Second Quarter of 2021 Saw Surge in 5G

There was a dramatic increase in 5G wireless adoption over the second quarter of this year, according to 5G Americas' press release on September 22:

By region, Omdia data indicates North America [U.S. and Canada] had a total of 44.6 million 5G connections by the end of Q2 2021, which is an addition of 17.9 million 5G connections and 67 percent quarter over quarter growth. Additionally, it had 501 million LTE connections by the end of Q2 2021, which marks a 0.66 percent quarterly decline in LTE.

In a pair of recent Perspectives from FSF Scholars, I wrote about how timely sunset of 3G networks – including AT&T's and T-Mobile's legacy networks – is one important factor in facilitating 5G adoption. Repurposing of additional spectrum from government use to licensed commercial use – particularly in the lower 3 GHz band – also will help realize the speed and capacity potential of 5G networks and thereby boost the U.S. economy and create new jobs. 

FTC Commissioner Wilson Recruits Student Researchers to Inform and Inspire Efforts to Pass a Federal Data Privacy Law

Citing what she describes as "significant information asymmetries," Republican FTC Commissioner Christine Wilson long has advocated for a comprehensive federal data privacy law. In fact, she discussed that very issue in her keynote address at the Free State Foundation's Twelfth Annual Telecom Policy Conference in March 2020.

More recently, she partnered with Duke University on a research project designed to expedite the currently stalled legislative process.

To date, efforts to pass a federal privacy law have been stymied by partisan disagreements regarding two issues in particular.

One, whether a federal data privacy law should preempt similar state laws. As I have argued on numerous occasions, most recently in "Pressures Multiply for Congress to Act on Data Privacy," a Perspectives from FSF Scholars published earlier this month, it should.

The growing list of states with their own, inconsistent statutes – which currently includes California (both the California Consumer Privacy Act and the California Privacy Rights Act), Virginia (the Virginia Consumer Data Protection Act), and Colorado (the Colorado Privacy Act) – unreasonably complicates companies' compliance efforts and creates chaos for consumers.

Two, whether it should provide for a private right of action. It should not. Generally speaking, class-action lawsuits benefit attorneys, not consumers. Case-by-case enforcement by the FTC is the better approach.

Unable to find common ground on these questions, lawmakers have made no observable progress of late. However, the fact that the Senate Commerce Committee is holding a hearing today titled "Protecting Consumer Privacy," the first of its kind this year, perhaps offers a glimmer of hope.

Given the failure to date of Congress to pass privacy legislation, there have been repeated calls for the FTC to commence a rulemaking. On September 20, a group of Democratic Senators led by Richard Blumenthal (CT) wrote to FTC Chair Lina Khan urging her to do just that.

Notably, and in specific response to the lack of legislative momentum, at one point Commissioner Wilson herself reluctantly expressed her support for an FTC privacy rulemaking, a statement that I highlighted in a July 2021 post to the FSF Blog.

But in light of a pattern of agency actions that Commissioner Wilson troublingly regards as an "abrupt departure from regular order" – including, most recently, the September 15th decision along party lines to withdraw the Vertical Merger Guidelines that were issued in 2020, to which she and fellow Republican Commissioner Noah Phillips responded with a co-authored Dissenting Statement – she has had a change of heart.

In an Oral Statement submitted to the House Commerce Committee's Subcommittee on Consumer Protection and Commerce in July of this year, she wrote the following:

In recent months, I had become more receptive to a [Magnuson]-Moss rulemaking on privacy to address the information asymmetry between the providers of goods and services and their users. But the Commission recently voted along party lines to pare back procedural safeguards and limit opportunities for public input during agency rulemakings. Given these changes, I am less inclined to support a Mag-Moss rulemaking on privacy. Federal privacy legislation remains the optimal solution.

In an attempt to facilitate that "optimal solution," Commissioner Wilson several months ago partnered with Duke University's Professor David Hoffman, along with students from its law school and Sanford School of Public Policy, to produce "a resource for legislators" – specifically, research-driven insight into how other federal statutes have addressed these two sticking points.

The fruits of that effort, which focused on both federal statutes (ten on the topic of preemption, six regarding remedies) and the European Union's General Data Protection Regulation (GDPR), have been made available publicly here.

In a keynote address delivered at "Exploring Options: Overcoming Barriers to Comprehensive Federal Privacy Legislation," a related event held on September 21, 2021 (video available here), Commissioner Wilson offered her perspective on these findings.

While acknowledging that the research revealed that "federal statutes that preempt an entire field of law are rare," Commissioner Wilson argued that the more common approach — where Congress "establish[es] a federal floor and allow[s] states to pass more stringent laws" — is not well suited to "fields like … the Internet that transcend state and national borders."

Given that:

1. "[T]he very nature of the Internet makes it likely that the most stringent state standard will become the de facto national standard," and
2. A primary regulatory objective should be to ensure that businesses are subject to consistent obligations,

Commissioner Wilson suggested that a better way forward would be to ensure that those rights and responsibilities established at the federal level are sufficiently robust on their own: "If the [federal] law provides strong rights and imposes appropriate standards and obligations on businesses, as well as robust and accessible remedies, more stringent state laws should not be necessary."

She also indicated that, given the dynamic and constantly evolving nature of the online experience, she would support "vesting the FTC with carefully tailored rulemaking authority … to facilitate updating key definitions and provisions over time."

With respect to remedies, Commissioner Wilson began with the point that a strong privacy law, one that empowers and adequately funds the FTC's efforts, would undercut one of the primary arguments as to why a private right of action may be necessary – that is, the perception that current levels of enforcement are inadequate.

She also highlighted research demonstrating that "abusive class action practices increase costs for businesses – while providing little in the way of redress for consumers, changed business practices, and deterrence."

Stepping back, Commissioner Wilson then made the foundational recommendation that "we … broaden the conversation" beyond solely whether or not to include a private right of action to "focus on establishing a constructive remedial framework."

In that vein, she cited "Breaking the Privacy Gridlock: A Broader Look at Remedies" by Jim Dempsey, Chris Hoofnagle, Ira Rubinstein, and Katherine Strandburg, when making the following three points:

1. Remedies should be tied to policy goals,
2. No one remedy can successfully promote even a simple goal and therefore an effective law should include multiple remedies, and
3. Intermediaries and third parties play a powerful role.

Asserting that "an 'all or nothing' approach will not serve the goals of privacy legislation," Commissioner Wilson suggested that alternative enforcement proposals be given serious consideration, including those that involve:

• A supervisory authority and/or third-party intermediaries, or
• A private right of action "in limited circumstances [with] substantive and procedural limits," exclusively "for specific, highly sensitive types of data," or providing only for injunctive relief.

In conclusion, she stated the following: "Ideally, the remedies contained in privacy legislation will turn on the kinds of injuries consumers may suffer."

At the same time, she teed up the question as to how the standing test set forth by the Supreme Court in its 2021 Transunion, LLC v. Ramirez decision might impact the options available to Congress.

NTIA Publishes Spectrum IT Modernization Report Supported by FSF Scholars

On September 24, NTIA published its spectrum IT modernization report, entitled "Plan to Modernize and Automate the Infrastructure of NTIA Related to Managing Federal Spectrum Use." This report details NTIA's spectrum IT modernization plan and requires the Department of Defense and agencies in the Interdepartment Radio Advisory Committee (IRAC) to submit spectrum IT modernization plans to NTIA so that their IT "is interoperable with the modernized infrastructure of the NTIA."

Congress required NTIA to publish this report in Section 9203 of the 2021 NDAA. The report states that NTIA assessed "each spectrum IT system in its IT infrastructure" and will procure new IT to replace outdated equipment and systems, some of which are more than three decades old. This process will ensure that spectrum use is interoperable between agencies and improve the functions, security, and automation of federal spectrum uses.

 

Free State Foundation scholars have written in support of federal spectrum infrastructure modernization. Senior Fellow Seth Cooper wrote in support of a bill with language identical to Section 9203 before it became law: "By all accounts, [Section 9203] is a reasonable and worthwhile measure that would bring about improvements in federal agencies' use and coordination of spectrum."

NTIA's spectrum modernization report appears to be a welcome development that will improve our government's use of spectrum. We look forward to further modernization plans from additional agencies.

T-Mobile’s Education Initiative Connects 3 Million Students

T-Mobile just announced that it connected over 3 million students in a single year through its free Internet program for school-age kids. This is a significant benchmark for such a recent educational initiative. 

Responding to the struggles many students faced with staying connected for remote learning, T-Mobile launched “Project 10Million” in September 2020, near the height of pandemic school closures. Project 10Million provides students enrolled in the National School Lunch Program with free high-speed data, free wireless hotspots, and at-cost devices. School administrators apply on behalf of their students, which helps maximize the program’s reach. In total, T-Mobile committed $10.7 billion towards its goal of connecting at least 10 million students by 2025.

Now with 3 million students connected in Project 10Million’s first year, T-Mobile’s investment is paying off, and it’s well on pace to reach 10 million students. This makes Project 10Million one of the largest and most successful private programs ensuring low-income persons get and stay connected.

Free State Foundation scholars support private initiatives by our nation’s broadband providers that boost adoption and narrow the digital divide. T-Mobile’s initiative is commendable, especially with the COVID-19 pandemic still impacting everyday life.

Strong Network Investment by U.S. Broadband Providers in Tumultuous 2020

Capital expenditures in networks and connectivity infrastructure by U.S. broadband providers totaled $79.4 billion in 2020, according to US Telecom's 2020 Broadband Capex Report. US Telecom's report was released on September 22.  

The $79.4 annual expenditure total is impressive considering the seismic economic disruptions and setbacks suffered by much of the U.S. economy in 2020. Last year's investment by U.S. broadband providers brings the total network capital investment by U.S. broadband providers since 1996 to a whopping $1.9 trillion. And as US Telecom's report points out, its estimates over the years likely are conservative since they exclude annual investment by small U.S. broadband providers as well as U.S. satellite broadband providers. Small providers and satellite providers made perhaps $2 billion in network investments in 2020. 

As I and other Free State Foundation scholars have pointed out in prior publications, continuing strong investment enabled U.S. broadband networks to successfully carry surging data traffic induced by COVID fears and government-imposed lockdowns in 2020. 

For more, see the 2020 Broadband Capex Report as well as a brief article about it by US Telecom's Mike Saperstein.  

Study Shows No Redlining in Urban Areas

 A new study released by NCTA - The Internet and Television Association Cable shows that gigabit offerings are widely available in urban areas regardless of income. And in another key finding, the study shows that there is also virtually no difference in availability based on race or ethnicity in urban areas.

The findings in the study appear to refute the frequent conjecture that low-income residents, and minority residents, are subject to "redlining" practices that result in less high-quality services available to them.

Comcast’s Latest Internet Essentials Expansion Includes Pell Grant Recipients

Yesterday, Comcast expanded its “Internet Essentials” program to cover Pell Grant recipients. Comcast will also donate $15 million worth of Internet service and devices, including 25,000 laptops.

These actions are the latest developments in Comcast’s long-standing pledge to connect more Americans. Internet Essentials is Comcast’s decade-old program for boosting high-speed Internet adoption among low-income persons, veterans, and seniors. Eligible subscribers get affordable home broadband up to 50/5 mbps for $9.95 per month. The program has had great success in narrowing the digital divide.

Free State Foundation scholars have previously shared news regarding Internet Essentials 10-Year Progress Report. This report highlighted the success of Internet Essentials and need for continuing its mission. Over the past 10 years, Comcast’s $700 million investment in Internet Essentials connected 10 million Americans to high-speed broadband. During that time, Internet Essentials was responsible for 40% of new Internet subscriptions by low-income families with school-aged children. And also in that report, Comcast committed another $1 billion to connect 50 million Americans over the next decade.

Expanding Internet Essentials to the roughly 7 million annual Pell Grant recipients will contribute to meeting this goal. The COVID-19 pandemic made many Americans deeply familiar with how critical connectivity is to achieving a quality education. And changes to learning methods such as hybrid classrooms will make affordability and adoption efforts more important than ever for education.

Free State Foundation scholars support private initiatives by our nation’s broadband providers to boost adoption and close the digital divide. Internet Essentials is such a successful initiative. Senior Fellow Seth Cooper highlighted the 10-Year Progress Report back in March. Senior Fellow Andrew Long covered expansions to the program in February. And Free State Foundation President Randolph J. May featured earlier Internet Essentials expansions in 2020, 2019, 2018, and 2017.

The latest announcement from Comcast is timely and welcome.

FCC is Set to Auction Spectrum Licenses in Lower 3 GHz Band in October

On September 20, LightReading reported on an application submitted to the FCC by AT&T, Ericsson, and Nokia that seeks permission to test wireless network operations in several sites across the country in the 3.45-3.55 GHz band. This band is schedule for public auction by the FCC beginning October 5 of this year. The importance of clearing this spectrum as well as adjacent spectrum for licensed commercial use was the subject my February 2021 Perspectives from FSF Scholars titled "Fast Action on the Lower 3 GHz Band Will Secure America's 5G Future." 

The upcoming auction is important because it will put more mid-band spectrum into commercial use for 5G services. And hopefully, it will be followed by successive auctions of lower 3 GHz spectrum that will further increase 5G capacity and capabilities in the United States. 

Copyright Office Releases Study on State Infringements and Sovereign Immunity

On August 31, the U.S. Copyright Office released its policy study on "Copyright and State Sovereign Immunity." The study was requested following the U.S. Supreme Court's 2020 decision in Allen v. Cooper, which held that the Eleventh Amendment barred liability for copyright infringements by states under the Copyright Remedy Clarification Act of 1990 (CRCA). My July 2020 Perspectives From FSF Scholars titled "Congress Should Stop States From Infringing Copyrights" was written in response to Allen v. Cooper.

The Copyright Office's study summarizes the record of copyright infringement actions brought against states since the CRCA, provides an account of other alleged copyright infringements by state agencies as well as state officials, and it explores other possible legal bases for addressing copyright infringements by states in light of the limitations imposed by Allen v. Cooper.

My August 20 blog post noted one post-Allen case decided by a U.S. District Court that appears to leave the door open to takings claims regarding alleged copyright infringement by a state. Expect to hear more from Free State Foundation Scholars in the near future on the Copyright Office's copyright and state sovereign immunity study as well as more on post-Allen court decisions involving alleged infringements by states. 

Privacy Recap: Biden Nominates Bedoya to FTC, House Commerce Committee Proposes $1B for New Privacy Bureau

It's not yet Wednesday, and already it's been an eventful week with respect to the FTC and data privacy.

First, President Biden on Monday nominated Alvaro Bedoya to be the third Democrat to serve as a Commissioner at the FTC. The official announcement by the White House states that "[h]is research and advocacy focus on the idea that privacy is for everyone" and touts his work on facial recognition technology.

Mr. Bedoya is a visiting law professor at Georgetown Law, where he serves as the founding director of the Center on Privacy & Technology.

Republican Commissioner Noah Phillips tweeted that "Alvaro would bring a bright and thoughtful voice and a depth of experience working across the aisle on privacy to the FTC."

Second, the House Committee on Energy & Commerce yesterday began a full committee markup of the so-called Build Back Better Act, a series of legislative recommendations for budget reconciliation.

Today, lawmakers are expected to consider Subtitle O, which would appropriate $1 billion over the next ten years to fund a new Privacy Bureau at the FTC "to accomplish the work of the Commission related to unfair or deceptive acts or practices relating to privacy, data security, identity theft, data abuses, and related matters."

News reports suggest Republican opposition to this proposal, including its hefty price tag, which totals nearly three times the agency's budget for fiscal year 2021: $351 million.

At the same time, politicians from both sides of the aisle continue to agree on the persistent and distinct need for federal privacy legislation.

In the Politico piece linked to above, a Republican committee aide speaking anonymously emphasized the importance "of passing actual legislation with real privacy protections for all Americans."

Likewise, Democratic Senator Maria Cantwell (WA) tweeted that the proposal is "an important step for protecting consumers," but also that she "will continue to fight for a federal privacy and data security law that protects consumers and creates certainty for businesses."

In a recent Perspectives from FSF Scholars, "Pressures Multiply for Congress to Act on Data Privacy," I listed the mounting pressures on Congress to adopt a comprehensive federal data privacy regime, which include the following:

• Three states (California twice, Virginia, and Colorado) so far have passed inconsistent laws that unnecessarily create costly headaches for businesses and confusion for consumers.
• The European Union (EU) has in place the General Data Protection Regulation (GDPR) and, in August, China adopted the Personal Information Protection Law.
• Cyberattacks, including one involving the information of over 50 million consumers discovered in August by T-Mobile, call out for a comprehensive data privacy regime.
• The lack of a federal data privacy law impedes efforts to reestablish a privacy shield for personal data transfers from the EU to the U.S.

I therefore suggested that legislation along the lines of the Setting an American Framework to Ensure Data Access, Transparency, and Accountability (SAFE DATA) Act, reintroduced this session by Republican Senators Roger Wicker (MS) and Marsha Blackburn (TN), might serve as a promising starting place.

Relatedly, in a December 2019 piece for the Free State Foundation entitled "Federal Privacy Legislation: Bipartisan Discussions Devolve into Dueling Drafts." I compared an earlier iteration of the SAFE DATA Act favorably to the Consumer Online Privacy Rights Act, rival legislation cosponsored by Senator Cantwell.

PRESS RELEASE: Congress Should Not Adopt Tax Credits for Government-Owned Broadband Systems

 

The following statement may be attributed to Randolph May, President of the Free State Foundation:

“Today the House Ways and Means Committee is continuing its markup of various legislative measures pursuant to the reconciliation process instructions. There are likely others, but one particularly ill-conceived proposal caught my eye. The proposal (Section 135111 in Part 1- Infrastructure Financing) to create a tax credit for the operations and maintenance costs of government-owned broadband systems should not be adopted. Even absent the proposed tax credits, government owned networks already receive preferential treatment vis-a-vis private network operators with regard to accessing public rights of way, avoiding cumbersome permitting processes, benefitting from taxpayer-funded subsidies, and the like. The proposed 30% tax credit for government networks would make it even more difficult for private sector broadband operators that must invest their own risk capital in new or upgraded broadband facilities to compete. Marketplace competition for broadband services would be dampened and consumers will be the losers."   

For a more complete examination of the problem nature of government owned networks, see this Free State Foundation Perspectives and the extensive further readings included in the piece:

“Biden Broadband Plan Favoring Government-Owned Networks Lacks a Constitutional Foundation:

https://freestatefoundation.org/wp-content/uploads/2021/05/Biden-Broadband-Plan-Favoring-Government-Owned-Networks-Lacks-a-Constitutional-Foundation-051121.pdf  

Proposed Universal Service Contribution Factor for Q4 Is 29.1 Percent

In a September 10, 2021, Public Notice, the FCC's Office of Managing Director announced that the Universal Service Fund (USF) contribution factor for the fourth quarter of this year will be 29.1 percent, a slight drop from the third quarter's 31.8 percent but still untenably high.

Free State Foundation President Randolph May has described this fee, which is imposed upon consumers' steadily declining use of "telecommunications services" (think: landline phones) but not "information services" (that is, the Internet), as a regressive tax that "negatively impacts low income subscribers who can least afford to pay it more than higher income subscribers who can."

In a May 2021 Newsweek op-ed, FCC Commissioner Brendan Carr made a compelling case that "[w]e should start requiring Big Tech to pay its fair share." Shortly thereafter, in "Congress May Invest Billions in Broadband: It Should Reform the Universal Service Fund Too," Justin (Gus) Hurwitz, a member of the Free State Foundation's Board of Academic Advisors, agreed that "we should discuss, as Commissioner Carr rightly suggests, who should pay for" USF-related projects.

And as I noted in a July post to the FSF Blog, Republican Senators Roger Wicker (MS), Shelley Moore Capito (WV), and Todd Young (IN) have introduced the Funding Affordable Internet with Reliable (FAIR) Contributions Act, legislation that would direct the FCC to consider the viability of Commissioner Carr's proposal.

"Build Resilient Communities – A Tocquevillian Perspective"

I am pleased to be a Fellow at the National Academy of Public Administration. As such, I was pleased to contribute this short piece to NAPA's "Thoughts from Our Fellows" forum styled "Build Resilient Communities." 

*     *     *  

Perhaps the primary responsibility of local governments, whether cities or counties, is to provide for the public health and safety of their citizens. And, of course, providing and maintaining certain basic infrastructure, such as streets, sidewalks, local transportation, is also crucial to fostering an environment in which a vibrant social and economic life can flourish. But here, in thinking about building resilient communities, I want to invoke Alex de Tocqueville – and urge that his observations, after traveling throughout America, are no less important today than they were in 1835 when he published his famous book, Democracy in America.

In perhaps the most oft-quoted passage, Tocqueville reported that:

The political associations that exist in the United States are only a single feature in the midst of an immense assemblage of associations in that country. Americans of all ages, all conditions, and all dispositions, constantly form associations. They have not only commercial and manufacturing companies, in which all take part, but associations of a thousand other kinds—religious, moral, serious, futile, general or restricted, enormous or diminutive.

While acknowledging a necessary role for government, Tocqueville asked, rhetorically: “What political power could ever carry on the vast multitude of lesser undertakings which the American citizens perform every day, with the assistance of the principle of association?”

As a keen student of human nature, Tocqueville recognized the positive role that private associational activity could play in enriching an individual’s life. Tocqueville famously suggested "the heart is enlarged and the mind is developed" only by the reciprocal influence of men and women working together in their voluntary associations. This voluntary associational engagement, whether undertaken through religious or various other civil society organizations, is a predicate to building resilient communities, not only by virtue of the positive contributions they make but also by virtue of providing a means for meeting the innate need of individuals to live satisfying lives.

This voluntary associational engagement, whether undertaken through religious or various other civil society organizations, is a predicate to building resilient communities, not only by virtue of the positive direct contributions they make but also by virtue of providing a means for meeting the innate need of most individuals to participate in communal activities in order to live satisfying lives.

 

 

Court Rejects Flimsy First Amendment Challenges to Copyright Anti-Circumvention Law

A Copyright Alliance blog post on September 2 by Devin Hartline calls attention to a July 15 courtroom defeat for parties challenging the anti-circumvention and anti-trafficking provisions contained in Section 1201 of the Digital Millennium Copyright Act (DMCA). In Green v. U.S. Department of Justice, the U.S. District Court for the District of Columbia denied a request for a preliminary injunction that would have enjoined enforcement of Section 1201. The Plaintiff's request was based on as-applied First Amendment challenges – which were rejected by the District Court.

In October 2020, Free State Foundation President Randolph May and I published a Perspectives from FSF Scholars paper titled "Congress Should Preserve Anti-Circumvention Rights: The Online Market for Movies and Music Depends on DMCA Section 1201." In that paper, FSF President May and I explained that the success of Internet-based services for accessing copyrighted music, movies, and TV shows depended on the maintenance of strong "anti-circumvention" rights that are secured under Section 1201. And we wrote that "Congress must preserve these rights so that copyright owners and service providers can continue to rely on encryption and password protection to give access to paying consumers while preventing unauthorized users from accessing content to which they are not legally entitled."

 

Our October 2020 Perspectives paper mentioned expressly mentioned a previous court decision in the Green case: 

[F]ederal courts have rejected broad-based First Amendment challenges to Section 1201, including challenges tied to alleged fair uses of copyrighted works. For example, in Green v. U.S. Department of Justice (2019) the U.S. District Court for the District of Columbia rejected pre-enforcement claims that Section 1201(a)'s anti-circumvention and anti-trafficking provisions are unconstitutionally overbroad and burden a substantial number of possible fair uses of copyrighted materials by third parties. The District Court in Green also rejected claims that the triennial rulemaking process constitutes a prior restraint on speech, as the process does not call for censorship based on content, viewpoint, or speaker identity. Like other District Court decisions, Green followed the Second Circuit's holding in Universal City Studios, Inc. v. Corley (2001) that Section 1201's anti-circumvention and anti-trafficking provisions implicate functional, non-speech aspects of computer codes used to circumvent TPMs, thus rendering those provisions content neutral. Corley held that Section 1201's prohibitions advance a substantial government interest in preventing mass digital piracy and it also held that interest is unrelated to the suppression of free expression. Green and other District Court decisions have followed Corley in this regard. 

As noted above, the District Court's July 2021 order addressed as-applied challenges that were not addressed by its June 2019 order. In short, the court rightly recognized – again – that Section 1201 furthers a substantial government interest in protecting copyrighted works on the Internet and it does not substantially burden more speech than necessary to accomplish that interest. For some solid analysis of the court's latest order, read Mr. Hartline's blog post.

PRESS RELEASE: FSF Announces New Hire and New Board Member

 

Free State Foundation President Randolph May announced today that Andrew Magloughlin, a recent graduate of The George Washington Law School, has joined the think tank on a full-time basis as a Legal Fellow. And Ilan Wurman, associate professor of law at Arizona State University, has been appointed to FSF’s Board of Academic Advisors.

Please see their linked bios for further background.