the FCC's Wireless Telecommunications Bureau), Kenneth Feree
(Chief of the FCC's Media Bureau), and William Maher (Chief of the FCC's
Wireline Competition Bureau), and Bryan Tramont (Senior Legal Advisor to FCC
Chairman Michael Powell). Location: Sidley
Austin Brown & Wood, Conference room 6-E.
|6th Circuit Rules on Insurance Defense and Patent Suits
11/4/ The U.S.
Court of Appeals (6thCir) issued its split
National v. SST Fitness, a case regarding an insurer's
ability to recoup money paid for the defense of an insured in a patent and
trademark infringement case, under reservation that there is no duty top defend,
when the insured later obtaineds a declaratory judgment that there is no duty to
defend or indemnify. Applying Ohio principles of contract law, the Appeals Court
held that the insurer may recover.
SST Fitness Corporation (SST) purchased
liability insurance from United National
Insurance Company (United National), which agreed to provide defense costs
and indemnify SST. In another action, Precise Exercise
Equipment filed a complaint against SST alleging patent and trademark
infringement and other claims. United National paid SST's defense costs, but
first wrote a letter to SST in which it stated that it "reserves the right to
recoup from SST any defense costs and fees to be paid subject to this
reservation letter on the basis that no duty to defend now exists or has existed
with regard to the tendered suit." SST accepted payment of its defense costs
without objecting to the reservation.
United National then filed a complaint against
SST seeking a declaratory judgment that United National owed no duty to defend
or indemnify SST in the patent infringement action. The District Court granted
declaratory judgment to United National. The U.S. Court of Appeals (6thCir)
affirmed. See, June 29, 1999
United National then sought to recover the amounts that it had paid for the defense
of SST under reservation. The District Court denied this motion. The Appeals
Court reversed. United National gets its money back.
|3rd Circuit Rules on Bankruptcy
Jurisdiction in Learnout & Hauspie Case
11/4. The U.S.
Court of Appeals (3rdCir) issued its
Partners v. Learnout & Hauspie,
a bankruptcy jurisdiction case.
Learnout & Hauspie (LH) is a speech recognition software company that
is incorporated and headquartered in Belgium. Stonington Partners is
an ERISA fiduciary that manages institutional capital on behalf of public and
private entities, including pension funds, private endowments, and financial
institutions. It purchased Dictaphone Corporation in 1995, and sold it to LH in
Stonington filed an action in Delaware Chancery Court against LH
and several former officers and directors alleging that LH bought Dictaphone
with worthless LH stock, and that LH procured Dictaphone by fraud.
LH then filed a bankruptcy petition in the U.S. Bankruptcy Court (DDel). The
next day it filed an insolvency proceeding in the nation of Belgium.
Stonington filed claims in both insolvency proceedings. It sought to pursue
its Dictaphone claim in the Belgium court, where it would receive more favorable
treatment. LH argued that the Delaware
Bankruptcy Court has exclusive jurisdiction. The Bankruptcy and District Court
ruled in favor of LH.
The Court of Appeals reversed and remanded. It wrote that "We conclude that
the order preventing Stonington from pursuing the issue of the priority,
treatment, and classification of its claims in the Belgian proceedings and
ordering that these issues be determined exclusively by the Delaware Bankruptcy
Court in accordance with the Bankruptcy Code was issued without consideration of
all relevant legal principles. Accordingly, we will reverse and remand for
further proceedings consistent with this opinion."
|This edition of the TLJ Daily E-Mail Alert is laid out in
two columns, rather than the usual three. TLJ requests comments
from readers regarding whether two or three columns is a better
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