From October 2006 to February 2007, lawyer Le Quoc Quan held a Reagan-Fascell Fellowship under the International Forum for Democratic Studies at the National Endowment for Democracy, where he conducted independent research on civil society. Upon his return home to Vietnam in March, he was arrested and charged under Article 79 of the Criminal Code, which proscribes “activities aimed at overthrowing the Government.” The National Endowment for Democracy calls upon the government of Vietnam to arrange for his immediate release.