FC: An open letter to the Internet Archive on Scientology and the DMCA

From: Declan McCullagh (declanat_private)
Date: Wed Sep 25 2002 - 08:41:38 PDT

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    News report on Scientology's successful attempt to have pages removed from 
    the Internet Archive (at archive.org):
    http://news.com.com/2100-1023-959236.html
    
    Scientology's recent white paper a church spokeswoman sent to Politech:
    http://www.politechbot.com/p-03917.html
    
    I'd like to invite both the Archive folks (who provide an excellent and 
    valuable service) and a Scientology representative to reply to Politech and 
    clarify what's going on. It would be a public service for the Archive to 
    publicize what procedures it will follow when receiving DMCA 
    cease-and-desist letters in the future. It could, for instance: (1) change 
    the default "page deleted" text; (2) forward the letter to 
    chillingeffects.org; (3) offer the archivee the opportunity to reply; (4) 
    investigate the request to make sure it's not overly broad; (5) pledge to 
    do its best to preserve the public availability of information in the Archive.
    
    It would be a public service for Scientology to state that it's interested 
    only in pursuing legitimate violations of its copyrights that are not 
    protected by a reasonable definition of fair use and it has no intention of 
    going further than that. If its request to the Archive was broader, and it 
    seems to be, I'd encourage Scientology to narrow it.
    
    -Declan
    
    ---
    
    From: Dave_Touretzkyat_private
    To: infoat_private
    cc: brewsterat_private, media-relationsat_private, hugh.scottat_private,
        declanat_private
    Subject: open letter to the Internet Archive
    Date: Tue, 24 Sep 2002 19:48:06 -0400
    
    As the owners of SlatkinFraud.com, one of the websites that has been
    blocked completely from the Internet Archive, we were left puzzled and
    disturbed by the recent explanation provided by archive.org for our
    site's omission.
    
    While we understand that the organization behind the Wayback Machine
    does not want to unwittingly contribute to copyright infringement, we
    are distressed by the way in which the removal of our site was
    conducted, and the lack of feedback that we received from archive.org
    when we questioned this decision earlier this year.
    
    When a Wayback Machine user attempts to access the archived version of
    SlatkinFraud.com, they are instead provided with a misleading message
    claiming that the 'site owners' requested that it not be included in
    the archive.  This is wholly untrue, and entirely in contradiction to
    the actual views of the website owners in question, who would very
    much like to see our site become part of the Internet Archive.  The
    material contained within SlatkinFraud.com is wholly owned and
    maintained by its site owners.
    
    Unfortunately, as has become clear in recent days, SlatkinFraud.com is
    not the only site that has been summarily removed from the Archive
    based on complaints from the Church of Scientology.  In the explanation
    recently provided by archive.org, the writer notes that the Church
    "asserted ownership" of an unknown quantity of material that was, at
    the time, available through the Wayback Machine archives.  The
    maintainers of archive.org, however, have apparently made no effort
    whatsoever to inform site owners of these complaints lodged against
    their material, and in fact, until now, had not even replied to direct
    questions regarding the removal of certain sites when asked by the
    site owners in question.
    
    This is clearly not an acceptable system for determining what sites or
    material should be archived by the Wayback Machine, since it does not
    adhere to one of the main provisions of the Digital Millennium
    Copyright Act: the counter-notification process.
    
    Under the DMCA, the owner of a site that has been alleged to contain
    infringing material has the right to challenge that claim via a
    counternotification letter to the hosting ISP if he or she believes
    that the material in question does not infringe on the copyright in
    question.  After receiving this counter-notification from the user, the
    ISP is obliged to replace any files that were temporarily removed
    pending the complaint, at which point the original complainant must
    either initiate formal legal action against the owner of the site, or
    drop the matter entirely.
    
    This system provides an important check to the sometimes perilous
    balance between the rights of copyright owners, and those of users.  By
    formalizing the process, and allowing a response from the individual
    responsible for the alleged infringement, it frees the hosting company
    from the annoyance of dealing with frivolous claims.
    
    A similar situation that arose resulted from similar complaints made
    by Church of Scientology lawyers about certain listings on the popular
    search engine Google.  These complaints initially resulted in the
    wholesale removal of several Scientology-related sites from the Google
    database.  Once this omission was discovered, the decision taken by
    Google to remove the sites without notice led to an outcry from its
    users.  In fact, on closer examination of the complaints from
    Scientology, it became immediately obvious that the Church's lawyers
    were acting in bad faith by deliberately mixing trademark and
    copyright complaints, even though trademark complaints are not covered
    under the DMCA at all.
    
    The ensuing barrage of criticism and media coverage both national and
    international forced Google to reconsider its decision.  After several
    days, the company replaced the links in question, and agreed to make
    public any further DMCA complaints in cooperation with Chilling
    Effects, a non-profit website dedicated to preventing abuse of
    existing copyright law.  This solution was welcomed by Google users,
    who had felt betrayed not only by the removal itself, but by the lack
    of disclosure on the part of Google regarding the initial complaints.
    
    The explanation offered by the Internet Archive does not mention
    whether the original complaints received from the Church of
    Scientology were made under the provisions of the Digital Millennium
    Copyright Act.  Such information would be helpful to site owners such
    as ourselves, as it would assist us in determining whether a complaint
    is justified, and remove any infringing material on our own volition.
    
    Assuming that it was, in fact, a DMCA request, it would serve
    archive.org well to follow the same procedure as that eventually and
    successfully - - adopted by Google, and make every effort to inform
    site owners of such complaints in a timely manner.  This could be done
    through a simple email alert system that would inform the site owner
    that a complaint had been made, or through a similar policy to that of
    Google, and publicizing the letters, either on the archive.org website
    itself or through an interested third party such as Chilling Effects.
    
    This would allow the site owners to decide whether or not to issue a
    counter-notification, and relieve the Internet Archive of any concerns
    over contributory liability that may have played a role in its
    decision to remove the material without warning.  It would also
    discourage copyright owners from making frivolous complaints about
    material that is obviously protected by fair use, since the process
    requires that formal legal action be taken within thirty days of
    receiving the counter notification letter.
    
    Should archive.org decide not to re-list a site within the Wayback
    Machine at this point, which is, of course, its right, it should also
    refrain from suggesting that this was at the request of the site
    owner, and instead, explain its own concerns over potential
    infringement.
    
    Finally, given the enormity of the Internet Archive project, and the
    benefits that it has provided, and, we hope, will continue to provide
    to the online community, it is essential for the Library maintainers
    to be open and transparent about the methodology used in selecting
    sites to be archived.  Removing sites from the archive in a clandestine
    fashion, as dictated by the current policy, will only lead to
    increased concern that the Archive itself is rewriting the Internet
    history that it seeks to chronicle.
    
    The Internet Archive's stated commitment is to provide a useful,
    wide-ranging resource for researchers, historians and scholars.  It is
    surely in part due to such an admirable mandate that the Internet
    Archive has benefited from contributions from sponsors such as Alexa
    Internet, AT&T, Compaq and Xerox PARC, not to mention many individual
    supporters who believe in the idea of an Internet history that is
    freely accessible to all.  It is doubtful that these supporters would
    want to see this ambitious initiative tainted by the suggestion that
    the integrity of the archive itself has been corrupted by those who
    would misuse copyright and trademark laws to censor views with which
    they disagree.  The risk of such silent, selective discrimination
    against protected speech is great; the power to prevent such abuses by
    making all information related to such attempts to discriminate will
    always be greater.
    
    Clearly, the best course of action is for the Internet Archive to
    adopt policy that is not only transparent, but dedicated to protecting
    not only its own interests, but those of copyright owners, site
    creators and, of course, the thousands of individuals who use the
    Wayback Machine and other Internet Archive services on a daily
    basis.  On balance, the approach taken by Google, modified
    appropriately for the particular situation faced by the Internet
    Archive, would seem to be an excellent roadmap for the Internet
    Archive to follow.
    
    Kady O'Malley, Dave Touretzky, and Scott Pilutik
    
    Owners of SlatkinFraud.com
    
    
    
    
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