4/15. The European Commission (EC) Union announced in a release that it sent a document titled "Statement of Objections" (SOO) to Google regarding its "comparison shopping service", and a second item that announces that it has instituted a "separate antitrust investigation into Google's conduct as regards the mobile operating system Android".

The EC released only news releases. It did not release the text of either the SOO or its notice to Google of its Android investigation. Google did not release either document either.

The two matters are separate investigations. Both are in the nature of antitrust regulation.

The EC has a long history of regulating and fining successful technology companies that are incorporated and based in the United States, for business activities that take place largely outside of the countries within the EC's jurisdiction, and for which U.S. regulators have already concluded a parallel proceeding.

These redundant EC proceedings have generated billions of dollars in fines for the EC, and much lucrative work for European lawyers, lobbyists, economists, and consultants.

EC Competition Commissioner Margrethe Vestager (at left) stated in a release that "Google has had market shares of more than 90% in general internet search in most EU Member States for many years" and that "Google artificially favours its own comparison shopping service and that this constitutes an abuse."

The EC also announced that Vestager will travel to the U.S. on April 15 through 20 to, among other things, meet with FTC Chairman Edith Ramirez. The FTC declined to take action against Google in early 2013.

Google's Amit Singhal stated in a release that "we respectfully but strongly disagree with the need to issue a Statement of Objections and look forward to making our case" regarding search.

He argued that "While Google may be the most used search engine, people can now find and access information in numerous different ways -- and allegations of harm, for consumers and competitors, have proved to be wide of the mark."

Google also issued a second release in which it defended its Android related business practices.

FTC Investigation Regarding Search Practices. On January 3, 2013, the U.S. Federal Trade Commission (FTC) announced in a statement that it will take no action against Google with respect to search bias or other search related practices. (At the same time, the FTC filed and simultaneously settled an administrative complaint against Google regarding its abuse of standards essential patents (SEPs) for which it was bound by FRAND commitments.) See, story titled "FTC Concludes Its Investigation of Google" TLJ Daily E-Mail Alert No. 2,504, January 7, 2013.)

The FTC wrote back in 2013 that it decided "to close the portion of its investigation relating to allegations that Google unfairly preferences its own content on the Google search results page and selectively demotes its competitors' content from those results".

It noted that complaining entities alleged that Google "unfairly promoted its own vertical properties through changes in its search results page" and "manipulated its search algorithms in order to demote vertical websites that competed against Google's own vertical properties."

The FTC concluded that "the evidence presented at this time does not support the allegation that Google’s display of its own vertical content at or near the top of its search results page was a product design change undertaken without a legitimate business justification. Rather, we conclude that Google’s display of its own content could plausibly be viewed as an improvement in the overall quality of Google’s search product. Similarly, we have not found sufficient evidence that Google manipulates its search algorithms to unfairly disadvantage vertical websites that compete with Google-owned vertical properties. Although at points in time various vertical websites have experienced demotions, we find that this was a consequence of algorithm changes that also could plausibly be viewed as an improvement in the overall quality of Google’s search results.

Just under four months before the FTC made its announcement regarding its Google investigation, staff of the FTC's Bureau of Competition (BOC) submitted to the full Commission a massive report.

This August 8, 2012 report is 116 pages. However, the FTC did not release this report, or even disclose its conclusions, back in January of 2013. This report was first disclosed to the public by the Wall Street Journal (WSJ) only last month.

The WSJ published a story on March 19, 2015, by Brody Mullins, Rolfe Winkler, and Brent Kendall titled "Inside the U.S. Antitrust Probe of Google".

The FTC/BOC staff concluded that there were violations of antitrust law pertaining to scraping (threatening to remove web sites from Google search results if they did not allow Google to use their content in specialized search results, such as maps), advertising data (making it more costly for advertisers that also used competing search engines), and exclusive deals (restricting other web sites its search results from working with competing search engines), but not to search bias.

See also, related story in this issue titled "Conclusions of the FTC's Staff Report Regarding Google".

EC Investigation Regarding Search Practices. The EC issued another release regarding search practices. It states the EC's "preliminary view that the company is abusing a dominant position, in breach of EU antitrust rules, by systematically favouring its own comparison shopping product in its general search results pages in the European Economic Area (EEA)."

This release states several "preliminary conclusions".

First, "Google systematically positions and prominently displays its comparison shopping service in its general search results pages, irrespective of its merits."

Second, "Google does not apply to its own comparison shopping service the system of penalties, which it applies to other comparison shopping services on the basis of defined parameters, and which can lead to the lowering of the rank in which they appear in Google's general search results pages."

Third, "Froogle, Google's first comparison shopping service, did not benefit from any favourable treatment, and performed poorly."

Fourth, "As a result of Google's systematic favouring of its subsequent comparison shopping services ``Google Product Search´´ and ``Google Shopping´´, both experienced higher rates of growth, to the detriment of rival comparison shopping services."

Finally, "Google's conduct has a negative impact on consumers and innovation. It means that users do not necessarily see the most relevant comparison shopping results in response to their queries, and that incentives to innovate from rivals are lowered as they know that however good their product, they will not benefit from the same prominence as Google's product."

EC Investigation Regarding Android. The EC stated in another release regarding the Android investigation that it has "opened formal proceedings against Google to investigate in-depth if the company's conduct in relation to its Android mobile operating system as well as applications and services for smartphones and tablets has breached EU antitrust rules. The Commission will assess if, by entering into anticompetitive agreements and/or by abusing a possible dominant position, Google has illegally hindered the development and market access of rival mobile operating systems, mobile communication applications and services in the European Economic Area (EEA)."

The EC also disclosed that this investigation will "focus on the following three allegations".

First, "whether Google has illegally hindered the development and market access of rival mobile applications or services by requiring or incentivising smartphone and tablet manufacturers to exclusively pre-install Google’s own applications or services".

Second, "whether Google has prevented smartphone and tablet manufacturers who wish to install Google's applications and services on some of their Android devices from developing and marketing modified and potentially competing versions of Android (so-called “Android forks”) on other devices, thereby illegally hindering the development and market access of rival mobile operating systems and mobile applications or services".

Third, "whether Google has illegally hindered the development and market access of rival applications and services by tying or bundling certain Google applications and services distributed on Android devices with other Google applications, services and/or application programming interfaces of Google."

See also, related story in this issue titled "Reaction to the EC's Google Announcement".

4/15. That Federal Trade Commission's (FTC) Bureau of Competition (BOC) August 8, 2012 staff report regarding Google contained the following conclusions:

"Staff concludes that Google's conduct has resulted -- and will result -- in real harm to consumers and to innovation in the online search and advertising markets. Google has strengthened its monopolies over search and search advertising through anticompetitive means, and has forestalled competitors' and would-be competitors' ability to challenge those monopolies, and this will have lasting negative effects on consumer welfare. Specifically, Staff believes that:
    1. Google has unlawfully maintained its monopoly over general search and search advertising, in violation of Section 2, or otherwise engaged in unfair methods of competition, in violation of Section 5, by scraping content from rival vertical websites in order to improve its own product offerings.
    2. Google has unlawfully maintained its monopoly over general search, search advertising, and search syndication, in violation of Section 2, or otherwise engaged in unfair methods of competition, in violation of Section 5, by entering into exclusive and highly restrictive agreements with web publishers that prevent publishers from displaying competing search results or search advertisements.
    3. Google has unlawfully maintained its monopoly over general search and search advertising, in violation of Section 2, or otherwise engaged in unfair methods of competition, in violation of Section 5, by maintaining contractual restrictions that inhibit the cross-platform management of advertising
campaigns."

Section 2 is a reference to Section 2 of the Sherman Act, which is codified at 15 U.S.C. § 2. It is the single firm conduct provision. There is a long history of enforcement of this section by the FTC and Department of Justice. Also, there exists a large body of case law construing this section.

Section 2 provides that "Every person who shall monopolize, or attempt to monopolize, or combine or conspire with any other person or persons, to monopolize any part of the trade or commerce among the several States, or with foreign nations, shall be deemed guilty of a felony, and, on conviction thereof, shall be punished by fine not exceeding $100,000,000 if a corporation, or, if any other person, $1,000,000, or by imprisonment not exceeding 10 years, or by both said punishments, in the discretion of the court."

Section 5 is a reference to Section 5 of the FTC Act, which is codified at 15 U.S.C. § 45. This is the FTC's main consumer protection statute.

It provides, in relevant part, that "Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful." The FTC under the Obama administration has been moving towards using this as an antitrust statute.

Section 5 of the FTC Act has hardly been invoked as an antitrust statute for decades. The FTC did rely upon Section 5 of the FTC Act in its administrative action against Intel in 2010, but that was settled by consent agreement, so the FTC's authority to proceed under Section 5 was not subjected to judicial review. See, story titled "FTC and Intel Settle Antitrust Claims" and related stories in TLJ Daily E-Mail Alert No. 2,018, August 4, 2010.

There is no body of case law that gives meaning to Section 5 as an antitrust statute. This is what makes it so attractive to advocates of aggressive FTC regulation. Invoking Section 5 may enable the FTC to regulate conduct that is not unlawful under the antitrust statutes -- the Sherman Act and Clayton Act.

Since the invocation of Section 5 would mean relying upon four words, without any body of case law, there is little to constrain the FTC in determining what constitutes a violation of Section 5. And, there is little to put companies on notice in advance as to what might constitute a violation of Section 5.

4/15. The European Commission (EC) announced that it has initiated two antitrust proceedings against Google related to certain search related business practices and Android related business practices.

Google issued a release in which it defended its search related business practices, and a second release in which it defended its Android related business practices.

Others divided on the merits of the EC's actions.

Criticism of the EC's Actions. James Waterworth of the Computer and Communications Industry Association (CCIA) stated in a release that "Competition online has never been as robust as it is today. With the Internet's global reach, open standards, and rapidly declining prices in hardware, software, and cloud computing tools, it has never been easier to start a national or global online business."

He added that "In the five years since the Commission opened its investigation of Google, consumers have more choices in how they navigate the Internet and find information. The rise of social networks, mobile apps and voice search tools -- like Apple's Siri and Amazon's Echo -- that help users explore the web illustrates that competition is driving innovation. Consumers are the primary beneficiary of this dynamic. This is not a characteristic of a stagnant market dominated by any single entity."

Berin Szoka of the Tech Freedom stated in a release that "Brusselcrats don’t know a good thing for consumers when they see it -- at least, if it's ‘Made in the USA,’ ... Android is the most open operating system on the market today, allowing users to install an endless variety of apps, even through alternative app stores not approved by Google. This new investigation sounds like a continuation of the Franco-German obsession with ‘replacing’ Google’ with European alternatives, which recently led the EU Parliament to call for Google’s breakup -- without actually waiting for any legal charges. Antitrust law shouldn't be a tool for protectionism -- or for technocrats to second-guess the preferences of European consumers."

Similarly, Geoffrey Manne of the International Center for Law and Economics, stated in a release that "Competition laws don't require Google or any other large firm to make life easier for competitors. To suggest that competition is thwarted unless Google provides “equal access” to other providers’ product search results on Google’s own general search results page is to deny the dynamic reality of today's market -- let alone the evolving market of the future."

Also, with respect to Android, Manne stated that "far from foreclosing competition, Android actually facilitates competition better than any of its competitors."

He elaborated that "Google has always offered its version of Android to equipment manufacturers on a royalty-free basis. Licensees are free to download, distribute and modify Android code as they wish. OEMs can create mobile devices that run “pure” Android or they can apply their own user interfaces — and consumers decide which apps they download on Android devices. Apps that compete directly with Google such as Facebook, Amazon, Microsoft Office, and Expedia are easily available to Android users; and many of these apps come pre-loaded onto Android devices."

Praise for the EC's Actions. Fair Search, a group of companies that includes Microsoft, Oracle, Nokia, Expedia, and TripAdvisor, stated in a release that the EC's "actions are significant steps toward ending Google's anti-competitive practices, which have harmed innovation and consumer choice. More than 30 companies and consumer organizations filed complaints concerning Google's abuse of its dominance in search. Google's abuses have devastated rivals, from mapping to video search to product price comparison."

Fair Search is dominated by large U.S. based companies. However, Allegro, a Poland based online auction web site, and Foundem, Buscape, and Twenga, comparison shopping web sites based in the United Kingdom, Brazil and France, respectively, are also members.

Similarly, John Simpson of the U.S. based Consumer Watchdog stated in a release that "Google continues to manipulate its search results in an unfair and anticompetitive way".

He added that the FTC "failed to stop the abuses despite a staff recommendation that charges be filed. I'm optimistic the Europeans will end the Internet giant's search manipulation and that Google will implement the required changes on this side of the Atlantic as well."

Simpson also stated that "Google has one of the biggest lobbying operations in Washington and is executives have close ties to the Obama Administration ... Could those connections have helped the Internet giant get what was a virtual free pass back in 2013?"

The Consumer Watchdog is a frequent critic of the business practices of Google.

The House will return from its Easter recess. It will meet at 2:00 PM for legislative business. The House will consider several items under suspension of the rules, including HR 601 [LOC | WW], the "Eliminate Privacy Notice Confusion Act", a bill to amend the Gramm Leach Bliley Act to create an exception to the annual privacy notice for financial institutions that have not changed their policies or practices since their last notice. Votes will be postponed until 6:30 PM. See, Rep. McCarthy's schedule.

The Senate will return from its Easter recess at 2:00 PM.

Deadline to submit comments to the Department of Homeland Security's (DHS) U.S. Citizenship and Immigration Services (USCIS) regarding its collection of data related to its E-Verify program. See, notice in the Federal Register, Vol. 80, No. 28, February 11, 2015, at Pages 7625-7626.

Deadline to submit comments to the Office of the U.S. Trade Representative (OUSTR) regarding its the preferential tariff treatment and other customs related provisions of the U.S. Australia Free Trade Agreement. See, notice in the Federal Register, Vol. 80, No. 27, February 10, 2015 at Pages 7303-7318.

Deadline to submit reply comments to the Federal Communications Commission (FCC) in response to its Second Further Notice of Proposed Rulemaking and Seventh Further Notice of Proposed Rulemaking (2ndFNPRM and 7thFNPRM) regarding collection of data by FCC Form 323, titled "Ownership Report for Commercial Broadcast Stations", and by FCC Form 323-E, titled "Ownership Report for Non Commercial Broadcast Stations". The FCC adopted this NPRM February 11, 2015, and released it on February 12, 2015. It is FCC 14-19 in MB Docket No. 07-294 and MD Docket. No. 10-234. See, notice in the Federal Register, Vol. 80, No. 38, February 26, 2015, at Pages 10442-10452.

The House will meet at 10:00 AM for morning hour, and at 12:00 PM for legislative business. The agenda includes consideration of HR 1152 [LOC | WW], the "IRS Email Transparency Act", under suspension of the rules. See, Rep. McCarthy's schedule.

2:00 PM. The House Judiciary Committee (HJC) will hold a hearing on HR 9 [LOC | WW], the "Innovation Act". The witnesses will be Michelle Lee (head of the USPTO), Kevin Kramer (Yahoo's Deputy General Counsel for IP), Robert Armitage, David Simon (Salesforce.com's SVP for IP), and Hans Sauer (Biotechnology Industry Organization). Webcast. See, notice. Location: Room 2141, Rayburn Building.

2:30 PM. The Senate Intelligence Committee (SIC) will hold a closed hearing on undisclosed matters. No webcast. See, notice. Location: Room 219, Hart Building.

6:30 PM. The Consumer Electronics Association (CEA) will host an event titled "Digital Patriots Dinner". There will be a reception at 6:30 PM. Dinner will be at 7:30 PM. Location: National Building Museum, 401 F St., NW.

Deadline to submit reply comments to the Federal Communications Commission (FCC) in response to its Notice of Proposed Rulemaking (NPRM) regarding FCC regulated entities' public inspection files. The FCC proposes to require that cable operators, satellite TV providers, broadcast radio licensees, and satellite radio licensees publish certain information to an FCC operated public access web site. See, NPRM [52 pages in PDF]. The FCC required broadcast television licenses to publish their public inspection disclosures in an FCC web site in 2012. The FCC now proposes to expand this requirement to others. The FCC adopted this item on December 17, 2014 and released it on December 18, 2014. It is FCC 14-209 in MB Docket No. 14-127. See, notice in the Federal Register, Vol. 80, No. 30, February 13, 2015, at Pages 8031-8052.

The House will meet at 10:00 AM for morning hour, and at 12:00 PM for legislative business. See, Rep. McCarthy's schedule.

The Senate will meet at 9:30 AM.

10:00 AM. The House Judiciary Committee (HJC) will meet to mark up three bills: HR 427 [LOC | WW], the "Regulations From the Executive in Need of Scrutiny Act of 2015", HR 1759 [LOC | WW], the "All Economic Regulations are Transparent (ALERT) Act of 2015", and HR 758 [LOC | WW], the "Lawsuit Abuse Reduction Act of 2015". Webcast. See, notice. Location: Room 2141, Rayburn Building.

10:00 AM. The House Appropriations Committee's (HAC) Subcommittee on Financial Services and General Government will hold a hearing on the FY 2016 budget for the Securities and Exchange Commission (SEC). The witness will be SEC Chairman Mary Jo White. See, notice. Location: Room 2359, Rayburn Building.

2:00 PM. The Senate Appropriations Committee's (SAC) Subcommittee on Homeland Security will hold a hearing titled "From Protection to Partnership: Funding the DHS role in Cybersecurity". The witnesses will be Andy Ozment (Assistant Secretary, DHS/NPPD Office of Cybersecurity and Communication), Luke McCormack (DHS Chief Information Officer), and Greg Garcia (Financial Services Sector Coordinating Council). See, notice. Location: Room 138, Dirksen Building.

6:00 - 8:00 PM. The Consumer Electronics Association (CEA) will host an event titled "CES on the Hill". There will be a media preview at 5:30 PM. This is an invitation only event. Location: Rayburn Building Cafeteria, Room B-357.

EXTENDED FROM FEBRUARY 17. Extended deadline to submit comments to the Department of Homeland Security's (DHS) U.S. Coast Guard (USCG) in response to its notice in the Federal Register (FR) requesting comments regarding maritime cyber security standards. See, original notice in the FR, Vol. 79, No. 243, December 18, 2014, at pages 75574-75575, and extension notice in the FR, Vol. 80, No. 31, February 17, 2015, at Pages 8336-8337.

The House will meet at 9:00 AM for legislative business. See, Rep. McCarthy's schedule.

10:00 AM. The Senate Judiciary Committee (SJC) will hold an executive business meeting. The agenda includes consideration of the nominations of Sally Yates (to be Deputy Attorney General), Kara Stoll (to be a Judge of the U.S. Court of Appeals for the Federal Circuit), and Roseann Ketchmark (USDC/WDMissouri). Live and archived webcast. See, notice. Location: Room 226, Dirksen Building.

11:00 AM. The House Commerce Committee's (HCC) Subcommittee on Commerce, Manufacturing and Trade will hold a hearing on HR __, the "Targeting Rogue and Opaque Letters Act" or "TROL Act". The witnesses will be David Long (Kelley Drye, on behalf of Innovation Alliance), Gregory Dolin (Baltimore University School of Law), Diane Lettelleir (J.C. Penney Corporation, on behalf of United for Patent Reform), and Charles Duan (Public Knowledge). Webcast. See, notice. Location: Room 2123, Rayburn Building.

2:30 PM. The Senate Intelligence Committee (SIC) will hold a closed hearing on undisclosed matters. No webcast. See, notice. Location: Room 219, Hart Building.

Rep. McCarthy's schedule states that "no votes are expected in the House".

Supreme Court conference day. See, 2014-2015 calendar. Closed to the public.

10:30 AM. The Federal Communications Commission (FCC) will host an event titled "Open Commission Meeting". Open to the public. Webcast. Location: FCC, Commission Meeting Room, 445 12th St., SW.

2:00 - 5:00 PM. The American Enterprise Institute (AEI) will host an event titled "Honeypots and Sticky Fingers: The Electronic Trap to Reveal Iran’s Illicit Cyber Network". The keynote speaker will be Keith Alexander (IronNet Cybersecurity). He was until recently the head of the NSA and the U.S. Cyber Command. The other speakers will be Frederick Kagan (AEI) and Tommy Stiansen (Norse Corporation). Free. Open to the public. No CLE credits. See, notice. Location: AEI, 12th Floor, 1150 17th St., NW.

3:00 PM. Deadline for members of the House of Representatives to submit proposed amendments to the House Rules Committee to HR 1560 [LOC | WW], the "Protecting Cyber Networks Act". See, notice.

10:00 AM. The Senate Commerce Committee (SCC) will hold a hearing titled "Advancing Telehealth Through Connectivity". The witnesses will be Kristi Henderson (University of Mississippi Medical Center), Jonathan Linkous (American Telehealth Association), Chris Gibbons (FCC), and Todd Rytting (Panasonic). Webcast. Location: Room 253, Russell Building.

11:30 AM - 1:00 PM. The Center for Strategic and International Studies (CSIS) will host a speech by Kevin Rudd (former Prime Minister of Australia) titled "U.S. China 21: Constructive Realism, Common Purpose". The other speakers will be Brent Scowcroft and Christopher Johnson. See, notice. Webcast. Location: CSIS, 1616 Rhode Island Ave., NW.

1:00 - 2:30 PM. The American Bar Association (ABA) will host a webcast panel discussion titled "Coping with COPPA and Drafting Effective Browse and Click Wrap Agreements". The speakers will be Adam Losey, Stephen Chow, and Leonard French. Prices vary. CLE credits. See, notice.

1:00 - 2:30 PM. The American Bar Association (ABA) will host a webcast panel discussion titled "Best Practices for Incident Response and Cyber Coverage". The speakers will be George Huff, James Rhyner, John Dimaria, and Wesley Sunu. Prices vary. CLE credits. See, notice.

Deadline to submit requests to testify at the U.S. International Trade Commission's (USITC) May 5, 2015 hearing titled "Trade and Investment Policies in India, 2014-2015". See, notice in the Federal Register, Vol. 80, No. 38, February 26, 2015, at Page 10513.

9:00 AM - 5:30 PM. Day one of a two day meeting of the National Science Foundation's (NSF) Advisory Committee for Cyberinfrastructure. See, notice in the Federal Register, Vol. 80, No. 37, February 25, 2015, at Pages 10164-10165. Location: NSF, 4201 Wilson Blvd., Arlington, VA.

10:00 AM - 12:30 PM. The Brookings Institution (BI) will host a panel discussion titled "Taiwan’s Shifting Political Landscape and the Politics of the 2016 Elections". See, notice. Location: BI, 1775 Massachusetts Ave., NW.

11:00 AM. The House Small Business Committee will hold a hearing titled "Small Business, Big Threat: Protecting Small Businesses from Cyber Attacks". The witnesses will be Steve Grobman (Intel), Todd McCracken (National Small Business Association), and Dan Berger (National Association of Federal Credit Unions). Webcast. See, notice. Location: Room 2360, Rayburn Building.

8:30 AM - 1:00 PM. Day two of a two day meeting of the National Science Foundation's (NSF) Advisory Committee for Cyberinfrastructure. See, notice in the Federal Register, Vol. 80, No. 37, February 25, 2015, at Pages 10164-10165. Location: NSF, 4201 Wilson Blvd., Arlington, VA.

Deadline to submit pre-hearing briefs and statements in advance of the U.S. International Trade Commission's (USITC) May 5, 2015 hearing titled "Trade and Investment Policies in India, 2014-2015". See, notice in the Federal Register, Vol. 80, No. 38, February 26, 2015, at Page 10513.

Supreme Court conference day. See, 2014-2015 calendar. Closed to the public.

Deadline to submit comments to the Department of the Treasury's (DOT) Financial Crimes Enforcement Network (aka FinCEN) regarding in response to three notices in the Federal Register (FR) regarding extending the information collection mandates to support the financial surveillance activities of the FinCEN. See, notice regarding the requirements imposed on money services businesses, operators of credit card systems, and others (FR, Vol. 80, No. 35, February 23, 2015, at Pages 9505-9506), notice regarding the requirement imposed on insurance companies, non-bank mortgage lenders, and others (FR, Vol. 80, No. 35, February 23, 2015, at Pages 9504-9505), and notice regarding the requirements imposed on brokers or dealers in securities and futures commission merchants (FR, Vol. 80, No. 35, February 23, 2015, at Pages 9506-9507).

10:00 AM - 3:30 PM. The Department of Health and Human Services' (DHHS) Agency for Healthcare Research and Quality (AHRQ) will host an event titled "Meeting for Software Developers on the Common Formats for Patient Safety Data Collection and Event Reporting". See, notice in the Federal Register, Vol. 80, No. 28, February 11, 2015, Pages 7605-7606. Location: AHRQ, Eisenberg Conference Center, 540 Gaither Road, Rockville, MD.

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