In the News

  • August 16, 2017

    Woodsford Litigation Funding, one of the leading global third party funders, has announced a funding facility agreement with Lewis Baach which ensures the firm can offer clients an expedited, one-stop arrangement for the financing of high value litigation and arbitration.

  • August 16, 2017
    www.americanlawyer.comThe American Lawyer
  • August 16, 2017

    Third-party funder Woodsford Litigation Funding said Wednesday it has reached a $20 million agreement with law firm Lewis Baach Kaufmann Middlemiss PLLC to provide it with financing to pursue litigation and arbitration worldwide on behalf of the firm's clients.

    The deal, referred to as a funding facility agreement, will allow Lewis Baach to offer clients a financing arrangement to cover matters in any jurisdiction around the world in which the firm is prepared to offer contingency fee arrangements, Woodsford said. The deal will also cover situations...

    “In our experience, the resources and the resolve that Woodsford brings to the equation, combined with a strong claim, a determined client, and a formidable legal team, makes the difference between justice delivered or denied,” Liston said.

    www.law360.comLaw360
  • August 15, 2017

    "The ability to understand a case, price a case and look at a case honestly — to evaluate its strengths and weaknesses — becomes more important," said Eric Lewis of  Lewis Baach Kaufmann Middlemiss PLLC. "I spend more time on strategy than I did 10 to 15 years ago. I spend more time talking to clients as cases go along."

    www.law360.comLaw360
  • July 27, 2017

    A little more than a year ago, the Pentagon lifted its ban on transgender people serving openly in the military, noted Elizabeth Marvin, an attorney with Lewis Baach in Washington, D.C. Reversing the decision "will undoubtedly adversely impact transgender service members who are currently serving openly under the Obama-era policy," she said. 

    ...

    HR should be aware that Trump's decision "will impassion people on both sides of the issue. Managers need to be educated about transgender issues, and companies should adopt a zero-tolerance policy regarding harassment of transgender employees," Marvin said. "Work should be a place where transgender employees feel safe and are not judged."

    www.shrm.orgSociety for Human Resource Management
  • June 28, 2017

    In September 2016, the US Congress passed the Justice Against State Sponsors of Terrorism Act (“JASTA”) into law, overriding President Obama’s veto to narrow the scope of foreign sovereign immunity for terrorism related claims and expanding liability under the Anti-Terrorism Act (“ATA”) to now also include those who ‘aid, abet, or conspire’ with a foreign terrorist organisation. JASTA’s twin expansions of liability now make it easier to hook Middle Eastern countries and institutions into the web of costly US litigation. As President Obama himself recognised as a basis for his veto, ‘courts [can] potentially consider even minimal allegations…sufficient to open the door to litigation and wide-ranging discovery…’

    Lexis Middle East Law
  • June 21, 2017

    Katherine Toomey was interviewed about renewed Chamber of Commerce efforts to obtain disclosure of third party funding arrangements for litigation.   She noted that the process of obtaining funding can be helpful “because oftentimes you are engaging in a real testing of the strength of the case. . .  You have people who are very knowledgeable and are interested in making sure they're making a good investment, asking you some very hard questions about the weakest parts of your case. So the cases that make it through are stronger for the process."

    www.law360.comLaw360
  • June 19, 2017

    "There will surely be a rash of fringe (and truly offensive) trademark filings as a result of this decision," Ron Abramson, an IP attorney with Lewis Baach, told Ars in an e-mailed comment. "However, none of them will likely ever be major brands, thus the issue should not have great practical significance."

    www.arstechnica.comArs Technica
  • June 19, 2017

    The U.S. Supreme Court on Monday decided in Matal v. Tam that the federal government’s ban on offensive-trademark registrations violates the First Amendment. Here, attorneys tell Law360 why the decision is significant.

    Ron Abramson, Lewis Baach PLLC.  “In today’s decision, there was no dissent from any side of the spectrum. The differences in the bases for the separate opinions of the justices
    were nuanced, going to whether it was necessary to address additional questions such as whether registered trademarks represent government of private speech. One group said it was private speech — and thus highly protected — and a second group said it didn’t matter because this type of censorship would be prohibited under either standard. There will surely be a rash of fringe, and truly offensive, trademark filings as a result of this decision. However, none of them will likely ever be major brands, thus the issue should not have great practical significance.”

    www.law360.comLaw360
  • June 8, 2017

    “This ruling will affect industries across the board,” said Ronald Abramson, a partner in the law firm of Lewis Baach Kaufmann Middlemiss PLLC.  The decision is important not just for its economic impact, but because of its effects on patent law. “This is the first time in a long time that an authoritative court has distinguished patent rights from contract rights and said that you can’t make up your own contract rights to affect patent rights,” said Abramson. “This breathes some new life into restraints on alienation, which have been ignored by the Federal Circuit for the last 25 years. It also opens up the door to antitrust and patent misuse, [two other legal limits on patentees] which have withered under the Federal Circuit.”

    www.ip-watchIntellectual Property Watch
  • June 7, 2017

    En Lewis Baach Kaufmann Middlemiss asesoran a clientes internacionales en litigios también internacionales, investigaciones y compliance. "Nuestra práctica trasciende las fronteras de los Estados Unidos permanentemente. En mi caso, me dedico a asesorar clientes latinoamericanos respecto de sus necesidades legales en los Estados Unidos", dice Cristian Francos*, socio de la firma y su cara en la Argentina.

    *Mr. Francos is admitted to practice only in Buenos Aires; not engaged in the practice of law in the District of Columbia. 

    El Cronista
  • June 4, 2017

    It would not be out of the ordinary, then, for a VEB official to have brief courtesy meetings with New York bankers about continuing business, though they would not be allowed to discuss new bond deals, said Aaron Wolfson, a partner at Lewis Baach who previously worked at JPMorgan and prosecuted banks for skirting sanctions.

    Business DayThe New York Times
  • May 31, 2017

    Ron Abramson, partner at law firm Lewis Baach, said the decision represents “a complete and harsh slap down for the Federal Circuit, at long-last rejecting the Federal Circuit’s long questioned 1992 decision in Mallinckrodt v Medipart, which held that a contractual reservation of rights could overcome the rule of exhaustion by prior sale that applies to the patent property right.”

    He added: “I am a bit surprised to see that the court also went eight to nothing for ‘full monte’ exhaustion—upholding not only domestic patent exhaustion as widely expected, but applying the same rule to foreign sales as well, despite the fact that foreign patents under which the latter sales occurred are entirely separate from any corresponding US patents.”

    www.ippropatents.comIP Pro Patents
  • May 31, 2017

    Lewis Baach’s Ron Abramson said the verdict represents a “complete and harsh slapdown” for the CAFC.  “At long-last”, the court rejected the CAFC’s “long questioned 1992 decision in Mallinckrodt v Medipart, which held that a contractual reservation of rights could overcome the rule of exhaustion by prior sale that applies to the patent property right,” he explained.  “The holding will loosen manufacturers’ control over ‘refillable’ products, as well as the ability to control importation of products sold abroad by threat of patent infringement.” He added, “It also removes a large cloud on commercial freedom of sale perpetuated by the Federal Circuit since its controversial Mallinckrodt decision 25 years ago.”

    www.intellecutalpropertymagazine.comIntellectual Property Magazine
  • May 29, 2017

    Mr. Francos authored the article and is admitted to practice only in Buenos Aires; not engaged in the practice of law in the District of Columbia. 

    www.lanacion.com.arLa Nacion
  • May 26, 2017

    Manuel Varela, natural de Domaio, es abogado en un bufete en Washington que lleva la denuncia de la familia propietaria del banco, intervenido tras un informe del FinCEN americano

    Faro de Vigo
  • May 23, 2017

    Ron Abramson, partner at Lewis Baach, explained its meaning: “Under this ruling, the controlling statute on patent venue is the narrower provision of Section 1400(b), whose meaning is not impacted by the broader provision in the general venue provisions of 35 USC 1391(c). “There will now be fewer places to bring a patent infringement lawsuit, to be sure.”

    www.ippropatents.comIP Pro Patents
  • May 21, 2017
    La familia propietaria considera que la negativa a dar información constituyó una violación de la ley
    EconomíaEl País
  • May 17, 2017
    Com minha experiência como promotor em Nova York, acompanho a Lava-Jato com otimismo. Agora, falta viabilizar acordos de leniência que punam empresas corruptas, mas não as liquidem
    Page 60Página Aberta
  • May 8, 2017

    Eric Lewis of Lewis Baach Kaufmann Middlemiss writes: Good lawyers don't get stuck in boxes. They are problem solvers who bring judgment and experience to their clients' issues, whoever those clients may be. They try to prevent economic interests from affecting their service to clients. They earn trust. Satisfaction in the law can be, and should be, measured in more than one way.

    Law Firm Management Supplement Section page 8New York Law Journal
  • April 18, 2017

    On April 18, 2017, the International Islamic Relief Organization of Saudi Arabia (“IIROSA”) launched a major humanitarian distribution of food and other necessities in refugee camps in Juba, South Sudan to alleviate the plight of the South Sudanese affected by the famine. The distribution of the approximately $250,000 worth of much needed aid from IIROSA – including food items such as flour, sugar, corn, oil, and dried milk, as well as other basic goods – was made in conjunction with the South Sudanese Ministry of Humanitarian Affairs and a local charity partner.

  • April 12, 2017

    Asked whether there was any chance the bill could be enacted, Elizabeth Marvin, a Washington-based lawyer with Lewis Baach, told IBTimes UK: "there's a very slim chance... they certainly could enact it but it would be challenged and in light of the Supreme Court decision in Obergefell v Hodges it would be struck down as unconstitutional."

    www.ibtimes.co.ukInternational Business Times
  • April 7, 2017

    "The federal courts are pretty jealous about their jurisdiction, and Article III standing is a brick
    wall," said Ronald Abramson of Lewis Baach PLLC.

    www.law360.comLaw360
  • March 31, 2017

    Lewis Baach Kaufmann Middlemiss represents Al Jazeera's Ahmad Zeidan and independent correspondent Bilal Kareem in an action challenging their inclusion on the United States’ “Kill List.”  Kate Toomey explains the case in an audio interview.

    www.aljazeera.comAljazeera
  • March 31, 2017

    Elizabeth Marvin, a partner with Lewis Baach in Washington DC, told IBTimes UK: "In my practice, I came to learn pretty quickly that neither side really feels like they win usually when a case is settled".  According to Marvin, the repeal isn't doing anything for North Carolina's LGBT communities: "What the repeal did was basically return the state to pre-HB2."

    www..ibtimes.co.ukInternational Business Times
  • March 31, 2017

    The men’s lawyer, Jeffrey D. Robinson, said that they should be given the right to contest their inclusion on any list that could get them killed.  “Before the state applies its power in force to lead to my death, give me an opportunity to show that you got the wrong person,” said Mr. Robinson.

    www.nytimes.comThe New York Times
  • March 30, 2017

    Jeff Robinson comments to Politico on new litigation filed by Lewis Baach on behalf of two journalists against the Trump administration.    The new suit contends that plaintiffs Zaidan and Kareem have been mistakenly included on the U.S. “kill list.” And must have a mechanism to challenge their status. "This is a very deliberate process that needs to give some access to people who deny they should be included," Robinson said.

    www.politico.comPolitico - Under the Radar
  • March 30, 2017

    “The transgender community is certainly in limbo, which is difficult because the community has been highlighted and sort of brought to the surface in recent months,” said Lewis Baach PLLC partner Elizabeth Marvin. “A lot of attention has been placed on them, and there are no specific protections for them.”

    www.law360.comLaw360
  • March 2017

    Beginning April 1, 2017, Lewis Baach will operate worldwide under the name Lewis Baach Kaufmann Middlemiss.  

  • March 23, 2017

    However, Lewis Baach’s Ronald Abramson called the ruling ‘concerning’.  "In my view, by extending copyright protection to these designs, the court has broken a key limitation on copyright protection, and this will come back to haunt the courts in very troublesome
    ways, not only in the fashion industry, but in other areas, such as architecture and computer
    software, where design and functionality are often intertwined and the designs can be highly 'free form'.”  He added, “Businesses in those fields will now start asserting these ‘copyrights’ very aggressively, in ways that were never intended by the Copyright Act. Note also that the law also provides for design patents, a form of IP specifically created for designs of useful articles.  However, design patents have a relatively short term of 15 years. Copyrights, by contrast, typically have a 100-year term. The result here is very concerning.”

    www.intellectualpropertymagazine.comIntellectual Property Magazine
  • March 23, 2017

    Ronald Abramson, an IP litigator with Lewis Baach PLLC, New York, was critical of the ruling,
    saying the “Supreme Court just did what Congress would not: extend copyright protection to clothing designs.” Abramson told Bloomberg BNA in an email message that the ruling “has broken a key limitation on copyright protection, and this will come back to haunt the courts” in areas like architecture and computer software, “where design and functionality are often intertwined and the designs can be highly ‘free form.’”

    www.iplaw.bna.comBloomberg BNA
  • March 22, 2017

    Lewis Baach's Ron Abramson said the verdict illustrates SCOTUS’ “disinclination to have ‘special rules’ for patent law that widely diverge from the resolution of analogous questions in related legal fields.”  He added, “What the decision does do is cut way back on a defence that occasionally allows a patent infringement defendant to escape liability for damages. Due to the infrequency that this defence prevailed, I would say this decision will not have a monumental impact.”

    www.intellectualpropertymagazine.comIntellectual Property Magazine
  • March 21, 2017

    The impact of the decision will be limited because laches was rarely asserted in patent cases and was even more rarely successful, said Ron Abramson, a partner with Lewis Baach.  "The decision was widely expected and again illustrates the Supreme Court’s disinclination to have `special rules' for patent law that widely diverge from the resolution of analogous questions in related legal fields," Abramson said in an e-mailed analysis.

    www.forbes.comForbes
  • March 8, 2017

    Elizabeth Marvin, an attorney with Lewis Baach in Washington, D.C., said that whether Title IX encompasses gender identity discrimination "could potentially have an impact on employers, because it would require the [Suprerme] Court to consider whether Title IX's prohibition on discrimination on the basis of sex includes gender identity," should the issue again reach the Supreme Court. "A decision that 'sex' as used in Title IX encompasses gender identity would effectively expand the definition of 'sex' as used in other statutes, such as Title VII."

    www.shrm.orgSociety for Human Resource Management
  • February 23, 2017

    Lewis Baach’s Ron Abramson said SCOTUS had “cut off” an argument that could have expand US patent jurisdiction beyond reason.  “Everyone on the court agrees that there has to be more than one US component under the provision in question [to infringe]… the decision does straighten out an area where the lower court had pushed US law too far,” Abramson said.

    www.intellectualpropertymagazine.comIntellectual Property Magazine
  • February 23, 2017

    Ron Abramson, partner at Lewis Baach, agreed with Dragseth that the ruling raises questions.  “I’m not sure I buy the fine points of the court’s statutory construction reasoning, and I see many open questions raised by this decision.  However, the big point here is that the Supreme Court has, quite properly in my view, cut off an argument that could have expanded US patent jurisdiction beyond reason by an exporter who did nothing more with respect to the US than supply a commodity component that is later used in making some further product abroad, where only the final product would have infringed had it
    been made in the US.”

    www.lifesciencesipreview.comLife Sciences Intellectual Property Review
  • February 23, 2017
    The Supreme Court’s ruling yesterday in Life Technologies v Promega will curb the extraterritorial reach of US patent law, according to experts, but its failure to define “substantial portion” is another example of increasing uncertainty.

    Critical of the judgement, Ron Abramson, partner at Lewis Baach, was unsure whether he “buys the fine points of the court’s statutory construction reasoning” and sees “many open questions raised by this decision.” [...]

    www.ippropatents.comIPPRO Patents
  • February 2017

    Manuel Varela and Cristián Francos* were interviewed by AUNO legal magazine on Litigation Funding

    Manuel Varela y Cristián Francos* fueron entrevistados por la revista legal AUNO respecto del financiamiento de litigios

    *Mr. Francos is admitted to practice only in Buenos Aires; not engaged in the practice of law in the District of Columbia. 

    Page 28-29AUNO
  • 2017 Edition

    Lewis Baach is pleased to announce the release of “Getting the Deal Through:  Litigation Funding 2017,” which offers the first comprehensive overview of the laws and regulations governing litigation funding on a country-by-country basis. Lewis Baach attorneys David Liston, Alex Patchen and Tara Plochocki authored the chapter on the United States.

  • January 16, 2017

    A host of likely legal challenges will confront Middle East related entities doing business in or with the United States under President Trump, write Waleed Nassar and Kate Toomey.

    The New Arab
  • January 3, 2017

    As the market continues to pound out a separation between the niche players and the global elites, major legal consumers are increasingly turning to boutique firms for some of their more challenging work. Between their dexterity, fee flexibility, and, depending on the size of the boutique, deeper resources, we are seeing a growing interest in boutiques and niche firms in the legal market.

    www.forbes.comForbes
  • January 3, 2017

    Complaints brought by employees belonging to what is traditionally the majority group should be taken as seriously as complaints brought by employees belonging to historically disadvantaged groups, noted Elizabeth Marvin, an attorney with Lewis Baach in Washington, D.C.

    www.shrm.orgSociety for Human Resource Managment
  • December 19, 2016
    In an op-ed, Kate Toomey discusses how disapproval of the pantsuit is symbolic of the struggles that women have faced for professional acceptance in fields dominated by men.
    www.nationallawjournal.comNational Law Journal
  • December 13, 2016

    “This is a really important action for this court,” Ali Jaber’s attorney Jeffrey Robinson said to the D.C. Circuit’s three-judge panel Tuesday morning.

    Robinson called on the court to decide whether it will be held hostage to the political-question doctrine that prevents courts from interfering in executive policymaking – one of the primary reasons cited by U.S. District Judge Ellen Huvelle for dismissing the lawsuit back in March.

    www.courthousenews.com
  • December 13, 2016

    On Monday, Dec. 12, the U.S. Supreme Court issued a unanimous decision clarifying subsection 1 of the bank fraud statute, 18 U.S.C. §1344, in Shaw v. United States. Notwithstanding a veritable ocean of case law, regulations and statutes that delineate the difference between a bank’s property and that of its customers, the court quickly pushed such technical arguments to the side, holding that — for the purposes of the bank fraud statute — there is no practical difference between targeting a bank customer’s funds and targeting the bank’s own funds.

    www.law360.comLaw360
  • December 13, 2016

    For the first time ever, the victim of an apparent U.S. drone strike got a hearing in a U.S. court. 

     

    WUSA Channel 9
  • December 12, 2016

    “The court’s decision is in keeping with the long-standing principle that a fraud can be prosecuted under the criminal law even if the victim does not suffer a loss — which is an important distinction between criminal fraud and civil fraud,” said A. Katherine Toomey, a partner at Lewis Baach PLLC.

    www.Law360.comLaw360
  • 2016
    Insiders 'Back on the Hook' After U.S. Supreme Court Insider Decision

    For two years, stock traders and the attorneys who represent them said the law surrounding insider trading was a muddle, with no one knowing what exactly is or isn’t legal.
    The U.S. Supreme Court Dec. 6 said it had ‘‘easily’’ settled the question (Salman v. United States, 2016 BL 404795, U.S., No. 15-628, 12/6/16).

    ‘‘Going forward, even remote tippees of inside information are at risk if the government can demonstrate that the defendant knew he was trading on inside information and the chain of disclosure is sufficiently close, even if no money changes hands.’’ Eric Lewis, Lewis Baach PLLC

    Page 1Bloomberg BNA White Collar Crime Report
  • December 6, 2016

    Both the speed and the unanimity of the decision sent a strong message re-affirming existing insider trading prosecutions, according to Eric Lewis, a partner at Lewis Baach, a Washington DC law firm specializing in financial crimes.

    "It was somewhat surprising that the Supreme Court took this case," Lewis told ValueWalk, noting that it had been two decades since the high court took up an insider trading case.

    www.valuewalk.comValueWalk
  • November 17, 2016

    Eric Lewis got a phone call from an old friend’s sister shortly after he wrote an op-ed in The New York Times in 2013 detailing his time playing under a high school football coach who was also a serial sexual predator.

    That call ultimately led Lewis to take a turn this week as a journalist—a departure from his busy career as a prominent lawyer handling international fraud disputes, including representing Bernie Madoff’s investment firm in its liquidation—at his nearly 40-lawyer firm Lewis Baach in Washington, D.C.

    www.americanlawyer.comThe American Lawyer
  • November 16, 2016

    The Appellate Division, First Department, recently affirmed the dismissal of various claims brought by New Greenwich Litigation Trustee, successor to the claims of two feeder funds in the Bernard Madoff affair, against various third-party fund administrators, accountants and auditors.

    New York Law Journal
  • November 13, 2016
    The types of cases that the U.S. Justice Department will pursue is uncertain in Trump administration

    "If you’re a public-integrity prosecutor, and you’ve been doing that for five years, you know who all the players are,” said Anthony Capozzolo, a former prosecutor in the Eastern District.

    www.wsj.comThe Wall Street Journal
  • November 3, 2016

    A decision by the Supreme Court overturning the 4th Circuit's decision could "considerably erode" the American Civil Liberties Union's (ACLU's) challenge to H.B. 2 in Carcaño, said Elizabeth Marvin, an attorney with Lewis Baach in Washington, D.C.

    www.shrm.orgSociety for Human Resource Management
  • October 12, 2016

    The justices directly confronted the issue of race in their questions, said Jeffrey Robinson, an attorney with Lewis Baach PLLC in Washington. Robinson extensively worked on civil rights and death penalty cases and formerly worked at the NAACP Legal Defense Fund, though not in connection with Buck.

    www.bna.comBloomberg BNA
  • October 9, 2016

    "It's still their burden to prove their allegations, which right now is based on a lot of innuendo and leaps of logic," said Waleed Nassar, a partner at Lewis Baach, which represents two of the Saudi charities named in the case.

    thehill.comThe Hill
  • October 7, 2016

    “The government is looking for the Goldilocks number -- not too high and not too low,” said Katherine Toomey, a litigation partner at Lewis Baach Pllc in Washington who’s not involved in the Deutsche Bank case. “They want a deterrent for conduct and punishment, but without putting a major institution out of business or costing jobs.”

    www.bloomberg.comBloomberg
  • October 5, 2016

    The U.S. Supreme Court is set to hear arguments Tuesday in a case that could make it more difficult for federal prosecutors to bring some bank fraud cases, and may also help determine whether banks are legally owners of customer deposits once they are made.

    "Had the government used the second clause to go after Shaw, there would be no case before the Supreme Court," said A. Katherine Toomey, the managing partner of Lewis Baach PLLC's Washington office.  "What seems the weirdest to me is that he was only charged under subsection one," she said.

    www.law360.comLaw360
  • October 3, 2016
    www.alarabiya.net
  • September 29, 2016

    Next week, for the second time in two years, the U.S. Supreme Court will hear argument in a case for the purpose of resolving a split in the circuits concerning the scope of the bank fraud statute — 18 U.S.C. §1344. 

    www.law360.comLaw360
  • September 29, 2016

    Mr. Lewis said that “there is no there there” on the allegations of any Saudi government role in the attacks, given the kingdom’s long history of being at war with Al Qaeda.

    “The notion that senior Saudi officials or the Saudi government had an interest in supporting Sept. 11 and the attack on the World Trade Center is patently absurd,” he said.

    www.nytimes.comThe New York Times
  • September 28, 2016

    Anthony Capozzolo, counsel at Lewis Baach PLLC in New York who spent six years as an Assistant U.S. Attorney for the Eastern District of New York primarily, agreed. He told Bloomberg BNA that one of the biggest reasons the government didn't go forward was because the Supreme Court's decision “eviscerated” the government's case.

    The ruling made it “nearly impossible to prove attempts,” Capozzolo said.

    www.bna.comBloomberg BNA
  • September 26, 2016
    New York Law Journal
  • September 8, 2016

    “The Department of Justice views this decision as having a material effect on the way they’ve been prosecuting quid pro quo cases in the past,” said Anthony M. Capozzolo, a former federal prosecutor, who interpreted the McDonnells’ decisions as “a sign that they’re going to handle these cases differently.”

    The New York Times
  • September 8, 2016

    Such an apparent disagreement is not uncommon, said Anthony Capozzolo, a former federal prosecutor who handled public corruption cases in New York. But he told the Two-Way that the Justice Department's action is a "game changer" that could impact other public integrity cases.

    "The government had a good case in terms of jury appeal," Capozzolo said. "But it appears the department's decision is solely based on the view that McDonnell's activity did not rise to the level of the standard in the Supreme Court decision."

    www.npr.org
  • September 1, 2016

    Elizabeth Marvin, an attorney with Lewis Baach in Washington, D.C., agreed, saying, "A holding that the bill also violates Title VII [of the Civil Rights Act of 1964] is a logical extension of the Aug. 26 holding." However, she added, "It is far too early to predict an ultimate outcome."

    www.shrm.orgSociety for Human Resource Management