A.r.s Week in Review - 5/5/2002
Week in Review Volume 7, Issue 5
5/5/2002 by Rod Keller [rkeller@...]
Alt.religion.scientology Week in Review summarizes the most significant
postings from the Usenet group Alt.religion.scientology for the preceding
week for the benefit of those who can't follow the group as closely as
they'd like. Out of thousands of postings, I attempt to include news of
significant events, new affidavits, court rulings, new contributors,
whatever. I hope you find it useful. Like many readers of a.r.s, I have a
kill file. So please take into consideration that I may not have seen some
of the most significant postings.
The articles in A.r.s Week in Review are brief summaries of articles
posted to the newsgroup. They include message IDs for the original
articles, and many have a URL to get more information. You may be able to
find the original article, depending on how long your site stores articles
in the newsgroup before expiring them.
Free A.r.s Week in Review subscriptions are available. Subscriptions are
also available on Yahoo. Email firstname.lastname@example.org or
see http://groups.yahoo.com/group/weekinreview. PDA channel available at
Week in Review is archived at:
> IRSTaxes published an article on May 1st on the IRS decisions that have led
to a tax deduction for Scientology services, and the ability of
non-Scientologists to deduct tuition to religious schools.
"In M. Sklar, the United States Court of Appeals for the Ninth Circuit
held that the taxpayers were not permitted to deduct, as a charitable
contribution, any portion of the amounts they paid for their children's
religious school tuition. The Sklars lost in court, largely because they
failed their burden of proving the amount of the tuition payments that
were allocable to 'intangible religious benefits.' This column discusses
Sklar and the possible planning opportunities suggested by the case.
"In RL Hernandez, the United States Supreme Court upheld the denial of the
deduction for the Scientologists' auditing and training payments.
Pursuant to a central tenet known as the 'doctrine of exchange,' the
Church set forth schedules for mandatory fixed prices for auditing and
training sessions that varied with the length and the level of
sophistication of the auditing or training sessions.
"Notwithstanding the government's victory in Hernandez, the IRS obsoleted
its earlier ruling disallowing charitable deductions for Scientologists'
payments auditing and training sessions. In October 1993, the IRS released
favorable exemption ruling letters to at least 25 Church of
Scientology-related groups. Shortly after Hernandez was decided, the IRS
also entered into a closing agreement with the Scientologists.
"The Sklars argued that in allowing the Scientologists to deduct the cost
of religious instruction and denying the deduction they claimed for
religious instruction, the IRS had violated the Establishment Clause of
the First Amendment. The Ninth Circuit disagreed, noting that the Supreme
Court had rejected a similar claim in Hernandez because adopting such a
policy could require excessive government entanglement with religion. The
Ninth Circuit also dismissed the Sklar's administrative inconsistency
claim. A taxpayer may challenge the IRS's disparate treatment of the
taxpayer if the taxpayer can show that it is similarly situated to the
group being treated differently by the agency. The court, however, doubted
that the Sklars were similarly situated to the persons who benefit from
the Scientologists' closing agreement because the religious education of
the Sklars' children did not seem to be similar to the auditing and
training or 'other qualified religious services' conducted by the Church
"While the Sklars lost the case in the Tax Court and in the Ninth Circuit,
it is likely that other taxpayers will assert similar claims. The Ninth
Circuit's opinion offers some indication of the facts that must be proved
to win such a case. In future cases, taxpayers may present more facts
concerning the nature of the auditing and training offered by the Church
of Scientology to establish that the religious training that they or their
children received was similar to the religious training received by the
"Allowing taxpayers to claim charitable deductions for tuition paid for
religious training could cause a significant drain on federal income tax
revenues. Many commentators have questioned the IRS's authority to
disregard the Supreme Court's Hernandez opinion. If taxpayers like the
Sklars prevail on an administrative inconsistency claim, the IRS may
regret its concession to the Scientologists.
"Determining whether taxpayers who pay for religious training or other
intangible religious benefits may claim charitable deductions may create
an intractable problem. The closing agreement between the IRS and the
Scientologists is not source of the problem. Allowing a charitable
deduction for some, but not all, payments made to religious organizations
inevitably requires government entanglement with religion. Indeed,
determining whether an organization is organized for religious purposes
requires government entanglement. Whether such entanglement is excessive
enough to violate the Establishment Clause of the First Amendment is
likely to be an issue in many of these cases."
> RussiaThe Associated Press reported on May 1st that Scientology has won a
decision in Russia that may allow them to register as a religion.
"The Church of Scientology has won a ruling in a Moscow court preventing
authorities from using a widely criticized religion law to stop the group
from registering, church officials said Wednesday. In a one-day trial
Tuesday in a Moscow district court, judges argue that liquidating a
religious organization that doesn't pose a threat to public order is a
violation of freedom of religion, the church said. Leisa Goodman, human
rights director for the Church of Scientology, said by telephone from Los
Angeles that the ruling 'opens the door not only to Scientology but to
thousands of other religions.'
"The religion law, championed by the dominant Russian Orthodox Church,
requires all religious groups to register with Russian authorities.
Several groups, particularly foreign-based ones, have met with legal
troubles since its passage and say it limits religious freedoms Russia
that were won with the collapse of the Soviet Union. Authorities have 10
days to appeal the ruling to a higher court, Goodman said."
> BelgiumLe Soir reported on February 22nd that a court in Belgium has ruled that
by keeping PC folders on its members, Scientology is violating personal
"On one hand members demanded their folders back as individual citizens.
On the other hand the cult demanded everything back intact, asserting it
was the cult's property. The Brussels law court could only determine that
the contents of these files stood in contravention to the personal data
security law. There was detailed medical information, reports on people's
intimate lives, including sexual conduct, testimony about family members,
and confessional reports obtained through the use of the electrometer.
This was data which would be illicit for an organization to own without
written agreement of the individual. Besides that, the people upon whom
these reports were kept did not have access to them to make corrections,
in accordance with law."
> CCHRThe Vancouver Sun reported on April 30th that officials are reviewing the
treatment of an ECT patient whose cause has been publicized by Scientology
and the CCHR.
"The newly created Provincial Health Services Authority is beginning its
own probe of an elderly Riverview Hospital patient who has received more
than 100 electric shock treatments against his will. At the same time, the
Public Guardian and Trustee's office of B.C. is 'pursuing and making
inquiries' about alternatives to the electroconvulsive treatments that
71-year-old Michael Matthews has received.
"Matthews, who has been confined to Riverview for the last four decades,
was interviewed recently by a Vancouver Sun reporter and photographer who
were later ordered off the Riverview property by hospital security guards.
At the time, Mathews said of his treatments: 'I'm braver now, but I don't
like it. They hurt, I don't want it.'
"Matthews' situation was documented in The Vancouver Sun after records of
ECT doctors' billings were obtained by Vancouver resident Julie Butler,
director of an organization called the Citizens Commission on Human
Rights, a Church of Scientology affiliate that exposes, and lobbies
against, 'psychiatric abuses.'
"Case manager Linda Irwin advised Butler in a letter that alternatives to
ECT are being investigated in the Matthews' case. Butler has been
visiting Matthews for the past several months and was apparently his only
visitor, but Riverview authorities banned her from the hospital last
> Penelope CruzThe National Enquirer reported on May 2nd that Penelope Cruz has decided
to adopt Scientology in an effort to win back Scientology celebrity Tom
"Determined Spaniard Penelope does her best to win back the vertically
challenged Tom. Insiders say that Penelope is 'desperately trying' to win
him back. 'Penelope has decided to do whatever it takes to become Mrs Tom
Cruise,' whispers a source close to the couple. 'But Tom's friends believe
the relationship is done for.' Indulging in some serious soul-searching in
Madrid after he kicked her out of his Beverley Hills home, Penelope
'realised she'd caused all the problems with Tom' and, 'in a series of
teary phone calls, she promised Tom that she'd mend her ways.' No longer
will she squabble with Nicole Kidman or regard their children with
distaste. She will ditch her own religious beliefs for the teachings of
the Church of Scientology."
> Lisa McPhersonThe St. Petersburg Times reported on April 29th that Scientology is trying
to remove attorney Ken Dandar from the Lisa McPherson wrongful death case.
"The Church of Scientology is rolling out an aggressive set of legal
maneuvers aimed at wiping out one of its biggest headaches: the lawsuit
blaming the church for the 1995 death of Lisa McPherson. The church is
zeroing in on Tampa attorney Ken Dandar, who in representing McPherson's
family has mustered an unrelenting challenge costing the church millions
and fueling unending bad publicity. Accusing Dandar of professional
misconduct and perjury, the church is taking the rare step of trying to
get him removed from the case.
"In a hearing before Circuit Judge Susan Schaeffer, the church intends to
argue the whole case should be tossed because of alleged 'misconduct, sham
pleadings, (and) perjury' by Dandar; his client, McPherson's aunt, and
millionaire Bob Minton, who spent $2-million to keep the case going.
'Plaintiff herself and not merely her counsel or her financier or her
consultants and witnesses chose to convert this case into a broadside
attack on the church and the Scientology religion,' the motion says.
Dandar called the claims 'outrageous lies by Scientology.'
"The wrongful death case erupted on April 19 when Minton, the New England
millionaire who has devoted the last half-decade to fighting Scientology,
stunned all those following the case by taking the stand as a witness for
Scientology and attacked Dandar, calling him a 'lying thief.' Minton's
surprising testimony was not a reversal of his opposition to Scientology,
said his attorney Bruce Howie of St. Petersburg. Minton was facing
possible jail time for contempt of court and needed to clear the record,
Howie said. 'He realizes that the church will take advantage of his
testimony, but in the long run it's in his own best interest to tell the
truth,' Howie said. That hearing, before Judge Baird, set in motion the
church's strategy to compromise Dandar.
"Dandar has a backup. Waiting in the wings is Tampa attorney Luke Lirot,
famed defender of Tampa's adult entertainment industry. 'I would consider
it a privilege to be involved in the case,' said Lirot, who is
representing Dandar. 'I'm going to do whatever is necessary to assist.'
Lirot said he is not fazed by the scale of the lawsuit or the Church of
Scientology as a legal opponent. 'I often embrace difficult issues,' he
From the St. Petersburg Times on May 1st:
"Millionaire Scientology critic Robert Minton has expanded his criticism
of the lawyer fighting the Church of Scientology over the death of Lisa
McPherson. In a 26-page affidavit, Minton elaborated on his earlier
testimony in the case, arguing that Tampa attorney Ken Dandar asked him to
lie, drew up false court records for him to sign and urged him to generate
bad publicity for Scientology to prejudice potential jurors in the
McPherson wrongful death case. Minton has become Scientology's star
witness as it tries to get the wrongful death case dismissed on grounds of
serious misconduct by Dandar and his client.
"For two hours Tuesday, Scientology's New York attorney Samuel Rosen tried
to grill Dandar about his financial arrangement with Minton and how he has
spent the more than $2-million Minton has given to the case. It was a
fiery exchange, with Dandar refusing to answer some questions and
responding to others: 'It's none of your business.' Baird, who will decide
whether Dandar should be disqualified from the case, gave Dandar a stern
warning. 'This isn't a game,' the judge said. 'Listen to the questions.
Answer the questions, and we'll get through this.'
"Much of the inquiry centered on two Swiss bank checks totaling $750,000.
Minton says he gave the checks to Dandar. However, Dandar says Minton told
him only that the money came from an anonymous donor. Rosen questioned why
Dandar never investigated the source of the money."
From the Tampa Tribune on May 3rd:
"Even if a leading Scientology critic lied in court about paying more than
$2 million to fund a lawsuit against the church, 'Who cares?' said the
judge in the case. Millionaire church critic Bob Minton likely will face
contempt of court proceedings and could be prosecuted for criminal
perjury, but that does not affect a wrongful death lawsuit brought against
the church by the Lisa McPherson estate, Pasco-Pinellas Circuit Judge
Susan Schaeffer said Thursday. 'You guys are spending too much time on
stuff that doesn't have anything to do with this trial,' the judge told a
panel of church attorneys.
"Whether or not Minton chooses to spend his money underwriting the lawsuit
on behalf of McPherson's elderly aunt has no effect on the issue of
whether McPherson's death while under church care in December 1995 was an
accident or homicide, Schaeffer said. The judge repeatedly wondered aloud
why Minton would fund the lawsuit without a contract stating the bulk of
any monetary award would be donated to groups critical of the church, as
he now contends. 'I don't know what the funny business is, but there are
weird things going on when someone gives someone $2 million and there's
not a written agreement,' Schaeffer said. 'There is something crazy going
"Schaeffer also had sharp words for Dandar. She scolded Dandar for
implying in court records that the church was 'blackmailing, extorting or
otherwise convincing Robert Minton to change his deposition testimony'
without firm evidence to back up the allegation. 'No wonder people look so
askance at lawyers these days,' the judge said.
"The case is simple, the judge repeatedly told church attorneys. Either
McPherson died from an accidental blood clot while undergoing a religious
procedure to heal mental problems or she died after becoming dehydrated
and falling into a coma while church officials ignored the situation,
From the St. Petersburg Times on May 3rd:
"Scientology lawyers want Circuit Judge Susan Schaeffer to remove Dandar
and dismiss the lawsuit because of 'a pattern of misconduct' by Dandar,
his client and Robert Minton, an outspoken church critic who has given
$2-million of his own money in support of the lawsuit. That misconduct,
church lawyers claim, has resulted in 'incalculable damages' to the church
that can only be remedied by the lawsuit's dismissal. 'The complaint was
written to say they murdered her - the whole church is murderers,' church
attorney Eric Lieberman told the judge. Schaeffer told him, 'Just because
you have to fight hard (against) some of the allegations doesn't mean I
make the case go away.'
"Minton is now accusing Dandar of urging him to lie under oath, drawing up
false court records and urging him to drum up anti-Scientology publicity.
On Thursday, Schaeffer questioned the relevancy of Minton's allegations,
many of them centered on how the case was financed and what would happen
to any money awarded by a jury. 'It doesn't matter if Mr. Minton gave six
trillion dollars,' she said. 'I don't know why in the world anybody cares
about it. It surely doesn't get the case thrown out.'
"Minton will answer to the court for any perjury he might have committed,
Schaeffer said. But, she noted, he is not a witness in the wrongful death
case. Over and over, she asked church lawyers, 'What does that have to do
with the wrongful death case?' 'We're going to trial,' she said. 'I want
to deal with the wrongful death case set for June. It's set, and it's
going. This case is about money, money on both sides,' Schaeffer said. 'If
you're going after the church just to go after the church just to create
more rancor in Clearwater you can't use my courtroom for that.'
"One of the more graphic claims in the lawsuit is that McPherson was
bitten by cockroaches as she lay dying at Scientology's Fort Harrison
Hotel. But at the end of the hearing Thursday, Schaeffer told Dandar she
has decided he does not have enough evidence to make that claim to a
> Protest SummaryKeith Henson reported protests at the Toronto Scientology org on April
28th and May 5th.
"Gregg and I showed up at the Toronto org about noon. The org was flat
out deserted, no 'bodies in the shop' not even the oldtime members. A
passer by told Gregg they had all moved about ten blocks away to 49 Front
street where they were holding a scientology 'revival meeting' complete
with a bunch of white and blue balloons. About half an hour into the
picket, we shut off the camera and moved. It was an area with about the
same pedestrian traffic as Yonge St., but unlike the main location not as
many people are clued in.
"I took up a station about 120 feet down the street. I was splitting my
time handing out flyers and talking to a religious studies guy when Brian
McPherson came up and started needling me about about Dandar and Minton.
"Gregg gave out 75 flyers right in front of the doorway of the rented art
gallery where scientology was running a 'What is Scientology exhibit.'
Virtually every one of the people who were not scientologists coming out
took a flyer. One of the store employees in front of my location came out
and thanked me, took a flyer and said he would check out Scientology on
the web. Gregg said the woman running the store next door to the
Scientologists came out and talked to him. She was not very happy with
them, said it has really hurt business the entire week.
"Buttnor, Felsky, and McPherson called the cops. They had quite a
conversation with the cops, but while the cops did ask for our names, they
blew off the org."
"Gregg and I put in one hour and a half starting about 1:30. Then we broke
for a long lunch and came back about 5:40 for another session. The org had
a tent out with table and chairs. There were few takers Gregg saw. When
Gregg showed up Mario could be heard running about saying 'f*ck, f*ck,
f*ck' in total frustration. The cult was largely in hiding for Gregg.
"Ms. X was picketing with us one of the cult drones got right in her face
with a camera. Gregg got good tape of one incident in the late picket.
Brian McPherson and Gwen Jones were trying to rag at Gregg, who promptly
played some head games on them. 'Big Mike' showed up, pushed Gregg and
grabbed a handful of flyers out of Gregg's hand. Caught nicely on tape
too. Gregg was able to recover the Xenu flyers to the extreme surprise of
"The Toronto org had some kind of event going, something about going OT in
CW. Gregg counted the chairs (160) and the people who showed up. They
filled about 1/4 of the chairs. Most of the people Gregg recognized as
tapped out old timers. There were 10 or fewer new faces and most of them
got a Xenu flyer. Even if the cult took the flyers away from them inside
the door, the people know they can look it up on the net.
"Gregg gave out about a hundred Xenu flyers. I must have given out
something like 250 of several kinds for the whole day. I didn't get a
count on how many Ms X gave out, but Gregg said lots of people were coming
by with flyers in their hands. It is getting harder to give out flyers
because such a high fraction of the people already have taken one."
> Salt Lake CityDeseret News reported on May 4th that Scientology volunteers will be
spending time with the elderly in the area.
"In recognition of the recent National Volunteer Week, the Church of
Scientology's volunteer ministers are launching a new program, 'Listeners
for the Living.' It involves spending time with the elderly and listening
to their stories."
> Reed SlatkinReuters reported on April 29th that Scientology minister and Ponzi scheme
creator Reed Slatkin pled guilty to fraud charges.
"Reed Slatkin, the investment advisor who provided start-up funds for
Internet service provider EarthLink pleaded guilty on Monday to 15 charges
of fraud and conspiracy for bilking almost 800 clients out of nearly $600
million. Slatkin entered his plea before U.S. District Judge Margaret
Morrow under the terms of a plea deal announced by the U.S. Attorney's
Office on Mar. 27.
"'Your Honor, it is an acceptable representation of my conduct,' Slatkin
told Judge Morrow after prosecutors described to the court how he had used
investments from new clients to pay returns to old clients, in what is
commonly known as a Ponzi scheme. It is not clear whether Slatkin can pay
the $254.6 million in restitution he agreed to pay since he has filed for
bankruptcy protection from creditors. Slatkin was led by U.S. marshals
into the courtroom wearing the standard-issue green jacket, blue pants and
manacles around his waist and wrists."
From the Santa Barbara News-Press on April 30th:
"After spending the weekend in the federal detention center in downtown
Los Angeles, EarthLink co-founder and former Hope Ranch resident Reed
Slatkin pleaded guilty in federal court Monday to orchestrating one of the
biggest Ponzi schemes in U.S. history. Mr. Slatkin, 53, pleaded guilty to
15 charges, ranging from mail fraud and money laundering to conspiracy to
obstruct justice. The charges against Mr. Slatkin carry a maximum sentence
of 105 years in federal prison and fines of up to $3.75 million. Federal
authorities believe the sentence could range from 12 to 15 years; his
defense attorney believes it could be much lower."
> Xenu.netLinux Journal published an interview with the creator and ISP for xenu.net
on April 30th.
"Google's decision to pull Xenu.net from its index, under the
controversial Digital Millennium Copyright Act, and the later commitment
to making DMCA takedown letters public caused a publicity storm that, when
it cleared, left 'Operation Clambake,' Xenu.net, at the top of a Google
search for the word 'Scientology.' We asked Andreas Heldal-Lund, the
site's webmaster, and Paul Wouters, of their long-suffering ISP, Xtended
Internet, how the popular site is handling the load.
"LJ: What hardware are you running Linux on?
"Paul: The main servers are running on Intel ISP boxes (1150s and 2150s).
The load-balanced server at XS4ALL is a Penguin 2U server.
"LJ: Andreas, what are the secrets of developing a search-engine-friendly
"Andreas: I've not had to focus on being search-engine-friendly for years.
Xenu.net is on top now basically because the cult attacks have generated
so much attention.
"LJ: How do you get so many incoming links?
"Andreas: Mostly the same reason as above. Few are so disliked as this
cult here on the net. Each time the cult tries to close my site, the more
attention they send my way.
"LJ: Can your Linux server(s) handle the traffic?
"Paul: Right now there is no problem whatsoever. The servers are doing
less then 80KB/sec. We did have some problems after being slashdotted
twice and the site appearing in the Washington Times and on CNN. We found
the hardcoded limit of 128 Apache children had been reached on the main
server. We recompiled Apache with 512, which was reached again around 6pm.
We then went for 1024 and restarted. At this point we also added two more
servers and used DNS roundrobin to try and load balance things a bit.
"At the peak, at 8pm, we ran into performance problems on the Linux
firewall. These weren't resolved until after the massive peaks. We
optimized all the TCP socket options and we added more memory to the
firewall (the socket options eat up a lot of memory).
"When the Church of Scientology coerced the search engine, Google.com,
into dropping the anti-Scientology site Xenu.com from its listings,
free-speech advocates were outraged. But Xenu's owner wasn't worried; he
knew what happens when you mess with the Net."
From Readme on May 1st:
"Seventy-five million years ago, a galactic tyrant named Xenu (pronounced
'ZEE-NOO') killed all living beings with a hydrogen bomb, then brainwashed
their disembodied minds. Eventually, Xenu was overthrown by his former
followers and locked away in a mountain prison encircled by an
impenetrable force field. He remains there to this day.
"This story is one of the fundamental beliefs of the religion known as
Scientology. According to 'Countercultures', a 1995 book by the cult
critic William Zellner, the Church of Scientology charges as much as
$400,000 to completely free a believer from the residual effects of Xenu's
brainwashing. Scientology has come under fire for its controversial
practices, which critics allege include cult-like brainwashing and
lucrative global racketeering. The Church has trademarked its teachings
and has a reputation for using legal threats, specifically the charge of
copyright infringement, to muzzle these disaffected onetime believers and
"In the most recent Web war between Scientology and its critics, the
popular search engine Google caved in to legal pressure from the church
and removed any mention of the most well-known anti-Scientology website
Xenu.net from its search results. According to the church, Xenu had made
secret Scientology teachings public, in violation of church-owned
copyrights and trademarks.
"On March 21 Google sent Heldal-Lund an e-mail with a listing the Xenu
pages that they had removed from their searchable archives. The e-mail
also stated that his webpages could be reinstated if he submitted a
counter notification to Google. Heldal-Lund did not respond. Because of
his silence, recent articles portray the Xenu founder as a cowering victim
of Scientology's legal abuse, afraid of being sued. Two days after sending
the e-mail, battered by a barrage of protests and under scrutiny from
free-speech advocates for the hasty decision, Google restored Xenu.net's
homepage and related links to its archive, claiming they had been
"'I do not consider this a Scientology victory,' said Heldal-Lund, in an
e-mail interview. 'The result [of the church's actions] is a lot of media
attention and hundreds of thousands of hits on Xenu. The cult achieved the
opposite of what they aimed for.'"
From an editorial in the San Jose Mercury News on May 2nd:
"Search engines like Google provide an indispensable road map for
navigating the Internet; hypertext links are the vehicles that quickly
take you where you want to go. Search engines and links provide
information in context; they enhance the Internet's richness of ideas. As
such, they warrant full free-speech protections. But a tussle between the
Church of Scientology and Google has exposed a First Amendment
vulnerability. A poorly worded copyright-protection law is putting dissent
and speech on the Internet at some risk.
"The church threatened to sue Google for contributory copyright violations
for merely listing links to Web pages that, the Scientologists said,
illegally published copyrighted passages. The church demanded that Google
remove the links to the site, Operation Clambake, from its automated
search results. The brash tactic initially worked. Google complied because
of potential liability that Congress created in the Digital Millennium
Copyright Act. The law provides search engines with immunity if they take
down a disputed link in response to a complaint.
"The Church of Scientology was the first to target search engines; if it
succeeded, others may follow, filing complaints to stifle critics or to
isolate Web sites that make fair use of copyrighted works. Word that the
largest stand-alone search engine had caved to the Scientologists stirred
a small protest at Google's Mountain View headquarters. And that, in turn,
inspired the company to try a novel approach.
"As of last month, whenever it receives a complaint that causes it to
remove a link, Google is forwarding a copy of the complaint to the Web
site of Chilling Effects Clearinghouse, a new Internet civil liberties
organization. Chilling Effects posts each complaint, which also lists the
Web address of the site that Google no longer carries. The result may be
to give substantial attention to sites the Scientologists hoped to make
invisible. Google is also including information on its site on how Web
page owners can seek to have their links reinstated by filing a
countercomplaint. Google's new approach is commendable, even ingenious.
But it doesn't remove the shadow of liability that Congress created in the
1998 copyright protection law. Courts and Congress should make clear:
Linking is a virtue of the Internet, not a crime."