Supreme Court Rules Hotels Not Required to Surrender Registries to Law Enforcers Without a Warrant

What happens when law enforcers enter a hotel and demand to see the registry? That question was, surprisingly, up in the air until now. Even though common sense would dictate that a hotel isn’t required to surrender such information without a warrant being issued the question had to go all the way to the Supreme Court for a definitive answer. Luckily the Nazgûl decided to rule in favor of privacy:

The Supreme Court gave a big boost to privacy Monday when it ruled that hotels and motels could refuse law enforcement demands to search their registries without a subpoena or warrant. The justices were reviewing a challenge to a Los Angeles ordinance requiring hotels to provide information to law enforcement—including guests’ credit card number, home address, driver’s license details, and vehicle license number—at a moment’s notice. Similar ordinances exist in about a hundred other cities stretching from Atlanta to Seattle.

Los Angeles claimed the ordinance (PDF) was needed to battle gambling, prostitution, and even terrorism, and that guests would be less likely to use hotels and motels for illegal purposes if they knew police could access their information at will.

Justice Sonia Sotomayor, writing for the 5-4 majority, ruled (PDF) that the Los Angeles ordinance violated the Fourth Amendment and is an illegal “pretext to harass hotel operators and their guests.”

What should concern people is that this ruling was determined by only one vote. Had a single Nazgûl voted the other way it would have been legal for law enforcers to storm a hotel and confiscate the registry without even obtaining a warrant. This is why the whole concept of majority rules doesn’t sit well with me. Sometimes the majority make the right decision, such as in this case, and sometimes they make the wrong decision.

It should be noted that this ruling doesn’t require hotels to surrender their registries without a warrant but it doesn’t stop them from voluntarily surrendering them. You should still avoid shitty hotels like Motel 6 that make it company policy to violate their customers’ privacy.

History of Crypto War I

In its zeal to preserve the power to spy on its citizens members of the United States government have begun pushing to prohibit civilians from using strong cryptography. While proponents of this prohibition try to scare you with words such as terrorists, drug cartels, and pedophiles let’s take a moment to remember the last time this war was waged:

Encryption is a method by which two parties can communicate securely. Although it has been used for centuries by the military and intelligence communities to send sensitive messages, the debate over the public’s right to use encryption began after the discovery of “public key cryptography” in 1976. In a seminal paper on the subject, two researchers named Whitfield Diffie and Martin Hellman demonstrated how ordinary individuals and businesses could securely communicate data over modern communications networks, challenging the government’s longstanding domestic monopoly on the use of electronic ciphers and its ability to prevent encryption from spreading around the world. By the late 1970s, individuals within the U.S. government were already discussing how to solve the “problem” of the growing individual and commercial use of strong encryption. War was coming.

The act that truly launched the Crypto Wars was the White House’s introduction of the “Clipper Chip” in 1993. The Clipper Chip was a state-of-the-art microchip developed by government engineers which could be inserted into consumer hardware telephones, providing the public with strong cryptographic tools without sacrificing the ability of law enforcement and intelligence agencies to access unencrypted versions of those communications. The technology relied on a system of “key escrow,” in which a copy of each chip’s unique encryption key would be stored by the government. Although White House officials mobilized both political and technical allies in support of the proposal, it faced immediate backlash from technical experts, privacy advocates, and industry leaders, who were concerned about the security and economic impact of the technology in addition to obvious civil liberties concerns. As the battle wore on throughout 1993 and into 1994, leaders from across the political spectrum joined the fray, supported by a broad coalition that opposed the Clipper Chip. When computer scientist Matt Blaze discovered a flaw in the system in May 1994, it proved to be the final death blow: the Clipper Chip was dead.

The battlefield today reflects the battlefield of Crypto War I. Members of the government are again arguing that all civilian cryptography should be weakened by mandating the use of key escrow that allows the government to gain access to any device at any time. As with the last war, where the government proposed Clipper Chip was proven to be completely insecure, this war must be looked at through the eye of government security practices or, more specifically, lack of security practices. It was only last week that we learned some of the government’s networks are not secure, which lead to the leaking of every federal employee’s personal information. How long do you think it would take before a hack of a government network lead to the leaking of every escrow key? I’d imagine it would take less than a week. After that happened every device would be rendered entirely insecure by anybody who downloaded the leaked escrow keys.

What everybody should take away from this is that the government is willing to put each and every one of us at risk just so it can maintain the power to spy on use with impunity. But its failure to win Crypto War I proved that the world wouldn’t come to an end if the government couldn’t spy on us with impunity. Since Crypto War I the power of law enforcement agents to acquire evidence of wrongdoing (according to the state) didn’t suddenly stop, terrorist attacks didn’t suddenly become a nightly occurrence, and children being abducted by pedophiles didn’t suddenly become a fact of everyday life.

Crypto War II is likely inevitable but it can be won just as the last one was. The first step to victory is not allowing yourself to be suckered by government lies.

The Sorry State of E-Mail

As I briefly mentioned last week I’ve been spending time setting up a new e-mail server. For years I’ve been using OS X Server to run my e-mail server because it was easy to setup. But there are a lot of things I dislike about OS X Server. The biggest problem was with the change from 10.6 to 10.7. With that update OS X Server went from being a fairly serious piece of server software that a small business could use to being almost completely broken. Apple slowly improved things in later released of OS X but its server software remains amateur hour. Another thing that I dislike about OS X Server is how unstable it becomes the moment you open a config file and make some manual changes. The graphical tool really doesn’t like that but it also don’t give you the options necessary to fine tune your security settings.

My e-mail server has grown up and now runs on CentOS. I’ve tried to tighten up security as much as possible but I’ve quickly learned how sorry of a state e-mail is in. One of my goals was to disable broken Transport Layer Security (TLS) settings. However this presents a sizable problem because there are a lot of improperly configured e-mail servers out there. Unlike web servers where you can usually safely assume clients will be able to establish a connection with a sever using properly configured TLS no such assumptions can be made with e-mail servers. Some e-mail servers don’t support any version of TLS or Secure Socket Layer (SSL) and those that do often have invalid (expired, self-signed, etc.) certificates. In other words you can’t disable unsecured connections without being unable to communicate with a large number of e-mail servers out there. Let me just say that as much as I hate how everybody uses Google because it makes the government’s surveillance apparatus cheaper to implement I appreciate that the company actually has properly configured e-mail servers.

Another problem with securing e-mail servers is that they rely on the STARTTLS protocol. I say this is a problem because the first part of establishing a secure connection via STARTTLS is asking the server if it supports it through an unsecured connection. This has allowed certain unscrupulous Internet service providers (ISPs) to intercept and edit out the mention of STARTTLS support from a server’s reply, which causes the client to revert to an unsecured connection for the entire communication. This wouldn’t be a problem if we could safely assume all e-mail servers support TLS because then you could configure servers to only use TLS.

What’s the answer? Ultimately I would say it is to move away from e-mail as we currently know it. But that’s easier said than done so I will continue to strong urge people to utilize Pretty Good Privacy (PGP) to encrypt and sign their e-mails. Even if a PGP encrypted e-mail is transmitted over an unsecured connection the amount of data a snoop can collect on you is far less (but since PGP can only really encrypt the contents of the e-mail a great deal of metadata is still available to anybody observing the communication between e-mail servers).

I also urge people to learn how to setup their own e-mail servers and to do it. Ars Technica and Sealed Abstract have good guides on how to setup a pretty secure e-mail server. However there is the problem that many ISPs block the ports used by e-mail server on their residential packages. So implementing an e-mail server out of your home could require getting a business account (as well as a static Internet protocol (IP) address). A slightly less optimal (because your e-mail won’t be stored on a system you physically control) option of setting up your e-mail server on a third-party host is a way to bypass this problem. Unless people stop relying on improperly configured e-mail servers there isn’t a lot of hope for salvaging e-mail as a form of secure communication (this should give people involved in professions that require confidentiality, such as lawyers, a great deal of concern).

Many people will probably become discouraged after reading this post and tell themselves that securing themselves is impossible. That’s not what you should take away from this post. What you should take away from this post is that the problem requires us to roll up our sleeves, further our knowledge, and fix it ourselves. Securing e-mail isn’t hopeless, it just requires us to actually do something about it. For my part I am willing to answer questions you have regarding setting up an e-mail server. Admittedly I won’t know the answer to every question but I will do my best to provide you with the knowledge you need to secure yourself.

OpenBazaar Will Kill Us All

Mainstream economists are obsessed with control. Unlike the Austrian tradition, which correctly states that there is no way to control economies, mainstream economists believe that an ideal economy, whatever that is, can be had if a strong enough centralized power forces people to obey the correct plan. This obsession leads them to see doom and gloom in the strangest of places. Consider OpenBazaar. OpenBazaar is a decentralized commerce platform that allows anybody to buy and sell goods online without going through a middleman such as Amazon or eBay. Sounds empowering, doesn’t it? Not according to mainstream economists. To them the idea of OpenBazaar undermines the control they worship and is therefore a threat to humanity:

While Hoffman could be right that OpenBazaar will revolutionize online commerce, its business model could also potentially threaten America’s tech industry. The wild and uncontrollable nature of OpenBazaar’s technology, especially if it winds up being used to facilitate terrorism, could push authorities to launch a broad crackdown on other technologies as well that law enforcement considers an impediment to its work.

And if the potential harm from a marketplace seems limited to you, consider what could happen from the combination of this type of technology with Artificial Intelligence. As AI evolves, even tech visionaries like Microsoft founder Bill Gates and Tesla chief Elon Musk have expressed concern over the ability of humans to control the outcome, especially if machines are eventually able to ‘think’ autonomously. Now apply OpenBazaar’s decentralized and police-resistant model to this and you have a recipe for disaster: machines with free will and the ability to communicate with each other under the human radar. Maybe an Isaac Asimov-inspired fantasy at one time, this is hardly an impossible scenario anymore given the rapid pace of technological development.

You have to admire how he states OpenBazaar could hurt the technology industry and immediately turn around and explain how it could greatly enhance the technology industry by helping artificial intelligence (AI) advance (although, again due to an obsession with power, he sees the advancement of AI as extremely dangerous).

This article shows just how insane of an obsession with power mainstream economists possess. Anything that could be potentially disruptive, which all technology can be, is seen as a threat. Computers were originally feared by many mainstream economists because they stood to replace a lot of human labor. In fact this attitude is still alive. Light bulbs probably had numerous mainstream economists shitting their pants because they would replace the candle.

Here we have a platform that enabled individuals to buy and sell goods without having to go through a middleman or front the expense of running their own commerce front end. It could allow some little old lady in the backwoods of Alabama to sell the excellent arts and crafts she’s known locally for. A manufacturer or parts for old automobiles who only sold locally could setup an online presence and sell to anybody in the world. There is so much potential for this kind of platform but mainstream economists don’t see it because the potential derives from an ability to bypass controls.

Let us also not forget the cost of control. Silk Road was revolutionary not because it allowed people to buy and sell illicit drugs but because it protected people participating in voluntary trade from violent law enforcers. It made the illicit drug trade much safer for everybody involved because the biggest threat to somebody buying or selling illicit drugs is a group of heavily armed trigger happy cops kicking down their door at oh dark thirty in the hopes of finding a little baggy of pot and a dog to shoot (not necessarily in that order). The control mainstream economists worship requires violence and tools that protect people from that violence stand to make the world a safer place. That’s why I don’t believe tools like OpenBazaar are a danger to society. If anything they stand to save a lot of peaceful people from the truncheon of the state.

Lazy Libertarians

This weekend several of my friends and I had the privilege of running the CryptoParty for B-Sides MSP. It wasn’t the first CryptoParty I’ve either hosted or helped host but all of the previous ones were for various libertarian groups. I cannot properly express the difference between being a part of a CryptoParty with security professionals versus libertarians. Unlike the libertarian CryptoParties I’ve been involved with, none of the people at B-Sides MSP went on a tirade about how the otherwise entirely incompetent government can magically crack all crypto instantly.

Libertarians like to consider themselves the paragons of personal responsibility. However, time and again, I see that a lot of libertarians putting more effort into making excuses for their laziness than doing anything productive. Using secure communication tools is one of these areas where supposedly responsible libertarians like to be entirely irresponsible. This is kind of ironic because libertarians tend to be the ones bitching about government surveillance the loudest.

It was during the CryptoParty at B-Sides MSP that I made a decision. From now on I’m going to call out lazy libertarians. Whenever I host or otherwise participate in a CryptoParty for libertarians and one of them goes off about the incompetent government suddenly being incredibly competent I’m just going to tell them to shut the fuck up so the adults can continue talking. If you are a libertarian and you sincerely oppose government surveillance then prove your sincerity by utilizing the really awesome and very effective tools we have available to secure our communications. Use Pretty Good Privacy (PGP) to encrypt your e-mails, call people with Red Phone or Signal, send text messages with TextSecure or Signal, and encrypt your computer and mobile device’s storage. Unless you’re doing these things I can’t take any claims you make about hating government surveillance seriously. If you want to be lazy and make up conspiracy theories that’s your thing but I am going to call your ass out for it.

Actual security professionals, some of whom knew a hell of a lot more about cryptography than me (not that that’s very hard), took these tools seriously and so should as well. The only people claiming that the government can break all cryptography instantly are conspiracy theorists who know absolutely dick about cryptography and people wanting to justify their laziness. Don’t be either of those. Instead embrace the personal responsibility libertarians like to tout and take measures to make government surveillance more expensive.

When is Discussing Cryptography a Jailable Offense

A 17 year-old is facing 15 years in a cage because he discussed cryptography. Specifically he discussed how members of the Islamic State could utilize cryptography to further their goals:

A 17-year-old Virginia teen faces up to 15 years in prison for blog and Twitter posts about encryption and Bitcoin that were geared at assisting ISIL, which the US has designated as a terror organization.

The teen, Ali Shukri Amin, who contributed to the Coin Brief news site, pleaded guilty (PDF) Thursday to a federal charge of providing material support to the Islamic State in Iraq and the Levant.

Dana Boente, the US Attorney for the Eastern District of Virginia, said the youth’s guilty plea “demonstrates that those who use social media as a tool to provide support and resources to ISIL will be identified and prosecuted with no less vigilance than those who travel to take up arms with ISIL.”

According to the defendant’s signed “Admission of Facts” filed Thursday, Amin started the @amreekiwitness Twitter handle last June and acquired some 4,000 followers and tweeted about 7,000 times. (The Twitter handle has been suspended.) Last July, the teen tweeted a link on how jihadists could use Bitcoin “to fund their efforts.”

According to Amin’s court admission (PDF):

The article explained what Bitcoins were, how the Bitcoin system worked and suggested using Dark Wallet, a new Bitcoin wallet, which keeps the user of Bitcoins anonymous. The article included statements on how to set up an anonymous donations system to send money, using Bitcoin, to the mujahedeen.

Some may point out that this is obviously bad because it supports the “enemies of America.” But it brings up a very important question. Where is the line drawn between aiding an enemy and simply discussing cryptography? I write a lot of posts about how encryption can be used to defend against the state. That information could very well be read by members of the Islamic State and used to secure their communications against American surveillance. Have I aided the enemy? Has every cryptographer who has written about defending against government surveillance aided the enemy?

Lines get blurry when governments perform widespread surveillance like that being done by the National Security Agency (NSA). Regular people who simply want to protect their privacy, which is supposedly protected by the Constitution in this country, and military enemies of the government suddenly find themselves using the same tools and following the same privacy guides. What works, at least in regards to secure communications and anonymization, for people wanting privacy and military enemies is the same. Therefore a guide aimed at telling people how to encrypt their e-mail so it can’t be read by the NSA also tells an agent of the Islamic State how to do the same.

Where is the line drawn? Is it the language used? If you specifically mention members of the Islamic State as the intended audience are you then guilty? If that’s the case wouldn’t the obvious solution be writing generic guides that explain the same things? Wouldn’t that mean the information written by Ali Shukri Amin would have been perfectly fine if he simply didn’t tailor it for members of the Islamic State?

As the state’s use of widespread surveillance is utilized to enforce more laws the desire of regular people to secure their communications will increase (because, after all, we’re all breaking the law even if we don’t intent to or know we are doing it). They will use the same tools and guides as members of the Islamic State could use. Will every cryptographer face the same fate as Ali Shukri Amin?

If You Defend Eric Casebolt You Are an Idiot

I haven’t discussed the event in McKinney, Texas because, sadly, stories of police abuse are so frequent that it’s hard to say anything new about them. But idiots rising to defend badged abusers have managed to piss me off enough to write a post. For those of you who aren’t familiar with the situation this video will explain everything:

Thank the gods for people who record the police.

The officer who threw the girl to the ground and kept her pinned is Eric Casebolt. He recently resigned from the force in the hopes of dodging any consequences for actions. That hardly seems necessary though when so many neocons are willing to rise to his defense. Believe it or not there are a lot of people justifying what Casebolt did.

What could possibly justify an officer rushing into a crowd of non-threatening teenagers, run around like a rabid dog, and toss an obviously unarmed girl to the ground? That depends on which idiot is defending him. One of the most common justifications given is the number of teenagers present.

Apparently there is some number, one that none of these abuse apologists will provide, of people present where an officer can transition from a calm and collected professional into a psychotic abuser. It doesn’t matter that the teenagers in the video are obviously non-threatening. It doesn’t matter that the attire of most of the teenagers, especially the girl thrown to the ground, makes it almost entirely impossible for them to conceal a weapon. The simple fact that there are so many of them gives the officer justification to abuse that girl according to these boot lickers.

A lot of abuse defenders have been making a point of the teenagers failing to cooperate with the officers. Failing to cooperate in this case must mean failing to kowtow immediately because none of the teenagers appear to be engaging the officers. Standing idly by as a psychotic nutball runs around screaming threats of violence is not failing to cooperate; it’s actually an exceptionally polite way to deal with the situation. Those teenagers had every right to tackle that officer to the ground as soon as he began assaulting that girl.

“Totality of the situation” is a phrase being favored by these boot lickers. What particular aspects of this situation when combined justify this situation? Who knows. I honestly suspect “totality of the situation” is code for “too many black youths being present” because I can’t see any justification for the violent displayed by the officer in that video.

Simply put, everybody who has been defending Casebolt is an idiot. They are the reason for this country has become a tyrannical police state. Coldbolt should be arrested and tried for assault just as anybody else not wearing a badge would have been in that situation. He should compensate the girl he assaulted an amount agreed upon by a jury because she is the victim and deserves redress. Unless the law applies to everybody equally and wrongs are expected to be righted as much as possible a society cannot consider itself free.

The Libertarian “Fantasy”

Gods bless Mother Jones. Between Slate and itself there are enough criticisms about libertarianism based on entirely fabricated claims to fill an encyclopedia. Take the latest shot fired by Mother Jones aimed at the predominance of men in libertarianism:

Jeet Heer investigates a burning question today: why are most libertarians men? He offers several plausible explanations, but I think he misses the real one, perhaps because it’s pretty unflattering to libertarians.

So here’s the quick answer: Hardcore libertarianism is a fantasy. It’s a fantasy where the strongest and most self-reliant folks end up at the top of the heap, and a fair number of men share the fantasy that they are these folks. They believe they’ve been held back by rules and regulations designed to help the weak, and in a libertarian culture their talents would be obvious and they’d naturally rise to positions of power and influence.

The reason this is such a laughable criticism is because it’s being made by a statist publication. Advocates of statism suffer the biggest fantasy of all. Not only do they believe a handful of people who know best must be given ultimate power over the ignorant (their word) masses but they believe that their advocacy of statism qualifies them to hold one of those positions of power.

Libertarianism is the belief that nobody is qualified to hold power over another. It is the antithesis of power fantasies. Statism teaches that a handful of people know what’s best for everybody else and that the best society can be achieved by giving those people a truncheon with which to smash anybody who disobeys in the face. On the opposite side of the spectrum is libertarianism, which teaches that the best society can be achieved by individuals peacefully cooperating with one another. Under libertarianism there is no heap on which the “strongest and most self-reliant” can sit. Libertarianism doesn’t get suckered into the claim that the “rules and regulations” are designed to help the weak. Instead libertarianism recognizes that individuals given ultimate power will use that power for personal gain.

Even advocates of statism admit that the, according to them, shitty world we live in today is actually the product of their own philosophy. Critics of libertarianism often submit the fact that there isn’t a pure libertarian society as proof that it’s unworkable. But they fail to recognized that such a claim also admits that all of today’s social ills; including the overwhelming power held by corporations, unaccountable police, and the preference of military invasion of mutually beneficial trade; are the products of statism. I’m always amused by the simultaneous claim that libertarian doesn’t exist and it’s at fault for the world’s social ills but I digress. Statists are correct in their admission because these social ills require positions of power to manifest. They require a heap on which the “strongest and most self-reliant” can sit. And that heap only exists in a society with coercive hierarchy, i.e. a state.

One can argue why there are more men than women in libertarianism, which is something it shares with other social and political philosophies, but claiming it’s because it fulfills power fantasies of men isn’t a valid argument.

The Only Solution for Marriage Equality

The problem with suffering under a state for the entirety of your life is that you become conditioned to seeing everything as a political solution. Take the issue of same-sex marriage. Same-sex marriage has been a political hot button issue in recent years. One side, the sane one, wants same-sex couples to enjoy the same privileges and heterosexual couples while the other side, the insane one that believes legislating morality is good policy, oppose the idea. The first side wants to legalize same-sex marriage whereas the other side wants to keep it illegal. Too few, due to conditioning instilled by a life under statism, ask the import question, why is the state involved in marriage at all?

Marriage, after all, is nothing more than voluntary association. Two or more people, sometimes under religious rules and sometimes not, decide they want to enter an agreement that typically involves sharing property and power of attorney. It seems that Alabama is the first state where this question was genuinely considered and it resulted in the abolition of marriage licenses:

Why are there marriage “licenses” – a permission slip granted or denied by the state – rather than just contracts like any other? Why does government stand in the position to veto the choices of two people who want to commit to each other?

These are questions that the Alabama Senate considered in May this year. The result was the passage of Senate Bill 377, supported by 22 senators and opposed by only 3. Under this legislation, licenses would no longer exist for marriage. Marriage would become a plain contract filed with the Probate offices.

In effect, this would restore the traditional role of law in marriage as it has existed in most times and places, before the racially motivated and eugenically inspired idea of “marriage licenses” came along in the early part of the 20th century.

Being a political solution I wouldn’t be surprised if something was inserted to fuck certain classes of people over (say polygamous groups) but it’s certainly a more sane solution than deciding whether certain forms of marriage should be legal or illegal.

Religious aspects of marriage, when applicable, should remain exclusively in the hands of the religious. The contractual aspects of marriage should remain in the hands of the individuals entering the arrangement and their representatives (and, if things fall apart, their chosen party to resolve the dispute). The idea that the state, which is the most immoral institution in the world, should be allowed to grant or refuse permission is ludicrous. How, exactly, is an organization build on theft, kidnapping, assault, and murder a good moral judge for deciding whether or not individuals can voluntarily enter a contractual arrangement? I’m glad everybody isn’t trapped in the legalize or prohibit mentality.

If You’re Not Paying for the Service You’re the Product

There ain’t no such thing as a free lunch (TANSTAAFL) is a phrase made famous by Heinlein’s The Moon is a Harsh Mistress. In the book the people who inhabit the moon periodically say “TANSTAAFL,” as a reminder that nothing comes for free. The Internet has become the biggest embodiment of this fact. Most Internet services are “free.” Gmail, Facebook, and Twitter are just a handful of examples of services that cost users nothing and are therefore advertised as free. Anybody who understands the concept behind TANSTAAFL knows that these services aren’t free. In fact if you’re not paying for a service then there’s a very good chance that you’re the product. Normally this means your personal information is sold to advertisers but sometimes an Internet company takes things to the next level. Hola, a virtual private networks (VPN) provider that offered its service for “free”, is an example of this:

Hola is easy-to-use browser plugin available in the Google Chrome Store with currently more than 6 Million downloads. But, unfortunately, Hola could be used by hackers to maliciously attack websites, potentially putting its users at risk of being involved in illegal or abusive activities.

Hola uses a peer-to-peer system to route users’ traffic. So, if you are in Denmark and wants to watch a show from America, you might be routed through America-based user’s Internet connections.

However, Hola is not leaving a chance to make money out of a free service. It has been selling access to users’ bandwidth for profit to a third-party service called Luminati, which then re-sells the connections, Hola founder Ofer Vilenski confirmed.

I would never trust a free service provider that required me to install special client software because of the threat of shit like this. Facebook and Twitter are limited in the damage they can do by the fact that their service doesn’t rely on local software (unless you use their apps on your mobile device). Neither service can, for example, sell your bandwidth. Hola, which relied on a Chrome plugin, could because it had software resident on its users’ systems. If somebody is offering a “free” service but requires the installation of special software just remember TANSTAAFL. Since it’s free you’re the product and with resident software on your system the service provider can offer its real customers a lot more than a mere web page can.