The new New York rules were challenged, and Judge Frederick J. Scullin of the United States District Court for the Northern District of New York struck down five of the rules as unconstitutional infringement of the First Amendment. The endorsement, portrayals, "Irrelevant characteristics", and nicknames provisions were stricken; however, the domain name limitations, 30-day solicitation, and communications rules were upheld. State Bar President Kathryn Madigan promised to work with the court system to develop new rules that will survive constitutional strict scrutiny.