ISPs and Copyright Infringement: The Legal Battle Over Liability - Episode 618 of the Community Broadband Bits Podcast

Alfred Yen (00:07):
That's the question that's involved in this case, should simply notifying Cox by extension any other Internet Service Provider that one of its subscribers as infringing be enough to put that service provider on. Notice that they're responsible now for any continuing infringement.

Christopher Mitchell (00:24):
Welcome to another episode of the Community Broadband Bits podcast. [00:00:30] I'm Christopher Mitchell at the Institute for Local. I'm in St. Paul, Minnesota where it is once again a beautiful, beautiful day. We've had about 30 top 10 weather days this year, so that's been great. Today I'm speaking with Professor Alfred Yen, who is Professor of Law and Dean's Distinguished Scholar at Boston College Law School. Welcome to the show.

Alfred Yen (00:52):
Thank you very much. Glad to be here.

Christopher Mitchell (00:54):
This case, we're going to talk about Cox and copyright and downloading music without paying it for [00:01:00] it or at least being accused of such, but just give us a brief sense of what your specialty is and make sure you note the part about sports.

Alfred Yen (01:08):
My principal academic specialty is copyright law, which explains my involvement with cases like this. I also teach in the sports law area in tort law and there is some crossover between tort law and this case, which is why I'm particularly interested in it.

Christopher Mitchell (01:24):
Right, so we're going to talk about this case and the facts and how [00:01:30] we're hoping the Supreme Court will take it because we're kind of in a bad position right now with decisions that have been made by lower courts. We're going to try not to get too heavy into the law for people that are more interested in how this has an impact on Internet Service Providers, but what are the key facts as you would lay them out briefly?

Alfred Yen (01:48):
I know your listeners know not everybody who gets Internet service performs as an angel with his Internet service and some people download infringing copies of music. [00:02:00] People do other terrible things on the Internet too. It's important to note lots of good things, right? You may do work over the Internet, you may do your medical care, handle your finances. There's a lot of very, very important things that people do every day over the Internet, and that's important to keep in mind as a critical fact in this case. The question in this case is really who's responsible when somebody downloads infringing music over the Internet, the position of the music industry is that [00:02:30] as long as they notify the Internet Service Provider about the infringing behavior of its customer, if they do not cut the service of the customer off, they become liable for all the infringement that the customer commits.

(02:46):
This is a complicated question. It's not as simple as Johnny's a bad voice. We're going to take away his Internet service because the Internet service is not just like a lollipop, as I mentioned earlier, because the Internet service [00:03:00] supports many critical things. Cutting somebody's Internet service off means taking away vital resources to their lives, and if the subscriber is a hospital or a business or something like that, cutting their Internet service off is really a big deal. That's the question that's involved in this case. Should simply notifying Cox and by extension any other Internet Service Provider that one of its subscribers is infringing, be enough to put that service provider on notice [00:03:30] that they're responsible now for any continuing infringement?

Christopher Mitchell (03:33):
Yes, I think there's a bunch of ways that we could go at this and I would like to identify a few things and then move right past them. One is that the allegations of infringing actions and downloading music are not always accurate. Sometimes they make mistakes. The industry can accidentally identify people who actually have not infringed. We have seen that the recording industry [00:04:00] is, in this case, the big labels and some of the small labels, but not individual artists or things like that, as best I can tell. And so we are taking the position of the labels, I think in this case. Is that right?

Alfred Yen (04:12):
Yeah, the plaintiffs are largely recognizable names in the music business. Yes, I would say that's true. I haven't to be honest, looked at the name of every plaintiff in the case, but the name plaintiff is Sony Music, so

Christopher Mitchell (04:25):
I think there's 10 labels involved, so I get annoyed when people talk about the [00:04:30] Internet Service Provider industry and then they only talk about the big cable companies because there's so many different ones. But for people who aren't familiar, Cox is one of the larger cable companies in the nation. It's also, oddly enough a privately owned one as opposed to the companies like at and t and others that are traded publicly. And then in this case, in 2019, a Virginia jury found that Cox basically screwed up and had not adequately responded to the copyright [00:05:00] infringement notifications and awarded a large sum a billion dollars in a penalty that's being fought about. And then the Fourth Circuit basically said the penalty was too great, but still that Cox could be held liable for it and specifically if they found that Cox had committed secondary copyright infringement by failing to address piracy basically. So that's where we are basically, and both sides want the Supreme Court to resolve this in different ways, but one of the [00:05:30] things that I found super interesting is that other ISPs have settled quietly with the labels, and I don't really know if that means that if Cox would just write a check that the industry would be okay with the failure to address the copyright concerns or what, but I thought that was interesting.

Alfred Yen (05:47):
I can't speak for what would make the music industry satisfied.

(05:51):
I believe that the music industry's desire is to make the Internet Service Providers a collection point for revenue. [00:06:00] If you want to listen to music over the Internet, there's lots of things you could do. You could go to Spotify and you would pay to listen to music. To the extent that there are some individuals who leak outside the paid systems and then listen to music for free, the mucus industry would like to make them pay. They can't go after those people individually, so they would like to make the service providers the point of collection for those fees. I think for your audience, the challenging [00:06:30] question is, let's suppose hypothetically we said, all right, Comcast Cox, or maybe a local community service provider is responsible for infringement committed by its subscribers. How would the service provider respond? They probably would find it difficult to, if you will, meter the infringement by each person.

(06:55):
I'm not sure we'd want this to have our service providers looking over our shoulders and going, [00:07:00] ah, that looks like infringement to us, so we're going to charge you so now we can pay the music business. They'd more likely raise the cost of Internet service generally to pay a portion of that raised cost over the music business in settlement for the infringement. That's the next most obvious thing that I can think about, which effectively means that people who don't commit copyright infringement over the Internet wind up subsidizing the people who do. As an Internet user. I'm not sure I'm too keen on that. [00:07:30] I don't download music over the Internet, so why should I pay for somebody who does?

Christopher Mitchell (07:34):
Right, and in particular from the rest of us that are not engaged in that activity, we don't want to see the immediate harm potentially to ourselves of having service providers keeping records of all the things that we're doing online. It's kind of the opposite of what a lot of the people who listen to this show are interested in, but also the cost to a smaller ISP to be able to do that are significant, whether that is a community run, [00:08:00] ISP or a what we sometimes call two guys in a truck with the wireless Internet Service Providers often in more rural areas to try and set these things up. You mentioned something I want to come back to before we move on though, and that was families use the Internet, and so I don't know, and I know that you've filed a brief with the court for your own reasons, making points as to why they should consider this for review. [00:08:30] I don't know if you touched on that, but one of the other things I wanted to make sure we touched on is that you could have a situation in which everyone that uses a wireless access point would be cut off for one person having infringed in some way.

Alfred Yen (08:46):
That's correct. It could be true that the acts of infringement are that Billy's buddy Sam comes over while they've all got their laptops hooked up to the home device. Sam is the one downloading [00:09:00] music and Billy's family gets their Internet service cut off. It's also possible that this could happen at a business, so you could imagine a large office would have an Internet account and one person or maybe even a guest at the office would download some infringing music and again, maybe they're going to get their Internet service cut off. From my point of view, one of the things that's really tricky in this situation is how society thinks through the benefits and costs [00:09:30] of precipitously cutting somebody's Internet service off. Long ago in the last century, I guess when the Internet was getting going, the Internet was kind of like a curiosity. It was almost like a toy you had and if the result of misbehaving with your toy is that you lose your toy, you might say, well, all right, as is now happened with the Internet, people do really important things over the Internet. They talk to their employers, they take care of their healthcare, they pay their bills, so on and so forth. Cutting somebody's Internet service off [00:10:00] could be a big deal in their lives. Somebody could even theoretically have life-threatening consequences if they can't get in touch with their doctor or something. And so saying that we want to effectively force people to cut Internet service off upon being notified of a subscriber's infringement is potentially risking consequences that I'm not sure we want to risk for this.

Christopher Mitchell (10:24):
For me, that's where I often try to look to history and I think academics often do as well, and so [00:10:30] we've dealt before with what happens if bank robbers use a telephone to plan their caper. They do not lose their telephone service. It was found to be, and I think people had considered this back in the day, when people use the telephone for criminal reasons, they don't take it away from the whole family.

Alfred Yen (10:49):
Yes, so I'm not sure that I'm the right person to settle this debate about how we characterize Internet Service Providers, but service providers [00:11:00] would love to be treated like the phone company that we don't pay any attention to what goes over phone lines. They're just like the phone company, and we could see some reason for that. Of course, your service provider is busy selling you all kinds of ancillary services to go along with their Internet service in a way that maybe the phone provider doesn't. Your cable tv, for example, and different kinds of service providers act in different ways. So I'm not sure that that blanket characterization is always going [00:11:30] to apply.

Christopher Mitchell (11:31):
The analogy breaks down because they're not one-to-one, but I just like to remind people that this is not the first time we've had to deal with a situation where someone is using what we would call in my mind, what I would call a essential infrastructure or a utility service to do something that we all would actually like to discourage. I think perhaps not every last person, but most of us actually want to make sure that people who create content [00:12:00] are compensated in some way, and we don't want to find ways, encourage ways of evading that, but at the same time, there has to be a balancing act.

Alfred Yen (12:08):
Well, that's right. I mean, something that I've noted in some of my scholarship, the particular legal interpretation of the law urged by the record companies in this case would make the electric company responsible for your infringement. So if they didn't send the notices to Cox but sent them to Pacific Gas and Electric instead, there's [00:12:30] nothing in their legal interpretation as I read it other than the conclusion, well, I guess Pacific Gas and Electric needs to turn your power off now, and I think we really think that's a bad idea to just turn people's power off.

Christopher Mitchell (12:43):
There are a number of things that I think some people might be interested in pursuing on their own. I guess I would say that there's a mismatch between the industry's interpretation of what might be infringement and what others might pursue [00:13:00] between making available is I think one of the key phrases whether one is actually distributing or simply making available for distribution. And it seems to me that when I review the last 15 years of reading about these things on tech dirt and other tech news sites, that there's often, there's something that if we saw a criminal process, we would expect a higher standard of proof and a common sense of what is meant by these different terms and what constitutes breaking [00:13:30] the law. Now, I don't want to put you on the spot for things that you're not writing on, so if you want to comment on that, that would be great, but also I want to get a sense of what you focused on in your brief.

Alfred Yen (13:42):
Well, let me deal with the first question. When the music industry says it's notified Cox of infringement, I think technically what they mean is that they have notified Cox of unauthorized downloads of music files.

Christopher Mitchell (13:56):
If we pause there for one second, and the way that they do that I think is [00:14:00] they have perhaps subcontractors or they have some automated service which is scanning to see an activity that it perceives to be an infringement and then letting Cox know of the time and the IP address that this activity took place. Right. I think that's more or less what

Alfred Yen (14:17):
That's roughly as I understand it also correct because of doctrines like fair use, it's always possible that in any given circumstance that unauthorized download is not in fact an infringement, and the music [00:14:30] industry's position in this litigation is we can presume that it's infringement in reality, there's a way it's supposed to work. If it's going to work the way it's supposed to work, then everybody needs to be well-informed about copyright law and their rights. That's not always possible these days, I believe. When a service provider like Cox gets a complaint like this, they notify the subscriber that something is going on, and typically what happens [00:15:00] is the subscriber goes, well, I guess I better stop doing that. That's typically what happens, even if they might've had legal reason to do that. So some smaller subset of all those who were accused of infringement actually persist.

Christopher Mitchell (15:13):
The numbers in the case suggested that less than 1% of Cox's users had received these. Of those that did receive it, 95% of them ceased the activity after they were notified. So yes, what you're saying is not only, I think true the facts of the case seem to suggest that it is true.

Alfred Yen (15:30):
[00:15:30] Certainly that is Cox's position. I have not seen the underlying proof of those facts, but I'll take Cox's brief at its word on that. So this actually gets a little bit to the legalities of the brief that I filed. The decision below in the Fourth Circuit takes the position that Cox is culpably responsible for the infringement committed by its subscribers after notice because the notices received from the automated service that you mentioned MarkMonitor [00:16:00] make Cox substantially certain that those accounts will continue to infringe. There is tort doctrine that suggests, although I'm not sure again, let's not get too legalistic about this, but assuming for the sake of discussion that one is culpably responsible for failing to stop something that someone is substantially certain for consequences, that one is substantially certain of It isn't clear to me that Cox is substantially certain that these people are going to infringe [00:16:30] because upon receiving the notice from MarkMonitor, if their anti infringement program really results in 95% of those people stopping infringement, they're not substantially certain those accounts will infringe. And so I think that's one of the errors the lower court made is that they didn't really pay attention to the details of the facts and how they stack up with the law.

Christopher Mitchell (16:53):
One of the things that I saw, which again, I know that you're, you're not every law professor in the [00:17:00] world's knowledge all wrapped into one, but I had seen someone writing about this citing Ashcroft versus the Free Speech Coalition saying that is well established as a general rule. The government may not suppress lawful speech as a means to suppress unlawful speech. Now, first of all, I don't know if it's actually the government doing it because we're asking a private corporation to do it, so it may not be the same, but I was just curious if that's something that has come up as you're thinking about this, which is precisely [00:17:30] what you're saying. We're going to cut people off from the entire Internet if someone is alleged to have infringed on one aspect of it.

Alfred Yen (17:38):
Although one could cast this in free speech terms, I don't think that this case is likely to be decided on them because although downloading music to listen to is a behavior that could be considered speech enhancing, and certainly although some of the things that you [00:18:00] do on the Internet clearly are speech, this doesn't shake out as well, we're censoring his views about cancer in order to suppress his noxious views about Nazis or something like that. That's not what this case is really about. Now, that having been said, what you mentioned about the Ashcroft case does encapsulate a portion of what is going on here because when we talk about the government may not infringe law or [00:18:30] suppress lawful speech in order to suppress unlawful speech, what we're really saying is that when government takes an action, and in this case government takes an action through the court system, there are trade-offs.

(18:42):
It's not the case that we can precisely stop every bad actor by stopping only the bad actions and none of the good actions that flow from that. And that's really what Cox's position is in this litigation is that if you cut the Internet service off from [00:19:00] every subscriber that we get a mark monitor notice for, there's going to be some pretty severe, if the word I would use is collateral damage because yeah, you might've just cut the Internet service for a hospital off. That would be terrible, right? You might've just cut off a police department from its Internet service. That would be terrible. So that to just say as a blanket rule, you're responsible for all of that infringement Cox's position, which I think has some merit, isn't that overreaching?

Christopher Mitchell (19:30):
[00:19:30] And additionally, you could be cutting it off to people that have no other means of getting online. So it's not just that it's inconvenient and that they would have to change a service provider and then try to better monitor their behavior or their behavior of guests or whatever. They may have no other options, which is a significant issue.

Alfred Yen (19:51):
It could be in some cases that that is true. And again, I know it's a relatively extreme example, but also I don't think it's entirely unheard of. If [00:20:00] you cut the Internet service to a hospital off, maybe a heart transplant patient doesn't find out the heart's available in time.

Christopher Mitchell (20:06):
Yes. Yeah, there's all kinds of things, frankly, you and I think if this were to happen, which I hope that it won't no matter what comes out, but the kinds of things that will come up will be surprising. And no amount of brainstorming right now will surprise us for how weird things will reverberate through is my experience of watching these things.

Alfred Yen (20:26):
Absolutely. We don't know what people are doing out there. That turns [00:20:30] out to be really important. We don't know

Christopher Mitchell (20:33):
Now if the Supreme Court doesn't take this up, and I have to say that the Supreme Court at this point is taking, what, 50 or 60 cases a year, and presumably there's, I don't know, lots cases that are presented to it, maybe a few hundred that experts would say have a good shot. It doesn't mean that it's likely to necessarily take this from what I'm seeing.

Alfred Yen (20:55):
That's right. We don't know if the Supreme Court will take this. The reasons for them [00:21:00] to take it are first other courts have interpreted the same law that the Fourth Circuit interpreted in ways that are not fully consistent. So there's an argument that those are the cases the Supreme Court takes as we got to get all the lower courts on the same page. The second would be if the Supreme Court is convinced that allowing the Fourth Circuit decision to stand would take the law in the wrong direction. That's something that I happen to believe is true, but I can't tell [00:21:30] you the justices would agree with me. I do think that someday the Supreme Court's going to have to take an Internet Service Provider case like this. Could it be this one? It could be. Or the Supreme Court could say, ah, let's let it stew out there a little longer and we'll wait for the next one to come along.

Christopher Mitchell (21:46):
So I think if I'm interpreting what you're saying correctly, if the Supreme Court doesn't hear this and then perhaps the ninth Circuit comes to the exact same, has a very similar case and comes to the opposite conclusion at that point, would it be more [00:22:00] or is there already sufficient difference between the circuits that the Supreme Court might be that motivated to take it?

Alfred Yen (22:07):
There's certainly sufficient difference between the circuits that the Supreme Court could with a very straight face say, we're taking this to resolve a conflict among the circuits. Absolutely. I mean, could the conflict be bigger? I mean, sure. Right, but there's enough there that they could act if they cared to. Part of the reason we can't tell whether the Supreme Court would take this case is the Supreme Court might think this is a case worth taking, but [00:22:30] in the list of priorities that they have given other cases that are there, they might say, look, we just can't do it this year. That's possible.

Christopher Mitchell (22:37):
At this point, one of the things that I feel like I naturally fall into which is incorrect, is assuming that something will be different the day that we know what the Supreme Court has accepted and what it has not accepted. But right now, if the Supreme Court doesn't hear it, is it the case that the labels feel emboldened to try and force more Internet Service Providers [00:23:00] to cut off customers as a result of accused infringement?

Alfred Yen (23:04):
I would think the labels would feel emboldened. I imagine that even with the Fourth Circuit decision now, they feel emboldened. I'm sure they're busy suing other service providers elsewhere, and those cases are going through the legal system right now.

Christopher Mitchell (23:17):
Yeah, I believe there's one with Verizon. I am not sure that I've heard of anyone with smaller ISPs, but I have to assume that they will start getting letters from lawyers that are [00:23:30] kind of, or perhaps from the industry trade groups saying, you're at risk if you're not removing people from service. If we send you letters about infringement, it is one of those things that I don't run an ISP myself, so I don't know how they react to this sort of a thing, but it's really quite scary to me because what I would expect to see them is some ISPs to do what I would hope when you say, no, we're not going to do that. But others to say, well, if that's what we [00:24:00] have to do to stay out of the courts, that's what we're going to do.

Alfred Yen (24:03):
Lemme offer a couple of perspectives here deliberately contrasting the music industry's position is that, well, we have property rights. I mean, they're copyright rights and somebody's got to be responsible when our rights are violated, and I don't want to underplay that as not as being something that we just don't care about. I think we do care about that. I think the question is what consequences are we willing to accept in order [00:24:30] to hammer down every last instance of copyright infringement? Now, the second thing that I'd like to make sure we focus on here is the structure of damages in copyright law. In an ordinary lawsuit, the damages that the plaintiff can get are the value of the thing that was lost. So if I fall asleep at the wheel and run over your mailbox, all you can get from me is the cost of putting up [00:25:00] another mailbox.

(25:01):
There's nothing else. Now, that is one of the things that the music industry could get for violation of copyright rights, the value of a song. But of course, each download's not worth a whole lot these days, given what a Spotify subscription costs, there's something else in copyright law called statutory damages, and the plaintiff can elect to take statutory damages in lieu of the other sort of damages, [00:25:30] compensatory damages, and those damages can reach into the five figures per infringement. And that's what jacks the cost to Cox, for example, so high. And so when we start talking about small service providers, not a multi bazillion dollar company like Cox, and somebody says, well, look, it's not that it's 25 cents a song or something like that. We think we're going to be able to get the courts to give us a thousand dollars [00:26:00] a song. Well, then I can understand why they would sweat and say, well, look, that would make us bankrupt. If we lost that case, we'd be bankrupt. And so then they would say, oh, all right. Well, what kind of check will you take from us to make this go away? Which is, as I said earlier, I think in the end what the music industry would like to make the service providers a point of collection for them.

Christopher Mitchell (26:24):
When I was digging back in to refresh myself on this, it took me a little while to find her, [00:26:30] but it reminds me of Jami Thomas, a woman here from Minnesota actually who was found. The two have infringed. She had made available, I believe two albums and 24 songs or something like that, and was asked to pay hundreds of thousands of dollars for 24 songs, and there was opportunities to negotiate down. And one of the things that I saw that was interesting was reading news [00:27:00] coverage on a news site from the music industry saying that the music industry wanted to put the responsibility on the ISPs because they didn't like the negative publicity of going after a single mother and not trying to collect hundreds of thousands of dollars from her.

Alfred Yen (27:18):
Well, that is one of the reasons they would like to go after the ISPs. Absolutely. If somebody says, guess what, I'm suing Comcast, and nobody's going to get too upset about that, [00:27:30] but if somebody says, I'm suing a family of four with an income of $65,000 a year for several hundred thousand dollars of damages for something that their 13-year-old child did, that doesn't sound so nice. Right? That sounds pretty

Christopher Mitchell (27:45):
Nasty. Yes.

Alfred Yen (27:46):
I think it's more than simply the optics of suing each individual subscriber. It's also an economic decision. If they were to go after each person for copyright infringement, they would have to prove [00:28:00] that case against each person. Now, granted, many of those people might not defend themselves because hiring lawyers is expensive, so that's one problem. They'd have to prove those cases. Second, even if they won them, they'd have to collect the money. And if you want to collect a hundred thousand dollars from Ms. Thomas's family, my guess is they don't have it. There's nothing you can do, right? Correct.

Christopher Mitchell (28:23):
Yes. She declared bankruptcy. I believe

Alfred Yen (28:25):
If you're going to collect a billion dollars from Comcast, they actually might have it. [00:28:30] And so it's an economic decision as well. It's economically efficient for them to have one big lawsuit against the defendant who's got the money. Then 50,000 little lawsuits against 50,000 defendants, most of whom do not have the money.

Christopher Mitchell (28:45):
I don't feel that just because you have identified the deep flaws with the music industry, labels coming after the ISPs that you should necessarily tell them how they [00:29:00] should do it. But you had said you think it would be important to balance these things, and I'm curious if in the work that you've done, if you have a sense that there's a solution that would work better both to discourage the infringement as well as not going overboard with it.

Alfred Yen (29:18):
I don't know if I have a solution, because obviously if it was out there, somebody might've tried it by. Now.

(29:25):
When I think about this, the decision to cut somebody's Internet service off is [00:29:30] sort of like, it's the whole enchilada. It's the most draconian thing you can do to slow somebody who's a persistent infringer down. This is probably something your listeners know better than I would, but I would hypothesize that, for example, if certain applications are used to commit this infringement, like file sharing software of a certain type, that they might be able to disable the use of that file sharing software on a particular account. I would imagine that could be done and that would have the consequence of slowing down a lot of infringement. [00:30:00] If you're using one of these big file sharing services, that would slow you down a lot, but it wouldn't have the drastic effect of, wait a minute, I can't get my email, I can't talk to my doctor. I can't get into my bank account.

Christopher Mitchell (30:11):
Yes. Although what's fun is, I'm not sure if you're familiar, Comcast was doing that on the order of 12 years ago or so with BitTorrent, and they were doing it in a way that actually had some negative results for some business software and a few other things. But I think the thing [00:30:30] that people were most frustrated with is they refused to disclose it publicly to their customers. And so I do think that with what you're saying, if an ISP was to say, our policy is if you are accused of infringement in multiple ways, we will use this solution to try to interfere with your use of that software. As long as it's disclosed, I think it would fall within the reasonableness of an ISP taking action. So for the people in here that remember [00:31:00] that, it's just an interesting sort of bit of history.

Alfred Yen (31:04):
That's right. One of the things I think the law should be doing is asking what is the reasonable accommodation between the responsibility of the service provider and the consequences of actions the service provider might take versus the copyright holder's understandable desire to have some security of its rights. And I think that long ago, maybe cutting off Internet service was all you could do, [00:31:30] but today, the sophistication of Internet service is much greater and it might allow much more fine targeted solutions. So one possibility would be certain applications. Another might be to block certain IP addresses. If you know the address from which the downloads are coming, the illegal downloads are coming, you could block access to that address for that particular account. I would imagine a service product could do that. And again, that would be far more targeted.

Christopher Mitchell (31:55):
Right. And I think that some of the people who run ISPs might be shuttering a bit at the thought of having to [00:32:00] take responsibility for this and the fact that now an IP address could be used by multiple different servers of entirely unrelated sites. But I certainly think all of those bad ideas or ideas that have negative consequences are far preferable to yanking the entire service from an account that has an accusation of infringement. Is there anything else that we should cover before I let you go?

Alfred Yen (32:26):
I can't think of it off the top of my head, to be honest. I think it's been a really fun [00:32:30] discussion.

Christopher Mitchell (32:31):
Well, I'm glad that you said that because I feel like sometimes a person comes on and they don't really, I sort of bounce around from idea to idea without a clear path. So I'm glad you enjoyed it. I certainly did.

Alfred Yen (32:43):
Well, thank you so much.

Ry Marcattilio (32:44):
We have transcripts for this and other podcasts available @CommunityNets.org/broadbandbits. Email [email protected] with your ideas for the show. Follow Chris on Twitter. His handle is @communitynets. Follow communitynets.org [00:33:00] stories on Twitter, the handle is @muninetworks. Subscribe to this and other podcasts from ILSR, including building Local Power, local energy rules, and the Composting for Community Podcast. You can access them anywhere you get your podcasts. You can catch the latest important research from all of our initiatives if you subscribe to our monthly [email protected]. While you're there, please take a moment to donate your support in any amount. Keeps us going. [00:33:30] Thank you to Arnie Hesby for the song Warm Duck Shuffle, licensed through Creative Commons.