Re: [DMCA-Activists] NY Fair Use on the Broadcast Flag

[Ruben Safir]

Except your not NY Fair Use

NY Fair Use is at
fairuse.nylxs.com and is a sub-committee of NYLXS.

Ruben

On Sun, Mar 02, 2003 at 03:52:59PM -0500, Seth Johnson wrote:
> 
> PDF version of following:
> 
> > http://rm.nyfairuse.org/flag/extdoc/NPRM 02-231 Reply Comments.pdf
> 
> 
> The FCC Public Comments Search Page is at:
> > http://gullfoss2.fcc.gov/prod/ecfs/comsrch_v2.cgi
> 
> Type 02-230 under "Proceeding" to see all comments submitted.  New
> Yorkers for Fair Use's comment is at:
> > http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513483420
> 
> -- Seth
> 
> 
> Before the 
> Federal Communications Commission 
> Washington, DC 20554 
> 
> In the Matter of
> 
> Digital Broadcast Copy Protection
> 
> MB Docket No. 02-230
> 
> 
> REPLY COMMENTS OF NEW YORKERS FOR FAIR USE
> 
> 
> February 19, 2003
> 
> Jay Sulzberger
> New Yorkers for Fair Use
> 622-A President Street
> Brooklyn, NY  11215
> (718) 398-8431
> 
> 
> 
> REPLY COMMENTS OF
> NEW YORKERS FOR FAIR USE
> 
> 
> I. INTRODUCTORY COMMENTS
> 
> New Yorkers for Fair Use first thanks the FCC for the consideration and
> care and time that the staff must have spent to transform and publish
> the thousands of comments submitted by groups and individuals in
> response to NPRM 02-231.
> 
> It may be instructive to note that in a prospective future world, a
> world in which the Broadcast Flag has been mandated, the FCC offices
> might reasonably expect to have encountered greater difficulties in
> handling proceedings such as this.  In this future, the FCC might
> receive some comments via digital broadcast, and perhaps some flag of
> the many flags that would be necessary in any realistic BF system, might
> not have been set properly or perhaps might not have been read properly.
> 
> There is enough difficulty today in transforming, searching, indexing,
> and arranging copyrighted and public domain works, even with untrammeled
> computers and untrammeled networks, that a new and different kind of
> software, intended precisely to make access and distribution impossible
> in certain instances, would surely interfere here, at this living nexus
> of citizen, small business, cartel, monopoly, and governmental
> regulatory agency.
> 
> II. PUBLIC RESPONSE TO THE "BROADCAST FLAG" MANDATE PROPOSAL
> 
> New Yorkers for Fair Use wishes to point out the remarkable phenomenon
> that more than 5600 public comments have been lodged in response to this
> proposal.
> 
> Some of these comments that are standardized texts express the
> commentator's opinions near enough for her to sign them and send them in
> with relatively little reflection. In some cases reading the text,
> thinking about what it says, signing, and then pressing a button is
> enough to send the comment to the FCC.  At the time we analyzed the
> comments several weeks ago, there were a total of 5,667 comments posted
> to the FCC's public comments system on this matter, 77% of which (4,382)
> were in the standardized texts category, including the texts composed by
> Digital Consumer (3,560 / 63%) and Citizens for a Sound Economy (822 /
> 15%).
> 
> 
> However, perhaps an even more reliable sign of the public's great
> concern for this issue, is the 1,285 other comments that citizens
> composed on the basis of their own reflection.  These are the comments
> whose words are mostly the commentator's own, and thus copyrighted under
> United States law at the moment of composition.
> 
> The volume of comments, in both of these categories, expressing
> opposition to the imposition of the Broadcast Flag Mandate, speaks for
> itself.
> 
> 
> Among the self-composed comments, the care that their authors took in
> their composition is striking, as is the strength of their opposition. 
> There are almost no comments, except from large cartels, or highly
> regulated very large corporations, all with strong perceived direct
> interests in the outcome, that express support for the broadcast flag
> mandate.  There are also a few comments from large corporations and
> trade organizations opposed to the BFM and, as in the case of the
> pro-BFM comments, most are from bodies with perceived direct interests.
> 
> (Note: our method for separating standardized texts was approximate, a
> matter of flagging comments which used a number of distinguishing
> phrases.  This efficient method could not hope to separate those
> instances in which the standard text was edited by the commentator or in
> which the commentator may have added original commentary.)
> 
> Let us now examine a different classification of the comments.
> 
> 
> III. “BROADCAST FLAG” MANDATE COMMENTS
> 
>       A. Proponents of the “Broadcast Flag” Mandate
> 
> Here are the comments which support imposition of the entire system that
> would be necessitated to realize the objectives of the broadcast flag
> proposal:
> 
> American Conservative Union
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394649
> 
> CBS Television Affiliates Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513395009
> 
> Digital Transmission Licensing Administrator,  LLC
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513395250
> 
> Directors Guild of America, Inc.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513388991
> 
> DIRECTV, Inc.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513397369
> 
> Information Technology Industry Council (ITI)
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394476
> 
> Media Access Group at WGBH
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394503
> 
> Motion Picture Association of America, Inc.,  et al.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513395156
> 
> Motorola
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513397321
> 
> National Broadcasting Company, Inc.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394476
> 
> National Cable & Telecommunications Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513393934
> 
> National Football League, et al.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394221
> 
> National Music Publishers' Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513307461
> 
> NBC Television Affiliates Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394973
> 
> North American Broadcasters Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513395146
> 
> Panasonic / Matsushita Electric Corporation of America
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513289166
> 
> Thomson Inc.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394743
> 
> Viacom
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394608
> 
> Walt Disney Company and ABC Television Network
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394657
> 
> 
>               i. General Response
> 
> In each case, except for the American Conservative Union -- whose
> comment simply seems to us to be 180 degrees from what we would expect
> from an organization which supports property rights, privacy rights, and
> free markets -- the organizations, whether for profit or not, express
> their support because they fear the consequences of a continuation of
> our present system of private ownership of computers and free private,
> tribal, business, and public use of the Net.  All their analyses proceed
> from the bizarre assumption that hypothetical losses of projected
> profits from untried and, mostly, incoherent theories about possible
> future "business models" justify an end to the system of strong rights
> of the individual citizen under which they have prospered these last
> twenty years. These groups have famously cried "Wolf!" before, and yet
> now Hollywood makes half its gross from tapes and DVDs of their product.
> 
> They have also failed to develop the computer and the Net, and have
> lagged for years behind academic, individual, and tribal use of these
> wonderful works of Man.  Their claim to now simply own, by what right is
> not clear except perhaps force majeure, both every individual computer
> and all means of mass communication, will, we are confident, be rejected
> by the People when the People hear of it.
> 
> We fully expect the FCC to also reject this claim, perhaps merely
> prudentially, so as to avoid revisiting this issue when citizens start
> to realize that their devices do not work as well under a broadcast flag
> mandate as under our present system of strong rights of the individual
> to copy, transform and arrange material in the privacy of one's house,
> and to risk copyright infringement by use of the Net to send and receive
> works, both works whose copyright the individual holds, and works whose
> copyright is held neither by the sender nor by the receiver.
> 
>               ii. “ Copy Protection” versus “Redistribution Control ”
> 
> Some of these Pro-BFM comments recognize that we are here dealing with
> two quite distinct, but directly abutting, bundles of rights and
> practical powers.  Several of the large pro-BFM organizations admit that
> I have a right to do as I please in the privacy of my own home.  The
> phrase of art here is "The BFM, done right, only affects redistribution,
> not copying and transformation in the privacy of the home."
> 
> New Yorkers for Fair Use agrees that the right of free use of material
> copyrighted to others in the privacy of one's house is an important
> principle which the FCC must uphold, at risk of assaulting the most
> basic property rights of Americans.  But we disagree that the second
> bundle of rights is not ours anymore.
> 
> Any perfectly working system of "broadcast flag" hardware and software,
> which allowed free copying and transformation in the home, would still
> constitute prior restraint, on a massive scale and of an incontinent
> nature, on our rights of free speech and free assembly. The underlying
> assumption of any "broadcast flag" system is that certain large
> interests own all our computers and all our Net, and that we the People
> will have to make do with what privileges they grant us.
> 
> This, of course, is not the way things really are. Companies and cartels
> are transitory instruments of individuals, tribes, and groups, and have
> no independent claims to own all the world.  And when the world changes,
> as it is now changing with the coming of massive compute power available
> to individuals, and massive communication power available to
> individuals, well, institutions such as companies and cartels change
> more slowly, and so some will suffer diminution of stock value, loss of
> customers, fall in profits, etc..
> 
> Of course, other instruments of groups of free men, women, and children,
> will rise in value, grow in customers, increase in profits, etc.  It is
> ever thus, and the FCC can only hurt the natural flexible growth and
> spread of new powers to all persons on earth by agreeing that a few
> large frightened and insufficiently intelligent cartels and monopolies
> be granted complete ownership of the means of digital production and
> distribution.
> 
> On a less grand note, let us point out that the imposition of a system
> of BF which respects the in-the-house bundle of rights and practical
> powers while granting the degree of suppression of the fundamental
> freedom to distribute which is necessary to assure no infringement, is
> much harder to accomplish than the already difficult-to-implement
> proposed "No copy" systems of BF.
> 
>               iii. Establishment of Precedent
> 
> Finally there is one point, mentioned by the American Music Publishers
> Association, with which we agree: In imposing the "broadcast flag," the
> FCC may be setting a precedent which would affect other media and
> means.  Where we differ from these pro-BFM commentators is that we think
> BFM is very bad.
> 
> 
>       B. Opponents of the “Broadcast Flag” Mandate
> 
>               i. “Consumer Rights”
> 
> We now discuss the comments by advocacy groups which might be classified
> as "Against the BFM, on the basis that it will impair convenient use of
> traditional media in the home.".
> 
> Center for Democracy and Technology
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394761
> 
> Consumer Electronics Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513397277
> 
> Consumer Federation of America
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513391743
> 
> Public Knowledge and Consumers Union
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394714
> 
> 
> This line of argument is sometimes called the "consumer rights"
> argument.  New Yorkers for Fair Use rejects this line of argument in
> principle -- though, as mentioned in our opening paragraphs, we agree
> that the imposition of any broadcast flag mandate would indeed make many
> things even more inconvenient than they are today.  Many of the
> organizations making this argument are about twenty years old, and they
> helped fight for our right to use VCRs in the home.  The leaders of
> these organizations see the present opposition to DRM as a continuation
> of that old and passionate and honorable battle.
> 
> This line of reasoning is correct in that the right to private ownership
> and private use of the VCR is a part of our property rights and a part
> of our freedom to use information, absent any specific harms to certain
> protected classes of individuals and organizations.  But the entire
> ground of the old VCR battle was different from the present battle.
> 
> The VCR is a limited device which mostly only serves in most people's
> houses to copy the productions of large movie makers and TV show
> makers.  The VCR may be part of a full studio to make music, movies,
> etc., in an individual's house or a company's studios, but it is not a
> universal digital production and distribution device, as a computer
> connected to the Net is.  So perhaps the battle over the VCR might be
> called a battle between "consumers" and "producers," though if that were
> felt to have been the full story, one might doubt that our side could
> have won.  But the fact that the battle was really a battle for our
> freedom to make use of information as we see fit was always understood
> implicitly.  Indeed that was the deep unconscious spring of our side's
> passion.  But because at the surface the issue was phrased as "consumers
> versus producers," those lines of argument have come down without
> sufficient critical examination to the present discussion.
> 
> Opposition to DRM is a struggle of the whole world for our property
> rights and our equally important rights of free speech and free
> assembly, and for the right of every citizen to be treated in the manner
> in which every citizen is treated in a free country: not as a consumer,
> but as a producer and a transformer of works of the mind and heart. The
> weakness of the old "consumers vs producers" line of reasoning, a
> weakness based on an inadequate analysis, is that it proposes that we
> are fighting for what few privileges the cartels and monopolies will
> grant us.
> 
> In other words, proponents of the "consumers vs producers" line give
> away the whole game before the discussion begins.  They start their
> argument by agreeing that really, at bottom, certain special interests
> control and own everything and they are the only productive force in the
> world.
> 
> Thus "consumers vs producers" is not the line upon which NYFU fights. 
> We do not come to the table pleading for scraps.  Our rights and
> practical powers are not grants from Infotainment Central.  We are all
> producers and distributors by right of copyrighted and other kinds of
> stuff and we stand on the Earth equal in stature and rights with
> Infotainment Central and Microsoft.
> 
>               ii. Classic “Fair Use”
> 
> There is a small class of comments from librarians and scholars.
> 
> Library Associations
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394836
> 
> American Foundation for the Blind
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394595
> 
> 
> Though their arguments may formally seem close to the "consumer rights"
> arguments they are of a completely different nature.  We are rather at
> the locus classicus of "Fair Use."  If we do not carefully preserve and
> keep alive the ancient liberties and new powers of the scholar, of the
> student, of the tinkerer, of the engineer, of the scientist, of the
> artist, of the politician, of the citizen, we will enter a new dark
> age.  This is, after all, how the last Dark Age of Europe came about.
> 
>               iii. Fundamental Principles
> 
> Finally, let us consider the class of the most forceful and important of
> all the comments.  These are the comments opposing the broadcast flag
> which found their arguments upon the fundamental principles of private
> property and freedom of speech and assembly.  The number and power of
> these comments is extraordinary.  They are mostly in individuals' own
> words, with some long important comments coming from organizations with
> professionals who have studied and understood just how bad the broadcast
> flag would be for our rights and our practical powers.
> 
> Electronic Frontier Foundation
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513395409
> 
> Electronic Privacy Information Center (EPIC)
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513393727
> 
> Free Software Foundation
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513395086
> 
> LXNY
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513395495
> 
> And numerous comments by individuals, catalogued here:
> http://rm.nyfairuse.org/flag/
> 
> 
> These comments share a number of insights which will surely become more
> widely understood.  We will not rehearse here again these arguments. 
> But we would like to suggest to the FCC that such arguments will be made
> by more and more people.
> 
> It is certain that the public and its advocates, including consumer
> advocates, will come to understand the more powerful arguments grounded
> in our rights as free men, women, and children.  This move is already in
> progress: New Yorkers for Fair Use found it promising when, at a
> September 17, 2002 meeting at the Department of Commerce addressing
> other DRM mandate proposals, we discovered that many advocates of the
> public interest already were taking up the "owners and makers" position,
> rather than addressing the question of government mandated content
> control from a "consumer rights" standpoint.
> 
> 
> 
> IV. EXISTING TECHNOLOGY
> 
> Finally, New Yorkers for Fair Use would like to suggest that the FCC
> move slowly here.  The entire technical landscape is shifting as we
> write.  Shortly GNU Radio, a free, as in Free Software Foundation,
> software-defined general receiver and transmitter suite, will make
> available rich and flexible digital TV receivers at low cost:
> 
> http://www.gnu.org/software/gnuradio/gnuradio.html
> 
> If the FCC imposes the broadcast flag mandate, then the best and least
> costly Digital TV receiver will be made illegal.
> 
> 
> 
> New Yorkers for Fair Use
> http://www.nyfairuse.org
> 
> 
> 
> 
> APPENDIX: ADDITIONAL COMMENTS OPPOSED TO THE BROADCAST FLAG MANDATE
> 
> These comments do not fall into any of the above categories, and
> sometimes make arguments with implicit presuppositions which New Yorkers
> for Fair Use do not accept, or on principles which New Yorkers for Fair
> Use do not accept.  We here make short replies to some of the arguments
> in this class of comments.
> 
> It is difficult for New Yorkers for Fair Use to make a strong enough
> disclaimer here before making response.  New Yorkers for Fair Use does
> not support any reduction in our present rights, both the bundle of
> in-the-house rights and the bundle of rights of free speech, free
> assembly, and Fair Use, Fair Use in the broadest legal and political and
> philosophical senses. New Yorkers for Fair Use also does not support any
> reduction of our present practical powers of information transmission
> and transformation, whether by combination in restraint of trade,
> governmental suppression, or combination of these, or by any other
> means.
> 
>       A. “DRM Needs Much Work”
> 
> The following comments include in their theses that "DRM needs much
> work."
> 
> Banks, LIN, Midwest, Post-Newsweek, Raycom
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513299133
> 
> Computer & Communications Industry Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394889
> 
> Philips Electronics North America Corporation
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394869
> 
> Veridian Corporation
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513299133
> 
> Verizon
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394774
> 
> Home Recording Rights Coalition
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513397442
> 
> One theme of the arguments here has already been mentioned above: the
> technical, legal, and economic difficulties of designing, implementing,
> and imposing any BF system which would entirely respect the in-the-house
> bundle of powers, while at the same time so suppress certain classes of
> transmission as to attain the dystopian vision of the MPAA.  But there
> is another theme that is also persuasive within a limited discourse: no
> matter what principles of rights is assumed: the Broadcast Flag's
> sought-for effects can more easily be obtained by hard encryption,
> either with or without government mandates, either with or without
> cartel collusion against citizens' rights and powers.  To repeat our
> disclaimer: New Yorkers for Fair Use rejects all claims of the
> Englobulators to own all the world's communications systems.  But if the
> Englobulators want to try, we think that private competitive offerings
> will make the work of defending our rights and powers more likely to
> succeed, because free individuals and communities and companies are
> unlikely to buy trammeled devices, and unlikely to support trammeled
> communications systems when there are untrammeled competitors.
> 
>       B. Oppose Government Mandate/Question FCC Jurisdiction
> 
> The following comments include the argument "The FCC has no power to
> dictate specific designs of computers.".
> 
> Business Software Alliance et al.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513397470
> 
> Microsoft Corp.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513402019
> 
> Pacific Research Institute
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513392775
> 
> TiVo Inc.
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513390640
> 
> 
> Of course, New Yorkers for Fair Use agrees.  Further, beyond the lack of
> power of the FCC to do these things, we believe that no government or
> cartel has by right such a terrible power to deny us our rights, as
> designers, users, owners, makers, and citizens.
> 
>       C. Establish Voluntary Standards
> 
> The following comment includes the argument "Let various bodies freely
> decide upon arrangements to further their varied and complexly
> supporting and opposing desires.".
> 
> Information Technology Association of America
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394917
> 
> Our disclaimer applies here with particular force, since some of those
> who make this argument support reduction of our rights and practical
> powers by means of agreements among cartels and monopolies, backed by
> unequal laws favoring these special interests.
> 
> But certainly freedom of speech and assembly, without threat of force,
> or economic oppression, includes the freedom to arrange affairs among
> individuals, tribes, and businesses.  To this degree, as long as other
> vital freedoms and powers are not suppressed, New Yorkers for Fair Use
> supports free arrangements.
> 
>       D. Do Not Apply to Internet Carriers
> 
> This comment points out that if that unlikely but great evil, a
> Broadcast Flag Mandate, is forced on Broadcast Digital TV by the FCC,
> certainly carriers of transmissions over the Net must not fall under the
> shackles.
> 
> Internet Commerce Coalition and U.S. Internet Service Provider
> Association
> http://gullfoss2.fcc.gov/prod/ecfs/retrieve.cgi?native_or_pdf=pdf&id_document=6513394602
> 
> 
> New Yorkers for Fair Use agrees.  It is better to have some free
> communications systems than to have none.
> 
> -- 
> 
> DRM is Theft!  We are the Stakeholders!
> 
> New Yorkers for Fair Use
> http://www.nyfairuse.org
> 
> [CC] Counter-copyright: http://cyber.law.harvard.edu/cc/cc.html
> 
> I reserve no rights restricting copying, modification or distribution of
> this incidentally recorded communication.  Original authorship should be
> attributed reasonably, but only so far as such an expectation might hold
> for usual practice in ordinary social discourse to which one holds no
> claim of exclusive rights.
> 
> 
> _______________________________________________
> DMCA-Activists mailing list
> address@hidden
> http://mail.gnu.org/mailman/listinfo/dmca-activists

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