USDC
Opinion: Elsevier against SciHub and LibGen
2015


UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
----------------------------------------

15 Civ. 4282(RWS)
OPINION

ELSEVIER INC., ELSEVIER B.V., and ELSEVIER LTD.,

Plaintiffs,

- against -

WWW.SCI-HUB.ORG, THE LIBRARY GENESIS PROJECT, d/b/a LIBGEN.ORG, ALEXANDRA ELBAKYAN, and JOHN DOES 1-99,

Defendants.

----------------------------------------

APPEARANCES

Attorneys for the Plaintiffs

DEVORE & DEMARCO LLP
99 Park Avenue, Suite 1100
New York, NY 1001 6
By:
Joseph DeMarco, Esq.
David Hirschberg, Esq.
Urvashi Sen, Esq.

Pro Se

Alexandra Elbakyan
Almaty, Kazakhstan

1

Sweet, D.J.,

Plaintiffs Elsevier Inc., Elsevier B.V., and Elsevier, Ltd. (collectively, "Elsevier" or the "Plaintiffs") have moved for a preliminary injunction preventing defendants Sci-Hub, Library Genesis Project (the " Project"), Alexandra Elbakyan ("Elbakyan"), Bookfi.org, Elibgen.org, Erestroresollege.org, and Libgen.info (collectively, the "Defendants") from distributing works to which Elsevier owns the copyright. Based upon the facts and conclusions below, the motion is granted and the Defendants are prohibited from distributing the Plaintiffs' copyrighted works.

Prior Proceedings

Elsevier, a major publisher of scientific journal articles and book chapters, brought this action on June 2, 2015, alleging that the Defendants, a series of websites affiliated with the Project (the "Website Defendants") and their owner and operator, Alexandra Elbakyan, infringed Elsevier's copyrighted works and violated the Computer Fraud and Abuse Act. (See generally Complaint, Dkt. No. 1.) Elsevier filed the instant motion for a preliminary injunction on June 11, 2015, via an Order to Show Cause. (Dkt. Nos. 5-13.) On June 18, 2015, the Court granted

2

Plaintiffs' Order to Show Cause and authorized service on the

Defendants via email.
week,

(Dkt.

No.

1 5.)

During the following

the Plaintiffs served the Website Defendants via email and

Elbakyan via email and postal mail.
On July 7,
Part One Judge,
and Elbakyan,

2015,

See Dkt.

Nos.

the Honorable Ronnie Abrams,

24-31. )
acting as

held a telephone conference with the Plaintiffs

during which Elbakyan acknowledged receiving the

papers concerning this case and declared that she did not intend
to obtain a lawyer.
conference,

(See Transcript,

Dkt.

No.

38. )

After the

Judge Abrams issued an Order directing Elbakyan to

notify the Court whether she wished assistance in obtaining pro
bono counsel,
se,

and advising her that while she could proceed pro

the Website Defendants,

not being natural persons,
(Dkt. No.

obtain counsel or risk default.

telephonic conference was held on July 14 ,

must

3 6. )

A second

2015,

during which

Elbakyan stated that she needed additional time to find a
lawyer.

( See Transcript,

the request,

Dkt.

No.

4 2. )

Judge Abrams granted

but warned Elbakyan th�t "you have to move quickly

both in attempting to retain an attorney and you' ll have to
stick to the schedule that is set once it' s set. "
After the telephone conference,

(Id.

at 6. )

Judge Abrams issued another

Order setting the preliminary injunction hearing for September
1 6 and directing Elbakyan to inform the Court by July 21 if she
wished assistance in obtaining pro bono counsel.
3

(Dkt. No.

4 0. )

The motion for a preliminary injunction was heard on
September 1 6,
hearing,

201 5.

None of the Defendants appeared at the

although Elbakyan sent a two-page letter to the court

the day before.

(Dkt. No.

50.)

Applicable Standard

Preliminary injunctions are "extraordinary and drastic
remed[ies]

that should not be granted unless the movant,

clear showing,
Armstrong,

carries the burden of persuasion. "

5 20 U. S.

district court may,

9 68,

972 (1997).

by a

Mazurek v.

In a copyright case,

at its discretion,

a

grant a preliminary

injunction when the plaintiffs demonstrate 1) a likelihood of
success on the merits,
injunction,
favor,

2) irreparable harm in the absence of an

3) a balance of the hardships tipping in their

and 4 ) that issuance of an injunction would not do a

disservice to the public interest.
F. 3d 27 5,

278 ( 2d Cir.

W PIX,

Inc.

v. ivi,

Inc.,

691

2012).

The Motion is Granted

With the exception of Elbakyan,

none of the Defendants

filed any opposition to the instant motion,

participated in any

hearing or telephone conference, or in any other way appeared in
4

the case.

Although Elbakyan acknowledges that she is the "main

operator of sci-hub. erg website"
only represent herself pro

se;

(Dkt.

No.

50 at 1. ), she may

since the Website Defendants are

not natural persons, they may only be represented by an attorney
See Max Cash Media, Inc.

admitted to practice in federal court.
v.

Prism Corp. , No.

(S.D. N. Y.

12 Civ.

147, 2012 WL 2861 162, at *1

July 9, 2012);

Auth. , 722 F. 2d 20, 22

(2d Cir.

1983)

(stating reasons for the

rule and noting that it is "venerable and widespread").

Because

the Website Defendants did not retain an attorney to defend this
action, they are in default.
However, the Website Defendants' default does not
the Plaintiffs to an injunction, nor does

automatically entit

the fact that Elbakyan's submission raises no mer
challenge to the Plaintiffs' claims.
Music, No.
2015).

13 Civ.

s-based

See Thurman v.

5194, 2015 WL 2 168134, at *4

Bun Bun
May 7,

(S. D. N. Y.

Instead, notwithstanding the default, the Plaintiffs

must present evidence sufficient to establish that they are
entitled to injunctive relief.
Curveal Fashion, No.
(S. D. N. Y.
Cir.

09 Civ.

Jan 20, 2010);

See id. ;

Inc.

v.

8458, 2010 WL 308303, at *2

CFTC v.

Vartuli, 228 F. 3d 94, 98

2000).

A. Likelihood of S

Gucci Am.,

ss on the
5

rits

(2d

, -

Elsevier has established that the Defendants have
reproduced and distributed its copyrighted works,
of the exclusive rights established by 17
Complaint,

Dkt. No. 1,

at 11-13.)

(1)

"two elements must be

ownership of a valid copyright,

and

(2)

copying of

constituent elements of the work that are original."
Records,

LLC v. Doe 3,

Feist Publ'ns,

See

U.S.C. § 106.

In order to prevail on a

claim for infringement of copyright,
proven:

in violation

604 F.3d 110,

117

Arista

(2d Cir. 2010)

Inc. v. Rural Tel. Serv. Co.,

499 U.S.

(quoting

340,

361

(1991) ) .
Elsevier has made a substantial evidentiary showing,
documenting the manner in which the Defendants access its
ScienceDirect database of scientific literature and post
copyrighted material on their own websites free of charge.
According to Elsevier,

the Defendants gain access to

ScienceDirect by using credentials fraudulently obtained from
educational institutions,

including educational institutions

located in the Southern District of New York,
legitimate access to ScienceDirect.
Woltermann

(the "Woltermann Dec.") ,

which are granted

(See Declaration of Anthony
Dkt. No. 8,

at 13-14.)

As

an attachment to one of the supporting declarations to this
motion,

Elsevier includes a sequence of screenshots showing how

a user could go to �ww.sc�-hub.org,
6

one of the Website

Defendants,

search for information on a scientific article,

a set of search results, click on a link,
copyrighted article on ScienceDirect,

get

and be redirected to a

via a proxy.

See

Elsevier also points to a

Walterman Dec. at 41-44 and Ex. U.)

Twitter post (in Russian) indicating that whenever an article is
downloaded via this method,
own servers.
1 2,

Ex.

B.)

the Defendants save a copy on their

(See Declaration of David M. Hirschberg,
As specific examples,

with their copyright registrations.
Dkt.

No. 9,

Exs. B-D.)

No.

Elsevier includes copies of

two of its articles accessed via the Defendants'

Doda,

Dkt.

websites,

along

(Declaration of Paul F.

This showing demonstrates a

likelihood of success on Elsevier' s copyright infringement
claims.
Elsevier also shows a likelihood of success on its claim
under the Computer Fraud and Abuse Act ("CFAA").
prohibits,

inter alia,

The CFAA

obtaining information from "any protected

computer" without authorization,

18 U.S. C. § 1030(a)(2)(C),

and

obtaining anything of value by accessing any protected computer
with intent to defraud.

Id.

§ (a) (4).

The definition of

"protected computer" includes one "which is used in or affecting
interstate or foreign commerce or communication,

including a

computer located outside the United States that

is used in a

manner that affects interstate or foreign commerce or
communication of the United States."
7

I .

§ (e) (2) (B);

Nexans

Wires S. A.
2006).

v.

Sa

Inc.

166 F.

App'x 559, 562 n. 5

(2d Cir.

Elsevier's ScienceDirect database is located on multiple

servers throughout the world and is accessed by educational
institutions and their students, and qualifies as a computer
used in interstate commerce, and therefore as a protected
computer under the CFAA.

See Woltermann Dec.

at 2-3. )

As

found above, Elsevier has shown that the Defendants' access to
ScienceDirect was unauthorized and accomplished via fraudulent
university credentials.

While the C fAA requires a civil

plaintiff to have suffered over $5,000 in damage or loss, see
Register. com, Inc.

v.

Verio, Inc. , 356 F. 3d 393, 439

(2d Cir.

2004), Elsevier has made the necessary showing since it
documented between 2,000 and 8,500 of its articles being added
to the LibGen database each day

(Woltermann Dec.

at 8, Exs.

G &

H) and because its articles carry purchase prices of between
$19. 95 and $41. 95 each.
Leon, No.

12 Civ.

Id.

at 2;

see Millennium TGA, Inc.

1360, 2013 WL 5719079, at *10

(E. D. N.Y.

v.

Oct.

18, 2013). 1
Elsevier's evidence is also buttressed by Elbakyan's
submission, in which she frankly admits to copyright
infringement.

1

(See Dkt.

No.

50.)

She discusses her time as a

While Elsevier's articles are likely sufficient on their own to qualify as

"[]thing[s]

of value" under the CFAA,

Elbakyan acknowledges in her submission

that the Defendants derive revenue from their website.
50,

at

1

{"That is true that website collects donations,

pressure anyone to send them.").)

8

Letter,

Dkt. No.

however we do not

student at a university in Kazakhstan, where she did not have
access to research papers and found the prices charged to be
just insane.
(Id.

at 1.)

She obtained the papers she needed

"by pirating them," and found may similar students and
researchers, predominantly in developing count

s, who were in

similar situations and helped each other illicitly obtain
research materials that they could not access legitimately or
afford on the open market.

Id.)

As Elbakyan describes it, "I

could obtain any paper by pirating it, so I solved many requests
and people always were very grateful for my help.

After that, I

created sci-hub.org website that simply makes this process
automatic and the website immediately became popular."

(Id.)

Given Elsevier's strong evidentiary showing and Elbakyan's
admissions, the first prong of the preliminary injunction test
is firmly established.

B. Irreparable Harm

Irreparable harm is present "where, but for the grant of
equitable relief, there is a substantial chance that upon final
resolution of the action the parties cannot be returned to the
positions they previously occupied."

Brenntag Int'l Chems.,

Inc. v. Bank of India, 175 F.3d 245, 249

(2d Cir. 1999).

Here,

there is irreparable harm because it is entirely likely that the
9

•'

damage to Elsevier could not be effectively quantified.
Register.com,

356 F.3d at 404

{"irreparable harm may be found

where damages are difficult to establish and measure.").
would be difficult,

if not impossible,

It

to determine how much

money the Plaintiffs have lost due to the availability of
thousands of their articles on the Defendant websites;

some

percentage of those articles would no doubt have been paid for
legitimately if they were not downloadable for free,

but there

appears to be no way of determining how many that would be.
There is also the matter of harm caused by "viral infringement, "
where Elsevier's content could be transmitted and retransmitted
by third parties who acquired it from the Defendants even after
the Defendants' websites were shut down.
Inc.,
275

765 F. Supp. 2d 594,

(2d Cir. 2012).

620

(S.D.N.Y.

See WPIX,
2011),

'to prove the loss of sales due to

infringement is .

notoriously difficult.'"

Colting,

81

607 F.3d 6 8,

(2d Cir. 2010)

Corp. v. Petri-Kine Camera Co.,
(Friendly,

aff'd 691 F.3d

"(C]ourts have tended to issue injunctions

in this context because

1971)

Inc. v. ivi,

Salinger v.

(quoting Omega Importing

451 F.2d 1190,

1195

(2d Cir.

J.)).

Additionally,

the harm done to the Plaintiffs is likely

irreparable because the scale of any money damages would
dramatically exceed Defendants' ability to pay.
F.3d at 249-50

Brenntag,

175

(explaining that even where money damages can be
10

quantified, there is irreparable harm when a defendant will be
unable to cover the damages).
Defendants'

It is highly likely that the

activities will be found to be willful - Elbakyan

herself refers to the websites'

activities as "pirating" (Dkt.

No. 50 at 1) - in which case they would be liable for between
$750 and $150,000 in statutory damages for each pirated work.
See 17 U.S.C.

§ 504(c);

HarperCollins Publishers LLC v. Open

Road Integrated Media, LLP, 58 F.
2014).

Supp. 3d 380, 38 7 (S.D.N.Y.

Since the Plaintiffs credibly allege that the Defendants

infringe an average of over 3,000 new articles each day
(Woltermann Deel. at 7), even if the Court were to award damages
at the lower end of the statutory range the Defendants'
liability could be extensive.

Since the Defendants are an

individual and a set of websites supported by voluntary
donations, the potential damages are likely to be far beyond the
Defendants'

ability to pay.

C. Balance of Hardships

The balance of hardships clearly tips in favor of the
Plaintiffs.

Elsevier has shown that it is likely to succeed on

the merits, and that it continues to suffer irreparable harm due
to the Defendants'
free.

making its copyrighted material available for

As for the Defendants, "it is axiomatic that an infringer
11

of copyright cannot complain about the loss of ability to offer
its infringing product."
omitted).

W PIX,

691 F.3d at 287 (quotation

The Defendants cannot be legally harmed by the fact

that they cannot continue to steal the Plaintiff' s content,

even

See id.

if they tried to do so for public-spirited reasons.

D. Public Interest

To the extent that Elbakyan mounts a legal challenge to the
motion for a preliminary injunction,
interest prong of the test.

it is on the public

In her letter to the Court,

notes that there are "lots of researchers .

she

. especially in

developing countries" who do not have access to key scientific
papers owned by Elsevier and similar organizations,

and who

cannot afford to pay the high fees that Elsevier charges.
No.

50,

at 1.)

Elbakyan states in her letter that Elsevier
operates by racket:
any papers.

(Dkt.

if you do not send money,

On my website,

as they want for free,

you will not read

any person can read as many papers

and sending donations is their free will.

Why Elsevier cannot work like this,

(Id.)

I wonder?
Elbakyan

also notes that researchers do not actually receive money in
exchange for granting Elsevier a copyright.

Id.)

Rather,

she

alleges they give Elsevier ownership of their works "because
Elsevier is an owner of so-called
12

'high-impact'

journals.

If a

researcher wants to be recognized,

make a career - he or she

needs to have publications in such journals.n

{ Id. at 1-2.)

Elbakyan notes that prominent researchers have made attempts to
boycott Elsevier and states that "[t]he general opinion in
research community is that research papers should be distributed
for free (open access),

not sold.

And practices of such

companies like Elsevier are unacceptable,
distribution of knowledge."

because they limit

ld. at 2.)

Elsevier contends that the public interest favors the
issuance of an injunction because doing so will "protect the
delicate ecosystem which supports scientific research
worldwide."

(Pl.'s Br.,

Dkt. No. 6,

at 21.)

It states that the

money it generates by selling access. to scientific research is
used to support new discoveries,
maintain a "de
discovery."

to create new journals,

and to

nitive and accurate record of scientif

( Id.)

It also argues that allowing its articles to

be widely distributed

sks the spread of bad science - while

Elsevier corrects and retracts articles whose conclusions are
later found to be flawed,

it has no way of doing so when the

content is taken out of its control.

Id. at 22.)

Lastly,

Elsevier argues that injunctive relief against the Defendants is
important to deter "cyber-crime," while

ling to issue an

injunction will incentivize pirates to continue to publish
copyrighted works.
13

It cannot be denied that there is a compelling public
interest in fostering scientific achievement, and that ensuring
broad access to scientific research is an important component of
that effort.

As the Second Circuit has noted, "[c]opyright law

inherently balances [] two competing public interests .

.

. the

rights of users and the public interest in broad accessibility
of creative works, and the rights of copyright owners and the
public interest in rewarding and incentivizing creative efforts
(the

'owner-user balance' )."

WPIX, 691 F.3d at 287 .

Elbakyan' s

solution to the problems she identifies, simply making
copyrighted content available for free via a foreign website,
disserves the public interest.

As the Plaintiffs have

established, there is a "delicate ecosystem which supports
scientific research worldwide,"

( Pl.' s Br., Dkt. No. 6 at 21),

and copyright law pays a critical function within that system.
"Inadequate protections for copyright owners can threaten the
very store of knowledge to be accessed; encouraging the
production of creative work thus ultimately serves the public' s
interest in promoting the accessibility of such works. "
691 F.3d at 287 .

W PIX,

The existence of Elsevier shows that

publication of scient ific research

generates substantial

economic value.
The public' s interest in the broad diffusion of scientific
knowledge is sustained by two critical exceptions in copyright
14

law.

First,

the "idea/expression dichotomy" ensures that while

a scientific article may be subject to copyright,

the ideas and

See 17 U. S.C. § 102(b)

insights within that article are not.

("In no case does copyright protection for an original work of
authorship extend to any idea,

procedure,

method of operation,

concept,

to this distinction,

every idea,

principle,

process,

system,

or discovery").

theory,

"Due

and fact in a

copyrighted work becomes instantly available for public
exploitation at the moment of publication."
537 U.S. 186,

219

(2003).

So while Elsevier may be able to keep

its actual articles behind a paywall,
them are fair game for anyone.
doctrine,

comment,

the discoveries within

Secondly,

codified at 17 U.S.C. § 107,

expressions,

as well as ideas,

news reporting,

Eldred v. Ashcroft,

the "fair use"

allows the public to use

nfor purposes such as criticism,

teaching .

.

.

scholarship,

or

research" without being liable for copyright infringement.

(emphasis added)

Under this doctrine,

themselves may be taken and used,
purposes,

Elsevier' s articles

bu.t only for legitimate

and not for wholesale infringement.

U.S. at 219.2

See Eldred,

537

The public interest in the broad dissemination and

use of scientific research is protected by the idea/expression
dichotomy and the fair use doctrine.

2

See Golan v. Holder,

The public interest in wide d1sseminat1on of scientific works

by the fact that copyrights are given only limited

464

15

U.S.

duration.

417, 431-32

132

is also served

See Sony Corp.

(1984).

S.

Ct. 873,

890 (2012);

Eldred,

537 U.S. at 219.

Given the

importance of scientific research and the critical role that
copyright plays in promoting it,

the public interest weighs in

favor of an injunction.

Conclusion

For the reasons set forth above,

It is hereby ordered that:

preliminary injunction is granted.

1. The Defendants,
agents,

their officers,

servants,

employees,

the motion for a

directors,

principals,

successors and assigns,

and

all persons and entities in active concert or participation
with them,

are hereby temporarily restrained from unlawful

access to,

use,

reproduction,

and/or distribution of

Elsevier's copyrighted works and from assisting,

aiding,

or

abetting any other person or business entity in engaging in
unlawful access to,

use,

reproduction,

and/or distribution

of Elsevier' s copyrighted works.
2. Upon the Plaintiffs'

request,

have registered Defendants'

those organizations which

domain names on behalf of

Defendants shall disclose immediately to the Plaintiffs all
information in their possession concerning the identity of
the operator or registrant of such domain names and of any
16

bank accounts or financial accounts owned or used by such
operator or registrant.
3. Defendants shall not transfer ownership of the Defendants'
websites during the pendency of this Action,

or until

further Order of the Court.
4. The TLD Registries for the Defendants'
administrators,

websites,

or their

shall place the domain names on

registryHold/serverHold as well as serverUpdate,
serverDelete,

and serverTransfer prohibited statuses,

until

further Order of the Court.
5. The Defendants shall preserve copies of all computer files
relating to the use of the websites and shall take all
necessary steps to retrieve computer files relating to the
use of the websites that may have been deleted before entry
of this Order.
6. That security in the amount of $ 5, 000 be posted by the
Plaintiffs within one week of the entry of this Order.
Fed.

R.

Civ.

P. 6 5(c).

17

See

It is so ordered.

New York,

fY
October ? ;--1

2015
R BERT W. SWEET

U.S.D.J.

18


Hamerman
Pirate Libraries and the Fight for Open Information
2015


| | SEPTEMBER 11TH, 2015 | A BI-WEEKLY WEBPAPER | ISSUE 61

|
---|---|---|---|---
PIRATE LIBRARIES and the fight for open information
/ by _Sarah Hamerman_ |

In a digital era that destabilizes traditional notions of intellectual
property, cultural producers must rethink information access.

Over the last several years, a number of _pirate libraries_ have done just
that. Collaboratively run digital libraries such as
[_Aaaaaarg_](http://aaaaarg.fail/),
_[Monoskop](http://www.monoskop.org/Monoskop)_ , _[Public
Library](https://www.memoryoftheworld.org/)_ , and
_[UbuWeb_](http://www.ubuweb.tv/) have emerged, offering access to humanities
texts and audiovisual resources that are technically ‘pirated’ and often hard
to find elsewhere.

Though these sites differ somewhat in content, architecture, and ideological
bent, all of them disavow intellectual copyright law to varying degrees,
offering up pirated books and media with the aim of advancing information
access.

“Information wants to be free,” has served as a catchphrase in recent internet
activism, calling for information democracy, led by media, library and
information advocates.

As online information access is increasingly embedded within the networks of
capital, the digital text-sharing underground actualizes the Internet’s
potential to build a true information commons.

With such projects, the archive becomes a record of collective power, not
corporate or state power; the digital book becomes unlocked, linkable, and
shareable.

Still, these sites comprise but a small subset of the networks of peer-to-peer
file sharing. Many legal battles waged over the explosion of audiovisual file
sharing through p2p services such as Napster, BitTorrent and MediaFire. At its
peak, Napster boasted over 80 million users; the p2p music-sharing service was
shut down after a high-profile lawsuit by the RIAA in 2001.

The US Department of Justice brought charges against open access activist
_[Aaron Swartz](http://www.fvckthemedia.com/issue51/editorial)_ in 2011 for
his large-scale unauthorized downloading of files from the JStor Academic
database. Swartz, who sadly committed suicide before his trial, was an
organizer for Demand Progress, a campaign against the Stop Online Piracy Act,
which was defeated in 2012. Swartz’s actions and the fight around SOPA
represent a benchmark in the struggle for open-access and anti-copyright
practices surrounding the digital book.

Aaaaaarg, Monoskop, UbuWeb and Public Library are representative cases of the
pirate library because of their explicit engagement with archival form, their
embrace of ideas of the _[digital commons](https://en.wikipedia.org/wiki/Digital_Commons)_ within current left-leaning thought, and their like-minded focus on critical theory and the arts.

All of these projects lend themselves to be considered _as libraries_ ,
retooled for open digital networks.

_Aaaaaarg.org_ , started by Los Angeles based artist Sean Dockray, hosts
full-text pdfs of over 50,000 books and articles. The library is connected to a an
alternative education project called the Public School, which serves as a
platform for self-organizing lectures, workshops and projects in cities across
the globe. _Aaaaaarg_ ’s catalog is viewable by the public, but
upload/download privileges are restricted through an invite system, thus
circumventing copyright law.

![](http://i.imgur.com/rbdvPIG.png)

The site is divided into a “Library,” in which users can search for texts by
author; “Collections,” or user-generated grouping of texts designed for
reading groups or research interests; and “Discussions,” a message board where
participants can request texts and volunteer for working groups. Most
recently, _Aaaaaarg_ has introduced a “compiler” tool that allows readers to
select excerpts from longer texts and assemble them into new PDFs, and a
reading tool that allows readers to save reference points and insert comments
into texts. Though the library is easily searchable, it doesn’t maintain
high-quality _[metadata](https://en.wikipedia.org/wiki/Metadata)_. Dockray and
other organizers intend to preserve a certain subjective and informal quality,
focusing more on discussion and collaboration than correct preservation and
classification practice.

_Aaaaaarg_ has been threatened with takedowns a few times, but has survived by
creating mirrored sites and reconstituted itself by varying the number of A’s
in the URL. Its shifts in location, organization, and capabilities reflect
both the decentralized, ad-hoc nature of its maintenance and the organizers’
attempts to elude copyright regulations. Text-sharing sites such as _Aaaaaarg_
have also been referred to as _[shadow
libraries_](http://supercommunity.e-flux.com/texts/sharing-instinct/),
reflecting their quasi-covert status and their efforts to evade shutdown.

Monoskop.org, a project founded by media artist _[Dušan
Barok](http://monoskop.org/Du%C5%A1an_Barok)_ , is a wiki for collaborative
studies of art, media and the humanities that was born in 2004 out of Barok’s
study of media art and related cultural practices. Its significant holdings -
about 3,000 full-length texts and many more excerpts, links and citations -
include avant-garde and modernist magazines, writings on sound art, scanned
illustrations, and media theory texts.

As a wiki, any user can edit any article or upload content, and see their
changes reflected immediately. Monoskop is comprised of two sister sites: the
Monoskop wiki and Monoskop Log, the accompanying text repository. Monoskop Log
is structured as a Wordpress site with links hosted on third-party sites, much
like the rare-music download blogs that became popular in the mid-2000s.
Though this architecture is relatively unstable, links are fixed on-demand and
site mirroring and redundancy balance out some of the instability.

Monoskop makes clear that it is offering content under the fair-use doctrine
and that this content is for personal and scholarly use, not commercial use.
Barok notes that though there have been a small number of takedowns, people
generally appreciate unrestricted access to the types of materials in Monoskop
log, whether they are authors or publishers.

_Public Library_ , a somewhat newer pirate library founded by Croatian
Internet activist and researcher Marcell Mars and his collaborators, currently
offers a collection of about 6,300 texts. The project frames itself through a
utopian philosophy of building a truly universal library, radically extending
enlightenment-era conceptions of democracy. Through democratizing the _tools
of librarianship_ – book scanning, classification systems, cataloging,
information – it promises a broader, de-institutionalized public library.

In __[Public Library: An
Essay](https://www.memoryoftheworld.org/blog/2014/10/27/public-library-an-essay/#sdendnote19sym)__ , Public Library’s organizers frame p2p libraries as
“fragile knowledge infrastructures built and maintained by brave librarians
practicing civil disobedience which the world of researchers in the humanities
rely on.” This civil disobedience is a politically motivated refutation of
intellectual property law and the orientation of information networks toward
venture capital and advertising. While the pirate libraries fulfill this
dissident function as a kind of experimental provocation, their content is
audience-specific rather than universal.

_[UbuWeb](http://www.ubuweb.com/resources/index.html)_ , founded in 1996 by
conceptual artist/ writer Kenneth Goldsmith, is the largest online archive of
avant-garde art resources. Its holdings include sound, video and text-based
works dating from the historical avant-garde era to today. While many of the
sites in the “pirate library” continuum source their content through
community-based or peer-to-peer models, UbuWeb focuses on making available out
of print, obscure or difficult to access artistic media, stating that
uploading such historical artifacts doesn’t detract from the physical value of
the work; rather, it enhances it. The website’s philosophy blends the utopian
ideals of avant-garde concrete poetry with the ideals of the digital gift
economy, and it has specifically refused to accept corporate or foundation
funding or adopt a more market-oriented business model.

![](http://i.imgur.com/pHdiL9S.png)

**Pirate Libraries vs. “The Sharing Economy”**

In pirate libraries, information users become archive builders by uploading
often-copyrighted content to shared networks.

Within the so-called “ _[sharing
economy](https://en.wikipedia.org/wiki/Sharing_economy)_ ,” users essentially
lease e-book content from information corporations such as Amazon, which
markets both the Kindle as platform. This centralization of intellectual
property has dire impacts on the openness of the digital book as a
collaborative knowledge-sharing device.

In contrast, the pirate library actualizes a gift economy based on qualitative
and communal rather than monetized exchange. As Mackenzie Wark writes in _A
Hacker Manifesto_ (2004), “The gift is marginal, but nevertheless plays a
vital role in cementing reciprocal and communal relations among people who
otherwise can only confront each other as buyers and sellers of commodities.”

From theorizing new media art to building solidarity against repressive
regimes, such communal information networks can crucially articulate shared
bodies of political and aesthetic desire and meaning. According to author
Matthew Stadler, literature is by nature communal. “Literature is not owned,”
he writes. “It is, by definition, a space of mutually negotiated meanings that
never closes or concludes, a space that thrives on — indeed requires — open
access and sharing.”

In a roundtable discussion published in _New Formations_ , _Aaaaaarg_ founder
Sean Dockray remarks that the site “actively explored and exploited the
affordances of asynchronous, networked communication,” functioning upon the
logic of the hack. Dockray continues: “But all of this is rather commonplace
for what’s called ‘piracy,’ isn’t it?” Pirate librarianship can be thought of
as a practice of civil disobedience within the stringent information
environment of today.

These projects promise both the realization and destruction of the public
library. They promote information democracy while calling the _professional_
institution of the Library into question, allowing amateurs to upload,
catalog, lend and maintain collections. In _Public Library: An Essay_ , Public
Library’s organizers _[write](https://www.memoryoftheworld.org/blog/2014/10/27
/public-library-an-essay/)_ : “With the emergence of the internet…
librarianship has been given an opportunity… to include thousands of amateur
librarians who will, together with the experts, build a distributed peer-to-peer network to care for the catalog of available knowledge.”

Public Library frames amateur librarianship as a free, collaboratively
maintained and democratic activity, drawing upon the language of the French
Revolution and extending it for the 21st century. While these practices are
democratic in form, they are not necessarily democratic in the populist sense;
rather, they focus on bringing high theoretical discourses to people outside
the academy. Accordingly, they attract a modest but engaged audience of
critics, artists, designers, activists, and scholars.

The activities of Aaaaaarg and Public Library may fall closer to ‘ _[peer
preservation](http://computationalculture.net/article/book-piracy-as-peer-preservation)_ ’
than ‘peer production,’ as the desires to share information
widely and to preserve these collections against shutdown often come into
conflict. In a _[recent piece](http://supercommunity.e-flux.com/texts/sharing-instinct/)_ for e-flux coauthored with Lawrence Liang, Dockray accordingly
laments “the unfortunate fact that digital shadow libraries have to operate
somewhat below the radar: it introduces a precariousness that doesn’t allow
imagination to really expand, as it becomes stuck on techniques of evasion,
distribution, and redundancy.”

![](http://i.imgur.com/KFe3chu.png)

UbuWeb and Monoskop, which digitize rare, out-of-print art texts and media
rather than in-print titles, can be said to fulfill the aims of preservation
and access. UbuWeb and Monoskop are openly used and discussed as classroom
resources and in online arts journalism more frequently than the more
aggressively anti-copyright sources; more on-the-record and mainstream
visibility likely -- but doesn’t necessarily -- equate to wider usage.

**From Alternative Space to Alternative Media**

Aaaaaarg _[locates itself as a
‘scaffolding’](http://chtodelat.org/b9-texts-2/vilensky/materialities-of-independent-publishing-a-conversation-with-aaaaarg-chto-delat-i-cite-mute-and-neural/)_ between institutions, a platform that unfolds between institutional
gaps and fills them in, rather than directly opposing them. Over ten years
after it was founded, it continues to provide a community for “niche”
varieties of political critique.

Drawing upon different strains of ‘alternative networking,’ the digital
text-sharing underground gives a voice to those quieted by the mechanisms of
institutional archives, publishing, and galleries. On the one hand, pirate
libraries extend the logic of alternative art spaces/artist-run spaces that
challenge the “white cube” and the art market; instead, they showcase ways of
making that are often ephemeral, performative, and anti-commercial.

Lawrence Liang refers to projects such as Aaaaaarg as “ _[ludic
libraries](http://supercommunity.e-flux.com/texts/sharing-instinct/)_ ,” as
they encourage a sense of intellectual play that deviates from well-
established norms of utility, seriousness, purpose, and property.

Just as alternative, community-oriented art spaces promote “fringe” art forms,
the pirate libraries build upon open digital architectures to promote “fringe”
scholarship, art, technological and archival practices. Though the comparison
between physical architecture and virtual architecture is a metaphor here, the
impact upon creative communities runs parallel.

At the same time, the digital text-sharing underground builds upon Robert W.
McChesney’s calls in _Digital Disconnect_ for a democratic media system that
promotes the expansion of public, student and community journalism. A truly
heterogeneous media system, for McChesney, would promote a multiplicity of
opinions, supplementing for-profit mass media with a substantial and varied
portion of nonprofit and independent media.

In order to create a political system – and a media system – that reflects
multiple interests, rather than the supposedly neutral status quo, we must
support truly free, not-for-profit alternatives to corporate journalism and
“clickbait” media designed to lure traffic for advertisers. We must support
creative platforms that encourage blending high-academic language with pop-
culture; quantitative analysis with art-making; appropriation with
authenticity: the pirate libraries serve just these purposes.

Pirate libraries help bring about what Gary Hall calls the “unbound book” as
text-form; as he writes, we can perceive such a digital book “as liquid and
living, open to being continually updated and collaboratively written, edited,
annotated, critiqued, updated, shared, supplemented, revised, re-ordered,
reiterated and reimagined.” These projects allow us to re-imagine both
archival practices and the digital book for social networks based on the gift.

Aaaaaarg, Monoskop, UbuWeb, and Public Library build a record of critical and
artistic discourse that is held in common, user-responsive and networkable.
Amateur librarians sustain these projects through technological ‘hacks’ that
innovate upon present archival tools and push digital preservation practices
forward.

Pirate libraries critique the ivory tower’s monopoly over the digital book.
They posit a space where alternative communities can flourish.

Between the cracks of the new information capital, the digital text-sharing
underground fosters the coming-into-being of another kind of information
society, one in which the historical record is the democratically-shared basis
for new forms of knowledge.

From this we should take away the understanding that _piracy is normal_ and
the public domain it builds is abundant. While these practices will continue
just beneath the official surface of the information economy, it is high time
for us to demand that our legal structures catch up.


Mars & Medak
System of a Takedown
2019


System of a Takedown: Control and De-­commodification in the Circuits of Academic Publishing
Marcell Mars and Tomislav Medak

Since 2012 the Public Library/Memory of the World1 project has
been developing and publicly supporting scenarios for massive
disobedience against the current regulation of production and
circulation of knowledge and culture in the digital realm. While
the significance of that year may not be immediately apparent to
everyone, across the peripheries of an unevenly developed world
of higher education and research it produced a resonating void.
The takedown of the book-­sharing site Library.nu in early 2012
gave rise to an anxiety that the equalizing effect that its piracy
had created—­the fact that access to the most recent and relevant
scholarship was no longer a privilege of rich academic institutions
in a few countries of the world (or, for that matter, the exclusive
preserve of academia to begin with)—­would simply disappear into
thin air. While alternatives within these peripheries quickly filled
the gap, it was only through an unlikely set of circumstances that
they were able to do so, let alone continue to exist in light of the
legal persecution they now also face.

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The starting point for the Public Library/Memory of the World
project was a simple consideration: the public library is the institutional form that societies have devised in order to make knowledge
and culture accessible to all their members regardless of social or
economic status. There’s a political consensus that this principle of
access is fundamental to the purpose of a modern society. Yet, as
digital networks have radically expanded the access to literature
and scientific research, public libraries were largely denied the
ability to extend to digital “objects” the kind of de-­commodified
access they provide in the world of print. For instance, libraries
frequently don’t have the right to purchase e-­books for lending and
preservation. If they do, they are limited by how many times—­
twenty-­six in the case of one publisher—­and under what conditions
they can lend them before not only the license but the “object”
itself is revoked. In the case of academic journals, it is even worse:
as they move to predominantly digital models of distribution,
libraries can provide access to and “preserve” them only for as
long as they pay extortionate prices for ongoing subscriptions. By
building tools for organizing and sharing electronic libraries, creating digitization workflows, and making books available online, the
Public Library/Memory of the World project is aimed at helping to
fill the space that remains denied to real-­world public libraries. It is
obviously not alone in this effort. There are many other platforms,
some more public, some more secretive, working to help people
share books. And the practice of sharing is massive.
—­https://www.memoryoftheworld.org

Capitalism and Schizophrenia
New media remediate old media. Media pay homage to their
(mediatic) predecessors, which themselves pay homage to their
own (mediatic) predecessors. Computer graphics remediate film,
which remediates photography, which remediates painting, and so
on (McLuhan 1965, 8; Bolter and Grusin 1999). Attempts to understand new media technologies always settle on a set of metaphors

(of the old and familiar), in order to approximate what is similar,
and yet at the same time name the new. Every such metaphor has
its semiotic distance, decay, or inverse-­square law that draws the
limit how far the metaphor can go in its explanation of the phenomenon to which it is applied. The intellectual work in the Age of
Mechanical Reproduction thus received an unfortunate metaphor:
intellectual property. A metaphor modeled on the scarce and
exclusive character of property over land. As the Age of Mechanical
Reproduction became more and more the Age of Discrete and
Digital Reproduction, another metaphor emerged, one that reveals
the quandary left after decades of decay resulting from the increasing distanciation of intellectual property from the intellectual work
it seeks to regulate, and that metaphor is: schizophrenia.
Technologies compete with each other—­the discrete and the
digital thus competes with the mechanical—­and the aftermath of
these clashes can be dramatic. People lose their jobs, companies
go bankrupt, disciplines lose their departments, and computer
users lose their old files. More often than not, clashes between
competing technologies create antagonisms between different
social groups. Their voices are (sometimes) heard, and society tries
to balance their interests.
If the institutional remedies cannot resolve the social antagonism,
the law is called on to mediate. Yet in the present, the legal system
only reproduces the schizoid impasse where the metaphor of property over land is applied to works of intellect that have in practical
terms become universally accessible in the digital world. Court
cases do not result in a restoration of balance but rather in the
confirmation of entrenched interests. It is, however, not necessary
that courts act in such a one-­sided manner. As Cornelia Vismann
(2011) reminds us in her analysis of the ancient roots of legal mediation, the juridical process has two facets: first, a theatrical aspect
that has common roots with the Greek dramatic theatre and its
social function as a translator of a matter of conflict into a case for
weighted juridical debate; second, an agonistic aspect not unlike a
sporting competition where a winner has to be decided, one that

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leads to judgment and sanction. In the matter of copyright versus
access, however, the fact that courts cannot look past the metaphor of intellectual property, which reduces any understanding of
our contemporary technosocial condition to an analogy with the
scarcity-­based language of property over land, has meant that they
have failed to adjudicate a matter of conflict between the equalizing effects of universal access to knowledge and the guarantees of
rightful remuneration for intellectual labor into a meaningful social
resolution. Rather they have primarily reasserted the agonistic
aspect by supporting exclusively the commercial interests of large
copyright industries that structure and deepen that conflict at the
societal level.
This is not surprising. As many other elements of contemporary
law, the legal norms of copyright were articulated and codified
through the centuries-­long development of the capitalist state
and world-system. The legal system is, as Nicos Poulantzas (2008,
25–­26) suggests, genetically structured by capitalist development.
And yet at the same time it is semi-­autonomous; the development
of its norms and institutional aspects is largely endogenous and
partly responsive to the specific needs of other social subsystems.
Still, if the law and the courts are the codified and lived rationality
of a social formation, then the choice of intellectual property as a
metaphor in capitalist society comes as no surprise, as its principal
objective is to institute a formal political-­economic framework for
the commodification of intellectual labor that produces knowledge
and culture. There can be no balance, only subsumption and
accumulation. Capitalism and schizophrenia.
Schizophrenia abounds wherever the discrete and the digital
breaking barriers to access meets capitalism. One can only wonder
how the conflicting interests of different divisions get disputed
and negotiated in successful corporate giants like Sony Group
where Sony Pictures Entertainment,2 Sony Music Entertainment3
and Sony Computer Entertainment coexist under the same roof
with the Sony Electronics division, which invented the Walkman
back in 1979 and went on to manufacture devices and gadgets like

home (and professional) audio and video players/recorders (VHS,
Betamax, TV, HiFi, cassette, CD/DVD, mp3, mobile phones, etc.),
storage devices, personal computers, and game consoles. In the
famous 1984 Betamax case (“Sony Corp. of America v. Universal
City Studios, Inc.,” Wikipedia 2015), Universal Studios and the Walt
Disney Company sued Sony for aiding copyright infringement with
their Betamax video recorders. Sony won. The court decision in
favor of fair use rather than copyright infringement laid the legal
ground for home recording technology as the foundation of future
analog, and subsequently digital, content sharing.
Five years later, Sony bought its first major Hollywood studio:
Columbia Pictures. In 2004 Sony Music Entertainment merged with
Bertelsmann Music Group to create Sony BMG. However, things
changed as Sony became the content producer and we entered the
age of the discrete and the digital. Another five years later, in 2009,
Sony BMG sued Joel Tenenbaum for downloading and then sharing
thirty-­one songs. The jury awarded US$675,000 to the music
companies (US$22,000 per song). This is known as “the second
file-­sharing case.” “The first file-­sharing case” was 2007’s Capitol Records, Inc. v. Thomas-­Rasset, which concerned the downloading of
twenty-­four songs. In the second file-­sharing case, the jury awarded
music companies US$1,920,000 in statutory damages (US$80,000
per song). The defendant, Jammie Thomas, was a Native American
mother of four from Brainerd, Minnesota, who worked at the time
as a natural resources coordinator for the Mille Lacs Band of the
Native American Ojibwe people. The conflict between access and
copyright took a clear social relief.
Encouraged by the court decisions in the years that followed, the
movie and music industries have started to publicly claim staggering numbers in annual losses: US$58 billion and 370,000 lost jobs
in the United States alone. The purported losses in sales were,
however, at least seven times bigger than the actual losses and,
if the jobs figures had been true, after only one year there would
have been no one left working in the content industry (Reid 2012).
Capitalism and schizophrenia.

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If there is a reason to make an exception from the landed logic of
property being imposed onto the world of the intellect, a reason
to which few would object, it would be for access for educational
purposes. Universities in particular give an institutional form to
the premise that equal access to knowledge is a prerequisite for
building a society where all people are equal.
In this noble endeavor to make universal access to knowledge
central to social development, some universities stand out more
than the others. Consider, for example, the Massachusetts Institute
of Technology (MIT). The Free Culture and Open Access movements
have never hidden their origins, inspiration, and model in the
success of the Free Software Movement, which was founded in
1984 by Richard Stallman while he was working at the MIT Artificial
Intelligence lab. It was at the MIT Museum that the “Hall of Hacks”
was set up to proudly display the roots of hacking culture. Hacking
culture at MIT takes many shapes and forms. MIT hackers famously
put a fire truck (2006) and a campus police car (1994) onto the
roof of the Great Dome of the campus’s Building 10; they landed
(and then exploded) a weather balloon onto the pitch of Harvard
Stadium during a Harvard–­Yale football game; turned the quote
that “getting an education from MIT is like taking a drink from a Fire
Hose” into a literal fire hydrant serving as a drinking fountain in
front of the largest lecture hall on campus; and many, many other
“hacks” (Peterson 2011).
The World Wide Web Consortium was founded at MIT in 1993.
Presently its mission states as its goal “to enable human communication, commerce, and opportunities to share knowledge,”
on the principles of “Web for All” and the corresponding, more
technologically focused “Web on Everything.” Similarly, MIT began
its OpenCourseWare project in 2002 in order “to publish all of
[MIT’s] course materials online and make them widely available to
everyone” (n.d.). The One Laptop Per Child project was created in
2005 in order to help children “learn, share, create, and collaborate” (2010). Recently the MIT Media Lab (2017) has even started its
own Disobedience Award, which “will go to a living person or group

engaged in what we believe is extraordinary disobedience for
the benefit of society . . . seeking both expected and unexpected
nominees.” When it comes to the governance of access to MIT’s
own resources, it is well known that anyone who is registered and
connected to the “open campus” wireless network, either by being
physically present or via VPN, can search JSTOR, Google Scholar,
and other databases in order to access otherwise paywalled journals from major publishers such as Reed Elsevier, Wiley-­Blackwell,
Springer, Taylor and Francis, or Sage.
The MIT Press has also published numerous books that we love
and without which we would have never developed the Public
Library/Memory of the World project to the stage where it is now.
For instance, only after reading Markus Krajewski’s Paper Machines: About Cards & Catalogs, 1548–­1929 (2011) and learning how
conceptually close librarians came to the universal Turing machine
with the invention of the index card catalog did we center the
Public Library/Memory of the World around the idea of the catalog.
Eric von Hippel’s Democratizing Innovation (2005) taught us how end
users could become empowered to innovate and accordingly we
have built our public library as a distributed network of amateur
librarians acting as peers sharing their catalogs and books. Sven
Spieker’s The Big Archive: Art from Bureaucracy (2008) showed us the
exciting hybrid meta-­space between psychoanalysis, media theory,
and conceptual art one could encounter by visiting the world of
catalogs and archives. Understanding capitalism and schizophrenia would have been hard without Semiotext(e)’s translations of
Deleuze and Guattari, and remaining on the utopian path would
have been impossible if not for our reading of Cybernetic Revolutionaries (Medina 2011), Imagine No Possessions (Kiaer 2005), or Art
Power (Groys 2008).

Our Road into Schizophrenia, Commodity
Paradox, Political Strategy
Our vision for the Public Library/Memory of the World resonated
with many people. After the project initially gained a large number

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of users, and was presented in numerous prominent artistic
venues such as Museum Reina Sofía, Transmediale, Württembergischer Kunstverein, Calvert22, 98weeks, and many more, it was no
small honor when Eric Kluitenberg and David Garcia invited us to
write about the project for an anthology on tactical media that was
to be published by the MIT Press. Tactical media is exactly where
we would situate ourselves on the map. Building on Michel de
Certeau’s concept of tactics as agency of the weak operating in the
terrain of strategic power, the tactical media (Tactical Media Files
2017) emerged in the political and technological conjuncture of the
1990s. Falling into the “art-­into-­life” lineage of historic avant-­gardes,
Situationism, DIY culture, techno-­hippiedom, and media piracy, it
constituted a heterogeneous field of practices and a manifestly
international movement that combined experimental media and
political activism into interventions that contested the post–­Cold
War world of global capitalism and preemptive warfare on a hybrid
terrain of media, institutions, and mass movements. Practices of
tactical media ranged from ephemeral media pranks, hoaxes, and
hacktivism to reappropriations of media apparatuses, institutional
settings, and political venues. We see our work as following in
that lineage of recuperation of the means of communication from
their capture by personal and impersonal structures of political or
economic power.
Yet the contract for our contribution that the MIT Press sent us in
early 2015 was an instant reminder of the current state of affairs
in academic publishing: in return for our contribution and transfer
of our copyrights, we would receive no compensation: no right to
wage and no right to further distribute our work.
Only weeks later our work would land us fully into schizophrenia:
the Public Library/Memory of the World received two takedown
notices from the MIT Press for books that could be found in its
back then relatively small yet easily discoverable online collection
located at https://library.memoryoftheworld.org, including a notice
for one of the books that had served as an inspiration to us: Art
Power. First, no wage and, now, no access. A true paradox of the

present-­day system of knowledge production: products of our
labor are commodities, yet the labor-­power producing them is
denied the same status. While the project’s vision resonates with
many, including the MIT Press, it has to be shut down. Capitalism
and schizophrenia.4
Or, maybe, not. Maybe we don’t have to go down that impasse.
Starting from the two structural circumstances imposed on us by
the MIT Press—­the denial of wage and the denial of access—­we
can begin to analyze why copyright infringement is not merely, as
the industry and the courts would have it, a matter of illegality. But
rather a matter of legitimate action.
Over the past three decades a deep transformation, induced by
the factors of technological change and economic restructuring,
has been unfolding at different scales, changing the way works
of culture and knowledge are produced and distributed across
an unevenly developed world. As new technologies are adopted,
generalized, and adapted to the realities of the accumulation
process—­a process we could see unfolding with the commodification of the internet over the past fifteen years—­the core and
the periphery adopt different strategies of opposition to the
inequalities and exclusions these technologies start to reproduce.
The core, with its emancipatory and countercultural narratives,
pursues strategies that develop legal, economic, or technological
alternatives. However, these strategies frequently fail to secure
broader transformative effects as the competitive forces of the
market appropriate, marginalize, or make obsolete the alternatives
they advocate. Such seems to have been the destiny of much of the
free software, open access, and free culture alternatives that have
developed over this period.
In contrast, the periphery, in order to advance, relies on strategies
of “stealing” that bypass socioeconomic barriers by refusing to
submit to the harmonized regulation that sets the frame for global
economic exchange. The piracy of intellectual property or industrial
secrets thus creates a shadow system of exchange resisting the

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asymmetries of development in the world economy. However, its
illegality serves as a pretext for the governments and companies of
the core to devise and impose further controls over the technosocial systems that facilitate these exchanges.
Both strategies develop specific politics—­a politics of reform, on
the one hand, and a politics of obfuscation and resistance, on the
other—­yet both are defensive politics that affirm the limitations
of what remains inside and what remains outside of the politically
legitimate.
The copyright industry giants of the past and the IT industry giants
of the present are thus currently sorting it out to whose greater
benefit will this new round of commodification work out. For those
who find themselves outside of the the camps of these two factions
of capital, there’s a window of opportunity, however, to reconceive
the mode of production of literature and science that has been
with us since the beginning of the print trade and the dawn of capitalism. It’s a matter of change, at the tail end of which ultimately
lies a dilemma: whether we’re going to live in a more equal or a
more unjust, a more commonised or a more commodified world.

Authorship, Law, and Legitimacy
Before we can talk of such structural transformation, the normative
question we expect to be asked is whether something that is considered a matter of law and juridical decision can be made a matter
of politics and political process. Let’s see.
Copyright has a fundamentally economic function—­to unambiguously establish individualized property in the products of creative
labor. A clear indication of this economic function is the substantive requirement of originality that the work is expected to have
in order to be copyrightable. Legal interpretations set a very low
standard on what counts as original, as their function is no more
than to demarcate one creative contribution from another. Once
a legal title is unambiguously assigned, there is a person holding

property with whose consent the contracting, commodification,
and marketing of the work can proceed.5 In that respect copyright
is not that different from the requirement of formal freedom that
is granted to a laborer to contract out their own labor-­power as a
commodity to capital, giving capital authorization to extract maximum productivity and appropriate the products of the laborer’s
labor.6 Copyright might be just a more efficient mechanism of
exploitation as it unfolds through selling of produced commodities
and not labor power. Art market obscures and mediates the
capital-­labor relation
When we talk today of illegal copying, we primarily mean an
infringement of the legal rights of authors and publishers. There’s an
immediate assumption that the infringing practice of illegal copying
and distribution falls under the domain of juridical sanction, that it is
a matter of law. Yet if we look to the history of copyright, the illegality
of copying was a political matter long before it became a legal one.
Publisher’s rights, author’s rights, and mechanisms of reputation—­
the three elements that are fundamental to the present-­day
copyright system—­all have their historic roots in the context of
absolutism and early capitalism in seventeenth-­and eighteenth-­
century Europe. Before publishers and authors were given a
temporary monopoly over the exploitation of their publications
instituted in the form of copyright, they were operating in a system
where they were forced to obtain a privilege to print books from
royal censors. The first printing privileges granted to publishers, in
early seventeenth-­century Great Britain,7 came with the responsibility of publishers to control what was being published and
disseminated in a growing body of printed matter that started to
reach the public in the aftermath of the invention of print and the
rise of the reading culture. The illegality in these early days of print
referred either to printing books without the permission of the
censor or printing books that were already published by another
printer in the territory where the censor held authority. The transition from the privilege tied to the publisher to the privilege tied to
the natural person of the author would unfold only later.

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In the United Kingdom this transition occurred as the guild of
printers, Stationers’ Company, failed to secure the extension of its
printing monopoly and thus, in order to continue with its business,
decided to advocate the introduction of copyright for the authors
instead. This resulted in the passing of the Copyright Act of 1709,
also known as the Statute of Anne (Rose 2010). The censoring
authority and enterprising publishers now proceeded in lockstep to
isolate the author as the central figure in the regulation of literary
and scientific production. Not only did the author receive exclusive
rights to the work, the author was also made—­as Foucault has
famously analyzed (Foucault 1980, 124)—­the identifiable subject of
scrutiny, censorship, and political sanction by the absolutist state.
Although the Romantic author slowly took the center stage in
copyright regulations, economic compensation for the work would
long remain no more than honorary. Until well into the eighteenth
century, literary writing and creativity in general were regarded as
resulting from divine inspiration and not the individual genius of
the author. Writing was a work of honor and distinction, not something requiring an honest day’s pay.8 Money earned in the growing
printing industry mostly stayed in the pockets of publishers, while
the author received literally an honorarium, a flat sum that served
as a “token of esteem” (Woodmansee 1996, 42). It is only once
authors began to voice demands for securing their material and
political independence from patronage and authority that they also
started to make claims for rightful remuneration.
Thus, before it was made a matter of law, copyright was a matter of
politics and economy.

Copyright, Labor, and Economic Domination
The full-­blown affirmation of the Romantic author-­function marks
the historic moment where a compromise is established between
the right of publishers to the economic exploitation of works and
the right of authors to rightful compensation for those works. Economically, this redistribution from publishers to authors was made

possible by the expanding market for printed books in the eighteenth and nineteenth centuries, while politically this was catalyzed
by the growing desire for the autonomy of scientific and literary
production from the system of feudal patronage and censorship
in gradually liberalizing and modernizing capitalist societies. The
newfound autonomy of production was substantially coupled to
production specifically for the market. However, this irenic balance
could not last for very long. Once the production of culture and
science was subsumed under the exigencies of the generalized
market, it had to follow the laws of commodification and competition from which no form of commodity production can escape.
By the beginning of the twentieth century, copyright expanded to
a number of other forms of creativity, transcending its primarily
literary and scientific ambit and becoming part of the broader
set of intellectual property rights that are fundamental to the
functioning and positioning of capitalist enterprise. The corporatization of the production of culture and knowledge thus brought
about a decisive break from the Romantic model that singularized
authorship in the person of the author. The production of cultural
commodities nowadays involves a number of creative inputs from
both credited (but mostly unwaged) and uncredited (but mostly
waged) contributors. The “moral rights of the author,” a substantive
link between the work and the person of the author, are markedly
out of step with these realities, yet they still perform an important
function in the moral economy of reputation, which then serves as
the legitimation of copyright enforcement and monopoly. Moral
rights allow easy attribution; incentivize authors to subsidize
publishers by self-­financing their own work in the hope of topping
the sales charts, rankings, or indexes; and help markets develop
along winner-­takes-­all principles.
The level of concentration in industries primarily concerned with
various forms of intellectual property rights is staggering. The film
industry is a US$88 billion industry dominated by six major studios
(PwC 2015c). The recorded music industry is an almost US$20
billion industry dominated by only three major labels (PwC 2015b).

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60

The publishing industry is a US$120 billion industry where the
leading ten companies earn in revenues more than the next forty
largest publishing groups (PwC 2015a; Wischenbart 2014).

The Oligopoly and Academic Publishing
Academic publishing in particular draws the state of play into stark
relief. It’s a US$10 billion industry dominated by five publishers and
financed up to 75 percent from library subscriptions. It’s notorious
for achieving extreme year-­on-­year profit margins—­in the case of
Reed Elsevier regularly over 30 percent, with Taylor and Francis,
Springer, Wiley-­Blackwell and Sage barely lagging behind (Larivière,
Haustein, and Mongeon 2015). Given that the work of contributing
authors is not paid but rather financed by their institutions (provided, that is, that they are employed at an institution) and that
these publications nowadays come mostly in the form of electronic
articles licensed under subscription for temporary use to libraries
and no longer sold as printed copies, the public interest could be
served at a much lower cost by leaving commercial closed-­access
publishers out of the equation entirely.
But that cannot be done, of course. The chief reason for this is that
the system of academic reputation and ranking based on publish-­
or-­perish principles is historically entangled with the business of
academic publishers. Anyone who doesn’t want to put their academic career at risk is advised to steer away from being perceived
as reneging on that not-­so-­tacit deal. While this is patently clear
to many in academia, opting for the alternative of open access
means not playing by the rules, and not playing by the rules can
have real-­life consequences, particularly for younger academics.
Early career scholars have to publish in prestigious journals if they
want to advance in the highly competitive and exclusive system of
academia (Kendzior 2012).
Copyright in academic publishing has thus become simply a mechanism of the direct transfer of economic power from producers to
publishers, giving publishers an instrument for maintaining their

stranglehold on the output of academia. But publishers also have
control over metrics and citation indexes, pandering to the authors
with better tools for maximizing their impact and self-­promotion.
Reputation and copyright are extortive instruments that publishers
can wield against authors and the public to prevent an alternative
from emerging.9
The state of the academic publishing business signals how the
“copyright industries” in general might continue to control the
field as their distribution model now transitions to streaming or
licensed-­access models. In the age of cloud computing, autonomous infrastructures run by communities of enthusiasts are
becoming increasingly a thing of the past. “Copyright industries,”
supported by the complicit legal system, now can pressure proxies
for these infrastructures, such as providers of server colocation,
virtual hosting, and domain-­name network services, to enforce
injunctions for them without ever getting involved in direct, costly
infringement litigation. Efficient shutdowns of precarious shadow
systems allow for a corporate market consolidation wherein the
majority of streaming infrastructures end up under the control of a
few corporations.

Illegal Yet Justified, Collective Civil
Disobedience, Politicizing the Legal
However, when companies do resort to litigation or get involved in
criminal proceedings, they can rest assured that the prosecution
and judicial system will uphold their interests over the right of
public to access culture and knowledge, even when the irrationality
of the copyright system lies in plain sight, as it does in the case of
academic publishing. Let’s look at two examples:
On January 6, 2011, Aaron Swartz, a prominent programmer
and hacktivist, was arrested by the MIT campus police and U.S.
Secret Service on charges of having downloaded a large number
of academic articles from the JSTOR repository. While JSTOR, with
whom Swartz reached a settlement and to whom he returned the

61

62

files, and, later, MIT, would eventually drop the charges, the federal
prosecution decided nonetheless to indict Swartz on thirteen
criminal counts, potentially leading to fifty years in prison and a
US$1 million fine. Under growing pressure by the prosecution
Swartz committed suicide on January 11, 2013.
Given his draconian treatment at the hands of the prosecution
and the absence of institutions of science and culture that would
stand up and justify his act on political grounds, much of Swartz’s
defense focused on trying to exculpate his acts, to make them less
infringing or less illegal than the charges brought against him had
claimed, a rational course of action in irrational circumstances.
However, this was unfortunately becoming an uphill battle as the
prosecution’s attention was accidentally drawn to a statement
written by Swartz in 2008 wherein he laid bare the dysfunctionality
of the academic publishing system. In his Guerrilla Open Access
Manifesto, he wrote: “The world’s entire scientific and cultural heritage, published over centuries in books and journals, is increasingly
being digitized and locked up by a handful of private corporations. . . . Forcing academics to pay money to read the work of their
colleagues? Scanning entire libraries but only allowing the folks at
Google to read them? Providing scientific articles to those at elite
universities in the First World, but not to children in the Global
South? It’s outrageous and unacceptable.” After a no-­nonsense
diagnosis followed an even more clear call to action: “We need
to download scientific journals and upload them to file sharing
networks. We need to fight for Guerilla Open Access” (Swartz 2008).
Where a system has failed to change unjust laws, Swartz felt, the
responsibility was on those who had access to make injustice a
thing of the past.
Whether Swartz’s intent actually was to release the JSTOR repository remains subject to speculation. The prosecution has never
proven that it was. In the context of the legal process, his call to
action was simply taken as a matter of law and not for what it
was—­a matter of politics. Yet, while his political action was pre-

empted, others have continued pursuing his vision by committing
small acts of illegality on a massive scale. In June 2015 Elsevier won
an injunction against Library Genesis, the largest illegal repository
of electronic books, journals, and articles on the Web, and its
subsidiary platform for accessing academic journals, Sci-­hub. A
voluntary and noncommercial project of anonymous scientists
mostly from Eastern Europe, Sci-­hub provides as of end of 2015
access to more than 41 million academic articles either stored
in its database or retrieved through bypassing the paywalls of
academic publishers. The only person explicitly named in Elsevier’s
lawsuit was Sci-­hub’s founder Alexandra Elbakyan, who minced no
words: “When I was working on my research project, I found out
that all research papers I needed for work were paywalled. I was
a student in Kazakhstan at the time and our university was not
subscribed to anything” (Ernesto 2015). Being a computer scientist,
she found the tools and services on the internet that allowed her to
bypass the paywalls. At first, she would make articles available on
internet forums where people would file requests for the articles
they needed, but eventually she automated the process, making
access available to everyone on the open web. “Thanks to Elsevier’s
lawsuit, I got past the point of no return. At this time I either have
to prove we have the full right to do this or risk being executed like
other ‘pirates’ . . . If Elsevier manages to shut down our projects or
force them into the darknet, that will demonstrate an important
idea: that the public does not have the right to knowledge. . . .
Everyone should have access to knowledge regardless of their
income or affiliation. And that’s absolutely legal. Also the idea
that knowledge can be a private property of some commercial
company sounds absolutely weird to me” (Ernesto 2015).
If the issue of infringement is to become political, a critical mass
of infringing activity has to be achieved, access technologically
organized, and civil disobedience collectively manifested. Only in
this way do the illegal acts stand a chance of being transformed
into the legitimate acts.

63

64

Where Law Was, there Politics Shall Be
And thus we have made a full round back to where we started. The
parallel development of liberalism, copyright, and capitalism has
resulted in a system demanding that the contemporary subject
act in accordance with two opposing tendencies: “more capitalist
than capitalist and more proletarian than proletariat” (Deleuze
and Guattari 1983, 34). Schizophrenia is, as Deleuze and Guattari
argue, a condition that simultaneously embodies two disjunctive
positions. Desire and blockage, flow and territory. Capitalism is
the constant decoding of social blockages and territorializations
aimed at liberating the production of desires and flows further
and further, only to oppose them at its extreme limit. It decodes
the old socius by means of private property and commodity
production, privatization and abstraction, the flow of wealth and
flows of workers (140). It allows contemporary subjects—­including
corporate entities such as the MIT Press or Sony—­to embrace their
contradictions and push them to their limits. But capturing them in
the orbit of the self-­expanding production of value, it stops them
at going beyond its own limit. It is this orbit that the law sanctions
in the present, recoding schizoid subjects into the inevitability of
capitalism. The result is the persistence of a capitalist reality antithetical to common interest—­commercial closed-­access academic
publishing—­and the persistence of a hyperproletariat—­an intellectual labor force that is too subsumed to organize and resist the
reality that thrives parasitically on its social function. It’s a schizoid
impasse sustained by a failed metaphor.
The revolutionary events of the Paris Commune of 1871, its mere
“existence” as Marx has called it,10 a brief moment of “communal
luxury” set in practice as Kristin Ross (2015) describes it, demanded
that, in spite of any circumstances and reservations, one takes a
side. And such is our present moment of truth.
Digital networks have expanded the potential for access and
created an opening for us to transform the production of knowledge and culture in the contemporary world. And yet they have
likewise facilitated the capacity of intellectual property industries

to optimize, to cut out the cost of printing and physical distribution.
Digitization is increasingly helping them to control access, expand
copyright, impose technological protection measures, consolidate
the means of distribution, and capture the academic valorization
process.
As the potential opening for universalizing access to culture and
knowledge created by digital networks is now closing, attempts at
private legal reform such as Creative Commons licenses have had
only a very limited effect. Attempts at institutional reform such as
Open Access publishing are struggling to go beyond a niche. Piracy
has mounted a truly disruptive opposition, but given the legal
repression it has met with, it can become an agent of change only if
it is embraced as a kind of mass civil disobedience. Where law was,
there politics shall be.
Many will object to our demand to replace the law with politicization. Transitioning from politics to law was a social achievement
as the despotism of political will was suppressed by legal norms
guaranteeing rights and liberties for authors; this much is true. But
in the face of the draconian, failed juridical rationality sustaining
the schizoid impasse imposed by economic despotism, these developments hold little justification. Thus we return once more to the
words of Aaron Swartz to whom we remain indebted for political
inspiration and resolve: “There is no justice in following unjust laws.
It’s time to come into the light and, in the grand tradition of civil
disobedience, declare our opposition to this private theft of public
culture. . . . With enough of us, around the world, we’ll not just send
a strong message opposing the privatization of knowledge—­we’ll
make it a thing of the past. Will you join us?” (Swartz 2008).

Notes
1

We initially named our project Public Library because we have developed it
as a technosocial project from a minimal definition that defines public library
as constituted by three elements: free access to books for every member of
a society, a library catalog, and a librarian (Mars, Zarroug and Medak, 2015).
However, this definition covers all public libraries and shadow libraries
complementing the work of public libraries in providing digital access. We have
thus decided to rename our project as Memory of the World, after our project’s

65

initial domain name. This is a phrase coined by Henri La Fontaine, whose men-

66

tion we found in Markus Krajewski’s Paper Machines (2011). It turned out that
UNESCO runs a project under the same name with the objective to preserve
valuable archives for the whole of humanity. We have appropriated that objective. Given that this change has happened since we drafted the initial version
of this text in 2015, we’ll call our project in this text with a double name Public
Library/Memory of the World.
2

Sony Pictures Entertainment became the owner of two (MGM, Columbia Pictures) out of eight Golden Age major movie studios (“Major Film Studio,” Wikipedia 2015).

3

In 2012 Sony Music Entertainment is one of the Big Three majors (“Record
Label,” Wikipedia 2015).

4

Since this anecdote was recounted by Marcell in his opening keynote in the
Terms of Media II conference at Brown University, we have received another
batch of takedown notices from the MIT Press. It seemed as no small irony,
because at the time the Terms of Media conference reader was rumored to be
distributed by the MIT Press.

5

“In law, authorship is a point of origination of a property right which, thereafter, like other property rights, will circulate in the market, ending up in the
control of the person who can exploit it most profitably. Since copyright serves
paradoxically to vest authors with property only to enable them to divest that
property, the author is a notion which needs only to be sustainable for an
instant” (Bently 1994).

6

For more on the formal freedom of the laborer to sell his labor-­power, see
chapter 6 of Marx’s Capital (1867).

7

For a more detailed account of the history of printing privilege in Great Britain,
but also the emergence of peer review out of the self-­censoring performed by
the Royal Academy and Académie de sciences in return for the printing privilege, see Biagioli 2002.

8

The transition of authorship from honorific to professional is traced in Woodmansee 1996.

9

Not all publishers are necessarily predatory. For instance, scholar-­led open-­
access publishers, such as those working under the banner of Radical Open
Access (http://radicaloa.disruptivemedia.org) have been experimenting with
alternatives to the dominant publishing models, workflows, and metrics, radicalizing the work of conventional open access, which has by now increasingly
become recuperated by big for-­profit publishers, who see in open access an
opportunity to assume the control over the economy of data in academia.
Some established academic publishers, too, have been open to experiments
that go beyond mere open access and are trying to redesign how academic
writing is produced, made accessible, and valorized. This essay has the good
fortune of appearing as a joint publication of two such publishers: Meson Press
and University of Minnesota Press.

10

“The great social measure of the Commune was its own working existence”
(Marx 1871).

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