In legal writing, David Mellinkoff, a professor at the UCLA School of Law, is widely credited with singlehandedly launching the plain English movement in American law with the 1963 publication of "The Language of the Law." In 1977, New York became the first state to pass legislation requiring plain English in consumer contracts and leases. In 1979, Richard Wydick published "Plain English for Lawyers". Plain English writing style is now a legal duty for companies registering securities under the Securities Act of 1933, due to rules the Securities and Exchange Commission (SEC) adopted in 1998. In 2011, PLAIN (Plain Language Action and Information Network) published "Federal Plain Language Guidelines".