The changes brought about by the Internet over the past decade have been phenomenal. Ten years ago, if you mentioned e-mail, the vast majority of people would not have known what you were referring to. World Wide Web sites were nonexistent then, as HTML was just an idea, not released until mid-1991.

As recently as June 1993, there were only 130 Web servers, where today, about 5 years later, there are more than 2 million (See above) (Hobbes’ Internet Timeline). Of the almost 200 million adults (age 18+) in the United States, fully one-fourth of them are Internet users (CyberStats). Almost any imaginable information can be found on the Internet, from car repair tips, travel guides, to your favorite singer’s new album, complete with online ordering. Today’s Internet presence is seen in all forms of communication, with most advertisements on television or in the newspaper now accompanied by the Web address for that company. People interested in buying a car can look on, say, Toyota’s web site to get information on the current models and pricing - information that they would have had to go to the dealership to get before the age of the Internet.

A large percentage of these companies do business over the Internet, allowing people to shop in a new way without even leaving their home. Along with businesses such as computer supply companies and CD stores, adult-oriented stores and non-commercial adult web sites also have a large presence on the Internet. Given that industry will supply what consumers demand, it is no surprise that these sites have boomed in popularity. The Internet is merely a reflection of society, and even though some people find it offensive, pornography and other adult material is a part of society.

The adult content on the Internet has become the source of much government controversy recently, as certain groups worry about the accessibility of this often pornographic or erotic information to children. The Family Research Council, which "exists to reaffirm and promote nationally, and particularly in Washington, DC, the traditional family unit and the Judeo-Christian value system upon which it is built," is one such group (FRC Vision & Work). These groups think that government action and regulation of what is available on the Internet is the best way to prevent children from accessing adult content, and support such regulation as the Communications Decency Act (CDA). One member of the Family Research Council stated that for the courts to hold the CDA unconstitutional would be "to sacrifice [our children] to perversions and excesses for the convenience and pleasure of the worst malefactors on-line -- in effect, to preserve the pornographers' new found sanctuary known as cyberspace" (Cyberchaos). Given the great importance of the Internet in today’s society as a medium of free speech, possible government limitation on what can be allowed on the Internet is taken very seriously by the large majority of the Internet.

However, we believe the solution to the problem of children accessing inappropriate material on the Internet is not government regulation and prior restraint, as some such as the Family Research Council would contend. Those familiar with the Internet realize that government regulation can only control material here in the United States, and the Internet is a worldwide network. Furthermore, attempts so far by the government to establish such regulations on the Internet content accessible to children have proven sweeping and vague, limiting adults’ First Amendment rights. These regulations have been met by vigorous protest from the American Civil Liberties Union and other similar organizations. The problem is that there is no way for many Internet content providers to comply with these laws other than by removing their content from the Internet, because there is no acceptable way to verify that someone requesting material from the site is of the legal age. Removing the content infringes upon other adults’ First Amendment rights because it denies them access. This is similar to the way magazines such as Playboy and Penthouse are sold in stores only to adults, while people know that some children can gain access to these magazines. Cigarettes can be sold legally only to adults, while statistics are published on the rates of teenage smoking. The same goes for alcohol. Our society knows that children are gaining access to these products, yet they are not removed from the market. These attempts at regulation of a product are not entirely successful, yet tighter restrictions are not imposed because of the rights of adults to use these products.

The first attempt at government regulation was made into law on February 8, 1996 in the form of Public Law 104-104, the "Telecommunications Act of 1996." Inside this one hundred and seven page law is a section known as the Communications Decency Act. This amendment to the Communications Act of 1934 includes a section that states

d) Whoever--
``(1) in interstate or foreign communications knowingly--``(A) uses an interactive computer service to send to  a specific person or persons under 18 years of age, or ``(B) uses any interactive computer service to display in a manner available to a person under 18 years of age, any comment, request, suggestion, proposal, image, or other communication that, in context, depicts or describes, in terms patently offensive as measured by contemporary community standards, sexual or excretory activities or organs, regardless of whether the user of such service placed the call or initiated the communication; or ``(2) knowingly permits any telecommunications facility under such person's control to be used for an activity prohibited by paragraph (1) with the intent that it be used for such activity, shall be fined under title 18, United States Code, or imprisoned not more than two years, or both.

The Federal District Court of Eastern Pennsylvania sided with the plaintiffs, finding the Government’s arguments for upholding the CDA unconvincing. They ruled the law unconstitutional in June of 1996, with Chief Judge Dolores K. Sloviter concluding that the statute "sweeps more broadly than necessary and thereby chills the expression of adults" and that the terms "patently offensive" and "indecent" were "inherently vague." Another judge, Judge Ronald L. Buckwalter, stated that the terms "patently offensive" and "indecent" were so vague that prosecution based on this would violate the "fundamental constitutional principle" of "simple fairness" and due process, protected by the Fifth Amendment. Judge Stewart Dalzell’s opinion explained at length why he believed the Act would abridge significant protected speech, particularly by noncommercial speakers, while "[p]erversely, commercial pornographers would remain relatively unaffected" (Reno v. American Civil Liberties Union).

This District Court decision was appealed, and the case went to the Supreme Court. The Government argued that the CDA did not violate First Amendment rights because it was overbroad or violate Fifth Amendment rights because it was vague. They contended that the CDA was constitutional under three prior Supreme Court decisions, (1) Ginsberg v. New York, 390 U.S. 629 (1968); (2) FCC v. Pacifica Foundation, 438 U.S. 726 (1978); and (3) Renton v. Playtime Theatres, Inc., 475 U.S. 41 (1986). The court went on to examine these cases, and concluded that they "raise[d]—rather than relieve[d]—doubts concerning the constitutionality of the CDA" (Reno v. American Civil Liberties Union).

In the case of Ginsberg the court upheld a New York statute that made it illegal to sell material considered obscene to those under 17 but not obscene to adults. The defense that the "constitutional freedom of expression" to see or read material concerning sex could not hinge on whether the person was a minor or adult was rejected. The court pointed out that in four important ways, the Ginsberg statute upheld was narrower in scope than the CDA. First, with the Ginsberg statute, parents who consented to their children having such material could purchase it for them. This parental consent would not "avoid the application of the statue" under the CDA. Second, the Ginsberg statute only applied to commercial transactions, unlike the CDA. Third, unlike the Ginsberg statute, the CDA does not include exemption for items with "literary, artistic, political, or scientific value." And fourth, the CDA raises the minimum age to 18, one year more than in the Ginsberg statute.

The Supreme Court decision in the Pacifica case held that the First Amendment "does not prohibit all governmental regulation that depends on the content of speech." The court stated that "the availability of constitutional protection for a vulgar and offensive monologue that was not obscene depended on the context of the broadcast." The Supreme Court ruling pointed out several significant differences in the order in the Pacifica case and the CDA. In the Pacifica case, the FCC, which has been regulating broadcasting for years, targeted this specific program, which was a departure from normal, to designate when it would be acceptable to broadcast the program, not whether it would be. The CDA’s prohibitions are not limited to specific times, and are not based on evaluations by an agency familiar with the Internet. Also, the Pacifica case deals with a radio broadcast, which has traditionally less First Amendment protection, given that warnings are not effective in protecting listeners from accidentally being exposed to indecent or vulgar material. With the Internet, accidentally coming across offensive material is unlikely, given the interactivity and confirmation required on the users part (Reno v. American Civil Liberties Union).

Another case used in the Government’s appeal of the CDA district court ruling was the Renton case. In this case, the Supreme Court upheld a zoning ordinance keeping adult theaters out of residential neighborhoods. This zoning was to prevent the secondary effects of the theaters, such as crime and decreasing property values, not deny free speech based on the content of the theaters. The Government claimed the CDA does just that, "cyberzoning" the Internet. But, the CDA is aimed at protecting children from the primary effects of offensive and inappropriate material, which is a "content based blanket restriction on speech" (Reno v. American Civil Liberties Union).

The case then went to the Supreme Court where it was ruled unconstitutional on June 26, 1997, based only on its violation of First Amendment rights. The Supreme Court declared that given the importance of specifics in statutes limiting free speech, the CDA was just too vague, especially given that there were no provisions in it to exempt material that has "scientific, educational, or other redeeming social value." The Supreme Court expressed its doubt that, given the vague nature of the bill, the CDA was "carefully tailored to the congressional goal of protecting minors from potentially harmful materials" (Reno v. American Civil Liberties Union). The ACLU summarized "the Court ruled that the CDA places an ‘unacceptably heavy burden on protected speech,’ that ‘threatens to torch a large segment of the Internet community’" (Cyberspace Will be Free!).

With the CDA ruled unconstitutional, the supporters of the CDA proposed another bill attempting to censor the Internet, which Congress passed on October 16, 1998 as part of the omnibus spending bill. This one, known as the "Child Online Protection    Act" (often called COPA, or CDA-II) states

The broad definitions in the Child Online Protection Act are also problematic, such as the definition in the bill for "harmful to minors."

Though COPA is aimed at commercial web sites, the definition of "commercial" in the law effectively "bans a wide range of protected expression that is provided for free on the Web by organizations and entities who also happen to be communicating on the Web ‘for commercial purposes’" (COPE Legal Challenge Filed). The COPA defines "commercial purposes" as being "engaged in the business of making such communications." It then defines "engaged in the business" as meaning:

There have been several other attempts by the government to regulate the Internet. Rep. Logfren (D-CA) introduced the "Internet Freedom and Child Protection Act of 1997," on February 13, 1997 (Internet Freedom and Child Protection Act of 1997). Rep. McDade (R-PA) introduced another bill, the "Family-Friendly Internet Access Act of 1997," on March 20, 1997 (Family-Friendly Internet Access Act of 1997). The "Internet Freedom and Child Protection Act of 1997" states:

Senator John McCain’s (R-Arizona) "Internet School Filtering Act" requires that all elementary and secondary schools "filter or block material deemed to be inappropriate to minors." (Internet School Filtering Act) It does not directly mention filtering software, but that is the implied method for meeting the requirements of the bill. There are several problems with filtering software, and they are discussed later on. One major drawback to this software mentioned in the later section is that it does not allow access to sites, such as those on breast cancer, that contain words similar to those on pornographic sites. Thus, older students may not be able to do research on such a topic or find useful information for personal use.

Senator McCain’s bill also contains a section concerning libraries:

The "Child Protection Act of 1998" requires the installation of filtering software on all computers in public libraries and schools that are accessible to minors and are connected to the Internet. It requires the software to be operating whenever the computer can be accessed by minors, but it does allow the software to be temporarily disabled in order for minors to gain access to data that is blocked by the software but is not obscene (Child Protection Act of 1998). This act is attached to an appropriations bill for 1999, so it may become law (Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 1999).

President Clinton has gone on record as being unsupportive of governmental regulation of the Internet. In a press conference held on July 16, 1997, he announced that "technology, not another federal law, is the best way to keep their children from peeking at porn and other ‘objectionable’ online material." His plan to prevent children from accessing pornographic sites has three parts: enforce current child pornography and obscenity laws on the Internet’s content, promote the use of filtering software and rating systems, and educate parents about how to use this technology effectively ("Clinton: Technology is the Answer"). His plan recognizes that the ultimate responsibility lies not with technology, but with the parents. "Technology is not a ‘silver bullet,’ and is no substitute for parental involvement." (White House release: Family Friendly Internet) President Clinton threatened to veto the omnibus spending bill because the Child Online Protection Act was attached to it ("FRC to President Clinton: Stop Protecting Pornographers").

Other lawmakers are also opposed to the government regulating the Internet. Rep. White (R – WA), proposed one interesting bill that surfaced in the House of Representatives on July 31, 1997. The "Internet Protection Act of 1997" was designed "to ensure that the development of the Internet and interactive computer services is unfettered by Federal and State regulation." It prevents the federal government or state governments from implementing any type of regulation of the Internet, unless certain criteria are met (Internet Protection Act of 1997). They are rather vague, however. The bill allows for Internet regulation when "regulation of Internet information services … is not in the public interest," but it fails to define "in the public interest." However, until such a situation occurs, the bill argues that government regulation should be avoided to promote "rapid and efficient technological and commercial innovation, deployment, and adoption of Internet information services." (Internet Protection Act of 1997)

Rep. Billy Tauzin, a co-author to the "Internet Protection Act of 1997," was the chairman of the House Subcommittee on Telecommunications, Trade, and Consumer Protection for the 105^th Congress (Committee Assignments, Member and Committee Information, Office of the Clerk, Bill Summary and Status). Sen. Conrad Burns, the chairman of the Senate’s Subcommittee on Communications for the 105^th Congress, is also opposed to censorship of the Internet (Committees; McClellan: Protecting the Internet from Regulation). Their positions allow them to wield a large influence over the regulatory bills that are sent to their committees; since all proposed bills must go to committee, their positions are possible choke points for proposed legislation that they dislike.

Donald McClellan, Jr., senior fellow at the Progress & Freedom Foundation and a former communications counsel to the U.S. Senate Committee on Commerce, Science, and Transportation, also argues that regulation does not promote progress and innovation. He says there are two main reasons the government should not regulate the Internet.

Some groups in the computer industry are also opposed to the government regulating the Internet. SafeSurf is one of them. In an open letter to Sen. Exon, an author of an amendment to the CDA, and Rep. Cox, a co-sponsor of the anti-regulatory Internet Protection Act of 1997, the first sentence reads "We are SafeSurf, a parent's online organization dedicated to protecting children on the Internet without censorship." The letter goes on to say, several times, that SafeSurf is opposed to punishing adults "merely for publishing information on the Internet." They argue that legislation should only be used to punish adults that attempt to deliberately subvert child protection systems and actually try to lure children to sites that contain pornographic material (SafeSurf: Open Letter to Congress). They wish to err on the side of allowing free speech, with the possibility of children seeing something they should not, in contrast to the CDA, CDA II, filtering software, etc., which errs on the side of being overly protective, with an attempt to guarantee that children will be shielded from pornographic material.

The industry itself has also tried to regulate child access to pornographic material. Some measures include the presentation of a credit card number, adult access code, adult personal identification number, digital certificate, or other method that allows each individual site to verify the age of people who wish to enter the site. The Child Online Protection Act requires that sites do this (Child Online Protection Act). This is an impractical method of verifying ages, because it excludes everyone that is unable to obtain such verification. Also, it is not foolproof – for example, children could use their parents’ credit card numbers. A third reason this solution is not easily implemented is because of the high costs to the Web sites. It is because of these problems that we believe this solution should not be used in preventing children from accessing pornography on the Internet.

Microsoft’s Internet Explorer and Netscape’s Navigator both support the RSACi style of site ratings. The RSACi system of ratings provides information about the level of sex and nudity in Web pages. In the creators’ words, it is designed to protect the "rights of freedom of speech of everyone who publishes on the Internet." (RSACi Home Page / About RSACi) This system allows sites to be self-rated ("Netscape to support Web ratings"). There are no requirements that any site be rated, nor is it possible to make this requirement apply to the entire Internet, since there is no international law-making body with the Internet under its jurisdiction. This is not an effective method of preventing children from seeing pornography on the Internet, although it could be used as part of a solution to that problem.

Another type of industry regulation is the use of filtering software. It is designed to be used by the end user, and it prevents sites meeting certain criteria from being displayed on the computer. Filtering software was a good idea to solving the problem of keeping children away from pornography. However, there are problems with filtering software that prevents it from being foolproof. There are several ways in which such software works. The first way in which filtering software works is by containing a list of offensive sites in different categories, such as nudity. This method will certainly not stop access to all sites containing nudity. Another way filtering software works is by blocking all sites that contain key words like "breast" ("How Filters Really Work"). This method prevents access to a large number of sites that contain such words but are unrelated to pornography, and does it guarantee that all offensive sites will be filtered out because of its dependence on sites containing certain key words. A third technique used by filtering software is to block all sites except those on a list of sites known to be clean ("How Filters Really Work"). Again, this method is not foolproof. Given the size of the Internet today and its dynamic structure, we think it is unlikely that it will ever be possible to have a completely accurate list of nonpornographic sites. The fourth technique used by filtering software is blocking access to certain parts of the Internet, such as newsgroups and chat rooms ("How Filters Really Work"). This technique not only blocks parts of the Internet that contain non-questionable material, but it does not block any other areas that may contain questionable material.

Most filtering software uses a combination of the above techniques to improve their accuracy. However, there is no guarantee that no non-pornographic sites will be blocked, nor is it possible to completely filter out all offensive sites. It is also possible for children to access the Internet from other locations besides their homes, such as libraries or friends’ houses. It is for these reasons we feel that filtering software is not the best solution to preventing children from seeing inappropriate material on the Internet.

Ellen Spertus wrote an article for MIT’s Technology Review in which she discussed her research at Microsoft on developing a smarter recognition filter to search for certain phrases or word patterns, rather than a filter based on single words alone. Most of her work deals with hate speech, but the ideas could be applied to detecting pornographic material. One example she gives of a verbal pattern found to be hateful is when "you" is modified by a noun phrase – "you stupid idiot" is more likely to appear than "you good person." (Spertus) Using an artificial intelligence agent is a better solution to filtering most e-mail, Usegroups, and Web pages, but pornographic pictures can be transmitted without accompanying text.

In 1997, the ACLU released a white paper entitled "Fahrenheit 451.2: Is Cyberspace Burning?" Subtitled "How Rating and Blocking Proposals May Torch Free Speech on the Internet," and authored by Ann Beeson and Chris Hansen of the ACLU’s Legal Department and Barry Steinhardt, the ACLU’s Associate Director, it focuses not on Congressional attempts like the CDA to directly regulate pornography on the Internet; rather, it is an investigation into how the ratings systems that are becoming so popular may one day spell the downfall for freedom of speech.

A series of steps is outlined that will most likely lead to government censorship:

• First, the use of PICS becomes universal; providing a uniform method for content rating.
• Next, one or two rating systems dominate the market and become the de facto standard for the Internet.
• PICS and the dominant rating(s) system are built into Internet software as an automatic default.
• Unrated speech on the Internet is effectively blocked by these defaults.
• Search engines refuse to report on the existence of unrated or "unacceptably" rated sites.
• Governments frustrated by "indecency" still on the Internet make self-rating mandatory and mis-rating a crime.

The ACLU’s paper lists six reasons why self-rating schemes, such as that under the RSACi standard, are not effective for the Internet. The first reason is that "self-rating schemes will cause controversial speech to be censored." The paper gives an example of the Critical Path AIDS Project web site, which provides safe sex information "written in street language with explicit diagrams" to teenagers. If unrated, it will be blocked; if rated, it will be blocked along with pornography. The second reason is that "self-rating is burdensome, unwieldy, and costly." The web site Art on the Net is a large, non-profit site that holds more than 26,000 art works; rating each one would require resources beyond the staff’s capabilities. Another reason it doesn’t work is that subjective material, such as art, may be labeled pornographic by one person but an excellent work by another. The third reason self-ratings don’t work is that "conversation can’t be rated." If rating is required, but some people don’t know how to effectively rate their e-mail (or they are afraid of penalties for misrating), they won’t send it. Thus, ratings don’t work well when it comes to chat rooms, newsgroups, or mailing lists. The fourth reason is that "self-rating will create ‘Fortress America’ on the Internet." America will be cut off from the rest of the Internet if ratings are required for sites to show up in search engines or for chat room participation. The fifth reason is that "self-ratings will only encourage, not prevent, government regulation." This is seen in the bills that have been proposed requiring ratings and imposing penalties for misrating. The sixth reason self-ratings don’t work is that they "will turn the Internet into a Homogenized Medium Dominated by Commercial Speakers." The reason for this is obvious.

The ACLU’s paper then considers third-party ratings, but rejects that for several reasons. The main one is that the potential is great for censorship to crop up, especially if one company or standard becomes the standard, such as RSACi. Since both Internet Explorer and Navigator, by far the two most common browsers, use this standard, this fear is already becoming realized. The paper goes on to argue against becoming too dependent on filtering software being used in either the home or libraries, for reasons that are mentioned earlier in this paper.

The ACLU’s paper concludes with its position that the Internet is a medium of incredibly free speech, and that its users should examine current regulation attempts very closely in order to prevent it from becoming "just another mainstream, lifeless medium with content no more exciting or diverse than that of television." The ACLU desires to maintain the freedom that users of the Internet are given, and its paper is an analysis of how that freedom might be taken away.

As the Internet has grown and developed over the few years in its lifespan, the online community has created its own culture, complete with its own set of "rules" and customs by which things are done. One standard that many experienced Internet users adhere to is their belief that there should be no regulation of the Internet, whether it be in respect to content, export regulations (such as the limitations on exporting encryption programs), information, or anything else. The extreme end of this group believes that everything should be free. They believe that source code should be openly distributed, like the Mozilla project or the Open Source Page at www.opensource.org. They distribute commercial, copyrighted, programs over Usenet groups and believe that information about building bombs should be available to all. Although all Internet users certainly do not agree with these views, most do agree with the freedom of online users to say and do what they want, within certain limitations. The online distribution of pornographic material is one topic that has grown over the Internet’s lifespan because of this feeling of freedom.

In the United States, it is illegal to distribute pornographic material to children. Given the availability of easy Internet access, some groups worry that children are finding pornographic material on the Internet. They have lobbied Congress to fix this problem. Congress responded by passing the Communications Decency Act, aimed at preventing Internet users from intentionally sending pornographic material to minors. When the CDA was found unconstitutional, Congress rallied for a second try, passing the Child Online Protection Act (or the CDA II), which makes it illegal for Internet users to post pornographic material on the World Wide Web without restricting access by minors. Other bills attempting to do the same thing as the CDA and CDA II have been proposed, and more will likely be introduced in the future. The industry has also made several attempts at restricting minors’ access to pornographic material, among which are filtering software and ratings systems built into browsers and web pages.

Meanwhile, other groups feel that the Internet should be a free-for-all, with Congress taking a hands-off approach. We do not doubt that children can find such material on the Internet, nor do we agree that they should be allowed access to it. But we do believe that until a solution is found that prevents children from accessing pornographic material while allowing adults access to the exact same material, that there should be no regulation at all. Current attempts by Congress have been unsuccessful in doing so. Until they are able to effectively restrict children’s access to pornographic material while allowing adults access to the exact same material, they should refrain from regulating the Internet at all.
 
 

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