Today we'll do a simple run through of a valuation method used to estimate the attractiveness of Cheniere Energy, Inc...

The American economy plunged deeper into crisis last month, losing 20.5 million jobs as the unemployment rate jumped to 14.7%, the worst devastation since the Great Depression.The Labor Department's monthly report Friday provided the clearest picture yet of the breadth and depth of the economic damage -- and how swiftly it spread -- as the coronavirus pandemic swept the country.Job losses have encompassed the entire economy, affecting every major industry. Areas like leisure and hospitality had the biggest losses in April, but even health care shed more than 1 million jobs. Low-wage workers, including many women and members of racial and ethnic minorities, have been hit especially hard."It's literally off the charts," said Michelle Meyer, head of U.S. economics at Bank of America. "What would typically take months or quarters to play out in a recession happened in a matter of weeks this time."From almost any vantage point, it was a bleak report. The share of the adult population with a job, at 51.3%, was the lowest on record. Nearly 11 million people reported working part time because they couldn't find full-time work, up from about 4 million before the pandemic.If anything, the numbers probably understate the economic distress.Millions more Americans have filed unemployment claims since the data was collected in mid-April. What's more, because of issues with the way workers are classified, the Labor Department said the actual unemployment rate last month might have been closer to 20%.It remains possible that the recovery, too, will be swift, and that as the pandemic retreats, businesses that were fundamentally healthy before the virus will reopen, rehire and return more or less to normal. The one bright spot in Friday's report was that nearly 80% of the unemployed said they had been temporarily laid off and expected to return to their jobs in the coming months.President Donald Trump endorsed this view in an interview Friday morning on Fox News. "Those jobs will all be back, and they'll be back very soon," Trump said, "and next year we're going to have a phenomenal year."But Diane Swonk, chief economist at Grant Thornton, said that such optimism was misplaced, and that many of the jobs could not be recovered."This is going to be a hard reality," Swonk said. "These furloughs are permanent, not temporary."Many businesses have indicated that employees can work from home throughout the summer, hurting sales at downtown restaurants. Meetings and conferences have been put off as well, reducing demand at hotels and other gathering places. And the longer the pandemic lasts, the more businesses will fail, deepening the downturn.The broad nature of the job cuts, too, means it will take longer for the labor market to recover than if the losses were confined to one or two areas."There is no safe place in the labor market right now," said Martha Gimbel, an economist and labor market expert at Schmidt Futures, a philanthropic initiative. "Once people are unemployed, once they've lost their jobs, once their spending has been sucked out of the economy, it takes so long to come back from that."Carrie Hines, a managing director at an advertising firm in Austin, Texas, had the kind of professional job -- adaptable to working from home -- that seemed insulated from the pandemic's effects. But her firm worked closely with companies in the airline, hotel and amusement park industries. When their business evaporated as a result of the outbreak, it was only a matter of time before Hines' firm felt the impact. She was laid off April 20."I was shocked," she said. "I've never had a gap in work since college."Hines and her husband are cutting back where they can, and they have canceled plans to send their three children to summer camp. "I never imagined this kind of job market where the entire advertising industry has been crushed," she said.The scale of the job losses last month alone far exceed the 8.7 million lost in the last recession, when unemployment peaked at 10% in October 2009."I thought the Great Recession was once in a lifetime, but this is much worse," said Beth Ann Bovino, chief U.S. economist at S&P Global.The only comparable period is when unemployment reached about 25% in 1933, before the government began publishing official statistics. Then, as now, workers from a variety of backgrounds found themselves with few prospects for quickly landing a new job.The government's official definition of unemployment typically requires people to be actively looking for work, making the measure ill-suited to a crisis in which the government is encouraging people to stay home. Some 6.4 million people left the labor force entirely in April, meaning they were neither working nor looking for work.Joblessness -- by any measure -- could be even higher in the report for May, which will reflect conditions next week. Some economists say the unemployment rate should fall over the summer as people begin to return to work. Several states have begun to reopen their economies, and others are expected to do so in coming weeks.But with the virus untamed, it's not clear how quickly customers will return to businesses. And epidemiologists and economists warn that if states move too quickly, they could risk a second wave of infections, imperiling public health and the economy."That would stop people from shopping and cause austerity," Bovino said.For businesses, the uncertainty about the path of the pandemic and about consumers' response to it is making planning difficult.When Austin Ramirez heard about the coronavirus earlier this year, his initial concern was for his supply chain. Ramirez runs Husco International, a manufacturer of hydraulic and electromechanical components for cars and other equipment. The company has a factory in China and receives parts from suppliers there and around the world.By April, virtually the entire U.S. auto industry was shut down, Husco included. (The company's nonautomotive production continued at a reduced rate.) Ramirez said he didn't know when business would bounce back. His goal is to weather the storm."There's no visibility or certainty on what the future demand is going to look like," he said. "We can't build a business model that relies on there being a big recovery six months from now."While most of Husco's roughly 750 North American workers have been furloughed during the crisis, the company has mostly avoided large-scale, permanent job cuts. Ramirez said he expected that most of his workers would come back when he needs them.But particularly in industries like retail and hospitality, layoffs that were initially temporary might not remain so as bankruptcies mount and business owners confront shifts in consumer behavior.Most forecasters expect the unemployment rate to remain elevated at least through 2021, and probably longer. That means that it will be years before workers enjoy the bargaining power that was beginning to bring them faster wage gains and better benefits before the crisis.This article originally appeared in The New York Times.(C) 2020 The New York Times Company

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An independent review last year found that Dr. Richard Strauss had abused at least 177 male students during his tenure at Ohio State University.

(California Court of Appeal) - Reversed a judgment of non-paternity. Held that the family court should have ordered genetic testing to determine whether a man was the father of a child born to another man's wife.

(California Court of Appeal) - Held that a father was not entitled to an adjustment in the child support arrears that accrued during his incarceration in federal prison. Vacated the decision below and remanded for further proceedings in this family court matter.

(United States Ninth Circuit) - In a 42 U.S.C. Section 1983 dispute involving the standing of a tax exempt claimant to intervene in a challenge to an unrelated action on the constitutionality of claimed exemptions, IRC sections 107 and 265(a)(6), judgment of the district court denying intervention is affirmed in part and vacated in part because motion to intervene as a matter of right is thwarted by the presumption of adequate representation, where the district court erred in apply an incorrect rule on the issue of permissive intervention.

(United States First Circuit) - In a joint appeal from a judgment of the district court arising from the criminal prosecution of defendants for tax evasion and related charges and involving allegations of defendants' use of charitable donations to finance an Islamic jihadist group, convictions and sentencing are reversed with respect to the court's overturn of the jury's conviction on the conspiracy counts, and affirmed with respect to all other convictions.

(United States Fourth Circuit) - District Court affirmance of bankruptcy court order confirming Chapter 11 reorganization plan of nonprofit public charity is vacated and case remanded where: 1) bankruptcy court did not make specific factual findings explaining why it approved and included certain release, injunction, and exculpation provisions applicable to nondebtors; and 2) appeal was not equitably moot.

(Court of Appeals of New York) - In an appeal from a judgment of the appellate division affirming the dismissal of plaintiff's action to enjoin demolition of a church building, judgment is affirmed because Section 5 of the Religious Corporations Law vests approval authority for all actions taken by the trustees of an incorporated Catholic church in the archbishop or bishop of the diocese to which that church belongs, and therefore does not require that the demolition of the church be authorized by the parishioners.

(Court of Appeals of New York) - In a tax-exempt charitable organization's action against a school district seeking to recoup erroneously paid taxes, summary judgment in favor of the school district is affirmed, where: 1) the school district was entitled to rely on the one-year statute of limitations in Education Law section 3813(2-b) rather than the general six-year period for contract actions; and 2) the taxpayer's cause of action for money had and received accrued when it paid the taxes, which was more than one year before it filed suit.

(United States Ninth Circuit) - In a challenge to federal statutory restrictions on certain types of advertising by public broadcast TV stations, the district court's grant of summary judgment to the FCC is: 1) affirmed in part, where 47 U.S.C. section 399b(a)(1), restricting paid advertisements for goods and services on behalf of for-profit corporations, was not an unconstitutional speech restriction under the intermediate scrutiny standard; 2) reversed in part, where sections 399b(a)(2) and (3), restricting public-issue advertisements and political advertisements, were unconstitutional speech restrictions under intermediate scrutiny, as there was no evidence of harm to a substantial governmental interest.

(United States Ninth Circuit) - In a religious organization's suit against a subdivision of a national anarchist group under the federal Freedom of Access to Clinic Entrances Act and common law trespass, district court's sanction order granting attorneys' fees and costs to non-parties, which followed the quashing of a subpoena seeking identifying information for seven e-mail account holders, is reversed where Rule 45(c)(1) cannot properly support a sanction where the cost of complying with the subpoena is minimal and there is no showing that the subpoena was facially defective or issued in bad faith.

(California Court of Appeal) - Judgment quieting title of disputed property to plaintiff is affirmed, where: 1) defendant nonprofit religious organization's status as a "public benefit corporation" does not make it a "public entity" immune from adverse possession under Civil Code section 1007; 2) a nonprofit religious organization's "welfare exemption" from property taxes means that no such taxes were "levied and assessed" on the property during the years it qualified for the exemption; and thus, 3) under the plain and binding language of Code of Civil Procedure Code section 325, the adverse possessor is consequently excused from the usual requirement that he pay taxes on the disputed land for five years.

(Court of Appeals of New York) - In this case, petitioner, a not-for-profit theater corporation, filed applications for real property tax exemptions with respondent assessor and was denied. Petitioner then commenced this RPTL article 7 proceeding for review of its tax assessments. Order of the Appellate Division granting the petition is affirmed, where: 1) the statute does not elevate one exempt purpose over another, and under the circumstances, the use of property to provide staff housing is reasonable incidental to petitioner's primary purpose of encouraging appreciation of the arts through theater; and 2) petitioner has demonstrated that it is entitled to an RPTL 420-a tax exemption.

(California Court of Appeal) - In a dispute between two factions of a church over control of church property, the trial court's judgment is affirmed over meritless claims that it erred: 1) when it found in favor of respondents based on appellants' excommunication from the Holy Hill Community Church (Church) by the Western California Presbytery (WCP); 2) by admitting evidence of events occurring after the cross-complaint was filed; and 3) when it prevented appellants' counsel from cross-examining a representative of the WCP whose testimony was sought by respondents.

(United States Ninth Circuit) - In an action brought by two nonprofit organizations challenging the California Attorney General's collection of IRS Form 990 Schedule B forms, containing identifying information for their major donors, under California's Supervision of Trustees and Fundraisers for Charitable Purposes Act, Cal. Gov't Code section 12584, the district court's preliminary injunction for plaintiffs is modified to prohibit making the information public but permit defendant to keep collecting the data for enforcement

(California Court of Appeal) - In a property tax refund action based on the welfare exemption set forth in Revenue and Taxation Code section 214, the trial court's judgment in favor of plaintiff is affirmed where: 1) the State Board of Equalization's (SBE) interpretation of section 214 was clearly erroneous; 2) the SBE's advisory rule regarding who must file a welfare exemption is not binding and therefore should not be given independent legal effect; and 3) the County failed to establish that the trial court should have denied a tax refund because plaintiff's claims were tardy and its claim forms were incomplete.

(California Court of Appeal) - In a case concerning the ownership of property that belonged to the Dioceses before the disaffiliation of a majority of members from the Episcopal Church in the U.S., the trial court's judgment in favor of plaintiffs is affirmed where, although the trial court made certain errors, applying neutral principles of law, the property belongs to plaintiffs.

(California Court of Appeal) - In a case to decide whether the City and County of San Francisco can compel state universities that operate parking lots in the city to collect city taxes from parking users and remit them to San Francisco, the trial court's denial of the City's petition for writ of mandate is affirmed where the California Constitution's 'home-rule provision' -- which grants charter cities broad powers, including the power to tax -- does not create an exception to the long-recognized doctrine that exempts state entities from local regulation when they are performing governmental functions.

(United States Ninth Circuit) - Upheld the constitutionality of California's requirement that charitable organizations must disclose the names and addresses of certain large contributors. Two nonprofit organizations contended that the disclosure requirement infringed their First Amendment right to free association. Disagreeing, the Ninth Circuit concluded that the disclosure requirement survived exacting constitutional scrutiny because it was substantially related to an important state interest in policing charitable fraud. The panel reversed and remanded for entry of judgment in the state's favor.

(California Court of Appeal) - Affirmed the denial of a Roman Catholic Diocese's petition to remove an individual from her position as trustee of an individual's trust and for damages. Held that the trial court did not abuse its discretion in excusing the trustee from liability for actions she took reasonably and in good faith.

(California Court of Appeal) - Held that a board member of a nonprofit corporation was not entitled to a preliminary injunction barring her from being removed from the board. Reversed a preliminary injunction, in this case involving a nonprofit that operates public radio stations.

(United States Second Circuit) - In a copyright infringement action brought by record companies and music publishers against internet music services that allowed users to search for free music, dealing with the requirement of the Digital Millennium Copyright Act (DMCA) safe harbor that an internet service provider adopt and reasonably implement a policy to terminate repeat infringers, under 17 U.S.C. section 512, the District Court's grant of partial summary judgment in favor of defendants and decision overturning a jury verdict in favor of plaintiffs is: 1) vacated as to partial summary judgment to the defendants based on the conclusion that defendant qualified for safe harbor protection under the DMCA because the District Court applied too narrow a definition of 'repeat infringer'; 2) reversed as to judgment as a matter of law to the defendants on claims that defendant permitted infringement of plaintiffs' copyrights in pre‐2007 MP3s and Beatles songs because there was sufficient evidence to allow a reasonable jury to conclude that defendant had red‐flag knowledge of, or was willfully blind to, infringing activity involving those categories of protected material; 3) remanded for further proceedings related to claims arising out of the District Court’s grant of partial summary judgment; and 4) affirmed in all other respects.

(California Court of Appeal) - In a former on-air radio personality's action for disability discrimination, wrongful termination and related employment claims, the trial court's grant of summary judgment to employer-defendant is reversed where material issues of fact exist regarding each of plaintiff's claims.

(United States Second Circuit) - In an amended opinion involving a copyright infringement action brought by record companies and music publishers against internet music services that allowed users to search for free music, dealing with the requirement of the Digital Millennium Copyright Act (DMCA) safe harbor that an internet service provider adopt and reasonably implement a policy to terminate repeat infringers, under 17 U.S.C. section 512, the District Court's grant of partial summary judgment in favor of defendants and decision overturning a jury verdict in favor of plaintiffs is: 1) vacated as to partial summary judgment to the defendants based on the conclusion that defendant qualified for safe harbor protection under the DMCA because the District Court applied too narrow a definition of 'repeat infringer'; 2) reversed as to judgment as a matter of law to the defendants on claims that defendant permitted infringement of plaintiffs' copyrights in pre‐2007 MP3s and Beatles songs because there was sufficient evidence to allow a reasonable jury to conclude that defendant had red‐flag knowledge of, or was willfully blind to, infringing activity involving those categories of protected material; 3) remanded for further proceedings related to claims arising out of the District Court’s grant of partial summary judgment; and 4) affirmed in all other respects.

(United States Ninth Circuit) - In a suit for trademark infringement and unfair competition brought under the Lanham Act by a producer of karaoke music tracks, alleging that the defendants performed karaoke shows using unauthorized 'media-shifted' files that had been copied onto computer hard drives from the compact discs released by the plaintiff, the district court's dismissal is affirmed where plaintiff did not state a claim under the Lanham Act because there was no likelihood of consumer confusion about the origin of a good properly cognizable in a claim of trademark infringement.

(United States Ninth Circuit) - In the appeal of a breach of contract and copyright infringement case involving the movie 'The Purge,' the district court's denial of defendant's anti-SLAPP motion to strike a state law claim for breach of implied-in-fact contract, is affirmed where the breach of contract claim did not arise from an act in furtherance of the right of free speech since the claim was based on defendants' failure to pay for the plaintiff's idea, not the creation, production, distribution, or content of the films.

(United States Second Circuit) - Affirming the dismissal for failure to state a claim allegations of First Amendment violations by the City of New York, but reversing as to Manhattan Community Access Corporation and its employees because public access TV channels are a public forum and the corporation and its employees were state actors when they fired workers who produced segments critical of the corporation.

(United States Fourth Circuit) - Affirming the district court's rejection of First Amendment violation claims brought by an exotic dancing venue complaining that a city regulates sexually oriented businesses differently than it does mainstream performances such as ballets and concerts, that the law violates the Equal Protection Clause of the Fourteenth Amendment by barring 18 to 21 year olds from owning sexually oriented businesses, but finding that the district court erred in rejecting a claim that the denial provisions of the licensing regulation are an unconstitutional prior restraint, striking this provision from the Ordinance and remanding to consider its severability.

(United States Ninth Circuit) - Reinstated a lawsuit alleging that a movie studio breached its collective-bargaining agreement with musicians who score motion pictures. The musicians' labor union contended that the movie studio breached the labor agreement by having the film Same Kind of Different As Me scored in Slovakia, rather than hiring union musicians in the U.S. and Canada. Finding genuine disputes of material fact, the Ninth Circuit reversed the entry of summary judgment for the movie studio and remanded for further proceedings.

(United States Ninth Circuit) - Held that an African American-owned operator of television networks sufficiently pleaded a claim that a cable television operator refused to enter into a carriage contract based on racial bias, in violation of 42 U.S.C. section 1981. Also, the section 1981 claim was not barred by the First Amendment. On interlocutory appeal, affirmed denial of a motion to dismiss.

(United States Ninth Circuit) - In a suit for trademark infringement and unfair competition brought under the Lanham Act by a producer of karaoke music tracks, alleging that the defendants performed karaoke shows using unauthorized 'media-shifted' files that had been copied onto computer hard drives from the compact discs released by the plaintiff, the district court's dismissal is affirmed where plaintiff did not state a claim under the Lanham Act because there was no likelihood of consumer confusion about the origin of a good properly cognizable in a claim of trademark infringement.

(United States Federal Circuit) - In a petition for cancellation of a trademark, brought by the owner of the INSIGNIA mark used to sell wines since 1978 against the registrant of the ALEC BRADLEY STAR INSIGNIA mark used for cigars and cigar products, the Trademark Trial and Appeal Board's denial of the petition is vacated and remanded for reconsideration where: 1) the Board erred in its legal analysis, in analyzing the 'fame' of INSIGNIA wine as an all-or-nothing factor, and discounting it entirely in reaching the conclusion of no likelihood of confusion as to source, contrary to law and precedent; and 2) as a result of this error, the Board did not properly apply the totality of the circumstances standard, which requires considering all the relevant factors on a scale appropriate to their merits.

(United States Federal Circuit) - Reversing the decision to refuse to register the mark FUCT because it comprises immoral or scandalous matter because the court held that the bar on registering immoral or scandalous marks is an unconstitutional restriction on free speech.

(United States Ninth Circuit) - Affirmed the dismissal of a trademark infringement lawsuit brought by a financial services company, holding that the use of its trademarks by a publishing company constituted nominative fair use.

(United States Seventh Circuit) - Held that a manufacturer of cellphone cases did not hold a valid trademark in the term CAPSULE. Affirmed a summary judgment in favor of the defendant in this trademark infringement lawsuit.

(United States Supreme Court) - Struck down a statutory provision that prohibits the registration of immoral or scandalous trademarks. An entrepreneur who founded a new clothing line filed a First Amendment challenge when the U.S. Patent and Trademark Office refused to register his desired trademark FUCT. The U.S. Supreme Court sided with him and invalidated a provision of the Lanham Act. Justice Kagan delivered the opinion of the Court, in which five other justices joined.

(United States Supreme Court) - Clarified the statute of limitations in qui tam lawsuits. Justice Thomas delivered the Court's unanimous opinion in this case involving the False Claims Act.

(United States Supreme Court) - Held that Title VII's charge-filing requirement is not jurisdictional and thus is subject to forfeiture if tardily asserted. The issue involved whether an employer waited too long to dispute that a discrimination plaintiff filed a proper complaint with the Equal Employment Opportunity Commission before initiating suit. Justice Ginsburg delivered the opinion for a unanimous Court.