This amicus curiae was filed by the Educational Testing Service (ETS) in the case of the United States of America and South Carolina Education Association v. South Carolina, which involved the validity of South 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 education program, is produced and administered by ETS. The issues before the court involved the current use of the NTE in South Carolina based upon ETS's study of valid uses of the NTE; the cutting score previously used for certification of prospective teachers in South Carolina; and the use of the NTE for classifying and compensating experienced teachers. Section I of the brief describes the ETS validity study and the action taken by the State Board of Education in reliance upon the study. Section II proposes that the study provides a rational basis for certification decisions and that the State's action in reliance on the study meets the applicable constitutional and statutory standards. Section III evaluates technical criticisms of the study, and concludes that its design and execution both represent informed professional judgment by ETS personnel. The brief, in conclusion, recommends that the court decline to grant injunctive relief; or, if granted, to permit implementation of the certification system adopted by the state in June 1976. (Author/JAC)