. >> general, can i ask you about reed elsevier? justice ginsburg suggested that the language was very similar in reed elsevier as it is here, but there are even further similarities. reed elsevier pointed out that the provision in question wasn't in title 28. here, too, it's not in title 28. in reed elsevier, it was pointed out that the provision there had numerous exceptions to it. here, too, there are numerous exceptions that we find that have been created by the courts over the years. in reed elsevier, the question was essentially one about timing. come to court after you file your registration. here, too, the question is one about timing. come to court after you make -- after you pay your taxes. so reed elsevier seems in multiple respects on all fours with this case. why is that wrong? >> i don't think so, justice kagan. repeating myself and i apologize, but -- we think the closest analogue is the very next provision in the united states code, 7422(a), which this court has held is jurisdictional, and is phrased in exactly the s

in reed elsevier, the question was essentially one about timing. come to court after you file your registration. here, too, the question is one about timing. come to court after you make -- after you pay your taxes. so reed elsevier seems in multiple respects on all fours with this case. why is that wrong? >> i don't think so, justice kagan. first, we think -- i guess i'm repeating myself and i apologize, but -- we think the closest analogue is the very next provision in the united states code, 7422(a), which this court has held is jurisdictional, and is phrased in exactly the same way as 7421(a). in fact, as i said, they were the same provision back in the earlier days. that's the closest analogue. this isn't -- and it's actually 7422 that's a statute that says do something first. but this - this statute is just a flat-out command that no suit shall be maintained to restrain - >> i take the point - >> the assessment or collection. >> but if you would comment on the similarities of reed elsevier to this case. how do you think it's different, if at

it's remarkably similar to the language in -- that was at issue in reed elsevier."no civil action for infringement shall be instituted." and that formulation, "no suit may be maintained," contrasts with of the tax injunction act, that says the district court shall not enjoin. that tax injunction act is the same pattern as 2283, which says "courts of the united states may not stay a proceeding in state court." so both of those formulas, the tia and the no injunction against proceedings in state court, are directed to "court." the anti-injunction act, like the statute at issue in reed elsevier, says "no suit shall be maintained," and it has been argued that that is suitor- directed in contrast to court- directed. >> right. well, i mean, this court has said several times that the tax injunction act was based on the anti-injunction act. you are quite right, the language is different. but we submit that the anti- injunction act itself, by saying that no suit shall be maintained, is -- is addressed to courts as well as litigants. i mean, after all, a case cannot go from