Harassment Policies: New Allegations Show More Work To Be Done

The specter of sexual harassment has once again risen up in tabletop gaming circles. Conventions are supposed to be places where gamers and geeks can be themselves and embrace their loves. Conventions need clear and well formulated harassment policies, and they need to enforce them. In this instance the allegations from multiple women have taken place at gaming conventions and gathering in different locations around the country. In one case, the harassment was took place over the course of years and spilled over into electronic formats.

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The alleged harasser in these cases was Sean Patrick Fannon, President of Evil Beagle Games, Brand Manager for Savage Rifts at Pinnacle Entertainment Group, as well as being a game designer and developer with a long history in the tabletop role-playing industry.

There is a long and untenable policy of harassment at conventions that stretches back to science fiction and fantasy fandom in the 1960s. Atlanta's Dragon*Con has been a lightning rod in the discussions about safety at geeky conventions after one of the convention's founders was arrested and pled guilty to three charges of molestation. We have also covered reports of harassment at conventions such as Paizo Con, and inappropriate or harassing behavior by notable industry figures. It is clear that clear harassment policies and firm enforcement of them is needed in spaces where members of our community gather, in order that attendees feel safe to go about their hobby. Some companies, such as Pelgrane Press, now refuse to attend conventions where a clear harassment policy is not available.

Several women have approached me to tell me about encounters with Fannon. Some of them asked not to be named, or to use their reports for background verification only. We also reached out to Sean Patrick Fannon for his comments, and he was willing to address the allegations.

The women that I spoke with had encounters with Fannon that went back to 2013 and 2014 but also happened as recently as the summer of 2017. Each of the locations were in different parts of the country, but all of them occurred when Fannon was a guest of the event.

The worse of the two incidents related to me happened at a convention in the Eastern part of the United States. In going back over texts and messages stretching back years the woman said that it "is frustrating [now] to read these things" because of the cajoling and almost bullying approach that Fannon would use in the messages. She said that Fannon approached her at the con suite of the convention, and after speaking with her for a bit and playing a game with a group in the suite he showed her explicit photos on his cellphone of him engaged in sex acts with a woman.

Fannon's ongoing harassment of this woman would occur both electronically and in person, when they would both be at the same event, and over the course of years he would continue to suggest that she should engage in sexual acts, either with him alone, or with another woman.

Fannon denies the nature of the event, saying "I will assert with confidence that at no time would such a sharing have occurred without my understanding explicit consent on the part of all parties. It may be that, somehow, a miscommunication or misunderstanding occurred; the chaos of a party or social gathering may have created a circumstance of all parties not understanding the same thing within such a discourse. Regardless, I would not have opened such a file and shared it without believing, sincerely, it was a welcome part of the discussion (and in pursuit of further, mutually-expressed intimate interest)."

The second woman, at a different gaming-related event in another part of the country, told of how Fannon, over the course of a day at the event, asked her on four different occasions for hugs, or physical contact with her. Each time she clearly said no to him. The first time she qualified her answer with a "I don't even know you," which prompted Fannon after he saw her for a second time to say "Well, you know me now." She said that because of the multiple attempts in a short period of time that Fannon's behavior felt predatory to her. Afterwards he also attempted to connect with her via Facebook.

Afterwards, this second woman contacted the group that organized the event to share what happened and they reached out to Fannon with their concerns towards his behavior. According to sources within the organization at the time, Fannon - as with the first example - described it to the organizers as a misunderstanding on the woman's part. When asked, he later clarified to us that the misunderstanding was on his own side, saying "Honestly, I should have gotten over myself right at the start, simply owned that I misunderstood, and apologized. In the end, that's what happened, and I walked away from that with a pretty profound sense of how to go forward with my thinking about the personal space of those I don't know or know only in passing."

Both women faced ongoing pressure from Fannon, with one woman the experiences going on for a number of years after the initial convention meeting. In both cases he attempted to continue contact via electronic means with varying degrees of success. A number of screen shots from electronic conversations with Fannon were shared with me by both women.

Diane Bulkeley was willing to come forward and speak on the record of her incidents with Fannon. Fannon made seemingly innocent, and yet inappropriate comments about her body and what he wanted to do with her. She is part of a charity organization that had Fannon as a guest. What happened to her was witnessed by another woman with whom I spoke about that weekend. As Bulkeley heard some things, and her witness others, their experiences are interwoven to describe what happened. Bulkeley described this first encounter at the hotel's elevators: "We were on the floor where our rooms were to go downstairs to the convention floor. I was wearing a tank top and shirt over it that showed my cleavage. He was staring at my chest and said how much he loved my shirt and that I should wear it more often as it makes him hot. For the record I can't help my cleavage is there." Bulkeley went on to describe her mental state towards this "Paying a lady a compliment is one thing, but when you make a direct comment about their chest we have a problem."

Later on in the same day, while unloading some boxes for the convention there was another incident with Fannon. Bulkeley described this: "Well, [the witness and her husband] had to move their stuff from a friends airplane hangar (we all use as storage for cars and stuff) to a storage until next to their house. Apparently Sean, while at the hanger, made grunt noises about my tank top (it was 80 outside) while Tammy was in the truck. I did not see it. But she told me about it. Then as we were unloading the truck at the new facility Sean kept looking down my shirt and saying I have a great view etc. Her husband said to him to knock it off. I rolled my eyes, gave him a glare and continued to work. I did go and put on my event day jacket (light weight jacket) to cover up a little."

The witness, who was in the truck with Fannon, said that he "kept leering down at Diane, glancing down her shirt and making suggestive sounds." The witness said that Fannon commented "'I'm liking the view from up here.'"

Bulkeley talked about how Fannon continued his behavior later on in a restaurant, having dinner with some of the guests of the event. Fannon made inappropriate comments about her body and embarrassed her in front of the other, making her feel uncomfortable throughout the dinner.

Bulkeley said that Fannon also at one point touched her hair without asking, and smelled it as well. "[Fannon] even would smell my long hair. He begged me to not cut it off at a charity function that was part of the weekend's event." She said that he also pressed his pelvis tightly against her body while hugging her. These incidents occurred at a convention during the summer of 2017.

Fannon denies these events. "The comments and actions attributed to me simply did not happen; I categorically and absolutely deny them in their entirety."

When asked for comment, and being informed that this story was being compiled Fannon commented "I do not recall any such circumstance in which the aftermath included a discourse whereby I was informed of distress, anger, or discomfort." He went on to say "The only time I recall having ever been counseled or otherwise spoken to about my behavior in such matters is the Gamers Giving/Total Escape Games situation discussed above. The leader of the organization at that time spoke to me specifically, asked me to be aware that it had been an issue, and requested I be aware of it in the future. It was then formally dropped, and that was the end of it until this time."

There were further reports; however, we have respected the wishes of those women who asked to remain anonymous for fear of online harassment. In researching this article, I talked to multiple women and other witnesses.

About future actions against the alleged behaviors he also said "It is easy, after all, to directly attack and excise obviously predatory and harassing behavior. It is much more difficult to point out and correct behavior that falls within more subtle presentations, and it's more difficult to get folks to see their actions as harmful when they had no intention to cause harm, based on their assumptions of what is and isn't appropriate. It's good for us to look at the core assumptions that lead to those behaviors and continue to challenge them. That's how real and lasting change within society is achieved."

Fannon's weekly column will no longer be running on E.N. World.

Have you suffered harassment at the hands of someone, industry insider or otherwise, at a gaming convention? If you would like to tell your story, you can reach out to me via social media about any alleged incidents. We can speak confidentially, but I will have to know the identity of anyone that I speak with.

This does open up the question of: At what point do conventions become responsible for the actions of their guest, when they are not more closely scrutinizing the backgrounds of those guests? One woman, who is a convention organizer, with whom I spoke for the background of this story told me that word gets around, in the world of comic conventions, when guests and creators cause problems. Apparently this is not yet the case in the world of tabletop role-playing game conventions, because there are a growing number of publishers and designers who have been outed for various types of harassing behavior, but are still being invited to be guest, and in some cases even guests of honor, at gaming conventions around the country. The message that this sends to women who game is pretty clear.

More conventions are rolling out harassment policies for guests and attendees of their conventions. Not only does this help to protect attendees from bad behavior, but it can also help to protect conventions from bad actors within the various communities that gather at our conventions. As incidents of physical and sexual harassment are becoming more visible, it becomes more and more clear that something needs to be done.

additional editorial contributions by Morrus

 

[Riley37]

As I wrote before, on the internet, no one knows you are a dog.

Yes and no. Several in this thread have revealed themselves as attack dogs. Maybe not as canine, technically...

If I had written, "I would almost guarantee that you haven't read all of the software EULAs that you have accepted," would you have written the same response?* Would that have been an issue of "check your privilege," or not knowing what other marginalized individuals' life experiences are?

No, I would not have written the same response. I would have pointed out that EULAs are a tool of publishers, and are therefore apples-to-oranges in a discussion of how cons can discourage harassment. Con harassment largely (if not always) occurs across power differential. Resources for people who have been harassed at a con, are generally resources for people on the lower side of a power differential. (Differentials including, but not limited to, guest of honor vs. first-time atttender; and gender, age, etc. See also: Daniel Holtzclaw.) Workplace anti-harassment posters (and OSHA and so forth) exist largely for the benefit of employees who are generally, as individuals, *on the lower side of a power differential relative to their employers*. The rest of your post suggests that you are sufficiently familiar with those posters, that you should know the difference between increasing and decreasing the tilt of those differentials, and should not need this explanation of why con posters are much, much closer in intent to OSHA posters than to EULAs.

So why that hypothetical question about my response if you had asked about EULAs? Are you trying to transfer the jury's annoyance with EULAs, to me, via rhetorical questions? No dice, sir; I'm already annoying enough; also, consider the voir dire. The jury you're looking for is in another castle.

So, while I don't doubt that you do this (on day 1 of each new job), I also don't understand how these mandated posted allow you to determine exactly where your boundaries fall.

True statement. "Technically correct; the BEST kind of correct!" You do not understand. Why do you claim a lack of understanding, as if it were a point of pride?

The posters, as you already know, rarely provide the full text of the relevant codes, let alone the case history; and those are not the most useful content for their typical reader. They provide a general statement of intent, from which I can infer, though with only rough estimation, something about where those boundaries *might* fall in a win-win scenario. The posters refer to more comprehensive sources, such as websites. Furthermore, their text isn't their only utility. If I'm pushing back, against a supervisor's demand which violates anti-harassment rules or other protections, then I'll start that conversation in a location such that when she says "Do it if you wanna keep your job", I can *point* at the posters. Though she may have never read *any* of the poster text, and she won't read posters there-and-then, the posters offer her a reminder that there is authority other than hers. (Or his, as the case may be.)

Comparisons between workplace anti-harassment posters, and documentation at cons (from posters on billboards, to policy summaries in program books, to QR codes on badges), as resources for people who want to know who might take their side, and who they should talk to next, are so trivially obvious that I leave them to your imagination. You have some knowledge of what improves resolution of harassment in workplaces; apply that to cons. You can do it!

I don't know, from what you've said, whether you have more experience siding with employers (analogous to con owners), or with individual workers, or with unions, or something else. But dang, are you working towards the most legally defensible approach, which gives con organizations the strongest claim of due diligence? Or are you looking for the most ground-up, culturally-rooted, nip-it-in-the-bud approach to making people like RedJenOSU and AfroDyte safer at cons, and thus more inclined to attend? Or something else?

The one time I was harassed at work, the harasser was the union shop steward. Does your mind jump to the relative role of the union versus the role of the employer? Or elsewhere? I asked her to keep her hands to herself, and from them on she did. No human, other than me and her, knew the he-said-she-said. If con harassment were resolved, more often, in such manner, then that would delight me as a human and a gamer, though it would neither intrigue nor employ me as a litigator. Words you won't often hear, from lawyers who chase profit: "I'm glad that worked out so easily".

If you are, as you say, always surprised, then I offer you this advice: mix your high-quality attention to the law, with more attention to people at other levels. Perhaps then you will more often anticipate how people will feel, when they read or hear your words, and therefore you will more often accurately anticipate the tone of their responses.

I have a wild speculation about how you feel, right now, reading these words. Maybe you're bristling and eager to one-up me, to point out the flaws in my words, to establish EN World dominance. Prove me wrong?

Could your next post, instead, do something towards making people like RedJenOSU and AfroDyte safer at cons, and thus more inclined to attend? If you want to also send me, directly, a nastygram, then go ahead. Blow off some steam, tear me a new one. Overload the profanity filter. Right after you add something to the cumulative resources of the project at hand. Heck, two birds with one stone: roll back to my post on Alphacon and Betacon, and tear it to shreds, by elaborating better methods of making BetaCon possible. You'll have victory over me, *and* over con harassers. One small step, towards tilting power differentials in the direction of justice. Justice is the goal of law, right?

 

[S'mon]

I believe some examples are necessary. In addition to helping potential harassers avoid the edge cases, especially with gross pick-up culture out there, one reason not often mentioned is to help inform the victims. Since sexual harassment has not been taken very seriously for so long, there are many instances of someone feeling harassed but doubting whether those in charge would agree. So at a convention, an incident might occur that isn't as blatant as groping, but the person feels harassed and the convention would consider it harassment, however, without the convention stating that as an example, the victim might reasonably be skeptical and not report it. The history of society and our industry in particular isn't real stellar in creating confidence in victims that they will be taken seriously unless a case is blatantly egregious (and sometimes even then it still hasn't been taken seriously!).

Plus add in being a witness to a situation like that, and there can be even more doubt about whether they should do something or not. Women have been indoctrinated to not be confrontational, so even watching their reaction might not be enough to clarify whether it was harassment or not if you are a witness. Too many situations can fall into an area of doubt, which historically usually leads to massive underreporting.

So I think a list of examples is absolutely necessary, not just to curtail potential harassers who are either uninformed or want to push the boundaries, but to tell potential witnesses and victims that the convention will take reports Hi even if they aren't over-the-top egregious.

Yes I agree. I think more certainty would be beneficial for both parties and for onlookers.

 

[lowkey13]

*Deleted by user*

 

[Riley37]

Quick aside, since I must have missed this in the past 900+ comments.

What is glagtery? Is that a placeholder for something else?

DannyAlcatraz invented the word as a place-holder for a form of criminal behavior. He was addressing the "we will never eliminate it so why bother" argument, IIRC. He pointed out that the legal system can deter and thus reduce the incidence of glagtery, perhaps as follows: reduction by 50% at a cost of $N (in police time, court costs, etc.), reduction by 75% at a much higher cost (N^2$?), reduction by 87.5% at a MUCH higher cost, which requires higher taxes and also civil liberties (chip in everyone's neck, etc.). Thus it's better to settle for the lower effort, and preserve resources for other tasks such as military defense, social safety nets, plague prevention, etc.

A good argument, but now that I give it more attention per your question, DannyAlcatraz didn't discuss the interplay between law enforcement, and factors at other levels, such as peer pressure, and differing values (Vulcan immigrants consider it normal while Romulan immigrants consider it abominable, there's a neighborhood where both live side by side, and all too often, humans get them confused). Also whether glagtery harms anyone other than the participants. See also: Mills "On Liberty".

I ran with the term, as if glagtery were a victimless crime when done with the mutual informed consent of all three individuals involved, and as if it were controversial in the TRPG con community (though not at GlagterCon).

Some people in this thread have equated "sexual attention only with clear consent!" and "ban male sexuality!". Comparisons with glagtery are a slippery slope, because the term's referent is not clearly established.

 

[lowkey13]

*Deleted by user*

 

[RedJenOSU]

No, in a perfect world, anybody could let their hair down, relax, dress in any manner they choose, get a drink at the convention hotel bar, get wasted in a suite party... and not be judged, sexually harassed, discriminated against, or become the victim of a sex crime.

You will have to abolish the sex instinct in all men to accomplish it.

That is a giant crock of !

Are you seriously saying that men are unable to control their bodies and prevent sexual attacks? Study after study has concluded that sexual attacks rarely if ever have anything to do with being overcome with sexuality. Sex crimes are almost always about displaying power over the less powerful.

If Sex crimes were about sex, we'd have a long list of lesbian sex offenders attacking other women.

If you can't control your penis, then grow up and do something to control it. It is not mine or any other woman's job to control your body.

 

[lowkey13]

*Deleted by user*

 

[RedJenOSU]

The person you are replying to has been banned from the thread for his comments; that said, your points are correct.

Yeah, I posted it before I had slogged through the all the updates since I had to go away for a few days of jury duty.

 

[Particle_Man]

Another idea is to make sure that little children and their parents are treated with respect at cons. Way back in the day when I went to a con (and dinosaurs roamed the earth) I was part of a game where a baby nearby was crying and the parent took the baby out and the GM lost his temper and cussed out the parent. That seems wrong. I also heard of a report where a parent was with a small child at a big comic/tv/movie con and a TV Star passed by and just tickled the kid’s belly but without permission. I thing that addressing things like this could also be done while addressing sexual harassment. The underlying idea of respect and boundaries seems to be the same in both cases.

If this is too far off topic I apologize.

 

[Riley37]

It's like Judge Learned Hand's PL > B.

(The burden of taking precautions must be less than the probability of loss * gravity of the loss).

Hey, you taught me something new-to-me: the "calculus of negligence". Thanks! Well, you brought it to my attention and then I skimmed a bit. I think that's kinda where DannyAlcatraz was going, except that he was discussing resource allocation by the government, rather than by private actors.

Insofar as I understand DannyAlcatraz's intent, he was framing the role of con management, in deterring harassment, as equivalent with the role of the government, in deterring crime; and he was talking only stick methods, with no mention of carrot methods. In terms of prevention cost, one can equate the government spending $1M on putting more cops on the street, with the government spending $1M on sponsoring more "This is your brain on drugs!" advertisements. Yet those are non-identical in secondary and side effects. (Especially: which streets?)

As for circular firing squads...

Yeah, I could do better. So far as I can tell, so could you. Let's both work on that? Let's give the "status quo defenders", Team BWBB (Boys will be Boys), more grief that we give each other? If you are confident that your hands are clean on that count, then I'll raise two points, and after that, opinions from people other than me, will be more useful than anything further from my biased perspective.

(1) Calithorne jumped into the thread. Elfcrusher quickly and accurately saw where Calithorne was going. Sadras snarked with "Alarmist much?". I saw Sadras siding with Calithorne, and in the process, *dismissing alarmism*. Dismissal of alarmism is a position which correlates very closely "there's no problem here, everything at cons is fine, boys will be boys, this is all a fuss over nothing, no one proved anything against Fannon." (A position which Fannon has disavowed.) You don't have to believe my individual story about my relatives in 1940s Germany, to take the point that some people have more "skin in the game" than Sadras does, and thus don't take lightly to dismissals of alarmism. There are all too many people with those stories, and so far as I know, *every* Holocaust survivor in the USA who has spoken up since 2016, is sounding alarms, *none* of them are saying this will just blow over. Is this the thread and topic, for responding to concerns, with immediate, reflexive dismissals of alarmism?

I didn't lose anyone, personally, at Isla Vista, nor at Toronto, but the people who feel less safe after those incidents, have a LOT in common with those who feel less safe *at cons*. Some of the language that Calithorne was using, is a close cousin to some of the language frequently used by fans of Eliot Roger. Are you open to the possibility that Elfcrusher knew something you didn't, about incels and how to recognize their close relatives in the manosphere? In much the same way that I recognize "blood and soil" as a phrase with a certain history, overlapping with my family history, when I hear it at Charlottesville? (Again: discount my story, maybe I'm a dog, but this dog recognizes that phrase.)

This is where you come in: you jump in, defending Sadras. So when Sadras yokes his wagon to Calithorne, and then you rise to Sadras's defense, because how dare anyone object to his accusations of alarmism... . at that point, what was your role in the process towards a circular firing squad?

Hint: you *eventually* saw Calithorne for what he was; notice whose IFF (Identify Friend or Foe) triggered long before yours did.

Did the posts (and the XPs) from *those who are most at risk from harassment at cons* play any role in how you stepped in? One of the "out" woman in the conversation has apparently concluded that I'm also a woman. Maybe I'm a dog, but if so, I bark online like a bitch. Maybe that's because I never defend anyone who's defending Calithorne; because I listen more to those who *do* have skin in the game, than to you and Sadras. (Sadras has, since Calithorne escalated all the way to ban, marked an Elfcrusher post with +XP. IMO that "+XP" falls way, way short of "Hey, you were right, I was wrong, next time I'll be slower to publicly mock you as an alarmist.")

(2) Cons and posters and EULAs. Yeah, you were trying to help. You're on Team Less Harassment.

Maybe you'll give some awesome help to the team which does poster layout, in terms of how much text belongs where, and what's best referred to other documents. I think you're fundamentally mistaken, in terms how whether the primary function of those posters, is the text on them. The post-guillotine heads of the owners of the Triangle Shirtwaist Factory would be more effective, for my purposes. They serve notice that there is someone *other* than the employer, who has the power to impose consequences. *All* of the text could be elsewhere, so long as the posters (or skulls) make the point that The Boss is not G-d. Well, we can disagree on posters, in this thread. Your methods, my methods, shared goals.

But, goodness... was it prudent to presume, in this thread of all threads, that anti-harassment posters (or ADA posters) in the workplace, are a safe and neutral analogy, with no "third rail" possibilities? Take my story of about requesting the workplace accommodation of "swastika-free work environment" as a hypothetical; I personally am a dog, or maybe an AI. But are there no other stories, from verifiable sources, of people who did something along the line of putting their ADA requests on the back burner, because they felt a overriding moral imperative, to first prod their employer into providing a swastika-free work environment?

It took over a month - wait, I'm a dog, it took however long it took some verifiable source to get the swastika graffiti out of THEIR workplace. Because managers have other priorities; Corporate is grading them on customer satisfaction feedback, not on whether employees see a swastika every time they use the gorram bathroom, and a work ticket for "remove swastika graffiti" processes no faster than a work ticket for "fix a leaky sink". Does your experience indicate otherwise?

For some of us, ANY topic involving harassment is touchy, *and that includes workplace harassment*, whether sexual or racial or otherwise (though sexual is the focus of this thread). If you can make your point *without* making assertions and analogies which rest on the role of posters in workplace harassment, then please do. For this thread. When you're laying out the poster, THEN check workplace posters for the optimum ratio of "We're Proud To Be A Safe Workplace!" with "here's our harassment policy" with "here's the hotline".

Okay. There's my two examples. That's why I'm so touchy about the workplace analogy. Maybe I'm extra and unreasonably touchy about swastikas in the workplace. If it's just me, then it's just me, block as needed. If it's not just me, if anyone who's been harassed at a con says "I also would find your posts more helpful if you shift your assumptions", then you have my request, and act as you see fit.

If it matters, what I've done so far: grain of salt on everything other than EN World, including my unverifiable claim about using every leverage I could to get swastika graffiti out of a bathroom at a store, and my unverifiable claim
of successfully asking my union shop steward to stop touching my butt. Would you accept, as evidence, my participation in other threads than this one, such as GenCon's response to Indiana's homophobia three years ago, or "Race vs. Ancestry" last month? Failing that, zooming in on this thread: even if my story about workplace sexual harassment is hypothetical or second-hand, at least it's on topic.

DannyAlcatraz asked what price people would pay, to attend cons with less sexual harassment; I was among the few to answer, and I extended my answer from $ price to behavioral. (I'm about to spend $80 on KublaCon. I'd gladly kick in another $20 for better anti-harassment. Negotiable, upwards.)

Rygar said... something Rygarish, he's gone now, about how anti-harassment would doom not just cons, but the entire TRPG industry, to economic failure. I laid out a schema for how the con market could self-segregate, with some con attenders preferring BWBB cons, and others preferring low-tolerance cons. I offered some specifics of how the two would differ, and raised the question of whether they'd both turn a profit. (Hooters isn't my cup of tea, but if it draws its target market *away* from the bar where I hang with co-ed sports league teammates, so much the better for both.)

I consider Troll Patrol useful; yeah, the mods stop the worst of them, eventually, but in the meantime, I see some merit in Elfcrusher spotting Calithorne, and I've done some of the same, because the shifting mix of good-faith and whataboutism makes the thread into Difficult Terrain.

I wrote an impassioned appeal to legalize glagtery. Dunno if that counts? Only insofar as occasional humor may offset the dryness of legalistic posts, in the mix of such a painful topic for survivors. I outed myself, not as a dog, but as an AI. (just kidding - all of my parents are real humans! with two opposable thumbs each! I even have a gender!)

But you're asking the wrong person. Self-assessment is notoriously biased. Does RedJenOSU find any of my contributions valuable? Or Jeanneliza? Do you care whether AfroDyte put me on her list of EN Worders whom she sees as potential harassers, if she ran into them at a con, and she turned down their advances? (I say she's safe from me, as I think twice before flirting with women who are out as lesbians, but does *she* see IFF factors in my online interactions with her?)

*sigh* Did you make your saving throw against Wall of Text? My fingertips would be bleeding, if I had fingers.

Thanks again for the Learned Hand reference.