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Most US school districts as of 23 March 2020 are and will remain closed until the end of the academic school year or “until further notice” because of COVID-19, according to data provided by a Maryland-based online publication that provides scholastic news and analysis. This Article assumes that while pre-kindergarten through 12th grade schools, institutions of higher education, and business and trade schools are closed, many are relying on internet-enabled distance learning (eLearning) alternatives in place of traditional classroom instruction.