This amicus curiae was filed by the Educational Testing Service (ETS) in the case of the United States of America and North Carolina Association of Educators v. North Carolina, which involved the validity of North Carolina's use of the National Teacher Examinations (NTE). The NTE, a battery of achievement tests designed to measure the academic preparation of students completing a teacher preparation program, is produced and administered by ETS. The issues before the court involved North Carolina's use of a cut-off score of 950 on the NTE to determine salary, retention, and tenure of teachers with substantial in-service experience, and to determine the certification of prospective teachers with no experience. It was charged that the NTE is biased against minority candidates, and the test's validity is limited. This brief argues that the NTE is carefully prepared to assess the academic preparation of prospective beginning teachers; that there are limited issues presented by the plaintiffs which should be decided; and that the ancillary issues raised by the plaintiffs concerning bias and validity of the NTE need not be decided by the court. The brief suggests that the court grant relief eliminating both the non-standard rating for experienced teachers and the cutting score of 950 for prospective teachers. (Author/JAC)