4/4. The Supreme Court granted certiorari in Central Virginia Community College v. Katz. See, Order List [13 pages in PDF] at page 7.

The underlying dispute in this case does not involve technology. This is a bankruptcy case. This case involves the authority of the Congress, under the bankruptcy clause of the Constitution, to abrogate state sovereign immunity in the bankruptcy code. See, 11 U.S.C. § 106(a). Four state colleges run by the state of Virginia challenge the constitutionality of § 106, asserting state sovereign immunity, 11th Amendment immunity, and the 10th Amendment. The Bankruptcy Court and the Court of Appeals ruled against the state colleges. Now, the Supreme Court will review this question.

The argument advanced by the state colleges is similar to those made by the state of Florida when it successfully argued before the Supreme Court that the Patent and Plant Variety Protection Remedy Clarification Act is an unconstitutional abrogation of state's 11th Amendment immunity. Indeed, the state colleges cite the Florida cases in their Petition for Writ of Certiorari [45 pages in PDF].

Hence, persons interested in state sovereign immunity and 11th Amendment immunity in the context of intellectual property litigation, may wish to follow developments in this case.

Wallace's Bookstores operated bookstores on the campuses of the four state colleges. It declared bankruptcy in U.S. Bankruptcy Court (E.D.Kent). Bernard Katz is the liquidating supervisor of the bankrupt estate. He commenced an adversary proceeding, under the bankruptcy code, to recover preferential transfers made by Wallace's Bookstores to the four state colleges, and to collect accounts receivable owed by the four state colleges.

11 U.S.C. § 106(a) provides that "Notwithstanding an assertion of sovereign immunity, sovereign immunity is abrogated as to a governmental unit to the extent set forth in this section with respect to the following: ..." It then lists numerous sections of the bankruptcy code, including 11 U.S.C. § 547, which pertains to preferential transfers.

The four state colleges filed motions to dismiss the complaint, based upon sovereign immunity. They asserted that § 106(a) is unconstitutional. The Bankruptcy Court denied these motions.

The four colleges appealed. The Court of Appeals (6thCir) affirmed. The four colleges sought rehearing en banc. Not one judge voted to rehear the case. The four colleges petitioned the Supreme Court for writ of certiorari. The Supreme Court has granted certiorari.

The four colleges argue in their petition that there is a split among the circuits on Congressional authority to abrogate state sovereign immunity in the bankruptcy code. They assert that the 6th Circuit ruling is in conflict with the rulings of five other circuits.

The four colleges also relied heavily in their petition on the Supreme Court's opinions in Seminole Tribe v. Florida, 517 U.S. 44 (1996), which held that the Congress lacks authority under Article I of the Constitution to abrogate the States' 11th Amendment immunity from suit in federal courts, and in Florida Prepaid v. College Savings Bank, 527 U.S. 627 (1999), which extended the Seminole Tribe holding to intellectual property suits.

The present case is Central Virginia Community College, et al. v. Bernard Katz, Sup. Ct. No. 04-885, a petition for writ of certiorari to the U.S. Court of Appeals for the 6th Circuit. The U.S. Bankruptcy Court's case number is 01-50545. The Appeals Court's case number is No. 03-6054.

4/4. The Supreme Court denied certiorari Ergonome v. Compaq Computer, a copyright infringement case involving the defense of fair use, and the recovery of attorneys fees. See, Order List [13 pages in PDF] at page 8.

Ergonome, a small company owned by a couple, held the copyright on a short book on computer related hand injuries. Compaq, which sells personal computers, acquired a copy of the booklet, and copied from it, without authorization, in its own user guides.

Compaq filed a complaint against Ergonome in distant and inconvenient forum seeking a declaratory judgment that its copying did not constitute infringement. The jury found that Compaq's copying of seven phrases and four illustrations was de minimis. The District Court also awarded Compaq $2,765,026.90 in attorneys fees as the prevailing party.

Ergonome appealed. The U.S. Court of Appeals (5thCir), applying the four prong fair use test of 17 U.S.C. § 107, affirmed. It also affirmed the attorneys fees award. Judge Edith Jones wrote the opinion.

See also, story titled "5th Circuit Rules on Copyright, Fair Use, Attorneys Fees, and Alter Egos" in TLJ Daily E-Mail Alert No. 991, October 6, 2004.

This case is Ergonome, Inc. v. Compaq Computer Corporation, Sup. Ct. No. 04-1105, a petition for writ of certiorari to the U.S. Court of Appeals for the 5th Circuit. The Appeals Court case number is 01-20861. It was an appeal from the U.S. District Court for the Southern District of Texas.

4/4. The U.S. Court of Appeals (8thCir) issued its opinion [4 pages in PDF] in Faegre v. Purdy, a cybersquatting case. The Court of Appeals affirmed the District Court order granting a preliminary injunction to Faegre, the trademark holder.

William S. Purdy is an anti-abortion activist and serial cybersquatter who registers domain names that often contain well known trademarks, and then causes web surfers who enter these domains in their browsers to be redirected to an anti-abortion web site.

Faegre & Benson is a large law firm based in Minneapolis, Minnesota. It has registered a trademark for its name. Purdy registered domains such as www.faegre-benson.com. Purdy made no commercial use of this domain.

Faegre & Benson, and two of its partners, filed a complaint in U.S. District Court (DMinn) against Purdy alleging violation of the Anticybersquatting Consumer Protection Act (ACPA), which is codified at 15 U.S.C. § 1125(d), violation of the Lanham Act, 15 U.S.C. §§ 1114(a), 1125(a), violation of the Minnesota Deceptive Trade Practices Act, Minn. Stat. Ann. §325D.44, and violation of tort law of the state of Minnesota. The plaintiffs' complaint requested injunctive and declaratory relief, and damages. The plaintiffs also filed a motion for a temporary restraining order (TRO) and a preliminary injunction (PI).

The District Court issued an order [PDF] granting the TRO and PI.

The District Court enjoined Purdy from using domain names identical to or confusingly similar to Faegre's marks unless the protest or critical commentary nature of the attached website is apparent from the domain name itself, from using marks identical to or confusingly similar to Faegre's marks, from displaying any website whose appearance is identical or confusingly similar to the trade dress of Faegre's website, and from illegally appropriating Faegre names.

Purdy appealed. The Court of Appeals affirmed. It wrote a brief opinion that contains no application of the ACPA, Lanham Act, or other bodies of law to the facts of this case.

This case is Faegre & Benson, et al. v. William S. Purdy, et al., U.S. Court of Appeals for the 8th Circuit, App. Ct. No. 04-1189, an appeal from the U.S. District Court for the District of Minnesota, D.C. No. 03-6472, Judge Michael Davis presiding.

4/4. The U.S. Court of Appeals (9thCir) issued its opinion [18 pages in PDF] in Bosley Medical Institute v. Kremer, a cybersquatting case. The Court of Appeals affirmed in part the District Court's judgment for Kremer, the cybersquatter.

Michael Kremer received hair replacement services from Bosley Medical Institute. He was displeased. He then registered the domain name www.BosleyMedical.com and created a non-commercial web site that is critical of Bosley. Bosley has registered the trademark "Bosley Medical".

Bosley filed complaints in U.S. District Court (SDCal) against Kremer alleging trademark infringement, dilution, violation of the Anticybersquatting Consumer Protection Act (ACPA), unfair competition, various state law claims, and libel. Bosley dismissed the libel claim.

This case did not go to trial. Also, the District Court allowed only limited discovery. Rather, the District Court granted summary judgment to Kremer on the trademark infringement, trademark dilution, and ACPA claims, all on the grounds that Kremer did not make commercial use of the mark. The District Court also dismissed the state law claims under California's anti-SLAPP statute.

This appeal followed.

The Court of Appeals affirmed the summary judgment on the trademark infringement claim. It held that "the noncommercial use of a trademark as the domain name of a website -- the subject of which is consumer commentary about the products and services represented by the mark -- does not constitute infringement under the Lanham Act."

The Court of Appeals reasoned that no one will buy hair replacement services from Kremer thinking that he is Bosley. It concluded that "Neither is Kremer capitalizing on the good will Bosley has created in its mark. Any harm to Bosley arises not from a competitor's sale of a similar product under Bosley's mark, but from Kremer’s criticism of their services. Bosley cannot use the Lanham Act either as a shield from Kremer’s criticism, or as a sword to shut Kremer up."

However, the Court of Appeals vacated and remanded the summary judgment for Kremer on the ACPA claim. It held that the District Court erred in applying the commercial use requirement to Bosley's ACPA claim. It should have confined its inquiry to the elements of the ACPA claim listed in the statute, at 15 U.S.C. § 1125(d)(1)(B). The Court of Appeals held that the District Court should have inquired whether Kremer had a bad faith intent to profit from his use of Bosley's mark in his web site's domain name. This claim goes back to the District Court for discovery and further proceedings. Kremer may yet prevail on this issue too.

Finally, the Court of Appeals reversed the dismissal of the state law claims under the California anti-SLAPP statute. These claims are remanded to the District Court, for discovery, and further proceedings.

This case is Bosley Medical Institute v. Kremer, Inc., et al. v. Michael Steven Kremer, U.S. Court of Appeals for the 9th Circuit, App. Ct. No. 04-55962, an appeal from the U.S. District Court for the Southern District of California, D.C. No. CV-01-01752-WQH, Judge William Hayes presiding. Judge Barry Silverman wrote the opinion of the Court of Appeals, in which Judges Thomas Nelson and Richard Tallman joined.

4/4. The Supreme Court issued an order in Merck v. Integra LifeSciences I, a drug patent case involving a research exemption to patent infringement. The Supreme Court wrote that "The motion of the Acting Solicitor General for leave to participate in oral argument as amicus curiae and for divided argument is granted." See, Order List [13 pages in PDF] at page 6. This is Sup. Ct. No. 03-1237. See also, story titled "Supreme Court Takes Case Involving Research Exemption to Patent Infringement" in TLJ Daily E-Mail Alert No. 1,053, January 11, 2005.

4/4. The Supreme Court denied certiorari in Focus Media, Inc. v. NBC, Inc., No. 04-1107. See, Order List [13 pages in PDF] at page 12. This lets stand the August 2, 2004 opinion [23 pages in PDF] of the U.S. Court of Appeals (9thCir). This is an involuntary Chapter 7 bankruptcy case involving a company that booked and paid for commercial spots from television and radio stations on behalf of advertising clients. The Appeals Court affirmed the District Court. The Court of Appeals case number is 03-55808. This was an appeal from the U.S. District Court for the Central District of California, D.C. No. CV-01-01146-AHS.

4/4. The Supreme Court denied certiorari in Tony Colida v. Sanyo North America Corporation, No. 04-8644. This is a petition for writ of certiorari to the U.S. Court of Appeals (FedCir) in a patent case. See, Order List [13 pages in PDF] at page 10.

4/4. The Supreme Court issued two opinions, neither of which are technology related, and an Order List [13 pages in PDF]. It then began a two week recess. It will return on Monday, April 18.

Tech Law Journal publishes a free access web site and subscription e-mail alert. The basic rate for a subscription to the TLJ Daily E-Mail Alert is $250 per year. However, there are discounts for subscribers with multiple recipients. Free one month trial subscriptions are available. Also, free subscriptions are available for journalists, federal elected officials, and employees of the Congress, courts, and executive branch. The TLJ web site is free access. However, copies of the TLJ Daily E-Mail Alert are not published in the web site until one month after writing. See, subscription information page.

Contact: 202-364-8882.
P.O. Box 4851, Washington DC, 20008.

Privacy Policy
Notices & Disclaimers
Copyright 1998 - 2005 David Carney, dba Tech Law Journal. All rights reserved.

The House will return from its Spring Recess. It will meet at 2:00 PM for legislative business. It will consider several non-technology related items under suspension of the rules. Votes will be postponed until 6:30 PM. See, Republican Whip Notice.

The Senate will meet at 9:45 AM.

8:00 AM. Sen. Charles Grassley (R-IA), the Chairman of the Senate Finance Committee, will speak at the Tax Executives Institute's 55th Midyear Conference. Location: Grand Hyatt Washington Hotel, 1000 H Street NW.

LOCATION CHANGE. 9:30 AM. The Senate Judiciary Committee will hold a hearing titled "Oversight of the USA PATRIOT Act". The witnesses will be Attorney General Alberto Gonzales and FBI Director Robert Mueller. Sen. Arlen Specter (R-PA) will preside. See, notice. Press contact: Blain Rethmeier (Specter) at 202 224-5225, David Carle (Leahy) at 202 224-4242 or Tracy Schmaler (Leahy) at 202 224-2154. Location: Room 216, Hart Building.

10:00 AM. The Senate Finance Committee will hold a hearing titled "Charities and Charitable Giving: Proposals for Reform". Location: Room 628, Dirksen Building.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in VM Tech v. Compaq Computer, No. 04-1436. Location: Courtroom 402, 717 Madison Place, NW.

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 holidaycc@state.gov or Anne Jillson at jillsonad@state.gov. Location: undisclosed.

12:30 - 2:00 PM. The DC Bar Association will host a panel discussion titled "Regulating Computer and Telecommunications Exports to China". The scheduled speakers are Matthew Borman (Deputy Assistant Secretary of Commerce for Export Administration), James Lewis (Center for Strategic and International Studies), Vera Murray (Director of Export Regulation at IBM), Maggie Hershey (Semiconductor Equipment and Materials International), and Barry Hurewitz (Wilmer Cutler). See, notice. Prices vary from $10 to $30. For more information, call 202 626-3463. Location: D.C. Bar Conference Center, B-1 Level, 1250 H St., NW.

6:00 - 8:15 PM. The DC Bar Association will host a continuing legal education (CLE) program titled "Legal Beat: How to Use Music Legally in a Business". The scheduled speaker is Joy Butler (Sashay Communications). See, notice. Prices vary from $70 to $124. For more information, call 202 626-3488. Location: D.C. Bar Conference Center, B-1 Level, 1250 H St., NW.

The House will meet at 10:00 AM for legislative business. See, Republican Whip Notice.

The Department of Homeland Security's (DHS) Data Privacy and Integrity Advisory Committee will hold a day long meeting. Nuala Kelly (DHS Chief Privacy Officer ) will speak at 8:30 AM. The other speakers include Assistant Secretary Parney Albright, Acting Under Secretary Randy Beardsworth, Acting Under Secretary Matthew Broderick, Under Secretary Michael Brown, and Under Secretary Janet Hale. Location: Colonial Room, Mayflower Hotel, 1127 Connecticut Ave., NW.

9:00 AM - 1:00 PM. The Department of Commerce (DOC) will host a half day workshop on radio frequency identification (RFID) technology. See, DOC notice [PDF]. Location: DOC, 1401 Constitution Ave., NW.

10:00 AM. The House Judiciary Committee's Subcommittee on Courts, the Internet, and Intellectual Property will hold a hearing titled "Digital Music Interoperability and Availability". The witnesses will be Mark Cooper (CFA), Ray Gifford (PFF), William Pence (Napster), and Michael Bracy (Future of Music Coalition). Press contact: Jeff Lungren or Terry Shawn at 202 225-2492. See, notice. Location: Room 2141, Rayburn Building.

RESCHEDULED FOR APRIL 13. 10:00 AM. The Senate Finance Committee will hold a hearing on the U.S. Dominican Republic Central America Free Trade Agreement (CAFTA). Location: Room 628, Dirksen Building.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Network Commerce v. Microsoft, No. 04-1445. Location: Courtroom 402, 717 Madison Place, NW.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Hynix Semiconductor v. U.S., No. 04-1417. Location: Courtroom 402, 717 Madison Place, NW.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in In Re Steelbuilding.com, No. 04-1447. This is an appeal from the U.S. Patent and Trademark Office's (USPTO) Trademark Trial and Appeal Board 's (TTAB) disposition [28 pages in PDF] affirming the denial of an application to register the mark Steelbuilders.com. The TTAB held that it "is merely descriptive and generic for the services recited in the application and that applicant has not demonstrated that it has acquired distinctiveness". Location: Courtroom 203, 717 Madison Place, NW.

1:00 PM. The House Judiciary Committee will hold a hearing on the USA PATRIOT Act. The witness will be Attorney General Alberto Gonzales. Press contact: Jeff Lungren or Terry Shawn at 202 225-2492. Location: Room 2141, Rayburn Building.

1:30 PM. The House International Relations Committee' Subcommittee on the Western Hemisphere will hold a hearing titled "China's Influence in the Western Hemisphere". See, notice. Location: Room 2172, Rayburn Building.

The House will meet at 10:00 AM for legislative business. See, Republican Whip Notice.

9:30 AM. The House International Relations Committee will hold a hearing titled "Defense Trade: Arms Export Controls in the Post- 9/11 Security Environment". Location: Room 2172, Rayburn Building. 

9:30 AM. The Senate Judiciary Committee will hold an executive business meeting. The agenda includes consideration of several non-technology related bills, and consideration of several judicial nominees, including Terrence Boyle (to be a Judge of the U.S. Court of Appeals for the 4th Circuit), Priscilla Owen (5th Circuit), Robert Conrad (Western District of North Carolina), James Dever (Eastern District of North Carolina), and Thomas Griffith (District of Columbia Circuit). All of these nominees have been listed on past agendas. See, notice. Press contact: Blain Rethmeier (Specter) at 202 224-5225, David Carle (Leahy) at 202 224-4242 or Tracy Schmaler (Leahy) at 202 224-2154. Location: Room 226, Dirksen Building.

10:00 AM. The House Government Reform Committee will hold a hearing on the Federal Information Security Management Act. Location: Room 2154, Rayburn Building.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in AT&T v. Microsoft, No. 04-1285. This is an appeal from the U.S. District Court (SDNY) in a patent infringement case. Location: Courtroom 203, 717 Madison Place, NW.

12:00 NOON - 1:30 PM. The DC Bar Association will host a panel discussion titled "Current Topics in Patent Law: The CREATE ACT and the Impact on the Patent Practice". The scheduled speakers are Stephen Maebius (Foley & Lardner), Jeffrey Kushan (Sidley Austin), and Stephen Belisle (Fitzpatrick Cella Harper & Scinto). See, notice. Prices vary from $10 to $30. For more information, call 202 626-3463. Location: D.C. Bar Conference Center, B-1 Level, 1250 H St., NW.

12:15 - 2:00 PM. The Forum on Technology and Innovation will host a panel discussion titled "The Future of U.S. Manufacturing - Does Making Anything Matter in the 21st Century". See, notice and registration pages. Lunch will be served. Location: Reserve Officers Association, 5th floor, One Constitution Ave., NE.

2:30 PM. The Senate Judiciary Committee's Subcommittee on Intellectual Property will hold a hearing titled "The Patent System Today and Tomorrow". Sen. Orrin Hatch (R-UT) will preside. See, notice. Press contact: Blain Rethmeier (Specter) at 202 224-5225, David Carle (Leahy) at 202 224-4242 or Tracy Schmaler (Leahy) at 202 224-2154. Location: Room 226, Dirksen Building.

9:30 AM. The U.S. Court of Appeals (DCCir) will hear oral argument in Program Suppliers v. Librarian of Congress, No. 04-1070. Judges Sentelle, Randolph and Tatel will preside. Location: Prettyman Courthouse, 333 Constitution Ave., NW.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Korszun v. Public Technologies Multimedia, No. 04-1504. This is an appeal from the U.S. District Court (DConn) in a software patent case. Location: Courtroom 402, 717 Madison Place, NW.

12:00 NOON - 2:00 PM. The Progress and Freedom Foundation (PFF) will host a panel discussion titled "The Indecency Debate: Should Congress Extend Broadcast Rules to Other Media?". The speakers will include Adam Thierer (PFF), Marsha MacBride (National Association of Broadcasters), Jill Luckett (National Cable Telecommunications Association), and Jerald Fritz (Allbritton Communications). Press contact, Patrick Ross at 202 289-8928. See, notice and registration pages. Location: Room B389, Rayburn Building, Capitol Hill.

Deadline to submit initial comments to the Federal Communications Commission (FCC) in response to its notice of proposed rulemaking (NPRM) [460 pages in PDF] in its proceeding titled "In the Matter of: Implementation of the Satellite Home Viewer Extension and Reauthorization Act of 2004 Implementation of Section 340 of the Communications Act". See also, FCC release [PDF]. This NPRM is FCC 05-24 in MB Docket No. 05-49. The FCC adopted this NPRM on February 4, 2005, and released it on February 7, 2005. See, story titled "FCC Releases SHVERA NPRM Regarding Significantly Viewed Signals" in TLJ Daily E-Mail Alert No. 1,073, February 9, 2005.

Deadline to submit initial comments to the Federal Communications Commission (FCC) to assist it in preparing its annual report to the Congress regarding progress made to achieve the objectives and carry out the purposes and provisions of Open-Market Reorganization for the Betterment of International Telecommunications Act (ORBIT Act). See, FCC notice [PDF]. This proceeding is IB Docket No. 04-158.

9:30 AM. The U.S. Court of Appeals (DCCir) will hear oral argument in Northpoint Technologies v. FCC, No. 02-1194. Judges Sentelle, Rogers and Tatel will preside. Location: Prettyman Courthouse, 333 Constitution Ave., NW.

2:00 PM. The Senate Commerce Committee will hold a hearing S 241, a bill to exempt the Universal Service support taxes and subsidies from the Anti-deficiency Act. See, notice. Press contact: Melanie Alvord or Aaron Saunders (Stevens) at 202 224-8456 or 202 224-3991, or Andy Davis (Inouye) at 202 224-4546. Location: Room 385, Russell Building. (This is not the Committee's hearing room.)

6:00 - 8:15 PM. The Federal Communications Bar Association (FCBA) will host a continuing legal education (CLE) seminar titled "Must Carry/Retrans Consent". Location: Dow Lohnes & Albertson, 1200 New Hampshire Ave., NW.

Deadline to submit to the Federal Communications Commission (FCC) oppositions to petitions to deny Nextel's and Sprint's joint applications for FCC approval of the transfer of control to Sprint of the licenses and authorizations held both by Nextel. That is, this is a merger review proceeding. See, FCC Public Notice [7 pages in PDF], No. DA 05-502, in WT Docket No. 05-63. On December 15, 2004, the two companies announced a "definitive agreement for a merger of equals". See, Nextel release and release.

Deadline to submit reply comments to the Federal Communications Commission (FCC) in response to BellSouth's petition for pricing flexibility for switched access services. See, FCC Public Notice DA 05-740 in WC Docket No. 05-148.

9:30 AM. The House Appropriation's Committee's Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia will hold a hearing on the federal judiciary. See, notice. Location: Room 2358, Rayburn Building.

12:00 NOON. The Federal Communications Bar Association (FCBA) will host a luncheon. The speaker will be Rep. Joe Barton (R-TX), the Chairman of the House Commerce Committee. Prices vary from $35 to $65. See, registration form [PDF]. Registrations and cancellations are due by 5:00 PM on April 7. Location: Mayflower Hotel, 1127 Connecticut Ave., NW.

1:00 PM. The House Appropriation's Committee's Subcommittee on Transportation, Treasury, and Housing and Urban Development, The Judiciary, District of Columbia will hold a hearing on the Supreme Court. Supreme Court Justice Clarence Thomas will testify. See, notice. Location: Room 2358, Rayburn Building.

6:00 - 8:30 PM. The Federal Communications Bar Association's (FCBA) Young Lawyers Committee will host an event titled "Happy Hour". For more information, contact Pam Slipakoff at 202 418-7705 or pam.slipakoff@fcc.gov. Location: Andale, 401 7th Street, NW.

6:00 - 8:15 PM. The DC Bar Association will host a continuing legal education (CLE) seminar titled "What You Need to Know About the DMCA and Its Application". The scheduled speakers are Peter Jaszi (American University Law School), Robert Kasunic (U.S. Copyright Office), Stacey King (Finnegan Henderson), and Alan Lewine (Litman Law Offices). See, notice. Prices vary from $70 to $115. For more information, call 202 626-3488. Location: D.C. Bar Conference Center, B-1 Level, 1250 H St., NW.