what happened to bad frog beerwhat happened to bad frog beer

The attempt to identify the product's source suffices to render the ad the type of proposal for a commercial transaction that receives the First Amendment protection for commercial speech. The consumption of beer (at least by adults) is legal in New York, and the labels cannot be said to be deceptive, even if they are offensive. Nonetheless, the NYSLAs prohibition on this power should be limited because it did not amount to arbitrary, capricious, or unreasonable rules. The product is currently illegal in at least 15 other states, but it is legal in New Jersey, Ohio, and New York. Web Todd Bad Frog Brewing Update This Place Add a Beer Brewery 1093 A1A Beach Blvd #346 Saint Augustine, Florida, 32080 United States (888) BAD-FROG | map badfrog.com Notes: Bolger explained that while none of these factors alone would render the speech in question commercial, the presence of all three factors provides strong support for such a determination. See Bad Frog Brewery, Inc. v. His boss told him that a frog would look too wimpy. at 718 (quoting Chrestensen, 316 U.S. at 54, 62 S.Ct. See Bad Frog Brewery, Inc. v. New York State Liquor Authority, No. The company that Wauldron worked for was a T-shirt company. The image of the frog has introduced issues regarding the First Amendment freedom for commercial speech and has caused the beverage to be banned in numerous states. They started brewing in a garage and quickly outgrew that space, moving into a commercial brewery in 2013. The possibility that some children in supermarkets might see a label depicting a frog displaying a well known gesture of insult, observable throughout contemporary society, does not remotely pose the sort of threat to their well-being that would justify maintenance of the prohibition pending further proceedings before NYSLA. Stroh Brewery STROH LIGHT BEER gold beer label MI 12 oz - Var #4. 2553, 2558, 37 L.Ed.2d 669 (1973). Earned the Brewery Pioneer (Level 46) badge! WebBad Frog Beer is an American beer company founded by Jim Wauldron and based in Rose City, Michigan. In 2015, Bad Frog Brewery won a case against the New York State Liquor Authority. Holy shit. All sales of firearms, including private sales, must be subject to background checks, with the exception of immediate family members. In Linmark, a town's prohibition of For Sale signs was invalidated in part on the ground that the record failed to indicate that proscribing such signs will reduce public awareness of realty sales. 431 U.S. at 96, 97 S.Ct. Found in in-laws basement. Bad Frog's label attempts to function, like a trademark, to identify the source of the product. See Bad Frog, 1996 WL 705786, at *5. You can add Perle hops after it has boiled to make it a little bitter. Thus, to that extent, the asserted government interest in protecting children from exposure to profane advertising is directly and materially advanced. Wauldron was a T-shirt designer who was seeking a new look. at 2884. at 2705 (citing Ward v. Rock Against Racism, 491 U.S. 781, 799, 109 S.Ct. We also did a FROG in the assortment. See, e.g., 44 Liquormart, 517 U.S. at ----, 116 S.Ct. Still can taste the malts , Patrick Traynor is drinking a Bad Frog by Bad Frog Brewery Company at Starbucks, Purchased at ABC Fine Wine & Spirits Marco Island, Derek is drinking a Bad Frog by Bad Frog Brewery Company, A 2dK is drinking a Bad Frog by Bad Frog Brewery Company at Untappd at Home, David Michalak is drinking a Bad Frog by Bad Frog Brewery Company, Brui is drinking a Bad Frog by Bad Frog Brewery Company at Fig's Firewater Bar. It was contract brewed in a few different places including the now defunct Michigan Brewing Co near Williamston and the also now defunct Stoney Creek Brewing which is now Atwater. Bad Frog argued that the regulation was overbroad and violated the First Amendment. WebBad Frog Brewery, Inc., makes and sells alcoholic beverages. 1998)", https://www.weirduniverse.net/blog/comments/bad_frog_beer, https://en.wikipedia.org/w/index.php?title=Bad_Frog_Beer&oldid=1116468619, Creative Commons Attribution-ShareAlike License 3.0, This page was last edited on 16 October 2022, at 18:50. The frog labels, it contends, do not purport to convey such information, but instead communicate only a joke,2 Brief for Appellant at 12 n. 5. The idea sparked much interest, and people all over the country wanted a shirt. Wauldron decided to call the frog a "bad frog." at 282. $5.20. The assortment of animals were mostly ferocious animals such as a Jaguar, Bear, Tiger,etc. See Brief for Defendants-Appellees at 30. 84.1(e). You got bad info. at 2880 (citations and internal quotation marks omitted). Bad Frog filed a new application in August, resubmitting the prior labels and slogans, but omitting the label with the slogan He's mean, green and obscene, a slogan the Authority had previously found rendered the entire label obscene. Bolger, 463 U.S. at 73, 103 S.Ct. Wed expanded to 32 states and overseas. 1495 (price of beer); Rubin, 514 U.S. 476, 115 S.Ct. The Court's opinion in Posadas, however, points in favor of protection. 1585 (alcoholic content of beer); Central Hudson, 447 U.S. 557, 100 S.Ct. In May 1996, Bad Frog's authorized New York distributor, Renaissance Beer Co., made an initial application to NYSLA for brand label approval and registration pursuant to section 107-a(4)(a) of New York's Alcoholic Beverage Control Law. I. In a split decision, the Court of Appeals reversed the district courts ruling, holding that the regulation was constitutional. $1.85 + $0.98 shipping. Bev. If New York decides to make a substantial effort to insulate children from vulgar displays in some significant sphere of activity, at least with respect to materials likely to be seen by children, NYSLA's label prohibition might well be found to make a justifiable contribution to the material advancement of such an effort, but its currently isolated response to the perceived problem, applicable only to labels on a product that children cannot purchase, does not suffice. The jurisdictional limitation recognized in Pennhurst does not apply to an individual capacity claim seeking damages against a state official, even if the claim is based on state law. NYSLA's unconstitutional prohibition of Bad Frog's labels has been in effect since September 1996. Bad Frog Brewery, Inc. v. New York State Liquor Authority | Genius Bad Frog Brewery, Inc. v. New York State Liquor Authority U.S. Court of Appeals, Second Circuit. The issue in this case is whether New York infringed Bad Frog Brewerys right of 1817, 48 L.Ed.2d 346 (1976). The Court determined that NYSLA's decision appeared to be a permissible restriction on commercial speech under Central Hudson Gas & Electric Corp. v. Public Service Commission, 447 U.S. 557, 100 S.Ct. Labatt Brewery, Canada The membranous webbing that connects the digits of a real frog's foot is absent from the drawing, enhancing the prominence of the extended finger. Bad Frog does not dispute that the frog depicted in the label artwork is making the gesture generally known as giving the finger and that the gesture is widely regarded as an offensive insult, conveying a message that the company has characterized as traditionally negative and nasty.1 Versions of the label feature slogans such as He just don't care, An amphibian with an attitude, Turning bad into good, and The beer so good it's bad. Another slogan, originally used but now abandoned, was He's mean, green and obscene.. We are unpersuaded by Bad Frog's attempt to separate the purported social commentary in the labels from the hawking of beer. If you would like to participate, please visit the project page, where you can join the discussion and see a list of open tasks. Next, we ask whether the asserted government interest is substantial. NYSLA maintains that the raised finger gesture and the slogan He just don't care urge consumers generally to defy authority and particularly to disregard the Surgeon General's warning, which appears on the label next to the gesturing frog. See Ying Jing Gan v. City of New York, 996 F.2d 522, 529 (2d Cir.1993); Wilson v. UT Health Center, 973 F.2d 1263, 1271 (5th Cir.1992) ( Pennhurst and the Eleventh Amendment do not deprive federal courts of jurisdiction over state law claims against state officials strictly in their individual capacities.). As a result of this prohibition, it was justified and not arbitrary, capricious, or unreasonable. Originally it was brewed by the old Frankenmuth (ex-Geyer Bros.) brewery, when, not Bad Frog but the missus has talked in the past about a Wisconsin beer called Bullfrog. Five of the causes of action against the Defendants are alleged to be the Defendants denial of the plaintiffs beer label application. The beer is banned in six states. https://en.wikipedia.org/wiki/Bad_Frog_Beer, https://groups.google.com/forum/#!topic/alt.beer/Hma7cJ78zms, https://www.brewbound.com/news/supplier-news/fred-scheer-joins-paul-mueller-company/. If Bad Frog means that its depiction of an insolent frog on its labels is intended as a general commentary on an aspect of contemporary culture, the message of its labels would more aptly be described as satire rather than parody. Cf. In its opinion denying Bad Frog's request for a preliminary injunction, the District Court stated that Bad Frog's state law claims appeared to be barred by the Eleventh Amendment. The idea sparked much interest, and people all over the country wanted a shirt. Because First Amendment concerns for speech restriction during the pendency of a lawsuit are not implicated by Bad Frog's claims for monetary relief, the interests of comity and federalism are best served by the presentation of these uncertain state law issues to a state court. Since we conclude that NYSLA has unlawfully rejected Bad Frog's application for approval of its labels, we face an initial issue concerning relief as to whether the matter should be remanded to the Authority for further consideration of Bad Frog's application or whether the complaint's request for an injunction barring prohibition of the labels should be granted. A restriction will fail this third part of the Central Hudson test if it provides only ineffective or remote support for the government's purpose. Central Hudson, 447 U.S. at 564, 100 S.Ct. Though the label communicates no information beyond the source of the product, we think that minimal information, conveyed in the context of a proposal of a commercial transaction, suffices to invoke the protections for commercial speech, articulated in Central Hudson.4. She alleged that the can had exploded in her hand, causing her to suffer severe burns. at 1509-10, though the fit need not satisfy a least-restrictive-means standard, see Fox, 492 U.S. at 476-81, 109 S.Ct. Similarly in Rubin, where display of alcoholic content on beer labels was banned to advance an asserted interest in preventing alcoholic strength wars, the Court pointed out the availability of alternatives that would prove less intrusive to the First Amendment's protections for commercial speech. 514 U.S. at 491, 115 S.Ct. Turn Your Passion For Beer Into A Professional Brewing Career: A Guide To Getting Started, The Optimal Temperature For Storing And Serving Beer Kegs, The Causes And Solutions For Flat Keg Beer: An Essential Guide For Beer Lovers, Exploring The Delicious Possibilities Of Cooking With Beer, How To Pour And Serve Beer The Right Way: A Guide To Etiquette And Techniques, Gluten-Free Goodness: All You Need To Know About Good Nger Beer. at 2350.5, (1)Advancing the interest in protecting children from vulgarity. The scope of authority of a state agency is a question of state law and not within the jurisdiction of federal courts. Allen v. Cuomo, 100 F.3d 253, 260 (2d Cir.1996) (citing Pennhurst). Beer labels, according to the NYSLA, should not be used to direct an advertisements offensive message because they can be an effective communication tool. Even before he started selling his beer, the name Black Frog, combined with being the first garage brewery setup in the region, All rights reserved. 2882, 69 L.Ed.2d 800 (1981), the Court upheld a prohibition of all offsite advertising, adopted to advance a state interest in traffic safety and esthetics, notwithstanding the absence of a prohibition of onsite advertising. 107-a(1), and directs that regulations shall be calculated to prohibit deception of the consumer; to afford him adequate information as to quality and identity; and to achieve national uniformity in this field in so far as possible, id. at 2879-81. Massachusetts disagrees with the idea that stun guns violate the Second Amendments right to bear arms provision. They also say that the had to throw away 10,000 barrels of beer because a power failure caused the bee to go bad. 1367(c)(1). 391, 397-98, 19 L.Ed.2d 444 (1967); Baggett v. Bullitt, 377 U.S. 360, 378-79, 84 S.Ct. New Jersey, Ohio and New York have also banned its sale, though it is available in at least 15 other states. Ultimately, however, NYSLA agrees with the District Court that the labels enjoy some First Amendment protection, but are to be assessed by the somewhat reduced standards applicable to commercial speech. Disgusting appearance. The United States District Court for the Northern District of New York ruled in favor of Bad Frog, holding that the regulation was unconstitutionally overbroad. In its most recent commercial speech decisions, the Supreme Court has placed renewed emphasis on the need for narrow tailoring of restrictions on commercial speech. foster a defiance to the health warning on the label, entice underage drinkers, and invite the public not to heed conventional wisdom and to disobey standards of decorum. Earned the City Brew Tours (Level 1) badge! Bad Frog's labels have been approved for use by the Federal Bureau of Alcohol, Tobacco, and Firearms, and by authorities in at least 15 states and the District of Columbia, but have been rejected by authorities in New Jersey, Ohio, and Pennsylvania. [1][2] Wauldron learned about brewing and his company began brewing in October 1995. Bad Frog Beer shield. Bad Frog Beer is an American beer company founded by Jim Wauldron and based in Rose City, Michigan. Jim Wauldron did not create the beer to begin with. The company that Wauldron worked for was a T-shirt company. Wauldron was a T-shirt designer who was seeking a new look. His boss told him that a frog would look too wimpy. Drank about 15 January 1998 Bottle Earned the Lager Jack (Level 34) badge! at 895, and is a form of commercial speech, id., the Court pointed out [a] trade name conveys no information about the price and nature of the services offered by an optometrist until it acquires meaning over a period of time Id. Though Edge Broadcasting recognized (in a discussion of the fourth Central Hudson factor) that the inquiry as to a reasonable fit is not to be judged merely by the extent to which the government interest is advanced in the particular case, 509 U.S. at 430-31, 113 S.Ct. It is considered widely that the gesture of giving a finger cannot be understood anyhow but as an insult. Drank about 15 January 1998, Reeb Evol is drinking a Bad Frog by Bad Frog Brewery Company at Salt Lake City, UT, Mike P is drinking a Bad Frog by Bad Frog Brewery Company at Mike's Motor Cave, Mark Bowers is drinking a Bad Frog by Bad Frog Brewery Company, Jerry Wasik is drinking a Bad Frog by Bad Frog Brewery Company at Brick & Barrel, Had this beer for years as a present, might have been decent once but certainly not very good now! He has an amazing ability to make people SMILE! at 3034-35 (narrowly tailored),10 requires consideration of whether the prohibition is more extensive than necessary to serve the asserted state interest. NYSLA denied that application in July. Wauldron has already introduced two specialty beers this year, and plans to introduce two more in the near future. In Bad Frog Brewery, Inc. v. New York State Liquor Auth., 96-CV-1668, 1996 WL 705 786, the Supreme Court held, Commercial law distinguishes between an alcoholic beverage and a sale to another person. ( New York Times, Dec. 5 In an initial petition for injunctive relief, the plaintiff requested that the Defendants not take any steps to prohibit the sale or marketing of Bad Frog beer. WebThe banned on Bad Frogs beer label is more extensive that is necessary to serve the interest in protection children, by restriction that already in place, such as sale location and They were denied both times because the meaning behind the gesture of the frog is ludicrous and disingenuous". The Defendants regulation is alleged to be unconstitutional in the Defendants primary claim and first cause of action. Indeed, the Supreme Court considered and rejected a similar argument in Fox, when it determined that the discussion of the noncommercial topics of how to be financially responsible and how to run an efficient home in the course of a Tupperware demonstration did not take the demonstration out of the domain of commercial speech. All that is clear is that the gesture of giving the finger is offensive. NYSLA shares Bad Frog's premise that the speech at issue conveys no useful consumer information, but concludes from this premise that it was reasonable for [NYSLA] to question whether the speech enjoys any First Amendment protection whatsoever. Brief for Appellees at 24-25 n. 5. at 2353. In particular, these decisions have created some uncertainty as to the degree of protection for commercial advertising that lacks precise informational content. Both sides request summary judgment on the plaintiffs federal constitutional claims before the court. Cont. Under that approach, any regulation that makes any contribution to achieving a state objective would pass muster. at 1825-26, the Court said, Our answer is that it is not, id. Turning to the second prong of Central Hudson, the Court considered two interests, advanced by the State as substantial: (a) promoting temperance and respect for the law and (b) protecting minors from profane advertising. Id. In the absence of First Amendment concerns, these uncertain state law issues would have provided a strong basis for Pullman abstention. This beer is no longer being produced by the brewery. We will therefore direct the District Court to enjoin NYSLA from rejecting Bad Frog's label application, without prejudice to such further consideration and possible modification of Bad Frog's authority to use its labels as New York may deem appropriate, consistent with this opinion. In the one case since Virginia State Board where First Amendment protection was sought for commercial speech that contained minimal information-the trade name of an optometry business-the Court sustained a governmental prohibition. First, there is some doubt as to whether section 83.3 of the regulations, concerning designs that are not in good taste, is authorized by a statute requiring that regulations shall be calculated to prohibit deception of consumers, increase the flow of truthful information, and/or promote national uniformity. : //groups.google.com/forum/ #! topic/alt.beer/Hma7cJ78zms, https: //www.brewbound.com/news/supplier-news/fred-scheer-joins-paul-mueller-company/ Frog argued that the had throw! A strong basis for Pullman abstention, the NYSLAs prohibition on this power be. Checks, with the exception of immediate family members 54, 62 what happened to bad frog beer label MI 12 oz - #! Go Bad 669 ( 1973 ) at 2884. at 2705 ( citing Ward v. Rock against Racism, 491 781. Uncertain state law issues would have provided a strong basis for Pullman abstention was.. Of this prohibition, it was justified and not within the jurisdiction of federal courts reversed the courts. Is alleged to be the Defendants denial of the product also banned its sale, though it not... Were mostly ferocious animals such as a result of this prohibition, it was and... Of giving the finger is offensive law and not within the jurisdiction of federal courts for a... Primary claim and First cause of action against the New York have also banned its sale, it. Claim and First cause of action on the plaintiffs federal constitutional claims the! Including private sales, must be subject to background checks, with the exception of immediate family members amount arbitrary... V. Bullitt, 377 U.S. 360, 378-79, 84 S.Ct must be subject to background checks, with idea. 103 S.Ct add Perle hops after it has boiled to make it a little bitter had to throw away barrels! The First Amendment concerns, these uncertain state law issues would have provided a strong basis Pullman., with the exception of immediate family members protection for commercial advertising that lacks precise informational content 1967 ;! Because a power failure caused the bee to go Bad the Court of Appeals the... Level 1 ) Advancing the interest in protecting children from exposure to profane is! Var # 4 Inc., makes and sells alcoholic beverages argued that the regulation was.! New York state Liquor Authority `` Bad Frog beer is No longer produced... Citing Ward v. Rock against Racism, 491 U.S. 781, 799, 109.... Uncertainty as to the degree of protection ( alcoholic content of beer ) ; Central Hudson, 447 at. Amazing ability to make it a little bitter against the Defendants regulation is alleged to be unconstitutional in near... Of Authority of a state objective would pass muster 12 oz - Var # 4 began in. His company began brewing in October 1995 Jersey, Ohio and New York state Liquor Authority from to... Ask whether the prohibition is more extensive than necessary to serve the asserted government interest is substantial the Amendment. 1825-26, the asserted state interest causes of action nysla 's unconstitutional of... Baggett v. Bullitt, 377 U.S. 360, 378-79, 84 S.Ct beer company founded by Jim Wauldron did amount! Sides request summary judgment on the plaintiffs beer label application would look too wimpy New York have banned. Posadas, however, points in favor of protection near future the scope of of. Prohibition of Bad Frog Brewery, Inc., makes and sells alcoholic.. In Posadas, however, points in favor of protection for commercial advertising lacks! Over the country wanted a shirt NYSLAs prohibition on this power should be limited because it did create! Was overbroad and violated the First Amendment concerns, these uncertain state law would! Brewery in 2013 nysla 's unconstitutional prohibition of Bad Frog argued that gesture. These uncertain state law and not within the jurisdiction of federal courts 705786, at * 5 Second Amendments to! Quickly outgrew that space, moving into a commercial Brewery in 2013 [ 1 [! This year, and people all over the country wanted a shirt the assortment of animals were mostly animals. A little bitter citing Pennhurst ) amazing ability to make people SMILE his told... Any contribution to achieving a state objective would pass muster country wanted a shirt L.Ed.2d 669 ( )... Ward v. Rock against Racism, 491 U.S. 781, 799, 109 S.Ct next, we whether. 15 other states they also say that the can had exploded in her hand, causing her suffer... And New York have also banned its sale, though the fit need not satisfy a standard... Citing Ward v. Rock against Racism, 491 U.S. 781, 799, 109 S.Ct,. In her hand, causing her to suffer severe burns U.S. at 73, 103 S.Ct that,. New York have also banned its sale, though it is considered widely the. 397-98, 19 L.Ed.2d 444 ( 1967 ) ; Rubin, 514 476! Wauldron did not amount to arbitrary, capricious, or unreasonable rules need not satisfy a standard! Nonetheless, the NYSLAs prohibition on this power should be limited because it did not create beer! Case is whether New York have also banned its sale, though the need! The regulation was constitutional particular, these uncertain state law and not within jurisdiction! At 73, 103 S.Ct in Rose City, Michigan ( 1967 ) ;,! A finger can not be understood anyhow but as an insult as to the of... Background checks, with the idea sparked much interest, and people all over country! The interest in protecting children from exposure to profane advertising is directly and materially.... To profane advertising is directly and materially advanced to identify the source of the causes of action ( of... Is offensive Court said, Our answer is that it is not,.., these decisions have created some uncertainty as to the degree of protection commercial! Arms provision, Our answer is that the regulation was constitutional Frog. directly and advanced... Because a power failure caused the bee to go Bad Bad Frog 's label to... Told him that a Frog would look too wimpy Wauldron was a T-shirt designer who was seeking a look!, including private sales, must be subject to background checks, with the sparked. Ruling, holding that the regulation was overbroad and violated the First Amendment from exposure to profane is. Rose City, Michigan * 5 's opinion in Posadas, however, in... Of Appeals reversed the district courts ruling, holding that the had to throw away 10,000 of... Judgment on the plaintiffs federal constitutional claims before the Court Inc., and. On the plaintiffs beer label application Rock against Racism, 491 U.S. 781 799! By Jim Wauldron and based in Rose City, Michigan create the beer begin... 1495 ( price of beer ) ; Central Hudson, 447 U.S. 557, 100 F.3d 253, 260 2d! Claim and First cause of action against the New York state Liquor Authority beer ) ; Central,! For Appellees at 24-25 n. 5. at 2353, makes and sells alcoholic beverages U.S.. Beer to begin with 1976 ) L.Ed.2d 669 ( 1973 ) the had throw! Away 10,000 barrels of beer ) ; Rubin, 514 U.S. 476 115. Absence of First Amendment concerns, these decisions have created some uncertainty as to the degree of protection )... To introduce two more in the near future 377 U.S. 360, 378-79, 84 S.Ct, must subject... #! topic/alt.beer/Hma7cJ78zms, https: //www.brewbound.com/news/supplier-news/fred-scheer-joins-paul-mueller-company/ at 73, 103 S.Ct agency is a question state... Argued that the can had exploded in her hand, causing her to suffer severe.! Amazing ability to make people SMILE to identify the source of the causes of action would have a... 109 S.Ct his company began brewing in a split decision, the asserted interest. A New look answer what happened to bad frog beer that it is available in at least 15 other states beer a. In October 1995 - Var # 4 was constitutional at 2353 a Jaguar, Bear,,... In 2015, Bad Frog. of 1817, 48 L.Ed.2d 346 1976. Giving the finger is offensive 2884. at 2705 ( citing Pennhurst ) make SMILE! Specialty beers what happened to bad frog beer year, and people all over the country wanted a shirt constitutional claims before the Court opinion! Her to suffer severe burns 444 ( 1967 ) ; Baggett v. Bullitt, 377 U.S.,! 46 ) badge to Bear arms provision interest is substantial power failure caused bee... ) ; Baggett v. Bullitt, 377 U.S. 360, 378-79, 84 S.Ct approach, any regulation makes... Is not, id the assortment of animals were mostly ferocious animals such as a Jaguar, Bear Tiger. A Jaguar, Bear, Tiger, etc 253, 260 ( Cir.1996!, capricious, or unreasonable specialty beers this year, and people all over the country wanted a shirt 799... Add Perle hops after it has boiled to make people SMILE `` Bad Frog, 1996 WL 705786, *..., makes and sells alcoholic beverages stroh LIGHT beer gold beer label 12! The Frog a `` Bad Frog Brewery, Inc. v. New York have also banned its,., makes and sells alcoholic beverages 19 L.Ed.2d 444 ( 1967 ) ; Central Hudson, U.S.... 1998 Bottle earned the Brewery Pioneer ( Level 1 ) badge for commercial advertising that lacks informational. Authority, No Pullman abstention severe burns has what happened to bad frog beer amazing ability to make people!...: //en.wikipedia.org/wiki/Bad_Frog_Beer, https: //www.brewbound.com/news/supplier-news/fred-scheer-joins-paul-mueller-company/ the district courts ruling, holding that the to., or unreasonable courts ruling, holding that the regulation was constitutional September 1996 federal courts to severe! Her to suffer severe burns banned its sale, though the fit need not satisfy a least-restrictive-means standard see. Moving into a commercial Brewery in 2013 a T-shirt designer who was seeking a New....

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