If you are a California attorney or paralegal, probably no day goes by in which you do not receive e-mail about online continuing legal education. As recently as 2000, however, you would not have received any, because the State Bar of California did not approve online continuing education courses until then.

Since 2000, online continuing education offerings have evolved to meet increased demand. Unfortunately, some things have not changed in the ensuing years, for example the lack of consistency between each state’s online CLE requirements and the confusion this causes attorneys who are licensed in more than one state. Online programs are now accepted in 42 states, but there are as many rules as there are states. Some states limit the total number of hours that can be earned online. California, for example, allows an attorney to fulfill all required CLE online—self-study and participatory. Minnesota only allows participatory credit for a live webcast, while California allows a participatory credit for an archived webcast. More confusion arises from the way online vendors categorize courses. For example, if a course is labeled as conferring law practice management credit, California attorneys may not think it is ineligible for CLE credit since California no longer has a separate law practice management CLE category. However, California attorneys can still take the course and count it as general credit.

A more positive change is the growing acceptance of online seminars, as evidenced by the increased number of seminars available as well as the number of lawyers who take them. In 2000, West LegalEdcenter did not exist, but now the concern offers nearly 7,000 online seminars covering approximately 17,000 hours. The number of lawyers taking online CLE has grown along with the supply. According to Robert Reich of InReach (formerly LegalSpan) and Brian Emerson of law.com, online CLE participation has seen substantial growth in volume and revenue since 2003.

"Podcasts: The Los Angeles County Bar Association and
the State Bar of California"
Another big change in electronic seminar delivery is the downloadable podcast. Spurred on by the popular downloading of music to handheld players (such as iPods), podcasts make CLE more portable and thus more convenient. Downloads allow attorneys to take programs along with them and earn CLE hours while waiting for a flight, waiting for a case to be called, or driving to work (with the use of a car stereo adapter). Podcasts also allow users to stop at any time and go back to any part at any time that is convenient. The State Bar of California considers podcasts participatory credit as long as the provider can verify that a lawyer has listened to the entire podcast. For example, the State Bar of California’s podcasts include a series of code words throughout the podcast that the lawyer is required to enter into an online account before receiving the certificate of participation.

The Los Angeles County Bar Association (LACBA) and the State Bar of California are embracing podcasts. LACBA’s offers nearly 300 CLE seminars as podcasts (see www.legalspan.com/lacba), and the State Bar of California offers over 800 seminars in the podcast format (www.legalspan.com/calbar). While West has thousands of MCLE programs available as audio only (viewable by clicking the “Podcast” link on the home page’s left side), they are not explicitly offered for MCLE credit. West's site states, "These programs currently are not available for MCLE credit." The West LegalEdCenter site goes on to note that others of its podcast programs, "may qualify for CLE self-study credits," but it would be up to the individual user to determine this based on their jurisdiction's MCLE rules.

Law.com's CLEcenter has also recently begun offering podcasts. Written course materials (in PDF) that are easily printed and referred to generally accompany podcasts.

The LACBA podcasts can be downloaded to an iPod, MP3 player, computer, or any other device that supports the Windows Media Audio file format. The podcasts have been so popular that in the first three months they were available, 50 percent of LACBA courses taken online were in the podcast format. For those who forget to finish a LACBA podcast course, an e-mail reminder is sent a few days after a podcast is downloaded. Podcasts are priced at generally priced at $25 an hour – with some higher. To introduce lawyers to podcasts, LACBA offers a free one-hour podcast that teaches how to use LACBA’s Civil Register online database. LACBA also has audio and video online seminars that can be previewed for free (most online providers offer this feature).

"State Bar of California"
The State Bar’s online program (www.legalspan.com/calbar) offers more than 900 seminars. Like LACBA’s online program, many of the seminars are produced by the State Bar and focus on California law. However, the State Bar’s catalog also includes generic seminars from the archives of technology partners such as LegalSpan. The State Bar’s advanced search menu offers ways to find courses by key words, faculty name, course number, and type of media. To further narrow the search, results can be limited to participatory only or ethics only.

America Lawyer Media’s (ALM) Law.com/CLEcenter
One of the earliest providers of online legal education was America Lawyer Media’s (ALM) Law.com, which began offering online courses in 1995. The company has gone through many incarnations during its life, and the online CLE provider CLEcenter (http://www.clecenter.com) is a separate division of Law.com. By 2000, the site had 250 hours of online programming and now has about 400 active seminars accredited in California ranging from one to three hours. The most popular format is audio only. It also offers live webcasts (which are later archived) lasting about 1.5 hours, with the last 20 minutes reserved for questions using a chat interface. CLEcenter.com users can purchase individual seminars (prices vary) or select a discounted bundle in a state or practice area. Lawyers can also use the site’s wizard to customize their own bundle of seminars. CLEcenter partners with the New York City Bar, Illinois State Bar LACBA, and the Recorder (ALM’s San Francisco legal newspaper).

Thomson-West’s LegalEdcenter
Thomson-West’s LegalEdcenter (http://westlegaledcenter.com) started offering online CLE in 2001 and in a recent interview claimed to provide the largest collection of online CLE programs available on the Internet. Its CLE catalog includes live webcasts and archived versions of previously recorded online programming. The site’s advanced search function allows the user to search for a program among the nearly 26,000 hours (total in all jurisdictions) of offerings by numerous criteria. West offers bonus features such as links to program materials and links to its online database. West also offers My CLE Tracker, which displays a user’s completed LegalEdcenter credits and the number of credits yet to be completed for the current reporting period. West LegalEdcenter programs start at $45 per hour.

The Rutter Group
The Rutter Group’s (www.rutteronline.com) online CLE courses feature streaming audio and video with written materials and links to related Web sites. Rutter’s 75 or so courses range from one to six hours, with most lasting three, at a cost of $35 per credit hour. Rutter offers an unlimited use pass at $495. Although this is a $100 increase from seven years ago, the pass also includes free admission to Rutter’s live programs, video replay programs, and lending library of video and audio tapes. To choose a course, browse through the list of courses or select a topic from the menu. Rutter tracks the amount of time a user spends online and offers participatory credit. Users can sample Rutter’s offerings (and earn one hour of MCLE credit) with the free one-hour trial course, "Persuasive Speaking Skills Inside and Outside the Courthouse."

Continuing Education of the Bar (CEB)
Continuing Education of the Bar (CEB) Continuing Education of the Bar (CEB) offers over 100 hours of streaming video, audio and MP3 courses (with written materials) in six practice areas plus the subjects that are required in California. The programs, which can be listened to in increments of 20 minutes, are offered for participatory credit. CEB offers "passport" discount programs, ranging from $625 for one individual to access 25 Anytime Anywhere hours to $1095 for one user to take unlimited live and On Demand seminars (with access to reference materials). Transferable passports cost up to $2350. CEB provides an online method to track credits completed with CEB, self-study credits, and even credits earned from other providers.

Practicing Law institute
Practising Law Institute’s (www.pli.edu) online courses are offered in a variety of formats, including over 1,000 podcasts and nearly 500 on demand or archived programs. Nearly 100 live webcasts are also forthcoming. Each course description includes a statement PLI offers a free sample of an online course, but unlike CEB, there is no CLE credit attached to the offer. PLI course prices vary widely: $49.99 per hour for podcasts, $129 for a one hour streaming audio course, and $1,250 for the 17-hour securities regulation institute (with the option of buying segments for $80 each). Courses are key word searchable.

American Bar Association Center for Continuing Legal Education
The American Bar Association Center for Continuing Legal Education (www.abanet.org/cle) offers audio or video webcasts at $119 per 1.5 hours of credit. In addition, the ABA’s CLE Now service offers nearly 50 free webcasts (www.abanet.org/cle/clenow). The free webcasts are self-study credits only, with most available only to ABA members.

Online "Partners"
InReach 
InReach (formerly LegalSpan [www.legalspan.com]) began offering online CLE in 1998. Since then, it has expanded to offering a catalog of hundreds of programs from four dozen partner content providers around the country, like the State Bar of California and the Los Angeles County Bar Association. The majority of InReach’s content is currently offered as archived video, according to Reich. However, the popularity of the CLE-to-Go products offered through partners such as the State Bar of California and the Association will likely push the company’s archived audio-only offerings past their current 10 percent. Archived programs, audio and video, are priced at $35 per hour, with live webcasts priced higher.

Lawline and Fast CLE
Similarly, other national vendors like Lawline (www.lawline.com) and FastCLE (www.fastcle.com) have partnered with various content providers, including Internet For Lawyers and the Illinois State Bar Association (respectively), to provide California CLE courses. Lawline offers primarily streaming video courses for $60 per hour, while FastCLE offers archived video seminars that are synchronized with PowerPoint slides and downloadable printed materials for less than $45 per hour ($269 for a 6 hour program).

Online availability of MCLE allows lawyers to take courses any time, anywhere. This is quite an alluring feature to the busy attorney who wants to earn MCLE credits or simply gain some new knowledge quickly. Vendors have increasingly removed the technological barriers to taking courses online, with most providing phone support and system requirements tests to determine whether a user’s computer is compatible with the vendors’ online systems before a purchase is made. The rising popularity of online MCLE has not diminished live program attendance, however. Live programs have their following, especially for lawyers who want to network with other lawyers at live events.