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.
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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.
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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.
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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.
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Washington Tech Calendar
New items are highlighted in red. |
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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.
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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).
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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.
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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.
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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.
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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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