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  **         **      **       ***               POLICY POST  
  **         **      **       ***               
  **         **      **       ***               May 12, 1995
  **         **      **       ***               Number 13
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  CENTER FOR DEMOCRACY AND TECHNOLOGY
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  A briefing on public policy issues affecting civil liberties online
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CDT POLICY POST Number 13                       May 12, 1995

CONTENTS: (1) CDT Testifies at Senate Judiciary Subcommittee Hearing
              On the Availability of Bomb-Making Materials on the
              Internet
          (2) About the Center for Democracy and Technology

This document may be re-distributed freely provided it remains in its 
entirety.
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SUBJECT: CDT Testifies at Senate Judiciary Subcommittee Hearing 
         On the Availability of Bomb-Making Materials on the
         Internet

The availability of bomb-making information and 'mayhem manuals' on the 
Internet was the subject of a hearing yesterday (5/11/95) before the 
Senate Judiciary Committee Subcommittee on Terrorism, Technology, and 
Government Information. CDT Executive Director Jerry Berman testified 
before the panel. Berman's testimony is available on CDT's online 
archives (URL's below).

The bombing in Oklahoma City has brought the Internet under new scrutiny 
by Congress and the Clinton Administration. In his opening statement, 
Subcommittee Chair Arlen Spector (R-PA) made clear the First Amendment 
issues raised by government efforts to censor certain material in 
cyberspace. However, Spector acknowledged that the availability of so 
called "mayhem manuals" (one of which he displayed before the hearing) 
raises concerns about public safety and national security.

Senator Patrick Leahy (D-VT), in his opening statement, urged caution 
and careful consideration of the benefits new communications 
technologies can bring before Congress rushes to restrict and limit its 
use.

"Before we head down a road that leads to censorship, we must think long 
and hard about its consequences. The same First Amendment that protects 
each of us and our right to think and speak as we choose, protects these 
others as well. The rule of this free society has long been that it is 
harmful and dangerous conduct, not speech, that justify adverse legal 
consequences", Leahy said.

Senator Leahy, an opponent of Senator Exon's Communications Decency Act 
(S. 314), and strong advocate of freedom of speech and the free flow of 
information in cyberspace, recently introduced S. 714, an alternative to 
Senator Exon's bill (the text of Leahy's bill is available from CDT, URL 
below).

Witnesses on the panel included:

* Jerry Berman, Executive Director, Center For Democracy and Technology
* Rabbi Marvin Hier, Dean of the Simon Wiesenthal Center 
* Robert Litt, Deputy Assistant Attorney General, US Detp. of Justice
* William Burrington, Assistant General Counsel. America Online
* Prof. Frank Tuerkheimer, U. of Wisconsin Law School


What Does It Mean To "Shout Fire In Cyberspace?"
-----------------------------------------------

CDT's Jerry Berman acknowledged the availability of bomb-making 
instructions and terrorist manuals on the Internet, but argued that such 
materials deserve the same degree of protection as identical materials 
available in bookstores or libraries.   

"As an open society, governed by the democratic principles of the First 
and Fourth Amendments, we tolerate and even encourage robust debate, 
advocacy and exchange of information on all subjects and in all media of 
expression, without exception.  Prior restraint or any government action 
which might chill speech have long been labeled intolerable, expect in 
the few circumstances in which that speech advocates imminent violence 
and is likely to produce such violence.  Even in these cases, 
Constitutional law and long-standing law enforcement policy have 
dictated great restraint in order to avoid chilling legitimate speech 
activity."

"Justice Holmes taught that the First Amendment does not protect a 
person from punishment for "falsely shouting fire in a theater and 
causing a panic,"  Schenk v. United States, 249 U.S. 47, 52 (1919), but 
what does it mean to "shout fire" in cyberspace?  We believe that 
shouting fire in cyberspace is actually far less threatening, and thus 
less deserving of censure, than the equivalent act in the physical 
world.  Though one can shout fire in an email message or on an Internet 
newsgroup, the likelihood that it will incite readers to imminent, 
criminal action is much reduced because the readers are dispersed around 
the country, and even around the world."

Berman added,

"The Center for Democracy and Technology believes that any prosecutorial 
or investigative activity must be predicated on speech **plus** a 
reasonable indication that the speech will lead to imminent violence.  
Speech alone is not enough to prosecute or investigate in other media, 
and it should not be sufficient in interactive media.  Moreover, we 
assert that current law and the FBI's strict interpretation of the 
existing Attorney General investigative guidelines are adequate to serve 
both law enforcement purposes and First Amendment interests.

In the sharpest exchange of the hearing, Senator Dianne Feinstein (D-
CA), expressed strong concern about the ability of children to access 
bomb-making material on the Internet. Visibly outraged by the testimony, 
Feinstein said, "I have a problem with people who use the First 
Amendment to teach others how to kill [other people]" Protecting such 
speech, "... is not what this country is about."

CDT's Jerry Berman responded, "Excuse me, Senator, but that *is* what 
this nation is all about."  

Feinstein countered that she believes that there is a " difference 
between free speech and teaching someone how to kill others", and 
suggested that the government should take a greater role in preventing 
the availability of such materials.

Deputy Assistant Attorney General Robert Litt, agreeing with CDT's 
assertion that the First Amendment protects bomb-making manuals and 
other such material regardless of the medium of distribution, added that 
the Justice Department has the authority under current law to prosecute 
individuals who use the Internet to commit crimes relating to  
"extortion, threats, conspiracy, and aiding and abetting the violation 
of other federal laws".  But Litt emphasized that such prosecutions must 
be predicated by **conduct**. 

Litt said:

"We can, therefore, clearly act to punish conduct that falls within the 
scope of existing laws. But when we address not conduct but possibly 
protected speech, the power of law enforcement is restricted by the 
First Amendment. As the Committee well knows, we must guard the public's 
right to free speech even while protecting the public from criminal 
activity. The Constitution imposes stringent limits on our ability to 
punish the mere advocacy of principals or the mere dissemination of 
information, without more, even if the communications in question are 
utterly repugnant".

However, the Justice Department staked out a more aggressive line on the 
issues of encryption and anonymity. On anonymity, Litt acknowledged the 
necessity of confidentiality for whistle-blowers and informants, but 
argued that the availability of complete anonymity on the Internet is of 
serious concern to law enforcement. 

In his prepared testimony, Litt echoed FBI Director Louis Freeh's recent 
comments that "... unless the encryption issue is adequately addressed, 
criminal communications over the telephone and the Internet will be will 
be encrypted and inaccessible to law enforcement even if a court has 
approved electronic surveillance," and pledged to continue to work to 
find solutions to this issue.

In a statement which appears to dredge up previous arguments from the 
Department in support of the Clipper Chip government key escrow 
proposal, Litt said:

"We believe that it is possible to deal with both of these issues -- 
encryption and anonymity.  Privacy rights should generally be protected, 
but society should continue to have, under appropriate safeguards and 
when necessary for law enforcement, the ability to identify people and 
hold them accountable for their conduct. In the case of encryption, the 
appropriate balance can be achieved by the widespread use of reliable, 
strong cryptography that allows for government access, with appropriate 
restrictions, in criminal investigations and for national security 
purposes. The federal escrowed encryption standard issued last year is 
designed to achieve this delicate balance for voice telephony."

Rabbi Marvin Hier of the Simon Wiesenthal Center, argued that the  
nature of the Internet, including its broad reach and the veil of 
anonymity, provides a fertile ground for hate-groups and other 
potentially dangerous organizations. While stressing the importance of 
the First Amendment, Hier recommended that:

* Law enforcement should have the ability to monitor hate
  groups and other organizations that clearly advocate an
  intention to commit violence that use the Internet to
  distribute information;

* Online service providers (particularly the commercial
  services such as AOL and Compuserve) should take steps to
  prevent their networks from being used to distribute material
  from these organizations;  and

* To look at the uses of these communications technologies and
  to examine what legal limits can be placed on it.

William Burrington, Assistant General Counsel and Director of Government 
Affairs for America Online, stressed that AOL does take steps to address 
violations of its terms of service agreement, and has removed users who 
use the network to post inappropriate material to public forums.  

However, Burrington cautioned that it is impossible and illegal under 
ECPA for a service provider to monitor every communication that travels 
across their network. Burrington further noted that, while it is 
possible for America Online to exercise limited control inside its own 
networks, monitoring and controlling content on the Internet is beyond 
the reach of any one because of the decentralized nature and global 
reach of the network.

Speaking from direct experience, University of Wisconsin Law Professor 
Frank Tuerkheimer stressed that the government should not attempt too 
prevent or censor the publication of bomb-making manuals or other such 
materials -- not only because such action is clearly contrary to the 
First Amendment, but also because the material would inevitably be 
published in another forum, rendering the government's argument moot.

This is precisely what occurred in 1979 in United States v. Progressive, 
Inc (476 F. Supp 990 (W.D. Wisc. 1979). In this case, the government, 
sought to prevent the publication of instructions on how to make a 
hydrogen bomb.  Professor Tuerkheimer was the federal prosecutor in the 
Progressive Case.  The article was ultimately published and the case 
became moot because the information was found to be available in a 
number of public libraries.

Tuerkheimer noted that it would be futile for the government to attempt 
to prosecute someone for distributing bomb making material on the 
Internet, since information on how to build an ammonium nitrate bomb 
similar to the device used in the Oklahoma City tragedy can be found in 
encyclopedias and in publications available from the US Department of 
Agriculture.

NEXT STEPS:

Although the issue of the availability of bomb-making manuals and the 
use of the Internet by malitia and hate-groups has received considerable 
attention in the press and on Capitol hill in recent weeks, as of this 
writing there has been no legislation introduced, and so far none of the 
counter-terrorism proposals specifically address this issue.  

CDT will closely track this issue, and will alert you to any 
developments as soon as they become available.


Paths to Relevant Documents
---------------------------

CDT Executive Director Jerry Berman's testimony is available at the 
following URL's:

http://www.cdt.org/policy/terrorism/internet_bomb.test.html

ftp://ftp.cdt.org/pub/cdt/policy/terrorism/internet_bomb.test

Additional hearing documents, including the Department of Justice 
testimony can be found at the following URL's 

http://www.cdt.org/policy/terrorism/May11_hearing.html

ftp://ftp.cdt.org/pub/cdt/policy/terrorism/00-INDEX.terrorism

The Text of S. 714, Senator Leahy's Alternative to the Communications 
Decency Act, can be found at:

http://www.cdt.org/speech/cda/950407s714.html

ftp://ftp.cdt.org/policy/legislation/s714.bill

---------------------------------------------------------------

(2) ABOUT THE CENTER FOR DEMOCRACY AND TECHNOLOGY

The Center for Democracy and Technology is a non-profit public interest 
organization. The Center's mission is to develop and advocate public 
policies that advance constitutional civil liberties and democratic 
values in new computer and communications technologies. 

Contacting us:

General information on CDT can be obtained by sending mail to 
 

CDT has set up the following auto-reply aliases to keep you informed on 
the Communications Decency Act issue.

For information on the bill, including
CDT's analysis and the text of Senator
Leahy's alternative proposal and 
information on what you can do to 
help                                    -- cda-info@cdt.org

For the current status of the bill,
including scheduled House and 
Senate action (updated as events 
warrant)                                -- cda-stat@cdt.org

World-Wide-Web:

   http://www.cdt.org/

ftp:

   ftp://ftp.cdt.org/pub/cdt/

gopher:

   CDT's gopher site is still under construction and should be
   operational soon.

snail mail:

Center For Democracy and Technology
1001 G Street, NW Suite 700 East
Washington, DC 20001
voice: +1.202.637.9800 
fax:   +1.202.637.9800
                                  ###


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