title: Fair use

text: In the decisions of the Second Circuit in "Salinger v. Random House" and in "New Era Publications Int'l v. Henry Holt & Co", the aspect of whether the copied work has been previously published was considered crucial, assuming the right of the original author to control the circumstances of the publication of his work or preference not to publish at all. However, Judge Pierre N. Leval views this importation of certain aspects of France's "droit moral d'artiste" (moral rights of the artist) into American copyright law as "bizarre and contradictory" because it sometimes grants greater protection to works that were created for private purposes that have little to do with the public goals of copyright law, than to those works that copyright was initially conceived to protect. This is not to claim that unpublished works, or, more specifically, works not intended for publication, do not deserve legal protection, but that any such protection should come from laws about privacy, rather than laws about copyright. The statutory fair use provision was amended in response to these concerns by adding a final sentence: "The fact that a work is unpublished shall not itself bar a finding of fair use if such finding is made upon consideration of all the above factors."


title: Fair use

text: The third factor assesses the amount and substantiality of the copyrighted work that has been used. In general, the less that is used in relation to the whole, the more likely the use will be considered fair.


title: Fair use

text: Using most or all of a work does not bar a finding of fair use. It simply makes the third factor less favorable to the defendant. For instance, in "Sony Corp. of America v. Universal City Studios, Inc." copying entire television programs for private viewing was upheld as fair use, at least when the copying is done for the purposes of time-shifting. In "Kelly v. Arriba Soft Corporation", the Ninth Circuit held that copying an entire photo to use as a thumbnail in online search results did not even weigh against fair use, "if the secondary user only copies as much as is necessary for his or her intended use".


title: Fair use

text: However, even the use of a small percentage of a work can make the third factor unfavorable to the defendant, because the "substantiality" of the portion used is considered in addition to the amount used. For instance, in "Harper & Row v. Nation Enterprises", the U.S. Supreme Court held that a news article's quotation of fewer than 400 words from President Ford's 200,000-word memoir was sufficient to make the third fair use factor weigh against the defendants, because the portion taken was the "heart of the work". This use was ultimately found not to be fair.


title: Fair use

text: The fourth factor measures the effect that the allegedly infringing use has had on the copyright owner's ability to exploit his original work. The court not only investigates whether the defendant's specific use of the work has significantly harmed the copyright owner's market, but also whether such uses in general, if widespread, would harm the potential market of the original. The burden of proof here rests on the copyright owner, who must demonstrate the impact of the infringement on commercial use of the work.


title: Fair use

text: For example, in "Sony Corp v. Universal City Studios", the copyright owner, Universal, failed to provide any empirical evidence that the use of Betamax had either reduced their viewership or negatively impacted their business. In "Harper & Row," the case regarding President Ford's memoirs, the Supreme Court labeled the fourth factor "the single most important element of fair use" and it has enjoyed some level of primacy in fair use analyses ever since. Yet the Supreme Court's more recent announcement in "Campbell v. Acuff-Rose Music Inc" that "all [four factors] are to be explored, and the results weighed together, in light of the purposes of copyright" has helped modulate this emphasis in interpretation.


title: Fair use

text: In evaluating the fourth factor, courts often consider two kinds of harm to the potential market for the original work.


title: Fair use

text: Courts recognize that certain kinds of market harm do not negate fair use, such as when a parody or negative review impairs the market of the original work. Copyright considerations may not shield a work against adverse criticism.


title: Fair use

text: One such factor is acknowledgement of the copyrighted source. Giving the name of the photographer or author may help, but it does not automatically make a use fair. While plagiarism and copyright infringement are related matters, they are not identical. Plagiarism (using someone's words, ideas, images, etc. without acknowledgment) is a matter of professional ethics, while copyright is a matter of law, and protects exact expression, "not" ideas. One can plagiarize even a work that is not protected by copyright, for example by passing off a line from Shakespeare as one's own. Conversely, attribution prevents accusations of plagiarism, but it does not prevent infringement of copyright. For example, reprinting a copyrighted book without permission, while citing the original author, would be copyright infringement but not plagiarism.


title: Fair use

text: The U.S. Supreme Court described fair use as an affirmative defense in "Campbell v. Acuff-Rose Music, Inc." This means that in litigation on copyright infringement, the defendant bears the burden of raising and proving that the use was fair and not an infringement. Thus, fair use need not even be raised as a defense unless the plaintiff first shows (or the defendant concedes) a case of copyright infringement. If the work was not copyrightable, the term had expired, or the defendant's work borrowed only a small amount, for instance, then the plaintiff cannot make out a case of infringement, and the defendant need not even raise the fair use defense. In addition, fair use is only one of many limitations, exceptions, and defenses to copyright infringement. Thus, a case can be defeated without relying on fair use. For instance, the Audio Home Recording Act establishes that it is legal, using certain technologies, to make copies of audio recordings for non-commercial personal use.


title: Fair use

text: Some copyright owners claim infringement even in circumstances where the fair use defense would likely succeed, in hopes that the user will refrain from the use rather than spending resources in their defense. Strategic lawsuit against public participation (SLAPP) cases that allege copyright infringement, patent infringement, defamation, or libel may come into conflict with the defendant's right to freedom of speech, and that possibility has prompted some jurisdictions to pass anti-SLAPP legislation that raises the plaintiff's burdens and risk.


title: Fair use

text: Although fair use ostensibly permits certain uses without liability, many content creators and publishers try to avoid a potential court battle by seeking a legally unnecessary license from copyright owners for "any" use of non-public domain material, even in situations where a fair use defense would likely succeed. The simple reason is that the license terms negotiated with the copyright owner may be much less expensive than defending against a copyright suit, or having the mere possibility of a lawsuit threaten the publication of a work in which a publisher has invested significant resources.


title: Fair use

text: Fair use rights take precedence over the author's interest. Thus the copyright holder cannot use a non-binding disclaimer, or notification, to revoke the right of fair use on works. However, binding agreements such as contracts or licence agreements may take precedence over fair use rights.


title: Fair use

text: The practical effect of the fair use doctrine is that a number of conventional uses of copyrighted works are not considered infringing. For instance, quoting from a copyrighted work in order to criticize or comment upon it or teach students about it, is considered a fair use. Certain well-established uses cause few problems. A teacher who prints a few copies of a poem to illustrate a technique will have no problem on all four of the above factors (except possibly on amount and substantiality), but some cases are not so clear. All the factors are considered and balanced in each case: a book reviewer who quotes a paragraph as an example of the author's style will probably fall under fair use even though they may sell their review commercially; but a non-profit educational website that reproduces whole articles from technical magazines will probably be found to infringe if the publisher can demonstrate that the website affects the market for the magazine, even though the website itself is non-commercial.


title: Fair use

text: Fair use is decided on a case-by-case basis, on the entirety of circumstances. The same act done by different means or for a different purpose can gain or lose fair use status.


title: Fair use

text: The "Oracle America, Inc. v. Google, Inc." case revolves around the use of application programming interfaces (APIs) used to define functionality of the Java programming language, created by Sun Microsystems and now owned by Oracle Corporation. Google used the APIs' definition and their structure, sequence and organization (SSO) in creating the Android operating system to support the mobile device market. Oracle had sued Google in 2010 over both patent and copyright violations, but after two cycles, the case matter was narrowed down to whether Google's use of the definition and SSO of Oracle's Java APIs (determined to be copyrightable) was within fair use. The Federal Circuit Court of Appeals has ruled against Google, stating that while Google could defend its use in the nature of the copyrighted work, its use was not transformative, and more significantly, it commercially harmed Oracle as they were also seeking entry to the mobile market. However, the U.S. Supreme Court reversed this decision, deciding that Google's actions satisfy all four tests for fair use, and that granting Oracle exclusive rights to use Java APIs on mobile markets "would interfere with, not further, copyright’s basic creativity objectives.”


title: Fair use

text: In April 2006, the filmmakers of the "Loose Change" series were served with a lawsuit by Jules and Gédéon Naudet over the film's use of their footage, specifically footage of the firefighters discussing the collapse of the World Trade Center.


title: Fair use

text: With the help of an intellectual property lawyer, the creators of Loose Change successfully argued that a majority of the footage used was for historical purposes and was significantly transformed in the context of the film. They agreed to remove a few shots that were used as B-roll and served no purpose to the greater discussion. The case was settled and a potential multimillion-dollar lawsuit was avoided.


title: Fair use

text: "This Film Is Not Yet Rated" also relied on fair use to feature several clips from copyrighted Hollywood productions. The director had originally planned to license these clips from their studio owners but discovered that studio licensing agreements would have prohibited him from using this material to criticize the entertainment industry. This prompted him to invoke the fair use doctrine, which permits limited use of copyrighted material to provide analysis and criticism of published works.


title: Fair use

text: In 2009, fair use appeared as a defense in lawsuits against filesharing. Charles Nesson argued that file-sharing qualifies as fair use in his defense of alleged filesharer Joel Tenenbaum. Kiwi Camara, defending alleged filesharer Jammie Thomas, announced a similar defense.


title: Fair use

text: A U.S. court case from 2003, "Kelly v. Arriba Soft Corp.," provides and develops the relationship between thumbnails, inline linking, and fair use. In the lower District Court case on a motion for summary judgment, Arriba Soft's use of thumbnail pictures and inline linking from Kelly's website in Arriba Soft's image search engine was found not to be fair use. That decision was appealed and contested by Internet rights activists such as the Electronic Frontier Foundation, who argued that it was fair use.


title: Fair use

text: On appeal, the Ninth Circuit Court of Appeals found in favor of the defendant, Arriba Soft. In reaching its decision, the court utilized the statutory four-factor analysis. First, it found the purpose of creating the thumbnail images as previews to be sufficiently transformative, noting that they were not meant to be viewed at high resolution as the original artwork was. Second, the photographs had already been published, diminishing the significance of their nature as creative works. Third, although normally making a "full" replication of a copyrighted work may appear to violate copyright, here it was found to be reasonable and necessary in light of the intended use. Lastly, the court found that the market for the original photographs would not be substantially diminished by the creation of the thumbnails. To the contrary, the thumbnail searches could increase the exposure of the originals. In looking at all these factors as a whole, the court found that the thumbnails were fair use and remanded the case to the lower court for trial after issuing a revised opinion on July 7, 2003. The remaining issues were resolved with a default judgment after Arriba Soft had experienced significant financial problems and failed to reach a negotiated settlement.


title: Fair use

text: In August 2008, Judge Jeremy Fogel of the Northern District of California ruled in "Lenz v. Universal Music Corp." that copyright holders cannot order a deletion of an online file without determining whether that posting reflected "fair use" of the copyrighted material. The case involved Stephanie Lenz, a writer and editor from Gallitzin, Pennsylvania, who made a home video of her thirteen-month-old son dancing to Prince's song "Let's Go Crazy" and posted the video on YouTube. Four months later, Universal Music, the owner of the copyright to the song, ordered YouTube to remove the video under the Digital Millennium Copyright Act. Lenz notified YouTube immediately that her video was within the scope of fair use, and she demanded that it be restored. YouTube complied after six weeks, rather than the two weeks required by the Digital Millennium Copyright Act. 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. On appeal, the Court of Appeals for the Ninth Circuit ruled that a copyright owner must affirmatively consider whether the complained of conduct constituted fair use before sending a takedown notice under the Digital Millennium Copyright Act, rather than waiting for the alleged infringer to assert fair use. 801 F.3d 1126 (9th Cir. 2015). "Even if, as Universal urges, fair use is classified as an 'affirmative defense,' we hold—for the purposes of the DMCA—fair use is uniquely situated in copyright law so as to be treated differently than traditional affirmative defenses. We conclude that because 17 U.S.C. § 107 created a type of non-infringing use, fair use is "authorized by the law" and a copyright holder must consider the existence of fair use before sending a takedown notification under § 512(c)."


title: Fair use

text: In June 2011, Judge Philip Pro of the District of Nevada ruled in "Righthaven v. Hoehn" that the posting of an entire editorial article from the "Las Vegas Review-Journal" in a comment as part of an online discussion was unarguably fair use. Judge Pro noted that "Noncommercial, nonprofit use is presumptively fair. ... Hoehn posted the Work as part of an online discussion. ... This purpose is consistent with comment, for which 17 U.S.C. § 107 provides fair use protection. ... It is undisputed that Hoehn posted the entire work in his comment on the Website. ... wholesale copying does not preclude a finding of fair use. ... there is no genuine issue of material fact that Hoehn's use of the Work was fair and summary judgment is appropriate." On appeal, the Court of Appeals for the Ninth Circuit ruled that Righthaven did not even have the standing needed to sue Hoehn for copyright infringement in the first place.


title: Fair use

text: In addition to considering the four fair use factors, courts deciding fair use cases also look to the standards and practices of the professional community where the case comes from. Among the communities are documentarians, librarians, makers of Open Courseware, visual art educators, and communications professors.


title: Fair use

text: Such codes of best practices have permitted communities of practice to make more informed risk assessments in employing fair use in their daily practice. For instance, broadcasters, cablecasters, and distributors typically require filmmakers to obtain errors and omissions insurance before the distributor will take on the film. Such insurance protects against errors and omissions made during the copyright clearance of material in the film. Before the "Documentary Filmmakers' Statement of Best Practices in Fair Use" was created in 2005, it was nearly impossible to obtain errors and omissions insurance for copyright clearance work that relied in part on fair use. This meant documentarians had either to obtain a license for the material or to cut it from their films. In many cases, it was impossible to license the material because the filmmaker sought to use it in a critical way. Soon after the best practices statement was released, all errors and omissions insurers in the U.S. shifted to begin offering routine fair use coverage.


title: Fair use

text: Before 1991, sampling in certain genres of music was accepted practice and the copyright considerations were viewed as largely irrelevant. The strict decision against rapper Biz Markie's appropriation of a Gilbert O'Sullivan song in the case "Grand Upright Music, Ltd. v. Warner Bros. Records Inc." changed practices and opinions overnight. Samples now had to be licensed, as long as they rose "to a level of legally cognizable appropriation." This left the door open for the "de minimis" doctrine, for short or unrecognizable samples; such uses would not rise to the level of copyright infringement, because under the "de minimis" doctrine, "the law does not care about trifles." However, three years later, the Sixth Circuit effectively eliminated the "de minimis" doctrine in the "Bridgeport Music, Inc. v. Dimension Films" case, holding that artists must "get a license or do not sample". The Court later clarified that its opinion did not apply to fair use, but between "Grand Upright" and "Bridgeport", practice had effectively shifted to eliminate unlicensed sampling.


title: Fair use

text: Producers or creators of parodies of a copyrighted work have been sued for infringement by the targets of their ridicule, even though such use may be protected as fair use. These fair use cases distinguish between parodies, which use a work in order to poke fun at or comment on the work itself, and satire, which comments on something else. Courts have been more willing to grant fair use protections to parodies than to satires, but the ultimate outcome in either circumstance will turn on the application of the four fair use factors.


title: Fair use

text: For example, when Tom Forsythe appropriated Barbie dolls for his photography project "Food Chain Barbie" (depicting several copies of the doll naked and disheveled and about to be baked in an oven, blended in a food mixer, and the like), Mattel lost its copyright infringement lawsuit against him because his work effectively parodies Barbie and the values she represents. In "Rogers v. Koons", Jeff Koons tried to justify his appropriation of Art Rogers' photograph "Puppies" in his sculpture "String of Puppies" with the same parody defense. Koons lost because his work was not presented as a parody of Rogers' photograph in particular, but as a satire of society at large. This was insufficient to render the use fair.


title: Fair use

text: In "Campbell v. Acuff-Rose Music Inc" the U.S. Supreme Court recognized parody as a potential fair use, even when done for profit. Roy Orbison's, Acuff-Rose Music, had sued 2 Live Crew in 1989 for their use of Orbison's "Oh, Pretty Woman" in a mocking rap version with altered lyrics. The Supreme Court viewed 2 Live Crew's version as a ridiculing commentary on the earlier work, and ruled that when the parody was itself the product rather than mere advertising, commercial nature did not bar the defense. The "Campbell" court also distinguished parodies from satire, which they described as a broader social critique not intrinsically tied to ridicule of a specific work and so not deserving of the same use exceptions as parody because the satirist's ideas are capable of expression without the use of the other particular work.


title: Fair use

text: A number of appellate decisions have recognized that a parody may be a protected fair use, including the Second ("Leibovitz v. Paramount Pictures Corp."); the Ninth ("Mattel v. Walking Mountain Productions"); and the Eleventh Circuits ("Suntrust Bank v. Houghton Mifflin Co."). In the 2001 "Suntrust Bank" case, Suntrust Bank and the Margaret Mitchell estate unsuccessfully brought suit to halt the publication of "The Wind Done Gone", which reused many of the characters and situations from "Gone with the Wind" but told the events from the point of view of the enslaved people rather than the slaveholders. The Eleventh Circuit, applying "Campbell", found that "The Wind Done Gone" was fair use and vacated the district court's injunction against its publication.


title: Fair use

text: Cases in which a satirical use was found to be fair include "Blanch v. Koons" and "Williams v. Columbia Broadcasting Systems".


title: Fair use

text: The transformative nature of computer based analytical processes such as text mining, web mining and data mining has led many to form the view that such uses would be protected under fair use. This view was substantiated by the rulings of Judge Denny Chin in "Authors Guild, Inc. v. Google, Inc.", a case involving mass digitisation of millions of books from research library collections. As part of the ruling that found the book digitisation project was fair use, the judge stated "Google Books is also transformative in the sense that it has transformed book text into data for purposes of substantive research, including data mining and text mining in new areas".


title: Fair use

text: Text and data mining was subject to further review in "Authors Guild v. HathiTrust", a case derived from the same digitization project mentioned above. Judge Harold Baer, in finding that the defendant's uses were transformative, stated that 'the search capabilities of the [HathiTrust Digital Library] have already given rise to new methods of academic inquiry such as text mining."


title: Fair use

text: There is a substantial body of fair use law regarding reverse engineering of computer software, hardware, network protocols, encryption and access control systems.


title: Fair use

text: In May 2015, artist Richard Prince released an exhibit of photographs at the Gagosian Gallery in New York, entitled "New Portraits". His exhibit consisted of screenshots of Instagram users' pictures, which were largely unaltered, with Prince's commentary added beneath. Although no Instagram users authorized Prince to use their pictures, Prince argued that the addition of his own commentary the pictures constituted fair use, such that he did not need permission to use the pictures or to pay royalties for his use. One of the pieces sold for $90,000. With regard to the works presented by Painter, the gallery where the pictures were showcased posted notices that "All images are subject to copyright." Several lawsuits were filed against Painter over the New Portraits exhibit.


title: Fair use

text: While U.S. fair use law has been influential in some countries, some countries have fair use criteria drastically different from those in the U.S., and some countries do not have a fair use framework at all. Some countries have the concept of fair dealing instead of fair use, while others use different systems of limitations and exceptions to copyright. Many countries have some reference to an exemption for educational use, though the extent of this exemption varies widely.


title: Fair use

text: Sources differ on whether fair use is fully recognized by countries other than the United States. American University's "infojustice.org" published a compilation of portions of over 40 nations' laws that explicitly mention fair use or fair dealing, and asserts that some of the fair dealing laws, such as Canada's, have evolved (such as through judicial precedents) to be quite close to those of the United States. This compilation includes fair use provisions from Bangladesh, Israel, South Korea, the Philippines, Sri Lanka, Taiwan, Uganda, and the United States. However, Paul Geller's 2009 "International Copyright Law and Practice" says that while some other countries recognize similar exceptions to copyright, only the United States and Israel fully recognize the concept of fair use.


title: Fair use

text: The International Intellectual Property Alliance (IIPA), a lobby group of U.S. copyright industry bodies, has objected to international adoption of U.S.-style fair use exceptions, alleging that such laws have a dependency on common law and long-term legal precedent that may not exist outside the United States.


title: Fair use

text: In November 2007, the Israeli Knesset passed a new copyright law that included a U.S.-style fair use exception. The law, which took effect in May 2008, permits the fair use of copyrighted works for purposes such as private study, research, criticism, review, news reporting, quotation, or instruction or testing by an educational institution. The law sets up four factors, similar to the U.S. fair use factors (see above), for determining whether a use is fair.


title: Fair use

text: On September 2, 2009, the Tel Aviv District court ruled in "The Football Association Premier League Ltd. v. Ploni" that fair use is a user right. The court also ruled that streaming of live soccer games on the Internet is fair use. In doing so, the court analyzed the four fair use factors adopted in 2007 and cited U.S. case law, including "Kelly v. Arriba Soft Corp." and "Perfect 10, Inc. v. Amazon.com, Inc.".


title: Fair use

text: An amendment in 2012 to the section 13(2)(a) of the Copyright Act 1987 created an exception called 'fair dealing' which is not restricted in its purpose. The four factors for fair use as specified in US law are included.


title: Fair use

text: Compared to the United States, Polish fair use distinguishes between private and public use. In Poland, when the use is public, its use risks fines. The defendant must also prove that his use was private when accused that it was not, or that other mitigating circumstances apply. Finally, Polish law treats all cases in which private material was made public as a potential copyright infringement, where fair use can apply, but has to be proven by reasonable circumstances.


title: Fair use

text: Section 35 of the Singaporean Copyright Act 1987 has been amended in 2004 to allow a 'fair dealing' exception for any purpose. The four fair use factors similar to US law are included in the new section 35.


title: Fair use

text: The Korean Copyright Act was amended to include a fair use provision, Article 35–3, in 2012. The law outlines a four-factor test similar to that used under U.S. law:


title: Fair use

text: Fair dealing allows specific exceptions to copyright protections. The open-ended concept of fair use is generally not observed in jurisdictions where fair dealing is in place, although this does vary. Fair dealing is established in legislation in Australia, Canada, New Zealand, Singapore, India, South Africa and the United Kingdom, among others.


title: Fair use

text: While Australian copyright exceptions are based on the Fair Dealing system, since 1998 a series of Australian government inquiries have examined, and in most cases recommended, the introduction of a "flexible and open" Fair Use system into Australian copyright law. From 1998 to 2017 there have been eight Australian government inquiries which have considered the question of whether fair use should be adopted in Australia. Six reviews have recommended Australia adopt a "Fair Use" model of copyright exceptions: two enquiries specifically into the Copyright Act (1998, 2014); and four broader reviews (both 2004, 2013, 2016). One review (2000) recommended against the introduction of fair use and another (2005) issued no final report. Two of the recommendations were specifically in response to the stricter copyright rules introduced as part of the Australia–United States Free Trade Agreement (AUSFTA), while the most recent two, by the Australian Law Reform Commission (ALRC) and the Productivity Commission (PC) were with reference to strengthening Australia's "digital economy".


title: Fair use

text: The "Copyright Act of Canada" establishes fair dealing in Canada, which allows specific exceptions to copyright protection. In 1985, the Sub-Committee on the Revision of Copyright rejected replacing fair dealing with an open-ended system, and in 1986 the Canadian government agreed that "the present fair dealing provisions should not be replaced by the substantially wider 'fair use' concept". Since then, the Canadian fair dealing exception has broadened. It is now similar in effect to U.S. fair use, even though the frameworks are different.


title: Fair use

text: "CCH Canadian Ltd v. Law Society of Upper Canada" [2004] 1 S.C.R. 339, is a landmark Supreme Court of Canada case that establishes the bounds of fair dealing in Canadian copyright law. The Law Society of Upper Canada was sued for copyright infringement for providing photocopy services to researchers. The Court unanimously held that the Law Society's practice fell within the bounds of fair dealing.


title: Fair use

text: Within the United Kingdom, fair dealing is a legal doctrine that provides an exception to the nation's copyright law in cases where the copyright infringement is for the purposes of non-commercial research or study, criticism or review, or for the reporting of current events.


title: Fair use

text: A balanced copyright law provides an economic benefit to many high-tech businesses such as search engines and software developers. Fair use is also crucial to non-technology industries such as insurance, legal services, and newspaper publishers.


title: Fair use

text: On September 12, 2007, the Computer and Communications Industry Association (CCIA), a group representing companies including Google Inc., Microsoft Inc., Oracle Corporation, Sun Microsystems, Yahoo! and other high-tech companies, released a study that found that fair use exceptions to US copyright laws were responsible for more than $4.5 trillion in annual revenue for the United States economy representing one-sixth of the total US GDP. The study was conducted using a methodology developed by the World Intellectual Property Organization.


title: Fair use

text: The study found that fair use dependent industries are directly responsible for more than eighteen percent of US economic growth and nearly eleven million American jobs. "As the United States economy becomes increasingly knowledge-based, the concept of fair use can no longer be discussed and legislated in the abstract. It is the very foundation of the digital age and a cornerstone of our economy," said Ed Black, President and CEO of CCIA. "Much of the unprecedented economic growth of the past ten years can actually be credited to the doctrine of fair use, as the Internet itself depends on the ability to use content in a limited and unlicensed manner."


title: Fair use

text: Fair Use Week is an international event that celebrates fair use and fair dealing. Fair Use Week was first proposed on a Fair Use Allies listserv, which was an outgrowth of the Library Code of Best Practices Capstone Event, celebrating the development and promulgation of ARL's "Code of Best Practices in Fair Use for Academic and Research Libraries". While the idea was not taken up nationally, Copyright Advisor at Harvard University, launched the first ever Fair Use Week at Harvard University in February 2014, with a full week of activities celebrating fair use. The first Fair Use Week included blog posts from national and international fair use experts, live fair use panels, fair use workshops, and a Fair Use Stories Tumblr blog, where people from the world of art, music, film, and academia shared stories about the importance of fair use to their community. The first Fair Use Week was so successful that in 2015 ARL teamed up with Courtney and helped organize the Second Annual Fair Use Week, with participation from many more institutions. ARL also launched an official Fair Use Week website, which was transferred from Pia Hunter, who attended the Library Code of Best Practices Capstone Event and had originally purchased the domain name fairuseweek.org.


title: The Daily Telegraph

text: The Daily Telegraph, known online and elsewhere as The Telegraph, is a national British daily broadsheet newspaper published in London by Telegraph Media Group and distributed across the United Kingdom and internationally.


title: The Daily Telegraph

text: It was founded by Arthur B. Sleigh in 1855 as "The Daily Telegraph & Courier". Considered a newspaper of record over "The Times" in the UK in the years up to 1997, "The Telegraph" generally has a reputation for high-quality journalism, and has been described as being "one of the world's great titles".


title: The Daily Telegraph

text: The paper's motto, "Was, is, and will be", appears in the editorial pages and has featured in every edition of the newspaper since 19 April 1858. The paper had a circulation of 363,183 in December 2018, descending further until it withdrew from newspaper circulation audits in 2019, having declined almost 80%, from 1.4 million in 1980. Its sister paper, "The Sunday Telegraph", which started in 1961, had a circulation of 281,025 as of December 2018. The two sister newspapers are run separately, with different editorial staff, but there is cross-usage of stories.


title: The Daily Telegraph

text: "The Telegraph" has had a number of news scoops, including the outbreak of World War II by rookie reporter Clare Hollingworth, described as "the scoop of the century", the 2009 MP expenses scandalwhich led to a number of high-profile political resignations and for which it was named 2009 British Newspaper of the Yearand its 2016 undercover investigation on the England football manager Sam Allardyce.


title: The Daily Telegraph

text: The "Daily Telegraph and Courier" was founded by Colonel Arthur B. Sleigh in June 1855 to air a personal grievance against the future commander-in-chief of the British Army, Prince George, Duke of Cambridge. Joseph Moses Levy, the owner of "The Sunday Times", agreed to print the newspaper, and the first edition was published on 29 June 1855. The paper cost 2d and was four pages long. Nevertheless, the first edition stressed the quality and independence of its articles and journalists:


title: The Daily Telegraph

text: However, the paper was not a success, and Sleigh was unable to pay Levy the printing bill. Levy took over the newspaper, his aim being to produce a cheaper newspaper than his main competitors in London, the "Daily News" and "The Morning Post", to expand the size of the overall market. Levy appointed his son, Edward Levy-Lawson, Lord Burnham, and Thornton Leigh Hunt to edit the newspaper. Lord Burnham relaunched the paper as "The Daily Telegraph", with the slogan "the largest, best, and cheapest newspaper in the world". Hunt laid out the newspaper's principles in a memorandum sent to Levy: "We should report all striking events in science, so told that the intelligent public can understand what has happened and can see its bearing on our daily life and our future. The same principle should apply to all other events—to fashion, to new inventions, to new methods of conducting business".


title: The Daily Telegraph

text: In 1876, Jules Verne published his novel "Michael Strogoff", whose plot takes place during a fictional uprising and war in Siberia. Verne included among the book's characters a war correspondent of "The Daily Telegraph", named Harry Blount—who is depicted as an exceptionally dedicated, resourceful and brave journalist, taking great personal risks to follow closely the ongoing war and bring accurate news of it to "The Telegraph"s readership, ahead of competing papers.


title: The Daily Telegraph

text: In 1908, Kaiser Wilhelm II of Germany gave a controversial interview to "The Daily Telegraph" that severely damaged Anglo-German relations and added to international tensions in the build-up to World War I. In 1928, the son of Baron Burnham, Harry Lawson Webster Levy-Lawson, 2nd Baron Burnham, sold the paper to William Berry, 1st Viscount Camrose, in partnership with his brother Gomer Berry, 1st Viscount Kemsley and Edward Iliffe, 1st Baron Iliffe.


title: The Daily Telegraph

text: In 1937, the newspaper absorbed "The Morning Post", which traditionally espoused a conservative position and sold predominantly amongst the retired officer class. Originally William Ewart Berry, 1st Viscount Camrose, bought "The Morning Post" with the intention of publishing it alongside "The Daily Telegraph", but poor sales of the former led him to merge the two. For some years, the paper was retitled "The Daily Telegraph and Morning Post" before it reverted to just "The Daily Telegraph". In the late 1930s, Victor Gordon Lennox, "The Telegraph"s diplomatic editor, published an anti-appeasement private newspaper "The Whitehall Letter" that received much of its information from leaks from Sir Robert Vansittart, the Permanent Under-Secretary of the Foreign Office, and Rex Leeper, the Foreign Office's Press Secretary. As a result, Gordon Lennox was monitored by MI5. In 1939, The Telegraph published Clare Hollingworth's scoop that Germany was to invade Poland.


title: The Daily Telegraph

text: In November 1940, Fleet Street, with its close proximity to the river and docklands, was subjected to almost daily bombing raids by the Luftwaffe and "The Telegraph" started printing in Manchester at Kemsley House (now The Printworks entertainment venue), which was run by Camrose's brother Kemsley. Manchester quite often printed the entire run of "The Telegraph" when its Fleet Street offices were under threat. The name Kemsley House was changed to Thomson House in 1959. In 1986, printing of Northern editions of the "Daily" and "Sunday Telegraph" moved to Trafford Park and in 2008 to Newsprinters at Knowsley, Liverpool.


title: The Daily Telegraph

text: During the Second World War, "The Daily Telegraph" covertly helped in the recruitment of code-breakers for Bletchley Park. The ability to solve "The Telegraph"s crossword in under 12 minutes was considered to be a recruitment test. The newspaper was asked to organise a crossword competition, after which each of the successful participants was contacted and asked if they would be prepared to undertake "a particular type of work as a contribution to the war effort". The competition itself was won by F. H. W. Hawes of Dagenham who finished the crossword in less than eight minutes.


title: The Daily Telegraph

text: Both the Camrose (Berry) and Burnham (Levy-Lawson) families remained involved in management until Conrad Black took control in 1986. On the death of his father in 1954, Seymour Berry, 2nd Viscount Camrose assumed the chairmanship of the "Daily Telegraph" with his brother Michael Berry, Baron Hartwell as his editor-in-chief. During this period, the company saw the launch of sister paper "The Sunday Telegraph" in 1960.


title: The Daily Telegraph

text: Canadian businessman Conrad Black, through companies controlled by him, bought the Telegraph Group in 1986. Black, through his holding company Ravelston Corporation, owned 78% of Hollinger Inc. which in turn owned 30% of Hollinger International. Hollinger International in turn owned the Telegraph Group and other publications such as the "Chicago Sun-Times", the "Jerusalem Post" and "The Spectator".


title: The Daily Telegraph

text: On 18 January 2004, Black was dismissed as chairman of the Hollinger International board over allegations of financial wrongdoing. Black was also sued by the company. Later that day, it was reported that the Barclay brothers had agreed to purchase Black's 78% interest in Hollinger Inc. for £245m, giving them a controlling interest in the company, and to buy out the minority shareholders later. However, a lawsuit was filed by the Hollinger International board to try to block Black from selling his shares in Hollinger Inc. until an investigation into his dealings was completed. Black filed a countersuit but, eventually, United States judge Leo Strine sided with the Hollinger International board and blocked Black from selling his Hollinger Inc. shares to the twins.


title: The Daily Telegraph

text: On 7 March 2004, the twins announced that they were launching another bid, this time just for "The Daily Telegraph" and its Sunday sister paper rather than all of Hollinger Inc. The then owner of the "Daily Express", Richard Desmond, was also interested in purchasing the paper, selling his interest in several pornographic magazines to finance the initiative. Desmond withdrew in March 2004, when the price climbed above £600m, as did Daily Mail and General Trust plc a few months later on 17 June.


title: The Daily Telegraph

text: In November 2004, "The Telegraph" celebrated the tenth anniversary of its website, "Electronic Telegraph", now renamed "www.telegraph.co.uk". The "Electronic Telegraph" launched in 1995 with The Daily Telegraph Guide to the Internet' by writer Sue Schofield for an annual charge of £180.00. On 8 May 2006, the first stage of a major redesign of the website took place, with a wider page layout and greater prominence for audio, video and journalist blogs.


title: The Daily Telegraph

text: On 10 October 2005, "The Daily Telegraph" relaunched to incorporate a tabloid sports section and a new standalone business section. "The Daily Mail"s star columnist and political analyst Simon Heffer left that paper in October 2005 to rejoin "The Daily Telegraph", where he has become associate editor. Heffer has written two columns a week for the paper since late October 2005 and is a regular contributor to the news podcast. In November 2005 the first regular podcast service by a newspaper in the UK was launched. Just before Christmas 2005, it was announced that "The Telegraph" titles would be moving from Canada Place in Canary Wharf, to new offices at Victoria Plaza at 111 Buckingham Palace Road near Victoria Station in central London. The new office features a "hub and spoke" layout for the newsroom to produce content for print and online editions.


title: The Daily Telegraph

text: In October 2006, with its relocation to Victoria, the company was renamed the Telegraph Media Group, repositioning itself as a multimedia company. On 2 September 2008, the "Daily Telegraph" was printed with colour on each page for the first time when it left Westferry for Newsprinters at Broxbourne, Hertfordshire, another arm of the Murdoch (Rupert Murdoch) company. The paper is also printed in Liverpool and Glasgow by Newsprinters. In May 2009, the daily and Sunday editions published details of MPs' expenses. This led to a number of high-profile resignations from both the ruling Labour administration and the Conservative opposition.


title: The Daily Telegraph

text: In June 2014, "The Telegraph" was criticised by "Private Eye" for its policy of replacing experienced journalists and news managers with less-experienced staff and search engine optimisers.


title: The Daily Telegraph

text: On 26 October 2019, the "Financial Times" reported that the Barclay Brothers were about to put the Telegraph Media Group up for sale. The "Financial Times" also reported that the Daily Mail and General Trust (owner of the "Daily Mail", "The Mail on Sunday", "Metro" and "Ireland on Sunday") would be interested in buying.


title: The Daily Telegraph

text: "The Daily Telegraph" supported Liz Truss in the July–September 2022 Conservative Party leadership election.


title: The Daily Telegraph

text: "The Daily Telegraph" is politically conservative and has endorsed the Conservative Party at every UK general election since 1945. The personal links between the paper's editors and the leadership of the Conservative Party, along with the paper's generally right-wing stance and influence over Conservative activists, have led the paper commonly to be referred to, especially in "Private Eye", as the "Torygraph". Even when Conservative support was shown to have slumped in the opinion polls and Labour gained the ascendant, the newspaper remained loyal to the Conservatives. This loyalty continued after Labour ousted the Conservatives from power by an election result in 1997, and in the face of Labour election wins in 2001 and the third successive Labour election win in 2005.


title: The Daily Telegraph

text: When the Barclay brothers purchased the Telegraph Group for around £665m in late June 2004, Sir David Barclay suggested that "The Daily Telegraph" might no longer be the "house newspaper" of the Conservatives in the future. In an interview with "The Guardian" he said, "Where the government are right we shall support them". The editorial board endorsed the Conservative Party in the 2005 general election.


title: The Daily Telegraph

text: During the 2014 Scottish independence referendum, the paper supported the Better Together 'No' Campaign. Alex Salmond, the former leader of the SNP, called "The Telegraph" "extreme" on "Question Time" in September 2015.


title: The Daily Telegraph

text: During the 2019 Conservative leadership election, "The Daily Telegraph" endorsed their former columnist Boris Johnson. In 2019, former columnist Graham Norton, who had left the paper in late 2018, said "about a year before I left, it took a turn" and criticised it for "toxic" political stances, namely for a piece defending US Supreme Court then-nominee Brett Kavanaugh and for being "a mouthpiece for Boris Johnson" whose columns were allegedly published with "no fact-checking at all".


title: The Daily Telegraph

text: It was fined £30,000 in 2015 for "sending an unsolicited email to hundreds of thousands of its subscribers, urging them to vote for the Conservatives."


title: The Daily Telegraph

text: In 2012, prior to the legalisation of same-sex marriage in the United Kingdom, Telegraph View published an editorial stating that it was a "pointless distraction" as "many [gay couples] already avail themselves of the civil partnerships introduced by Labour". "The Telegraph" wrote in another editorial that same year that it feared that changing "the law on gay marriage risks inflaming anti-homosexual bigotry".


title: The Daily Telegraph

text: In 2015, the newspaper published an article by former editor Charles Moore claiming a "gay rights sharia" was dictating what the LGBT+ community should believe following Dolce & Gabbana's openly gay founders criticising gay adoptions. Moore wrote that "If you are gay, Mr Strudwick seemed to assert, there are certain things you must believe. Nothing else is permitted under the gay rights sharia." Moore has previously expressed his views that civil partnerships achieved a "balance" for heterosexual and homosexual couples. In 2013, he wrote that "Respectable people are truly terrified of being thought anti-homosexual. In a way, they are right to be, because attacking people for their personal preferences can be a nasty thing."


title: The Daily Telegraph

text: Also in 2015, "The Telegraph" published its "Out at Work" list, naming "the top 50 list of LGBT executives".


title: The Daily Telegraph

text: Since then, "The Telegraph" appeared to shift towards a more liberal attitude on LGBT+ issues, publishing articles that then-Prime Minister Theresa May needed to be "serious about LGBT equality" and that "bathroom bills" in Texas – which were criticised as being transphobic – were "a Kafkaesque state intrusion". The newspaper also featured an article written by Maria Munir about their experience coming out to President Barack Obama as non-binary. Stonewall CEO Ruth Hunt penned an article in "The Telegraph" after the Orlando nightclub shooting in June 2016 that the attack on a gay nightclub "grew out of everyday homophobia".


title: The Daily Telegraph

text: Also in 2016, Telegraph Executive Director Lord Black was awarded Peer of the Year at the 2016 PinkNews Awards for his campaigning on LGBT rights.


title: The Daily Telegraph

text: "The Telegraph" has published articles which have been criticised by "PinkNews" as transphobic. In 2017, the newspaper published an article by Allison Pearson titled: "Will our spineless politicians' love affair with LGBT ever end?", arguing that NHS patients' being asked their sexual orientation was unnecessary and another in 2018 with the headline: "The tyranny of the transgender minority has got to be stopped".


title: The Daily Telegraph

text: "The Daily Telegraph"s sister Sunday paper was founded in 1961. The writer Sir Peregrine Worsthorne is probably the best known journalist associated with the title (1961–1997), eventually being editor for three years from 1986. In 1989, the Sunday title was briefly merged into a seven-day operation under Max Hastings's overall control. In 2005, the paper was revamped, with Stella being added to the more traditional television and radio section. It costs £2.20 and includes separate Money, Living, Sport and Business supplements.


title: The Daily Telegraph

text: "The Young Telegraph" was a weekly section of "The Daily Telegraph" published as a 14-page supplement in the weekend edition of the newspaper. "The Young Telegraph" featured a mixture of news, features, cartoon strips and product reviews aimed at 8–12-year-olds. It was edited by Damien Kelleher (1993–1997) and Kitty Melrose (1997–1999). Launched in 1990, the award-winning supplement also ran original serialised stories featuring popular brands such as "Young Indiana Jones" and the British children's sitcom "Maid Marian and Her Merry Men".


title: The Daily Telegraph

text: In 1995, an interactive spin-off called "Electronic Young Telegraph" was launched on floppy disk. Described as an interactive computer magazine for children, "Electronic Young Telegraph" was edited by Adam Tanswell, who led the relaunch of the product on CD-Rom in 1998. "Electronic Young Telegraph" featured original content including interactive quizzes, informative features and computer games, as well as entertainment news and reviews. It was later re-branded as "T:Drive" in 1999.


title: The Daily Telegraph

text: Telegraph.co.uk is the online version of the newspaper. It uses the banner title "The Telegraph" and includes articles from the print editions of "The Daily Telegraph" and "The Sunday Telegraph", as well as web-only content such as breaking news, features, picture galleries and blogs. It was named UK Consumer Website of the Year in 2007 and Digital Publisher of the year in 2009 by the Association of Online Publishers. The site is overseen by Kate Day, digital director of Telegraph Media Group. Other staff include Shane Richmond, head of technology (editorial), and Ian Douglas, head of digital production. The site, which has been the focus of the group's efforts to create an integrated news operation producing content for print and online from the same newsroom, completed a relaunch during 2008 involving the use of the Escenic content management system, popular among northern European and Scandinavian newspaper groups. Telegraph TV is a Video on Demand service run by "The Daily Telegraph" and the "Sunday Telegraph". It is hosted on "The Telegraph"s website, telegraph.co.uk.


title: The Daily Telegraph

text: Telegraph.co.uk became the most popular UK newspaper site in April 2008. It was overtaken by Guardian.co.uk in April 2009 and later by "Mail Online". As of December 2010, "Telegraph.co.uk" was the third most visited British newspaper website with 1.7 million daily browsers compared to 2.3 million for "Guardian.co.uk" and nearly 3 million for "Mail Online".


title: The Daily Telegraph

text: In November 2012, international customers accessing the Telegraph.co.uk site would have to sign up for a subscription package. Visitors had access to 20 free articles a month before having to subscribe for unlimited access. In March 2013, the pay meter system was also rolled out in the UK.


title: The Daily Telegraph

text: The website was launched, under the name "electronic telegraph" at midday on 15 November 1994 at the headquarters of "The Daily Telegraph" at Canary Wharf in London Docklands with Ben Rooney as its first editor. It was Europe's first daily web-based newspaper. At this time, the modern internet was still in its infancy, with as few as 10,000 websites estimated to have existed at the time – compared to more than 100 billion by 2009. In 1994, only around 1% of the British population (some 600,000 people) had internet access at home, compared to more than 80% in 2009.


title: The Daily Telegraph

text: Initially, the site published only the top stories from the print edition of the newspaper but it gradually increased its coverage until virtually all of the newspaper was carried online and the website was also publishing original material. The website, hosted on a Sun Microsystems Sparc 20 server and connected via a 64 kbit/s leased line from Demon Internet, was edited by Ben Rooney. Key personnel behind the launch of the site were Matthew Doull and Saul Klein and the then marketing manager of "The Daily Telegraph", Hugo Drayton, and the webmaster Fiona Carter. Drayton later became managing director of the newspaper.


title: The Daily Telegraph

text: An early coup for the site was the publication of articles by Ambrose Evans-Pritchard on Bill Clinton and the Whitewater controversy. The availability of the articles online brought a large American audience to the site. In 1997, the Clinton administration issued a 331-page report that accused Evans-Pritchard of peddling "right-wing inventions". Derek Bishton, who by then had succeeded Rooney as editor, later wrote: "In the days before ET it would have been highly unlikely that anyone in the US would have been aware of Evans-Pritchard's work – and certainly not to the extent that the White House would be forced to issue such a lengthy rebuttal." Bishton, who later became consulting editor for Telegraph Media Group, was followed as editor by Richard Burton, who was made redundant in August 2006. Edward Roussel replaced Burton.


title: The Daily Telegraph

text: "My Telegraph" offers a platform for readers to have their own blog, save articles, and network with other readers. Launched in May 2007, My Telegraph won a Cross Media Award from international newspaper organisation IFRA in October 2007. One of the judges, Robert Cauthorn, described the project as "the best deployment of blogging yet seen in any newspaper anywhere in the world".


title: The Daily Telegraph

text: In December 2010, "Telegraph" reporters posing as constituents secretly recorded Business Secretary Vince Cable. In an undisclosed part of the transcript given to the BBC's Robert Peston by a whistleblower unhappy that "The Telegraph" had not published Cable's comments in full, Cable stated in reference to Rupert Murdoch's News Corporation takeover bid for BSkyB, "I have declared war on Mr Murdoch and I think we are going to win." Following this revelation, Cable had his responsibility for media affairs – including ruling on Murdoch's takeover plans – withdrawn from his role as business secretary.


title: The Daily Telegraph

text: In May 2011, the Press Complaints Commission upheld a complaint regarding "The Telegraph"s use of subterfuge: "On this occasion, the commission was not convinced that the public interest was such as to justify proportionately this level of subterfuge." In July 2011, a firm of private investigators hired by "The Telegraph" to track the source of the leak concluded "strong suspicion" that two former Telegraph employees who had moved to News International, one of them Will Lewis, had gained access to the transcript and audio files and leaked them to Peston.


title: The Daily Telegraph

text: In May 2009, "The Daily Telegraph" obtained a full copy of all the expenses claims of British Members of Parliament. The "Telegraph" began publishing, in instalments from 8 May 2009, certain MPs' expenses.


title: The Daily Telegraph

text: The "Telegraph" justified the publication of the information because it contended that the official information due to be released would have omitted key information about redesignating of second-home nominations. This led to a number of high-profile resignations from both the ruling Labour administration and the Conservative opposition.


title: The Daily Telegraph

text: In September 2016, "Telegraph" reporters posing as businessmen filmed England manager Sam Allardyce, offering to give advice on how to get around on FA rules on player third party ownership and negotiating a £400,000 deal. The investigation saw Allardyce leave his job by mutual consent on 27 September and making the statement "entrapment has won".


title: The Daily Telegraph

text: "The Daily Telegraph" has been named the "National Newspaper of the Year" in 2009, 1996 and 1993, while "The Sunday Telegraph" won the same award in 1999.


title: The Daily Telegraph

text: Its investigation on the 2009 expenses scandal was named the "Scoop of the Year" in 2009, with William Lewis winning "Journalist of the Year". The "Telegraph" won "Team of the Year" in 2004 for its coverage of the Iraq War. The paper also won "Columnist of the Year" three years' running from 2002 to 2004: Zoë Heller (2002), Robert Harris (2003) and Boris Johnson (2004).


title: The Daily Telegraph

text: In 1979, following a letter in "The Daily Telegraph" and a Government report highlighting the shortfall in care available for premature babies, Bliss, the special care baby charity, was founded. In 2009, as part of the Bliss 30th birthday celebrations, the charity was chosen as one of four beneficiaries of the newspaper's Christmas Charity Appeal. In February 2010, a cheque was presented to Bliss for £120,000.


title: The Daily Telegraph

text: In 2014, "The Telegraph" designed a Newspaper-themed Paddington Bear statue, one of fifty located around London prior to the release of the film "Paddington", which was auctioned to raise funds for the National Society for the Prevention of Cruelty to Children (NSPCC).


title: The Daily Telegraph

text: In July 2014, the "Daily Telegraph" was criticised for carrying links on its website to pro-Kremlin articles supplied by a Russian state-funded publication that downplayed any Russian involvement in the downing of the passenger jet Malaysia Airlines Flight 17. These had featured on its website as part of a commercial deal, but were later removed. The paper is paid £900,000 a year to include the supplement "Russia Beyond the Headlines", a publication sponsored by the "Rossiyskaya Gazeta", the Russian government's official newspaper. It is paid a further £750,000 a year for a similar arrangement with the Chinese state in relation to the pro-Beijing "China Watch" advertising supplement.


title: The Daily Telegraph

text: In February 2015, the chief political commentator of the "Daily Telegraph", Peter Oborne, resigned. Oborne accused the paper of a "form of fraud on its readers" for its coverage of the bank HSBC in relation to a Swiss tax-dodging scandal that was widely covered by other news media. He alleged that editorial decisions about news content had been heavily influenced by the advertising arm of the newspaper because of commercial interests. Professor Jay Rosen at New York University stated that Oborne's resignation statement was "one of the most important things a journalist has written about journalism lately".


title: The Daily Telegraph

text: Oborne cited other instances of advertising strategy influencing the content of articles, linking the refusal to take an editorial stance on the repression of democratic demonstrations in Hong Kong to the "Telegraph" support from China. Additionally, he said that favourable reviews of the Cunard cruise liner "Queen Mary II" appeared in the "Telegraph", noting: "On 10 May last year "The Telegraph" ran a long feature on Cunard's Queen Mary II liner on the news review page. This episode looked to many like a plug for an advertiser on a page normally dedicated to serious news analysis. I again checked and certainly "Telegraph" competitors did not view Cunard's liner as a major news story. Cunard is an important "Telegraph" advertiser."


title: The Daily Telegraph

text: In response, the "Telegraph" called Oborne's statement an "astonishing and unfounded attack, full of inaccuracy and innuendo". Later that month, "Telegraph" editor Chris Evans invited journalists at the newspaper to contribute their thoughts on the issue. "Press Gazette" reported later in 2015 that Oborne had joined the "Daily Mail" tabloid newspaper and "The Telegraph" had "issued new guidelines over the way editorial and commercial staff work together".


title: The Daily Telegraph

text: In January 2017, the Telegraph Media Group had a higher number of upheld complaints than any other UK newspaper by its regulator IPSO. Most of these findings pertained to inaccuracy, as with other UK newspapers.


title: The Daily Telegraph

text: In October 2017, a number of major western news organisations whose coverage had irked Beijing were excluded from Xi Jinping's speech event launching a new politburo. However, the "Daily Telegraph" had been granted an invitation to the event.


title: The Daily Telegraph

text: In April 2019, "Business Insider" reported "The Telegraph" had partnered with Facebook to publish articles "downplaying 'technofears' and praising the company".


title: The Daily Telegraph

text: The paper published premature obituaries for Cockie Hoogterp, the second wife of Baron Blixen, Dave Swarbrick in 1999, and Dorothy Southworth Ritter, the widow of Tex Ritter and mother of John Ritter, in August 2001.


title: The Daily Telegraph

text: Editors for both the "Daily Telegraph" and the "Sunday Telegraph" have been criticised by "Guardian" columnist Owen Jones for publishing and authoring articles which espouse an anti-Semitic conspiracy theory. In 2018, Allister Heath, the editor of the "Sunday Telegraph" wrote that "Cultural Marxism is running rampant." Assistant comment editor of the "Daily Telegraph", Sherelle Jacobs, also used the term in 2019. "The Daily Telegraph" also published an anonymous civil servant who stated: "There is a strong presence of Anglophobia, combined with cultural Marxism that runs through the civil service."


title: The Daily Telegraph

text: In January 2019, the paper published an article written by Camilla Tominey titled "Police called in after Scout group run from mosque is linked to Islamic extremist and Holocaust denier" in which it was reported that the police were investigating Ahammed Hussain, the Leader of the Scout Group at the Lewisham Islamic Centre, because he had links to extremist Muslim groups that promoted terrorism and antisemitism.


title: The Daily Telegraph

text: In January 2020, the paper issued an official apology and accepted that the article contained many falsehoods, and that Hussain had never supported or promoted terrorism, or been anti-Semitic. The paper paid Hussain damages and costs. In their apology they said: "The article was published by our client following receipt of information in good faith from the Scout Association and the Henry Jackson Society; nevertheless our client now accepts that the article (using that expression to refer to both print and online versions) is defamatory of your client and will apologise to him for publishing it."


title: The Daily Telegraph

text: In 2016, the Hong Kong Free Press reported that "The Daily Telegraph" was receiving £750,000 annually to carry a supplement called 'China Watch' as part of a commercial deal with Chinese state-run newspaper "China Daily". "The Telegraph" published the supplement once a month in print, and published it online at least until March 2020. As of April 2020, "The Telegraph" appeared to have removed China Watch from its website, along with another advertisement feature section by a Chinese state-run media outlet titled "People's Daily Online". This followed the People's Daily Online section carrying misinformation about COVID-19, including claims that traditional Chinese medicine could help fight the virus.


title: The Daily Telegraph

text: "The Guardian" reported in 2018 that the China Watch newspaper supplement was being carried by "The Telegraph" along with other newspapers of record such as "The New York Times, The Wall Street Journal" and "Le Figaro".


title: The Daily Telegraph

text: In January 2021 British press regulator, the Independent Press Standards Organisation ordered "The Daily Telegraph" to publish corrections for a "significantly misleading" article published by Toby Young in July 2020 article "When we have herd immunity Boris will face a reckoning on this pointless and damaging lockdown" which spread COVID-19 misinformation that the common cold provided "natural immunity" to COVID-19 and that London was "probably approaching herd immunity".


title: The Daily Telegraph

text: "The Telegraph" has published multiple columns and news articles which promote pseudoscientific views on climate change, and misleadingly cast the subject of climate change as a subject of active scientific debate when there is a scientific consensus on climate change. It has published columns about the "conspiracy behind the Anthropogenic Global Warming myth", described climate scientists as "white-coated prima donnas and narcissists," and claimed that "global warming causes about as much damage as benefits." In 2015, a "Telegraph" news article falsely claimed that scientists predicted a mini-ice age by 2030. Climate change denying journalist James Delingpole was first to use "Climategate" on his "Telegraph" blog for a manufactured controversy where emails were leaked from climate scientists ahead of the Copenhagen climate summit and misleadingly presented to give the appearance that the climate scientists were engaged in fraud.


title: The Daily Telegraph

text: In 2014, "The Telegraph" was one of several media titles to give evidence to the House of Commons Select Committee 'Communicating climate science'. The paper told MPs they believe climate change is happening and humans play a role in it. Editors told the committee, "we believe that the climate is changing, that the reason for that change includes human activity, but that human ingenuity and adaptability should not be ignored in favour of economically damaging prescriptions."


title: The Daily Telegraph

text: In July 2021, Prime Minister Boris Johnson's former chief advisor, Dominic Cummings, said that Johnson had always referred to "The Telegraph" (and not the British public) as his "Real Boss".


title: The Daily Telegraph

text: "The Daily Telegraph", in particular its columnist and former editor Charles Moore, were staunch supporters of Owen Paterson, a former MP and minister who resigned after it was found that he had breached advocacy rules to lobby ministers for fees. A plan to overhaul the Commons standard and spare Paterson from being suspended and a possible recall petition that follows was leaked to the newspaper and it was "approvingly" splashed across the paper's front page. Boris Johnson flew back from the COP 26 summit in Glasgow to attend a "Telegraph" journalists' reunion at the Garrick and was seen to leave the club with Moore the same evening.


title: The Peripheral (TV series)

text: The Peripheral is an American science fiction streaming television series executive produced and created by Scott Smith. Produced by Amazon, it is loosely based on the 2014 book of the same name written by William Gibson. "Westworld" creators Jonathan Nolan and Lisa Joy serve as executive producers, along with Athena Wickham, Steve Hoban, and Vincenzo Natali. Set roughly a decade in the future, with some new technology that has changed society in subtle ways, a VR gamer is delivered a connection to an alternate reality, as well as a dark future of her own.


title: The Peripheral (TV series)

text: The series had its world premiere on October 11, 2022, at the Ace Hotel in Los Angeles, before its debut on October 21, 2022, on Amazon Prime Video.


title: The Peripheral (TV series)

text: In April 2018, a TV series adaptation of William Gibson's novel "The Peripheral" was announced by "Westworld" creators Lisa Joy and Jonathan Nolan for Amazon with a script-to-series commitment. It was announced in April 2019 that Joy and Nolan had signed a first look overall deal at Amazon Studios, and the project received a series order in the middle of November 2019, with Joy and Nolan executive producing under their overall deal. Beyond Joy and Nolan, executive producers include Athena Wickham, Steve Hoban, and Vincenzo Natali. The show has hour-long episodes, developed by Kilter Films, through Amazon Studios. Warner Bros. Television is also co-financier and producer, with Scott Smith as writer. Smith created the series, while also serving as showrunner and executive producer. Natali directed the show's pilot. On March 30, 2021, Greg Plageman joined the series as executive producer and replaced Smith as showrunner.


title: The Peripheral (TV series)

text: In October 2020, it was announced that Chloë Grace Moretz was cast in the lead role of Flynne Fisher, with Gary Carr also joining the main cast. In March 2021, Jack Reynor joined the series in a main role. The following month, Eli Goree, Charlotte Riley, JJ Feild, Adelind Horan, T'Nia Miller, and Alex Hernandez were added to the main cast. In June 2021, Louis Herthum, Chris Coy, Melinda Page Hamilton, Katie Leung, and Austin Rising joined the cast in recurring roles. In July 2021, Alexandra Billings joined the cast in a recurring role.


title: The Peripheral (TV series)

text: Principal photography for the series began on May 3, 2021, in London, England. Filming moved to Marshall, North Carolina on September 24. Production on the series wrapped on November 5, 2021.


title: The Peripheral (TV series)

text: "The Peripheral" had its world premiere on October 11, 2022, at the Ace Hotel in Los Angeles, before its debut on October 21, 2022, on Amazon Prime Video. As with other Amazon shows, the episodes air at midnight Eastern, so technically the release dates are the day before for the Pacific audience. The season includes 8 episodes.


title: The Peripheral (TV series)

text: The review aggregator website Rotten Tomatoes reported a 76% approval rating with an average rating of 6.6/10, based on 50 critic reviews. The website's critics consensus reads, "Somewhere on the edges of this sci-fi vision is a compelling narrative, but "The Peripheral" single-minded focus on its lofty ideas comes at the expense of character or coherence." Metacritic, which uses a weighted average, assigned a score of 57 out of 100 based on 20 critics, indicating "mixed or average reviews".


title: John C. Calhoun

text: John Caldwell Calhoun (; March 18, 1782March 31, 1850) was an American statesman and political theorist from South Carolina who held many important positions including being the seventh vice president of the United States from 1825 to 1832. He adamantly defended slavery and sought to protect the interests of the white South. He began his political career as a nationalist, modernizer, and proponent of a strong national government and protective tariffs. In the late 1820s, his views changed radically, and he became a leading proponent of states' rights, limited government, nullification, and opposition to high tariffs. He saw Northern acceptance of those policies as a condition of the South remaining in the Union. His beliefs and warnings heavily influenced the South's secession from the Union in 1860–1861.


title: John C. Calhoun

text: Calhoun began his political career with election to the House of Representatives in 1810. As a prominent leader of the war hawk faction, Calhoun strongly supported the War of 1812. He served as Secretary of War under President James Monroe and, in that position, reorganized and modernized the War Department. Calhoun was a candidate for the presidency in the 1824 election. After failing to gain support, he agreed to be a candidate for vice president. The Electoral College elected Calhoun vice president by an overwhelming majority. He served under John Quincy Adams and continued under Andrew Jackson, who defeated Adams in the election of 1828, making Calhoun the most recent U.S. vice president to serve under two different presidents, and he would be the most recent vice president re-elected, until Thomas R. Marshall got re-elected in 1916, 88 years later.


title: John C. Calhoun

text: Calhoun had a difficult relationship with Jackson, primarily because of the Nullification Crisis and the Petticoat affair. In contrast with his previous nationalism, Calhoun vigorously supported South Carolina's right to nullify federal tariff legislation that he believed unfairly favored the North, which put him into conflict with unionists such as Jackson. In 1832, with only a few months remaining in his second term, Calhoun resigned as vice president and entered the Senate. He sought the Democratic Party nomination for the presidency in 1844 but lost to surprise nominee James K. Polk, who won the general election. Calhoun served as Secretary of State under President John Tyler from 1844 to 1845, and in that role supported the annexation of Texas as a means to extend the slave power and helped to settle the Oregon boundary dispute with Britain. Calhoun returned to the Senate, where he opposed the Mexican–American War, the Wilmot Proviso, and the Compromise of 1850 before he died in 1850. He often served as a virtual independent who variously aligned as needed, with Democrats and Whigs.


title: John C. Calhoun

text: Later in life, Calhoun became known as the "cast-iron man" for his rigid defense of white Southern beliefs and practices. His concept of republicanism emphasized approval of slavery and minority states' rights as particularly embodied by the South. He owned dozens of slaves in Fort Hill, South Carolina. Calhoun asserted that slavery, rather than being a "necessary evil", was a "positive good" that benefited both slaves and owners. To protect minority rights against majority rule, he called for a concurrent majority by which the minority could block some proposals that it felt infringed on their liberties. To that end, Calhoun supported states' rights, and nullification through which states could declare null and void federal laws that they viewed as unconstitutional. He was one of the "Great Triumvirate" or the "Immortal Trio" of Congressional leaders, along with his colleagues Daniel Webster and Henry Clay.


title: John C. Calhoun

text: John Caldwell Calhoun was born in Abbeville District, South Carolina, on March 18, 1782, the fourth child of Patrick Calhoun (1727–1796) and his wife Martha (Caldwell). Patrick's father, also named Patrick Calhoun, had joined the Scotch-Irish immigration movement from County Donegal to southwestern Pennsylvania. After the death of the elder Patrick in 1741, the family moved to southwestern Virginia. Following the defeat of British General Edward Braddock at the Battle of the Monongahela in 1755, the family, fearing Indian attacks, moved to South Carolina in 1756.


title: John C. Calhoun

text: Patrick Calhoun belonged to the Calhoun clan in the tight-knit Scotch-Irish community on the Southern frontier. He was known as an Indian fighter and an ambitious surveyor, farmer, planter, and politician, elected to the South Carolina Legislature. As a Presbyterian, he stood opposed to the established Anglican planter elite based in Charleston. He was not a patriot in the American Revolution and opposed ratification of the federal Constitution on grounds of states' rights and personal liberties. Calhoun would eventually adopt his father's states' rights beliefs.


title: John C. Calhoun

text: Young Calhoun showed scholastic talent, and although schools were scarce on the Carolina frontier, he was enrolled briefly in an academy in Appling, Georgia. It soon closed. He continued his studies privately. When his father died, his brothers were away starting business careers, and so the 14-year-old Calhoun took over management of the family farm and five other farms. For four years he simultaneously kept up his reading and his hunting and fishing. The family decided he should continue his education, and so he resumed studies at the academy after it reopened.


title: John C. Calhoun

text: With financing from his brothers, he went to Yale College in Connecticut in 1802. For the first time in his life, Calhoun encountered serious, advanced, well-organized intellectual dialogue that could shape his mind. Yale was dominated by President Timothy Dwight, a Federalist who became his mentor. Dwight's brilliance entranced (and sometimes repelled) Calhoun.


title: John C. Calhoun

text: Dwight repeatedly denounced Jeffersonian democracy, and Calhoun challenged him in class. Dwight could not shake Calhoun's commitment to republicanism. "Young man," retorted Dwight, "your talents are of a high order and might justify you for any station, but I deeply regret that you do not love sound principles better than sophistry—you seem to possess a most unfortunate bias for error." Dwight also expounded on the strategy of secession from the Union as a legitimate solution for New England's disagreements with the national government.


title: John C. Calhoun

text: Calhoun made friends easily, read widely, and was a noted member of the debating society of Brothers in Unity. He graduated as valedictorian in 1804. He studied law at the nation's first independent law school, Tapping Reeve Law School in Litchfield, Connecticut, where he worked with Tapping Reeve and James Gould. He was admitted to the South Carolina bar in 1807.


title: John C. Calhoun

text: In January 1811, Calhoun married Floride Bonneau Colhoun, a first cousin once removed. She was the daughter of wealthy United States Senator and lawyer John  E. Colhoun, a leader of Charleston high society.


title: John C. Calhoun

text: Calhoun was not openly religious. He was raised as an orthodox Presbyterian, but he was attracted to Southern varieties of Unitarianism of the sort that attracted Jefferson. Southern Unitarianism was generally less organized than the variety popular in New England. He was generally not outspoken about his religious beliefs. After his marriage, Calhoun and his wife attended the Episcopal Church, of which she was a member. In 1821 he became a founding member of All Souls Unitarian Church in Washington, D.C.


title: John C. Calhoun

text: Historian Merrill D. Peterson describes Calhoun: "Intensely serious and severe, he could never write a love poem, though he often tried, because every line began with 'whereas' ..."


title: John C. Calhoun

text: With a base among the Irish and Scotch Irish, Calhoun won election to South Carolina's 6th congressional district of the House of Representatives in 1810. He immediately became a leader of the War Hawks, along with Speaker Henry Clay of Kentucky and South Carolina congressmen William Lowndes and Langdon Cheves. Brushing aside the vehement objections of both anti-war New Englanders and arch-conservative Jeffersonians led by John Randolph of Roanoke, they demanded war against Britain, claiming that American honor and republican values had been violated by the British refusal to recognize American shipping rights. As a member, and later acting chairman, of the Committee on Foreign Affairs, Calhoun played a major role in drafting two key documents in the push for war, the Report on Foreign Relations and the War Report of 1812. Drawing on the linguistic tradition of the Declaration of Independence, Calhoun's committee called for a declaration of war in ringing phrases, denouncing Britain's "lust for power", "unbounded tyranny", and "mad ambition".


title: John C. Calhoun

text: The United States declared war on Britain on June 18, inaugurating the War of 1812. The opening phase involved multiple disasters for American arms, as well as a financial crisis when the Treasury could barely pay the bills. The conflict caused economic hardship for Americans, as the Royal Navy blockaded the ports and cut off imports, exports, and the coastal trade. Several attempted invasions of Canada were fiascos, but the U.S. in 1813 seized control of Lake Erie and broke the power of hostile Indians in battles such as the Battle of the Thames in Canada in 1813 and the Battle of Horseshoe Bend in Alabama in 1814. These Indians had, in many cases, cooperated with the British or Spanish in opposing American interests.


title: John C. Calhoun

text: Calhoun labored to raise troops, provide funds, speed logistics, rescue the currency, and regulate commerce to aid the war effort. One colleague hailed him as "the young Hercules who carried the war on his shoulders". Disasters on the battlefield made him double his legislative efforts to overcome the obstructionism of John Randolph, Daniel Webster, and other opponents of the war. By 1814 the British were thwarted at the invasions of New York and Baltimore, but Napoleon Bonaparte capitulated, meaning America would now face Britain's formidable renforcement with units previously committed to Europe if the war were to continue. British and American diplomats signed the Treaty of Ghent undertaking a return to the borders of 1812 with no gains or losses. Before the treaty reached the Senate for ratification, and even before news of its signing reached New Orleans, a British invasion force was decisively defeated in January 1815 at the Battle of New Orleans, making a national hero of General Andrew Jackson. Americans celebrated what they called a "second war of independence" against Britain. This led to the beginning of the "Era of Good Feelings", an era marked by the formal demise of the Federalist Party and increased nationalism.


title: John C. Calhoun

text: Despite American successes, the mismanagement of the Army during the war distressed Calhoun, and he resolved to strengthen and centralize the War Department. The militia had proven itself quite unreliable during the war and Calhoun saw the need for a permanent and professional military force. In 1816 he called for building an effective navy, including steam frigates, as well as a standing army of adequate size. The British blockade of the coast had underscored the necessity of rapid means of internal transportation; Calhoun proposed a system of "great permanent roads". The blockade had cut off the import of manufactured items, so he emphasized the need to encourage more domestic manufacture, fully realizing that industry was based in the Northeast. The dependence of the old financial system on import duties was devastated when the blockade cut off imports. Calhoun called for a system of internal taxation that would not collapse from a war-time shrinkage of maritime trade, as the tariffs had done. The expiration of the charter of the First Bank of the United States had also distressed the Treasury, so to reinvigorate and modernize the economy Calhoun called for a new national bank. A new bank was chartered as the Second Bank of the United States by Congress and approved by President James Madison in 1816. Through his proposals, Calhoun emphasized a national footing and downplayed sectionalism and states rights. Historian Ulrich B. Phillips says that at this stage of Calhoun's career, "The word "nation" was often on his lips, and his conviction was to enhance national unity which he identified with national power"


title: John C. Calhoun

text: Regarding his career in the House of Representatives, an observer commented that Calhoun was "the most elegant speaker that sits in the House ... His gestures are easy and graceful, his manner forcible, and language elegant; but above all, he confines himself closely to the subject, which he always understands, and enlightens everyone within hearing."


title: John C. Calhoun

text: His talent for public speaking required systematic self-discipline and practice. A later critic noted the sharp contrast between his hesitant conversations and his fluent speaking styles, adding that Calhoun "had so carefully cultivated his naturally poor voice as to make his utterance clear, full, and distinct in speaking and while not at all musical it yet fell pleasantly on the ear". Calhoun was "a high-strung man of ultra intellectual cast". As such, Calhoun was not known for charisma. He was often seen as harsh and aggressive with other representatives. But he was a brilliant intellectual orator and strong organizer. Historian Russell Kirk says, "That zeal which flared like Greek fire in Randolph burned in Calhoun, too; but it was contained in the Cast-iron Man as in a furnace, and Calhoun's passion glowed out only through his eyes. No man was more stately, more reserved."


title: John C. Calhoun

text: John Quincy Adams concluded in 1821 that "Calhoun is a man of fair and candid mind, of honorable principles, of clear and quick understanding, of cool self-possession, of enlarged philosophical views, and ardent patriotism. He is above all sectional and factious prejudices more than any other statesman of this Union with whom I have ever acted." Historian Charles Wiltse noted Calhoun's evolution, "Though he is known today primarily for his sectionalism, Calhoun was the last of the great political leaders of his time to take a sectional position—later than Daniel Webster, later than Henry Clay, later than Adams himself."


title: John C. Calhoun

text: In 1817, the deplorable state of the War Department led four men to decline offers from President James Monroe to accept the office of Secretary of War before Calhoun finally assumed the role. Calhoun took office on December 8 and served until 1825. He continued his role as a leading nationalist during the Era of Good Feelings. He proposed an elaborate program of national reforms to the infrastructure that he believed would speed economic modernization. His priority was an effective navy, including steam frigates, and in the second place a standing army of adequate size—and as further preparation for an emergency, "great permanent roads", "a certain encouragement" to manufactures, and a system of internal taxation that would not collapse from a war-time shrinkage of maritime trade, like customs duties.


title: John C. Calhoun

text: A reform-minded modernizer, Calhoun attempted to institute centralization and efficiency in the Indian Department and in the Army by establishing new coastal and frontier fortifications and building military roads, but Congress either failed to respond to his reforms or responded with hostility. Calhoun's frustration with congressional inaction, political rivalries, and ideological differences spurred him to create the Bureau of Indian Affairs in 1824. The responsibilities of the bureau were to manage treaty negotiations, schools, and trade with Indians, in addition to handling all expenditures and correspondence concerning Indian affairs. Thomas McKenney was appointed as the first head of the bureau.


title: John C. Calhoun

text: As secretary, Calhoun had responsibility for the management of Indian affairs. He promoted a plan, adopted by Monroe in 1825, to preserve the sovereignty of eastern Indians by relocating them to western reservations they could control without interference from state governments. In over seven years Calhoun supervised the negotiation and ratification of 40 treaties with Indian tribes. Calhoun opposed the invasion of Spanish Florida launched in 1818 by General Jackson during the First Seminole War, which was done without direct authorization from Calhoun or President Monroe, and in private with other cabinet members, advocated censuring of Jackson as punishment. Calhoun claimed that Jackson had begun a war against Spain in violation of the Constitution and, that he had contradicted Calhoun's explicit orders in doing so. Specific official instructions not to invade Florida or attack the Spanish were not issued by the administration. However, Calhoun supported the execution of Alexander Arbuthnot and Robert Ambrister, two British soldiers living in Florida who were accused of inciting the Seminole to make war against the United States. Calhoun accused the British of being involved in "wickedness, corruption, and barbarity at which the heart sickens and which in this enlightened age it ought not scarcely to be believed that a Christian nation would have participated". He added that he hoped the executions of Arbuthnot and Ambrister would deter the British and any other nations "who by false promises delude and excite an Indian tribe to all the deeds of savage war". The United States annexed Florida from Spain in 1819 through the Adams–Onís Treaty.


title: John C. Calhoun

text: Calhoun's tenure as Secretary of War witnessed the outbreak of the Missouri crisis in December 1818, when a petition arrived from Missouri settlers seeking admission into the Union as a slave state. In response, Representative James Tallmadge Jr. of New York proposed two amendments to the bill designed to restrict the spread of slavery into what would become the new state. These amendments touched off an intense debate between North and South that had some talking openly of disunion. In February 1820, Calhoun predicted to Secretary of State John Quincy Adams, a New Englander, that the Missouri issue "would not produce a dissolution" of the Union. "But if it should," Calhoun went on, "the South would of necessity be compelled to form an alliance with...Great Britain." "I said that would be returning to the colonial state," Adams recalled saying afterward. According to Adams, "He said, yes, pretty much, but it would be forced upon them."


title: John C. Calhoun

text: After the war ended in 1815 the "Old Republicans" in Congress, with their Jeffersonian ideology for an economy in the federal government, sought to reduce the operations and finances of the War Department. Calhoun's political rivalry with William H. Crawford, the Secretary of the Treasury, over the pursuit of the presidency in the 1824 election, complicated Calhoun's tenure as War Secretary. The general lack of military action following the war meant that a large army, such as that preferred by Calhoun, was no longer considered necessary. The "Radicals", a group of strong states' rights supporters who mostly favored Crawford for president in the coming election, were inherently suspicious of large armies. Some allegedly also wanted to hinder Calhoun's presidential aspirations for that election. Thus, on March 2, 1821, Congress passed the Reduction Act, which reduced the number of enlisted men of the army by half, from 11,709 to 5,586, and the number of the officer corps by a fifth, from 680 to 540. Calhoun, though concerned, offered little protest. Later, to provide the army with a more organized command structure, which had been severely lacking during the War of 1812, he appointed Major General Jacob Brown to a position that would later become known as "Commanding General of the United States Army".


title: John C. Calhoun

text: Calhoun was initially a candidate for President of the United States in the election of 1824. Four other men also sought the presidency: Andrew Jackson, Adams, Crawford, and Henry Clay. Calhoun failed to win the endorsement of the South Carolina legislature, and his supporters in Pennsylvania decided to abandon his candidacy in favor of Jackson's, and instead supported him for vice president. Other states soon followed, and Calhoun therefore allowed himself to become a candidate for vice president rather than president. The Electoral College elected Calhoun vice president by a landslide on December 1, 1824. He won 182 of 261 electoral votes, while five other men received the remaining votes. No presidential candidate received a majority in the Electoral College, and the election was ultimately resolved by the House of Representatives, where Adams was declared the winner over Crawford and Jackson, who in the election had led Adams in both popular vote and electoral vote. After Clay, the Speaker of the House, was appointed Secretary of State by Adams, Jackson's supporters denounced what they considered a "corrupt bargain" between Adams and Clay to give Adams the presidency in exchange for Clay receiving the office of Secretary of State, the holder of which had traditionally become the next president. Calhoun also expressed some concerns, which caused friction between him and Adams.


title: John C. Calhoun

text: Calhoun also opposed President Adams' plan to send a delegation to observe a meeting of South and Central American leaders in Panama, believing that the United States should stay out of foreign affairs. Calhoun became disillusioned with Adams' high tariff policies and increased centralization of government through a network of "internal improvements", which he now saw as a threat to the rights of the states. Calhoun wrote to Jackson on June 4, 1826, informing him that he would support Jackson's second campaign for the presidency in 1828. The two were never particularly close friends. Calhoun never fully trusted Jackson, a frontiersman and popular war hero, but hoped that his election would bring some reprieve from Adams's anti-states' rights policies. Jackson selected Calhoun as his running mate, and together they defeated Adams and his running mate Richard Rush. Calhoun thus became the second of two vice presidents to serve under two different presidents. The only other man who accomplished this feat was George Clinton, who served as vice president from 1805 to 1812 under Thomas Jefferson and James Madison.


title: John C. Calhoun

text: During the election, Jackson's aide James Alexander Hamilton attempted a rapprochement between Jackson and Crawford, whom Jackson resented owing partially to the belief that it was he, not Calhoun, who had opposed the invasion of Florida. Hamilton spoke about this prospect with Governor John Forsyth of Georgia, who acted as a mediator between the Jackson campaign and Crawford. Forsyth wrote a letter back to Hamilton in which he claimed that Crawford had stated to him that it was Calhoun, not Crawford, who had supported censuring Jackson for his invasion of Florida. Knowing that the letter could destroy the partnership between Jackson and Calhoun, Hamilton and fellow-Jackson aide William B. Lewis allowed it to remain in Hamilton's possession without informing Jackson or the public of its existence.


title: John C. Calhoun

text: Early in Jackson's administration, Calhoun's wife Floride Bonneau Calhoun organized Cabinet wives (hence the term "petticoats") against Peggy Eaton, wife of Secretary of War John Eaton, and refused to associate with her. They alleged that John and Peggy Eaton had engaged in an adulterous affair while she was still legally married to her first husband, and that her recent behavior was unladylike. The allegations of scandal created an intolerable situation for Jackson. The Petticoat affair ended friendly relations between Calhoun and Jackson.


title: John C. Calhoun

text: Jackson sided with the Eatons. He and his late wife Rachel Donelson had undergone similar political attacks stemming from their marriage in 1791. The two had married in 1791 not knowing that Rachel's first husband, Lewis Robards, had failed to finalize the expected divorce. Once the divorce was finalized, they married legally in 1794, but the episode caused a major controversy, and was used against him in the 1828 campaign. Jackson saw attacks on Eaton stemming ultimately from the political opposition of Calhoun, who had failed to silence his wife's criticisms. The Calhouns were widely regarded as the chief instigators. Jackson, who loved to personalize disputes, also saw the Petticoat affair as a direct challenge to his authority, because it involved lower-ranking executive officials and their wives seeming to contest his ability to choose whomever he wanted for his cabinet. Secretary of State Martin Van Buren, a widower, took Jackson's side and defended the Eatons. Van Buren was a northerner and a supporter of the 1828 tariff (which Calhoun bitterly opposed). Calhoun and Van Buren were the main contenders for the vice-presidential nomination in the ensuing election, and the nominee would then presumably be the party's choice to succeed Jackson. That Van Buren sided with the Eatons, in addition to disagreements between Jackson and Calhoun on other issues, mainly the Nullification Crisis, marked him as Calhoun's likely vice presidential successor.


title: John C. Calhoun

text: Some historians, including Jackson biographers Richard B. Latner and Robert V. Remini, believe that the hostility towards the Eatons was rooted less in questions of proper behavior than in politics. Eaton had been in favor of the Tariff of Abominations. He was also politically close to Van Buren. Calhoun may have wanted to expel Eaton from the cabinet as a way of boosting his anti-tariff agenda and increasing his standing in the Democratic Party. Many cabinet members were Southern and could be expected to sympathize with such concerns, especially Treasury Secretary Samuel D. Ingham, who was allied with Calhoun and believed that he, not Van Buren, should succeed Jackson as president.