title: La bohème

text: Baz Luhrmann produced the opera for Opera Australia in 1990 with modernized supertitle translations, and a budget of only A$60,000 (A$130,545.17 in 2022). A DVD was issued of the stage show. According to Luhrmann, this version was set in 1957 (rather than the original period of 1830) because "...[they] discovered that 1957 was a very, very accurate match for the social and economic realities of Paris in the 1840s." In 2002, Luhrmann restaged his version on Broadway, the production won two Tony Awards out of six nominations; for Best Scenic Design and Best Lighting Design as well as a special award, the Tony Honor for Excellence in Theatre. To play the eight performances per week on Broadway, three casts of Mimìs and Rodolfos, and two Musettas and Marcellos, were used in rotation.


title: La bohème

text: Robin Norton-Hale directed a new production at the Cock Tavern Theatre, Kilburn, for OperaUpClose in December 2009. For act 2 the entire audience and cast moved downstairs to the pub itself, with the pub's patrons serving as extras in the Cafe Momus scene. In 2010 the production was transferred to the West End's Soho Theatre and won a Laurence Olivier Award.


title: La bohème

text: A 2019 production by Canada's Against the Grain Theatre featured a translated English libretto, and transposed the story to a contemporary Canadian urban setting. This production toured several Canadian cities before its production at Toronto's Tranzac Club was livestreamed by CBC Gem on October 13. The CBC broadcast received two Canadian Screen Award nominations at the 9th Canadian Screen Awards in 2021, for Best Performing Arts Program and Best Direction in a TV Movie.


title: Digital Millennium Copyright Act

text: The Digital Millennium Copyright Act (DMCA) is a 1998 United States copyright law that implements two 1996 treaties of the World Intellectual Property Organization (WIPO). It criminalizes production and dissemination of technology, devices, or services intended to circumvent measures that control access to copyrighted works (commonly known as digital rights management or DRM). It also criminalizes the act of circumventing an access control, whether or not there is actual infringement of copyright itself. In addition, the DMCA heightens the penalties for copyright infringement on the Internet. Passed on October 12, 1998, by a unanimous vote in the United States Senate and signed into law by President Bill Clinton on October 28, 1998, the DMCA amended Title 17 of the United States Code to extend the reach of copyright, while limiting the liability of the providers of online services for copyright infringement by their users.


title: Digital Millennium Copyright Act

text: The DMCA's principal innovation in the field of copyright is the exemption from direct and indirect liability of Internet service providers and other intermediaries. This exemption was adopted by the European Union in the Electronic Commerce Directive 2000. The Information Society Directive 2001 implemented the 1996 WIPO Copyright Treaty in the EU.


title: Digital Millennium Copyright Act

text: The Digital Millennium Copyright Act (DMCA) had its basis as part of the United States' commitment to comply with two treaties passed by the World Intellectual Property Organization (WIPO) in December 1996 that dealt with the nature of copyright with modern information systems such as the Internet. The WIPO Copyright Treaty identified numerous electronic works as eligible for copyright protection, and stated that circumvention of technological measures used to secure electronic works was to be prohibited. The WIPO Performances and Phonograms Treaty worked to normalize the copyright protections for performed works as uniformly for member states as possible.


title: Digital Millennium Copyright Act

text: The process of ratifying the treaties for the United States was the first major piece of copyright-related legislation since the Copyright Act of 1976, and led to numerous interested groups to express concerns for how the treaties should be implemented, including content producers and distributors, technology manufacturers, online service providers, researchers and academics, and consumer groups. Some groups urged for stronger copyright enforcement while others sought more relaxing of rules. As the bill was being formed in the Commerce Committee in the House of Representatives, the committee recognized that the final bill would be far more encompassing than just copyright reform but would be establishing key principles in the digital commerce marketplace.


title: Digital Millennium Copyright Act

text: In evaluating the enforcement of the WIPO Copyright Treaty with its anti-circumvention provisions with U.S. copyright law, lawmakers recognized that traditionally copyright law did not generally account for the medium of the work, as it was generally impossible to make an exact copy of an analog work previously, and current law was only concerned with unlawful acts of copyright violations. Since digital technology could allow for infinite numbers of exact copies of works to be made, the lawmakers agreed they had to extend copyright to include limits on devices and services which could be used for anti-circumvention in addition to acts of anti-circumvention. In establishing this, the lawmakers also recognized this would have a negative impact on fair use without exceptions, with electronic works potentially falling into the public domain but still locked beyond anti-circumvention measures, but they also needed to balance the rights of copyright holders. The DMCA as passed contained some basic fair use allowance such as for limited reverse engineering and for security research. Lawmakers opted to create a rulemaking mechanism through the United States Copyright Office to review the state of copyrights and fair use to make limited classes of allowance for fair use which would be considered lawful means of using anti-circumvention technology.


title: Digital Millennium Copyright Act

text: DMCA Title I, the WIPO Copyright and Performances and Phonograms Treaties Implementation Act, amends U.S. copyright law to comply with the WIPO Copyright Treaty and the WIPO Performances and Phonograms Treaty, adopted at the WIPO Diplomatic Conference in December 1996. The treaties have two major portions. One portion includes works covered by several treaties in U.S. copy prevention laws and gave the title its name. For further analysis of this portion of the Act and of cases under it, see WIPO Copyright and Performances and Phonograms Treaties Implementation Act.


title: Digital Millennium Copyright Act

text: The second portion (17 U.S.C. 1201) is often known as the DMCA anti-circumvention provisions. These provisions changed the remedies for the circumvention of copy-prevention systems (also called "technical protection measures"). The section contains a number of specific limitations and exemptions, for such things as government research and reverse engineering in specified situations. Although section 1201(c) of the title stated that the section does not change the underlying substantive copyright infringement rights, remedies, or defenses, it did not make those defenses available in circumvention actions. The section does not include a fair use exemption from criminality nor a scienter requirement, so criminal liability could attach to even unintended circumvention for legitimate purposes.


title: Digital Millennium Copyright Act

text: DMCA Title II, the Online Copyright Infringement Liability Limitation Act ("OCILLA"), creates a safe harbor for online service providers (OSPs, including ISPs) against copyright infringement liability, provided they meet specific requirements. OSPs must adhere to and qualify for certain prescribed safe harbor guidelines and promptly block access to alleged infringing material (or remove such material from their systems) when they receive notification of an infringement claim from a copyright holder or the copyright holder's agent (a "notice and takedown" process). OCILLA also includes a counternotification provision that offers OSPs a safe harbor from liability to their users when users claim that the material in question is not, in fact, infringing. OCILLA also facilitates issuing of subpoenas against OSPs to provide their users' identity.


title: Digital Millennium Copyright Act

text: DMCA Title III modified section 117 of the copyright title so that those repairing computers could make certain temporary, limited copies while working on a computer. It reversed the precedent set in "MAI Systems Corp. v. Peak Computer, Inc.", 991 F.2d 511 (9th Cor. 1993).


title: Digital Millennium Copyright Act

text: DMCA Title V added sections 1301 through 1332 to add a "sui generis" protection for boat hull designs. Boat hull designs were not considered covered under copyright law because boats are useful articles whose form cannot be separated from their function as determined by the Supreme Court case "Bonito Boats, Inc. v. Thunder Craft Boats, Inc.".


title: Digital Millennium Copyright Act

text: In addition to the safe harbors and exemptions the statute explicitly provides, 17 U.S.C. 1201(a)(1) requires that the Librarian of Congress issue exemptions from the prohibition against circumvention of access-control technology. Exemptions are granted when it is shown that access-control technology has had a substantial adverse effect on the ability of people to make non-infringing uses of copyrighted works.


title: Digital Millennium Copyright Act

text: The exemption rules are revised every three years. Exemption proposals are submitted by the public to the Registrar of Copyrights, and after a process of hearings and public comments, the final rule is recommended by the Registrar and issued by the Librarian. Exemptions expire after three years and must be resubmitted for the next rulemaking cycle.


title: Digital Millennium Copyright Act

text: The Copyright Office approved two exemptions in 2000, four in 2003, six each in 2006 and 2010, five in 2012, and nine in 2015.


title: Digital Millennium Copyright Act

text: Rulemaking was scheduled to occur in 2009, but the final rule was not issued until the following year. The 2010 exemptions, issued in July 2010, are:


title: Digital Millennium Copyright Act

text: After much criticism (see below), on December 29, 2015, the Copyright Office initiated a study to assess the operation of section 1201 and the triennial rulemaking process. This is different from usual public comments on exemption proposals. It includes the role of the anti-trafficking provisions and permanent exemptions, and the requirements of the rulemaking itself. The Office has issued a Notice of Inquiry requesting public comment.


title: Digital Millennium Copyright Act

text: Several comments were posted by individuals and organizations. An individual recalls that the Copyright Clause has limitations. Association of American Publishers "et al." hold there is no need to amend the statute or to significantly alter the rulemaking. They are happy with the protection they are being granted, including anti-trafficking provisions, and talk of placing the cart before the horse, when they argue about requiring a proof of the mindset that consumers would have when utilizing circumvention tools before actual acts of circumvention occur. In their opinion, the meaning of Section 1201 is to "extend", not merely duplicate, copyright holder's rights. Society of American Archivists say they are not aware that the anti-trafficking provisions of section 1201(a)(2) and 1201(b) have had any impact in deterring copyright infringement. They do know, however, that the provisions have created an absurd, Catch-22 situation for any archives that sought to adhere to the letter of the law. iFixit also talks of Catch-22 on stressing that since it is up to proponents to show that an exemption is relevant, they need to show that there's overwhelming market demand "if only it were legal". Rapid7 notice that DMCA adversely affects good faith security research by forbidding researchers from circumventing technological protection measures (TPMs) to analyze software for vulnerabilities. Cyberlaw Clinic at Harvard Law School points out that the rulemaking is a complicated, "ad hoc", and unduly burdensome process. Professors Andrea M. Matwyshyn, Steven M. Bellovin, Matt Blaze, J. Alex Halderman, and Nadia Heninger, jointly advocated making the security research exemption granted in the 2015 Triennial Section 1201 Rulemaking permanent.


title: Digital Millennium Copyright Act

text: The Learning Disabilities Association of America (LDA) commented that circumventing DRM restrictions to meet accessibility needs deserves a permanent exception. Entertainment Software Association gives a vivid and detailed description of a flourishing market which is only possible because of DMCA. They are deeply concerned about people with disabilities, but that concern is already being taken care of by the copyright holders, so that no permanent exception is needed.


title: Digital Millennium Copyright Act

text: Comments have also been submitted by, among others, R Street Institute American Association of Law Libraries, Business Software Alliance, Alliance of Automobile Manufacturers, Association of American Universities "et al.", Copyright Alliance, Association for Computing Machinery U.S. Public Policy Council, the Software and Information Industry Association, DVD Copy Control Association ("DVD CCA") "et al.", Microsoft Corporation, Association for Competitive Technology, Public Knowledge, American Automobile Association.


title: Digital Millennium Copyright Act

text: In June 2017, the Copyright Office published a report where it "shares the concern" that Section 1201 can affect activities unrelated to copyright infringement, but also expressed concerns over weakening "the right of copyright owners to exercise meaningful control over the terms of access to their works online", which they believe is "essential to the development of the digital marketplace for creative content". However, with respect to the question of whether the security research exemption granted in the 2015 Triennial cycle should be made permanent in some form, the Office recommended “that Congress consider expanding the reach of this exemption, easing the strict authorization requirement for researchers and restrictions on the use of information generated from the research, and abandoning or clarifying the multifactor test,” stating that “it continues to believe that the exemption adopted in 2015 can be a useful starting point, and notes that most of the security researchers who petitioned for that exemption .. agree.”


title: Digital Millennium Copyright Act

text: The anti-circumvention provisions in Section 1201 of the DMCA have seen some challenges in the courts but which have generally been upheld. While initially the challenges were focused on clear applications to software-based access control products, some cases considered how the DMCA also extended to hardware-based access controls.


title: Digital Millennium Copyright Act

text: Universal City Studios, Inc. v. Reimerdes/Universal City Studios, Inc. v. Corley - Eight movie studios had sued Eric Corley, Shawn Reimerdes, and Roman Kazan, editors of "", for posting the code of DeCSS, an algorithm to bypass the Content Scramble System (CSS) used to encrypt DVD content. The studios argued this was an anti-circumvention device under the DMCA. While Reimerdes and Kazan entered into consent decrees and were dropped from the suit, Corley continued the case, arguing that DeCSS as computer code was protected as free speech, and that this was one of the allowed provisions of fair use under the DMCA for users to make copies of media they legally owned. Both the District Court and the Second Circuit rejected Corley's arguments. While they agreed that while a computer program may be protected speech, distribution of anti-circumvention devices was not considered a fair use option covered by Section 1201, and thus DeCSS violated the DMCA and was not protected by First Amendment rights.


title: Digital Millennium Copyright Act

text: United States v. Elcom Ltd. - Moscow-based Elcom had developed software that was able to remove protections that one could place on an Adobe Acrobat PDF file, such as those used in ebook distribution. Adobe requested the U.S. Department of Justice take action against the company for violating the DMCA. Elcom argued in court that as written, the DMCA was unconstitutionally too vague and would allow for circumvention of use controls for purposes of fair use, and that it violated the First Amendment by placed too much burden on those seeking to use protected works for fair use. The initial ruling at the U.S. District Court for the Northern District of California rejected both arguments, following on the basis of "Corley". The ruling established that the DMCA was not unconstitutional, and that while it place a burden on accessing works for fair use, the DMCA did not outright restrict fair use; in the case of the ebook example, the ruling observed that the user may have to type a quote from the ebook rather than copy and paste from the unprotected version.


title: Digital Millennium Copyright Act

text: 321 Studios v. Metro Goldwyn Mayer Studios, Inc. - 321 Studios made copies that allowed users to copy DVDs, including those with CSS copy protection, to another DVD or to a CD-ROM. The company sought declaratory judgment from MGM Studios that their software did not violate the DMCA, or sought to have the DMCA ruled unconstitutional. The case, heard in the United States District Court for the Northern District of California, ruled against 321 Studios on both arguments, based on the past rulings from "Corley" and "Elcom" that 321 Studios' software was not protected speech and violated the DMCA with no respect to fair use, and that the questions on the constitutionality of the DMCA were answered from the prior cases. The case law from "Corley", "Elcom" and "321 Studios" effectively established that the DMCA could not be challenged as an unconstitutional law.


title: Digital Millennium Copyright Act

text: Chamberlain Group, Inc. v. Skylink Technologies, Inc. - Chamberlain manufactured garage door openers, while Skylink created universal garage door openers remotes that worked with a variety of manufacturers. Chamberlain had developed a security protocol for its remotes to match the remote to the door opening motor via a software-based rolling code as to prevent unauthorized opening. Skylink had been able to use a resynchronization feature of the Chamberlain security software as to create a universal remote to work with the Chamberlain openers. Chamberlain sued Skylink as it argued the rolling code was effective an access control device and thus Skylink violated the DMCA. Both the United States District Court for the Northern District of Illinois and the United States Court of Appeals for the Federal Circuit ruled in favor of Skylink that there was no DMCA violation. The courts ruled the DMCA did not create a new property right, and thus consumers that owned Chamberlain's product had a right to circumvent any restrictions, since this was typical practice on the market and customers, in purchasing a Chamberlain garage door opener, did not sign off to any end user license agreement to waive away those rights.


title: Digital Millennium Copyright Act

text: Lexmark International, Inc. v. Static Control Components, Inc. - Lexmark had developed a lock-out mechanism for its ink-jet printers that would require only its own ink cartridges to be used as replacements. The mechanism used an access program from the printer side that would then query a chip on the ink cartridge, and only accept that cartridge if it matched the expected response. Static Control Components had been able to reverse engineer the proper response by reading the program from the printer and were able to make their own third-party ink cartridges that worked with Lexmark printers. Lexmark sued under the DMCA and while they had won at the District Court, the case was reversed by the United States Court of Appeals for the Sixth Circuit. The Sixth Circuit affirmed that while Lexmark's programs to manage the lockout were copyrightable and thus would be eligible for protections under the DMCA, they had failed to include an anti-circumvention device that "effectively controls access" to the printer lockout program.


title: Digital Millennium Copyright Act

text: The law is currently unsettled with regard to websites that contain links to infringing material; however, there have been a few lower-court decisions which have ruled against linking in some narrowly prescribed circumstances. One is when the owner of a website has already been issued an injunction against posting infringing material on their website and then links to the same material in an attempt to circumvent the injunction. Another area involves linking to software or devices which are designed to circumvent (digital rights management) devices, or links from websites whose sole purpose is to circumvent copyright protection by linking to copyrighted material.


title: Digital Millennium Copyright Act

text: In July 2002, American Civil Liberties Union filed a lawsuit on the behalf of Benjamin Edelman, a computer researcher at Berkman Center for Internet and Society, seeking a declaratory judgment to affirm his first amendment rights when reverse engineering the censorware product of defendant N2H2 in case he intended to publish the finding. N2H2 filed a motion to dismiss, which the court granted on the basis that Edelman had not finished reverse engneeering, and the court did not make advisory opinions.


title: Digital Millennium Copyright Act

text: In August 2009, the DVD Copy Control Association won a lawsuit against RealNetworks for violating copyright law in selling its RealDVD software, allowing users to copy DVDs and store them on a harddrive. The DVD Copy Control Association claimed that Real violated the DMCA by circumventing anti-piracy measures ARccOS Protection and RipGuard, as well as breaking Real's licensing agreement with the Content Scrambling System.


title: Digital Millennium Copyright Act

text: On March 13, 2007, Viacom filed a lawsuit against YouTube and its corporate parent Google for copyright infringement seeking more than $1 billion in damages. The complaint was filed in the U.S. District Court for the Southern District of New York.


title: Digital Millennium Copyright Act

text: Viacom claims the popular video-sharing site was engaging in "massive intentional copyright infringement" for making available a contended 160,000 unauthorized clips of Viacom's entertainment programming. Google relied on the 1998 Digital Millennium Copyright Act's "safe harbor" provision to shield them from liability.


title: Digital Millennium Copyright Act

text: On June 23, 2010, U.S. District Judge Louis Stanton granted summary judgment in favor of YouTube. The court held that YouTube is protected by the safe harbor of the DMCA. Viacom appealed to the U.S. Court of Appeals for the Second Circuit.


title: Digital Millennium Copyright Act

text: On April 5, 2012, the federal Second Circuit Court of Appeals vacated Judge Louis Stanton's ruling, and instead ruled that Viacom had presented enough evidence against YouTube to warrant a trial, and the case should not have been thrown out in summary judgment. The court did uphold the ruling that YouTube could not be held liable based on "general knowledge" that users on its site were infringing copyright. The case was sent back to the District Court in New York, and on April 18, 2013, Judge Stanton issued another order granting summary judgment in favor of YouTube. Before it was send back to the Court of Appeals, a settlement was reached; no money changed hands.


title: Digital Millennium Copyright Act

text: On June 23, 2006, IO Group, Inc. filed a complaint against Veoh Networks, Inc. in the U.S. District Court for California's Northern District.


title: Digital Millennium Copyright Act

text: IO Group alleged that Veoh was responsible for copyright infringement by allowing videos owned by IO Group to be accessed through Veoh's online service without permission over 40,000 times between the dates June 1 and June 22.


title: Digital Millennium Copyright Act

text: Veoh is a Flash video site relying on user contributed content. IO Group argued that since Veoh transcoded user uploaded videos to Flash format it became a direct infringer and the materials were under their direct control, thereby disqualifying them for DMCA safe harbor protection.


title: Digital Millennium Copyright Act

text: Veoh has simply established a system whereby software automatically processes user-submitted content and recasts it in a format that is readily accessible to its users. Veoh preselects the software parameters for the process from a range of default values set by the thirdparty software... But Veoh does not itself actively participate or supervise the uploading of files. Nor does it preview or select the files before the upload is completed. Instead, video files are uploaded through an automated process which is initiated entirely at the volition of Veoh's users.


title: Digital Millennium Copyright Act

text: The Court has granted the Veoh's motion for summary judgment, on the basis of the DMCA, holding that the defendant's video-sharing web site complied and was entitled to the protection of the statute's "safe harbor" provision. Even though Veoh won the court case, it blamed the litigation as one of the causes of its preparing to file Chapter 7 bankruptcy and its subsequent sale to Qlipso.


title: Digital Millennium Copyright Act

text: After numerous DMCA takedown notices in response to his eBay listings, Timothy S. Vernor sued Autodesk in August 2007, alleging that Autodesk abused the DMCA and disrupted his right to sell used software he bought at a garage sale. In May 2008, a federal district judge in Washington State Autodesk's authorised that the software's license agreement preempted the seller from his rights under the first-sale doctrine. In September 2010, the U.S. Court of Appeals for the Ninth Circuit reversed, holding that "a software user is a licensee rather than an owner of a copy where the copyright owner (1) specifies that the user is granted a license; (2) significantly authorised the user's ability to transfer the software; and (3) imposes notable use authorisations."


title: Digital Millennium Copyright Act

text: In 2007, Stephanie Lenz, a writer and editor from Gallitzin, Pennsylvania made a home video of her 13-month-old son dancing to the Prince song "Let's Go Crazy" and posted a 29-second video on the video-sharing site YouTube. Four months after the video was originally uploaded, Universal Music Group, which owned the copyrights to the song, ordered YouTube to remove the video enforcing the Digital Millennium Copyright Act.


title: Digital Millennium Copyright Act

text: Lenz notified YouTube immediately that her video was within the scope of fair use, and demanded that it be restored. YouTube complied after six weeks—not two weeks, as required by the Digital Millennium Copyright Act—to see whether Universal planned to sue Lenz for infringement. Lenz then sued Universal Music in California for her legal costs, claiming the music company had acted in bad faith by ordering removal of a video that represented fair use of the song.


title: Digital Millennium Copyright Act

text: In August 2008, U.S. District Judge Jeremy Fogel of San Jose, California ruled that copyright holders cannot order a deletion of an online file without determining whether that posting reflected "fair use" of the copyrighted material.


title: Digital Millennium Copyright Act

text: On February 25, 2010, Judge Fogel issued a ruling rejecting several of Universal's affirmative defenses, including the defense that Lenz suffered no damages.


title: Digital Millennium Copyright Act

text: In 2015, the court ultimately upheld the finding that Universal was liable under 17 USC 512(f) (the DMCA's bad faith notice and takedown provision) for failing to consider fair use before sending its initial takedown notice.


title: Digital Millennium Copyright Act

text: In the case of Flava Works Inc. v. Gunter the court denied the defendant safe harbor protection under DMCA . The district court found that the defendant had knowledge of its users' infringing activity and also failed to prevent future infringing activity. As such the plaintiff's motion for preliminary injunction was granted. On appeal, however, the Seventh Circuit vacated the injunction, citing the standard set in eBay Inc. v. MercExchange, L.L.C., which states that courts should not rely on categorical rules as a standard for injunction.


title: Digital Millennium Copyright Act

text: In this case of Ouellette v. Viacom International Inc., the court denied plaintiff's attempt to find liability for YouTube and Myspace's takedowns of the plaintiff's homemade videos. Despite potential fair use claims, the court found it impossible to use the DMCA takedown provisions as a foundation for liability. The court found that the safe harbor provision serves "to limit the liability of internet service providers, not to create liability that could not otherwise be imposed under existing law independent of the DMCA."


title: Digital Millennium Copyright Act

text: In January 2011, Sony Computer Entertainment sued George Hotz over violating the Section 1201 of the Digital Millennium Copyright Act as well as the Federal Fraud and Abuse Act due to facilitating consumers to jailbreak their PlayStation 3 consoles. Hotz argued that because he had purchased the product, he had the right to do with it as he pleased. After three months, Sony and Hotz decided to settle out of court. This also included an injunction against George Hotz, barring him from hacking any more Sony products.


title: Digital Millennium Copyright Act

text: In 2013, Oliver Hotham wrote an article on WordPress (owned by Automattic, Inc.) critical of Straight Pride UK that included material from a press release sent to him by Straight Pride UK's press officer, Nick Steiner. Steiner sent WordPress a DMCA takedown notice claiming that Hotham's article infringed their copyright. WordPress and Hotham sued in a federal District Court in California, under §512(f) of the DMCA, claiming that the takedown notice was fraudulent, and that the takedown cost the plaintiffs time, lost work and attorneys' fees. In 2015, the court issued a default judgment in favor of WordPress and Hotham in the amount of $25,084.


title: Digital Millennium Copyright Act

text: Google asserted misuse of the DMCA in a filing concerning New Zealand's copyright act, quoting results from a 2005 study by California academics Laura Quilter and Jennifer Urban based on data from the Chilling Effects clearinghouse. Takedown notices targeting a competing business made up over half (57%) of the notices Google has received, the company said, and more than one-third (37%) "were not valid copyright claims."


title: Digital Millennium Copyright Act

text: Currently, there are three main abuses of the DMCA. First, fair use has been a legal gray area, and subject to opposing interpretations. This has caused inequity in the treatment of individual cases. Second, the DMCA has often been invoked overbearingly, favoring larger copyright holders over smaller ones. This has caused accidental takedowns of legitimate content, such as a record company accidentally removing a music video from their own artist. Third, the lack of consequences for perjury in claims encourages censorship. This has caused temporary takedowns of legitimate content that can be financially damaging to the legitimate copyright holder, who has no recourse for reimbursement. This has been used by businesses to censor competition.


title: Digital Millennium Copyright Act

text: The use of DMCA-enabled takedown notices has been raised for a number of services that allow users to provide content. Early concerns were focused on peer-to-peer file sharing services such as BitTorrent. Such services grew after Napster was sued by several music industry groups in "A&M Records, Inc. v. Napster, Inc." (2001) which ruled that Napster was liable for enabling copyright infringement under the DMCA since they maintained central servers that tracked file sharing; by switching to the peer-to-peer model, these new services avoided this possible legality. However, some still saw legal challenges, such as "MGM Studios, Inc. v. Grokster, Ltd." (2005) based on the fact they were operated commercially and promoted the ability to share copyrighted works. Non-commercial and open-source peer-to-peer services were able to survive from these case laws, leading entertainment groups to deploy software on the services to track downloads, and subsequently attempted to serve takedown notices and sue users on the services for copyright violations under the DMCA since around 2003. However, many of these methods were imprecise, leading to a number of false accusations at users.


title: Digital Millennium Copyright Act

text: In 2015 Volkswagen abused the DMCA to hide their vehicles' emissions cheat. It has been suggested that had the DMCA not prevented access to the software "..a researcher with legal access to Volkswagen's software could have discovered the code that changed how the cars behave in testing.."


title: Digital Millennium Copyright Act

text: Analog Copy Protection (ACP), the encryption technology created by Rovi Corporation (formerly Macrovision, now TiVo), is designed to thwart users' attempts to reproduce content via analog cables. When a DVD is played through an analog video cable and recorded using a VCR, Rovi's ACP technology will distort the copy partially or completely.


title: Digital Millennium Copyright Act

text: The technology works by adding additional lines to the video signal. In the NTSC video standard, blank lines (vertical blanking intervals) that the user cannot see are used for functions like closed captioning. Rovi Corporation uses these blank lines to implement its ACP technology.


title: Digital Millennium Copyright Act

text: The implementation of ACP has been ill-regarded by some video enthusiasts. Many claim that the technology has led to signal issues with VCRs and analog video equipment. Some VCRs misread the encryption used to prevent copying, distorting the video image regardless of whether the recording is original or a copy.


title: Digital Millennium Copyright Act

text: The DMCA has been criticized for forcing all producers of analog video equipment to support the proprietary copy protection technology of Rovi Corporation, a commercial firm. The producers of video equipment are forced by law to support and implement the corporation's proprietary technology. This benefits Rovi Corporation financially, whereas those forced to implement it receive neither profit nor compensation.


title: Digital Millennium Copyright Act

text: Additionally, some criticize the implementation of ACP as a violation of their fair use rights. A recently developed TV-streaming product called the Slingbox uses analog signals to convey video from television to a mobile device. However, the encryption used by ACP blocks analog transmission, rendering the Slingbox unusable. Additionally ACP blocks the use of recording for educational purposes. On one or more accounts, students have not been able to cite and record cable sources properly due to ACP restrictions.


title: Digital Millennium Copyright Act

text: The DMCA has affected the worldwide cryptography research community, since an argument can be made that any cryptanalytic research violates, or might violate, the DMCA. The arrest of Russian programmer Dmitry Sklyarov in 2001, for alleged infringement of the DMCA, was a highly publicized example of the law's use to prevent or penalize development of anti-DRM measures. While working for ElcomSoft in Russia, he developed "The Advanced eBook Processor", a software application allowing users to strip usage restriction information from restricted e-books, an activity legal in both Russia and the United States. Paradoxically, under the DMCA, it is not legal in the United States to provide such a tool. Sklyarov was arrested in the United States after presenting a speech at DEF CON and subsequently spent nearly a month in jail. The DMCA has also been cited as chilling to legitimate users, such as students of cryptanalysis (including, in a well-known instance, Professor Edward Felten and students at Princeton), and security consultants such as Niels Ferguson, who has declined to publish information about vulnerabilities he discovered in an Intel secure-computing scheme because of his concern about being arrested under the DMCA when he travels to the U.S.


title: Digital Millennium Copyright Act

text: In at least one court case, the DMCA has been used by open source software projects to defend against conversion of software (i.e., license violations) that involved removal of copyright notices.


title: Digital Millennium Copyright Act

text: Jonathan Bailey of "Plagiarism Today" argued that the DMCA has left Kindle Direct Publishing (an Amazon subsidiary) with no incentive to find new innovations for vetting submitted books for plagiarism or copyright theft before allowing them to be published. According to Bailey, "Amazon doesn’t do much to vet the books it publishes. Plagiarism isn’t even mentioned in its KDP help files. What this means is that it’s trivial to publish almost anything you want regardless of the quality of the work or, in these cases, how original it is. In fact, many complain that Amazon fails to vet works for even simple issues such as formatting and layout. Though Amazon will, sometimes, remove works that violates their terms of service after they get complaints, they’re happy to sell the books and reap the profits until they get such a notice. And, from Amazon’s perspective, this is completely legal. They are protected by the Digital Millennium Copyright Act (DMCA) as well as other laws, in particular Section 230 of the Communications Decency Act, that basically mean they are under no obligation to vet or check the works they publish. They are legally free to produce and sell books, physical and digital, regardless of whether they are plagiarized, copyright infringing or otherwise illegal."


title: Digital Millennium Copyright Act

text: There have been several Congressional efforts to modify the Act. The Unlocking Technology Act of 2013 was introduced to attempt to exempt non-infringing uses from the anti-circumvention clause. However, the bill was not passed by Congress. In 2014, the Unlocking Consumer Choice and Wireless Competition Act was passed, granting a specific exemption for unlocking cell phones, without affecting the other provisions of the DMCA.


title: Digital Millennium Copyright Act

text: Bills in 2015 included the Unlocking Technology Act of 2015, and the Breaking Down Barriers to Innovation Act of 2015. Republicans are considering legislation as well, as it becomes clear that Section 1201 is impeding the country's security. Facing escalating numbers of cyberthreats, cybersecurity researchers petitioned to conduct research to keep pace with evolving cybersecurity risks and vulnerabilities, stating: "Without such an exemption, security risks will lie unaddressed and the public will be substantially less safe." The bills are intended to address the fact that section 1201 prevents circumvention even when doing so is not copyright infringement. In addition, the section requires exemption proponents to bear the burden of proof every time their exemption comes up for triennial review, instead of there being a presumption of renewal for an exemption whose importance was previously proven.


title: Digital Millennium Copyright Act

text: Rick Boucher, a congressman from Virginia, led previous efforts by introducing the Digital Media Consumers' Rights Act (DMCRA).


title: Digital Millennium Copyright Act

text: A prominent bill related to the DMCA is the Consumer Broadband and Digital Television Promotion Act (CBDTPA), known in early drafts as the Security Systems and Standards Certification Act (SSSCA). This bill, if it had passed, would have dealt with the devices used to access digital content and would have been even more restrictive than the DMCA.


title: Digital Millennium Copyright Act

text: Senator Thom Tillis introduced a draft revision of the DMCA in December 2020. A fundamental change in his language would be to support "notice and stay down" for service providers, requiring them to take measures to prevent material that has already been determined to be violating copyright to be re-uploaded by users. While the draft was praised by the entertainment industry, free speech advocacy groups feared the language would require services to employ automatic filtering and would further limit freedom of expression.


title: Digital Millennium Copyright Act

text: On the fifth anniversary of the DMCA, and several times afterwards, the Electronic Frontier Foundation documented harmful consequences of the anti-circumvention provisions. They document that the DMCA:


title: Digital Millennium Copyright Act

text: In July 2016, the Electronic Frontier Foundation sued the US government in "Green v. Department of Justice" alleging that Section 1201 violates the First Amendment.


title: Dahlia

text: Dahlia (, ) is a genus of bushy, tuberous, herbaceous perennial plants native to Mexico and Central America. A member of the Compositae (also called Asteraceae) family of dicotyledonous plants, its garden relatives thus include the sunflower, daisy, chrysanthemum, and zinnia. There are 49 species of this genus, with hybrids commonly grown as garden plants. Flower forms are variable, with one head per stem; these can be as small as diameter or up to ("dinner plate"). This great variety results from dahlias being octoploids—that is, they have eight sets of homologous chromosomes, whereas most plants have only two. In addition, dahlias also contain many transposons—genetic pieces that move from place to place upon an allele—which contributes to their manifesting such great diversity.


title: Dahlia

text: The stems are leafy, ranging in height from as low as to more than . The majority of species do not produce scented flowers. Like most plants that do not attract pollinating insects through scent, they are brightly colored, displaying most hues, with the exception of blue.


title: Dahlia

text: The dahlia was declared the national flower of Mexico in 1963. The tubers were grown as a food crop by the Aztecs, but this use largely died out after the Spanish Conquest. Attempts to introduce the tubers as a food crop in Europe were unsuccessful.


title: Dahlia

text: Dahlias are perennial plants with tuberous roots, though they are grown as annuals in some regions with cold winters. While some have herbaceous stems, others have stems which lignify in the absence of secondary tissue and resprout following winter dormancy, allowing further seasons of growth. As a member of the Asteraceae, the dahlia has a flower head that is actually a composite (hence the older name Compositae) with both central disc florets and surrounding ray florets. Each floret is a flower in its own right, but is often incorrectly described as a petal, particularly by horticulturists. The modern name Asteraceae refers to the appearance of a star with surrounding rays.


title: Dahlia

text: Spaniards reported finding the plants growing in Mexico in 1525, but the earliest known description is by Francisco Hernández, physician to Philip II, who was ordered to visit Mexico in 1570 to study the "natural products of that country". They were used as a source of food by the indigenous peoples, and were both gathered in the wild and cultivated. The Aztecs used them to treat epilepsy, and employed the long hollow stem of the "Dahlia imperialis" for water pipes. The indigenous peoples variously identified the plants as "Chichipatl" (Toltecs) and "Acocotle" or "Cocoxochitl" (Aztecs). From Hernandez's perception of Aztec, to Spanish, through various other translations, the word is "water cane", "water pipe", "water pipe flower", "hollow stem flower" and "cane flower". All these refer to the hollowness of the plants' stem.


title: Dahlia

text: Hernandez described two varieties of dahlias (the pinwheel-like "Dahlia pinnata" and the huge "Dahlia imperialis") as well as other medicinal plants of New Spain. Francisco Dominguez, a Hidalgo gentleman who accompanied Hernandez on part of his seven-year study, made a series of drawings to supplement the four volume report. Three of his drawings showed plants with flowers: two resembled the modern bedding dahlia, and one resembled the species "Dahlia merckii"; all displayed a high degree of doubleness. In 1578 the manuscript, entitled "Nova Plantarum, Animalium et Mineralium Mexicanorum Historia", was sent back to the Escorial in Madrid; they were not translated into Latin by Francisco Ximenes until 1615. In 1640, Francisco Cesi, President of the "Academia dei Lincei" of Rome, bought the Ximenes translation, and after annotating it, published it in 1649–1651 in two volumes as "Rerum Medicarum Novae Hispaniae Thesaurus Seu Nova Plantarium, Animalium et Mineralium Mexicanorum Historia". The original manuscripts were destroyed in a fire in the mid-1600s.


title: Dahlia

text: In 1787, the French botanist Nicolas-Joseph Thiéry de Menonville, sent to Mexico to steal the cochineal insect valued for its scarlet dye, reported the strangely beautiful flowers he had seen growing in a garden in Oaxaca. In 1789, Vicente Cervantes, Director of the Botanical Garden at Mexico City, sent "plant parts" to Abbe Antonio José Cavanilles, Director of the Royal Gardens of Madrid. Cavanilles flowered one plant that same year, then the second one a year later. In 1791 he called the new growths "Dahlia" for Anders (Andreas) Dahl. The first plant was called "Dahlia pinnata" after its pinnate foliage; the second, "Dahlia rosea" for its rose-purple color. In 1796 Cavanilles flowered a third plant from the parts sent by Cervantes, which he named "Dahlia coccinea" for its scarlet color.


title: Dahlia

text: In 1798, Cavanilles sent D. pinnata seeds to Parma, Italy. That year, the Marchioness of Bute, wife of The Earl of Bute, the English Ambassador to Spain, obtained a few seeds from Cavanilles and sent them to Kew Gardens, where they flowered but were lost after two to three years.


title: Dahlia

text: In the following years Madrid sent seeds to Berlin and Dresden in Germany, and to Turin and Thiene in Italy. In 1802, Cavanilles sent tubers of "these three" ("D. pinnata, D. rosea, D. coccinea") to Swiss botanist Augustin Pyramus de Candolle at University of Montpelier in France, Andre Thouin at the Jardin des Plantes in Paris and Scottish botanist William Aiton at Kew Gardens. That same year, John Fraser, English nurseryman and later botanical collector to the Czar of Russia, brought "D. coccinea" seeds from Paris to the Apothecaries Gardens in England, where they flowered in his greenhouse a year later, providing "Botanical Magazine" with an illustration.


title: Dahlia

text: In 1804, a new species, "Dahlia sambucifolia", was successfully grown at Holland House, Kensington. Whilst in Madrid in 1804, Lady Holland was given either dahlia seeds or tubers by Cavanilles. She sent them back to England, to Lord Holland's librarian Mr Buonaiuti at Holland House, who successfully raised the plants. A year later, Buonaiuti produced two double flowers. The plants raised in 1804 did not survive; new stock was brought from France in 1815. In 1824, Lord Holland sent his wife a note containing the following verse:"The dahlia you brought to our isle


title: Dahlia

text: In 1805, German naturalist Alexander von Humboldt sent more seeds from Mexico to Aiton in England, Thouin in Paris, and Christoph Friedrich Otto, director of the Berlin Botanical Garden. More significantly, he sent seeds to botanist Carl Ludwig Willdenow in Germany. Willdenow now reclassified the rapidly growing number of species, changing the genus from "Dahlia" to "Georgina"; after naturalist Johann Gottlieb Georgi. He combined the Cavanilles species "D. pinnata" and "D. rosea" under the name of "Georgina variabilis"; "D. coccinea" was still held to be a separate species, which he renamed "Georgina coccinea".


title: Dahlia

text: Since 1789 when Cavanilles first flowered the dahlia in Europe, there has been an ongoing effort by many growers, botanists and taxonomists, to determine the development of the dahlia to modern times. At least 85 species have been reported: approximately 25 of these were first reported from the wild; the remainder appeared in gardens in Europe. They were considered hybrids, the results of crossing between previously reported species, or developed from the seeds sent by Humboldt from Mexico in 1805, or perhaps from some other undocumented seeds that had found their way to Europe. Several of these were soon discovered to be identical with earlier reported species, but the greatest number are new varieties. Morphological variation is highly pronounced in the dahlia. William John Cooper Lawrence, who hybridized hundreds of families of dahlias in the 1920s, stated: "I have not yet seen any two plants in the families I have raised which were not to be distinguished one from the other. Constant reclassification of the 85 reported species has resulted in a considerably smaller number of distinct species, as there is a great deal of disagreement today between systematists over classification.


title: Dahlia

text: In 1829, all species growing in Europe were reclassified under an all-encompassing name of "D. variabilis, Desf.", though this is not an accepted name. Through the interspecies cross of the Humboldt seeds and the Cavanilles species, 22 new species were reported by that year, all of which had been classified in different ways by several different taxonomists, creating considerable confusion as to which species was which. As of now Dahlias are classified into 15 different species by a botanist named Liberty Hyde Bailey. (Dr. Walbot). <https://web.stanford.edu/group/dahlia_genetics/dahlia_history.htm></https://web.stanford.edu/group/dahlia_genetics/dahlia_history.htm>


title: Dahlia

text: In 1830 William Smith suggested that all dahlia species could be divided into two groups for color, red-tinged and purple-tinged. In investigating this idea Lawrence determined that with the exception of "D. variabilis", all dahlia species may be assigned to one of two groups for flower-colour: Group I (ivory-magenta) or Group II (yellow-orange-scarlet).


title: Dahlia

text: The genus "Dahlia" is situated in the Asteroideae subfamily of the Asteraceae, in the Coreopsideae tribe. Within that tribe it is the second largest genus, after "Coreopsis", and appears as a well defined clade within the Coreopsideae.


title: Dahlia

text: Sherff (1955), in the first modern taxonomy described three sections for the 18 species he recognised, "Pseudodendron", "Epiphytum" and "Dahlia". By 1969 Sørensen recognised 29 species and four sections by splitting off "Entemophyllon" from section "Dahlia". By contrast Giannasi (1975) using a phytochemical analysis based on flavonoids, reduced the genus to just two sections, "Entemophyllon" and "Dahlia", the latter having three subsections, "Pseudodendron", "Dahlia", and "Merckii". Sørensen then issued a further revision in 1980, incorporating subsection "Merckii" in his original section "Dahlia".


title: Dahlia

text: When he described two new species in the 1980s ("Dahlia tubulata" and "D. congestifolia"), he placed them within his existing sections. A further species, "Dahlia sorensenii" was added by Hansen and Hjerting in (1996).


title: Dahlia

text: At the same time they demonstrated that "Dahlia pinnata" should more properly be designated "D. x pinnata". "D. x pinnata" was shown to actually be a variant of "D. sorensenii" that had acquired hybrid qualities before it was introduced to Europe in the sixteenth century and formally named by Cavanilles. The original wild "D. pinnata" is presumed extinct. Further species continue to be described, Saar (2003) describing 35 species. However separation of the sections on morphological, cytologal and biocemical criteria has not been entirely satisfactory.


title: Dahlia

text: To date these sectional divisions have not been fully supported phylogenetically, which demonstrate only section "Entemophyllon" as a distinct sectional clade. The other major grouping is the core "Dahlia" clade (CDC), which includes most of the section "Dahlia". The remainder of the species occupy what has been described as the variable root clade (VRC) which includes the small section "Pseudodendron" but also the monotypic section "Epiphytum" and a number of species from within section "Dahlia". Outside of these three clades lie "D. tubulata" and "D. merckii" as a polytomy.


title: Dahlia

text: Horticulturally the sections retain some usage, section "Pseudodendron" being referred to as 'Tree Dahlias', "Epiphytum" as the 'Vine Dahlia'. The remaining two herbaceous sections being distinguished by their pinnules, opposing ("Dahlia") or alternating ("Entemophyllon").


title: Dahlia

text: Only "Pseudodendron" ("D. imperialis") and "Dahlia" ("D. australis", "D. coccinea") occur outside Mexico.


title: Dahlia

text: There are currently 42 accepted species in the genus "Dahlia" but new species continue to be described.


title: Dahlia

text: The naming of the plant itself has long been a subject of some confusion. Many sources state that the name "Dahlia" was bestowed by the pioneering Swedish botanist and taxonomist Carl Linnaeus to honor his late student, Anders Dahl, author of "Observationes Botanicae". However, Linnaeus died in 1778, more than eleven years before the plant was introduced into Europe in 1789, so while it is generally agreed that the plant was named in 1791 in honor of Dahl, who had died two years before, Linnaeus could not have been the one who did so. It was probably Abbe Antonio Jose Cavanilles, Director of the Royal Gardens of Madrid, who should be credited with the attempt to scientifically define the genus, since he not only received the first specimens from Mexico in 1789, but named the first three species that flowered from the cuttings.


title: Dahlia

text: Regardless of who bestowed it, the name was not so easily established. In 1805, German botanist Carl Ludwig Willdenow, asserting that the genus "Dahlia" Thunb. (published a year after Cavanilles's genus and now considered a synonym of "Trichocladus") was more widely accepted, changed the plants' genus from "Dahlia" to "Georgina" (after the German-born naturalist Johann Gottlieb Georgi, a professor at the Imperial Academy of Sciences of St. Petersburg, Russia). He also reclassified and renamed the first three species grown, and identified, by Cavanilles. It was not until 1810, in a published article, that he officially adopted the Cavanilles's original designation of "Dahlia". However, the name "Georgina" still persisted in Germany for the next few decades. In Russian, it is still named Georgina ().


title: Dahlia

text: "Dahl" is a homophone of the Swedish word "dal", or "valley"; although it is not a true translation, the plant is sometimes referred to as the "valley flower".


title: Dahlia

text: "Dahlia" is found predominantly in Mexico, but some species are found ranging as far south as northern South America. "D. australis" occurs at least as far south as southwestern Guatemala, while "D. coccinea" and "D. imperialis" also occur in parts of Central America and northern South America. "Dahlia" is a genus of the uplands and mountains, being found at elevations between 1,500 and 3,700 meters, in what has been described as a "pine-oak woodland" vegetative zone. Most species have limited ranges scattered throughout many mountain ranges in Mexico


title: Dahlia

text: Slugs and snails are serious pests in some parts of the world, particularly in spring when new growth is emerging through the soil. Earwigs can also disfigure the blooms. The other main pests likely to be encountered are aphids (usually on young stems and immature flower buds), red spider mite (causing foliage mottling and discolouration, worse in hot and dry conditions) and capsid bugs (resulting in contortion and holes at growing tips). Diseases affecting dahlias include powdery mildew, grey mould ("Botrytis cinerea"), verticillium wilt, dahlia smut ("Entyloma calendulae" f. "dahliae"), phytophthora and some plant viruses. Dahlias are a source of food for the larvae of some Lepidoptera species including angle shades, common swift, ghost moth and large yellow underwing.


title: Dahlia

text: Dahlias grow naturally in climates that do not experience frost (the tubers are hardy to USDA Zone 8), consequently they are not adapted to withstand sub-zero temperatures. However, their tuberous nature enables them to survive periods of dormancy, and this characteristic means that gardeners in temperate climates with frosts can grow dahlias successfully, provided the tubers are lifted from the ground and stored in cool yet frost-free conditions during the winter. Planting the tubers quite deep (10 – 15 cm) also provides some protection. When in active growth, modern dahlia hybrids perform most successfully in well-watered yet free-draining soils, in situations receiving plenty of sunlight. Taller cultivars usually require some form of staking as they grow, and all garden dahlias need deadheading regularly, once flowering commences.


title: Dahlia

text: The inappropriate term "D. variabilis" is often used to describe the cultivars of "Dahlia" since the correct parentage remains obscure, but probably involves "Dahlia coccinea". In 1846 the Caledonia Horticultural Society of Edinburgh offered a prize of 2,000 pounds to the first person succeeding in producing a blue dahlia. This has to date not been accomplished. While dahlias produce anthocyanin, an element necessary for the production of the blue, to achieve a true blue color in a plant, the anthocyanin delphinidin needs six hydroxyl groups. To date, dahlias have only developed five, so the closest that breeders have come to achieving a "blue" specimen are variations of mauve, purples and lilac hues.


title: Dahlia

text: By the beginning of the twentieth century, a number of different types were recognised. These terms were based on shape or colour, and the National Dahlia Society included cactus, pompon, single, show and fancy in its 1904 guide. Many national societies developed their own classification systems until 1962 when the International Horticultural Congress agreed to develop an internationally recognised system at its Brussels meeting that year, and subsequently in Maryland in 1966. This culminated in the 1969 publication of "The International Register of Dahlia Names" by the Royal Horticultural Society which became the central registering authority.


title: Dahlia

text: This system depended primarily on the visibility of the central disc, whether it was open-centred or whether only ray florets were apparent centrally (double bloom). The double-bloom cultivars were then subdivided according to the way in which they were folded along their longitudinal axis: flat, involute (curled inwards) or revolute (curling backwards). If the end of the ray floret was split, they were considered fimbriated. Based on these characteristics, nine groups were defined plus a tenth miscellaneous group for any cultivars not fitting the above characteristics. Fimbriated dahlias were added in 2004, and two further groups (Single and Double orchid) in 2007. The last group to be added, Peony, first appeared in 2012.


title: Dahlia

text: In many cases the bloom diameter was then used to further label certain groups from miniature to giant. This practice was abandoned in 2012.


title: Dahlia

text: which are officially registered through the Royal Horticultural Society (RHS). The official register is "The International Register of Dahlia Names 1969" (1995 reprint) which is updated by annual supplements. The original 1969 registry published about 14,000 cultivars adding a further 1700 by 1986 and in 2003 there were 18,000. Since then about a hundred new cultivars are added annually.


title: Dahlia

text: The official RHS classification lists fourteen groups, grouped by flower type, together with the abbreviations used by the RHS;


title: Dahlia

text: Earlier versions of the registry subdivided some groups by flower size. Groups 4, 5, 8 and 9 were divided into five subgroups (A to E) from Giant to Miniature, and Group 6 into two subgroups, Small and Miniature. Dahlias were then described by Group and Subgroup, "e.g." 5(d) ‘Ace Summer Sunset’. Some Dahlia Societies have continued this practice, but this is neither official nor standardised. As of 2013 The RHS uses two size descriptors


title: Dahlia

text: Sizes can range from tiny micro dahlias with flowers less than 50mm to giants that are over 250mm in diameter. The groupings listed here are from the New Zealand Society:


title: Dahlia

text: In addition to the official classification and the terminology used by various dahlia societies, individual horticulturalists use a wide range of other descriptions, such as 'Incurved' and abbreviations in their catalogues, such as CO for Collarette.


title: Dahlia

text: Some plant growers include their brand name in the cultivar name. Thus Fides (part of the Dümmen Orange Group) in the Netherlands developed a series of cultivars which they named the Dahlinova series, for example Dahlinova 'Carolina Burgundy'. These are Group 10 Miscellaneous in the RHS classification scheme.


title: Dahlia

text: In 1805, several new species were reported with red, purple, lilac, and pale yellow coloring, and the first true double flower was produced in Belgium. One of the more popular concepts of dahlia history, and the basis for many different interpretations and confusion, is that all the original discoveries were single-flowered types, which, through hybridization and selective breeding, produced double forms. Many of the species of dahlias then, and now, have single-flowered blooms. "D. coccinea", the third dahlia to bloom in Europe, was a single. But two of the three drawings of dahlias by Dominguez, made in Mexico between 1570 and 1577, showed definite characteristics of doubling. In the early days of the dahlia in Europe, the word "double" simply designated flowers with more than one row of petals. The greatest effort was now directed to developing improved types of double dahlias.


title: Dahlia

text: During the years 1805 to 1810 several people claimed to have produced a double dahlia. In 1805 Henry C. Andrews made a drawing of such a plant in the collection of Lady Holland, grown from seedlings sent that year from Madrid. Like other doubles of the time it did not resemble the doubles of today. The first modern double, or full double, appeared in Belgium; M. Donckelaar, Director of the Botanic Garden at Louvain, selected plants for that characteristic, and within a few years secured three fully double forms. By 1826 double varieties were being grown almost exclusively, and there was very little interest in the single forms. Up to this time all the so-called double dahlias had been purple, or tinged with purple, and it was doubted if a variety untinged with that color was obtainable.


title: Dahlia

text: In 1843, scented single forms of dahlias were first reported in Neu Verbass, Austria. "D. crocea", a fragrant variety grown from one of the Humboldt seeds, was probably interbred with the single "D. coccinea". A new scented species would not be introduced until the next century when the "D. coronata" was brought from Mexico to Germany in 1907.


title: Dahlia

text: The exact date the dahlia was introduced in the United States is uncertain. One of the first dahlias in the USA may have been the "D. coccinea speciosissima" grown by William Leathe, of Cambridgeport, near Boston, around 1929. According to Edward Sayers, "it attracted much admiration, and at that time was considered a very elegant flower, it was however soon eclipsed by that splendid scarlet, the Countess of Liverpool". However, 9 cultivars were already listed in the catalog from Thornburn, 1825. And even earlier reference can be found in a catalogue from the Linnaean Botanical Garden, New York, 1820, that includes one scarlet, one purple, and two double orange Dahlias for sale.


title: Dahlia

text: the Dahlia than George C. Thorburn, of New York, who yearly flowers many thousand plants at his place at Hallet's Cove, near Harlaem. The show there in the flowering season is a rich treat for the lovers of floriculture : for almost every variety can be seen growing in two large blocks or masses which lead from the road to the dwelling-house, and form a complete field of the Dahlia as a foreground to the house. Mr. T. Hogg, William Read, and many other well-known florists have also contributed much in the vicinity of New York, to the introduction of the Dahlia. Indeed so general has become the taste that almost every garden has its show of the Dahlia in the season." In Boston too there were many collections, a collection from the Messrs Hovey of Cambridgeport was also mentioned.


title: Dahlia

text: In 1835 Thomas Bridgeman, published a list of 160 double dahlias in his "Florist's Guide". 60 of the choicest were supplied by Mr. G. C. Thornburn of Astoria, New York, who got most of them from contacts in the UK. Not a few of them had taken prizes "at the English and American exhibitions".


title: Dahlia

text: In 1872 J. T. van der Berg of Utrecht in the Netherlands received a shipment of seeds and plants from a friend in Mexico. The entire shipment was badly rotted and appeared to be ruined, but van der Berg examined it carefully and found a small piece of root that seemed alive. He planted and carefully tended it; it grew into a plant that he identified as a dahlia. He made cuttings from the plant during the winter of 1872–1873. This was an entirely different type of flower, with rich, red color and a high degree of doubling. In 1874 van der Berg catalogued it for sale, calling it "Dahlia juarezii" to honor Mexican President Benito Pablo Juarez, who had died the year before, and described it as "...equal to the beautiful color of the red poppy. Its form is very outstanding and different in every respect of all known dahlia flowers."


title: Dahlia

text: This plant has perhaps had a greater influence on the popularity of the modern dahlia than any other. Called "Les Etoiles du Diable" (Stars of the Devil) in France and "Cactus dahlia" elsewhere, the edges of its petals rolled backwards, rather than forward, and this new form revolutionized the dahlia world. It was thought to be a distinct mutation since no other plant that resembled it could be found in the wild. Today it is assumed that "D. juarezii" had, at one time, existed in Mexico and subsequently disappeared. Nurserymen in Europe crossbred this plant with dahlias discovered earlier; the results became the progenitors of all modern dahlia hybrids today.


title: Dahlia

text: As of 2015, 124 dahlia cultivars have gained the Royal Horticultural Society's Award of Garden Merit, including:-


title: Dahlia

text: The asterid eudicots contain two economically important geophyte genera, "Dahlia" and "Liatris". Horticulturally the garden dahlia is usually treated as the cultigen "D. variabilis" hort., which while being responsible for thousands of cultivars has an obscure taxonomic status (see also Cultivation).


title: Dahlia

text: Today the dahlia is still considered one of the native ingredients in Oaxacan cuisine; several cultivars are still grown especially for their large, sweet potato-like tubers. Dacopa, an intense mocha-tasting extract from the roasted tubers, is used to flavor beverages throughout Central America.


title: Dahlia

text: In Europe and America, prior to the discovery of insulin in 1923, diabetics—as well as consumptives—were often given a substance called "Atlantic starch" or "diabetic sugar", derived from inulin, a naturally occurring form of fruit sugar, extracted from dahlia tubers. Inulin is still used in clinical tests for kidney functionality.


title: Dahlia

text: The Bloemencorso Zundert is the largest flower parade in the world entirely made by volunteers using the dahlia. The parade takes place on the first Sunday of September in Zundert, Netherlands. The floats are large artworks made of steel wire, cardboard, papier-mâché and flowers. In the Bloemencorso Zundert, mostly dahlias are used to decorate the objects and it takes thousands of them just to cover one float. Around 8 million dahlias are needed for the entire corso. Of these, around 6 million are cultivated in Zundert. It was founded in 1936.


title: Dahlia

text: The flower species "Dahlia" is also a name used for children, especially daughters. The Swedish word "dal" means val, so Dahlia is sometimes referred to as "valley flower". The Dahlia symbolizes eternal bonds of commitment, so it is a popular flower of choice for weddings. Dahlia was first listed on the American female naming charts in 2006. The name's popularity has skyrocketed since around 2005. Since 2016, the number of babies named Dahlia per year has stayed at 839. It has reached the top 10 female baby names only once, but is still popular, especially in Montana, Alaska, Maine, and Rhode Island.


title: Miguel McKelvey

text: Miguel McKelvey (born 1974) is an American businessman, and the co-founder and former chief culture officer of WeWork.


title: Miguel McKelvey

text: McKelvey grew up in a "five-mother collective" in Eugene, Oregon. His family started and ran a weekly newspaper called the "Eugene Weekly."


title: Miguel McKelvey

text: In a January 2020 interview with Fortune, McKelvey called himself "a wild kid" on the high school basketball court. He said that he found a sense of accountability from his coach, who was a strict disciplinarian. He said of Coach Stepp, "I didn’t grow up with my father, so I never had someone telling me to keep in line."


title: Miguel McKelvey

text: He graduated from South Eugene High School in 1992. He first attended Colorado College and, after seeing a sculpture he created, his professor, Carl Reed, recommended he consider architecture for graduate school.  He transferred to the University of Oregon where he earned a Bachelor of Architecture degree in 1999.


title: Miguel McKelvey

text: McKelvey played on the Oregon Ducks basketball team for two years. However, the official record book indicates he lettered for only one year, 1997.


title: Miguel McKelvey

text: Before graduating from college, McKelvey worked as a busboy in a restaurant, and spent two summers at an Alaskan fish processing plant.


title: Miguel McKelvey

text: After graduating from college, McKelvey went to Tokyo to visit a friend, and while there, he co-founded English, baby!, a web portal and social network for students to create and take foreign-language online courses. The website offers vocabulary quizzes, grammar lessons, and a social network that connects English-language learners with English-fluent peers. The business grew to 25 employees.


title: Miguel McKelvey

text: McKelvey next moved to New York City, where he worked at Jordan Parnass Digital Architecture. The firm was responsible for all the American Apparel projects, and McKelvey became the manager of the international retail roll out.


title: Miguel McKelvey

text: Adam Neumann worked in the same office building, and the two met at a party.  In 2008, the two convinced their landlord to let them divide the floors of an empty building into semi-communal offices and rent them out; this was the start of Green Desk. McKelvey designed the name, logo, and a working website for the new business in one night. Green Desk was an eco-friendly coworking space, with a focus on recycled furniture and wind-power electricity. McKelvey and Neumann eventually sold the business to their landlord, Joshua Guttman, and evolved the concept into WeWork.


title: Miguel McKelvey

text: WeWork was founded in 2010, with its first office space in the Manhattan neighborhood of SoHo. McKelvey served as WeWork's chief culture officer. He directed construction, architecture, and web design for the company, and was also responsible for building and operating culture. Since 2010, The We Company has launched several new ventures: WeLive, a co-living venture; Rise by We, a luxury gym concept; and WeGrow, a private elementary school. In 2019, the company introduced The We Company, a parent brand that comprises WeWork, WeLive, WeGrow, and other ventures.


title: Miguel McKelvey

text: In 2017, McKelvey was named WeWork’s chief culture officer and in 2019, Fast Company named McKelvey one of its "Most Creative People."


title: Miguel McKelvey

text: McKelvey was married to Hiyam Khalifa, a former investment banker born in Detroit, before their divorce in 2017.


title: Aaron Ashmore

text: Aaron Richard Ashmore (born October 7, 1979) is a Canadian actor. He is known for his roles on American television series such as Jimmy Olsen on "Smallville", Steve Jinks on "Warehouse 13" and Johnny Jaqobis on the Canadian television series "Killjoys". He is the identical twin brother of actor Shawn Ashmore.


title: Aaron Ashmore

text: Aaron Ashmore is known for playing Marc Hall in "". Since then, he has appeared in the films "Safe", "A Separate Peace", and "A Bear Named Winnie". He has also had guest roles on television shows such as "The Eleventh Hour", "The West Wing", and "1-800-Missing". Ashmore played the recurring role of Troy Vandegraff on the UPN television series "Veronica Mars", as well as the role of Agent Steve Jinks on the Syfy show "Warehouse 13".


title: Aaron Ashmore

text: He was cast as Jimmy Olsen for the sixth season of "Smallville" on the WB television network and continued to play him into its eighth season. Two years after leaving the show, Ashmore returned to play his character's younger brother on the series finale. Ashmore's twin brother Shawn appeared on "Smallville" in earlier seasons, and he was offered the role of Jimmy Olsen by director Bryan Singer in "Superman Returns" before Sam Huntington was cast.


title: Aaron Ashmore

text: Besides his recurring role on "Smallville", Ashmore had roles in the 2007 films "Palo Alto", "Privileged", "The Stone Angel" and "The Christmas Cottage". He starred in the horror film "Fear Island". MTV.ca announced on October 6, 2010, that he would have a role in the Maple Pictures comedy film "Servitude".


title: Aaron Ashmore

text: In 2010, Ashmore starred as Marcus, one of three journalists who investigate a cult said to practice human sacrifice in a small town in Poland, in the horror film "The Shrine". He also starred as Eric in the romantic comedy "Conception". In 2011, Ashmore joined season three of the Syfy series "Warehouse 13", in which he played the role of ATF agent Steve Jinks, a human polygraph of sorts, who has the unique ability to discern whether someone is lying or not.


title: Aaron Ashmore

text: Ashmore next starred in the 2014 rom-com thriller "I Put a Hit on You" as Ray, a man whose girlfriend tries to have him assassinated after he rejects her marriage proposal. In 2015, Ashmore played a supporting role in the thriller film "Regression"; starred as Nick Hopewell in the Lifetime original film "Swept Under"; began his role as John Jaqobis, an interplanetary bounty hunter, in the Syfy original series "Killjoys;" and starred as Jesse in his second Lifetime film, "Wish Upon a Christmas". "Killjoys" ended after its fifth season in 2019.


title: Aaron Ashmore

text: Aaron and his identical twin brother Shawn (also an actor) were born in Richmond, British Columbia, the sons of Linda, a homemaker, and Rick Ashmore, a manufacturing engineer. They were raised in Brampton, Ontario, where he attended Turner Fenton Secondary School and Earnscliffe Senior Public School. They have a "GMA" tattoo on their wrists that stands for "Good Man Ashmore"; their grandfather had a similar tattoo. On June 20, 2014, Aaron married Zoë Kate. In 2016, the couple's first child was born, a daughter. Their second daughter was born in 2019.


title: Mikoyan

text: Russian Aircraft Corporation "MiG" (), commonly known as Mikoyan and MiG, was a Russian aerospace and defence company headquartered in Begovoy District, Moscow.


title: Mikoyan

text: Mikoyan was successor to the Soviet Mikoyan and Gurevich Design Bureau (Микоя́н и Гуре́вич, МиГ; OKB-155 design office prefix "MiG") founded in 1939 by aircraft designers Artem Mikoyan and Mikhail Gurevich. Mikoyan were notable for their fighter and interceptor aircraft which became a staple of the Soviet Air Force and Russian Air Forces, nations within the Soviet sphere of influence, and other nations such as India and many Arab states. Mikoyan aircraft were frequently used in aerial confrontations with American and allied forces during and since the Cold War, and have become commonly featured aircraft in popular culture. Mikoyan aircraft were the most produced jet fighter family.


title: Mikoyan

text: In 2006, Mikoyan became a division of the United Aircraft Corporation in a merger with Ilyushin, Irkut, Sukhoi, Tupolev, and Yakovlev by decree of the Russian President Vladimir Putin.


title: Mikoyan

text: Mikoyan was established on 8 December 1939 as the Pilot Design Department of the Aviation Plant #1 and headed by Artem Mikoyan and Mikhail Gurevich. It was later renamed "Experimental Design Bureau named after A.I. Mikoyan" otherwise known as the Mikoyan Design Bureau or Mikoyan OKB. In 1964 Gurevich retired, and Mikoyan died in 1970. He was succeeded by Rostislav A. Belyakov, and in 1978 the enterprise was named after Mikoyan.


title: Mikoyan

text: In 1995, Mikoyan OKB was merged with two production facilities to form the Moscow Aviation Production Association "MiG" (MAPO-MiG). In the 1990s MiG began developing Mikoyan Project 1.44, a fifth-generation jet fighter, but the project was hampered by a lack of funding and was eventually canceled.


title: Mikoyan

text: In December 1999, Nikolai Nikitin was appointed the corporation's General Director and General Designer. Nikitin focused most of the company's resources on the development of the Tu-334 passenger aircraft at the expense of military programs. This prompted the resignation in December 1999 of many of its leading military aircraft designers, including the chief designers and their deputies for the MiG-29 and MiG-31 programs.


title: Mikoyan

text: Nikitin was replaced by Valery Toryanin in November 2003, who was in turn replaced by Alexey Fedorov in September 2004. In 2006, the Russian government merged 100% of Mikoyan shares with Ilyushin, Irkut, Sukhoi, Tupolev, and Yakovlev as a new company named United Aircraft Corporation. Specifically, Mikoyan and Sukhoi were placed within the same operating unit.


title: Mikoyan

text: MiG failed to win any major aircraft tender in the post-Soviet era, falling behind its Russian rival Sukhoi. According to press reports, the company was shedding hundreds of employees in late 2017 due to a shortage of orders.


title: Mikoyan

text: As of 2015 the company's business offering consists mostly of modernized MiG-29 aircraft. MiG was developing a 4++ fighter, the MiG-35, with the first deliveries expected in late 2019.


title: Rain

text: Rain is water droplets that have condensed from atmospheric water vapor and then fall under gravity. Rain is a major component of the water cycle and is responsible for depositing most of the fresh water on the Earth. It provides water for hydroelectric power plants, crop irrigation, and suitable conditions for many types of ecosystems.


title: Rain

text: The major cause of rain production is moisture moving along three-dimensional zones of temperature and moisture contrasts known as weather fronts. If enough moisture and upward motion is present, precipitation falls from convective clouds (those with strong upward vertical motion) such as cumulonimbus (thunder clouds) which can organize into narrow rainbands. In mountainous areas, heavy precipitation is possible where upslope flow is maximized within windward sides of the terrain at elevation which forces moist air to condense and fall out as rainfall along the sides of mountains. On the leeward side of mountains, desert climates can exist due to the dry air caused by downslope flow which causes heating and drying of the air mass. The movement of the monsoon trough, or intertropical convergence zone, brings rainy seasons to savannah climes.


title: Rain

text: The urban heat island effect leads to increased rainfall, both in amounts and intensity, downwind of cities. Global warming is also causing changes in the precipitation pattern globally, including wetter conditions across eastern North America and drier conditions in the tropics. Antarctica is the driest continent. The globally averaged annual precipitation over land is , but over the whole Earth it is much higher at . Climate classification systems such as the Köppen classification system use average annual rainfall to help differentiate between differing climate regimes. Rainfall is measured using rain gauges. Rainfall amounts can be estimated by weather radar.


title: Rain

text: Rain is also known or suspected on other planets, where it may be composed of methane, neon, sulfuric acid, or even iron rather than water.


title: Rain

text: Air contains water vapor, and the amount of water in a given mass of dry air, known as the "mixing ratio", is measured in grams of water per kilogram of dry air (g/kg). The amount of moisture in air is also commonly reported as relative humidity; which is the percentage of the total water vapor air can hold at a particular air temperature. How much water vapor a parcel of air can contain before it becomes saturated (100% relative humidity) and forms into a cloud (a group of visible and tiny water and ice particles suspended above the Earth's surface) depends on its temperature. Warmer air can contain more water vapor than cooler air before becoming saturated. Therefore, one way to saturate a parcel of air is to cool it. The dew point is the temperature to which a parcel must be cooled in order to become saturated.


title: Rain

text: There are four main mechanisms for cooling the air to its dew point: adiabatic cooling, conductive cooling, radiational cooling, and evaporative cooling. Adiabatic cooling occurs when air rises and expands. The air can rise due to convection, large-scale atmospheric motions, or a physical barrier such as a mountain (orographic lift). Conductive cooling occurs when the air comes into contact with a colder surface, usually by being blown from one surface to another, for example from a liquid water surface to colder land. Radiational cooling occurs due to the emission of infrared radiation, either by the air or by the surface underneath. Evaporative cooling occurs when moisture is added to the air through evaporation, which forces the air temperature to cool to its wet-bulb temperature, or until it reaches saturation.


title: Rain

text: The main ways water vapor is added to the air are: wind convergence into areas of upward motion, precipitation or virga falling from above, daytime heating evaporating water from the surface of oceans, water bodies or wet land, transpiration from plants, cool or dry air moving over warmer water, and lifting air over mountains. Water vapor normally begins to condense on condensation nuclei such as dust, ice, and salt in order to form clouds. Elevated portions of weather fronts (which are three-dimensional in nature) force broad areas of upward motion within the Earth's atmosphere which form clouds decks such as altostratus or cirrostratus. Stratus is a stable cloud deck which tends to form when a cool, stable air mass is trapped underneath a warm air mass. It can also form due to the lifting of advection fog during breezy conditions.


title: Rain

text: Coalescence occurs when water droplets fuse to create larger water droplets. Air resistance typically causes the water droplets in a cloud to remain stationary. When air turbulence occurs, water droplets collide, producing larger droplets.


title: Rain

text: As these larger water droplets descend, coalescence continues, so that drops become heavy enough to overcome air resistance and fall as rain. Coalescence generally happens most often in clouds above freezing, and is also known as the warm rain process. In clouds below freezing, when ice crystals gain enough mass they begin to fall. This generally requires more mass than coalescence when occurring between the crystal and neighboring water droplets. This process is temperature dependent, as supercooled water droplets only exist in a cloud that is below freezing. In addition, because of the great temperature difference between cloud and ground level, these ice crystals may melt as they fall and become rain.


title: Rain

text: Raindrops have sizes ranging from mean diameter but develop a tendency to break up at larger sizes. Smaller drops are called cloud droplets, and their shape is spherical. As a raindrop increases in size, its shape becomes more oblate, with its largest cross-section facing the oncoming airflow. Large rain drops become increasingly flattened on the bottom, like hamburger buns; very large ones are shaped like parachutes. Contrary to popular belief, their shape does not resemble a teardrop. The biggest raindrops on Earth were recorded over Brazil and the Marshall Islands in 2004 — some of them were as large as . The large size is explained by condensation on large smoke particles or by collisions between drops in small regions with particularly high content of liquid water.


title: Rain

text: Intensity and duration of rainfall are usually inversely related, i.e., high intensity storms are likely to be of short duration and low intensity storms can have a long duration.


title: Rain

text: The final droplet size distribution is an exponential distribution. The number of droplets with diameter between formula_1 and formula_2 per unit volume of space is formula_3. This is commonly referred to as the Marshall–Palmer law after the researchers who first characterized it. The parameters are somewhat temperature-dependent, and the slope also scales with the rate of rainfall formula_4 (d in centimeters and R in millimeters per hour).


title: Rain

text: Deviations can occur for small droplets and during different rainfall conditions. The distribution tends to fit averaged rainfall, while instantaneous size spectra often deviate and have been modeled as gamma distributions. The distribution has an upper limit due to droplet fragmentation.


title: Rain

text: Raindrops impact at their terminal velocity, which is greater for larger drops due to their larger mass to drag ratio. At sea level and without wind, drizzle impacts at or , while large drops impact at around or .


title: Rain

text: Rain falling on loosely packed material such as newly fallen ash can produce dimples that can be fossilized, called raindrop impressions. The air density dependence of the maximum raindrop diameter together with fossil raindrop imprints has been used to constrain the density of the air 2.7 billion years ago.


title: Rain

text: In certain conditions precipitation may fall from a cloud but then evaporate or sublime before reaching the ground. This is termed virga and is more often seen in hot and dry climates.


title: Rain

text: Stratiform (a broad shield of precipitation with a relatively similar intensity) and dynamic precipitation (convective precipitation which is showery in nature with large changes in intensity over short distances) occur as a consequence of slow ascent of air in synoptic systems (on the order of cm/s), such as in the vicinity of cold fronts and near and poleward of surface warm fronts. Similar ascent is seen around tropical cyclones outside the eyewall, and in comma-head precipitation patterns around mid-latitude cyclones. A wide variety of weather can be found along an occluded front, with thunderstorms possible, but usually their passage is associated with a drying of the air mass. Occluded fronts usually form around mature low-pressure areas. What separates rainfall from other precipitation types, such as ice pellets and snow, is the presence of a thick layer of air aloft which is above the melting point of water, which melts the frozen precipitation well before it reaches the ground. If there is a shallow near surface layer that is below freezing, freezing rain (rain which freezes on contact with surfaces in subfreezing environments) will result. Hail becomes an increasingly infrequent occurrence when the freezing level within the atmosphere exceeds above ground level.


title: Rain

text: Convective rain, or showery precipitation, occurs from convective clouds (e.g., cumulonimbus or cumulus congestus). It falls as showers with rapidly changing intensity. Convective precipitation falls over a certain area for a relatively short time, as convective clouds have limited horizontal extent. Most precipitation in the tropics appears to be convective; however, it has been suggested that stratiform precipitation also occurs. Graupel and hail indicate convection. In mid-latitudes, convective precipitation is intermittent and often associated with baroclinic boundaries such as cold fronts, squall lines, and warm fronts.


title: Rain

text: Orographic precipitation occurs on the windward side of mountains and is caused by the rising air motion of a large-scale flow of moist air across the mountain ridge, resulting in adiabatic cooling and condensation. In mountainous parts of the world subjected to relatively consistent winds (for example, the trade winds), a more moist climate usually prevails on the windward side of a mountain than on the leeward or downwind side. Moisture is removed by orographic lift, leaving drier air (see katabatic wind) on the descending and generally warming, leeward side where a rain shadow is observed.


title: Rain

text: In Hawaii, Mount Waiʻaleʻale, on the island of Kauai, is notable for its extreme rainfall, as it is amongst the places in the world with the highest levels of rainfall, with . Systems known as Kona storms affect the state with heavy rains between October and April. Local climates vary considerably on each island due to their topography, divisible into windward ("Koolau") and leeward ("Kona") regions based upon location relative to the higher mountains. Windward sides face the east to northeast trade winds and receive much more rainfall; leeward sides are drier and sunnier, with less rain and less cloud cover.


title: Rain

text: In South America, the Andes mountain range blocks Pacific moisture that arrives in that continent, resulting in a desertlike climate just downwind across western Argentina. The Sierra Nevada range creates the same effect in North America forming the Great Basin and Mojave Deserts.


title: Rain

text: The wet, or rainy, season is the time of year, covering one or more months, when most of the average annual rainfall in a region falls. The term "green season" is also sometimes used as a euphemism by tourist authorities. Areas with wet seasons are dispersed across portions of the tropics and subtropics. Savanna climates and areas with monsoon regimes have wet summers and dry winters. Tropical rainforests technically do not have dry or wet seasons, since their rainfall is equally distributed through the year. Some areas with pronounced rainy seasons will see a break in rainfall mid-season when the intertropical convergence zone or monsoon trough move poleward of their location during the middle of the warm season. When the wet season occurs during the warm season, or summer, rain falls mainly during the late afternoon and early evening hours. The wet season is a time when air quality improves, freshwater quality improves, and vegetation grows significantly.


title: Rain

text: Tropical cyclones, a source of very heavy rainfall, consist of large air masses several hundred miles across with low pressure at the centre and with winds blowing inward towards the centre in either a clockwise direction (southern hemisphere) or counter clockwise (northern hemisphere). Although cyclones can take an enormous toll in lives and personal property, they may be important factors in the precipitation regimes of places they impact, as they may bring much-needed precipitation to otherwise dry regions. Areas in their path can receive a year's worth of rainfall from a tropical cyclone passage.


title: Rain

text: The fine particulate matter produced by car exhaust and other human sources of pollution forms cloud condensation nuclei, leads to the production of clouds and increases the likelihood of rain. As commuters and commercial traffic cause pollution to build up over the course of the week, the likelihood of rain increases: it peaks by Saturday, after five days of weekday pollution has been built up. In heavily populated areas that are near the coast, such as the United States' Eastern Seaboard, the effect can be dramatic: there is a 22% higher chance of rain on Saturdays than on Mondays. The urban heat island effect warms cities 0.6 to 5.6 °C (1.1 to 10.1 °F) above surrounding suburbs and rural areas. This extra heat leads to greater upward motion, which can induce additional shower and thunderstorm activity. Rainfall rates downwind of cities are increased between 48% and 116%. Partly as a result of this warming, monthly rainfall is about 28% greater between downwind of cities, compared with upwind. Some cities induce a total precipitation increase of 51%.


title: Rain

text: Increasing temperatures tend to increase evaporation which can lead to more precipitation. Precipitation generally increased over land north of 30°N from 1900 through 2005 but has declined over the tropics since the 1970s. Globally there has been no statistically significant overall trend in precipitation over the past century, although trends have varied widely by region and over time. Eastern portions of North and South America, northern Europe, and northern and central Asia have become wetter. The Sahel, the Mediterranean, southern Africa and parts of southern Asia have become drier. There has been an increase in the number of heavy precipitation events over many areas during the past century, as well as an increase since the 1970s in the prevalence of droughts—especially in the tropics and subtropics. Changes in precipitation and evaporation over the oceans are suggested by the decreased salinity of mid- and high-latitude waters (implying more precipitation), along with increased salinity in lower latitudes (implying less precipitation and/or more evaporation). Over the contiguous United States, total annual precipitation increased at an average rate of 6.1 percent since 1900, with the greatest increases within the East North Central climate region (11.6 percent per century) and the South (11.1 percent). Hawaii was the only region to show a decrease (−9.25 percent).


title: Rain

text: Analysis of 65 years of United States of America rainfall records show the lower 48 states have an increase in heavy downpours since 1950. The largest increases are in the Northeast and Midwest, which in the past decade, have seen 31 and 16 percent more heavy downpours compared to the 1950s. Rhode Island is the state with the largest increase, 104%. McAllen, Texas is the city with the largest increase, 700%. Heavy downpour in the analysis are the days where total precipitation exceeded the top one percent of all rain and snow days during the years 1950–2014.


title: Rain

text: The most successful attempts at influencing weather involve cloud seeding, which include techniques used to increase winter precipitation over mountains and suppress hail.


title: Rain

text: Rainbands are cloud and precipitation areas which are significantly elongated. Rainbands can be stratiform or convective, and are generated by differences in temperature. When noted on weather radar imagery, this precipitation elongation is referred to as banded structure. Rainbands in advance of warm occluded fronts and warm fronts are associated with weak upward motion, and tend to be wide and stratiform in nature.


title: Rain

text: Rainbands spawned near and ahead of cold fronts can be squall lines which are able to produce tornadoes. Rainbands associated with cold fronts can be warped by mountain barriers perpendicular to the front's orientation due to the formation of a low-level barrier jet. Bands of thunderstorms can form with sea breeze and land breeze boundaries, if enough moisture is present. If sea breeze rainbands become active enough just ahead of a cold front, they can mask the location of the cold front itself.


title: Rain

text: Once a cyclone occludes an occluded front (a trough of warm air aloft) will be caused by strong southerly winds on its eastern periphery rotating aloft around its northeast, and ultimately northwestern, periphery (also termed the warm conveyor belt), forcing a surface trough to continue into the cold sector on a similar curve to the occluded front. The front creates the portion of an occluded cyclone known as its "comma head", due to the comma-like shape of the mid-tropospheric cloudiness that accompanies the feature. It can also be the focus of locally heavy precipitation, with thunderstorms possible if the atmosphere along the front is unstable enough for convection. Banding within the comma head precipitation pattern of an extratropical cyclone can yield significant amounts of rain. Behind extratropical cyclones during fall and winter, rainbands can form downwind of relative warm bodies of water such as the Great Lakes. Downwind of islands, bands of showers and thunderstorms can develop due to low level wind convergence downwind of the island edges. Offshore California, this has been noted in the wake of cold fronts.


title: Rain

text: Rainbands within tropical cyclones are curved in orientation. Tropical cyclone rainbands contain showers and thunderstorms that, together with the eyewall and the eye, constitute a hurricane or tropical storm. The extent of rainbands around a tropical cyclone can help determine the cyclone's intensity.