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Thursday, April 16, 2009

That Uneasy Feeling

Many people have already pointed readers' attention to the symposium at Concurring Opinions on Danielle Citron's article on "cyber civil rights."  There is certainly much to recommend it, and I encourage readers to seek it out and get caught up on the discussion there.  And yet, I find something awkward and unsettling about the way much of the discussion has taken place.  The CoOp folks have deliberately disabled comments on many of the posts, although a few of the sympoiasts -- by and large those who are most critical of Citron's paper -- have opened their posts up for commentary, and folks who wanted to comment on other posts have been able to use this to circumvent the anti-comment norm of the other posts.


Of course, much commentary can be unhelpful and unduly emotional.  But that has not usually been a particular problem on CoOp, and I don't think the comments on the posts that have left the comment option enabled have suggested otherwise.  And of course the fact that some skeptical writers have been included in the symposium means some contrary points of view are aired even if no commenters are invited to the party.  But the whole thing leaves me feeling quite odd, for few reasons.  First, I think it weakens the quality of the public discussion of the symposium, in a way that's at odds with the usual norms of CoOp.  One of the original posts in the symposium argues that the editors thought that, "for this topic in particular," the costs of allowing comments would outweigh the benefits.  I don't think the results have borne that out; whether or not it was intended, the posts that don't allow comments have an air of ipse dixit, and a kind of "shut up, he explained" attitude toward readers who might disagree, while the posts that allow comments have provided for a more thorough and sensitive airing of the issues.  

Finally, there's something about the setup that I think is related to both the overall topic of the symposium and the views taken by those posters who are most sympathetic to Citron's arguments.  Those people who are most worried about the potential for "abusive" disagreement have also been, in my view, the symposiasts who have made the most sweeping, tendentious, and unsupported claims, both empirical and normative, in support of their arguments.  That makes their "arguments" more like assertions.  It not only prevents their arguments from being as strong as they could be -- for, in saying they are making the most tendentious and unsupported arguments, I am not saying they are necessarily making bad arguments -- but it also suggests, ironically enough given the topic, that those individuals who are making the claims that most demand heated disagreement are the same people who, on the one hand, fear being openly and heatedly (or "abusively") contradicted, and on the other would enforce this fear through legal means.  Moreover, the fact that they are taking matters into their own hands by blocking comments, although I am not crazy about this move, makes me question whether legal remedies are as necessary as they suggest they are.  

Of course, the CoOp editors had every right to make this move.  But I don't think it was required, and I think the symposium posts that allow for commentary have been stronger, and produced stronger conversations, than the ones that haven't, which in my view have been more likely simply to accept as true various assertions about both empirical and normative matters that are far more open to debate than they have acknowledged.  Notwithstanding the existence of some critics on the panel, that is the best recipe for a "symposium" to become little more than a cheering section of collected monologues.  That may, in fact, be what many or most legal academic symposia are: gatherings of people who already agree on political or other grounds and are seeking a means of getting subsidized airfare to hang out with one another.  (Is that not a fair description of many of the FedSoc and ACS conferences, despite the invited presence of a few dissenters?  And of countless symposia on, say, Brown, or PICS, or other cases?)  But we can hope for more.

Posted by Paul Horwitz on April 16, 2009 at 11:16 AM in Paul Horwitz | Permalink

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Comments

I'm one of the posters who left comments disabled. I'm not sure whether I'm also one of "symposiasts who have made the most sweeping, tendentious, and unsupported claims, both empirical and normative." In any event, I've gone with the default of leaving comments disabled because there's a small but significant chance that the trolls will descend. (How big? I don't know, but big enough that I can definitely imagine particular online lulz-seekers taking notice.) And if they do, I don't have the cycles this week to deal with it; there have been 8-hour stretches when I'm just not on the scene at all. So I made the call not to take the chance.

Posted by: James Grimmelmann | Apr 16, 2009 2:05:40 PM

I'm not sure there's really much of a correspondence between allowing comments and criticising the paper that is the subject of the symposium. Michael Froomkin's comment here lists the 'open' posts, which seem to me to run across the spectrum of opinions and are as diverse as the symposium as a whole. (In the interests of full disclosure, I am participating in the symposium and have one closed post and one open post, and explain why here)

Posted by: Daithí Mac Síthigh | Apr 16, 2009 2:16:16 PM

The trolls haven't descended yet Mr. Grimmelman, while the symposium has been going on for three days. And I note that the comments of Marc Randazza, who was deemed authoritative enough to debate Ms. Citron on public radio if not in this symposium, have been largely ignored.

Mr. Randazza's criticism of Ms. Citron's work, while blunt, seems valuable in that he alone has addressed what he contends to be deceptive or misleading use of data in her paper. The Auto-Admit "give him a congressional medal" cheering section, for instance - either Ms. Citron is not able to understand sarcasm when she reads it (in which case she has, to put it mildly, no business advocating policy changes for the internet based on alleged "cyberharassment"), or she used this incident deceptively. While the remaining participants, even the sckeptics, are quick to congratulate her and point out that her work is groundbreaking, none appears interested in addressing what appear to be serious flaws in her work.

So far, that's only come from Randazza, who while again, blunt, is hardly a troll. In fact his criticisms are the best this biased observer has seen, precisely, if cleaned up a bit, the sort of thing one would want to see in a symposium on a proposed important change in the law.

Posted by: Patrick | Apr 16, 2009 2:22:31 PM

We're talking about the AutoAdmit crowd here. I think it's pretty easy to say that someone else should subject themselves to such abuse. If they want to, fine, but I don't think there's any obligation.

Posted by: Bruce Boyden | Apr 16, 2009 2:22:44 PM

And yet they haven't come. So far your symposium seems to be getting most mentions through Simple Justice, which was linked by the Wall Street Journal's law page. That's hardly AutoAdmit.

You could always turn on moderated comments, assuming this is a Wordpress, Typepad, or Movable Type blog. That would be more work, but it's of course up to you as to whether the benefit of allowing comments from thoughtful outsiders outweighs the disadvantage.

Posted by: Patrick | Apr 16, 2009 2:32:47 PM

Patrick, two points: (a) we don't know what comments have been submitted, because they're being moderated; and (b) the point is about risk, not actual outcomes. I.e., if I leave comments open, what's the risk I'll get abusive comments? It seems to me that the risk was higher here than normal.

Is it your position that there's some sort of obligation to open comments on blog posts? Where does that obligation come from?

Posted by: Bruce Boyden | Apr 16, 2009 4:51:15 PM

I don't share Paul's uneasy feeling, but it's not clear to me why the risk here is higher than normal. Is the concern AutoAdmit trolls? They seem unlikely to troll the Concurring Opinions symposium on cyber civil rights, both because it's not really about them (it looks like only two posts -- Orin's and Frank's -- even mention AutoAdmit), and because it's an academic enough conversation that they are unlikely to be interested.

Posted by: joe. | Apr 16, 2009 5:08:18 PM

I am also one of the participants in the symposium. I turned comments on for my first post and off for the second, but just because I forgot to turn it on (the default is off). Who says website design doesn't impact behavior?

Posted by: Nancy | Apr 16, 2009 6:52:57 PM

It's not just AutoAdmit. There are worse things in Heaven and the Internet than are dreamt of on AutoAdmit.

Posted by: James Grimmelmann | Apr 16, 2009 7:10:26 PM

I'm in the symposium. I turned on comments in my post, though I regret it. In the future, I'd either go with no comments, or no posting, especially if the former policy is going to be subjected to this kind of uncharitable analysis.

Contrary to Paul's claim, I don't think that the folks who went the other way are making more tendentious and/or unsupported arguments. I do think they didn't want to deal with hassle by commentators who, largely, are abusive and petty. For example, Randazza has posted several times on my thread arguing that the original Citron article deliberately lied about statistics. Not - mind you - that she mis-cited articles, but that the underlying articles defined terms like cyber attacks in ways that he found implausible. Any reasonable reading of the article and its underlying sources is to the contrary. When this is pointed out, he shifted to a different place (Simple Justice), and called the discussion an "academic circle jerk" that "spunked out" posts like mine.

It's not clear to me why I ought to waste my time responding to such childish, insecure, nonsense. But I guess that some people (Paul?) would find all commentators to be constructive & useful dissenters, and the symposium poorer for not universally welcoming them. My view is that it's a large internet. We invited a cross-spectrum of voices to post, but we didn't - and never have - opened our blog up as a public forum. I've always moderated my comment threads, pruning them of fools.

Posted by: david hoffman | Apr 16, 2009 8:32:17 PM

I call them like I see them.

As Edmund Burke said, "All it takes for evil to triumph is for good people to do nothing.

I see multiple evils here. One is the evil in Citron's ideas, which as someone more blunt than even me said, is nothing more than warmed-over MacKinnon-Dworkin theory with the word "cyber" tacked on. However, that is certainly open to debate, and that debate will certainly rage long after you and I are both long retired.

The greater evils are, indeed, the lies she bases her paper on. As a number of supportive commentators noted, the theories are one thing, but showing the metaphorical "dead bodies" (the "victims" of cyber-harassment) really sets up the theory in a more persuasive manner. However, nobody but me bothered to check and see if the bodies were really "dead." Which leads me to my metaphor, -- the Academic Circle Jerk. See, metaphors are allowed on both sides of the debate.

One of the "dead bodies" was the target of an email sent to the Yale faculty. Citron's words:

A poster told the community there that he sent an email to a named student's faculty members with embarassing information about her. Posters hailed the sender as a hero who should be awarded a Congressional medal.

She goes on in her piece about how the online community supported and encouraged the action. "Site members applauded the e-mail and rallied around the sender." Here's the evidence.

http://randazza.wordpress.com/files/2009/03/autoadmitcom-notice-to-yls-faculty-concerning-heide-iravani.pdf

Citron writes:

"According to a 2006 study, individuals writing under female names received twenty-five times more sexually threatening and malicious comments than posters writing under male names. CCR at 65.

But, what is an "attack"?

"The set of behaviors defined as attacks included attempts to send a file to the user, attempted DCC chats with a user, malicious private messages sent to a user, and links sent to a user."

In other words, if someone so much as tried to chat with someone (regardless of content) or sent that person a link or a file, it was considered an "attack."

Of course, the next thing isn't a lie, but the fact that this "study" was conducted in three chat rooms, one called "teens," one called "Guild Wars" and one called "WOW" (World of Warcraft) is telling. At the risk offending fans of MMORPGs, this "study" was conducted on children and uber geeks. Further metaphorically speaking, this is like pointing to a car grill covered in crushed insects and saying "there are 2,000 dead here".

The worst part of this entire monstrosity is, however, NOT Citron's shoddy research and "dead body" fabrications -- but the shocking lack of criticism from other "academics." While I do not think it is an organized conspiracy, it sure looks like one. I think it is more likely a function of complete intellectual laziness coupled with the fact that very few law professors are qualified to engage in the kind of mental rigors that your average attorney handles on a routine basis.

It absolutely shocked me to learn how much the legal academy absolutely despises legal practitioners. In fact, it is considered to be a negative (if you want to teach full time) to have “too much” practice experience. The conventional wisdom is that once you've taught for three to five years, that's all you need in order to be a professor. More than that, and you're considered to be "too experienced." Digging through a few random CVs in the "symposium" it seemed to me that the average practice experience was less than two years (unscientific estimate - please correct me if you have the time to do the math). No wonder nobody was able to (or motivated to) actually peer-review the "Cyber Civil Rights" dreck.

One infamous quote that gets batted around the practical blawgosphere is this one:

We don’t want law school to be lawyer-training school. When we cave in to demands of that sort from the ABA and assorted study commissions, we actually invite alienation among law students and lawyers. Legal education should appreciate the depth of the legal discourse and explore its rich complexities. It should operate on a graduate-school level and graduate people truly learned in the law. -Marquette Prof. David Papke.

Papke took a beating for this from the practical blawgosphere. See, e.g., Greenfield, Gideon, Tannenbaum, and Bennett.

Is it any wonder then that law schools don't usually teach law students jack about how to practice law? Can you imagine any other profession where it would be a bona fide occupational requirement that you should be relatively inexperienced in whatever it is you are teaching? As Tannenbaum put it:

In medical school we teach students about the body, its organs, how it works, how it reacts to certain factors, and what causes disease and sickness. Then the "doctors" do a "residency" where they focus on the practicalities of "doctoring."

Accordingly, I think that my "circle jerk" metaphor is entirely appropriate. The timeline was this: Citron re-heated some MacKinnon-Dworkin theory and tacked on the prefix "cyber". The legal academy is the only portion of the academy that doesn't need to subject its work to peer-review, but rather submits it to student editors, who are "educated" by the same know-nothing buffoons who submit their crap to law reviews. Lo and behold, a bunch of kids who have no qualifications except that they took classes in law from people who primarily know nothing about practicing law, dont have the skills to critically examine the work. The work gets published, and the people you would expect to critically examine it -- they don't bother. Why not? Probably because there's nothing in it for them to do so.

And then in comes the barbarian, the philistine, the uncouth and unpolished First Amendment lawyer who finds the bullshit and lays it out for all to see. I'm sorry if I didn't lotion up to join in the mutual hand job experience, but I actually believe that the search for truth begins with "the truth." It isn't a mere "difference of interpretation." Lets put it this way, if I published "work" that showed evidence that there was no such thing as evolution. Better yet, here, have a laugh and watch this video:

http://randazza.wordpress.com/2008/06/13/a-banana-is-proof-of-what/

In that a christian minister shows that the banana is proof that there is a god. Of course, his "data" is BS. If I put that in a law review article though, would you still circle around and stroke me? I doubt it. The fact is that the Academy has a political orthodoxy, and if you adhere to it, your work is not subject to critical analysis. If you don't, then it is. What pisses me off is that I'm of the same political bent as most of the Academy, but I refuse to engage in its dishonesty and glad-handing.

If you find that to be "childish" or "insecure" I can accept those negative opinions as the cost of putting myself out there. However, I only bothered to intrude on your little love fest because not a single one of you did your job. Which, I suppose, can be forgiven... since almost none of you are qualified to do it in the first place.

Posted by: Marc J. Randazza | Apr 17, 2009 7:01:20 AM

Those people who are most worried about the potential for "abusive" disagreement have also been, in my view, the symposiasts who have made the most sweeping, tendentious, and unsupported claims, both empirical and normative, in support of their arguments. That makes their "arguments" more like assertions.

Yah and the man who wrote this sentence is making sweeping and substantiated assertions himself. Funny, that.

Posted by: Reese | Apr 17, 2009 7:51:40 AM

Mr. Boyden:

Patrick, two points: (a) we don't know what comments have been submitted, because they're being moderated; and (b) the point is about risk, not actual outcomes. I.e., if I leave comments open, what's the risk I'll get abusive comments? It seems to me that the risk was higher here than normal.

But we do have a sample from which we can judge the sort of comments likely to be submitted: those that appeared in the posts that were left open to comments, by Froomkin, Kim, and others. No AutoAdmit troll invasions occurred there. It would seem then, that the odds of an AutoAdmit troll invasion in comments to other posts would be low.

The worst sorts of internet trolls, those who frequent AutoAdmit, 4chan /b/, WoW chatrooms and the like, seem to have little interest in reading a site like Concurring Opinions. If they read legal sites at all, they're probably going to Above The Law, not a professorial blog where posters debate the merits of framing metalegal argument in terms of civil rights and free speech.

From what I've read of the posts it seems that more than a few participants (Orin Kerr is a notable exception) know little about how real internet trolls behave. If that's the case, if these people don't know this neighborhood of the internet, can they have an informed debate on a change to the structure of the internet to provide remedies for its alleged victims? Note that I'm not speaking of you specifically, because I don't know you from Adam.

Is it your position that there's some sort of obligation to open comments on blog posts? Where does that obligation come from?

Of course that's not my position. You are not a number. You are a free man. You may do whatever you wish at your own site, as I may at mine. Nonetheless, I believe that there are advantages to allowing outsiders to comment on blogs and to debate with the author of a blogpost. For instance, we could not have had this discussion through comments at a closed Concurring Opinions post. Whether the discussion has any value, of course, is for you and every other participant or reader to decide.

Posted by: Patrick | Apr 17, 2009 9:31:13 AM

I should add that by moderation, I mean "eyes on" human moderation, not captcha code verification as is used here and at Concurring Opinions. For instance, if someone wishes to write a comment at my site, the first comment won't appear until an author has read it and approved it. The primary purpose is to eliminate spamming robots, but a secondary benefit is that this ensures that people we perceive to be jerks are not allowed to comment at all.

Posted by: Patrick | Apr 17, 2009 9:42:22 AM

I'm grateful to Dave Hoffman for his comment. Let me say a couple of things. I wasn't aiming at being uncharitable, although I was certainly making judgments. I apologize if my language was too harsh, although I still think I am right that some of the more tendentious posts -- tendentious not in the sense that they were wrong, but in the sense that they made strong assertions that deserved real argument rather than simple assertion, and on which much of the remainder of their posts were premised -- were in the commentless category. (A commenter above says I have also made sweeping assertions. True! And people, including Dave, are welcome to disagree with them. But I provided a comment section as a check on myself and an opportunity for rebuttal.) I also agree with Dave that it's a large Internet, that the CoOp posters were under no obligation to post comments, as I wrote in my post, and that people can always react elsewhere. I wasn't saying the CoOp must post comments; I was suggesting that the symposium, and some posts in particular, would have been stronger if they had. I thought, and still do, that there is a relationship between this and the merits of some of the arguments made in favor of Danielle's piece. And I think Dave's description of what kind of comments constitute "abuse" tends to support this point, although it does not prove it. Mr. Randazza's comments, for instance, I think would be a lot stronger if they were much more civil. But I don't think they're abusive, at least not in the sense that, say, would give rise to a claim that this is the kind of abuse that warrants seeing online conduct of this sort as a civil rights issue. That's not to say some online conduct doesn't meet this definition. But I think Randazza's comments, some of which are petty and some of which merit serious consideration despite their tone, don't constitute abuse -- especially in this context, where the primary posters in question enjoy significant power and authority.

Posted by: Paul Horwitz | Apr 17, 2009 10:25:03 AM

An addendum to my last comment: The title "That Uneasy Feeling" was chosen deliberately. I wasn't saying CoOp was absolutely wrong; just that I had an uneasy feeling about the no-comment choice in this case, and that it pervaded my sense of the merits of the symposium comments, especially those in support of Danielle's arguments. Commenters are free to disagree with even an "uneasy feeling," as one commenter does above. Still, I was suggesting a sense of unease, not a desire to attack the symposium directly or to absolutely condemn the choice not to post comments on many posts. Although some of my language was harsh, I tried to make the overall sentiment sensitive.

Posted by: Paul Horwitz | Apr 17, 2009 10:27:48 AM

Mr. Randazza's comments, for instance, I think would be a lot stronger if they were much more civil..... I think Randazza's comments, some of which are petty....

Criticism fair. Criticism taken.

Posted by: Marc J. Randazza | Apr 17, 2009 10:32:01 AM

Paul writes: "And I think Dave's description of what kind of comments constitute "abuse" tends to support this point, although it does not prove it. Mr. Randazza's comments, for instance, I think would be a lot stronger if they were much more civil. But I don't think they're abusive, at least not in the sense that, say, would give rise to a claim that this is the kind of abuse that warrants seeing online conduct of this sort as a civil rights issue."

In my view, this statement is best seen as an empirical claim about how people the perceive risk of speech online. It appears that you and others are disposed to categorical claims: certain kind of speech should *never* be seen as abusive, even if the audience feels threatened. I certainly respect the intuitions behind such categories: regulatory creep; the importance of rights; concern about eggshells, etc. But the point of a post I wrote on CoOp is that your categorical claims are dependent on the values that speech is directed at. You'd feel differently if it were your ox being gored. And others disagree with you about the amount of threat conveyed by our commentators & their personal attacks on Danielle. And we've deleted the comments that threatened physical harm!

But the bigger point is this: you've made a claim about comment threads making arguments stronger because they can be exposed to critical reception. I think this is entirely theoretical, based on your priors, and entirely romantic. I read over the symposium threads. I don't think that a single post got better by the availability of comments, or a single one worse by their absence. Critics help argument when critics are thoughtful. There's no reason to expect that comment threads are generally going to be full of thoughtful people, though of course it happens. Generally, the posts were much more useful than the comments. There was particular reasons here to expect that our comment threads were going to be trolled & abused, and so we changed the default. Your unease, I think, relates to your tolerance for abuse, which isn't shared by everyone.

Posted by: david hoffman | Apr 17, 2009 11:49:50 AM

I appreciate your comment, Dave; a very gracious disagreement. Thanks. And props to Marc as well.

Posted by: Paul Horwitz | Apr 17, 2009 3:06:28 PM

I'm going to guess, from the direction of Paul's very interesting work on the First Amendment, that he strongly supports decisions like Hurley & Dale, which give associations the right to exclude based not on any external justification of their principles, but simply based on their own interpretation of their principles.

Given those ideals, and Robert Post's work on the nature of academic freedom (i.e., belonging to institutions and not individuals), why doesn't the freedom to exclude/not have comments (that belongs to the institution of the symposium, as put together by me and other bloggers here) trump the right of others to participate/comment?

Posted by: Frank | Apr 18, 2009 11:31:28 PM

Frank,

You seem to be missing the point. Of course Hurley, for example, was correctly decided. If a bunch of bigots want to have a parade, they get to pick who is in their parade. Seems right to me, even if I think the exclusion is objectionable.

Same thing with the "symposium." Excluding dissenting voices was, without a doubt, within the organizers' legal rights. I don''t think anyone would (or could) argue to the contrary. One of the first rules of blogs is "your blog, your rules." Even Paul says, quite clearly, "Of course, the CoOp editors had every right to make this move.

The point, as I understood it, of Paul's disagreement was that he felt that it weakened the symposium and it was worthy of criticism. Just like excluding gays from a St. Patrick's Day parade -- it doesn't violate any law, but forcing the organizers to invite in those they despise would. Nevertheless, both the St. Patricks Day parade and the "symposium" are diminished by their terror of those whose beliefs are in opposition to those of the organizers.

On my blog, I have purposely sought out authors whose beliefs will be in opposition to mine. I also permit comments that are quite scathing, even when directed at me. I consider this opposition to be a necessary tool in the pursuit for truth, as well as a necessary fire in which to galvanize my own work. Academia is not known for being so open to dissent and criticism, and this "symposium" has reinforced that.


Posted by: Marc J. Randazza | Apr 20, 2009 10:20:20 AM

I want to respond to the erroneous and reputation-harming suggestion that I "lied" about the University of Maryland study (and the broader issue as to the gendered nature of online harassment) and an AutoAdmit comment.

First, cyber harassment is indeed a gendered phenomenon. The non-profit organization Working to Halt Online Abuse (WHOA) has compiled statistics about individuals harassed online. In 2007, 61 percent of the individuals reporting online abuse were female while 21 percent were male. Similarly, in 2006, 70 percent of its online harassment complainants identified themselves as women. Overall, from 2000 to 2007, 72.5 percent of the 2,285 individuals reporting cyber harassment were female and 22 percent were male. Half of the victims were between the ages of 18 and 40 and reportedly had no relationship with their attackers. Similarly, the Stalking Resource Center, a branch of the National Center for Victims of Crimes, reports that approximately 60 percent of online harassment cases involve male attackers and female targets.

Academic research supports this statistical evidence. The University of Maryland’s Electrical and Computer Department recently studied the threat of attacks associated with the chat medium IRC. Researchers found that users with female names received on average 100 “malicious private messages,” which the study explicitly defined as “sexually explicit or threatening language,” whereas users with male names received only 3.7. Indeed, contrary to what has been misstated, the study explicitly explained that the “experiment show[ed] that the user gender has a significant impact on one component of the attack thread (i.e., the number of malicious private messages received for which the female bots received more than 25 times more private messages than the male bots)” and “no significant impact on the other kinds of attacks, such as attempts to send files to users and links sent to users.” The study explained that attacks came from human chat-users who selected their targets, not automated scripts programmed to send attacks to everyone on the channel, and that “male human users specifically targeted female users.”

I am extensively quoting the study to make clear that this analysis is not my interpretation of the study, but instead that of its authors.

Second, however one line of my BU article may be construed by others (i.e., the comment he deserves a Congressional medal), my editors, myself, Nathaniel Gleicher and others have read it as I have. But no matter, my work carefully cites all of the hundreds of harassing postings and does not include lies (the suggestion that I am deceiving others is itself defamatory as is the suggestion that the explanation of the Maryland study is). And the various stories of the attacks on women in both my BU Law Review article and my upcoming Michigan Law Review article are exact quotes as well and cannot be disputed.

I hesistated speaking to this issue as I fear cyber harassment, which I have clearly experienced personally and indeed as Dave notes has included menacing threats of physical harm (which we at CoOp removed).

Thus, we at CoOp feared that this would happen--harassing reputation harming assertions against women in the comments--and it did.

Danielle Citron

Posted by: Danielle Citron | Apr 28, 2009 9:09:58 AM

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