Given a text passage, come up with an appropriate title for it. The title should accurately represent what the main focus of the passage is. The title of a passage may be present in the first few sentences of the passage and/or be referred to multiple times in the passage. The title should be 1-5 words long.

Example Input: Luke Zimmerman ( born September 11 , 1980 in Evanston , Illinois , United States ) is an American actor , who is best known for his role as Tom Bowman on ABC Family 's The Secret Life of the American Teenager .
Example Output: Luke Zimmerman

Example Input: Goldfarb v. Virginia State Bar , 421 U.S. 773 ( 1975 ) , was a U.S. Supreme Court decision . It stated that lawyers engage in `` trade or commerce '' and hence ended the legal profession 's exemption from antitrust laws .
Example Output: Goldfarb v. Virginia State Bar

Example Input: The Vice-President of India ( currently , Venkaiah Naidu ) is the ex-officio Chairman of the Rajya Sabha , who presides over its sessions . The Deputy Chairman , who is elected from amongst the house 's members , takes care of the day - to - day matters of the house in the absence of the Chairman . The Rajya Sabha held its first sitting on 13 May 1952 . The salary and other benefits for a member of Rajya Sabha are same as for a member of Lok Sabha .
Example Output:
Rajya Sabha