Pharos: Human Rights Media


In January 2011, in the Difficult Problems for Cyberlaw class at Stanford (taught by Jonathan Zittrain, from Harvard Law School and the Berkman Center), I was part of a team that designed an organization that would help human rights activists from around the world safely upload and distribute media about human rights violation through the Internet.  We called it Pharos, with a full write-up of the details here, on the class’ wiki.

Our design brief was to design a contribution that would improve the Internet and address questions of cybersecurity.  We moved into the direction of protecting vulnerable people who wanted to distribute content, but who feared retribution from the government. As we were designing, the Arab Spring was just beginning, and we were in conversation with Facebook, Google, and YouTube directors who had to be making quick responses to foreign human rights violations and internet censorship.

Below is an end-to-end diagram of how the user would use the organization.

Design Portfolio-PharosEndToEnd

Here is our write up after our brief:

Our contribution towards a better Internet is a new organization, Pharos, that will enable, protect, and promote human rights media from around the world. Our starting premise is that there is an immense capability to capture video in the form of cheap mobile phone cameras and other digital recorders. Importantly, it has also become much easier to post such video online for free. This combination of developments should have led to a dramatic expansion in video to promote human rights and to expose human rights violations, but our view is that this development has not occurred.

Thus we set out to identify the obstacles that might be preventing or inhibiting the spread of human rights media, as well as to study existing services and solutions that could be used to surmount these obstacles. As a whole, we found that existing services are inadequate for a range of reasons including: susceptibility to government pressure, lack of security, lack of publicity, and many others. While our initial discussions and research led us to consider specific solutions to discrete problems, the interwoven nature of many of the problems led us to consider the viability and desirability of a single organization that could meet the many challenges simultaneously.

Accordingly, we propose Pharos as a solution to these many problems in the aggregate. It should be noted, however, that within these pages readers will still find discussions of many discrete problems pertaining to human rights media, as well as corresponding suggestions for solutions that could be implemented immediately by new applications or existing services (e.g. software making it easy to blur the faces of protesters). In our view, Pharos is an ambitious endeavor aimed at solving the many problems inhibiting the spread of human rights media, but addressing any of these problems individually would also be a highly worthwhile endeavor that has the promise of creating a better Internet.

Design - Pharos key Design - PHaros800px-Internal_structure

And here is our write-up for the class,

First and foremost, Pharos is a mission-driven organization: “To enable, protect, and promote human rights media.” To serve this mission, Pharos has two objectives. First, it enables technical solutions for receiving and publishing human rights media while protecting anonymity. Second, as an independent organization Pharos serves as a leader in promoting awareness of and discussions about the state of human rights media.


To enable, . . .

Pharos enables human rights media by facilitating technical solutions for receiving and publishing such media. Figure 1 (left) illustrates how Pharos is situated to accomplish this goal. The left-hand side of the picture shows how Pharos is positioned to receive human rights media, and the right-hand side shows how Pharos is positioned to publish that media.

Pharos is connected to the sources of human rights media – cameras, mobile phones, computers, video recorders, etc. – via the Internet.[1] The options for transmitting media to Pharos are numerous, and are represented in the picture by the blue cloud. Pharos leverages existing technologies to facilitate various paths through the cloud, such as public key encryption,[2] sneakernets,[3] Tor implementations,[4] direct web uploads, email, or any other method that allows individuals to send human rights media to Pharos anonymously. Furthermore, these technologies can be used together. For example, one could imagine a scenario in which a person captures a human rights violation through the video camera on his mobile phone, transfers that video to a computer at an Internet café, then encrypts the video using Pharos’s public encryption key, and finally uses a Pharos-specific Tor network to send the encrypted video to Pharos. Alternatively, if anonymity is less of a concern, the person could simply record the video on his mobile phone and upload it directly to Pharos’s website. In either case, part of Pharos’s mission is to ensure that that such paths through the cloud exist.

In addition to receiving human rights media, Pharos facilitates its publishing, which is depicted on the right-hand side of the “Pharos end-to-end diagram.”[5] Pharos can publish human rights media in two ways. First, Pharos has the ability to publish the media itself, and second, it can also work closely with existing organizations like YouTube and The New York Times to help with distribution. A real-life scenario could work as follows. A person records a small, peaceful demonstration on her mobile phone. Because YouTube is blocked in her country and the New York Times doesn’t deem the small demonstration to be newsworthy, she sends the video to Pharos, which publishes it on Pharos’s website. Later, the government cracks down on the demonstrators, claiming that they are violent. But because Pharos has received and published this video, a record of the peaceful demonstration is preserved and later picked up by major news organizations, eventually including the New York Times.

No other organization enables human rights media in this way or this effectively. Using the framework developed in the Existing Services Section, hierarchical organizations that are profit-seeking, such as CNN and The New York Times, may choose not to publish certain pieces of media because they are not newsworthy. Non-hierarchical organizations that publish user-generated content, like YouTube and Facebook, may not filter media by newsworthiness, but as profit-seeking organizations they are susceptible to governmental pressures to take down objectionable content and identify offending individuals. For these reasons, Pharos must have the capability to publish human rights media on its own, since it neither filters content by newsworthiness nor is subject to governmental pressures in the same ways that profit-seeking entities are. On the other hand, non-profit organizations like and Amnesty International do not have the resources or the expertise to enable technical solutions for exfiltrating human rights media. For this reason, Pharos must proactively enable such technical solutions for receiving human rights media. By building the two steps required to distribute human rights media to the world – receiving and publishing – into its mission, Pharos accomplishes what no existing organization can.

protect, . . .

A critical piece of Pharos’s mission is to protect the sources of the human rights media that it receives. Anonymity is a necessary component of any solution that encourages individuals to expose human rights violations, as the threat of reprisal is an effective mechanism for chilling the creation of such media.

Pharos protects its sources in two ways. First, Pharos scrubs any technical metadata that might identify the source that submitted a particular piece of media. For example, Pharos eliminates any record of the origin of the submission (e.g. IP address) and any record of the actual device (e.g. mobile phone number or computer MAC address) that was used to create the media. In this way, digital forensic techniques will not lead back to the source of a particular piece of content. Second, Pharos can actually blur the identities of participants in the media that it receives. For example, participants in a human rights protest might face reprisals if their identities become know to repressive governments. Pharos can deploy a combination of automated technical solutions and manual review to ensure that sensitive videos can be published without risking the safety of the participants in those videos.[6]

The protection of anonymity is not unique to Pharos. Traditional news organizations, like newspapers, vigorously protect the identity of their sources. However, extending such protection to user-generated content is unique to Pharos. Organizations like Facebook, YouTube, and Yahoo! have turned over the identities of its users to oppressive governments under certain circumstances, and will continue to do so. This dramatically reduces their effectiveness for distributing human rights media. In contrast, Pharos will guarantee the anonymity of its sources, as do traditional news organizations. While Pharos cannot be “jurisdictionless”,[7] it must exist in an environment where it can legally protect its sources. For more information, see Pharos – Organization and Governance.

and promote . . .

For Pharos to be an effective human rights distribution platform, it must promote awareness both of its existence and how to use it. Furthermore, as an independent organization, Pharos should promote general awareness of the state of human rights media.

Pharos must be top-of-mind for those individuals that have a need for its services. Pharos can only combat the efforts of oppressive governments to chill free speech if the citizens of those oppressive regimes feel that they can effectively create and distribute human rights media without the fear of reprisals. To achieve this level of publicity, Pharos must actively promote itself, both through the mainstream media and by grassroots efforts. For example, Pharos should work with citizen journalists to spread awareness of Pharos “on the ground,” and should partner with human rights organizations like Amnesty International,, and others.

On the publishing side, Pharos should work to maximize the distribution of the media it publishes so that it reaches as wide an audience as possible. In addition to publishing content itself, Pharos should work with other publishing platforms to promote its content. For example, Pharos could work directly with regional news sources, such as online versions of local newspapers, to republish its content and thus maximize its distribution.

By promoting itself, Pharos is promoting the creation, publishing, and distribution of human rights media. Pharos is unique in this position as a single entity that serves to promote an end-to-end solution focused exclusively on human rights media. Other organizations solve pieces of the puzzle, but only Pharos puts it all together. For example, actively promotes and facilitates the creation of human rights video,[8] but no longer supports receiving and publishing it.[9] Traditional news organizations like The New York Times and user-generated content services like YouTube facilitate publishing content, but not its creation. Furthermore, neither type of organization specifically focuses on human rights media. Only Pharos completes the puzzle.

human rights media.

While Pharos’s anonymization services help to solve the suppression of human rights media, they are also susceptible to abuse. In order to remain credible, Pharos must monitor the content that it receives and publishes to ensure that it is consistent with the spirit of Pharos’s mission. This is an immensely challenging problem and a nearly impossible line-drawing exercise, but other organizations have attempted to tackle the problem. For example, CNN’s iReport Community Guidelines provide an interesting point of reference for unwelcome content:[10]

  • Content that infringes someone’s copyright.
  • Content that you know to be untrue.
  • Spam, or repeated uploads that flood the site with duplicate versions of the same or similar content.
  • Pornography/sexually explicit content.
  • Obscene/lewd content.
  • Content that advocates violent behavior.
  • Content that contains violent images of killing or physical abuse that appear to have been captured solely, or principally, for exploitive, prurient or gratuitous purposes.
  • Content that advocates dangerous, illegal or predatory acts or poses a reasonable threat to personal or public safety.
  • Hate Speech/Racially or ethnically offensive content.

Deciding on what content is or is not acceptable will be an ongoing challenge (see Challenges and Critiques), and decisions will have to be made on a case-by-case basis. However, adopting a flexible set of guidelines like those adopted by iReport is a big step in the right direction.


  1. It should be noted, however, that Pharos is not restricted to receiving media over the Internet. For example, Pharos could publish a mailing address. For our purposes, however, we assume that the Internet is the easiest and most likely conduit through which Pharos will receive human rights media.

  2. See, e.g.,

  3. See, e.g.,

  4. See

  5. Before publishing any piece of media, Pharos protects the identity of its sources by anonymizing any files it receives. This process is described in greater detail in the next Section.

  6. The question of which videos should be subject to such blurring is left for further discussion. For example, a person who submits a video could explicitly request that the video be completely “anonymized.” In other cases, this might not be necessary. In yet other cases, Pharos may require such anonymization.

  7. See

  8. See

  9. See (noting that ‘the uploading and commenting functionality have been turned off’ on’s former video hosting site)


And finally, if you’re still with me — here are the Challenges & Critiques we put together, as to why our organization may have feasibility and viability issues.

This section of the wiki acknowledges key challenges facing the Pharos project and recommends future work that can be done to address some of these challenges. It addresses foundational critiques of the project, practical concerns, and potential unintended consequences that may result from the project.



Foundational Considerations: Defining the Problem

The Pharos project is premised on the idea that in spite of a rise in low-cost video technologies, a dearth of video footage about human rights abuses currently exists[1] and that this is because there is no end-to-end system that allows the upload, sanitization, and hosting of human rights videos. Assuming for the moment that there exists a true dearth of videos about human rights abuses, it is unclear what has stymied the use of video technologies to document and report human rights abuses. It is possible that few human rights videos have been circulated for reasons independent of a lack of a technological system that sanitizes and serves as an end-to-end upload-and-hosting service for human rights videos.

For example, Internet penetration in Africa remains low—one 2010 study estimates that only about 10.9 percent of continent’s population has Internet access.[2] The lack of Internet access could explain why human rights activists make limited use of video technologies to upload human rights content onto the web. Social norms may also drive whether and how technologies are used to further human rights. It is generally unlawful to record evidence of human rights abuses in countries that practice censorship and citizens in those countries may hew to the rule of law even if there is a real need and desire to report these abuses. In the latter instance, social practices surrounding technology use—not the lack of technology—might be the primary obstacle to the creation and dissemination of human rights videos.

In addition, some human rights activists might choose not to film and circulate videos documenting human rights abuses because increasing international exposure of a particular type of government abuse may not stop government abuses.[3] The “range of human rights abuses” is wide, and human rights advocacy taking the form of “pursuing reform through formal judicial routes or diplomatic channels” might be more effective in a variety of situations.[4] The solution offered by Pharos may be ill-suited to addressing first-order issues like network connectivity and social practices surrounding technology use.

More precision is needed in defining the problems Pharos hopes to solve. In internal discussions, the Pharos team proposed several hypotheses, each of which should be critically examined:

Human rights videos are not widely disseminated on the Internet because:

  • There is no tool to sanitize human rights videos (i.e. remove identifying information), and human rights abuses are not being recorded on video or uploaded to the Internet because of the fear of jeopardizing the physical security of individuals featured in human rights videos or of the uploader.
  • Human rights activists do not have the technological knowledge to use existing “liberation technologies” like Tor that can provide some measure of anonymity and security to the human rights activist.
  • Current technologies (like Tor) that can be used by human rights activists are underleveraged because human rights activists do not know about their existence.
  • For-profit services, such as YouTube, are particularly susceptible to government requests for takedown; as a result, human rights videos are not either being posted to these for-profit hosting sites or being taken down.

Some of the problems above can be addressed without the creation of a new organization and the design of a new technological system. For example, in order to address human rights activists’ lack of technical expertise, some researchers have run technology training sessions.[5] Patrick Meier, a researcher studying the use of technologies in civil resistance against repressive regimes, has led technology training sessions to teach individuals how to use existing technologies like Ushahidi, a tool that uses crowdsourced information to map the emergence of natural disasters and government abuses against citizens.[6]

If existing technologies are not being leveraged to the extent possible by human rights activists because they do not know of these tools’ existence, training sessions or branding efforts may similarly be used to inform human rights activists of the tools at their disposal. Low-cost video editing software that strips metatags from the video and enables face blurring could provide a similarly narrow solution to address the problem of government efforts to identify and jail dissidents who upload or are featured in human rights videos.

Going forward, more information providing support for the hypotheses debated within the team is needed to determine if a new technological system is needed, and if so, what features of such a technological system would most aid the dissemination of human rights media.

Practical Concerns

The success of Pharos’s mission depends on acquiring adequate funding; developing a clear policy to meet its objectives of enabling, protecting, and promoting human rights; and making video upload simple enough to encourage activists to use video technologies more frequently to capture and circulate content on human rights abuses.

 Costs and Funding

The costs of running a non-profit organization like Pharos would be significant. Resources would be needed to train a sophisticated technology team to keep Pharos’s servers secure. Regular staff would be needed to blur faces and remove metatags and other identifiable information from the videos. Educating human rights organizations about Pharos and branding and disseminating information about Pharos would also be expensive because it would require visiting many different NGOs around the world.

Finding sources of funding might be problematic because of the highly political nature of Pharos’s mission. Each of the potential sources of funding—governments, venture capitalists, and philanthropists—might have concerns that limit their willingness to donate.

Most governments would fear the destabilizing effects of videos posted by their citizens or the geopolitical consequences of funding such an effort. Most venture capitalists and other profit-seeking investors would not be interested in funding Pharos because Pharos will not generate profit.

Philanthropists would be the most promising source of funding. Many philanthropists would be attracted to the broad goals of Pharos. Some, however, may object to the organization’s definition of acceptable content or who sits on Pharos’s Board of Directors.[7] For example, an American philanthropist that generally supports ending human rights abuses may object if Pharos decides to host video content exposing American troops’ firing on Iraqi or Afghani civilians because of the video’s potential to further deepen anti-American sentiment in the Middle East.

Governance and Defining Acceptable Content


Daniel Pearl, before he was killed.

Extremist groups might submit videos to Pharos that are intended to terrorize a population. Determining whether it is appropriate to disseminate a video showing the capture or the killing of a civilian would be difficult. When the video of journalist Daniel Pearl’s beheading circulated on the Internet, many video hosting services decided to continue hosting the video even though some individuals, including Senator Joe Lieberman, asked for YouTube to remove graphic and violent videos that seemed to further the end of terrorists.[8] Like Lieberman, some philanthropists might object to content that is distributed to further the end of a terrorist or extremist organization.[9] YouTube’s Community Guidelines advises uploaders not to post content that contains “graphic or gratuitous violence”[10] and yet YouTube decided that the right of the public to know what had happened to Daniel Pearl trumped other concerns.

In a similar situation, what position would Pharos take? The killing of individuals for a political purpose falls squarely within the definition of a human rights violation in international treaties and soft-law principles. But should the board remove a video to refuse satisfying the whims of a terrorist organization? Or should a larger interest in human rights or in circulating the truth trump other considerations? What positions would the former political leaders on the Pharos board take and how would those views influence Pharos’s decision?

Defining the scope of acceptable content presents a particularly thorny problem for Pharos’s advisory board even though Pharos could skirt some issues by abiding by a policy that is as inclusive and as politically neutral as possible.

One set of policy guidelines the Pharos team intended to model was the CNN iReport Community Guidelines.[11] CNN iReport asks individuals to not post:

  • Content that infringes someone’s copyright.
  • Content that you know to be untrue.
  • Spam, or repeated uploads that flood the site with duplicate versions of the same or similar content.
  • Pornography/sexually explicit content.
  • Obscene/lewd content.
  • Content that advocates violent behavior.
  • Content that contains violent images of killing or physical abuse that appear to have been captured solely, or principally, for exploitive, prurient or gratuitous purposes.
  • Content that advocates dangerous, illegal or predatory acts or poses a reasonable threat to personal or public safety.
  • Hate Speech/Racially or ethnically offensive content.[12]

If adopted, several of the guidelines listed above would be difficult to interpret. Taking the example from before, would video content showing the capture of a civilian journalist and his beheading violate the guideline that bars content “contain[ing] violent images of killing or physical abuse . . . captured solely, or principally, for exploitive . . . or gratuitous purposes”?


Bullet ant

Furthermore, what is a human rights violation in one country might very well be a venerated tradition in another society. Determining the right level of deference to pay a particular society will be challenging. The Satere-Mawe, an indigenous people in Brazil, perform a male adulthood initiation ritual in which boys stick their hands in a glove filled with bullet ants whose bites inject venom into their victims, causing severe pain, temporary paralysis in the arms, and uncontrollable shaking that may last up to twenty-four hours.[13] In other societies, un-anaesthetized male circumcision is performed on teenage boys without sterilized medical instruments as part of a religious ritual, and botched circumcisions routinely lead to death.[14] Do these rituals constitute human rights abuses?

A board that consists of former political leaders, philanthropists, and academics is also likely to encounter disagreements that might stall the creation of, or adherence to, a clear policy regarding acceptable content.

Other Challenges

It is unclear how Pharos would identify and ban fabricated human rights videos if most individuals submitting videos do so with little to no identifying information attached on the video to help the Pharos content team determine what is credible content and what is not. Without an effective procedure to identify and remove fabricated videos, Pharos might instigate needless political unrest or erode its own credibility, undermining activists’ and viewers’ trust in its ability to disseminate accurate information.

Another area of concern is ease of use by the end users. To be successful, Pharos would ideally make video upload easier than currently available tools do. It is unclear whether the finished end-to-end system would solve most usability and data security problems for human rights activists.[15]

 Unintended Consequences

Threats to Human Security

If Pharos works as intended and broadcasts information about human rights abuses, governments will have a strong interest in discovering the identities of video uploaders and the identities of individuals in the videos. Governments will be most interested in accessing the videos given to Pharos in their pre-sanitized version so that government agents can identify the faces of protesters or use other identifiable features of the video to determine who shot the video.

A disgruntled employee at Pharos who intentionally leaks pre-sanitized videos or a sophisticated government-sponsored hacking team that accesses the pre-sanitized videos could jeopardize human rights activists.

The creation of Pharos could leave human rights activists worse off than before if Pharos’s promise of anonymization and security is relied upon and not kept.

Government Crackdowns on Internet Access


The falloff of Internet traffic during the Egyptian government’s crackdown on Internet access.

Other problems related to the Internet architecture within countries will likely play a larger role in the adoption of any liberation technology tool than the mere existence of the tool. In reaction to political unrest, the government of Egypt took its entire country offline on January 27, 2011.[16] Other countries like China block Internet access in certain portions of the country where political unrest—and human rights abuses—exists.[17]

If Pharos were to initially succeed at helping activists exfiltrate videos documenting human rights abuses, repressive regimes might react by taking their countries offline anytime there is political unrest likely to erupt in human rights abuses by their military and paramilitary forces. Such a result would undermine populations’ access not only to information about human rights, but also to a far-ranging scope of communication channels and information as a whole.

 Worsening of Human Rights Conditions

Despite its intention of improving human rights conditions around the world, Pharos might worsen human rights conditions in two ways.

First, the impulse to take human rights activism online might distract citizens—and governments—from participating in meaningful, real-world reforms.[18] The Internet is not always the best forum or outlet for pursuing relief from human rights abuses.

“The right path of action to help solve human rights problems is context-specific. If you really want a bad situation to change, you need to think about timing issues, framing issues, who to go to in order to publicize news about an abuse…. You have to examine what is the incident involved and who is the actor perpetrating the incidents. Tweeting or posting a video documenting a human rights abuse in most contexts will not induce the perpetrator to stop.” [19]

Second, the international naming-and-shaming of a government for its human rights abuses may also have the serious and unintended consequences of worsening human rights conditions for citizens living under the rule of a shamed government.

For example, in 2002, the Nigerian government sentenced Amina Lawal to death by stoning after she gave birth out of wedlock.[20] Her case quickly gained international attention, and the media and human rights activists in the West organized an international letter-writing campaign demanding the courts to reverse the sentence.[21] During this time, Lawal was not in danger and her case was still pending appeal.[22] As international uproar over the case increased, tensions between the local NGO representing Lawal and the Nigerian judicial system increased.[23] Significantly, many Western audiences had gotten the facts of Lawal’s case wrong and the local NGO representing Lawal feared that the inaccuracies in the media and in the activists’ letters to the Nigerian government were hurting Lawal’s case.[24] The NGO urged the well meaning, but misdirected, petitioners to stop.[25] They had reason to believe that the international scrutiny and mangling of the facts would do Lawal more harm than good: earlier, an unmarried teenager convicted of extramarital sex was flogged “deliberately . . . to defy” what a local official described as “letters from infidels.” [26]

Sanitizing the videos could go a long way toward protecting the victims featured in the videos, but encouraging the filming and circulation of human rights videos could still politicize issues in a way that may worsen conditions for individuals living under a repressive regime. Pharos needs to carefully consider the possibility that it could in fact worsen the very conditions it is designed to improve.


  1. Contra E-mail from Patrick Meier, Director of Crisis Mapping, Ushahidi and Doctoral Research Fellow, Harvard Humanitarian Initiative, Harvard University (Feb. 1, 2011, 18:21 PDT) (on file with author) (stating that there is currently no dearth of footage about human rights abuses circulating on the Internet, specifically pointing to the videos on YouTube and documenting government-endorsed brutality against civilian protesters in Egypt as Mubarak struggles to stay in power).
  2. Internet World Stats, Usage and Population Statistics,;;
  3. Interview with Jennifer Gibson, former human rights activist for Save the Children (Feb. 3, 2011) (on file with author). See, infra, Unintended Consequences.
  4. Gibson, supra, note 3.
  5. See generally, (detailing Patrick Meier’s insight on deploying crisis mapping technologies to further civil resistance against repressive regimes).
  6.; see also (mapping civil resistance by Sudanese citizens against the government and indicating times and places where protesters have been killed).
  7. See Governance and Defining Acceptable Content.
  8. See J. Lieberman and S. Collins, Violent Islamist Extremism, the Internet, and the homegrown Terrorist Threat. Senate Committee on Homeland Security and Governmental Affairs (Mar. 8 2008),
  9. See, e.g., Peter Finn, Khalid Sheik Mohammed Killed U.S. Journalist Daniel Pearl, Report Finds, WASH. POST, Jan. 20, 2011, (David Pearl’s killer said that the video of the beheading was made to serve Al Qaeda propaganda objectives).
  12. Id.
  13. Steve Backshall, Bitten by the Amazon, THE TIMES, Jun. 6, 2008,
  14. Thandisizwe Redford Mavundla, et. al., Rationalization of Male Circumcision as a Sacred Religious: Custom: Health Beliefs of Xhosa Men in South Africa, 20 J. TRANSCULT. NURSING 395, 396 (2009).
  15. See Technical Capabilities.
  16. See (displaying the falloff of Internet traffic coming to and from Egypt when the government banned Internet access Jan. 27, 2011 in response to political instability).
  18. See generally Evgeny Morozov, THE NET DELUSION 197-203 (2011) (arguing that young people’s participation in online political campaigns might produce an illusion of offline political reform).
  19. See Gibson, supra, note 3.
  20. Deborah L. Rhode and Amanda Packel, Leadership in a Global Context: Corporate Social Responsibility and International Human Rights, LEADERSHIP: LAW, POLICY, AND MANAGEMENT (forthcoming, Aspen Publishers, 2011).
  21. Id.
  22. Id.
  23. Id.
  24. Letter from BAOBAB for Women’s HUman Rights to paticipants of letter-writing campaign,
  25. Id.
  26. See Rhode, supra, note 21.

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