International Law Section 

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Note from the Editor of the March International Law Section Newsletter

The Executive Committee welcomes you to our first spring edition of the year! We certainly have a tremendous amount of activity we want to keep you abreast of, and hope you agree that it has never been a better time to be part of the International Law Section.

First of all, as a 2014 benefit of Section membership, we are pleased to offer 6 Hours of Self-Study CLE in the Specialty Areas -- Complimentary for Members of the International Law Section. This is an easy step towards fulfilling your MCLE requirements, as well as a great way to acquaint yourself with our vast arsenal of on-demand webinars geared towards international lawyers. In addition, we encourage you to check out our exciting new webinars this upcoming month.

We also would like to draw your attention to a couple of upcoming co-sponsored events: The ABA Section of International Law, Spring Meeting, in New York City takes place April 1-5, 2014.  California State Bar International Law Section members can register at a discounted rate and are also cordially invited to a complimentary California State Bar ILS Breakfast Meet and Greet during the ABA ILS Spring Meeting. On June 19-21, the California State Bar International Law Section is a cooperating entity for the the ABA Section of International Law: "International Families: Money, Children, and Long Term Planning" Conference in Seattle, Washington.  For detailed information, please scroll down and read on.

As in previous months, we continue to conduct our popular Careers in International Law Programs at law schools across the state of California and encourage law students to attend these events to learn first-hand from seasoned international law practitioners about this exciting and innovative field of practice.

As another highlight of this edition, the ILS Executive Committee would like to share details and photographic impressions of the section’s successful Visit to Tokyo and Osaka, Japan a couple of weeks ago. Last but not least, we encourage you to get actively engaged with the International Law Section and link up with our Executive Committee members. As always, we are interested in articles for our International Law Journal, webinar proposals, and your photographic impressions of foreign jurisdictions for a "Note From Abroad."

Sincerely,
Diana Mack's Signature
Editor

6 Hours of Self-Study CLE in the Specialty Areas -- Complimentary for Members of the International Law Section!

As a 2014 benefit of Section membership, we are pleased to offer six hours of MCLE credit, offering credit in all of the MCLE subfields.

The Section thanks you for your membership!If you were purchasing these courses individually in our Online Catalog, they would cost $210 -- so that's your Section membership more than paid for, and then some!

Just watch these programs, and keep a record of having done so in the event you're audited for MCLE compliance.

You can access these programs and the accompanying written materials any time this year in the Members Only Area.

Elimination of Bias in the Legal Profession

  • Navigating Diversity

Detection and Prevention of Substance Abuse and Emotional Distress

  • Coping with the Unique Challenges of Legal Practice

Legal Ethics

  • Avoiding the State Bar Disciplinary System
  • Client Trust Accounting Fundamentals
  • Ethical Implications for Lawyers in Cyberspace and Social Media
  • Ethics and Civility: Want an Extension? Forget about It!

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The International Law Section is now on LinkedIn. Please join the International Law Section LinkedIn Group at http://www.calbar.org/ils/linkedin. Connect with us today and also share our new LinkedIn Group with your LinkedIn connections.

In addition to LinkedIn, the International Law Section also has its own presence on both Facebook at http://www.facebook.com/CalbarILS and Twitter at https://twitter.com/CalbarILS. For the latest cutting-edge information and news from the International Law Section, connect with us on social media!

Spotlight on Members

Introduce Yourself to the Membership

Members are encouraged to introduce themselves and their areas of practice and/or service. Introductions will be included as received, subject to editing at the discretion of the Newsletter Editor and/or the State Bar. Send introductions in an e-mail to Editor Diana Mack with “Spotlight" in the “Subject" line. Feel free to include a photo of yourself!

Upcoming Events

International Law Webinars

Global Ethics and Compliance

Wednesday, April 23, 2014, 12:15 p.m. - 1:15 p.m. (Pacific)

This program offers 1 hour participatory MCLE credit in Legal Ethics. You must register in advance in order to participate.

Large or small, U.S. companies doing business outside the U.S. are subject to regulation of their conduct under the Foreign Corrupt Practices Act, as well as an increasing number of country specific global anti-bribery and anti-corruption legislation, which result in a myriad of rules and best practices for corporate gift-giving and similar acts that clients may not be sensitive to. All in-house and general outside corporate counsel need to understand the basic rules, how to ensure corporate policies reflect those regulations, conduct investigations when violations occur, and provide strategic training for employees with a view toward education and protection of clients in their business activities outside the U.S.

Moderator: Anne Hiaring Hocking, Hiaring + Smith, LLP

Speaker: Andria Bouskos is Corporate Counsel at Symantec, where she runs the global investigations program for Symantec's Office of Ethics and Compliance. Her role includes compliance investigations of alleged violations of laws such as the Foreign Corrupt Practices Act, other anti-bribery and anti-corruptions laws. Andria is an expert in corporate Codes of Conduct and Anti-Corruption Policies. Before taking on this corporate compliance role, she practiced white collar criminal defense in a law firm setting, and she has antitrust experience at the Federal Trade Commission as well as working on international competition law in Brussels.

ABC's of E-2 Visas

Thursday, May 1, 2014, 12 noon - 1 p.m. (Pacific)

This program offers 1 hour participatory MCLE credit and 1 hour Legal Specialization credit in Immigration & Nationality Law. You must register in advance in order to participate

The E-2 treaty investor visa is available to a citizen of a country which has a commercial treaty with the U.S., allowing certain investors to come to the U.S. to run their businesses. E-2 visas are temporary non-immigrant visas valid for 2 years, and there is no limit to the number of years that E-2 status can be extended

The investment being made must be "substantial", which can be a slightly ambiguous requirement. Generally speaking, the substantiality requirement means that the application must show that the investment is large enough to ensure that the investor will be financially committed to the successful operation of the enterprise. The investment involved must also place the investor's capital at commercial risk with the objective of turning a profit, and be subject to loss if the investment fails. In order to document all of these criteria, applicants should submit a detailed business plan demonstrating their strategy for making the business venture a success

The marginality of the business is another thing to be taken into consideration. A marginal business is an enterprise that does not have a present or future capacity to generate more than enough income to provide a minimal living for the treaty investor and his or her family. You don't have to prove that the business will be profitable within a short period of time, but you must prove that you have adequate financing to tide over short- term hiccups and sustain operations over a period of time. Also, you must show that in the future it will make a significant economic contribution, for example by creating jobs for Americans. As such, it is advisable to provide a 5-year business plan along with the petition/ application package.

Investors must also show that the funds were lawfully acquired, owned, and controlled. To establish the legality of the source of their funds, investors should document the origin and movement of the capital used for their investment.

Speakers:

  • Rajkrishna Lyer

  • Carl Shusterman, a Certified Specialist in Immigration Law, served as an INS Trial Attorney from 1976 to 1982 before entering private practice. Mr. Shusterman has testified as an expert witness before the United States Senate and has a case pending before the Supreme Court.

Moderator: Qiang Bjornbak was admitted to the State Bar of California in 2002. She has been an active practitioner since December 2002. From December 2002 to now, she has handled more than 300 bench trial cases in immigration law area. She was invited by American Bar Association to make speeches on immigration law for several times and she is the co-author of Year in Review relating to immigration law part, which has been published by the International Lawyer.

Healthcare as a Human Right: The Affordable Care Act (ACA) and International Law

Thursday May 8, 2014, 12 noon - 1 p.m. (Pacific)

This program offers 1 hour participatory MCLE credit and 1 hour Legal Specialization credit in Immigration & Nationality Law. You must register in advance in order to participate

The purpose of the webinar is to explore the extent to which the expansions of health insurance coverage under the Affordable Care Act (ACA) meet the goals of healthcare as a human right under PIL.

From a PIL perspective, the importance of healthcare as a right is embedded in the Universal Declaration of Human Rights, the International Covenant on Social Economic and Cultural Rights [ICESCR (General Committee Comment No. 14)], and the World Health Organization guidelines.

Article 25 of the Universal Declaration of Human Rights states: "Article 25.(1) Everyone has the right to a standard of living adequate for the health and well-being of himself and of his family, including food, clothing, housing and medical care and necessary social services, and the right to security in the event of unemployment, sickness, disability, widowhood, old age or other lack of livelihood in circumstances beyond his control."

ICESCR, general comment No. 24 states:

"Health is a fundamental human right indispensable for the exercise of other human rights. Every human being is entitled to the enjoyment of the highest attainable standard of health conducive to living a life in dignity..."

All countries which are members of the United Nations are entitled to become members of the World Health Organization (WHO). The United States is one of 191 nations that has joined the WHO.

The WHO is the authority for Health within the United Nations system, It is responsible for providing leadership in health, setting research agendas, norms and standards, evidence-based policies, and monitoring and assessing health trends.

The WHO has set a number of goals for the millennium including improving maternal health, combatting HIV/AIDS and other diseases, and developing a global partnership for to achieve these.

All the millennium goals are to achieve better health and improve the quality of life of people.

What one can take away from the declaration, covenants and customary international law, is that healthcare is mandated as a right, and if the United States Constitution and Supreme Court case law is given full weight it is a right under the law in the United States..

The ACA is not a guarantee to universal coverage, but an attempt to reach the scope of universal coverage within the parameters of a free-market system. Within a free-market the ACA is designed to make affordable coverage available to all legal residents, concomitantly with a desire among policymakers to avoid disrupting existing tax and benefit systems. So while the ACA is not a right as is warranted by most countries, under the covenants, declarations, and customary international law, it is an incremental movement to meeting the goals of international law.

While most of the Western European Union has ascribed to the principles of healthcare as a right, the closest which matches the ACA is that of the Netherlands. It is composed of a government, business and employee partnership, as well as co-payments, risk pools, and subsidies for those that cannot premiums for short-term care.

Healthcare in the Netherlands is composed of three tiers. The Primary Care Physicians is the gatekeeper to the second and third tiers. The first tier is somatic and mental health care, the second tier is short term acute care and the third tier is long term care

The health care system is in comparison to other Western countries quite effective. Healthcare in the Netherlands was overhauled in January 2006, to involve businesses, employees, and the government.

Long-term care, such as semi-permanent hospitalization and disability costs are covered by a state-controlled mandatory insurance. For all short-term medical treatment, there is a system of obligatory health insurance, with private health insurance companies. These insurance companies are obliged to provide a package with a defined set of insured treatments.

Other sources of health care payment are taxes, out of pocket payments, additional optional health insurance packages and a range of other sources. Affordability is guaranteed through a system of income-related allowances and individual and employer-paid income-related premiums.

A key feature of the Dutch system is that premiums may not be related to health status or age. Risk variances between private health insurance companies due to the different risks presented by individual policy holders are compensated through risk equalization and a common risk pool. Funding for all short-term health care is 50% from employers, 45% from the insured person and 5% by the government. Children under 18 are covered for free. Those on low incomes receive compensation to help them pay their insurance.

Thus overall, the Dutch system is quite similar to the ACA, and vastly different from the Single Payer system in Canada and the United Kingdom of Great Britain and Ireland.

Speakers:

  • Bryan Miller, J.D., LL.M. (Public International Law), M.S.P.H. (Public Health), Law Office of Bryan Barnet Miller
  • Dr. Chapin White, Ph.D., Senior Policy Researcher at Rand in Washington, D.C.

Moderator: Stephen Zollman, J.D., LL.M. (Health Law), Law Office of Stephen Zollman

Webinar: The Laws They are a Changing: Updates in China Law and Practices for Trademark Practitioners

Wednesday, May 28, 2014, 12:15 p.m. - 1:15 p.m.

This program offers 1 hour participatory MCLE credit. You must register in advance in order to participate.

China trademark law continues to evolve to meet the demands of investors and sellers of products in China. You will get an overview of existing China trademark practice, the new changes, and the practical effects of those changes. Several new remedies have been created under China law that are of interest in protecting clients' rights in China.

Speaker: Laura Wen-yu Young, Partner Wang & Wang, San Francisco, Taipei, Shanghai and Beijing. LYoung@wangandwang.com Laura has provided advice to clients about law in Taiwan and China for over 20 years. She is an expert on all aspects of intellectual property law and business transactions in Taiwan and China. In addition to extensive lectures through INTA, LES, PLI and the State Bar, Laura teaches classes at UC Berkeley Boalt Hall's Jurisprudence and Social Policy Program, McGeorge School of law and at Soochow University, China.

Moderator: Anne Hiaring Hocking, Hiaring + Smith, LLP

Careers in International Law Programs

Over the years, the International Law Section has been presenting the Careers in International Law programs at various law schools throughout California. Each program, geared towards both law students and practitioners, features a panel of seasoned attorneys in the international law arena, and the panelists speak about their career paths to pursuing an international law practice, provide advice about starting or growing an international law practice, and answer questions from the program attendees. In collaborating closely with the law schools which host the programs, the International Law Section continues to expand and deepen the relationships with various law schools and law students in California.

The American Bar Association’s Section of International Law has continued to serve as a co-sponsor of the programs.

We are very glad that the law schools’ interest in holding the Careers in International Law programs continues to grow.

This Spring, starting in February 2014, we are presenting the Careers in International Law programs at eight law schools in California.

We held the programs at the following law schools in February 2014: the University of California, Berkeley, School of Law, and the University of California Davis School of Law, and the programs were very well received.

In March 2014, we held the programs at the following law schools:

In April 2014, we will be holding the programs at the following law schools:

If you are interested in serving as a panel speaker, please contact Harumi Hata. We would like to hold the Careers in International Law programs at various law schools in the Fall 2014. If you know of any law school in California which may be interested in holding the program next Fall, please contact Harumi Hata, and please include the contact information for the faculty/administrator at the law school who will serve as the lead contact for us.

We thank many of you for your interest and participation in the Careers in International Law programs, and we look forward to your continued interest, support and participation.

Save the Date: Networking Mixer with the Shanghai Bar Association Delegation -- Los Angeles, May 1, 2014

Please join The State Bar of California International Law Section for a social networking mixer with the Shanghai Bar Association Delegation. The reception will start at 5:30 p.m. on May 1st, 2014.

Sheppard Mullin, Los Angeles
333 South Hope Street, Forty-Third Floor
Los Angeles, CA 90071

For those who are interested in attending the event, advance registration is required for building security purposes. Please RSVP to Qiang Bjornbak.

Request for Nominations for Warren M. Christopher International Lawyer of the Year Annual Award

The International Law Section annually recognizes and honors a California Lawyer for distinguished service in the promotion of the rule of law internationally or for significant achievement in the practice of international law. The winner of the first such award was given to the late Warren M. Christopher and subsequently the award was named in his honor.

Nominations for the award to be presented in 2014 (our 4th Award) are now being accepted. All members of the International Law Section are invited to submit nominations for the 2014 award. Nominees must be members of the State Bar of California. There is no requirement that a nominee be a member of the International Law Section. Please keep all nominations confidential.

Please send nominations, accompanied by any material supporting the nomination, to the International Law Section International Lawyer of Year Award, c/o Jeffery J. Daar, at jdaar@daarnewman.com or at Daar & Newman, 21700 Oxnard Street, Suite 350, Woodland Hills, CA 91367.  Nominations must be received by Jeff Daar or Daar & Newman by March 31, 2014.

Upcoming Co-Sponsored Events

ABA Section of International Law, Spring Meeting, New York City -- April 1-5, 2014

The American Bar Association Section of International Law's 2014 Spring Meeting will take place on April 1-5 and will include more than 60 continuing legal education programs and a number of social events and networking opportunities.

California State Bar International Law Section members can register at a discounted rate. To receive the discounted rate, check off the "Member of Cooperating Organization" and list the California Bar Association, Section of International Law. Registration form is available here.

California State Bar ILS Breakfast Meet & Greet during the ABA ILS Spring Meeting: A complimentary breakfast will be served on April 3, 2014 from 7:30 a.m. - 9:30 a.m. in the Vanderbilt Room. ABA and California Bar ILS section members are cordially invited to stop in at any time between 7:30 a.m. - 9:30 a.m. to network with others attending the spring meeting.

Please visit ambar.org/ilspring2014 for information on programming, registration, and hotel accommodations.

ABA Section of International Law: "International Families: Money, Children, and Long Term Planning" Conference, Seattle -- June 19-21, 2014

The ABA Section of International Law invites you to attend the “International Families: Money, Children, and Long Term Planning” Conference to be held from June 19-21, 2014 at the Fairmont Olympic Hotel in Seattle, Washington. It is more common today than ever before that a person will marry someone from another country, culture, or religion. These “international families” have unique problems not found in a traditional domestic family. Building on the success of the Section’s 2012 program on international family law, this conference will guide U.S. and foreign lawyers in representing international families through a myriad of issues, including issues related to property, money, children, and long term planning, particularly as it relates to cases in Asia.

Program Topics Include:

  • Recognition and Enforcement of Foreign Judgments and Orders in Asia
  • Domestic Violence Allegations in International Family Cases
  • Primer on Asian Family Law
  • Immigration and Its Impact on International Family Law
  • Military Families in the Asia-Pacific
  • Finding Hidden Overseas Assets
  • Estate Planning for Families that Span Two Continents
  • The Implementation and Future of the 1996 Hague Child Protection Convention in the U.S.
  • The Promise of the 1980 Hague Child Abduction Convention in Asia

The California State Bar International Law Section is a Cooperating Entity on this event and California State Bar International Law Section members can register for the conference at the discounted ABA Section of International Law Member Rates by using the hardcopy registration form. Please visit http://ambar.org/seattle2014 for more information on programming, hotel accommodations, and to download the hard copy form.

Recent Events

The State Bar of California International Law Section's Visit to Tokyo and Osaka, Japan, in March 2014

[See larger versions of the photos on our Facebook page.]

Based upon the State Bar of California International Law Section’s Friendship Agreement with each of the Dai-ichi Tokyo Bar Association and the Osaka Bar Association, we presented very successful Joint Seminars in Tokyo and Osaka, Japan. Brent Caslin (ILS Past Chair), Jeff Daar (ILS Immediate Past Chair), Bill Gay (ILS Executive Committee Advisor), Harumi Hata (ILS Executive Committee Member and ILS Secretary), Miwa Shoda (ILS Executive Committee Advisor), and Tom Stromberg (ILS member) participated in the Joint Seminars.

  The Joint Seminar with the Dai-ichi Tokyo Bar Association, entitled “Attorney-Client Privilege and In-House Lawyers’ Roles and Related Matters”, was held on March 3, 2014, in Tokyo. Jeff Daar, Harumi Hata, and Miwa Shoda presented at the seminar. Approximately 100 lawyers, including many who are in-house counsel, attended the Joint Seminar.

At the conclusion of the Joint Seminar in Tokyo, the State Bar of California International Law Section, represented by Brent Caslin, and the Dai-ichi Tokyo Bar Association exchanged tokens of appreciation  with each other.

 In addition to presenting at the Joint Seminar in Tokyo, we met with the leaders and the representatives of the Japan Federation of Bar Associations and the Dai-ichi Tokyo Bar Association and also with two of the Justices of the Supreme Court of Japan.

The Joint Seminar with the Osaka Bar Association and co-sponsored by the Osaka Chamber of Commerce and Industry, entitled “Current Trends of U.S. M&A and Cases Utilized M&A as Asian Market Entry Methods”, was held on March 6, 2014, in Osaka. Jeff Daar, Bill Gay, Harumi Hata, Miwa Shoda, and Tom Stromberg presented at the seminar. Approximately 125 lawyers and business executives attended the Joint Seminar.

 At the conclusion of the Joint Seminar in Osaka, the State Bar of California International Law Section, represented by Brent Caslin, and the Osaka Bar Association exchanged tokens of appreciation with each other.

 In addition to presenting at the Joint Seminar in Osaka, we met with the leaders and the representatives of the Osaka Bar Association.

Based upon the Joint Seminars and the visits in Japan, we were able to nurture and strengthen our relationship with each of the Dai-ichi Tokyo Bar Association and the Osaka Bar Association. We thank the representatives of the Dai-ichi Tokyo Bar Association and the Osaka Bar Association for planning and presenting the Joint Seminars with us, and we look forward to continue collaborating together in the future.

Barcelona Bar Association, International Law Section of the State Bar of California and Osaka Bar Association Friendship Agreements

On February 2, Barcelona and Osaka Bar Associations signed a friendship agreement with the aim of promoting the possibility for the young lawyers of both bar associations to become familiar with the legal practice in the other jurisdiction, by providing its young lawyers with an opportunity to participate in training at law firms of the other jurisdiction, as well as promoting the exchange of information concerning library resources and legal materials in order to keep their respective members informed and provide them with access to legal information of each jurisdiction.

Similar agreements have been signed between the International Law Section of the State Bar of California, and Barcelona Bar Association, as well as between Osaka Bar Association and the International Law Section of the State Bar of California. The signatures have been promoted by Kazuhiko Nishihara (Osaka Bar Association), Michael Newman (the International Law Section of the State Bar of California) and Josep Solsona (Barcelona Bar Association). With the signature of this document, the triangle of friendship agreements between the Bar Associations of Osaka, California and Barcelona has been cemented.

Get Involved with the International Law Section

The E-Media Committee is responsible for the Section's website, this E-Newsletter, and our Section's social media presence on Facebook and Twitter. Contact the Chair Diana Mack or Vice-Chair Pamela Fulmer.

The External Relationships Committee is responsible for the Section's relationships with foreign and domestic bar associations and other international law and business groups, including establishing new relationships. Contact the Co-Chair: Enrique Hernandez and Michael Newman.

The International Law Journal Committee is responsible for The California International Law Journal. The Committee Chair is the Editor-in-Chief, who is assisted by Co-Managing Editors and Associate Editors. Section members may seek appointment as Associate Editors. Contact the Chair and Editor-in-Chief: Will Pao.

The Law Student Outreach Committee is responsible for outreach to law students, including administering our annual Student Writing Competition, our Careers in International Law programs, and our International Law Society Advisory Committee.  Contact the Chair: Zahirah Mann.

The Programs Committee is responsible for the education programs and networking events for the Section. We welcome our section members to work with our Executive Committee to develop more webinar programs. If you wish to submit a proposal or have a question about any program, please contact both Program Committee Chair William T. Gay and Program Committee Vice Chair Qiang Bjornbak. The content and the time of the program need to be approved by both William T. Gay and Qiang Bjornbak. All the webinar programs must meet MCLE program requirements.  All the programs need to have international content. The content of the program should not be duplicative or conflicting with existing programs (for at least 6 months). The timing of the program should not be conflicting with any time slot of existing programs or black-out dates of state bar annual meeting.

Introducing the Public International Law (PIL) Committee: This new committee will focus on topics in public (vs. private) international law. We will develop Section programs and initiatives related to public international law, including international human rights, within California and worldwide.  At this early stage, we are looking for additional members and fresh ideas for PIL projects and activities. The PIL Committee will have monthly telephonic meetings. Contact the Chair: Mary Hansel.

Participation on one of our Committees is also a great way to determine if you would like to seek appointment to the Section's Executive Committee.

For more information about the International Law Section's activities, please see our website at http://international.calbar.ca.gov/ and our Facebook page at www.facebook.com/CALBARILS.

The California International Law Journal

California International Law Journal The California International Law Journal is currently soliciting articles for its upcoming issues. Standard articles range from 15-25 pages, double-spaced. Short articles range from 4-8 pages, double-spaced. While most articles are geared toward practitioners and professionals, we also publish academic articles that may be of interest to our readers. Topics may include anything that pertains to public or private international law, including transnational commercial disputes, procedural rules for international litigation, international criminal cases, immigration matters and international human rights issues.

If you are interested in submitting an article, please send us your proposed topic or manuscript as soon as possible to cilj.submissions@gmail.com, so that we can approve and, if selected for publication, assign an editor to work with you on finalizing your article.

New! Advertisement Spaces Available

The California International Law Journal publishes two times a year and has a circulation of about 1,500 copies. The Winter/Spring 2014 issue is coming up, and there are advertisement spaces available for the businesses that would like to reach an audience of California lawyers who practices in various areas of international law.  For a half-page ad, rates are as low as $300 per issue and $720 for three issues.  If you or someone you know are interested in more information, please reach out to Ellie Kim or Julie Martinez.

Meet Your Executive Committee

The International Law Section is managed by its Executive Committee, which is comprised of individuals with a broad range of legal specialties who share a dedication to the expansion of cross-border and international practice. Contact information for our Officers, Members, Advisors, and Advisors Emeritus can be found HERE. For information on becoming a Member of the Executive Committee in the future, click HERE.

Online CLE for Participatory Credit - Available Anytime!

Online CLEInternational Law Section past programs are available over the internet for participatory MCLE credit. For the entire catalog of the International Law Section’s programs available for MCLE credit, please see online CLE and select International Law. Be sure to check out CLEtoGo if you're interested in downloadable podcasts.

Contact Us

International Law Section
The State Bar of California
180 Howard Street
San Francisco, CA 94105-1639
ils@calbar.ca.gov

415-538-2380
FAX-415-538-2368

The International Law Section is a State Bar of California-approved MCLE provider.