TechLaw

Sen. Durbin Proposes $15 Million in Grants for Open Textbook Creators

Last week Sen. Richard Durbin introduced a bill (S. 1714) that would create a $15 million federal grant program for "open textbooks." The bill is a further example of continuing federal government interest in openness, transparency, and using information-sharing technologies to promote social aims.

Sen. Durbin is promoting his bill as a means to drive down the price of college textbooks, but I think it is going to have more far-reaching consequences than that. If it passes.

The bill defines "open textbook" as "a textbook or set of course materials in electronic format designed for use in a college course at an institution of higher education that is licensed under an open license."

New works and updates to existing works would be eligible for grants.

The bill defines "open license" as "an irrevocable intellectual property license that grants the public the right to access, customize, and distribute a copyrighted material."

Any college, and professor or group of professors, any for-profit or non-profit organization may apply to the Secretary of Education for a grant to produce open textbooks. It will be interesting to see how this all plays out in the legal education market, particularly in the areas of cyberlaw and intellectual property law where feelings about openness run strong. A shot of federal grant money might be all it takes to spur the development of new teaching materials from law clinics at Harvard or Berkeley, or stimulate interest from an established, commercial technology law publisher like MIT Press.

Grant-eligible teaching materials must be both "free as in freedom" and "free as in beer." S. 1714 provides that the "full and complete digital content of each open textbook" must be "made available free of charge to, and may be downloaded, redistributed, changed, revised, or otherwise altered by, any member of the general public."

The message to entrepreneurs is this: If you'd like to take the big textbook publishers down, the federal government might be willing to lend a hand. The hard part will be making a buck in the process.

Minor Win for Bloggers in Fourth Circuit's GHF Ruling

En route to tossing out a $2.9 million jury verdict for invasion of privacy and intentional infliction of emotional distress against the author of a hateful screed at <godhatesfags.com>, the U.S. Court of Appeals for the Fourth Circuit slipped in a goodie for bloggers at footnote 13:

[W]e believe that the First Amendment protects nonmedia speech on matters of public concern that does not contain provably false factual assertions. Any effort to justify a media/nonmedia distinction rests on unstable ground, given the difficulty of defining with precision who belongs to the "media."

Similar statements rejecting a distinction, for First Amendment purposes, between official "media" and non-media speakers were made in Flamm v. Am. Ass'n of Univ. Women, 201 F.3d 144, 149 (2d Cir. 2000), and In re IBP Confidential Bus. Documents Litig., 797 F.2d 632, 642 (8th Cir. 1986), both of which the Fourth Circuit cited.

The case is Snyder v. Phelps, No. 08-1026 (4th Cir., Sept.24, 2009).

Selective Outrage in Rocky Mountain Bank Case

I am a little bit mystified at the expressions of shock and outrage (yes, "outrage") at the news that Judge Ware has granted Rocky Mountain Bank's request for a TRO deactivating a Gmail account to which the bank had carelessly e-mailed detailed financial information on 1,325 bank customers.

Apparently this development alarms the many people out there in cyberspace who have the same attachment to their e-mail accounts as the National Rifle Association does to firearms.

The victims here are the bank customers, whose personal information is now certainly residing on several Google servers and possibly countless other online locations. The reasoning in the bank's motion for a temporary restraining order and the declaration of its president strikes me as unassailable.  The bank has a duty to do what it can to safeguard the personal, financial information of its customers.

The bank's customers are presently at risk of identity theft. The bank's shareholders are at risk of seeing their investment wiped away by a nasty data breach incident. Inaction, not action, is what should provoke "outrage" in these circumstances.

Google is also doing the right thing, following its privacy policy and the Electronic Communications Privacy Act by insisting on a court order before turning over information about its users. Now it has just such an order. Google's lawyer, Al Gidari of Perkins Coie in Seattle, filed an appearance in the case this afternoon. In another case, Google offered only token opposition, see the "Skanks of NYC" ruling, a precedent that may be relevant here.

As for the owner of the Gmail account, who has not yet been identified and who did not respond to the bank's subsequent attempts to contact him or her via the Gmail account, it is very difficult to see what rights might have been infringed by the bank's action against the account. Speculation about whether computer users have First Amendment claims against private computer network operators is interesting but fanciful.

Here are three cases that say computer users have no First Amendment rights against network operators:

• Kinderstart.com v. Google Inc., No. 06-2057 (N.D. Cal., July 13, 2006) (Google has no First Amendment duty to protect free speech rights of websites it indexes);
• Howard v. America Online Inc., 208 F.3d 741 (9th Cir. 2000)(interactive computer network is not a common carrier under Communications Act, not a state actor for First Amendment purposes);
• Estavillo v. Sony Computer Entertainment, No. 09-3007 (N.D. Cal., Sept. 22, 2009)(Sony Playstation 3 Network owed no First Amendment duty to user terminated for allegedly violating terms of use).

I'm not aware of any cases going the other way, or cases remotely suggesting that the owner of the Gmail account at issue in the Rocky Mountain Bank case has been denied due process or any other constitutional or statutory right. Hey, he or she has already gotten more due process than you get at Twitter.

Venkat has more to say here.

The Legal Profession's Stake in Openness

The legal profession took some lumps at the recently concluded the Gov 2.0 Summit held here in Washington earlier this month.

For three days, social media thinkers, Silicon Valley entrepreneurs and yes even Beltway bureaucrats discussed how governments can fulfill their public service mission and provide new opportunities for economic growth by opening up the vast stores of data under their control to free public consumption. Two themes are at work in the Gov 2.0 space, a political theme and an innovation theme. First, there is the "the best disinfectant is the light of day" theme, which posits that public decisionmaking will produce the most democratic and enlightened public policy. See Sunlight Foundation and Gapminder for examples. Second, there is the "government as platform for innovation" theme, which asserts that government data is an untapped source of improved public service and an engine of economic growth. Sites like Apps for Democracy and Data.gov offer a glimpse of what is going on here. Government data on energy, health, and technology (possessed by the U.S. Patent and Trademark Office, for example) are believed to be fertile-yet-untapped sources of commercial exploitation.

Where Are the Lawyers?

Unfortunately, the legal profession was missing from the proceedings, convicted in absentia for being part of the problem instead of part of the solution.

Open records advocate Carl Malamud condemned the federal judiciary for foot-dragging (and worse) when it comes to making legal information available to the public. There was a populist tone to his remarks: the rich have good access to legal information and the poor do not. He's right about that, of course. He's also right to observe, as he did in By The People, that: "The fees for bulk legal data are a significant barrier to free enterprise, but an insurmountable barrier for the public interest." Malamud also dinged judges and lawyers for numerous privacy violations in publicly available PACER data.

Also speaking at the Gov 2.0 event was Stephen Schultze, a fellow at Harvard's Berkman Center for Internet & Society. Schultze spoke about his involvement with the RECAP project, an inspired bit of civil disobedience that liberates "free" court opinions from behind the federal court system's PACER paywall. Schultze is also the author of an illuminating paper on PACER fees and the federal judiciary's fitful implementation of Congress's 2002 command that judicial information be "freely available to the greatest extent possible."

And that was it as far as the legal profession's presence at this event. If Malamud is correct that law is the operating system of democracy, one might have expected to hear about all the great things lawyers and courts are doing to make the law more available and understandable to all.

I wonder: Why has the legal profession been so patient with the status quo? Why has the legal profession been content to pay the government $.08 per page for PDFs, a miserable data format, fit only for printing and consumption by human eyeballs? Or pay even higher prices to download equally crippled Microsoft Word docs from legal information vendors?

Lawyers, It's Time to Tag

The World Wide Web Consortium recently released a draft document, Publishing Open Government Data, setting out what it believes are best practices for the online distribution of government data. The W3C's main point was that government data should be both human-readable and machine-readable. As for machine-readability, the W3C paper recommended:

• enrich your existing (X)HTML resources with semantics, metadata, and identifiers;
• encode the data using open and industry standards - especially XML - or create your own standards based on your vocabulary;
• make your data human-readable by either converting to (X)HTML, or by using real-time transformations through CSS or XSLT;
• use permanent patterned and/or discoverable "Cool URIs";
• allow for electronic citations in the form of standardized (anchor/id links or XLINKs/XPointers) hyperlinks.

Wow. What would happen if every court and legislature released their output in a machine-readable, XML format, tagged with a standard document type declaration (DTD) written by the best minds in the legal profession? What if these documents were tagged with metadata such as legal subject-area, parties, attorneys, rules of law and cases cited, accessible via a public API and a permanent URI for each decision, statute, and regulation?

Sounds good to me.

I wish judges and lawyers and legislators would start attaching metadata (tags) to their work. Today. Computer programmers came though BNA over a decade ago with the news that our lovingly crafted editorial output was, in fact, merely data. That hurt a bit, but we got over it, we started tagging our work so it could be processed by computers, and our editorial work is better today because of it. The legal profession needs to get over it too. The law should be machine-readable.

If these changes came about there would be a veritable Renaissance in the legal profession. The price of legal information would fall, to the benefit of everyone in the system: judges, lawyers and their clients. New value-added information products would come to market, making the practice of law more efficient and effective, making the administration of justice more efficient, making the law more understandable to lawyers and the public, and making legal services affordable to a greater segment of the population. The supposed hegemony of the "Big Three" legal information providers would be shattered. They, along with everyone else, would have the opportunity to compete in a new and vibrant market for legal information services, for a piece of a new, bigger and better and more lucrative pie. My mind is pretty pedestrian, I'm not good at imagining the future. So I'm left with this: Imagine what sorts of products Google might produce if it had under its control a free legal database of the entirety of the world's legal output.

If these changes came about, legal information (raw data) would become simultaneously less expensive and more valuable. Legal knowledge, legal strategy -- the work of lawyers -- would become even more valuable. The work of judges would be more influential and more widely known. In pro football terms, my favorite source for metaphors, the rules of the game, the upcoming schedule, the raw statistics, and the names of the players on each team are easily discoverable for free. Yet, as far as I know, there is no online forum or wiki where football coaches share their favorite plays. This is a better world than the one we're in.

Not only is this the direction the legal profession should be heading, we should be there now.

More food for thought, and a lot of high-minded discussion, are available at the Gov 2.0 Summit website, where event organizers O'Reilly Media Inc. and TechWeb have generously made available many papers and videos.

Shout out to Gov 2.0 Summit organizer Tim O'Reilly, who says he is trying to replace the traditional notion of "government as vending machine" (taxes go in, services come out) with a more enlightened conception of government as platform for innovation. In fact, the federal government is a place where laws go in and money comes out. Hitch your Government 2.0 wagon to that mindset and you can't miss.

Before anybody calls me, these are strictly personal observations.

California Privacy Law Not Preempted by CAN-SPAM Act

In California, the Song-Beverly Credit Card Act forbids merchants from asking for "personal information" when a customer uses a credit card to make a purchase. Addresses and telephone numbers are clearly covered by Song-Beverly. Zip codes are not, per Party City Corp v. Superior Court, 169 Cal.App.4th 497 (Cal. Ct.App. 2008).

How about e-mail addresses? Are they "personal information" forbidden to be collected by Song-Beverly? And if e-mail addresses are regulated by Song-Beverly, then is this aspect of Song-Beverly preempted by the federal CAN-SPAM Act?

Yesterday, in the case of Powers v. Pottery Barn Inc., D054336 (Cal. Ct.App., Sept. 21, 2009), a California intermediate appellate court ruled that the CAN-SPAM Act does not preempt a cause of action alleging that Song-Beverly was violated when a merchant (Pottery Barn, in this case) asked for and received the plaintiff's e-mail address during the course of a credit card transaction. CAN-SPAM does not preempt state laws of general applicability that only incidentally regulate e-mail, the court said. "Because Song-Beverly's regulation of what may be asked of credit card customers is not a regulation of what can be sent in commercial e-mails and is not in any manner specific to e-mail, we conclude Song-Beverly is not pre-empted by CAN-SPAM."

So the plaintiff's lawsuit, which seeks class status, lives on. As for the preliminary question of whether e-mail addresses are in fact "personal information" under Song-Beverly, the court didn't make a conclusive ruling on this point. It said that the record wasn't sufficiently developed to decide the question, adding that the allegations in the complaint were sufficient to avoid summary dismissal of the case. So the parties are free to fight this one out in a future hearing.

This could be a close question. E-mail addresses are generally considered -- see HIPAA, COPPA, GLBA here and PIPEDA in Canada -- to be personal information; but ... one leading federal privacy proposal, H.R. 2221 (the DATA Act), excludes e-mail addresses from its definition of personal information. State-law definitions are all over the map. And of course Song-Beverly does not specifically include e-mail addresses within its definition of personal information because, as the court pointed out, California lawmakers did not have e-mail regulation in mind when they wrote the law.

Finally, the court turned back Pottery Barn's claim that Song-Beverly's restriction on its ability to collect customer e-mail addresses violates the First Amendment. The court acknowledged Pottery Barn's First Amendment right to collect e-mail addresses, but added that this right was overcome by the state's "well-established and substantial" interest in protecting the privacy of its citizens. Marketers have lately been asserting a First Amendment right to access commercially valuable data, though without much success so far. A recent example I blogged about was IMS Health Inc v. Ayotte, in which the First Circuit turned back a First Amendment challenge to a New Hampshire law banning the sale of prescription drug information that identifies doctors' prescribing patterns. The U.S. Supreme Court declined June 29 to review the case.

Googling Juror Prompts Court to Overturn Jury Verdict

A jury trial is a taxing experience for everyone concerned. Almost all of the court's resources are dedicated to a single matter, especially in small jurisdictions where justice is dispensed by a judge, a secretary, a court reporter and a bailiff. Lawyers for each side, who have already invested hundreds of hours of pretrial effort, devote all their time to the case, from sun-up to sundown, for as long as the trial lasts. And then there are the jurors, who put aside their jobs and family obligations in order to hear evidence and reach a decision on a matter they have no prior training or experience in.  It is an exhausting effort all around.

Sometimes these sacrifices are utterly wasted, as they were in a 2007 personal injury case against a seatbelt manufacturer in Rapid City, S.D. (population 60,000 and birthplace of noted cyberlaw thinker Lawrence Lessig, according to Wikipedia). The case was tried for 19 days, eventually leading to a verdict in favor of the manufacturer. Unfortunately, the verdict was overturned when it came to light after the trial that one of the jurors had performed Google searches on the seatbelt manufacturer after he received his jury summons in the mail. This particular juror did not disclose his googling to the attorneys when they asked him, before the trial commenced, in a general sort of way, whether he had any prior knowledge about the case or the parties that would affect his impartiality. This particular juror subsequently compounded his subversion of  the judicial process by revealing the outcome of his Google research to several other jurors during jury deliberations.

The trial judge granted the injury victim's request for a new trial due to the juror's misconduct and due to the fact that the jury was exposed to extrinsic evidence during deliberations. A few days ago, the South Dakota Supreme Court affirmed the trial judge, in Russo v. Takata Corp., No. 2009 S.D. 83 (S.D., Sept. 16, 2009). "Today we announce no hard and fast rule that all such types of internet research by a juror prior to trial without notice to the court and counsel automatically doom a jury's verdict," the court wrote. Nevertheless, it said, the trial judge's conclusion that a new trial was necessary was not an abuse of discretion.

It seems to me that the good people of Rapid City should immediately stop telling prospective jurors the names of the parties involved in the cases they might be asked to decide. Most jurisdictions don't divulge this information; and now Rapid City has learned an expensive lesson why not. It also seems to me that attorneys should voir dire prospective jurors specifically about their online activities. The internet, Google, Facebook (this juror is on Facebook if you want to friend him) et al are the very first places people go for information. Most folks think that information on the Internet is very reliable, though they won't admit it; certainly they think the Internet is more reliable than the courtroom assertions of legal counsel. I don't think the Internet was much on the legal system's radar screen in Rapid City, S.D. I bet it is now.

Ninth Circuit Declines to Read Common Law Loyalty Obligations Into CFAA

No language in the CFAA supports LVRC's argument that authorization to use a computer ceases when an employee resolves to use the computer contrary to the employer's interest.

And with that remark the Ninth Circuit today parted company with International Airport Centers LLC v. Citrin, 440 F.3d 418 (7th Cir. 2006), a Seventh Circuit decision holding that an employee's computer use becomes unauthorized under the Computer Fraud and Abuse Act, 18 U.S.C. 1030, when the employee uses the computer in a manner contrary to the employee's common law duty of loyalty to the employer.

The case involved an ex-employee who e-mailed allegedly confidential information from his work computer to his personal computer shortly before he left the company. A typical scenario. In today's opinion, LVRC Holdings LLC v. Brekka, No. 07-17116 (9th Cir., Sept. 15, 2009), the court firmly rejected Citrin, holding instead that computer access becomes unauthorized when an employee contravenes employer-placed limits on use of a computer. Computer use does not become unauthorized, the court said, at the point when an employee's mental state switches from "loyal employee" to "disloyal competitor."

There is work for lawyers to do in the wake of this opinion. The court specifically noted that the employer did not have an employment agreement with the employee nor did the employer have in place guidelines that prohibited employees from e-mailing company information to their personal computers. So the employer here missed two opportunities to define the scope of authorized computer use by its employees, either of which might have turned the case its way.

Domain Name Deemed Tangible Property (Web Pages Too) in Utah

There's a passage in T.S. Eliot's 1922 essay "The Perfect Critic" that goes like this:

The vast accumulations of knowledge -- or at least of information -- deposited by the nineteenth century have been responsible for an equally vast ignorance. When there is so much to be known, when there are so many fields of knowledge in which the same words are used with different meanings, when every one knows a little about a great many things, it becomes increasingly difficult for anyone to know whether he knows what he is talking about or not.

I feel like that a lot, especially when it comes to cyberlaw. There are so many fields of law, each with their own specialized but overlapping vocabularies, each attempting to advance their own policy objectives, some shaped by frequent contemporary debate, some resting undisturbed for decades, all being applied in a haphazard fashion to the internet. The internet is reportedly 40 years old this week, yet the legal profession's take on it is not yet out of beta.

Consider domain names and web pages, two basic components of the internet. What exactly are they, in the eyes of the law? No one can say for sure. The Virginia Supreme Court ruled in Network Solutions Inc. v. Umbro International Inc., 529 S.E. 2d 80 (Va. 2000), that a domain name was a mere contractual right under Virginia law, not a property right subject to garnishment. A few years later, a federal appellate court, Kremen v. Cohen, 325 F.3d 1035 (9th Cir. 2003), held that a domain name was intangible property, the wrongful disposal of which by another could constitute "conversion." Under California law.

As for web pages, the creative expression displayed on a web page is protected by the Copyright Act. Other theories like trade dress, patent, state-law misappropriation are speculative at best.

Into this void two very interesting opinions were recently dropped by federal courts located in Utah. The first one, Margae Inc. v. Clear Link Technologies LLC, No. 2:07-cv-916 (D. Utah, May 5, 2009), held that under Utah law web pages were tangible property subject to protection under Utah's conversion doctrine. To reach this conclusion that court looked to a Utah tax law decision and the court's own sense of what a web page is like:

[A] web page has a physical presence on [a] computer drive, causes tangible effects on computers, and can be perceived by the senses. ... Further, Web pages can be physically restricted by the use of passwords and other security measures. In fact, the "conversion" alleged here is that Clear Link has "locked out" Margae's access to web pages.

Last month, in Jubber v. Search Market Direct Inc., No. 06-2299 (Bankr. D. Utah, Aug. 19, 2009), a bankruptcy case, the court said that domain names -- just like web pages -- are tangible property:

Based on the reasoning in Margae, which the Court elects to follow, the Court determines that like web pages and software, domain names can be perceived by the senses and access to them can be physically restricted by the use of passwords and other security measures. ... [The] Court concludes that like web pages and software, the Domain Name at issue is a type of tangible property that is capable of conversion.

(It was important for the court to find that domain names and web pages are tangible property, because under Utah's formulation of the conversion doctrine, intangible property cannot be converted.) I haven't given much thought (save for skepticism) to the implications of these rulings, other than to note that they seem relevant only to situations in which a party has lost control of a website -- either by loss of access to the server or by transfer of the domain name registration. These folks already had computer fraud and business tort remedies, and presumably contract remedies; now they have a property law claim as well. At least in Utah and California.

Clearly Disclosed Terms Save Marketer From Deceptive Contracting Claims

For me, the moment of maximum vigilance in an online purchase occurs when the seller asks for my credit card number. I suspect it is the same for everyone. The act of supplying this very important number is the digital equivalent of a handshake. We like the goods, we like the terms, so we supply our credit card number and click "OK" or "Charge this amount" or something similar. We do it all the time.

Another thing we do all the time is abandon offers for services that are "Free" for a limited time if the seller requests a credit card number, presumably to secure payment after the promotional period expires. Free? Great. You want my credit card? Forget it.

But we are promiscuous with our e-mail addresses. Most people I know have several, at least one dedicated to catching promotional or non-essential material, and they have a lot of faith in their spam filters. The provision of an e-mail address is frequently the price paid for receiving an e-book or some other free information good. We give our e-mail address out all the time. We don't attach much significance to it.

These are the thinking-without-thinking processes that Malcolm Gladwell wrote about in Blink: the extent to which decision-making is guided by subconscious, non-rational mechanisms. Supplying a credit card number means "Charge my account and send me the goods." Supplying an e-mail address means "Send me some e-mail," a significantly more casual transaction.

What if supplying an e-mail address could mean "Charge my account"? From a marketing perspective, that would be genius, right? But would it be lawful?

The answer, according to In re VistaPrint Corp. Marketing and Sales Practices Litigation, No. 4:08-md-1994 (S.D. Tex., Aug. 31, 2009), is yes. The court's decision demonstrates how a business can exploit human psychology and play tough with the consumer in an entirely fair and lawful manner.

VistaPrint sold business cards from its website. VistaPrint collected the buyer's credit card information at the point of sale. Following the sale, VistaPrint displayed additional web pages inviting the purchaser to "save" $10 on the just-completed transaction by enrolling in an affiliate marketing program that was free for the first 30 days. After 30 days, the purchaser's credit card would be charged $14.95 each month, unless the purchaser had cancelled the program.

Interested purchasers were asked to accept the invitation not by supplying their credit card information again but by entering their e-mail address and clicking on a "Yes" button indicating that they had read through and agreed to the terms of the offer. VistaPrint's web page indicated that the purchaser's e-mail address would "constitute [an] electronic signature."

The plaintiffs in this case -- a group of purchasers who supplied their e-mail addresses, clicked "Yes" on the acceptance screen, and subsequently neglected to cancel the program after 30 days had expired, thus incurring the monthly $14.95 charge -- first argued that the signup process was unlawfully deceptive. But the court rejected this argument, finding that VistaPrint had clearly and conspicuously explained the terms of the offer to the plaintiffs before inviting them to click "Yes."

According to the court: "This language is clear and easily understandable by anyone capable of making an online purchase of business cards."

The plaintiffs also contended that the monthly charges were "unauthorized" under the Electronic Funds Transfer Act, 15 U.S.C. 1693 et seq.  Not so, the court said. The EFTA excludes "any electronic fund transfer ... initiated by a person other than the consumer who was furnished with the card, code, or other means of access to such consumer's account by such consumer, unless the consumer has notified the financial institution involved that transfers by such person are no longer authorized." Here, the plaintiffs furnished VistaPrint with their credit card numbers when they purchased the business cards. And they later authorized VistaPrint to charge their account according to the terms of an offer that was clearly spelled out on the web page. "Plaintiffs typed their e-mail addresses into the spaces provided on Defendants' webpages, thereby authorizing Defendants to 'charge/debit [their] account according to the Offer Details,'" the court wrote.

It is hard to fault the court's legal reasoning on either the contracting or the EFTA points. Unlike other cases in which the purchaser was required to click a hyperlink to read important contract terms, a practice very recently found to be non-deceptive, VistaPrint conspicuously displayed the terms of its offer on the same page where it asked for the purchaser's e-mail address and assenting click. And nothing in the EFTA requires the purchaser's act of furnishing account information to be contemporaneous with his or her authorization to charge/debit the account.

Still, I wonder why VistaPrint asked for the purchaser's e-mail address as a means of assenting to its offer. After all, they already had this information and it does not appear that the e-mail address was used to authenticate the purchaser. Strictly as a matter of contract law, all VistaPrint needed was a mouseclick to seal the deal. Is it possible that asking for an e-mail address somehow minimizes in the purchaser's mind the significance of the click? Or distracts the purchaser from the rest of the language on the page? I honestly don't know the answer to these questions. This is sort of a flight of fancy, I admit, but there must be some reason for asking for the e-mail address. I wish I knew what it was.

p.s Yes, I know about Amazon.com 1-Click. Same general sort of deal though 1-Click is a convenience. VistaPrint is offering to pay $10 on the chance that the consumer will forget about that first $14.95 payment 30 days later.

Zulu Nation's Stirring Bid for Cyber-Homeland Opposed by Celebrity Chef's Wife

"During the ICANN meeting in Sydney, Australia, Gelila Puck shouted within earshot of dozens of ICANN participants, that Minds+Machines should not proceed with its application for <.ZULU>, which had already been approved by the King of the Zulu nation with assistance of the daughter of the President of the Republic of South Africa."

From complaint in Mind+Machines LLC v. Puck, No. 09-1237 (W.D. Wash., complaint filed Sept. 1, 2009). Details at Domain Name Wire, "Wolfgang Puck Starts .Food Fight Over Top Level Domain."