On March 31, 1998, the World Trade Organization released a decision in a U.S.-initiated dispute involving access by Kodak to the photographic film and paper market in Japan. The WTO panel decided against the United States, but it did not address the more general question of market barriers in Japan. In the process of arguing its position at the WTO, Japan made representations that its market for photographic film and paper is open. Rather than appeal the case, one U.S. strategy is to hold Japan to its representations about the openness of its markets. In the 105th Congress, S.Con.Res. 88 (D'Amato) and H.Con.Res. 233 (Houghton) call on Japan to establish and maintain an open, competitive market for consumer photographic film and paper and other products that face similar market access barriers there, such as autos and auto parts, glass, and telecommunications. For details on the Kodak-Fuji Film market access issue, see CRS Report 96-297, The Kodak-Fuji Film Trade Dispute . For information on the WTO Dispute Settlement Mechanism, see CRS Report 94-627, World Trade Organization: Institutional Issues and Dispute Settlement . This report will be updated as events warrant.