Deeplinks
Don't listen to the telecom lobby. Congress' vote to repeal the Federal Communications Commission's (FCC) broadband privacy rules has a profound impact on your online privacy rights.
According to those who supported the repeal, the rules never took effect (they were scheduled to do so throughout 2017), so the repeal doesn't change anything. You hear it from the likes of AT&T as well as lawmakers like Senator Jeff Flake (R-AZ), the author of the legislation who was asked about it at a recent town hall. You are hearing it now in state legislatures that are working diligently to fix the gap Congress created.
But that argument is meant to distract you from the real issue - you had a legal right to privacy from your broadband provider, and when Congress repealed the broadband privacy rules using the Congressional Review Act (CRA), Congress diminished that right and may have hamstrung the FCC from enforcing it in the future.
Here are the facts.
The FCC’s Broadband Privacy Rules Were Based on a Law Passed by Congress
All regulations passed by federal agencies must be founded in laws passed by Congress. In essence, a regulation from a federal agency is supposed to be a means of enforcing the law. Here, the underlying law is Section 222 of the Communications Act (under Title II of the Communications Act). Congress created Section 222 in 1996 as a means to protect our privacy from telecommunications carriers who have unique access to our communications and personal information. There was a window of time when Section 222 did not apply to broadband companies, but as a matter of law today it does. When you look at what the House and Senate said about the law when they passed it, it is clear Congress intended Section 222 to create an affirmative right to privacy in our communications.
The CRA repeal had a direct effect on Section 222. Obviously if the ISPs spent close to $8 million lobbying Congress to pass it, it must have had some impact. Here is what their money bought. Before the broadband privacy repeal, Internet providers had an obligation to follow all of the legal duties and responsibilities that protect our right to online communications privacy per Section 222 through FCC enforcement. But when Congress utilized the CRA to repeal the FCC’s broadband privacy rules, they effectively told the FCC “you can’t enforce the law in this specific way.” There was a lot to like in the now repealed privacy rules, but now that Congress has prohibited the FCC from enforcing those rules (or passing “substantially similar” rules) as a matter of federal law, it is basically up to the states to step in to fully restore our privacy rights until a new federal law is passed or the courts minimize the impact of the repeal.
Some More History on Section 222 in Terms of Broadband Privacy
From 1996 until 2005, Section 222 applied to telephone service and DSL broadband. It was unclear how the law applied to cable modems because the FCC had not explicitly decided how to classify broadband Internet through cable, though cable companies were generally regulated as television providers by the FCC. In an attempt to resolve this discrepancy and harmonize the application of the law the FCC embarked on a long and ultimately failed journey to classify broadband service as an “information service” under Title I while still retaining oversight akin to that for Title II telecommunications carriers through a now defunct legal theory known as ancillary jurisdiction.
This means that even when cable modems were “information services” as of 2002, and DSL in 2005, the FCC still believed it had authority over broadband companies to do things like enforce network neutrality—and did so during a Republican administration. However, Comcast defeated the “ancillary jurisdiction” theory in the courts and Verizon later defeated the FCC again assuring that anything classified as an “information service” under Title I is no longer subject to any meaningful consumer protections (this is also why Comcast, Verizon and AT&T want to be classified as information services today). If the FCC wanted to retain consumer protection authority over broadband companies, they needed to re-evaluate how it applied the law.
As the high speed broadband market became less competitive and given the dramatic power Internet providers can wield over how we use the web, EFF and others strongly advocated that the FCC put broadband back under Title II of the Communications Act so that the agency could enforce simple, light-touch regulations to protect privacy and net neutrality. The FCC (and federal courts) agreed, and in 2015, in a victory for fans of Internet freedom, the Commission re-classified broadband providers as telecommunications carriers under Title II. That means the law Congress passed in 1996 to protect our communications privacy, Section 222 of the Communications Act, once again clearly applied to all broadband Internet providers.
And This is What Congress Took Away
The FCC’s now-repealed and prohibited privacy rules divided Internet subscriber’s personal information into three distinct categories, each requiring broadband companies to get different types of consent from their customers before they could use or disclose that information. Those categories were “sensitive,” “non-sensitive,” and “exceptions to consent.” Sensitive information, including browsing history, app usage data, and the contents of communications, was given the highest protection. Before they could legally use that information for anything other than providing Internet service, your Internet provider needed your explicit opt-in consent.
The FCC agreed with privacy advocates including EFF that carriers have a legal duty under Section 222 (a) of the Communications Act to protect the "confidentiality of proprietary information of...customers." The now repealed privacy rules were the FCC’s attempt to define the contours of that legal duty. The other category of information that was subject to opt-in consent was “customer proprietary network information” (CPNI), defined as "information that relates to the quantity, technical configuration, type, destination, location, and amount of use of a telecommunications service subscribed to by any customer...made available to the carrier by the customer solely by virtue of the carrier-customer relationship." The full list of what the FCC considered CPNI can be found in paragraphs 58 to 84 of the now repealed Report and Order.
To reiterate, all of these consumer protections listed above are now prohibited as a matter of law and the FCC is not allowed to interpret and enforce the communications privacy law in this way at this time. That is, in essence, what Congress took away with its CRA repeal.
The Cable and Telephone Industry are Not Done Eliminating our Rights
Now that they have a law, Comcast, AT&T, and Verizon are coming in for the final blow against both privacy and Internet freedom. FCC Chairman Pai recently released his plan to reclassify broadband Internet provides as Title I information services. Make no mistake, such a plan will not only end Internet freedom by drastically enhancing the power of Comcast, AT&T, and Verizon to dictate the future of the Internet, but it will assure that any vestiges of privacy protections that remain under a neutered Section 222 are completely removed. Worst yet, the plan ignores the obvious gap in consumer protection that exists for telephone companies ever since the 9th Circuit Court of Appeals found that common carriers are exempt from FTC enforcement as well for the western United States.
We must put a stop to this plan. We came very close to stopping the broadband privacy repeal, and now we have to redouble our efforts, recruit more of our friends, and tell Washington D.C. that we value a free and open Internet that is protected by law.
All surveillance is political.
Nowhere is this more evident than on the local level when law enforcement acquires new surveillance technology. Too often, the political process advantages police over the public interest. In California, a new bill—S.B. 21—offers the rare opportunity to shift the balance in favor of privacy.
Californians: tell your state senator to vote in favor of S.B. 21.
Police know that once they acquire a new spy gadget or system, it’s difficult for elected officials to take it away, lest they seem “soft on crime” during the next election. When police do seek approval of privacy-invasive technology law enforcement agencies often provide only the barest amount of information to policymakers and the public about how a system works and how they intend to use it . Sometimes police officials will avoid the approval process altogether by purchasing equipment with asset forfeiture slush funds, by having them purchased for them by outside nonprofits, or by accepting free trials from vendors.
In the worst cases, police have abused this technology for their own political goals. In Calexico, for example, the U.S. Department of Justice found that police had quietly acquired $100,000 worth of high tech spy gear—GPS trackers, surreptitious audio and video recording devices, tactical binoculars, and even a special backpack for conducting field surveillance. These officers then used this technology to spy on elected officials and members of the public who filed police complaints, allegedly with the motive of extortion. The DOJ also criticized Calexico for approving body cameras, automated license plate readers, and a city-wide video system "before implementing the essential fundamentals of policing."
Police should not have unilateral power to decide which privacy invasions are in the public interest.
It’s time for Californians to seize back control of these surveillance technologies. Police should not have unilateral power to decide which privacy invasions are in the public interest. All surveillance technologies must go through a public process in which citizens and elected officials have a chance to decide the limits of high-tech policing, including whether to acquire and use new spying tools in the first place.
EFF urges the California legislature to pass S.B. 21, a surveillance technology reform bill introduced by State Sen. Jerry Hill. This legislation would require that police departments, before acquiring or using new spying technology, obtain approval in advance to do so from an elected board during a public hearing. When police obtain such approval, they must also get approval of a use policy that includes privacy safeguards.
The bill would require a biennial transparency report on surveillance technology in which an agency must disclose information such as the total cost for each surveillance technology, the number of times each technology was used, how effective the technology was, instances in which technology was shared with another agency, and instances in which the technology was used in violation of department policy.
The bill would also allow individuals to sue an agency if they’ve been harmed by a violation of the legislation.
S.B. 21 follows on the heels of similar legislation passed in Santa Clara County and an ordinance approved by the City of Oakland’s Privacy Advisory Commission. The legislation also strengthens previous laws passed by Sen. Hill, S.B. 34 and S.B. 741, which require government agencies to publish privacy policies for automated license plate readers and cell-site simulators respectively.
California should end unconstrained police surveillance. There is a clear way to defend against secret acquisition and arbitrary use of policing technologies that invade the privacy of thousands of innocent people per usage: pass bills like S.B. 21 to ensure the law is on our side.
This week EFF is in Geneva, at the Thirty-Fourth session of the Standing Committee on Copyright and Related Rights (SCCR) of the World Intellectual Property Organization (WIPO), to oppose a Broadcasting Treaty that could limit the use of video online. Ahead of this meeting, word was that delegations would be pushing hard to have a diplomatic conference to finalize the treaty scheduled at WIPO's October Assembly. In combination with initial uncertainty about whether the new United States administration would be maintaining its opposition to a diplomatic conference, we knew that it was important for EFF to be there to speak up for users.
The Broadcasting Treaty proposal simply doesn't make sense. It proposes to create a new layer of rights over material that has been broadcast over the air or over cable, in addition to any underlying copyrights over such material. Such rights would increase the cost and complexity of licensing broadcast content for use online, and create new and artificial barriers to the reuse of material that isn't protected by copyright at all, such as governmental and public domain works.
We'd like to be able to tell the delegates what we think about this, and normally we would be able to do that, because WIPO generally allows NGOs to deliver statements in its plenary meeting sessions. However this meeting has a new chair, whose working style involves fewer plenary sessions, and more informal sessions where which NGOs are only permitted to listen, not to speak or report. As as result, it's likely we won't have the opportunity to address delegates about until later in the week, if at all. But here is what we plan to say:
This week the Standing Committee has worked very hard to move the negotiations over the Broadcasting Treaty towards a diplomatic conference. Yet it appears to us that disagreements continue to exist at such a fundamental level, extending to the very objects of the treaty, that agreement remains unattainable.
The closest this Committee has ever come to agreement was when it narrowed the Treaty to cover only broadcasting organizations in the traditional sense from broadcast signal piracy. But as soon as the discussion is broadened to include transmissions over computer networks or post-fixation rights, it inevitably falls apart.
This is because there is no logic in granting exclusive rights to broadcasting organizations over Internet transmissions, without granting similar rights to other online video platforms. And if that is done, the new layers of rights and rightsholders will increase the complexity and risk of licensing video content, raising costs and barriers to innovation that outweigh any possible benefit to broadcasters.
We also have specific concerns that the current chairman's draft moves the proposal in the wrong direction, by eliminating previous text on limitations and exceptions, entrenching the inimical effects of Technological Protection Measures that criminalize fair use and innovation, and proposing a 50 year term -- 30 years longer than the term of protection under the Rome Convention.
More fundamentally, this treaty creates an unnecessary impediment to the legitimate reuse of broadcast material that is in the public domain, with little corresponding benefit. In our view the committee's time would be better invested by removing this item from the agenda to make more room for other relevant issues, such as the analysis of copyright related to the digital environment.
Overturning the Supreme Court Decision Would Allow Abstract Patents to Hurt innovation
One of the most important cases to cut back on the availability of vague, abstract patents was the 2014 decision Alice v. CLS Bank. In Alice, the U.S. Supreme Court reaffirmed the long-standing law that patents could not be granted on "laws of nature, natural phenomena, and abstract ideas." The decision reinvigorated the use of 35 U.S.C. § 101 to invalidate abstract patents based on the fact that they claim unpatentable subject matter.
Alice was a watershed moment. In the decades before Alice, the Court of Appeals for the Federal Circuit—the court that hears all patent appeals—had consistently expanded the scope of patentable subject matter. The case law was to the point that it seemed that so long as something was done "automatically," anything could be patented, including business methods, investment strategies, and patenting itself.
Since Alice, lower courts have routinely invalidated some of the worst abstract and vague patents. We've highlighted many of these abstract patents in our Stupid Patent of the Month series. There was also the patent on a "picture menu" that was used to sue over 70 companies. And the patent on using labels to store information in a data structure that, on being invalidated as abstract, ended an astonishing 168 cases.
Recently, we've heard that certain patent owners are lobbying Congress to modify 35 U.S.C. § 101 and legislatively overrule Alice. Many of these advocates like to claim that the software industry and innovation have been seriously harmed by Alice. But what has really happened?
Currently, five of the top 10 companies by market capitalization are information technology focused, a significant shift from ten years ago when only Microsoft made the cut. Tesla, who famously announced they were abandoning patents, is now the highest valued U.S. car maker. The 2017 Silicon Valley Report from Joint Venture Silicon Valley noted “seven straight years of economic expansion” in the Bay Area, a region known for its innovation.
Smaller innovators are also going strong. The Kauffman Index of Startup Activity shows a sharp increase in activity between 2014, the year Alice was decided, and 2016. Employment in the innovation and information products field in Silicon Valley grew by 5.2% between 2015 and 2016, more than any other category, and venture capital investment remains strong. Thus if Alice were in fact "decimating" the industry as one judge on the Federal Circuit predicted, there is little evidence of it. To be clear, this isn’t to say that Alice is the only reason the industry is thriving, but it is a reminder that software patents and the software industry are not the same thing.
Not only do current trends in the industry show that Alice did not harm the technology sector, but past trends confirm it. When the Federal Circuit dramatically expanded the scope of patentable subject matter, first in 1994 and again in 1998, there is no indication the shift provided additional stimulus to the already growing economy. Indeed, there is evidence that patenting has little effect on innovation. A 2014 Congressional Budget Office report noted that "the large increase in patenting activity since 1983 may have made little contribution to innovation," and in fact, "the proliferation of low-quality patents" were working to prevent small innovators from easily entering the market.
Alice has not harmed the technology industry and the argument for overturning it just isn't based in fact. If anything the evidence shows abstract patents do more to harm the technology industry than help it. Alice is working to rid the system of vague and overbroad abstract patents, without any serious negative effect on the technology sector, and should remain the law.
Republicans in Congress recently voted to repeal the FCC’s broadband privacy rules. As a result, your Internet provider may be able to sell sensitive information like your browsing history or app usage to advertisers, insurance companies, and more, all without your consent. In response, Internet users have been asking what they can do to protect their own data from this creepy, non-consensual tracking by Internet providers—for example, directing their Internet traffic through a VPN or Tor. One idea to combat this that’s recently gotten a lot of traction among privacy-conscious users is data pollution tools: software that fills your browsing history with visits to random websites in order to add “noise” to the browsing data that your Internet provider is collecting.
One of the goals of this post is to dispel misconceptions about these tools regarding problems users may think they solve.
We’ve seen this idea suggested several times, and we’ve received multiple questions about how effective it would be and whether or not it protects your privacy, so we wanted to provide our thoughts. Before we begin, however, we want to note that several seasoned security professionals have already weighed in on the effectiveness and risks involved in using these tools.
While we want to be optimistic and encourage more user-friendly technology, it’s important to evaluate new tools with caution, especially when the stakes are high. Additionally, one of the goals of this post is to dispel misconceptions about these tools regarding problems users may think they solve.
Limitations of ISP Data Pollution Tools
After reviewing these sorts of tools, we’ve come to the conclusion that in their current form, these tools are not privacy-enhancing technologies, meaning that they don’t actually help protect users’ sensitive information.
To see why, let’s imagine two possible scenarios that could occur if your browsing history were somehow leaked.
First, imagine the tool visited a website you don’t want to be associated with. Many data pollution tools try to prevent this by blacklisting certain potentially inappropriate words or websites (or only searching on whitelisted websites) and relying on Google’s SafeSearch feature. However, even with these protections in place, the algorithm could still visit a website that might not be embarrassing for everyone, but could be embarrassing for you (say, a visit to an employment website when you haven’t told your employer you’re thinking of leaving). In this case, it might be difficult to prove it was the automated tool and not you who generated that traffic.
Second, sensitive data is still sensitive even when surrounded by noise. Imagine that your leaked browsing history showed a pattern of visits to websites about a certain health condition. It would be very hard to claim that it was the automated tool that generated that sort of traffic when it was in fact you.
It’s reasonable to assume that whoever is analyzing this data will put some effort into filtering out noise when looking for trends—after all, this is a standard industry-wide practice when doing data analysis on large data sets. This doesn’t necessarily mean that the data analysis will always beat the noise generation, but it’s still an important factor to consider. Likewise, layering noise onto a prominent pattern will not make that pattern any less prominent. Additionally, your Internet provider may already have years of data about your browsing habits from which it can extrapolate to help with its noise-filtering efforts.
Even if these specific problems were solved, we would still be reluctant to say that data pollution software could successfully protect your privacy. That’s because this kind of traffic analysis is an active area of research, and there aren’t any well-tested large scale models to show that these techniques work yet.
In other words, there are currently too many limitations and too many unknowns to be able to confirm that data pollution is an effective strategy at protecting one’s privacy. We’d love to eventually be proven wrong, but for now, we simply cannot recommend these tools as an effective method for protecting your privacy.
Changing Internet Provider Behavior is a Worthy Goal, but Your Energy is Better Spent Calling Congress
Data pollution tools aren’t likely to succeed at their other primary goal besides protecting privacy: convincing Internet providers to stop mining our data to sell targeted ads. The theory here is that if enough people used these tools, then the vast majority of browsing data Internet providers collected would be inaccurate. Inaccurate data is worthless for targeting ads, so there would no longer be any monetary incentive for Internet providers to try to sell targeted ads—and thus no incentive to keep collecting browsing data in the first place.
Unfortunately, a huge fraction of customers would have to be using data pollution tools for them to have an impact on major Internet providers’ bottom lines. And while it's wonderful to imagine the majority of Internet users up in arms and installing one of these projects, it'd be as useful (if not more so) for all these users to call their lawmakers directly and convince them to pass privacy-protecting legislation instead. In fact, it would probably take far fewer people to get Congress to change its mind than it would to affect a large Internet provider’s bottom line.
Culture Jamming for the Web
With all of that said, these tools could potentially be effective at one thing: confusing your Internet provider’s ad-targeting algorithms and making the ads they show you less relevant. If this sort of culture jamming appeals to you, then these tools could help you accomplish that. Just keep in mind that you’ll have to rely on other techniques to protect your privacy from your Internet provider, and that to really achieve the sort of change we need, we also need to take the time to talk to our lawmakers and make our voices heard directly. Only through a combination of activism, technology, and legislation will we truly be able to protect our privacy online.
For years, U.S. government surveillance of innocent Americans has been a topic of heated debate, especially for those in the tech community.
With Congress gearing up for a fight over the 2017 reauthorization of a surveillance authority that lets the NSA spy on innocent Americans without a warrant—Section 702, enacted as part of the FISA Amendments Act—that debate is sure to rage on in the coming months.
So we sent reporter David Spark to the RSA Conference in San Francisco, California in February to ask one simple question: What don’t you want the NSA to know about you?
The answers spanned the spectrum, from emails, to phone calls, to web browsing records, to financial information, to information about individuals’ children, to nothing.
Some got philosophical. “Everyone says, ‘I have nothing to hide,’ and that’s not the point,” one attendee told us. “The point is that I want to control what people know about me.”
Others turned the question on its head, asking instead why the NSA is conducting surveillance on Americans. “I don’t think their charter is to spy on Americans, so why are they?” one asked.
And some got blunt. One attendee said he already assumes the NSA knows a lot about him already. “It scares me and offends me,” he said.
If the warrantless spying on Americans scares and offends you, contact your representatives in Congress and tell them to pull the plug on Section 702 surveillance. And watch the video to see other RSA Conference attendees’ responses.
Special thanks to David Spark (@dspark) and Spark Media Solutions for their support and production of this video. The background music heard at the end—the song Hydrated—is licensed CC BY-NC-SA 3.0 by Kronstudios. EFF original work (i.e., every thing but the background music heard at the end) is licensed CC BY 4.0.
Online platforms must be allowed to assert their anonymous users’ First Amendment rights in court, EFF argued in a brief filed Monday in a California appellate court.
The case, Yelp v. Superior Court, concerns whether online review website Yelp has the legal right to appear in court and make arguments on behalf of its users.
Courts across the country have increasingly recognized that online platforms do have the right to argue for their users’ free speech rights, particularly when private litigants or government officials seek to learn the speakers’ identities.
A California trial court, however, ruled in December 2016 that Yelp could not assert a user’s First Amendment rights after the platform received a subpoena seeking the identity of a Yelp user that a plaintiff alleged had defamed him and his business.
But as EFF’s brief [.pdf] argues, online platforms have both a legal right and an important role to play in asserting their users’ free speech rights.
Besides anonymous speakers asserting their own rights to directly challenge the legal demands to unmask them, online platforms are increasingly asserting their users’ rights in court. Platforms assert their users’ rights for a variety of reasons, including deterring frivolous efforts to unmask speakers and upholding their own platforms’ views on the importance of free speech. They also seek to make their platforms hospitable to important speech that may only be offered under the veil of anonymity. Simply put, many online platforms recognize that a key to maintaining the robust forum their users rely upon requires having their users’ backs.
The trial court’s ruling is dangerous, EFF argues, because it “threatens to undermine online platforms’ standing to assert their users’ First Amendment rights and thereby erode the ability for the Internet to serve as a forum for anonymous speakers.”
If platforms do not have a legal right to stand up for their users, “defense of these vexatious requests will fall solely to users themselves, many of whom may not know their rights or may otherwise not be in a position to fight for them,” EFF’s brief argues.
Two weeks ago the Copyright Society of China (also known as the China Copyright Association) launched its new 12426 Copyright Monitoring Center, which is dedicated to scanning the Chinese Internet for evidence of copyright infringement. This frightening panopticon is said to be able to monitor video, music and images found on "mainstream audio and video sites and graphic portals, small and medium vertical websites, community platforms, cloud and P2P sites, SmartTV, external set-top boxes, aggregation apps, and so on."
When it finds content that matches material submitted to it by a copyright holder, the Center provides them with a streamlined notification and takedown machine, from the issuance of warning notices through to the provision of mediation services. The Center's technology service provider also provides platforms with filtering technology that can allow infringing materials to be blocked from upload or download to begin with, obviating the need for a separate takedown procedure.
The Copyright Society of China, which instituted the 12426 initiative, is formally a private association, and lists amongst the venture's partners American media companies such as 21st Century Fox and Warner Bros. On the other hand, the Society is headed by a representative of the National Congress of the Communist Party of China, and includes within its mission "to provide technical support for the government to carry out network copyright supervision according to law."
The 12426 service utilizes proprietary commercial technology for its copyright monitoring, and much of the same technology is used by Chinese Internet companies for complying with Chinese government mandates for political censorship. For example, earlier this month it came to light that the Chinese government, at least at a provincial level and possibly at a national level, requires every provider of non-residential public Wifi hotspots to monitor and record their users' activity. This is in addition to the well-documented surveillance and censorship of Chinese online platforms such as Weibo and WeChat.
Copyright Surveillance and Censorship Closer to Home
Although this stifling surveillance machine is a human rights crisis in its own right for China's 720 million Internet users, it also provides a cautionary tale for the West, where copyright holder lobbyists are advocating for very similar filtering and surveillance mechanisms to be made mandatory. In that sense, China's copyright surveillance machine of today may warn of the European or American Internet of tomorrow.
For example, it is thanks to the copyright industry that German Wifi network operators are required to password-protect their networks to prevent them being used by anonymous users (who might infringe copyright). And in Europe right now, a current proposal would require user content platforms to filter uploads for material that copyright holders claim to be infringing.
This European proposal would put into place exactly the same kind of filtering that China's copyright surveillance industry provides today, repurposing technologies that the authoritarian regime also uses for the repression of political dissent. And this kind of repurposing goes both ways—technologies and legal processes developed in the first instance for copyright enforcement are also misused for political censorship and repression.
Another uncomfortable similarity between the Chinese Internet censorship regime and developments in the West is the close intermingling of public and private initiatives. Just as the Chinese Community Party sits at the head of the Copyright Society of China, so too the heavy hand of government can be found behind many notionally self-regulatory industry schemes from North America and Europe that aim to address copyright infringement. These government-led arrangements, that we call Shadow Regulation, are notoriously lacking in transparency, accountability, and user participation. The above mentioned European proposal, which pushes platforms and copyright owners into "voluntary" agreements concerning upload filtering, is a textbook case in point.
The announcement of China's government-linked 12426 Copyright Monitoring Center is absolutely chilling. It is just as chilling that the governments of the United States and Europe are being lobbied by copyright holders to follow China's lead. Although this call is being heard on both sides of the Atlantic, it has gained the most ground in Europe, where it needs to be urgently stopped in its tracks. Europeans can learn more and speak out against these draconian censorship demands at the Save the Meme campaign website.
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