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From: mnemo...@well.sf.ca.us (Mike Godwin)
Newsgroups: comp.org.eff.news
Subject: EFF News 1.01 (Special Edition)--complete in one file (long)
Message-ID: <22485@well.sf.ca.us>
Date: 8 Jan 91 03:49:15 GMT
Followup-To: comp.org.eff.talk
Organization: Whole Earth 'Lectronic Link, Sausalito, CA
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Approved: mnemo...@well.sf.ca.us
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*** EFF News #1.01 (January 7, 1991) ***
*** The Electronic Frontier Foundation, Inc. ***
*** SPECIAL EDITION: AMICUS BRIEF IN LEN ROSE CASE ***
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Editors: Mitch Kapor (mka...@eff.org)
Mike Godwin (mnemo...@eff.org)
REPRINT PERMISSION GRANTED: Material in EFF News may be reprinted if you
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We can also be reached at:
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Cambridge, MA 02141
(617) 864-0665
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USENET readers are encouraged to read this publication in the moderated
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*** EFF News #1.01: AMICUS BRIEF IN ROSE CASE ***
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ELECTRONIC FRONTIER FOUNDATION SEEKS AMICUS STATUS IN LEN ROSE CASE
The Electronic Frontier Foundation has been tracking closely the
cases in which Len Rose, a Baltimore Unix consultant, has been
charged with crimes relating to the transmission of Unix software.
The EFF believes that the federal prosecution pending against Rose
in Baltimore and scheduled to go to trial at the end of this month
raises important legal issues affecting the public interest in
electronic communications. Accordingly, EFF has filed a motion seeking
*amicus curiae* ("friend of the court") status to be heard on the
important Constitutional and statutory issues raised by the
case.
EFF has simultaneously filed a memorandum of law in support of
Len Rose's motion to dismiss the portion of the indictment charging
him with violating the Computer Fraud and Abuse Act, Title 18
United States Code, Section 1030(a)(6). EFF believes that this
statute, which appears to prohibit the communication of a broad
category of "information through which a computer may be accessed
without authorization," is unconstitutionally vague and overbroad,
and in violation of the First Amendment guarantees of freedom of
speech and association. EFF supports the goal of preventing
unauthorized computer intrusion, but believes that this statute
sweeps too broadly, prohibiting constitutionally protected communications
and chilling discussions about computer technology.
An additional purpose of the brief is to introduce the trial court
to the world of electronic communication and to make the court aware
of the exciting possibilities it holds for speech and association.
To that end, the brief cites to the Well (attaching its conference
list as an addendum) and to EFF Co-founder John Perry Barlow's
concept of the "virtual town meeting," published by the WHOLE EARTH
REVIEW.
The texts of the amicus motion, the amicus brief, and the
attachment follow.
*******************************************************
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
___________________________________
)
UNITED STATES OF AMERICA )
)
v. ) Criminal Case No. JSM-90-0202
)
)
LEONARD ROSE )
)
___________________________________)
MOTION OF ELECTRONIC FRONTIER FOUNDATION
FOR LEAVE TO FILE MEMORANDUM OF LAW AMICUS CURIAE
The Electronic Frontier Foundation, through its undersigned
counsel, respectfully moves this Court for leave to appear as
amicus curiae in the above-captioned case for the limited purpose
of filing the attached memorandum of law in support of the
defendant's motion to dismiss the portions of his indictment
charging him with violations of the Computer Fraud and Abuse Act of
1986, 18 1030(a)(6).
This case, which is being watched nationwide, presents a
constitutional question of first impression involving the CFAA that
will have a profound impact on the development of computer-based
communications technologies. For the reasons set forth below, EFF
believes that the enclosed memorandum of law contains relevant
authority and arguments that are not likely to be raised by the
parties to this action and that would be of assistance to Court in
deciding this important issue.
1. The Electronic Frontier Foundation is a nonprofit
organization established in 1990 to promote the public interest in
the development of computer-based communication technology.
2. The founders and directors of Electronic Frontier Foundation
include Mitchell Kapor and Steven Wozniak, two of our nation's
leading experts in the area of computer technology. Mr. Kapor
founded the Lotus Development Corporation and designed and
developed the Lotus 1-2-3 spreadsheet software. Mr. Wozniak was
one of the co-founders of Apple Computer, Incorporated. These
individuals have comprehensive knowledge of the developing
computer-based technologies and the promises and threats they
present.
3. The Foundation's goals, as set forth in its mission
statement, are as follows:
Engage in and support educational activities which increase
popular understanding of the opportunities and challenges
posed by developments in computing and telecommunications.
Develop among policy-makers a better understanding of the
issues underlying free and open telecommunications, and
support the creation of legal and structural approaches which
will ease the assimilation of these new technologies by
society.
Raise public awareness about civil liberties issues arising
from the rapid advancement in the area of new computer-based
communications media. Support litigation in the public
interest to preserve, protect, and extend First Amendment
rights within the realm of computing and telecommunications
technology.
Encourage and support the development of new tools which will
endow non-technical users with full and easy access to
computer-based telecommunication.
4. While the Foundation regards unauthorized entry into
computer systems as wrong and deserving of punishment, it also
believes that legitimate law enforcement goals must be served by
means that do not violate the rights and interest of the users of
electronic technology and that do not chill use and development of
this technology.
5. This case presents a question of first impression that falls
squarely within the expertise and interest of the Electronic
Frontier Foundation -- whether the CFAA, which makes it a crime to
communicate "information through which a computer may be accessed
without authorization," is unconstitutionally overbroad and vague,
in violation of the First and Fifth Amendments. The Court's ruling
on this issue could have important implications for speech and
publications relating to computer-based technologies, and,
ultimately, for the use and development of these technologies.
Accordingly, the Electronic Frontier Foundation respectfully
requests that this Court grant it leave to appear as amicus curiae
and to file the attached memorandum of law on this important
constitutional issue.
DATED: January 7, 1991
Respectfully submitted,
THE ELECTRONIC FRONTIER FOUNDATION
by its Attorneys,
______________________________
Harvey A. Silverglate
Sharon L. Beckman
Silverglate & Good
89 Broad St., 14th Floor
Boston, Massachusetts 02110
(617) 542-6663
Michael Godwin, Staff Attorney
Electronic Frontier Foundation
155 Second Street
Cambridge, Massachusetts 02142
(617) 864-005
**************************************************************
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
______________________________
)
UNITED STATES OF AMERICA )
)
v. ) Crim. Case No. JSM-90-0202
)
LEONARD ROSE )
_______________________________)
MEMORANDUM OF LAW AMICUS CURIAE OF THE
ELECTRONIC FRONTIER FOUNDATION
IN SUPPORT OF DEFENDANT'S MOTION TO DISMISS
COUNTS I AND II OF THE INDICTMENT
This is a case of first impression involving the Computer
Fraud and Abuse Act of 1986, 18 USC 1030(a)(6),
which makes it a crime to disseminate certain "information"
relating to computers and computer security. Amicus curiae
The Electronic Frontier Foundation submits this memorandum
of law in support of the defendant's motion to dismiss the
two counts of the indictment charging him with violating
section 1030(a)(6) on the ground that the law is
substantially overbroad and vague, in violation of the First
and Fifth Amendments to the United States Constitution.
INTRODUCTION
Advances in computer technology have enabled new methods
of communication, including computer conferencing systems
(often referred to as electronic bulletin boards),
electronic mail, and online publications. Note, An
Electronic Soapbox: Computer Bulletin Boards and the First
Amendment, 39 Fed. Comm. L. J. 217 (1988). These media,
still in their embryonic stages of development, offer great
promise for a society that values freedom of speech and
association, for they are inexpensive, easily accessible, and
permit instantaneous communication and association without
regard to geographic boundaries. As Professor Tribe has
observed, computers are fast becoming the printing presses of
the future: "As computer terminals become ubiquitous and
electronic publishing expands, the once obvious boundaries
between newspapers and television, telephones and printing
pressed, become blurred." L. Tribe, American Constitutional
Law 1009 (1988). EFF founder Mitchell Kapor has described
how computer-based communications also facilitate freedom of
association:
In the physical world, our sense of community
withers. Urban centers as places to live are being
abandoned by all who can afford to leave. In the
global suburbs in which more and more of us live,
one's horizon is limited to the immediate family.
Even close neighbors are often anonymous.
In the realities that can be created within digital
media there are opportunities for the formation of
virtual communities--voluntary groups who come
together not on the basis of geographical proximity
but throug a common interest. Computer and
telecommunications systems represent an enabling
technology for the formation of community, but only
if we make it so.
M. Kapor, Why Defend Hackers?, 1 EFF News (December 10,
1990). See I. de Sola Pool, Technologies of Freedom
(1983); L. Becker, Jr., The Liability of Computer Bulletin
Board Operators for Defamation Posted by Others, 22 Conn. L.
Rev. 203 (1989) ("Many computers owners find these boards a
new and exciting medium of communication."); Note, An
Electronic Soapbox, 39 Fed. Comm. L.J. at 218-223.
The possibilities for communication and association
through electronic conferencing are limited only by the
inclinations and imaginations of systems operators and users.
While computer technology is one popular topic for discussion
on bulletin board systems, these systems also facilitate
wide-ranging discussions of literary, artistic, social and
political issues. Id. at 222. See, e.g., Attachment A (a
print out of the list of conferences available on the Whole
Earth `Lectronic Link, popularly known as the WELL, a BBS
operated out of Sausalito, California). The analogies used
to describe electronic conferencing systems -- ranging from a
public bulletin board to a virtual town meeting --
indicate the richness of these for communication and
association.
Increasing reliance by individuals, businesses and
government on computer technology has also given rise to
other interests, including new permutations of privacy and
property interests, in electronically stored information.
The protection of these new interests is a proper concern of
government; but in creating new prohibitions and protections,
the government ought not, indeed constitutionally may not,
sweep so broadly as to prohibit the dissemination of
information relating to the new technology.
The law is now struggling to catch up with changes in
computer-based technology. Unless lawyers and judges
appreciate the promises of computer-based technology for
speech and association, and unless they afford electronic
communications the full protections of the First Amendment,
the resulting law will stifle these developing communications
media. Tribe has described the problem and its consequences
this way:
"The rate of technological change has outstripped the
ability of the law, lurching from one precedent to
another, to address new realities. Novel communications
are pressed into service while still in their infancy,
and the legal system's initial encounters with these
newborns have a lasting influence....`[t]echnical
laymen, such as judges, perceived the new technology in
that early, clumsy form, which then becomes their image
of its nature, possibilities, and use. This perception
is an incubus on later understanding.'"
L. Tribe, American Constitutional Law 1007 (1988) (quoting
I. de Sola Pool, Technologies of Freedom 7 (1983).
The Supreme Court has made clear that the Constitution
is flexible enough to protect interests created by new
technologies unimaginable to the framers. We have seen this
evolution, for example in response to developments in wiretap
technology, which enabled the government to intercept
communications without physical trespass. Recognizing that
constitutional doctrine must evolve with interests created by
new technology, the Supreme Court abandoned its trespass-
based analysis and ruled that the Fourth Amendment protects
not only private physical areas but also communications in
which an individual has an reasonable expectation of privacy.
Katz v. United States, 389 U.S. 347 (1967).
There is no question that speech and association
accommodated by computer-based technologies are protected by
the First Amendment. The question before this Court is
whether, in its early attempts to regulate these new
technologies, the government has swept too broadly, chilling
the freedom of speech and association that the Constitution
guarantees.
ARGUMENT
SECTION 1030(a)(6) OF THE COMPUTER FRAUD AND ABUSE ACT
IS UNCONSTITUTIONALLY OVERBROAD AND VAGUE
IN VIOLATION OF THE FIRST AMENDMENT GUARANTEES
OF FREEDOM OF SPEECH AND OF THE PRESS AND OF ASSOCIATION.
A statute is unconstitutionally overbroad on its face if
it "does not aim specifically at evils within the allowable
area of [government] control, but ... sweeps within its ambit
other activities that constitute an exercise" of protected
expressive or associational rights. Thornhill v. Alabama,
310 U.S. 88, 97 (1940) (holding statute prohibiting picketing
facially invalid because it banned even peaceful picketing
protected by the First Amendment). Section 1030(a)(6)
suffers from this fatal flaw because, on its face, it appears
to prohibit the possession or communication of
constitutionally protected speech and writing concerning
computer systems or computer security.
Section 1030(a)(6) prohibits trafficking "in any
password or similar information through which a computer may
be accessed without authorization." The word "password" is
not defined in the statute, but the legislative history
suggests that Congress intended it to be interpreted so as to
include a password or its functional equivalent--a code or
command that functions like the combination to a safe:
The Committee also wishes to make clear that
"password", as used in this subsection, does not
mean only a single word that enables one to access
a computer. The Committee recognizes that a
"password" may actually be comprised of a set of
instructions or directions for gaining access to a
computer and intends that the word "password" be
construed broadly enough to encompass both single
words and longer more detailed explanations on how
to access others' computers.
S. Rep. No. 432, 99th Cong., 2d Sess. 13 (1986).
The Senate Report also indicates that the word password was
intended to reach "conduct associated with `pirate bulletin
boards.'" Id. The word "traffic" is also broadly defined to
mean "transfer, or otherwise dispose of, to another or obtain
control of with intent to transfer or dispose of." 18 U.S.C.
1029(e)(5).
The most problemmatic statutory phrase is the one under
which the defendant is charged, making it a criminal offense
to communicate "information through which a computer may be
accessed without authorization." This phrase is not
defined in the statute, and if it is construed to prohibit
the communication of information other than "passwords" or
"detailed explanations on how to access others'
computers," its scope would be impossible to ascertain.
On its face, then, section 1030(a)(6) could be used to
prohibit the communication of a broad category of information
relating to computers or even the mere possession of such
information by one who intends to to communicate it. The
statute would apparently prohibit the giving of a speech or
the publication of a scholarly article on computer security
if the speech or article contained "information" that another
person could use to access a computer without authorization.
The statute could be read to prohibit computer professionals
from discussing the operations of programs designed to test
computer security, since such knowledge could be used to
facilitate access to a computer system without authorization.
The statute is even susceptible to an interpretation that
would prohibit a journalist from publishing an article
describing the security deficiencies of a government computer
system, even if all of the information contained in the
article came from publicly available sources.
The claim that section 1030(a)(6) could be used to
prosecute a journalist and that it therefore has a chilling
effect on freedom of the press is not simply imagined. In
United States v. Riggs, 739 F. Supp. 414, 416 n.1 (N.D. Ill.
1990), a federal grand jury returned a multicount indictment
charging the editor/publisher of an electronic newsletter
with "traffick[ing] in information through which a computer
may be accessed without authorization," in violation of
section 1030(a)(6). Although the government eventually
dropped the section 1030(a)(6) charges, the prosecution
has had a substantial chilling effect on Neidorf, who is no
longer publishing his newsletter.
The statute is also overbroad in that it appears to
sweep within its prohibition discussions regarding computer
systems and computer security taking place on electronic
bulletin boards. The legislative history of section
1030(a)(6) reveals that while Congress intended the provision
to penalize conduct associated with electronic bulletin
boards, Congress may not have been aware of the richness,
depth, and variety of discussions its language would
prohibit. The Senate Report states that section 1030(a)(6)
was "aimed at penalizing conduct associated with `pirate
bulletin boards,' where passwords are displayed that permit
unauthorized access to others' computers." Senate Report at
13. Yet the statutory language sweeps much more broadly,
prohibiting not only the posting of passwords, but also
discussion of other "information" that could theoretically be
used by another to access a computer without authorization.
This is not surprising, for while the legislative history is
replete with references to so-called "pirate bulletin
boards," there is no indication in the history that Congress
was made aware of the sophisticated and constitutionally
protected discussions about computers and computer security
occurring on bulletin board systems across the country on a
daily basis.
Section 1030(a)(6) violates the First Amendment because
it prohibits constitutionally protected communications about
computers and computer security because of their
communicative impact. The statutory requirement that the
defendant possess an intent to defraud does not cure this
defect. Communications concerning computers and computer
security are constitutionally protected, unless they fall
within the narrow subset of communications amounting to
"advocacy ... directed to inciting or producing imminent
lawless action" and "likely to incite or produce such
action." Brandenburg v. Ohio, 395 U.S. 444 (1967). Outside
this narrowly defined category of unprotected speech,
Congress may not pass a law prohibiting the dissemination of
information about computers or computer security unless the
prohibition is "necessary to serve a compelling [government]
interest and ... narrowly drawn to achieve that end." See
Widmar v. Vincent, 454 U.S. 263 (1981). Even if the purpose
underlying section 1030(a)(6) -- presumably, preventing
unauthorized intrusion into computers in which the government
has an interest -- were considered to be "compelling," it is
apparent that the broad prohibition of the communication of
"information through which a computer may be accessed without
authorization" is not "narrowly drawn" to achieve that end.
The potential unconstitutional applications of this
statute to protected and socially productive speech and
activity far exceed its legitimate reach. As the Riggs case
demonstrates, this is plainly not a statute whose overbreadth
could be deemed insubstantial or imagined. Broadrick v.
Oklahoma, 413 U.S. at 616 (where conduct and not merely
speech is involved, the overbreadth of a statute must be
"substantial ... judged in relation to the statute's plainly
legitimate sweep").
The overbreadth of this statute cannot be cured through
case-by-case adjudication. Given the broad definition of
"password" suggested by the legislative history of the CFFA,
it impossible to imagine what additional "information"
sharing Congress could constitutionally prohibit. The
statutory language under which the defendant is charged --
prohibiting dissemination of "information that could be used
to access a computer without authorization," has no
constitutionally legitimate core. See Houston v. Hill, 107 S.
Ct. 2502 (1987) (invalidating ordinance forbidding the
interruption of an on-duty police officer because there was
no definable core of constitutionally unprotected expression
to which it could be limited).
Moreover, judicial efforts to narrow the scope of this
language through case-by-case adjudication could not
eliminate its direct and substantial chilling effect on
research, education, and discussions concerning computer
technology. Application of the overbreadth doctrine is
appropriate where, as here, the "statute's very existence may
cause others not before the court to refrain from
constitutionally protected speech or expression." Broadrick
v. Oklahoma, 413 U.S. at 613. The Supreme Court has
repeatedly emphasized that
"[p]recision of regulation must be the touchstone in an
area so closely touching our most precious freedoms,"
N.A.A.C.P. v. Button, 371 U.S. 415, 438 ..."[f]or
standards of permissible statutory vagueness are strict
in the area of free expression.... Because First
Amendment Freedoms need breathing space to survive,
government may regulate in the area only with narrow
specificity." Id. at 432-433 .... When one must guess
what conduct or utterance may lose him his position one
necessarily will "steer far wider of the unlawful zone
.... Speiser v. Randall, 357 U.S. 513 .... For "[t]he
threat of sanctions may deter ... almost as potently as
the actual application of sanctions. N.A.A.C.P. v.
Button, supra.... The danger of that chilling effect
upon the exercise of vital First Amendment rights must
be guarded against by sensitive tools which clearly
inform [individuals] what is being proscribed.
Keyishian v. Board of Regents, 385 U.S. 607, 603-604 (1967).
This statute hangs over citizens "like a sword of
Damocles," threatening them with prosecution for any speech
or writing relating to computer security. That a court may
ultimately vindicate such citizens "is of little consequence-
-for the value of a sword of Damocles is that it hangs--not
that it falls." Arnett v. Kennedy, 416 U.S. 230, 232 (1974)
(Marshall, J., dissenting). For every speaker or writer who
risks criminal prosecution "by testing the limits of the
statute, many more will chose the cautious path and not speak
at all." Id.
For the reasons given above, the Electronic Frontier
Foundation urges this Court to invalidate section 1030(a)(6)
on the ground that it is unconstitutionally vague and
overbroad.
DATED: January 7, 1991.
Respectfully submitted,
THE ELECTRONIC FRONTIER FOUNDATION,
Amicus Curiae,
by its Attorneys,
____________________________
Harvey A. Silverglate
Sharon L. Beckman
Silverglate & Good
89 Broad St., 14th Floor
Boston, Massachusetts 02110
(617) 542-6663
Michael Godwin, Staff Attorney
Electronic Frontier Foundation
155 Second Street
Cambridge, Massachusetts 02142
(617) 864-0665
***********************************************************
ATTACHMENT A
CONFERENCES ON THE WELL
Best of the WELL - vintage material - (g best)
Business - Education
----------------------
Apple Library Users Group(g alug) Agriculture (g agri)
Brainstorming (g brain) Classifieds (g cla)
Consultants (g consult) Consumers (g cons)
Design (g design) Desktop Publishing(g desk)
Disability (g disability) Education (g ed)
Entrepreneurs (g entre) Homeowners (g home)
Investments (g invest) Legal (g legal)
One Person Business (g one) Periodical/newsletter(g per)
Telecomm Law (g tcl) The Future (g fut)
Translators (g trans) Travel (g tra)
Work (g work)
Social - Political - Humanities
---------------------------------
Aging (g gray) AIDS (g aids)
Amnesty International (g amnesty) Archives (g arc)
Berkeley (g berk) Buddhist (g wonderland)
East Coast (g east) Emotional Health****(g private)
Environment (g env) Christian (g cross)
Couples (g couples) Current Events (g curr)
Dreams (g dream) Drugs (g dru)
Firearms (g firearms) First Amendment (g first)
Fringes of Reason (g fringes) Gay (g gay)
Gay (Private)# (g gaypriv) Geography (g geo)
German (g german) Hawaii (g aloha)
Health (g heal) Histor (g hist)
Interview (g inter) Italian (g ital)
Jewish (g jew) Liberty (g liberty)
Mind (g mind) Miscellaneous (g unclear)
Men on the WELL** (g mow) Nonprofits (g non)
North Bay (g north) Northwest (g nw)
Parenting (g par) Peace (g pea)
Peninsula (g pen) Poetry (g poetry)
Philosophy (g phi) Politics (g pol)
Psychology (g psy) San Francisco (g sanfran)
Scam (g scam) Sexuality (g sex)
Singles (g singles) Southern (g south)
Spirituality (g spirit) Transportation (g transport)
True Confessions (g tru) WELL Writer's Workshop***(g www)
Whole Earth (g we) Women on the WELL*(g wow)
Words (g words) Writers (g wri)
**** Private Conference - mail wooly for entry
***Private conference - mail sonia for entry
** Private conference - mail flash for entry
* Private conference - mail carolg for entry
# Private Conference - mail hudu for entry
Arts - Recreation - Entertainment
-----------------------------------
ArtCom Electronic Net (g acen) Audio-Videophilia (g aud)
Boating (g wet) Books (g books)
CD's (g cd) Comics (g comics)
Cooking (g cook) Flying (g flying)
Fun (g fun) Games (g games)
Gardening (g gard) Nightowls* (g owl)
Jokes (g jokes) MIDI (g midi)
Movies (g movies) Motorcycling (g ride)
Music (g mus) On Stage (g onstage)
Pets (g pets) Radio (g rad)
Restaurant (g rest) Science Fiction (g sf)
Sports (g spo) Star Trek (g trek)
Television (g tv) Theater (g theater)
Weird (g weird) Zines/Factsheet Five (g f5)
* Open from midnight to 6am
Grateful Dead
-------------
Grateful Dead (g gd) Deadplan* (g dp)
Deadlit (g deadlit) Feedback (g feedback)
GD Hour (g gdh) Tapes (g tapes)
Tickets (g tix) Tours (g tours)
* Private conference - mail tnf or marye for entry
Computers
-----------
AI/Forth (g ai) Amiga (g amiga)
Apple (g app) Atari (g ata)
Computer Books (g cbook) Art & Graphics (g gra)
Hacking (g hack) HyperCard (g hype)
IBM PC (g ibm) LANs (g lan)
Laptop (g lap) Macintosh (g mac)
Mactech (g mactech) Microtimes (g microx)
OS/2 (g os2) Printers (g print)
Programmer's Net (g net) Software Design (g sdc)*
Software/Programming (software) Unix (g unix)
Word Processing (g word)
* Private Conference - Send email to tao for entry.
Technical - Communications
----------------------------
Bioinfo (g bioinfo) Info (g boing)
Media (g media) Netweaver (g netweaver)
Packet Radio (g packet) Photography (g pho)
Radio (g rad) Science (g science)
Technical Writers (g tec) Telecommunications(g tele)
Usenet (g usenet) Video (g vid)
Virtual Reality (g vr)
The WELL Itself
---------------
Deeper (g deeper) Entry (g ent)
General (g gentech) Help (g help)
Hosts (g hosts) Policy (g policy)
System News (g news) Test (g test)
--
Mike Godwin, (617) 864-0665 |"If the doors of perception were cleansed
mnemo...@well.sf.ca.us | every thing would appear to man as it is,
Electronic Frontier | infinite."
Foundation | --Blake