Transnational Law Blog

I Want a Certificate in Space Law, Too!

As I am coming out of finals, graduating from law school, and staring the Bar exam dead in the eye, I am fascinated by this article on Res Communis about the first law student to graduate with a specialty in space law. It should come as no surprise that I'm planning a career in transnational law but I take my hat off to anyone that is planning a career in space law-- that is just too international and out-of-this-world cool! I'll admit it, I'm jealous!

The University of Mississippi Law School is the only ABA-accredited law school in the nation with a program specializing in space law. This spring law student Michael Dodge will be the first law student in the history of U.S. jurisprudence to graduate with this unique distinction. Requirements to earn the certificate include courses on U.S. space and aviation law, international space and aviation law, and remote sensing; as well as participation in the publication of the Journal of Space Law and independent research.

Law Dean Samuel M. Davis said, "We are particularly proud to be offering these space law certificates for the first time, since ours is the only program of its kind in the U.S. and only one of two in North America."

According to the article, Dodge said his interest in space law stems from a fascination with space exploration that began when he was a young child, so when he started law school, his interest in space was based mostly on science and history.

"Once I came to the law school, I read that there was an attorney here that specialized in space law," he said. "After that, I became curious as to why space needed regulation, and how legal regimes could be constructed to govern such an expanse. After meeting Professor (Joanne) Gabrynowicz, my curiosity only grew, and ever since, I have been dedicated to researching legal issues associated with humankind’s utilization of space."

While most major law schools are just recently overhauling their programs to focus on transnational law (or what they call "international" law), Ole Miss is taking the lead on what I'm sure will prove to be a very important field of law in the very near future.

Yo Ho Ho and a Bottle of Rum

An article at IntLawGrrls entitled, The Jolly Roger Still Flies, reminds us that piracy is still a very lucrative business-- I don't mean piracy in the intellectual property sense of the word-- I mean REAL pirates! Here is a piece of the article:

...[T]oday’s pirates seem to have gone largely unmentioned in the mainstream press, despite their having taken some 3200 sailors hostage over the last 10 years, which they’ve ransomed for millions of dollars (paid by the shipowners). In fact, total worldwide losses due to commercial vessel piracy are estimated at USD 13-16 billion per year. Just a little over a week ago, for example, Somalian farmers cum pirates took control of a French luxury liner, the Ponant, in the Gulf of Aden. The passengers had been dropped off and the ship was taken after it pulled out of port, as are many ships in this Gulf, where they’d apparently have to be racing along at 200 nautical miles/hour to escape capture. The 22-member crew was hostaged for a reported $2 million, but the French military operation managed to net 6 of 13 pirates and some of the booty. The legal questions now are: where will these 6 pirates be tried and how should such cases be handled in the future? International maritime law does not provide a complete answer: a state seizing a ship from pirates is authorized to prosecute the pirates (indeed, the law of nations upon which the ATCA was built required states to prosecute alleged pirates and put them to death if convicted)...

Click here for the entire post, which gives an overview of some law pertaining to pirates.

UPDATE (4/15/08): Apparently, pirates are a popular topic of discussion currently. The FP Passport blog has an integrated satellite map that shows reported incidents of pirate attacks and hijackings off the coast of Somalia between January and November of 2007 as well as incidents in 2005 and 2006. See it here.

The U.S. Military's Contemplated Use of the Blogosphere

While I was perusing the blogosphere about a week ago, I came across a post on Opinio Juris that caught my attention entitled, US Military Thought About Recruiting-- or Hiring-- Bloggers, which discusses a 2006 report for the Joint Special Operations University that suggests using bloggers to verbally attack a specific person or promote a specific message. The Opinio Juris post cited an article from the Wired Blog's Danger Room entitled, Military Report: Secretly 'Recruit or Hire Bloggers', that republished the following paragraph from the report:

Information strategists can consider clandestinely recruiting or hiring prominent bloggers or other persons of prominence... to pass the U.S. message. In this way, the U.S. can overleap the entrenched inequalities and make use of preexisting intellectual and social capital. Sometimes numbers can be effective; hiring a block of bloggers to verbally attack a specific person or promote a specific message may be worth considering. On the other hand, such operations can have a blowback effect, as witnessed by the public reaction following revelations that the U.S. military had paid journalists to publish stories in the Iraqi press under their own names. People do not like to be deceived, and the price of being exposed is lost credibility and trust.

Other than an interesting story about Big Brother, I didn't think much of the two posts until I got an email from the Washington Post asking me to check out their new national security blog called Intel Dump. The author of the Opinio Juris post, Kevin Jon Heller, made a point of saying, "I hereby pledge that, as a blogger, I have not been recruited, purchased, or 'made' by the US military (or the mafia, for that matter)." I wonder if the author of Intel Dump, Phillip Carter, can make the same claim? Carter is an attorney in NY, working for McKenna, Long, and Aldridge, and he served on active and reserve duty for nine years in the U.S. Army as a military police and civil affairs officer. I am not saying there is any connection between Carter and the military report, but he does seem like the perfect candidate to accomplish the military's objectives as outlined in the report.

Frankly, I don't have a problem with the military recruiting or hiring or simply using bloggers to disseminate their message or attack someone in the blogosphere, and I don't care if they do it openly or in secret. The military doesn't quite understand the blogosphere. The report asks more than once, "How could (to paraphrase CBS’ Klein) 'some guys in pajamas writing at home' succeed in influencing not just the careers of prominent journalists, producers and media executives, but also potentially the course of an entire election or public opinion about a war?" What is unique about the blogosphere is not the infinite amount of information but the dialogue that occurs between different blogs and between bloggers and their readers. The military report argues that if the blogger and his blog were prominent enough, then the information posted on it would influence the rest of the blogosphere.

As previously observed, blog influence can be affected by the structure of the blogosphere, in particular, the network of hyperlinks connecting one blog to another. To illustrate, imagine starting at any random blog. By following a series of links from one blog to another, one is likely to hit one of the top blogs within a few hops. Moreover, information on that top blog may have propagated out to some of the blogs that linked to it, and so on from there, perhaps even reaching the blog from whence one started. Thus, even if one is not initially aware of a particular blog, one may end up there or being exposed to information posted on it. Overall, one is more likely to encounter a well-connected blog, or information posted on it, than one that is not.

Just because a blog links to a post does not necessarily mean that the blogger agrees with it. The writer of a blog (speaking from experience) links to posts he has an opinion about and he links to it because he wants to share his opinion about it. Often times, the opinion shared is contrary to the opinion in the original post. Plus, the readers of blogs does not take what they read at face value, and they generally formulate their own opinions by comparing the different opinions of several bloggers.

The users of blogs are not stuck with the editorial agenda of their local newspaper's publisher. Unlike the paper version of the Washington Post, a reader of blogs can freely move from one source of information to the next, comparing the information and filtering out absurdities. The information can be tested by reading other blogs or by questioning the blogger. This is the real threat to any sort of hegemonic information system. Even if the military inserted clandestine bloggers to disseminate their "message", it would not automatically be accepted as truth because it would be subject to the criticism and judgment of the entire blogosphere. This is why I invite the military to join in the discussion! The more people involved, the better the discussion is going to be-- even if someone is just trying to add misinformation.

It should also be noted that the report doesn't really state whether the military plans to hire bloggers to disseminate their message in the USA or in other countries. However, after a closer read, it appears the military is considering using bloggers in other countries.

Just as during World War II, the military recruited the top Hollywood directors and studios to produce films about the war (in effect conducting domestic influence campaigns in the name of maintaining the national morale and support for the war effort), waging the war against terrorism and its underlying causes, as spelled out in the National Security Strategy, may require recruiting the prominent among the digirati (probably those native to the target region) to help in any Web-based campaign. The importance of credibility and reputation to blog influence must be taken into account when considering using a blog as a vehicle for information operations. This is especially critical given the apparent poor image and reputation of the U.S. government in countries we want to influence.

But what is said by a blogger in one country, can quickly become the subject matter of a blog in another country. The media has been relying on bloggers in Tibet to get information about the unrest there, and a blogger secretly working for the US government could potentially provide false data that would then be disseminated throughout the blogosphere here in the US. However, I still believe the blogosphere and the average blog reader would be able to deal with that kind of information and weigh its legitimacy by comparing it to other sources of information.

The study also had a very interesting analysis of the blogosphere and bloggers, which is worth a read. I particularly liked the section summarizing who most bloggers are:

Nearly 75 percent of Americans use the Internet regularly, and those who use it most regularly tend to be young, male, have some degree of college education and generally are in or from the middle to upper-middle income brackets. These are the people who tend to be the most politically active, as well. Blog creators follow this trend, being generally young, affluent, educated males with broadband access and at least six years’ experience online.

Wow! That pretty much sums me up!

No Holiday After Fidel

Foreign Policy Passport Blog has a good list of articles discussing Fidel Castro's stepping down in a post called After Fidel.  An interesting post at the Disinformation Blog (a Myspace blog) entitled, Farewell Fidel! But We Forgot Our Detainees at Guantanamo Bay, reminds us that the ever controversial Cuba is also home to the infamous Navy base.  The post features an excerpt from Martin Cohen's new travel book No Holiday: 80 Places You Don't Want To Visit, which I've taken the liberty of republishing below:

NO HOLIDAY 32: Guantánamo Bay, Cuba

The most famous of all the Cuban bays

How to get there

For years and years you used to be able to just wander in and out of the US Navy Camp on the South Eastern tip of Cuba. But that all changed after the Revolution. Nowadays Americans are not even allowed to visit any part of the island—at the risk of a $10,000 fine. Those who really want to see Cuba have to employ a "roundabout route" (like maybe fly to Pakistan and join the Taliban). But for non-Americans, the easiest way to see Camp Delta is still to go to Havana and then down to Guantánamo Town, notable for its French-style architecture. There, for a couple of US dollars, they can hire a driver for the day, and be driven up a steep rough road to the Loma Malones observation point. This is a little rock shelter under a canopy, complete with a tourist-standard public telescope.

What to see

And from the little observation refuge, it should be possible to see far below, set amongst one of the wildest and least hospitable landscapes of Cuba, a kind of Wild West fort, complete with wooden stockades and watchtowers flying the Stars and Stripes. If you're lucky, through the telescope you may also see US soldiers frog-marching prisoners, clad in their famous orangey-red jump-suits, from their cells to the interrogation rooms.

The land surrounding the bay is dry and baked by the sun, and there is a fringe of cacti to the northwest, a relic of Fidel Castro's attempts, in the early 1960s, to discourage Cubans from fleeing to capitalism. The inhabitants of the base call this the Cactus Curtain, a sly reference to the more famous Iron one. Their idea was that on one side there were people living in perpetual fear and misery, whilst on the other was a world of freedom: singing, drinking and laughter in the bright sunshine. (Only it is not clear if they appreciated then which side of the curtain they were living on.)

One American student at the lookout, who had sneaked into the country by her own roundabout route, gives the flavor. "It looks so boring," she complains, "just like Los Alamos."

Boring, yes. But "Guantánamo has become an icon of lawlessness... dangerous to us all," as Amnesty International said in a statement marking the third year of Guantánomo's new role as a concentration camp and torture center. For that reason alone, it is well worth stopping off, if you're in Cuba, for a look.

The Death of Guanxi

I was recently ranting to Steve Dickinson that people who think guanxi is the key to doing business in China don't understand China's legal system and are probably functioning with the misconception that China's legal system is unreliable. He didn't state whether he agrees with me or not, he simply said guanxi is dead, and pointed me in the direction of an article he recently wrote for China International Business entitled, Debunking the Guanxi Myth. Check it out, it's worth the time, and I've taken the liberty of republishing the four basic points Dickinson argues to bust the myth of guanxi.

1. No foreigner can recreate a Chinese-style guanxi network. In China, guanxi refers to a vast network of connections arising from party, family and work connections that may go back several generations. No guanxi network relies on a single individual. The elimination of one member of the network is therefore not fatal. Foreigners almost always rely on only one or two individuals for their supposed connection. This kind of network is too fragile to be of enduring value. Foreign investors who think they have created a guanxi network in China are usually simply deluding themselves.
2. Connections with local government officials are short-term and can be abruptly terminated. Many foreign investors do not realize that government officials in China are regularly moved from office to office and from region to region. As a result, the connection with a local official is unlikely to be a long-term connection. It is quite common to negotiate a project for several years and then learn that the official in charge has been transferred to a new post. Where the project is not in compliance with the law, their replacements will often refuse to sign the documents that have already been negotiated.
3. The Chinese provider of guanxi may suddenly disappear. If the project depends on the protection of a single individual, what will happen if that person dies, is demoted, or prosecuted for corruption? This change in fortune can be a particular disaster where the foreign investor has already contributed funds, because the project can be cancelled with no refund on the investment.
4. A project based on guanxi gives too much power to the Chinese side of the deal. In many cases, the provider of guanxi will make use of the fact that the project is not in compliance with the law to ask for additional benefits. Since the foreign side has no legal recourse, the foreign side must accede to what is in effect a blackmail request or risk the collapse of the project. When the foreign investor comes to a lawyer for help, there is nothing that can be done, since the project itself is either illegal or poorly documented.

In my opinion, "guanxi" refers to the period of time in China from 1980 to 2000 as depicted by books like Mr. China, which essentially advise finding Chinese solutions to Chinese problems. The period in China when the only way to protect your interests was through political connections and bribery is rapidly giving way to a reliable legal system. It's now better to have a good contract than a seemingly powerful friend.

Tangential to this subject is a post by Dickinson's partner Dan Harris over at the China Law Blog called, Chinese Cultural Awareness Simplified: Don't Be an Asshole. Harris argues that "knowledge of Chinese culture is secondary to knowledge of business when it comes to doing a China deal" and that point is very similar to the point argued in this post that guanxi is secondary to knowing and complying with the law.

Recommended Reading: Experience Not Logic

The Experience Not Logic blog is informative and a pleasure to read.  The blog is primarily devoted to discussing legal and cultural issues concerning China.  Its name is derived from an 1881 Oliver Wendell Holmes, Jr., quote, in which he said, "The life of the law has not been logic; it has been experience."  About that quote, the blog's author, Will Lewis, wrote, "Each time I read a US court decision, Holmes' quote flashes through my mind.  In China, the rule is the same, but the experience is different. Here's to broadening the experience..."

Experience Not Logic features a variety of posts, discussing a broad range of issues from patent reform in the US to model arbitration clauses.  The posts are well-researched and Lewis writes with a hint of amused sarcasm reminiscent of Hunter S. Thompson, making his posts on fairly boring legal stuff actually readable and surprisingly fun.  Some of the opening lines from a post on corporate social responsibility are a perfect example:

Critics of capitalism have long clung to the idea that the inherent competition leads to conflict, and conflict in capitalism reinforces the unfortunate Hobbesean conclusion that man's life is "solitary, poor, nasty, brutish, and short." And then CSR, the classic liberal's wet dream, comes and spoils the party by showing the world that soaring profits can go hand in hand with doing good.

We really appreciate the fact that Mr. Lewis is a law student-- he is a 2L at the University of San Diego-- and he is publishing an excellent blog. Keep up the good work! We'll be reading!

Invisible College: New Blog Focusing on Transnational Law and Issues

A new blog was launched today, Invisible College. Much like TLB, Invisible College notes that it is dedicated to discussing transnational legal issues as well as anything else that affects the international arena. Its authors are students and recent grads in law, economics and journalism, and seem to hail primarily from Canada and Europe.

This new forum looks to be very interesting. Welcome to the Blogosphere!

A Look At The Coming Outer Space War With China

The Wired Blogs recently published a series of posts entitled, How China Loses The Coming Space War, which are written by MIT researcher Geoffrey Forden, Ph.D., examining the possibility of an all-out Chinese assault on American satellites (h/t Wendy Jackson). A year ago China performed a successful anti-satellite test, shooting down one of its own obsolete weather satellites, putting into overdrive widespread speculation about a possible outer space war with China. In a previous post we joined in this speculation, discussing the new space race and China's use of anti-technology technology as a means to defeat the USA in an armed conflict. Forden obviously believes that the USA would ultimately win an outer space contest with China. His arguments are quite compelling and worth reading in their entirety.

In Part One of the series, Forden opens up with a fictional account of how China's space war against the US could begin:

High above Asia, as the bars and clubs of Beijing begin to fill up at the end of another work day, a US early warning satellite spots the tell-tale plume of a missile streaking out of the wastes of Western China.  Warning bells sound all through the Pentagon. Tensions have been running high between China and the United States, as the two countries struggle to resolve the latest installment of the Taiwanese crisis.  And China has had a run of unprecedented activity in space: the past two days have seen China launch four large missions into deep space, three within the last six hours.. Fortunately, a high-resolution American spy satellite will be over that second launch site within minutes, giving the US a unique ability to determine what is going on.  But even though tasking orders are given to photograph the suspected launch site, none are returned.  The satellite, code-named Crystal 3, no longer responds to commands.  Within minutes, US Space Command reports that four NAVSTAR/GPS satellites—used to guide American drones and precision bombs—have stopped broadcasting.  China’s space war against the United States has started.

Forden then gives a brief summary of his research and overall conclusion, which is that the fear of a single strike that could cripple America's satellite network--an outer space Pearl Harbor-- is unrealistic. The rest of Part One is devoted to analyzing China's successful anti-satellite test. Through a process of backtracking, scientists have reconstructed the collision of the missile and the satellite.

"By backtracking the debris to the point where they all converge, we can determine the two most important aspects of the Chinese ASAT: how China destroyed that satellite, and just how capable its satellite-killer really is." Based on the information gathered from backtracking, Forden concludes that the Chinese have accomplished a phenomenal feat. According to him, China "accomplished the most sophisticated of space maneuvers: a hit-to-kill interception, the equivalent of hitting a bullet with a bullet."

In Part Two, Forden argues that China does not have the ability to launch enough anti-satellite missiles to cripple the US armed forces. "The United States may be the country most dependent on space for its military activities.  But it is also the least vulnerable, because of the tremendous redundancy of its space assets." He analyzes whether China could destroy deep-space navigation satellites, early warning satellites, communications satellites, and low altitude satellites, and he concludes that China just couldn't do enough damage to render the USA forces impotent. The sheer number of American military and civilian satellites is simply far more than the number of anti-satellite missiles China has at its disposal.

The most interesting aspect of Part Three is Forden's plea for countries to avoid space warfare. He points out that the destruction of any satellite in outer space will create debris fields that will continue to orbit the Earth, eventually damaging or destroying other satellites.

These debris fields could easily cause a run-away chain of collisions that renders space unusable -- for thousands of years, and for everyone.  Not only is this a quickly growing and important sector of the world’s economy (sales of GPS receivers alone reportedly exceeds $20 billion annually), but space is also used for humanitarian missions such as forecasting floods in Bangladesh or droughts in Africa.  We cannot allow space to be forever barred to our use for what turns out to be a very minor military advantage.  If the military utility of attacks in space are so minor; if the active defense of space assets is impractical, counterproductive, and unnecessary; and if the danger resulting from the consequent debris affects all space-faring nations for thousands of years to come, it is clear that diplomacy is in every country's interest.

The first step the United States should take is a simple declaration that we guarantee the continued flow of information to any country whose satellite is destroyed by an ASAT.  We could do this using either our military or civilian-owned satellites. After all, if the space assets of the United States are not vulnerable to attacks because of the inherent redundancy, the same cannot be said of China’s other potential regional competitors such as Australia, India, or Japan. Each of these countries has only a handful of satellites that could be quickly destroyed if China chooses to attack them.  This declaration would effectively eliminate any military advantage that a country might get from attacking its neighbors limited fleet of satellites.  After that, we should adopt the code of conduct that is being developed by the Stimson Center that establishes “rules of the road” for responsible space-faring nations.  Finally, we should work toward a treaty banning the future testing of these most dangerous of anti-satellite weapons: the so-called "kinetic kill interceptors" that create such large amounts of debris.  It'd be a first step towards containing the worst effects on war in space.

Forden's series of posts consider the worst possible scenarios and conclude that the American armed forces would still be effective. "And much like Japan’s failure to destroy the US carrier fleet, a Chinese attack on US satellites would fail to cripple our military, China’s strategic goal in launching a space war." However, Forden does not discuss the possible consequences of China synchronously launching a cyber attack on the US. It seems like that would make a significant difference in his analysis. Either way, his analysis of the space war situation is fascinating and certainly worth reading.

Transnational Commercial Disputes In The USA Ain't Easy

A post on China Law Blog entitled, Who Needs International/Foreign Law? Not Us, We're Americans, raises a number of transnational law issues and is well worth a read. Dan Harris, the author of the post, questions whether or not US courts have an obligation to abide by international treaties and whether they abide by that obligation, and he uses the Hague Convention Rules on International Service of Process as an example. I encourage you to read the entire article but here is a portion of it:

For at least the third time (two times is coincidence, three times is a trend), a US court has allowed a case to go forward against a defendant despite plaintiff's having clearly failed to abide by the Hague Convention Rules on international service of process. The most recent instance is in a still pending case so I cannot go into the specifics on that one.

Virtually every time we have sought to get the US courts to enforce the Hague Convention or even, in one instance, when we sought to get a US court to pretty much ignore the Hague Convention, the US court has seemed perfectly willing to rule as though the United States has no obligation to abide by a treaty it signed. I have a strong sense US Courts (both state courts and federal courts) will not enforce the Hague Convention's technical service requirements (including that the summons and complaint must usually be translated into the language of the country in which it is being served). Oh, and getting a US court to throw out or stay (delay) a case so that an already pending case in another country can be decided first -- forget it. My conclusion is that US courts are happy to ignore foreign/international law in favor of handling things under US law, whether US law should apply or not.

US court judgments usually are not enforceable outside the United States and one of the reasons given for this is the failure of American courts to recognize foreign law. My foreign clients (these are international businesspeople, not in any way anti-American) are complaining to me more and more about US courts and how "they think they can ignore the rest of the world." One particularly piqued client (from a country very friendly to the United States) pointedly told me this is one of the reasons why America is becoming more and more hated and why we are losing our power. He insisted that the courts in his country would have ruled differently on the same issue and I think he is correct.

If the United States is serious about globalization, it is time our courts start recognizing that ours is not the only law in the world and that it actually behooves US business to make our courts more international in the context of business disputes.

The comments that follow the post also address some interesting transnational law issues. One in particular, a comment posted by a person named Twofish, addresses the constitutional issue of whether the Hague Convention is a self-executing treaty or a non-self-executing treaty. A self-executing treaty becomes federal law (and therefore preempts state law) as soon as it is signed. A non-self-executing treaty requires Congress to pass additional laws implementing the terms of the treaty once it has been signed, which means the terms of the treaty are not federal law until Congress has made them federal law.

Whether or not a treaty is self-executing is a very important question when determining whether state law preempts the terms of a treaty. A good example of a self-executing treaty is the CISG. As we mentioned in a previous post, it is considered a self-executing treaty because of the specificity of its language; because of its apparent purpose to create rules that would bind individuals; and because of the apparent views of the political branches that no further action is necessary. As a self-executing treaty, the CISG preempts inconsistent state law under the Supremacy Clause.

Dan Harris of China Law Blog also touches upon the enforceability of foreign judgments in the USA. The enforceability of foreign judgments is determined by state law because the USA is not a party to any treaty. Although the USA has not adopted it, many states have adopted the Uniform Money Judgment Enforcement Act. This Act requires the enforcement of foreign money judgments but allows for a number of exceptions, including lack of notice; lack of subject matter or personal jurisdiction; the foreign court procedures are not compatible with due process; enforcement would violate public policy; or there is a conflict with another final judgment. Many other countries, particularly civil law countries, also require reciprocity.

I am curious as to why Dan Harris does not talk about international arbitration? He has had some very interesting posts about arbitration in the past (see here for example), but he does not discuss it as an alternative in this context. Arbitral awards are enforceable under the New York Convention while the enforceability of court judgments (at least when the US is involved) turns only on local law. His post is discussing these matters in the context of China, which is a party to the New York Convention. China also has its own arbitration body, the China International Economic and Trade Arbitration Commission (CIETAC), which was established to settle international commercial disputes. I would be very interested to know what Dan Harris thinks of CIETAC and arbitration in general as an alternative to a judicial forum.

And the matter is also open to other bloggers and blog readers: Arbitrate or litigate in a traditional judicial forum? Do you tell your clients to put in an arbitration clause? Is it truly easier to enforce an award from arbitration than a court judgment? This inquiring mind wants to know!

The Traveler IQ Challenge

TravelPod's Traveler IQ Challenge is a very fun and addictive way to learn and test your knowledge of geography. It has been making the rounds on Facebook, but now you can access it directly online. FP Passport gave it the following description:

The site presents a blank world map with country borders, and asks you to click as closely as you can to various cities and famous locations. There are 12 rounds, starting with easy world cities (think London and Paris) and getting progressively harder (think Niamey, Niger and Honiara, Solomon Islands). You're only allowed to pass on to the next level after you've passed each round. It's incredibly addictive, because you can take the test as many times as you want, and the program will generate different locations each time you take it. It also gets really, really difficult.

I understand getting to the 12th round is rather difficult. If you make it, perhaps the holiday spirit will encourage you to share your game strategy.