On November 16, the United States Panel on Multi-District Litigation conducted a lottery among the federal court circuits in which lawsuits are pending over OSHA’s ETS. Under the rules applicable to the ETS, all legal challenges to the ETS are to be consolidated and transferred to one Circuit Court of Appeals for hearing and decision. The lottery resulted in the selection of the Sixth Circuit Court of Appeals to receive and hear these cases. We will continue to monitor for further developments.