On Oct. 30, 2020, CLINIC submitted comments in response to a Notice of Proposed Rulemaking titled, "Professional Conduct for Practitioners-Rules and Procedures, and Representation and Appearances," and that would allow practitioners to make limited appearances in immigration court. As detailed in the comment, CLINIC strongly supports EOIR clarifying that practitioners can make limited appearances because such appearances allow more noncitizens to have access to counsel, at least for parts of their cases. However, CLINIC expressed significant concerns about: 1) sections of the rule that are not written clearly or whose effects have not been fully analyzed, 2) adding burdens to pro bono attorneys, and 3) proposed changes to the discipline section of the regulation.