There were a couple of cases decided recently that we thought would be worth bringing to your attention. The first involved a question of choice of law and forum selection that originated in Ohio and transferred to the Arizona federal court. In its decision, the Arizona court invalidated a choice of law and venue provision in the franchise agreement of Zounds Hearing Franchising and went on to rule that parties could not circumvent by contract Ohio franchise law written to protect franchisees. The second case came out of Colorado where a former franchisee began operating a competing business in violation of the non-compete clause she had agreed to as part of her original franchise agreement. The court reasserted the validity of the non-compete clause in the franchise agreement for Homewatch International, Inc.