In Harkness v. Unemployment Compensation Board of Review, 591 Pa. 543, 920 A.2d 162 (2007), the Pennsylvania Supreme Court held that in some circumstances a corporation can be represented by a non-attorney. The Supreme Court held that a non-attorney representing a corporation at an unemployment compensation proceeding was not engaged in the unauthorized practice of law. The Supreme Court explained that what constitutes the practice of law is to be determined on a case-by-case basis, noting that advancement of the public interest was the focus, "both in terms of the protection of the public as well as in ensuring that the regulation of the practice of law is not so strict that the public good suffers." Id. at 551, 920 A.2d at 167. An unemployment compensation proceeding is routine and resolves factual issues, as opposed to intricate legal questions. The proceedings are heard by a referee in an administrative hearing where the rules of evidence are relaxed, and there is no right to discovery. Accordingly, the Supreme Court concluded that a non-lawyer could represent a corporation in an unemployment proceeding.