494 lines
31 KiB
Plaintext
494 lines
31 KiB
Plaintext
"Closing the Net"
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by
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Greg Costikyan
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[Reproduced with permission from the January 1991 issue of _Reason_
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magazine. A one-year subscription (11 issues) is $19.95. Copyright
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1991 by the Reason Foundation, 2716 Ocean Park Blvd., Suite 1062,
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Santa Monica, CA 90405. Please do not remove this header.]
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Back in early February, newspapers across the country reported that
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computer hackers were interfering with emergency calls over the 911
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communications network. The reports said the hackers had penetrated the
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system using information from a secret computer document.
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The scare grew out of an indictment by a grand jury in Lockport,
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Illinois. On February 7, Craig Neidorf and Robert Riggs were indicted on
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seven counts of wire fraud, violation of the Computer Fraud and Abuse Act
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of 1986, and interstate transportation of stolen goods.
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Prosecutors alleged that Neidorf and Riggs had conspired to steal,
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using fraudulent methods, a confidential and proprietary document from the
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Bell South telephone company. This document, it was claimed, could allow
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computer hackers to disrupt the 911 emergency network.
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The arrest of Neidorf and Riggs was only the beginning. The Secret
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Service, which has authority over crimes involving government computers,
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had embarked on a vast, nationwide investigation of hacker activity:
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Operation Sun Devil.
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Imagine the night face of North America, shining not with cities but
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with lines of light showing the transmission of data. Brightest are New
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York City, the financial capital, and California, the technological
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capital, with Washington, D.C., a close third. The lines that crisscross
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the country are telephone wires and cables, microwave transmissions, and
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packet-switching networks designed for computer communication. Here and
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there, beams dart into space to reflect off satellites and back to earth.
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The computer networks in this country are huge. The largest are
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entities like UseNet and InterNet, which link every academic computing
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center of any size and are accessible to every scientist, university
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student, and faculty member in the nation. The networks also include
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government-operated systems, such as MilNet, which links military computers
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that do not carry confidential information. And there are the commercial
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services, such as Dow Jones News/Retrieval, SportsNet, CompuServe, GEnie,
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and Prodigy. CompuServe is the largest of these, with half a million
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subscribers.
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In addition to these massive entities are thousands of tiny bulletin
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board services, or BBSes. Anyone with a computer and a modem can start a
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BBS; others can then call it up and use it. BBSes offer, in miniature,
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essentially the same services that the commercial nets offer: the ability
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to chat with others by posting messages to an electronic bulletin board and
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the ability to upload and download software and text files. There are more
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than 5,000 BBSes in the United States, most of them operated for fun. Few
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charge their users. In my local calling area alone, I know of BBSes for
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writers, gamers, Macintosh enthusiasts, gays, and the disabled -- and I'm
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sure there are others.
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The vast majority of BBSes deal with unexceptional topics. But some
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boards deal with questions of computer security. These attract hackers.
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Naturally, hackers discuss their hobby: breaking into computers.
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Usually, however, bulletin board discussions are general in nature.
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Hackers are not stupid, and they know that posting credit card numbers or
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the like is evidence of criminal activity. By and large, BBS discussions
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rarely, if ever, contain information that would be illegal if published in
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print form. It's not illegal, after all, to tell your readers how to
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commit illegal acts. If it were, books like _The_Anarchist's_Cookbook_ and
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_Scarne_on_Cards_ (and half the murder mysteries in print) would be banned.
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The laws dealing with electronic transmissions, however, are far
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from clear. And the methods used to enforce these vague laws set a
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dangerous precedent for abridging freedom of speech.
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In the future, the Net -- the combination of all the computer
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networks -- will be the primary means of information transmission, with
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print publication merely its adjunct. The Net will replace the press, and
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users of the Net must enjoy precisely the freedoms enjoyed by the press.
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If users of the Net have to worry about police surveillance, if censorship
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is rife, if the state forbids mere discussion of certain topics -- then the
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liberty for which the Founders fought will have been destroyed, not by war
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or tyranny, but by mere technological change.
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From the government's point of view, the arrest of Neidorf and Riggs
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did not end the threat to the 911 network. The document they had stolen
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was not a single piece of paper that could be returned to its rightful
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owner. It was an electronic document that Riggs had downloaded from a Bell
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South computer.
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Riggs belonged to a hacker group called the Legion of Doom, whose
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members shared information. It was likely that others in the group had
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copies of the 911 document. Worse, Riggs had uploaded the 911 document to
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a bulletin board service in Lockport, Illinois. Neidorf had downloaded the
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file from the Lockport BBS. Anyone else who used the same BBS could have
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downloaded it, too, meaning that dozens of people might have this dangerous
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information. Worse yet, Neidorf had published an edited version of the
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Bell South document in an issue of his underground computer magazine,
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_Phrack_.
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Unlike conventional magazines, _Phrack_ never saw a printing press;
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it was distributed electronically. After preparing an issue, Neidorf would
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dispatch it, via various computer networks, to his address list of 1,300
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names. Any recipient could then upload the magazine to a bulletin board or
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to one of the academic or commercial nets. That meant thousands, perhaps
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millions, of people had access to the information in the Bell South
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document.
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We may imagine that the Secret Service was gravely concerned about
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the potential threat to emergency services. If not, then their subsequent
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actions are hard to fathom.
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On March 1, 1990, employees of Steve Jackson Games, a small game
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company in Austin, Texas, arrived at their place of business to find that
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they were barred from the premises. The Secret Service had a warrant, and
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the agents conducting the search wouldn't let anyone in until they were
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done.
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The agents ransacked the company's offices, broke a few locks, and
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damaged some filing cabinets. They searched the warehouse so thoroughly,
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says company founder Steve Jackson, that afterward it "looked like a
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snowstorm," with papers strewn randomly. The agents confiscated three
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computers, a laser printer, several pieces of electronic equipment
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(including some broken equipment from a storeroom), several hard drives,
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and many floppy disks. They told Jackson they were seizing the equipment
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"as evidence" in connection with a national investigation.
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Among the equipment seized was the computer through which S.J. Games
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ran a BBS to communicate with customers and freelancers. It had never been
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a congregating point for hackers and was about as much a threat to the
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public order as a Nintendo game.
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The loss of the equipment was bad enough. Worse, the Secret Service
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seized all existing copies -- on hard drives, floppy disks, and paper -- of
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S.J. Games' next product, a game supplement called GURPS Cyberpunk. The
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loss of that data shot Jackson's publication schedule to hell. Like many
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small publishers, S.J. Games runs on tight cash flow. No new products, no
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income. No income, no way to pay the bills.
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Over the next several weeks, Jackson was forced to lay off about
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half of his 17 employees. By dint of hard work, he and his staff managed
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to reproduce the data they'd lost, mostly from memory. S.J. Games finally
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published GURPS Cyberpunk as "The Book Seized by the Secret Service." It
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has sold well by the (low) standards of the field.
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Jackson estimates the raid has cost him more than $125,000, a sum a
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small company like his can ill afford. (The company's annual revenue is
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less than $2 million.) He was nearly put out of business by the Secret
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Service.
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What justified the raid and the seizures? Apparently, this: The
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managing editor of Steve Jackson Games is Loyd Blankenship. Blankenship
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ran The Phoenix Project, a BBS of his own in the Austin area. Blankenship
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consorted with hackers. He was fascinated by the computer underground and
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planned to write a book about it. He may or may not have once been a
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hacker himself. He certainly knew and corresponded electronically with
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admitted members of the Legion of Doom.
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But perhaps Blankenship's worst luck was this: An issue of
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Neidorf's _Phrack_ magazine included an article titled "The Phoenix
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Project." As it happens, that article had nothing to do with Blankenship's
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BBS of the same name. But the Secret Service was well aware of the
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contents of _Phrack_. Indeed, the revised indictment of Neidorf and Riggs,
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issued in July, cited the article by title. The same morning that the
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Secret Service raided Steve Jackson Games, agents awakened Blankenship and
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held him at gunpoint as they searched his house. They seized his computer
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and laser printer as "evidence."
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Consider the chain of logic here. Robert Riggs is accused of a
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crime. Riggs belongs to a group. Loyd Blankenship is friends with other
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members of the group, though not with Riggs himself. Steve Jackson Games
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employs Blankenship. Therefore, the Secret Service does grievous financial
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injury to Steve Jackson Games. This is guilt by association taken to an
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extreme.
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Neither Blankenship, nor Steve Jackson Games, nor any company
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employee, has ever been charged with so much as spitting in a public place.
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The Secret Service refuses to comment, saying only that S.J. Games was not
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a target of the investigation.
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The company is now receiving legal help from the Electronic Frontier
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Foundation, an organization devoted to promoting civil liberties in
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electronic media. The Secret Service has returned most -- but not all --
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of the company's seized equipment. Some of it is broken and irreparable.
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The government has made no offer of restitution or replacement.
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On May 8, 1990, the Secret Service executed 28 or more search
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warrants in at least 14 cities across the country. The raids involved more
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than 150 agents, plus state and local law enforcement personnel.
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According to a press release from the U.S. Attorney's office in
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Phoenix, the operation targeted "computer hackers who were alleged to have
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trafficked in and abused stolen credit card numbers [and] unauthorized
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long-distance dialing codes, and who conduct unauthorized access and damage
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to computers." The agency claimed the losses might amount to millions of
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dollars. In later releases and news reports, that figure was inflated to
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tens of millions of dollars.
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Nationwide, the government seized at least 40 computers and 23,000
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disks of computer information. In most cases, the subjects of these
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searches have remained anonymous. Presumably, they have either been
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advised by counsel to remain silent or have been so intimidated that they
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wish to attract no further attention.
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John Perry Barlow reports in _Whole_Earth_Review_ that the Secret
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Service held families at gunpoint while agents charged into the bedrooms of
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teenage hacker suspects. He adds that some equipment seizures deprived
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self-employed mothers of their means of support. These reports remain
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unconfirmed. It's clear, however, that the Secret Service closed down a
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number of BBSes by the simple expedient of seizing "as evidence" the
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computers on which those BBSes operated.
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Bulletin board services are venues for speech. They are used mainly
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to exchange information and ideas. Nothing in the nature of the technology
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prevents the exchange of illegal ideas. But in a free society, the
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presumption must be that, in absence of proof to the contrary, the use of a
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medium is legitimate. The Secret Service has not indicted, let alone
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convicted, the operators of any of the BBSes closed down on May 8.
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If law enforcement officials suspect that a magazine, newspaper, or
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book publisher may be transmitting illegal information, they get a warrant
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to search its files and perhaps a restraining order to prevent publication.
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They don't, however, seize its printing presses to prevent it from
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operating. A clearer violation of freedom of the press could hardly be
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imagined. Yet that is precisely what the Secret Service has done to these
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BBSes.
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One of the BBSes closed down was the JolNet BBS in Lockport,
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Illinois, which Neidorf and Riggs had used to exchange the 911 document.
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Ironically, JolNet's owner, Richard Andrews, had triggered the
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investigation by noticing the document, deciding it was suspicious, and
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notifying the authorities. He had cooperated fully with the investigators,
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and they rewarded him by seizing his equipment.
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The Ripco BBS in Chicago was among those raided by the Secret
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Service. Operated by Bruce Esquibel under the handle of "Dr. Ripco," it
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was a freewheeling, wide-ranging board, one of the best known BBSes in the
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Chicago area. Speech was extraordinarily free on the Ripco board.
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"I felt that any specific information that could lead to direct
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fraud was not welcome and would be removed, and persons who repeated
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violating this themselves would be removed from the system also," Esquibel
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writes. But just about anything else was open for discussion. Hackers did
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indeed discuss ways of breaking into computers. And the Ripco board
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contained extensive text files, available for downloading, on a variety of
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subjects to which some might take exception. For instance, there was a
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series of articles on bomb construction -- material publicly available from
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books such as _The_Anarchist's_Cookbook_.
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Along with the computer on which Ripco operated, the Secret Service
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seized two other computers, a laser printer, and a 940-megabyte WORM drive,
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an expensive piece of equipment. The additional seizures mystify Esquibel.
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"My guess is that after examining the rat's nest of wires around the three
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computers, they figured anything plugged into the power strip must have
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been tied in with [the rest] in some way," he says.
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The Secret Service has yet to return any of Esquibel's equipment.
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He has yet to be charged with any crime, other than failure to register a
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firearm. (He had three unlicensed guns at his office; he informed the
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Secret Service agents of this before they began their search.) Says
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Esquibel, "The government came in, took my personal property to determine
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if there was any wrongdoing somewhere. It seems like a case of being
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guilty until proven innocent...It's just not right...I am not a hacker; [I
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don't] have anything to do with credit cards or manufactured explosives.
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Until the weapons charge I never had been arrested, and even my driving
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record has been clean since 1978."
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It appears that the Secret Service has already achieved its goal.
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The Ripco board was a place where "dangerous" speech took place, and the
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agency closed it down. Why bother charging Esquibel with a crime?
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Especially since he might be acquitted.
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Secret Service agents searched the home of Len Rose, a computer
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consultant from Baltimore, on May 8. The agents not only seized his
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computers but confiscated every piece of electronic equipment in the house,
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including his fax machine, along with some family pictures, several boxes
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of technical books, and a box containing his U.S. Army medals.
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On May 15, Rose was indicted on four counts of wire fraud, aiding
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and abetting wire fraud, and interstate transportation of stolen goods.
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Among other things, the indictment alleged that Rose is a member of the
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Legion of Doom, a claim both he and admitted Doomsters vociferously deny.
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The interstate-transportation charge is based on the fact that Rose
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was in possession of source code for Unix, an operating system used by a
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wide variety of minicomputers and computer workstations. (Source code is
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the original text of a program.) In theory, Unix is the property of AT&T,
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which developed the system. AT&T maintains that Unix is protected as a
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confidential, unpublished work. In fact, AT&T has sold thousands of copies
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across the country, and every systems programmer who works with Unix is
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likely to have some of the source code lying around.
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The wire-fraud counts are based on the fact that Rose sent a copy of
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a "Trojan horse" program by electronic mail. Trojan horse programs are
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sometimes used by hackers to break into computers; they are also sometimes
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used by systems managers to monitor hackers who try to break in. In other
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words, a Trojan horse program is like a crowbar: You can use it to break
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into someone's house, or you can use it to help renovate your own house.
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It has both legitimate and illegitimate uses.
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Rose is a computer consultant and has dealt with security issues
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from time to time. He maintains that his Trojan horse program was used
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solely for legitimate purposes -- and, in any case, would no longer work,
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because of changes AT&T has made to Unix since Rose wrote the program.
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Rose is not charged with actually attempting to break into computers,
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merely with possessing a tool that someone could use to break in. In
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essence, the Secret Service found Len Rose in possession of a crowbar and
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is accusing him of burglary.
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By seizing Rose's equipment, the Secret Service has effectively
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denied him his livelihood. Without his equipment, he cannot work. Rose
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says he has lost his home, his credit rating and credit cards, his
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business, and some of his friends. He can no longer afford to retain his
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original attorney and is now represented by a public defender.
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Rose's difficulties are compounded by a theft conviction arising
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from a dispute with a former client regarding the ownership of computer
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equipment. Nevertheless, it seems brutal for the Secret Service to deny
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him the means to support his family and to pay for an effective defense.
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Investigators must long ago have gleaned whatever evidence his equipment
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may have contained.
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Ultimately, the case against Neidorf and Riggs fell apart. In June,
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the grand jury issued a revised indictment. It dropped the charges of
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violating the Computer Fraud and Abuse Act and added seven new counts of
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wire fraud, some involving electronic mail between Neidorf and Riggs.
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Neidorf was charges with two counts of wire fraud for uploading issues of
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_Phrack_ to JolNet. In other words, mere distribution of his publication
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was deemed to be "fraud" because _Phrack_ contained material the Secret
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Service claimed had been obtained by fraudulent means. The new indictment
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also reduced the "value" of the document Riggs allegedly stole from more
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than $70,000 to $20,000.
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On July 9, Riggs pleaded guilty in a separate indictment to one
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count of conspiracy in breaking into Bell South's computer. Sentencing was
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set for September 14 -- after Neidorf's trial was to begin. Riggs agreed
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to be a witness for the prosecution of Neidorf.
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On July 28, Neidorf's trial began in Chicago. Within four days, it
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was over. The prosecution's case had collapsed.
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Under cross-examination, a Bell South employee admitted that the
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stolen document was far from confidential. Indeed, any member of the
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public could purchase a copy by calling an 800 number, requesting the
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document, and paying $13 -- far less than the $20,000 claimed value or the
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$5,000 minimum required to support a charge of transporting stolen goods
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across state lines.
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Testimony also revealed that the contents of the document could not
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possibly allow someone to enter and disrupt the 911 network. The document
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merely defined a set of terms used in telecommunications and described the
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procedures used by Bell personnel in setting up a 911 system.
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Riggs, testifying for the prosecution, admitted that he had no
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direct knowledge that Neidorf ever gained illegal access to anything; that
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Neidorf was not himself a member of the Legion of Doom; and that Neidorf
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had not been involved in the initial downloading of the document in any
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way.
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In short, Neidorf and Riggs had not conspired; therefore, Neidorf
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should not have been charged with the fraud counts. The only value of
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which Bell South was "deprived" by Riggs's downloading was $13; therefore,
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he was, at worst, guilty of petty theft. The interstate-transportation
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counts were moot, since the "stolen goods" in question were worth less than
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the $5,000 minimum.
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Not only was there no case against Neidorf -- there also was no case
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against Riggs. The government dropped the case against Neidorf. Riggs,
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however, had already pleaded guilty.
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The computer nets do need policing. Computer crooks can steal and
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have stolen millions of dollars. But a balance must be struck between
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civil liberties and the legitimate needs of law enforcement. The laws as
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currently constituted are inadequate from both perspectives, and the Secret
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Service seems determined to interpret them with a callous disregard for
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civil liberties.
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To attack computer crime, prosecutors primarily use the statutes
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dealing with wire fraud and interstate transportation of stolen goods, the
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Computer Fraud and Abuse Act of 1986, and the Electronic Communication
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Privacy Act of 1986. The wire fraud statute prohibits the use of the
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telephone, wire services, radio, and television in the commission of fraud.
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The courts have, logically, interpreted it to apply to electronic
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communications as well.
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The interstate transportation statute prohibits transportation of
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stolen goods valued at $5,000 or more across state lines. Neidorf's lawyer
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moved to dismiss those counts, claiming that nothing tangible is
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transported when a document is uploaded or downloaded. The judge ruled
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that tangibility was not a requirement and that electronic transmission
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could constitute transportation. The Computer Fraud and Abuse Act
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prohibits knowingly, and with intent to defraud, trafficking in information
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that can be used to gain unauthorized access to a computer.
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The Electronic Communications Privacy Act makes it a crime to
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examine private communications transmitted electronically. Among other
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things, it requires law enforcement agencies to obtain search warrants
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before opening electronic mail. It is unclear whether electronic mail
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files on a BBS's hard drive are covered by a warrant that permits seizure
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of the hard drive, or whether separate warrants are needed for each
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recipient's mail.
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The reliance on fraud statutes to fight computer crime presents
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problems. Fraud is the use of chicanery, tricks, or other forms of
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deception in a scheme to deprive the victim of property. Most attempts by
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hackers to gain illegal access to a computer do involve chicanery or
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tricks, in some sense -- the use of other people's passwords, the use of
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known bugs in systems software, and so on. Much of the time, however, a
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hacker does not deprive anyone of property.
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If the hacker merely signs on and looks around, he deprives the
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computer operators of a few dollars of computer time at worst. If he
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downloads a file, the owner still has access to the original file. If the
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file's confidentiality has value in itself -- as with a trade secret --
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downloading it does deprive the owner of something of value, but this is
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rarely the case.
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We need a "computer trespass" statute, with a sliding scale of
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punishments corresponding to the severity of the violation. Just as
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burglary is punished more severely than trespass, so a hacker who steals
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and uses credit card numbers ought to be punished more severely than one
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who does nothing more than break into a computer and examine a few public
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files. In the absence of such a scheme, law enforcement personnel
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naturally try to cram all computer violations into the category of fraud,
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since the fraud statutes are the only laws that currently permit
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prosecution of computer crimes. As a result, petty crimes are charged as
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felonies -- as with Neidorf and Riggs.
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Legitimate users and operators of computer networks need to be
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protected from arbitrary seizures and guilt by electronic association. The
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criminal code permits law enforcement personnel to seize equipment used in
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a crime or that might provide criminal evidence, even when the owner has no
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knowledge of the crime. But the purpose of such seizures is to allow the
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authorities access to evidence of criminal activity, not to shut down
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businesses. Searchers need not remove computer equipment to inspect the
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files it contains. They can sit down and make copies of whatever files
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they want on the spot. Even if they expect some piece of incriminating
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material to be hidden particularly well -- for example, in a specially
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protected file or in a ROM chip -- it is unreasonable to hold onto the
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seized equipment indefinitely.
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And it's clearly wrong to seize equipment that cannot, by any
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stretch of the imagination, contain incriminating data. In both the Steve
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Jackson and Ripco cases, the Secret Service seized laser printers along
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with other equipment. Laser printers have no permanent memory (other than
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the factory-supplied ROM chips that tell them how to operate). They print
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words on paper, that's all. They cannot contain incriminating information.
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Even computers themselves cannot possibly constitute evidence. When
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you turn off a computer, its memory dies. Permanent data exist only on
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storage media -- hard drives, floppy disks, tape drives, and the like.
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Even if law enforcement personnel have some compelling reason to take
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storage media away to complete a search, they have no reason to take the
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computers that use those media.
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Just as a computer is not evidence because it once carried
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incriminating information, a network is not a criminal enterprise because
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it once carried data used in or derived from fraudulent activity. Yet
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under current law, it seems that the operator of a bulletin board is liable
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if someone posts an illegal message on it. Say I run a BBS called Mojo.
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You dial Mojo up and leave Mario Cuomo's MasterCard number on the board,
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inviting anyone to use it. Six people sign on, read the message, and fly
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to Rio courtesy of the governor before I notice the message and purge it.
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Apparently, I'm liable -- even though I had nothing to do with obtaining
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Cuomo's credit card number, never used it, and strenuously object to this
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misuse of my board.
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Such an interpretation threatens the very existence of the academic
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and commercial nets. A user of UseNet, for instance, can send a message to
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any other user of UseNet. The network routes messages in a complex fashion
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-- from Computer A to Computer B to Computer C, and so on, depending on
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what computers are currently live, the volume of data transmitted among
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them, and the topography of the net itself. The message could pass through
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dozens of computers before reaching its destination. If someone uses the
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message to commit fraud, the system operators of every computer along its
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path may be criminally liable, even though they would have no way of
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knowing the contents of the message.
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Computer networks and BBSes need the same kind of "common carrier"
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protection that applies to the mails, telephone companies, and wire
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services. Posting an illegal message ought to be illegal for the person
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who posts it -- but not for the operator of the board on which the message
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appears.
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The main function of the Net is to promote communication. People
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use it to buy goods, research topics, download software, and a myriad of
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other things as well, but most of their computing time is spent
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communicating: by posting messages to bulletin boards, by "chatting" in
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real time, by sending electronic mail, by uploading and downloading files.
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It makes no sense to say that discussion of a topic in print is OK, but
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discussion of the same topic via an electronic network is a crime.
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Yet as currently interpreted, the law says that mere transmission of
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information that someone _could_ use to gain access to computers for
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fraudulent purposes is itself fraud -- even if no fraudulent access takes
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place. The Secret Service, for instance, was willing to indict Neidorf for
|
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publishing information it thought could be used to disrupt the 911 network
|
|
-- even though neither Neidorf nor anyone else actually disrupted it. We
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must clearly establish that electronic communications are speech, and enjoy
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the same protections as other forms of speech.
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The prospects for such legal reform are not bright. Three times in
|
|
this century, technological developments have created new venues for
|
|
speech: with radio, with television, and with cable. On the grounds of
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scarcity, government restricts freedom of speech on radio and television;
|
|
on the grounds of natural monopoly, government regulates speech on cable.
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Recent events, such as the conviction of former Cornell graduate student
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Robert T. Morris for introducing a virus into the nationwide ARPANet, have
|
|
aroused worry about hacker crimes. But concern for the rights of
|
|
legitimate users of computer nets has not received that same level of
|
|
publicity. If anything, recent trends lean toward the adoption of more
|
|
draconian laws -- like the Computer Fraud and Abuse Act, which may make it
|
|
illegal even for computer security professionals to transmit information
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about breaches of security.
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|
The Net is vast -- and growing fast. It has already changed the
|
|
lives of thousands, from scientists who learn of new breakthroughs far more
|
|
quickly than if they had to wait for journal publication, to stay-at-home
|
|
writers who find in computer networks the personal contact they miss
|
|
without office jobs. But the technology is still in its infancy. The Net
|
|
has the capacity to improve all our lives.
|
|
A user of the Net can already find a wide variety of information,
|
|
from encyclopedia entries to restaurant reviews. Someday the Net will be
|
|
the first place citizens turn to when they need information. The morning
|
|
paper will be a printout, tailored to our interests and specifications, of
|
|
articles posted worldwide; job hunters will look first to the Net; millions
|
|
will use it to telecommute to work; and serious discussion will be given to
|
|
the abolition of representative government and the adoption of direct
|
|
democracy via network voting.
|
|
Today, we are farmers standing by our country lanes and marveling as
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|
the first primitive automobiles backfire down the road. The shape of the
|
|
future is murky. We cannot know what the Net will bring, just as a farmer
|
|
seeing a car for the first time couldn't possibly have predicted six-lane
|
|
highways, urban sprawl, the sexual revolution, and photochemical smog.
|
|
Nonetheless, we can see that something remarkable is happening, something
|
|
that will change the world, something that has the potential to transform
|
|
our lives. To ensure that our lives are enriched and not diminished, we
|
|
must ensure that the Net is free.
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-- Greg Costikyan is a writer of fiction and nonfiction who has designed 23
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commercially published games.
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