The Faculty Lounge

VAP Trap: The Survey

Lounge readers may recall the thread from February on whether we are sustaining a "VAP trap" by sustaining so many VAP programs at a time when most think the market for tenure-track jobs at American law schools is likely to contract significantly.

That post led to an avalanche of comments from (among others) current VAPs about their situations.  One commenter offered in the comments to survey fellow VAPS, and I offered to publish the survey results here.

The organizer of the survey sent me the results this morning.  They are below.  Please don't ask me questions about them; I am simply presenting what was sent to me.  If the person who ran the survey monitors this thread, s/he may (or may not) wish to respond to questions.

(Anyone wishing to dredge up issues about confidentiality of commenter identities and the like should first consider this article in yesterday's NY Times.)

Sunny Samaritans’ Suit Survives

(Yes, I am entertaining myself with alliteration as we slump towards the end of the semester)

U.S. District Judge Saundra Brown Armstrong has refused to dismiss the class action suit against ASRM (the American Society for Reproductive Medicine), SART (the Society for Assisted Reproductive Technology), and all clinics and egg-donor agencies that agreed to follow their pricing guidelines.  (I’ve uploaded the order here: Download Order denying mtd)  The suit alleges that the caps the societies have imposed on permissible oocyte compensation are per se illegal. 

As regular Lounge readers may recall, this is a case about which I’ve blogged quite a bit, and I wrote a law review article in 2009 arguing that the ASRM-SART Ethical guidelines were simply horizontal price-fixing of the type long considered per se illegal in other industries.  And, as I noted of the ASRM-SART motion to dismiss shortly after it was first filed back in July of 2011, “this sounds suspiciously like the standard, and typically unsuccessful, professional association defense.”

As a refresher, ASRM guidelines state that any payment by a member clinic to an egg donor in excess of $5,000 requires justification, and any donor payments above $10,000 "go beyond what is appropriate." The societies claimed that the pricing guidelines were not a per se violation because they were motivated by ethical concerns, rather than by a desire to enrich the societies or their member clinics and agencies.

According to the motion to dismiss, the maximum price rules serve several salutary functions: (1) they protect the health and safety of egg donors and infertile patients by reducing their incentive to hide medical information, (2) they resolve "social welfare concerns" about the exploitation or undue inducement of egg donors, (3) they protect against the devaluation of human life, and (4) the price caps provide access to donated eggs for infertile couples with limited economic means.  Regular Loungers are already aware of my views on these arguments, and those of you new to that debate can catch up by following the links below.  Judge Armstrong concluded that these issues were debatable and denied the motion to dismiss, refusing to hold as a matter of law that per se analysis should not apply to the societies’ pricing guidelines.

Judge Armstrong also addressed one argument under the rule of reason analysis that I had not noticed in the pleadings: ASRM and SART attempted to define the relevant market to include numerous other "alternative income-generating opportunities" that are "close substitutes for egg donation," including “blood, platelet, or plasma donation or paid clinical trials by hospitals, universities, companies, or research institutions.”  Really??  I’ll anxiously await the evidence on that.  The Judge refused to settle this at the pleading stage as well and denied the motion to dismiss under rule of reason analysis. 

I will provide further updates on the case as I get them and many thanks to my colleague, Barak Richman, for forwarding the latest news on this front.

Related Posts:

ASRM Seeks Dismissal of Egg Donor Suit

Kamakahi v. ASRM et al. — Updates

Politics And Profits in The Egg Business (When Sunny Samaritans Sue, IV)

When Sunny Samaritans Sue, Part III

When Sunny Samaritans Sue, Continued

When Sunny Samaritans Sue

(Image source)

Scholarship Tips

As the semester draws to a close, I'm sure many of us our thinking about scholarly projects for the summer.  I wondered if now would be a good time to open a post to share some "scholarship tips".  What is the most important thing you would advise colleagues, or want to make sure you remember to do yourself, in new scholarly projects?  Issues relating to approaching research, effective use of research assistants, outlining a proposal, developing successive drafts etc...

Not the First

With the movie 42 coming out on Friday, I’m sure we’ll hear folk say that Jackie Robinson was the first black Major League baseball player.  But that distinction belongs to Moses Fleetwood Walker who played in the American Association in 1884.  The color barrier was instituted to keep him out and, of course, Robinson broke it in 1947.  Walker was originally an integrationist but his struggle with racism led him to champion Garvey’s “Back to African Movement.”  He led an interesting life.

Cultural Competence & The Curriculum

I am a co-chair of our Multiculturalism Affairs Committee here at SLU Law, and our (faculty/staff/student) committee is in the midst of discussions about ways to enhance ‘cultural competence’ at SLU Law.  One thought as to how to do so is to introduce changes into the curriculum, concertedly oriented towards exposing students to the legal and social issues faced, both historically and contemporarily, by racial minorities, immigrants, women, Native Americans, queer folk, the disabled, and others.  Discussions are at a very preliminary stage, but different thoughts have already emerged about how best to better incorporate the teaching of cultural competence into the curriculum.  Some people seem to favor adding ‘diversity elements’ to each 1L course; others favor some sort of separate, required first-year course aimed at getting students to think seriously about in/justice in the American legal system over time; while others want to see us add a ‘justice track’ to the curriculum which would culminate—after several courses and other prerequisites—in some sort of certificate or other recognition on one’s transcript.  Of course, none of these are mutually exclusive.

I’m curious about other people’s experiences at other law schools with these kinds of curricular proposals.  I’m aware that CUNY-Law has some sort of required 1L course on justice, and I would love to hear more from people there, and also anywhere else where people have at least discussed these sort of curriculum changes—even if no changes were ultimately made.  What were the challenges you faced in instituting these kinds of curricular changes?  Were they sustainable?  Did they face opposition?  From colleagues, or from students, or from other quarters?  What changes did you see in your law school after adopting the kinds of curricular changes I’m discussing here?  Thanks to everyone in advance for your comments and discussion.

Why do the Initials Matter so Much?

    Recently, there was a discussion on the IPProfs board about why more IP law professors fail to join the American Intellectual Property Law Association (AIPLA). Most who commented on why they were not members seemed to be concerned with the positions AIPLA has taken on issues arising in IP law, finding that the organization, at best, lacked transparency on how the positions advocated were developed. But for me, the reason I am no longer a member is the requisite for academic membership in AIPLA. To qualify for membership from the academy, you have to teach at an AALS approved institution. In other words, anyone who teaches at an institution that has only ABA or state accreditation is not a “real” IP law professor.

    Of course, the AIPLA is not the only organization that does this. The AALS also has rules that prevent active participation at AALS events if your school is not an AALS member. Many of my colleagues used to be active with the AALS. They were interested in presenting papers and panels at the meeting, but were also willing to do scut work that goes with running an academic organization. With the exclusionary system now in place, faculty from non-AALS schools need not try to present papers as their work is automatically rejected. Even those of us who are willing to roll up our sleeves to do the behind the scenes work are excluded.

    This limitation on participation is unjustifiable. Great scholarship can come from anywhere in the legal academy (or, dare we admit it, from those outside of the academy). As an example, think of Dean Erwin Chemerinsky of U.C. Irvine. If we follow the standards being used by the AALS, he was a great scholar when he was at Duke as it has both ABA and AALS recognition, but when he became the founding Dean at U.C. Irvine, he immediately became worthless as a scholar as it did not have either ABA or AALS accreditation when he joined. Even today, his scholarship is apparently substandard to the AALS as his institution, like my own, is only provisionally approved by the ABA and is years away from being eligible for AALS membership.

    If the AALS (or AIPLA) are intent on being true academic societies, the “no one does it as well as our members” snobbery needs to go (except for the few elected officer positions where membership may be appropriately required). If the AALS is truly a “learned societ[y]” as its web site suggests, it needs to start acting like an academic-based organization  — one that is open to all scholars who produce quality work.

New Law School Rankings: Employment Data Cleaned Of School Funded Jobs

I've taken the same data that Gary Rosin used in this post (which ranked schools by percentage employed in full-time, long-term jobs requiring a JD) and cleaned the list...by excluding all such positions that were funded by the law school.  

One concern I have about Gary's list - similar to concerns about US News rankings - is that once you eliminate the top schools, an ordinal ranking suggests large distinctions between schools with small acutal differences.  Thus, the gap in Gary's list from the #1 school (Penn) to the #31 school (Georgia) is 25 percentage points; Penn placed 94.4% of its students and Georgia placed 69.4%.  But the gap between Georgia and the school 30 places down the list - #61 FIU (which placed 63.6 of its students) - was only 5.8 percentage points.  A law school candidate might be agnostic as between Georgia and FIU, based on placement, but not between Penn and Georgia.  

I am going to publish my list from number 1 to 197, but a savvy reader would be well advised to consider schools in clusters.  For example, this time using my list, schools 1 to 6 place over 85% of their grads in legit L/T, F/T JD required jobs.  Call that cluster 1.  Schools 7-19 place over 75%.  Schools 20-52 place over 65%.  Schools 53-98 place over 55%.  And so on.

Even this clustering obscures important facts for anyone comparing law schools, the primary one of which is this: outside of a few elite schools, most grads with jobs are working somewhere geographically close to their law school.  So a graduate of #34 Campbell University has a comparatively good shot at a job; it's probably going to be in North Carolina.  Ditto #28 South Texas College of Law.  And if your goal is Big Law, particularly in $160K-ville, you'd best take that #17 Northwestern offer (even if you did get into #16 LSU or #15 West Virginia.)  I do love Alabama - after all, it was my first academic home - but if I had an offer from #14 Yale and #13 Alabama...well, you know where this is going.

And a close reader might consider whether a particular school claims a very high number of graduates going into solo practice.  While solos are treated the same as associates at Wilmer Hale, for statitstical purpose, the average solo is probably going to earn less during her first few years than she would have made in a non-JD job.  You can go here and and sort through all sorts of these issues. 

Are there any notable distinctions between my list and Gary's?  That is, did some schools hire a big chunk of their grads in long-term, full-time JD required positions?  A few.  Virginia falls from #2 to #11  - or almost 15 percentage points.  A bunch of schools - Chicago, NYU, Columbia, and others - showed distinctly weaker placement numbers, though they remained quite strong, comparatively.  And then there was George Washington which fell from 14 to 76 or from 81% employed to 60.35%.  This is an admirable form of back-end financial aid for unemployed grads, and phenomenally expensive, but it does confound the rankings a bit.

My chart is after the jump.  If you want to compare Gary's ranking which includes law school funded jobs, it's here. 

Tired but Finished

Last summer I blogged about my book on the term of Uncle Tom. Well, the 530+ page behemoth is now finished.  I posted the short Introduction on SSRN if anyone is interested in reading.  Now on to book #2.

Clark on SLU

I think faculty lounge readers will be very interested in Annette Clark's thoughtful and thought-provoking reflection on the events surrounding her departure as dean at SLU, "Postscript to a Deanship," which appeared recently in the Toledo Law Review.   There is a lot in the article that's worthy of comment and reflection.  The article reminds me that I should have said something last year when my friend and former colleague Phil Pucillo was blogging about about SLU here at the faculty lounge.  Some people questioned why Phil, who's not a SLU faculty member, was blogging about this -- and I guess that was related to his urging faculty members to speak out.  Phil is one of my heroes for having taken a stand in favor of faculty governance when he was on the Ave Maria faculty.  His stand for faculty governance makes him an ideal person to comment on the situation at SLU and also to give some perspective on the likely consequences for everyone involved -- and the reasons why faculty might remain silent, as well as why they might speak out.

By the way, many congratulations to the Seattle University law school's community on recruitng Annette Clark as their dean.

Signposts: The Chapters

Last week I talked some about Signposts: New Directions in Southern Legal History, which Sally Hadden and Patti Minter co-edited.  It has  just appeared from the University of Georgia Press (and is available at a nice discount at amazon and Barnes and Noble).  The book is designed to highlight the extraordinary breadth of work going on in southern legal history -- which spans a huge amount of time (from the seventeenth through the late twentieth century), as well as subjects of study (from local courts through appellate courts, to legislatures, treatise-writers, and humble litigants), and methods (often social history these days, but also intellectual and cultural history).  At some point I hope to talk a lot more about just how expansive legal history is these days -- and the challenges that poses for those of us looking for unifying themes.  I want to talk about the problems legal historians face; I've been thinking about this in particular as I've been reading the Companion to American Legal History.  I think the Companion really helps pull together those themes, but that's a story for another time.

Right now I want to mention each of the individual chapters, because I think this gives a sense of the scope of the work in this volume.  The chapters are "In my mother's house: Dowry Property and Female Inheritance Patterns in Spanish Florida" by Susan Richbourg Parker; " The Law and Order campaign in New Orleans, 1763-1765 : A Comparative View" by Thomas N. Ingersoll;  "'Using the faculties conceded to her by law': Slavery, Law, and Agency in Spanish New Orleans, 1763-1803" by Jennifer M. Spear; "South Carolina's Grand Jury Presentments: The Eighteenth-Century Experience" by Sally E. Hadden; "Guarding Republican Liberty : St. George Tucker and Judging in Federal Virginia" by Jessica K. Lowe; "The Shades of Loyalty: Elisha W. Chester and the Cherokee Removal" by Tim Alan Garrison; " The Material Conditions of Dependency: The Hidden History of Free Women's Control of Property in the Early Nineteenth-Century South" by Laura F. Edwards; "Democracy, and Lynching, in America," by Christopher R. Waldrep; "The World Made by Laws and the Laws Made by the World of the Old South," by me; "Peaceful Revolution and Popular Sovereignty: Reassessing the Constitutionality of Southern Secession," by Roman J. Hoyos; "Strategic Litigation and the Death of Reconstruction," by Cynthia Nicoletti; "The Homestead Exemption and Southern Legal Culture," by James W. Ely, Jr; "A Place for Themselves in the Modern World: Southern Women and Alcohol in the Age of Prohibition, 1912-1933" by Lisa Lindquist Dorr; "Race, Property, and Negotiated Space in the American South: A Reconsideration of Buchanan v. Warley," by Patricia Hagler Minter; "Race, Law, and Southern Public Higher Education, 1860s-1960s," by Peter Wallenstein; "The Southern Roots of the Reapportionment Revolution," by Charles L. Zelden; and "Defending the Right to Discriminate: The Libertarian Challenge to the Civil Rights Movement," by Christopher W. Schmidt.

When I have a little more time I want to compare the subject matter of these essays to the subjects in the 1989 volume edited by Kermit Hall and James Ely, An Uncertain Tradition: Constitutionalism and the History of the South.  One obvious difference is that Hadden and Minter deal with legal (as opposed to constitutional) history.  I think that's a good gauge of how interests have broadened over the past twenty-five years. 

books.google has a preview of the book here.

Roisman on Property and Human Rights

I'm delighted to see that Florence Roisman's casebook on Property and Human Rights has appeared from Carolina Academic Press.  Cribbing now from the Press' website:

This book contains materials regarding intersections of property law with civil and human rights claims in the United States and internationally. The chapters cover The Nature of Property, The Development of Civil Rights Principles in the U.S., International Human Rights Law, and Human Rights in the U.S. Roisman addresses homelessness, expropriation, and discrimination on the bases of race, sex, sexual orientation, disability, and other characteristics. Among the recent cases presented are the U.S. Supreme Court’s 2004 decision rejecting a claimed property interest in the recognition of a protective order, a South African case enforcing a right to housing, a 2003 Maryland decision assessing the need for just cause for eviction in Low Income Housing Tax Credit developments, a 2002 9th Circuit opinion regarding disability discrimination, and the Michigan Supreme Court decision overturning Poletown. 

This book looks terrific and I'm looking forward to reading it and I hope teaching from it as well.

> v. =

Many people last week opened their Facebooks to find a pink equality sign on a red background populating their Facebook newsfeed.  Apparently, the wide-spread adoption of this equality sign as one’s profile photo was a ‘true Internet phenomenon,’ with various news stories covering this Facebook phenomenon more than the real-world phenomenon of gay marriage itself.  As to the relation between the two, for most people, the goal in adopting the pink-on-red equality sign as their Facebook profile photo appeared to be to demonstrate support for gay marriage and a certain notion of equality which (as nearly everyone reading this blog is already aware) were the subjects of litigation heard by the U.S. Supreme Court last week.

Others, however, took different tacks, adopting other pink-on-red symbols as their Facebook profile photos.  Here I want to concentrate on one such symbol that found its way into Facebook-space, and one which is associated with the group ‘Against Equality’:  

Like the equality sign that the Human Rights Campaign popularized, the Against Equality greater-than symbol is usually yellow (rather than pink), situated against a blue (rather than red) background.  (So far as I know, Human Rights Campaign has never attempted to trademark the equality sign and/or to challenge Against Equality’s use of a similarly configured—but very different meaning—greater-than symbol.) 

I became aware of the Against Equality collective as I was writing a piece on “Dignity, Legal Pluralism, and Same-Sex Marriage,” in which I argued that mainstream gay and lesbian organizations (such as Human Rights Campaign, but many others as well) were missing out on real opportunities afforded by—as these organizations and supportive courts pejoratively characterized them—‘separate but equal’ relationship-recognition schemes in states like California (still) and Connecticut (no longer). 

NYU Names Trevor Morrison as New Law Dean

NYU has named Columbia law professor Trevor Morrison as its new law dean.  Morrison's areas of expertise include constitutional law, federal courts, separation of powers, and executive branch legal interpretation.  He clerked for Justice Ginsburg, was an associate at Wilmer, Cutler & Pickering, has served in the Justice Department and the White House, and taught at Cornell.  He will take the helm on June 1.

For additional reading, click here (NYU), here (Columbia), and here (New York Times).

Sunstein's Least-Cited Article?

The following vignette is a great example of why we should be quite skeptical of judging the quality of an article by how many citations it has....

I'm writing a short essay on a survey of student attitudes towards intestacy and also towards the marital elective share that I conduct on the first day of my trusts and estates class.  I survey student attitudes on those issues as a way of introducing them to some of the topics we're going to be talking about in class -- and I often find that the students' ideas about what should happen don't really match up at all with what does happen.  And therein begins some great discussion both on the first day of class and down the road in the semester.  I use surveys at other points in the class to gauge students' attitudes towards cases and see if they vary according to gender.  It won't surprise any trusts and estates teachers that male and female students differ greatly in their attitude toward In re Strittmater.  But that's really a story for another time.

I remember about fifteen years ago -- back when I was teaching administrative law -- really enjoying an article that Cass Sunstein wrote (actually co-authored, though I'd forgotten this) on a survey he conducted in his administrative law class about students' attitudes towards allocation of resources in response to risk.  (The article is by Christopher E. Houston and Sunstein, Risk Assessment, Resource Allocation, and Fairness: Evidence from Law Students 48 Journal of Legal Education 496-523 (December 1998).)  And so I was looking for that article this weekend as a sort of model for this very compact essay I'm writing.  I remembered that it was in the Journal of Legal Education, but I'd forgotten the title.  But I figured that it would have been cited a bunch and would be easy to find.  It actually didn't take long to find, thanks to the magic of westlaw, but I was surprised that it hadn't been cited much, at all -- I think only twice in westlaw's JLR file.  

I mean, I'd understand it if it were on pre-Civil War popular constitutional thought -- even more so if it were on pre-Civil War trusts and estates or landscape art and property law.  But this is Cass Sunstein -- and it's on adminstrative law and risk.  Just further evidence that you shouldn't judge an article -- even an article's utility -- solely by its citations.

Dismantling Tenure Prospectively

In an earlier thread about incentivizing law review placements, an interesting sub-discussion emerged after I suggested that one of the problems with tenure is that it potentially disincentivizes faculty from doing our jobs and then we look for ways to re-incentivize faculty to do more and/or higher quality scholarship.  A comment was made that perhaps tenure isn't the problem because if it was creating poor institutional incentives, some schools would - or might - prospectively attempt to abolish tenure.  But then of course those schools wouldn't be able to compete for high quality faculty with schools that do offer tenure.

I hadn't initially intended to suggest that any system in which some schools prospectively abolished tenure while others didn't could possibly be effective.  In such a system, faculty would not be attracted to work at schools without tenure when they could have tenure somewhere else.  So my initial thought was really a general comment about tenure - in a system where we all potentially can get tenure, there are less incentives to do our jobs.  The only obvious alternative would be a system with no tenure across the board or a system where tenure "meant" something less significant than it does now and it was possible to remove tenure for unproductive faculty.

But the discussion in the other thread got me thinking about whether it would be possible to think about an effective system in which some schools prospectively decided to abolish tenure while others didn't.  Assuming that there are institutional incentives to abolish tenure AND assuming that ABA rules don't actually require tenure (two big assumptions, I know), wouldn't it be possible for, say, high-ranked schools (US News proxy for quality again - sorry!) to abolish tenure without losing good faculty?  In other words, could the prestige value of working at those schools, and potentially the higher salaries and lower teaching loads that "may" be associated with working at those schools, outweigh the detriment of not having tenure?  Faculty members who are prepared to be engaged teachers, scholars etc may have no problem with such a system and may still see those schools as aspirational places to work despite the lack of tenure.  Or is that a completely crazy idea?

 

 

The Curious Case of the Missing Q

About a month ago I opened my email only to find an “Important Announcement from the Harvard Gay and Lesbian Caucus,” a longstanding Harvard University community and alumni group with a deep and interesting history.  Apparently, the HGLC was going to become the HGSC, or Harvard Gender and Sexuality Caucus.  The message went on to explain the name-change in the following way:  “As many of you know, we have struggled to find a name that represents our diverse community and its values. When we have talked about simply adding to the HGLC acronym, there has not been any clear consensus about whether we should also specify transsexual, intersex, queer, and questioning members, and how we could keep the name from becoming increasingly unwieldy. Many of our members are strongly opposed to the term ‘queer,’ and feel that it does not represent who they are or the community they are a part of.”

I was frustrated with this decision by a group that I have had a longstanding affiliation with.  Not only did I believe that the ‘unwieldy’ acronyms that so many groups around the nation have persisted with better represent the necessarily conflictual and coalitional aspect of any (gender and sexuality) organizing, but so was I dismayed at the ongoing attempts to erase those of us who are queer (Q).  I blamed same-sex marriage and, more specifically, the hegemonic gay and lesbian politics of same-sex marriage.

Richard Bales Named Dean Of Ohio Northern Law

Professor Rick Bales of Northern Kentucky University School of Law has been selected as the new law school dean at Ohio Northern University.  Bales, who holds a JD from Cornell, joined the NKU faculty in 1998.  His primary (but not sole) focus area is employment law and he is a longtime blogger at Workplace Prof Blog.  Let's hope he blogs as dean!  (Dan Rodriguez certainly did - for a while at least.)

Thomas Cooley Law And Western Michigan Consider Affiliation

The Western Michigan University Thomas Cooley School of Law?  Could happen, if the current proposal for a new formal alliance is approved.  They would remain separate institutions, formally, with separate governance structures.  I'm not sure how much this would be like the linkage between Detroit College of Law and Michigan State University, resulting in the current Michigan State College of Law.  The new school remains independent of MSU, notwithstanding its name.

For Cooley, this would be a major branding event - affiliating the school with a state university.  For Western State, the situation seems similar to the Southern New England School of Law - UMass Dartmouth merger.  Just as UMass Dartmouth was unlikely to get a law school without the merger, Western Michigan seems similarly unlikely to gain a law school without this proposal. 

Picture of the future? Western Michigan University Thomas Cooley School of Law, Tampa Campus .

April in Academia

I want to thank Dan and everyone else for welcoming me to The Lounge for this month.  April often proves to be the cruelest month of the academic year for both students and faculty, but I hope to liven it up a bit with posts on the continuing debate over same-sex marriage and what comparative experience, as well as a left perspective, can add to this debate.  I also plan to post on comparative legal academic work, in general, and my work on Islamic legal institutions in India, in particular.  As time permits, I may also digress into a discussion of transgender rights, as they have recently played out in Pakistan, and also elsewhere; this is the subject of new work of mine and potentially the topic of a second book (after I finish the first…).  For the time being, I will leave with you a question recently posed on Columbia Law School’s Gender & Sexuality Law Blog—Can You Oppose Gay Marriage and Not Be Anti-Gay?—and an answer:  Yes (& No).  Recent work of mine on this question/topic is here and here.  I'm looking forward to all of the discussions this month!

Welcome Jeff Redding To The Lounge

We're very pleased to welcome Professor Jeff Redding to the Faculty Lounge this month.  Jeff is an assistant professor at Saint Louis University School of Law.  He teaches civil procedure and comparative law and publishes in these areas, as well as sexuality and the law.  He presented his forthcoming piece, The Case of Ayesha, Muslim ‘Courts,’ and the Rule of Law: Some Ethnographic Lessons for Legal Theory,  at the 2012 Stanford/Yale/Harvard Junior Faculty Forum in the Law & Humanities category.  I confess: whenever I hear legal scholars talk about ethnography, I assume something interesting is happening.  

Welcome to the Lounge!