Wednesday, March 7, 2012
On Thursday, May 31, 2012, the Widener Environmental Law Center (WELC) in Wilmington, Delaware, will host a one-day scholar workshop on recent developments in the growing field of global and domestic constitutional environmental rights. Workshop organizers Professors Erin Daly and Jim May invite you to attend to present a work in progress, to comment, or to observe.
The program is open to (1) scholars who are interested in sharing significant works-in-progress, such as books, articles, advocacy and constitutional amendments, and (2) scholars who would be interested in providing comments to a work in progress, (3) observers.
The workshop is limited to 50 participants.
The deadline is March 31, 2012.
More information here.
Tuesday, March 6, 2012
This year's topic of Drake University Law School Annual Constitutional Law Center Symposium is Constitutionalism and the Poor and it will be held April 14, 2012.
Here's the line-up:
9:00 a.m. Keynote Address: "Dandridge v. Williams Redux: A Look Back From the 21st Century"? - Peter Edelman, Professor of Law, and Faculty Director of the Center on Poverty, Inequality, and Public Policy at Georgetown University Law Center
9:45 a.m. “Occupy Pennsylvania Avenue: How the Government’s Unconstitutional Actions Harm the Poor” - Ilya Shapiro, Senior Fellow in Constitutional Studies and Editor-in-Chief of Cato Supreme Court Review at the CATO Institute
10:30 a.m. “Whither the Canaries?” - Julie Nice (pictured left) Herbst Foundation Professor of Law at University of San Francisco School of Law
11:00 a.m. “Constitutional Essentials” - Frank Michelman, Robert Walmsley University Professor at Harvard Law School
11:30 a.m. “Implicit Bias: Structural Racialization and a New Constitution” - john powell (pictured right) Director, Haas Diversity Research Center and Robert D. Haas Chancellor’s Chair in Equity and Inclusion, University of California, Berkeley
12:00 p.m. “State Constitutions and Poverty” - James Gardner, Vice Dean for Academic Affairs and Joseph W. Belluck and Laura L. Aswad SUNY Distinguished Professor of Civil Justice at SUNY Buffalo Law School, State University of New York
More information here.
Wednesday, February 29, 2012
The Fordham Urban Law Journal will host its Volume XXXIX Symposium next Friday, March 9, titled Gun Control and the Second Amendment: Developments and Controversies in the Wake of District of Columbia v. Heller and McDonald v. Chicago.
The Journal put together a terrific line-up, available here. The program runs from 10 am to 5 pm on Friday, March 9, 2012, at the Fordham University School of Law, James B.M. McNally Amphitheater. CLE credit is available.
Thursday, February 2, 2012
For scholars working on constitutional issues relating to social justice and gender, a terrific-looking conference, Social Justice Feminism, will be held at University of Cincinnati College of Law on October 26-27, 2012.
The deadline is April 1, 2012; submissions of abstracts for individual papers, as well as complete panels, are invited.
More info here.
[pictured: from the Race, Gender and Social Justice at U Cincinnati College of Law, via]
Wednesday, February 1, 2012
From Madison to Zuccotti Park: Confronting Class and Reclaiming the American Dream will be held at University of Wisconsin, Madison, and seeks to "bring together scholars, economists, activists, policymakers, and others to critically examine both the relationships between and the complexities of class and inequality."
More info here.
Wednesday, January 4, 2012
Five of the hot topics sessions involve constitutional law issues:
Occupy Wall Street as a Transformative Social Movement: Its Meaning and Prospects for the Future,
(Thursday, 10:30 am - 12:15 pm)
Our Intensifying National Debate: Is Health Care Reform Constitutional?
(Friday, 10:30 am - 12:15 pm)
The Singular Legacy of Professor Derrick Bell,
(Friday, 4:00 pm - 5:45 pm)
Politics, Ethics, and the Supreme Court: The Present and Future of Supreme Court Recusal
(Friday, 4:00 pm - 5:45 pm)
Church Autonomy, the Ministerial Exception, and Hosanna-Tabor v. EEOC
(Saturday, 10:30 am - 12:15 pm)
The Section on Constitutional Law is sponsoring two panels, from 2:00-5:00 pm on Thursday, American Citizenship in the 21st Century and Article V: To All Intents and Purposes, with the business meeting after the program.
The Section of Law and Religion is sponsoring Blasphemy, Religious Defamation, and Religious Nationalism: Threats to Civil Society from Religious Speech and Its Suppression.
The Section on Minority Groups is sponsoring Minority Conservatives and Their Impact on Constitutional Theory.
The Section on Professional Responsibility is sponsoring Does the First Amendment Protect Attorney Advice, Assistance, and Representation?
The Section on Legal History is sponsoring Was Emancipation Legal: Reflections on the Sesquicentennial of the Emancipation Proclamation.
Sunday, December 4, 2011
“A Living, Working Faith”:
Remembering Our Colleague
Derrick A. Bell, Jr.
at COLUMBIA LAW SCHOOL, NY, NY on Saturday December 10th, 2011
This one day conference organized by Professors Kendall Thomas and Penelope Andrews will honor the work of the late ConLawProf Derrick Bell.
9 a.m. to 9.15 a.m:
Welcome − Professor Kendall Thomas, Columbia Law School and
Professor Penelope Andrews, CUNY School of Law
9.15 a.m. - 10.30 a.m.
The Elusive Quest for Equality and the Permanence of Racism: Faces at the Bottom of the Well and We Are Not Saved
Reflections Panel 1:
Chair: Professor Penelope Andrews, CUNY School of Law
Professor Twila Perry, Rutgers University School of Law
Professor Sheila Foster, Fordham University School of Law
Professor Rose Villazor, Hofstra University School of Law
Professor Olati Johnson, Columbia University School of Law
10.30 a.m to 10. 45 a.m. Morning Tea
10.45 a.m. to 12:15 p.m.
Reflections Panel 2:
Chair: Professor Kendall Thomas, Columbia University School of Law
Professor Susan Sturm, Columbia University School of Law
Professor Jenny Rivera, CUNY School of Law
Professor Leonard Baynes, St. John’s University School of Law
Professor Beryl Jones-Woodin, Brooklyn Law School
Professor Sonia Katyal, Fordham University School of Law
12:15 to 1:15 p.m. Lunch
1:15 p.m. – 2.45 p.m.
Derrick Bell as Teacher
Chair: Professor Ruthann Robson, CUNY School of Law
Professor Vanessa Merton, Pace University School of Law
Professor Joy Radice, New York University School of Law
Professor Andrea McArdle, CUNY School of Law
Professor Robin Lenhardt, Fordham University School of Law
Professor I. Bennett Capers, Hofstra University School of Law
2:45 p.m. – 4:15 p.m.
Chair: Professor Paulette Caldwell, New York University School of Law
Professor David Troutt, Rutgers University School of Law
Professor Julie Suk, Cardozo School of Law, Yeshiva University
Professor Rachel Godsil, Seton Hall University School of Law
Professor Taja-Nia Henderson, Rutgers University School of Law
Professor Theodore Shaw, Columbia University School of Law
4.00 to 5 p.m.
Closing Comments and Further Reflections
AN INFORMAL OPEN MICROPHONE FOR FOLKS IN THE AUDIENCE AND PANELISTS TO MAKE COMMENTS . . . OR SING!
Thursday, November 10, 2011
Starts today at the Mayflower Hotel in DC.
More information here.
Thursday, November 3, 2011
The ABA Standing Committee on Law and National Security, with partners at the University of Virginia, Duke, and Georgetown, announced the "21st Annual Review of the Field of National Security Law," on Thursday and Friday, November 1 and 2, 2011, at the Ritz Carlton Hotel in Washington, D.C.
Organizers put together a very impressive line-up, including Chief Prosecutor for the Office of Military Commissions BG Mark S. Martins and State Department Legal Adviser Harold Hongju Koh.
The full program is here; here's a Letter of Invitation; and here's the registration form; and click here for on-line registration. E-mail Holly McMahon, at firstname.lastname@example.org, with questions.
Wednesday, November 2, 2011
From the organizers:
Junior Faculty Forum
Request for Submissions
Stanford, Yale, and Harvard Law Schools announce the Junior Faculty Forum (the successor to the Stanford/Yale Junior Faculty Forum that has convened for the past twelve years) to be held at Harvard Law School on June 1-2, 2012, and seek submissions for this meeting. The Forum's objective is to encourage the work of young scholars by providing experience in the pursuit of scholarship and the nature of the scholarly exchange. Meetings are held each spring, alternating between Yale, Stanford, and Harvard.
Approximately twelve junior scholars (with one to seven years of teaching and who are not yet tenured) will be chosen on a blind basis from among those submitting papers to present. One or more senior scholars, not necessarily from one of the host institutions, will comment on each paper. The audience will include the invited young scholars, faculty from the host institutions, and invited guests. The goal is discourse on both the merits of particular papers and on appropriate methodologies for doing work in that genre. We hope that comment and discussion will communicate what counts as good work among successful senior scholars and will also challenge and improve the standards that now obtain. The Forum also hopes to increase the sense of community among legal scholars generally, particularly among new and veteran professors.
Each year the Forum invites submissions on selected topics in public and private law, legal philosophy, and law and humanities -- alternating loosely between public law and humanities subjects in one year, and private and dispute resolution law in the next. The focus of this year’s session will be public law and the humanities. The topics to be addressed include ... Constitutional Law...
There is no publication commitment associated with the Forum, nor is published work eligible. The host institution will pay presenters= travel expenses and provide accommodation; presenters will be required to attend the entire Forum schedule. Paper submissions for the Forum should be sent to Ms. Kaitlin Burroughs at Harvard Law School (1525 Massachusetts Avenue, Cambridge, MA 02138). Electronic submissions should be sent to email@example.com. The deadline for submission is February 15, 2012. Please note on the cover letter which topic your paper falls under.
Inquiries concerning the Forum should be sent to Adriaan Lanni (firstname.lastname@example.org) or Gabriella Blum (email@example.com) at Harvard Law School, Joseph Bankman at Stanford Law School (firstname.lastname@example.org), or Ian Ayres at Yale Law School (email@example.com). We very much hope that young scholars will submit work. If the strong commitment of the host schools can make it so, participation at the Forum will benefit presenters and the profession.
Thursday, October 13, 2011
Headliners include Justices Scalia and Thomas ("A Celebration of Service"), former U.S. Attorney General Michael Mukasey (Eleventh Annual Barbara K. Olson Memorial Lecture), former U.S. Solicitor General Paul Clement and Prof. Laurence Tribe (Annual Rosenkranz Debate on health care reform), and Utah Senator Mike Lee.
The Convention runs from Thursday, November 10, to Saturday, November 12, at the Mayflower Hotel.
Tuesday, October 11, 2011
Tourgee´ is best known, by ConLawProfs anyway, as the attorney for Homer Plessy in Plessy v. Ferguson. For years, I've used Peter Irons' discussion of Tourgee´when teaching the background and litigation of Plessy, including Tourgee´s daring arguments asking the Justices to imagine themselves Black.
The Center for the Study of the American South at UNC-Chapel Hill will be hosting what looks to be an exciting conference, “A Radical Notion of Democracy: Law, Race, and Albion Tourgée, 1865-1905,” that "recalls the legacies of Reconstruction to offer insight into ongoing policy debates."
The one day Public Law and Humanities Symposium is Friday November 5 in Raleigh, NC. Registration and program details here.
Monday, September 26, 2011
Wisconsin has recently been the site of several recent controversies regarding labor law, including academic labor, and the University of Wisconsin Law School Conference, The Constitutionalization of Labor and Employment Law?, on October 28-29, 2011 in Madison is sure to address some of these issues.
Additionally, the conference organizers note that recent "U.S. Supreme Court cases have contained much legal discussion at the intersection of constitutional law concepts and the law of the workplace – both in the public-sector workplace where constitutional state action exists and in the private-sector workplace where it does not. Recent cases include: Garcetti v. Ceballos, Christian Legal Society v. Martinez, City of Ontario v. Quon, NASA v. Nelson, Engquist v. Oregon Dept. of Agricultural, and Ricci v. DeStefano."
The 5 panels are Equal Protection, 13th Amendment, Workplace Privacy, Freedom of Association and Freedom of Speech.
More information, including registration information is here. The "symposium fee is waived for full-time members of academia," pre-registration is required and the deadline is October 18.
September 26, 2011 in Affirmative Action, Association, Conferences, Current Affairs, Equal Protection, First Amendment, Fourteenth Amendment, Fourth Amendment, Fundamental Rights, Privacy, Race, Recent Cases, Scholarship, Speech, Supreme Court (US), Thirteenth Amendment | Permalink | Comments (0) | TrackBack (0)
Friday, August 12, 2011
Scheduled slightly before the January 2012 AALS Conference, the Feminist Legal Theory Collaborative Research Network conference is seeking papers and works-in-progress on legal feminism for its next day long conference, at George Washington University Law School on Wednesday, January 4, 2012.
The Feminist Legal Theory Collaborative Research Network, FLT-CRN, describes itself as a newly-constituted group that seeks to bring together scholars across a range of fields who are interested in feminist legal theory. The inaugural meeting took place at the Law and Society Association meeting in June 2011.
The deadline is Friday September 23, 2011.
The submission process and registration process is through Westlaw's TWEN, and more information is available at Feminist Law Professors Blog.
Prof. Kurt Lash (Illinois) and Prof. Neil Siegel (Duke) debated congressional authority this week over at Volokh. Their points are drawn from Lash's "Resolution VI": The Virginia Plan and Authority to Resolve Collective Action Problems Under Article I, Section 8, and Robert Cooter and Siegel's Collective Action Federalism: A General Theory of Article I, Section 8.
The articles turned on somewhat different ideas. Lash's "Resolution VI," as the name suggests, focuses on and criticizes the theory, popularized by Jack Balkin in his article Commerce, among others, that Resolution VI informs (and under a strong version even is) the meaning of the Commerce Clause and other Article I, Section 8 authorities. (Resolution VI of the Virginia Plan, amended and adopted in the Philadelphia Convention, says that Congress should have power to "legislative in all Cases for the general interests of the Union, and also in those Cases in which the States are separately incompetent, or in which the harmony of the United States may be interrupted by the Exercise of Individual Legislation." That language obviously isn't in the Constitution; instead, the Committee of Detail recommended, and the Convention adopted, enumerated powers.)
Cooter and Siegel's piece, in contrast, looks to Resolution VI as just one piece of evidence supporting their theory of collective action federalism. Siegel explains (from Volokh):
Robert Cooter and I have observed that the eighteen clauses of Section 8 mostly concern collective action problems created by two kinds of spillovers: interstate externalities and national markets. . . .
The theory of collective action federalism draws from history, from this evidence in the constitutional text, and from subsequent historical understandings and mistakes, and from modern economics to provide a structural account of the American federal system established in part by Section 8. Its various clauses form a coherent set, not a collection of unrelated powers. Coherence comes from the connection that the specific powers have to collective action problems that the federal government can address more effectively than the states can address by acting alone.
The states often cannot achieve an end when doing so requires multiple states to cooperate. According to collective action federalism, the clauses of Section 8 empower Congress to solve collective action problems that predictably frustrate the states. In the language of the Commerce Clause in particular, such problems are "among the states."
The debate at Volokh was largely around Resolution VI and its effect (or not) on Article 1, Section 8 powers. This is an important debate, to be sure, and it'll likely play some role in the challenges to the Affordable Care Act. (The Constitutional Accountability Center makes the argument in its amicus briefs in the cases; Elizabeth Wydra, CAC's chief counsel, outlines the argument here, in the recent SCOTUSblog symposium on the ACA.) But Cooter and Siegel's collection action federalism is much broader than just Resolution VI.
Here are links to the posts at Volokh:
- Siegel, The Theory of Collective Action Federalism
- Lash, Resolution VI in Current Scholarship and the ACA Debate
- Siegel, What Collective Action Federalism Is and Is Not
- Lash, The Framers' Intent in Cases Involving the National Interest Where the States are "Separately Incompetent"
- Siegel, Prof. Lash's Originalist Claims
- Lash, James Wilson's Resolution VI and Original Public Meaning
- Siegel, Collective Action Federalism and Judicial Enforcement of Enumerated Powers
- Lash, Neil Siegel and the Claims of Resolution VI Proponents: A Reply
Thursday, August 11, 2011
The Wisconsin Journal of Law, Gender & Society seeks contributors to its 2012 symposium, When Gender Norms Become Law: Recognizing and Correcting for Gender Bias. The symposium is on February 10, 2012, at the University of Wisconsin Law School, Madison.
We are seeking original scholarship, from both scholars and practitioners, addressing ways in which gender norms are reflected in legislation, judicial precedent, and administrative findings. Ideally, proposals would highlight:
- An analysis of the inherent and functional gender biases in these policies and practices and
- Recommendations as to how the same policies could be pursued without the resulting gender disparity.
Topics could include: findings of fact that shape evolving areas of law, the role of social sciences in evidence, and differing approaches to gender considerations across legal systems. Interested parties should send an abstract to WJLGS.Symposium@gmail.com by October 1, 2011. Those selected for the Symposium will be notified by November 2011. The Journal's Symposium issue will be published in Fall 2012.
Questions may be addressed to Symposium Editor Meredith Davis at firstname.lastname@example.org.
Tuesday, August 9, 2011
Hosted by New York Law School - - - the law school closest to the former World Trade Center - - - this conference considers the state of civil liberties a decade after 9/11.
Organizers include both the American Constitution Society and the Federalist Society, so there is a diversity of viewpoints in the speakers, although there is woefully inadequate participation by women in the announced schedule below.
The Justice Action Center (of NYLS), the American Constitution Society, and the Federalist Society present:
Civil Liberties 10 Years After 9/11
Friday, September 9, 2011
10:00 a.m.-5:00 p.m
New York Law School
185 West Broadway, New York, NY 10013
General admission is $25.00 for individuals not affiliated with the Law School; CLE credits available.
Registration information here.
9:00 a.m.-10:00 a.m.
Continental Breakfast, Registration, and Opening Remarks
Panel 1: Separation of Powers: The Roles and Inter-Relationships of the Executive, Legislative, and Judicial Branches since 9/11
This panel will discuss the appropriate scope of and limits on the powers of each branch of government since 9/11, including specific exercises of power by each branch that some have criticized as violating the Constitution's checks and balances.
Moderator: Linda Greenhouse, Yale Law School; Columnist, The New York Times
David Cole, Georgetown Law School
Richard Epstein, New York University School of Law; The Hoover Institution; University of Chicago Law School
Peter Shane, Ohio State University Moritz College of Law
Vince Warren, Executive Director, Center for Constitutional Rights
John Yoo, University of California, Berkeley Law School; Deputy Assistant Attorney General, Office of Legal Counsel, U.S. Department of Justice 2001-03)
Panel 2: National Security and Civil Liberties: A Decade of Striking a Delicate Balance, or a False Choice?
Lunch will be available starting at noon
This panel will address not only the overarching (alleged) tensions between liberty and security, but also specific measures that the government has implemented since 9/11 that affect particular civil liberties as well as the rights of particular groups of individuals.
Moderator: Caroline Fredrickson, Executive Director, American Constitution Society
Muneer Ahmad, Yale Law School
Jamil N. Jaffer, Senior Counsel, House Intelligence Committee; Associate Counsel to the President, White House, 2008-09; Counsel to the Assistant Attorney General, National Security Division, U.S. Department of Justice, 2007-08
Anil Kalhan, Drexel University Earle Mack School of Law
Sigal Mandelker, Proskauer Rose LLP; Deputy Assistant Attorney General, U.S. Department of Justice, Criminal Division 2006-09
Joanne Mariner, Director, Human Rights Program, Roosevelt House Public Policy Institute, Hunter College
Geoffrey Stone, University of Chicago Law School
2:30 p.m.-4:00 p.m.
Panel 3: Courts, Accountability, and Justice: Forums for Assuring that Justice Is Served
This panel will discuss efforts to bring to justice individuals who have been accused of responsibility for the 9/11 attacks and other actual or planned acts of terrorism, as well as government and military officials and their contractors who have been accused of abuses. It will consider the appropriate judicial and non-judicial forums and procedures for ensuring that those who are responsible for acts of war, crimes, and abuses of power will be held accountable, consistent with principles of fairness and justice, and that those unjustly accused are exonerated.
Moderator: Chief Judge Dennis Jacobs, Chief Judge, U.S. Court of Appeals for the Second Circuit
Michael Chertoff, Covington & Burling LLP; Secretary of the Department of Homeland Security 2005-09
Eugene Fidell, Yale Law School; President, National Institute of Military Justice
Martin Flaherty, Fordham Law School; Princeton University
Andrew McCarthy, Co-Chair, Center for Law and Counterterrorism; Assistant U.S. Attorney for the Southern District of New York 1993-96
Anthony Romero, Executive Director, American Civil Liberties Union
4:00 p.m.-5:00 p.m.
Wine and Cheese Reception
Sunday, August 7, 2011
SCOTUSblog is hosting an on-line symposium on the constitutionality of the Affordable Care Act. From the symposium description:
Last week the Thomas More Law Center, a Christian legal group, filed a petition for certiorari in which it asked the Court to review a Sixth Circuit decision, which rejected the group's claim that a provision of the Patient Protection and Affordable Care Act requiring all Americans to purchase health insurance by 2014 is unconstitutional. With similar challenges currently pending in the Fourth and Eleventh Circuits, it seems likely that the Court will take up the constitutionality of the Act at some point in the future--perhaps even during the upcoming Term. During the next two weeks, SCOTUSblog will host an online symposium on the Act and the Court: when and whether the Court is likely to review the Act, and how it might rule if it does.
Posts so far are here; here's a list of contributors:
- Jonathan Adler, Case Western Reserve University School of Law
- Cory Andrews, Washington Legal Foundation
- Erwin Chemerinsky, University of California – Irvine School of Law
- Richard Epstein, University of Chicago Law School
- Charles Fried, Harvard Law School
- Abbe R. Gluck and Gillian Metzger, Columbia Law School
- Mark Hall, Wake Forest University School of Law
- Dawn Johnsen, Indiana University Maurer School of Law
- Bradley Joondeph, Santa Clara University School of Law
- Orin Kerr, The George Washington University Law School
- David Kopel, Independence Institute
- John Kroger, Attorney General of Oregon
- Robert Levy, Cato Institute
- Stephen Presser, Northwestern University
- Elizabeth Price Foley, Florida International University College of Law
- David B. Rivkin and Lee A. Casey, Baker Hostetler
- Robert Schapiro, Emory University School of Law
- Steven Schwinn, John Marshall Law School
- Ilya Shapiro, Cato Institute
- Ilya Somin, George Mason University School of Law
- Laurence Tribe, Harvard Law School
- Adam Winkler, University of California Los Angeles School of Law
- Elizabeth Wydra, Constitutional Accountability Center
Wednesday, July 13, 2011
Fix Congress First is hosting a Conference on the Constitutional Convention September 24 and 25, 2011, at Harvard University. The Conference is co-chaired by Lawrence Lessig and Mark McKinnon; Lessig and McKinnon make their case for an Article V convention, and frame some of the issues for the Conference, here.
According to the Conference web-site:
On September 24th, people from across America and across the political spectrum will convene at Harvard University to discuss the advisability and feasibility of organizing towards a Constitutional Convention. While the conference's lead organizers are proponents of a convention--and are particularly passionate about the need to reduce the influence of private money in politics--we actively encourage the participation of those who support a convention for other reasons, and those who oppose holding a convention at all.
[Image: Scene at the Signing of the Constitution of the United States, by Howard Chandler Christy, East Stairway, U.S. House of Representatives, U.S. Capitol Building.]
Sunday, July 10, 2011
Writing about Race? Justice? Translation?
Here are three CFPs that might be of interest, especially for work that is interdisciplinary.
The interdisciplinary journal, University of Florida Journal of Law and Public Policy, is accepting submissions for December 2011 special edition on race, deadline August 28. "Our goal is to inform discussions of race in the public policy arena by highlighting key legal challenges facing ethnic and racial minorities. We are seeking original works that provide thought provoking commentary on issues of race and awaken the consciousness of readers." Submissions to EIC Yvette Sturkes, ysturkes AT ufl.edu.
The third annual Law & Literature Conference at John Jay, CUNY, scheduled for March 2012 is soliciting submissions. The theme is The Idea of Justice, after Amartya Sen's book of the same name and Nobel Prize in Economics winner Sen will be the keynote speaker. Abstract deadline is January 2012. Conference website here, updates forthcoming. Other law and literature CFPs are available from the wonderful Christine Corcos over at Law & Humanities Blog.
The annual meeting of philoSOPHIA, known for its new journal of the same name, will be in April 2012 at Miami University in Ohio. The conference "will have as its theme ‘Translation,’ broadly conceived, taking the work of translation to include translating across disciplines, genres, traditions, texts, historical epochs, and languages." Submissions of abstracts deadline is December 1, 2010. More information here.
[image: desk of former Florida governors via]