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On what basis might one bestow the description, the “toughest GC position in the US”?

A journalist, writing for InsideCounsel, June 2006 at 70, ruminates that Charles James, the general counsel of Chevron “might have one of the toughest GC gigs in the nation.” James himself modestly disagrees, as he thinks the general counsel at Microsoft or Merck might deserve that unwanted sobriquet. The article…