The Court said “There is often no clearly articulated state policy on what constitutes “the practice of law.”

In 1999, the Federal Trade Commission and the United State Department of Justice have declined to accept mere assumptions as grounds for permitting unauthorized practice laws to restrict lay providers’s right to pursue their occupations and the public’s right to chose. See Palmoar, supra note 55 at 431 Minnesotalawreview.org. Stifled Justice. Harm to the public resulting from the unauthorized practice of law is historically overstated. Parallel advancements in information technology and consumer sophistication make injury even more remote today.

One study found that only two percent of UPL inquiries, investigations, and complaints arise from consumer complaints.  Unauthorized practice of law statutes assume a pre-internet level of naivety that simply no longer exists for growing numbers of sophisticated computer users.