Free speech on campus
Time to stop indulging privileged militant progressive puritan student bigots. Free speech? Not at four in five UK universities http://www.theguardian.com/education/2015/feb/02/free-speech-u...
By: Pat Condell
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Mark Steyn - Defending Free Speech
Defending free speech requires defending unpopular speech. http://www.LibertyPen.com.
By: LibertyPen
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There #39;s no such thing as free speech | Johan Snel | TEDxEde
Historian and journalist Johan Snel is Research fellow in Media, Religion Public Sphere and Senior Lecturer of Journalism at Ede #39;s Christian University of ...
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There's no such thing as free speech | Johan Snel | TEDxEde - Video
Aftermath of Free Speech near David Cameron
After a 10 minute "Big Business and War Party" talk in Witney town centre, the angry locals actually called the Police on us. Never have I felt more like a 13th century gibbering heretic who...
By: Charles Veitch
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VOTE FOR BIG BUSINESS WAR (Free Speech)
Filmed March 2015 in Witney, Oxfordshire (where David Cameron is the local MP) Even though everything I say in this video is ironic, satirical, and obviously politically charged; try and think...
By: Charles Veitch
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College is the place where students should be encouraged to, as Yale promises, "think the unthinkable, discuss the unmentionable, and challenge the unchallengeable." Unfortunately, schools all across the country not only fall short on promises of free expression and academic freedom but openly suppress constitutionally protected speech on campus by using tools such as speech codes to shut down forms of expression that might be uncomfortable, disagreeable, or even offensive to some members of the campus community.
To give a clearer picture of campus censorship, we at the Foundation for Individual Rights in Education (FIRE) today announce our fourth annual list of the top 10 threats to free speech on campus.
While I explained in December why I think 2014 might be remembered as the "Year of the Heckler," the most significant event for FIRE last year was the launch of our ambitious and large-scale Stand Up for Speech Litigation Project. In order to try to end the problem of campus speech codes once and for all, students and faculty members worked with the law firm of Davis Wright Tremaine to file lawsuits against six colleges, including Ohio University, Iowa State University, Chicago State University, the University of Hawaii at Hilo, Citrus College in California, and, most recently, Western Michigan University.
We're happy to report that some colleges, like the University of Hawaii at Hilo, were receptive to working with FIRE and our lawyers to swiftly and amicably fix their unconstitutional codes. But as you will see, some colleges, including Chicago State University, acted quite differently.
Note that not every "honoree" is a college or university, the list is presented in no particular order, and several honorees like Brandeis University and the Department of Education are repeat offenders.
Let us know if your school or alma mater should've been on the list, or if you have been censored on campus. FIRE is happy to work with schools to improve their speech codes. You can find more information on our website at http://www.thefire.org.
University of Iowa
Observers were quick to criticize art professor Serhat Tanyolacar's installation of a statue he intended to be anti-racist: a collage of newspaper headlines and images covering instances of racial violence printed on a robe and hood reminiscent of that of the Ku Klux Klan. The University of Iowa (UI), however, responded not with a defense of Tanyolacar's First Amendment rights but by censoring and publicly denouncing the artist for offending students. One public statement proclaimed that there was "no room for divisive, insensitive, and intolerant displays," and UI President Sally Mason publicly apologized to students who felt "terrorized" by the artwork and for failing to provide a "respectful, all-inclusive, educational environment." Despite heavy criticism from FIRE and the National Coalition Against Censorship, UI has shown remarkable indifference to Tanyolacar's First Amendment rights, which most definitely protect the work it brazenly censored. If UI were serious about its legal and moral obligations to protect freedom of speech, it would apologize to Tanyolacar for failing in its duty to reject demands for censorship. And then it would apologize to its students for the exceedingly poor education on freedom of speech it has given them.
U.S. Department of Education
The Departments of Education and Justice mandated an unconstitutional speech code in May 2013 for all colleges receiving federal funding. The federal requirement came as a result of the agencies' year-long joint investigation into the University of Montana's practices and policies regarding sexual misconduct. The resolution of that investigation defined sexual harassment in a shockingly broad way, prohibiting "any unwelcome conduct of a sexual nature," including "verbal conduct" (i.e., speech). No wonder Chris Rock said he wouldn't play college campuses anymore! Worse, the resolution was labeled a "blueprint for colleges and universities throughout the country," suggesting that if schools didn't adopt the new definition, they risked losing their federal funding.
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Is this logo free speech? Mark Tenally/AP hide caption
Is this logo free speech?
You're on the Internet, which means you're never more five seconds away from someone claiming you squashed their First Amendment rights by, say, blocking them on Twitter.
Repeat after me: the First Amendment prohibits citizens' speech from being infringed upon by the government.* But because the universe delights in dark humor, it turns out that one recent, obnoxious claim about free speech violations might have some real legs.
The latest skirmish in the Washington Redskins' team name controversy involves the legal status of the team's trademark. As my colleague Kenya Downs wrote last month, the U.S. Patent and Trademark Office (USPTO) can deny or rescind a trademark if it is "disparaging of persons, institutions or national symbols." Citing that rationale, the office canceled six of the Redskins' trademarks last summer.
Last week, the Redskins filed a lawsuit saying the office violated their right to free speech. The team's lawyers argue it was singled out "for disfavored treatment based solely on the content of its protected speech, interfering with the ongoing public discourse over the Redskins' name by choosing sides and cutting off the debate. This the U.S. Constitution does not tolerate."
Mark Joseph Stern, who covers legal issues at Slate, called this "a desperate move by a cynical man to maintain a monopoly on an offensive ethnic slur," before adding, "It is also probably correct."
Stern said the the USPTO's rules on offensive trademarks are can appear arbitrary and ideologically driven for instance, when the office rejected the lesbian motorcycle club Dykes on Bikes application for a trademark.
He explains why this is a problem:
"A company whose trademark is revoked is almost certain to change its namemeaning trademark revocation is, at bottom, government coercion of speech...
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Dixie State officials declined to comment Wednesday.
The lawsuit is directed by the Philadelphia-based Foundation for Individual Rights in Education, part of a nationwide series of lawsuits over free speech issues on college campuses.
"The function of an education is the free exchange of ideas," said Catherine Sevcenko, a lawyer with the group. "You got there to sort of have your ideas tested."
The students Jergins, Joey Gillespie and Forrest Gee say in court documents that the public school requires students to get permission before posting things on campus. They asked to put up three fliers featuring the photos with satirical captions last October. But they say they were denied because the fliers violated school policy by mocking people.
Later that fall, the students wanted to put up "Free Speech Wall" in the center of campus covered with blank sheets of paper for students to write their own messages.
The students say they got four signatures from different administrators required to hold on-campus events, but officials said it had to be held in a designated free-speech zone. The students say the area is a patio in an out-of-the-way spot where few students pass by.
The lawsuit says even fewer people stopped after a police officer came to watch for about 30 minutes, even though they had declined a police presence.
The students also say the event-approval process is arbitrary, pointing to a water-gun fight they wanted to hold to recognize the Second Amendment that was denied by administrators, even though a different water-gun fight was approved.
The lawsuit names seven Dixie State administrators, including President Richard Williams. Dixie State has about 8,600 students.
Young Americans for Liberty is a libertarian-leaning organization associated with former U.S. Rep. Ron Paul.
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Students sue, saying Dixie State violates free speech
By Lindsay Whitehurst, Associated Press
March 5th, 2015 @ 7:11am
SALT LAKE CITY (AP) Three Dixie State University students filed a lawsuit Wednesday saying that administrators at the southern Utah college violated their free speech rights by refusing to let them post fliers with satirical pictures of President Barack Obama, former President George W. Bush and the revolutionary leader Che Guevara.
The members of Young Americans for Liberty also say one of their events designed to celebrate free speech was wrongly relegated to a small, out-of-the-way part of the St. George-based campus. The lawsuit filed in federal court seeks damages and changes to rules the students call arbitrary.
"I don't think we have any other options," said plaintiff William Jergins, a 24-year-old senior studying political science, economics and math. "Things like we did, kind of poking fun at public figures, I don't think should be disallowed."
Dixie State officials declined to comment Wednesday.
The lawsuit is directed by the Philadelphia-based Foundation for Individual Rights in Education. The legal action is part of a nationwide series of lawsuits over free-speech issues on college campuses.
"The function of an education is the free exchange of ideas," said Catherine Sevcenko, a lawyer with the group. "You got there to sort of have your ideas tested."
The students_Jergins, Joey Gillespie and Forrest Gee_say in court documents that the public school requires students to get permission before posting things on campus. They asked to put up three fliers featuring the photos with satirical captions last October. But they say they were denied because the fliers violated school policy by mocking people.
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Unfazed by the controversy, the British filmmaker behind the BBC documentary on the Delhi gangrape incident on Thursday accused the Indian government of trying to "muzzle free speech" by banning its telecast in India.
Leslee Udwin's 'Storyville: India's Daughter' was due to be aired in the UK on Sunday to coincide with International Women's Day but the telecast was brought forward in the wake of attempts by the Indian government to block its release worldwide.
It has led to threats of legal action from the Indian home ministry but Udwin remains defiant.
She has called on Prime Minister Narendra Modi to "deal with the unceremonious silencing of the film".
"This is the greatest fight of our times and I wanted to applaud the reaction of the Indian people to the crime with this film. But that has been turned around by this ban, which is an attempt to muzzle free speech," Udwin said in London.
"I have constantly stressed this is not an Indian problem, it is a global problem. I remain confident that this film will be a powerful tool for change," she said.
At the heart of the worldwide uproar is an interview with one of the four men facing the death penalty over the 2012 brutal rape and murder of a 23-year-old paramedical student.
The documentary included an interview conducted by Udwin and BBC, of Mukesh Singh, the driver of the bus in which the student was brutally gangraped by six men on December 16, 2012. Mukesh has made derogatory statements against women, Delhi police has said.
The BBC has defended the broadcast of the documentary in the UK late last night, saying it is a "revealing insight into a horrific crime that sent shock waves around the world and led to protests across India demanding changes in attitudes towards women."
The BBC said it brought forward the broadcast "given the intense level of interest in the 'Storyville' film, enabling viewers to see this incredibly powerful documentary at the earliest opportunity."
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Reuters
The University of Oxford had to cancel a debate on abortion last year because people objected that both panelists were male.
Concern that the Islamic State militant 'Jihadi John' may have been radicalised while attending a London university has re-stoked the debate about free speech in academic institutions.
Mohammed Emwazi was last week identified as the IS militant who has appeared in numerous beheading videos for IS. Emwazi attended the University of Westminster between 2006 and 2009. Former students have told the press that the university "created a hostile environment towards non-Muslims" and that it was heavily reliant on the income from foreign students, many of whom were Muslim, and so did not sufficiently scrutinise those invited to speak there.
The university has strongly defended the claims. And although the concerns may not prove true, they have prompted the institution to suspend all student events of a "sensitive" nature.
These fears come amid an ongoing debate about the freedom of expression at British universities and it doesn't just apply to religious groups. Recent cases include Oxford University cancelling a debate on abortion last year because people objected to the fact it was being debated by two men. And among the more bizarre examples are Birmingham University's ban on sombreros because they were deemed "racist" and UCL's student union banning the Nietzsche reading group.
Concerns were raised earlier this year by both academics and religious groups about the potential effect of the new Counter-Terrorism and Security Act. Guidance accompanying the Bill, which was issued in January, said universities would have to monitor groups on campus and vet talks and speakers.
While most Christians would support attempts to crack down on radicalisation, there were fears that this could have a negative impact on Christian unions and evangelical organisations hosting events at British universities.
The Universities and Colleges Christian Fellowship (UCCF) said at the time the Bill was being debated that although they supported government efforts to combat terrorism, there needed to be a distinction between Islamist radicalisation and the work of Christian unions. "The basic tenets of the Christian faith have nothing to do with terrorism, so what possible justification can there be for jeopardising time-honoured freedoms in an attempt to counter Islamist threats?" the chairman of the board of trustees John Lenton and director Richard Cunningham said in a joint statement.
Academics also saidin February that the proposed legislation was a threat to freedom of speech and would place an "unenforceable duty on educational institutions". The government responded to these concerns, and proposed amendments to protect the freedom of expression in universities.
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Is extremism putting free speech in UK universities under threat?
Kirsten Powers writes about politics, human rights and faith for USA Today and The Daily Beast. Chris Zarconi/Intelligence Squared U.S. hide caption
Kirsten Powers writes about politics, human rights and faith for USA Today and The Daily Beast.
There is agreement on both the political left and right that a majority of college professors in the United States are liberal or left-of-center. But do liberals stifle free speech particularly that of political and social conservatives on college campuses?
Social conservatives often argue that campuses, as a whole, are generally hostile to views that don't conform to the social and political left. Conservatives and evangelicals are rarely asked to speak at colleges and universities, they argue. And they point to numerous incidents where, when schools have asked conservatives to speak, those invitations have been revoked after clamor from left-leaning students and faculty.
But there are many who disagree with the premise that liberals quash intellectual diversity on college campuses. They argue that criticism is not censorship, but that conservatives too often label it as such. And when speech has been curtailed at colleges, they say, it's far more often by administrators seeking to quell or ward off campus disruption than by left-leaning students and faculty.
In the latest event from Intelligence Squared U.S., two teams faced off on in an Oxford-style debate on the motion, "Liberals Are Stifling Intellectual Diversity On Campus." In these events, the team that sways the most people by the end of the debate is declared the winner.
Before the debate at George Washington University in Washington, D.C., 33 percent of the audience voted in favor of the motion, 21 percent were opposed and 46 percent were undecided. After the debate, 59 percent agreed with the motion, while 32 percent disagreed, making the team arguing in favor of the motion the winner.
FOR THE MOTION
Greg Lukianoff, president of the Foundation for Individual Rights in Education (FIRE), is the author of Unlearning Liberty: Campus Censorship and the End of American Debate and Freedom from Speech. He has published articles in The Wall Street Journal, The Washington Post, The New York Times, Stanford Technology Law Review, The Chronicle of Higher Education and numerous other publications. He is also a blogger for Huffington Post and authored a chapter in the anthology New Threats to Freedom. Lukianoff is a frequent guest on local and national syndicated radio programs, has represented FIRE on national television and has testified before the U.S. Senate about free speech issues on America's campuses. He is a co-author of FIRE's Guide to Free Speech on Campus.
Angus Johnston (left), founder of StudentActivism.net, and Jeremy Mayer, a professor at George Mason University, argue against the motion, "Liberals Are Stifling Intellectual Diversity On Campus." Chris Zarconi/Intelligence Squared U.S. hide caption
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Debate: Do Liberals Stifle Intellectual Diversity On The College Campus?
Free Speech Debate?
There was a "Freedom of Speech Debate" in Copenhagen, I guess the shooter also thought this was stupid. This is a clip from Some Garbage Podcast, it airs liv...
By: Christopher Cantwell
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Carlow University's founders, the Sisters of Mercy, held values that align with the philosophy of a peaceful liberty, which made it the perfect place to set up two 4- by 8-foot plywood boards to form a free speech wall, a student leader said Monday.
Passers-by are free to write messages on the boards at the Oakland-based Catholic university, said Carlow senior Richard Haynes, 30, a history major.
It really is up to the interpretation of who is writing it, said Haynes, founder and president of the Carlow chapter of the Young Americans for Liberty, which sponsors the wall.
Handwritten messages range from those supporting equality and social justice, such as Liberty is Truth and America should give up racism for Lent, to calls for changes to the education system, such as There should not be any grades.
Founded in December, the Carlow chapter of the Young Americans for Liberty set up the wall Feb. 24 on the campus. It plans to take it down Friday.
The group obtained permission to set up the wall from the vice president of student engagement. The $100 for the supplies to build the wall came from the Student Activities Board, Carlow spokesman Drew Wilson said.
Carlow is a university where a free exchange of ideas is expected, he said.
These ideas are going to be here whether there is a wall or not, he said.
Founded in 2008, Young Americans for Liberty is a libertarian and conservative youth organization headquartered in Arlington, Va., according to the organization. There are more than 570 chapters nationwide. Chapters often set up free speech walls, said Deirdre Hackleman, spokeswoman for the national office.
Tory N. Parrish is a staff writer for Trib Total Media. She can be reached at 412-380-5662 or tparrish@tribweb.com.
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Photo by: The News-Gazette
Protesters chant for Chancellor Phyllis Wise to go, in front of the Swanlund Administration Building in Champaign on Tuesday August 26, 2014. Wise chose not to pass on Professor Steven Salaita's appointment to the university's board of trustees.
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URBANA The Steven Salaita saga has landed the University of Illinois on a list it probably would rather not make.
The UI is included in the fourth annual "10 worst colleges for free speech" list published by the Foundation for Individual Rights in Education.
The foundation criticized the UI for revoking a job offer to Salaita after he posted inflammatory tweets about Israel last summer. The decision sparked a nationwide debate over free speech and "civility" on college campuses and prompted boycotts by prominent academic groups.
But campus spokeswoman Robin Kaler argued that the vigorous debate about the decision proved that free speech is alive and well on campus.
"Over the past several months, members of the campus community have expressed a wide array of opinions on a hiring decision. This is the kind of free discussion that is the bedrock of our institution and all of higher education," the UI's statement said.
"Anyone who has witnessed the vigorous and passionate debates that have taken place and are still taking place on our campus would appreciate that there is plenty of space for freedom of expression and opinion."
Salaita had left a tenured position at Virginia Tech to accept a job with the UI's American Indian Studies program when the job was withdrawn by campus administrators. Chancellor Phyllis Wise later issued a statement explaining that the campus would not tolerate "personal and disrespectful words or actions that demean and abuse either viewpoints themselves or those who express them." That prompted critics to charge administrators were imposing a "speech code" on faculty. Wise has repeatedly said that was not her intent.
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Updated: Group puts UI in top 10 'worst colleges for free speech'
The Kansas Board of Regents controversial social media policy has landed the board on a nonprofits list of educational institutions with the worst regard for free speech rights.
Mondays 10 Worst Colleges for Free Speech in 2014 list by the Foundation for Individual Rights in Education chides the Regents for enacting an overly broad policy on the improper use of social media.
FIREs annual worst of the worst list includes two institutions that arent colleges the Kansas board and the U.S. Department of Education. The list is critical of the profound effect they had on campus expression throughout the country last year.
Under the Regents policy, universities can let faculty go if they use social media in a way that is contrary to the best interest of the university. The Regents adopted the policy in December 2013 after The University of Kansas professor David Guths Twitter post about the Washington Navy Yard shootings, which killed a dozen people.
The blood is on the hands of the #NRA, Guth wrote. Next time, let it be YOUR sons and daughters. Shame on you. May God damn you.
The policy was revised in May 2014 to add language referencing First Amendment rights, but those critical of the policy say revisions didnt go far enough to protect free-speech rights.
Nothing has changed since May 2014, said Breeze Richardson, a Regents spokeswoman. To continue to repeat the policy does X, Y and Z is misleading because it doesnt mandate anything happen. The reality is those who dont like the policy dont like the law.
Also on FIREs list of worst abusers of student and faculty free speech rights are Brandeis University; California State University, Fullerton; Chicago State University; Georgetown University; University of Illinois at Urbana-Champaign; University of Iowa; Marquette University; and Modesto (Calif.) Junior College.
Our colleges and universities are supposed to be where students go to debate and explore new ideas, said FIRE president Greg Lukianoff. But too often on the modern college campus, students and their professors find their voices silenced by administrators who would rather they be absent from the often contentious marketplace of ideas. When this happens, FIRE will be there to call out these reckless censors.
FIRE claims more than half of the top U.S. colleges maintain speech codes that violate the First Amendment.
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A student group at Carlow University recently erected on campus a large outdoor poster-board, and on its otherwise blank surface, invited passersby to answer a question posed in blue marker: What is free speech?
For 10 days now, answers have been filling up the board, both weighty and whimsical, as students and others stop long enough to get whatever is on their mind off their chest and onto what the group has dubbed Free Speech Wall.
Thoughts on politics and religion, pointed observations about education and police, as well as expressions of personal sorrow and affirmation have appeared. The comments are helping the group, a campus chapter of Young Americans for Liberty, promote a dialogue on campus about the dimensions of free expression.
America should give up racism for lent, read one. Learning to love myself each day. You should too. stated another. Words might cost me my freedom, but they will never cost me my soul or my dignity, read yet another.
And then there was this:Can we have two-ply toilet paper?
The newly formed group approached school administrators with the idea, saying the project fit with the Catholic universitys mission to pursue truth in learning and to respect others, said Richard Haynes, 30, a senior history major from Smithton. The school agreed.
Two connected eight-foot-by-four-foot poster-boards attached to plywood went up in Carlows Hospitality Garden, next to Frances Warde Hall.The board is to come down at the end of today, and messages from it will be used to help organize a teach-in on campus.
Mr. Haynes said the anonymous messages on the board left up round the clock were largely upbeat and respectful. He said organizers removed nothing, but pointing to faded marker on some messages, he added, The weather seems to have taken some things down.
Drew Wilson, a Carlow spokesman, said administrators saw merit to the idea. Besides, he added, the feelings would exist on campus even if the wall was not there.
One student took the opportunity to say, Athiests have morals too.Another invoked recent police brutality protests with the words Hands up. Dont shoot. Still others tackled sexual and gender identify.
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Bill C-51 will End Free Speech in Canada
The new Anti-terror legislation proposed by the Conservative Government of Canada targets extremist propaganda on the internet. The language of Bill C-51 is ...
By: Vladivostok3701
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The decision on the Diocese of Bacolod is the Supreme Courts most convoluted exaltation of free speech. Few realize how it undercuts the Commission on Elections.
Shortly before the 2013 elections, a bishop installed two 610-foot tarpaulins on the facade of Bacolods San Sebastian Cathedral. The first said, Ibasura RH Law (Junk the Reproductive Health Law). The second bore the heading Conscience Vote and two lists of candidates, [Anti-RH] Team Buhay (with a check mark) and [Pro-RH] Team Patay (with an x). These lists included candidates only, not legislators who voted for or against the RH Law but were not running in 2013. A Comelec officer asked the bishop to remove the tarpaulins, citing a Comelec rule limiting posters to 23 feet, or be charged with an election offense.
How would you resolve this case? You might rule that the Comelec may validly level the playing field with a poster size rule. Or you might rule that the Comelec cannot restrict how one uses ones own property for free speech.
Eleven of 14 justices upheld the bishop. Marvic Leonen wrote the decision for eight justices. Very curiously, Antonio Carpio wrote a separate 6-page concurring opinion representing two justices, while Estela Perlas-Bernabe wrote a separate 4-page concurring opinion. Arturo Brion wrote for the three dissenters.
To appreciate the decisions nuances, we need to go into technical free speech doctrine. One must first determine whether a rule restricting speech is content-based or content-neutral. A content-based rule blocks speech based on its content (You may not criticize the President) and is much harder to justify. A content-neutral rule blocks speech based on time, manner or place but not content (No rallying without a permit).
This is not abstract legalese; these rules determine whether Carlos Celdrans jail term is valid, for example. Celdran was convicted of offending religious feelings, a crime committed if one performed acts notoriously offensive to the feelings of the faithful inside a place of worship. Celdrans critics argue that this definition is content-neutral and focused on place, and stress that he protested inside the Manila Cathedral. Celdrans defenders argue that this definition is content-based because one cannot establish notoriously offensive without analyzing his speechs content, and that a crime defined by offensiveness is impossible to justify under free speech.
Returning to the bishop, the decision surprisingly classified the Comelecs poster size rule as content-based, arguing that it only affects election-related but not commercial posters. Further, it argued that a maximum size limits the words in a poster. Carpio, Perlas-Bernabe and Brion all sharply protested that a poster size rule is content-neutral. (I would agree as an illiterate official can enforce it.) This counterintuitive ruling confuses how one may draft future Comelec regulations.
Beyond this crucial technical rule, the decision argued that the Team Patay tarpaulins are not election propaganda that can be regulated by the Comelec, but social advocacy on the RH Law that only incidentally advocated voting or not voting for certain candidates. Further, the decision argued that the Comelec may only regulate election material connected to candidates. Carpio and Brion emphatically protested that there is no such limitation on the Comelecs powers and that allowing unrestricted advocacy by private persons allegedly unconnected to candidates opens a wide backdoor to abuse. Indeed, the decision seems naive because the tarpaulins explicitly asked viewers to vote or not to vote for explicitly named candidates. And as Brion stressed, how can one separate candidates from their key advocacies?
Finally, the decision argued that government may not restrict the bishops use of church property as political billboards. Brion dissented that the decision implied that the Comelec may only regulate election material in public places, yet government validly imposes regulations on private property such as zoning and building restrictions.
The long decision had other nuances. It ruled that Article IX-C, Section 4 of the Constitution only applies to media franchise holders and candidates, and this cannot be invoked against the bishop. However, this is also the basis for the Comelecs 2013 right to reply rules, and the decision unwittingly nullified these for the reasons I previously raised (To Grace Poe: Right to reply already law, 10/29/14).
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