11. The named plaintiffs are briefly identified below. Their interests and involvement with the Internet and interactive computer communications are described more fully in paragraphs 122-137.
12. Plaintiff AMERICAN LIBRARY ASSOCIATION, INC. ("ALA"), founded in 1876, is a non-profit, educational organization committed to the preservation of the American library as a resource indispensable to the intellectual, cultural, and educational welfare of the Nation. The ALA's direct membership includes over 3,000 libraries, over 55,000 librarians, and other individuals. Plaintiff FREEDOM TO READ FOUNDATION ("FTRF") is a non-profit membership organization established in 1969 by the ALA to promote and defend First Amendment rights; to foster libraries as institutions fulfilling the promise of the First Amendment for every citizen; to support the rights of libraries to include in their collections and make available to the public any work they may legally acquire; and to set legal precedent for the freedom to read on behalf of all citizens.
13. Plaintiffs AMERICA ONLINE, INC. ("AOL"), COMPUSERVE INCORPORATED ("COMPUSERVE"), MICROSOFT NETWORK ("MSN"), and PRODIGY SERVICES COMPANY ("PRODIGY") are the four leading commercial online services in the United States, each providing online services (including access to and content on the Internet) to millions of customers worldwide.
14. Plaintiff AMERICAN BOOKSELLERS ASSOCIATION, INC. ("ABA"), organized in 1900, is the leading association of general interest bookstores in the United States. ABA has over 5500 members, including 4300 bookstores, which do business in over 7000 locations across the country. AMERICAN BOOKSELLERS FOUNDATION FOR FREE EXPRESSION ("ABFFE") was organized in 1990. The purpose of the ABFFE is to inform and educate booksellers, other members of the book industry, and the public about the dangers of censorship and to promote and protect the free expression of ideas, particularly freedom in the choice of reading materials.
15. Plaintiff AMERICAN SOCIETY OF NEWSPAPER EDITORS ("ASNE") is a nonprofit professional organization of more than 850 individuals who hold positions as directing editors of daily newspapers throughout the United States. For over 50 years, ASNE has worked to provide an effective and unfettered press in the service of the American people by exercising and defending the First Amendment rights of the press to gather and publish news.
16. Plaintiff APPLE COMPUTER, INC., is a global and innovative leader in developing personal computers, personal computer software, and server hardware and software for the Internet. The company offers a wide range of products and services for business and personal computer and data communication. Apple's current and announced products include hardware and software for accessing the Internet, hardware and software for implementing and maintaining Internet servers and other services such as operating system and database storage and retrieval, and content software particularly for education, business and home computing, and communication. In addition, Apple maintains eWorld which provides online services including access to the Internet.
17. Plaintiff ASSOCIATION OF AMERICAN PUBLISHERS, INC. ("AAP") is the major national association in the United States of publishers of general books, textbooks, and educational materials. Its approximately 200 members include most of the major commercial book publishers in the U.S. and many smaller or non-profit publishers, including university presses and scholarly associations. AAP's members publish most of the general, educational, and religious books produced in the United States, and are particularly active in all facets of the electronic medium, including publishing a wide range of electronic products and services.
18. Plaintiff ASSOCIATION OF PUBLISHERS, EDITORS AND WRITERS is an unincorporated association of publishers, editors and individual writers who publish their materials both in print and online. Brought together by a common interest in protecting the right to free expression, its members write, edit and publish works on a wide range of subjects, including politics, techno- logy, finance, education, human sexuality and the arts. As producers and consumers of online content, its members will be directly subject to or affected by the Act.
19. Plaintiff COMMERCIAL INTERNET EXCHANGE ASSOCIATION ("CIX") is the nation's largest trade association of commercial Internet service providers ("ISPs") and access providers. CIX members provide carriage for approximately 75% of the world's Internet traffic, constituting millions upon millions of electronic messages each day. In addition to serving as passive carriers, many CIX members also provide Internet content, and assist customers in presenting content on the Internet through "World Wide Web," "gopher," and other Internet sites.
20. Plaintiff FAMILIES AGAINST INTERNET CENSORSHIP ("FAIC") is a voluntary, non-profit organization of parents across the country. FAIC was founded on the belief that parents are the people best suited to decide what their children should and should not see. To be a member of FAIC, one must (1) oppose censorship, (2) have an electronic mail address, and (3) have at least one child living at home.
21. Plaintiff HOTWIRED VENTURES LLC, a California limited liability company, is the creator of HotWired, a cyberstation on the World Wide Web offering interactive information about culture, lifestyle, and technology to over 300,000 subscribers.
22. Plaintiff INTERACTIVE SERVICES ASSOCIATION, formed in 1981, is the leading association devoted exclusively to promoting and developing consumer interactive services worldwide. ISA's several hundred members span the entire interactive industry, and include numerous commercial online services and other Internet content and service providers.
23. Plaintiff MICROSOFT CORPORATION is a worldwide leader in software for personal computers. The company offers a wide range of products and services for business and personal use. Microsoft's current and announced products include software for accessing the Internet, software for implementing and maintaining Internet servers and other services such as operating system and database storage and retrieval, and content software including compilations of musical, artistic, literary, encyclopedic, technical, statistical, and general business and specialized news information.
24. Plaintiff NETCOM ON-LINE COMMUNICATIONS SERVICE, INC., is an Internet service provider. The Company's core business is providing dial-up accounts for individuals and high- speed dedicated connections for businesses. NETCOM operates its own digital network and provides e-mail, NetNews, and web services for its customers. Many of NETCOM's customers connect to the Internet using the Netcruiser access software that NETCOM developed and produced.
25. Plaintiff NEWSPAPER ASSOCIATION OF AMERICA is a nonprofit organization representing the interests of more than 1,500 newspapers that account for approximately 85 percent of the daily newspaper circulation in the United States. Approximately 175 member newspapers in North America currently make their editions available on the Internet.
26. Plaintiff OPNET, INC., is an Internet access provider located in Bryn Mawr, Pennsylvania. OpNet provides access to the Internet to individuals and businesses throughout the Philadelphia area. OpNet also provides World Wide Web site maintenance, file storage, and server support to organizations which seek to put information on the World Wide Web.
27. Plaintiff SOCIETY OF PROFESSIONAL JOURNALISTS is a voluntary, non-profit organization of nearly 14,000 members. The Society is the largest and oldest organization of journalists in the United States, representing every branch and rank of print and broadcast journalism, and for more than 80 years has been dedicated to perpetuating a free press. Many of the members of the Society write news stories, articles, and columns made available over the Internet and other interactive computer networks.
28. Plaintiff WIRED VENTURES, LTD., a California limited partnership, publishes Wired, a monthly magazine that addresses the cultural implications of the digital revolution, focusing on the impact of new technologies on our society. In addition to being distributed in printed format, the editorial content of Wired magazine is available on the Internet through HotWired (a cyberstation on the World Wide Web) and elsewhere.
29. Plaintiff CITIZENS INTERNET EMPOWERMENT COALITION ("CIEC") is an unincorporated coalition of parents, individuals, private companies, and non-profit organizations, sharing the common goals of promoting the continued development of the Internet as a forum for the free exchange of valuable information and ideas, and promoting the ability of parents to supervise and assist their children in the appropriate use of the resources of this global communications medium, free from improper governmental censorship. Coordinated by the Center for Democracy and Technology, the American Library Association, and America Online, CIEC's members include providers of both Internet content and access services, as well as public interest organizations. As users of the Internet, as providers of Internet content and services, and as organizations that include parents and other individuals who themselves use the Internet, CIEC's members are directly subject to or affected by the Act. Among CIEC's current members -- in addition to the named plaintiffs -- are AMERICAN ASSOCIATION OF STATE COLLEGES AND UNIVERSITIES, AMERICANS FOR TAX REFORM, ASSOCIATION OF AMERICAN UNIVERSITIES, ASSOCIATION OF AMERICAN UNIVERSITY PRESSES, ASSOCIATION OF NATIONAL ADVERTISERS, ASSOCIATION OF RESEARCH LIBRARIES, CENTER FOR DEMOCRACY AND TECHNOLOGY, COALITION FOR NETWORKED INFORMATION, MEDIA ACCESS PROJECT, MEDIA INSTITUTE, MICROSYSTEMS, INC., NATIONAL ASSOCIATION OF STATE UNIVERSITIES & LAND-GRANT COLLEGES, PEOPLE FOR THE AMERICAN WAY, RECORDING INDUSTRY ASSOCIATION OF AMERICA, SPECIAL LIBRARIES ASSOCIATION, SURFWATCH, INC., and THE UNIVERSITY OF CALIFORNIA SANTA BARBARA LIBRARY.
30. Defendant UNITED STATES DEPARTMENT OF JUSTICE is a federal executive agency, authorized to conduct federal criminal investigations and prosecutions on behalf of the United States Government throughout the United States. Defendant JANET RENO is the Attorney General of the United States. She is the chief executive officer of defendant UNITED STATES DEPARTMENT OF JUSTICE and is authorized to conduct federal criminal investigations and prosecutions throughout the United States. Defendants have responsibility for enforcing the Act, including initiating criminal prosecutions.
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