INTERNET-DRAFT N. Elkins Intended Status: Informational EDCO B. Shein Software Tool and Die V. Bertola Open-Exchange Expires: April 20, 2019 October 17, 2018 Human Rights Considerations of Internet Filtering draft-elkins-hrpc-ifilter-00 Abstract This document is a survey of the filtering of content. The focus is on the human rights involved as cited in the Universal Declaration of Human Rights" which is one of the foundational documents for HRPC. The recent years have seen an increase in content filtering for a variety of reasons including to further the aims of governments who wish to maintain their rule and suppress dissent but also to enforce cultural norms, human rights and compliance with the law. Filters also exist for security (botnets, malware etc.), user-defined policies (parental control, corporate blocking of social networks during work time, etc.), spam control, upload of copyrighted material and other reasons. This document is based on several real world considerations: the existence of national and regional sovereignty, Internet Service Providers (ISPs) and Content Distribution Networks (CDNs) that provide connectivity and content hosting services, Over- the-top (OTTs) and Content Delivery Platforms (CDPs) that play a disproportionate role in capturing the attention and "eyeballs" of many of the users of the Internet. Status of this Memo This Internet-Draft is submitted to IETF in full conformance with the provisions of BCP 78 and BCP 79. Internet-Drafts are working documents of the Internet Engineering Task Force (IETF), its areas, and its working groups. Note that other groups may also distribute working documents as Internet-Drafts. Internet-Drafts are draft documents valid for a maximum of six months and may be updated, replaced, or obsoleted by other documents at any time. It is inappropriate to use Internet-Drafts as reference material or to cite them other than as "work in progress." Elkins Expires April 20, 2019 [Page 1] INTERNET DRAFT ifilter October 17, 2018 The list of current Internet-Drafts can be accessed at http://www.ietf.org/1id-abstracts.html The list of Internet-Draft Shadow Directories can be accessed at http://www.ietf.org/shadow.html Copyright and License Notice Copyright (c) 2018 IETF Trust and the persons identified as the document authors. All rights reserved. This document is subject to BCP 78 and the IETF Trust's Legal Provisions Relating to IETF Documents (http://trustee.ietf.org/license-info) in effect on the date of publication of this document. Please review these documents carefully, as they describe your rights and restrictions with respect to this document. 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Elkins Expires April 20, 2019 [Page 2] INTERNET DRAFT ifilter October 17, 2018 Table of Contents 1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . 4 2 Content Filtering by States and Public Authorities . . . . . . . 5 2.1 Filtering to Prevent Freedom of Assembly or Information . . 6 2.2 Filtering to Enforce Cultural Norms . . . . . . . . . . . . 6 2.3 Filtering to Prevent Violence . . . . . . . . . . . . . . . 7 2.4 Child Pornography . . . . . . . . . . . . . . . . . . . . . 7 2.5 Unauthorized Gambling and Illegal E-Commerce . . . . . . . . 7 2.6 User Generated Content (UGC) . . . . . . . . . . . . . . . . 8 3 Content Filtering by Internet Service Providers . . . . . . . . 8 3.1 Filtering for Network and Computer Security . . . . . . . . 9 3.2 Filtering on Behalf of the User . . . . . . . . . . . . . . 9 3.3 Filtering for Commercial Reasons . . . . . . . . . . . . . . 10 4 Content Filtering by Platforms Providing Content and Services . 10 4.1 Enforcing Cultural Norms . . . . . . . . . . . . . . . . . . 11 4.2 Blocking Extremist Activity . . . . . . . . . . . . . . . . 12 4.3 Blocking Activity Inciting Violence . . . . . . . . . . . . 13 4.4 Copyright Protection . . . . . . . . . . . . . . . . . . . . 13 4.5 Filtering for Network and Computer Security . . . . . . . . 14 4.6 Content Filtering by End-Users . . . . . . . . . . . . . . . 14 5 Security Considerations . . . . . . . . . . . . . . . . . . . . 14 6 IANA Considerations . . . . . . . . . . . . . . . . . . . . . . 14 6 References . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 6.1 Normative References . . . . . . . . . . . . . . . . . . . . 15 6.2 Informative References . . . . . . . . . . . . . . . . . . . 15 Authors' Addresses . . . . . . . . . . . . . . . . . . . . . . . . 16 Elkins Expires April 20, 2019 [Page 3] INTERNET DRAFT ifilter October 17, 2018 1 Introduction This document explores the use cases and history of filtering of content at a protocol and category level, grouping them by type of entity. The focus is on the human rights involved as cited in the Universal Declaration of Human Rights" [UDHR] which is one of the foundational documents for HRPC. However, any case of content blocking has an impact on online expression, thus the document tries to provide a complete picture of all the reasons and mechanisms that lead to the filtering and removal of content from the Internet. The recent years have seen an increase in content filtering by for a variety of reasons. States, through different legal instruments and public authorities, require the blocking of Internet content with different aims; undemocratic governments may wish to maintain their rule and suppress dissent, but also democratic governments use blocking to enforce cultural norms, human rights and compliance with the law . Filters are also widely used by network operators and Internet access providers for security (stopping botnets, malware etc.), to implement user-defined policies (parental control, corporate blocking of social networks during work time, etc.), to reject spam and for other reasons. Over-the-top (OTTs) [WikiOTT] and Content Delivery Platforms (CDPs) - providers like Facebook, Google (YouTube), and Twitter that distribute streaming media or other content and services as a standalone product directly over the Internet, bypassing telecommunications and connectivity providers - implement filters to prevent the upload of copyrighted material or other content that infringes their policies; in some countries, such filters are mandated by law. End users also want to apply content filters or content classification schemes at the edge of the network, for example, to protect underage users of the local network or to prevent the risk of reaching dangerous and inappropriate websites by error. While filtering usually attracts the highest attention, there are other ways to discriminate content that could be employed, leading to similar results. For example, an access provider may isolate the traffic directed to a specific website or service and slow it down, or apply additional fees for it, up to the point where users desist trying to connect to that destination. Content tagging can also constitute a weaker content discrimination system; even if the content remains accessible, marking it as dangerous or unsafe with prominent advance warnings will discourage users from accessing it. Some call all content filtering "censorship". For example, the Internet Draft [Censorship] defines blocking of content as: "Censorship is where an entity in a position of power - such as a Elkins Expires April 20, 2019 [Page 4] INTERNET DRAFT ifilter October 17, 2018 government, organization, or individual - suppresses communication that it considers objectionable, harmful, sensitive, politically incorrect or inconvenient. (Although censors that engage in censorship must do so through legal, military, or other means, this document focuses largely on technical mechanisms used to achieve network censorship.)" We find the use of the word "censorship" in this context to have purely negative connotations. That is, the implication of using the word "censorship" implies that filtering of content is always "bad" or as acting against important human rights. The reality of the situation is that filtering of content is done for many reasons, including several which may be regarded as "good": acting to preserve human rights either directly, when hateful and violent content is removed, or, in the case of security filters, indirectly, by providing safer Internet access that can encourage users to spend more time and energies online and enjoy all the deriving opportunities for education, free speech and assembly. All in all, a balancing of rights is often at stake, and the right to free expression of a content creator is not the only right that has to be considered and protected. We thus feel that the entire subject needs a more nuanced and careful examination, trying to establish principles, guidelines and technical protocols that can increase transparency and user control over these practices, allowing users to distinguish between the bad and the good uses of content classification and filtering schemes. 2 Content Filtering by States and Public Authorities States may filter content through several legal instruments and by order of different public authorities. In democratic countries, cases of content blocking are usually defined by a law and justified by an appropriate balancing of rights (see section 2.2) and needs/benefits. Depending on the country, the law may delegate to a specific public authority - either independent, or part of the government - the power to order blocking of websites and other content, or such power may be deferred to court orders following due legal process. In authoritarian countries, such legal basis and processes are often missing, and the blocking is more focused on protecting the authority of the ruler (see section 2.1). In technical terms, the filtering can either be applied at the IP address level, via firewall rules or routing alterations, or at the DNS level, by altering the results of the queries for the blocked names. The latter method is more precise, avoiding to block all other websites and services hosted on the same IP address, but is also Elkins Expires April 20, 2019 [Page 5] INTERNET DRAFT ifilter October 17, 2018 easier to circumvent for end users; thus, democratic countries usually prefer the latter method while undemocratic ones generally prefer the former. The procedure to apply the filters usually involves the appropriate public authority sending a list of the blocked IP addresses and/or DNS names to all the country's Internet access providers, requiring them to implement it on their routers and/or DNS resolvers. Providers not complying with these requests usually are subject to fines, to the cancellation of their license to operate (in countries where such license exists) or even to the penal prosecution of their legally responsible managers. 2.1 Filtering to Prevent Freedom of Assembly or Information What is sometimes informally called "censorship", has to do with the action of some governments to block websites that promote dissent and counter-information and organize protest actions and assemblies to contest the government, or even platforms such as Facebook or Twitter which might enable dissidents to organize protests. Other filtering is done to suppress knowledge of people who participated in protest movements being harassed, jailed or even killed. Some governments actually shut down the Internet altogether to prevent any witnesses to unfortunate activities. These activities may all be regarded as acting against basic human rights in [UDHR]. 2.2 Filtering to Enforce Cultural Norms Some filtering is done via legislation to enforce cultural norms, such as blocking sites which promote totalitarian and violent ideologies or falsify history and news in ways that attack and endanger certain parts of society. For example, in several countries the advocacy of totalitarian regimes such as nazi-fascism and communism, or of racist ideas and practices against religious or ethnic minorities (Holocaust denial, racism against people of African origin, etc.), is forbidden by law. While websites located inside the country can be physically taken down, the groups promoting these ideas often use anonymous hosting services in foreign countries, thus making blocking the access at the Internet provider level the only instrument available to these countries to enforce these laws. Elkins Expires April 20, 2019 [Page 6] INTERNET DRAFT ifilter October 17, 2018 In the general balancing of rights, this type of content - which may be seen as disinformation, and is generally used to promote undemocratic practices and discrimination against specific minorities and ethnic groups - is often considered extremely harmful to the safety and rights of the affected minorities and to democracy and public order in general, up to the point of overcoming the free speech rights of the content authors. This kind of rights balancing also depends on cultural norms, with countries such as the United States giving priority to the free speech rights even of hateful authors, and countries in Europe and Asia giving priority to the general safety and social peace. Thus, the related filtering practices have to be applied by country, depending on the nationality of the end user and on the applicability of jurisdiction. 2.3 Filtering to Prevent Violence As an extension of the previous case, filtering often also applies to content inciting violence and promoting terrorism, or making violence easier. Its objective is to protect the right to safety of the general population. The EU wishes to fine Facebook, Google, etc. for problematic content. [BBCTECH] reads in part: "If authorities flag content that incites and advocates extremism, the content must be removed from the web within an hour, the proposal from the EU's lead civil servant states. Net firms that fail to comply would face fines of up to 4% of their annual global turnover." In the United States, a federal court has issued a temporary injunction against publishing plans for 3-d printed guns on the Internet. 2.4 Child Pornography Another type of content which is often blocked is child pornography, as a way to discourage the exploitation of children for sexual reasons and protect their safety. [Child-Porn] A number of countries will obtain the IP addresses of visitors to child pornography sites. They will attempt to tie these IP addresses to actual human beings so that they can be prosecuted. 2.5 Unauthorized Gambling and Illegal E-Commerce Elkins Expires April 20, 2019 [Page 7] INTERNET DRAFT ifilter October 17, 2018 In most countries, certain services are regulated and thus a license, often connected to the payment of specific taxes and fees, is required before being allowed to offer them online. While there may also be an economic motivation to this, such regulation is generally justified as protecting the safety and health of the population. Among the most commonly regulated businesses are: - Gambling - Weapons - Medical products and drugs requiring a doctor's prescription - Alcohol - Cigarettes and tobacco Some countries - for example Italy [ITALY-REG] - use content filtering to prevent access to websites offering these products for sale without meeting the country's regulation and/or without having paid the appropriate taxes and fees 2.6 User Generated Content (UGC) Legislation to attempt to ensure that User Generated Content (UGC) does not violate copyright laws has been proposed. [EUCOPY] The summary is: " Tech giants must pay for work of artists and journalists which they use Small and micro platforms excluded from directive's scope Hyperlinks, "accompanied by "individual words" can be shared freely Journalists must get a share of any copyright-related remuneration obtained by their publishing house" 3 Content Filtering by Internet Service Providers Internet Service Providers (ISPs) provide access to the Internet to the general public. As such, they are usually required to apply any State-mandated filters, depending on the applicable jurisdiction, as described in section 2. However, there are additional cases in which ISPs implement filtering, or weaker content discrimination methods, on their own - they will be described in this section. Elkins Expires April 20, 2019 [Page 8] INTERNET DRAFT ifilter October 17, 2018 3.1 Filtering for Network and Computer Security Most of the common threats to the security of the Internet, both in terms of network security and of security of the end users and of their devices, are based on connections to unsafe websites and services - either services that have been designed for malicious purposes since the beginning, or legitimate services that have been cracked and infected with malicious software. For example, phishing relies on leading the user's browser to a forgery of the website of one of the user's suppliers, like his bank or her utility provider. Malware, such as ransomware and viruses, is commonly spread by connecting the user's browser to an infected website that downloads the executable to his device and launches it. Botnets rely on stable connections between the clients on user devices (often millions of them) and one or more "command and control" hosts which move over time. To counter these attacks and protect their users and their network, ISPs often acquire timely lists of malicious hosts from specialized providers and make them inaccessible by filtering them at the connection level, either by IP address or by DNS name. This practice is becoming even more common and more useful as the so- called Internet of Things (IoT) gains adoption. IoT devices usually are strongly automated but have very little computing power, security features and update capabilities, making them very vulnerable to exploits and takeovers. Thus, protecting the home network rather than the individual device becomes the most viable solution for the security of the Internet. 3.2 Filtering on Behalf of the User In some cases, the end users actually desire that some content is filtered out and made inaccessible, so that they cannot reach it even by mistake. Three common cases are: -Security filters: The user explicitly asks the ISP to filter out malicious websites, as per the previous section. -Parental control filters: From [UK-Controls] The user asks the ISP to block content which is not deemed safe for children. This block is usually customizable by each user, depending on their own desires, and is requested by families with children accessing the Internet from their home network. In some countries, the provision of this service by the ISPs is either mandated by law or required by industry self-regulation efforts. Elkins Expires April 20, 2019 [Page 9] INTERNET DRAFT ifilter October 17, 2018 -Productivity filters: The user - typically a corporate network administrator - asks the ISP to block content which is inappropriate or disallowed on the workplace, as it would endanger the corporate network or reduce productivity. This content usually includes social networks, sports and leisure websites, etc. These filters can be provided for free, included in the Internet access service, or can constitute a specific additional service requiring opt-in and the payment of an additional fee. Services of this type are commonly available in several European countries, often with millions of customers. 3.3 Filtering for Commercial Reasons Some ISPs provide limited Internet access services that only allow access to specific types of applications (instant messaging, for example) or do not include access to specific types of applications (video streaming, for example). In these cases, connections to the disallowed content are blocked or slowed down significantly. This kind of filtering could also depend on specific partnerships - for example, an ISP may encourage its users to use a specific search engine by slowing down the connections to the other ones, in exchange for monetary compensation by the preferred search engine. Due to concerns over the market and competition impact of these practices, including potential limitations of user rights, they have been made illegal in some countries, upholding the so-called "network neutrality" principle. 4 Content Filtering by Platforms Providing Content and Services In addition to filters at the edge of the Internet, enforced by ISPs either on behalf of the State or on their own, those that manage the content and its delivery inside the network filter content as well. Again, this may happen because of their decisions, or because these companies are incorporated to do business under the laws of one or more nation-states, and therefore are subject to the regulations of such nation-states. This kind of filtering happens under several forms. For over-the-top and content delivery platforms (OTTs/CDPs), content may be examined and blocked, often automatically, when the user uploads it onto the platform, or may be verified and removed following a request by other users or after a court order. In some cases, for example in search engine results, the content will not be blocked, but will be marked as unsafe with a prominent warning discouraging the user to proceed with the connection, or will not be shown unless the user disables the default "safe" mode. Elkins Expires April 20, 2019 [Page 10] INTERNET DRAFT ifilter October 17, 2018 Many of these platforms also employ policies that lead to the exclusion of a user from the platform after a certain number of breaches to acceptable content guidelines, thus silencing the user permanently (though users may try to open a new account, but losing all their existing followers and connections). Content Delivery Networks (CDNs) and hosting providers also have the option of taking websites down entirely by shutting down their web service (see section 4.4 for an example). Similarly, domain name registries and registrars may make content temporarily inaccessible by discontinuing the domain name registration for the hostname used in URLs, though, differently from CDNs and OTTs, they cannot actually remove the content from the Internet. While some of these filters depend on applicable laws, in most cases the content guidelines are self-imposed, and may err on the side of content restrictions to reduce the legal risk for the platform, at the cost of reducing the user's chances to speak. In some cases these filters are managed by algorithms and artificial intelligence applications, making it hard for the user to even understand why the content has been blocked; often, no explanation and appeal mechanism is provided, or the appeal is untimely and ineffective. Even when laws apply, given the global nature of these platforms, the applicable laws are often not those of the user's own country, and it is almost impossible for the user to exert any legal rights or request due judiciary process. Additionally, the more the specific service is globally consolidated in the hands of a few big competing players and the more these filters become impactful; particularly in the case of OTT social networks, the termination of an account often cannot be adequately replaced by a new account on any competing service or even on the same one. Some examples of similar situations follow. 4.1 Enforcing Cultural Norms The article from the Guardian [FBNorms] expresses the thoughts of the authors so well that we will be citing a lengthy passage. From [FBNorms]: "Facebook allows people to live-stream their suicide attempts "as long as they are engaging with viewers" but will remove footage "once there's no longer an opportunity to help the person". Pledges to kill oneself through hashtags or emoticons or those that specify a fixed Elkins Expires April 20, 2019 [Page 11] INTERNET DRAFT ifilter October 17, 2018 date "more than five days" in the future shouldn't be treated as a high priority. These are tiny snippets from a cache of training materials that Facebook content moderators need to absorb, in just two weeks, before policing the world's largest social network. The guidelines also require moderators to learn the names and faces of more than 600 terrorist leaders, decide when a beheading video is newsworthy or celebratory, and allow Holocaust denial in all but four of the 16 countries where it's illegal - those where Facebook risks being sued or blocked for flouting local law. The documents detail what is and is not permitted on the platform, covering graphic violence, bullying, hate speech, sexual content, terrorism and self-harm. For the first time the public has a glimpse of the thought process behind some of the company's editorial judgements that go beyond the vague wording of its community standards or statements made in the wake of a live-streamed murder." The article goes on to posit that this may be the "most important editorial guide sheet the world has ever created". This use case brings up an issue which we may wish to consider. That is, there is no reason that Facebook, as a private company, needs to share with anyone what its methodology is for filtering. However, considering the enormous impact of Facebook, it is in the public interest to know the methodology. In short, Facebook may be considered a public utility. 4.2 Blocking Extremist Activity From [BBCTECH], some of the content providers on the Internet are acting to censor content pertaining to potential extremist activity "In 2017, Google said it would dedicate more than 10,000 staff to rooting out violent extremist content on YouTube YouTube said staff had viewed nearly two million videos for violent extremism from June to December 2017 YouTube said more than 98% of such material was flagged automatically, with more than 50% of the videos removed having fewer than 10 views Industry members have worked together since 2015 to create a database of "digital fingerprints" of previously identified content to better Elkins Expires April 20, 2019 [Page 12] INTERNET DRAFT ifilter October 17, 2018 detect extremist material. As of December 2017, it contained more than 40,000 such "hashes" In 2017, Facebook claimed that 99% of all Islamic State and al Qaeda- related content was removed before users had flagged it. The social network said that 83% of the remaining content was identified and removed within an hour Between August 2015 and December 2017, Twitter said that it had suspended more than 1.2 million accounts in its fight to stop the spread of extremist propaganda. It said that 93% were flagged by internal tools, with 74% suspended before their first tweet." 4.3 Blocking Activity Inciting Violence [Myanmar] The United Nations report on the genocide of Rohingya muslims ties it to posts on Facebook. Apparently, the Facebook content provider had very few people who could read Burmese. So, posts were not reviewed. The posts by the Myanmar military, intended to incite violence, indeed did so. There was wholesale killing of Rohingya muslims. Facebook is now censoring such posts and has hired many Burmese speakers. [DailyStormer] In August 2017 Cloudflare, one of the leading global CDNs, terminated the account of the Daily Stormer, a website advocating white supremacy and antisemitism, thus removing the website from the Internet. At the same time, several domain name registrars (GoDaddy, Tucows, Namecheap) discontinued the domain names used by the website. In the end, the website became accessible again by finding registries, registrars and hosters that would accept it, but in practice it was made almost unavailable for several weeks. 4.4 Copyright Protection Another reason for content filtering by OTTs, CDNs and hosting services is copyright protection. This has become a particularly active area since the EU adopted its digital copyright rules negotiating position (i.e., still in early stages) on 2018-09-12. Such rules will require all online platforms to implement automated content control at upload and screen the content for copyrighted material. [EU-DIGCOPY] We may wish to study how the music industry has evolved copyright protection over the past 100+ years in the US and elsewhere. Elkins Expires April 20, 2019 [Page 13] INTERNET DRAFT ifilter October 17, 2018 In brief (US) they rely on designated third-party agencies (such as BMI, ASCAP, Harry J Fox) to provide licensing and collect royalties and distribute those back to copyright owners. Statutory fees were set by the US congress. Private agreements are also possible, and common, of course. The music industry has developed a sophisticated ecosystem and rather than rely first on threats of criminal prosecution (which is possible in extreme cases) instead tries to convert as much of the problem as possible into civil claims (you used my work, you owe me money!). This is in stark contrast to the EU directive which approaches the problem via fines etc. and seems to create none of that infrastructure. 4.5 Filtering for Network and Computer Security Like ISPs, OTTs and CDNs also try to keep the network secure by making malicious or infected websites inaccessible. Search engines will mark results as unsafe; online platforms will disable links; hosting services and CDNs will terminate the web service. Some of the considerations in section 3.1 also apply here. However, effective filtering measures at the Internet access point fully protect the end user. To obtain the same effectiveness by acting at the core of the network, all the OTTs, hosting services and CDNs of the planet should be effective at taking down malicious content in a timely manner. Currently, this effectiveness varies; even a few "rogue" players being uncooperative to abuse and security takedown requests are enough to provide safe havens for attackers. 4.6 Content Filtering by End-Users Finally, the users themselves may want to block or mark content for several reasons. The content filtering types and purposes are the same described in section 3.2, but rather than relying on the ISP's infrastructure, they deploy appropriate software on their devices. This also includes user-controlled content classification mechanisms that avoid blocking content entirely, but still allow end users to preselect what they want to see or to miss on the Internet. 5 Security Considerations No new security vulnerabilities are introduced as a result of this document. 6 IANA Considerations Elkins Expires April 20, 2019 [Page 14] INTERNET DRAFT ifilter October 17, 2018 No IANA actions are requested by this document. 6 References 6.1 Normative References 6.2 Informative References [Censorship] Hall, J., Aaron, M., Jones, B., Feamster, N., "A Survey of Worldwide Censorship Techniques", https://tools.ietf.org/html/draft-hall-censorship-tech-05, May 2018, Work-in-progress [BBCTECH] https://www.bbc.com/news/technology-45495544, Sept. 2018 [EU-DIGCOPY] http://www.europarl.europa.eu/news/en/press- room/20180906IPR12103/parliament-adopts-its-position-on-digital- copyright-rules, Sept. 2018 [FBNorms] https://www.theguardian.com/news/2017/may/22/facebook- moderator-guidelines-extreme-content-analysis, May 2017 [Myanmar] https://www.theguardian.com/technology/2018/aug/27/facebook-removes- accounts-myanmar-military-un-report-genocide-rohingya, August 2018 [Child-Porn] https://gizmodo.com/fbis-disturbing-hacking-powers- challenged-in-court-over-1794885187, May 2017 [UDHR] United Nations, "Universal Declaration of Human Rights", 1948, [EUCOPY] http://www.europarl.europa.eu/news/en/press- room/20180906IPR12103/parliament-adopts-its-position-on-digital- copyright-rules, September 2018 [ITALY-REG] https://www.adm.gov.it/portale/lagenzia/monopoli- comunica/contrasto-illegalita, January 2007 [UK-Controls] https://www.ispreview.co.uk/index.php/2017/10/uk-gov- softens-stance-mandatory-isp-filters-adult-internet-content.html, October 2017 [DailyStormer] Prince, M., "Why We Terminated Daily Stormer", https://blog.cloudflare.com/why-we-terminated-daily-stormer/, August 2017 Elkins Expires April 20, 2019 [Page 15] INTERNET DRAFT ifilter October 17, 2018 [WikiOTT] WikiPedia, "Over-the-top media services", https://en.wikipedia.org/wiki/Over-the-top_media_services, October 2018 Authors' Addresses Nalini Elkins Enterprise Data Center Operators (EDCO) EMail: nalini.elkins@e-dco.com Barry Shein Software Tool and Die EMail: bzs@theworld.com Vittorio Bertola Open Exchange EMail: vittorio.bertola@open-xchange.com Elkins Expires April 20, 2019 [Page 16]