Anonymity on the Internet Must be Protected

Karina Rigby

Paper for MIT 6.805/STS085: Ethics and Law on the Electronic Frontier, Fall 1995

1. Introduction

1. The quality of state of being unknown or unacknowledged.
2. One that is unknown or unacknowledged.[26]
The internet community is quickly changing and evolving as more of the world comes on-line. Free speech and anonymity have always been important real-world societal issues and have been the topics of numerous heated court cases. These issues are becoming increasingly important as more people discover the digital world and find the need for anonymity in this new society. Over the last few years, an intense battle has been raging between the citizens of the net over the issue of whether on-line anonymity should be eliminated. One side feels that people should have enough conviction in their beliefs to state them without hiding behind anonymity. The other side feels that anonymity is vital for the protection of freedom of expression. Whichever side one agrees with, it is obvious that the technology for anonymity on the internet is readily available and that a definite vacuum is being filled by anonymity services.

This paper will examine the issue of anonymity on the internet, first providing a background on how anonymity services work and why these services came into existence. In this discussion, I will limit the scope of my subject to the services provided by anonymous and pseudonymous remailers and posting sites which are currently used by thousands of people each day to send email and post to internet newsgroups. Although the issues of digital cash and cryptography have close ties to anonymity, these subjects will not be discussed here. After a background on anonymity has been provided, I will go on to present arguments for and against anonymity on the internet and discuss a number of famous conflicts involving anonymity on the internet. I will then present some specific barriers to on-line anonymity, including attacks by net citizens, concerns of system administrators, and legal issues. Finally, based on this discussion, I will show that anonymity on the internet provides a vital service and enhances freedom of expression and that most negative affects of anonymity can be minimized by following a few guidelines related to how anonymous services are provided and used.

2. Background

2.1 How on-line anonymity works

Although internet users can send messages by borrowing other user's accounts or by forging identities, one of the most common and least complicated ways of obtaining anonymity on the internet is by making use of one of many anonymity services. Some of these services are connected directly to specific newsgroups on the usenet. Other anonymity providers are global and service the entire internet. These anonymity servers make use of what are called "remailers", which are basically computers on the internet that forward electronic mail or files to other network addresses. Before the remailer forwards the information, it strips the header from the original email so that the information showing where the message originated is no longer attached to the email. Many anonymity services replace the header with anonymous addresses such as nobody@nowhere. The eventual recipient of the message then has no idea about who sent the email and where it originated. This type of service is termed truly anonymous. Other anonymity services use similar remailers, but also give each user an anonymous ID, almost like a mailbox on the server, which stores the address of the sender so that any replies to anonymous email can be forwarded to the original sender. This type of anonymity, called pseudonymity, allows users to be anonymous but reachable.

2.2 History

Anonymous posting/reply services on the internet were started around 1988 and were introduced primarily for use on specific newsgroups which discussed particularly volatile, sensitive and personal subjects. One of the first of these services was started by Dave Mack for use on Anonymous postings on newsgroups such as this one soon became the primary method of communication. Anonymity services which utilized remailers originated with the Cypherpunk group in mid-1992. Global anonymity servers which served the entire internet soon sprang up, combining the functions of anonymous posting as well as anonymous remailing in one service. The new global services also introduced the concept of pseudonymous emails which allowed replies to anonymous mail.[19] These and other global servers which were started in the US died quickly as a result of numerous barriers such as attacks by net citizens and system administrators. These issues are discussed in section 6. The average life span of most anonymity servers is about 6 months because of these barriers and there are usually only 20 to 30 of these servers operating around the world at any one time.[26] Some of the most used of these global servers include the Kleinpaste, Clunie and Helsingius servers.[19] Even these servers were temporarily and/or permanently shut down due to the intense conflict surrounding their use. Foreign anonymity servers often fare better due to a more relaxed attitude of foreign system administrators.

The Helsingius server, which is called and run by Johan "Julf" Helsingius, is one of the most stable global anonymity servers. Julf Helsingius' original impetus to provide a global anonymity service was his desire to prove that censorship on the internet is impossible because there is always a technological solution which can circumvent the problem.[3] The site is based on scripts and C code which was written by K. Kleinpaste and was originally intended to serve only Scandinavia. Helsingius eventually expanded to worldwide service due to a flood of international requests. This server, which is one of the most popular, currently has over 200,000 registered users.[20] Although has undergone numerous temporary shutdowns and has been involved in a recent police investigation (discussed in section 6), it has survived for over 3 years. and similar servers are currently the primary anonymity servers on the internet today. According to Raph Levien, graduate student at the University of California, Berkeley who tracks the anonymity providers, up to 15,000 email messages a day are sent through anonymous remailing services.[16] A list of some of the current anonymity services can be found at the University of California at Berkeley.[22]

3. Arguments for anonymity

The society in which we live can frequently be extremely conservative, often making it dangerous to make certain statements, have certain opinions, or adopt a certain lifestyle. Anonymity is important for on line discussions involving sexual abuse, minority issues, harassment, sex lives, and many other things. Additionally, anonymity is useful for people who want to ask technical questions that they don't want to admit they don't know the answer to, report illegal activities without fear of retribution, and many other things. For example, the state of Florida maintains an anonymous hotline for government workers to report wastes and abuses to the comptroller's office.[12] Without anonymity, these actions can result in public ridicule or censure, physical injury, loss of employment or status, and in some cases, even legal action. Protection from harm resulting from this type of social intolerance is a definite example of an important and legitimate use of anonymity on the internet. An example of how vital such anonymity can be is exemplified by the following excerpt from a newsgroup post during a temporary shutdown of
"I had been posting to a nontechnical misc newsgroup about an intimate topic for which I felt I required privacy. I have received immeasurable help from the people in that news group....Please, folks, believe me, I *need* this service. Please consider my point of view and permit to turn the service back on."[18]
Doctors who are members of the on-line community often encourage their patients to connect with others and form support groups on issues about which they do not feel comfortable speaking about publicly.[18] It is essential to be able to express certain opinions without revealing your true identity. One relevant example of anonymity in the real world is the debate over Caller ID on telephones.[4] A great deal of people were extremely disturbed that the person on the receiving end of a telephone call would know the identity of the caller. People had taken for granted that they could be anonymous if they wanted and were distressed at the idea of that anonymity being taken away. Many net users feel the same way about on-line anonymity.

Anonymity is extremely effective in promoting freedom of expression. Julf Helsingius asserts that anonymity is beneficial because it gives people an outlet for their opinions, even controversial ones. He feels that it is "good to bring out things like that in daylight because that actually allows you to ...start processing it, see how people react to it, and so on."[3] This may have sort of a cathartic effect in that it allows people to get their feelings out without physically hurting people of other cultures, races, etc. Additionally, anonymity hinders some methods of controlling the actions of other people. This is an additional argument in the usefulness of anonymity in the protection of freedom of expression.

There are many long-standing precedents for anonymity in publishing. The responsibility of a journalists not to reveal their sources is recognized almost universally. Many authors write under pen-names and there are still some cases where the true identity of the author has never been discovered. Even the Federalist Papers were published under a pseudonym.[12] Most newspapers publish letters to the editor and help columns and allow the letters to be anonymous or signed with a pseudonym and many newspaper articles are merely credited to "AP Newswire". Additionally, anonymous peer reviews of proposals and articles is common in academic circles.

An additional argument for anonymity is that it is a part of society and unavoidable. Anonymous communication can be achieved in real life by sending an unsigned letter or making an anonymous phone call. From the large number of users who take advantage of anonymous services on the internet, it can be seen that these services are truly necessary and fill a specific need. The availability of the technology to set up such an anonymous server also makes the elimination of such servers virtually impossible; as soon as one is shut down, another one is created.[19] The current availability of such services eliminates the need to forge an identity or use another person's identity to correspond anonymously. People on the net are anonymous to some degree anyway because of the inherent characteristics of the medium. Services providing additional anonymity are only expanding on this feature of the net.

Pseudonymity comes in useful in that it allows users to send mail to pseudonymous users in response to their mail or post. People are able to respond to emails that they like or dislike or that they find offensive or disruptive. This makes the pseudonymous user more responsible for his or her actions than the completely anonymous user. They are still accountable for their actions on the net but are protected from "real world" damage.

Abolishing anonymity servers is not necessary since the technology exists to produce kill files which allow users to choose for themselves what they consider offensive. This allows individuals to filter out anonymous posts and emails which they dislike, while still reaping the benefits afforded by anonymous services. Although some people will automatically discount any anonymous postings, other people don't care who wrote it, as long as it is intelligent or funny. Still others use anonymity specifically to allow their opinions to be judged on their merit, rather than by the name attached to them.

4. Arguments against anonymity

With the benefits of on-line anonymity also come the disadvantages. Extreme abuse and illegal activity on the net is one of the most visible drawbacks to anonymity on the net. In general, abusive and frivolous anonymous email and posting is done mostly by users who have just discovered anonymity servers and whenever the novelty wears off, the frequency of the abuse decreases. However, a small minority of people who use anonymity servers are sociopaths who are attracted by the ease with which they can avoid responsibility and accountability for their actions. Examples of the these actions include kidnapping, terrorism, harassment, personal threats, hatespeech, financial scams, disclosure of trade secrets and exposure of personal information or secrets, among other things. One user expressed the desire to ban anonymity from the internet because he had no recourse against an anonymous user who posted his address, phone number and the name of his employer on the internet in retaliation for something that he had said.[18] Although such uses of anonymity go against the philosophy of 'netiquette' which citizens of the net use to partially govern the net, it can be argued that the user who complained would have been protected from this retaliation if he had posted his original comment anonymously.

Some people argue that the use of on-line anonymity in these cases of abusive or hurtful activity are especially bad because people are more likely to believe things that they see in print, as opposed to something they hear in an anonymous phone call or conversation. The instantaneous means by which this printed information can be distributed around the world also gives many people cause for concern. Additionally, it is almost impossible to control illegal activity which is perpetrated or discussed anonymously over the internet since, in most cases, police are not able to track the offender down. The recent case involving and the Finnish police is one exception, but this instance is in the extreme minority of cases where the identity of an anonymous user who has used the internet for criminal activity has not remained secret.

Some users value free speech so much that they have no problems with the hatespeech which a minority of users profess in anonymous posts and emails. They do, however, object to the fact that these users use anonymity as a shield for their beliefs. Some people use the existence of this problem to argue that anonymity is only needed to avoid retribution due to lack of understanding in the on-line society. They feel that dealing with societal problems which make people feel the need to express their opinions anonymously is a better solution than sanctioning these problems by allowing the existence of anonymous services. Additionally, many of the people who cause the intolerant conditions in some areas of the net which cause people to feel the need to express their opinions anonymously are the same people that abuse the anonymous services by using them to attack their opponents with impunity. There is a possibility that this problem could be diminished if societal problems were dealt with directly instead of discussed anonymously. This argument loses significant power, however, due to the fact that these problems have persisted for centuries in real-life society as well. Rude, inappropriate and offensive emails and posts were present on the internet long before anonymity servers were created. The best way do deal with rude people is to ignore them, and not to eliminate a service which has many benefits to the net. As one user mentioned: "It is akin to ...closing down the highway system because a few people speed."[18]

Some users agree that anonymity is useful for some newsgroups or discussions on sensitive topics, but they object to the fact that anonymity servers provide anonymity for everybody on every newsgroup. They feel that each newsgroup should decide whether or not they want anonymous posts and then set up a server designed specifically for that group. A number of newsgroups already function like this, but other newsgroups that object to anonymous posts are still subjected to them because users are able to use global services such as Many users feel that the introduction of such services has changed the culture of the net.

5. Famous cases

5.1 The ARMM censorship case

The issue of how anonymous people should be allowed to be has always been a controversial subject. Julf Helsingius has always felt that the anonymity of the people who use his service should be protected completely (or as completely as possible, as will be described in section 5.2). Many net users disagreed with this policy and felt that users who employ anonymity services in order to post abusive messages or commit illegal acts should be exposed. One of the greatest supporters of this view was Dick Depew, the news administrator on usenet. Depew strongly disagreed with Helsingius' policy of complete anonymity and announced in March of 1993 that he would cancel all anonymous messages originating from Helsingius' server.[19] Depew had written a piece of software which he called ARMM (standing for Automatic Retroactive Minimal Moderation) which was designed to send out cancel messages instead of posting the anonymous posts. Since Depew was an administrator on usenet, he was in a position to do this, whereas normal users of the system did not have this capability.[19]

After 2 anonymous messages were canceled using the ARMM program, an anonymous user called an8785 retaliated by posting Depew's address of employment and the name and phone number of his supervisor on the net. He told users that he had done this in response to Depew's censorship and urged users to complain to Depew's supervisor. Helsingius eventually deactivated the account of anonymous user an8785, but never revealed his identity. About a month later, Depew released a revised version of the ARMM program on the Helsingius server, which some people felt was in response to the fact that Helsingius refused to reveal the identity of an8785. The revised program severely backfired, both technically and politically. The software had a bug which caused it to post hundreds of messages on various newsgroups, causing a few mailservers to crash and generally making many net users angry.[19] This situation caused a great deal of outcry over attempts at censoring and policing the net. It also caused many users to publicly express their support for Helsingius' policy of absolute anonymity. Both of these issues are extremely important in the ongoing debate about what sort of legal restrictions should be put on the net and what types of legislation will be created for this purpose (this will be discussed in section 7).

5.2 Anonymity and the Church of Scientology

In January of this year, the Church of Scientology asserted that somebody had broken into a CoS computer and had stolen privileged information. An anonymous user then spread this information on the internet and posted it on alt.religion.scientology and other newsgroups, where supporters and critics of the church have been feuding for 3 1/2 years.[15,16] The church submitted a request to one of the newsgroups to close down completely because the posts had allegedly violated trademarks and copyrights held by the church. The church also threatened to hold the newsgroup operator and Netcom, the internet provider, legally responsible for such violations.[16] A federal judge eventually refused the Church's request for an injunction against Netcom and the newsgroup operator to stop posting such information. The judge ruled that it would be an impossible burden on the service provider to have to monitor all of the traffic through its service.[17] This ruling shows that there is some hope that anonymity on the internet will eventually be legally preserved.

On February 2, lawyers for the Church of Scientology also contacted the operators of several anonymity services, including Julf Helsingius, and demanded that they stop further anonymous posts to the newsgroups or legal action would ensue. After Helsingius made it clear that he would not voluntarily reveal the identity of the user in question, he was informed that the Finnish police were being contacted via Interpol. On February 8, Finnish police informed Helsingius that if he did not reveal the identity of the anonymous user, they would serve him with a search warrant to seize his entire server with the identities of all of the users who utilize his anonymity service. The Finnish police used the fact that the anonymous user was suspected of "unauthorized use of a computer" as the grounds for their search and the confiscation of the information from Julf Helsingius. Faced with the choice between revealing the identity of only one of his users or all of them, Helsingius reluctantly supplied the Finnish police with the name of the anonymous user involved in the CoS case. On February 14, Helsingius is informed that the criminal investigation in the CoS has been dropped.[14,20,21] In this case, Helsingius was forced to choose between protecting a user who relied on their service for anonymity at a time when anonymity was crucial and protecting the records of all of the other users of the system. The most practical choice was made and Helsingius intends to continue his anonymity service, but it will be interesting to see if any changes are made in the system as a result of this choice. Additionally, the fact that complete anonymity on the internet was compromised by the authorities brings up many legal questions about the future of anonymity on the internet. This issue will be discussed in section 7.

5.3 Anonymity in criminal cases

Recent debates about regulation of the internet have involved the hot topics of child pornography and abuse. The use of anonymity or pseudonymity in these criminal activities has recently come up in a court case involving two men in Texas. Gene Howland and Daniel Van Deusen ran a bulletin board service called "Lifestyles" in Houston, Texas which provided its more than 1000 subscribers with pornographic material, including child pornography. The two men, using the pseudonyms "Poo Bear" and "Wild One", lured two young boys to their home and forced them to commit sexual acts. Both men were indicted on March 11 on charges of sexual assault, aggravated sexual assault and indecency with a child.[7] Cases such as this one encourage assertions that the internet should be regulated and that anonymity should be eliminated since it enables people to use on-line services to commit criminal acts more easily.

6. Barriers to anonymity

6.1 Attacks by net citizens

About once a month, Julf Helsingius, who runs, receives mailbombs from irate net users who are upset about an anonymous post or email that came through his server. This causes many delays or the loss of data. Julf's general solution to this problem is to block the service of the site from which the mailbomb came for a few days. This usually discourages the mailbomber enough to stop, at least temporarily.[4] However, if enough people bomb the server, the loss of anonymity service could be more widespread or the server may even end up being shut down completely.

6.2 Concerns of system administrators

System administrators are often adamantly against the use of their sites for anonymity servers. They are afraid that they will be held responsible for acts such as terrorism or kidnapping which take place because of anonymous messages which pass through their system. Administrators would often rather shut down an anonymity server than deal with all of the politics that surround the use of such servers. This is one of the main reasons for the short life spans of many anonymity servers on the net. At one point in the life of the server, an unknown authority on the internet appealed to the main administrator of the Finnish university network to shut down the anonymous server. At that point in time, the server shared the internet connection with the university network and it created a difficult situation for Julf Helsingius. He decided to shut down the service for a few weeks until he could get a completely commercial connection that was totally separate from that of the university network.[3] Other server operators often do not have this option and are forced to shut their servers down due to a conflict of interest with system administrators.

The validity of the concerns of system administrators can be demonstrated in the civil court case of Stratton vs. Prodigy. An anonymous user of Prodigy accused Stratton Oakmont Inc., a New York investment bank, of acting fraudulently and illegally in one of its initial public offerings. As a result of this anonymous statement, Stratton filed a $200 million libel suit against Prodigy and the anonymous user. Stratton considers the network responsible for shielding the user with anonymity and stated: "If Prodigy is in the publishing business, then it opens itself up to libel charges."[6] Cases such as this one intimidate numerous system administrators and result in the shutdown of many anonymity servers each year.

Sometimes system administrators try to block anonymity service in their areas by using tactics other than just trying to shut the anonymity server down. An example of such a scheme was the famous case involving the ARMM program which tried to censor anonymous messages and remove them from newsgroups. Although this program backfired and generated much opposition to censorship on the net, the possibility of future use of such programs is not eliminated. Any system administrator with enough technical knowledge to create a better program of this kind may be able to effectively censor any anonymous messages at their site.

7. Legal issues

US law does not specifically guarantee the right to anonymity, although it is generally understood that anonymity in some form is protected under the First Amendment to the Constitution.[22] This is exemplified in the Supreme Court decision on the case of New York Times Co. vs. Sullivan, 1964. The court stated that: "an author's decision to remain an aspect of the freedom of speech protected by the First Amendment" and "the anonymity of an author is not ordinarily a sufficient reason to exclude her work product from the protections of the First Amendment."[22,24] In 1958, the Supreme Court upheld the right of the NAACP to keep from disclosing their membership list to the government.[22] The Supreme court has also struck down several laws which require the disclosure of the names of member of dissident groups.[22] Additionally, an example as simple as that of going into a voting both and anonymously entering your vote demonstrates that the US government does understand the importance of anonymity in some cases. Other countries are also gradually realizing the importance of anonymity. The most recent Canadian Copyright Act specifically guarantees the right of an author to write under a pseudonym or remain anonymous.[8]

US legislation is sure to examine the subject of on-line anonymity as laws slowly begin to catch up with important issues regarding the internet. One daunting look into current legal cases, however, seems to paint a grim picture for anonymity on the internet. Justice Scalia recently stated in a ruling on McIntyre vs. Ohio Elections Commission that he found anonymity generally dishonorable. He wrote that "It facilitates wrong by eliminating accountability, which is ordinarily the very purpose of the anonymity." He also felt that creating legal protection for anonymous communication without a reason to expect "threats, harassment or reprisals seems to me a distortion of the past that will lead to a coarsening of the future".[22,23] Additionally, the Supreme Court of California recently upheld a state law prohibiting anonymous mass political mailings by political candidates.[22] The fact that this case involves limiting anonymous speech, which is strongly protected by the First Amendment, does not bode well for media such as on-line communications which would have inherently less protection.

The recent clash between Finnish police and, the longest running anonymity server, is bound to inspire many net citizens who prize their anonymity to push for legislation, in Finland and around the world, to protect this precious resource and make it harder to legally raid anonymity servers. The recent court ruling earlier this year in the dispute between Netcom and The Church of Scientology which held that network administrators should not be responsible for all of the traffic through their server, including anonymous messages, shows that defenders of the right to anonymity do have the support of some members of the judicial system. On the other hand, the rise in the number of criminals who have joined the on-line community and are using the internet to discuss or participate in criminal activity is sure to inspire legislators to push for stricter laws on the limitations of anonymity in cases where illegal activity has occurred. Companies are also beginning to fight against anonymity on the internet because they fear that it will undermine long-established laws designed to protect the ownership of information and control its dissemination. It will be interesting to watch this battle play itself out in the coming years.

8. Rules

Current rules regarding anonymity on the internet are not global and are severely dependent on the opinion of the service providers who run the servers. Net users and readers of anonymous posts are also not unified in their opinions of what is acceptable or not. Julf Helsingius' policy is that if people on his system abuse the anonymity service to repeatedly post abusive articles in cultural newsgroups he will usually send them a warning message, and in some cases even cut them off.[3] He has also instituted a policy which limits the size of the files which can be sent through his server. This was done to minimize the amount of copyrighted software and pornographic images that could be transmitted via his service since both of these types of files are usually rather large.[15]

There has been a significant push on the internet to force anonymity providers to reveal the identity of users who have committed criminal or severely abusive acts. Julf Helsingius opposes this idea and feels that he does not have the right to judge what is right and wrong. Additionally, the international scope of his service means that the concept of illegal activities is not universal. He uses the example of pornographic images to prove his point. Posting pornographic images on the internet is considered illegal in many countries, while it is perfectly legal in others. He feels that it is not his place to draw the line on these issues.[3] Additionally, in many countries which have entered the on-line community, writings which are critical of the government, such as the exposure of human rights abuses in China and elsewhere, are illegal. The international nature of the net simply makes it impossible to enforce the laws of every country individually. It is quite possible that on-line anonymity will be reduced as soon as US legislation catches up with internet activities unless the digital community shows that it can regulate itself. One way to do this, is to draw up a set of guidelines on the use of anonymity services and stick to them. A very good example of such a set of rules can be found in a document written by L. Detweiler called Anonymity on the Internet.[19] Examples of some of the most important rules that must be followed in order to discourage legislators from stepping in are as follows:

For users:

For operators: For readers: If these and other guidelines are followed, problems associated with anonymity on the internet can be minimized.

9. Conclusion

Freedom of expression must be allowed. With this freedom comes all sorts of problems, but these types of problems are not unique to the internet. Unpopular speech is a necessary consequence of free speech and it was decided long ago, during the drafting of the Constitution and the Bill of Rights, that the advantages of free speech outweigh the disadvantages. This principle should hold on the internet as well. Anonymity servers on the internet provide a vital service with many benefits to the on-line community. The minority of users who abuse this service by sending harassing messages or engaging in illegal activities are a definite disadvantage to anonymity on the internet but this problem can be reduced significantly by following guidelines suggested here. The fact remains that more than 15,000 email messages are sent anonymously each day which shows that there is a significant need for anonymity services on the net. If anonymity service is a truly negative thing for the internet, it will eventually die out by itself from lack of use. Attempts to artificially eliminate this service through legislation would not be right. This wish that the internet remain unregulated seems rather naive, however. It is hoped, at least, that future national and international legislation on the internet allows the vital service of anonymity to remain. A common set of guidelines for the use of anonymity on the entire internet is vital. Such guidelines will only function on an international scale if both lawmakers and net users work together and try to figure out a solution.


  1. The American Heritage Dictionary of the English Language, Third Edition, Houghton Mifflin Company, Copyright 1992.
  2. Anonymity on the Internet, Part 2 <
  3. Don't try to Control the Network Because it's Impossible Anyway
  4. Anonymously Yours --Part 1
  5. Anonymously Yours --Part 2
  6. Solutions to On-Line Lies
  7. A Crime By Any Other Name...
  8. Canadian law supporting right to anonymity
  9. Legally Online
  10. Personal Technology
  11. Anarchy, Chaos on the Internet Must End
  12. Response to editorial by Avi Baumstein
  13. Response to editorial in the SF Cronical
  14. Police actions in Finland
  15. Unmasked on the Net, Time Magazine, March 6, 1995 Volume 145, No. 9.
  16. Internet's anonymity a boon the the 'twisted' Phyladelphia Inquirer by Reid Kanaley, February1, 1995.
  17. Ruling Supports Internet Provider Against Copyright Violation ChargeEdupage, March 2, 1995.
  18. Anonymity on the Internet, Part 3
  19. Anonymity on the Internet, Part 1
  20. World-wide internet community appalled over the Scientology seizure
  21. Press release on anon servers, child porn and scientologists Helsinki, Finland, February 20, 1995.
  22. Anonymity and Its Enmities (Article 4)by A. Michael Froomkin.
  23. 63 U.S.L.W. 4294, 4293-94 (Scalia, J., dissenting).
  24. McIntyre v. Ohio Elections Commission, 63 U.S.L.W. 4279 (U.S. April 18, 1995)
  25. Feb. 22, 1995, Postcard from Cyberspace: The Helsinki Incident and the Right to Anonymity, by Daniel Akst, Los Angeles Times.
  26. Comment by Raph Levien on the Dec. 31, 1994, New York Times article: Computer Jokes and Threats Ignite Debate on Anonymity.
  27. Computer Jokes and Threats Ignite Debate on AnonymityThe New York Times, December 31, 1994, pp. 1, 53.
  28. Identity Crisis on the InternetNew Scientist 11 Mar 95