Media Law Prof Blog

Editor: Christine A. Corcos
Louisiana State Univ.

Friday, August 18, 2017

Comedian Dean Obeidallah Sues "Daily Stormer" For Defamation

From the New York Times: Comedian Dean Obedallah is suing the neo-Nazi website The Daily Stormer for defamation over its statement that Mr. Obeidallah was behind the May 2017 bombing at a stadium in Manchester, England, that killed more than 20 people.

More here from Forbes. 

The Daily Stormer went offline when it lost its hosting on GoDaddy and Google last week. It obtained a Russian host earlier this week, but has apparently lost that address as well. It is unclear whether the site now is available on the Internet. 

August 18, 2017 | Permalink

Brauneis on Parodies, Photocopies, Recusals, and Alternative Copyright Histories: The Two Deadlocked Supreme Court Fair Use Cases @RobertBrauneis

Robert Brauneis, George Washington Law School, has published Parodies, Photocopies, Recusals, and Alternate Copyright Histories: The Two Deadlocked Supreme Court Fair Use Cases. Here is the abstract.

Before any of the Supreme Court’s trio of fair use decisions – Sony v. Universal City Studios, Harper & Row v. Nation, and Campbell v. Acuff-Rose – there were the 1958 case of CBS v. Loew’s and the 1974 case of Williams & Wilkins v. United States: two copyright infringement suits that had turned on fair use in the lower courts, and that the Supreme Court had decided to review and had heard argument in. In both of those cases, however, one of the Justices recused himself, and the others deadlocked 4-4, leading to summary affirmance of the lower court judgments. How would the Court have decided those cases without the recusals? How would the decisions have affected the development of copyright and fair use doctrine? And were the recusals justified? The papers of a number of Justices, combined with other historical materials, provide surprisingly good answers to those questions. In CBS v. Loew’s, a case in which the Ninth Circuit had held that a Jack Benny parody of the movie Gaslight infringed copyright in that work, the Supreme Court voted to reverse. Justice Douglas started to draft an opinion for the Court, only to recuse himself to pursue a business opportunity with CBS that never materialized. In Williams & Wilkins, a case in which the Court of Claims had held the photocopying practices of two government libraries to fall within the scope of fair use, the Court would also most likely have reversed, with Justice Blackmun providing the fifth vote to decide that the practices were infringing. However, Blackmun recused himself because the Mayo Clinic, whose employment he had left fifteen years previously, took the position that the photocopying was fair use, and was one of thirteen parties signing on to one of many amicus briefs in the court below. Justice Douglas’s recusal, I argue, was unjustified, and Justice Blackmun’s dubious at best. In a world in Douglas and Blackmun had not recused themselves and the Court had decided CBS and Williams & Wilkins, how could copyright law look different than it now does? I explore that question at three different moments in time. First, I argue that immediately after a CBS v. Loew’s decision in 1958, there might not have been a fair use doctrine separate from a general inquiry into copyright infringement. Second, I contend that just after a Williams & Wilkins decision in 1974, fair use doctrine would likely have focused entirely on what have become known as “productive” or “transformative” uses, while excluding “non-productive” uses and eschewing any distinction between commercial and noncommercial uses. Finally, I consider the present moment, and consider the possible continuing impact of hypothetical decisions in CBS and Williams & Wilkins. Ultimately, however, my goal is not to prove exactly how CBS or Williams & Wilkins would have come out, or would have diverted the path of fair use doctrine or copyright infringement analysis. Rather, I am interested in using the materials that are available about those cases, and the realization that the Supreme Court came very close to deciding them, to free up my imagination, and yours, about how copyright law and the fair use doctrine could be different than they are.

Download the article from SSRN at the link.

August 18, 2017 | Permalink

Voss on the General Data Protection Regulation (GDPR) and the Proposed ePrivacy Regulation @wgvoss @ToulouseBS

W. Gregory Voss, Toulouse Business School, has published First the GDPR, Now the Proposed ePrivacy Regulation at 21 Journal of Internet Law 3 (July 2017). Here is the abstract.

On January 10, 2017, less than nine months after the General Data Protection Regulation (GDPR) was adopted by the European Union, the European Commission issued its proposal for a new ePrivacy Regulation. In analyzing this new proposal, this article first places European Union ePrivacy legislation in context before detailing the main points of the proposed ePrivacy Regulation, including its broad territorial scope, its material scope, its interface with the GDPR, as well as provisions on cookies, confidentiality of communications, application of the concept of consent and unsolicited direct marketing communications and enforcement measures (including sanctions). Next, this article discusses advisory and industry reactions to the proposed Regulation, and outlines the legislative process, prior to making certain conclusory remarks.

Download the article from SSRN at the link.

August 18, 2017 | Permalink

Broadhurst on Cybercrime: Thieves, Swindlers, Bandits, and Privateers in Cyberspace

Roderic Broadhurst, Australian National University; ANU Cybercrime Observatory, has published Cybercrime: Thieves, Swindlers, Bandits and Privateers in Cyberspace. Here is the abstract.

This chapter describes the definitions and scope of cybercrime including an outline of the history of hackers and the role of criminal networks and markets in the dissemination of malicious software. Cybercrime types and methods are described, including the widespread use of deception in computer misuse and identity theft. The challenges facing law enforcement and the important role of private and public partnerships, as well as cross-national co-operation in the suppression of cybercrime are illustrated.

Download the article from SSRN at the link.

August 18, 2017 | Permalink

Thursday, August 17, 2017

Pauli on Negotiating News at the White House @TAMULawSchool

Carol Pauli, Texas A&M University School of Law, is publishing Enemy of the People: Negotiating News at the White House in the Ohio State Journal of Dispute Resolution. Here is the abstract.

How can the press serve as a check on executive power when the president calls it “fake” and the White House denies facts? As journalists debate the right response, this article offers advice from the perspective of a journalist who is now in the legal academy. Drawing on legal scholarship in the field of conflict resolution — as well as literature in journalism and political science — this article analyzes the White House press briefing as a negotiation over both the content of news and the relationship of the press and president. It aims to help the press fulfill the urgent public need for news: the verified, factual, shared reality that makes self-government possible. Ultimately, the article concludes that the press can improve its negotiating position in several ways. Among them, it should resist anger, formulate expansive goals, use teamwork, and respond to government falsehoods in measured and nimble ways. The press should increase its own transparency in order to build trust and to distinguish its work from the blur of rumors that fill social media. Finally, it should decide in advance what government moves would be unacceptable and what actions it would take in response.

Download the article from SSRN at the link.

August 17, 2017 | Permalink

Thornburg on Twitter and the #So-Called Judge

Elizabeth G. Thornburg, Southern Methodist University School of Law, has published Twitter and the #So-Called Judge. Here is the abstract.

One-hundred-forty characters may be insufficient to deliver a treatise on the judiciary, but it is more than enough to deliver criticism of the third branch of government. Today, these tweeted critiques sometimes come not from the general public but from the President himself. Attacks such as these come at a challenging time for court systems. We live in a highly politicized, polarized society. This polarization is reflected in attitudes toward the courts, particularly the federal courts. Unfortunately, public doubts about the court system come at a time when public understanding of the structure of government, and especially the court system, is abysmally low. All of this context raises a number of related questions. When the prolific executive tweeter calls out a federal judge, is President Trump just venting or has he tapped into a strong subset of American opinion on the judiciary? And, if so, does a “so-called judge” have a role in engaging, informing, perhaps even rebutting these opinions? Further, could 140 characters be an effective platform to use in fulfilling that role? This article will address the specific issue of judges using Twitter to promote the interests of the courts as institutions. After section II’s brief description of the mechanics of Twitter, section III will discuss why and how judges communicate through Twitter. Section IV will sound a note of caution based on two factors: 1) a web of judicial ethics rules that limit judicial speech (including Twitter); and 2) the nature of the Twitter experience and the way people use it, which can hinder attempts to effectively reach the desired audience. The article will conclude by arguing that in this day and age, when much of America gets its news from social media and those platforms are being used to delegitimize the judiciary, the third branch can ill afford to disengage. Judicial tweeting, within the limits of the ethics rules, should be encouraged rather than shunned.

Download the article from SSRN at the link.

August 17, 2017 | Permalink

O'Callaghan on Developing a Right to Be Forgotten in the United States

Patrick O'Callaghan, University College Cork, School of Law, is publishing The Chance 'to Melt into the Shadows of Obscurity': Developing a Right to Be Forgotten in the United States in Privacy: Core Concepts and Contemporary Issues (A Cudd and M. Navin, eds., New York: Springer, 2018).

This chapter argues that there is some (limited) evidence of a right to be forgotten in the jurisprudence of U.S. courts. For the purposes of this argument, the right exists whenever interests in being forgotten and/or forgetting are understood as weighty enough to impose a duty on government and/or fellow citizens to respect those interests. Most of the relevant cases belong to the pre-digital era but nevertheless provide some doctrinal support for a right to be forgotten in the digital era. In particular, the chapter pays close attention to the privacy challenges associated with search engines and argues that may be possible to implement a Google Spain-inspired right to be forgotten (in the sense of delisting or deindexing search results) in the United States.

Download the essay from SSRN at the link.

August 17, 2017 | Permalink

Ram on Science as Speech

Natalie Ram, University of Baltimore School of Law, is publishing Science as Speech in volume 102 of the Iowa Law Review (2017). Here is the abstract.

In April 2015, researchers in China reported the successful genetic editing of human embryos using a new technology that promised to make gene editing easier and more effective than ever before. In the United States, the announcement drew immediate calls to regulate or prohibit outright any use of this technology to alter human embryos, even for purely research purposes. The fervent response to the Chinese announcement was, in one respect, unexceptional. Proposals to regulate or prohibit scientific research following a new breakthrough occur with substantial frequency. Innovations in cloning technology and embryonic stem cell research have prompted similar outcries, and even resulted in legislative action. Meanwhile, the U.S. government instituted a funding “pause” on certain infectious-disease research while it contemplated whether researchers should even be permitted to complete such work. Regulations such as these often seek to prevent researchers from discovering information and, consequently, can limit discourse on important matters of public concern. This Article argues that such de facto censorship implicates the First Amendment, and that constitutional scrutiny is necessary whenever the government regulates scientific inquiry in an effort to suppress knowledge production. This Article establishes a framework for assessing whether and when legislatures cross the constitutional line by regulating scientific experimentation. Applying this framework in a variety of contexts, from gene editing and human cloning to infectious-disease research, this Article also identifies both constitutionally sound and constitutionally suspect purposes for which government actors have regulated scientific research.

Download the article from SSRN at the link.

August 17, 2017 | Permalink

Amar and Brownstein on the First Amendment Academic Freedom Rights of Public College Students and Faculty

Vikram D. Amar, University of Illinois College of Law, and Alan E. Brownstein, University of California, Davis, College of Law, are publishing A Close-Up, Modern Look at First Amendment Academic Freedom Rights of Public College Students and Faculty in volume 101 of the Minnesota Law Review (2017). Here is the abstract.

Like many other terms bandied about these days, “academic freedom” is something that means different things to different people, and for that reason is often misunderstood. In this Article, we focus on what, if any, special freedoms of expression are enjoyed under the First Amendment to the U.S. Constitution by students and faculty members at any of the nation’s hundreds of public universities. Analyzing key Supreme Court precedent over the last generation, and the way these cases play out in prominent recent disputes — many of which have been litigated extensively in the lower courts — we conclude that while the First Amendment affords significant protections for expression insofar as public higher educational institutions can be likened to municipalities for some purposes, university administrators have a fair degree of control over speech that can be said to be connected directly to the research, classroom teaching, and extracurricular activities that make up the heart of modern university experience. Particularly as to faculty, First Amendment freedoms may be less than many people assume; in some respects (because of the nature of their public jobs), public university faculty may enjoy less expressive latitude than non-academic employees. There are, of course, sources of support for free speech beyond the First Amendment — such as institutional tradition and policy, state law, contract law, federal due process, and public subsidy. To the extent that advocates want more — rather than less — expressive freedom for students and faculty at universities because of the special role such institutions fill in society, those non-First-Amendment sources may prove more helpful than First Amendment doctrine.

Download the article from SSRN at the link.

August 17, 2017 | Permalink

Wednesday, August 16, 2017

Michigan Radio Station Gives Up FCC License

Lake Isabella/Mount Pleasant, Michigan, radio station WRAX-FM has surrendered its license to operate to the FCC, before the agency held a scheduled hearing on whether the station's license should be renewed. The FCC scheduled that hearing on August 3. The station has operated once per year since it received its license seven years ago. More here in a press release from the FCC. 

 

Statement from Commissioner Mignon L. Clyburn on the application of Radioactive, LLC for renewal of the license.

August 16, 2017 | Permalink

Levy on The Virtues of Unvirtuous Spaces

Alexandra Frell Levy, Notre Dame Law School, has published The Virtues of Unvirtuous Spaces at 50 Wake Forest Law Review 403 (2017). Here is the abstract.

Websites that facilitate sexual commerce have, in recent years, become pet enemies of some self-styled anti-trafficking advocates. However, this war on intermediaries should not be confused with an actual fight against human trafficking. The same pathways that may give rise to exploitation are no less available to law enforcement seeking to recover victims - a fact that recommends against shuttering these spaces.

Download the article from SSRN at the link.

August 16, 2017 | Permalink

Tuesday, August 15, 2017

Katsirea on Search Engines and Press Archvies Between Memory and Oblivion @sheffielduni

Irini Katsirea, Department of Journalism Studies, University of Sheffield, is publishing Search Engines and Press Archives between Memory and Oblivion in the European Law Review. Here is the abstract.

Search engines’ comprehensive digital memory has led to a desire for greater informational self-determination. The seminal judgment in Google Spain gave impetus to the development of data protection law as the preferred legal remedy for claimants who seek to erase their digital past. This article argues that the ‘right to be forgotten’ is a contourless and ill-conceived right, which can apply to a variety of markedly dissimilar cases, while paying insufficient regard to the fundamental rights of search engine users, website publishers and of the search engines themselves. Even though the decoupling of names from search results does not interfere with the original expression, it is intended to suppress this expression by drastically reducing its findability and hence its significance in the digital age. Search engines, with their intransparent modus operandi, are entrusted to unravel the Gordian knot between data protection and freedom of expression. But as the ‘right to be forgotten’ begins to cast its overly broad net over press archives, the Gordian knot risks tightening further.
Download the article from SSRN at the link.

August 15, 2017 | Permalink

Friday, August 11, 2017

CNN and Jeffrey Lord Part Ways Over a Tweet

After commentator Jeffrey Lord sent the words "Sieg Heil!" to a liberal activist who works at Media Matters, CNN ended its association with him. Mr. Lord had been appearing on the network to represent the Trump campaign and subsequently Trump administration views since the late summer of 2015. The tweet was one in a series of exchanges with Angelo Carusone over an ad boycott of Sean Hannity. CNN called the Nazi reference "indefensible." Mr. Lord said the network misunderstood his tweet.

More here from CNN, here from ABC News, and here from Politico.

August 11, 2017 | Permalink

Marzen on Public Records Denials

Chad G. Marzen, Florida State University College of Business, has published Public Records Denials. Here is the abstract.

Transparency and openness in our national, state and local governments is a cardinal principle in our democratic system. Since 1967, the Freedom of Information Act has been the primary applicable law which enables citizens to obtain public information from executive branch agencies of the federal government. Essentially every state also has a freedom of information act, public records law, or similar law which allows citizen access to public documents and records. A largely unexplored area of the academic literature involving freedom of information laws relates to the sanctions or penalties which may exist for noncompliance. This Article advocates for changes and revisions to existing state laws to provide for more stringent penalties in the event a public records request is knowingly denied. Enhanced penalties and legal consequences for improper public records request denials are critical to ensure open and transparent access to public information.

Download the article from SSRN at the link.

August 11, 2017 | Permalink

Tehranian on Sex, Drones & Videotape: Rethinking Copyright's Authorship-Fixation Conflation in the Age of Performance @SouthwesternLaw

John Tehranian, Southwestern Law School, is publishing Sex, Drones & Videotape: Rethinking Copyright's Authorship-Fixation Conflation in the Age of Performance in volume 68 of the Hastings Law Journal (2017). Here is the abstract.

For more than two centuries, the Copyright Act has eschewed the task of defining authorship. However, with the decoupling of the act of creation from the act of fixation and the dramatic advance of technology, the issue of authorship has gained renewed relevance in recent years, as questions of authorship have permeated numerous high-profile legal controversies. To cite a few examples, the metaphysics of authorship lay at the heart of copyright squabbles involving Naruto (the crested macaque who famously took a selfie), Cindy Lee Garcia (the actress who received death threats for her appearance in the controversial movie The Innocence of Muslims), and, less obviously, Terry Bollea (the wrestler professionally known as Hulk Hogan who bankrupted Gawker Media with a sex-tape lawsuit). With its exegesis of the Garcia v. Google decisions (both Judge Kozinski’s original opinion and the Ninth Circuit’s resounding reversal en banc), its reconsideration of the Supreme Court’s seminal decision in Burrow-Giles Lithographic Co. v. Sarony, and its analysis of authorial inquiries raised by interviews, drone and surveillance footage, bootleg recordings, paparazzi photographs and classroom note-taking, this Article identifies and critiques the problematic juridical conflation of copyright’s authorship and fixation requirements. As the Article argues, copyright’s authorship-as-fixation regime rests on a faulty premise, betrays copyright law’s role in recognizing and rewarding creativity and denies copyright interests to the very individuals who have provided significant, if not the most important, original contributions to works within copyright’s traditional subject matter. As a result, the Article calls for a fundamental reconsideration of the concept of authorship, including the issue of performer copyrights, in order to better align copyright law with its utilitarian goals, the realities of the creative process and broader public policy.

Download the article from SSRN at the link.

August 11, 2017 | Permalink

Thursday, August 10, 2017

Rosati on The CJEU Pirate Bay Judgment and Its Impact on the Liability of Online Platforms @eLAWnora

Eleonora Rosati, University of Southampton School of Law, is publishing The CJEU Pirate Bay Judgment and Its Impact on the Liability of Online Platforms in the European Intellectual Property Review. Here is the abstract.

In its 2017 judgment in The Pirate Bay (C-610/15) the CJEU developed further its construction of the right of communication to the public within Article 3(1) of Directive 2001/29 (the InfoSoc Directive), and clarified under what conditions the operators of an unlicensed online platform are potentially liable for copyright infringement. The Court held that the operators of a platform that makes available to the public third-party uploaded copyright content and provides functions such as indexing, categorization, deletion and filtering of content may be liable for copyright infringement, jointly with users of the platform. For a finding of liability it is not required that the operators possess actual knowledge of the infringing character of the content uploaded by users. The decision encompasses different types of platforms and operators with different degrees of knowledge of the character – lawful or unlawful – of the content made available therein. It calls into consideration the relationship between liability for (harmonized) primary copyright infringement and (unharmonized) secondary copyright infringement. In relation to the current EU policy discussion of the so called ‘value gap proposal’, the judgment reinforces the position of the European Commission, especially the basic idea that the making available, by a hosting provider, of third-party uploaded copyright content may fall within the scope of the right of communication to the public. The Court’s reasoning also prompts a reflection as to whether a hosting provider that is primarily responsible for acts of communication to the public is actually eligible for the safe harbour within Article 14 of Directive 2000/31 (the E-Commerce Directive).

Download the article from SSRN at the link.

August 10, 2017 | Permalink

Tuesday, August 8, 2017

Citron and Wittes on Denying Bad Samaritans Section 230 Immunity @daniellecitron @benjaminwittes

Danielle Keats Citron, University of Maryland School of Law, and Benjamin Wittes, Brookings Institution, are publishing The Internet Will Not Break: Denying Bad Samaritans Section 230 Immunity in the Fordham Law Review. Here is the abstract.

What do a revenge pornographer, gossip-site curator, and platform pairing predators with young people in one-on-one chats have in common? Blanket immunity from liability, thanks to lower courts’ interpretation of section 230 of the Communications Decency Act (CDA) beyond what the text, context, and purpose support. The CDA was part of a campaign — rather ironically in retrospect — to restrict access to sexually explicit material online. Lawmakers thought they were devising a safe harbor for online providers engaged in self-regulation. The CDA’s origins in the censorship of “offensive” material are inconsistent with outlandishly broad interpretations that have served to immunize from liability platforms dedicated to abuse and or those that deliberately tolerate illegality. In contrast to a strike-oriented view of the CDA’s safe harbor, its modest revision will not break the “Internet.” Whether this would have been true at the time of its passage two decades ago, it would not be true today. Conditioning immunity from liability on reasonable efforts to address unlawful activity would not end innovation or free expression as we know it. The current environment of perfect impunity for platforms deliberately facilitating online abuse is not a win for free speech because harassers speak unhindered while the harassed withdraw from online interactions. With modest adjustments to section 230, either through judicial interpretation or legislation, we can have a robust culture of free speech online without shielding from liability platforms designed to host illegality or who deliberately host illegal content.

Download the article from SSRN at the link.

August 8, 2017 | Permalink

Verstraete, Bambauer, and Bambauer on Identifying and Countering Fake News @markverstraete @dbambauer @JaneYakowitz

Mark Verstraete, Derek E. Bambauer, and Jane R. Bambauer, all of the University of Arizona College of Law, have published Identifying and Countering Fake News as Arizona Legal Studies Discussion Paper No. 17-15. Here is the abstract.

Fake news has become a controversial, highly contested issue recently. But in the public discourse, “fake news” is often used to refer to several different phenomena. The lack of clarity around what exactly fake news is makes understanding the social harms that it creates and crafting solutions to these harms difficult. This report identifies several distinct types of fake news: hoax, propaganda, trolling, and satire. It specifies distinct features of each type that can be targeted by regulation to shift its production and dissemination. The report introduces a visual matrix to organize different types of fake news and show the ways in which they are related and distinct. The two defining features of fake news are 1) whether the author intends to deceive readers and 2) whether the motivation for creating fake news is financial. These distinctions are a useful first step towards crafting solutions that can target the pernicious forms of fake news (hoaxes and propaganda) without chilling the production of socially valuable satire. Finally, the study identifies several possible solutions based on changes to law, markets, code, and norms. These starting points include: expanding legal protections for Internet platforms to encourage them to pursue editorial functions; creating new platforms that do not rely on online advertising; encouraging existing platforms to experiment with technical solutions to identify and flag fake news; and encouraging platforms to use their own powerful voices to criticize inaccurate information.

Download the article from SSRN at the link.

August 8, 2017 | Permalink

Monday, August 7, 2017

He on China's Cultural Censorship System and Its Influence on Copyright Protection @QMJIP

Tianxiang He, School of Law, City University of Hong Kong, has published Control or Promote? China's Cultural Censorship System and Its Influence on Copyright Protection at 7 Queen Mary Journal of Intellectual Property 74 (April 2017). Here is the abstract.

China is famous for its strict censorship system regarding cultural goods. China is not, of course, the only country which advocates censorship, but its uniqueness lies in the political purposes that its censorship system serves. This article explores China’s censorship system in the cultural sector in detail. It examines the ex ante and ex post censorship system in three major areas – publications, traditional broadcasting channels and online publishing – as well as the interplay between related legislations, regulations and national enforcement campaigns. This article explains how China uses these legal instruments and utilizes enforcement campaigns to strategically live up to its international obligations and serve the political needs of content control and market domination, rather than merely the outward purposes of these regulatory instruments and campaigns such as copyright protection.

Download the article from SSRN at the link.

August 7, 2017 | Permalink

Spiwak on US Telecom and Its Aftermath

Lawrence J. Spiwak, Phoenix Center for Advanced Legal & Economic Public Policy Studies, has published US Telecom and Its Aftermath as Phoenix Center Policy Bulletin No. 42 (2017). Here is the abstract.

In 2015, the Federal Communications Commission made the controversial decision to reclassify broadband Internet access as a common carrier “telecommunications” service under Title II of the Communications Act. While much of the debate has focused on the legality of reclassification, little attention has been paid to actual implementation. As detailed in this Bulletin, a proper implementation of Title II precluded the Commission’s approach, forcing the Agency to ignore the “vast majority of rules adopted under Title II” and “tailor[] [Title II] for the 21st Century.” Surprisingly, the D.C. Circuit found in United States Telecom Association v. FCC that the agency had wide latitude to interpret the Communications Act and not only upheld the agency’s decision to reclassify but also its gross distortion of Title II. In so doing, the D.C. Circuit has extended Chevron deference beyond any reasonable limit, greatly expanding the Commission’s authority well beyond its statutory mandate. This Bulletin first presents several examples of how the 2015 Open Internet Order ignores both the plain language of Title II and the extensive case law to achieve select political objectives, followed by a discussion of the D.C. Circuit’s acceptance of such legal perversions. Next, this Bulletin discusses how the FCC attempted to use the same theory of the case found in USTelecom to regulate the prices of Business Data Services. Conclusions and policy recommendations are at the end.

Download the article from SSRN at the link.

August 7, 2017 | Permalink