Category: Blog Posts Page 52 of 75

By: Eli Hill,

Under the Americans with Disabilities Act (“ADA”), private entities, including businesses and nonprofits, must provide individuals with disabilities equal access to the services they offer.[1]  When a private entity uses a space for a public gathering with the purpose of education, sales, recreation, or presentation, that service is considered a public accommodation.[2]  Since the dawn of the digital age, the courts have continued to grapple with whether website operations should be classified as a “public accommodation”.[3]

The  courts have been hesitant to classify any business operation within cyberspace as a public accommodation.[4]  At the time the ADA was enacted in 1990, society was not as reliant on the Internet as today.[5]  Listed examples of public accommodations in the policy itself only include services that are offered within “brick and mortar” buildings.[6]  As businesses extended their brands and marketing online, disability advocates pressed the courts to reconcile this shift against the ADA language and intentions.[7]

To date, business websites are still not counted as a public accommodation on its own.[8] However, the courts have found that websites which offer information on physical store locations are a beneficial support for the public accommodation provided in-store.[9]  Expanding this idea further, the courts are exploring the idea of websites as gateways to actual business interactions.[10]   The intangible barriers are earning attention alongside the tangible ones and so committees are again pushing for a more progressive analysis of the ADA.[11]

As the construction of websites grossly outpaces physical space constructions, the obstructions in access to the digital portals require equal attention.[12]  More and more companies continue to abandon the physical storefront model of operation and build their corporate strategies around purely web-based models. [13]  Accordingly, a dynamic interpretation of the ADA against an equally dynamic digital sphere will remain a necessary platform of judicial review.[14]

[1] 28 C.F.R. § 35. 104, 35.160 Lexis (Feb. 2, 2018)

[2] See U.S. Dept. of Justice: Civil Rights Div., Title III Technical Assistance Manual III-1 (2000), https://www.ada.gov/taman3.html.

[3] See Joseph L. Friedman & Gary C. Norman, The Norman/Friedman Principle: Equal Rights to Information and Technology Access, 18 Tex. J. on c.l. & c.r. 47, 48-9 (Fall 2012).

[4] Id. at 47.

[5] See id.

[6] See 42 U.S.C.S. § 12181 Lexis (Feb. 26, 2018) (listing out examples of public accommodations).

[7] See, Rendon v. Valleycrest Prods., 294 F.3d 1279, 1283 (11th Cir. 2002).

[8] See e.g., Gomez v. Bang & Olufsen Am., Inc., No. 1:16-cv-23801 LEXIS, 15457 (S.D. Fla. Feb. 2, 2017).

[9] See Nat’l Fed’n of the Blind v. Target Corp., 452 F. Supp. 2d 946 (N.D. Cal. 2006); see also Earll v. Ebay, Inc., 599 F. App’x 695 (9th Cir. 2015) (finding that there must be a connection between the good and service offered by a public accommodation and an actual physical space).

[10] See generally Del-Orden v. Bonobos, Inc., 2017 U.S. Dist. LEXIS 209251 (S.D.N.Y. Dec. 20, 2017) (comparing “brick and mortar” walls and websites as offering boundaries from which customers operate within).

[11] See Magee v. Coca-Cola Refreshments USA, Inc., 833 F.3d 530 (5th Cir. 2016) (referencing the need to address website accessibility).

[12] See Bradley Allan Arehart & Michael Ashley Stein, Integrating the Internet, 83 Geo. Wash. L. Rev. 449, 454 (Feb, 2015).

[13] See Gil v. Winn-Dixie Stores, Inc., 257 F. Supp. 3d 1340 (S.D. Fla. 2017) (finding by jury trial for the first time the need to recognize websites as a nexus to the business operation).

[14] See id.

Image Source: https://www.shrm.org/resourcesandtools/hr-topics/talent-acquisition/pages/website-accessibility-disabilities-regulations-doj.aspx.

By: James DeSantis,

Thanks to its ubiquitous placement at the beginning and end of commercially released films, the criminality of copyright infringement is perhaps the most widely viewed criminal statute in the United States.[1] Despite its prominent place in the American psyche, the very existence of criminal liability for violating copyright laws is of relatively recent origin and one that has only ever been intermittently enforced.[2] It is important to distinguish between civil and criminal liability for copyright infringement. Civil action by one party against another is by far the most common way of protecting copyright infringement; whereas, criminal action for copyright infringement requires enforcement by government agencies and can lead to prison sentences.[3] Criminal liability for copyright abuse follows a consistent pattern of periodically raising fines and penalties while simultaneously lowering the legal thresholds for what types of activities constitute criminal infringement. Despite the increasingly stiffer penalties, expanded prosecutorial powers, and wide public awareness, criminal enforcement for copyright infringement is more honored in the breach than the observance− rarely does a breach result in serious liability.

Under the Constitution’s Copyright Clause, Congress has the power “to promote the Progress of Science and the useful Arts, by securing limited Times to Authors and Inventors the exclusive Right to their respective writings and Discoveries.[4]” The first criminal provision in U.S. copyright law was introduced 1897, which made it a misdemeanor for the “unlawful performances and representations of copyrighted dramatic and musical compositions” as long as the violation had been “willful and for profit.[5]” Until the implementation of criminal penalties for copyright infringement, copyright concerns were entirely a civil rather than a criminal matter.[6] The idea was that copyright violations were of private financial concerns rather then the purview of the criminal justice system, especially considering that many types of copyright infringement can be beneficial to the public.[7]

As the entertainment industry grew and the technology advanced, the financial gains for reproducing another’s successful work became an ever increasing concern and criminal penalties for copyright infringement were greatly expanded in 1909 with amendments to the Copyright Act.[8] The Act expanded the copyright law to include all copyrighted material and added penalties of up to one year in prison.[9] Over the years, Congress periodically raised the statutory punishment for criminal copyright violations. First, in 1948, fines were increased from $1,000 to $10,000 and again in 1976, fines were raised from $10,000 to $25,000.[10] However, it was not until 1982, coinciding with the advent of home video and compact cassettes, that congress made copyright infringement for audio and visual recordings a felony punishable by both a $250,000 fine and five years imprisonment.[11] While criminal punishments exist on paper, criminal charges for copyright infringement are rarely enforced.[12] Of the 3300 published copyright cases between 1948 and 1997, only sixty-eight (two percent) involved criminal charges.[13]

The first major court decision of the then nascent issue of mass online copyright infringement occurred in United States v. LaMacchia, which exposed the legal limitations the government faced in attempting to enforce criminal copyright laws in the digital age.[14] The 1994 ruling dismissed a criminal action against a 21-year-old MIT student who made copyrighted software freely available for download through his electronic bulletin board.[15] Despite causing over $1,000,000 in losses to the software companies, LaMacchia could not be prosecuted under the existing law because it could not be shown that he personally profited from the scheme.[16] In response to the Supreme Court’s ruling in LaMacchia, which became known as the “LaMacchia loophole,” Congress passed the No Electronic Theft Act (NET Act) in 1997, amending the language requiring “commercial gain” to any “receipt, or expectation of receipt, of anything of value.”[17]

Originally heralded as a major legislative victory for the software and entertainment industries, the NET Act has been so rarely enforced by the Department of Justice (DOJ) that is widely seen as a major disappointment.[18] Despite no shortage of potential prosecutions that could be pursued, the NET Act is emblematic of how the mere existence of a law on the books is of little value, if the law is never actually enforced.[19]

Out of frustration with the lack of governmental assistance in combating rampant online piracy, the entertainment and software industries have aggressively lobbied congress to expropriate federal funds to go after online pirates and to allow the DOJ file civil suits against suspected pirates.[20] These lobbying efforts have had limited legislative success, and the chance that an individual in the United States will be criminally accountable for engaging in online piracy is negligible.[21] For all the efforts lobbying the U.S. government to take a more aggressive role in prosecuting online copyright infringers under federal criminal statutes, the most noticeable effect is the use ever more intimidating anti-piracy banners shown before films and on the back of CDs.[22] While Hollywood and the music industry aggressively warn customers of the criminal repercussions for illegally sharing a copyrighted work, in reality, governmental enforcement against online copyright infringement is rare.[23] So rare that the next time you see the FBI’s intimidating warning label you should see it as a public service announcement on behalf of entertainment companies rather than a genuine threat of prosecution from the U.S.’s highest law enforcement agency.

[1]http://thefbiwarningscreens.wikia.com/wiki/The_FBI_Warning_Screens_Wiki. (Public interest in FBI Warning screens is so high that they have even developed their own cult following as evidenced by their own Wikia fan page.)

[2] Ting Ting Wu, The New Criminal Copyright Sanctions: A Toothless Tiger?, 39 IDEA: J.L. and Tech. 527, 529 (1999).

[3] 18 U.S. Code § 2319.

[4] U.S. Const. Art. I, § 8, cl. 8.

[5] Act of Jan. 6, 1897, ch. 4, 29 Stat. 481-82.

[6] See 17 U.S.C. §§ 502-505.

[7] Geraldine Szott Moohr, The Crime of Copyright Infringement: An Inquiry Based on Morality, Harm, and Criminal Theory, 83 B.U. L. Rev. 731, 733 (2003). (Copyright laws have always been a balance between private interests and benefits that accrue to the public).

[8] The Criminalization of Copyright Infringement in the Digital Age, 112 Har. L. R. 7, 1705, 1707 (1999).

[9] The Copyright Act of 1909 § 28.

[11] Piracy and Counterfeiting Amendments Act of 1982, Pub. L. 97-180, 96 Stat. 91

[12] Lawrence M. Solan, Statutory Inflation and Institutional Choice, 44 Wm. & Mary L. Rev. 2209 (2003).

[13] Ting Ting Wu, The New Criminal Copyright Sanctions: A Toothless Tiger?, 39 IDEA 527, 529 (1999).

[14] United Sates v. LaMacchia, 871 F. Supp. 535 (D. Mass 1994).

[15] Benj Edwards, The Lost Civilization of Dial-Up Bulletin Board Systems, The Atlantic (Nov. 4, 2016) (Bulletin Board Systems (BBS) were a precursor to the modern Internet in which individuals had their own servers that could be accessed remotely. The advent of Internet service providers and dial up modems destroyed the market for BBS in matter of months).

[16] United States v. LaMacchia, 871 F. Supp. at 542.

[17] No Electronic Theft Act (NET Act) Pub. L. 105-147. 111 Stat. 2678 (1997). (Making it a crime to willfully upload copyrighted materials to the Internet regardless of presence or absence of a profit motive).

[18] See Virginia Man Sentenced for Violation of the “No Electronic Theft” (NET) Act for Unlawful Distribution of Software on the Internet (March 3, 2000); First Criminal Copyright Conviction Under the “No Electronic Theft” (NET) Act for Unlawful Distribution of Software on the Internet, https://www.justice.gov/archive/opa/pr/1999/August/371crm.htm.

[19] Stuart Biegel, Beyond our Control?: Confronting the Limits of our Legal System in the Age of the Internet, The MIT Press, (2013).

[20] See The Protecting Intellectual Rights Against Theft and Expropriation Act of 2004 (Aptly titled the PIRATE Act, the bill would allow federal prosecutors to file civil lawsuits against suspected copyright infringers and would allocate federal funds specifically for combating online piracy.); see also, Internet Property Enforcement Act of 2007, S.2317; Contra, Prioritizing Resources and Organization for Intellectual Property Act of 2008 (PRO-IP Act of 2008, H.R. 4279)

[21] See Kevin Paulson, Guilty Verdict in First Criminal Trial for Online Music Piracy, WIRED, May 23, 2008 https://www.wired.com/2008/05/guilty-verdict/.

[22] https://www.iprcenter.gov/ip-theft/digital-ip-theft.

[23] Ting Ting Wu, The New Criminal Copyright Sanctions: A Toothless Tiger?, 39 IDEA: J.L. and Tech. 527, 529 (1999).

Image Source: https://www.hollywoodreporter.com/thr-esq/fbi-anti-piracy-warnings-over-time-pictures-322495.

By: Daria Ivanova,

The field of environmental conservation has never been the most technologically advanced one, partially because of the lack of funds and partially because of the lack of motivation on behalf of the conservation community.^[1] This, generally, old-school community has been attempting to solve main problems by extending protected areas and investing in ecosystem services, such as water purification.^[2] However, a younger generation of conservation actors believes that this is not enough to address exponentially growing and ever-changing environmental problems.^[3] Alex Dehgan and Paul Bunje perceived this problem in the environmental conservation field and seized the opportunity.^[4] They figured that if technology can help solve wildlife extinction, why can’t they use it?^[5] In fact, they believe in the power of technology to the extent that they claim that “[w]e’ll need a tribe of hackers, makers, economists, engineers, and entrepreneurs to help a sometimes technophobic conservation community reverse the sixth mass extinction.”^[6]

A device Conservation X Labs has been developing is a child of the problem it is being created to eradicate. Conservation X Labs was awarded $159,000 to work on the development of the device which could analyze the origin and the species of timber imports.^[7] These funds were obtained from a giant lumber company, Lumber Liquidators, which violated the Lacey Act protecting wildlife and plants from illegal harvesting.^[8] The investigation purporting to uncover those illegal activities spanned for several years.^[9] The Environmental Investigation Agency agents have been traveling from across the world to China to find out who smuggled Russian timber there.^[10] This all could have been prevented if the law enforcement personnel had a device which could identify the type of timber smugglers were attempting to illegally introduce into the market.^[11] Now it seems to be closer to reality.

One of the reasons why the scientific community has not used the technology that much was the price. However, nowadays, it is becoming more accessible. For example, in Biodiversity Conservation All. v. United States Forest Serv., 765 F.3d 1264 (10th Cir. 2014), Biodiversity Conservation Alliance contested the United States Forest Service’s decision to change one of Wyoming’s trails. The Forest Service used satellite imagery to identify the number of fens which could be affected by the change and the plant life in fens.^[12] Even though the technology in that case did not necessarily work to preserve the environment, the Conservation X Labs’ device promises incredibly beneficial uses.

The Conservative X device looks like a video game joystick, but it is actually a hand-held scanner which is not as expensive as similar modern prototypes.^[13] The system behind using the scanner is following. Living cells have a part which the scientists call a “barcode.”^[14] The “barcode” is a sequence of DNA located in mitochondria which has 648 base-pair region.^[15] The University of Guelph in Ontario contains the Barcode of Life Database which has the mitochondrial DNA of 275,000 species.^[16] Using this database, scientists can identify the sequences specific to a certain species, then synthesize it and freeze-dry onto reference chips.^[17] The people using the scanner would insert a small piece of a ground-up tissue mixed with a drop of water in a one of two kinds of microfluidic chips.^[18] One type of chip would simply say yes or no, whereas the other type could compare to up to several references chips.^[19] Introducing this type of device would not only offer the enforcement agencies a way to efficiently prevent numerous violations, but would it also encourage the innovation in the environmental enforcement field. By showing that technology can be both affordable and beneficial for protecting the environment, Conservation X Labs and other similar entities do way more than just creating technological help for the conservation community. It forces a strong culture clash within the whole community.^[20]

^[1] Scott Dance, Concerned Activists, Lawmakers Waiting for Delayed Data on Maryland’s Environmental Law Enforcement, TheBaltimoreSun.com (Oct. 31, 2016 06:42PM), www.baltimoresun.com/features/green/blog/bs-md-environmental-enforcement-20161027-story.html.

^[2] Richard Leakey, Conservation Alone ‘Is Not Enough’, BBCNews (Sep. 10, 2007), http://news.bbc.co.uk/2/hi/science/nature/6983914.stm.

^[3] Eillie Anzilotti, Bold Conservation Ideas Go from Concept to Reality on This New Collaboration Platform, Fast Company.com (Sep. 20, 2017), https://www.fastcompany.com/40468095/bold-conservation-ideas-go-from-concept-to-reality-on-this-new-collaboration-platform.

^[4] Virginia Gewin, A Handheld DNA Scanner Could Crack Down on Wildlife Identity Theft, The Atlantic.com (Feb. 9, 2018), https://www.theatlantic.com/technology/archive/2018/02/conservation-tech/552779.

^[5] Julia Luthringer, Who Are Tomorrow’s Leaders in Ocean Conservation?, Huffpost.com: The Blog (Sep. 15, 2016, 03:17PM),  https://www.huffingtonpost.com/conservation-x-labs/who-are-tomorrows-leaders_b_12031010.html.

^[6] Gewin, supra note 4.

^[7] Id.

^[8] Kiken v. Lumber Liquidators Holdings, Inc., 155 F. Supp. 3d 593 (E.D. Va. 2015).

^[9] Jani Actman, From Trees to Tigers, Case Shows Cost of Illegal Logging, National Geographic.com (Nov. 10, 2015), https://news.nationalgeographic.com/2015/11/151110-timber-russian-far-east-illegal-logging-siberia.

^[10] Id.

^[11] Ian Evans, Deeply Talks: Fighting Illegal Fishing With Big Data, Robots and A.I., NewsDeeply.com (Feb.14, 2018), https://www.newsdeeply.com/oceans/articles/2018/02/14/deeply-talks-fighting-illegal-fishing-with-big-data-robots-and-a-i.

^[12] Biodiversity Conservation All. v. U. S. Forest Serv., 765 F.3d 1264 (10th Cir. 2014).

^[13] Gewin, supra note 4.

^[14] Nick Lane, Biodiversity: On the Origin of Bar Codes, Nature.Com (Nov. 18, 2009), www.nature.com/news/2009/091118/full/462272a.html.

^[15] Nicola Davis, How DNA Barcodes Can Beat the Wildlife Traffickers, The Guardian (Aug. 16, 2014), https://www.theguardian.com/science/2014/aug/16/biodiversity-determined-by-difference-in-dna-barcode.

^[16] Sue Palminteri, Portable DNA Analysis Tool Identifies Species on Site to Help Combat Wildlife Crime, Mongabay (Dec. 6, 2017), https://news.mongabay.com/wildtech/2017/12/portable-dna-analysis.

^[17] Gewin, supra note 4.

^[18] Id.

^[19] Id.

^[20] Id.

Image Source: https://www.theatlantic.com/technology/archive/2018/02/conservation-tech/552779/.

By: Helen Vu,

On February 6, 2018, SpaceX launched its first Falcon Heavy rocket into outer space with a Tesla Roadster attached to it and a spacesuit-wearing mannequin named “Starman” strapped into the car’s driver’s seat.[1] The rocket and the Roadster launched out of Kennedy Space Center at Cape Canaveral, Florida, and are expected to eventually reach Mars after entering into orbit around the sun.[2] This feat was groundbreaking, not only because it involved a convertible hurtling through outer space, but also because it was a private spaceflight company rather than a national government agency that funded the development of the world’s most powerful rocket.[3]

When it comes to competition in the field of space exploration, most people think of the post-Cold War Space Race between the United States and the Soviet Union.[4] At the start of the 1950’s, people around the world watched carefully to see which country would beat the other to the final frontier of outer space.[5] After the United States effectively won the race by putting the first man on the moon in 1969, the public’s interest in space travel slowly waned.[6] However, at the beginning of the 21st century, a handful of private entities entered the realm of space exploration and began competing amongst themselves to be the company that revolutionizes space travel.[7]

This privatization of space exploration and increased competition will inevitably lead to faster development of technology at lower costs. However, such rapid growth also means that our current body of space law will quickly become outdated and fail to meet the regulatory needs of a newly privatized market. The Outer Space Treaty, an agreement established in 1967 by the United Nations, provides a framework for governance of the shared use of outer space.[8] It was modeled after other treaties dealing with maritime activities and the exploration of Antarctica, and sought to mitigate any risks that accompany the study of new frontiers.[9] Under the Treaty, a state is internationally liable for any damage caused by a space object launched from its territory, even if the space object was operated by a private entity.[10] While this policy leads to a clear demarcation of state liability, imposing liability upon a country merely because it allows a company to launch an object into space from within its borders does not seem like an equitable or feasible solution. Holding a country accountable for its own actions in outer space is drastically different from holding a country accountable for the actions of a private entity. Further questions arise when companies someday facilitate space travel for private individuals who might perform acts while in space that lead to damage. Must a country’s economy face the consequences of what would likely be the monstrously expensive actions of a single person? How could we reasonably expect an individual to pay for the high cost of damages done in outer space?

A possible solution lies in the combination of insurance and indemnification policies. Before Russia’s Federal Space Agency sent the world’s first space tourist, Dennis Tito, into outer space in 2001, the country took out a $100,000 insurance policy on Tito.[11] An additional step could be to contract with private spaceflight companies in advance to ensure that they reimburse the state for any damages that may arise out of the launch.[12] By taking out insurance policies on space flights in addition to entering into indemnification contracts with the countries they launch out of, private companies may be able to mitigate some of the risk that arises out of their space exploration.

Before the launch of the Falcon Heavy, Elon Musk, the CEO of SpaceX, stated that there was “an extremely tiny” chance that the rocket could hit Mars.[13] Although the possibility of that happening is almost zero, we will still cross our fingers and hope that Starman and his Roadster don’t cross paths with any litigation-happy extraterrestrial creatures on his journey.

[1] See Tariq Maliq, Success! SpaceX Launches Falcon Heavy Rocket on Historic Maiden Voyage, Space.com (Feb. 6, 2018), https://www.space.com/39607-spacex-falcon-heavy-first-test-flight-launch.html.

[2] See id.

[3] See Nell Greenfieldboyce, SpaceX Set To Launch World’s Most Powerful Rocket, The Two-way (Feb. 5, 2018), https://www.npr.org/sections/thetwo-way/2018/02/05/582464054/spacex-set-to-launch-worlds-most-powerful-rocket.

[4] See The Space Race, History.com (2010), http://www.history.com/topics/space-race.

[5] See id.

[6] See id.

[7] See Timeline: 50 Years of SpaceFlight, Space.com (Sept. 28, 2012), https://www.space.com/4422-timeline-50-years-spaceflight.html.

[8] Monica Grady, Private companies are launching a space race – here’s what to expect,

[9] See id.

[10] Dr. Frans G. von der Dunk, Passing the Buck to Rogers: International Liability Issues in Private Spaceflight, 86 Neb. L. Rev. 400, 409 (2007).

[11] See id.

[12] See id.

[13] See Loren Grush, Elon Musk’s Tesla Overshot Mars’ Orbit, but it Won’t Reach the Asteroid Belt as Claimed, The Verge (Feb. 8, 2018), https://www.theverge.com/2018/2/6/16983744/spacex-tesla-falcon-heavy-roadster-orbit-asteroid-belt-elon-musk-mars.

Image Source:  https://fsmedia.imgix.net/69/ca/9e/05/611b/47ea/8580/49057a4a632d/spacex-says-by-late-next-year-the-falcon-heavy-will-launch-two-astronauts-to-the-moon.pngrect=0%2C61%2C1103%2C368&dpr=2&auto=format%2Ccompress&w=650.

By: James DeSantis,

The battle against Internet piracy has been raging for almost two decades. The release of Napster in June 1999 marked the beginning of a Golden Age of peer-to-peer file sharing where billions and billions of dollars of copyrighted materials were plundered with near impunity. Blindsided by a precipitous drop in album sales, the Recording Industry Association of America (RIAA), a trade organization representing the recording industry, has consistently tried to stop the hemorrhaging of industry revenue by any means necessary.

Initially spending years focusing their legal efforts at shutting down P2P file-sharing services, legal action against individuals, or end-users, engaging in the illegal sharing of copyrighted material began en masse in 2003 when the RIAA filed hundreds of lawsuits against individuals identified to have committed Internet piracy.[1] Over the next five years, the RIAA would go on to file more than 30,000 lawsuits targeting alleged copyright infringers comprising a significant percentage of all intellectual property litigation in the country.[2] Aimed at striking fear into the heart of would-be downloaders, the RIAA lawsuits relied on filling mass “John Doe” copyright infringement lawsuits listing hundreds of defendants at a time.[3]

Mass John Doe lawsuits are an ingenious legal strategy utilized almost exclusively to prosecute copyright infringement. First the plaintiff identifies the unauthorized downloader’s Internet protocol address (IP address) and then files hundreds, sometimes thousands, of lawsuits against John Doe, or an otherwise unknown defendant. The plaintiff is able to file a single lawsuit against multiple defendants by invoking Rule 20 of the Federal Rules of Civil Procedure for the permissive joinder of parties.[4] After the lawsuits has been filed, the plaintiff asks for a court ordered subpoena compelling the Internet service provider (ISPs) to provide individual account holder information matching the IP address.[5] Once the ISPs turn over the individual user’s relevant identifying information (i.e. their name and address), the RIAA uses the threat of litigation to extract a settlement from the user.[6] The RIAA’s end user lawsuits were usually settled for $2500; the intrepid individuals who tried fight the RIAA lawsuits were highly publicized for subjecting low level offenders to lengthy court battles and excessive damages.[7]

Although it is impossible to determine the long term net effect of RIAA’s mass fillings of lawsuits against individual music fans had in tackling the issue of music piracy, one indication that the policy was of limited success is the RIAA’s decision to abandon the strategy in 2008 for other approaches.[8]

One of the RIAA’s more recent concerted efforts to tackle piracy, known as the “six strikes initiative” or Copyright Alert System, involved a cooperation between the five biggest ISPs and copyright owners that entailed sending warning notices to individual customers caught violating copyrights. The more strikes a customer receives the more threatening the letters become with the fifth and sixth letters alerting the copyright offender that his internet speed will be temporarily reduced to 256kpbs for two to three days as punishment.[9] In total, the “six strikes policy” sent out 13 million copyright notices with offenders becoming less and less likely to offend with every subsequent notice. Despite the promising data, the Copyright Alert System lasted four years before being shelved in early 2017.[10]

As of 2018, the RIAA is does not have any plans to go after individual copyright infringers instead focusing their efforts on prosecuting torrent sites and their administrators. It seems that the RIAA has learned that just because a battle should be fought does not mean that it can be won.

[1] David Kravets, File Sharing Lawsuits at a Crossroads, After 5 Years of RIAA Litigation, Wired, Sept. 4, 2008, https://www.wired.com/2008/09/proving-file-sh/.

[2] Matthew Sag, IP Litigation in United States District Courts: 1994 to 2014 (January 14, 2016), 101 Iowa L. R. 1065 (2016).

[3] Id. at 113.

[4] Fed. R. Civ. P. 20(a)(2).

[5] Felicia Boyd, The End of John Doe Copyright Suits in the US?, Intellectual Property Magazine (Sept. 2012), http://www.btlaw.com/files/Uploads/Documents/Publications/028-029_Sept_2012-FO.pdf.

[6] Sean B. Karunaratne, e-Case against Combating BitTorrent Piracy through Mass John Doe Copyright In infringement Lawsuits, 111 Mich. L. Rev. 283 (2012).

[7] Jemima Kiss, BitTorrent: Copyright Lawyers Favorite Target Reaches 200,000 Lawsuits, The Guardian (Aug. 9, 2011).

[8] Sarah McBride & Ethan Smith, Music Industry to Abandon Mass Suits; The Wall Street Journal (Dec. 19, 2008).

[9] Adrianne Jeffries, Internet Providers Launch Controversial Copyright Alert System, Promise ‘Education’ Over Lawsuits, The Verge (Feb. 25, 2013) (256kbps is a little bit faster then typical dialup speed).

[10] Corinne Reichert, Copyright Infringement Alert System Abandoned in US, The Verge (Jan. 30, 2017).

Image Source: http://www.zdnet.com/article/censorship-creep-pirate-bay-block-will-affect-one-third-of-uk/.

By: Seth Bruneel,

About ten years ago someone had an idea. It is doubtful that patent protection is available for the idea, but protection from patents was the idea. Several major US companies got together to find ways to mitigate the risk of facing off against non-practicing entities (“NPE”), also termed “Patent Trolls.” [1]  The answer to their problems came about as Allied Security Trust.

Allied Security Trust (“AST”) is a consortium of companies that pool resources to share costs in acquiring and licensing patents. [2] The companies pool their money in AST, which in turn buys patents on the open market. [3] AST then resells the patents on the condition that the buyer grants a free license to all of the members of the consortium. [4]  This allows a member-company to have access to more patents at less cost than it would have access to on its own and worry less about infringing on patent owner’s rights, specifically, those rights owned by a NPE. [5]

Earlier this month, AST, which now includes Google and Ford Motor Company, purchased another 70 patents. [6]  Perhaps taking a page out of Costco Wholesale’s book and “buying in bulk,” AST secured the patents for a total cost of $2.5 million.[7]  The price of a patent ranted from $25,000 to $390,000, putting the average price of a single patent at $128,000. [8]

One way AST is able to keep prices down is the way the program is structured. Patent owners submit a proposal to sell their patent to the group through AST at a take-it-or-leave-it price.[9]

AST turned this practice into an annual event last year with the title “Industry Patent Purchase Program” (“IP3”).[10]  The program was an initial success but was adjusted this year to limit the participants to AST “members only” and narrowed the scope of the patented technologies up for sale to: (1) Internet of Things; (2) Wireless; (3) Content Delivery; (4) Networking; and (5) Communications. [11]

It will be interesting to see if this idea catches on in other areas of technology and if so, what the USPTO’s response to this “patent-sharing” idea.

[1] ABOUT US, http://www.ast.com/about-us/asts-mission/ (last visited Feb. 15, 2018).

[2] SERVICES, http://www.ast.com/services/ (last visited Feb. 15, 2018).

[3] Id.

[4] Malathi Nayak, Google, Ford, Others Complete Defensive Patent Group Buy, PATENT TRADEMARK & COPYRIGHT J. (Feb. 9, 2019), https://www.bloomberglaw.com/document/X7OEB2CG000000?emc=bnaptcj%3A11&jcsearch=bna%2520000001616bfad7b6a1eb6fff20b70000#jcite (last visited Feb. 15, 2018).

[5] See ABOUT US, supra note 1.

[6] See Nayak, supra note 4.

[7] Id.

[8] Id.

[9]  See Nayak, supra note 4.

[10] Announcing IP3 – The First Industry Patent Purchase Program, (May 18, 2016), http://www.ast.com/news_article/calling-patent-owners-google-ibm-ford-cisco-leading-global-companies-want-buy-patents-new-ip3-purchase-program-ast/ (last visited Feb. 15, 2018).

[11] Gene Quinn, AST Acquires 70 Patent Assets in Fixed Price, Fixed Term Buying Program, IPWATCHDOG (Feb. 13, 2018), http://www.ipwatchdog.com/2018/02/13/ast-acquires-70-patent-assets-fixed-price-fixed-term-buying-program/id=93662/ (last visited Feb. 15, 2018).

Image Source: https://infograph.venngage.com/p/90715/what-are-patents.

By: Eli Hill,

During the  opening ceremonies of the 2018 Winter Olympics, people watching around the world gave witness to a world record being broken.  In the largest display of its kind, over 1,218 drones took to the night skies of Pyeongchang for a large-scale synchronized performance.[1]  The mechanized fleet put on a colorful, LED dotted and darting spectacle, eventually forming the shape of a swaying snowboarder and transitioning into the iconic image of the interlocking Olympic Rings.[2]

Orchestrated by Intel, these drones were part of the company’s “Shooting Star” platform, a project that had been building to this Pyeongchang moment for many years.[3] After launching an initial synchronized swarm of 100 drones with four controlling pilots from a test site in 2015, Shooting Star capabilities grew to handle over 500 drones with just one controlling pilot only a year later in 2016.[4]  Most notably, Intel brought its Shooting Star show into the public’s direct line of sight during Lady Gaga’s 2017 Super Bowl halftime show when a 300 drone fleet converged to form the image of a fluttering American Flag above the NRG stadium.[5]

While ‘drone shows’ represent a relatively new sort of spectacle, the Olympics have been slowly incorporating drones within their broadcast productions for many years.[6]  During the 2014 Winter Olympics in Sochi, Russia, the Olympic Broadcasting Services (“OBS”) used drone cameras to film freestyle skiing and snowboarding, events which in of themselves also embodied the idea of a fresh spectacle. [7] Able to capture thrilling moments from dynamic viewpoints, the OBS went on to use 50 high speed drone cameras at events, for athlete introductions, and during the presentation of awards at the 2016 Summer Games in Rio.[8]

As global broadcasting platforms continue to experiment with drone capabilities in the realm of entertainment, traditional caution and safety concerns over commercial drone use remain.[9]   Recent risk assessments claim that the majority of drone-related accidents stem from faulty tech rather than human operating error.[10]  Given that drone show choreography puts greater reliance on the automated programming, those overseeing mass events remain appropriately cautious.  Broadcasts of both Shooting Star displays at the Super Bowl and at Pyeounchang were prerecorded, as concerns over weather conditions, fleet visibility, and the assured safety of a live audience forced Intel to adopt a more conservative roll out.[11] Currently, Intel has no plans to sell models of its Shooting Star drones, but given the popularity of their displays, it’s merely a matter of time until the general public has access to tech capable of creating individualized spectacles.[12]

While many countries have taken steps to regulate civilian drone use within the airspace of their own borders, international standards and policies still lack definitive traction.[13]  The United Nations continues to advocate strongly for the registration of all commercial drones within a national database.[14] In the last year, member states of the International Civil Aviation Organization (“ICAO”) included drone management guidelines as an action item at their annual symposium.[15]  Despite the championing recognitions, the popularity fueling the drone culture is clearly outpacing any policy being designed to regulate it.

By 2024, the global market growth of drones is projected to reach upwards of $13 billion.[16]  The current lag in standardized regulations allow drone manufactures to occupy a unique position of influence, especially at high profile, multinational sporting events.  Da-Jiang Innovations (“DJI”), the drone manufacturer responsible for over half of all small civilian drone sales, has capitalized on the absence of explicit international regulations by supplying the protections against its very own products.[17] Responding to concerns from South Korean authorities over civilian piloted drones, DJI developed a software patch that temporary prevents all drones of DIJ design from operating within protected Olympic event areas.  Providing such a service is not unusual for DIJ, as they have instituted these self-regulations at U.S. political party conventions, the G7 Summit in Japan, and the 2016 Euro football tournament in France.[18]

In addition to their record-breaking display at the Opening Ceremonies, Intel plans to deploy its light-show legions nightly in Pyueongchang. [19] Squadrons of 300 drones will animate the airspace above Olympic medal presentations for the duration of the Winter Games.[20]  As these displays continue to showcase the wonders of drones, not just their weaponing, their commercial popularity will remain on the rise.  The continued spectacle will push international policy and put pressure on international policy to keep pace.

[1] See Brian Barrett, Inside the Olympics Opening Ceremony World-Record Drone Show, Wired, (8:00pm on Feb. 9, 2018), https://www.wired.com/story/olympics-opening-ceremony-drone-show/.

[2] See id.

[3]See Jacob Brogan, How Intel Lit Up the Super Bowl with Drones and Why, Slate, (10:25am on Feb. 6, 2017),  http://www.slate.com/blogs/future_tense/2017/02/06/how_the_intel_drones_at_the_lady_gaga_super_bowl_halftime_show_worked.html.

[4] See id.

[5] See Nathan Bohlander, Here Come the Drones- And the Legal Headaches, Law360 (Feb. 23, 2017)(describing drone show in connection to Super Bowl halftime).

[6] See generally, Waibel, M., Keays, B., Augugliaro, F.. Drones shows: Creative potential and best practices, Verity Studios (Jan. 2017), https://veritystudios.com/whitepaper/#appendix.

[7] See Zehra Betul Ayranci, Use of Drones in Sports Broadcasting, 33 Ent. & Sports Law. 79 (2017).

[8] See id. at 80.

[9] See Waibel, supra note 6.

[10] See id.

[11] See Barrett, supra note 1.

[12] See Dieter Bohn, Intel’s new Shooting Star Mini drones can make indoor light shows, The Verge (11:15pm on Jan. 8, 2018), https://www.theverge.com/2018/1/8/16866880/intels-shooting-star-mini-drones-indoor-light-shows-ces-2018.

[13]  See Ayranci, at 90.

[14] See id.

[15] See Philbin, Anthony, ICAO to Seek Global Traffic Management Solutions for Drone Operations, ICAO.int (May 15, 2017, Montreal), https://www.icao.int/Newsroom/Pages/ICAO-to-seek-global-traffic-management-solutions-for-drone-operations.aspx.

[16]  Ayrunci, at 90.

[17] See Malek Murison, DJI Puts No-Fly Zones in Place for South Korea Winter Olympics, DroneLife Blog (Feb. 7, 2018), https://dronelife.com/2018/02/07/dji-no-fly-zones-south-korea-winter-olympics/.

[18] See id.

[19] See Brian Barrett, Inside the Olympics Opening Ceremony World-Record Drone Show, Wired, (8:00pm on Feb. 9, 2018), https://www.wired.com/story/olympics-opening-ceremony-drone-show/.

[20] See id.

Image Source: https://www.businesswire.com/news/home/20180209005739/en/Intel-Drone-Light-Show-Breaks-Guinness-World.

By: Kaley Duncan,

“Alexa tell me a joke.”

“I wondered why the baseball was getting bigger…and then it hit me.”[1]

From dad jokes, to making a playlist on Spotify, and even dimming the lights in your home, Amazon’s Alexa can assist you with pretty much anything.[2]

Personal assistant devices like Alexa, Siri, and Google Home are the new consumer fad. While many competitors such as Google Home have hit the market, Alexa seems to be the preferred device.[3] As of May 2016, less than one year after its release, close to 2,000,000 Alexas had been sold.[4] According to Amazon, Alexa has 10,000 skills available and “the more customers use Alexa, the more she adapts to speech patterns, vocabulary, and personal preference.”[5] With Alexa’s pairing device, Echo Dot, you can now have a voice controlled personal assistant in every room of your house.[6]

Because these devices are such an integral part of consumers’ lives, privacy is a growing concern. Much like Apple’s feud with the F.B.I. over access to the San Bernadino shooter’s iPhone, many tech companies have been standing up to the government and refusing to hand over consumer data.[7] In May 2015, big companies including Facebook, Dropbox, Google, Apple, Twitter, and Yahoo signed a letter addressed to former President Obama urging him to back their privacy stances.[8] This concern was soon shared by Amazon’s legal team when Benton County prosecutor, Nathan Smith, demanded information from Alexa in regards to a murder investigation.[9] In a memorandum to the Circuit Court of Arkansas, Amazon stated that “[Alexa’s] interactions may constitute expressive content that implicates privacy concerns and First Amendment Protections.”[10] Amazon has since given up its legal battle as the murder suspect voluntarily gave up information regarding his Echo devices.[11] However, this suit brings up an interesting issue: Is Amazon’s novel approach just a legal hail marry used to ensure consumer privacy, or should artificially intelligent (“AI”) machines such as Alexa be entitled to First Amendment protections?

Toni Massaro and Helen Norton’s study suggests that they might be.[12] Some AI machines are so removed from human interference, that arguments for granting them first amendment rights may not be as absurd as they sound.[13]

“Modern computers can gather create, synthesize, and transmit vast seas of information as they become more ‘human-like’…Such computer speakers are increasingly self-directed or ‘autonomous’…[S]peech they produce is theirs, not ours, with no human creator or director in sight.”[14]

According to Massaro and Norton, current free speech ideology does not limit freedom of speech protection to only humans.[15] This may be true of even the least advanced artificially intelligent machines. Free speech theories tend to focus more on the expression of the speech rather than the speaker.[16] Therefore enabling extension of the right to not only humans, but anything that can produce a relevant expression via speech.[17]

Not surprisingly, many are opposed to extending constitutional rights to machines.[18] Conjuring images of a machine world gone mad, reminiscent of the movie The Terminator, might lead some to be resistant. However, Massaro and Norton suggests a compromise; Rather than give AI machines primary rights, leave the primary rights to humans and give some sort of secondary rights to machines.[19] That way, if information distributed by machines is not beneficial to humans, it may be judicially restricted.[20]

As AI machines are quickly advancing, this debate cannot be pushed aside much longer. It may not be long until your Alexa is granted constitutional rights too.

[1] TJ Farhadi, 11 Dad Jokes that Prove Alexa is Funnier than Siri, Review Weekly Blog (Feb. 3, 2016) https://www.review-weekly.com/blog/technology/11-dad-jokes-from-amazon-echo/.

[2] Grant Clauser, What is Alexa? What is the Amazon Echo, and Should You Get One? NY TIMES: The Wirecutter (Feb. 10, 2017), http://thewirecutter.com/reviews/what-is-alexa-what-is-the-amazon-echo-and-should-you-get-one/; see also TJ Farhadi, 11 Dad Jokes that Prove Alexa is Funnier than Siri, Review Weekly Blog (Feb. 3, 2016) https://www.review-weekly.com/blog/technology/11-dad-jokes-from-amazon-echo/.

[3] Andrew Gebhart, Google Home vs. Amazon Echo: Alexa Takes Round 1, CNET (Feb. 2, 2017), https://www.cnet.com/news/google-home-vs-amazon-echo/.

[4] BI Intelligence, How Many Amazon Echo Smart Home Devices have been Installed?, Business Insider (Jun. 7, 2016, 8:00PM), http://www.businessinsider.com/how-many-amazon-echo-smart-home-devices-have-been-installed-2016-6.

[5] Amazon Developer, https://developer.amazon.com/alexa (last visited Mar. 12, 2017).

[6] Amazon Prime, https://www.amazon.com/Amazon-Echo-Dot-Portable-Bluetooth-WiFi-Speaker-with-Alexa/b?node=14047587011 (last visited Mar. 12, 2017).

[7] Arash Khamooshi, Breaking Down Apple’s iPhone Fight with the U.S. Government, NY Times (Mar. 16, 2016) https://www.nytimes.com/interactive/2016/03/03/technology/apple-iphone-fbi-fight-explained.html?_r=0.

[8] Hope King, Tech Companies Standing up to Government Data Requests, CNN Tech (June 18, 2015, 6:06PM), http://money.cnn.com/2015/06/18/technology/data-protection-government/.

[9] Eric Ortiz, Prosecutors Get Warrant for Amazon Echo Data in Arkansas Murder Case, NBC News (Dec. 28, 2016, 2:13PM), http://www.nbcnews.com/tech/internet/prosecutors-get-warrant-amazon-echo-data-arkansas-murder-case-n700776.

[10] Mem. ex rel Amazon’s Mot. to Quash Search Warrant at 1–2, Ark. v. Bates, No. CR-2016-370-2 (Benton Co. Cir. Ct. Ark. 2017), available at https://www.documentcloud.org/documents/3473747-Amazon-Memorandum-Seeking-to-Quash-Echo-Search.html#document/p1.

[11] Rich McCormick, Amazon Gives up Fight for Alexa’s First Amendment Rights after Defendant Hands Over Data, The Verge (Mar. 7, 2017, 1:20AM) http://www.theverge.com/2017/3/7/14839684/amazon-alexa-first-amendment-case

[12] Toni Massaro & Helen Norton, Siri-ously? Free Speech Rights and Artificial Intelligence 110 Nw. Law Rev. 1169, 1173 (2016) (explaining that artificially intelligent machines might be entitled rights to freedom of speech)

[13] Id. at 1169.

[14] Id. at 1172.

[15] Id. at 1177.

[16] Toni Massaro & Helen Norton, Siri-ously? Free Speech Rights and Artificial Intelligence 110 Nw. Law Rev. 1169, 1175–78 (2016) (explaining that artificially intelligent machines might be entitled rights to freedom of speech)

[17] Id.

[18] Id. at 1774.

[19] Id.

[20] Id.

Image Source: https://lawstreetmedia.com/blogs/technology-blog/alexa-first-amendment/.

By: Lilias Gordon,

You are walking out the door in a rush so you do a quick self pat-down search — phone, wallet, keys — good to go. Most of us take our phones everywhere. Phones keep our calendars, emails, photos, text messages, and just about everything else. We download applications that collect even more information. How much of that massive amount of information is private? Not much. First, there are multiple ways your phone can be tracked by both your service provider and the government. Second, there is a limited expectation of privacy over the content of a cell phone if a person is stopped by police officers. Third, we self-disclose massive amounts of information about ourselves over social media that can go to third parties or the government. So, when you pat down your pockets to make sure you don’t go anywhere without your phone, perhaps you are searching yourself so that nobody else has to.

Cell phones can be tracked by the government pulling information from your service provider. A person places or receives a call on their cell phone, which connects to the nearest cellular tower transmitting information through the strongest signal.^[1] Service providers keep records about how long the call lasted, between whom, and most importantly the location of the call based on the tower that was being used.^[2] This is how the government can get a hold of cell-site location information (CSLI) for both past calls and in real time.^[3]

People generally do not have a reasonable expectation of privacy in the location data given from their cell phone GPS or by CSLI.^[4] In fact, no search occurs when a person voluntarily uses their cell phone in public, that information goes to the service provider, then the government accesses that information, possibly to place a suspect at the scene of a crime.^[5] This analysis is under the Katz test for reasonable expectation of privacy; Supreme Court has observed that there is never a physical intrusion because the GPS is just a part of the phone.^[6]

This issue is being addressed by state legislatures — but much like T-Mobile, the coverage it is patchy.^[7] Courts are divided on whether the Stored Communications Act makes it illegal for the government to track your location in real time without probable cause and a warrant.^[8] Neither Congress nor the Supreme Court has settled the debate as to whether warrants should be required for the government to access location information through a person’s cell phone.^[9] The majority of the South, minus Florida, has decided that no warrant is required to track a cell phone. Few states, California being one of them, require a warrant for all cell phone location information.^[10] How the government can track a cell phone greatly depends on where a person is in the country.

Unfortunately, this is not the only way a person can be tracked using a cellphone. Cell site simulators (CSS) are a tool used by the FBI that act like a nearby cell phone tower, tricking a phone into sending all the data intended to be transmitted to the cell phone carrier.^[11] This tool can be used by the government to find out a person’s cell phone number based on knowing only the person’s general location.^[12] The opposite is also true; if an officer knows identifying information about a person’s phone, they can use a CSS to locate its exact location.^[13] The government can use either a person’s general location or general identifying information about a phone to find out that phone’s exact location in real time using a CSS.

Additionally, the contents of a person’s phone may be subject to search. Consider, there is a reason most people have pass-codes protecting their phones. A typical smart phone can store anything from a detailed calendar, a person’s internet search history, pictures from a vacation, or every text message sent from that phone. The Supreme Court articulated in Riley that police may not search digital information on a cell phone seized from an individual who has been arrested legally unless they obtain a warrant. ^[14] But one of the major takeaways of this case was that the reasonable expectation of privacy does not extend to include all the data on an arrestee’s cell phone.^[15]

The applications we install is at least one more way we use our phones to disclose a massive amount of information to private companies and potentially the government. For example, Snapchat has built a brand on pictures and videos that are self-deleting. Pitching Snapchat as secure is a thin vainer of privacy considering all the ways a picture sent over Snapchat can be recovered. First, a recipient can easily screenshot a picture, saving it to their phone.^[16] Other companies have invented apps that automatically save Snapchat photos and videos to the recipient’s phone (without notifying the sender).^[17] Sent Snapchats can also be dug out of a phone by forensics firms who work with law enforcement and lawyers.^[18]

Snapchat’s Privacy Policy list all the information Snapchat collects from people who use their product and how this information is used.^[19] Snapchat collects “whatever information you send through the service, such as Snaps and Chats to your friends,” “information about your location,” “images and other information from your device’s camera and photos,” “information that other users provide about you when they use [Snapchat] services.”^[20] Snapchat’s Privacy Policy also answers the question of what they do with all the information they collect. For example, user’s information is shared with third-party targeting advertisers or in order to comply with any legal or governmental request.^[21]

Cell phones are incredibly convenient and serve just about any purpose people can think of. It is no surprise we use them as much as we do. However, cell phones are also incredibly convenient for law enforcement.

^[1] United States v. Jones, 908 F. Supp. 2d 203, 206 (D.D.C. 2012).

^[2] Id. at 207.

^[3] Id. at 210.

^[4] United States v. Skinner, 690 F.3d 772, 777 (6th Cir. 2012).

^[5] Id. at 779.

^[6] Id. at 778.

^[7] Cell Phone Location Tracking Laws By State, ACLU https://www.aclu.org/issues/privacy-technology/location-tracking/cell-phone-location-tracking-laws-state (accessed 10:43AM, Feb. 6, 2019).

^[8] 1-2 Criminal Constitutional Law § 2.03 (2017).

^[9] Id.

^[10] Id.

^[11] Coleman Torrans, How Did They Know That? Cell Site Simulators and the Secret Invasion of Privacy, 92 Tul. L. Rev. 519, 521 (2017).

^[12] Id.

^[13] Id.

^[14] Riley v. California, 134 S. Ct. 2473, 2493 (2014).

^[15] Id.

^[16] Danielle Young, Now You See It, Now You Don’t… Or Do You?: Snapchat’s Deceptive Promotion of Vanishing Messages Violates Federal Trade Commission Regulations, 30 J. Marshall J. Info. Tech. & Privacy L. 827 (2014).

^[17] Drew Guarini, ‘Snap Save,’ New iPhoneApp, Lets You Save Snapchats–Without Letting The Sender Know, Huff. Post (Aug. 9, 2013), http://www.huffingtonpost.com/2013/08/09/snapchat-snap-save_n_3732477.html.

^[18] DL Clade, Forensics Firm Discovers that Snapchat Photos Don’t Disappear After All, PETA PIXEL (May 10, 2013), http://petapixel.com/2013/05/10/forensics-firm-discovers-that-snapchat-photos-dont-disappear-after-all/.

^[19] Privacy Policy, Snapchat, http://www.snapchat.com/privacy/ (last visited Feb. 6, 2018).

^[20] Id.

^[21] Id.

Image Source: http://blogs.motivators.com/2011/12/dont-forget-your-things-doormat.html.