How the Government is Handling Online Privacy and Cybersecurity

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Transcript

Planet Lex: The Northwestern Pritzker School of Law Podcast

How the Government is Handling Online Privacy and Cybersecurity

04/24/2017

[Music]

Intro: Welcome to Planet Lex: The Podcast of Northwestern Pritzker School of Law, with your host Dean Daniel B. Rodriguez, bringing it to you from Chicago, Illinois. Take it away, Dan.

Daniel B. Rodriguez: Hello and welcome to Northwestern Law’s Planet Lex, podcasting from the Northwestern Pritzker School of Law here in Chicago, Illinois. My name is Dan Rodriguez, I am your host.

Joining me today to talk about issues of technology, privacy and the law, is my colleague Jim Speta. Jim has been a member of the Northwestern Law Faculty since 1999. His research interests include telecommunications, law and Internet policy, antitrust, administrative law, and market organization.

He previously clerked for Judge Harry Edwards on the United States Court of Appeals for the D.C. Circuit and practiced Appellate Telecom and Antitrust Law with the Chicago Law Firm of Sidley Austin or maybe it was Sidley & Austin when you were there.

Jim Speta: That’s exactly right.

Daniel B. Rodriguez: Took away the ampersand. So Jim, thank you for joining me.

Jim Speta: Great to be here.

Daniel B. Rodriguez: So no big secret what’s on folks’ minds certainly those who are in the telecom world is the fate of net neutrality. As we are here meeting on March 28, I am looking at a blog post from earlier this morning entitled “You have just hours to stop Congress from giving away your web browsing history. Time to make some calls.” What’s that about?

Jim Speta: Just at the end of the Obama administration, the FCC adopted rules that would forbid Internet service providers from collecting and using customer information such as where are you browsing, how long are you there, what services are you using without a very explicit consumer opt in. This legislation will rescind those rules and forbid the FCC from making any similar rules in the future.

Daniel B. Rodriguez: And what is the status of the legislation again as we’re here near the end of March?

Jim Speta: It’s already passed the Senate basically on a party-line vote of 50 to 48 and it’s pending in front of the house. It’s expected to pass and president Trump is expected to sign it.

Daniel B. Rodriguez: What is the concern, what is the worry that underlies; first, let’s start with the regulations themselves? What is the boogeyman here?

Jim Speta: The worry is that the Internet service provider to whom an individual connects is in a position to capture an extraordinary amount of personal information just based on what you’re doing on the Internet, and today of course, people do everything on the Internet. So the FCC’s rules were designed to protect individual’s privacy in their web use essentially.

Daniel B. Rodriguez: So when you mentioned a moment ago that under the current regulations, there’s an opt-in provision so it sort of puts the onus on the providers to have to request consumers to opt-in. How many would opt out, and I guess, it’s just another way of asking the question is, what is the real threat to individuals’ privacy?

Jim Speta: That’s a very contested issue, although it’s usually contested at the level of whether people care about their privacy, we have some data from other types of services that when people are given very explicit information about how their personal information is being used, they do opt out in more significant numbers but they tend to opt out in the range of 20-40%, 50% depending on the kind of information, not in the range of 80% or 90% or a 100%.

Daniel B. Rodriguez: If Congress is successful as it appears it would be in enacting this repeal and then actually enacting this overturning the FCC Regs and the President signs it, is it still available to the Federal Communications Commission to adopt modified regulations, would that be permissible under the relevant statutes.

Jim Speta: The relevant statute, and you and I share this sort of interest in this quirk of administrative law, it’s called the Congressional Review Act, which gives Congress 60 days to pass a law overruling any regulation. That law says that the agency cannot then adopt a substantially similar regulation and the issue then would be is any modified rule substantially similar.

I think the intent of Congress in passing this repealer is to try to get the Federal Communications Commission out of the business of regulating Internet privacy in preference to the Federal Trade Commission.

Daniel B. Rodriguez: Interesting. So that brings us since we’re talking about the FCC back to the new Chair, Mr. Ajit Pai, who was appointed by the Trump administration recently to head the FCC. I see here he’s advertised at the time of the inauguration as a net neutrality votes as net neutrality vote ahead the FCC. So in getting us to talk about the new Chairperson I guess, 04:37 on what this business of net neutrality is about.

Jim Speta: The essence of net neutrality is the question of whether there ought to be regulations on your access provider, your Comcast or your AT&T, the company from whom you get your Internet access, regulations that forbid that company from discriminating among different content providers or application providers.

(00:05:00)

And in 2015 after basically ten years of trying to do so, the FCC adopted some rules forbidding that discrimination that the D.C. Circuit upheld just last year.

Daniel B. Rodriguez: So let me just underscore the 2015 because there’s a sense when one reads some of the popular literature on net neutrality, it’s sort of a state of nature in some sense or it’s always been around or it’s part of the underlying philosophy of communications law of the Internet, but that’s not the case at all, right? As you mentioned, it’s really been more or less a couple of years since the relevant regulatory authorities have put a stake in the ground and said, net neutrality is part and parcel of how we should think about regulating the Internet.

Jim Speta: That’s true. And the issue of net neutrality is tied to an underlying much more important issue of regulatory classification. To go back to the sort of premise of communications law, there has been a non-discrimination obligation in Communications Law since the beginning of Communications Law, since 1934, but what was different was when the Internet came into being say in the mid-1990s, when it became a commercially and much more popularly available service, was that the FCC said we’re going to leave our hands off the Internet and we’re not going to treat it as the same kind of service as traditional telephone service, not going to treat it as what we call a common carrier service.

Now when the Internet became in the mid-2000s, 2005-2006, the dominant form of personal communication, the FCC began to reconsider that issue and to say, maybe we need to think about some controls over how Internet carriers can behave, and starting in 2005, the FCC adopted some principles and some policies suggesting what they wanted was a non-discrimination rule for Internet carriers as well.

And it went back and forth to the D.C. Circuit twice and failed. The D.C. Circuit was not convinced that the FCC had authority to impose these rules without also calling Internet service a common carrier service. So in 2015, the big step that the FCC took and it was — it’s an enormous step was to say broadband Internet access service is common carrier service and we are going to impose many of the same rules that have always applied to telephone companies to Internet carriers.

Daniel B. Rodriguez: Tell us a little bit about the FCC in this context. I mean, I notice you didn’t mention the C word that is “Congress” in this discussion, they enacted the Telecommunications Act in the mid-1990s, but it sounds like despite the drama over how to think about regulating or not regulating the Internet, this was mostly actions in the part of the Relevant Regulatory Commission and not big bad Congress.

Jim Speta: It was mostly actions on the part of the Federal Communications Commission. Congress considered bills, couldn’t get them passed, many representatives and senators expressed their views to the FCC at one point in say around 2010, more than 200 members of Congress wrote to the FCC saying don’t do a net neutrality regulation.

And so it was a politically contested issue, was an issue on which President Obama weighed in and during the entire time of President Obama’s FCC, there were three Democratic appointees and two Republican appointees and this issue split the Commission 3:2. One of the reasons we know that the new chairman, Chairman Pai is so opposed to net neutrality regulation is that he dissented from the 2015 order.

Daniel B. Rodriguez: So his appointment came as no surprise to anyone with the election of Donald Trump. I’m curious was this an issue that was prominent at all in the presidential election, was this an issue about which Trump or the other Republicans ran?

Jim Speta: No, it was mentioned and it was mentioned in the Republican platform but it didn’t have any salience as far as I could tell in the political campaign in 2016. It had a little bit of salience in 2012 and President Obama, as I said, did mention it a few times and was clearly and personally in favor of net neutrality regulation.

Daniel B. Rodriguez: Does the Chairman have the power — he obviously doesn’t have the unilateral power but just from the political winds, does he have the power to make good on his promise to eradicate the open Internet order?

Jim Speta: He probably does. He probably has to wait for appointment of a full FCC and because we are outside this sort of funny 60-day window that’s being used in the Broadband Privacy Order, the FCC would have to go through a new rule-making proceeding, which as we know notice and comment and a whole bunch of other public procedures before it repealed but the Republicans will have three votes and the Democratic appointees will have two votes because we have a Republican President.

Daniel B. Rodriguez: Right, and whereas if the Senate were under Democratic control, there could be a real likelihood, right, that there would be confirmation wars, it doesn’t appear likely if the Senate’s vote on the broadband privacy rules right, which was 52 to 48 rate as you described exactly on party lines, is any indication that would be probably identical to the vote on confirmation of FCC commissioners?

(00:10:00)

Jim Speta: I think that’s exactly right.

Daniel B. Rodriguez: Let me ask you a different question, which is sort of the what’s the big deal question with respect to the repeal of the open Internet order, at least based on what I read, and this falls under the rubric of a little knowledge is a dangerous thing. But I am sure you’ll correct me, and that is, the net neutrality rules only apply as I understand it to what is called the Internet backbone, right, so the sort of the basic structure of the Internet.

Now we know that a lot of the utilization by consumers of information that comes through streaming of Netflix and others are through these big companies AT&T, Comcast, Verizon and the like. My understanding is, most of that activity, significant part of the activity that consumer use, again, streaming of Netflix videos, for example, is outside of the Internet backbone as it were, right? So the questions of discrimination in terms of fast speed for these particular companies isn’t covered in any event under principles of net neutrality, or is that incorrect?

Jim Speta: No, you are exactly right that there were significant gaps in the FCC’s net neutrality order that didn’t go — therefore the order didn’t go all of the way towards the nondiscrimination requirements. Some of those have to do with what you’ve mentioned the way the backbones interconnect with the local access networks, some of them have to do with classifying what services were subject to a nondiscrimination obligation. So the rule tried to eliminate discrimination between different kinds of services but if the access network decided to offer the service itself it just wasn’t subject to the rule.

The important part of the rule was this reclassification, to call Internet access a common carrier service then gave the FCC the power to go those additional steps. If they felt interconnection was a problem or if they felt classification of types of services was a problem they were clearly going to be able to regulate it and they put a stake in the ground that said what we want is an open Internet, a non-discriminatory Internet.

Daniel B. Rodriguez: So this dwells in the realm of speculation I suppose, had the election come out the other way. Actually not true. So let me say this, suppose there is a change in administration and in the coming two years, coming four years there is a greater emphasis on revisiting the matter of net neutrality. Of course, technology will have changed somewhat by that time. Do you anticipate and could you anticipate that the FCC in tandem with the new administration will revisit the question of how broad to expand the scope of regulation? I guess, a less cumbersome way of asking the question is, is it possible that these streaming services and things outside the scope of the Internet backbone and these very big and growing companies like Verizon, Comcast, others, will be subject to greater regulation and greater control?

Jim Speta: Yes, and one of the concerns of industry and of consumer groups is that we could see a lot of back and forth about what the scope of the regulation is, even on these fundamental questions of common carrier classification.

I think my sense is, if we had a new administration, the question for every administration is what are we going to spend our time doing? It’s possible that Commissioner Pai will decide that it’s not his most important priority to repeal the net neutrality rules, but if he does, it may be not a high priority for the next administration to bring them back again.

I think that the companies who act in this space act under the shadow of regulation. And so, we have some hope that the companies have an economic interest as well as a political interest in keeping the Internet the seedbed of innovation, the openness that we’ve all sort of enjoyed, and no one, industry or consumer groups, really wants the rules to keep going back and forth and back and forth.

Daniel B. Rodriguez: There can be, as you point out, collective interest, but as you know wearing your antitrust hat restrictions on collective action, right? So I was struck by — I mean maybe this is anachronistic but in 2014 one observation was that just 30 companies controlled essentially a one-half of all the primetime Internet traffic. My guess is that that’s probably even a smaller number now. So would consolidation in the industry represent threats to our nation’s antitrust laws?

Jim Speta: It remains to be seen under the Trump administration how much active antitrust enforcement there will be in these areas, but even under the Obama administration there wasn’t outside of the merger context much antitrust activity in the digital marketplace. But you have identified I think what’s exactly the right problem today in residential access networks more than 60% of all traffic during primetime comes from Netflix and from YouTube and —

Daniel B. Rodriguez: I am doing my fair share.

Jim Speta: I am doing my fair share too, absolutely.

Daniel B. Rodriguez: While there is funny cat videos out there and episodes of ‘Homeland’, it’s not a commercial for SHOWTIME then I am going to be working on it.

Jim Speta: What unifies the two issues that you have identified, the broadband privacy rules and the net neutrality rules was a view from the Obama FCC that Internet service providers had a significant amount of market power, that is, we just don’t have that many choices where we’re going to get our high-speed Internet service.

(00:15:08)

And in fact the Obama FCC on the broadband privacy rules was explicit that it needed to apply the rules to ISPs but not to Google or to Facebook or to Amazon because you had a choice. If you didn’t like Google you could use Bing, if you didn’t like Facebook you could use I guess Google. If you don’t like Amazon you can go to the store.

But if that changes, if at the content and application layer we seem to get the same sort of concentration that we’re having at the Internet service provider level, then we should be concerned in a very similar way to apply policies at all of those layers.

Daniel B. Rodriguez: So if we’re not too far in the weeds already let me get even deeper in weeds by asking a question that strikes me is fascinating, maybe you and I and a handful of listeners will be the only ones to think it so, and that is a potential lacuna and regulation.

And so I refer back to a decision, remarkable decision from the Ninth Circuit late last summer in which the Circuit Court was asked to consider the scope of an agency we haven’t yet talked about which is the Federal Trade Commission, the FTC’s authority under Section 5 to regulate, I think it was AT&T, right.

If I am correct about this. I am sure you will correct me if I am wrong. The holding was the FTC lacks this regulatory authority, because even though the AT&T in this particular context was not acting as a common carrier that it has the status of a common carrier, and so, as a status of the common carrier it’s hands off from the FTC, which at the time is based on what I have read is remarkable ruling leaves a significant regulatory hole.

Jim Speta: It does leave a significant regulatory hole and that is what the Ninth Circuit held. It has always been a difficult question of institutional design whether the Federal Trade Commission should have authority over everything or whether there should be carve outs when there are specialized agencies like the FCC. This issue is not just present in the case you’re referring to but it’s present in the broadband privacy rules that you talked about.

When the Federal Trade Commission which has become our general purpose privacy regulator faces the question of what to do about privacy on the Internet, it faces the same problem of having a gap of being able to regulate ISPs.

Daniel B. Rodriguez: So one of the things I read said the lacunar, the gap is even greater in the following sense. They use the example of Google.

So here’s Google that would fall under — let’s say that’s being regulated for privacy concerns. Under the rubric of the Ninth Circuit holding Google would not be able to be regulated because of — for example Google’s Fiber Broadnet Internet access business. So in other words it would have the activity of a common carrier.

At the same time the FCC would lack the authority to regulate it under Section 222 of the Communications Act, given its non-common carrier status. That may be too convoluted but is that a real risk? I mean, if that’s the risk then either agency would have the authority to regulate.

Jim Speta: I think it’s a risk from the way the Ninth Circuit wrote its opinion. I think at the end of the day it can’t be the case, that the Federal Trade Commission has no ability to regulate Google’s core privacy issues in its search business or its advertising business or with respect to Gmail, just because Google runs a few access networks that are not integrated in any way with its core search services. That just can’t be the right result under the law, but you’re right. That’s one possible reading of the Ninth Circuit.

Daniel B. Rodriguez: Is their third alternative in terms of a regulatory agency or is that — are they the only two games in town leaving aside state regulation other things that are probably unrealistic in this context?

Jim Speta: The only third option on the table is to leave privacy regulation alone? So the direction that the repealer in Congress today is pointing is to take these issues from the FCC to the Federal Trade Commission, but there’s also a very vigorous debate. Former Commissioner Josh Wright is most sort of attached to this debate of getting the FTC out of the business of regulating privacy, simply because of the view those markets don’t need regulation consumers can protect themselves through negotiating with the companies that might collect their information.

Daniel B. Rodriguez: Let me shift to a little outside of the realm of privacy into the issue of cyber security and now though it’s at least a couple years old, you recall the controversy, significant controversy over, I think it was Apple and the FBI, when the FBI was seeking to decrypt some of that data in order to give the FBI a much more significant weapon to combat ISIS and others, what’s the status of that both from the vantage point of law and regulation?

Jim Speta: The status of that is quite open. The courts for the most part have come down on the side of the companies that have refused to provide information without proper legal process. Part of this has to do with did the government need a warrant to get something? What did it need to establish the warrant, and part of it was did they have an obligation to keep information or to maintain backdoors?

(00:20:01)

Interestingly, Trump was quite critical of Apple’s decisions in the campaign and he has promised and his new national security staff has promised that they’re going to seek legislation requiring companies to keep back doors and to keep information so that there’s a lot more ability for the national surveillance to get at this information when it’s necessary.

Daniel Rodriguez: So I want to ask you about the so-called Internet of Things. So I noticed there’s a new device that Amazon sells actually three devices to be more accurate powered by something called Alexa, the Echo, the Echo Dot and the Tap. As I understand it, which is to say, not very well, it’s a portal or device really into this remarkable development of the Internet of Things and raises interesting issues not only a technology, but how if at all we think about regulating it, can you take us through that?

Jim Speta: Well, personally, I think Alexa is an incredibly cool device, it’s one of a number of devices. Google has one called Google Home, Apple is extending Siri to do this where it essentially becomes an interface between you and the Internet but verbally. And so, if I have an Alexa device in my room I say, Alexa, put Tide on the shopping list or I can even say, Alexa, order Tide if I’ve set it up so that when I do that it orders Tide from my Amazon account or I can have Alexa order me and Uber or play music that’s the number one application for it right now, and all of these devices are trying to essentially create a smart home and a smart digital butler for me in all aspects of my life.

Daniel Rodriguez: I mean, again, naive question, what’s to stop this device from falling into the wrong hands which is to say, your Alexa falls into my hands, and I say, Alexa, drain my entire bank account, SPETA now, or you see what I’m getting at, I mean, not only the issues of privacy but sort of the misuse of this.

Jim Speta: Well, like all of these devices we worry about whether they’re hackable, right? Can I hack your device? Can you hack back into my device? But we don’t even need to go that far we have some examples of kids ordering things from Amazon by just saying, Alexa, order me a new doll house.

Daniel Rodriguez: Let me say to our listeners, don’t — we’re not endorsing that device so any listeners have kids.

Jim Speta: And Amazon obviously gave a refund when they found out that this happened and they advise people to protect their credit card with a verbal password, et cetera, but when you do those things of course the device becomes less convenient for you. So like all of the Internet of Things the real issue for consumers is to be aware of what’s happening with it and on the privacy front to come back to the issue of privacy what information is being collected when you use these devices.

Daniel Rodriguez: So maybe there’s not a lot of daylight between you and Chairman Pie in the sense that these are matters not so much for regulation, but for a consumer responsibility and control?

Jim Speta: I think that’s right at the first level, which is, I want to see these devices and these services deployed, see what they can do, I’m not anti-regulatory in the sense that I don’t think we can ever reach conclusions about what are good practices and what are bad practices.

Personally, I was very sympathetic with the FCC’s regulation of privacy issues for Internet service providers because they are in a position to capture what my political affiliation is, what my favorite sports team is or to use something probably more important. If I’m searching for information on the Internet about some disease that I have, they can capture all of that information and that isn’t a significant privacy issue to me.

Daniel Rodriguez: So that provides the nexus between Internet of Things and also Big Data, the availability in the utilization of Big Data through technology that is available and might become available.

Jim Speta: Sure, and this is the big wave that’s coming. Just this past couple of months we’ve seen a few lawsuits and a Federal Trade Commission action against TV manufacturers Vizio, Samsung and LG all sell these smart TVs that you can watch Netflix or you can surf the web or do other things through the TV, and now the allegation is that those companies who created the TV have embedded in there a capture that sends back to a centralized server and then they sell it to advertisers what it is I’m watching, what it is I’m surfing, et cetera, and it’s disclosed somewhere, but —

Daniel Rodriguez: In the fine print as it were.

Jim Speta: Exactly.

Daniel Rodriguez: As you mentioned before Alexa as a device competes with or at least to some extent builds on Google Home and Google Assistant, Siri maybe in an earlier iteration, so I guess, I want to ask what’s unique about Alexa, does Amazon have intellectual property in this device that makes it do very different things than those?

Jim Speta: Well, I know a little bit more about Alexa, because Northwestern Law graduates are everywhere and we have a Northwestern Law grad who is leading the music team for the Alexa business model, and I talked to him a few weeks ago and Amazon’s advantages are a couple fold in this area, first of which is they have a platform which is well-known, they’ve got this brand name.

(00:24:56)

The second of which is they actually beat Google and Apple into the home. They have these devices out there being deployed and then the third thing is they just have already built a great ecosystem where you can order things, you have applications and you can do a lot more things today on Alexa than you can do on Google Home.

As to intellectual property Alexa faces the same sort of conflict that a lot of digital services do. On the one hand their optimal view would be to keep their customers within their ecosystem as much as possible.

On the other hand they know what customers want to do is to access lots of different services over their platform, they want to access Uber, even though Amazon doesn’t own Uber, they want to access —

Daniel Rodriguez: Not now.

Jim Speta: Not yet. They want to access music from Spotify as well as music from Amazon Music.

So Amazon has both a built-in business incentive to open their platform to other companies, but also an incentive to try to capture value as much as possible, and as you watch digital businesses make these sort of choices between open interfaces and closed interfaces, it’s one of the most exciting issues out there right now.

Daniel Rodriguez: Well, when I studied Antitrust Law in the Stone Ages one of the ways that the law dealt with that is through some restrictions on time, so I wonder whether or not that old model of restricting ties in that respect applies to this new technology.

Jim Speta: It sure does, and sort of the bridge between that was the famous Microsoft case involving browsers, right? And the question was, could you have the Windows operating system so integrated with the Internet Explorer browser that you couldn’t have another browser on the system?

Today that same question is going on in Amazon. My sense from watching how Amazon and Google and Apple are developing these services is that they understand that the value of being able to reach out to third parties being able to have this open ecosystem of apps is an incredibly valuable thing to consumers, then the question becomes a matter of economics; like on the Apple App Store, they take 30% of revenue. So the question is going to be, when you have a platform, what’s the cut?

Daniel Rodriguez: Well, you mentioned the three companies, right, and not a coincidence; Amazon, Google and Apple. At least historically legendarily the last one you mentioned, Apple, has been the most reticent to that open platform to generalize, but even they are coming around, you suggest.

Jim Speta: Absolutely they are coming around, they are coming around somewhat on the App Store, they are coming around on music, they are coming around on a number of other services. I think that’s what consumers want.

Daniel Rodriguez: Does that mean that I no longer will have to pay a quarter every time I use the expression the Genius Bar?

Jim Speta: I can’t give you a legal advice on that one.

Daniel Rodriguez: Okay, thanks. What do you think, so now let’s get to 30,000 feet, what is the future hold for sort of avenues of the federal government to deal with these extraordinarily impactful and changing elements of technology?

Jim Speta: I think it’s quite challenging, and part of the challenge is that as we say in the business, Congress always regulates by looking through the rearview mirror, but the pace of acceleration as you’ve talked about with John McGinnis and with others on this show, the pace of innovation is just accelerating, and so, we are confronting an era in which not just the techniques of innovation in the business sphere but the techniques of innovation in response to possible regulation is just something that’s very hard for general purpose legislators to keep up with, and if they don’t trust regulatory agencies to do it, then it’s going to be very, very hard to do.

Daniel Rodriguez: Do the courts fill an important vacuum or are they even looking even more in a rearview mirror?

Jim Speta: They are definitely looking more in a rearview mirror in the sense that matters only come to courts after there’s been a problem after a technology or a business model has been deployed and people have an objection to it or there’s been a real harm to it.

One possible solution is the drafting of general standards and leave it to a common law process, but again, in an era of accelerating regulation you change the business model when you get sued and you simply move on to the next thing.

Daniel Rodriguez: Are there other countries that are farther along than we are dealing with these regulatory dilemmas or is this a frustration that’s shared universally?

Jim Speta: I think it’s a frustration that’s shared universally, I mean, I think the fundamental trade-off is how much permission do you want to require before new technologies come to market.

In the U.S. we’ve basically made the judgment, we don’t want a lot of regulation except in certain spheres of new technologies before they come to market. Surely when health is at issue, like with the Federal Food and Drug Administration, then we want there to be permission before new technologies, but in the Internet and digital technologies we’ve never wanted that, and so, your trade off is between losing your ability to regulate versus preserving it by stopping innovation and its tracks.

Daniel Rodriguez: Interesting. We’re going to need to devote an entire additional show in all of our respective spare time to talk about issues that I know you’ve been writing and thinking and teaching about in connection with the so-called sharing economy. Uber, Airbnb and those greatest hits, so that’s a teaser for a future show, but meanwhile thank you for joining me and that’s our show for today. Thanks to Professor Jim Speta.

(00:30:07)

Jim Speta: Thank you Dan.

Daniel Rodriguez: Thanks for listening. I’m Dan Rodriguez signing off from the Northwestern Pritzker School of Law.

[Music]

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