Participated in an amicus brief (with the Reporters Committee and other amici) filed with the U.S. Supreme Court in Georgia v. Public.Resource.Org. The brief concurred with the Eleventh Circuit that Georgia cannot copyright its official code, and by extension, the annotations to that code. The brief argued that the government edicts doctrine at issue here can be grounded in the First Amendment, as it is analogous (in purpose at least) to the First Amendment right of access to judicial proceedings recognized by the Court. The brief also argued that permitting states to copyright their official codes hinders access to them by the press and public. [2019]