ASIL Launches International Law 2012

ASIL has just launched International Law 2012, a web-based initiative to gather and disseminate information to the public and the news media about where the U.S. presidential candidates stand on important international legal issues. Click here to view the presidential candidates' views on issues including the intersection of the Geneva Conventions and counter-terror operations; international trade and the World Trade Organization; efforts to regulate climate change; and the continued viability of the nuclear non-proliferation regime and regulation of weapons of mass destruction.

Hofstra Law Launches First ABA Accredited Programs in Cuba and Ecuador

FOR IMMEDIATE RELEASE: March 28, 2012

Hofstra Law Is the First American Law School to Seek ABA Accreditation for
Study Abroad in Cuba, Ecuador

Hempstead, N.Y. — In response to the U.S. government’s recent lifting of the ban on educational travel to Cuba, the Maurice A. Deane School of Law at Hofstra University has established a Cuba Field Study program to be conducted in Havana during the Law School’s spring break.

Approximately 30 students will participate in the Cuba Field Study: Export Laws and Export Controls, which will run from March 31-April 7. Participating students will stay at the Hotel Ambos Mundos, and classes will be held at the National Museum of Fine Arts of Havana, the former Supreme Court of Justice building, in Old Town Havana.

“Hofstra Law is excited to be one of the first law schools to take advantage of the government’s endorsement of educational exchange with Cuba, and we hope that our program will provide students with an academically and culturally enriching experience,” said Hofstra Law Dean Nora V. Demleitner. “This expansion of our study abroad offerings also responds to the complexities of the legal field which increasingly demands future lawyers to be prepared for an ever more interconnected world.”

According to the American Bar Association (ABA), Hofstra Law is the first American law school to seek accreditation from the ABA for a study abroad program in Cuba. An ABA inspector will be onsite during the field study to ensure that the program meets all standards set forth for foreign-program accreditation.

“Students have a limited amount of time to soak up as many educational experiences in law school as they can,” said Jeffrey Dodge, assistant dean for global initiatives & multicultural affairs. “Trade regulations between the United States and other countries can change quickly, and as a result there is an increased need for law school graduates to be able to navigate the complex waters of U.S. export laws and controls on behalf of international business clients.”

The Cuba Field Study will be taught by Assistant Professor Juli Campagna, who has studied, practiced and taught law in Europe, Asia and Latin America. Campagna will draw on her background in international business and transactional law to teach students about such U.S. laws as the Export Administration Act, the International Emergency Economic Powers Act and the amendments to IEEPA pursuant to the International Emergency Economic Powers Enhancement Act. Students will also learn the key licensing provisions and procedures of the Export Administration Regulations (EAR) and examine the Trading With the Enemy Act.

“Hofstra Law’s Cuba Field Study is a unique opportunity for students to gain practical legal knowledge as well as to experience a culture that is vastly different from that of a more traditional study abroad program,” said Campagna. “Most of our students have never been to a Communist country before, and the cultural differences between the U.S. and Cuba certainly will add another dimension to their learning experience.”

Demleitner, Campagna and Dodge traveled to Cuba last year as part of a government-sponsored education mission to explore educational exchange opportunities there. This new program is a direct outgrowth of that visit, and as a result of her experience on the ground in Cuba, Campagna has organized a series of field trips and guest lecturers as part of the course.

Hofstra Law is also offering a new Ecuador Field Study: Special issues in International Environmental Law in Otavalo during the upcoming spring break. In this program, students will learn about special issues in international law, such as climate change policy responses, protection of forests and the role transnational corporations play in the creation and resolution of international environmental challenges. Students will also learn about topics specific to Ecuador, such as the high-profile litigation against Chevron for alleged environmental and social harms in Ecuador’s Amazon region, and the rights given to nature in the new Ecuadorian constitution. The course will be taught by Carol Casazza Herman ’84, the visiting practitioner-in-residence in environmental law.

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The Maurice A. Deane School of Law at Hofstra University prepares passionate students to make an impact in their communities and beyond. Accredited by the American Bar Association and ranked in the top 100 law schools nationwide, Hofstra Law is located on the campus of Hofstra University in Hempstead, New York. Along with a Juris Doctor (J.D.) degree program, the Law School offers Master of Laws (LL.M.) degree programs in American Legal Studies (for foreign law graduates) and Family Law.

Article from the NY Times on Overseas Internships

Overseas Internships Can Benefit, for a Price

By PHYLLIS KORKKI

AS the world becomes more interconnected, employers are clamoring for global experience in their work forces. So it should come as no surprise that college internships are going global, too.

Such internships can be pricey, because air fare is generally not included, a paycheck is unlikely and it can be hard to arrange them without outside help. But they can offer a window into a different business culture, along with a chance to practice language skills and perhaps earn college credit.

“I think if a student is interested in pursuing any sort of career outside of the U.S., it’s a great idea to immerse yourself in the environment” through an overseas internship, said Lauren Berger, author of “All Work, No Pay” and chief executive of Internqueen.com, an online internship site.

And she doesn’t think you need rich parents to intern abroad. Financial aid could be available, she said, or “students can choose to work hard during the year and save up for something like that.”

Stephen Keil, a sophomore majoring in international relations and minoring in French at Syracuse University, worked full time last summer to save for his fall internship with theCouncil of Europe in Strasbourg, France. The university arranged the internship.

Mr. Keil did research for the council’s Pompidou Group, which combats drug abuse and drug trafficking. He is considering a career in the State Department, so the experience was very useful, he said, “and my French improved greatly.”

During the school year, Syracuse students who study abroad have the option of pursuing internships in addition to taking classes, but their tuition is the same regardless. Beyond tuition, program fees (including housing) range from $5,735 to $7,500, and substantial financial aid is available, said Suzanne Shane, program director at SU Abroad. In summer, students may pursue a full-time internship for credit without taking other courses. For this option, they pay about $1,000 a credit, as well as fees ranging from $2,000 to $3,840 when lodging is part of the package.

In the United States, a debate has arisen over the fairness of unpaid internships. So the idea of not receiving a salary, and in fact paying thousands of dollars more while putting in almost three months of work abroad, may not sit well with some students. But others feel that paying to have internships arranged helps to ensure their quality.

Joe Roma, director of programs for Intrax Internships Abroad, said: “We do a great deal of work seeking host companies that are going to provide value to the student.” Intrax is a for-profit global education company whose internship arm offers positions in Asia, Latin America and Europe.

Intrax’s internship programs cost from around $5,600 to $7,900. That includes placement, visa help, housing, a global skills training course, cultural activities, insurance and individual support, he said. Airfare is extra, and very rarely are students paid. “Some companies offer a stipend; we don’t arrange that,” Mr. Roma said.

Cheryl Miyake, a junior at Stanford majoring in sociology, got an internship in Beijing last summer through Intrax after meeting a company representative at a career fair. She interned for a local company that offers music and English immersion classes to children.

“Not only did I get to travel and work on my Mandarin speaking skills, but I really got to understand what Chinese business culture is like,” she said, gaining a better sense of “guanxi,” a code of building relationships that is important to conducting business.

She was relieved that Intrax handled setting up a work visa, which can be hard to obtain in China, and arranged housing in Western-style apartments.

While in Beijing, she was part of a group of students that took training courses arranged by Intrax. Being able to meet others who, like her, were undergoing a certain amount of culture shock, was helpful, she said.

OF course, students who are already abroad can look for positions on their own. But Ms. Berger advises students to tread carefully. Studying abroad is such a valuable, pleasurable and short-term experience that it could add more stress to work as well, she said. As an alternative, she suggests that students arrange 10 or so informational interviews with professionals while they take classes abroad.

“People have internships on the brain” these days, she said, but it’s important to choose the right time and place for them.

Hofstra Law Announces Program to Cuba

I am delighted to officially announce Hofstra Law's second new spring break abroad program.  The Cuba Field Study: Export Laws and Export Controls will take place from Saturday, March 31 to Saturday, April 7, 2012.  The one credit course will be taught by Professor Juli Campagna.  On the Cuba Field Study, students will learn about the Export Administration Act, the International Emergency Economic Powers Act (IEEPA), and the amendments to IEEPA pursuant to the International Emergency Economic Powers Enhancement Act.  Students will learn the key licensing provisions and procedures of the Export Administration Regulations.  Another topic of the course is the Trading with the Enemy Act.  While the course cannot focus on this Act in depth over one week, the professor will look at the restrictions on travel to Cuba that come under it.  As many of you know, there are significant restrictions on travel to Cuba.  The U.S. government opened Cuba for educational travel last year, making this the first known student law program to enter the country. Students on the program must travel together down and back to Cuba on a U.S. government approved chartered flight.  Visit the website to learn more about all the things included in the program fee.

The Cuba Field Study program is open to second, third, and fourth year J.D. students as well as all LL.M. students.  No separate tuition will be charged for the program as it's included in the spring semester credit load.  A program fee is assessed to cover student's housing, food, flight to/from Havana, and more in Cuba.  The application deadline is Friday, January 27, 2012.

An information session is scheduled for Wednesday, January 11 at Noon in room 242.  Please plan to attend if you are interested in learning more about both of the spring break opportunities and ask questions of the professors teaching on them.  Visit the program webpages for more information.  A poster on the Cuba program is attached.  Students from all ABA law schools may participate in these programs.

Ecuador Field Study:  http://law.hofstra.edu/Ecuador 

Cuba Field Study:  http://law.hofstra.edu/Cuba 

I look forward to seeing many of you at the information session next week.

From The Chronicle of Higher Education

January 6, 2012
Despite Dismal Job Market, Many Law Students Forgo Key Opportunities on Campus
By Libby Sander

Today's law graduates face a challenging job market and roiling global economy, but findings from a survey of more than 33,000 J.D. students suggest that they're not doing all they could to burnish their skills.

"Many law students still seem to think of law school as an educational hurdle to surmount rather than as preparation for professional life," Thomas D. Morgan, a professor at George Washington University Law School, wrote in a foreword to a report on the 2011 Law School Survey of Student Engagement, released on Friday by Indiana University at Bloomington's Center for Postsecondary Research. "The data suggest that students may not be taking full advantage of the opportunities law school affords them to prepare for the world they are about to enter."
That world is less eager for new lawyers, he said. And the current legal landscape is shaped by three powerful forces that recent graduates would be wise to heed: a competitive job market that rewards specialists, not generalists; a shift toward collaborative work, with fellow lawyers and other experts; and a global outlook that increasingly demands international contacts and at least some knowledge of foreign law.

Yet more than a quarter of respondents to the survey said they had never sought out a mentor—a professor or a practicing lawyer—who could discuss potential practice concentrations. Fewer than one-third said they worked frequently with other students on class projects, says the report, "Navigating Law School: Paths in Legal Education."

Responses on international contacts were "particularly troubling," Mr. Morgan noted.
As part of the most recent annual survey, researchers focused on a smaller group—7,500 American J.D. students at 22 law schools—to examine their awareness of international students pursuing graduate law degrees on their campuses. The Americans indicated that their interaction with the international students was very limited, in both social and academic settings. Less than 6 percent of the American respondents, for instance, reported interacting frequently with the international students in informal study activities. (The percentage of students reporting social interactions was higher.)

That limited contact is a missed opportunity for both groups, Mr. Morgan said.
The report's authors, meanwhile, recommended that law schools reconsider how they prepare students to work in a global economy. "If law schools want their students to learn in a more internationally diverse environment," the report states, "they must affirmatively structure the law-school experience to encourage interaction."

This year's survey also delved into alternative paths some law students take toward earning their degree: attending part time or transferring to a different school. Approximately 14 percent of respondents were part-time students; roughly 3 percent had begun their legal education at a different institution and transferred.

When it came to the amount of time spent studying and preparing for class, both groups reported experiences very similar to those of full-time law students who had attended only one school. In other areas, there were exceptions: Part-time students, for instance, were less likely than their full-time peers to take advantage of career-counseling services, and participated less frequently in experiential learning.

International Institute of Space Law Announces Moot Court Competition Problem

The International Institute of Space Law (IISL) has released the Problem for the 21^st Manfred Lachs Space Law Moot Court Competition in 2012. Also, the Manfred Lachs Trophy has now found a permanent home in the Peace Palace, the seat of the International Court of justice (ICJ).

The student competition is based on a hypothetical space law dispute before the International Court of Justice (ICJ). Preliminary competitions will be held between March and June 2012 in North America, Europe and the Asia Pacific. A new African regional round is being planned for 2012. The winning teams of the regional rounds will meet in the World Finals in Naples, Italy in October 2012 during the annual IISL Colloquium on the Law of Outer Space, in the framework of the International Astronautical Congress (IAC). The Final Round is traditionally judged by three judges of the International Court of Justice.

The “Case concerning On-orbit Collision, Non-cooperative Satellite Removal, and Damages”, is available at http://www.iislweb.org/docs/2012problem.pdf.

The 2012 Problem challenges the students to research and debate the legal issues posed by space debris including mitigation and removal measures, and the use of satellites as a tool to combat natural disasters on Earth.

The contact details for the Regional Rounds are:

Asia Pacific:             Dr. Yuri TAKAYA (Ms.) - lachsmoot-asiapacific@iislweb.org

Europe:                         Mr. Raphael Milchberg - lachsmoot-europe@iislweb.org

North America:             Dr. Milton (Skip) Smith - lachsmoot-northamerica@iislweb.org

More information about the competition can be found at: http://www.iislweb.org/lachsmoot 

More information about the IISL can be found at: http://www.iislweb.org/.

Joining the International Bar Association

The International Bar Association (IBA), established in 1947, is the world’s leading organisation of international legal practitioners, bar associations and law societies. The IBA influences the development of international law reform and shapes the future of the legal profession throughout the world, whilst providing its members with unique international networking and professional development opportunities.

Through their new student membership initiative the IBA aims to enhance the study of law by giving students access to the extensive range of academic and professional materials produced by the IBA and its broad range of committees and sections, including all newsletters, journals, magazines, webcasts and reports. As well as some content specifically for students, such as opportunities to have your work published, vocational interviews, group projects and competitions.

Additionally, IBA membership includes a broad range of international legal practitioners, providing students with the opportunity to familiarise themselves with future employers and their work. Their membership includes top international law firms such as Linklaters, Clifford Chance, Allen & Overy LLP, White & Case LLP, Slaughter and May, and Freshfields Bruckhaus Deringer LLP, as well as 195 bar associations and law societies, over

45,000 individual lawyers, and more than 1,000 corporate counsel members representing hundreds of multinational corporations including Coca-Cola, IBM, ExxonMobil and AT&T. And now, law students can be members.

Student membership is charged at an annual fee of £20. However, students who sign up now will receive complementary membership for the rest of 2011, as well as membership for the duration of 2012.

If you are interested in joining the IBA take at look at their website.

Hofstra Law Day of Service - September 17

On Saturday, September 17, Hofstra Law School will recognize the 9/11 National Day of Service and Remembrance by participating in three community service projects in Nassau County.  The projects are with Habitat for Humanity, the Garden City Bird Sanctuary, and the Long Beach Animal Rescue.  All projects will start by meeting at Hofstra Law at 8:15 a.m. where breakfast will be provided.  Volunteers will then carpool to the sites.  Habitat for Humanity asks that people stay until 3 p.m. and lunch will be provided.  Volunteers on this project will assist in building a home for a local family in need.  The project at the Garden City Bird Sanctuary ends at Noon and involves a multitude of tasks at varied skill levels - painting, raking, planting, and general work outdoors.  The Long Beach Animal Rescue needs assistance preparing animal cages for adoption visits.  Volunteers on this project are free to leave by Noon.  In total, we are looking for 60 students, faculty and staff to volunteer - the majority to serve on the Habitat for Humanity and Garden City Bird Sanctuary projects.  Family members and friends are welcome to join us.

The 9/11 Day of Service and Remembrance was originally started in 2002 by David Paine and Jay Winuk.  Tragically, Jay's younger brother Glenn was one of the nearly 3,000 people killed on 9/11. Glenn Winuk was a Hofstra Law alum and partner at the international law firm Holland & Knight LLP. When the World Trade Center was attacked, Glenn helped to evacuate his law offices, then raced into the WTC's South Tower to participate in the rescue efforts. In 2003, David and Jay formed the nonprofit group MyGoodDeed and successfully advocated Congress for 9/11 to serve as the National Day of Service and Remembrance.  

We hope many of you will join the Hofstra Law community in recognizing 9/11 in a day of service to others.  To sign up, please email Joanne Masci at lawjzm@hofstra.edu with your project preference and the names of the volunteers in your group.  If you have any questions on the logistics, please feel free to contact me directly. 

Announcement RE Volunteer Opportunities with Americans for Informed Democracy

Summer is soon coming to an end (boo!). But don't be too sad - we have some great opportunities for you to get involved in important and exciting campaigns this school year (yeah!).
We still have a few spots available on our climate change, hunger, sex & justice, and security campaign teams! Are you an inspired young person with an interest in mobilizing your peers to understand and take action on these issues? Looking for a chance to hone your organizing and leadership skills? Then we need you!

We are recruiting the following positions for each of our four teams:

    * Coordinator: leads strategy development and supports other team members
    * Organizer: recruits other interested students to join the cause
    * Issue Analyst: monitors, analyzes and writes about related news and debates
    * Communications Guru: spreads the word about team activities, events and information via print and social media (Facebook, Twitter, etc.)
These are year-long, volunteer positions. We're looking for multiple people for each position, on each campaign. Details and job descriptions are available on our website. Each campaign team will plan their strategy for the coming year this August.
Here's a quick pitch for each issue:
Hunger Campaign Team: Overcoming chronic hunger is one of the most crucial challenges facing our world today. Each day nearly 1 billion people across the world go without enough food to lead a productive and healthy life. As a result, problems like extreme poverty, disease, conflict, and climate change become all the more devastating and entrenched. Ending hunger is a vital step towards making this world a more equal, just, peaceful, and sustainable place. We still have spots available for outstanding young adults from across the nation to come together and campaign to end the grave injustice of global hunger.
Sex & Justice Campaign Team:  Sexual and reproductive health and rights encompass a wide variety of issues that pose challenges especially for women and adolescents in developing countries. Girls are becoming mothers instead of going to secondary school. Sexually transmitted infections are spreading. Mothers are dying in childbirth. Gender based violence persists. Even though these issues are complex, we have the power to advocate for change. Stand up against injustice and inequality. Join the sex & justice campaign team!
Climate Change Campaign Team: When it comes to tackling climate change, today’s young people know there’s not a second to waste! All around the world, young people are rising up to tell our leaders that we won’t stand for any more empty promises, failed agreements, and injustice. From our college campuses and city halls to COP conferences worldwide, our voices are being heard, and we’re seeing great progress, especially at the local level. But critical battles around climate adaptation and emissions continue, and we need your voice more than ever! We’re offering outstanding individuals the opportunity to join our Climate Change campaign team and lead our network around this critical issue! Apply today to make your vision for a sustainable, just planet a reality.
Security Campaign Team: This September marks the tenth anniversary of 9/11. Are we secure? How do we define security? How much should we be spending on defense, versus other approaches like diplomacy and development? The Security Campaign Team will inspire student debate around these and other critical questions. Hot topics will include US engagement in Iraq and Afghanistan, nuclear weapons, and defense spending. Join us!

To apply, please send a statement of interest to opportunities@aidemocracy.org. Positions will be filled on a rolling basis. Hurry – we only have a few spots left!
Have questions? Contact us at opportunities@aidemocracy.org.

National Law Journal Interviews New ABA international Law Section Chair

ABA Section to Focus on Protections for the Disabled Internationally

Amanda Bronstad


07-27-2011

Michael Burke, a corporate partner at Arnall Golden Gregory in Washington, D.C., takes over as chairman of the American Bar Association's Section of International Law on Aug. 9. One of his priorities is to focus on the rights of the disabled worldwide. During an interview with The National Law Journal Burke talked about the disabled, the legal implications of the debt crisis sweeping Europe, the burgeoning Chinese economy and the democratic shifts in the Middle East. He also discussed increased government enforcement of the Foreign Corrupt Practices Act.

This article has been edited for length and clarity.

NLJ: What issues do you intend to focus on during your term as chairman of the ABA's international law section?

Michael Burke: We're going to start a task force on legal empowerment of the poor worldwide -- access to justice, things like that.

Our section worked on recommendations that the United States formally sign on to the United Nations Convention on the Rights of Persons with Disabilities. I would like to push these forward. My mother is actually a paraplegic and has been for almost 30 years. Looking at the Americans with Disabilities Act and comparing that with what people with physical disabilities face outside the United States, it's one of those areas where we should feel lucky we're in the United States and have something like the ADA on the books. It's really a place where the U.S. can advocate for the rights of disabled persons in other countries and in some ways lead by example. That hit home for me.

The second priority is legal empowerment of the poor. We have in our section a pretty deep commitment on rule-of-law issues. Part of it is property rights -- ensuring people across different economic spectrums have property rights and can really not only protect their property but also can leverage it. In some jurisdictions, it's almost impossible for people to go to court to protect their rights as an economic matter. That's one area that really shouldn't be. We like to think the legal systems as constructed are accessible to everybody, regardless of what their economic status is.

NLJ: The annual conference for the ABA's international law section is in Dublin, Ireland. You've done several deals in Ireland, where a debt crisis has pummeled the country. How do you see the country's economic condition affecting legal work there?

M.B.: For financial services, which is where a lot of deals in the late 2000s in Ireland were, that work is significantly lower than it was -- placements of securities offerings on Irish exchanges, things like that. There is only really one bank that's kind of left standing on its own out of five domestic banks that were active five to six years ago.

In other sectors, the Irish economy is actually doing pretty well. Their export sector is doing really well -- everything from agriculture to finished products. They're doing a lot in the green energy space, both building -- for example, in wind energy the turbines -- and providing the services to wind farms to get them up and running.

Ireland remains an active place for setting up a European or non-U.S. headquarters of companies because they've got a 12.5 percent corporate tax rate, and that makes it hugely attractive for U.S. companies and other companies that want to set up and use Ireland as a jumping off point for business operations elsewhere in Europe.

NLJ: In Europe, though, many countries, most prominently Greece and Portugal, have failed to emerge from their own debt crises. How do you see this affecting legal work in Europe?

M.B.: There's a huge difference. The German economy seems to be doing pretty well and business transactional work in Germany -- Scandinavia also, Sweden is doing well -- is continuing on a pace it was before. In parts of Europe, the level of legal work is the same. Obviously, for folks who've got a concentration in one of these vulnerable economies, you'll see a pretty big slowdown, because people want the debt situation to sort itself out before making any significant moves on the business side. It's in a holding pattern, with the potential to slow down significantly in the weaker European economies.

NLJ: Your practice focuses a lot on China. This market is particularly hot but comes with a host of challenges, not the least of which is extensive government regulation. How do you see this market changing in the coming year?

M.B.: There are lots of strings attached to doing business there. We're still going to be talking about in-bound Chinese investment -- Chinese companies coming to the United States, either as purchasers in a merger/acquisition context or doing an IPO here.

There's still a pool of money Chinese companies can easily access. The Chinese have been extremely active in places like Africa and South America on natural resources exploitation, and that's going to continue.

If a U.S. company goes into China, it can be a good market for them if they understand what they want to get out of it. With China, you've got a lot of homework to do. One example: In the past year, I was advising a company on setting up an operation in China and the regulatory scheme changed three times in six months. The Chinese government is not great at publicizing changes and regulations. Sometimes you hear about these changes second- or third-hand, and it adds a level of complexity and frankly cost for foreign companies operating there.

NLJ: You've done some deals in the Middle East. Given the turmoil in many of those countries, how do you anticipate lawyers getting involved in this region going forward?

M.B.: As a section, we've been active in Egypt and a couple other places in transition issues. For the most part, we haven't seen a lot of changes on the business side. A lot of places in the Middle East had somewhat advanced and somewhat transparent, investor-friendly laws and regulations that pertain to foreigners investing or otherwise doing business in the region. Where a lot of the countries are now seeing that they maybe lagged a bit behind is the civil side -- the relationship between people and their government. That's going to change. And in a lot of places it has.

There's no organized bar in Egypt the way we have in the United States. What we've been doing, and this is something the section has done a lot of and does well, when a local government has a specific question on a piece of regulation, whether drafting a law or regulation up through what a foreign investment law should look like, we offer pro bono legal systems on that. Egypt really kicked into high gear in May, and we've been interfacing with our members and local lawyers there.

NLJ: The ramp-up in Foreign Corrupt Practices Act enforcement is a major topic among defense attorneys and government officials. What's the next phase in the anti-bribery law?

M.B.: The next phase is not only the Justice Department going for the home runs -- the big cases, where they're getting multimillion-dollar, sometimes hundreds of millions of dollars, settlements out of big companies, but also looking at small and midsize companies. That's a big concern for a lot of people. The Justice Department now has the resources to really go after big and small companies -- and they are.

The other thing we're seeing is this expansion of whom the companies are responsible for. It's not clear a company is responsible just for its own employees. That has evolved to be that they're responsible for their own employees plus, in many cases, distributors. Now the Justice Department seems to be pushing out the definition a bit more to include people who are just acting on behalf of a company, regardless of an employment or distributorship relationship. That has the potential to create huge headaches for companies, because they really have to keep an eye on what their employees or their agents are doing.