The proposed opinion fails to give in-house counsel any concrete advice on how to avoid practicing law without authorization. And ambiguity has consequences. The U.S. Supreme Court, discussing another ethics issue, has held that “[a]n uncertain privilege . . . is little better than no privilege at all.” Upjohn Co. v. United States, 449 U.S. 383, 393 (1981). The same applies here – an ambiguous opinion is no better than no rule at all. Under the current system, in-house counsel provide a great service to their own clients and to the overall system of justice. But rules like this one may force them and their clients to alter their traditional roles in Florida, a change that will only hurt everyone involved. The current law does not demand any greater specificity. Therefore, ACC requests that this Court reject the proposed opinion to remove obstacles and uncertainty that would affect in-house counsel across the country.