After nearly ten years, on Tuesday, June 5, 2018, the World Wide Web Consortium (the “W3C”), the private organization focused on enhancing online user experiences, published the long awaited update to its Web Content Accessibility Guidelines 2.0 (“WCAG 2.0”), known as the WCAG 2.1.  Those who have been following along with website accessibility’s ever-evolving legal landscape are well aware that, despite not having been formally adopted by regulators for the vast majority of the private sector, compliance with WCAG 2.0 at Levels A and AA has become the de facto baseline for government regulators, courts, advocacy groups, and private plaintiffs when discussing what it means to have an accessible website.

WCAG 2.1’s Purpose and Key Features

The WCAG 2.1 is intended to provide a better web experience for three major groups of individuals:  users with cognitive or learning disabilities, users with low vision, and users with disabilities using mobile devices.  To achieve that goal, WCAG 2.1 builds upon WCAG 2.0, retaining all of WCAG 2.0’s Success Criteria and adding 17 new Success Criteria – 5 at Level A, 7 at Level AA, and 5 at Level AAA.  (Please note:  (i) the W3C does not recommend Level AAA conformance be required as a general policy for entire sites because it is not possible to satisfy all Level AAA Success Criteria for some content; and (ii) the current legal landscape sets website accessibility compliance at the Level A and AA conformance levels.)  Entities covered by Title III of the Americans with Disabilities Act (“ADA”), thus focusing on complying with WCAG 2.0/2.1 conformance levels A and AA to make their websites accessible, should be aware that, of the 12 Level A and AA Success Criteria new to WCAG 2.1, there a few notable guidelines that will specifically apply to desktop websites, such as:

  • Requiring the purpose of input fields requesting personal information to be identifiable by assistive technologies;
  • Providing a minimum color contrast ratio for non-text content (including all visible focus indicators) of 3:1;
  • Ensuring individuals with disabilities who choose to override spacing can read page text;
  • Modifying keyboard shortcuts so that individuals with disabilities can turn off or remap the shortcut using a non-printable keyboard character (e.g., Ctrl, Alt, etc.); and
  • Providing status messages (such as, shopping cart updates) that can be presented to the user by assistive technologies without receiving focus.

What WCAG 2.1 Means For Those Currently Complying With WCAG 2.0

As noted above, while formal website accessibly regulations governing all sectors of private business have not been adopted by the U. S. Department of Justice (“DOJ”) (and current Trump administration policies suggest that formal regulations will not be adopted in the near-term future), substantial conformance with WCAG 2.0 Levels A and AA has been considered the default standard cited to in the majority of recent litigations and settlement agreements with private plaintiffs, advocacy groups, and government regulators (e.g., DOJ).  In its abstract, the W3C notes, “The publication of WCAG 2.1 does not deprecate or supersede WCAG 2.0.  While WCAG 2.0 remains a W3C Recommendation, the W3C advises the use of WCAG 2.1 to maximize future applicability of accessibility efforts.”  Therefore, as WCAG 2.1 gains more exposure we expect that it will quickly begin to replace WCAG 2.0 as the default standard cited to in future website accessibility litigations and settlement agreements.

Companies that are currently required to conform with WCAG 2.0 (e.g., due to a settlement agreement, internal policy, etc.) should continue their efforts to achieve that required level of accessibility, however, where possible, they should also consider incorporating the new elements added to WCAG 2.1 to the extent feasible (and going forward as new content is added) as a best practice.  (The W3C joins in this recommendation.)  As WCAG 2.1 inherited WCAG 2.0’s requirements and overall structure and frame work, companies will be able to update web content to meet the WCAG 2.1 without losing conformance with WCAG 2.0 (as the backward compatibility built into WCAG 2.1 means content that conforms to WCAG 2.1 also conforms to WCAG 2.0).  That said, given that WCAG 2.0/2.1 remain privately authored guidelines as opposed government-mandated regulations (and, as such, a handful of courts have refused to specifically impose WCAG 2.0 as the required means of complying with website accessibility obligations), we would be surprised to see courts require companies already complying with WCAG 2.0 to immediately require compliance with WCAG 2.1.

WCAG 2.1 Is Not Quite the Update Places of Public Accommodation Have Been Looking For

While the publication of WCAG 2.1 will likely receive a reasonable amount of fanfare, once the dust settles and everyone has had time to fully appreciate its content, WCAG 2.1 will likely be considered a let down by both businesses and individuals with disabilities.  As WCAG 2.1 was being drafted over the past four years, the W3C would regularly offer open comment periods to the public.  In the comments received, a large number of respondents requested, even moreso than adding new Success Criteria, that WCAG 2.1 provide updates to the original WCAG 2.0 requirements to help developers apply these guidelines to the newest types of technologies (e.g., touch screen, mobile devices, apps, responsive technology, etc.).  Unfortunately, due to time limitations, such updates are not included in WCAG 2.1 and the original WCAG 2.0 Success Criteria text remains largely unchanged.  The W3C has publically acknowledged this shortcoming noting the WCAG 2.1 advancements are “incremental” and stating, “[m]any people hoped WCAG 2.1 would provide more new guidance than it does.  The requirement of compatibility with WCAG 2.0 along with the aggressive timeline limited what could confidently be added to it. WCAG 2.1 provides important and timely guidance but is still only a step—the Working Group expects to develop another dot-release, WCAG 2.2, to expand the new coverage even further. WCAG 2.2 may be developed under a similar timeline and requirements set than WCAG 2.1 was, though we plan to refine the process to address process challenges experienced during the development of WCAG 2.1.”  Therefore, at this time, companies looking for additional guidance regarding how to apply the WCAG 2.0 requirements using modern programming and design techniques and/or to mobile devices/apps should continue to refer to other sources of  guidance such as:  

Looking Forward

While an additional dot release of WCAG 2 (WCAG 2.2) may be published in the future, the next major version update to WCAG will be WCAG 3.0 (also known as project “Silver”).  Currently, WCAG 3.0 is scheduled for release in 2021 and is intended to be a much more inclusive set of guidelines that are easier to understand and implement.  We will provide additional information on WCAG 3.0 developments as they become available.

Additional Information and Resources

In anticipation of the WCAG 2.1 release, the W3C has completely updated its website to create a helpful, easy to use, interface intended to assist website developers with meeting the WCAG 2.0/2.1 guidelines.  This new information provided on the updated W3C website includes: a list of transcription services (for creating videos with audio descriptions), WCAG 2.0/2.1 tutorials, and information for applying WCAG 2.0/2.1 to mobile apps.   Please see https://www.w3.org/WAI/ for more information.

The first quarter of 2018 has already stirred up an array of legal matters that employers in the hospitality industry should be conscious of, both in their day-to-day operations and long-term planning. In February alone, the U.S. House of Representatives passed legislation to curb lawsuits focused on the inaccessibility of brick-and-mortar business establishments and a federal appeals court ruled that discrimination based on sexual orientation violates Title VII of the Civil Rights Act of 1964 (“Title VII”). Earlier this month, the U.S. Department of Labor announced a pilot program that will allow employers to avoid potential penalties for overtime and minimum wage violations. In addition, the #MeToo movement continues to be top of mind across all industries, and hospitality employers should be vigilant in their training and employee awareness efforts. Due diligence in change-of-ownership transactions should include labor relations issues, especially with unionized employees.

This edition of Epstein Becker Green’s Take 5 addresses important and evolving issues confronting employers in the hospitality industry:

  1. Will Congress Slam the Breaks on ADA “Drive By” Lawsuits?
  2. Expanding Sex Discrimination Protection to LGBT Employees in the Hospitality Industry
  3. Effective Compliance Training in the Hospitality Industry in the Wake of #MeToo
  4. Transactional Due Diligence Should Include Labor Relations Issues
  5. Voluntary PAID Program Permits Employers to Escape Potential High Penalties for Self-Reported FLSA Violations—but at What Risk?

Read the full Take 5 online or download the PDF.

New Jersey Unemployment Compensation Law (N.J.S.A. 43:21-4) provides that an unemployed individual who meets an earnings and employment duration threshold is eligible to receive unemployment benefits if he or she “is able to work, and is available for work, and . . . actively seeking work.”  An individual’s eligibility for benefits is subject to disqualification conditions outlined in N.J.S.A. 43:21-5.  One such condition (N.J.S.A. 43:21-5(a)) states that an individual is ineligible for benefits if he or she leaves work “voluntarily without good cause attributable to such work and for each week thereafter until [he or she] becomes reemployed and works eight weeks in employment.”  Accordingly, an individual may voluntarily leave work and remain eligible for benefits so long as the individual can show that he or she left work with “good cause attributable to such work.”  The inquiry does not end there.

What constitutes “good cause attributable to such work” is a fact-specific inquiry.  The New Jersey Department of Labor and Workforce Development has promulgated regulations that seemingly address particular circumstances under which an individual will be found to have left work with “good cause attributable to such work.”  Pursuant to N.J.A.C. 12:17-9.3(b), for example, “[a] n individual who leaves a job due to a physical and/or mental condition or state of health which does not have a work-connected origin but is aggravated by working conditions will not be disqualified for benefits for voluntarily leaving work without good cause ‘attributable to such work,’ provided there was no other suitable work available which the individual could have performed within the limits of the disability.”  Notably, the regulation does not include a requirement that the individual notify his or her employer of the health condition and inquire as to the availability of “other suitable work.”

Another exception to the disqualification rule was added in 2015, when the Legislature amended N.J.S.A. 43:21-5(a) to allow an individual who voluntarily leaves employment to be eligible for unemployment benefits if he or she does so to accept employment elsewhere, begins the other employment within seven days, and his or her “weekly hours or pay [is] not less than the hours or pay of the employment of the first employer.”  The amendment essentially protects an employee who voluntarily leaves employment for another job with at least the same hours or pay, but is terminated prior to working the requisite eight weeks to become eligible for unemployment benefits.

With the backdrop of this legislative and regulatory history, in Margo S. Ardan v. Board of Review, the New Jersey Supreme Court, in a 4-3 majority opinion, recently clarified two issues surrounding the application of the above two exceptions to the disqualification rule for voluntarily leaving employment.  First, the Court explained what a claimant must prove to demonstrate the unavailability of “other suitable work” under N.J.A.C. 12:17-9.3(b).  Second, the Court concluded that the 2015 amendment to N.J.S.A. 43:21-5(a) was not retroactive.  While the Court’s latter holding concerning the retroactivity of the 2015 amendment will likely have little impact on employers, the Court’s decision with regard to a claimant’s required evidentiary showing under N.J.A.C. 12:17-9.3(b) may increase the number of employees who seek accommodations for health problems aggravated by working conditions.  These requests may give rise to an employer’s obligation to engage in the interactive process under the Americans with Disabilities Act (ADA) and the New Jersey Law Against Discrimination (LAD) to determine whether the employee can be accommodated.

Plaintiff Ardan, who suffered “chronic neck, lower-back, and left-knee pain,” began working at a medical center as a registered nurse in September 2010.  Her job duties required her to “walk substantial distances,” and to bend and lift, which aggravated her ailments.  Ardan neither requested less arduous work nor informed her employer of her condition while employed.  In 2012, she resigned from her position at the medical center and accepted a desk job as a healthcare communicator to ease the strain on her body without significantly reducing her wages.  After seven weeks at her new job, Ardan was terminated.

Ardan applied for unemployment benefits.  The Deputy Director of the Division of Unemployment and Disability Insurance denied her application, and the Appeal Tribunal, the Board of Review, and the Appellate Division all subsequently upheld the denial.  The appellate panel, in particular, concluded that Ardan did not offer sufficient proof regarding the unavailability of “other suitable work” under N.J.A.C. 12:17-9.3(b), which it interpreted to require notice to the employer and employee inquiry regarding an alternative position to accommodate the condition.  The panel also found that the 2015 amendment to N.J.S.A. 43:21-5(a) was not retroactive.  The Court granted Ardan’s petition for certification.

On appeal, the Court addressed whether Ardan had shown that her situation fell within the scope of N.J.A.C. 12:17-9.3(b).  This required the Court to determine whether she had presented sufficient evidence that there was “no other suitable work available which [she] could perform within the limits of her disability.”  Rejecting an interpretation of the regulation that would always require a claimant to notify her employer and request an accommodation to prove the absence of “other suitable work,” the Court interpreted the regulation as calling for “an individualized determination” – meaning that in some cases, sufficient proof of the unavailability of “other suitable work” would only need to consist of evidence of the claimant’s medical condition, combined with proof of a job’s physical demands, the “small size of the workplace,” or any other “relevant factors,” whereas other circumstances would require a claimant to prove the absence of “other suitable work” by presenting evidence that she both notified her employer and inquired about an accommodation before leaving the job voluntarily.  The Court did not explain when such notice and inquiry would be required.

Applying the above standard, the Court concluded that Ardan failed to proffer sufficient evidence to prove the unavailability of “other suitable work.”  She had not submitted objective evidence that her former employer had no position available to accommodate her to which she could have been assigned.  Nor had she investigated or sought her employer’s assistance in pursuing a less arduous position.  Consequently, the Court characterized Ardan’s belief that there were no suitable positions at the hospital to accommodate her condition as “premised on nothing but speculation.”

Next, the Court addressed whether the 2015 amendment to N.J.S.A. 43:21-5(a) applied retroactively to Ardan’s claim.  An amendment is retroactive if the Legislature expresses its intent that the law apply retroactively; the amendment is curative; or the parties’ expectations warrant it.  After reviewing the amendment’s legislative history, the Court found no evidence that the Legislature intended retroactive application.  The amendment was also not curative because the Legislature did not amend the statute to correct an error or ambiguity.  Retroactive application was similarly not warranted by the parties’ expectations because, when the matter was being decided on appeal, the parties’ expected that the outcome would be determined by the statutory and regulatory scheme then in existence, under which Ardan was disqualified.

The Court’s opinion in Ardan incentivizes an employee to seek an accommodation from his or her employer prior to leaving a job for health reasons.  Because the Court did not adopt a bright-line rule requiring an employee to always request an accommodation from his or her employer to make the evidentiary showing required by N.J.A.C. 12:17-9.3(b), it remains unclear when an employee must apprise her employer of the need for an accommodation to prove the unavailability of “other suitable work.”  Cautious employees who are seeking to preserve their eligibility for unemployment benefits will notify employers of their condition and seek an accommodation.  When these discussions occur, employers should be aware of their obligations under the ADA and LAD to engage in the interactive process to determine whether the employee can be accommodated.  Failure to do so may result in a disability discrimination claim.  Employers are further advised to consult with counsel when faced with these accommodation requests.

Employers in New York City are required to provide their employees with reasonable accommodations related to childbirth and pregnancy. The New York City Commission on Human Rights has published a new factsheet and notice. The notice should be provided to all employees upon hire, and posted in the workplace to provide employees with notice of their rights under the NYC Human Rights Law.

The notice and factsheet outline employers’ responsibilities with respect to pregnant employees, and recommend that employers work with employees to implement accommodations that recognize employee contributions to the workplace and help keep them in the workplace for as long as possible. The notice and factsheet also provide employees with examples of reasonable accommodations, such as breaks to rest or use the bathroom while at work, and time and space to express breast milk at work.

Our colleague Joshua A. Stein, a Member of the Firm at Epstein Becker Green, has a post on the Retail Labor and Employment Law blog that will be of interest to many of our readers in the hospitality industry: “Start Spreading the News – EDNY Denies Motion to Dismiss Website Accessibility Complaint.”

Following is an excerpt:

While the ADA finished celebrating its 27th anniversary at the end of July, for plaintiffs looking to bring website accessibility complaints in New York the party is still ongoing. Following on the heels of last month’s decision of the U.S. District Court for the Southern District of New York in Five Guys, Judge Jack B. Weinstein of the U.S. District Court for the Eastern District of New York, in Andrews vs. Blick Art Materials, LLC, recently denied a motion to dismiss a website accessibility action, holding that Title III of the ADA (“Title III”), the NYS Human Rights Law and the New York City Human Rights Law all apply to websites – not only those with a nexus to brick and mortar places of public accommodation but also to cyber-only websites offering goods and services for sale to the public. …

Read the full post here.

Our colleague Joshua A. Stein, a Member of the Firm at Epstein Becker Green, has a post on the Retail Labor and Employment Law blog that will be of interest to many of our readers in the hospitality industry: “As the ADA Turns 27, Recent Developments Suggest No End to Website Accessibility Lawsuits.”

Following is an excerpt:

Today marks the 27th Anniversary of the Americans with Disabilities Act (ADA).  Unfortunately for businesses, two recent developments in the context of website accessibility suggest that there is no reason to celebrate and every reason to believe the ever-increasing wave of demand letters and lawsuits in this area will continue unabated.

First, in Lucia Marett v. Five Guys Enterprises LLC (Case No. 1:17-cv-00788-KBF), the U.S. District Court for the Southern District of New York has finally issued a decision directly speaking to the applicability of Title III of the ADA (Title III) to websites, denying Five Guys’ motion to dismiss, and holding that Title III does indeed apply to websites.  Facing a class action lawsuit brought by serial plaintiff, Lucia Marett, Five Guys sought to dismiss the claim that its website (which, among other things, allows customers to order food online for delivery or pick up at its brick and mortar stores) violated Title III and related state/local statutes because it is inaccessible to the blind, on the grounds that Title III does not apply to websites and, even if it did, the case was moot because Five Guys was in the process of updating its website to provide accessibility.  The Court rejected Five Guys’ arguments.  Citing both the text and the broad and sweeping purpose of the ADA, the Court held that Title III applies to websites – either as its own place of public accommodation or as a result of its close relationship as a service of Five Guys’ restaurants (which the court noted are indisputably public accommodations under Title III).  …

Read the full post here.

Employers often struggle to provide employees with their requested accommodations and to comply with disability laws while still effectively running their business. This struggle has been compounded with the Equal Employment Opportunity Commission’s aggressive pursuit of litigation in this area in recent years.  A New York federal court recently weighed in on the issue in Kelly v. Starwood Hotels & Resorts Worldwide, Inc., 15 Civ. 6309 (DLC), 2017 U.S. Dist. LEXIS 43485 (S.D.N.Y. Mar. 24, 2017), holding that an employer is only required to provide an employee with a “plainly reasonable” accommodation, not the employee’s requested accommodation.

In Kelly, the plaintiff, a service express agent (“agent”) at the Westin Hotel, alleged that Starwood failed to provide her with reasonable accommodations for her disabilities in violation of the Americans with Disabilities Act (“ADA”) and the New York City Human Rights Law (“NYCHRL”).  Agents at the Westin are staffed 24 hours a day across three shifts, morning, afternoon and overnight, and are responsible for answering hotel guest phone calls, and facilitating guest services such as wake up calls and room service.  The shifts are generally determined by seniority pursuant to the collective bargaining agreement but are subject to change depending on the hotel’s staffing needs.

In December 2014, the plaintiff provided Starwood with a doctor’s note indicating that she had been diagnosed with hypertension, hyperthyroidism, osteoarthritis, chronic elbow pain and cardiac arrhythmia, and recommending that the plaintiff avoid working long hours and night shifts, which could exacerbate her condition. The plaintiff requested that Starwood accommodate her by not assigning her to work double shifts or overnight shifts.  Starwood denied the requested accommodation because granting that request would have violated the seniority system dictated by the collective bargaining agreement.  Starwood proposed alternative accommodations that it would make for the plaintiff, including: (1) she would not be required to work double shifts; (2) when she was scheduled to work overnight, Starwood would post a sign-up sheet to allow other employees to volunteer to switch shifts with the plaintiff; and (3) when the plaintiff was unable to switch out of an overnight shift, Starwood would allow her to use paid time off, sick leave or leave pursuant to the Family and Medical Leave Act of 1993 (“FMLA”), with the assurance that she would not be disciplined for doing so.

Despite the fact that the plaintiff did not work a double shift or overnight shift after she requested an accommodation, she nevertheless argued that Starwood violated Federal and City disability laws because it did not provide her with the specific accommodation she had requested. Specifically, the plaintiff maintained that Starwood should have either refrained from assigning her any overnight shifts or should have offered other agents overtime pay as an incentive to take her assigned overnight shifts.

The Court disagreed. In granting Starwood’s motion for summary judgment and dismissing the Complaint, the Court held that “[h]aving offered a plainly reasonable set of accommodations to [the plaintiff], Starwood is not required to do more.”  Even under NYCHRL’s more liberal standard, the Court held that Starwood was not required to provide the plaintiff with the specific accommodation that she requested, but rather any “reasonable accommodation,” which it had done; the Court found that the accommodations offered by Starwood in not assigning the plaintiff to double shifts, and affording her opportunities to avoid working overnight shifts, were reasonable.  Additionally, the Court noted that the plaintiff was unable to identify any essential functions, benefits or privileges of employment from which she was excluded.  On the contrary, the Court held that the accommodations that Starwood offered the plaintiff allowed her to “satisfy the essential requisites of a job” and “to enjoy the right or rights associated with the position.”

Employers defending the reasonableness and sufficiency of an accommodation presented to an employee should take heed of the Court’s analysis in Kelly.  An accommodation need not be the employee’s preferred accommodation.  Rather, an accommodation will meet the statutory requirements so long as it provides the employee with the ability to perform the essential functions of the job, while also enjoying full and equal benefits and privileges of employment.

Our colleague Joshua A. Stein, a Member of the Firm at Epstein Becker Green, has a post on the Retail Labor and Employment Law blog that will be of interest to many of our readers in the hospitality industry: “Latest Website Accessibility Decision Further Marginalizes the Viability of Due Process and Primary Jurisdiction Defenses.”

Following is an excerpt:

In the latest of an increasing number of recent website accessibility decisions, in Gorecki v. Hobby Lobby Stores, Inc. (Case No.: 2:17-cv-01131-JFW-SK), the U.S. District Court for the Central District of California denied Hobby Lobby’s motion to dismiss a website accessibility lawsuit on due process and primary jurisdiction grounds.  In doing so, the Hobby Lobby decision further calls into question the precedential value of the Central District of California’s recent outlier holding in Robles v. Dominos Pizza LLC (Case No.: 2:16-cv-06599-SJO-FFM) which provided businesses with hope that the tide of recent decisions might turn in their favor. …

Read the full post here.

Our colleague Joshua A. Stein, a Member of the Firm at Epstein Becker Green, has a post on the Retail Labor and Employment Law blog that will be of interest to many of our readers in the hospitality industry: “Nation’s First Website Accessibility ADA Trial Verdict Is In and It’s Not Good for Places of Public Accommodation.”

Following is an excerpt:

After years of ongoing and frequent developments on the website accessibility front, we now finally have – what is generally believed to be – the very first post-trial ADA verdict regarding website accessibility. In deciding Juan Carlos Gil vs. Winn-Dixie Stores, Inc. (Civil Action No. 16-23020-Civ-Scola) – a matter in which Winn-Dixie first made an unsuccessful motion to dismiss the case (prompting the U.S. Department of Justice (“DOJ”) to file a Statement of Interest) – U.S. District Judge Robert N. Scola, Jr. of the Southern District of Florida issued a Verdict and Order ruling in favor of serial Plaintiff, Juan Carlos Gil, holding that Winn-Dixie violated Title III of the ADA (“Title III”) by not providing an accessible public website and, thus, not providing individuals with disabilities with “full and equal enjoyment.”

Judge Scola based his decision on the fact that Winn-Dixie’s website, “is heavily integrated with Winn-Dixie’s physical store locations” that are clearly places of public accommodation covered by Title III and, “operates as a gateway to the physical store locations” (e.g., by providing coupons and a store locator and allowing customers to refill prescriptions). …

Read the full post here.

Employers Under the Microscope: Is Change on the Horizon?

When: Tuesday, October 18, 2016 8:00 a.m. – 4:00 p.m.

Where: New York Hilton Midtown, 1335 Avenue of the Americas, New York, NY 10019

Epstein Becker Green’s Annual Workforce Management Briefing will focus on the latest developments in labor and employment law, including:

  • Latest Developments from the NLRB
  • Attracting and Retaining a Diverse Workforce
  • ADA Website Compliance
  • Trade Secrets and Non-Competes
  • Managing and Administering Leave Policies
  • New Overtime Rules
  • Workplace Violence and Active-Shooter Situations
  • Recordings in the Workplace
  • Instilling Corporate Ethics

This year, we welcome Marc Freedman and Jim Plunkett from the U.S. Chamber of Commerce. Marc and Jim will speak at the first plenary session on the latest developments in Washington, D.C., that impact employers nationwide.

We are also excited to have Dr. David Weil, Administrator of the U.S. Department of Labor’s Wage and Hour Division, serve as the guest speaker at the second plenary session. David will discuss the areas on which the Wage and Hour Division is focusing, including the new overtime rules.

In addition to workshop sessions led by attorneys at Epstein Becker Green – including some contributors to this blog! – we are also looking forward to hearing from our keynote speaker, Former New York City Police Commissioner William J. Bratton.

View the full briefing agenda here.

Visit the briefing website for more information and to register, and contact Sylwia Faszczewska or Elizabeth Gannon with questions. Seating is limited.