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January 19, 2005, 9:00 AM ET, Alert No. 1,059.
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Supreme Court Denies Certiorari in American Axle v. Dana

1/18. The Supreme Court denied certiorari in American Axle v. Dana, a patent case involving vehicle driveshafts. What is significant about this Supreme Court proceeding is that Google and eBay sought unsuccessfully to use this proceeding to obtain a Supreme Court ruling on procedure in patent litigation. The Supreme Court granted their motion to file an amicus curiae brief, but did not heed their recommendations. See, Order List [10 pages in PDF], at page 6.

Google and eBay do not care about vehicle driveshaft technology, American Axle and Manufacturing or Dana Corporation, or the patents in suit, U.S. Patent Nos. 5,643,093 and 5,637,042.

Rather, Google and eBay argued that the U.S. Court of Appeals (FedCir) should not have engaged in a de novo review of factual issues underlying the trial court's claim construction. They argued that this practice amounts to retrying cases, and that this results in longer uncertainty in the marketplace.

The two companies wrote in their amicus brief [17 pages in PDF] that "One of the primary functions of patents is to provide public notice of the exclusive rights of the patentee. This Court has reiterated that, for a patent to serve this public notice function, entities in the marketplace must have a significant degree of certainty in the construction of patent claims. Yet, the Federal Circuit’s de novo review of factual issues underlying a district court’s claim construction undermines certainty by giving rise to an untenably high reversal rate. Because the district court’s claim construction is not given the proper weight, patent litigants can treat the Federal Circuit as a court of first instance, thereby encouraging prolonged and wasteful litigation rather than innovation. The Federal Circuit’s failure to give greater deference to the district court’s underlying findings of fact is an outlier in the law, and it is therefore necessary for this Court to review the Federal Circuit’s rule of de novo review of all aspects of patent claim construction."

The amicus brief elaborated that "the establishment of the Court of Appeals for the Federal Circuit may have improved intrajurisdictional uniformity", but its practice of giving "no deference to district court claim constructions has given rise to a new, and equally dangerous, form of uncertainty. Because the Federal Circuit regularly substitutes its own view of the evidence underlying claim construction for the determination made in the district court, it reverses claim construction rulings at a rate of over 33%, far higher than the reversal rate of any circuit court in the country and higher than the Federal Circuit reversal rate on any other issue." The brief added that "the problem is getting worse, not better. Recent data show that the Markman reversal rate is increasing with time."

"The result is that in virtually every patent case -- at least every one that turns upon claim construction—any dissatisfied litigant can treat the Federal Circuit almost as a court of first instance. Instead of setting forth the parameters of the case, and thereby providing a measure by which the parties can evaluate the merits of their case, the district court’s Markman ruling has become little more than a ``first take´´ on claim construction."

"In short," Google and eBay concluded, "with the current standard of review, all incentives point to more patent litigation and less resolution based on the merits of patent infringement claims and the inventions underlying them. The promotion of ``the Progress of Science and useful Arts´´ is subordinated to the tactics and costs of patent litigation."

Perhaps it is also notable that the original District Court action was filed in 1998. Moreover, Dana Corporation regularly writes in its 10-Q statements filed with the Securities and Exchange Commission (SEC) that "We are involved in various legal proceedings incidental to our business" and "the outcome of these matters cannot be predicted with certainty ..."

The amicus brief of Google and eBay was written by Mark Lemley, a professor at Stanford University Law School, and Of Counsel at the law firm of Keker & Van Nest.

See also, February 12, 2002 opinion of the U.S. Court of Appeals (FedCir), which is also reported at 279 F.3d 1609. The Federal Circuit's August 2004 opinion is not precedential, and not in the Federal Circuit's web site.

This case is American Axle & Manufacturing, Inc. v. Dana Corporation, Sup. Ct. No. 04-717, a petition for writ of certiorari to the U.S. Court of Appeals for the Federal Circuit, App. Ct. No. 01-1008. The Court of Appeals case is an appeal from the U.S. District Court for the Eastern District of Michigan, D.C. No. 98-74521.

NCTA Files Brief with Supreme Court in Brand X Case

1/18. The National Cable & Telecommunications Association (NCTA), and several cable companies, filed a brief [50 pages in PDF] with the Supreme Court in NCTA v. Brand X, a case regarding the regulatory classification of cable modem service. The Federal Communications Commission (FCC), which also sought review of the Court of Appeals opinion, wants internet access via cable to be treated as an information service, which carries less regulatory burdens, rather than as telecommunications. The NCTA brief emphasizes Chevron deference.

On March 14, 2002, the FCC adopted a Declaratory Ruling and Notice of Proposed Rulemaking [75 pages in PDF]. The Declaratory Ruling (DR) component of this item states that "we conclude that cable modem service, as it is currently offered, is properly classified as an interstate information service, not as a cable service, and that there is no separate offering of telecommunications service." This item is FCC 02-77 in Docket No. 00-185 and Docket No. 02-52.

On October 6, 2003, a three judge panel of the U.S. Court of Appeals (9thCir) issued its opinion [39 pages in PDF], which is also published at 345 F.3d 1120, vacating the FCC's declaratory ruling. See, story titled "9th Circuit Vacates FCC Declaratory Ruling That Cable Modem Service is an Information Service Without a Separate Offering of a Telecommunications Service" in TLJ Daily E-Mail Alert No. 754, October 7, 2003; and story titled "Reaction to 9th Circuit Opinion in Brand X Internet Services v. FCC" in TLJ Daily E-Mail Alert No. 756, October 9, 2003.

On December 3, 2004, the Supreme Court granted certiorari. See, story titled "Supreme Court Grants Certiorari in Brand X Case" in TLJ Daily E-Mail Alert No. 1,030, December 3, 2004.

The NCTA brief argues that the Court of Appeals, in vacating the FCC's declaratory ruling, failed to give Chevron deference to the FCC's ruling.

The Supreme Court wrote in Chevron that "When a court reviews an agency's construction of the statute which it administers, it is confronted with two questions. First, always, is the question whether Congress has directly spoken to the precise question at issue. If the intent of Congress is clear, that is the end of the matter; for the court as well as the agency, must give effect to the unambiguously expressed intent of Congress. If, however, the court determines Congress has not directly addressed the precise question at issue, the court does not simply impose its own construction on the statute, as would be necessary in the absence of an administrative interpretation. Rather, if the statute is silent or ambiguous with respect to the specific issue, the question for the court is whether the agency's answer is based on a permissible construction of the statute. ... We have long recognized that considerable weight should be accorded to an executive department's construction of a statutory scheme it is entrusted to administer ..." (Footnotes omitted.) See, Chevron U.S.A., Inc. v. Natural Resources Defense Council, 467 U.S. 837 (1984).

On June 4, 1999, the U.S. District Court (DOr) issued its opinion in AT&T v. Portland, a case to which the FCC was not a party, holding that the City of Portland has the authority to condition the transfer of control of TCI's cable licenses on AT&T's opening of its internet cable facilities to competing ISPs. AT&T appealed. On June 22, 2000, the Court of Appeals (9thCir) issued its opinion reversing the District Court. It reasoned that cable modem service is a telecommunications service, and hence, cannot be regulated by local franchising authorities.

Then, when the Court of Appeals issued its opinion in the Brand X case, it determined that it was bound by its holding in the Portland case, under the doctrine of stare decisis. The Court of Appeals did not apply Chevron deference. In addition, any other circuit would not have been bound by the 9th Circuit's Portland opinion. And, the 9th Circuit only heard this case because it won the multi-circuit lottery after multiple petitions for review and appeals had been filed.

The NCTA brief argues that the FCC's declaratory ruling "is the best reading of the statute and certainly constitutes a permissible interpretation. It must therefore be upheld under the Chevron doctrine, and the judgment of the court of appeals must be reversed."

It continues that "To reach that result, the Court need not resolve the stare decisis issue that kept the court of appeals from extending Chevron deference to the FCC’s regulatory classification -- although, as we explained in our petition for a writ of certiorari, this case does provide an opportunity to address that issue. If the Court reaches the stare decisis issue, it should state that the court of appeals erred. Chevron rests on the premise that statutory silence or ambiguity reflects an implicit delegation of legislative authority. Thus, stare decisis no more precludes a court from deferring to a reasonable administrative interpretation of a statute committed to an agency's administration than it precludes a court from obeying subsequent statutory amendments."

The present brief was filed on behalf of the the NCTA, Charter Communications, Inc., Cox Communications, Inc., Time Warner Inc., and Time Warner Cable Inc.

DOJ Antitrust Chief Suggest Topics for Study

1/5. Hewitt Pate, Assistant Attorney General in charge of the Department of Justice's (DOJ) Antitrust Division, submitted a comment to the Antitrust Modernization Commission (AMC) in which he suggested topics that the AMC might study. This was one of many comments received by the AMC.

Hewitt PatePate (at right) made a number of recommendations that largely reflect proposals that he or other DOJ officials have made in the past in speeches, papers and prepared testimony.

He suggested in this comment that the AMC might conduct empirical studies of the benefits of antitrust enforcement. He wrote that "Some antitrust commentators contend that there is no empirical foundation for the conviction that antitrust enforcement benefits consumers and the economy". Robert Crandall at Brookings, who has studied antitrust and telecommunications, is one scholar who has made this assertion. Pate suggests that the AMC come up with some evidence to support what the Antitrust Division does.

The Cato Institute also submitted a comment [PDF]. It wrote that "There is a good case to be made that ... the antitrust laws therefore should be scrapped entirely."

Pate also suggested that the AMC study antitrust immunities and exemptions for various industries, as well as the state action doctrine, which exempts state created impediments to competition. The DOJ disfavors exemptions that place entities beyond its regulatory reach.

Pate also suggested that the AMC study state enforcement of federal antitrust laws, civil fines for federal government Sherman Act cases, the availability of treble damages in non-cartel Sherman Act cases, the ability of indirect purchasers to recover damages, the fundamental prohibitions of the Sherman Act, and other topics.

The AMC has also received recommendations from other persons and entities. See especially, comment [PDF] from Sen. Mike DeWine (R-OH) and Sen. Herb Kohl (D-WI), the Chairman and ranking Democrat on the Senate Judiciary Committee's Antitrust Subcommittee.

Sun Microsystems submitted a comment [PDF] in which it suggested that the AMC "should undertake to study whether antitrust law and policy should require standards-setting organizations ("SSOs") to adopt procedures and intellectual property rights ("IPR") policies that require disclosure -- of the intellectual property to be incorporated in a proposed standard and relevant license terms -- early in the standard development process and prior to voting on the standard in question (ex ante adoption). Consideration should also be given to permitting standards development working groups to discuss these matters so that informed decisions can be made on the desirability of incorporating IPRs in the design of the standard." (Footnotes omitted. Parentheses in original.)

The U.S. Telecom Association submitted a comment [PDF] suggesting that the AMC study "the proper role of the states in antitrust enforcement". It suggests limiting certain state authority.

The Association for Competitive Technology submitted a comment [PDF] in which it stated that antitrust is undermining intellectual property rights. It stated that "competitors and some regulators have recently sought to use antitrust suits to force IPR holders to give up control over their protected works, as in the recent Microsoft case where several state Attorneys General proposed that Microsoft be forced to publicly provide the source code to Internet Explorer free of charge. Similarly, European regulators have shown increasing willingness to subject protected works to a compulsory license regime because of alleged competition concerns. The precedents created by these intellectual property seizures will undercut intellectual property rules for ALL successful companies and reduce incentives for research and innovation in the future."

Similarly, the U.S. Chamber of Commerce submitted a comment [PDF] in which it stated that "Holders of intellectual property rights should be free to exploit those rights within their defined scope. Ownership of a patent or copyright should be viewed in the same manner as ownership of any other asset or group of assets, and should not be presumed to confer monopoly power in a relevant antitrust market."

See also, AMC web page containing hyperlinks to comments.

More News

1/18. The Supreme Court announced that it "will take a recess from Monday, January 24, 2005, until Tuesday, February 22, 2005." See, Order List [10 pages in PDF].

1/18. The Department of Commerce's (DOC) Technology Administration (TA) announced that April 26, 2005 is the deadline to submit nominations for the 2006 National Medal of Technology awards. See, TA notice. For more information, contact Mildred Porter at 202 482-5572 or

1/18. The U.S. Department of Agriculture's (USDA) Rural Utilities Service (RUS) published a notice in the Federal Register that announces FY 2005 funding levels for its Distance Learning and Telemedicine (DLT) grant, combination loan-grant and loan programs, and that reminds applicants that the deadline to submit applications is February 1, 2005. See, Federal Register, January 18, 2005, Vol. 70, No. 11, at Pages 2844 - 2849.

1/14. The U.S. Court of Appeals (DCCir) issued its opinion [PDF] in AT&T v. FCC, a case regarding a Federal Communications Commission (FCC) order interpreting AT&T’s tariff on resales of 800 telephone service. AT&T petitioned for review, and the Court of Appeals granted the petition. This case is AT&T v. FCC, a petition for review of a final order of the FCC, No. 04-1431. Judge Roberts wrote the opinion of the Court, in which Judges Tatel and Ginsburg joined.

The mail servers of some subscribers of the TLJ Daily E-Mail Alert blocked delivery of yesterday's issue. Hence, it has been published in the Tech Law Journal web site. See, TLJ Daily E-Mail Alert No. 1,058.
Washington Tech Calendar
New items are highlighted in red.
Wednesday, January 19

The House will not meet. It will next meet on January 20, 2005. See, Republican Whip Notice.

The Senate will not meet. It will next meet on January 20, 2005.

8:30 AM - 12:00 NOON. The National Institute of Standards and Technology (NIST) will host a meeting to discuss the policy, privacy, and security issues associated with Homeland Security Presidential Directive-12, titled "Common Identification Standard for Federal Employees and Contractors". See, agenda [PDF]. The event is free and open to the public. However, January 11 is the deadline to register. Contact Sara Caswell at or 301 975-4634. Location: auditorium, Potomac Center Plaza, 550 12th Street, SW (near the Smithsonian and L’Enfant Plaza metro stations).

9:00 AM. The Senate Foreign Relations Committee will hold a hearing on the nomination of Condi Rice to be Secretary of State. Location: Room 216, Hart Building.

9:30 AM. The Senate Judiciary Committee will hold an executive business meeting. It will consider the nomination of Alberto Gonzales to be Attorney General. Sen. Arlen Specter (R-PA) will preside. See, notice. Location: Room 226, Dirksen Building.

9:30 AM - 5:00 PM. The North American Numbering Council (NANC) will meet. See, FCC notice [PDF] and notice in the Federal Register, December 3, 2004, Vol. 69, No. 232, at Page 70259. Location: FCC, Room TWC305, 445 12th, SW.

9:30 AM - 12:30 PM. The Federal Information Systems Security Educators' Association (FISSEA) will host a workshop on NIST Special Publication 800-16, titled "Information Technology Security Training Requirements: A Role- and Performance-Based Model". See, Part 1 [845 KB in PDF], Part 2 [96 KB in PDF], and Part 3 [374 KB in PDF]. Preregistration is required. See, notice. Location: National Institute of Standards and Technology (NIST), North Building.

POSTPONED. 12:00 NOON. The Federal Communications Bar Association's (FCBA) Common Carrier Practice Committee will host a brown bag lunch. The topic will be the FCC's Remand Order on unbundled network elements. The speakers will include Tom Hughes (SBC) and Praveen Goyal (Covad Communications). RSVP to by Friday, January 7. Location: Hogan & Hartson, Moot Courtroom, 555 13th St., NW. The FCBA has not yet rescheduled this event.

2:00 PM. The Senate Finance Committee will hold a hearing on the nomination of Michael Leavitt to be Secretary of Health and Human Services. Location: Room 215, Dirksen Building.

2:00 - 4:00 PM. The Department of State's International Telecommunication Advisory Committee (ITAC) will meet to prepare for the International Telecommunications Union's (ITU) Telecommunication Standardization Advisory Group (TSAG) meeting. See, the ITU's calendar of meetings. See, notice in the Federal Register, December 20, 2004, Vol. 69, No. 243, at Page 76027. For more information, including the location, contact Julian Minard at Location: undisclosed.

2:00 PM. The Software and Information Industry Association (SIIA) will host an event titled "Improving the Ed Tech RFP: What Works and What Doesn't". See, notice. The price to participate is $40 for non-members of the SIIA. This event will be webcast and telecast only.

2:30 PM. The Senate Energy and Natural Resources Committee will hold a hearing on the nomination of Samuel Bodman to be Secretary of Energy. Location: Room 366, Dirksen Building.

4:00 - 5:00 PM. The President's National Security Telecommunications Advisory Committee (NSTAC) will meet via conference call. The NSTAC addresses issues and problems related to implementing national security and emergency preparedness communications policy. This meeting is closed to the public. See, notice in the Federal Register, January 4, 2005, Vol. 70, No. 2, at Page 370.

6:30 PM. Federal Communications Bar Association's (FCBA) Young Lawyers Committee will host an event titled "Happy Hour". For more information, contact Jason Friedrich at or 202 354-1340, or Ryan Wallach at or 202 303-1159. Location: Porter's, 1207 19th St., NW.

Thursday, January 20

The House will meet at 10:00 AM. No votes are expected. See, Republican Whip Notice.

The Senate will meet at 3:00 PM. It will begin with a period for morning business, and then proceed to consideration of cabinet nominees. See, Senate calendar. See also, Congressional Inaugural Committee web site.

Inauguration Day. This is not a federal holiday listed in the Office of Personnel Management's (OPM) list of federal holidays. The OPM states that "An employee who works in the District of Columbia, Montgomery or Prince George's Counties in Maryland, Arlington or Fairfax Counties in Virginia, or the cities of Alexandria or Falls Church in Virginia, and who is regularly scheduled to perform non-overtime work on Inauguration Day, is entitled to a holiday. There is no in-lieu-of holiday for employees who are not regularly scheduled to work on Inauguration Day."

The Copyright Office will be closed. The Federal Communications Commission (FCC) will be closed. See, FCC calendar [PDF]. The Department of Justice (DOJ) issued a memorandum stating that its Washington DC area employees may take the day off; however, it is silent on closure of DOJ offices.

Friday, January 21

9:30 AM. The U.S. District Court (DC) will hold a status conference in US v. Microsoft (D.C. No. 1998-cv-01232) and New York v. Microsoft (D.C. No. 1998-cv-01233) Judge Colleen Kotelly will preside. Location: Courtroom 11, Prettyman Courthouse, 333 Constitution Ave., NW.

Deadline to submit to the Federal Communications Commission (FCC) oppositions to petitions to deny the applications of NextWave Telecom and Cellco Partnership dba Verizon Wireless for FCC approval of their proposed transfer of control of broadband Personal Communications Services (PCS) licenses from NextWave to Cellco. See, FCC notice [4 pages in PDF]. This notice is DA 04-3873 in WT Docket No. 04-434.

EXTENDED TO JANUARY 28. Deadline to submit reply comments to the Federal Communications Commission (FCC) in response to the FCC's public notice regarding BellSouth's petition for forbearance from certain Title II and Computer Inquiry requirements. This proceeding is WC Docket No. 04-405. See, notice of extension [PDF].

Deadline for licensees to submit responses to the Federal Communications Commission (FCC) to its second audit letter and notice of cancellation to certain licensees in the paging and radiotelephone service and certain licensees operating on 929-930 MHz exclusive private carrier paging channels. See, notice in the Federal Register, December 21, 2004, Vol. 69, No. 244, at Pages 76469 - 76470.

Monday, January 24

The Supreme Court will begin a recess. It will return from recess on February 22, 2005.

Extended deadline to submit reply comments to the Federal Communications Commission (FCC) in response to its notice of proposed rulemaking (NPRM) regarding service rules for advanced wireless services (AWS) in the 1915-1920 MHz, 1995-2000 MHz, 2175-2180 MHz and 1.7 GHz and 2.1 GHz bands. The FCC adopted this NPRM at its September 9, 2004 meeting, and released the text on September 24, 2004. It is FCC 04-218 in WT Docket No. 04-356 and WT Docket No. 02-353. See, original notice in the Federal Register, November 2, 2004, Vol. 69, No. 211, at Pages 63489-63498, and extension notice in the Federal Register, November 30, 2004, Vol. 69, No. 229, at Pages 69572 - 69573. See also, story titled "FCC Makes Additional 20 MHz of Spectrum Available for Advanced Wireless Services" in TLJ Daily E-Mail Alert No. 975, September 13, 2004.

Tuesday, January 25

7:30 AM. The Information Technology Association of America (ITAA) will host a breakfast seminar titled "Expediting the Security Clearance Process: New Law, New Opportunities for Federal Contractors". See, ITAA notice. For more information, contact Shannon Zelsnack at Prices range from $50 to $95. Location: Sheraton Premiere Tysons Corner Hotel.

10:00 AM - 12:00 NOON. The Department of State's International Telecommunication Advisory Committee (ITAC) will meet to prepare for the Organization of American States' (OAS) Inter-American Telecommunication Commission's (CITEL) Permanent Consultative Committee II meeting in Guatemala to be held in April 2005. See, notice in the Federal Register, December 30, 2004, Vol. 69, No. 250, at Pages 78515-78516. For more information, including the location, contact Cecily Holiday at or Anne Jillson at Location: undisclosed.

12:15 PM. The Federal Communications Bar Association's (FCBA) Young Lawyers Committee will host a brown bag lunch. The topic will be "The Basics of IP-Television: Technology and Regulation". The speakers will be engineers from the Federal Communications Commission's (FCC) Media Bureau (MB), and representatives of SBC Communications and the National Cable & Telecommunications Association (NCTA). For more information, contact Jason Friedrich at or 202 354-1340 or Ryan Wallach at or 202 303-1159. Location: Willkie Farr & Gallagher, 1875 K Street, NW, Second Floor.

2:00 - 4:00 PM. The American Enterprise Institute (AEI) will host a panel discussion title "Class Action Reform: How Far and How Fast?". The speakers will be Robert Gasaway (Kirkland & Ellis), George Priest (Yale Law School), David McIntosh (Mayer Brown Rowe & Maw), and Michael Greve (AEI). See, notice. Location: AEI, 12th floor, 1150 17th St., NW.

TIME? The Judicial Conference of the United States (JC) will hold a public hearing on its proposed amendment to Appellate Rule 25 regarding electronic filings. The JC has proposed amendments to Civil Rule 5, Appellate Rule 25, and Bankruptcy Rule 5005. Each of these proposed amendments would permit the applicable court, by local rules, to "permit or require papers to be filed, signed, or verified by electronic means" (or similar language). Current rules provide that the applicable court may "permit" filing by electronic means. See, JC notice [PDF] and notice in the Federal Register, Federal Register, December 2, 2004, Vol. 69, No. 231, at Page 70156. Location: undisclosed.

Wednesday, January 26

The Federal Communications Commission (FCC) will hold a Broadband PCS Spectrum Auction. This is Auction No. 58. This auction had previously been scheduled for January 12, 2005. See, notice [3 pages in PDF].

8:00 AM. The Federal Communications Bar Association (FCBA) will host a breakfast with Rep. Chip Pickering (R-MS), Vice Chairman of the House Commerce Committee. For more information, contact at Location: J.W. Marriott Hotel, 1331 Pennsylvania Ave., NW.

9:30 AM. The Senate Judiciary Committee will meet. This meeting has been described as both a hearing on pending judicial nominations, and as an executive business meeting. See, Committee notice. Location: Room 226, Dirksen Building.

10:00 AM. The Senate Banking Committee will hold an organizational meeting. The Committee will consider its rules, subcommittee structure, and funding. Sen. Richard Shelby (R-AL) will preside. See, notice. Location: Room 538, Dirksen Building.

12:00 NOON - 1:30 PM. The DC Bar Association will host a brown bag lunch titled "International Aspects of Criminal Antitrust Enforcement". The speakers will be Lisa Phelan (Chief of the Department of Justice's Antitrust Division's National Criminal Enforcement Section) and Anthony Nanni (Fried Frank Harris Shriver & Jacobson). See, notice. Prices vary from $5 to $10. For more information, call 202 626-3463. Location: Fried Frank, 1001 Pennsylvania Ave., NW.

12:00 NOON - 1:30 PM. The DC Bar Association will host a brown bag lunch titled "I’m an IP attorney, how can I do pro bono work?". The speakers will be Mary Kennedy (Finnegan Henderson) and Maureen Syracuse (Director of the DC Bar Association's Pro Bono Program). See, notice. Prices vary from $5 to $10. For more information, contact Rebecca McNeill 202 408-4086 or Location: Finnegan Henderson, 901 New York Ave., NW.

4:00 - 5:45 PM. The American Enterprise Institute (AEI) will host a panel discussion title "Trade Policy: The Next Four Years". The speakers will be Lael Brainard (Brookings Institution), Edward Gresser (Progressive Policy Institute), Gary Hufbauer (Institute for International Economics), Brink Lindsey (Cato Institute), and Claude Barfield (AEI). See, notice. Location: AEI, 12th floor, 1150 17th St., NW.

6:00 - 8:15 PM. The Federal Communications Bar Association (FCBA) will host continuing legal education (CLE) seminar titled "An Overview of Contract Drafting". Location: Dow Lohnes & Albertson, 1200 New Hampshire Ave. NW.

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