→ Continued from “Captives of the Cloud: Part I”

Is the future of the world the future of the internet?

– Julian Assange1 01/14 The cloud is the informational equivalent to the container terminal. It has a higher degree of standardization and scalability than most earlier forms of networked information and communication technology. From social networking to retail, from financial transactions to e-mail and telephone, these and many other Metahaven services end up in the cloud. Surely, the internet already was a wholesale for all types of information and media formats. As Milton Captives of the Mueller notes, these “used to be delivered through separate technologies governed by Cloud: Part II separate legal and regulatory regimes,” while now having converged on the internet and its protocols.2 In the cloud, such “digital convergence” goes even further: data becomes more effectively and thoroughly harvested, analyzed, validated, monetized, looked into, and controlled than in the internet; its centralization is not just one of protocol, but also of location.

The Form of the Cloud Many writers in recent decades have grappled with a seemingly borderless information society rooted in physical territories, and finding words for this condition has been key to most serious writing about information networks. For example, the term “space of flows” was coined in the 1990s by the Spanish sociologist Manuel Castells. It describes the spatial conditions of the global movement of goods, information, and money. According to Castells, the space of flows is

constituted by a circuit of electronic exchanges (micro-electronics-based devices, telecommunications, computer processing, broadcasting systems, and high-speed transportation – also based on information technologies) that, together, form the material basis for the processes we have observed as being strategically crucial in the network society.3 e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I Castells adds that this material basis is “a spatial form, just as it could be ‘the city’ or ‘the region’ in the organization of the merchant society or the industrial society.”4 As legal scholars Tim Wu and Jack Goldsmith note in their study Who Controls the Internet?, beneath “formless cyberspace” rests “an ugly physical transport infrastructure: copper wires, fiberoptic

10.16.12 / 11:23:36 EDT “Cypherpunk Dream” versus “Data's Empire.” The dichotomy of the internet according to Michael Froomkin.

“Like” versus “Law”: An “Extrajudicial Dislike” by US Senator Joe Lieberman prompting an industrial embargo against WikiLeaks.

10.16.12 / 11:23:36 EDT cables, and the specialized routers and switches propose a radical reification of it. This that direct information from place to place.”5 would mean its transformation into a finite James Gleick describes the network’s data “thing” among other finite things, and not center, the cables, and the switches as “wheel- always see the network and its derivatives works,” and the cloud as its “avatar.”6 The cloud like something immaterial and invisible, presupposes a geography where data centers without a form we can trace and change.9 can be built. It presupposes an environment protected and stable enough for its server farms 03/14 In discussion with Aureli, the theorist Boris Groys to be secure, for its operations to run smoothly asserts that the network is situated on (or below) and uninterrupted. It presupposes redundant a “defined territory, controlled by the military.” power grids, water supplies, high-volume, high- On those terms, Groys claims, speed fiber-optic connectivity, and other advanced infrastructure. It presupposes cheap the goal of future wars is already energy, as the cloud’s vast exhaust violates even established: control over the network and the most lax of environmental rules. While data the flows of information running through its in the cloud may seem placeless and architecture. It seems to me that the quest omnipresent, precisely for this reason, the for global totalitarian power is not behind infrastructure safeguarding its permanent us but is a true promise of the future. If the availability is monstrous in size and scope. network architecture culminates in one According to 2012 research by the New York global building then there must be one Times, the cloud uses about thirty billion watts power that controls it. The central political of electricity worldwide, roughly equivalent to question of our time is the nature of this thirty nuclear power plants’ worth of output. future power.10 About one quarter to one third of this energy is consumed by data centers in the United States. According to one expert, “a single data center A Renaissance of the State can take more power than a medium-size town.”7 The early internet, in the hearts and minds of its đđđđđđđđđđA data center is a windowless, large, flat idealists, was something of an anarchic place. building. Its architecture is foreshadowed by the John Perry Barlow prefigured the “cyber-idealist” suburban big boxes of Walmart and the like. position in his manifesto, “A Declaration of the Unlike megamalls, the precise locations of data Independence of Cyberspace,” published in 1996. centers are secret. Companies don’t usually Barlow asserts that the network and its advertise where data centers are: not the public inhabitants are independent from the old- image of their operations, but their actual fashioned rules and regulations of territorial operations, depend on them.8 To users, the cloud states, who have “no sovereignty where we seems almost formless, or transparent – always gather”: available, ever-changing, hanging in the air, on screens, in waves, appearing and disappearing, Your legal concepts of property, expression, “formless cyberspace” indeed. Yet at the core of identity, movement, and context do not this informational ghost dance lies a rudimentary apply to us. They are all based on matter, physical form – steel and concrete and there is no matter here. ... Our infrastructure. If the enormous, energy-slurping identities have no bodies, so, unlike you, we data factories are the cloud’s true form, then cannot obtain order by physical coercion. these instances of the “space of flows” recall the We believe that from ethics, enlightened medieval castle, the treasure chest, and the self-interest, and the commonwealth, our military base. They recall the political and governance will emerge. Our identities may military conflicts that have dominated geography be distributed across many of your since recorded history. As the architect and jurisdictions.11 writer Pier Vittorio Aureli states, Barlow’s manifesto declared cyberspace a socio- Any power, no matter how supreme, political commons. A space seemingly beyond

totalitarian, ubiquitous, high-tech, e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I gravity, beyond the state – “a world that all may democratic, and evasive, at the end has to enter without privilege or prejudice”; “a world land on the actual ground of the city and where anyone, anywhere may express his or her leave traces that are difficult to efface. This beliefs.” Barlow’s ideas have somehow is why, unlike the web, the city as the actual resonated; indeed, Saskia Sassen mentions that space of our primary perception remains a “a distinct issue concerning the relation between very strategic site of action and the state and digital networks is the possibility counteraction. ... But in order to critically for the average citizen, firm, or organization frame the network, we would need to operating in the internet to escape or override

10.16.12 / 11:23:36 EDT most conventional jurisdictions.” Some of this of any jurisdiction.20 HavenCo joined the dotcom thought, according to Sassen, is “still rooted in boom with angel investment from Joi Ito (among the earlier emphasis of the internet as a others), who declared himself, still in 2002, “a decentralized space where no authority great fan of the concept.”21 Sealand’s fragile structures can be instituted.”12 Milton Mueller sense of half-tested nationhood would comments that cyber-libertarianism “... was theoretically raise the bar for any opposing never really born. It was more a prophetic vision jurisdiction to physically invade the offshore than an ideology or ‘ism’ with a political and 04/14 host. It would, indeed, demonstrate that cyber- institutional program. It is now clear, however, libertarian ideology could take full control of an that in considering the political alternatives and experimental country, and reform the internet in ideological dilemmas posed by the global its name. James Grimmelmann, a professor at internet we can’t really do without it ...”13 New York Law School, is skeptical about Sealand đđđđđđđđđđConfusingly and hilariously, one place where and HavenCo’s treatment of the law: the rhetoric of borderless information freedom is most pervasive is in the cloud. The world’s most HavenCo was selling the end of law. ‘Third- powerful information companies have inserted world regulation’ was a euphemism for some of the internet’s foundational optimism in minimal regulation – or none at all. In its their mission statements. These tech giants talk search for the lowest common about themselves as heartwarming charities. denominator, HavenCo was willing to divide Every billionaire CEO is his own private Dalai by zero.22 Lama. Pseudo-liberal jabberwocky of assumed universal validity permeates the junkspace of Grimmelmann also questions HavenCo’s mission statements, annual reports, and TED effectiveness, as “for most purposes, cheap talks, especially when it comes to the cloud. commodity hosting on one side of the Atlantic or Microsoft wants to help everyone around the the other could easily outcompete Sealand’s world “realize their full potential.”14 Facebook more expensive boutique product in the middle aims to give “people the power to share and of the North Sea.”23 Grimmelmann rhetorically make the world more open and connected.”15 continues, “in an age of YouTube, BitTorrent, and Skype makes it “simple to share experiences the darknet, who needs HavenCo?”24 Sealand with the people that matter to you, wherever they was the flagship store of the internet’s anarcho- are.”16 And Instagram, bought by Facebook, libertarian movement. The P2P BitTorrent envisions “a world more connected through platform The Pirate Bay famously tried to buy the photos.”17 ailing principality in 2007, offering citizenship.25 đđđđđđđđđđCyber-utopianism never translated into a Michael Froomkin, in a June 2012 lecture at the policy outlook of sorts. But it is still associated Oxford Internet Institute, sketched out an with a set of practices and spatial forms: online arresting and slightly dystopian view of the anonymity, cryptography, Peer-To-Peer (P2P) file current internet. It looked like a complete sharing, TOR (The Onion Router) bridges, dichotomy – a dialectic between two opposing bulletproof hosting, and offshore data havens, to visions, each serving broadly similar goals by name a few examples. Michael Froomkin, a completely antithetical means.26 The dialectic professor at the University of Miami School of was between “Cypherpunk Dream” and “Data’s Law, defined the data haven in 1996 as “the Empire” (see diagram), where most of the information equivalent to a tax haven.”18 This anarchic (Barlow-style) stuff would be on the “place where data that cannot legally be kept first side, and most of the cloud and surveillance can be stashed for later use; an offshore web on the other. Oddly, two cloud-based services, host” appears omnipresent in the cyber- YouTube and Twitter, still appeared under the libertarian universe of thought, and is indeed an Cypherpunk Dream, presumably because of the extreme form of keeping information away from pivotal role both services play in online activism antagonistically minded states, corporations or and “getting the information out.” Froomkin courts.19 The data haven is the spatial form that, connects Data’s Empire to a “renaissance of the at least theoretically, enables the evasion of state” – a re-emergence of state power over the sovereign power, while establishing an enclosed e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I network and the networked, perhaps, Froomkin territory on the face of the earth. The data haven suggests, in an unwitting reaction to a largely once provided a business model for the unrealized spectre of internet utopianism and Principality of Sealand, an unrecognized mini- anarchy. While both the Cypherpunk Dream and state founded by a British family on a former war Data’s Empire seem to have a business model, platform in the North Sea. A notorious example the first one’s is Ayn Rand-style anarcho- in internet law, Sealand was, in the early 2000s, capitalism, while the latter’s looks more like a home to the servers of HavenCo, a startup digital form of industrial capitalism. The cloud, providing offshore data hosting beyond the reach with its data factories, “scalability,”

10.16.12 / 11:23:36 EDT The WikiLeaks blockade: an embargo by a private “cloud” of companies, impacting the site's key resources. The actual embargo is below the timeline; some of the “countermeasures” are displayed above it.

Escape Chess: Julian Assange's jurisdictional cat-and-mouse game with the powers that be.

10.16.12 / 11:23:36 EDT standardization and centralization, indeed looks ‘law’ says on it, if it has no correspondence with a little like an industrial revolution, yet it is one what people do, it is no law at all.”31 And indeed, largely one without a working class. This it isn’t. A mere thirteen years after Foucault in industrial complex actually dislikes most things Cyberspace, the controversial whistleblowing that are small. Indeed, many of Silicon Valley’s web site WikiLeaks found itself to be the living cloud protagonists practice “acq-hiring”: proof of this, as it became embargoed by US promising startups are purchased only to get companies. hold of their talented staff, while the product or 06/14 đđđđđđđđđđWikiLeaks began in 2007 as an concept that staff worked on gets discarded.27 “uncensorable” web platform for the release of One of the most arresting aspects of Froomkin’s leaked documents. Through an anonymous drop scheme however is not in the dialectic as such, box, users could upload digital files to WikiLeaks. but in the reason he suggests for why it came The material would be published only if it had not about in the first place. been published before, and if it were of historical, ethical, or political significance. The The Legal Void of “Like” vs. “Law” site first used a wiki format, where users and Cyber-libertarians, in hopes of evading the members would analyze and comment on on the state’s grasp, assumed that its coercive powers leaks. The wiki format was since abandoned, but would be constrained by jurisdictional and the name WikiLeaks remained. The site would be constitutional limits. As James Grimmelmann practically uncensorable for any government, concisely puts that thought, “HavenCo since its hosting was set up in multiple simultaneously thumbed its nose at national law jurisdictions. Its materials would be stored on and relied on international law to protect servers in multiple countries, and thus be Sealand.”28 The possibility of states evading their protected by the laws of these countries – a bit own law, or international law, going rogue, sub- like a distributed version of the Sealand data or supra-legal in their handling of disruptive haven. On July 29, 2009, as WikiLeaks published actors, was not considered. The dream of the high-exposure loan book of the bankrupt offshore information freedom reflects this vision. Kaupthing Bank, the site ran a discouraging note But state power can be deployed in a legal void, for its adversaries which demonstrated the legal as was recognized early on by James Boyle, a firewalls it had constructed for itself against professor of law at Duke University. In his 1997 state and corporate power: text Foucault in Cyberspace, Boyle refuted much of the legalistic optimism of cyber-utopianism: No. We will not assist the remains of Kaupthing, or its clients, to hide its dirty Since a document can as easily be retrieved laundry from the global community. from a server 5,000 miles away as one five Attempts by Kaupthing or its agents to miles away, geographical proximity and discover the source of the document in content availability are independent of question may be a criminal violation of both each other. If the king’s writ reaches only as Belgium source protection laws and the far as the king’s sword, then much of the Swedish constitution.32 content on the Net might be presumed to be free from the regulation of any particular Upon receiving a complaint from Kaupthing, a sovereign.29 Reykjavik court silenced Iceland’s national broadcaster RUV, which was planning to break Even then, Boyle argued, de facto authority can the story on television. So instead of airing the still be exercised by the state, as story, the TV host pointed viewers to the WikiLeaks web site, where they could see the the conceptual structure and documents for themselves – to great social and jurisprudential assumptions of digital political effects in Iceland. WikiLeaks could libertarianism lead its practitioners to evade the gag order by hosting its information ignore the ways in which the state can offshore – indeed, multiple times so. It was, as often use privatized enforcement and Boyle would say, beyond the power of a particular

state-backed technologies to evade some e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I sovereign. WikiLeaks systematically won its of the supposed practical (and jurisdictional chess games until, on November constitutional) restraints on the exercise of 28, 2010, it began releasing its biggest leak ever: legal power over the Net.30 a trove of hundreds of thousands of classified diplomatic communications from US embassies Boyle stressed that state power doesn’t need to all over the world, now commonly referred to as operate in ways that confront its constitutional “Cablegate.” limits. In a similar vein, Grimmelmann concludes đđđđđđđđđđWikiLeaks’ source of income is that “no matter what a piece of paper labeled crowdfunding; the site relies on public

10.16.12 / 11:23:36 EDT donations, processed by the Wau Holland to deny Domain Name System (DNS) service and Foundation based in Kassel, Germany. Wau cloud-storage facilities, disrupt payment Holland is reported to have collected about one systems services, and disable an iPhone app million euros in donations to WikiLeaks in 2010. designed to display the site’s content.” Benkler This, according to CBS News, would have paid asserts that the attack came from multiple WikiLeaks founder Julian Assange a salary of sources, some of which were more clearly and about sixty-six thousand euros that year.33 The directly involved and identified than others. Yet crowdfunding went through “conventional 07/14 indirectly and opaquely, Yochai Benkler argues, payment channels”: PayPal, an online payment the attack came on behalf of the Obama system owned by eBay, Western Union, and VISA administration, and MasterCard, two corporations which together virtually dominate the credit card having entailed an extra-legal public- market. One could say that the WikiLeaks private partnership between politicians donations relied on a private “cloud” of gunning to limit access to the site, intermediary, US-based companies. According to functioning in a state constrained by the WikiLeaks’ own account, funding after the First Amendment, and private firms release of the first cables peaked at an all-time offering critical functionalities to the site – high of 800 thousand individual donations in a DNS, cloud storage, and payments, in single month.34 particular – that were not similarly đđđđđđđđđđ Upon the release of the cables, WikiLeaks’ constrained by law from denying service to Sweden-based servers were hit by a vast the offending site. The mechanism coupled distributed denial of service (DDOS) attack, a legally insufficient but publicly salient which compelled the organization to make the insinuation of illegality and dangerousness move of hiring cloud space from Amazon Web with a legal void.38 Services (AWS). On December 1, 2010, a day after the site’s move to the cloud, Amazon kicked all James Boyle asserted that there can be a WikiLeaks files from its servers, marking the “formal language of politics organized around effective beginning of a pan-industrial, state- relations between sovereign and citizen, corporate embargo.35 Amazon’s decision was expressed through rules backed by sanctions,” prompted by an aggressive call to arms from Joe versus an “actual experience of power.” The Lieberman, senior US Senator for Connecticut, distinction is significant – it captures, spot on, and chairman of the Senate Committee on the role of the state in the WikiLeaks embargo. Homeland Security. Lieberman urged American The “actual experience of power” operates much enterprises – including Amazon – to stop more like a social network – Senator Lieberman providing services to the whistleblowing site, occupying a powerful node, capable (or, even though he had no legal authority to enforce believably suggesting being capable) of a this.36 His words amounted to nothing more than potentially devastating set of cascading effects an opinion. Lieberman took the position of both in case his friendly suggestions are not followed accuser and judge, stating that “it sure looks to up – Don Corleone’s offer you can’t refuse, pure me that Assange and WikiLeaks have violated the and simple. Power then is to personally govern Espionage Act.”37 The result was that WikiLeaks’ the pressing and depressing of “Like” buttons, vital infrastructure fell through, as key deciding on life or death, like Romans once companies withdrew themselves from WikiLeaks presided over the fate of gladiators. Facebook’s without the check of a court. EveryDNS, a “Like” symbol – a thumbs up – has its origins in California-based domain name registry, stopped ancient Rome. Arguably, Lieberman clicked the providing access to the wikileaks.org domain “Dislike” – thumbs down – on WikiLeaks, causing name server, so that the site would only be a wave of consequences resulting from his reachable if a user entered its IP address in the private, social, network power, while backed by browser bar. MasterCard, PayPal, VISA, and his stature as a Senator. James Grimmelmann Western Union ceased to process WikiLeaks comments: donations. Apple removed a WikiLeaks iPhone app from its store, as was noted in Part I of this e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I It is not just that Lieberman possesses the essay. These operations, together, amounted to usual sovereign power, so that his public an extra-legal embargo for which the statements are raw threats. There is a organization was unprepared. Yochai Benkler, a political cost to him to pushing legislation; professor of law at Harvard University, examines it will have to be checked by the judicial the embargo in detail in a 2011 article, analyzing system, etc. Rather, he is a actor within a how WikiLeaks became constrained by “a large- nexus of sovereign, economic, and social scale technical distributed-denial-of-service power, leveraging some of those in service (DDoS) attack with new patterns of attack aimed of his goals.39

10.16.12 / 11:23:36 EDT fundamental mistake” in its judgment.45 At the The WikiLeaks financial embargo by VISA and embassy, meanwhile, Assange’s life seems to MasterCard was fought in an Icelandic court by have become fully equivalent to that of DataCell, the company acting as WikiLeaks’ local WikiLeaks’ data. The Ecuadorian outpost here is payment processor. A July, 2012 ruling required like an offshore internet server, beyond the grasp that Valitor, VISA and MasterCard’s payment of Western powers – and indeed, there was handling agent in Iceland, should resume widespread anger when Britain briefly processing donations to the site as a contractual 08/14 threatened Ecuador to annul the status of its obligation to DataCell. The ruling was touted (by London embassy’s premises.46 WikiLeaks) as “a significant victory against đđđđđđđđđđAssange himself frequently deploys Washington’s attempt to silence WikiLeaks.”40 It chessboard metaphors when talking about remains, however, questionable as to whether jurisdiction in a multipolar world. His personal the order against Valitor will actually restore television show, The World Tomorrow, was funding to the site. James Grimmelmann doubts produced by RT, the Western branch of Russia’s that US payment links to WikiLeaks are state broadcaster (which, as especially liberal answerable to the Icelandic ruling. He suggests commentators prefer to add, is “Kremlin- that backed”). As Assange explained to the Daily Mail in September 2012, “if it proceeds to a global payment networks still have seams prosecution then it is a chess game in terms of along national boundaries. Valitor, a my movements. I would be well advised to be in a company which can be thought of as jurisdiction that is not in an alliance with the US Wikileaks’ “accepting bank,” will not ...” In Assange’s view, necessarily have donation payments to process. The ruling does not affect the we must see the countries of the world as a embargo still in place by VISA and chess board with light and dark areas in Mastercard who continue to control the ever shifting arrangements depending on money flow between the issuing bank (on our latest publication.47 behalf of their customers) and Valitor.41 If WikiLeaks, and Julian Assange, are making one Sveinn Andri Sveinsson, a lawyer for DataCell, is thing clear, it is that the jurisprudential less pessimistic. Sveinsson was quoted calling assumptions of cyber-libertarianism can have a the victory a “good day for the freedom of visceral afterlife in the nondigital, material expression.”42 Still, the case was decided as a world. Traditional liberal-constitutional niches matter of contractual law rather than like freedom of expression and civil disobedience constitutionality.43 are no longer that convincing; they, in a sense, đđđđđđđđđđThe situation for WikiLeaks got worse exhibit the same weaknesses as Sealand and the whenđthe organization's founder, Julian Pirate Bay in their wide-eyed expectation of state Assange,đwas accusedđof (but not charged for) power curbed by law. The gross inequality in sexual misconduct in Sweden. This led Interpol resources between the state and its idealist to issue a Red Notice – normally reserved for the critics becomes painfully obvious when states likes of Muammar Gaddafi – for Assange's deliberately shredđto pieces,đlike discarded arrest, and an ensuing two-year standoff paperwork,đlegally certified limits on their between Assange and UK prosecutors. After executive power. It is becoming increasingly Assange lost his appeal against his extradition to obvious that liberal-democratic conceptions like Sweden at the Supreme Court in May 2012, the network neutrality, internet freedom, and WikiLeaks founder escaped to the Ecuadorian freedom of expression, despite their key Embassy in London, applying for (and receiving) democratic value, don’t give any actual political asylum – apparently not to evade protection to those who need them most. In a Swedish accusations, but to prevent Assange’s global internet under a renaissance of the state, possible extradition to the United States on it is not just the network, but the networked, who presumed charges of espionage.44 are the ultimate subject of power.

đđđđđđđđđđ The lines along which Assange’s legal team e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I fought his extradition, followed by his move into Captives of the Cloud, or: the Dissent of the the embassy, are in remarkable consistency with Networked WikiLeaks’ multi-jurisdictional hosting model. In early 2011, Birgitta Jónsdóttir, an Icelandic The case brought to the surface deep Member of Parliament, found out that the US ambiguities in the treaties regulating Department of Justice sought information about extraditions, prompting theđCambridge Journal of her Twitter account. Jónsdóttir was under International and Comparative Lawđto argue that investigation because of her alleged involvement the UK Supreme Court’s decision displayed “a in the making of a WikiLeaks video called

10.16.12 / 11:23:36 EDT Collateral Murder, which was edited and time getting permissions for officials produced in Iceland in 2010.48 The video entering my offline home, same should documents the shooting of unarmed civilians in apply to online home.49 Baghdad by a US helicopter crew; the scene was filmed from the gun turret camera of an Apache Her message was retweeted over 100 times. The attack helicopter. The video material used in problem is that in the cloud, there is no Collateral Murder was received by WikiLeaks equivalent to a “home.” Cloud computing may from a source in the US military, alleged to be 09/14 sometimes mimic or emulate some of the virtues Private First Class Bradley Manning. Manning is of the anarcho-libertarian internet, such as currently under a court martial pretrial for anonymous PGP keys and personalized security charges including “aiding the enemy.” A Grand architecture.50 Amazon Web Services – a Jury investigation into WikiLeaks brought about company which extra-legally censored WikiLeaks the DOJ’s interest in the Jónsdóttir’s Twitter on the request of Joe Lieberman – boasts that it information, along with the account information errs on the side of “protecting customer privacy,” of Jacob Appelbaum and Rob Gonggrijp, and is “vigilant in determining which law computer experts who are also alleged to have enforcement requests we must comply with.” helped with the production of Collateral Murder. Indeed, it heroically says, “AWS does not hesitate All Twitter user information is stored on servers to challenge orders from law enforcement if we in the US, which are accessible to US law think the orders lack a solid basis.”51 However, all enforcement with or without a court order. The cyber-anarchic playtime must happen under the subpoena was issued so that the receiving party gaze of the web’s digital Walmart, without any was forbidden from talking about it; Twitter’s definition of what a “solid basis” is. In addition, lawyer however successfully lifted the gag order, the possibility of revolving door interests so that Jónsdóttir, Gonggrijp and Appelbaum between business and government can’t be ruled could be informed about the subpoena. On out either. Amazon’s current, Washington D.C.- November 13, 2011, Jónsdóttir tweeted: based Deputy Chief Information Security Officer is reported to possess a “distinguished career in A foreign government would have a hard federal government security and law

Twittertracing in the cloud: the US Department of Justice, in its pursuit of WikiLeaks, subpoenaed Icelandic MP Birgitta Jónsdóttir's Twitter account.

10.16.12 / 11:23:36 EDT enforcement.”52 A cloud service provider’s own People talk about shifting their lives to the security staff may in various ways – socially, cloud―their informational lives, at least. geographically, and through expertise – be You may store photographs in the cloud; e- already intimately connected to the very law mail passes to and from the cloud and enforcement agencies whose requests it is never really leaves the cloud. All traditional supposed to scrutinize. As Rebecca Rosen ideas of privacy, based on doors and locks, explains, the notion of data storage being physical remoteness and invisibility, are handled by a cloud provider already removes 10/14 upended in the cloud.55 some of the legal constraints on evidence- gathering by law enforcement, especially on Jónsdóttir, Appelbaum and Gonggrijp tried to subpoenas: find out if, and which, other social media companies had received similar subpoenas. They Grand jury subpoenas are used to collect had reason to believe this would be the case, evidence. Unlike warrants, subpoenas can because Twitter is known (and often praised) for be issued with less than probable cause. collecting relatively little information about its The reasoning for the lower bar is in part users; it would seem, as Glenn Greenwald wrote, that if someone does not want to turn over “one of the least fruitful avenues to pursue” for the requested evidence, he or she can the DOJ to rely solely on Twitter information.56 contest the subpoena in court. Grand juries Jónsdóttir’s demands for transparency were can subpoena not only the person who flatly refused. US Attorney Neil MacBride wrote created a document but any third parties in a court filing that her request demonstrated who might be in possession of that an “overriding purpose to obtain a roadmap of document. Under the Stored the government’s investigation.” MacBride Communications Act, a grand jury can further stated that subpoena certain types of data from third parties whose only role is storing that the subscribers have no right to notice data.53 regarding any such developments in this confidential criminal investigation – any This, then, reflects an outdated idea of a third more than they have a right to notice of tax party’s role in a subpoena. At the time the law records requests, wiretap orders, or other developed, it could be assumed that “any third confidential investigative steps as to which party with access to someone’s data would have this Court’s approval might be obtained.57 a stake in that data and a relationship with the person who created it.” As Rosen concludes, “in This is a brazenly imperialist thing for MacBride the old days of storing information in filing to say. If the US government wants, for the cabinets, subpoena power was constrained purpose of a “confidential criminal because people didn’t save everything and investigation,” to have the tax records of a non- investigators had to know where to look to find US citizen like Jónsdóttir, it can’t simply incriminating evidence.”54 A cloud provider is a subpoena them from a US cloud service. It must new kind of third party; it manages and hosts file a case with a foreign government, and vast troves of personal data belonging to its demonstrate probable cause. Apparently, to customers. But it is not a stakeholder in such MacBride, obtaining information on a non-US data. Neither was the manufacturer of a filing subject from a US server is the same obtaining cabinet a stakeholder in the private documents such information from foreign territory; smooth stored in it. There are many such filing cabinets compliance is simply expected, and indeed in the cloud, storing the online self. Together, presupposed. In a piece for the Guardian, they form the scattered “online home” we Jónsdóttir referred to her legal ordeal as an inhabit. Information in the cloud perversely example of ongoing attempts of the US to silence echoes the utopian dream of a weightless and the truth as a means of maintaining power. She autonomous internet, independent from the wrote that the DOJ’s subpoena constituted a constraints of territory. But this utopian dream “hack by legal means.”58 Perhaps out of a is, in reality, a centrally managed corporation. As e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I misunderstanding of the mechanisms of social James Gleick writes, media, or out of genuine Orwellian intent, cloud subpoena procedures can take on grotesque all that information―all that information dimensions. For example, in December 2011, the capacity―looms over us, not quite visible, Boston District Attorney subpoenaed Twitter over not quite tangible, but awfully real; the following material: amorphous, spectral; hovering nearby, yet not situated in any one place. Heaven must Guido Fawkes, @p0isonANon, once have felt this way to the faithful. @occupyBoston, #BostonPD, #d0xcak3.59

10.16.12 / 11:23:36 EDT his aunt – returned to prison for heroin The subpoena sought not just information on a dealing.63 specific user, but on all users connected to certain words and hashtags associated with the Ars Technica adds that “worried about the fate of Occupy movement’s activities in Boston, and the two children in his charge, Monsegur has hacktivist collective Anonymous, at a given point allegedly been aiding the FBI since his arrest last in time. WikiLeaks, in linking to this story, summer – aid which culminated in arrests today tweeted that it was now time for Twitter to move 11/14 of several LulzSec members.”64 The Guardian its servers offshore.60 The Australian journalist completes this story, as Bernard Keane concluded from the Boston DA’s bizarre “fishing expedition” that Monsegur ... provided an FBI-owned computer to facilitate the release of 5m the only real solution is social media emails taken from US security consultancy networks outside the jurisdiction of nation- Stratfor and which are now being published states. WikiLeaks is currently establishing by WikiLeaks. That suggests the FBI may its own social network, Friends of have had an inside track on discussions WikiLeaks, and Anonymous has established between Julian Assange of WikiLeaks, and AnonPlus; there have also been anonymous Anonymous, another hacking group, about microblogging sites such as Youmitter the leaking of thousands of confidential established, but their lack of critical mass emails and documents.65 is a key impediment, as is resilience in the face of surges in traffic, and they remain The space of flows is absolutely not smooth. It vulnerable, to the extent that it’s looks like a data center, and the coal plant that enforceable, to authorities claiming to powers it. It looks like Julian Assange’s room in exercise jurisdiction over whatever servers the Ecuadorian Embassy in London. It looks like are used to host the networks.61 the Principality of Sealand. It looks like Sabu’s social housing unit on Manhattan's Lower East Groys’s “future power” over the network is Side. The landing from the digital onto the unlikely to pose direct, legal limits on free material is hard; it comes with a cruelty and speech. Instead, like in the WikiLeaks embargo, it intensity we haven’t even begun to properly directly affects the material basis of those who understand. Along these lines, we might grasp an speak. One is tempted to think of the ways in emerging political geography of information, which the FBI pursued hacker collectives resources, and infrastructure. In such a Anonymous and LulzSec after their DDoS attacks geography, the state and the cloud are among the on MasterCard and VISA. The FBI fully exploited most important layers, but they are not the only the real-world frailties and vulnerabilities of the layers by far. Saskia Sassen writes that we need hackers, who presented themselves as to problematize “the seamlessness often invulnerable superheroes online. But they attributed to digital networks. Far from being weren’t, in reality. The authorities made no seamless, these digital assemblages are ‘lumpy,’ qualms about the question whether or not partly due to their imbrications with nondigital Anonymous and LulzSec’s cyber-conflict entailed conditions.”66 acts of “civil disobedience.” They were treated as Once again, the world indeed is lumpy enough for cyber-terrorists, and the option for their us not to draw easy conclusions. This story is not practices to constitute a legitimate realm of civic over yet. Tomorrow’s clouds are forming. protest was eclipsed – even though some of the đđđđđđđđđđ× most thorough previous analysis of Anonymous 'Written by Daniel van der Velden and Vinca Kruk. Research 62 Assistant: Alysse Kushinski. Design Assistants: Rasmus had focused on these possibilities. One of the Svensson, Allison Kerst and Michael Oswell. All images group’s most prominent members, Sabu, was courtesy of Metahaven. Metahaven 2012. apprehended by the FBI and turned into an đđđđđđđđđđ informant. New York Magazine wrote about Sabu, using his real name instead of his online đđđđđđđđđđTo be continued in “Captives of the Cloud: pseudonym: e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I Part III. Tomorrow’s Clouds.”

On the day that he joined forces with the hacker collective Anonymous, Hector Xavier Monsegur walked his two little girls half a dozen blocks to their elementary school. “My girls,” he called them, although they weren’t actually his children. Monsegur, then 27, had stepped in after their mother –

10.16.12 / 11:23:36 EDT Metahaven is an Amsterdam-based design collective đđđđđđ1 John Perry Barlow, “A on the cutting blade between politics and aesthetics. Julian Assange, in: “The Julian Declaration of the Independence Assange Show: Cypherpunks of Cyberspace,”đElectronic Founded by Vinca Kruk and Daniel van der Velden, Uncut (p.1)”,đRT.com, July 29, Frontier Foundation, February 8, Metahaven's work – both commissioned and self- 2012. See 1996. See directed – reflects political and social issues through http://www.youtube.com/watch https://projects.eff.org/~ba research-driven design, and design-driven research. ?v=i85fX9-sKYo rlow/Declaration-Final.html. Research projects included the Sealand Identity đđđđđđ2 đđđđđđ12 Project, and currently include Facestate, and Iceland Milton Mueller,đNetworks and Saskia Sassen,đTerritory – as Method. Solo exhibitions include Affiche Frontière States. The Global Politics of Authority – Rights. From 12/14 Internet Governance. Cambridge Medieval to Global Assemblages, (CAPC musée d'art contemporain de Bordeaux, 2008) (MA): The MIT Press, 2010, 9-10. (Princeton/Oxford: Princeton and Stadtstaat (Künstlerhaus Stuttgart/Casco, 2009). University Press, 2006, 2008), Group exhibitions include Forms of Inquiry (AA London, đđđđđđ3 330. Manuel Castells,đThe Information 2007, cat.), Manifesta8 (Murcia, 2010, cat.), the Age: Economy, Society and đđđđđđ13 Gwangju Design Biennale 2011 (Gwangju, Korea, cat.), Culture, Vol I: The Rise of the Milton Mueller,đNetworks and Graphic Design: Now In Production (Walker Art Center, Network Society (Malden, MA: States, 268. Minneapolis, 2011, and Cooper-Hewitt National Design Blackwell 1996 [2000]), 442. đđđđđđ14 Museum, New York, 2012, cat.) and The New Public đđđđđđ4 “About (Museion, Bolzano, 2012, cat.). Metahaven's work was Ibid. Microsoft”đSeeđhttp://www.mi published and discussed in The International Herald crosoft.com/about/en/us/defa đđđđđđ5 ult.aspx. Tribune, The New York Times, Huffington Post, Courrier Jack Goldsmith and Tim Wu,đWho International, Icon, Domus, Dazed, The Verge, Controls the Internet?: Illusions đđđđđđ15 l'Architecture d'Aujourd'hui, and Mute, among other of a Borderless World (Oxford: See Gillian Reagan, “The publications. Vinca Kruk is a Tutor of Editorial Design Oxford University Press, 2006), Evolution of Facebook’s Mission 73. Statement.”đNew York Observer, and Design Critique at ArtEZ Academy of Arts in July 13, 2009. See Arhem. Daniel van der Velden is a Senior Critic at the đđđđđđ6 http://observer.com/2009/07/ Graphic Design MFA program at Yale University, and a James Gleick,đThe Information: A the-evolution-of-facebooks-m History, a Theory, a Flood, (New ission-statement/. Tutor of Design at the Sandberg Instituut Amsterdam. York: Pantheon Books, 2011), In 2010, Metahaven released Uncorporate Identity, a 396. đđđđđđ16 design anthology for our dystopian age, published by See “About Skype” see Lars Müller. đđđđđđ7 http://about.skype.com/. James Glanz, “The Cloud Factories: Power, Pollution and đđđđđđ17 the Internet,”đNew York Times, See Instagram FAQ September 22, 2012. http://instagram.com/about/f Seeđhttp://www.nytimes.com/2 aq/. 012/09/23/technology/data-ce nters-waste-vast-amounts-of- đđđđđđ18 energy-belying-industry-imag A. Michael Froomkin, “Flood e.html?pagewanted=1&ref=technologCyo.ntrol on the Information Ocean: Living With Anonymity, Digital Cash, and Distributed đđđđđđ8 Databases,”University of When, for example Dutch Pittsburgh Journal of Law and filmmaker Marije Meerman, Commerce 395 (1996). See while working on a documentary http://osaka.law.miami.edu/~ about the financial crisis and the froomkin/articles/ocean.htm. role of high-speed trading, wanted to find data centers đđđđđđ19 servicing the New York Stock See “Data Haven by Bruce Exchange, she found no official Sterling from Islands in the Net”, record of where these were technovelgy.com. located. Instead, Meerman Seeđhttp://www.technovelgy.c tracked them down by looking om/ct/content.asp?Bnum=279. for clues on the web sites of the construction companies that đđđđđđ20 built them, and by flipping The Principality of Sealand is through local files of New Jersey discussed at length in our town hall meetings. Eventually, book,đUncorporate Identity. In she mapped a ring of data our interview with hacker, centers around New York City. cryptographer, and internet See Marije Meerman, lecture at entrepreneur Sean Hastings, a Mediafonds, Amsterdam, self-styled inventor of Sealand’s January 12, 2012, and data haven, Hastings declared đhttp://itunes.apple.com/us/ that “the world needs a frontier. app/money-speed-inside-black Every law, for good or ill, is an -box/id424796908?mt=8. imposition on freedom. The frontier has always been a place đđđđđđ9 for people who disagree with the Pier Vittorio Aureli. In Pier morality of current law to be Vittorio Aureli, Boris Groys, able to get away from it.” Sean

e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I Metahaven, and Marina Hastings, in “The Rise And Fall Vishmidt, “Form.” InđUncorporate Of The Data Haven, Interview Identity (Baden: Lars Müller, with Sean Hastings,” Metahaven 2010),đ262. and Maria Vishmidt eds.,đUncorporate Identity đđđđđđ10 (Baden: Lars Müller, 2010), Boris Groys. In Pier Vittorio 65.đLater examples include Aureli, Boris Groys, Metahaven, Seasteading, an enterprise and Marina Vishmidt, “Form.” founded by Patri Friedman, InđUncorporate Identity (Baden: designed to be a set of sovereign Lars Müller, 2010),đ263. floating sea vehicles under ultraminimal governance đđđđđđ11 without welfare or taxes. In

10.16.12 / 11:23:36 EDT 2011, Seasteading received http://www.newyorker.com/rep funding from Paypal founder đđđđđđ31 đđđđđđ42 orting/2010/06/07/100607fa_f Peter Thiel. This “libertarian sea Grimmelmann, “Sealand, Omar R. Valdimarsson, “Iceland act_khatchadourian?currentPa colony” was directly modeled Havenco, And The Rule Of Law.” Court Orders Valitor to Process ge=all. after the Principality of Sealand, 484. WikiLeaks mixed with the gated Donations.”đBloomberg, July 12, đđđđđđ49 community, the ranch, and the đđđđđđ32 2012.đSee Twitter.đSee cruise ship. It is uncertain “Icelandic bank Kaupthing http://www.bloomberg.com/new https://twitter.com/ioerror/ whether such physical havens, if threat to WikiLeaks over s/2012-07-12/iceland-court-o statuses/135980031037022208. realized in the first place, will confidential large exposure rders-valitor-to-process-wik ever escape their founding vision report.”đWikiLeaks.org, July 31, ileaks-donations-1-.html. đđđđđđ50 of conservative-libertarian 2009. See 13/14 See “AWS Security and frontier romanticism.đSee http://wikileaks.org/wiki/Ic đđđđđđ43 Compliance Center.” See Cooper Smith, “Peter Thiel, elandic_bank_Kaupthing_threa Charles Arthur,đThe Guardian. http://aws.amazon.com/securi PayPal Founder, Funds t_to_WikiLeaks_over_confiden Ibid.đSee ty/. ‘Seasteading,’ Libertarian Sea tial_large_exposure_report,_ http://www.guardian.co.uk/me Colony,” Huffington Post, August 31_Jul_2009. dia/2012/jul/12/wikileaks-co đđđđđđ51 19, 2011, see urt-victory-visa. See “Amazon Web Services: Risk http://www.huffingtonpost.co đđđđđđ33 and Compliance White Paper m/2011/08/18/peter-thiel-sea See Xeni Jardin, “WSJ obtains đđđđđđ44 July 2012.” See steading_n_930595.html. Wikileaks financial data: William Neuman and Maggy http://d36cz9buwru1tt.cloudf spending up, donations Ayala, “Ecuador Grants Asylum ront.net/AWS_Risk_and_Compli đđđđđđ21 down.”đBoingboing, December to Assange, Defying Britain.”đThe ance_Whitepaper.pdf. Joi Ito, “Havenco Doing Well 24, 2010.Seeđhttp://boingboing.n New York Times, August 15, According BBC.” Quoted from et/2010/12/24/wsj-obtains-wi 2012. See đđđđđđ52 Slashdot, July 10, 2002. See kileak.html and Joshua Norman, http://www.nytimes.com/2012/ See Malcolm Ross, “Appian http://joi.ito.com/weblog/20 “WikiLeaks’ Julian Assange Now 08/17/world/americas/ecuador - World 2012 – Developer 02/07/10/havenco-doing-w.htm Making $86k/year.”đCBS News, to-let-assange-stay-in-its- Track.”Appian.com, March 16, l December 24, 2010. embassy.html?pagewanted=all&_r=02012. See Seeđhttp://www.cbsnews.com/8 http://www.appian.com/blog/u đđđđđđ22 301-503543_162-20026597- ncategorized/appian-world-20 James Grimmelmann, “Sealand, 5035 43.html. đđđđđđ45 12-developer-track. Havenco, And The Rule Of Tiina Pajuste, “Assange v Law.”Illinois Law Review 405, đđđđđđ34 Swedish Prosecution Authority: đđđđđđ53 2012, 460. See See “Banking the (mis)application of European Rebecca J. Rosen, “How Your http://illinoislawreview.org /wp- Blockade.”đWikiLeaks.org. See and international law by the UK Private Emails Can Be Used content/ilr-content/arti http://wikileaks.org/Banking - Supreme Court - Part Against You in Court.”đThe cles/2012/2/Grimmelmann.pdf Blockade.html. I.”đCambridge Journal of Atlantic, July 8, 2011. See International and Comparative http://www.theatlantic.com/t đđđđđđ23 đđđđđđ35 Law, June 20, 2012. See echnology/archive/2011/07/ho Grimmelmann, “Sealand, Ryan Paul, “Wikileaks kicked out http://www.cjicl.org.uk/inde w-your-private-emails-can-be - Havenco, And The Rule Of Law.” of Amazon’s cloud.”đArs Technica, x.php?option=com_easyblog&view=eunsteryd-against-you-in-court/2 462. December 1, 2010.đSee &id=22&Itemid=101 41505/ http://arstechnica.com/secur đđđđđđ24 ity/2010/12/wikileaks-kicked - đđđđđđ46 đđđđđđ54 Grimmelmann, “Sealand, out-of-amazons-cloud/. The British authorities sent a Ibid. Havenco, And The Rule Of Law.” letter to Ecuador saying that 463. đđđđđđ36 “You need to be aware that there đđđđđđ55 Alexia Tsotsis, “Sen. Joe is a legal base in the UK, the James Gleick,đThe Information, đđđđđđ25 Lieberman: Amazon Has Pulled Diplomatic and Consular 395–96. Cory Doctorow, “Pirate Bay Hosting Services For Premises Act 1987, that would trying to buy Sealand, offering WikiLeaks.”đTechcrunch, allow us to take actions in order đđđđđđ56 citizenship.” boingboing.net, December 1, 2010. to arrest Mr Assange in the Glenn Greenwald, “DOJ January 12, 2007.đSee Seeđhttp://techcrunch.com/20 current premises of the subpoenas Twitter records of http://boingboing.net/2007/0 10/12/01/amazon. embassy. We sincerely hope that several WikiLeaks 1/12/pirate-bay-trying-to.ht ml. we do not reach that point, but if volunteers.”đSalon.com, January đđđđđđ37 you are not capable of resolving 8, 2011. See đđđđđđ26 Paul Owen, Richard Adams, this matter of Mr Assange’s http://www.salon.com/2011/01 Michael Froomkin, “Internet Ewen MacAskill, “WikiLeaks: US presence in your premises, this /08/twitter_2/singleton/. Regulation at a Crossroads.” Senator Joe Lieberman suggests is an open option for us.” See Lecture atđOxford Internet New York Times could be Mark Weisbrot, “Julian Assange đđđđđđ57 Institute, University of Oxford, investigated.”đThe Guardian, asylum: Ecuador is right to stand Kevin Poulsen, “Feds: WikiLeaks June 2012. YouTube. December 7, 2010.đSee up to the US.”đThe Guardian, Associates Have ‘No Right’ To Seeđhttp://www.youtube.com/w http://www.guardian.co.uk/wo August 16, 2012. See Know About Demands For Their atch?v=b2aVcdcr4MA. rld/2010/dec/07/wikileaks-jo e- http://www.guardian.co.uk/co Records.”đWired, June 2, lieberman-new-york-times-i mmentisfree/2012/aug/16/juli 2011.đSee đđđđđđ27 nvestigated. an-assange-asylum-ecuador http://www.wired.com/threatl See Liz Gannes, “The Vanity of evel/2011/06/wikileaks-twitt er/ the ‘Acqhire’: Why Do a Deal That đđđđđđ38 đđđđđđ47 Makes No Sense?”đAllThingsD, Yochai Benkler, “WikiLeaks and Sarah Oliver, “‘It’s like living in a đđđđđđ58 August 10, 2012. See the Protect-IP Act: A New space station’: Julian Assange Birgitta Jónsdóttir, “Evidence of http://allthingsd.com/201208 Public-Private Threat to the speaks out about living in a one- a US judicial vendetta against 10/the-vanity-of-the-acqhire - Internet Commons,”đDaedalus 4 room embassy refuge with a WikiLeaks activists mounts.”đThe why-do-a-deal-that-makes-no - (2011), 154–55. mattress on the floor and a blue Guardian, July 3, 2012.đSee sense/ lamp to mimic daylight.”đThe http://www.guardian.co.uk/co đđđđđđ39 Daily Mail,September 29, 2012. mmentisfree/2012/jul/03/evid đđđđđđ28 James Grimmelmann, e-mail to See ence-us-judicial-vendetta-wi Grimmelmann, “Sealand, author. July 17, 2012. http://www.dailymail.co.uk/n kileaks-activists-mounts?INT

Havenco, And The Rule Of Law.” e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I ews/article-2210522/Its-like - CMP=SRCH. 479. đđđđđđ40 living-space-station-Julian - Charles Arthur, “WikiLeaks Assange-speaks-living-room- đđđđđđ59 đđđđđđ29 claims court victory against embassy-refuge-mattress-floo Bernard Keane, “The Boston James Boyle,đFoucault In Visa.”đThe Guardian, July 12, r-blue-lamp-mimic-daylight.h fishing party and Australians’ Cyberspace: Surveillance, 2012. See tml rights online.”đCrikey, January 17, Sovereignty, and Hard-Wired http://www.guardian.co.uk/me 2012.đSee Censors, 1997. dia/2012/jul/12/wikileaks-co đđđđđđ48 http://www.crikey.com.au/201 Seeđhttp://law.duke.edu/boyl urt-victory-visa. See Raffi Khatchadourian, “No 2/01/17/the-boston-fishing-p esite/foucault.htm. Secrets. Julian assange’s arty-and-australians-rights- đđđđđđ41 mission for total online/. đđđđđđ30 James Grimmelmann, e-mail to transparency.”đThe New Yorker, Ibid. author, July 17, 2012. June 7, 2010. See đđđđđđ60

10.16.12 / 11:23:36 EDT Twitter. See http://twitter.com/wikileaks /status/159247260121706496

đđđđđđ61 Bernard Keane, ibid.

đđđđđđ62 See Gabriella Coleman,đThe Many Moods Of Anonymous: Transcript. Discussion at NYU

Steinhardt, March 4, 2011. See 14/14 http://www.onthemedia.org/20 11/mar/04/the-many-moods-of- anonymous/transcript/

đđđđđđ63 Steve Fishman, “Hello, I Am Sabu ... “đ New York Magazine, June 3, 2012. See http://nymag.com/news/featur es/lulzsec-sabu-2012-6/

đđđđđđ64 Nate Anderson, “LulzSec leader ‘Sabu’ worked with FBI since last summer.”đArs Technica, March 6, 2012. See http://arstechnica.com/tech- policy/2012/03/report-lulzse c- leader-sabu-worked-with-fb i- since-last-summer/

đđđđđđ65 Charles Arthur, Dan Sabbagh and Sandra Laville, “LulzSec leader Sabu was working for us, says FBI.”đThe Guardian, March 7, 2012. See http://www.guardian.co.uk/te chnology/2012/mar/06/lulzsec - sabu-working-for-us-fbi

đđđđđđ66 Saskia Sassen, Ibid., 382-3. e - f l u x j o r n a # 3 8 — c t b 2 0 1 đ M h v C a p t i v e s o f h l u d : P r I

10.16.12 / 11:23:36 EDT