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April 2, 2008, Alert No. 1,741.
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En Banc 9th Circuit Panel Rejects Section 230 Immunity in Roommates.com Case

4/3. An en banc panel of the U.S. Court of Appeals (9thCir) issued its 8-3 opinion [PDF] in FHCSFV v. Roommates.com, a Section 230 immunity case.

The majority held, as did the three judge panel, that an interactive computer service, such as Roommates.com, can be held liable for the speech of users, despite language to the contrary in Section 230. Moreover, the majority held, the web site's search and e-mail notification functions, have no immunity.

This opinion is arguably inconsistent with both the language and purpose of Section 230, as well as the opinions of other circuits. This opinion argues that it is distinguishable from other Section 230 opinions because Roommates.com users provide information in response to an online questionnaire. This, the 9th Circuit asserts, causes or induces the users to make statements, and hence, makes Roommates.com a content creator.

This opinion will likely invite government regulation of internet speech, and private litigation to suppress internet expression. It may also lead some interactive web site operators to refrain from allowing users to post content out of fear of litigation and liability under this court's theory of inducement of speech.

Craigslist Opinion. On March 14, 2008, the  U.S. Court of Appeals (7thCir) issued its opinion [10 pages in PDF] in Chicago Lawyers v. Craigslist, a Section 230 case based upon similar facts. The 7th Circuit held that Craigslist does have Section 230 immunity. See, story titled "7th Circuit Applies Section 230 Immunity in Craigslist Case" in TLJ Daily E-Mail Alert No. 1,731, March 17, 2008.

In both the Roommates.com case, and the Craigslist case, attorneys filed lawsuits seeking to impose liability under civil rights laws upon web site operators for the statements of the web sites' users regarding roommates, apartments, and housing. The 7th Circuit held that Section 230 immunizes the web site operator. The 9th Circuit held that for some user statements it does not. The 7th Circuit opinion did not cite the opinion of the three judge panel of the 9th Circuit.

The just released 9th Circuit opinion attempts to distinguish the 7th Circuit opinion. It states that "No other circuit has considered a case like ours and none has a case that even arguably conflicts with our holding today. No case cited by the dissent involves active participation by the defendant in the creation or development of the allegedly unlawful content; in each, the interactive computer service provider passively relayed content generated by third parties, ... and did not design its system around the dissemination of unlawful content. ... Nothing in the service craigslist offers induces anyone to post any particular listing or express a preference for discrimination ... the Seventh Circuit’s opinion is actually in line with our own." (See, footnote 33.)

Background. For a review of the facts of the Roommotes.com case, see story titled "9th Circuit Holds Roommates.com May be Liable for Speech of Users" in TLJ Daily E-Mail Alert No. 1,581, May 15, 2007. See also, story titled "9th Circuit to Rehear Section 230 Case En Banc" in TLJ Daily E-Mail Alert No. 1,657, September 18, 2007.

The just released opinion states that Roommates.com is a "website designed to match people renting out spare rooms with people looking for a place to live".

It adds that Roommates.com "requires each subscriber to disclose his sex, sexual orientation and whether he would bring children to a household. Each subscriber must also describe his preferences in roommates with respect to the same three criteria: sex, sexual orientation and whether they will bring children to the household. The site also encourages subscribers to provide ``Additional Comments´´ describing themselves and their desired roommate in an open-ended essay."

Statute. 47 U.S.C. § 230 provides that "No provider or user of an interactive computer service shall be treated as the publisher or speaker of any information provided by another information content provider."

It defines "interactive computer service" as "any information service, system, or access software provider that provides or enables computer access by multiple users to a computer server, including specifically a service or system that provides access to the Internet and such systems operated or services offered by libraries or educational institutions".

Court of Appeals Opinion. The majority wrote that in passing the Communications Decency Act (CDA), which includes Section 230, the "Congress sought to immunize the removal of user-generated content, not the creation of content".

It added that the CDA "was not meant to create a lawless no-man’s-land on the Internet".

The majority concluded that Roommates.com has no Section 230 immunity for statements made by users in response to its questionnaire. The majority imposed an inducement to speak exception to Section 230.

The majority wrote that "The CDA does not grant immunity for inducing third parties to express illegal preferences. Roommate's own acts -- posting the questionnaire and requiring answers to it -- are entirely its doing and thus section 230 of the CDA does not apply to them. Roommate is entitled to no immunity."

It also wrote that "By requiring subscribers to provide the information as a condition of accessing its service, and by providing a limited set of pre-populated answers, Roommate becomes much more than a passive transmitter of information provided by others; it becomes the developer, at least in part, of that information. And section 230 provides immunity only if the interactive computer service does not ``creat[e] or develop []´´ the information ``in whole or in part.´´"

It also wrote that "When a business enterprise extracts such information from potential customers as a condition of accepting them as clients, it is no stretch to say that the enterprise is responsible, at least in part, for developing that information."

The 7th Circuit's Craigslist opinion rejected a causation or inducement exception based upon the facts in that case. It wrote this: "Nothing in the service craigslist offers induces anyone to post any particular listing or express a preference for discrimination; for example, craigslist does not offer a lower price to people who include discriminatory statements in their postings. If craigslist ``causes´´ the discriminatory notices, then so do phone companies and courier services (and, for that matter, the firms that make the computers and software that owners use to post their notices online), yet no one could think that Microsoft and Dell are liable for ``causing´´ discriminatory advertisements." (Parentheses in original.)

The 9th Circuit majority also held that Roommates.com "is not entitled to CDA immunity for the operation of its search system, which filters listings, or of its email notification system, which directs emails to subscribers according to discriminatory criteria. Roommate designed its search system so it would steer users based on the preferences and personal characteristics that Roommate itself forces subscribers to disclose. If Roommate has no immunity for asking the discriminatory questions, ... it can certainly have no immunity for using the answers to the unlawful questions to limit who has access to housing." (Footnote omitted.)

Judge Alex Kozinski wrote the opinion of the Court of Appeals, in which Judges Stephen Reinhardt, Barry Silverman, William Fletcher, Raymond Fisher, Richard Paez, Milan Smith, and Randy Smith joined. Judge Kozinski, who also wrote the opinion of the three judge panel, was appointed by former President Reagan.

Dissent. Judge Margaret McKeown wrote a dissent, in which Judges Pam Rymer and Carlos Bea joined. Judge McKeown was appointed by former President Clinton. Judge Rymer was appointed by the elder President Bush. Judge Bea was appointed by the current President Bush.

The dissenting opinion states that "The majority's unprecedented expansion of liability for Internet service providers threatens to chill the robust development of the Internet that Congress envisioned."

It adds that the majority's "approach would essentially swallow the immunity provision. The combination of solicitation, sorting, and potential for liability would put virtually every interactive website in this category. Having a website directed to Christians, Muslims, gays, disabled veterans, or childless couples could land the website provider in hot water."

This case is Fair Housing Council of San Fernando Valley and Fair Housing Council of San Diego v. Roommate.com, LLC, U.S. Court of Appeals for the 9th Circuit, App Ct. Nos. 04-56916 and 04-57173, appeals from the U.S. District Court of the Central District of California.

The web site is named Roommates.com (a plural). However, the business entity is named Roommate.com (a singular). This article uses the singular version to refer to both the web site and the legal entity that operates the web site.

Secretary Gutierrez Writes Sen. Leahy Regarding Patent Reform

4/3. Secretary of Commerce Carlos Gutierrez sent a letter [4 pages in PDF] to Sen. Patrick Leahy (D-VT), the Chairman of the Senate Judiciary Committee (SJC), regarding S 1145 [LOC | WW], the "Patent Reform Act of 2007".

First, he expressed support for the applicant quality submissions (AQS) provisions in the bill.

Second, he expressed opposition to the bill's inequitable conduct language. He wrote that the Bush administration "recognizes and supports statutory changes to the doctrine of inequitable conduct".

He also wrote that the "standard should more clearly target actual fraud affecting the examination process and preserve judicial discretion in application of appropriate sanctions. However, the Administration strongly opposes any statutory changes to the doctrine of inequitable conduct in the absence of a strong provision requiring Applicant Quality Submissions. Applicant quality standards and inequitable conduct reform are inextricably linked."

He argued that "Inequitable conduct reform alone, without Applicant Quality Submissions, would merely invite fraud on the patent system."

Third, he wrote that the administration supports "establishment of an effective, efficient post-grant patent review process that truly functions as a lower-cost alternative to litigation for those who want to challenge a patent's validity. We support the structural approach to post-grant review as outlined in the bill (including a first window of opportunity to challenge a patent and a narrow second window throughout the patent life), provided that it has sufficient access requirements and estoppel effects to ensure that the review procedures are more efficient, manageable and timely." (Parentheses in original.)

He added that "The Administration will oppose a post-grant structure that does not protect against frivolous harassment of patent holders."

Fourth, he wrote that the administration's "overriding concern continues to be proposed revisions to the law governing the appropriate assessment of damages in patent infringement cases." He said that "The incentive to innovate must continue to be supported by an assurance to patent owners that they will be fully compensated for harm caused by infringement."

Gutierrez elaborated that "While the Administration opposes language that limit a court's discretion, we would support statutory changes to current damages law that have the effect of directing or guiding courts to clearly identify the factors and evidence relevant to the determination of damages and to consider only those factors when making their determinations. Such a ``gatekeeper´´ function would promote transparency without limiting necessary discretion."

On February 4, 2008, Nathaniel Wienecke, of the Department of Commerce, sent a letter [6 pages in PDF] to Sen. Leahy (D-VT) announcing and explaining the Bush administration's strong opposition to S 1145 in its current form. See, story titled "Bush Administration Opposes Senate Version of Patent Reform Act" in TLJ Daily E-Mail Alert No. 1,711, February 5, 2008.

At 11:00 AM.on April 4, Jon Dudas, head of the U.S. Patent and Trademark Office (USPTO) will hold a telephonic news conference regarding S 1145.

FCC Releases Agenda for April 10 Meeting

4/3. The Federal Communications Commission (FCC) released a tentative agenda [4 pages in PDF] for its event scheduled for April 10, 2008, titled "Open Commission Meeting".

1. The FCC's agenda states that it is scheduled to approve a Report and Order (R&O) and Order Proposing Modification increasing the spectrum available for code division multiple access (CDMA) satellite systems in the 1.6/2.4 GHz Big LEO bands to provide ancillary terrestrial component (ATC) service from 11 MHz to 19.275 MHz, and rules regarding interference.

See, the FCC's Second Order on Reconsideration, Second Report and Order, and Notice of Proposed Rulemaking [28 pages in PDF], adopted on November 7, 2007, and released on November 9, 2007. It is FCC 07-194 in IB Docket No. 07-253.

2. The FCC's agenda states that it is scheduled to approve a Notice of Proposed Inquiry in response to a Petition [60 pages in PDF] filed by nine public safety organizations regarding 911 call forwarding and carriers' blocking options for non-service initialized (NSI) phones.

The petition states that "Fraudulent 911 calls from NSI devices are significantly contributing to the overtaxing of the call receipt and call processing portions of the 911 service delivery system. PSAPs receive thousands of these calls each month and have little or no power to stop them. The calls divert essential resources from the life-saving mission of 911 and inhibit PSAPs' ability to answer and respond to true emergency calls. The 911 Entities respectfully request that the Commission address this very serious issue by further considering the call-blocking option and other possible solutions to the problem."

3. The FCC's agenda states that it is scheduled to approve a R&O regarding implementation of the Warning, Alert and Response Network (WARN) Act.

See, FCC's Notice of Proposed Rulemaking (NPRM) [PDF], adopted and released on December 14, 2007. It is FCC 07-214 in PSHS Docket No. 07-287.

The WARN Act was enacted in late 2006 a part of the port security bill. It establishes a process for commercial mobile service providers to voluntarily elect to transmit emergency alerts. See also, stories titled "Bush Signs Port Security Bill" in TLJ Daily E-Mail Alert No. 1,469, October 16, 2006, and "House and Senate Approve Port Security Bill With Tech Provisions" in TLJ Daily E-Mail Alert No. 1,461, October 4, 2006.

4. The FCC's agenda states that it is scheduled to approve an Order addressing several petitions filed by TracFone Wireless in 2004 for designation as an Eligible Telecommunications Carrier (ETC), eligible only to receive universal service Lifeline support subsidies, in the states of New York, Florida, Virginia, Connecticut, Massachusetts, Alabama, North Carolina, Tennessee, Delaware, and New Hampshire, and in the District of Columbia. See also, TracFone's notice of ex parte communication [PDF] of April 1, 2008. This is CC Docket No. 96-45.

5. The FCC's agenda also includes several Notices of Apparent Liability for Forfeiture alleging violation of the FCC's rules banning importation and interstate shipment of analog only television receivers, or violation of the FCC's rules regarding labeling of analog only TV receivers.

This event is scheduled for 9:30 AM on Thursday, April 10, 2008, in the FCC's Commission Meeting Room, Room TW-C305, 445 12th Street, SW. The FCC's recent events titled "Open Commission Meeting" have rarely been held at the time announced by the FCC. The FCC does not always take up all of the items on its published program. The FCC sometimes adds items to the program without providing the "one week" notice required 5 U.S.C. § 552b. The FCC usually does not release at its events copies of the items that it adopts at its events.

Court of Appeals Reinstates Complaint Against Facebook Founders

4/3. The U.S. Court of Appeals (1stCir) issued its opinion in ConnectU v. Zuckerberg, reversing the judgment of the District Court, which dismissed the case for lack of jurisdiction.

This is a dispute arising out of the formation of the social networking web sites known as Facebook and ConnectU. The plaintiff, ConnectU LLC, alleges that Mark Zuckerberg and other defendants stole its trade secrets and infringed its software copyright to create the Facebook web site. However, this opinion does not go to the merits of any of the claims. Rather, this opinion deals only with jurisdiction.

ConnectU filed its original complaint in U.S. District Court (DMass) alleging only state law claims, including misappropriation and unauthorized use of confidential source code and business plan. This complaint based its claim of federal jurisdiction upon diversity of citizenship. ConnectU promptly filed an amended complaint that also pled copyright infringement, a federal claim. This complaint based its claim of jurisdiction on the federal claim.

The District Court dismissed the amended complaint on the basis that there was not complete diversity of citizenship. The Court of Appeals reversed, and remanded to the District Court for consideration of both the federal (under federal question jurisdiction) and the state law (under supplemental jurisdiction) claims.

This case is ConnectU LLC v. Mark Zuckerberg, et al., U.S. Court of Appeals for the 1st Circuit, App. Ct. No. 07-1796, an appeal from the U.S. District Court for the District of Massachusetts, Judge Douglas Woodlock presiding.

Washington Tech Calendar
New items are highlighted in red.
Friday, April 4

The House will meet at 10:00 AM. See, Rep. Hoyer's schedule for week of March 31 states that "no votes are expected in the House".

The Senate will meet at 9:00 AM. It will resume consideration of HR 3221 [LOC | WW], the "Renewable Energy and Energy Conservation Tax Act of 2007".

8:00 AM - 3:00 PM. The National Science Foundation's (NSF) Directorate for Mathematical and Physical Sciences Advisory Committee will meet. See, notice in the Federal Register, March 7, 2008, Vol. 73, No. 46, at Page 12472. Location: NSF, 4201 Wilson Blvd., Arlington, VA.

8:30 AM - 1:45 PM. George Mason University (GMU) law school will host a conference titled "The Genesis of Unlicensed Wireless Policy". See, notice. Location: Room 121, GMU School of Law, 3301 Fairfax Drive, Arlington, VA.

9:00 AM - 4:00 PM. The Federal Communications Commission's (FCC) Consumer Advisory Committee will meet. The agenda includes digital television transition issues. See, FCC notice and notice in the Federal Register, March 17, 2008, Vol. 73, No. 52, at Page 14249. Location: FCC, Commission Meeting Room, Room TW-C305, 445 12th St., SW.

9:00 AM - 5:00 PM. Day two of a two day meeting of the Architectural and Transportation Barriers Compliance Board. From 9:00 AM to 3:30 PM, the meeting will be closed to the public. See, notice in the Federal Register, April 1, 2008, Vol. 73, No. 63, at Pages 17302-17303. Location: Marriott at Metro Center Hotel, 775 12th St., NW.

11:00 AM. Jon Dudas, head of the U.S. Patent and Trademark Office (USPTO) will hold a telephonic news conference regarding S 1145 [LOC | WW], the "Patent Reform Act of 2007". See also, April 3, 2008, letter [PDF] from Secretary of Commerce Carlos Gutierrez to Sen. Patrick Leahy (D-VT). To participate, call 800-857-2849; the code #1531188.

Day three of a three day conference hosted by the Consumer Electronics Association (CEA) titled "CEA Washington Forum". Location: JW Marriot Hotel.

Monday, April 7

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Voda v. Cordis, App. Ct. No. 2007-1297. Location: Courtroom 201, 717 Madison Place, NW.

EXTENDED FROM MARCH 24. Deadline to submit reply comments to the Federal Communications Commission (FCC) in response to its Notice of Proposed Rulemaking (NPRM) regarding pole attachments and 47 U.S.C. § 224. The FCC adopted this NPRM on October 31, 2007, and released the text [40 pages in PDF] on November 20, 2007. This NPRM is FCC 07-187 in WC Docket No. 07-245. See, notice in the Federal Register, February 6, 2008, Vol. 73, No. 25, at Pages 6879-6888, and story titled "FCC Sets Comments Deadlines for Pole Attachments NPRM" in TLJ Daily E-Mail Alert No. 1,714, February 8, 2008. See also, notice of extension in the Federal Register, February 12, 2008, Vol. 73, No. 29, at Page 8028.

Deadline to submit initial comments to the Federal Communications Commission (FCC) in response to its Second Further Notice of Proposed Rulemaking regarding interference protection rights for LPFM stations. The FCC adopted this item on November 27, 2007, and released the text on December 11, 2007. It is FCC 07-204 in MB Docket No. 99-25. See, notice in the Federal Register, March 6, 2008, Vol. 73, No. 45, at Pages 12061-12065, and Public Notice [PDF] (DA 08-531).

Tuesday, April 8

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Cygnus Telecom v. Telesys Communications, App. Ct. No. 2007-1328, and Cygnus Telecom v. AT&T, App. Ct. No. 2007-1023. Location: Courtroom 201, 717 Madison Place, NW.

The U.S. Court of Appeals (FedCir) will hear oral argument in Luma v. Stryker, App. Ct. No. 2007-1353, a patent infringement case involving endoscopy medical devices -- Courtroom 402, 717 Madison Place, NW.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Jang v. Boston Scientific, App. Ct. No. 2007-1385, a patent case involving stent technology. Location: Courtroom 203, 717 Madison Place, NW.

10:00 AM. The U.S. Court of Appeals (FedCir) will hear oral argument in Ricoh v. Quanta Computer, App. Ct. No. 2007-1567. Location: Courtroom 203, 717 Madison Place, NW.

9:00 AM - 4:00 PM. The President's Council of Advisors on Science and Technology (PCAST) will meet. The agenda includes, among other items, a panel on "approaches and barriers to research partnerships among universities and the private sector" and a "briefing on the 2008 Science and Engineering Indicators developed by the National Science Board". See, notice in the Federal Register, March 25, 2008, Vol. 73, No. 58, at Pages 15755-15756. Location: Room 100, Keck Center of the National Academies, 500 5th St., NW.

9:30 AM. The U.S. Court of Appeals (DC) will hear oral argument in Comcast v. FCC, App. Ct. No. 07-1445. This is Comcast's petition for review of the Federal Communications Commission's (FCC) Memorandum Opinion and Order (MO&O) [20 pages in PDF] released on September 4, 2007, denying Comcast's request for a waiver of the integration ban for set top boxes. See, story titled FCC Denies Comcast's Request for Waiver of Integration Ban in TLJ Daily E-Mail Alert No. 1,636, September 7, 2007. This MO&O is FCC 07-127 in CS Docket No. 97-80. See also, FCC brief [103 pages in PDF]. Judges Ginsburg, Griffith and Silberman will preside. This is the first of three cases on the agenda. Location: 333 Constitution Ave., NW.

10:00 AM. The Senate Commerce Committee (SCC) will hold a hearing titled "Federal Trade Commission Reauthorization". The witnesses will be the five Commissioners of the FTC. See, notice. Location: Room 253, Russell Building.

10:00 AM. The President's Export Council (PEC) will meet. See, notice in the Federal Register, March 12, 2008, Vol. 73, No. 49, at Page 13208. Location: Department of Commerce, Room 4830, 1401 Constitution Ave., NW.

1:30 - 4:30 PM. The Department of Homeland Security's (DHS) National Infrastructure Advisory Council will meet. See, notice in the Federal Register, March 10, 2008, Vol. 73, No. 47, at Page 12747. Location?

2:00 - 4:00 PM. The Department of State's (DOS) International Telecommunication Advisory Committee (ITAC) will meet to prepare advice on submission of contributions to CITEL PCC.II. (This is the Organization of American States Inter-American Telecommunication Commission's (CITEL) Permanent Consultative Committee II (PCC.II). See, notice in the Federal Register, February 28, 2008, Vol. 73, No. 40, at Page 10854. Location: FCC, 445 12th St., SW.

2:30 PM. The Senate Commerce Committee (SCC) will hold a hearing titled "Oversight of the DTV Transition". See, notice. Location: Room 253, Russell Building.

6:00 - 9:15 PM. The DC Bar Association will host part two of a two part program titled "Preserving Intellectual Property Rights in Government Contracts Series: A Beginner's Guide". The price to attend ranges from $80 to $115. For more information, contact 202-626-3488. See, notice. This event qualifies for continuing legal education (CLE) credits. Location: DC Bar Conference Center, B-1 Level, 1250 H St., NW.

Wednesday, April 9

9:00 - 10:30 AM. The Information Technology and Innovation Foundation (ITIF) will host a lecture by Bill Hefley, editor of the book [Amazon] titled "Service Science, Management and Engineering: Education for the 21st Century". This event is free and open to the public. Coffee and pastries will be served. See, notice and registration page. Location: ITIF, Suite 200, 1250 Eye St., NW.

6:00 - 9:00 PM. The DC Bar Association will host an event titled "50th Anniversary Celebration: BADC Patent Trademark & Copyright Section". For more information, contact MaryEva Candon at 202-223-5447. The price to attend ranges from $75 to $100. See, notice. Location: Dolley Madison House, U.S. Court Of Appeals for the Federal Circuit, 1520 H St., NW.

Deadline to submit comments to the U.S. Patent and Trademark Office (USPTO) regarding its proposal to revise its rules of practice pertaining to any claim using alternative language to claim two or more independent and distinct inventions (Alternative Claims Notice of Proposed Rule Making). This is also the deadline to submit comments regarding the USPTO's initial regulatory flexibility analysis (IRFA) on this proposed change to the rules of practice. See, notice in the Federal Register, March 10, 2008, Vol. 73, No. 47, at Pages 12679-12684.

Thursday, April 10

POSTPONED. 10:00 AM - 12:00 NOON. The House Science Committee's (HSC) Subcommittee on Investigations and Oversight will hold a hearing titled "American Decline or Renewal?: Globalizing Jobs or Technology". Location: Room 2318, Rayburn Building.

9:30 AM. The Federal Communications Commission (FCC) may hold an event titled "Open Commission Meeting". See, tentative agenda [4 pages in PDF]. Location: FCC, Commission Meeting Room, Room TW-C305, 445 12th Street, SW.

10:00 AM. The Senate Commerce Committee (SCC) will hold a hearing titled "Phantom Traffic". The SCC notice states that this hearing "will examine concerns regarding traffic over telephone networks that is sent without identifying information used for intercarrier billing purposes". Location Room 253, Russell Building.

10:00 AM - 12:00 NOON. The House Intelligence Committee (HIC) will hold a closed hearing titled "Cybersecurity Initiative". See, notice. Location: Room H-405, Capitol Building.

10:00 AM - 12:00 NOON. The American Enterprise Institute (AEI) will host an event titled "Is Free Trade Good for Your Health?". The speakers will be Ann Owen (Hamilton College), Paul Wolfowitz (AEI), Jeremy Norris (Hudson Institute), and Roger Bate (AEI). See, notice. The event is free and open to the public. Location: AEI, 12th floor, 1150 17th St., NW.

6:00 - 8:15 PM. The Federal Communications Bar Association's (FCBA) Wireless Practice Committee will host a program titled "Wireless Technologies: An Overview and Policy Discussion on What's Current and What’s Next". This event qualifies for continuing legal education (CLE) credits. Prices vary. The deadline for registrations and cancellations is 5:00 PM on April 8. See, registration form [PDF]. Location: Wiley Rein, 1776 K St., NW.

Day one of a three day conference hosted by the American Bar Association's (ABA) Section of Intellectual Property Law titled "23rd Annual Intellectual Property Law Conference". See, conference web site and brochure [PDF]. Location: Crystal Gateway Marriott Hotel, Arlington, VA.

Deadline to submit initial comments to the Federal Communications Commission (FCC) in response to its Notice of Proposed Rule Making (NPRM) regarding a broadcast television substitution in Riverside, California. See, notice in the Federal Register, March 11, 2008, Vol. 73, No. 48, at Pages 12928-12929.

Friday, April 11

2:30 - 4:30 PM. The DC Bar Association and others will host a program titled "Wired in the Workplace: Challenges Posed by Electronic Communication Devices and New Media". This program is part of the 2008 Judicial & Bar Conference. See, notice. The price to attend is $50. For more information, contact Verniesa Allen at 202-626-3439. Location: Reagan International Trade Center, 1300 Pennsylvania Ave., NW.

Day two of a three day conference hosted by the American Bar Association's (ABA) Section of Intellectual Property Law titled "23rd Annual Intellectual Property Law Conference". See, conference web site and brochure [PDF]. Location: Crystal Gateway Marriott Hotel, Arlington, VA.

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