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Message: [QUOTE="Robert Kern, post: 5160438"] Thanks for the link. While it has not really changed my opinion (as discussed at length in my other reply), I did not know that the 9th Circuit had formalized the "overt act" test in their civil procedure rules, so there is at least one jurisdiction in the US that does currently work like this. None of the others do, to my knowledge, and this is the product of judicial common law, not statutory law, so it's still pretty shaky. -- Robert Kern "I have come to believe that the whole world is an enigma, a harmless enigma that is made terrible by our own mad attempt to interpret it as though it had an underlying truth." -- Umberto Eco [/QUOTE]