Wednesday, December 4, 2013

Want to improve your legal writing? Check out Bryan Garner’s Blog

Want to improve your legal writing? Check out Bryan Garner’s Blog - Usage Tip of the Day

Writing skills are one of the most important tools of the legal profession. The written word is used to advocate, inform, persuade and instruct. Although mastering legal writing skills takes time and practice, superior writing skills are essential to success.

An excellent way to continue to improve your writing skills is to subscribe to Bryan Garner's blog at According to the LawProse philosophy, legal writing should be simple and direct. What distinguishes effective from ineffective legal writers is empathy for the reader.
I have been reading Bryan Garner’s “Usage Tip of the Day” for a few months now, and have seen many posts addressing language problems I see frequently. What is most helpful is that Garner provides an engaging and clear explanation of the problems, along with identified sources -- all the better to remember the “rules.”

Here is one example:
LawProse Lesson #126:“That” vs. “which”

Posted on July 16, 2013 by Bryan A. Garner:

We now come to an issue that has provoked swearing matches in recent months: how to choose between that and which as relative pronouns. Consider:
Republicans oppose new taxes that are unnecessary. (Some taxes might be necessary.)
Republicans oppose new taxes, which are unnecessary. (None, in their view, would ever be necessary.)
Republicans oppose new taxes which are unnecessary. (Ambiguous.)
Most American editors don’t like the third version because of its palpable ambiguity. They insist on choosing between a commaless-that and a comma-plus-which. A commaless-that clause narrows (restricts) the meaning; a comma-plus-which doesn’t narrow (it’s called nonrestrictive). The choice of the relative pronoun reinforces the semantic difference conveyed by the presence or absence of a comma.
So that’s that.
Except it’s not. Though it was born in Britain, this useful distinction has really taken hold only in American English. Hence many British authorities (e.g., Gooden, Greenbaum, Trask) say that it is permissible to use a commaless-which to introduce a restrictive clause, as here: I saw the speeding car which ran over your cat. In that sentence, most American editors would either change which to that or put a comma before which — after discerning the true meaning.
Some American commentators (e.g., Lynch) minimize the importance of the American rule while still reciting it: “It boils down to this: if you can tell which thing is being discussed without the which or that clause, use which; if you can’t, use that” (Lynch, p. 218).
Other commentators cite what they consider exceptional cases: We want to assign only that book which will be most helpful. But such sentences can always be improved by other means: We want to assign only the book that will be most helpful.
The only real exception occurs with by which, for which, in which, etc.: We’ve consulted all the cases in which Justice Kagan has recused herself.
My advice: heed the that/which distinction. Use many more thats than whiches. Try not to be distracted too much when reading current British writing (in which commaless-whiches are rampant). And know that many British sources (Ayto, Times Guide) do hew to this nuance, which Americans have elevated to the status of a rule.
Which stalwart American sources champion the rule? The Chicago Manual of Style, Bernstein, Follett, Garner (ahem), and Words into Type, among others.
This is the house that (not which) Fowler built.

If you don’t already know who Bryan A. Garner is – his extensive writing on the language of the law led The Green Bag to call him “the leading authority on good legal writing.” A chorus of other publications — including The New York Times, Trial magazine, and Harvard Law Review — have echoed that sentiment.
Garner is editor-in-chief of Black’s Law Dictionary and the author of many leading works on legal style, including A Dictionary of Modern Legal Usage, The Elements of Legal Style, The Redbook: A Manual on Legal Style, The Winning Brief, and The Winning Oral Argument. His latest books are Making Your Case: The Art of Persuading Judges, co-written with Justice Antonin Scalia, and Garner on Language and Writing, an anthology published by the American Bar Association. His magnum opus is the 897-page Garner’s Modern American Usage, published by Oxford University Press. It is widely considered the preeminent authority on questions of English usage.

Read Garner’s daily blog and amass a wealth of legal writing tips to improve your skills!

Monday, December 2, 2013

Mobile Apps for Legal Research #7: Fastcase

Fastcase is an online platform for searching U.S. case law and statutes. The Fastcase app (iOS, Android) brings a pared-down version of Fastcase to mobile devices. The standout characteristic of the Fastcase app is that it is free to use--no Fastcase subscription required. Anyone can download the app and search an impressive collection of primary U.S. law.

The app contains a comprehensive collection of state and federal appellate level opinions, as well as a large collection of federal district court orders. It also has statute sets for the U.S., all fifty states, and the District of Columbia. The Fastcase app provides the most recent statute set for each jurisdiction and one or more superseded sets. You can search or browse the statutes. The browsable superseded statute sets make checking on the law in effect at a particular time in the past as simple as looking up the current statutes.

The Fastcase app offers basic search capabilities. It supports Boolean searching, wildcards, and proximity operators (though initially the proximity operators did not seem to work for me). But it  does not offer any of the advanced data visualization options present in Fastcase itself.

The app defaults to a relevancy ranking for its search results. The relevancy ranking looks primarily at the occurrences of the search terms in each document, and ranks the documents based on the frequency and location of the terms. The app is aware of how each document is cited in the database, but it does not use the information in its relevancy algorithm.

The app integrates citation analysis into its results by displaying two numbers beside each result--the number of times the document is cited in the entire database, and the number of times it is cited by the other documents returned by the current search. Tap the numbers, and the app gives you a list of the citing documents.

The app also lets you sort your search results based on the citation analysis. You can sort the results so that the documents cited the most in the database are at the top of the list, or so that the documents cited the most by other documents in your search results are at the top.

The app's document display delivers documents with few bells and whistles. Within the text of the document, your search terms are highlighted. In the document view, you can scroll through the document, go back to your search results, access the list of citing documents, and save the document. The save option saves the document to your Fastcase account. If you subscribe to Fastcase, you can access the document by logging into your account; if you don't subscribe, the saved documents are inaccessible.

While in document display, you can jump to the "most relevant" section of the document. The app identifies a single paragraph that seems to relate most to your search terms. In a long case dealing with multiple issues, the "most relevant" button can save time scrolling through the case looking for the highlighted terms.

Another option while viewing a document is to search within it. This search is not a "search within results" such as other legal research platforms offer, allowing you to narrow your search with additional terms. It is a find tool similar to the find function in a browser or word processor. It searches the current document for the terms you provide and has no connection to your original search.

In my testing, I had two issues with the app. The first is that some of the hyperlinks within the documents did not work. Citations to cases and statutes contained within the Fastcase database are hyperlinked so that you can jump quickly to the cited document. I tested twenty links at random, and four of them did not work. While twenty is a small sample size, I find a 20% failure rate unacceptable, particularly since I expect internal hyperlinks to work close to 100% of the time.

My second problem with the app is its relevancy ranking for search results. Fastcase claims that its "powerful sorting algorithms bring the best results to the top of the list every time." That statement is not true for the app's relevancy ranking. The algorithm places too much emphasis on the search terms themselves and ignores important measures such as the court issuing the opinion and the context of the term. For example, I ran a search for copyright AND "fair use." This is a broad search that returns many results. To get to useful results, I would generally have to narrow it with additional information. But with the search as is, the best results are Sony, Campbell, and Harper Row, three of only four United States Supreme Court cases to address fair use under the 1976 Copyright Act. I would expect my search to return those three cases at the top. In Lexis and Google Scholar, those three cases are the top three results. In the Fastcase app, Sony and Harper Row are results 4 and 5. Campbell is buried at 21, two screens away from the top of the list. Even though Campbell is a hugely significant fair use case, the Fastcase app puts federal district court cases ahead of it in the results because they use the phrase "fair use" more often.

Another example of the relevancy ranking's less than stellar performance is a search for Miranda. Again, this is not a search that I would use in actual research, but it is a search that should return a predictable set of results. It should return Miranda v. Arizona, but it should also return near the top other significant Miranda rights cases, such as Edwards v. Arizona, Rhode Island v. Innis, and Oregon v. Elstad. A search for Miranda in Lexis, Westlaw, and Google Scholar all return these or similar cases in the top 10 results. But the Miranda search in the Fastcase App returns cases with a party named Miranda. Of the first 50 search results, only two were Miranda rights cases rather than cases with a party named Miranda. I should find cases with Miranda as a party if I search cases by party name, but the best search alogrithms understand that Miranda used as a keyword more likely refers to a legal doctrine than a person.

I was able to avoid some of the problems created by the relevancy ranking by sorting my search results in the app by times cited. A general times cited sort had its own issues; a case that was cited for a proposition unrelated to my search could end up at the top of the search results, messing up the rankings. The times cited within the search results sort solved this issue by bringing up only documents cited by cases that contained my search terms, and were therefore were likely citing the documents on my issue. While this search approximated the results that I expected and got from other legal research platforms, I think it is an imperfect solution because it shifts from a focus on search terms to the exclusion of everything else to a focus on citation analysis to the exclusion of everything else.

Overall, the Fastcase app is a decent free option for legal research. The ability to view superseded statutes is a strong selling point, as are the innovative citation analysis and clean interface. Unfortunately, the issues with internal hyperlinks prevent the app from being one you could depend on in a situation where reliable access is a priority, such as quick searches in the midst of a court hearing.

The relevancy ranking serves as both a plus and a minus. The minus is that you can never be sure that you're not missing a highly relevant case a pager or two deeper in the results. Because of this, I would not use the app as a replacement for other legal research platforms. The plus is that the ranking may reveal cases that you would have overlooked in a more standard list of results. This makes the Fastcase app a good place to turn to get a new perspective on your research.

Monday, November 25, 2013

Happy Thanksgiving

(image "Thanksgiving Cornucopia" by Lawrence OP)

The library staff is taking a break from the blog to celebrate Thanksgiving. We will resume posting next week.

Have a wonderful Thanksgiving holiday. 

Wednesday, November 20, 2013

Westlaw and Lexis in Contrast: One Example

Despite their differences in design, Westlaw and Lexis often seem like two ways to get to the same content. They both have vast databases, which results in significant overlap, particularly in primary law like cases and statutes. The temptation is to evaluate them based on their appearance and usability, pick the one you like best, and ignore the other. But Westlaw and Lexis do have different content, and you can miss valuable information if you limit yourself to only one when both are available. Consider the following example, shared by Scott Burgh, Chief Law Librarian at the City of Chicago Department of Law Library, via the Law-Lib Listserv:

In the course of helping a patron, we needed to check the court file for the trial court in the case of Phillies v.  Byrne, 732 F2d 87.  To pull the file at the National Archives, one needs the docket number, but the trial case from ND Illinois is unreported.  The reporter volume and Westlaw list nothing of the lower court's docket, so that was of no help.  However, Lexis came through because a [search for] 732 F2d 87 gave us the trial level docket number [in the prior history field].  This Lexis result with the docket number allowed us to proceed to the National Archives . . . .

The point of the example is not that Lexis is the go-to source for federal district court docket numbers--Lexis does not always include the lower court docket number in the prior history it provides for an opinion. The point is that for any given research task, Lexis may have information that Westlaw does not, and vice versa. When conducting legal research, you should consider all the resources you have available.  If you focus on a single information platform, you may lose sight of the information you need.

Monday, November 18, 2013

Mobile Apps for Legal Research #6: Bloomberg Law Reports

Bloomberg Law is new to the legal research arena, and it does not yet have a mobile app version of its search platform. What Bloomberg Law does have is a current awareness app--Bloomberg Law Reports.

Bloomberg Law Reports acts as a reader for Bloomberg's BNA Law Reports on iOS mobile devices (Bloomberg Law has not released a version of the app for other platforms such as Android). To use the app, you must first log into Bloomberg Law and access your Bloomberg BNA email notifications. The app provides a link to the email notifications page, but you cannot manage the notifications from within the app.

The email notifications page provides a list of the law reports available through your Bloomberg Law subscription. To make a report available in the app, you must add it to your current notifications using the blue "Set Notification" button next to the report. Once you set the notification for a report, the report will appear in the app. The report will also be listed under "Current Notifications" on the email notifications page. To remove a report from the app, access the email notifications page and click on the red X next to the report under "Current Notifications."

Once you have loaded some reports, the Bloomberg Law Reports app works like an RSS reader. Each report is listed as a separate feed, and the app indicates how many unread articles are in each report. When you access a report, an article displays in the reading pane, and you can move between articles by swiping left and right or by choosing from a list of article headlines. Once you view an article in the reading pane, the app marks it as read.

You can choose to browse all the articles in a report, or you can search the articles by keyword. The search can be useful if you are interested in a subset of a report's topic. For instance, I receive the Patent, Trademark, & Copyright Law Daily Report, but I am only interested in copyright news. The search function saves me the time of browsing through all of the headlines for just copyright articles, and it finds me articles I would have overlooked in browsing because the headlines don't mention a copyright issue.

The Bloomberg Law Reports app has several drawbacks. The first is specific to Western New England School of Law. The app cannot access Bloomberg's servers through the law school's wireless network. If you are on our campus, you will not be able to update the content in the app via WiFi. You can still use the app to read articles that you have already downloaded, since the app is designed to automatically store between 20 and 200 articles for offline reading. The connectivity issue is probably related to law school's network configuration, so I don't put the blame on Bloomberg. But the issue does affect my willingness to use the app because it limits the currentness of the articles I see.

A bigger issue with the app is the way it is integrated into Bloomberg Law's notification system. Bloomberg Law primary supplies notifications is through email. The app sits on top of the email notification system almost as an afterthought. When you set the notification for a report, you automatically subscribe to the report's email list. Bloomberg Law does not provide a way to receive notifications via the app without also receiving the same notifications via email. Since my main reason to use such an app is to replace email notifications, the required duel delivery makes the app redundant. 

The app as an individual program is great--simple, visually clean, and effective. But the concept of the app falls flat. Why do I need a dedicated Bloomberg Law app to mimic an RSS reader when I already have an RSS reader? Bloomberg Law should have put its effort into providing RSS feeds of its BNA Law Reports. An RSS feed would allow me to use my own reader on any platform and free me from the email notifications. The app is great, but Bloomberg Law had better options available for delivering its content.

Wednesday, November 13, 2013

There's now a new app for the Constitution of the United States.

Since Neal Smith started reviewing apps for your legal research, I thought I might let you know about another app that's been made available from the Library of Congress and the Government Printing Office, the Constitution Annotated app. Constitution Day was recently marked by the launching of this new app and web publication that makes analysis and interpretation of the constitutional case law by Library experts freely accessible to all. This resource includes analysis of Supreme Court cases through the end of June 2013 and is expected to be updated repeatedly throughout the year as new court decisions are issued. Users can locate constitutional amendments, federal and state laws that were held unconstitutional, and tables of cases with corresponding topics and constitutional implications. Analysis is provided by the Congressional Research Service in the Library of Congress.

"Legal professionals, teachers, students and anyone researching the constitutional implications of a particular topic can easily locate constitutional amendments, federal and state laws that were held unconstitutional, and tables of recent cases with corresponding topics and constitutional implications," stated the Library of Congress in a press release.

As of now, the Constitution Annotated app is available for the IOS platform, but an Android version is also under development. A link to is here where you will find the Constitution Annotated page which includes a link to download the app. The Constitution Annotated web page available on GPO's Federal Digital System is a digitally signed, searchable PDF with the GPO's Seal of Authenticity.

Students taking ConLaw classes may just want to have it handy.

And along the same lines, if you're looking for free information about the US CODE try going to this government site, the U.S. House of Representatives web site. It doesn't have an app yet, nor is it annotated, but it does have all the Code as it is today, and includes a "Popular Name Tool". The currency date for each section of the United States Code is displayed above the text of the section. If the section has been affected by any laws enacted after that date, those laws will appear in a list of "Pending Updates". If there are no pending updates listed, the section is current as shown. The Code online is current through Pub. L. 113-47.

Monday, November 11, 2013

Mobile Apps for Legal Research #5: Lexis Advance HD

Lexis Advance HD is the Lexis search app for iPad. The app delivers a pared-down version of Lexis Advance that promises comprehensive and efficient research on the go (as this marketing video indicates). I found Lexis Advance HD a user friendly and fairly comprehensive research app, but thought it fell short on efficiency.

Lexis Advance HD opens to an attractive home screen. At the top is the standard Lexis Advance search bar, and below is the workspace. The workspace displays a welcome screen, and you can also access several content boxes: folders, search history, alerts, and offline documents. The design of the workspace demonstrates an understanding of touch screen design--rather than moving between the content boxes by means of tabs or links, you swipe across the box to move to the next one.

While I like the design of the home page, the functionality is lacking. The home screen provides no way to access content by browsing. Certainly this is not an issue of space. A browse screen would fit nicely in place of the welcome screen, which provides nothing but a visual placeholder. The lack of browsing is deeper than the home screen. The app offers no browsing functionality whatsoever (beyond browsing your search history, folder contents, alerts, and offline documents). You can only access content by searching. This is the first place where the app fails to deliver efficiency. If you want information from a particular source, you have to search the system and take the time to limit your search to that source through the content filters. If you want to see the table of contents for a resource such as treatise (something easily done on Lexis Advance using the Browse Sources function), you're out of luck. I could not figure out how to access any tables of contents. The lack of such browse capabilities may an infrequent issue (I prefer filtering my searches to browsing), but I will miss the added efficiency a browse function could provide.

The app's search harness the complete Lexis Advance search capability. You can perform a natural language or terms and connectors search and narrow your search with a wide array of filters. On the result screen, the filtering menu is displayed with white text on a black background, making the menu and the search results (standard black text on white) readily distinguishable. The contrast works well; I like the look of the app's result screen better than Lexis Advance.

The app uses the tab system from Lexis Advance to manage document access. Every document and search opens in a new tab. When I saw that the app contained the tabs, I was disappointed. I dislike the tab system in Lexis Advance because every time I access a tab, the system reloads it, which takes a second or two. The delay is not long, but it is noticeable, particularly when I am moving back and forth between several tabs. I expected a similar performance hit in the app, and was pleasantly surprised. The app's tab system actually works. Once a tab loads, it remains in memory, so I can switch between tabs instantaneously. These tabs are a good idea, not the detriment I expected.

Several features are missing from the results screen (and document screens). For instance, the app does not let you create alerts. The alert box in the workspace displays existing alerts, but you cannot edit them or add new ones. You also cannot directly save documents offline. The offline functionality is tied to the folders. When you save a document to a folder, you have the option of also saving it offline. And if you go to your folders and open a document that is not saved offline, the app gives you nice simple button you can tap to save it offline. I think the app would be more efficient if the offline button were available whenever you viewed a document. Saving to a folder is an unnecessary extra stop if all you want is to be able to read a case in the app without an Internet connection.

Another place Lexis dropped the ball on efficiency is the document annotation feature. You can highlight text and annotate documents in the app, but only when you access the documents through your folders. This means that if you a person who uses the Lexis Advance annotation feature, you have to save all the documents you want to read to a folder first. If you are also someone who read the documents you find as you search, the app forces you to open each document, save it to a folder, open the folder, and reopen the document before you read it. I am uncertain why the annotation feature would need to be designed in such a way, or why it would be designed that way if it were not necessary.

Despite its flaws, I like the Lexis Advance HD app. In some ways, it is superior to Lexis Advance, particularly when it comes to the tabs. Until Lexis fixes the tab system in Lexis Advance, I am more likely to use the app when I want to search Lexis than I am to use Lexis Advance. Even with the lack of a browse feature and the convoluted annotation system, Lexis Advance HD is one of the best legal research apps I have tried, though not always an efficient one.

Wednesday, November 6, 2013

Tweeting Law Part 2

Last year Spot-On Legal Research featured a post on Tweeting Law. In it, Elliot Hibbler discussed the value of Twitter as a means of "staying abreast of hot legal issues, including issues that might be a good starting point for a Law Review Note." Patrick M. Ellis, a student at Michigan State University College of Law, used Twitter as more than a starting point for his Law Review Note. He set out to determine if Twitter could be a legitimate source of legal information for scholarship by using it as his primary research tool for his note.

You can see the results of Ellis's foray into Twitter for yourself. A working draft of his note, 140 Characters or Less: An Experiment in Legal Research, is available at SSRN. Here is the abstract:

In 1995, Robert Ambrogi, former columnist for Legal Technology News, wrote about the Internet’s potential to revolutionize the accessibility and delivery of legal information. Almost 20 years later, Ambrogi now describes his initial optimism as a “pipe dream.” Perhaps one of the greatest problems facing the legal industry today is the sheer inaccessibility of legal information. Not only does this inaccessibility prevent millions of Americans from obtaining reliable legal information, but it also prevents many attorneys from adequately providing legal services to their clients. Whether locked behind government paywalls or corporate cash registers, legal information is simply not efficiently and affordably attainable through traditional means.
There may, however, be an answer. Although the legal industry appears to just be warming up to social media for marketing purposes, social media platforms, like Twitter, may have the untapped potential to help solve the accessibility problem. This Note attempts to prove that assertion by showing an iteration of social media’s potential alternative use, as an effective and free information sharing mechanism for legal professionals and the communities and clients they serve.
Generally speaking, law review editors and other academicians demand that authors support every claim with a citation, or, at the very least, require extensive research to support claims or theses. This Note seeks to fulfill this requirement, with a variation on conventional legal scholarship. Almost all of the sources in this Note were obtained via Twitter. Thus, this somewhat experimental piece should demonstrate social media’s potential as an emerging and legitimate source of legal information. By perceiving and using social media as something more than a marketing tool, lawyers, law schools, and, most importantly, clients, may be able to tap into a more diverse and more accessible well of information. This redistribution of information accessibility may not only solve some of the problems facing the legal industry, but also has the capability to improve society at large.
Twitter won't replace Westlaw and Lexis anytime soon, but Ellis makes a good case for adding Twitter to the list of sources to check when conducting research.

Tuesday, November 5, 2013

Mobile Apps for Legal Research #4: Scanner Apps

Electronic resources are rapidly displacing print, but print continues to be a valuable source of information. Every legal researcher at some point ends up in the stacks of a law library, paging through an unusual treatise or a superseded statute. Then its off to the photocopier or scanner with the treatise to capture the one or two pages of valuable information for later use. I have spent many hours hunched over photocopiers, fighting with the spines of tightly bound books and thinking that there must be an easier way.

Thanks to smartphones and tablets, there now is an easier way to scan pages from a book. With the right app, a smartphone or tablet becomes a portable document scanner. The apps work by photographing the pages of a book (or any other document) and converting the images into PDF files. 

There are a wide variety of scanner apps available. I decided to test and review some of them. Rather then choosing one app and testing all of its features, I found ten free iPad apps and tested one feature: scanning pages from a book. I used each app to scan three pages from a book of selected commercial statutes. I then evaluated each app on two criteria: the quality of the scan, and how long it took me to learn the app well enough to scan and email the three pages. Here are the results.

Best in Show

FasterScan HD

With FasterScan HD, I took just over three and half minutes to successfully scan three pages and email the PDF document to myself, not the fastest time (despite the name), but respectable. The app stayed out of its own way and let me scan; every button did what I expected every time. The resulting PDF is not perfect, but it is the closest any of the apps came (as you'll see below). The text is reasonably crisp, and most of the imperfections are a result of the book I used--from use and abuse during law schools, the pages have developed a permanent wave, which explains the wobbly lines of text in the PDF.

Honorable Mention

DocScan HD

DocScan HD was the easiest of the apps to use.  I scanned all three pages in two and half minutes, a full minute faster than FasterScan. Unfortunately, DocScan fell short on the quality. The PDF, while quite readable, has a blurriness to it that the FasterScan PDF does not . With more time and a steadier hand, I could probably improve upon DocScan's quality, but today's rankings are based solely on today's results.


JotNot is hard to distinguish from DocScan HD. I took a few seconds longer to scan the three pages in JotNot, but JotNot is far from difficult to use, and the resulting PDF is almost identical in quality to the PDF created by DocScan. JotNot ranks next to DocScan HD and just below FasterScan HD.



TinyScan produced a decent PDF, but the noticeable bleed through of text from the underlying page and the six minutes it took me to scan and email three pages from a book push TinyScan down into the merely acceptable range.  It is the best of the mediocre, but still mediocre.

CamScanner HD

Time to scan and email three pages: 3:05.
Resulting PDF: readable, though some squinting may be required.

Time to scan and email three pages: 6:04, which is pretty good considering each page had to be emailed separately.
    Resulting PDF: Readable, but don't expect too much of the app's image stabilization.


Time to scan and email three pages: 3:40
Resulting PDF: A little light on the black and heavy on the fuzz in some places, but readable (with a good imagination).


Time to scan and email three pages: 6:48
Resulting PDF: Crisp black text, but at the cost of giving life to every imperfection and ghost of text on the page.


Scan it All

I spent 10 minutes with this app unsuccessfully trying to email a PDF of the pages I scanned. Then I took a look at the PDF on the iPad, realized two of the three pages were blurry to the point of being unreadable, and abandoned Scan it All.

Click Scan (Anti-Shake Document Scanner Pro)

Click Scan not only created an unreadable document, it managed somehow to flip the image so that the text is backward. If you avoid only one iPad app this week, make it Click Scan.