Packingham v. North Carolina, 582 U.S. 98 (2017), is a case in which the Supreme Court of the United States held that a North Carolina statute that prohibited registered sex offenders from using social media websites was unconstitutional because it violated the First Amendment to the U.S. Constitution, which protects freedom of speech. In 2010, Lester Gerard Packingham, a registered sex offender, posted on Facebook under a pseudonym to comment favorably on a recent traffic court experience. Police then identified Packingham and charged him with violating North Carolina's law. Packingham moved to dismiss the charges, arguing that the state's law violated the First Amendment. The trial court dismissed this motion and ultimately convicted Packingham. A state appellate court initially reversed the trial court, holding that the law did violate the First Amendment, but the North Carolina Supreme Court, the state's highest court, disagreed and reinstated the conviction. In June 2017, the U.S. Supreme Court unanimously reversed the North Carolina Supreme Court's judgment. In the majority opinion authored by Justice Anthony Kennedy, the Court held that social media—defined broadly to include Facebook, Amazon.com, The Washington Post, and WebMD, among many others—is a "protected space" under the First Amendment for lawful speech. The Court offered that North Carolina could protect children through less restrictive means, such as prohibiting "conduct that often presages a sexual crime, like contacting a minor or using a website to gather information about a minor". == Background == === North Carolina statute === In 2008, the state of North Carolina passed a law that made it a felony for a registered sex offender "to access a commercial social networking Web site where the sex offender knows that the site permits minor children to become members or to create or maintain personal Web pages". The law defined a "commercial social networking Web site" using four criteria. Specifically, the website must: be "operated by a person who derives revenue from membership fees, advertising, or other sources related to the operation of the Web site". facilitate "the social introduction between two or more persons for the purposes of friendship, meeting other persons, or information exchanges". allow "users to create Web pages or personal profiles that contain information such as the name or nickname of the user, photographs placed on the personal Web page by the user, other personal information about the user, and links to other personal Web pages on the commercial social networking Web site of friends or associates of the user that may be accessed by other users or visitors to the Web site". provide "users or visitors... mechanisms to communicate with other users, such as a message board, chat room, electronic mail, or instant messenger". The law exempted websites that "Provid[e] only one of the following discrete services: photo-sharing, electronic mail, instant messenger, or chat room or message board platform", as well as websites that have as their primary purpose "the facilitation of commercial transactions involving goods or services between [their] members or visitors". === Facts of the case === In 2002, Lester Gerard Packingham was convicted of taking "indecent liberties with a child", a felony that required him to register as a sex offender. A North Carolina court sentenced him to 10–12 months in prison with 24 months of supervised release. He was given no other special instructions on his behavior outside of prison other than to "remain away from" the minor. In 2010, after a state court dismissed a traffic ticket against Packingham, he submitted a post on Facebook under the name "J. R. Gerrard", stating: "Man God is Good! How about I got so much favor they dismissed the ticket before court even started? No fine, no court cost, no nothing spent. . . . . .Praise be to GOD, WOW! Thanks JESUS!" The Durham Police Department identified Packingham as the author of the post after cross-checking the time of the post with recently dismissed traffic tickets, and a grand jury indicted him for violating the North Carolina statute. === Lower court proceedings === Initially, Packingham moved to dismiss his indictment, arguing that it violated the First Amendment. A North Carolina Superior Court judge denied this motion, and he was convicted of violating the North Carolina social media law. Packingham appealed his conviction to the North Carolina Court of Appeals, which reversed the trial court's decision in 2013. Applying intermediate scrutiny, the court of appeals determined that North Carolina's law violated the First Amendment because it was too broad, applying to all registered sex offenders regardless of whether the offender had committed a crime involving a minor or whether the offender was a continuing threat to minors. The appeals court also stated that the law had been defined broadly enough to prohibit a registered sex offender from conducting a wide array of Internet activity, such as "conducting a 'Google' search, purchasing items on Amazon.com, or accessing a plethora of Web sites unrelated to online communication with minors". In 2015, the North Carolina Supreme Court, the state's highest court, reversed the court of appeals, holding that the law was "constitutional in all respects". The North Carolina Supreme Court found that the statute was a "limitation on conduct" and did not impede any free speech. The state had a vested interest in “forestalling the illicit lurking and contact of minors” by registered sex offenders and potential future victims, and upheld Packingham's conviction. == Supreme Court ruling == Packingham filed a petition for a writ of certiorari with the Supreme Court of the United States. The federal government also filed a brief recommending that the Supreme Court grant certiorari, arguing that the North Carolina Supreme Court incorrectly decided the case in favor of the state. The U.S. Supreme Court granted certiorari in October 2016. Amicus briefs in support of Packingham were filed by the libertarian Cato Institute and the American Civil Liberties Union. The North Carolina Supreme Court filed a brief supporting its prior decision, urging the importance of protecting minors from being stalked online. === Oral argument === The oral argument took place in February 2017. Packingham’s lawyer, David T. Goldberg, argued that the law banned “vast swaths of First Amendment activity”, went too far in restricting which Internet sites could be accessed, and forbade use of the Internet in general. The law targeted speech on some of the platforms that Americans use most often, Goldberg noted, and that under the law Packingham could not even use Twitter to read the myriad messages discussing his own case. He further noted that the law imposes punishment without regard to whether the offender actually did anything wrong. North Carolina’s senior deputy Attorney General, Robert C. Montgomery, argued for the state, and claimed that communication through social media sites is a “crucial channel”. Justice Sonia Sotomayor asked Montgomery to provide evidence as to the claim that by giving Packingham Internet privileges, he would commit another crime. Justice Stephen Breyer added that “It seems to be well-settled law that the state can’t (bar usage) unless there is a 'clear and present danger'." === Opinion of the Court === In June 2017 the Supreme Court delivered a judgment in favor of Packingham, unanimously voting to reverse the state court's ruling. Justice Anthony Kennedy authored the decision, joined by Justice Ginsburg, Justice Breyer, Justice Sotomayor, and Justice Kagan. Kennedy explained the decision: "A fundamental principle of the First Amendment is that all persons have access to places where they can speak and listen, and then, after reflection, speak and listen once more." He continued that "By prohibiting sex offenders from using those websites, North Carolina with one broad stroke bars access to what for many are the principal sources for knowing current events, checking ads for employment, speaking and listening in the modern public square, and otherwise exploring the vast realms of human thought and knowledge." Citing Ashcroft v. Free Speech Coalition as a precedent, Kennedy also wrote: "It is well established that, as a general rule, the Government 'may not suppress lawful speech as the means to suppress unlawful speech'." === Concurring opinion === Justice Samuel Alito wrote an opinion concurring in the judgment, joined by John Roberts and Clarence Thomas. While Alito agreed that the state statute at issue violated the First Amendment, he noted that there are reasonable scenarios for which legal bans for sex offenders can be placed, such as for sites targeted at teenagers. Justice Gorsuch took no part in the decision of the case. == Impact == Packingham v. North Carolina was one of the first U.S. Supreme Court cases to ana
Clef (app)
Clef was a San Francisco-based technology company, known for developing a mobile app that created a two-factor authentication for websites. It allowed users to access sites with a single login password management service which stores encrypted passwords in private accounts. It had a standard verification method that requires access to data on the mobile phone to confirm the user's identity. The application required a Wi-Fi or mobile network, and the user could log in by scanning the computer screen with their phone. == History == Clef was founded in 2013 by Mark Hudnall, B. Byrne and Jesse Pollak. It raised $1.6 million in seed funding in November 2014. Clef integrated with many websites and applications, including WordPress. On March 17, 2017, Clef announced they would no longer support the plugin after June 6, 2017; Clef was acquired by Authy, another 2FA service, which later got acquired by Twilio.
ServerNet
ServerNet is a switched fabric communications link primarily used in proprietary computers made by Tandem Computers, Compaq, and HP. Its features include good scalability, clean fault containment, error detection and failover. The ServerNet architecture specification defines a connection between nodes, either processor or high performance I/O nodes such as storage devices. == History == Tandem Computers developed the original ServerNet architecture and protocols for use in its own proprietary computer systems starting in 1992, and released the first ServerNet systems in 1995. Early attempts to license the technology and interface chips to other companies failed, due in part to a disconnect between the culture of selling complete hardware / software / middleware computer systems and that needed for selling and supporting chips and licensing technology. A follow-on development effort ported the Virtual Interface Architecture to ServerNet with PCI interface boards connecting personal computers. Infiniband directly inherited many ServerNet features. As of 2017, systems still ship based on the ServerNet architecture.
Why We Post
Why We Post is a research project funded by the European Research Council and launched in 2012 by Daniel Miller with the objective of examining the global impact of new social media. The study is based on ethnographic data collected through the course of 15 months in China, India, Turkey, Italy, United Kingdom, Trinidad, Chile and Brazil. The results of this project were released on 29 February 2016. This included the first three of eleven Open Access books (available via UCL Press), a five-week e-course (MOOC) on FutureLearn in English, also available in Chinese, Portuguese, Hindi, Tamil, Italian, Turkish, and Spanish on UCLeXtend. In addition a website containing key discoveries, stories and over 100 films is available in the same 8 languages.
Change data capture
In databases, change data capture (CDC) is a set of software design patterns used to determine and track the data that has changed (the "deltas") so that action can be taken using the changed data. The result is a delta-driven dataset. CDC is an approach to data integration that is based on the identification, capture and delivery of the changes made to enterprise data sources. For instance it can be used for incremental update of data loading. CDC occurs often in data warehouse environments since capturing and preserving the state of data across time is one of the core functions of a data warehouse, but CDC can be utilized in any database or data repository system. == Methodology == System developers can set up CDC mechanisms in a number of ways and in any one or a combination of system layers from application logic down to physical storage. In a simplified CDC context, one computer system has data believed to have changed from a previous point in time, and a second computer system needs to take action based on that changed data. The former is the source, the latter is the target. It is possible that the source and target are the same system physically, but that would not change the design pattern logically. Multiple CDC solutions can exist in a single system. === Timestamps on rows === Tables whose changes must be captured may have a column that represents the time of last change. Names such as LAST_UPDATE, LAST_MODIFIED, etc. are common. Any row in any table that has a timestamp in that column that is more recent than the last time data was captured is considered to have changed. Timestamps on rows are also frequently used for optimistic locking so this column is often available. === Version numbers on rows === Database designers give tables whose changes must be captured a column that contains a version number. Names such as VERSION_NUMBER, etc. are common. One technique is to mark each changed row with a version number. A current version is maintained for the table, or possibly a group of tables. This is stored in a supporting construct such as a reference table. When a change capture occurs, all data with the latest version number is considered to have changed. Once the change capture is complete, the reference table is updated with a new version number. (Do not confuse this technique with row-level versioning used for optimistic locking. For optimistic locking each row has an independent version number, typically a sequential counter. This allows a process to atomically update a row and increment its counter only if another process has not incremented the counter. But CDC cannot use row-level versions to find all changes unless it knows the original "starting" version of every row. This is impractical to maintain.) === Status indicators on rows === This technique can either supplement or complement timestamps and versioning. It can configure an alternative if, for example, a status column is set up on a table row indicating that the row has changed (e.g., a boolean column that, when set to true, indicates that the row has changed). Otherwise, it can act as a complement to the previous methods, indicating that a row, despite having a new version number or a later date, still shouldn't be updated on the target (for example, the data may require human validation). === Time/version/status on rows === This approach combines the three previously discussed methods. As noted, it is not uncommon to see multiple CDC solutions at work in a single system, however, the combination of time, version, and status provides a particularly powerful mechanism and programmers should utilize them as a trio where possible. The three elements are not redundant or superfluous. Using them together allows for such logic as, "Capture all data for version 2.1 that changed between 2005-06-01 00:00 and 2005-07-01 00:00 where the status code indicates it is ready for production." === Triggers on tables === May include a publish/subscribe pattern to communicate the changed data to multiple targets. In this approach, triggers log events that happen to the transactional table into another queue table that can later be "played back". For example, imagine an Accounts table, when transactions are taken against this table, triggers would fire that would then store a history of the event or even the deltas into a separate queue table. The queue table might have schema with the following fields: Id, TableName, RowId, Timestamp, Operation. The data inserted for our Account sample might be: 1, Accounts, 76, 2008-11-02 00:15, Update. More complicated designs might log the actual data that changed. This queue table could then be "played back" to replicate the data from the source system to a target. Data capture offers a challenge in that the structure, contents and use of a transaction log is specific to a database management system. Unlike data access, no standard exists for transaction logs. Most database management systems do not document the internal format of their transaction logs, although some provide programmatic interfaces to their transaction logs (for example: Oracle, DB2, SQL/MP, SQL/MX and SQL Server 2008). Other challenges in using transaction logs for change data capture include: Coordinating the reading of the transaction logs and the archiving of log files (database management software typically archives log files off-line on a regular basis). Translation between physical storage formats that are recorded in the transaction logs and the logical formats typically expected by database users (e.g., some transaction logs save only minimal buffer differences that are not directly useful for change consumers). Dealing with changes to the format of the transaction logs between versions of the database management system. Eliminating uncommitted changes that the database wrote to the transaction log and later rolled back. Dealing with changes to the metadata of tables in the database. CDC solutions based on transaction log files have distinct advantages that include: minimal impact on the database (even more so if one uses log shipping to process the logs on a dedicated host). no need for programmatic changes to the applications that use the database. low latency in acquiring changes. transactional integrity: log scanning can produce a change stream that replays the original transactions in the order they were committed. Such a change stream include changes made to all tables participating in the captured transaction. no need to change the database schema == Confounding factors == As often occurs in complex domains, the final solution to a CDC problem may have to balance many competing concerns. === Unsuitable source systems === Change data capture both increases in complexity and reduces in value if the source system saves metadata changes when the data itself is not modified. For example, some Data models track the user who last looked at but did not change the data in the same structure as the data. This results in noise in the Change Data Capture. === Tracking the capture === Actually tracking the changes depends on the data source. If the data is being persisted in a modern database then Change Data Capture is a simple matter of permissions. Two techniques are in common use: Tracking changes using database triggers Reading the transaction log as, or shortly after, it is written. If the data is not in a modern database, CDC becomes a programming challenge. === Push versus pull === Push: the source process creates a snapshot of changes within its own process and delivers rows downstream. The downstream process uses the snapshot, creates its own subset and delivers them to the next process. Pull: the target that is immediately downstream from the source, prepares a request for data from the source. The downstream target delivers the snapshot to the next target, as in the push model. === Alternatives === Sometimes the slowly changing dimension is used as an alternative method. CDC and SCD are similar in that both methods can detect changes in a data set. The most common forms of SCD are type 1 (overwrite), type 2 (maintain history) or 3 (only previous and current value). SCD 2 can be useful if history is needed in the target system. CDC overwrites in the target system (akin to SCD1), and is ideal when only the changed data needs to arrive at the target, i.e. a delta-driven dataset.
Textual case-based reasoning
Textual case-based reasoning (TCBR) is a subtopic of case-based reasoning, in short CBR, a popular area in artificial intelligence. CBR suggests the ways to use past experiences to solve future similar problems, requiring that past experiences be structured in a form similar to attribute-value pairs. This leads to the investigation of textual descriptions for knowledge exploration whose output will be, in turn, used to solve similar problems. == Subareas == Textual case-base reasoning research has focused on: measuring similarity between textual cases mapping texts into structured case representations adapting textual cases for reuse automatically generating representations.
Critical security parameter
In cryptography, a critical security parameter (CSP) is information that is either user or system defined and is used to operate a cryptography module in processing encryption functions including cryptographic keys and authentication data, such as passwords, the disclosure or modification of which can compromise the security of a cryptographic module or the security of the information protected by the module.