[Ir-l] [IR-L]: threats to free speech via defamtion law

[Dave Bird]

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On: 20 Apr 2000 10:17:54 -0000, in Newsgroups: uk.current-events.usenet-
censorship, uk.politics.censorship, alt.censorship, demon.service,
In<3F719232BAA at 127.0.0.1>, Frog <FrogRemailer at NoReply.org> wrote:
>________________________________:
>________________________________:
>Applying the law to the Internet:
>--------------------------------:
>--------------------------------:
>An FIPR Briefing Paper

(Draft, for discussion, released without permission)

In<002b01bfae35$a1612060$0100a8c0 at DIRECTOR>, 
  Caspar Bowden <cb at fipr.org> writes:
: ***************************
: I'm grateful for the comments about the paper made on the 
: cyber-rights list, but it would be unfair to the members of 
: our Advisory Council if I did not make its status as a FIRST 
: DRAFT crystal clear....8<...if you have further comments to 
: make, you might want to e-mail me direct - but I'm afraid I'm 
: too busy on RIP at the moment to guarantee a response.
:
My own comments follow underneath.  Public debate here or threaded 
to this article on those newsgroups wellcomed by me :-> :-> :->

>The recent out-of-court settlement of the Laurence Godfrey v Demon
>Internet defamation case has been seen by many commentators as a
>landmark in the application of the law to the Internet. However, this
>shows a poor understanding of the actual issues and of the history of
>the subject. In fact, the details of the case make it of limited
>relevance and the key judgment was made over a year ago. What is more,
>it was not even the first "Internet libel" case in the UK, that "honour"
>going to Laurence Godfrey v Philip Hallam-Baker back in 1996, nor the
>first time an Internet Service Provider (ISP) has been taken to court in
>the UK! Dr Laurence Godfrey has previously issued writs against
>Australian, New Zealand, Canadian and American based organisations.
>
>The real importance of the case has been that it has brought the issue
>of the liability of ISPs into the limelight and it has intensified the
>debate as to how best to arrange for justice, as well as the law, to be
>applied to the Internet.
>
>This rest of this briefing reviews the salient facts of the recent
>Godfrey cases, then moves on to discuss the position of ISPs under the
>Defamation Act 1996. It covers Copyright issues, the upcoming EIJ
>Electronic Commerce Directive and then surveys the law in the USA.
>
>A practical framework for moving forward from the present unsatisfactory
>situation is then proposed. This balances the rights of individuals and
>companies against those who publish material on the Internet, whilst
>also providing suitable safeguards for ISPs so that they can continue to
>compete effectively for business in the global marketplace.
>
>Godfrey v Demon
>
>Two cases were settled on the 30th March. They differ in some of the
>details.
>
>The first case relates to events in January 1997 when an unknown user of
>an ISP in Ohio, USA forged a "Usenet" article in the name of Dr Laurence
>Godfrey. The article was "squalid, obscene and defarnatory". Godfrey
>immediately posted articles to deny he was the author and tried, and
>failed, to persuade the American ISP to reveal the identity of the
>forger.
>
>Usenet works by distributing articles to hundreds of thousands of local
>servers where they will be preserved for a week or two for customers to
>read. After that time they "expire" and are deleted, though some systems
>may archive them for longer-term access. A few days after the article
>had been posted, Godfrey became aware that the article was still
>available on Demon's news service and requested its removal. Demon took
>no action. When Godfrey's solicitor wrote formally, the article had
>already expired from Demon's service, but Demon made no response the
>letter. Godfrey issued a writ in January 1998. In a March 1999 hearing
>Mr Justice Morland struck out Demon's defence under Section 1 of the
>Defamation Act.
>
>The second case relates to events in the summer of 1998. A user of an
>anonymous posting service published articles in several newsgroups that
>made defamatory claims about Dr Godfrey's personal life. These articles
>were almost immediately cancelled so that they were no longer available.
>However, whilst they were still available a Demon Internet customer
>retrieved a copy and re-posted the remarks along with some sardonic
>commentary of his own. Godfrey asked for this article to be removed and
>cancelled, but Demon did not act.
>
>The first case was settled for a payment of £5,000, the second for
>£10,000. Dr Godfrey's costs (said to be of the order of £230,000) are to
>be paid by Demon.
>
>The Defamation Act 1996
>
>As can be seen from the facts set out above, there would never have been
>any legal action if Demon had acted upon Dr Godfrey's requests. However,
>Demon sought to claim that because the operation of the news server was
>automatic the Defamation Act 1996 excused them from liability. Mr
>Justice Morland held that this was "in law hopeless" and struck out
>their defence.
>
>It should be noted that there are some special definitions of "author",
>"editor" and "publisher" in the Defamation Act - they do not quite have
>their everyday meanings. Under the Act, Demon was not a publisher, but
>failed to meet the other tests in Section 1(1) since they had been put
>on notice of the existence of the defamatory material. The other
>defences under the Act of just being the printer or transporter of the
>material were not applicable, with the crucial issue being the amount of
>potential control over future publication.
>
>The operation of the Defamation Act is usually described as a "notice
>and take-down" regime. ISPs have substantial protection until they are
>put on notice. When the notice is served they must promptly take down
>the material to escape liability.
>
>ISPs as judge and jury
>
>When articles are clearly defamatory then "notice and take-down" sounds
>simple to operate. However, not every case is clear and so the ISP will
>incur the expense of getting a legal opinion. "Vulgar abuse" will not be
>held by the courts to be defamatory - but expert advice may be needed in
>order to distinguish the nature of a particular example of invective.
>
>il Having removed the material the ISP's problems are not at an end. The
>author may admit the I ldefamation but claim justification - what they
>said was true - and require that their contract I twith the ISP be
>honoured and their material be reinstated. Should the ISP hold a private
>trial to decide the merits of the case? If the ISP seeks a legal
>indemnity from the author and reinstates the material, what then is
>their position if the author turns out to be a "man of straw" and the
>indemnity is worthless? If the author promises future good behaviour
>then has "reasonable care" been taken by any ISP who thereafter offers
>the author access to the Net?
>
>The most immediately obvious result from the March 1999 ruling was a
>substantial rise in the number of complaints being made to ISPs (Demon
>is now receiving several complaints a week). The expense of judging
>these complaints in a fair and consistent manner is clearly substantial.
>One must expect to see ISPs, particularly those who are providing
>low-margin services, starting to take the view that it is too expensive
>to be "right" and that automatic action upon complaints, whatever their
>merits, will be rather more cost-effective.
>
>Of course defamation is not restricted to Usenet. There are, if
>anything, more complaints being made to ISPs about web sites -
>particularly as people start to use the new medium for campaigning.
>Problems have occurred with sites dealing with miscarriages of justice
>and attempts to discuss the operation of local councils' social services
>and planning departments. Since the ISPs will never be in a position to
>decide whether a campaigning site is actually telling the truth - when
>complaints are made it is inevitable the site will be removed.
>
>To guard themselves against the liability that would arise if the
>campaigners turned out to be right and hence the site was not unlawful -
>the ISPs will be increasingly adding clauses to contracts that allow
>them to act almost arbitrarily to remove material. This will dismay
>legitimate businesses who will see these clauses, as they potentially
>apply to them, as unfair or unreasonable. There is a considerable risk
>that business will be tempted offshore where web-hosting services do not
>have such apparently one-sided provisions.
>
>Now of course all of the problems that the "poor unfortunate ISPs" have
>are exactly those that have been faced by book publishers, high street
>newsagents, magazine publishers (and even Golf Club noticeboards!) for
>decades. However, there are some very important differences. The first
>is one of scale. Literally millions of people are now creating content
>on the Internet and that material can be seen by tens of millions. The
>lack of filtering by professionals before publication makes defamation
>several orders of magnitude more likely to occur.
>
>The second difference is the equality the Internet provides. Individuals
>defamed on the Internet will often have similar access to the medium in
>order to rebut the defamatory statement and they can do this almost
>immediately. This differs from the conventional media where publishers
>and broadcasters may have to be compelled to publish a retraction, which
>can be much delayed and far less prominent.
>
>The main difference that the ISPs experience is one of global
>competition. W.H. Smith operates under the same legal regime as John
>Menzies, but placing web sites on the other side of the planet, where
>ISPs are immunised against their customers' actions, is just as easy and
>effective as hosting them at the centre of the UK Internet industry in
>London's Docklands.
>
>Copyright and other laws
>
>This briefing has, so far, been concentrating on defamation - but this
>is just the tip of a very large iceberg. Copyright infringement and
>misuse of Intellectual Property is extremely widespread and once again
>the ISP must act as judge and jury to decide the merits of a case. If
>Disney complains that a website contains an unlicensed image of Mickey
>Mouse then it may be easy to make a decision. What if (and Demon report
>this as a real life case) two lingerie companies each counterclaim that
>a photograph of model wearing their goods is their property and the
>other is infringing. The ISP has a 50/50 chance of making the right
>decision - and if the wrong decision is made then there will be
>considerable damages to be paid for both continuing to publish the image
>and for removing a website for no valid reason.
>
>Besides a whole raft of civil issues, there are some criminal offences
>that can be committed by publishing material - sedition and blasphemy
>may not be fashionable, but they are still on the statute book. Looking
>at more modem concerns, it is also possible to commit offences under the
>Race Relations Act and indeed publishing instructions on how to grow
>cannabis or synthesise LSD are unlikely to be lawful. Although in many
>cases the rights and wrongs would be obvious, there will always be cases
>that are difficult to decide.
>
>The ISP industry has addressed one particular criminal issue, that of
>publishing "child pornography" by setting up the Internet Watch
>Foundation (IWF). This body acts as a clearinghouse for the industry,
>operating a hot line for the public and doing some proactive scanning of
>areas where the material is common. It uses its expertise to determine
>if images are illegal and advises ISPs accordingly as to whether
>material needs to be removed.
>
>Industry and the Government perceive the IWF to be an effective way of
>dealing with a complicated problem, but it is not cheap to run. The ISP
>industry would not welcome the extra financial burden of funding further
>centralised bodies to address other issues such as defamation or
>copyright infringement.
>
>The European ECommerce Directive
>
>The Draft European ECommerce Directive - which is expected to be
>completed this year - provides for a defence of "mere conduit" to
>protect network providers who are merely shifting packets around. There
>is a further protection for the operators of caches who are storing
>information locally to avoid the expense, and delay, of continual
>fetching data from its onginal remote site
>
>Article 14 of the Directive on "hosting" requires member states to
>protect ISPs from liability where they are unaware of the content of
>information stored on their systems. It further provides for a "notice
>and take-down" regime, without, as is appropriate for a Directive,
>specifying the details of how this should actually be implemented.
>
>The law in the USA
>
>The USA grants substantial immunities to ISPs. In particular, the
>Telecommunications Act of 1996 230(c)( 1) provides that in many
>circumstances "No provider or user of an interactive computer service
>shall be treated as the publisher or speaker of any information provided
>by another information content provider."
>
>Furthermore the Digital Millennium Copyright Act 1998 (Title II)
>provides several clear schemes to protect ISPs and network operators.
>There are specific immunities for transitory digital communications and
>for "caches" that provide "automatic technical processes" for local
>storage of material to reduce bandwidth costs.
>
>The most interesting part of the DMCA is the way in which copyright
>infringement by ISP customers is dealt with. The Act provides for a
>"notice and take-down" regime within which the ISP does not decide upon
>the merits of a notice but has merely to act upon it. The law also
>describes a "counter notif1cation'' that can be used by the author of
>material to have it replaced. Again the ISP has no freedom of action but
>merely obeys the notice.
>
>In our view, the process described in the DMCA has significant
>advantages for all parties and we will now describe a version of this
>regime, applying it to all issues, not just copyright:
>
>Report, Remove, Respond and Replace (or R4 reasonable redress)
>
>We recommend the following scheme to the Government. We believe that it
>finds an appropriate balance between inconvenience to ISPs and prompt
>justice for those who are suffering harm. It is intentionally designed
>to be "lightweight" and in very many cases it rnay operate without the
>courts becoming involved at any stage.
>
>The scheme is presented as a series of steps with commentary as
>appropriate. It is envisaged that the procedure would apply not only to
>all civil actions, but also to criminal matters where it would be usual
>for the police to issue the relevant initial report. The main technical
>challenge for the lawyers will be how to place it onto the statute book
>in such a way as to affect a wide range of existing laws. However, this
>is likely to be necessary anyway for the legislation that will soon be
>required to implement the ECommerce Directive.
>
>1. Report of material to be removed
>
>The aggrieved party reports the exact material that is being complained
>about and that needs to be removed. The report must include the real
>world identity of the complainant to enable the ISP to check that the
>report is genuine. By making a report to an ISP in the UK, the
>complainant is submitting to the jurisdiction of the British courts. It
>would be an offence (equivalent to perjury) to knowingly make an
>incorrect report. It might be wise to obtain legal advice before issuing
>a notice, but in straightforward cases this will probably be an
>unnecessary expense.
>
>The USA legislation requires the ISP to register a service address for
>notices. This has the effect of simplifying internal procedures for
>dealing with notices. However, it should not be necessary to go as far
>as the Americans and remove all the protection the procedure gives if no
>service address is registered.
>
>2: Removal of material
>
>The ISP removes the nominated material, in a timely fashion, and reports
>on this to its author. In removing the material, the ISP is indemnified
>against both the issuer of the report and the original author of the
>material, who may or may not have a contract with the ISP.
>
>Some might argue that it is for the author to remove the material, but
>it is to be expected that the ISP will be able to do this quite rapidly
>and thus mitigate the damage that is being done. Authors may
>intentionally refuse to respond quickly and, since Internet "time" moves
>so much faster than the clock, this will in itself magnify the damage.
>
>3. Response by the author
>
>The author may readily accept that their material - perhaps they posted
>it to Usenet whilst inebriated should never have appeared. The aggrieved
>party may still take action in the courts, but the likelihood is that in
>many cases the incident will end here.
>
>However, the author may respond that their material should not have been
>removed. They may say that it was legal and that a rnistake or a
>misidentification has been made. They can then choose to either fight in
>the courts or to issue a Replacement Notice to require the ISP to
>replace the rnaterial. Once again, false statements would be a serious
>offence.
>
>We feel that in the great majority of cases, where damage will not be
>unduly magnified by a slight delay, the author should be given the
>opportunity, prior to removal, to provide their formal response and thus
>prevent the material from being removed at all.
>
>4. Replacement of material
>
>The ISP acts on any Replacement Notice that they receive. Once again, if
>their action is timely, then they incur no liability to anyone by doing
>this. It remains open for the aggrieved party to take action in the
>courts to ensure the removal of the matetial, but provided the ISP obeys
>any order of the court, it would not be liable for damages or costs.
>
>There is the possibility that orchestrated campaigns might cause sites
>to become unavailable for long periods through serial issuing of removal
>notices. It would be appropriate to allow for a court to order that
>particular sites have some immunity from removal notices.
>
>Summary
>
>Mr Justice Morland's judgment of March 1999 confirmed that the
>Defamation Act applies to material posted on the Internet - which should
>have surprised no one. However, "notice and take-down" is putting
>burdens onto UK ISPs that foreign competitors do not have. This burden
>has been increasing rapidly and the publicity surrounding the settlement
>of the Godfrey case will make things worse.
>
>The R4 approach, which can be seen "here, now, working" in the USA's
>Digital Millermium Copyright Act provides a straightforward solution.
>The key legal supports are that the ISPs are not liable if they follow
>the process and that malicious or negligent claimants can be penalised
>by the courts. The public policy result will be that the law will be
>applied on the Internet without having to co-opt the ISPs to become the
>judge and jury.
>
>Richard Clayton, FIPR Advisory Council Member 3 April 2000

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 Herewith the response I made to this originally, and
 again when it appeared on cyber-rights list.
 ====================================================

 I am not Froggie, but I have certainly seen this... not last
 week but the week before. I was too wrecked to travel again at
 the weekend, so spent some time then analysing the faults in
 this document; which was supposed to appear on www.fipr.org
 within days (I am not in the league of being an FIPR person, 
 I'm a layman not "industry" or lawyer).  

 I strongly think this sort of this SHOULD and MUST be discussed
 on ordinary lists and newsgroups, among its victims as well as 
 proposers.  Given Demon's current mad behaviour, I would hardly
 be happy to let outsiders and IPSs determine or fate for us in secret.

 Main points. 1--Defamation should be no harder AND NO EASIER to
 enforce than off line.
 2--Decision should be removed entirely from ISPs [see only Demon's
 current behaviour as reason why], ISPs don't want it either.


      ++++++++++++++++++++++++++++++++++++++++++++++

         ..........pointing out aspects
 of the "industry view" that have insufficient regard to user interests
 (and actually are bad for the industry too).  Reply MkII :->

 I wish to discuss, outwith developing these recommendations,
 certain aspects of the current situation... see elsewhere.

 This reply is written on the basis that, while I may not approve
 of current censorship laws or want them extended to the Internet
 in this form, then -- should you recommend this -- I would expect 
 the following changes for fairness and precision.

                  ==============

 These proposals are primarily for the benefit of the ISP, so
 that he has an exact procedure with no variation by which he 
 may exempt himself from liability:  by making it entirely 
 a matter between the complainant and author. As a side effect 
 it may make authors resolve disputes without troubling the courts,
 where they wish this. In effect it takes the ISP out of the loop 
 because whenever he receives the equivalent of a solicitor's letter, 
 he simply turns round to the author and says "I need to be assured 
 you have a proper response to this."

 #############################################################
 It is intended only that those who can enforce defamation or
 IP rights now can equally enforce them on the Internet. It is
 not intended to make the Internet *more* open to removal of
 material than other media, nor -- given the "playful spirit"
 of the Internet -- to open up ISPs or anyone else to nuisance 
 by floods of meritless notices. 
 #############################################################




 REPORT.......

 [**0] ISPs should not be required to register, but shd make available
 contact details for notices in writing and telephone confirmation
 which are picked up in reasonable, proportionate to the size and hours
 of business, time.

 The report must be in writing and signed, with real world contact
 details for written and telephone reply.  If they get no response,
 they would be prudent to make the ISP aware by phone. The complainant
 affirms under penalty of perjury, BY VIRTUE OF MAKING THIS NOTICE,
 he has assured himself he has a case that material held by the ISP 
 is unlawful against him or a person he is authorised to represent 
 and that -- absent any resolution -- he is willing and able to pursue 
 it in UK courts against the author. He should specify exactly the 
 names of all files or documents which are infringing, and how which 
 passages of the worst examples infringe what law; together with any 
 basic ownership information in the case of intellectual property.

 .....AND REMOVE.

 [**1] The ISP shd satisfy himself that the complaint has the above form
 and contains the required information, taking the complainant's word
 for its truthfulness,
 [**2] and that he has some of the named documents by the named author;  
 [**3]he must also make one ATTEMPT to verify the
 complaint e.g. by phone, and one ATTEMPT to contact the author.

 He must then act on the notice as soon as possible from being aware 
 (within three hours of business trading?) and anyway with reasonable 
 speed (by the same time next whole business day?).  He must stop 
 the document/s being readable on that medium or the author reassert
 -ing them there before a response is given. Where feasible he should  
 avoid blocking read to anything which is not the offending documents.
 This is an entirely automatic action done on the liability of the
 complainant, and the ISP avoids liability to complainant or author.

 Meritless complaints will, nine times out of ten, be dealt with
 by the author's right to respond and restore; however we also need 
 to provide for some rare but real abuses.  The author may sue the 
 complainant for anything done about his complaint if it was perjur-
 ious as to facts, reasonable case, or intent to proceed  i.e. proof 
 or perjury may emerge months later and have cost thousands, after
 court orders were issued on perjured information.  Malicious idiots 
 outside the UK may issue hundreds of notices and never appear to 
 pursue them when defied, so an author should be able to petition 
 the court that a complainant be denied power of notice if he has 
 issued many similar notices which were neither conceded to informally 
 nor proceeded with successfully in court. [This may be beyond off-line
 redress, but is justified by the new circumstances allowing courts
 and authors to have their time wasted with such new speed and volume].

 RESPOND....

 The author may take this as a shot across his bows and accept 
 removal.  Nothing stops the complainant suing anyway; but removal
 is a sign of goodwill, while restoration after notice may be taken
 as evidence of wilfulness if the author loses in court. The author's
 other option is to resist by a response notice.

 The response must be in writing and signed, with real world contact
 details for written and telephone reply.  If they get no reaction,
 they would be prudent to make the ISP aware e.g. by phone. The author
 affirms under penalty of perjury by virtue of making the notice 
 that (specify one or other)  *EITHER*  the  complaint is void because 
 he  issued no such documents, *OR* he stands by the material and will 
 defend it in the UK courts  if  the complainant insists on proceeding.

 ...AND RESTORE

 The ISP should satisfy himself that the response was in the above form 
 taking the author's word for its truthfulness and, where so claimed, 
 that the author does not have those documents on the system.  He should 
 ATTEMPT to contact the author for confirmation e.g. by phone; however 
 the issuer of any notice takes all responsibility that the contents are
 truthful and it will be implemented, with whatever consequence for him.  
 
 Once there is a formally correct response then the relevant read and 
 write accesses must be restored, within the same time limits.  This is
 an entirely automatic action on the responsibility of the author, and
 the ISP is not liable to him or to the complainant.  If the complainant
 still insists on removal then he had better seek a court order for it; 
 which the ISP must of course obey once one is obtained.  

 A complainant may petition that an author be denied right of response
 notices, if he has many times failed to appear in the UK courts
 when the complaint was pursued against him.


 NOTE: the complainant may not know the author's identity, but the ISP
 certainly will and will have verified it.  The author can remain 
 anonymous to the precise extent of providing a pre-paid registered(*)
 envelope for forwarding a writ to a verified address.
 ((*) it has a different name now).   Also, the ISP should reserve the
 power to be objecting party to a false complaint.... almost always
 they would want the author to deal with this, but there are rare 
 occasions when they might need their own recourse against pests.


########################################################################
########################################################################
########################################################################

 Demon Internet have been removing or threatening many users for any 
 complaint of apparent defamation, no matter how trivial or unlikely
 to be proceeded with.  Example email.........


Hello,

We have received information that your posting to the newsgroup
............. (<...............................>) contains material
which is alleged to be defamatory relating to......................

We cannot and do not make any judgement as to whether there is material
which is defamatory.  However, the state of the law at the moment means
that should that material be found to be defamatory, now that we have
been notified, Thus plc may be liable for damages along with you. Those
damages could be substantial and we could both incur heavy legal
expenses.

In addition, the current state of the law could leave Demon Internet
liable if it failed to take action and you disseminated any further
material through our systems which was later found to be defamatory.

While we do not necessarily agree with the current legal position we
must accept it, and have therefore removed the posting in question and
have temporarily barred your newsgroup access.

Before we can restore your newsgroup access you will need to read the
attached undertaking. If you agree to the terms, please sign and return
it, either by fax or by post to the address shown on the form. Once the
undertaking is received we will restore access to your service.

If you agree to be bound by the undertaking set out below, please delete
the parts which are not relevant, sign at the end, insert the date and
return the form to the legal department, Demon at Thus, 322 Regents
Park Road, Finchley, London, N3 2QQ, Fax No. 020 8492 7008.


UNDERTAKING REGARDING ALLEGED DEFAMATORY MATERIAL

I understand that there has been a complaint about my newsgroup postings
which contain material which it is claimed is defamatory of Dr Laurence
Godfrey.

I do not make any admission as to whether or not the material is, in
fact, defamatory.  However, I undertake not to disseminate any
defamatory material using the Demon service either by posting such
material myself or by providing a link to it.

I acknowledge that my use of the Demon service is governed by the
Conditions of Use, clause 15 of which states that the account must not
be used for any illegal purpose and clause 13 of which states that I
will indemnify Demon against the effect of any misuse, or claims
resulting from such misuse.

I understand that Thus plc may look to me for payment of any losses
suffered by it as a result of my misuse of the Demon service.

I understand that my newsgroup access will not be restored until Thus
plc receives this undertaking signed by me to show that I agree to be
bound by its terms.

Signed:_____________________     Date:________________________

Name:______________________      Received by Thus plc:_________________
                 (Please Print)

Please do not hesitate to contact me if you wish to discuss this
further.

Mark
Mark Gracey       -    Legal Liaison Manager    -    Thus Legal Services
legalnotice at demon.net    -   tel: 0845 272 0666   -   fax: 0870 052 2740



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          '-|:::|@\      (")"""-.         .-|:::|@\  --+--.(")"""-'         
            ||  |""       ||""|             ||  |""    '   ' |""|

 DEMOCRACY: two wolves & a lamb     LIBERTY: a lamb with a kalashnikov
        voting what's for lunch     contesting  the  vote
          

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