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November 7, 2007 nº 561 - Vol. 5

"Nothing in life is to be feared. It is only to be understood."

Marie Curie

In today's Grammatigalhas: As the current news abundantly conveys, valuation of common stock is perhaps legal valuation's most prominent art form.

• Top News

25 Percent of Pakistan's Lawyers Arrested

Under house arrest but having somehow gained access to a cell phone, the ousted chief judge of the Pakistan supreme court urged the country's lawyers today to continue to defy a state of emergency imposed by Musharraf, on Saturday. “The lawyers should convey my message to the people to rise up and restore the Constitution,” Iftikhar Chaudhry urged lawyers by speakerphone at an Islamabad Bar Association meeting before his cell phone connection was cut off. “I am under arrest now, but soon I will also join you in your struggle,” Chaudhry said. So far, although lawyers have turned out en masse, their protests have appeared to lack popular support. About 3,000 Pakistani lawyers, rounded up since Saturday, sit in jails across the country with no courts operating to which they can seek release. Pakistan's courts are in virtual "lockdown”. The country has approximately 12,000 lawyers. Reports say that police were promised a cash bounty for beating and arresting lawyers in Lahore, where much of the protesting has occurred. Thousands of lawyers have been protesting Musharraf's suspension of the Pakistan constitution and firing of many appellate judges, and hundreds have been arrested in clashes with authorities during the past 72 hours. Although the president says he declared what many see as a form of martial law in order to combat terrorism, the move is commonly understood as an attempt to prevent the supreme court—many of whose judges have been fired by Musharraf—from ruling that his re-election last month, while he remains in the military, is unconstitutional.

Chinese stocks valuation

Thanks to the capitalist stock mania sweeping the communist mainland, Chinese private and state-owned companies issuing stock for the first time are becoming incredibly valuable in speculators' eyes, sometimes overnight. The first day the state-owned energy company, PetroChina, listed shares on the Shanghai stock exchange, its market valuation ran up to more than $1 trillion. Analysts are skeptical about the way China's stocks are valued, particularly those with huge amounts of untradable government shares, like PetroChina. But to the buyers in Shanghai, at least, it dethroned Exxon Mobil as the most valuable company in the world. And by the same criteria, they would consider China Mobile the world's most valuable telecommunications company. ICBC, a state-owned bank that was nearly insolvent a decade ago, is worth more than Citigroup to the speculators. A more stable measure of a hot stock prospect is the value investors place on its initial public offering. When Country Garden, a southern China real estate company, went public in Hong Kong in April, it raised more capital than Google, which took in $1.9 billion in 2004. PetroChina raked in $8.9 billion in capital in Shanghai the other day. ICBC raised about $21 billion last year in Hong Kong. And on Tuesday, another newcomer, Alibaba.com, one of the biggest Chinese Internet companies, raised nearly as much as Google did. Afterward, the speculators sent Alibaba's stock soaring 193 percent on its first day of trading to a putative value of nearly $26 billion. Many analysts argue that there is nothing underlying the skyrocketing valuations - or, sometimes, that the companies' obscure finances make it impossible to know. And if the Chinese stock market is a bubble, the new billionaires will disappear as quickly as they rose, since much of their wealth was generated by the stock markets, as well as by the Chinese real estate boom and the Chinese economy, the fastest-growing in the world.

Muslim scholars decry 'fatwa chaos'

Around the world, an explosion in the number of fatwas - pronouncements by religious leaders intended to shape the actions of the faithful on everything from sex to politics - is driving efforts by prominent Muslims to rein in the practice. That's proving a nearly impossible task, given Islam's decentralized nature and the growing number of outlets for the edicts. With no pope or patriarch to arbitrate orthodoxy, "it's the nature of Islamic thought to have many options," says the Islamic Research Compilation Center in Cairo. "But there are too many unqualified opinions being spread, and this is wrong." Clerics are supposed to have religious and legal training on which to base their authority. Even trained scholars have issued contradictory fatwas about whether suicide bombing and attacks on civilians are justified, creating political and theological controversies.

Bankers among 20 arrested in Brazil

Brazilian police have arrested 20 people including an employee of UBS, the Swiss bank, on suspicion of crimes including money laundering, tax evasion and illegal transfer of money overseas. UBS, Credit Suisse and US insurance giant AIG are among those under investigation.

Award on corporate governance on non-listed companies

The prestigious Monique Raynaud-Contamine Award for young lawyers, a prize attributed by the Union International des Avocats (UIA), has been awarded this year to Raquel Azevedo, a junior partner at PACSA & Cameira in London, for her report on “Corporate governance on non-listed companies – special features of corporate governance in connection with family-run companies.” The London office of PACSA & Cameira specializes in legal advise to English investors wishing to invest in Brazil and has established links with firms in Rio de Janeiro and São Paulo.

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• Crumbs!

1 - Musharraf's chief critic silenced as lawyers continue protests.

(Read more)

2 - Bush promises help for Turkey over rebels as he tries to avert Iraq attack.

(Read more)

3 - Gordon Brown hopes 23 Bills will boost his popularity as poll lead slips.

(Read more)

4 - BMW misses profit estimate. (Read more)

• MiMIC Journal

The newest billionaires: China's economy churns out dozens

The United States has more billionaires than any other country: 415 by Forbes's last count. No. 2, and closing fast? China. A year ago, there were 15 billionaires in China. Now, there are more than 100, according to the widely watched Hurun survey, and 66, according to Forbes. Unlike America's rich, China's are hardly famous, even in China. Gates, Buffett and Brin are known around the world. But Yang, Guo and Zhang?

Chinese province 'may sue Mattel'

China's Guangdong province is likely to join a planned libel suit against the US toy giant Mattel, according to the China Daily. Mattel recalled more than 21 million Chinese-made toys this summer, but later said that 85% of the recall was due to its own design faults.

• Grammatigalhas

Legal Meaning Is Not Everyday Meaning

Valuation

Placing a value or worth on an asset. Stock analysts determine the value of a company's stock based on the outlook for earnings and the market value of assets on the balance sheet. Stock valuation is normally expressed in terms of price/earnings (P/E) ratios. A company with a high P/E is said to have a high valuation, and a low P/E stock has a low valuation. Other assets, such as real estate and bonds, are given valuations by analysts who recommend whether the asset is worth buying or selling at the current price. Estates also go through the valuation process after someone has died.

Irrational Exuberance

The late 90s astronomical valuations of some high-tech companies suggested that stock analysts can stray (badly) from DCF. In April 1999, AOL was selling at 700 times its earnings, assumed a "sky is the limit" growth potential. It defied all conventional valuation logic.

At the time Fed Chairman Alan Greenspan admonished investors against "irrational exuberance." Greenspan looked wise when, during 2000, the bubbles of many stocks burst. For example, Globe.com went public in 1998 and had the largest one day price leap in history. In 2001, the stock was pulled from the NASDAQ market listings because its price was too low.

Discount for lack of marketability

This discount, also known as the liquidity discount, comes into play in situations where the business owner's ability to readily sell his or her business is questionable. For example, publicly traded companies are highly marketable, and their shares can be quickly turned into cash. Closely held companies, however, are sometimes far more difficult to sell. Depending on the valuation, it may be necessary to subtract a discount for lack of marketability, or add a premium for the presence of marketability.

Everyday "Legal" Jargon

Stock Valuation

Valuation of common stock is perhaps legal valuation's most prominent art form. And, as we've been observing, "value, like beauty, is in the eye of the beholder."

But is stock price a good criterion? Academics, reformers, and business leaders all yearn for a single, objective, easy-to-read measure of corporate performance that can be used to judge the quality of public corporation law and practice. This collective desire is so powerful that it has led many commentators to grab onto the first marginally plausible candidate: share price.

Contemporary economic and corporate theory (as well as recent business history) nevertheless warn us against unthinking acceptance of share price as a measure of corporate performance.

Share Price as a Metric of Corporate Performance

It is easy for us to forget, today, that for much of the 20th century, scholars and business leaders alike viewed stock prices as only very weak indicators of business performance. In their 1932 classic The Modern Corporation and Private Property, Adolph Berle and Gardiner Means noted drily that “the values accorded to securities on the faith of market quotations are only ‘paper’ and perhaps ought not to be invested with any great amounts of significance.” John Maynard Keynes had an even more cynical view. In his 1936 The General Theory of Employment, Interest, and Money, Keynes famously described the stock market as a “beauty contest” in which prices were largely disconnected from value.

This sort of skepticism about the relationship between stock price and corporate value largely disappeared during the 1960s and 1970s. The disappearance can be traced in large part to the development, and subsequent academic promotion, of two fundamental ideas in modern corporate finance.

The first fundamental idea is the idea of an “efficient” stock market. According to efficient market theory, stock prices in a liquid market incorporate new information quickly and accurately. So quickly and accurately, in fact, that the market price of a company’s shares offers the best possible estimate of the underlying economic value of shareholders’ equity interest in the firm.

The second fundamental idea might be termed the “principal-agent” model of the firm. As commonly employed, the principal-agent model views the shareholders in a corporation as the “principals” of the firm who should benefit from the firm’s profits. Other groups that participate in corporations—including creditors, executives, and rank- and-file employees—are viewed as outsiders or “agents” who ought to extract from the firm only the payments their contracts legally entitle them to extract. The principal-agent model as a result views shareholders as the sole residual claimants in corporations. This implies that any increase in the total value of the firm will produce an equivalent increase in the value of shareholder equity, while a decline in firm value produces an identical decline in shareholder wealth.

Taken together, efficient market theory and the principal-agent model provide the essential ingredients for an almost-irresistibly appealing final product--an apparently accurate, objective, and easy way to calculate corporate performance. All we need to do is observe stock price. Efficient market theory and the principal-agent model accordingly provide the foundation for one of the most common and powerful and omnipresent (if often unspoken) assumptions in contemporary discussions of corporate law: the assumption that anything that raises share price must be good.

How nice if this were true. How disappointing that stock prices do not, in fact, accurately capture corporate value.

Five Lessons on the Fallibility of Share Price

Twenty years ago, the claim that stock prices do not necessarily measure corporate performance might have provoked howls of protest from many readers. Especially during the mid-1980s, when efficient market theory and the principal-agent model were at their zenith, finance theorists and corporate scholars often embraced the notion that stock prices capture economic value with a passion that bordered on the religious.

Our collective confidence in the accuracy of stock prices was badly shaken, however, on October 19, 1987, when the Dow Jones industrial average inexplicably lost 23 percent of its value in a single trading session. (The value appeared again, equally mysteriously, a few months later). In 2000, the dramatic collapse of the 1990s tech stock bubble further undermined many observers’ trust in market prices. Most recently, we have had to contend with a series of high-profile cases like Enron and Global Crossing, in which corporations saw their share price first soar beyond any sane estimate of value and then crash as forcefully.

Such object lessons have taken their toll on most people’s faith in the strength of the supposed connection between stock prices and corporate performance. They have also spurred academics to produce not one, but several, important literatures that examine how and why stock prices often fail to accurately measure underlying corporate value. Most readers are probably familiar with one or more of these literatures. My guess is that, if pressed, most also would concede stock prices often bear only a weak relationship to corporate performance.

But at least a few die-hard souls might defend the market’s efficiency. Many others might be tempted to suggest that stock prices, while imperfect, nevertheless capture value reasonably accurately much of the time. Still others would squirm uncomfortably and change the subject. Such is the power of the dream of measurability to capture our hearts.

In both business and scholarship, however, it is important to use our heads. We may hope for a single, objective, accurate, easy-to-read measure of corporate performance. Hope nevertheless is not the same thing as reality. For readers romantic enough to cling to the dream of measuring corporate performance by stock price, I offer below a brief reminder of some of the many reasons why contemporary economic and corporate scholarship teaches us that stock prices often fail to reflect true corporate value.

1. The Problem of Private Information

Even the most zealous defenders of efficient market theory usually concede stock prices do not fully reflect “private” information that is not available to the investing public. In the parlance of finance economics, the market is at best semi-strong efficient.

Yet once we admit that prices do not incorporate private information, we are forced into a second admission: prices will often fail to reflect information that is valuable, even essential, to valuing firms. Consider the classic and rather common example of nonpublic information that the company’s books are being cooked.

Some readers might object that the sort of price inaccuracy that results from private information is likely to persist only for the short term. Eventually, the good--or bad--news must come out. But in today’s stock market, many influential investors (including both outsiders like hedge funds and mutual funds and insiders like executives whose options are about to vest) expect to hold their stock for only a few weeks or months. As a result, short term inaccuracies can lead to long term distortions in corporate strategy and policy.

2. Obstacles to Arbitrage

Efficient market theory relies on arbitrage to incorporate new information quickly and fully into market price. Modern finance economists have come to believe, however, that in real life, stock traders often face serious obstacles to arbitrage, including but not limited to capital constraints, short sales restrictions, borrowing constraints, and holding period constraints.

Once we recognize that there are limits to arbitrage, we must also recognize that some kinds of “public” information—especially information that is difficult for average investors to obtain or understand—will tend to be incorporated into market prices only slowly and incompletely. Many sophisticated observers believe, for example, that during the 1990s, the prices of many tech firms’ shares failed to fully reflect publicly-available information about the dilutive effects of employee stock options. Again, the result was significant inaccuracies in stock prices that persisted long enough to seriously distort investment strategy, executive compensation, and other important business decisions.

3. Behavioral Finance and Investor Irrationality

The notion that stock prices accurately measure the value of shareholders’ equity depends, at a very fundamental level, on an underlying belief that investors value stocks by making rational estimates of future risks and returns. Contemporary economists, however, increasingly question investor rationality on both theoretical and empirical grounds. The hottest new field in finance is “behavioral finance” – the study of how investors’ emotions and cognitive biases systematically distort stock prices.

The rise of behavioral finance has deep-seated implications not only for finance economists, but for corporate governance experts as well. A stock market driven by manias and cognitive quirks can hardly provide a reliable basis for gauging corporate performance. (Remember Pets.com?)

4. Options Theory, Team Production, and the Problem of Multiple Residual Claimants

Even if stock prices accurately captured the economic value of shareholder equity, they would be a good measure of corporate performance only if changes in equity value necessarily mirrored changes in aggregate firm value. The principal-agent model addresses this issue by “assuming the can opener”—that is, by assuming that shareholders are the sole residual claimants in corporations.

Modern options theory and team production theory both teach that this assumption is incorrect. Options theory demonstrates that creditors are also potential residual claimants and residual risk bearers in firms. As a result, shareholders can increase the economic value of their equity interest simply by extracting value from creditors. For example, they can pursue high-risk strategies that raise share price while degrading the quality and value of the firm’s debt.

In the same vein, team production theory teaches that economic production often requires executives, employees, customers, and other non-shareholder groups to make firm-specific investments (e.g., sunk cost investments of time or effort, or investments in knowledge, skills, or relationships uniquely specialized to a particular firm). Often these firm-specific investments cannot be protected with formal contracts. As a result, non-shareholder constituencies end up being residual claimants and risk bearers.

This means, again, that shareholders can raise stock price not only by increasing the value of the firm as a whole, but also by extracting wealth from non-shareholder constituencies. Oracle’s recent purchase of competitor Peoplesoft offers an example of just such a rob-Peter-to-pay-Paul strategy. Peoplesoft’s shareholders earned a modest premium from the sale. Because Oracle plans to stop selling many of Peoplesoft’s products and lay off much of its workforce, much of the gain seems likely to come from Peoplesoft’s employees and customers.

5. Share Price and the Diversified Shareholder

So far the discussion has focused on why stock prices fail to accurately capture the economic value of shareholder equity (as predicted by efficient market theory) and why changes in shareholder equity often fail to mirror changes in the overall value of the firm (as assumed by the principal-agent model). Yet even if these problems did not exist—even if we ignore evidence and reason, and assume efficient market theory and the principal-agent model accurately describe modern corporations--we still cannot safely assume that share price measures corporate performance for diversified shareholders.

This is because diversified shareholders own stocks in many firms and in many industries. They also often own corporate bonds, government bonds, and real estate. If individuals, they “own” and usually invest in their own human capital (knowledge and skills they sell to employers). As a result, diversified investors worry about business strategies that increase the value of one of their investments by harming the value of others. For example, diversified shareholders have mixed emotions about corporate takeovers, which provide gains for target shareholders but often depress the prices of bidding firms. They worry about high-risk strategies that raise share price while devaluing debt. They are distressed when the companies they invest in shy away from investing in research or employee training that provides valuable spillover benefits to other companies they also invest in. And they worry when their financial capital is managed in a way that harms their human capital—for example, when corporations raise share price by reducing employee wages or polluting the environment.

Enron offers a wonderful example of how policies that ruthlessly maximize the price of one firm often produce spillover effects that harm diversified investors’ other interests. By trading risky energy derivatives, Enron for many years achieved superlative returns on its shares. Eventually, however, its gambling luck ran out, and the firm was tipped into insolvency. Most of the resulting losses were borne not by Enron stockholders (many of whom made enormous amounts of money over the years) but by Enron bondholders, customers, counterparties, and employees, along with the residents of Houston, Texas.

These considerations argue against assuming there is a tight connection between stock prices and underlying corporate wealth generation. A corporation or a corporate law system designed around the philosophy that anything that raises share price is good is likely to produce a firm that cooks its books; that avoids long-term projects that won't appeal to unsophisticated investors; that chases after investment fads and fancies; that tries to opportunistically exploit creditors, employees, and customers; and that pursues business strategies that harm its diversified shareholders' other investment interests.

If we allow our desire for a universal performance measure to blind us to the fallibility of share price, we court costly error. Three recent examples of just such erroneous triumphs of hope over experience: the rise and fall of the Revlon doctrine; the 1990s infatuation with options-based executive compensation; and academics' current preoccupation with event studies, regressions on Tobin's Q, and other forms of empirical scholarship that attempt to judge the quality of corporate law and practice according to changes in share price.

As If Your Life Depended On It… or How to get to Carnegie Hall? - Practice, practice

Set off on the right/wrong foot

Begin something well/badly. The left foot is the wrong foot. The Romans held that anything to do with the left had evil consequences. The gods guarded your right but evil spirits hovered on your left. The Latin for left is “sinister”, a word that has lost its 'leftness' in English but retains the ancient meaning of foreboding. The Romans lived in such intense dread of the powers of evil that guards were appointed to stand at the doorway to all public places to make sure that the right-foot rule was obeyed. The tradition of the bride being carried over the threshold is thought to have originated in this superstition. It would not do for her to start the marriage off on the wrong foot.

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• Historia Verdadera

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• Brief News

High-priced oil adds volatility to power scramble

As the price of oil surges toward a symbolic milestone of $100 a barrel — hitting above $98 in early Asian trading Wednesday — it is creating new winners and losers across the globe. Eight years ago, oil was trading at $16 a barrel. The prospect of triple-digit oil prices has redrawn the economic and political map of the world, challenging some old notions of power. Oil-rich nations are enjoying historic gains and opportunities, while major importers — including China and India, home to a third of the world's population — confront rising economic and social costs. Managing this new order is fast becoming a central problem of global politics. Countries that need oil are clawing at each other to lock up scarce supplies, and are willing to deal with any government, no matter how unsavory, to do it.

Bush's Import-Safety Plan Is Detailed

A new Bush administration proposal to give the federal government sweeping authority over imports won plaudits yesterday as a step toward restoring public confidence in product safety. But some advocacy groups warned that unless the plan was backed by significant funds, it would prove meaningless. The proposal provides for the federal government to revamp the way it monitors $2 trillion worth of imported products each year. Under the plan, imports deemed to be especially risky would undergo mandatory safety certifications in the country of origin before shipment. Importers could submit less risky products to voluntary certification in exchange for speedier handling at entry ports. Fines would increase for companies that sent hazardous products to the United States.

Law Firm Launches Web 'Chat Service' for Potential PI Clients

For potential clients who need a personal injury lawyer, setting an appointment and going to an attorney's office for an initial consultation can be a daunting process. But a British firm hopes to encourage the solicitor-shy to come to them by offering an Internet "chat service" that gives potential clients a chance for a live "talk" with a lawyer simply by logging onto a computer. The option offered by a Manchester firm known as Pannone is highly unusual in the United Kingdom, and probably elsewhere, too.

EU to dismantle more border posts

Officials are preparing to agree Thursday that nine nations are ready to join Europe's free travel zone. Frontier posts are to be dismantled across Eastern Europe and passport checks scrapped as the European Union prepares to extend its free travel zone to the borders of Ukraine and Belarus. Continental Europe's Schengen system does away with internal passport controls.

Pre-Exit Antics

More companies are suing job hoppers for luring staffers or clients while still employed there, claiming breach of fiduciary duty.

Clifford Chance Lays Off Six Lawyers

In another sign that the credit crunch is affecting Big Law, Clifford Chance laid off six associates in its structured-finance area yesterday. The lawyers worked exclusively for S&P assisting in the documentation for rating mortgage-backed securities, a business that’s collapsed. McKee Nelson are encouraging associates to take sabbaticals, change practice groups or leave the firm. So what’s going on? We keep telling you about phat year-end bonuses being doled at big law firms, yet at the same time we’re starting to see Big Law layoffs? Is it just that these firings will be limited to collapsed practice area, or will we see start to see the credit crunch affect other areas?

Turkish PM welcomes delayed vote on US House Armenian genocide resolution

Turkish Prime Minister Erdogan said Monday that he views a decision by US lawmakers to postpone debate on a resolution labeling as genocide the World War I-era killings of over one million Armenians by Turkish soldiers with "cautious optimism." Erdogan commented Monday after talks with Bush, thanking the administration and House members who opposed the bill. Turkey has long objected to any attempts to classify the 1915 Armenian killings as genocide. Several other countries - including France, Canada and Argentina - have nonetheless passed laws or resolutions to that effect.

Senate judiciary panel backs Mukasey as US attorney general

Reports came that the US Senate Judiciary Committee voted 11-8 Tuesday in favor of the nomination of former federal judge Michael Mukasey to serve as the next US attorney general. The committee's hearing on the nomination is still ongoing. Mukasey's nomination now goes to the full US Senate for a final vote. Most Democrats on the Senate Judiciary Committee voted against the nomination. Several senators on the committee balked at voting for Mukasey over his refusal to unequivocally denounce waterboarding as torture.

Supreme Court to weigh ineffective assistance of counsel in death penalty plea bargain

The US Supreme Court on Monday granted certiorari in Arave v. Hoffman (07-110) to consider whether a death row inmate in Idaho should be able to accept a plea bargain after his conviction based on an argument that the deal was rejected because of bad advice from his lawyer. Convicted of murder in 1989, Maxwell Alton appealed and argued that he should be allowed to take the plea bargain after the fact. Alton initially rejected the plea bargain due to his lawyer's advice that that Idaho's death penalty system would soon be overturned. The US Court of Appeals for the Ninth Circuit accepted Hoffman's argument and ordered the lower court to direct the state to release Hoffman or offer him the original plea bargain.

• Daily Press Review

Ugandan rebel deputy feared dead
BBC News, Centrist newscaster, London, England

Sixteen Ituri warlords give up the fight
CongoPlanet.com, Independent online news aggregator

NPP just came to loot the country - Wayo
GhanaWeb, Online news portal, Amsterdam, Netherlands

Sudan: Cease Darfur Camp Evictions
Human Rights Watch (Africa), International news press releases

Woodstock killers still at large
iafrica, Online news portal, Cape Town, South Africa

'Is she saying Mandela was a crook?'
Independent Online, News portal, Cape Town, South Africa

Trial within a trial set to begin in Motata case
Mail & Guardian Online, Liberal, Johannesburg, South Africa

'Several versions' of Motata recordings
News24.com, Online news portal, Cape Town, South Africa

UN praises Cuba's ability to feed people
Brazil Sun, Independent online news aggregator

Manning and PNM win Trinidad Elections 2007
Caribbean News Portal, Online news aggregator

US: Makeshift Military Commissions Rules Unfair
Human Rights Watch (Americas), International news press releases

Mexico: People, Nature Share Responsibility for Tabasco Tragedy
IPS Latin America, International cooperative of journalists, Rome, Italy

Kern wept - Former State Minister jolted by Cuban bulb saga
Jamaica Gleaner, Independent daily, Kingston, Jamaica

Peru: Photo of the day - 5 Trucks of Contraband Seized
Living in Peru, News portal, Lima, Peru

Pakistan is the latest in a string of foreign policy failures for Bush
The Globe and Mail, Centrist daily, Toronto, Canada

GO train assault haunts victim
Toronto Star, Liberal daily, Toronto, Canada

Tunisia continuing to strengthen ties with Indonesia
Antara News, News agency, Jakarta, Indonesia

Who's Going to Do the Hard Medical Work?
Chosun Ilbo, Conservative daily, Seoul, South Korea

The science of love: Look into my eyes
India Express, News portal, Mumbai, India

Bar raided in Mumbai, 29 girls held
India Times, Conservative daily, New Delhi, India

Three relationships the U.S. must tend to
Japan Times, Independent centrist, Tokyo, Japan

Not that many illegals working at gas stations
Malaysian Star, Online news portal, Selangor Darul Ehsan, Malaysia

Mexico army searches mudslide, 16 feared dead
New Zealand Herald, Conservative daily, Auckland, New Zealand

Erekat: There's progress in the Israeli position
People's Daily Online, English-language, Beijing, China

It's over for Willie and the Bulldogs
Sydney Morning Herald, Centrist daily, Sydney, Australia

Rise up, Chaudhry tells lawyers
The Hindu, Left-leaning daily, Chennai, India

Police may get post-charge powers
BBC News, Centrist newscaster, London, England

McGeady can surpass Ronaldo, says Boruc
BreakingNews.ie, Online news portal, Cork, Ireland

Murdered Meredith's flatmate: 'I heard her die in sick sexual fantasy'
Daily Mail, Conservative daily, London, England

Microsoft invites Xbox users to 4 days of free gaming
DMeurope, Online news portal, Amsterdam, Netherlands

Unanimous approval for new Liverpool FC stadium
icLiverpool, Online news portal, Liverpool, England

In Russian renaissance, safety takes backseat
International Herald Tribune, Independent daily, Paris, France

Dictatorship in Pakistan: Musharraf's Martial Plan
Spiegel International, Liberal newsmagazine, Hamburg, Germany

Millions may get right to flexible work
The Guardian, Liberal daily, London, England

Duma votes to suspend arms treaty
The Irish Times, Centrist daily, Dublin, Ireland

Oil workers arrested over plane disturbance
The Scotsman, Moderate daily, Edinburgh, Scotland

Macca's Nancy fought cancer
The Sun, Conservative tabloid, London, England

Eight-limbed girl has headless twin removed
The Telegraph, Conservative daily, London, England

Surgery starts to save Lakshmi from twin sharing her body
Times Online, Conservative daily, London, England

Police Admit They Confiscated Nationalists' Film
Arutz Sheva, Online, right-wing, Tel Aviv, Israel

Saudi Curriculum to be Made Available Online
Asharq Al-Awsat, Pan-Arab daily, London, England

Russia votes to suspend arms treaty
Gulf News, Independent daily, Dubai, United Arab Emirates

Mideast: High Stakes for Annapolis Peace Meet
IPS Middle East, International cooperative of journalists, Rome, Italy

Mobily Starts SR1b 3G Network Expansion
Middle East North African Network, Online financial portal, Amman, Jordan

NATO, UN Chiefs Condemn Afghan Bombing
Nahamet, Online news portal, Beirut, Lebanon

Israel accuses IAEA chief of playing into Iran's hands
The Daily Star, Independent daily, Beirut, Lebanon

Hafidh freed before one day of his execution
Yemen Times, Independent weekly, Sana'a, Yemen

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The messages that appear in this newsletter are for informational purposes only. They are not intended to be and should not be considered legal advice nor substitute for obtaining legal advice from competent, independent, legal counsel in the relevant jurisdiction.

Transmission of this information is not intended to create, and receipt does not constitute, an attorney-client relationship. The information contained on this list may or may not reflect the most current legal development.