"On 5-6 October 2009, the Office of the UN High Commissioner for Human Rights (OHCHR) held a consultation: "Operationalizing the framework for business and human rights presented by the Special Representative"... This essay will briefly consider Mr. Ruggie's remarks... Mr. Ruggie focused on two significant issues facing an effort to implement any system of governance of business enterprises at the supra-national level--(1) implementation challenges; and (2) alternative approaches. Mr. Ruggie identified five key challenges to the framework he has been developing.