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`No. 18-302
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`
`In the
`Supreme Court of the United States
`_________________________
`ANDREI IANCU, UNDER SECRETARY OF COMMERCE
`FOR INTELLECTUAL PROPERTY AND DIRECTOR,
`UNITED STATES PATENT AND TRADEMARK OFFICE,
`Petitioner,
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`V.
`ERIK BRUNETTI,
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`Respondent.
`_________________________
`On Writ of Certiorari to the
`United States Court of Appeals
`for the Federal Circuit
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`BRIEF OF AMICUS CURIAE SIMON TAM
`IN SUPPORT OF RESPONDENT
`_________________________
` STUART BANNER
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` Counsel of Record
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` UCLA School of Law
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` Supreme Court Clinic
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` banner@law.ucla.edu
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`TABLE OF CONTENTS
`TABLE OF AUTHORITIES ...................................... ii
`INTEREST OF AMICUS CURIAE ............................ 1
`SUMMARY OF ARGUMENT ..................................... 1
`ARGUMENT .............................................................. 2
`The ban on registering immoral trademarks
`is the last vestige of a Victorian legal culture
`in which government officials routinely re-
`stricted speech to promote morality. ......................... 2
`A. When Congress banned the registration
`of immoral trademarks, there were many
`other areas of law in which judges and
`other officials restricted speech they con-
`sidered immoral. ................................................... 3
`1. Copyright ........................................................... 3
`2. The Comstock laws ........................................... 6
`3. Film censorship ................................................. 8
`B. The Lanham Act’s “immoral … or scan-
`dalous” clause is the last remnant of fed-
`eral law authorizing the restriction of
`immoral but non-obscene speech. ...................... 10
`C. The only interest advanced by the ban on
`registering immoral trademarks is the
`now-impermissible Victorian aim of insu-
`lating the public from offensive speech. ............. 11
`CONCLUSION ......................................................... 13
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`ii
`TABLE OF AUTHORITIES
`Barnes v. Miner, 122 F. 480 (C.C.S.D.N.Y.
`1903) ........................................................................ 5
`Bleistein v. Donaldson Lithographing Co.,
`188 U.S. 239 (1903) ................................................. 6
`Block v. City of Chicago, 87 N.E. 1011 (Ill.
`1909) .................................................................... 8, 9
`Broder v. Zeno Mauvais Music Co., 88 F. 74
`(C.C.N.D. Cal. 1898) ................................................ 4
`Carey v. Population Servs., Int’l, 431 U.S.
`678 (1977) .............................................................. 11
`Forsyth Cty. v. Nationalist Movement, 505
`U.S. 123 (1992) ...................................................... 12
`Hallmark Prods., Inc. v. Carroll, 121 A.2d
`584 (Pa. 1956) .......................................................... 9
`Hamling v. United States, 418 U.S. 87
`(1974) ..................................................................... 10
`Hoffman v. Le Traunik, 209 F. 375 (N.D.N.Y.
`1913) ........................................................................ 5
`Joseph Burstyn, Inc. v. Wilson, 343 U.S. 495
`(1952) ....................................................................... 9
`Keene v. Kimball, 82 Mass. 545 (1860) ...................... 5
`Manual Enters., Inc. v. Day, 370 U.S. 478
`(1962) ..................................................................... 10
`Martinetti v. Maguire, 16 F. Cas. 920 (C.C.D.
`Cal. 1867) ................................................................. 4
`Matal v. Tam, 137 S. Ct. 1744 (2017) .................. 1, 12
`Message Photo-Play Co. v. Bell, 166 N.Y.S.
`338 (N.Y. App. Div. 1917) ....................................... 9
`Miller v. California, 413 U.S. 15 (1973) .................. 11
`Mitchell Bros. Film Grp. v. Cinema Adult
`Theater, 604 F.2d 852 (5th Cir. 1979) .................... 5
`Mutual Film Corp. v. Industrial Comm’n,
`236 U.S. 230 (1915) ................................................. 8
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`iii
`People v. Muller, 96 N.Y. 408 (1884) ......................... 7
`Roth v. United States, 354 U.S. 476 (1957) ............. 11
`Shook v. Daly, 49 How. Pr. 366 (N.Y. Ct.
`Comm. Pleas 1875) .................................................. 5
`Snyder v. Phelps, 562 U.S. 443 (2011) ..................... 12
`Texas v. Johnson, 491 U.S. 397 (1989) .................... 12
`United States v. 12 200-Ft. Reels of Super
`8MM. Film, 413 U.S. 123 (1973) ........................... 10
`United States v. 31 Photographs, 156 F.
`Supp. 350 (S.D.N.Y. 1957) .................................... 10
`United States v. Bennett, 24 F. Cas. 1093
`(C.C.S.D.N.Y. 1879) ................................................. 7
`United States v. Britton, 17 F. 731 (S.D. Ohio
`1883) ........................................................................ 7
`United States v. Clarke, 38 F. 732 (E.D. Mo.
`1889) ........................................................................ 7
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`18 U.S.C. § 1461 ....................................................... 10
`18 U.S.C. § 1465 ....................................................... 10
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`Comstock Laws:
`17 Stat. 302 (1872) .................................................. 6
`17 Stat. 598 (1873) .................................................. 6
`Trademark Act of 1905, Pub. L. No. 58-84, 33
`Stat. 724 (1905) ....................................................... 2
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`Samantha Barbas, How the Movies Became
`Speech, 64 Rutgers L. Rev. 665 (2012) ................... 9
`William Henry Browne, A Treatise on the
`Law of Trade-Marks (1873) .................................... 2
`Easton S. Drone, A Treatise on the Law of
`Property in Intellectual Productions (1879) ........... 3
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`iv
`Lawrence M. Friedman, Human Rights,
`Freedom of Expression, and the Rise of the
`Silver Screen, 43 Hofstra L. Rev. 1 (2014) ............. 8
`E.H. Heywood, Cupid’s Yokes (1876) ......................... 6
`Harry D. Nims, The Law of Unfair
`Competition and Trade-Marks
`(2d ed.
`1917) ........................................................................ 2
`David M. Rabban, Free Speech
`in Its
`Forgotten Years (1997) ............................................ 6
`Joseph Story, Commentaries on Equity
`Jurisprudence (Isaac F. Redfield ed., 10th
`ed. 1870) ................................................................... 3
`Amy Werbel, Lust on Trial: Censorship and
`the Rise of American Obscenity in the Age of
`Anthony Comstock (2018) ........................................ 6
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` 1
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`INTEREST OF AMICUS CURIAE1
`Amicus Simon Tam is a musician, lecturer, and
`political activist. He is the founder of The Slants
`Foundation, a nonprofit organization dedicated to
`supporting the work of artists-activists. Tam was the
`respondent in Matal v. Tam, 137 S. Ct. 1744 (2017),
`thanks to which the name of his band—The Slants—
`is now a registered trademark. He has an interest in
`supporting the civil rights of members of marginal-
`ized communities, many of whom, like Tam, use
`trademarks as a means of expression.
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`SUMMARY OF ARGUMENT
`The ban on registering “immoral” or “scandalous”
`trademarks is a relic of the Victorian era, when
`judges and other government officials were often en-
`listed to scrub public discourse of anything that
`might offend the most prudish sensibilities. Like the
`copyright law (which at the time also denied protec-
`tion to ostensibly immoral works), the Comstock
`laws, and the early film censorship schemes, the ban
`on registering immoral trademarks was part of a
`world in which the government routinely restricted
`speech that government officials deemed to be im-
`moral.
`Needless to say, that world is long gone. We rec-
`ognized long ago that Americans hold extremely di-
`verse views of what is moral and what is not, and
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`1 No counsel for a party authored this brief in whole or in part,
`and no person other than amicus and his counsel made a mone-
`tary contribution intended to fund the preparation or submis-
`sion of this brief. The parties have consented to the filing of this
`amicus brief.
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`that government officials have no business restrict-
`ing non-obscene speech to enforce one view of moral-
`ity over another. Today, the “immoral … or scandal-
`ous” clause of the Lanham Act is a holdover from an-
`other age.
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`ARGUMENT
`The ban on registering immoral trade-
`marks is the last vestige of a Victorian le-
`gal culture in which government officials
`routinely restricted speech to promote
`morality.
`Before the enactment of the Trademark Act of
`1905, trademarks were governed by common law,
`under which an immoral mark was ineligible for pro-
`tection. As one of the earliest American trademark
`treatises observed, “[t]o be a ‘lawful trade-mark’ the
`emblem must not transgress the rules of morality.”
`William Henry Browne, A Treatise on the Law of
`Trade-Marks 465 (1873). This ban on immoral
`trademarks was incorporated in the Trademark Act
`of 1905, which required the Patent Office (as it was
`then called) to refuse registration to any mark that
`“[c]onsists of or comprises immoral or scandalous
`matter.” Pub. L. No. 58-84, § 5(a), 33 Stat. 724, 725
`(1905). See Harry D. Nims, The Law of Unfair Com-
`petition and Trade-Marks 384 (2d ed. 1917) (“The
`provision of the United States statute excluding from
`registration marks that are scandalous or immoral
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`in their purport, corresponds to the common-law
`rule.”).2
`At the time, there were many other areas of the
`law in which judges and other government officials
`were likewise enlisted to purge immorality from pub-
`lic discourse. In these other areas, however, public
`officials are no longer called upon to perform this
`role. Today, the prohibition on registering immoral
`trademarks stands as an anachronistic remnant of
`an era that vanished long ago.
`
`A. When Congress banned the registration
`of immoral trademarks, there were many
`other areas of law in which judges and
`other officials restricted speech they
`considered immoral.
`Trademark law circa 1905 was typical of the era’s
`law in restricting speech to promote morality. We
`will discuss three examples: copyright, the Comstock
`laws, and film censorship.
`
`1. Copyright
`The most obvious analogue to trademark law was
`copyright law, which likewise denied protection to
`expression a court deemed immoral. See, e.g., Easton
`S. Drone, A Treatise on the Law of Property in Intel-
`lectual Productions 185 (1879) (“The protection of
`the [copyright] law will not be extended to a publica-
`tion which is obscene, or has a positive immoral ten-
`dency.”); Joseph Story, Commentaries on Equity Ju-
`
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`2 The PTO has long treated “immoral” and “scandalous” as syn-
`onyms, so we will do the same. Cf. Gov’t Br. 6 (also treating the
`two terms as synonyms).
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`risprudence 2:124 (Isaac F. Redfield ed., 10th ed.
`1870) (“no copyright can exist, consistently with
`principles of public policy, in any work of a clearly
`irreligious, immoral, libellous, or obscene descrip-
`tion”).
`For example, when the owner of a copyrighted
`play called “The Black Crook” sued an infringer who
`presented a nearly identical play called “The Black
`Rook,” the court refused to enforce the copyright be-
`cause the judge believed “The Black Crook” was im-
`moral. “The principal part and attraction of the spec-
`tacle seems to be the exhibition of women in novel
`dress or no dress,” he complained. Martinetti v.
`Maguire, 16 F. Cas. 920, 922 (C.C.D. Cal. 1867).
`“[T]he benefit of copyright is a privilege conferred by
`congress,” the court declared. “In conferring this
`privilege or monopoly upon authors and inventors, I
`suppose that it is both proper and constitutional for
`congress so to legislate, as to encourage virtue and
`discourage immorality.” Id.
`Similarly, in a suit alleging the infringement of a
`copyrighted song entitled “Dora Dean,” the court
`would not enforce the copyright because the song in-
`cluded this line: “She’s the hottest thing you ever
`seen.” Broder v. Zeno Mauvais Music Co., 88 F. 74,
`78 (C.C.N.D. Cal. 1898). The court reasoned: “It is
`difficult to escape the conclusion that the word ‘hot-
`test,’ as used in the song ‘Dora Dean,’ has an immor-
`al signification.” Id. at 79. The court concluded that
`the word “has an indelicate and vulgar meaning, and
`that for that reason the song cannot be protected by
`copyright.” Id.
`Another court denied copyright protection to a
`combined stage and film performance portraying “a
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`human being in nude or seminude conditions making
`quick changes of dress or costume,” on the ground
`that it was “lascivious and immoral.” Barnes v. Min-
`er, 122 F. 480, 489 (C.C.S.D.N.Y. 1903). The perfor-
`mance was not “of a nature calculated to elevate,
`cultivate, inform, or improve the moral or intellectu-
`al natures of the audience,” the court insisted. Id.
`Because it depicted “domestic infelicity and marital
`infidelity and gross immorality,” it was not entitled
`to copyright. Id.
`In such cases, courts earnestly believed they had a
`duty to shield the public from immoral speech. “The
`rights of the author are secondary to the right of the
`public, to be protected from what is subversive of
`good morals,” one court declared. Shook v. Daly, 49
`How. Pr. 366, 368 (N.Y. Ct. Comm. Pleas 1875).
`Courts thus refused “to vindicate the claims of any
`party to the exclusive enjoyment or disposal of an
`immoral or licentious production.” Keene v. Kimball,
`82 Mass. 545, 549 (1860). It was well established
`during the era that “[t]o be entitled to be copyright-
`ed, the composition must be original, meritorious,
`and free from illegality or immorality.” Hoffman v.
`Le Traunik, 209 F. 375, 379 (N.D.N.Y. 1913) (inter-
`nal quotation marks omitted).
`It has been a very long time since copyright law
`was used to police morality. By the 1970s, such deci-
`sions had long been deemed “vestiges of a bygone
`era.” Mitchell Bros. Film Grp. v. Cinema Adult Thea-
`ter, 604 F.2d 852, 861 (5th Cir. 1979). “[I]t is inap-
`propriate for a court,” the Fifth Circuit concluded, to
`use copyright law “to interpose its moral views be-
`tween an author and his willing audience.” Id. In
`stark contrast to the prim censoriousness of the Vic-
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`torians, we have come to recognize the wisdom of
`Justice Holmes’s remark that it is “a dangerous un-
`dertaking for persons trained only to the law to con-
`stitute themselves final judges of the worth of picto-
`rial illustrations” or indeed any other form of expres-
`sion. Bleistein v. Donaldson Lithographing Co., 188
`U.S. 239, 251 (1903).
`
`2. The Comstock laws
`When the ban on registering immoral trademarks
`was enacted, the state and federal governments were
`engaged in a similar effort to purge immoral materi-
`als from the marketplace and the mail. Under what
`were colloquially known as the Comstock laws (in
`honor of Anthony Comstock, their enthusiastic pro-
`ponent), Congress prohibited the exhibition and sale
`of any “article of an immoral nature,” 17 Stat. 598
`(1873), and barred from the mail every “publication
`of a vulgar or indecent character,” 17 Stat. 302
`(1872). See Amy Werbel, Lust on Trial: Censorship
`and the Rise of American Obscenity in the Age of An-
`thony Comstock (2018).
`In one typical case, the early libertarian Ezra
`Heywood was convicted and sentenced to two years
`in prison for publishing a short pamphlet called
`“Cupid’s Yokes,” in which he argued that marriage
`should be abolished. David M. Rabban, Free Speech
`in Its Forgotten Years 32-38 (1997). The pamphlet
`consisted entirely of policy arguments and could not
`have been thought, even then, to appeal to anyone’s
`prurient interest. (The most heated passage is one in
`which Heywood calls Comstock “a religious mono-
`maniac” who has contrived “to use the Federal
`Courts to suppress free inquiry.” E.H. Heywood, Cu-
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`pid’s Yokes 12 (1876).) The court nevertheless con-
`cluded that Heywood’s pamphlet was “offensive to
`decency” and capable of causing “thoughts of an im-
`moral tendency.” United States v. Bennett, 24 F. Cas.
`1093, 1104 (C.C.S.D.N.Y. 1879).
`Similar cases were common during the period. In
`New York, a store clerk was convicted of selling pho-
`tographs of paintings from the Salon in Paris and
`the Centennial Exhibition in Philadelphia, paintings
`that depicted nude women. The fact that experts
`considered the paintings fine art made no difference,
`in the view of the state Court of Appeals, because the
`images might “deprave or corrupt those whose minds
`are open to such immoral influences.” People v. Mul-
`ler, 96 N.Y. 408, 411 (1884). A St. Louis physician
`was convicted of placing in the mail his treatise on
`venereal disease, because, as the trial court charged
`the jury, the treatise included “immodest and inde-
`cent matter.” United States v. Clarke, 38 F. 732, 733
`(E.D. Mo. 1889). Even those who wrote sealed per-
`sonal letters were prosecuted, on the theory that the
`purpose of the Comstock laws was “to purify the
`mails by stopping the dissemination of immoral and
`debasing matter” regardless of whether anyone but
`the addressee would read it. United States v. Britton,
`17 F. 731, 732 (S.D. Ohio 1883).
`Such opinions seem comically puritanical today,
`because our world is so different from the one inhab-
`ited by the judges and legislators of the era. In the
`late 19th and early 20th centuries, however, the
`managers of the legal system were committed to pu-
`rifying discourse of all kinds, including trademarks.
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`3. Film censorship
`As Americans began watching movies around the
`turn of the 20th century, judges and legislators
`placed great importance on preventing the public
`from seeing any immorality on the screen. See Law-
`rence M. Friedman, Human Rights, Freedom of Ex-
`pression, and the Rise of the Silver Screen, 43 Hof-
`stra L. Rev. 1 (2014). Many states and cities estab-
`lished censorship regimes that required a govern-
`ment official to approve a film as moral before it
`could be exhibited. See, e.g., Mutual Film Corp. v.
`Industrial Comm’n, 236 U.S. 230, 240 (1915) (up-
`holding an Ohio statute allowing the screening of
`“[o]nly such films as are, in the judgment and discre-
`tion of the board of censors, of a moral, educational,
`or amusing and harmless character”).
`In 1907, for example, Chicago enacted an ordi-
`nance prohibiting the exhibition of “immoral pic-
`tures.” Block v. City of Chicago, 87 N.E. 1011, 1012
`(Ill. 1909). Under this ordinance, the city banned the
`showing of a 1908 film called “The James Boys,”
`which depicted the career of the outlaw Jesse James
`and his gang, who had committed a series of cele-
`brated robberies approximately forty years earlier.
`“It is true that pictures representing the career of
`the ‘James Boys’ illustrate experiences connected
`with the history of the country,” the Illinois Supreme
`Court acknowledged in upholding the ban—“but it
`does not follow that they are not immoral.” Id. at
`1016. The court reasoned that “[p]ictures which at-
`tempt to exhibit that career necessarily portray ex-
`hibitions of crime.” Id. The court concluded of “The
`James Boys,” along with another banned film: “They
`are both immoral, and their exhibition would neces-
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`sarily be attended with evil effects upon youthful
`spectators.” Id.
`A few years later, New York barred the exhibition
`of a film depicting the life of the birth control advo-
`cate Margaret Sanger, because the city official re-
`sponsible for censoring films determined “that in his
`judgment the film tends to teach immorality.” Mes-
`sage Photo-Play Co. v. Bell, 166 N.Y.S. 338, 341
`(N.Y. App. Div. 1917). When the ban was challenged,
`the court had little doubt that “the action of the
`commissioner is justified, both in the interests of
`public decency and public welfare,” because watch-
`ing the film might cause audience members to devel-
`op an interest in using birth control. Id. at 344. “[I]t
`fairly appears,” the court worried, “that the concen-
`tration of the minds of those in attendance at such a
`production on this question of birth control for a con-
`siderable period of time—for the film is long—may
`engender a desire to obtain the information, of the
`existence of which they are thus assured.” Id.
`These film censorship regimes were held unconsti-
`tutional long ago. See, e.g., Joseph Burstyn, Inc. v.
`Wilson, 343 U.S. 495 (1952); Hallmark Prods., Inc. v.
`Carroll, 121 A.2d 584 (Pa. 1956); see generally Sa-
`mantha Barbas, How the Movies Became Speech, 64
`Rutgers L. Rev. 665 (2012). But they were just get-
`ting off the ground in 1905, when Congress prohibit-
`ed the registration of immoral trademarks. At the
`time, regulators and courts vigilantly policed speech
`of all kinds in order to prevent any sort of immorali-
`ty from reaching the public.
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`10
`B. The Lanham Act’s “immoral … or scan-
`dalous” clause is the last remnant of fed-
`eral law authorizing the restriction of
`immoral but non-obscene speech.
`There appear to be only two other federal statutes
`that, like the Lanham Act, still include text facially
`authorizing government officials to restrict speech
`for being immoral. These are the statutes governing
`obscenity. On their face, these statutes purport to
`govern immoral speech as well as obscene speech. 18
`U.S.C. § 1461 bars obscene matter from the mail, as
`well as “[e]very paper, writing, advertisement, or
`representation … for any indecent or immoral pur-
`pose.” 18 U.S.C. § 1465 prohibits the production and
`transportation of obscene material, as well as “any
`other matter of indecent or immoral character.”
`In these two statutes, however, the “immoral”
`provisions have long been interpreted to be coexten-
`sive with the ban on obscenity. That is, for many
`years it has been the case that speech cannot be re-
`stricted as immoral if it is not obscene. See, e.g.,
`United States v. 31 Photographs, 156 F. Supp. 350,
`352 n.2 (S.D.N.Y. 1957) (“I do not believe that the
`word ‘immoral’ adds to the class of material excluded
`from importation by the word ‘obscene,’ and the Gov-
`ernment has not contended that it does.”); see also
`Manual Enters., Inc. v. Day, 370 U.S. 478, 482-84
`(1962) (lead opinion); United States v. 12 200-Ft.
`Reels of Super 8MM. Film, 413 U.S. 123, 130 n.7
`(1973); Hamling v. United States, 418 U.S. 87, 112-
`14 (1974).
`This narrowing construction has been necessary
`because the Court has made clear that while obscen-
`ity is unprotected by the First Amendment, speech
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`11
`that is not obscene is protected even if some consider
`it immoral. “[W]here obscenity is not involved, we
`have consistently held that the fact that protected
`speech may be offensive to some does not justify its
`suppression.” Carey v. Population Servs., Int’l, 431
`U.S. 678, 701 (1977); see also Roth v. United States,
`354 U.S. 476 (1957); Miller v. California, 413 U.S. 15
`(1973). It has been well established for more than
`half a century that expression “should not be sup-
`pressed merely because it offends the moral code of
`the censor.” Roth, 354 U.S. at 513 (Douglas, J., dis-
`senting).
`The Lanham Act thus appears to be the only sur-
`viving federal statute ostensibly authorizing the re-
`striction of speech for being immoral but not ob-
`scene. When Congress enacted this provision in
`1905, examples of such regulation were common-
`place. Today, the “immoral … or scandalous” clause
`of the Lanham Act is the last one standing.
`
`C. The only interest advanced by the ban on
`registering immoral trademarks is the
`now-impermissible Victorian aim of insu-
`lating the public from offensive speech.
`The government’s brief demonstrates all too clear-
`ly that the only interest advanced by the “immoral
`… or scandalous” clause is that of preventing mem-
`bers of the public from being offended by speech they
`consider immoral. The government offers a few dif-
`ferent euphemisms for this interest: “protecting the
`sensibilities of the public,” Gov’t Br. 32; “encouraging
`the use of trademarks that are appropriate for all
`audiences,” Gov’t Br. 33; and preventing members of
`the public from viewing material they find “shocking
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`12
`to the sense of propriety,” Gov’t Br. 34 (internal quo-
`tation marks and ellipsis omitted). These all mean
`the same thing—restricting speech that might offend
`some people because they find it immoral.
`In 1905, when this provision was enacted, the
`First Amendment was an infrequent basis for litiga-
`tion. First Amendment doctrine barely existed. The
`government routinely restricted speech on the
`ground that it might offend some people’s sense of
`morality.
`Today, by contrast, it is a staple of First
`Amendment jurisprudence that speech may not be
`restricted for the purpose of preventing listeners
`from being offended. See Matal v. Tam, 137 S. Ct.
`1744, 1764 (2017) (lead opinion) (rejecting the notion
`that “[t]he Government has an interest in preventing
`speech expressing ideas that offend”); Snyder v.
`Phelps, 562 U.S. 443, 458 (2011) (“[S]peech cannot be
`restricted simply because it is upsetting.”); Forsyth
`Cty. v. Nationalist Movement, 505 U.S. 123, 134-35
`(1992) (“Speech cannot be financially burdened, any
`more than it can be punished or banned, simply
`because it might offend.”); Texas v. Johnson, 491
`U.S. 397, 414 (1989) (“If there is a bedrock principle
`underlying the First Amendment, it is that the
`government may not prohibit the expression of an
`idea simply because society finds the idea itself
`offensive or disagreeable.”).
`The government’s proffered interest is thus just as
`anachronistic as the “immoral … or scandalous”
`clause itself. It would have been a good argument in
`1905, but it hasn’t been for a very long time.
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`13
`CONCLUSION
`The judgment of the U.S. Court of Appeals for the
`Federal Circuit should be affirmed.
`Respectfully submitted,
` STUART BANNER
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` Counsel of Record
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` UCLA School of Law
`
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`
` Supreme Court Clinic
`
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`
`
` 405 Hilgard Ave.
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`
`
` Los Angeles, CA 90095
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` (310) 206-8506
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` banner@law.ucla.edu
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