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History of copyright
The history of copyright starts with early privileges and monopolies granted to printers of books. The British Statute of Anne 1710, full title "An Act for the Encouragement of Learning, by vesting the Copies of Printed Books in the Authors or purchasers of such Copies, during the Times therein mentioned", was the first copyright statute. Initially copyright law only applied to the copying of books. Over time other uses such as translations and derivative works were made subject to copyright and copyright now covers a wide range of works, including maps, performances, paintings, photographs, sound recordings, motion pictures and computer programs.
Today national copyright laws have been standardised to some extent through international and regional agreements such as the Berne Convention and the European copyright directives. Although there are consistencies among nations' copyright laws, each jurisdiction has separate and distinct laws and regulations about copyright. Some jurisdictions also recognize moral rights of creators, such as the right to be credited for the work.
Copyrights are exclusive rights granted to the author or creator of an original work, including the right to copy, distribute and adapt the work. Copyright does not protect ideas, only their expression or fixation. In most jurisdictions copyright arises upon fixation and does not need to be registered. Copyright owners have the exclusive statutory right to exercise control over copying and other exploitation of the works for a specific period of time, after which the work is said to enter the public domain. Uses which are covered under limitations and exceptions to copyright, such as fair use, do not require permission from the copyright owner. All other uses require permission and copyright owners can license or permanently transfer or assign their exclusive rights to others.
Early developments
[edit]The earliest recorded historical case-law on the right to copy comes from ancient Ireland. The Cathach is the oldest extant Irish manuscript of the Psalter and the earliest example of Irish writing. It contains a Vulgate version of Psalms XXX (30) to CV (105) with an interpretative rubric or heading before each psalm. It is traditionally ascribed to Saint Columba as the copy, made at night in haste by a miraculous light, of a Psalter lent to Columba by St. Finnian. In the 6th century, a dispute arose about the ownership of the copy and King Diarmait Mac Cerbhaill gave the judgement "To every cow belongs her calf, therefore to every book belongs its copy."[1] The Battle of Cúl Dreimhne was fought over this issue.
Modern copyright law has been influenced by an array of older legal rights that have been recognized throughout history, including the moral rights of the author who created a work, the economic rights of a benefactor who paid to have a copy made, the property rights of the individual owner of a copy, and a sovereign's right to censor and to regulate the printing industry. The origins of some of these rights can be traced back to ancient Greek culture, ancient Jewish law, and ancient Roman law.[2] In Greek society, during the sixth century B.C.E., there emerged the notion of the individual self, including personal ideals, ambition, and creativity.[3] The individual self is important in copyright because it distinguishes the creativity produced by an individual from the rest of society.[citation needed] In ancient Jewish Talmudic law there can be found recognition of the moral rights of the author and the economic or property rights of an author.[4]
Prior to the invention of movable type in the West in the mid-15th century, texts were copied by hand and the small number of texts generated few occasions for these rights to be tested. During the Roman Empire, a period of prosperous book trade, no copyright or similar regulations existed,[5] copying by those other than professional booksellers was rare. This is because books were, typically, copied by literate slaves, who were expensive to buy and maintain. Thus, any copier would have had to pay much the same expense as a professional publisher. Roman book sellers would sometimes pay a well-regarded author for first access to a text for copying, but they had no exclusive rights to a work and authors were not normally paid anything for their work. Martial, in his Epigrams, complains about receiving no profit despite the popularity of his poetry throughout the Roman Empire.[5]
The printing press came into use in Europe in the 1400s and 1500s, and made it much cheaper to produce books.[citation needed] As there was initially no copyright law, anyone could buy or rent a press and print any text. Popular new works were immediately re-set and re-published by competitors, so printers needed a constant stream of new material. Fees paid to authors for new works were high, and significantly supplemented the incomes of many academics.[6]
Printing brought profound social changes. The rise in literacy across Europe led to a dramatic increase in the demand for reading matter.[7] Prices of reprints were low, so publications could be bought by poorer people, creating a mass-market readership.[6] In German-speaking areas, most publications were academic papers, and most were scientific and technical publications, often autodidactic practical instruction manuals on topics such as dike construction.[6] After copyright law became established (in 1710 in England, and in the 1840s in German-speaking areas) the low-price mass market vanished, and fewer, more expensive editions were published.[6][8] Heinrich Heine, in a 1854 letter to his publisher, complains: "Due to the tremendously high prices you have established, I will hardly see a second edition of the book anytime soon. But you must set lower prices, dear Campe, for otherwise I really don't see why I was so lenient with my material interests."[6]
Early privileges and monopolies
[edit]The origin of copyright law in most European countries lies in efforts by the church and governments to regulate and control the output of printers.[9] Before the invention of the printing press, a writing, once created, could only be physically multiplied by the highly laborious and error-prone process of manual copying by scribes. An elaborate system of censorship and control over scribes did not exist, as scribes were scattered and worked on single manuscripts.[10] Printing allowed for multiple exact copies of a work, leading to a more rapid and widespread circulation of ideas and information (see print culture).[9] In 1559 the Index Expurgatorius, or List of Prohibited Books, was issued for the first time.[10]
In Europe printing was invented and widely established in the 15th and 16th centuries.[9] While governments and church encouraged printing in many ways, which allowed the dissemination of Bibles and government information, works of dissent and criticism could also circulate rapidly. As a consequence, governments established controls over printers across Europe, requiring them to have official licences to trade and produce books. The licenses typically gave printers the exclusive right to print particular works for a fixed period of years, and enabled the printer to prevent others from printing the same work during that period. The licenses could only grant rights to print in the territory of the state that had granted them, but they did usually prohibit the import of foreign printing.[9]
The republic of Venice granted its first privilege for a particular book in 1486. It was a special case, being the history of the city itself, the Rerum venetarum ab urbe condita opus of Marcus Antonius Coccius Sabellicus.[11] The second author in the world to achieve copyright, Royal printing privileges, was the humanist and grammarian Antonio de Nebrija, in Lexicon hoc est Dictionarium ex sermone latino in hispaniensem (Salamanca, 1492). From 1492 onwards Venice began regularly granting privileges for books.[12] The Republic of Venice, the dukes of Florence, and Leo X and other Popes conceded at different times to certain printers the exclusive privilege of printing for specific terms (rarely exceeding 14 years) editions of classic authors.[citation needed]
The first copyright privilege in England bears date 1518 and was issued to Richard Pynson, King's Printer, the successor to William Caxton. The privilege gives a monopoly for the term of two years. The date is 15 years later than that of the first privilege issued in France. Early copyright privileges were called "monopolies," particularly during the reign of Queen Elizabeth, who frequently gave grants of monopolies in articles of common use, such as salt, leather, coal, soap, cards, beer, and wine. The practice was continued until the Statute of Monopolies was enacted in 1623, ending most monopolies, with certain exceptions, such as patents; after 1623, grants of letters patent to publishers became common.[13]
The earliest German privilege of which there is trustworthy record was issued in 1501 by the Aulic Council to an association entitled the Sodalitas Rhenana Celtica, for the publication of an edition of the dramas of Hroswitha of Gandersheim, which had been prepared for the press by Conrad Celtes .[14] According to historian Eckhard Höffner indicated that there was no effective copyright legislation in Germany in the early 19th century.[15] Prussia introduced a copyright law in 1837, but even then authors and publishers just had to go to another German state to circumvent its ruling.[15]
As the "menace" of printing spread, governments established centralized control mechanisms,[16] and in 1557 the English Crown thought to stem the flow of seditious and heretical books by chartering the Stationers' Company. The right to print was limited to the members of that guild, and thirty years later the Star Chamber was chartered to curtail the "greate enormities and abuses" of "dyvers contentyous and disorderlye persons professinge the arte or mystere of pryntinge or selling of books." The right to print was restricted to two universities and to the 21 existing printers in the city of London, which had 53 printing presses. The French crown also repressed printing, and printer Etienne Dolet was burned at the stake in 1546. As the English took control of type founding in 1637, printers fled to the Netherlands. Confrontation with authority made printers radical and rebellious, and 800 authors, printers and book dealers were incarcerated in the Bastille before it was stormed in 1789.[16] The notion that the expression of dissent or subversive views should be tolerated, not censured or punished by law, developed alongside the rise of printing and the press. The Areopagitica, published in 1644 under the full title Areopagitica: A speech of Mr. John Milton for the liberty of unlicensed printing to the Parliament of England, was John Milton's response to the English parliament re-introducing government licensing of printers, hence publishers. In doing so Milton articulated the main strands of future discussions about freedom of expression. By defining the scope of freedom of expression and of "harmful" speech Milton argued against the principle of pre-censorship and in favour of tolerance for a wide range of views.[17]
Early British copyright law
[edit]In England the printers, known as stationers, formed a collective organisation, known as the Stationers' Company. In the 16th century, the Stationers' Company was given the power to require all lawfully printed books to be entered into its register. Only members of the Stationers' Company could enter books into the register. This meant that the Stationers' Company achieved a dominant position over publishing in 17th-century England (no equivalent arrangement formed in Scotland and Ireland). The monopoly came to an end in 1695, when the English Parliament did not renew the Stationers' Company's power.[9]
In 1707, the parliaments of England and Scotland were united as a result of the Anglo-Scottish Union. The new parliament was able to change the laws in both countries and an important early piece of legislation was the Copyright Act of 1710, also known as the Statute of Anne, after Queen Anne. The act came into force in 1710 and was the first copyright statute. Its full title was "An Act for the Encouragement of Learning, by vesting the Copies of Printed Books in the Authors or purchasers of such Copies, during the Times therein mentioned".[9]
The enforcement of the Statute of Anne in April 1710 marked a historic moment in the development of copyright law. As the world's first copyright statute it granted publishers of a book legal protection of 14 years with the commencement of the statute. It also granted 21 years of protection for any book already in print.[18] The Statute of Anne had a much broader social focus and remit than the monopoly granted to the Stationers' Company. The statute was concerned with the reading public, the continued production of useful literature, and the advancement and spread of education. The central plank of the statute is a social quid pro quo; to encourage "learned men to compose and write useful books" the statute guaranteed the finite right to print and reprint those works. It established a pragmatic bargain involving authors, the booksellers and the public.[19] The Statute of Anne ended the old system whereby only literature that met the censorship standards administered by the booksellers could appear in print. The statute furthermore created a public domain for literature, as previously all literature belonged to the booksellers forever.[20]
According to Patterson and Lindberg, the Statute of Anne:[20]
... transformed the stationers' copyright - which had been used as a device of monopoly and an instrument of censorship – into a trade-regulation concept to promote learning and to curtail the monopoly of publishers ... The features of the Statute of Anne that justify the epithet of trade regulation included the limited term of copyright, the availability of copyright to anyone, and the price-control provisions. Copyright, rather than being perpetual, was now limited to a term of fourteen years, with a like renewal term being available only to the author (and only if the author were living at the end of the first term).
When the statutory copyright term provided for by the Statute of Anne began to expire in 1731, London booksellers thought to defend their dominant position by seeking injunctions from the Court of Chancery for works by authors that fell outside the statute's protection. At the same time, the London booksellers lobbied parliament to extend the copyright term provided by the Statute of Anne. Eventually, in a case known as Midwinter v Hamilton (1743–1748), the London booksellers turned to common law and started a 30-year period known as the "battle of the booksellers", with London booksellers locking horns with the newly emerging Scottish book trade over the right to reprint works falling outside the protection of the Statute of Anne. The Scottish booksellers argued that no common law copyright existed in an author's work. The London booksellers argued that the Statute of Anne only supplemented and supported a pre-existing common law copyright. The dispute was argued out in a number of notable cases, including Millar v Kincaid (1749–1751) and Tonson v Collins (1761–1762).[21]
Common law copyright
[edit]A debate raged on whether printed ideas could be owned and London booksellers and other supporters of perpetual copyright argued that without it scholarship would cease to exist and that authors would have no incentive to continue creating works of enduring value if they could not bequeath the property rights to their descendants. Opponents of perpetual copyright argued that it amounted to a monopoly, which inflated the price of books, making them less affordable and therefore prevented the spread of the Enlightenment. London booksellers were attacked for using rights of authors to mask their greed and self-interest in controlling the book trade.[22][23] When Donaldson v Beckett reached the House of Lords in 1774, Lord Camden was most strident in his rejection of common law copyright, warning the Lords that, should they vote in favour of common law copyright, effectively a perpetual copyright, "all our learning will be locked up in the hands of the Tonsons and the Lintots of the age". Moreover, he warned, booksellers would then set upon books whatever price they pleased "till the public became as much their slaves, as their own hackney compilers are". He declared that "Knowledge and science are not things to be bound in such cobweb chains."[24]
In its ruling, the House of Lords established that the rights and responsibilities in copyright were determined by legislation.[25] There is, however, still disagreement over whether the House of Lords affirmed the existence of common-law copyright before it was superseded by the Statute of Anne. The Lords had traditionally been hostile to the booksellers' monopoly and were aware of how the doctrine of common law copyright, promoted by the booksellers, was used to support their case for a perpetual copyright. The Lords clearly decided against perpetual copyright[26] and, by confirming that the copyright term (the length of time that a work is in copyright) did expire according to statute, the Lords also affirmed the public domain. The ruling in Donaldson v Beckett confirmed that a large number of works and books first published in Britain were in the public domain, either because the copyright term granted by statute had expired or because they were first published before the Statute of Anne was enacted in 1710. This opened the market for cheap reprints of works by Shakespeare, Milton and Chaucer, works now considered classics. The expansion of the public domain in books broke the dominance of the London booksellers and allowed for competition, with the number of London booksellers and publishers rising nearly threefold, from 111 to 308, between 1772 and 1802.[27]
Eventually an understanding was established whereby authors had a pre-existing common-law copyright over their work, but that with the Statute of Anne parliament had limited these rights in order to strike a more appropriate balance between the interests of the author and the wider social good.[28] According to Patterson and Livingston, confusion about the nature of copyright has remained ever since. Copyright has come to be viewed both as a natural-law right of the author and as the statutory grant of a limited monopoly. One theory holds that copyright is created simply by the creation of a work, the other that it is owed to a copyright statute.[29]
In August 1906, The Copyright Law for Music Act 1906, known also as the T. P. O'Connor Bill, was added to copyright law when it was passed by the British Parliament, following many of the popular music writers at the time dying in poverty due to extensive piracy by gangs during the piracy crisis of sheet music in the early 20th century.[30][31][32][33] The gangs would buy a copy of the music at full price, copy it, and resell it, often at half the price from the original.[34]
Early French copyright law
[edit]In pre-revolutionary France all books needed to be approved by official censors and authors and publishers had to obtain a royal privilege before a book could be published. Royal privileges were exclusive and usually granted for six years, with the possibility of renewal. Over time it was established that the owner of a royal privilege has the sole right to obtain a renewal indefinitely. In 1761 the Royal Council awarded a royal privilege to the heirs of an author rather than the author's publisher, sparking a national debate on the nature of literary property similar to that taking place in Britain during the battle of the booksellers.[35]
In 1777 a series of royal decrees reformed the royal privileges. The duration of privileges were set at a minimum duration of 10 years or the life of the author, which ever was longer. If the author obtained a privilege and did not transfer or sell it on, he could publish and sell copies of the book himself, and pass the privilege on to his heirs, who enjoyed an exclusive right into perpetuity. If the privilege was sold to a publisher, the exclusive right would only last the specified duration. The royal decrees prohibited the renewal of privileges and once the privilege had expired anyone could obtain a "permission simple" to print or sell copies of the work. Hence the public domain in books whose privilege had expired was expressly recognised.[35]
After the French Revolution a dispute over Comédie-Française being granted the exclusive right to the public performance of all dramatic works erupted and in 1791 the National Assembly abolished the privilege. Anyone was allowed to establish a public theatre and the National Assembly declared that the works of any author who had died more than five years ago were public property. In the same degree the National Assembly granted authors the exclusive right to authorise the public performance of their works during their lifetime, and extended that right to the authors' heirs and assignees for five years after the author's death. The National Assembly took the view that a published work was by its nature a public property, and that an author's rights are recognised as an exception to this principle, to compensate an author for his work.[35]
In 1793 a new law was passed giving authors, composers, and artists the exclusive right to sell and distribute their works, and the right was extended to their heirs and assigns for 10 years after the author's death. The National Assembly placed this law firmly on a natural right footing, calling the law the "Declaration of the Rights of Genius" and so evoking the famous Declaration of the Rights of Man and of the Citizen. However, author's rights were subject to the condition of making depositing copies of the work with the Bibliothèque Nationale and 19th-century commentators characterised the 1793 law as utilitarian and "a charitable grant from society".[35]
Early United States copyright law
[edit]The Statute of Anne did not apply to the American colonies. The economy of early America was largely agrarian and only three private copyright acts had been passed in America prior to 1783. Two of the acts were limited to seven years, the other was limited to a term of five years. In 1783 several authors' petitions persuaded the Continental Congress "that nothing is more properly a man's own than the fruit of his study, and that the protection and security of literary property would greatly tend to encourage genius and to promote useful discoveries." But under the Articles of Confederation, the Continental Congress had no authority to enact copyright law. The Continental Congress passed a resolution urging the States to "secure to the authors or publishers of any new book not hitherto printed ... the copy right of such books for a certain time not less than fourteen years from the first publication; and to secure to the said authors, if they shall survive the term first mentioned, ... the copy right of such books for another term of time no less than fourteen years.[36] Three states had already enacted copyright statutes in 1783 prior to the Continental Congress resolution, and in the subsequent three years all of the remaining states except Delaware passed a copyright statute. Seven of the States followed the Statute of Anne and the Continental Congress' resolution by providing two fourteen-year terms. The five remaining States granted copyright for single terms of fourteen, twenty and twenty one years, with no right of renewal.[37]
At the Philadelphia Convention in 1787, both James Madison of Virginia and Charles Cotesworth Pinckney of South Carolina submitted proposals that would allow Congress the power to grant copyright for a limited time. These proposals are the origin of the Copyright Clause in the United States Constitution, which allows the granting of copyright and patents for a limited time to serve a utilitarian function, namely "to promote the progress of science and useful arts". The first federal copyright act was the Copyright Act of 1790. It granted copyright for a term of 14 years "from the time of recording the title thereof" with a right of renewal for another 14 years if the author survived to the end of the first term. The act covered not only books, but also maps and charts. Only works both printed within the United States and created by citizens were eligible. With exception of the provision on maps and charts the Copyright Act of 1790 is copied almost verbatim from the Statute of Anne.[37]
At the time works only received protection under federal statutory copyright if the statutory formalities, such as a proper copyright notice, were satisfied. If this was not the case the work immediately entered into the public domain. In 1834 the Supreme Court ruled in Wheaton v. Peters (a case similar to the 1774 case of Donaldson v Beckett in Britain) that although the author of an unpublished work had a common law right to control the first publication of that work, the author did not have a common law right to control reproduction following the first publication of the work.[37]
Early internationalisation
[edit]The Berne Convention was first established in 1886, and was subsequently re-negotiated in 1896 (Paris), 1908 (Berlin), 1928 (Rome), 1948 (Brussels), 1967 (Stockholm) and 1971 (Paris). The convention relates to literary and artistic works, which includes films, and the convention requires its member states to provide protection for every production in the literary, scientific and artistic domain. The Berne Convention has a number of core features, including the principle of national treatment, which holds that each member state to the convention would give citizens of other member states the same rights of copyright that it gave to its own citizens (Article 3-5).[38]
Another core feature is the establishment of minimum standards of national copyright legislation in that each member state agrees to certain basic rules which their national laws must contain. Though member states can if they wish increase the amount of protection given to copyright owners. One important minimum rule was that the term of copyright was to be a minimum of the author's lifetime plus 50 years. Another important minimum rule established by the Berne Convention is that copyright arises with the creation of a work and does not depend upon any formality such as a system of public registration (Article 5(2)). At the time some countries did require registration of copyright, and when Britain implemented the Berne Convention in the Copyright Act 1911 (1 & 2 Geo. 5. c. 46) it had to abolish its system of registration at Stationers' Hall.[38]
The Berne Convention focuses on authors as the key figure in copyright law and the stated purpose of the convention is "the protection of the rights of authors in their literary and artistic works" (Article 1), rather than the protection of publishers and other actors in the process of disseminating works to the public. In the 1928 revision the concept of moral rights was introduced (Article 6bis), giving authors the right to be identified as a such and to object to derogatory treatment of their works. These rights, unlike economic rights such as preventing reproduction, could not be transferred to others.[38]
The Berne Convention also enshrined limitations and exceptions to copyright, enabling the reproduction of literary and artistic works without the copyright owners prior permission. The detail of these exceptions was left to national copyright legislation, but the guiding principle is stated in Article 9 of the convention. The so-called three-step test holds that an exception is only permitted "in certain special cases, provided that such reproduction does not conflict with a normal exploitation of the work and does not unreasonably prejudice the legitimate interests of the author". Free use of copyrighted work is expressly permitted in the case of quotations from lawfully published works, illustration for teaching purposes, and news reporting (Article 10).[38]
Copyright in communist countries
[edit]Copyright and technology
[edit]- Digital technology introduces a new level of controversy into copyright policy.
- Inclusion of software as copyright subject matter on the recommendation of CONTU and then later with the EU Computer Programs Directive.
- Enactment of Agreement on Trade-Related Aspects of Intellectual Property Rights (TRIPS).
- Controversy over the copyrightability of databases (Feist Publications v. Rural Telephone Service and contradictory cases); links to the debate over sui generis database rights.
- Enactment of the World Intellectual Property Organization Copyright Treaty; nations begin passing anti-circumvention laws.
Commentators such as Barlow (1994) have argued that digital copyright is fundamentally different and will remain persistently difficult to enforce; others such as Richard Stallman (1996)[39] have argued that the Internet deeply undermines the economic rationale for copyright in the first place. These perspectives may lead to the consideration of alternative compensation systems in place of exclusive rights for all types of information, including software, books, movies, and music.[40][41]
Expansions in scope and operation
[edit]- Move from common law and ad hoc grants of monopoly to copyright statutes.
- Expansions in subject matter (largely related to technology).
- Expansions on duration.
- Creation of new exclusive rights (such as performers' and other neighbouring rights).
- Creation of collecting societies.
- Criminalisation of copyright infringement.
- Creation of anti-circumvention laws.[42]
- Courts' application of secondary liability doctrines to cover file sharing networks
See also
[edit]- History of music piracy
- History of patent law
- Copyleft
- International copyright
- Copyright infringement
[edit]- ^ Royal Irish Academy. "The Cathach/The Psalter of St. Columba". Library Cathach. Archived from the original on 2014-07-02.
- ^ Bettig, Ronald V. (1996). Copyrighting Culture: The Political Economy of Intellectual Property. Boulder, Colorado: Westview Press. p. 11. ISBN 0-8133-1385-6.
- ^ Ploman, Edward W., and L. Clark Hamilton (1980). Copyright: Intellectual Property in the Information Age. London: Routledge & Kegan Paul. p. 5. ISBN 0-7100-0539-3.
{{cite book}}
: CS1 maint: multiple names: authors list (link) - ^ Ploman, Edward W., and L. Clark Hamilton (1980). Copyright: Intellectual Property in the Information Age. London: Routledge & Kegan Paul. p. 7. ISBN 0-7100-0539-3.
{{cite book}}
: CS1 maint: multiple names: authors list (link) - ^ a b Martial, The Epigrams, Penguin, 1978, James Mitchie
- ^ a b c d e Thadeusz, Frank (18 August 2010). "No Copyright Law: The Real Reason for Germany's Industrial Expansion?". Spiegel Online.
- ^ Copyright in Historical Perspective, p. 136-137, Patterson, 1968, Vanderbilt Univ. Press
- ^ Lasar, Matthew (23 August 2010). "Did Weak Copyright Laws Help Germany Outpace The British Empire?". Wired.
- ^ a b c d e f MacQueen, Hector L; Charlotte Waelde; Graeme T Laurie (2007). Contemporary Intellectual Property: Law and Policy. Oxford University Press. p. 34. ISBN 978-0-19-926339-4.
- ^ a b de Sola Pool, Ithiel (1983). Technologies of freedom. Harvard University Press. p. 14. ISBN 978-0-674-87233-2.
- ^ Armstrong, Elizabeth. Before Copyright: the French book-privilege system 1498–1526. Cambridge University Press, Cambridge: 1990, p. 3
- ^ Armstrong, Elizabeth. Before Copyright: the French book-privilege system 1498–1526. Cambridge University Press, Cambridge: 1990, p. 6
- ^ Deazley, Ronan. Rethinking copyright: history, theory, language. (Cheltenham, UK: Edward Elgar Publishing Limited, 2006), p. 24.
- ^ Kawohl, F. (2008) "Commentary on Imperial privileges for Conrad Celtis (1501/02) Archived 2013-03-19 at the Wayback Machine in: Primary Sources on Copyright (1450–1900), eds L. Bently & M. Kretschmer, www.copyrighthistory.org
- ^ a b Eckhard Höffner (8 December 2010). "Copyright and Structure of Author's Earnings, from his book:Geschichte und Wesen des Urheberrechts (History and Nature of Copyright)". Slideshare. Retrieved April 11, 2015.
- ^ a b de Sola Pool, Ithiel (1983). Technologies of freedom. Harvard University Press. p. 15. ISBN 978-0-674-87233-2.
- ^ Sanders, Karen (2003). Ethics & Journalism. Sage. p. 66. ISBN 978-0-7619-6967-9.
- ^ Ronan, Deazley (2006). Rethinking copyright: history, theory, language. Edward Elgar Publishing. p. 13. ISBN 978-1-84542-282-0.
- ^ Ronan, Deazley (2006). Rethinking copyright: history, theory, language. Edward Elgar Publishing. pp. 13–14. ISBN 978-1-84542-282-0.
- ^ a b Jonathan, Rosenoer (1997). Cyberlaw: the law of the internet. Springer. pp. 34. ISBN 978-0-387-94832-4.
- ^ Ronan, Deazley (2006). Rethinking copyright: history, theory, language. Edward Elgar Publishing. p. 14. ISBN 978-1-84542-282-0.
- ^ Van Horn Melton, James (2001). The rise of the public in Enlightenment Europe. Cambridge University Press. p. 139. ISBN 978-0-521-46969-2.
- ^ Keen, Paul (2004). Revolutions in Romantic literature: an anthology of print culture 1780–1832. Broadview Press. p. 80. ISBN 978-1-55111-352-4.
- ^ Ronan, Deazley (2006). Rethinking copyright: history, theory, language. Edward Elgar Publishing. p. 19. ISBN 978-1-84542-282-0.
- ^ Rimmer, Matthew (2007). Digital copyright and the consumer revolution: hands off my iPod. Edward Elgar Publishing. p. 4. ISBN 978-1-84542-948-5.
- ^ Marshall, Lee (2006). Bootlegging: romanticism and copyright in the music industry. Sage. p. 15. ISBN 978-0-7619-4490-4.
- ^ Van Horn Melton, James (2001). The rise of the public in Enlightenment Europe. Cambridge University Press. pp. 140–141. ISBN 978-0-521-46969-2.
- ^ Ronan, Deazley (2006). Rethinking copyright: history, theory, language. Edward Elgar Publishing. p. 24. ISBN 978-1-84542-282-0.
- ^ Jonathan, Rosenoer (1997). Cyberlaw: the law of the internet. Springer. pp. 34–35. ISBN 978-0-387-94832-4.
- ^ Atkinson, Benedict. & Fitzgerald, Brian. (eds.) (2017). Copyright Law: Volume II: Application to Creative Industries in the 20th Century. Routledge. p181.
- ^ Dibble, Jeremy. (2002). Charles Villiers Stanford: Man and Musician Oxford University press. pp340-341. ISBN 9780198163831
- ^ Sanjek, Russell. (1988). American Popular Music and Its Business: The First Four Hundred Years. Oxford University Press. ISBN 9780195043105
- ^ Johns, Adrian. (2009). Piracy: The Intellectual Property Wars from Gutenberg to Gates. University of Chicago Press. p354. ISBN 9780226401195
- ^ Johns, Adrian. (2009). Piracy: The Intellectual Property Wars from Gutenberg to Gates. University of Chicago Press. pp349-352. ISBN 9780226401195
- ^ a b c d Yu, Peter K (2007). Intellectual Property and Information Wealth: Copyright and related rights. Greenwood Publishing Group. pp. 141–142. ISBN 978-0-275-98883-8.
- ^ Peter K, Yu (2007). Intellectual Property and Information Wealth: Copyright and related rights. Greenwood Publishing Group. p. 142. ISBN 978-0-275-98883-8.
- ^ a b c Peter K, Yu (2007). Intellectual Property and Information Wealth: Copyright and related rights. Greenwood Publishing Group. p. 143. ISBN 978-0-275-98883-8.
- ^ a b c d MacQueen, Hector L; Charlotte Waelde; Graeme T Laurie (2007). Contemporary Intellectual Property: Law and Policy. Oxford University Press. p. 37. ISBN 978-0-19-926339-4.
- ^ Richard Stallman. "Reevaluating Copyright: The Public Must Prevail".
- ^ Samudrala, Ram (1994). "The Free Music Philosophy". Retrieved 2011-09-13.
- ^ Samudrala, Ram (1994). "A Primer on the Ethics of Intellectual Property". Retrieved 2011-09-13.
- ^ See Jessica Litman, Digital Copyright (2000), for a detailed discussion of the legislative history behind the passage of the 1998 Digital Millennium Copyright Act, one of the first statutes prohibiting circumvention.
Further reading
[edit]- Eaton S. Drone, A Treatise on the Law of Property in Intellectual Productions, Little, Brown, & Co. (1879).
- Dietrich A. Loeber, '"Socialist" Features of Soviet Copyright Law', Columbia Journal of Transnational Law, vol. 23, pp 297–313, 1984.
- Joseph Lowenstein, The Author's Due : Printing and the Prehistory of Copyright, University of Chicago Press, 2002
- Christopher May, "The Venetian Moment: New Technologies, Legal Innovation and the Institutional Origins of Intellectual Property", Prometheus, 20(2), 2002.
- Millar v. Taylor, 4 Burr. 2303, 98 Eng. Rep. 201 (K.B. 1769).
- Lyman Ray Patterson, Copyright in Historical Perspective, Vanderbilt University Press, 1968.
- Eric Anderson, Pimps and Ferrets: Copyright and Culture in the United States, 1831–1891, 2010. https://archive.org/details/PimpsAndFerretsCopyrightAndCultureInTheUnitedStates1831-1891
- Brendan Scott, "Copyright in a Frictionless World", First Monday, volume 6, number 9 (September 2001), http://firstmonday.org/issues/issue6_9/scott/index.html.
- Charles Forbes René de Montalembert, The Monks of the West from St Benedict to St Bernard, William Blackwood and Sons, London, 1867, Vol III.
- Augustine Birrell, Seven Lectures on the Law and History of Copyright in Books, Rothman Reprints Inc., 1899 (1971 reprint).
- Drahos, P. with Braithwaite, J., Information Feudalism, The New Press, New York, 2003. ISBN 1-56584-804-7(hc.)
- Paul Edward Geller, International Copyright Law and Practice, Matthew Bender. (2000).
- New International Encyclopedia
- Computer Associates International, Inc. v. Altai, Inc., 982 F.2d 693 (2d Cir. 1992)
- Armstrong, Elizabeth. Before Copyright: the French book-privilege system 1498-1526. Cambridge University Press (Cambridge: 1990)
- Siegrist, Hannes, The History and Current Problems of Intellectual Property (1600–2000), in: Axel Zerdick ... (eds.), E-merging Media. Communication and the Media Economy of the Future, Heidelberg 2004, p. 311–329.
- Gantz, John and Rochester, Jack B. (2005), Pirates of the Digital Millennium, Upper Saddle River: Financial Times Prentice Hall; ISBN 0-13-146315-2
- Löhr, Isabella, Intellectual cooperation in transnational networks: the league of nations and the globalization of intellectual property rights, in: Mathias Albert ... (eds.), Transnational political spaces. agents - structures - encounters, Frankfurt/Main 2009, p. 58–88.
- Ronan Deazley, Martin Kretschmer and Lionel Bently (eds) Privilege and Property: Essays on the History of Copyright. Open Book Publishers (Cambridge: 2010). ISBN 978-1-906924-18-8
- Selle, Hendrik; "Open Content? Ancient Thinking on Copyright", Revue internationale de droit de l'Antiquité 55 (2008) 469–84.
External links
[edit]- Primary Sources on Copyright (1450–1900) (British, French, German, Italian, US documents)
- International Copyright and Neighbouring Rights: The Berne Convention and Beyond Companion website with historical documents related to international copyright


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Because We Haven't Brought You Enough News on Canadian Agriculture Lately …
Photo: Let Ideas Compete
Here are two interesting items:
A Macleans article about one investment firm's effort to assemble one of the biggest farms in the world by piecing together Aboriginal land.
And a very interesting National Post series about Canada's massive illegal tobacco market, most of it centered on Aboriginal land as well, but including cameos by the Hell's Angels, mafiosos, and others.
I am in the midst of a few quick trips to Canada, and am reminded of how little of their news crosses the border to us.

subset: commoncrawl


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Teen Sublime speaks to Angelina Decker, the owner and director of The Reworks clothing brand, which recyleces and reuses specifically selected second hand clothing.
Tag Archives: recycle
Elate Cosmetics
Elate Cosmetics, a makeup brand with bamboo zero waste packaging, a conscious beauty ethos and cruelty-free natural cosmetic products.
Anna's Anchor
Anna's Anchor (aka Marty Ryan) is an upcoming band from Ireland using their music to influence and educate people on the importance of taking care of our Earth.
Teen Sublime: What was the inspiration behind starting up Anna's Anchor?
Marty Ryan: I started Anna's Anchor as a solo project initially for a couple of reasons. My old band was beginning to slow down at the time when I really wanted to push things and start touring properly. I figured if I had a project that just involved myself, I could achieve that, as the only thing holding it back would be myself. I also had gone through some pretty tough times with my family in my early twenties and I needed some kind of an outlet to get all of the overwhelming emotions off my chest. It seemed the perfect way to work a lot of those things out.
TS: Where did you get the name Anna's Anchor from?
MR: I put an awful lot of thought behind the name actually, there's a number of different reasons as to where it came from. The initial batch of songs was a coping mechanism to come to terms with my mother's alcohol abuse, so I wanted the name to allude to that in some kind of way, so I started off with the acronym "AA" and tried to figure out a name off of that. I'm from a little village called ANNAcotty and my favourite song is "Anchor" by a band called "Osker". Combine the two and you've got Anna's Anchor. It also helped in choosing that name as the domain name was still available!
TS: What did you do before you played music?
MR: That's a funny one for me to answer as music has literally only just become a full-time endeavour for me. I've worked as an environmental consultant for the last 3 years in Ireland after finishing my degree in Environmental Science. The job involved a lot of environmental compliance work between various industries and Environmental Protection Agency. It's been so tough because music has been a full-time endeavour, but so has my job that's allowed me to exist as a functioning member of society. That's meant I've had to put all my annual leave and weekends into touring which has made it super difficult for my loved ones, something I feel bad for but this is something I have to do. You do what you have to do to try and follow your dream even if that means working around the clock and not taking a proper holiday for years. That struggle aside, I've been very fortunate to work a job that is in an area that I'm very passionate about while making enough money to get Anna's Anchor off the ground.
TS: What do you think is the power of the music which you create?
MR: I think the real power is behind the lyrical content. The songs are very autobiographical, dealing with a lot of the struggles I've had to cope with in my life. It's scary putting your personal life out in the public domain in that regard but it's a very necessary and cathartic process for me in which a lot of people can relate to. Whilst the topics can be somewhat difficult to talk about, so many people go through similar things and can find a common ground with the songs. For me, that's one of the best parts of being in this position as a musician.
TS: What is the story behind 'Everybody's Welcome' as an album?
MR: Everybody's Welcome is very much a two-sided coin. The album as a whole is about the stray path we're led down and that I built for myself, in that if you work hard in college, get a good degree, get a decent job then you'll live a happy life. That false belief that I was kind of clutching onto led to the darkest part of my life really and the title "Everybody's Welcome†is meant in a literal sense that I do treat everyone fairly and give anyone my time that wants it, and on the flip side, it represents the disillusionment I've come across from people that claim to be of that mantra and are only out for their own personal gain.
TS: What was the motivation behind the environmental message of the new single 'Precautionary'?
MR: Having dedicated a large portion of my life to studying and practising environmental science, one thing that always comes up is the definition of sustainability, which is basically the idea that one generation passes the world onto to the next in better shape than when they got it. I personally feel from an environmental, economic and social perspective, that hasn't necessarily happened with any generation, particularly at the moment. I'm the first person in my family to graduate from university, yet the reality is I'll probably never own a house of my own; there are drastic changes in weather that are only becoming more frequent due to our overexploitation of the world's resources; and to top it all off, hate and racial tension is more prevalent than ever. It's difficult to be positive about all of that, but the reality is that keeping hope and positivity is the only thing you actually can do, and that's what the song's about. It's a heavy lyrical concept but it's married with the most upbeat music I've ever written. I love that conflicting message between the two moods of the song which is the overarching theme of the whole record, really.
TS: Would you call yourself punk rock because of the activist tone in your music?
MR: I don't think I consider myself "punk rock" to be honest but I do really believe in treating others equally and as best as possible. I do really try my best to be as considerate and compassionate as I can. I still have a long way to go but it certainly is an ethic that I feel strongly about and how I treat the environment around me is an extension of this belief. It just so happens that this is pretty close to the "Punk Rock" ethic if there is such a thing. The social commentary is a new concept for me musically but the reality is I'm only really experiencing the result of government and industry decisions now, so it's personal and that's why I'm writing about it. The idea of what is and isn't punk rock is an interesting debate because not everyone practices what they preach and that really is what the new album is really about. I've worked for middle-aged men and women with no piercings or hair dye that work at a desk and are bigger punks than some of the biggest protest song acts out there will ever be.
TS: Who were your influences growing up?
MR: When I was younger I was really into bands like The Cure, Interpol and Smashing Pumpkins. As I've grown a little older I've been a lot more influenced by local acts. There's something special about seeing a band from your locality doing something special. It has given me the belief that I can do it myself. Windings have been the biggest band for me in that regard. I probably wouldn't be pursuing music like this if it wasn't for them, I owe them everything in truth. And So I Watch You From Afar are another Irish band that has left a huge impact on me. I've seen them twice in a 100 cap room in my hometown, Limerick, that has since closed, the bigger venue in the city a few times, all the way up to headlining the Olympia. In my mind, they've stayed true to the art that they've made, worked their asses off and been recognised for it. That means more to me than anything that a huge rockstar will ever do.
TS: What is your lyric writing process like?
MR: I usually keep a note in my phone of lyrical topics that I'd like to write a song about when I have the time. Separately I'll have a bunch of different guitar parts floating around if I feel one suits the mood of a lyrical topic I have noted down, I'll begin to flesh lyrics out to it. The main thing for me is to make sure that every word in there has meaning. I only have 3-4 minutes to pour out my heart so every word has to count.
TS: Is there anything else which you do in order to raise awareness about taking care of our Earth?
MR: On a personal level, I've volunteered with some local groups that have been involved in cleaning up our local river basin as well as some research projects that have been aimed towards reducing the environmental impact that agriculture has on our water courses, that's been really fun. As a band we have had some of our CD releases printed on a recycled card instead of plastic, downsized our van to be more efficient and on our upcoming tour, we will be following suit from our friends in ASIWYFA with taking out canteens and removing bottled water from our rider. They're small steps but we have been provided with a platform and we want to do as much good as we can with whatever privilege we've been provided with.
If you would like more information about Anna's Anchor head to annasanchor.com


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Automated teller machine (ATM) malware was not as common when Trend Micro started to analyze samples in 2015. The fact that some criminal gangs in South America and Russia had studied how these machines work and made special software to attack them was remarkable at the time. ATMs are unlike the usual Windows environments, so an attacker would need knowledge on a special set of application programming interfaces (APIs) and how they interact with specific bank applications.
Since our first collaboration with Europol's European Cybercrime Centre (EC3) where we explained the different cyberthreats targeting ATMs, we observed the ATM malware landscape evolving toward network-based attacks. We published a second paper detailing this evolution and the ATM malware families that emerged over the years.
[READ RESEARCH: Cashing in on ATM Malware: A Comprehensive Look at Various Attack Types]
We have seen a lot of shifts in the ATM malware field, but the most important one is not technical: ATM malware has become a common feature in the cybercriminal underground and is now being offered as part of attackers' arsenal for stealing cash. ATM malware has become a commodity, and any criminal with US$1,000 to invest can start attacking ATMs in no time.
Notably, these criminal offerings are coming from the Russian-speaking criminal underground. This is not to say that South American gangs have stopped attacking ATMs in their region, but that the Russian criminal undergroundhas a more dynamic, thriving marketplace, where all kinds of illicit transactions are more likely to happen.
[RELATED: Revisiting the Russian Cybercriminal Underground]
ATM Malware 101: Criminal Advice and Help Online
Cybercriminal offerings usually include more than the malware. Often, these underground sellers provide instructions, practical bits of advice, and troubleshooting guides.
As an example, one of the most publicized ATM malware offerings, the so-called "Cutlet Maker," had a concrete description of the hardware needed to pull off a successful heist, as well as detailed step-by-step instructions for using the program.
Part of the Cutlet Maker package: a description of the ATM brand and model to target, as well as the equipment needed to attack it
Along with this "user manual" of sorts, the seller shares his own troubleshooting advice on how to make the software work in different environments. Here is an English translation of the introduction for this guide:
"The original and the second manual outline all the information that is needed for it to work. Tav really has it all. In this manual, there will be only information on how to get around the difficulties that may arise. Here I will present my own experience."
We can't be sure if "Tav" is the original author of the malware or the manual, or the internal name of this malware. The document's metadata identifies the manual's author as "Bogdan."
Screenshot of the troubleshooting guide for Cutlet Maker. The author describes the ATM's USB port location, along with advice on how to devise a stick for attaching the USB cable and accessing the internal USB port
[RELATED READ: Dissecting PRILEX and CUTLET MAKER ATM Malware Families]
The included guide describes the target ATM's external and internal details. This is a translation of the advice from the criminal seller:
"The ports we need are located behind the plastic canopy, which is above the ATM screen, followed quite often by the bank's advertising paper. This cover keeps on three clips, they are located in the upper part of the plastic – on the left, in the middle, and on the right. Pry the knife gently so that this cover does not break, put it on top of the ATM so as to not interfere further. We take out a flashlight, shine and see the following:"
The author describes what the attacker will see once the panel that uncovers the internal USB port is removed
Some of the advice also includes mobile phone usage and how doing it incorrectly can allow law enforcement to track the attacker.
However, not all of the advice found on these criminal guides are purely physical. There is, for instance, an explanation on how to disable an installed antivirus program, if the machine is protected by one:
"Adobe services are disabled here. We do the same with our antivirus. Next, go to the Startup tab, remove the checkmarks from our antivirus. Then, apply and proceed. Next, go to the antivirus folder C:/Program.../Our antivirus/ and change the name of the .exe: For example, from kvp.avp.exe to any other.
You have turned off the antivirus, now you can run our malware from a flash drive."
The aforementioned appears to be a simplistic approach and would not work on a more hardened, modern security solution. However, such a solution will not always be found on a dedicated machine like an ATM.
A snippet explaining how to disable the antivirus program, if the ATM has one installed
Case Study: An ATM Malware Reseller
ATM malware is becoming a common offering in criminal underground forums, and it's not the exotic or niche item it was before. A seller was even seen offering multiple malware families in one of these forums. These posts are probably not from the original malware authors; they're likely from resellers taking a cut from the sales.
List of recent threads in a popular criminal forum
List of three underground forum threads showing different ATM malware files being offered by the same seller
While looking through these criminal forums, we couldn't help but notice a particular reseller who was specializing in ATM malware, so we decided to take a closer look into the user's profile. The criminal postings by M_ (full username redacted) were peddling many different ATM malware toolkits in criminal forums.
The forum poster does not appear to be the original coder of these projects; he's a reseller, based on the comments from buyers and other forum users. The seller has replied multiple times to forum threads with "I'm selling the same software at a substantially lower price." Also, this person has videos demonstrating how the malware works, posted on DarkVideo, a video streaming site. Other forum users have accused this actor of selling software that does not work. As a side note, his written Russian reads as if it was translated, which implies that he might not be a native speaker.
M_ has advertised a variety of ATM malware for the following prices:
Based on this individual's online presence and forum activity, we could compose a more detailed profile, which is available only to LEA members.
ATM Malware as a Commodity for Digital Bank Heists
The number of ATM malware offerings in cybercriminal underground forums has significantly increased in the last two years. This type of malware, which used to belong exclusively to criminal gangs (that used them for their benefit), is now becoming a mainstream tool that's bought and used by enterprising criminals. In other words, ATM malware is becoming a commodity that allows any would-be criminal with a few hundred dollars to start attacking ATMs.
Some of these criminal advertisements will no doubt be pure scams, but some of them appear to deliver. In fact, we have seen positive reviews that indicate some of the sellers offer working malware. There are several families available, but we can see that some are becoming more popular than others — reminiscent of the time when Zeus and SpyEye were competing to be the top banking trojan in the cybercriminal underground.
What can we expect in the near future? If things don't take a radical turn, more criminals will start trying to subvert unprotected ATMs. However, the techniques they use are very basic, and the technical level of the average attacker is low. This means that security countermeasures that get in their way might deter them from committing this crime.
Unfortunately, unprotected ATMs are still common, but banks could eliminate these low-hanging fruits by putting up more security measures. If this happens, we might see ATM attacks go back to being more targeted and highly technical, but the likelihood of this happening depends on each bank's defense budget.
If your company owns a significant amount of unprotected ATMs in the field, the risk of them becoming targeted with ATM malware grows every month.
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- Kong API Gateway Misconfigurations: An API Gateway Security Case Study


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Rayman Classic v1.0.0 Cracked APK + DATA
Rayman Classic v1.0.0 Cracked APK + DATA for Android.
To celebrate its 20th anniversary, the original Rayman is back… and for the 1st time on your mobile!
Embark on epic adventures with Rayman in one of the most influent platform game of all times and relive the experience of playing the original version of the 1995 hit.
"Rayman is side-scrolling, comic animation at its finest" Gamespot 1996
"Rayman ranks as one of the most visually appealing games of this or any year" Gamepro 1995
"This will probably go down in the history books as the brightest platform game ever" Playstation Magazine 1995
"One of the greatest platformers games to come out on PC" Joystick 1995
The evil Mr Dark has stolen the Great Protoon and captured the Electoons! Play as Rayman, the legendary limbless hero, free the Electoons, defeat Mr Dark and restore the world's harmony.
• EMBODY Rayman, your favorite hero born in 1995
• REDISCOVER the fantasy cartoon worlds of the original game: The Dream Forest, The Band Lands, The Blue Mountains, The Candy Castle…
• RUN, dodge, jump, punch your way through the various levels of this classic platform game.
• UNLEASH Rayman's special powers from the telescopic fist to the helicopter and defeat hostile creatures.
• SEEK OUT & FREE the Electoons to complete each level and restore the cosmic balance.
• HELP iconic and funny side characters in each world: The fairy Betilla, Tarayzan, Joe the extraterrestrial.
• DEFEAT each and every boss (Moskito, Mister Sax, Mr Dark…) in epic showdowns to free your friends.
• BEAT the Hardcore mode with one single life or choose the Casual mode for infinite tries.
Want to get the feeling of the original controls: this game supports gamepad!
You are a Rayman's fan? Go check out our other awesome Rayman games from Ubisoft: Rayman Jungle Run, Rayman Fiesta Run & Rayman Adventures!
Game available in: English, French, Italian, German, Spanish, Chinese, Japanese, Korean and Russian.
Download [Google Play]


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US Steel Cello Ensemble – Noise In The Library LP
Putojefe RecordsBob Rutman's life could be compared to the life of Odysseus, although we're not here to write his biography; Putojefe is happy to present his phenomenal Noise In The Library, recorded with the U.S. Steel Cello Ensemble, an all-steel string quartet established by himself in Boston in 1976.
The Ensemble consists of one Steel Cello and three Bow Chimes, played by Rutman and a rotating cast of guest musicians: in this instance, Daniel Orlansky –one of Rutman's closest collaborators and longest-lasting member of the band–, Stephanie Wolff and Alex Dorsch. The instruments, built and developed by Rutman, are impressive sound sculptures in themselves, made of large flexible sheets of metal and defined by the artist as "American Industrial folk instruments".
The Bürgermeister von Mitte needs no introduction. He has literally traveled history, from Nazi Germany to the New York of the Seventies, landing again in Berlin in recent years. A tireless performer aged 88, he has toured the US and Europe extensively, playing both small galleries and underground venues as well as established cultural institutions as the MoMA, London's ICE and the Berlin Atonal Festival.
Rutman is internationally recognised as the multifaceted avant-garde artist par excellence, as attested by his diverse collaboration with key figures of post-war culture: Dorothy Carter, Merce Cunningham, Laurie Anderson, Philip Lamantia, Wim Wenders, Asmus Tietchens and many others.
Captivating from the beginning to the end, primitive and futuristic in its form, Noise In The Library remains as the U.S. Steel Cello Ensemble's sole recording featuring the exceptional overtone singer Stephanie Wolff, whose vocals are intertwined with Bob Rutman's chant in Tibetan Buddhist style. Prior to this, Wolff had only appeared as a guest singer with the groundbreaking krautrock outfit Brainticket. Her deep and delicate tones go beyond spirituality and take listeners on a space travel to open skies.
Recorded live at Passionskirche in Berlin on May 31st, 1989, in the prime of the Ensemble's career, this is one of the last few examples of great, powerful music made by humans without the indiscriminate use of electronics or binary codes.
A sometimes frightening and breathtakingly intense performance, as thoroughly mysterious as early American soil, as it first appeared to the eyes of visionary European minds.


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A month or so ago I bought these bright blue shorts at Gap and didn't have much in my closet that they matched. This is when having a huge stash of fabrics and patterns comes in handy. I made a muslin to get the fit ironed out and it was pretty simple after that. I have found I really need some sort of embellishment or design element at my neckline to make the girls look more proportionate to my body. Also, it has to be really fitted through the bust or I look like a boy.
Initially I planned to wear this belted but, because of the suit-like boucle fabric, it was too hold-all-my-calls-I'll-be-in-a-meeting looking for my taste. I do haul around two boys and a baby after all. I feel most comfortable by not looking overly formal in my casual wear.
Lined jackets usually turn out well for me. You would think I should have a closet full of them. This fabric is from JoAnn's and is from the same line of fabrics that this top came from and that I now cannot remember the name of. I think it was Venice something or another. Anyone remember the name of this line? Does anyone other then me ever pay attention to that?
If I remember correctly (currently I have misplaced my pattern for verification), I made a 12 at the shoulders, a 10 through the upper torso, cut the side fronts a 6 through the bust, and tapered out to a 12 at the hips. A hook and eye was added by the top button to keep the front overlapping edge flat against the other side.
Here you can see it does indeed button up and fit me. I just prefer the more casual one button look.
I added a full lining of Ambiance. After making a few Burda jackets, I always liked how they never had the front interfaced facing seamed over the bustline. If you look hard enough you can see where the front facing was split in two, with the middle part cut from lining fabric.
This has been completed for two weeks but I didn't like the original buttons I chose for it. I usually really like picking out buttons and will do it at a button sale for a whole bunch of garments that I've planned out. Sometimes it is a year or two until I get around to them but I like to have it all on hand when the mood to make something new arises. Rarely do I change my mind about the notions I've picked out for something but this time I'm not sure what I was thinking.
Jacket with original buttons that were white with black backings |
This was a nice project without any major problems or fit issues and now I have something really cute to match my shorts. I still want to make the other version with the ruffled collar at some point. It will probably be a sleeveless vest just to change things up.


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Session 4 R- A Developmental Approach to Separation and Loss
Please contact us if you have questions or want to discuss anything you've read or seen on our website further. We are available to answer any questions and assist you with an adoption application, if needed. We will get back to you within three business days.
Hours of operation
9 am – 5 pm, Monday to Friday.


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Our new Trail D3O Gloves feature added D3O knuckle protection for those pesky trail obstacles. Pair that with silicone-printed fingers for grip and brake lever control, an AX Suede palm for durability and bar feel, and added ventilation for hot spots and you're left with a protective trail glove that gives nothing up to control or breathability.
- Adjustable, debossed neoprene cuff closure makes for a snug fit around your wrist, keeping unwanted debris from sneaking into your gloves.
- Ax Suede palm provides durability without sacrificing bar-feel.
- Brushed tricot thumb wipe for sweat.
- Compatible with conductive touchscreens.
- D3O protective foam is strategically sewn into Nylon fabric for added finger protection.
- Fabric Content: Back of hand: 90% Nylon, 10% Elastane; Palm: 100% Polyester Ax Suede
- Laser-perforated palm aids in breathability and ventilation for the hottest spots on your hands.
- Silicone-printed fingers provide maximum handlebar and brake grip.


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The IRS is planning to create a new, online portal called "Where's My Economic Impact Payment" where people can obtain details about their payment from the economic stimulus package and also provide their banking information.
After the CARES Act passed through Congress, Treasury and the IRS had estimated there would be 171 million rebate payments under the Act and that 101 million of these would have to be paid by paper check (through the mail) unless the IRS received direct deposit information for those recipients before the check was sent.
The Treasury Department is expected to take the first step on Friday, April 10th which involves clearing the payments that will be directly deposited. Banks expect a Treasury Department transmission Friday to confirm the money will reach the correct accounts. The IRS is meant to start processing the payments on Monday, April 13th and direct deposits would show up in recipients' bank accounts on Wednesday.
As a refresher, the payments are up to $1,200 for individuals, $2,400 for couples and an extra $500 for children. Additional info can be found here.
For those who do not yet have direct deposit information on file with the IRS, there are three options to handle that before a paper check ends up in the mail:
Each month, we will send you a roundup of our latest blog content covering the tax and accounting tips & insights you need to know.
We care about the protection of your data.
You can count on us for professional, timely and reliable tax and accounting services. If you're ready to get started, just fill out this form and we'll be in touch.


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Today's operating room requires an enhanced focus on the needs of your patients and staff, as well as safety. Stryker's iSuite is your customized, efficient, and seamlessly integrated operating room - designed to tackle the many demands of your OR and allow you and your team to focus on the patient.
To create your iSuite, our team will guide you through the entire process, one Stryker has successfully completed thousands of times. Our process is comprised of three essential elements – design, equip and connect. This includes designing and planning your room, providing excellent equipment and connecting your OR to the world.
Connect with
Stryker Communications
We design
A state-of-the art surgical experience starts with great design. Combining best in class design tools and years of experience, our sales consultants and design experts will work with you to establish goals, timelines, and deliverables.
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Virtually create your OR using ByDesign, Stryker's exclusive 3D room design software.
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Through the ground-breaking power of mixed reality, the HoloLens' self-contained holographic computer brings your OR to life.
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Envision your OR of the future through our immersive design experience, wherever you are.
One of the most important considerations when building a new operating room is planning and designing the new environment. With decades of experience, we have teams and technology to make sure we get it right.
Learn moreFrom design to execution, our team will oversee the process of creating your customized iSuite operating room.
Learn moreOur iSuite offers a combination of equipment and software that transform the traditional operating room into a modern, state-of-the-art surgical environment, empowering your surgical teams. We collaborate with you to understand your unique business needs for you to deliver outstanding patient care. Design. Equip. Connect. Partnership.
Learn moreWe equip
From surgical tables, lights and equipment management, to video integration systems, Stryker offers all the major equipment for the fully integrated OR. Create a unique, customized environment, regardless of your specialty.
Illuminate the surgical field in your operating suite with our Chromophare F Generation surgical light. Offering multiple configuration options, you can customize the lighting experience to fit your OR.
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Learn moreThe Operon D760 is an economical way to bring our quality to your surgical suite. Delivered with the same quality and service which is exemplified by Stryker's history, the D760 provides a robust solution for your facility.
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Learn moreThe Operon D850 surgical table is designed to deliver on the increasing demand for flexibility, while providing for a wide range of applications with its improved mobility and modular design.
Learn moreLike the Operon line of surgical tables, our surgical table accessories are characterized by robust construction, ergonomic functionality and a wide range of applications designed to meet the needs of various surgical specialties.
Learn moreWe connect
Seamlessly connect and share critical data including surgical video with hospitals, surgeons, staff, providers, EMR systems, and patients. Stryker's workflow and connectivity solutions securely integrate information systems with your devices. Our platform allows the flexibility to archive, edit, and share surgical content. In addition, it allows you to communicate important information internally and externally to maximize educational opportunities and expand your continuity of patient care.
Our OR integration, with its intuitive workflow and safety features, allows nurses to focus on their patients rather than managing the nuances of the surgical space.
Learn moreiSuite live video connects clinicians within the operating room to other ORs, pathology for lab verification, surgeons for intraoperative consultations, and to auditoriums for education.
Learn moreOur EHR connectivity solution that allows bi-directional communication with the EMR.
Learn moreOur AV router with modular matrix configurability centralizes room control for OR video and surgical devices.
Learn moreOur media asset management system that allows you to archive, edit and share media content captured during surgical cases.
Learn moreWe partner
Our partnership goes beyond designing, equiping and connecting your iSuite integrated operating room. With our ProCare services you can count on a trusted partner for expert support and maintenance for your medical equipment.
Our Flex Financial solutions provide a range of smart purchasing alternatives designed to fit your organization's needs.
SMACC Number 2019·22279


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Turquoise Mala Chain Silver Skull Necklace
Necklace Profile:
🔱Our Mala skull chains are made of natural turquoise stones and 925 silver beads to create an exquisite conversation piece. The complimentary sterling silver beads and the realistically sculpted Guru skull bead complete the look. Blue turquoise is said to improve the flow of fortune and attract good luck and it brings a sense of light and tranquility.
🔱 Each chain will be carefully handmade with a lot of love and attention to details, we can customize any length of your preference to perfectly suit your taste.
🔱 Fully customizable chain with a black buffalo horn skull or an antler skull or a sterling silver skull to give the chain necklace your own personal touch.
🔱 With over 200 grams of exotic materials, this chain necklace not only looks otherworldly but also feels luxurious and bold.
🔱 Customizable bead size, please contact us for options.
99.9% Satisfaction Guarantee.Because there's always room for improvement and our commitment to craftsmanship and service extends beyond delivery.
We at Mortis Ores want you to be thrilled with your new purchase. If you don't have a positive experience of our work for any reason, we will do all it takes to make sure you are satisfied with our after care service.
How to Return an Item
Step #01: Contact us
Send an email to email@example.com and tell us you want to return your product. Be sure to include your order number in the email. It's crucial that you contact us first, as we have multiple return addresses in Asia and Europe.
Unfortunately, we cannot confirm any returns from customers if we are not contacted ahead of time!
Step #02: Send the item back to us
Send the item back to us, to the address given by our support team. Make sure you leave a note with your order number in your return package. You will be responsible for paying for your own shipping costs for returning your item (except for quality-related issue). Shipping costs are non-refundable. We recommend using a traceable shipping service or purchasing shipping insurance.
If returning for refund, please ensure your jewelry has no visible signs of wear and, if possible, is returned using the original packaging including original papers/invoice.
PLEASE NOTE: If returning an order from outside of our product origin countries, please ensure that your courier understands and marks the shipment as RETURNED GOODS, therefore no duties or import fees are charged to shipment. If the shipment comes with tax/duties, the package will be refused and returned to you.
Step #03: Get your refund
Once we receive your item, we will inspect it and notify you that we have received your returned item. We will immediately notify you on the status of your refund after inspecting the item.
If your return is approved, we will initiate a refund to your credit card (or original method of payment). You will receive the credit within a certain amount of days, depending on your card issuer's policies.
Restocking Fees
We charge the following restocking fees for all made to order jewelry:
One-Size Necklaces / Pendants / Adjustable Rings
Returnable for a refund within 15 days of delivery. A 15% restocking & handling fee will be deducted from your refund.
Custom Sized / Bespoke Jewelry
Personalized jewelry are ineligible for return, exchange, or refund. unless it is a quality related issue upon delivery. In the unlikely event of such issue, please contact us within 48 hours of delivery confirmation.
Precious Gemstones and Diamonds Jewelry
Diamonds and gemstones are final sale and therefore ineligible for refund, return, or exchange. For any craftsmanship related issue, we will fix your jewelry at our costs.
Cancellation Policy
If you wish to cancel your order, please email us with your cancellation request as soon as possible to avoid cancellation fees. Because of the made-to-order nature of our work, you may do so without charge within 48 hours/the following business day of initial order time. Orders cancelled after 48 hours may be subject to cancellation fees appropriate to the order.
Fit & Size Exchanges
We offer size exchanges on most standard sized jewelry, please contact us for more information on remaking, exchanging, or modifying your customized jewelry.
Engraved Jewelry
Engraved jewelry may be returned or exchanged depending how the engraving is done, please contact us when necessary.
Shipping & Quality Related Issues
If you do not receive your product (due to lost mail for example)
If the item you receive is defective or faulty, damaged during shipping , we refund you the credit to the original payment method or resend the item after receiving photo/video proof. If you believe your item was damaged during shipping, it is important to send our Customer Care team photographs or video showing the damaged packaging as well as " Proof of Damage" documentation issued by the courier, where applicable, to process your exchange or refund. Alternatively, if the package was damaged on delivery, you can reject it. Mortis Ores will ship you a new replacement at the earliest date possible upon courier's confirmation.
For damaged product, it is important to report such damage within 48 hours after your package has been delivered.Once we receive your package, we will issue credit in the amount of your item, plus the cost of the return shipping, provided that you also include a copy of the receipt itemizing the return shipping cost.
Please be aware that the actual colors of our printed items or natural antlers, gemstones may differ slightly to the colors displayed by your digital devices' screen, this by no means will be considered defective or faulty by our quality standard.
If you feel your item is significantly different from the product description and photos, you can A: Return it within 15 days of receiving your product and get a store credit or a full refund, or B: Get a partial refund and keep the item.
Mortis Ores reserves the right to charge 15% handling fee for all items returned due to non-quality issues.
If you receive a wrong item:You can either 1) exchange it for the right item ( when in stock) or 2) return it for a full refund. Customers must confirm their eligibility for an exchange or return with our Customer Care team before sending the items back.
Our return policy lasts 15 calendar days. If 15 calendar days have gone by since you have received your purchase, unfortunately we can't offer you a refund or exchange.
If an item is missing from your order: contact our Customer Care team to inform about the missing item from your order. Once we confirm that an item was missing, we will offer a full refund of the item value or initiate the replacement process.
To be eligible for a return, all merchandise returns must be unworn, unused, unwashed, and still, have the original tags attached ( where applicable ).
To complete your return, please make sure to specify order number(s) on the return packaging so we can ensure your credit is refunded accurately.
You will be responsible for paying for your own shipping costs for returning your item, except for any quality related issues. Shipping costs are non-refundable. In case if you have paid import duty of your purchase, we cannot refund your import duty & taxes or any other associated brokerage fees.
The following terms also apply:
* All returns must be authorized by Mortis Ores by Email.
* Money back guarantee does not apply to engraved items, print-on-demand garments (except for quality-related issues), gift cards, or sale items.
* For Made-to-Order custom sized jewelry, we do not offer refunds but we do facilitate exchanges for different sizes or different jewelry of equal values.
* Mortis Ores reserves the right to revoke this offer if we identify what we believe to be a pattern of abuse or fraud.
* We do not cover import duties, tariffs, or other fees paid by customers to third parties in order to receive the order.
* We do not provide refunds for products that have been used, altered, or damaged after you've received the shipment.
* Returned apparel must be unworn and unwashed ( free of any detectable stains from makeup, deodorant or wear )
* Damages and defective items must be reported within 48 hours of receiving merchandise or it cannot be returned.
* If you believe you have received an incorrect item, please contact us within 48 hours of receiving your package.
* We recommend shipping packages back using Flat Rate shipping with a tracking number, as we are not responsible for lost packages or stolen packages. Without proof of receipt and delivery, Mortis Ores will not issue return credit.
* Please note that original shipping fees are non-refundable and return shipping costs are the customer's responsibility. Mortis Ores does not provide return shipping labels. A restocking fee of 15% of original purchase price will be assessed on orders that are refused by the customer at the time of delivery due to non-damage or non-quality issues, or returned due to an "un-deliverable" address.
Reserved Rights Regarding Returns
Mortis Ores reserves the right to solely define and limit, refuse, and/or reject returns from customers at any time due to:
- An irregular or excessive returns history indicative of "wardrobing;"
- An irregular or excessive returns history involving worn, altered, laundered, damaged, or missing items; or,
- Potential fraudulent or criminal activity.
Sale Items
All sale items cannot be returned for refund or store credit. Additionally, all print-on-demand garments are non-returnable, however, we do offer sizing exchanges for first-time customers.
Non-returnable items:
- Gift cards
- Any item not in its original condition, is damaged or missing parts for reasons not due to our error.
- Any item that is returned more than 15 days after delivery.
- Shipping costs.
- Made-to-Order Jewelry, Bespoke Jewelry and other print-on-demand arts and garments (unless there is actually something wrong with the print or product).
Return by Mail
Kindly note that without including your order number on the returns slip with your returned item(s) there may be a delay in processing your return.
Pack your item(s) securely in the original product packaging, if possible. All items must be returned in original condition (including all paperwork, packaging, and accessories) with tags attached, where applicable.
All return shipping charges must be prepaid. We do not accept COD deliveries; they will be rejected. We recommend sending your return via local Flat Rate shipping with a tracking number and insurance, as we are not responsible for lost or stolen packages.
If you are shipping an item over $75, you should consider using a traceable shipping service or purchasing shipping insurance. We can't guarantee that we will receive your returned item without traceable shipment.
Refunds (if applicable)
Once your return is received and inspected, we will send you an email to notify you that we have received your returned item. We will also notify you of the approval or rejection of your refund.
If your return is approved, then your refund will be processed within 2 business days, and a credit will automatically be applied to your credit card or original method of payment, within a certain amount of days, usually between 7-14 business days, the refund will reflect on your bank or credit card statement.
Mortis Ores does not credit original shipping charges.
Still Need Help? Catch Us Here!
Precious Metal Jewelry Care
With time, any precious metal jewelry piece that is exposed to air will tarnish.Silver and brass tarnishes faster in areas with high humidity and air pollution. Additionally contact with materials like cosmetics, hairspray, perfume, deodorant, body lotion, bleach, etc., can speed up the tarnishing process.
- Avoid direct contact with body lotions, perfume, hair sprays, sunscreen or other chemicals.Remember to remove rings & jewelry while applying those products.
- Remove jewelry before going to bed.
- Keep away from heat / direct sunlight, avoid humidity,keep your silver jewelry out of the bathroom and shower area.
- Remove jewelry when bathing, showering, swimming or during spa treatment.
- Remove jewelry during physical activities, e.g. gym, cleaning, gardening.
- Do not use paper towel or tissue to clean/wipe as they may contain wooden particles that may scratch the jewelry,use a soft silver cloth.
- Store jewelry in an air tight jewelry box to keep them moisture free.
- Avoid sulfur producers such as leather, newspaper, rubber and when preparing foods containing sulfur such as eggs, onions, fish or shellfish.
To clean or silver or brass, use a soft cloth with a polish formulated specifically to remove tarnish. You can find fine silver polishes, solutions, or cloths appropriate to remove tarnish at hardware stores or specialty craft stores. For our special decayed or black coated jewelry, retouches will be needed to restore the finish, please contact us for such complimentary service.
Leather, Antler, Bone & Fossil Care
Exotic materials such as leather, antler, animal bones and Mammoth ivory fossil should be kept out of direct sunlight or extreme heat or cold for prolonged period of time, and should be removed when using strong chemicals and other abrasive substances (including hand sanitizer).
Avoid sudden temperature changes, for example, if you stay for a long period in an air-conditioned cold & dry room, remove your exotic jewelry and put it in your pocket when you go out into hot and intense sunny outside.
Exotic jewelry should also be removed when washing hands, showering, swimming, dish-washing, or partaking in any water activities, especially in chlorine-sanitized pools and seawater. As with most jewelry, we would advise that you remove your ring when you plan on doing anything that may cause harm to the jewelry, including physical labor or heavy lifting, such as during workout sessions and gardening. Also, if the ring fits too tight and it is a struggle to remove the ring, this can cause damages and cracks.
To best condition your antler and Mammoth ivory fossil jewelry, we recommend unscented baby oil. Apply a few small drops baby oil on your jewelry and wipe with clean soft cloth or gloves once every 2-3 weeks for best results.
Once the fossil or antler jewelry get dirty, never use detergent to clean, use soft brush or cloth to wipe.
If you need any further care tips about our jewelry, please contact us here.


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This technique also applies to navigational components that are repeated. Web pages often contain a navigation menu or other navigational component that allows the user to jump to other Web pages. This technique makes the placement of navigational components more predictable by presenting the links or programmatic references inside a navigational component in the same relative order each time the navigational component is repeated. Other links can be removed or inserted between the existing ones, for example to allow navigation inside a subsection of a set of Web pages, but the relative order is not changed.
A Web site has a logo, a title, a search form and a navigation bar at the top of each page; these appear in the same relative order on each page where they are repeated. On one page the search form is missing but the other items are still in the same order.
A Web site has a left-hand navigation menu with links to the major sections of the site. When the user follows a link to another section of the site, the links to the major sections appear in the same relative order in the next page. Sometime links are dropped and other links are added, but the other links always stay in the same relative order. For example, on a Web site of a company that sells products and offers training, when a user moves from the section on products to the section on training, the links to individual products are removed from the navigation list, while links to training offerings are added.
Resources are for information purposes only, no endorsement implied.
List components that are repeated on each Web page in a set of Web pages (for example, on each page in a Web site).
For each component, check that it appears in the same relative order with regard to other repeated components on each Web page where it appears.
For each navigational component, check that the links or programmatic references are always in the same relative order.
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If this is a sufficient technique for a success criterion, failing this test procedure does not necessarily mean that the success criterion has not been satisfied in some other way, only that this technique has not been successfully implemented and can not be used to claim conformance.


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I know very little about .NET but know my way around C++. I have a C++ interface which I have been asked to wrap to make it .NET callable. I did some research and came across terms like platform invoke, c++/cli, and C++ Invoke...I'm rather confused as I would imagine with the code already there, wrapping should just be a technicality. I would appreciate any simple pointers to how would be a straightforward simple way of going about it, and any resources which could help me do so. I've found only a couple examples online including on this website but it's a bit cryptic to me and I'm wondering if i could be pointed to some more basic tutorial like resources if available.
Thank you