number of women board members the people responsible for affection waiting that quota don't have standing to the right to vote for board members is one of the most important contractual rights that shareholders have as owners of the company and given the existence of the injuries in your reply brief but they weren't even mentioned before having to do the making it more difficult to invest and also he's at a disadvantage actually alleged in his whining you know allegations of this nature in terms of he's changing his vote and that sort of thing so we've got the corporation over here in and you've got him but i don't see how he is subject to a quota vote that's what the link i'm missing sure your honor the lot is at phrased in the passive voice it just says that a certain number of women must be elected now shareholders are responsible for doing the electing and just because the state has chosen to punish a rd party for any infractions does not mean that the law is not regulating shareholders there are plenty of cases where the law is not directed at the regulated party but as a matter of common sense that operates on his party so we can take for example the duarte case out of the th circuit which said that families of sex offenders have standing to challenge laws that regulate where sex offenders live because the practical consequence is also to regulate where the family members live or out of this circuit we have a party ventures in which this court said that shareholders of any club the injury being pressured it's changing the dynamic of the election and savoring vote in favor of women now even if he allowed the quota even if anyone plowed the court and they're still what the call what i'd like to do i'm asking a very specific question and you're making very general arguments and i appreciate i understand your argument completely but i'm trying to cross reference it with yes yes your honor thank you i have the complaint in front of me and i would say that the allegations following things his injury such as paragraph twenty two which say that the women quota is designed to compel the election of more females on to corporate board and a lot of last impact impact behavior of shareholders like mr me one who are responsible for doing the voting and if we go down just a little bit we say of course that he intends to vote and that the quota injures his right to vote for the candidate of his choice free from the threat that the corporation will be fine and i think this is a case similar to some of these contracting cases that have come out of the th circuit and the supreme court where the injury is not the denial of any certain outcome it's not that his preferred candidate won't be elected it's being subject to a system in which  that this case was brought as a present forstmann case speaking person active relief and that's why the allegations are more general and we do believe that he's injured no matter how you vote but in terms of which cases are b this circuit where there was no penalty at all the family members the family members were free to move wherever they wanted but as a practical matter it was impacting their freedom to move where they wanted because they wanted to live with with their family member was regulated by the regulation and lastly i would point to it owner operator independent truckers association out of the devon it and wage the compliance with the law at issue there which regulated  t hours for individual truckers it was regulated it was measured at the carrier level and yet the individual operators had standing to bring suit because the court recognized that ultimately it was their behavior that the statute was trying to influence here we know that the statute is trying to influence shareholder behavior it's trying to get them to vote in a certain way and even if they don't conform to the state preferred behavior they suffer an injury because they've been put at a disadvantage that stricken here in the nature of the law that one type of a privilege and the other is and and so i think those three cases  really highlight part of the assumption behind that is that he's not going to vote for a female candidate and he hasn't alleged that so i don't see that one vote is privileged over the other in the end they all get a again anyway you've got it he's going to be injured because if you vote for the woman again to the will in compliance with the quota because he fears the potential legal consequences he's been forced to vote on immutable characteristic if  consequences of that which is that our vote now has essentially been worded in a free election although it would have been on equal footing and people would have voted their conscience and now we have a law that is coercing various people out the quo that he still injured because presumably everybody else some people are being coerced by the law and that is tilting the election in favor of a certain candidate and i think if we look at how the la out it's very difficult for the government to contend that the law isn't having some sort of coercive effect because since the law has gotten back hundreds of women have been elected to corporate boards and so that supports the allegation that the not challenging the corporations authority or whatever decisions they may or it makes with respect to who's nominated that's correct your honor because whatever effect it's having on the nomination committee  correctly well certainly i think the lower courts have interpreted shareholders standing very expansively because enter any interference with the right to elect board members is an injury regardless of whether that action ends up effectuating i discriminated in the st place to challenge mandatory discrimination i think that the court found in the peterson case or is this court found in monterey mechanical even if you would have would have done that action anyway if the about three minutes left and i didn't know if you wanted them to now or later thank you your honor i appreciate that and i will reserve the rest of my time  articles read what he has not done so here he also lacks standing as a shareholder under potential considerations it cannot show that he has suffered injury or will suffer an injury that is separate and apart from any injury to o corporations to depend on shareholder votes to be in compliance with the law doesn't mean that it harms those shareholders if a corporation is out of compliance with the law this is this is in fact particular evidence here with  that choose the director they harm or the alleged harm does not fall on the share on the shareholders so while shareholders well again well corporations are  qualify for the harm that's that was described and that was additional moderate mechanical regarding r k ventures yes that is the plaintiffs in that case for shareholders but they were also principal owners of the corporation and really focused on the fact that they were bringing a case as a case for personal international  haven't he alleged pacifically that he changed his vote and therefore because of the law and therefore standing well your honor i would certainly give more it was certainly provide more allegations that what is currently alleged this complaint but again there is no i think it would have to be again he would have to be able though opposing counsel suggests that it speculate about whether they will ever enforce the law st i want to point out that they are enforcing the law in fact the secretary of state is gathering information on complying companies and not complying company the publishing bill the only way to be sure that there will not be term forstmann and that be here at the corporation or if we take a political analogy if you have to if you have to vote for a certain a woman representative the only way to be sure that that's not going to happen is by changing your behavior and so that shows why there's a credible threat of injury each time because you don't know unless you unless you change your behavior and that's just a feature of a voting and it would be very regressive today that would only have ending if you're a majority shareholder because that would mean that only those people with the stream power and capital are able to go to the courthouse and those that are meanwhile stuck wondering if the