4/12. The U.S. Court of Appeals (5thCir) issued its opinion [25 pages in PDF] in Keelan v. Majesco, an employment discrimination case brought by U.S. workers against a software company alleging discrimination on the basis of national origin. The Court of Appeals affirmed the District Court's summary judgment for the employer.

Majesco Software is a company that is based in Irving, Texas, which is part of the Dallas metropolitan area. It is a subsidiary of Mastek, an Indian software company based in Bombay, India.

Mastek is in the business of providing outsourced software and information technology solutions and technicians for business customers. Majesco sells Mastek's software and services in the U.S.

Ivor Keelan and David Sullivan are former employees of Majesco Software. They assert that they were discriminated against while employed, and terminated, because they were Americans, rather than Indians. Keelan was terminated by Majesco in November of 2001. Sullivan left to take employment with another company, but asserts constructive discharge.

Keeland and Sullivan introduced evidence that Majesco personnel made statements to the effect that U.S. employees of Majesco were being forced out. However, the evidence in this case also reflected that Keelan and Sullivan were sales representatives who did not sell much, and that Majesco treated its Indian born employees the same.

Keelan and Sullivan filed a complaint in U.S. District Court (NDTex) against Majesco alleging discrimination in the terms and conditions of their employment and in Keelan's termination and Sullivan's constructive discharge. The District Court granted summary judgment to Majesco.

This appeal followed. The Court of Appeals affirmed the District Court.

This case is Ivor Keelan and David Sullivan v. Majesco Software, Inc., U.S. Court of Appeals for the 5th Circuit, No. 04-10317, an appeal from the U.S. District Court for the Northern District of Texas.

4/12. The U.S. Court of Appeals (7thCir) issued is second opinion [11 pages in PDF] in Ameritech v. McCann, a case regarding a state District Attorney (DA) who requests and receives information from Ameritech, but refuses to pay, as required by § 2706 of the ECPA. The Court of Appeals held that the DA must pay, instructed the District Court to write a declaratory judgment to that effect, and specified the language to be included.

This is the second time that the Court of Appeals has issued an opinion in this case. On July 22, 2002, this Court of Appeals issued its first opinion [11 pages in PDF], holding that the 11th Amendment does not bar an electronics communications provider from suing a state law enforcement agency in federal court for prospective injunctive relief for an ongoing violation of the Electronic Communications Privacy Act (ECPA). See, story titled "7th Circuit Construes ECPA and 11th Amendment" in TLJ Daily E-Mail Alert No. 475, July 23, 2002.

The present opinion restates the holding of the first opinion. However, it also goes much. It includes an expanded basis for rejecting 11th Amendment immunity. It rejects several other arguments advanced by McCann, including Constitutional authority for the underlying statute, interpretation of the ECPA, and lack of authority to preempt state law. The present opinion directs the District Court to issue a declaratory judgment, and spells out in condescending detail the contents of that declaratory judgment. The Court of Appeals wrote that this second opinion was made necessary, not only by the "intransigence" of McCann, but also because the District Court's "neglected" to enter a "proper judgment" after the Court of Appeals reversed its previous judgment

Ameritech (which has been acquired by SBC) is an incumbent local exchange carrier in the state of Wisconsin. It provides, among other things, landline telephone service.

Michael McCann has been the District Attorney of Milwaukee County since 1968. The DA's office requests and receives information from Ameritech pursuant to the Electronic Communications Privacy Act (ECPA), which is codified at 18 U.S.C. § 2510, et seq.

18 U.S.C. § 2706, which is at issue in this case, provides that "a governmental entity obtaining the contents of communications, records, or other information under section 2702, 2703, or 2704 of this title shall pay to the person or entity assembling or providing such information a fee for reimbursement for such costs as are reasonably necessary and which have been directly incurred in searching for, assembling, reproducing, or otherwise providing such information. Such reimbursable costs shall include any costs due to necessary disruption of normal operations of any electronic communication service or remote computing service in which such information may be stored."

This litigation involves McCann's refusal to pay, pursuant to § 2706, for terminating automated messaging account (AMA) reports that are requested and received from Ameritech. This is industry jargon for obtaining information about who is telephoning someone else. That is, since landline phone companies bill for outgoing calls, their record keeping systems organize information by caller. However, the phone companies can compile data on incoming calls to a particular number. The Court of Appeals opinion details this process, and just how expensive and time consuming it is for companies like Ameritech to aggregate and organize this data.

McCann has for a long time requested this data, but refused to pay for it. The Court of Appeals wrote that "State and federal law-enforcement officials throughout the nation pay routinely. Not so in Wisconsin, where officials have dug in their heels."

The Court of Appeals also noted that "Public officials in Wisconsin not only refuse to pay but also make a disproportionately high number of demands compared with law-enforcement officials in other states. That Wisconsin's prosecutors treat terminating AMA reports as free doubtless explains this fact, and the volume of demands explains Ameritech's concern about the drain on its resources."

McCann has long tried to evade his legal obligation under § 2706 by asserting that he has 11th Amendment immunity. The 11th Amendment of the U.S. Constitution provides that "The judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State."

The 11th Amendment may be archaic and outdated, but it remains in the Constitution. States, such as Wisconsin, have discovered numerous ways to profit from its abuse.

The Supreme Court has long limited the application of 11th Amendment immunity by the doctrine announced in Ex Parte Young, 209 U.S. 123 (1908). That case held that the 11th Amendment bars a suit for money damages, but not a claim for prospective injunctive relief.

The Court of Appeals, in its first opinion, provided a straightforward application of the doctrine of Ex Parte Young. That is, Ameritech is seeking prospective injunctive relief, not money damages, so its suit is not barred.

This present opinion also addresses additional arguments raised by McCann. He argued that the Congress lacks authority to preempt in this area. The Court of Appeals rejected this argument on the basis that there is no state statute that has been preempted.

"No state law excuses or forbids compensation", the Court of Appeals wrote. "So, too, state law that fails to provide for compensation when telephone companies disclose information is not inconsistent with a federal law that does require compensation; payment is compatible with both laws. Only a state law along the lines of ``a District Attorney is entitled to records for free´´ would pose a preemption issue, and there is no such law in Wisconsin."

McCann also argued that the Congress lacks Constitutional authority in this area. That is, he did not challenge the authority of the Congress to pass a law requiring phone companies to provide data, services, and surveillance assistance to DAs. Nor did he challenge the authority of the Congress to give states authority to conduct wiretaps. Rather, he only challenged the authority of the Congress to require compensation from phone companies.

The Court of Appeals rejected this argument. It noted that the Constitution includes an interstate commerce clause, and that this includes the power to regulate the phone system. It cited as authority for this proposition a line of case beginning in 1878 with Pensacola Telegraph Co. v. Western Union Telegraph Co., 96 U.S. 1

McCann also argued that the DA's office is not a "governmental entity" within the meaning of the statute, and that the records obtained by the DA's office are not "records" within the meaning of the statute. The Court of Appeals rejected these arguments.

The Court of Appeals also specified the language that the District Court must put in a declaratory judgment upon remand. The Court of Appeals took this unusual step because, after its 2002 reversal, the District Court issued a declaratory judgment, but refused to specify what was enjoined.

The Court of Appeals wrote in its present opinion that "the declaratory judgment should provide that in the future the District Attorney must tender compensation as part of every request under Wis. Stat. §968.135 that Ameritech provide a terminating AMA report, and must agree to litigate the amount of compensation in state court if Ameritech deems the tender inadequate. Unless such an offer is made and included in the state court's order, Ameritech need not provide the requested information."

This language goes well beyond providing prospective injunctive relief. It not only enjoins McCann, prospectively, from continuing his violation of the ECPA, it also specifies that future litigation must be in state court (where the 11th Amendment is inapplicable), and that if McCann violates the injunction, Ameritech may violate its obligations to provide data to McCann.

Also, the Court of Appeals went beyond the doctrine of Ex Parte Young in its analysis of McCann's immunity argument. It wrote that "Once states open their courts to litigation, they must apply federal rules as well as those under state law. The supremacy clause gives no other alternative. ... State courts must comply with the wiretap laws and the fourth amendment; so too they must comply with other federal rules affecting what information, and under what conditions, telecommunications firms provide to state prosecutors. Thus when the District Attorney petitions the state court for an order compelling Ameritech to prepare and provide a terminating AMA report, Ameritech (as the respondent) is entitled to insist that the state court follow federal law by attaching a price tag under §2706(b). ... No prosecutor or court in Wisconsin has been “commandeered” to do anything; §2706 just places a condition on activity that states elect to engage in, and from which they may desist as freely." (Parentheses in original. Citations omitted.)

This present opinion not only provides Ameritech prospective injunctive relief. It appears calculated to assure that Ameritech will in fact get paid for the debts that the DA will incur. Moreover, this opinion appears to further chip away at state sovereign immunity and 11th Amendment immunity.

Thus, this opinion may be pertinent, not only for phone companies that get stiffed by DAs who request ECPA assistance, but also for others who suffer from abusive assertions of state immunity.

Some of these assertions involve telecommunications and technology. For example, states and their public utilities commissions (PUCs) regulate phone companies, services and prices; they have also sometimes asserted 11th Amendment immunity in challenges to their PUCs' orders. (See also, Verizon Maryland v. Public Service Comm. of Maryland [PDF], which is reported at 535 U.S. 635.) Also, states, and state university systems, often assert 11th Amendment immunity to claims of patent infringement and copyright infringement.

This case is Ameritech Corporation v. Michael McCann, U.S. Court of Appeals for the 7th Circuit, Nos. 04-2262, 04-2385, 04-4308 and 05-1002, appeals from the U.S. District Court for the Eastern District of Wisconsin, D.C. No. 99-675, Judge Rudolph Randa presiding.

The 2002 opinion of the Court of Appeals was written by Judge Flaum and joined by Judges Wood and Williams. The present opinion was written by Judge Frank Easterbrook, and joined by Judges Evans and Kanne.

4/12. Representatives of business groups, and Rep. Joe Barton (R-TX), held a news conference in a House Commerce Committee hearing room to announce the formation of a coalition named TeleConsensus, which advocates updating U.S. telecommunications laws.

Rep. Barton, the Chairman of the House Commerce Committee (HCC), stated that the HCC will hold a number of hearings "this Spring and this Summer" to try to develop consensus "on what needs to be done to revamp our telecommunications laws".

He said that he plans to work "on a bipartisan basis" to "put together a bill that becomes law". He said too that communications technology has changed significantly since the last major rewrite of telecommunications laws in 1996. However, he offered no specifics regarding the likely contents of any bill. Nor did he advocate any specific statutory changes.

After opening comments by Rep. Barton, and the other participants, Rep. Barton took one question regarding indecency, and then left.

The other participants at this event were Thomas Donohue, P/CEO of the U.S. Chamber of Commerce, John Engler, P/CEO of the National Association of Manufacturers (NAM), and Harry Alford, P/CEO of the National Black Chamber of Commerce (NBCC).

Donohue stated that the U.S. is "crippled by a multitude of legacy regulations".

The speakers were vague about specific changes to telecommunications law. Teleconsensus has not yet released any draft legislation, or outline of draft legislation.

However, Teleconsensus did release six vaguely worded guiding principles:

  "1. Federal telecommunications laws must be updated to foster innovation, expand consumer choice, spur investment, create jobs, enhance efficiency, and increase productivity.
  2. Telecommunications markets should be driven by consumer demand, advances in technology, and competition between telecommunications companies, while encouraging public safety, consumer protection, and access for people with disabilities, as well as other public interest goals.
  3. Universal service, which ensures affordable basic telephone service for all Americans and Internet access in the nation's schools and libraries, is an important national commitment and must be preserved.
  4. Government should not burden consumers with discriminatory or excessive telecommunications taxes, nor should obsolete regulations limit Americans' access to innovative services and choices.
  5. Consumer choice and private-sector investment should drive the deployment of high-speed Internet access into our communities.
  6. Additional spectrum should be allocated for innovative wireless services."

Back in October of 2004 the U.S. Chamber of Commerce released a report titled "Sending the Right Signals: Promoting Competition Through Telecommunications". See, story titled "US Chamber Offers Communications Policy Recommendations" in TLJ Daily E-Mail Alert No. 993, October 8, 2004. The just announced coalition builds upon this study.

The coalition's members include the Chamber, NAM, NBCC, and other business groups. BellSouth, Verizon, SBC, T-Mobile USA, Time Warner, and the Electronic Industries Alliance are also members. The coalition is seeking more members.

Bill Kovacs, of the U.S. Chamber of Commerce, will coordinate the efforts of Teleconsensus. See also, US Chamber release.

4/12. Reed Elsevier's LexisNexis stated in a release that it provided personal information on another 280,000 individuals, including names and social security numbers, to unknown persons who may use the information for criminal activity. On March 9, 2005, Reed Elsevier announced that its Seisint unit, which aggregates data on individuals, may have provided personal information on 32,000 individuals to unknown persons. Reed Elsevier acquired Seisint last year, and made it a part of its LexisNexis U.S.

Reed Elsevier's LexisNexis stated on April 12 that "In addition to the 30,000 individuals already notified, LexisNexis will begin notifying approximately 280,000 additional individuals whose information may have been acquired during these recently identified incidents." It added that "LexisNexis has concluded that unauthorized persons, primarily using IDs and passwords of legitimate Seisint customers, may have acquired personal-identifying information, such as Social Security numbers (SSN) or Driver’s License numbers (DLN), of individuals in the U.S. in some 59 incidents."

Rep. Joe Barton (R-TX), Chairman of the House Commerce Committee, stated that ""Once again we're forced to ask, why should it continue to be legal to sell a person's Social Security number without permission? Both Democrats and Republicans on this committee are determined to get to the bottom of this problem, and if it takes a new law to protect people from identity thieves, so be it."

4/12. The Recording Industry Association of America (RIAA) announced that on April 13 record companies will file in U.S. District Courts around the U.S. another round a complaints against individuals alleging copyright infringement. The RIAA stated in a release that this round a lawsuits targets students at universities that make use of Internet2.

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

The Senate will meet at 9:30 AM. It will resume consideration of HR 1268, the Iraq/Afghanistan Supplemental Appropriations bill.

9:15 AM - 2:30 PM. The U.S. Patent and Trademark Office (USPTO) will host a seminar on intellectual property enforcement in China. The USPTO states that "Press must confirm attendance by 3:00 p.m., Tuesday, April 12 to (571) 272-8334". Press contact: Brigid Quinn or Ruth Nyblod at 571 272-8400. See, notice. Location: Marriott Inner Harbor Hotel, 110 South Eutaw Street, Baltimore, Maryland.

9:30 AM. The Senate Judiciary Committee will hold a hearing titled "Securing Electronic Personal Data:  Striking a Balance Between Privacy and Commercial and Governmental Use". 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.

RESCHEDULED FROM APRIL 6. 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 House Judiciary Committee will meet to mark up several bills, including HR 32, the "Stop Counterfeiting in Manufactured Goods Act". Press contact: Jeff Lungren or Terry Shawn at 202 225-2492. Location: Room 2141, Rayburn Building.

1:30 PM. The House Homeland Security Committee will hold a hearing titled "The Department of Homeland Security: Promoting Risk-Based Prioritization and Management". Secretary of Homeland Security Michael Chertoff will testify. Press contact: DHS at 202 282-8010, or Ryan Patmintra (HHSC) at 202 226-9600. Location: Undisclosed.

1:30 PM. The House International Relations Committee's Subcommittee on the Western Hemisphere will hold a hearing titled "U.S. Trade Agreements with Latin America". Location: Room 2172, Rayburn Building.

2:30 PM. The Senate Commerce Committee's Subcommittee on Trade, Tourism, and Economic Development will hold a hearing on S 714, the "Junk Fax Prevention Act of 2005". The scheduled witnesses are be Michael Griffin (NASA), Dave Feeken (a real estate broker from Kenai, Alaska), Jon Bladine (News-Register Publishing Company, McMinnville, Oregon), and Steve Kirsch (Propel Software Corporation). 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 253, Russell Building.

6:00 - 8:15 PM. The DC Bar Association will host a continuing legal education (CLE) program titled "How to Prosecute a Trademark Before the U.S. Patent and Trademark Office". The scheduled speakers are Leigh Ann Lindquist (Sughrue Mion), Mark Bergsman (Dickstein Shapiro Morin & Oshinsky), and Jody Drake (Sughrue Mion). 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.

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

RESCHEDULED FOR APRIL 28. 9:30 AM. The Federal Communications Commission (FCC) will hold a meeting. The event will be webcast by the FCC. Location: FCC, 445 12th Street, SW, Room TW-C05 (Commission Meeting Room).

9:30 AM. The Senate Judiciary Committee will hold an executive business meeting. The agenda includes consideration of several bills, and several judicial nominees, including the nominations of Thomas Griffith (to be a Judge of the U.S. Court of Appeals for the District of Columbia Circuit), Janice Brown (DC Circuit), Terrence Boyle (4th Circuit), Priscilla Owen (5th Circuit), Robert Conrad (Western District of North Carolina), and James Dever (Eastern District of North Carolina). This Committee rarely follows its announced agenda. 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 Commerce Committee's Subcommittee on Telecommunications and the Internet will hold a hearing titled "The ORBIT Act: An Examination of Progress Made in Privatizing the Satellite Communications Marketplace". The hearing will be webcast by the Committee. See, notice. Press contact: Larry Neal or Jon Tripp at 202 225-5735. Location: Room 2123, Rayburn Building.

10:00 AM. The Senate Commerce Committee will meet to mark up several bills, including S 432, the "Minority Serving Institution Digital & Wireless Technology Opportunity Act of 2005" and S 714, the "Junk Fax Prevention Act of 2005". 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 253, Russell Building.

10:00 AM. The House Judiciary Committee's Subcommittee on Crime, Terrorism, and Homeland Security will hold a hearing titled "Oversight Hearing of the Department of Justice to Examine the Use of Section 218 of the USA PATRIOT Act". This is the section that changed the standard for issuance of a FISA order. Location: Room 2141, Rayburn Building.

TIME CHANGE. 11:00 AM. The House Ways and Means Committee will hold a hearing titled "United States-China Economic Relations and China's Role in the World Economy". See, notice. Location: Room 1100, Longworth Building.

12:15 PM. The Federal Communications Bar Association's (FCBA) Cable Practice Committee and Common Carrier Practice Committee will jointly host a brown bag lunch titled "Phone Companies' Entry into Video". The speakers will be Libby Beatty (National Association of Telecommunications Officers & Advisors), Neal Goldberg (National Cable & Telecommunications Association), and Bill Richardson (Wilmer Cutler). RSVP to Quyen Truong at ttruong at dowlohnes dot com or 202 776-2058. Location: Dow Lohnes & Albertson, Suite 800, 1200 New Hampshire Ave., NW.

2:00 PM. The House Appropriation's Committee's Subcommittee on Science, State, Justice, and Commerce, and Related Agencies will hold a hearing on the Federal Communications Commission. See, notice. Location: Room H-309, Capitol Building. (This is a small hearing room with very few public seats.)

2:00 PM. The House Appropriation's Committee's Subcommittee on Homeland Security will hold a hearing titled "Science and Technology". See, notice. Under Secretary of Homeland Security Charles McQueary will testify. Location: Room 2359, Rayburn Building.

4:00 PM. Pamela Samuelson (University of California at Berkeley School of Law) will present a draft paper titled "Why Congress Excluded Processes and Systems from the Scope of Copyright". See, notice of event. This event is part of the Spring 2005 Intellectual Property Workshop Series sponsored by the Dean Dinwoodey Center for Intellectual Property Studies at the George Washington University Law School (GWULS). For more information, contact Robert Brauneis at 202 994-6138 or rbraun at law dot gwu dot edu. The event is free and open to the public. Location: GWULS, Faculty Conference Center, Burns Building, 5th Floor, 716 20th St., NW.

6:00 PM. Day one of a two day conference hosted by the American Enterprise Institute (AEI), Münchner Kreis, and Georgetown University titled "The Future of Telecommunications Industries: Transatlantic Symposium". See, notice. Registration required by April 8. See, registration page. Location: Riggs Library, Main Campus, Georgetown University, 37th and O Streets, NW.

8:45 AM - 5:15 PM. Day two of a two day conference hosted by the American Enterprise Institute (AEI), Münchner Kreis, and Georgetown University titled "The Future of Telecommunications Industries: Transatlantic Symposium". See, notice. Registration required by April 8. See, registration page. Location: Riggs Library, Main Campus, Georgetown University, 37th and O Streets, NW.

9:30 AM. The U.S. Court of Appeals (DCCir) will hear oral argument in U.S. International Trade Commission v. ASAT Inc., No. 05-5009. See, U.S. International Trade Commission's (USITC) proceeding conducted pursuant to Section 337 of the Tariff Act of 1930, 19 U.S.C. § 1337, titled "In the Matter of Certain Encapsulated Integrated Circuit Devices and Products Containing Same" and numbered 337-TA-501. See also ASAT web site. Judges Ginsburg, Rogers and Tatel will preside. Location: Prettyman Courthouse, 333 Constitution Ave., NW.

10:00 AM - 3:00 PM. The Federal Communications Commission's (FCC) Technological Advisory Council will meet. See, notice in the Federal Register, March 25, 2005, Vol. 70, No. 57, at Page 15316. Location: FCC, 445 12th Street, SW, Commission Meeting Room (TW-C305).

Deadline to submit reply comments to the Federal Communications Commission (FCC) regarding TSA Stores, Inc.'s Petition for Declaratory Ruling to preempt a provision of the statutes of the state of Florida as applied to interstate telephone calls. This is CG Docket No. 02-278, which pertains to rules implementing the Telephone Consumer Protection Act of 1991 (TCPA). See, notice in the Federal Register, March 1, 2005, Vol. 70, No. 39, at Pages 9875-9876.

The Supreme Court will return on from the recess that it began on Monday, April 4. See, Order List [12 pages in PDF] at page 12.

Deadline to submit to the Federal Communications Commission (FCC) replies to 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.

10:00 AM - 2:00 PM. The American Enterprise Institute (AEI) will host an event titled "Managing Spectrum: Why Economics Matters". The speakers will include William Baumol (New York University), Gerald Faulhaber (University of Pennsylvania), and Robert Hahn (AEI-Brookings Joint Center for Regulatory Studies). See, notice. Location: AEI, 12th floor, 1150 17th St., NW.

11:00 AM. The House Homeland Security Committee's Subcommittee on Economic Security, Infrastructure Protection, and Cybersecurity will meet. The agenda contains one item, HR 285,  the "Department of Homeland Security Cybersecurity Enhancement Act of 2005". Location: Room 210, Cannon Building.

2:30 PM. The Senate Judiciary Committee's Subcommittee on Antitrust, Competition Policy and Consumer Rights will hold a hearing to examine the SBC/ATT and Verizon/MCI mergers, focusing on remaking the telecommunication industry. 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.

6:00 - 815 PM. The Federal Communications Bar Association (FCBA) will host a continuing legal education (CLE) seminar titled "Telecom Act Re-write". Location: Wiley Rein & Fielding Conference Center, 1776 K St., NW.

Day one of a three day conference hosted by the National Institute of Standards and Technology (NIST), National Institute of Health (NIH), and Internet2 titled "4th Annual PKI R&D Workshop: Multiple Paths to Trust". See, NIST notice, registration page, and conference website. Location: NIST, Gaithersburg, MD.

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