Thank You, Satanists

Last week in a blog post here, I suggested that those of us disheartened by the Hobby Lobby and Wheaton College verdicts protest by getting ordained in the universal-ordination church of their choice. Astute readers asked whether more people legally qualified to preside over weddings and funerals by the Church of Universal Life could possibly have an impact on the pervasive redefinition of “religious liberty” being put forward by the religious right. It’s a symbolic effect, I grant you. But the idea is to make clear that if “religious liberty” is to be attached to some “religious” beliefs like opposition to contraception, it should be attached to all beliefs that proclaim themselves to be religious, whether or not those in power agree with them, or even know what the Church of Spiritual Humanism is. The more “out there” the religion, the stronger the rhetorical impact, throwing into stark relief just how un-American it is to allow individuals to impose their religious beliefs on others.

So I was happy to hear a similar line of argument come up this week from the Satanic Temple, a New York-based religious organization (although non-tax-exempt, because it doesn’t believe religious organizations should be), announced an ingenious response to the Hobby Lobby verdict. They have created a letter of exemption for women  to show their doctors in hopes of getting out of the requirements of the “informed consent” laws now applied to abortion procedures in 35 states. It reads, in part:

As an adherent to the principles of the Satanic Temple, my sincerely held religious beliefs are:

  • My body is inviolable and subject to my will alone.
  • I make any decision regarding my health based on the best scientific understanding of the world, even if the science does not comport with the religious or political beliefs of others.
  • My inviolable body includes any fetal or embryonic tissue I carry so long as that tissue is unable to survive outside my body as an independent human being.
  • I, and I alone, decide whether my inviolable body remains pregnant and I may, in good conscience, disregard the current or future condition of any fetal or embryonic tissue I carry in making that decision.

Since the bearer of the letter sincerely, religiously believes in science, they must be allowed to follow their conscience. It’s twisted, but it’s brilliant.

Yes, this is the same group best known for its efforts to erect a statue of Satan in front of the Oklahoma State Capitol, just like the 10 Commandments, and for their attempted Black Mass at Harvard.  Pre-Hobby Lobby,  both stunts had struck me as mildly amusing but not very effective. Some of these actions are actually a little mean-spirited, like Pastafarians gaining the legal right to wear their “religious headgear,” the colander, in driver’s-license photos. The civil-religion hot-button they’re pushing is from a lawsuit of Sikhs and Muslims against the MTA. And haven’t the Sikhs and Muslims suffered enough without being compared to people who believe sarcastically in a Flying Spaghetti Monster? Likewise the atheists who delivered the opening prayer at the infamous Greece, New York, town meeting, after courts ruled that such prayer was somehow legal. The fact that it was atheist prayer seemed meant to “prove a point,” and that point, to me, was that New Atheists have become just another religious sect, and they should get off their high horse. (Note: atheists get REALLY MAD when you  say this.)

But now that SCOTUS has ushered in a new religious order, I’m inclined to see the Satanic Temple’s efforts as sincere, and a little less self-serving. They certainly want to be seen that way, as witness a very interesting interview with a Satanic spokesperson in Salon.

“Given the current state of things, given those dominant religious voices that we’re hearing right now, it is still infinitely better that a diversity of faiths and beliefs are respected and granted rights and privileges, rather than letting one set of beliefs co-opt the authority of the government.

A lot of organizations have worked hard to get religion out of the government, and I think that it’s clear that it’s not necessarily working. So there’s other alternatives.”

But just because they are sincere doesn’t mean I expect them to have the results they set out to. The Religion News Service recently published an admirably straight-faced explainer of the campaign, quoting legal scholars from Mormon and Catholic institutions to the effect that the exemption “may face legal hurdles,” starting with, you guessed it, whether the Satanic Temple is actually a religion at all. The reporters’ conclusion struck me as a) the understatement of the week, and b) not the point. The point is that ridiculous verdicts call for ridiculous responses, and the more “alternatives” the better.

Brook Wilensky-Lanford is the author of Paradise Lust: Searching for the Garden of Eden (Grove Press, 2011) and the editor-in-chief of online literary magazine Killing the Buddha.

  • DKeane123

    Enjoyed this article up until the point you decided to start ragging on atheists – when I got REALLY MAD. On the fact that new atheists are somehow equated with a religious sect – please put some meat on that in a blog post or something. BTW – these Satanists are atheists.

    - We don’t go door to door proselytizing.
    - There is no dogma – everyone’s views are up for examination by the actual facts.
    - There are no authorities – Richard Dawkins does not speak for new atheists and his opinion is not handed down to the rest of us.
    - We don’t go to church (although some like community on Sundays),
    - We aren’t looking to save your eternal soul, although we would like to have you not waste your time in this life.

    A.C. Grayling puts this subject to bed here:
    http://www.acgrayling.com/can-an-atheist-be-a-fundamentalist

  • Keri Davies

    So the Catholics and the Mormons challenge the Satanic Temple’s status as a religion. Is Mormonism a religion? Can it prove itself to be one? Or is it just a collection of quaint fairy tales?

    The theoretical physicist John Barrow (Between Inner Space and Outer Space, OUP, 1999, p.88) put it simply and clearly:

    If a “religion” is defined to be a system of ideas that contains unprovable statements, then Gödel has taught us that, not only is mathematics a religion, it is the only religion that can prove itself to be one.

  • DKeane123

    If mathematics is a religion, then it has the most successful prophecy rate in the history of humankind.

  • LegalizeLezMarriage

    Sorry, I couldn’t hear anything you said. Your horse is too high up.

  • Jim Reed

    That might not be quite fair. But something kind of related, QED has been called the most perfect thing ever stringing out decimals in predictions of properties of the electron that are later verified by experiment.

  • DKeane123

    Excellent non-response and half insult. I am nothing but humble, as I realize I am nothing special in this universe. FYI – atheists are one of the biggest supporters of Lez Marriage.

  • LegalizeLezMarriage

    huh? wha? “naaaay”?

  • DKeane123
  • LegalizeLezMarriage
  • DKeane123

    That is pretty funny.

  • David B.

    A shame that these “satanists” are nothing but a bunch of film producers trying to make a buck on these issues. These guys are playing atheists like a fiddle. Read about it straight from their ex-marketing guy http://www.shanebugbee.com/?p=2454

  • process

    Actually, that’s not TST’s “ex-marketing guy”. He’s a delusional man who believes himself to be the originator of a lot of successful enterprises he has had no role in. He believes that Bill Maher’s Religiulous was stolen from his idea, because apparently Shane had gone to the Creation Museum as well. Shane also writes that the idea for the Bill Nye/Ken Hamm debate was stolen from him. The documentary Craigslist Joe was stolen from Shane because Shane traveled the country and filmed it. Shane was kicked out of the Church of Satan, and now he has a beef with the Satanic Temple, while also claiming that his ideas were stolen from him at its inception. Big surprise. He also both claims that the Satanic Temple is building a cult (without qualifying that claim), and that it’s just a film. He both says they take it too seriously, and also says that they are insincere. He says it’s all his idea, he also says it conflicts with his values. He says he did “marketing”, but doesn’t even say what that means. You say they are “making a buck on these issues”, where exactly do you think a profit is being made? Everybody in the Satanic Temple, working actively, has put almost everything they have into it, and more — but you cite Shane, of all people, to claim otherwise.

  • Nyskraa Famine Iscariot

    It’s somewhat disappointing to me that people still largely think of self-identifying Satanists as being either insincere or rebellious criminal teenagers. Perhaps if those who are inclined towards theism were involved in these sorts of things, it would be less the case (and, to our collective shame, those latter type do exist – but they’re not the majority). I have been a Satanist for many years, and while I do not espouse atheism as does The Satanic Temple, I do agree with them on a number of issues (as well, I do not discount them being sincere Satanists simply due to theological differences).

  • http://www.facebook.com/joselcosta Jose C.

    “These Satanists are Atheists….” BULLS**T – please read the section in the SATANIC BIBLE called “THE GOD YOU SAVE MAY BE YOURSELF” (Book Of Lucifer) for ANTON LaVEY’s account on DEISM, rather than ATHEISM… Religiously/Spiritually, a Satanist believes that God and the Devil are very much one and the same, or are a part of an exchange of spiritual power and authority that is represented by each deity taking the throne of spiritual authority in turn, one after the other (this is called “KATHENOTHEISM”) and so you MUST read the SATANIC RITUALS book as well for this topic as it is explained by LaVey (“THE UNKNOWN KNOWN” it is called) Moreover, look through the list of “Devils” or “Fallen Gods” that are to be found in the SATANIC BIBLE called “THE INFERNAL NAMES” or names of all the devils/fallen gods of all the world’s histories and cultures and their respective spiritual traditions… ABADDON, ASMODEUS (Judaism, Israel) AHPUCH (Mayan) BALOR, BILE (Celtic) CIMERIES (Ancient Africa) DEMOGORGON, DIABOLUS (Ancient Greece) EMMA-O (Ancient Japan) FENRIZ (Old Norse) HECATE (Ancient Greece) KALI (Hindu) MANTUS (Etruscan) NIHASA (American Indian) NIJA (Ancient Poland) PWCCA (Wales) RIMMON (Ancient Syria) SET (Ancient Egypt) SUPAY(Incan) TCHORT (Ancient Russia) TUNRIDA (Ancient Norway/Sweden) YAOTZIN (Aztec) YEN-LO WANG (Ancient China) Just to name a few in Alphabetical order ! Don’t fall for the trick and trend of Satanists actually being ATHEISTS….

  • zero

    Some Satanists are atheists – we’re not all affiliated nor do we all regard LaVey as our primary source. Just so you know…

  • Christopher

    I cannot thank the RD enough for all of these wonderful articles on the Declaration of Religious Rights by Satanists and Feminist and Humanists as the look for ways to fight back against the ruling in Hobby Lobby. Also recently on Huffington Post was a wonderful story on a movement in Red China now to reestablish the worship of Mao. In researching this religion of Mao it has become evident that the worship or religious admiration of Marx and Lenin and even Stalin is well documented. I never could have found all of this information without the RD and especially Kara Loewentheil with her interview with Sara Posner talking about “positive rights” and how their religion of positive right (aka socialism) works.

    Hardly anyone would believe me when I talked about Socialism being a religion as valid and now the documentation is just overwhelming. I don’t even need to try to prove it. I just send then all the documentation i have because of Kara and the RD.

    This line just made my skin tingle with delight: “Since the bearer of the letter sincerely, religiously believes in science, they must be allowed to follow their conscience. It’s twisted, but it’s brilliant.”

    It has become clearly obvious that the Religion of Socialism and its scions is and has been established in the United States. Thank you all who have contributed in exposing this information. I cannot thank you all enough as it will continue in assisting me in never pay tithing (taxes like income taxes and Socialist Security) into this now well known and documented religion. The legal arguments and facts you have handed to me in my quest to be free from the Religion of Socialism have been a fulfillment of my quest and beliefs about the religion of Satan…Socialism.

    I do hope you realize what this can mean concerning the establishment clause. Do you?

  • Christopher

    Thank you so much for this. More evidence that Atheism and Socialism are religions. My establishment clause violation case just keeps getting better. Thanks!

  • Christopher

    Catholics and Mormons need not prove a thing. I do hope the proof of the religion of Socialism just keeps pouring in. It is so excited. Just think of the Establishment Clause violations that can now be used against Socialist programs like the :Sacred Trust”…”Sacred Pact”…Sacred Obligation” of Social Security. It just makes me all happy inside. And these Feminists and Satanists don’t even seem to understand what they are doing to themselves. It is just SOOOO Awesome!

  • Christopher

    Thank you so much.This really helps my establishment clause RFRA defense against paying Income and Social Security taxes.

  • Christopher

    How wonderful. Thanks for the help!

  • Christopher

    How wonderful to you too. Thanks for the help! My establishment clause case just keeps getting better.

  • DKeane123

    I like you. You redefine words and assemble them into sentences that don’t make sense. I’m sure we would have a very productive discussion in this comments section.

  • DKeane123

    This comment needs more cow bell.

  • Christopher

    What words have I redefined? “Religion”? The SCOTUS did that in Seeger and Welsh. These Satanists are correct about only really needing a deeply held belief and an “ultimate reality.” Marx and Mao preached ultimate realities.

    I really am thankful for this information. What doesn’t make sense about that?

    “[E]stablishment clause violation” is quite clear I thought.

    And my RFRA case does indeed just keep getting better with all this wonder testimony.

    I am sorry if I am confusing. Maybe it’s because I have sex daily. I mean dyslexia. I had to learn to read in my twenties by hearing though my eyes.

  • zero

    Also, we’re not all USAvian…

  • DKeane123

    I know, you keep talking about your case on all the comments. I wish you luck – please keep us all up to date by posting about it over and over again.

  • PhiloKGB

    You are both right and amusingly, shortsightedly naïve. The very existence of the establishment clause presupposes a means to determine what sorts of constructs deserve the protections afforded religions. That you think you can successfully argue for the inclusion of something called “socialism” apparently without pouring grease on that slope is just precious.

  • Christopher

    I am sorry to ask but what does “USAvian” mean?

  • Christopher

    I am happy to. I changes and update every day and when people write new and wonderful things i Like to thank them personally. Is that that not polite on a thread such as this?

  • Christopher

    That is funny. I didn’t include them. The SCOTUS and Congress did in Seeger and Welsh and many others. Socialism is a civic/civil/secular religion.

    The protections afforded religion are under the free exercise clause not the establishment clause. The free exercise clause is essentially dead since the Smith ruling. The RFRA protections FAR exceed any past SCOTUS jurisprudence, at least that is what Justice Alito just ruled.

    Civic and/or secular religions are not allowed to be established. See Lee v. Weisman, 505 U.S. 577, 578, 112 S.Ct. 2649, U.S.R.I.,1992 “the government may not establish an official or civic religion as a means of avoiding the establishment of a religion with more specific creeds…”

    And School Dist. of Abington Tp., Pa. v. Schempp, 374 U.S. 203, 212, 83 S.Ct. 1560, U.S.Md. 1963. “We agree of course that the State may not establish a ‘religion of secularism’ in the sense of affirmatively opposing or showing hostility to religion, thus ‘preferring those who believe in no religion over those who do believe.’ Zorach v. Clauson, supra, 343 U.S., at 314, 72 S.Ct., at 684, 96 L.Ed. 954.”

    As civic and secular religions are not allowed to be established by the government any such action or statute would be blatantly unconstitutional and therefore could not be a compelling government interest. And please remember that the burden of proof as to whether or not there is a compelling government interest is on the government, not upon the claimant and the United States Supreme Court in Gonzales stated the claimants, not the government “must be deemed likely to prevail.”

    I have used the RFRA since 1997 AD. I have not filed or paid an income tax in over 35 years. So shortsighted really does not apply. And I also knew in 1997 AD that there would be a ruling like Hobby Lobby that gave me the real meaning and power of the RFRA and destroyed the ruling in LEE making tax law now clearly subject to RFRA (see footnote 43). Perfect for me. Just perfect.

  • zero

    A resident/citizen of the USA. In preference to the term ‘American’ which of course can refer to a resident of any of several countries. Just being ‘cute’ – to employ an americanism..
    Meaning to say that I am not involved in your battle over the establishment clause, merely an interested observer – from a country which does have an established church and a mostly atheist or religiously apathetic population.

  • Christopher

    Interesting. Thanks you for the explanation. I refuse to name myself a resident or a citizen of the U.S.

    Residents in the State where I spend most of my time are required to obtain Driver’s licenses. I want nothing to do with that. This State does not have a law on becoming a citizen so…

    I am not a U.S. citizen as I would need to be residing in Washington D.C. or a U.S. territory. So I am just an American.

  • zero

    Gosh. Such a complicated country…

  • Christopher

    Yes. A nation of sovereigns. No involuntary subjects here. Many voluntary subjects/slaves though. Most in fact. Very sad.

  • The Broker

    If you were following any of what’s been written, you’d see that this has to do with claiming exemption on the grounds that something presents a burden upon the practice of your own religious values, not that you claim an exemption on the nonsensical grounds that certain policies or practices are embraced by a religion. There is certainly overlap regarding religions and values, so it’s simply asinine to say you reject certain social policies simply because you deem them socialist. How do they conflict with your religious values? Are you a Christian? I think there is a strong argument to be made for Christ’s own socialism.

  • The Broker

    Again, this has to do with claiming exemption on the grounds that something presents a burden upon the practice of your own religious values, not that you claim an exemption on the nonsensical grounds that certain policies or practices are embraced by a religion. There is certainly overlap regarding religions and values, so it’s simply asinine to say you reject certain social policies simply because you deem them socialist. How do they conflict with your religious values? Are you a Christian? I think there is a strong argument to be made for Christ’s own socialism. But please, let us now how you pursue your “case” — or do you just intend to post about it in absolutely every comment thread while tucked see

  • JamesMMartin

    You still have it wrong. It’s the Universal Life Church, not the Life Universal Church.

  • Christopher

    If I was following it? That is funny. I read every Amicus brief for Hobby Lobby. About 100 of them. I have been working on the RFRA since 1995 AD. I have done over 120 hours of research on Hobby Lobby and the Socialist religion since June 30th 2014 AD and thousands of hours since 1996 AD.

    Listen to Sara Posner’s interview with Kara Loewentheil especially at the 33:00 mark where she says:
    “It easier for our legal system to understand a boss who says I don’t want to pay for X because that violates my religious beliefs than it is to understand an employee who says, I need my boss to pa… no I need to be able to get this thing in this in this particular way for my religious belief. So that’s kind of part of the problem. If this was like a a ban on contraceptives then that would be a different story but part of the problem is with the positive and negative rights is that technically you can get contraception somewhere else.” — Kara Loewentheil
    http://religiondispatches.org/the-real-strategy-behind-hobby-lobby-that-well-see-going-forward/

    Did you get that: “I need to be able to get this thing in this in this particular way for my religious belief,” which means OTHER PEOPLE HAVE TO PAY FOR IT aka socialism is the religion of the feminists.

    I am REQUIRED by our religious doctrines to “eschew socialism.” Our religious leaders for over 100 years have declared socialism to be the counterfeit religion of Satan and that Social Security is directly in opposition to the teachings of Christ. The Catholic Popes have said similar about Communism…Socialisms father or child depending.

    I AM NOT asking you to believe. Just telling you what our doctrine is. The Amish don’t pay Social Security taxes or take Social Security benefits either as it is against their faith.

    An Atheist in LEE v. WEISMAN, 505 U.S. 577 (1992) stopped ALL American Christians at VOLUNTARY High school graduations from Gov. schools from being able to say a prayer. They stopped Christians from forcing their beliefs on a single atheist. I AGREE. So why is the reverse not also true? What is good for one religion must be good for ALL religions.

    Why can’t I stop Socialists from practicing their religion on the same EXACT grounds? Or at least be exempted from paying Tithing/taxes to pay for your into your Communist, 2nd plank, Income Tax or Social Security Religion called a “Sacred Trust” Jimmy Carter; “Sacred Pact,” FDR; “sacred possessive rights,” Congressional Record; “sacred compact,” Bill Clinton and Al Gore; “sacred covenant,” Obama.

    “Sacred”… time and again is is called “sacred.” It is not sacred to me. It is EVIL to me.

    So what are you all helping me with?:

    “Attempting to define religion, in general and for the purposes of the Establishment Clause, is a notoriously difficult, if not impossible, task. … (“Few tasks that confront a court require more circumspection than that of determining whether a particular set of ideas constitutes a religion within the meaning of the first amendment.”).” Alvarado v. City of San Jose 94 F.3d 1223, 1227 (C.A.9 (Cal.),1996)

    These WONDERFUL articles are putting together the evidence I need so the Courts can easily define the Socialist agenda as a religious agenda. THANKS! And especially thanks to Kara Loewentheil, Mao and Trotsky and their religious followers!

  • The Broker

    All I can do is reiterate, and maybe you’ll get it through your thick skull. (More likely you’ll misappropriate a lot more citation):

    If you were following any of what’s been written, you’d see that this has to do with claiming exemption on the grounds that something presents a burden upon the practice of your own religious values, not that you claim an exemption on the nonsensical grounds that certain policies or practices are embraced by a religion. There is certainly overlap regarding religions and values, so it’s simply asinine to say you reject certain social policies simply because you deem them socialist. How do they conflict with your religious values? Are you a Christian? I think there is a strong argument to be made for Christ’s own socialism.

  • The Broker

    Anyway, let us know how you plan to pursue your claim that you don’t have to pay taxes because you feel socialism is a religion. Glad you feel you have an iron clad case. Might want to consult a lawyer though. Not certain you’ll find one who agrees…

  • Christopher

    You are SO VERY RIGHT concerning “claiming exemptions”. And if you can claim a religious exemption then you are defining your beliefs as a religion. Read Seeger. That is all I really need. AWESOME! That is VERY important to my case because in Malnak v. Yogi 592 F.2d 197, 212 (3d. Cir., 1979), Circuit Judge Adams wrote a thought provoking concurring opinion concerning what is and what is not religion:

    “A more difficult question would be presented by government propagation of doctrinaire Marxism, either in the schools or elsewhere. Under certain circumstances Marxism might be classifiable as a religion and an establishment thereof could result.”

    That is EXACTLY what I am working to ensure. “Under certain circumstances Marxism might be classifiable as a religion and an establishment thereof could result.” AWESOME!

    RUTGERS JOURNAL OF LAW & RELIGION wrote the following about some of my arguments: “The plaintiffs’ argument is compelling and could prove successful…” So my tinfoil hat impressed Rutgers and that was BEFORE the new Hobby Lobby ruling and all this new religion of Socialism stuff from RD and other sources. I have repeatedly won in our State’s Supreme Court and in district court.

    Here is more of what Rutger’s wrote:
    “The individual mandate and annual shared responsibility payment of the PPACA may fail the second prong of the Lemon test, which requires that a government action not inhibit or advance religion, if the Court construes Socialism or Marxism as falling within Seeger’s and Welsh’s broad interpretation of “religion.”… As the plaintiffs indicate, this characterization of Marxism is vulnerable to falling within the definition of religion set forth by Welsh: “any set of beliefs addressing matters of ‘ultimate concern’ occupying a ‘place parallel to that filled by God in traditionally religious persons.’” The plaintiffs’ argument is compelling and could prove successful, depending upon the court’s interpretation of “religion” and its understanding of Socialist and Marxist values.

  • Christopher

    And what you don’t seem to understand is that I agree you should get those exemptions under the RFRA. And when you do then the Courts will have admitted that Socialism is a religion and then the establishment clauses forces the government to STOP FORCING PEOPLE to pay for YOUR religion and your “sacred pact between the generations”.

    “No tax in any amount, large or small, can be levied to support any religious activities or institutions, whatever they may be called, or whatever form they may adopt to teach or practice religion.” TORCASO v. WATKINS, 367 U.S. 488 (1961)

    You are correct that there is a strong argument to be made about Christ promoting socialism. Our faith says Satan tried to counterfeit Christ’s plan with Socialism. The difference between Christ’s plan and Socialism/Marxism is that one is voluntary and the other is forced on you by the government and they TAKE. Whereas Christian charity is based on giving, not having it TAKEN by threats of imprisonment or fines.

  • The Broker

    Oh? You’ve already won then? I guess you’re exempt from paying taxes now? Funny how you cite other cases by name, but in your own alleged Court cases you mysteriously only offer some quotes. Can you properly cite one of your alleged numerous Court battles?

  • Christopher

    I need not pursue my claim. I can just wait. I have not filed or paid an income tax in over 35 years. The government current’s agrees with me so their is no case or controversy CURRENTLY. I don’t pay Social Security tax or Medicare tax etc. I don’t have an SSN. The RFRA can be used as a claim or a DEFENSE. I am preparing my case so that if my family needs it as a claim or defense we can use it. To date the government has agreed with me and even informed me in writing, signed by the District Director, that we are not required to mail or file a return. Three of my three attorneys have informed me that we are not required to file and that the RFRA protects us.

    Even Rutger’s JOURNAL OF LAW & RELIGION said my arguments were “compelling” and they didn’t get to see a tenth of my work or all this NEW WONDERFUL stuff from Kara L. and Religion Dispatches (RD).

    The lead attorney for the IRS in this District told the lawyer I was working with in a Tax Court case ( I was a consultant) that the Supreme Court was going to eventually have to decided on this issue of Socialism as a religion and what a dollar is.

    I have never found an attorney that does not agree with me after looking at my research as a whole and I have shown it to dozens during my political travels around the country.

  • Christopher

    No need. The first level is administrative. Didn’t you know that? The IRS already sent me letters saying we are not required to mail or file a 1040 return. My nephew went to court to get an exemption from Social Security and the 9th Circuit ruled it was premature because there was no case or controversy as the IRS had not yet made a determination. They did. He got the Religious exemption and no need for court.

    And if I were to cite the cases I won in this State then I would expose exactly who I am and I am not interested in totally surrendering my privacy yet. I am listed as one of the plaintiffs in article by Rutgers. If you can tell me which one I will give you some of the cases.