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They Knew it Was Going to Be Easy

February 13th, 2007

News from the hacker community… the digital rights management (DRM) technology that protects HD-DVD and Blu-Ray high definition video discs has been broken. That’s really not news as it was an inevitability.

The Slashdot commentary on this was interesting and pointed out something I hadn’t thought of before. I will refrain from quoting the whole comment and instead paraphrase: it is impossible to secure a message when the recipient and the attacker are the same person. And now you are asking, what does that mean?

Okay, quick cryptography lesson from someone who only understands the basic. Assume two people (Bob and Alice) who want to send communication between eachother privately. In order for this communication to occur they must use one of several encryption methodologies. In general, this is done by both Bob and Alice knowing a “secret” and using that secret to encrypt and decrypt the message. Now, a third person (Charles) wants to listen in, but can’t because he doesn’t know the secret. Works pretty well, for the most part.

Now with DRM, the paradigm is different. Alice (played by the record label or movie studio) wants to send a message to Bob (played by you and I) that he can only listen/watch in certain circumstances. But Bob also wants to watch his DVD in a non-authorized fashion (say, with a Linux box)… which means Bob has a dual identity. He is both Bob and Charles. Any secret Bob knows, Charles knows… and now the gig is up. It may be that Bob doesn’t know what the secret is, exactly, that he knows, but it is only a matter of time before smart people figure it out. That’s what happened with DVDs several years ago, and that’s what happened with the next generation systems.

But this is not what I want to talk about. The title of this post is “They Knew it Was Going to Be Easy” because the makers of DRM knew everything I just said above. They are not, contrary to the opining of the Slashdot crowd, stupid. In fact, they knew this so well that they got a law passed to criminalize the activity… a little something known as the Digital Millennium Copyright Act. §1201(A) reads:

No person shall circumvent a technological measure that effectively controls access to a work protected under this title

Which makes the breaking of DRM a against the law… even if the DRM is really stupid.

So yes, it is easy… but so is bopping someone on the nose. Doesn’t take anything more than one of my fists and decent aim. Which is why we pass laws in the first place, to create artificial incentives which conform behavior in a particular manner as established by the legislative process (I love this link!). The media companies said they wanted to keep pirates from breaking into their stuff, they recognized it couldn’t be done with technology alone, so they appealed to the legislature and got the needed protection.

Which is to say… they knew it was going to be easy.

probonogeek Law

Copyrights in the News

February 5th, 2007

I’ve got three different copyright stories, all within a 24 hour period. Clearly the world is beginning to take notice.

First up, the “creator” of the Electric Slide has issued a DMCA take down notice to YouTube for videos where the Electric Slide is being performed incorrectly. First, to silence all of those “the DMCA goes to far” folks (of which I am, arguably, one of… but not in this case), the DMCA is only involved here because YouTube has a chance to avoid contributory liability by taking down the material. The original poster of the material can then serve notice to YouTube that the material is not infringing, at which point YouTube must repost it. Then, YouTube having done its part, it’s up to the two parties to resolve the issue. The real issue here is one of basic copyright law.

Which presents an interesting question: can dance moves be copyrighted? The expert from the CNet article (Jason Schultz of the EFF) seems to pass this question off as if it’s a no-brainer. Just like a song, performing it without permission is a violation of the §106 of the Copyright Act. But I’m not convinced. To perform a dance I must follow a series of steps, also known as instructions. A series of instructions is generally referred to as a process… and processes, as a rule, are not copyrightable. They are not copyrightable because in this country we protect processes through the patent system. It’s very easy to state the rule: “patent ideas, copyright expression.” I could make the case that dance steps could be either, but by law it cannot be both.

That’s not even the most interesting question… see, the videos he wants taken down show the dance performed incorrectly. Which means that if it were patented, he would have no action (except, maybe, for this thing called the Doctrine of Equivalents, and I don’t want to talk about that). On the copyright front, there is no literal copying, so you get into a whole fair use thing. Not to mention, if the rights holder is saying “I grant a license to people to dance this correctly,” is there an implied license to dance it incorrectly?!

Next story, from the Washington Post, the GW Hatchet ran a story a few days ago which was picked up by the local TV station. Who in turn did not bother to credit the paper. They argue the idea of the story cannot be protected, thus they have no responsibility to attribute, much less seek permission. But, the Post reports the story used direct quotes from the college paper… that is copyright infringement. But putting that aside, I think the legal obsession with copyright has gone too far. It’s not a question of whether the paper is bound by law to attribute, but whether it was the right thing to do.

Lastly, Mikhail Gorbachev is appealing to Bill Gates to drop a criminal suit against a Russian school headmaster who is accused of using unlicensed copies of Windows in the school. Apparently former heads of state don’t have a lot to do these days. But it raises two interesting points. First, why are we talking criminal charges? Who was harmed in a way that requires punishment beyond restitution? Make the school pay, remove the software, whatever… but jail? Second, Microsoft is in a great position now to push out a marketing and political win. It agrees to give the school the pirated software, free of charge, and lets the guy off the hook. Now you’ve got another school district locked into the Microsoft hegemony and they get to make nice with the Nobel Peace Prize winner. What I don’t understand is why this issue is on Gorbachev’s radar. Is this the beginning of a larger campaign for my humane copyright laws?

probonogeek Law

Quick Post on Standing and the First Amendment

December 1st, 2006

Washington Post has an article on the Supreme Court’s decision to hear a challenge to the Bush Administration’s faith-based initiative program. There are a lot of opinions flying around about the faith-based thing, and I’m not really interested in getting into it (for discussions on religion, I suggest checking out my friends’ discussions).

What I am interested in is the Administration’s effort to get this case booted on procedural grounds. They argue the plaintifs in the case lack standing, which means the plaintifs have not personally suffered a harm. The plaintifs are suing as tax-payers, meaning the only harm they allege is that their tax dollars are being spent in an unconstitutional manner.

The administration is not wrong in that tax-payer suits are dangerous… to allow any old tax-payer to bring a suit would flood the courts with law suits while providing little context for the court to rule. See, the problem with the average tax-payer is that they have no specific facts, no information, nothing to bring to the table that a judge can consider. As such, we have a doctrine that says general tax-payer status does not count for standing.

The administration, however, is dead wrong when “[i]n written arguments filed with the Supreme Court, Solicitor General Paul Clement said the appeals court had transformed a narrow exception in law into a “roving license” for citizens to challenge any action of the executive branch of government.” See the mention of the narrow exception? That’s what is known as a bald face lie.

The narrow exception he’s referring to, and the only exception I know of to the tax-payer standing doctrine, is for establishment of religion cases. The argument is simple… if the government is, in fact, using tax dollars for unconstitutional establishment of religion (as the plaintifs argue in this case), who exactly suffers a harm other than the general tax-payer? Who, without this exception, has standing to challenge? Certainly not the religious institution receiving the funding. If no one has standing, then the behavior continues without scrutiny.

Which, I suppose, is exactly what the Bush Administration wants in this instance.

probonogeek Law

IP in the News

November 29th, 2006

Two stories worth noting/commenting about and then it’s back to work on my Kolab replacement technology… and maybe I’ll try to find a job.

First up, the United States Supreme Court heard oral arguments today on a topic near and dear to my heart: obviousness. In order to receive a patent from the United States government an invention must pass a series of tests. They are generally conceived of as: utility, novelty, and nonobvious. At this point utility is pretty much a non-test, as everything has some utility. There used to be a doctrine about public good, but a famous case about those drink dispensers and how they trick you into thinking the juice is fresh (when, in fact, the juice you see is colored water in a continuous cycle) ended any need for public benefit.

Novelty is perhaps the hardest hurdle to cross, because any prior art can nullify your patent. Of course, there is no easy way to access prior art and because trade secret is such a big thing in the technology sector, a lot of prior art is never widely published.

Which leaves us with obviousness. Under the statute, a patent is not to be granted to an idea with someone of “ordinary skill” in the same field could have come up with it. The point being that just because you were first to come up with something anyone could have done does not mean you should have exclusive rights. However, the statute was pretty much eviscerated by the Federal Circuit when they observed that such inquiries have a “hindsight” problem. Essentially, when the court tries to consider the obviousness it does so in the context of the inventions existence. It’s obvious because it’s already be done. But the Federal Circuit wanted to know if it was obvious at the time of invention.

The Federal Circuit’s test on this is odd and I’m not going to get into it because I don’t really understand it. Justice Scalia is quoted to have declared it “gobbledygook” and “meaningless.” Sounds about right. It’s also worth noting that the Supreme Court usually reverses the Federal Circuit if it bothers to take the case, which means the test will likely be rejected and replaced with something better. Which is a good thing.

In the past I have argued the reversal rate reflected a fundamental disconnect between the Federal Circuit and the Judiciary itself. However, my Circuit Court research from last spring makes me doubt that claim. Unlike the regional circuit courts, which can split on the same question, the Federal Circuit holds sole initial appelate jurisdiction over patent claims. Thus there is no such thing as a circuit split in the area of patent law. I suggest this is a bad thing, as it leads to ossification and reduced experimentation, but the Federal Courts Improvement Act of 1982 disagrees with me on this point.

Much of what the Supreme Court does is pick winners in circuit splits, which means one circuit usually gets upheld and the other gets overturned. But in the Federal Circuit context, if the Justices agree with the the Fed Circuit, it’s easier and quicker to simply deny cert. The only time they need to bother with a case is when they want to consider overturning a decision. Following the logic, we would expect the only time the Federal Circuit to be upheld is when four justices disagree (enough to grant cert) but can’t find a fifth to form a majority. Since most patent decisions are 7-2 or better, we rarely see this situation.

In other news, the first report of a major university selling it’s professor’s fair use rights has emerged. Apparently Cornell University has entered into an agreement with Association of American Publishers (think RIAA for books) which will significantly constrain the ability for professors to distribute learning materials to students without paying a royalty. Now, I’m not going to say the issue isn’t tricky, but this is no Napster situation. Professors are not stealing anything… they are teaching students. Considered by some to be the most noble of all professions.

The heart of the issues is §107 of the Copyright Act, which codifies fair use rights. The act has a four item list which are considered non-exclusive factors to be used in determining a fair use. Since it is a non-exclusive list, there are other factors, but these are the big four. The very first one reads

the purpose and character of the use, including whether such use is of a commercial nature or is for nonprofit educational purposes;

So, as you can see, the professors might think that their teaching falls under the nonprofit education purpose fair use exemption.

The publishers counter that they produce educational materials for the purpose of making a profit. If the very people who are supposed to be buying these products (teachers and students) can just get them for free, then there is no money to be had and it’s time to get out of the business. Which is as good an argument as any.

Of course, for decades (if not centuries) professors would have books placed on reserve at the university library where students could access the book for free. Online reserve, which is at the heart of the agreement, is just a natural extension of the old concept, right?

The article first caught my attention because of the inflammatory headline: “Professors get ‘F’ in copyright protection knowledge.” Which I thought was pretty extreme, given the difficult legal questions at issue. But the article redeemed itself way at the bottom when it recognized that not all matters are legal. Even if the publishers are 100% correct, they are essentially biting the hand that feeds them… the professors they are seeking to limit are the very professors who write the material in the first place. Here’s the quote from the article.

At Harvard University, in Cambridge, Mass., Chris Dede, a professor of learning technologies at the Graduate School of Education, says the Internet may let faculty members publish their own material and cut the book industry out of the picture.

“If publishers push too hard, faculty may just decide they no longer need a middleman who collects all the profits in each direction,” Dede says.

Which just goes to show you… you might have the best legal argument in the world, but if it doesn’t hold up outside of the courtroom your just chasing short term victories in your long plunge off the cliff.

probonogeek Law, Technology

Putting a Price on Political Tresspass to Chattels

November 22nd, 2006

Let me start this post off with a valuable terminology lesson. A chattel, which looks a lot like cattle and even covers livestock in its definition, is essentially any kind of property which is not real property. Better stated, a chattel is anything you can own and move.

Having said that, take a look at this article in the Seattle PI about the New Hamshire Democrats suing the Republicans for $4.1 million on a tresspass to chattel theory. Here’s a quick summary: Democrats and Republicans in a big fight over a House seat in the 2002 election (yes, four years ago); Democrats spend an estimated $8.2 million on a phone bank get-out-the-vote (GOTV) system; Republicans pay a telemarketer to place “hang up” calls to the phone bank, effectively blocking outgoing calls from the phone bank; Republican incumbent wins 2002 race; bunch of Republicans are sent to jail for their involvement.

It’s all well a good that people are being thrown into jail for this behavior, but the Democrats are looking for financial reimbursement. See, the race is lost and there isn’t much that can be done about that (although, one wonders if this could have been the deciding factor…), but what about 2004, or 2006, or 2008? Certainly, the Republicans should have to restore the Democrats to the position they would have been but not for their tortious behavior.

Well, that’s what this case is about. See, the Republicans are arguing all they owe is $4,974 (the actual cost of the disrupted telephone service and rental costs). Essentially, the only costs the Democrats can show “on paper.” Wherease the Democrats are asking for enough money to be able to run the phone bank again. So, whose right?

If the Republicans are right, heaven help us. Because that is the green light to the party (any party) to engage in clearly tortious activity with actual1 loses as the only penalty. If I may pant an analogy… if I run into your car and it blows up, the Republicans would argue I only owe you a new car. But what if, as a result of your car blowing up, you miss an important business meeting and lose out on a million dollar deal? Or, let’s say you suffer serious physical injury that prevents you from certain kinds of valuable work? In those cases, within the realm of foreseeability, the defendant must compensate the plaintiff.

The Republicans acted indefensibly, criminally, and knowingly. It’s not enough that those responsible are being thrown in jail… the injured party must be fairly compensated. Shutting down a GOTV system on election day is worth more than $4,974.

1. Actual damages, just the harm immediately suffered, as opposed to special damages, which cover the rest of the kinds of harm.

probonogeek Law, Politics

Important Update

November 18th, 2006

Today I received unofficial word (official word to arrive via United States Postal Service) that I passed the California Bar Examination. Now all I need is to be found a moral person and I’m in the club.

Here’s a pretty picture of my unofficial notification

Click to enlarge

probonogeek Law, Personal

Copyright Law and Political Ads

October 30th, 2006

The Seattle Times has an editorial today that has finally pushed me into writing something about the intersection of copyright and political advertisement. For those of you who don’t wish to read the article, it’s a piece from the Times’ Editorial Board calling on Darcy Burner to renounce an ad put out by the DCCC. The add uses a snippet from a TVW broadcast where Rep. Dave Reichert (R) said sometimes he listed to the GOP leadership and sometimes he doesn’t. Unfortunately for him, he said it such that a little pruning makes it sound like he’s a GOP waterboy.

But the Editorial is not just upset about the careful choice of words, they are upset because it infringes upon the copyright of WTV. So the obvious question is, does it? I haven’t done a ton of research on the topic, but my gut says copyright is not an issue here.

First, the footage is being used in a political ad, which means it has ample First Amendment protection (in fact, as political speech it has the most First Amendment protection of all other speech). Second, while TVW isn’t a governmental entity, it is a 501 (c)(3) non-profit corporation (meaning it has to be for the public good) and it receives nearly 100% of all funding from the Washington State government. Third, the footage is of a public official making public commentary, which means his words and appearance are newsworthy. There has always been an exception to copyright when the news is at stake (see INS v. AP… although the law is muddled here).

There was a Washington Post editorial a few years back about how President Bush rarely gives press conferences, choosing instead to do one-on-one interviews with private news outlets (CBS, NBC, ABC, FOX, etc). As a result, historical snafus on camera become the private copyright of the company which can be forced out of circulation by the White House by threatening to never grant another exclusive interview.

Thankfully Bush has been giving more press conferences of late, so this issue never really matured. But imagine, for a moment, if it did. Would the courts actually uphold a copyright infringement case against a political organization for using footage in an effort to broaden political discourse? I’m fairly certain that was not the purpose of copyright law.

In fact, the Times’ Board shot itself in the foot with the following line.

Rather, it is about the use of copyrighted TVW footage without permission, which would never have been granted in this case.

The purpose of the copyright is to ensure those who take the effort to make the copy are properly compensated. To say that the owner of the copyright would refuse the request, even if properly compensated, means the copyright law is being abused.

…and I’m not even going to talk about fair use.

One more thought on this topic regarding YouTube. I’ve been reading some election blogs which have taken to distributing political ads, and their unique commentary, via the popular video sharing service. This is often the only way to see footage of ads which have been pulled from the air for reasons like embarrassing the candidate, provoking public outrage, spreading untruths, being stupid. These ads live on via YouTube, reviewed and distributed among the political junkies.

Are they legit? First analysis says it’s copyright infringement. They aren’t copying a few seconds, they are taking the whole kitten-kaboodle. No obvious fair use defense here. But it is political commentary, so it has the whole political speech component. Also, you’ve got the fact that the distribution is done by private individuals, so the initial producers (the one who pulled the ad in the first place) can claim its not their fault while continuing to get a little bang for their buck on an ad they were forced to pull off the air.

Which means that politics and market forces are going to be more important than the law, but it’s still an interesting question.

probonogeek Law, Politics

Truth in Technology Law

October 11th, 2006

I keep meaning to write something about my thoughts on North Korea… but I can’t seem to bring myself to do it. So here are a few words about something less important.

Two big developments to report in the world of internet joojoo. First, a Florida jury awarded a Florida women an $11 million defamation award against a Louisiana woman who posted mean things about her business online. This case is interesting for a couple of reasons. First, it’s a default judgment, which means the defendant never showed up in court to fight the claim. As a result, we have some jurisdictional issues here. The Florida courts do not, be default, have authority over those in Louisiana. You either have to file in Louisiana or opt for Federal Court. It is possible the defendant waved jurisdiction, but I assume for purposes here that she not an idiot.

Based the article all she did was post defamatory messages about the Florida women’s business in an online community. Are these acts sufficient to establish contacts with the forum state? Under the standard International Shoe test for jurisdiction, I’d have to say no. The defendant did not avail herself of the benefits of the forum state and it sure doesn’t conform to my notions of fair play.

Which brings me the reason the Florida women sued in the first place… she wanted to send a message. See, the defendant can’t pay the judgment. She couldn’t even pay a lawyer. The suit was brought to scare her, and others, away from the internet. But this sort of award should never have happened if there were equal parties in the proceeding. Yes, the message has been sent, and the message is wrong and damaging for communication on the internet. The ability to speak should not be limited to those who can afford lawyers.

Second big news: GooTube. But in less than a day after the announcement comes a flood of analysis saying Google is going to get its pants sued off. The theory goes that most (cough, cough) of the YouTube content is copyrighted. Let’s assume that’s true. Up until now, content holders have tolerated YouTube’s infringement because even if you sue and win, YouTube has shallow pockets… which means no actual award payment… which means no incentive to sue.

But now, cry the pundents (and Microsoft’s Ballmer), the holder of YouTube has cash. Lot’s of cash! So here come the lawyers. Which is probably true… lots of people will sue with hopes of reaching a settlement with the Google giant.

That being said, I don’t think Google will spend a dime on settlements with these content vultures. First, Google has shown a willingness to stand against copyright abuse with their book scanning project, the legality of which is something of intense debate. Second, and more importantly, a plain reading of the law shows Google isn’t infringing any copyrights. See, under the Digital Millennium Copyright Act, a service provider (such as YouTube) is not liable for infringement by its users provided it has a reasonable means for rights holders to take down the violating copy.

Now, maybe a Grokster style complaint can be won against Google… but the Grokster decision was based largely on the intent of the company. Essentially, the court felt Grokster was encouraging copyright violation in its business plan. YouTube is quite different and we’ve seen an explosion of user driven content flourish there. I don’t think Groskter sticks.

At this point, two days since the announcement, every single newspaper I read has run a story about the legal pitfalls for Google, so it’ll be interesting to see how this plays out in the courts, the public, and the market.

probonogeek Law, Technology

Observations on Constitutional Issues

June 28th, 2006

Three interesting constitutional issues have been in the news recently and I thought I’d post a little on the subject… you know, say a few things that might be damaging to a later political career. Fun stuff.

First up, flag burning. I’m on record as believing this to be a horrible amendment. It’s not that I think burning the flag is a celebrated activity which should be praised… it’s more the fear and temptation of adopting “exception” clauses into the Constitution. You know, things like, “no illegal search and seizure… except if you did something bad, in which case the police can just turn our life in side out.” Obviously a popular sentiment, right? I mean, the only people who would have anything to fear is those who are breaking the law. Thankfully a super majority of the Senate does not disagree with me, and the amendment will stay off the books for another year. Hopefully the 2006 elections will bring an end to all of this reckless constitutional gamesmanship.

Next up, the President has been pushing for line-item veto authority to help eliminate pork barrel spending from the Federal budget. First, let’s all say in unison how much we hate pork barrel spending… and then quickly respond how our district’s funding is actually critical and should be maintained. Thank god for hypocrisy. But less interesting than Congress’ inability to withhold its own spending is this somewhat crazy idea that this law will pass Constitutional review.

The Supreme Court struck down an earlier attempt to grant the President a line-item veto in the 90’s. The justices adopted a very formalist stance, saying the Constitution requires bicameralism and presentment, afterwhich the President’s only options are to (1) sign, (2) veto, (3) do nothing and the law will go into effect in 10 days. It’s an all or nothing, up or down, end of story.

The new line-item claims to fix those problems… but seems to be barking up the wrong tree. The articles I’ve read describe the biggest change between the 90’s version and this one as allowing the Congress to re-vote on any items struck, requiring only a simply majority to reinstate (instead of just 2/3rds). Well, folks, that doesn’t really get to the Supreme Court’s issue. The President is given an entire bill and either likes it or dislikes it, there is no middle ground under the Constitution. Unless the Court’s recent change is far more drastic then I’m lead to believe, this statute has no change of surviving review.

Last on the chopping block, signing statements. Recently the Senate Judicial Committee held hearings on the Bush Administration’s use of signing statements, which are essentially executive decrees on how he will interpret the law. These are not unprecedented in American history, and for good reason. The President in charged with faithfully executing the laws, which means he or she must interpret and apply.

What this does not mean, if you ask me, is that the President may ignore laws. When signing the torture ban last year, the President said in conjunction, “I reserve the right to ignore this law as I see fit.” That isn’t interpretation, that’s reading in a right not present in the law. How does he get away with it, you ask? The Administration claims the signing statements save the statute from being unconstitutional.

That’s not gonna fly. If a statute is unconstitutional, the executive branch cannot save it by narrowing it’s scope. This is basic rule of administrative law. Congress cannot act beyond it’s authority, period. Laws which do so are unconstitutional both in areas where it has no authority AND those where it would if it had been more narrowly drafted. If the bar on torture is, in fact, an unconstitutional incursion on the separation of powers (as the President contends) then the whole act is invalid.

Senator Spector, the chairman, said it best “”There’s a real issue here as to whether the president may, in effect, cherry-pick the provisions he likes and exclude the ones he doesn’t like.”

probonogeek Law

Holy Constitutional Amendments Batman

June 20th, 2006

No, I’m not talking about the Flag Desecration Amendment or the Sanctity of Marriage Amendment. Actually, I’m not even discussing an actual amendment before Congress. What we’ve got here is a bonefide shadow amendment.

Here’s the scope… a bunch of folks (Rs and Ds) are going around trying to convince Legislatures to adopt a different distribution system for their Electoral College votes. Remember from civics class that every state gets two votes in the EC just for being a state and an additional vote for each representative in the House. To become President you need a majority of the EC or else the much despised 12th Amendment is activated and the killer robots come out of the Appalachians and replace all of our elected leaders. Most states (actually, it could be all states) deliver their electoral votes in a winner takes all strategy. Thus, if I were to win California by 52% I would receive all 55 electoral votes (of a total 538).

The result of the system, as currently designed, encourages a candidate to do just enough to win a state and nothing more. Thus Washington State, who has voted D every time since Roland Regan in 1984 (where Mondale took only Washington, D.C. and his home state of Massachusetts), is rarely visited by either national party. The state is not “swing” and thus the votes are already secured to one party.

Enter in our friends at the National Popular Election of the President and their crazy ideas about popular sovereignty. The idea is for states representing a majority of the EC votes to enter into a compact whereby they will award all of their electoral votes to the candidate who wins the national popular vote. So, if a candidate wins 53% of the popular vote he is assured to win the Electoral vote because all of the states in the compact will assign their votes to him.

It’s clever, to be certain, but the website doesn’t answer some of my questions… like, what does the system do when a candidate only wins a plurality, like Clinton in 1996? From the sounds of it, he wins, no questions asked. Hmmm…?

Regardless of whether you think it’s a good idea (and that’s a whole other blog post) it certainly is a neat way of going about making changes to the Constitution without having to go through the big lengthy process. Given the current system favors small states, which hold more than the 1/3rd of the votes in the Senate to stop such an amendment, this seems like a good approach to accomplish the otherwise impossible.

You can see their progress on their Wikipedia entry.

probonogeek Law