title: Section 230

text: This rule, cementing Section 230's liability protections, has been considered one of the most important case laws affecting the growth of the Internet, allowing websites to be able to incorporate user-generated content without fear of prosecution. However, at the same time, this has led to Section 230 being used as a shield for some website owners as courts have ruled Section 230 provides complete immunity for ISPs with regard to the torts committed by their users over their systems. Through the next decade, most cases involving Section 230 challenges generally fell in favor of service providers, ruling in favor of their immunity from third-party content on their sites.


title: Section 230

text: While Section 230 had seemed to have given near complete immunity to service providers in its first decade, new case law around 2008 started to find cases where providers can be liable for user content due to being a "publisher or speaker" related to that content under §230(c)(1). One of the first such cases to make this challenge was "Fair Housing Council of San Fernando Valley v. Roommates.com, LLC" 521 F.3d 1157 (9th Cir. 2008), The case centered on the services of Roommates.com that helped to match renters based on profiles they created on their website; this profile was generated by a mandatory questionnaire and which included information about their gender and race and preferred roommates' race. The Fair Housing Council of San Fernando Valley stated this created discrimination and violated the Fair Housing Act, and asserted that Roommates.com was liable for this. In 2008, the Ninth Circuit in an "en banc" decision ruled against Roommates.com, agreeing that its required profile system made it an information content provider and thus ineligible to receive the protections of §230(c)(1).


title: Section 230

text: The decision from "Roommates.com" was considered to be the most significant deviation from "Zeran" in how Section 230 was handled in case law. Eric Goldman of the Santa Clara University School of Law wrote that while the Ninth Circuit's decision in "Roommates.com" was tailored to apply to a limited number of websites, he was "fairly confident that lots of duck-biting plaintiffs will try to capitalize on this opinion and they will find some judges who ignore the philosophical statements and instead turn a decision on the opinion's myriad of ambiguities". Over the next several years, a number of cases cited the Ninth Circuit's decision in "Roommates.com" to limit some of the Section 230 immunity to websites. Law professor Jeff Kosseff of the United States Naval Academy reviewed 27 cases in the 2015–2016 year involving Section 230 immunity concerns, and found more than half of them had denied the service provider immunity, in contrast to a similar study he had performed in from 2001 to 2002 where a majority of cases granted the website immunity; Kosseff asserted that the "Roommates.com" decision was the key factor that led to this change.


title: Section 230

text: Around 2001, a University of Pennsylvania paper warned that "online sexual victimization of American children appears to have reached epidemic proportions" due to the allowances granted by Section 230. Over the next decade, advocates against such exploitation, such as the National Center for Missing and Exploited Children and Cook County Sheriff Tom Dart, pressured major websites to block or remove content related to sex trafficking, leading to sites like Facebook, MySpace, and Craigslist to pull such content. Because mainstream sites were blocking this content, those that engaged or profited from trafficking started to use more obscure sites, leading to the creation of sites like Backpage. In addition to removing these from the public eye, these new sites worked to obscure what trafficking was going on and who was behind it, limiting ability for law enforcement to take action. Backpage and similar sites quickly came under numerous lawsuits from victims of the sex traffickers and exploiters for enabling this crime, but the court continually found in favor of Backpage due to Section 230. Attempts to block Backpage from using credit card services as to deny them revenue was also defeated in the courts, as Section 230 allowed their actions to stand in January 2017.


title: Section 230

text: Due to numerous complaints from constituents, Congress began an investigation into Backpage and similar sites in January 2017, finding Backpage complicit in aiding and profiting from illegal sex trafficking. Subsequently, Congress introduced the FOSTA-SESTA bills: the Allow States and Victims to Fight Online Sex Trafficking Act (FOSTA) in the House of Representatives by Ann Wagner (R-MO) in April 2017, and the Stop Enabling Sex Traffickers Act (SESTA) U.S. Senate bill introduced by Rob Portman (R-OH) in August 2017. Combined, the FOSTA-SESTA bills modified Section 230 to exempt service providers from Section 230 immunity when dealing with civil or criminal crimes related to sex trafficking, which removes section 230 immunity for services that knowingly facilitate or support sex trafficking. The bill passed both Houses and was signed into law by President Donald Trump on April 11, 2018.


title: Section 230

text: The bills were criticized by pro-free speech and pro-Internet groups as a "disguised internet censorship bill" that weakens the section 230 immunity, places unnecessary burdens on Internet companies and intermediaries that handle user-generated content or communications with service providers required to proactively take action against sex trafficking activities, and requires a "team of lawyers" to evaluate all possible scenarios under state and federal law (which may be financially unfeasible for smaller companies). Critics also argued that FOSTA-SESTA did not distinguish between consensual, legal sex offerings from non-consensual ones, and argued it would cause websites otherwise engaged in legal offerings of sex work would be threatened with liability charges. Online sex workers argued that the bill would harm their safety, as the platforms they utilize for offering and discussing sexual services in a legal manner (as an alternative to street prostitution) had begun to reduce their services or shut down entirely due to the threat of liability under the bill.


title: Section 230

text: Many social media sites, notably the Big Tech companies of Facebook, Google, and Apple, as well as Twitter, have come under scrutiny as a result of the alleged Russian interference in the 2016 United States elections, where it was alleged that Russian agents used the sites to spread propaganda and fake news to swing the election in favor of Donald Trump. These platforms also were criticized for not taking action against users that used the social media outlets for harassment and hate speech against others. Shortly after the passage of FOSTA-SESTA acts, some in Congress recognized that additional changes could be made to Section 230 to require service providers to deal with these bad actors, beyond what Section 230 already provided to them.


title: Section 230

text: Numerous experts have suggested that changing 230 without repealing it entirely would be the optimal way to improve it. Google's former fraud czar Shuman Ghosemajumder proposed in 2021 that full protections should only apply to unmonetized content, to align platforms' content moderation efforts with their financial incentives, and to encourage the use of better technology to achieve that necessary scale. Researchers Marshall Van Alstyne and Michael D. Smith supported this idea of an additional duty-of-care requirement. However, journalist Martin Baron has argued that most of Section 230 is essential for social media companies to exist at all.


title: Section 230

text: Some politicians, including Republican senators Ted Cruz (TX) and Josh Hawley (MO), have accused major social networks of displaying a bias against conservative perspectives when moderating content (such as Twitter suspensions). In a Fox News op-ed, Cruz argued that section 230 should only apply to providers that are politically "neutral", suggesting that a provider "should be considered to be a liable 'publisher or speaker' of user content if they pick and choose what gets published or spoke." Section 230 does not contain any requirements that moderation decisions be neutral. Hawley alleged that section 230 immunity was a "sweetheart deal between big tech and big government".


title: Section 230

text: In December 2018, Republican representative Louie Gohmert introduced the Biased Algorithm Deterrence Act (H.R.492), which would remove all section 230 protections for any provider that used filters or any other type of algorithms to display user content when otherwise not directed by a user.


title: Section 230

text: In June 2019, Hawley introduced the Ending Support for Internet Censorship Act (S. 1914), that would remove section 230 protections from companies whose services have more than 30 million active monthly users in the U.S. and more than 300 million worldwide, or have over $500 million in annual global revenue, unless they receive a certification from the majority of the Federal Trade Commission that they do not moderate against any political viewpoint, and have not done so in the past 2 years.


title: Section 230

text: There has been criticism—and support—of the proposed bill from various points on the political spectrum. A poll of more than 1,000 voters gave Senator Hawley's bill a net favorability rating of 29 points among Republicans (53% favor, 24% oppose) and 26 points among Democrats (46% favor, 20% oppose). Some Republicans feared that by adding FTC oversight, the bill would continue to fuel fears of a big government with excessive oversight powers. Nancy Pelosi, the Democratic Speaker of the House, has indicated support for the same approach Hawley has taken. The chairman of the Senate Judiciary Committee, Senator Graham, has also indicated support for the same approach Hawley has taken, saying "he is considering legislation that would require companies to uphold 'best business practices' to maintain their liability shield, subject to periodic review by federal regulators."


title: Section 230

text: Legal experts have criticized the Republicans' push to make Section 230 encompass platform neutrality. Wyden stated in response to potential law changes that "Section 230 is not about neutrality. Period. Full stop. 230 is all about letting private companies make their own decisions to leave up some content and take other content down." Kosseff has stated that the Republican intentions are based on a "fundamental misunderstanding" of Section 230's purpose, as platform neutrality was not one of the considerations made at the time of passage. Kosseff stated that political neutrality was not the intent of Section 230 according to the framers, but rather making sure providers had the ability to make content-removal judgement without fear of liability. There have been concerns that any attempt to weaken Section 230 could actually cause an increase in censorship when services lose their exemption from liability.


title: Section 230

text: Attempts to bring damages to tech companies for apparent anti-conservative bias in courts, arguing against Section 230 protections, have generally failed. A lawsuit brought by the non-profit Freedom's Watch in 2018 against Google, Facebook, Twitter, and Apple on antitrust violations for using their positions to create anti-conservative censorship was dismissed by the D.C. Circuit Court of Appeals in May 2020, with the judges ruling that censorship can only apply to First Amendment rights blocked by the government and not by private entities.


title: Section 230

text: In the wake of the 2019 shootings in Christchurch, New Zealand, El Paso, Texas, and Dayton, Ohio, the impact on Section 230 and liability towards online hate speech has been raised. In both the Christchurch and El Paso shootings, the perpetrator posted hate speech manifestos to 8chan, a moderated imageboard known to be favorable for the posting of extreme views. Concerned politicians and citizens raised calls at large tech companies for the need for hate speech to be removed from the Internet; however, hate speech is generally protected speech under the First Amendment, and Section 230 removes the liability for these tech companies to moderate such content as long as it is not illegal. This has given the appearance that tech companies do not need to be proactive against hateful content, thus allowing the hate content to proliferate online and lead to such incidents.


title: Section 230

text: Notable articles on these concerns were published after the El Paso shooting by "The New York Times", "The Wall Street Journal", and "Bloomberg Businessweek", among other outlets, but which were criticized by legal experts including Mike Godwin, Mark Lemley, and David Kaye, as the articles implied that hate speech was protected by Section 230, when it is in fact protected by the First Amendment. In the case of "The New York Times", the paper issued a correction to affirm that the First Amendment protected hate speech, and not Section 230.


title: Section 230

text: Members of Congress have indicated they may pass a law that changes how Section 230 would apply to hate speech as to make tech companies liable for this. Wyden, now a Senator, stated that he intended for Section 230 to be both "a sword and a shield" for Internet companies, the "sword" allowing them to remove content they deem inappropriate for their service, and the shield to help keep offensive content from their sites without liability. However, Wyden warned that because tech companies have not been willing to use the sword to remove content, they could be at risk of losing the shield. Some have compared Section 230 to the Protection of Lawful Commerce in Arms Act, a law that grants gun manufacturers immunity from certain types of lawsuits when their weapons are used in criminal acts. According to law professor Mary Anne Franks, "They have not only let a lot of bad stuff happen on their platforms, but they've actually decided to profit off of people's bad behavior."


title: Section 230

text: Representative Beto O'Rourke stated his intent for his 2020 presidential campaign to introduce sweeping changes to Section 230 to make Internet companies liable for not being proactive in taking down hate speech. O'Rourke later dropped out of the race. Fellow candidate and former vice president Joe Biden has similarly called for Section 230 protections to be weakened or otherwise "revoked" for "big tech" companies—particularly Facebook—having stated in a January 2020 interview with "The New York Times" that "[Facebook] is not merely an internet company. It is propagating falsehoods they know to be false", and that the U.S. needed to "[set] standards" in the same way that the European Union's General Data Protection Regulation (GDPR) set standards for online privacy.


title: Section 230

text: In the aftermath of the Backpage trial and subsequent passage of FOSTA-SESTA, others have found that Section 230 appears to protect tech companies from content that is otherwise illegal under United States law. Professor Danielle Citron and journalist Benjamin Wittes found that as late as 2018, several groups deemed as terrorist organizations by the United States had been able to maintain social media accounts on services run by American companies, despite federal laws that make providing material support to terrorist groups subject to civil and criminal charges. However, case law from the Second Circuit has ruled that under Section 230, technology companies are generally not liable for civil claims based on terrorism-related content. U.S. Supreme Court Justice Clarence Thomas has stated that Section 230 gives companies too much immunity in these area, as reported in his several dissenting statements to court orders denying certification of cases related to Section 230. Thomas believed that the Supreme Court needed to review the limits granted by Section 230.


title: Section 230

text: The Supreme Court will hear the cases of "Gonzalez v. Google LLC" and "Twitter, Inc. v. Taamneh" in the 2022 term. "Gonzalez" involves Google's liability for the YouTube recommendation options that appeared to promote recruitment videos for ISIS that led to the death of a U.S. citizen in a 2015 Paris terrorist attack. Google has claimed it is not liable under Section 230 protections. In "Twitter", the company had been found liable for hosting terrorism-related content from third-party users under the Anti-Terrorism Act under 18 U.S.C. § 2333, without the consideration of Section 230's protections.


title: Section 230

text: In February 2020, the United States Department of Justice held a workshop related to Section 230 as part of an ongoing antitrust probe into "big tech" companies. Attorney General William Barr said that while Section 230 was needed to protect the Internet's growth while most companies were not stable, "No longer are technology companies the underdog upstarts...They have become titans of U.S. industry" and questioned the need for Section 230's broad protections. Barr said that the workshop was not meant to make policy decisions on Section 230, but part of a "holistic review" related to Big Tech since "not all of the concerns raised about online platforms squarely fall within antitrust" and that the Department of Justice would want to see reform and better incentives to improve online content by tech companies within the scope of Section 230 rather than change the law directly. Observers to the sessions stated the focus of the talks only covered Big Tech and small sites that engaged in areas of revenge porn, harassment, and child sexual abuse, but did not consider much of the intermediate uses of the Internet.


title: Section 230

text: The DOJ issued their four major recommendations to Congress in June 2020 to modify Section 230. These include:


title: Section 230

text: In 2020, several bills were introduced through Congress to limit the liability protections that Internet platforms had from Section 230 as a result of events in the preceding years.


title: Section 230

text: President Donald Trump was a major proponent of limiting the protections of technology and media companies under Section 230 due to claims of an anti-conservative bias. In July 2019, Trump held a "Social Media Summit" that he used to criticize how Twitter, Facebook, and Google handled conservative voices on their platforms. During the summit, Trump warned that he would seek "all regulatory and legislative solutions to protect free speech".


title: Section 230

text: In late May 2020, President Trump made statements that mail-in voting would lead to massive fraud, in a pushback against the use of mail-in voting due to the COVID-19 pandemic for the upcoming 2020 primary elections, in both his public speeches and his social media accounts. In a Twitter message on May 26, 2020, he stated that, "There is NO WAY (ZERO!) that Mail-In Ballots will be anything less than substantially fraudulent." Shortly after its posting, Twitter moderators marked the message with a "potentially misleading" warning (a process it had introduced a few weeks earlier that month primarily in response to misinformation about the COVID-19 pandemic) linking readers to a special page on its site that provided analysis and fact-checks of Trump's statement from media sources like CNN and "The Washington Post", the first time it had used the process on Trump's messages. Jack Dorsey, Twitter's CEO, defended the moderation, stating that they were not acting as a "arbitrator of truth" but instead "Our intention is to connect the dots of conflicting statements and show the information in dispute so people can judge for themselves." Trump was angered by this, and shortly afterwards threatened that he would take action to "strongly regulate" technology companies, asserting these companies were suppressing conservative voices.


title: Section 230

text: On May 28, 2020, Trump signed the "Executive Order on Preventing Online Censorship" (EO 13925), an executive order directing regulatory action at Section 230. Trump stated in a press conference before signing his rationale for it: "A small handful of social media monopolies controls a vast portion of all public and private communications in the United States. They've had unchecked power to censor, restrict, edit, shape, hide, alter, virtually any form of communication between private citizens and large public audiences." The EO asserts that media companies that edit content apart from restricting posts that are violent, obscene or harassing, as outlined in the "Good Samaritan" clause §230(c)(2), are then "engaged in editorial conduct" and may forfeit any safe-harbor protection granted in §230(c)(1). From that, the EO specifically targets the "Good Samaritan" clause for media companies in their decisions to remove offensive material "in good faith". Courts have interpreted the "in good faith" portion of the statute based on its plain language, the EO purports to establish conditions where that good faith may be revoked, such as if the media companies have shown bias in how they remove material from the platform. The goal of the EO is to remove the Section 230 protections from such platforms, and thus leaving them liable for content. Whether a media platform has bias would be determined by a rulemaking process to be set by the Federal Communication Commission in consultation with the Commerce Department, the National Telecommunications and Information Administration (NTIA), and the Attorney General, while the Justice Department and state attorney generals will handle disputes related to bias, gather these to report to the Federal Trade Commission, who would make determinations if a federal lawsuit should be filed. Additional provisions prevent government agencies from advertising on media company platforms that are demonstrated to have such bias.


title: Section 230

text: The EO came under intense criticism and legal analysis after its announcement. Senator Wyden stated that the EO was a "mugging of the First Amendment", and that there does need to be a thoughtful debate about modern considerations for Section 230, though the political spat between Trump and Twitter is not a consideration. Professor Kate Klonick of St. John's University School of Law in New York considered the EO "political theater" without any weight of authority. The Electronic Frontier Foundation's Aaron Mackey stated that the EO starts with a flawed misconstruing of linking sections §230(c)(1) and §230(c)(2), which were not written to be linked and have been treated by case law as independent statements in the statute, and thus "has no legal merit".


title: Section 230

text: By happenstance, the EO was signed on the same day that riots erupted in Minneapolis, Minnesota in the wake of the murder of George Floyd, an African-American from an incident involving four officers of the Minneapolis Police Department. Trump had tweeted on his conversation with Minnesota's governor Tim Walz about bringing National Guard to stop the riots, but concluded with the statement, "Any difficulty and we will assume control but, when the looting starts, the shooting starts", a phrase attached to Miami Police Chief Walter E. Headley to deal with violent riots in 1967. After internal review, Twitter marked the message with a "public interest notice" that deemed it "glorified violence", which they would normally remove for violating the site's terms, but stated to journalists that they "have kept the Tweet on Twitter because it is important that the public still be able to see the Tweet given its relevance to ongoing matters of public importance." Following Twitter's marking of his May 28 tweet, Trump said in another tweet that due to Twitter's actions, "Section 230 should be revoked by Congress. Until then, it will be regulated!"


title: Section 230

text: By June 2, 2020, the Center for Democracy & Technology filed a lawsuit in the United States District Court for the District of Columbia seeking preliminary and permanent injunction from the EO from being enforced, asserting that the EO created a chilling effect on free speech since it puts all hosts of third-party content "on notice that content moderation decisions with which the government disagrees could produce penalties and retributive actions, including stripping them of Section 230s protections".


title: Section 230

text: The Secretary of Commerce via the NTIA sent a petition with a proposed rule to the FCC on July 27, 2020, as the first stage of executing on the EO. FCC chair Ajit Pai stated in October 2020 that after the Commission reviewed what authority they have over Section 230 that the FCC will proceed with putting forth their proposed rules to clarify Section 230 on October 15, 2020. Pai's announcement, which came shortly after Trump again called for Section 230 revisions after asserting Big Tech was purposely hiding a reporting of leaked documents around Hunter Biden, Joe Biden's son, was criticized by the Democratic FCC commissioners Geoffrey Starks and Jessica Rosenworcel and the tech industry, with Rosenworcel stating "The FCC has no business being the president's speech police."


title: Section 230

text: A second lawsuit against the EO was filed by activist groups including Rock the Vote and Free Press on August 27, 2020, after Twitter had flagged another of Trump's tweets for misinformation related to mail-in voting fraud. The lawsuit stated that should the EO be enforced, Twitter would not have been able to fact-check tweets like Trump's as misleading, thus allowing the President or other government officials to intentionally distribute misinformation to citizens.


title: Section 230

text: Following the November election, Trump has made numerous claims on his social media accounts contesting the results, including claims of fraud. Twitter and other social media companies have marked these posts as potentially misleading, similar to previous posts Trump has made. As a result, Trump threatened to veto the defense spending bill for 2021 if it did not contain language to repeal Section 230. Trump made good on his promise, vetoing the spending bill on December 23, 2020, in part for not containing a repeal of Section 230. The House voted to overturn the veto on December 28, 322–87, sending the bill to the Senate to vote to overturn. The Senate similarly voted to override the veto on January 1, 2021, without adding any Section 230 provisions.


title: Section 230

text: During this, Trump urged Congress to expand the COVID-19 relief payments in the Consolidated Appropriations Act, 2021 that he had signed into law on December 27, 2020, but also stated that they should address the Section 230 repeal and other matters that were not addressed in the defense bill. The Senate majority leader Mitch McConnell stated on December 28 that he would bring legislation later that week that would include the expanded COVID-19 relief along with legislation to deal with Section 230, as outlined by Trump. Ultimately, no additional legislation was introduced.


title: Section 230

text: In the wake of the 2021 United States Capitol attack on January 6, 2021, Pai stated that he would not be seeking any Section 230 reform before his prior planned resignation from office on January 20, 2021. Pai stated that this was mostly due to the lack of time to implement such rule making before his resignation, but also said that he would not "second-guess those decisions" of social media networks under Section 230 to block some of Trump's messages from January 6 that contributed to the violence. In the days that followed, Twitter, Facebook, and other social media services blocked or banned Trump's accounts claiming his speech during and after the riot was inciting further violence. These actions were supported by politicians, but led to renewed calls by Democrat leaders to reconsider Section 230, as these politicians believed that Section 230 led the companies to fail to take any preemptive action against the people who had planned and executed the Capitol riots. Separately, Trump filed class-action lawsuits against Twitter, Facebook, and YouTube in July 2021 related to his bans from the January 2021 period, claiming their actions were unjustifable, and claiming that Section 230 was unconstitutional. Trump's lawsuit against Twitter was dismissed by a federal judge in May 2022, stating that the suit's First Amendment claims were inactionable against non-government groups like Twitter, though allowed an amended claim to be filed.


title: Section 230

text: In March 2021, Facebook's Mark Zuckerberg, Alphabet's Sundar Pichai, and Twitter's Jack Dorsey were asked to testify to the House Committee on Energy and Commerce relating to the role of social media in promoting extremism and misinformation following the 2020 election; of which Section 230 was expected to be a topic. Prior to the event, Zuckerberg proposed an alternate change to Section 230 compared to previously proposed bills. Zuckerberg stated that it would be costly and impractical for social media companies to traffic all problematic material, and instead it would be better to tie Section 230 liability protection to companies that have demonstrated that they have mechanisms in place to remove this material once it is identified.


title: Section 230

text: In July 2021, Democratic senators Amy Klobuchar and Ben Ray Luján introduced the "Health Misinformation Act", which is intended primarily to combat COVID-19 misinformation. It would add a carveout to Section 230 to make companies liable for the publication of "health misinformation" during a "public health emergency" — as established by the Department of Health and Human Services — if the content is promoted to users via algorithmic decisions.


title: Section 230

text: Following Frances Haugen's testimony to Congress that related to her whistleblowing on Facebook's internal handling of content, House Democrats Anna Eshoo, Frank Pallone Jr., Mike Doyle, and Jan Schakowsky introduced the "Justice Against Malicious Algorithms Act" in October 2021, which is in committee as H.R.5596. The bill would remove Section 230 protections for service providers related to personalized recommendation algorithms that present content to users if those algorithms knowingly or recklessly deliver content that contributes to physical or severe emotional injury. "“The last few years have proven that the more outrageous and extremist content social media platforms promote, the more engagement and advertising dollars they rake in",” said Representative Frank Pallone Jr., the chairman of the Energy and Commerce Committee. “"By now it’s painfully clear that neither the market nor public pressure will stop social media companies from elevating disinformation and extremism, so we have no choice but to legislate, and now it’s a question of how best to do it",” he added.


title: Section 230

text: The state of Florida (predominantly Republican after the 2020 election) passed its "deplatforming" Senate Bill 7072 in May 2021, which had been proposed in February 2021 after Trump had been banned from several social media sites. SB 7072 prevents social media companies from knowingly blocking or banning politicians, and grants the Florida Elections Commission the ability to fine these companies for knowing violations, with fines as high as per day for state-level politicians. The bill exempts companies that own theme parks or other large venues within the state, thus would exempt companies such as Disney whose parks provide a significant tax revenue to the state. The Computer & Communications Industry Association (CCIA) and NetChoice filed suit against the state to block enforcement of the law, in Netchoice v. Moody, asserting that the law violated the First Amendment rights of private companies. Judge Robert Lewis Hinkle of the United States District Court for the Northern District of Florida issued a preliminary injunction against the law on June 30, 2021, stating that "The legislation now at issue was an effort to rein in social-media providers deemed too large and too liberal. Balancing the exchange of ideas among private speakers is not a legitimate governmental interest", and further that the law "discriminates on its face among otherwise identical speakers".


title: Section 230

text: Texas H.B. 20, enacted in September 2021, intended to prevent large social media providers from banning or demonetizing their users based on the user's viewpoint, including for views expressed outside of the social media platform, as well as to increase transparency in how these providers moderate content. The CCIA and NetChoice filed suit to prevent enforcement of the law in NetChoice v. Paxton. A federal district judge placed an injunction on this law in December 2021, stating that the law's "prohibitions on 'censorship' and constraints on how social media platforms disseminate content violate the First Amendment". However, the Fifth Circuit reversed the injunction on a 2–1 order without yet ruling on the merits of the case in May 2022, effectively allowing the Texas law to come into effect. The CCIA and NetChoice appealed the Fifth Circuit decision directly to the U.S. Supreme Court seeking an emergency injunction to block the law. They argued that regulations on how social media platforms moderate users' content may prevent them from moderating at all in certain situations and thus force them to publish material they find objectionable, an outcome that would violate the social media platforms' First Amendment rights.


title: Section 230

text: On May 31, 2022, the Supreme Court restored the injunction by court order (with four Justices, Samuel Alito, Clarence Thomas, Elena Kagan, and Neil Gorsuch dissenting) while lower court litigation continued. The Fifth Circuit reversed the district court ruling in September 2022, with Judge Andy Oldham stating in the majority opinion, "Today we reject the idea that corporations have a freewheeling First Amendment right to censor what people say." The decision creates a circuit split with the potential to be heard by the Supreme Court. The Fifth Circuit agreed to rejoin enforcement if the law in October 2022 while several tech companies petitioned the case to the Supreme Court.


title: Section 230

text: Numerous cases involving Section 230 have been heard in the judiciary system since its introduction, many which are rote applications of Section 230.


title: Section 230

text: The following is a partial list of legal cases that have been established as case law that have influenced the interpretation of Section 230 in subsequent cases or have led to new legislation around Section 230.


title: Section 230

text: Directive 2000/31/EC, the e-Commerce Directive, establishes a safe harbor regime for hosting providers:


title: Section 230

text: The updated Directive on Copyright in the Digital Single Market (Directive 2019/790) Article 17 makes providers liable if they fail to take "effective and proportionate measures" to prevent users from uploading certain copyright violations and do not respond immediately to takedown requests.


title: Section 230

text: In "Dow Jones & Company Inc v Gutnick", the High Court of Australia treated defamatory material on a server outside Australia as having been published in Australia when it is downloaded or read by someone in Australia.


title: Section 230

text: Under the "Defamation Act 2005" (NSW), s 32, a defence to defamation is that the defendant neither knew, nor ought reasonably to have known of the defamation, and the lack of knowledge was not due to the defendant's negligence.


title: Section 230

text: The Electronic Commerce Directive 2000 (e-Commerce Directive) has been implemented in Italy by means of Legislative Decree no. 70 of 2003. The provisions provided by Italy are substantially in line with those provided at the EU level. However, at the beginning, the Italian case-law had drawn a line between so-called "active" hosting providers and "passive" Internet Service Providers, arguing that "active" Internet Service Providers would not benefit from the liability exception provided by Legislative Decree no. 70. According to that case-law, an ISP is deemed to be active whenever it carries out operations on the content provided by the user, such as in case it modifies the content or makes any enrichment of the content. Under certain cases, courts have held ISPs liable for the user's content for the mere facts that such content was somehow organised or enriched by the ISP (e.g. by organizing the contents in libraries or categories, etc. or monetised by showing ads).


title: Section 230

text: Failing to investigate the material or to make inquiries of the user concerned may amount to negligence in this context: "Jensen v Clark" [1982] 2 NZLR 268.


title: Section 230

text: Directive 2000/31/CE was transposed into the law. Article 6 of the law establishes safe haven for hosting provider as long as they follow certain rules.


title: Section 230

text: In "LICRA vs. Yahoo!", the High Court ordered Yahoo! to take affirmative steps to filter out Nazi memorabilia from its auction site. Yahoo!, Inc. and its then president Timothy Koogle were also criminally charged, but acquitted.


title: Section 230

text: In 1997, Felix Somm, the former managing director for CompuServe Germany, was charged with violating German child pornography laws because of the material CompuServe's network was carrying into Germany. He was convicted and sentenced to two years probation on May 28, 1998. He was cleared on appeal on November 17, 1999.


title: Section 230

text: The Oberlandesgericht (OLG) Cologne, an appellate court, found that an online auctioneer does not have an active duty to check for counterfeit goods (Az 6 U 12/01).


title: Section 230

text: In one example, the first-instance district court of Hamburg issued a temporary restraining order requiring message board operator Universal Boards to review all comments before they can be posted to prevent the publication of messages inciting others to download harmful files. The court reasoned that "the publishing house must be held liable for spreading such material in the forum, regardless of whether it was aware of the content."


title: Section 230

text: The laws of libel and defamation will treat a disseminator of information as having "published" material posted by a user, and the onus will then be on a defendant to prove that it did not know the publication was defamatory and was not negligent in failing to know: "Goldsmith v Sperrings Ltd" (1977) 2 All ER 566; "Vizetelly v Mudie's Select Library Ltd" (1900) 2 QB 170; "Emmens v Pottle & Ors" (1885) 16 QBD 354.


title: Section 230

text: In an action against a website operator, on a statement posted on the website, it is a defence to show that it was not the operator who posted the statement on the website. The defence is defeated if it was not possible for the claimant to identify the person who posted the statement, or the claimant gave the operator a notice of complaint and the operator failed to respond in accordance with regulations.


title: Walter Emanuel Jones

text: Walter Emanuel Jones (born November 30, 1970) is an American actor, martial artist and dancer, known for playing the role of Zack Taylor, the original Black Ranger on the hit television series "Mighty Morphin Power Rangers".


title: Walter Emanuel Jones

text: He also appeared in successful television shows including "Family Matters", "Step by Step", "Sabrina, the Teenage Witch", "Moesha", "Buffy the Vampire Slayer", "Early Edition", "NYPD Blue", "", "Off Centre" and "The Shield".


title: Walter Emanuel Jones

text: He gave his voice talent to animated movies including "Open Season 2" (2008) and "Cloudy with a Chance of Meatballs 2" (2013).


title: Walter Emanuel Jones

text: Jones was born and raised in Detroit. He lost the middle finger on his left hand at the age of 4. He began his career by an uncredited role in the successful TV show "Beverly Hills, 90210". In 1992, he took part in the "Malcolm X" movie.


title: Walter Emanuel Jones

text: Jones played the character of Zack Taylor, the original "Black Power Ranger" in the "Power Rangers" series. He was written out of the series midway through the second season, after a contract and pay dispute, and was replaced by Johnny Yong Bosch as the Black Ranger. Jones returned to "Power Rangers" in the "Lost Galaxy" season (1999) where he played the voice of Hexuba's Nightmare Monster in the episode "Dream Battle"; he also acted in an episode of "" (2002) entitled "Forever Red" in which many previous Red Rangers teamed up. Again, he did not appear as his original character, Zack, but rather provided the voice for one of the antagonists, a general in the Machine Empire named Gerrok. He was also one of the special commentators, along with fellow co-star Amy Jo Johnson, on the "1993" episode of "I Love the '90s". He also reunited with Austin St. John (with whom he formed a close friendship during their time together on the show) as co-host for a special airing of the original pilot episode of "Power Rangers" called "The Lost Episode".


title: Walter Emanuel Jones

text: Jones was the very first actor to do voicework for any character other than a Ranger (mainly for monsters or villains) on a "Power Rangers" show after having a role as a Ranger himself. Other former Rangers who would do voicework after Jones included Archie Kao, Catherine Sutherland, Jason Faunt, Valerie Vernon, Sean Cw Johnson and Johnny Yong Bosch.


title: Walter Emanuel Jones

text: Jones was a lead character in the teen drama Malibu Shores playing "Mouse". Jones also had major roles in the independent movie "The Dogwalker". He has appeared in other well-known productions, including a small part in "Buffy the Vampire Slayer" in the season 4 episode "Fear, Itself" and the Disney Channel Original Movie, "Brink!". He also appeared as Harlan Band in the Nickelodeon series "Space Cases", his second role as a main character and as a teenager. He guest starred in an episode of "Family Matters" as Kissel, and portrayed a supporting character in the first season of "The Shield" named Rondell Robinson, a drug dealer. He had a small role in the film "Suckers" in which he played a character named Clay. He also appeared in many successful TV shows including "Family Matters", "Step by Step", "Sabrina, the Teenage Witch", "Moesha", "Early Edition", "NYPD Blue", "" and "Off Centre". Additionally, he played a small role in the film "House of the Dead 2" as "locker zombie". Jones also had a cameo appearance in the movie "".


title: Walter Emanuel Jones

text: Jones also had a major role in the backyard wrestling movie "Backyard Dogs", which spent time as the lowest-rated movie on the Internet Movie Database. As of July 2007, it is no longer on the list as it was straight-to-video. Jones voiced characters in the successful animated movies "Open Season 2" (2008) and "Cloudy with a Chance of Meatballs 2" (2013).


title: Walter Emanuel Jones

text: He appeared briefly as a salsa dance instructor on "Age of Love". He also appeared in "Mighty Med" and as a poet in an episode of Disney XD's "Pair of Kings". Additionally Jones has also been featured in a PetSmart commercial and a Bank of America commercial as well. In 2002, he appeared in the movie "Love and a Bullet". In 2016, he appeared in the movie "" and the short movie "Star Trek : Captain Pike".


title: Walter Emanuel Jones

text: In January 2019, he starred in "The Order" alongside Austin St. John, Catherine Sutherland, David Yost, Johnny Yong Bosch, Paul Schrier, Karan Ashley, Steve Cardenas, Erin Cahill, Blake Foster, Nakia Burrise, Hilary Shepard Turner, Dan Southworth, Alyson Sullivan, Deborah Estelle Phillips and Azim Rizk.


title: People Nation

text: People Nation is an alliance of street gangs generally associated with the Chicago area. They are rivals of the Folk Nation alliance of gangs.


title: People Nation

text: The People Nation was formed in reaction to the creation of the Folk Nation alliance of gangs. In 1978, the El Rukn (now Black P. Stones), Vice Lords and Latin Kings formed an alliance system of their own, and titled it the "People".


title: People Nation

text: Jeff Fort of El Rukns, Bobby Gore of the Vice Lords, and Gustavo Colon of the Latin Kings were instrumental in the forming of this alliance. Among initial members to the People were the Mickey Cobras (then named the Cobra Stones), Bishops, Spanish Lords, soon after the Gaylords and the South Side Popes.


title: People Nation

text: Gangs demonstrate their particular alignment by "representing" through symbols, colors, graffiti, hand signs, and words. Representing also encompasses physical orientation to the left side of the body. The People Nation Gangs wear all identifiers to the left. An earring in the left, a left pants leg rolled up, and a cap tilted to the left may all indicate affiliation to the alliance.


title: People Nation

text: The People Nation's hand sign is thrown to the left shoulder. The gang members fold their arms in a manner that is pointed to the left. The People Nation alliance in most instances uses a five-pointed star in their gang graffiti.


title: People Nation

text: The five-pointed star has its origins with the Blackstone Rangers/Black P. Stone Ranger Nation, one of the larger street gangs. The alliance's term "five alive, six must die" is in reference to the five-pointed star versus the six-pointed star of their rivals in the Folk Nation alliance. Commonly used by the People Nation alliance are drawings of pitchforks pointed down in disrespect to the Folk Nation alliance.


title: People Nation

text: Certain terms are used by the People Nation alliance, such as "all is well" when greeting each other. The five-pointed star is not the only symbol used by the People Nation. Others include a 3D pyramid, a five-pointed crown, a die with its front-side showing five dots, a crescent moon with its concave side facing to the right and sometimes with a small five-pointed star to the right of that moon symbol.


title: KaiOS

text: KaiOS is a mobile Linux distribution for keypad feature phones based on the Firefox OS open-source project. It is developed by KaiOS Technologies (Hong Kong) Limited; a company based in Hong Kong, whose largest shareholder is Chinese multinational electronics conglomerate TCL Corporation."" KaiOS runs on feature phones made with low-power hardware and low power consumption (and therefore long battery life). KaiOS supports modern connectivity technologies like 4G LTE E, VoLTE, GPS, and Wi-Fi. KaiOS runs HTML5-based apps. KaiOS supports over-the-air updates and has "KaiStore", a dedicated app marketplace. Some applications are preloaded, including Facebook and YouTube. , there are 500+ apps in KaiStore. The mobile operating system is comparatively lightweight on hardware resource usage, and is able to run on devices with just 256 megabytes (MB) of memory.


title: KaiOS

text: The operating system was first released in 2017, and is developed by KaiOS Technologies Inc., a Hong Kong-based company headed by CEO Sebastien Codeville, with offices in other countries. In June 2018, Google invested US$22 million in the operating system. India-based telecom operator Reliance Jio also invested $7 million for a 16% stake in the company. In May 2019, KaiOS raised an additional US$50 million from Cathay Innovation, and previous investors Google and TCL Holdings.


title: KaiOS

text: In market share study results announced in May 2018, KaiOS beat Apple's iOS for second place in India, while Android dominates with 71%, albeit down by 9%. KaiOS growth is being largely attributed to the popularity of the competitively-priced JioPhone. In Q1 2018, 23 million KaiOS devices were produced.


title: KaiOS

text: In March 2020, Mozilla and KaiOS Technologies announced a partnership to update KaiOS with a modern version of the Gecko browser engine, and more closely aligned testing infrastructure. This change should give KaiOS four years worth of performance and security improvements and new features, including TLS 1.3, WebAssembly, WebGL 2.0, Progressive Web Apps, new video codecs like WebP, AV1, and modern JavaScript and Cascading Style Sheets (CSS) features.


title: KaiOS

text: Devices that are installed with KaiOS include (KaiStore may not be included, if device vendor removed it):


title: KaiOS

text: All KaiOS devices have ABC keypad with exceptions being Jiophone 2 and Ghia GQWERTY having a QWERTY keypad.


title: KaiOS

text: , KaiOS Technologies has partnered with Mozilla, Airfind, Avenir Telecom (Energizer), Facebook, Google, Bullitt, Doro, HMD Global, Micromax, NXP, Spreadtrum, Qualcomm, Jio, Sprint, AT&T, T-Mobile, and Orange S.A.


title: KaiOS

text: In March 2020, KaiOS Technologies partnered with Mozilla to bring the modern version of Gecko browser engine to future KaiOS builds.


title: KaiOS

text: With the release of the Nokia 8110 4G, an active community around both KaiOS and the phone arose and released the first version of a jailbreak. This gave users the ability to use apps outside KaiStore including old Firefox OS apps on KaiOS devices, as well as flashing their devices with community-created ROMs, such as GerdaOS.


title: 2016 ICC World Twenty20

text: The 2016 ICC World Twenty20 was the sixth edition of the ICC World Twenty20, the world championship of Twenty20 International cricket. It was held in India from 8 March to 3 April 2016, and was the first edition to be hosted by India.


title: 2016 ICC World Twenty20

text: Seven cities hosted matches in the tournament – Bangalore, Dharamshala, Kolkata, Mohali, Mumbai, Nagpur, and New Delhi. For the second time, there were 16 participating teams, 10 of which qualified automatically due to their status as full members of the International Cricket Council (ICC), and another six qualifying through the 2015 World Twenty20 Qualifier. The tournament was divided into three stages. In the first stage, the eight lowest-ranked teams played off, with the top two joining the eight highest-ranked teams in the Super 10 stage. Finally, the top four teams overall contested the knockout stage. In the final, played at Eden Gardens, Kolkata, the West Indies defeated England by four wickets. Indian batsman Virat Kohli was named the player of the tournament, while Bangladesh's Tamim Iqbal and Afghanistan's Mohammad Nabi led the tournament in runs and wickets, respectively.


title: 2016 ICC World Twenty20

text: For the second time, the tournament featured 16 teams. All ten full members qualified automatically, joined by the six associate members: Ireland, Scotland, Netherlands, Afghanistan, Hong Kong and Oman who all qualified through the 2015 ICC World Twenty20 Qualifier, played in Ireland and Scotland between 6 and 26 July 2015. Oman made its debut in the tournament.


title: 2016 ICC World Twenty20

text: The top eight Full Member nations in the ICC T20I Championship rankings as of 30 April 2014 automatically progressed to the Super 10 stage, with the remaining eight teams competing in the group stage. From the group stage, Bangladesh and associate nation Afghanistan advanced to the Super 10 stage. Test playing nation Zimbabwe and Ireland failed to advance to the Super 10 stage for the second time.


title: 2016 ICC World Twenty20

text: In October 2015 Shahryar Khan, chairman of the Pakistan Cricket Board (PCB), said that Pakistan would consider pulling out of the tournament if the series against India did not go ahead. Although the series was ultimately cancelled, Pakistan received government clearance in February 2016 to visit India to compete in the tournament. In early March, Pakistan sent a delegation to assess the security arrangements ahead of the tournament. Following the visit, the match between India and Pakistan was moved from Dharamsala to Eden Gardens in Kolkata, at the request of the PCB, and on 11 March, Pakistan confirmed their participation at the tournament.


title: 2016 ICC World Twenty20

text: The match referees’ responsibilities throughout the men's tournament were shared between six members of the Elite Panel of ICC Referees :


title: 2016 ICC World Twenty20

text: The on-field responsibilities for officiating the men's tournament were shared by all 12 of the Elite Panel of ICC Umpires and three umpires from the International Panel of ICC Umpires :


title: 2016 ICC World Twenty20

text: On 21 July 2015, the Indian cricket board announced the name of the cities which will be hosting the matches. Bangalore, Chennai, Dharamshala, Mohali, Mumbai, Nagpur and New Delhi were the venues along with Kolkata, which also hosted the final of the event. Chennai could not host a match due to legal issues regarding the construction of three stands at the M. A. Chidambaram Stadium. VCA Stadium, Nagpur hosted all Group B games and HPCA Stadium, Dharamshala hosted all Group A matches. The India vs Pakistan match, was scheduled to be played at HPCA Stadium. With the announcement that HPCA authority could not provide the required security for Pakistani team, the match was moved to Eden Gardens, Kolkata.


title: 2016 ICC World Twenty20

text: There were some initial concerns about the Feroz Shah Kotla stadium in Delhi hosting the first semi-final, due to one of the block of stands needing a clearance certificate from the South Delhi Municipal Corporation (SDMC). If the clearance was not approved, the ICC and BCCI were planning an alternative venue to host the match. However, on 23 March, the Delhi & District Cricket Association were granted clearance from the SDMC to use the block at the Feroz Shah Kotla.


title: 2016 ICC World Twenty20

text: The 2016 ICC World Twenty20 declared a total prize money pool of $10 million for the tournament, 33% more than the 2014 edition. The prize money was distributed according to the performance of the teams as follows:


title: 2016 ICC World Twenty20

text: The following warm-up matches for the 2016 ICC World Twenty20 were played between 3 March and 15 March between all participants.


title: 2016 ICC World Twenty20

text: Due to security concerns, the ICC stated that if Pakistan finished second in Group 2, the two semi final venues would be switched.


title: 2016 ICC World Twenty20

text: England and the West Indies were both contesting the tournament final for a second time, having won one previous tournament each (in 2010 and 2012, respectively). West Indian captain Darren Sammy won the toss and elected to bowl, as he had done throughout the tournament. England posted a total of 155/9 from their 20 overs, with Joe Root top-scoring with 54 runs from 36 balls. For the West Indies, Carlos Brathwaite took 3/23 and Samuel Badree took 2/16, including a maiden. The West Indies subsequently reached their target with just two balls to spare. They required 19 runs from the final over, bowled by Ben Stokes, which Brathwaite reached by hitting four consecutive sixes. Marlon Samuels scored 85 not out from 66 balls – the highest score in World T20 final history – and was named the final's Man of the Match for the second time. The match was played to a near-capacity crowd, with 66,000 people in attendance.


title: 2016 ICC World Twenty20

text: The leading run-scorer in the tournament was Tamim Iqbal, with 295, and the highest wicket-taker Mohammad Nabi with 12.


title: Tidal power

text: Tidal power or tidal energy is harnessed by converting energy from tides into useful forms of power, mainly electricity using various methods.


title: Tidal power

text: Although not yet widely used, tidal energy has the potential for future electricity generation. Tides are more predictable than the wind and the sun. Among sources of renewable energy, tidal energy has traditionally suffered from relatively high cost and limited availability of sites with sufficiently high tidal ranges or flow velocities, thus constricting its total availability. However, many recent technological developments and improvements, both in design (e.g. dynamic tidal power, tidal lagoons) and turbine technology (e.g. new axial turbines, cross flow turbines), indicate that the total availability of tidal power may be much higher than previously assumed and that economic and environmental costs may be brought down to competitive levels.


title: Tidal power

text: Historically, tide mills have been used both in Europe and on the Atlantic coast of North America. The incoming water was contained in large storage ponds, and as the tide goes out, it turns waterwheels that use the mechanical power to mill grain. The earliest occurrences date from the Middle Ages, or even from Roman times. The process of using falling water and spinning turbines to create electricity was introduced in the U.S. and Europe in the 19th century.


title: Tidal power

text: Electricity generation from marine technologies increased an estimated 16% in 2018, and an estimated 13% in 2019. Policies promoting R&D are needed to achieve further cost reductions and large-scale development. The world's first large-scale tidal power plant was France's Rance Tidal Power Station, which became operational in 1966. It was the largest tidal power station in terms of output until Sihwa Lake Tidal Power Station opened in South Korea in August 2011. The Sihwa station uses sea wall defense barriers complete with 10 turbines generating 254 MW.


title: Tidal power

text: Tidal energy is taken from the Earth's oceanic tides. Tidal forces result from periodic variations in gravitational attraction exerted by celestial bodies. These forces create corresponding motions or currents in the world's oceans. This results in periodic changes in sea levels, varying as the Earth rotates. These changes are highly regular and predictable, due to the consistent pattern of the Earth's rotation and the Moon's orbit around the Earth. The magnitude and variations of this motion reflect the changing positions of the Moon and Sun relative to the Earth, the effects of Earth's rotation, and local geography of the seafloor and coastlines.


title: Tidal power

text: Tidal power is the only technology that draws on energy inherent in the orbital characteristics of the Earth–Moon system, and to a lesser extent in the Earth–Sun system. Other natural energies exploited by human technology originate directly or indirectly from the Sun, including fossil fuel, conventional hydroelectric, wind, biofuel, wave and solar energy. Nuclear energy makes use of Earth's mineral deposits of fissionable elements, while geothermal power utilizes the Earth's internal heat, which comes from a combination of residual heat from planetary accretion (about 20%) and heat produced through radioactive decay (80%).


title: Tidal power

text: A tidal generator converts the energy of tidal flows into electricity. Greater tidal variation and higher tidal current velocities can dramatically increase the potential of a site for tidal electricity generation. On the other hand, tidal energy has high reliability, excellent energy density, and high durability.


title: Tidal power

text: Because the Earth's tides are ultimately due to gravitational interaction with the Moon and Sun and the Earth's rotation, tidal power is practically inexhaustible, and is thus classified as a renewable energy resource. Movement of tides causes a loss of mechanical energy in the Earth-Moon system: this results from pumping of water through natural restrictions around coastlines and consequent viscous dissipation at the seabed and in turbulence. This loss of energy has caused the rotation of the Earth to slow in the 4.5 billion years since its formation. During the last 620 million years the period of rotation of the Earth (length of a day) has increased from 21.9 hours to 24 hours; in this period the Earth-Moon system has lost 17% of its rotational energy. While tidal power will take additional energy from the system, the effect is negligible and would not be noticeable in the foreseeable future.


title: Tidal power

text: Tidal stream generators make use of the kinetic energy of moving water to power turbines, in a similar way to wind turbines that use the wind to power turbines. Some tidal generators can be built into the structures of existing bridges or are entirely submersed, thus avoiding concerns over aesthetics or visual impact. Land constrictions such as straits or inlets can create high velocities at specific sites, which can be captured using turbines. These turbines can be horizontal, vertical, open, or ducted.


title: Tidal power

text: Tidal barrages use potential energy in the difference in height (or hydraulic head) between high and low tides. When using tidal barrages to generate power, the potential energy from a tide is seized through the strategic placement of specialized dams. When the sea level rises and the tide begins to come in, the temporary increase in tidal power is channeled into a large basin behind the dam, holding a large amount of potential energy. With the receding tide, this energy is then converted into mechanical energy as the water is released through large turbines that create electrical power through the use of generators. Barrages are essentially dams across the full width of a tidal estuary.


title: Tidal power

text: Dynamic tidal power (or DTP) is a theoretical technology that would exploit an interaction between potential and kinetic energies in tidal flows. It proposes that very long dams (for example: 30–50 km length) be built from coasts straight out into the sea or ocean, without enclosing an area. Tidal phase differences are introduced across the dam, leading to a significant water-level differential in shallow coastal seas – featuring strong coast-parallel oscillating tidal currents such as found in the UK, China, and Korea. Induced tides (TDP) could extend the geographic viability of a new hydro-atmospheric concept 'LPD' (lunar pulse drum) discovered by a Devon innovator in which a tidal 'water piston' pushes or pulls a metered jet of air to a rotary air-actuator & generator. The principle was demonstrated at London Bridge June 2019. Plans for a 30 m, 62.5kwh 'pilot' installation on a (Local Authority) tidal estuary shoreline in the Bristol Channel are underway.


title: Tidal power

text: A new tidal energy design option is to construct circular retaining walls embedded with turbines that can capture the potential energy of tides. The created reservoirs are similar to those of tidal barrages, except that the location is artificial and does not contain a pre-existing ecosystem.


title: Tidal power

text: The lagoons can also be in double (or triple) format without pumping or with pumping that will flatten out the power output. The pumping power could be provided by excess to grid demand renewable energy from for example wind turbines or solar photovoltaic arrays. Excess renewable energy rather than being curtailed could be used and stored for a later period of time. Geographically dispersed tidal lagoons with a time delay between peak production would also flatten out peak production providing near baseload production at a higher cost than other alternatives such as district heating renewable energy storage. The cancelled Tidal Lagoon Swansea Bay in Wales, United Kingdom would have been the first tidal power station of this type once built.


title: Tidal power

text: The first study of large scale tidal power plants was by the US Federal Power Commission in 1924. If built, power plants would have been located in the northern border area of the US state of Maine and the southeastern border area of the Canadian province of New Brunswick, with various dams, powerhouses, and ship locks enclosing the Bay of Fundy and Passamaquoddy Bay (note: see map in reference). Nothing came of the study, and it is unknown whether Canada had been approached about the study by the US Federal Power Commission.


title: Tidal power

text: In 1956, utility Nova Scotia Light and Power of Halifax commissioned a pair of studies into commercial tidal power development feasibility on the Nova Scotia side of the Bay of Fundy. The two studies, by Stone & Webster of Boston and by Montreal Engineering Company of Montreal, independently concluded that millions of horsepower (i.e. gigawatts) could be harnessed from Fundy but that development costs would be commercially prohibitive.


title: Tidal power

text: There was also a report on the international commission in April 1961 entitled "Investigation of the International Passamaquoddy Tidal Power Project" produced by both the US and Canadian Federal Governments. According to benefit to costs ratios, the project was beneficial to the US but not to Canada. A highway system along the top of the dams was envisioned as well of


title: Tidal power

text: A study was commissioned by the Canadian, Nova Scotian and New Brunswick governments (Reassessment of Fundy Tidal Power) to determine the potential for tidal barrages at Chignecto Bay and Minas Basin – at the end of the Fundy Bay estuary. There were three sites determined to be financially feasible: Shepody Bay (1550 MW), Cumberland Basin (1085 MW), and Cobequid Bay (3800 MW). These were never built despite their apparent feasibility in 1977.


title: Tidal power

text: The Snohomish PUD, a public utility district located primarily in Snohomish County, Washington State, began a tidal energy project in 2007. In April 2009 the PUD selected OpenHydro, a company based in Ireland, to develop turbines and equipment for eventual installation. The project as initially designed was to place generation equipment in areas of high tidal flow and operate that equipment for four to five years. After the trial period the equipment would be removed. The project was initially budgeted at a total cost of $10 million, with half of that funding provided by the PUD out of utility reserve funds, and half from grants, primarily from the US federal government. The PUD paid for part of this project from reserves and received a $900,000 grant in 2009 and a $3.5 million grant in 2010 in addition to using reserves to pay an estimated $4 million of costs. In 2010 the budget estimate was increased to $20 million, half to be paid by the utility, half by the federal government. The utility was unable to control costs on this project, and by October 2014, the costs had ballooned to an estimated $38 million and were projected to continue to increase. The PUD proposed that the federal government provide an additional $10 million towards this increased cost, citing a gentlemen's agreement. When the federal government refused to pay this, the PUD cancelled the project after spending nearly $10 million from reserves and grants. The PUD abandoned all tidal energy exploration after this project was cancelled and does not own or operate any tidal energy sources.


title: Tidal power

text: In 1966, Électricité de France opened the Rance Tidal Power Station, located on the estuary of the Rance River in Brittany. It was the world's first tidal power station. The plant was for 45 years the largest tidal power station in the world by installed capacity: Its 24 turbines reach peak output at 240 megawatts (MW) and average 57 MW, a capacity factor of approximately 24%.


title: Tidal power

text: The world's first marine energy test facility was established in 2003 to start the development of the wave and tidal energy industry in the UK. Based in Orkney, Scotland, the European Marine Energy Centre (EMEC) has supported the deployment of more wave and tidal energy devices than at any other single site in the world. EMEC provides a variety of test sites in real sea conditions. Its grid connected tidal test site is located at the Fall of Warness, off the island of Eday, in a narrow channel which concentrates the tide as it flows between the Atlantic Ocean and North Sea. This area has a very strong tidal current, which can travel up to in spring tides. Tidal energy developers that have tested at the site include: Alstom (formerly Tidal Generation Ltd); ANDRITZ HYDRO Hammerfest; Atlantis Resources Corporation; Nautricity; OpenHydro; Scotrenewables Tidal Power; Voith. The resource could be 4 TJ per year. Elsewhere in the UK, annual energy of 50 TWh can be extracted if 25 GW capacity is installed with pivotable blades.


title: Tidal power

text: Tidal power can affect marine life. The turbines' rotating blades can accidentally kill swimming sea life. Projects such as the one in Strangford include a safety mechanism that turns off the turbine when marine animals approach. However, this feature causes a major loss in energy because of the amount of marine life that passes through the turbines. Some fish may avoid the area if threatened by a constantly rotating or noisy object. Marine life is a huge factor when siting tidal power energy generators, and precautions are taken to ensure that as few marine animals as possible are affected by it. The Tethys database provides access to scientific literature and general information on the potential environmental effects of tidal energy. In terms of global warming potential (i.e. carbon footprint), the impact of tidal power generation technologies ranges between 15 and 37 gCO-eq/kWhe, with a median value of 23.8 gCO-eq/kWhe. This is in line with the impact of other renewables like wind and solar power, and significantly better than fossil-based technologies.


title: Tidal power

text: The main environmental concern with tidal energy is associated with blade strike and entanglement of marine organisms as high-speed water increases the risk of organisms being pushed near or through these devices. As with all offshore renewable energies, there is also a concern about how the creation of electromagnetic fields and acoustic outputs may affect marine organisms. Because these devices are in the water, the acoustic output can be greater than those created with offshore wind energy. Depending on the frequency and amplitude of sound generated by the tidal energy devices, this acoustic output can have varying effects on marine mammals (particularly those who echolocate to communicate and navigate in the marine environment, such as dolphins and whales). Tidal energy removal can also cause environmental concerns such as degrading far-field water quality and disrupting sediment processes. Depending on the size of the project, these effects can range from small traces of sediment building up near the tidal device to severely affecting nearshore ecosystems and processes.


title: Tidal power

text: Installing a barrage may change the shoreline within the bay or estuary, affecting a large ecosystem that depends on tidal flats. Inhibiting the flow of water in and out of the bay, there may also be less flushing of the bay or estuary, causing additional turbidity (suspended solids) and less saltwater, which may result in the death of fish that act as a vital food source to birds and mammals. Migrating fish may also be unable to access breeding streams, and may attempt to pass through the turbines. The same acoustic concerns apply to tidal barrages. Decreasing shipping accessibility can become a socio-economic issue, though locks can be added to allow slow passage. However, the barrage may improve the local economy by increasing land access as a bridge. Calmer waters may also allow better recreation in the bay or estuary. In August 2004, a humpback whale swam through the open sluice gate of the Annapolis Royal Generating Station at slack tide, ending up trapped for several days before eventually finding its way out to the Annapolis Basin.


title: Tidal power

text: Environmentally, the main concerns are blade strike on fish attempting to enter the lagoon, the acoustic output from turbines, and changes in sedimentation processes. However, all these effects are localized and do not affect the entire estuary or bay.


title: Tidal power

text: Saltwater causes corrosion in metal parts. It can be difficult to maintain tidal stream generators due to their size and depth in the water. The use of corrosion-resistant materials such as stainless steels, high-nickel alloys, copper-nickel alloys, nickel-copper alloys and titanium can greatly reduce, or eliminate corrosion damage.


title: Tidal power

text: Mechanical fluids, such as lubricants, can leak out, which may be harmful to the marine life nearby. Proper maintenance can minimize the number of harmful chemicals that may enter the environment.


title: Tidal power

text: The biological events that happen when placing any structure in an area of high tidal currents and high biological productivity in the ocean will ensure that the structure becomes an ideal substrate for the growth of marine organisms. In the references of the Tidal Current Project at Race Rocks in British Columbia, this is documented.


title: Tidal power

text: Several structural materials and coatings were tested by the Lester Pearson College divers to assist Clean Current in reducing fouling on the turbine and other underwater infrastructure.


title: Tidal power

text: Tidal energy has a high initial cost, which may be one of the reasons why it is not a popular source of renewable energy, although research has shown that the public is willing to pay for and support research and development of tidal energy devices. The methods of generating electricity from tidal energy are relatively new technology. Tidal energy is however still very early in the research process and it may be possible to reduce costs in future. The cost-effectiveness varies according to the site of the tidal generators. One indication of cost-effectiveness is the Gibrat ratio, which is the length of the barrage in metres divided by the annual energy production in kilowatt hours.


title: Tidal power

text: As tidal energy is reliable, it can reasonably be predicted how long it will take to pay off the high up-front cost of these generators. Due to the success of a greatly simplified design, the orthogonal turbine offers considerable cost savings. As a result, the production period of each generating unit is reduced, lower metal consumption is needed and technical efficiency is greater.


title: Tidal power

text: The high load factors resulting from the fact that water is 800 times denser than air, and the predictable and reliable nature of tides compared with the wind, make tidal energy particularly attractive for electric power generation. Condition monitoring is the key for exploiting it cost-efficiently.


title: Racial policy of Nazi Germany

text: The racial policy of Nazi Germany was a set of policies and laws implemented in Nazi Germany under the dictatorship of Adolf Hitler, based on a specific racist doctrine asserting the superiority of the Aryan race, which claimed scientific legitimacy. This was combined with a eugenics programme that aimed for racial hygiene by compulsory sterilization and extermination of those who they saw as "Untermenschen" ("sub-humans"), which culminated in the Holocaust.


title: Racial policy of Nazi Germany

text: Nazi policies labeled centuries-long residents in German territory who were not ethnic Germans such as Jews (understood in Nazi racial theory as a "Semitic" people of Levantine origins), Roma (also known as Gypsies, an "Indo-Aryan" people of Indian subcontinent origins), along with the vast majority of Slavs (mainly ethnic Poles, Serbs, Russians etc.), and most non-Europeans as inferior non-Aryan subhumans (i.e. non-Nordics, under the Nazi appropriation of the term "Aryan") in a racial hierarchy that placed the "Herrenvolk" ("master race") of the "Volksgemeinschaft" ("people's community") at the top.


title: Racial policy of Nazi Germany

text: The racial policy of the Nazi Party and the German state was organized through the Office for Racial policy, which published circulars and directives to relevant administrative organs, newspapers, and educational institutes.


title: Racial policy of Nazi Germany

text: Adolf Hitler himself along with other members of the Nazi Party in the Weimar Republic (1918–1933) were greatly influenced by several 19th- and early 20th-century thinkers and proponents of philosophical, onto-epistemic, and theoretical perspectives on ecological anthropology, scientific racism, holistic science, and organicism regarding the constitution of complex systems and the theorization of organic-racial societies. In particular, one of the most significant ideological influences on the Nazis was the 19th-century German nationalist philosopher Johann Gottlieb Fichte, whose works had served as an inspiration to Hitler and other Nazi Party members, and whose ideas were implemented among the philosophical and ideological foundations of Nazi-oriented Völkisch nationalism.


title: Racial policy of Nazi Germany

text: The Aryan Master Race conceived by Adolf Hitler and the other Nazis graded humans on a scale of pure Aryans to non-Aryans (who were viewed as subhumans). At the top of the scale of pure Aryans were Germans and other Germanic and Northern European peoples, including the Dutch, Scandinavians, and the English. Latins were held to be somewhat inferior, but were tolerated; and the French were thought to have a suitable admixture of Germanic blood.


title: Racial policy of Nazi Germany

text: The feeling that Germans were the Aryan "Herrenvolk" (Aryan master race) was widely spread among the German public through Nazi propaganda and among Nazi officials throughout the ranks, in particular when the Reichskommissar of Ukraine Erich Koch said:


title: Racial policy of Nazi Germany

text: The Nazis considered the Slavs as Non-Aryan "Untermenschen" ("sub-humans") who were to be enslaved and exterminated by Germans. Slavic nations such as the Ukrainians, Czechs, Slovaks, Bulgarians and Croats who collaborated with Nazi Germany were still being perceived as not racially "pure" enough to reach the status of Germanic peoples, yet they were eventually considered ethnically better than the rest of the Slavs, mostly due to pseudoscientific theories about these nations having a considerable admixture of Germanic blood. In countries where these people lived, there were according to Nazis small groups of non-Slavic German descendants. These people underwent a "racial selection" process to determine whether or not they were "racially valuable", if the individual passed they would be re-Germanised and forcefully taken from their families in order to be raised as Germans. This secret plan Generalplan Ost ("Master Plan East") aimed at expulsion, enslavement and extermination of most Slavic people. Nazi policy towards them changed during World War II as a pragmatic means to resolve military manpower shortages: they were allowed, with certain restrictions, to serve in the Waffen-SS, in spite of being considered subhumans. Nazi propaganda portrayed people in Eastern Europe with an Asiatic appearance to be the result of intermingling between the native Slavic populations and Asiatic or Mongolian races as sub-humans dominated by the Jews with the help of Bolshevism. At the bottom of the racial scale of non-Aryans were Jews, ethnic Poles, ethnic Serbs and other Slavic people, Romani, and black people. The Nazis originally sought to rid the German state of Jews and Romani by means of deportation (and later extermination), while blacks were to be segregated and eventually eliminated through compulsory sterilization.


title: Racial policy of Nazi Germany

text: Volkisch theorists believed that Germany's Teutonic ancestors had spread out from Germany throughout Europe. Of the Germanic tribes that spread through Europe, the theorists identified that the Burgundians, Franks, and Western Goths joined with the Gauls to make France; the Lombards moved south and joined with the Italians; the Jutes made Denmark; the Angles and Saxons made England; the Flemings made Belgium; and other tribes made the Netherlands.


title: Racial policy of Nazi Germany

text: Nazi racial beliefs of the superiority of an Aryan master race arose from earlier proponents of a supremacist conception of race such as the French novelist and diplomat Arthur de Gobineau, who published a four-volume work titled "An Essay on the Inequality of the Human Races" (translated into German in 1897). Gobineau proposed that the Aryan race was superior, and urged the preservation of its cultural and racial purity. Gobineau later came to use and reserve the term Aryan only for the "German race" and described the Aryans as 'la race germanique'. By doing so he presented a racist theory in which Aryans–that is Germans–were all that was positive. Houston Stewart Chamberlain's work "The Foundations of the Nineteenth Century" (1900), one of the first to combine Social Darwinism with antisemitism, describes history as a struggle for survival between the Germanic peoples and the Jews, whom he characterized as an inferior and dangerous group. The two-volume book "Foundations of Human Hereditary Teaching and Racial Hygiene" (1920–21) by Eugen Fischer, Erwin Baur, and Fritz Lenz, used pseudoscientific studies to conclude that the Germans were superior to the Jews intellectually and physically, and recommended eugenics as a solution. Madison Grant's work "The Passing of the Great Race" (1916) advocated Nordicism and proposed using a eugenic program to preserve the Nordic race. After reading the book, Hitler called it "my Bible".


title: Racial policy of Nazi Germany

text: Racist author and Nordic supremacist Hans F. K. Günther, who influenced Nazi ideology, wrote in his "Race Lore of German People" ("Rassenkunde des deutschen Volkes") about the danger of "Slavic blood of Eastern race" mixing with the German and combined virulent nationalism with Antisemitism. Günther became an epitome of corrupt and politicized pseudo-science in post-war Germany. Among the topics of his research were attempts to prove that Jews had an unpleasant "hereditary smell". While one of the most prominent Nazi writers, Günther still was not considered the most "cutting edge" by Nazis.


title: Racial policy of Nazi Germany

text: The July 1933 Law for the Prevention of Hereditarily Diseased Offspring – written by Ernst Rüdin and other theorists of "racial hygiene" – established "Genetic Health Courts" which decided on compulsory sterilization of "any person suffering from a hereditary disease." These included, for the Nazis, those suffering from "Congenital Mental Deficiency", schizophrenia, "Manic-Depressive Insanity", "Hereditary Epilepsy", "Hereditary Chorea" (Huntington's), Hereditary Blindness, Hereditary Deafness, "any severe hereditary deformity", as well as "any person suffering from severe alcoholism". Further modifications of the law enforced sterilization of the "Rhineland bastards" (children of mixed German and African parentage).


title: Racial policy of Nazi Germany

text: The Nazi Party wanted to increase birthrates of those who were classified as racially elite. When the Party gained power in 1933, one of their first actions was to pass the Law for the Encouragement of Marriage. This law stated that all newly married couples of the Aryan race could receive a government loan. This loan was not simply paid back, rather a portion of it would be forgiven after the birth of each child. The purpose of this law was very clear and simple: to encourage newlyweds to have as many children as they could, so that the Aryan population would grow.


title: Racial policy of Nazi Germany

text: Approximately 525,000 Jews were living in Germany in 1933 (0.75% of the entire German population). Discrimination against Jews began immediately after the national seizure of power in 1933. The Nazi Party used populist antisemitic views to gain votes. Using the "stab-in-the-back legend", they blamed poverty, the Hyperinflation in the Weimar Republic, unemployment, and the loss of World War I and surrender by the "November Criminals" all on the Jews and "cultural Bolsheviks", the latter considered to be in a conspiracy with the Jews. German woes were attributed to the effects of the Treaty of Versailles. In 1933, persecution of the Jews became active Nazi policy. This was at first hindered by the lack of agreement on who qualified as a Jew as opposed to an Aryan; this caused legislators to balk at an antisemitic law for its ill-defined terms. Bernhard Lösener described it as "total chaos", with local authorities regarding anything from full Jewish background to Jewish blood as defining a Jew; Achim Gercke urged Jewish blood. Those of mixed descent ("Mischlinge") were especially problematic in their eyes. The first antisemitic law was promulgated with no clear definition of a Jew. Finally, the criterion was set at three or four Jewish grandparents; two or one rendered a person a "Mischling".


title: Racial policy of Nazi Germany

text: On April 1, 1933, the Nazi boycott of Jewish businesses was observed throughout Germany. Only six days later, the Law for the Restoration of the Professional Civil Service was passed, banning Jews from government jobs. It is notable that the proponents of this law, and the several thousand more that were to follow, most frequently explained them as necessary to prevent the infiltration of damaging, "alien-type" ("Artfremd") hereditary traits into the German national or racial community ("Volksgemeinschaft"). These laws meant that Jews were now indirectly and directly dissuaded or banned from privileged and superior positions reserved for "Aryan Germans". From then on, Jews were forced to work in more menial positions, becoming second-class citizens or to the point that they were "illegally residing" in Nazi Germany.


title: Racial policy of Nazi Germany

text: In the early years of Nazi rule, there were efforts to secure the elimination of Jews by expulsion; later, a more explicit commitment was made to extermination. On August 25, 1933, the Nazis signed the Haavara Agreement with Zionists to allow German Jews to emigrate to Palestine in exchange for a portion of their economic assets. The agreement offered a way to leave an increasingly hostile environment in Nazi Germany; by 1939, 60,000 German Jews (about 10% of the Jewish population) had emigrated there. Thereafter, Nazi policy eventually changed to one of total extermination. Nazi doctrine culminated in the Holocaust, or so-called "Final Solution", which was made official at the January 1942 Wannsee Conference.


title: Racial policy of Nazi Germany

text: Between 1935 and 1936, persecution of the Jews increased apace while the process of ""Gleichschaltung"" (lit.: "standardisation", the process by which the Nazis achieved complete control over German society) was implemented. In May 1935, Jews were forbidden to join the "Wehrmacht" (the armed forces), and in the summer of the same year, anti-semitic propaganda appeared in shops and restaurants. The Nuremberg Laws were passed around the time of the great Nazi rallies at Nuremberg; on September 15, 1935, the "Law for the Protection of German Blood and Honor" was passed. At first this criminalised sexual relations and marriage only between Germans and Jews, but later the law was extended to "Gypsies, Negroes and their bastard offspring"; it became punishable by law as "Rassenschande" or racial pollution. After this, the "Reich Citizenship Law" was passed, and was reinforced in November by a decree; it included only people of "German or related blood", which meant that all Jews were stripped of their citizenship and their official title became "subjects of the state". This meant that they were deprived of basic citizens' rights, e.g. the right to vote. This removal of citizens' rights was instrumental in the process of anti-semitic persecution: the process of denaturalization allowed the Nazis to exclude—"de jure"—Jews from the ""Volksgemeinschaft"" ("national community"), thus granting judicial legitimacy to their persecution and opening the way to harsher laws and, eventually, extermination of the Jews. Philosopher Hannah Arendt pointed out this important judicial aspect of the Holocaust in "The Origins of Totalitarianism" (1951), where she demonstrated that to violate human rights, Nazi Germany first deprived human beings of their citizenship. Arendt underlined that in the Declaration of the Rights of Man and of the Citizen, citizens' rights actually preceded human rights, as the latter needed the protection of a determinate state to be actually respected.


title: Racial policy of Nazi Germany

text: The drafting of the Nuremberg Laws has often been attributed to Hans Globke. Globke co-authored several aspects of the laws, such as the ordinance which legally required Jews with non-Jewish names to take on the additional first names Israel or Sara, along with the official legal commentary on the Reich Citizenship Law.


title: Racial policy of Nazi Germany

text: In 1936, Jews were banned from all professional jobs, effectively preventing them from having any influence in education, politics, higher education, and industry. There was now nothing to stop the anti-Jewish actions that spread across the German economy.


title: Racial policy of Nazi Germany

text: Between 1937 and 1938, new laws were implemented, and the segregation of Jews from the "German Aryan" population was completed. In particular, Jews were punished financially for being Jewish.


title: Racial policy of Nazi Germany

text: From March 1, 1938, government contracts could not be awarded to Jewish businesses. On September 30, "Aryan" doctors could only treat "Aryan" patients. Provision of medical care to Jews was already hampered because Jews were banned from being doctors.


title: Racial policy of Nazi Germany

text: On August 17, Jews with first names of non-Jewish origin were legally required to add "Israel" (males) or "Sara" (females) to their names, and a large letter "J" was to be printed on their passports on October 5. On November 15, Jewish children were banned from going to state-run schools. By April 1939, nearly all Jewish companies had either collapsed under financial pressure and declining profits, or been persuaded to sell out to the government, further reducing their rights as human beings; they were, in many ways, effectively separated from the German populace.


title: Racial policy of Nazi Germany

text: The increasingly totalitarian regime that Hitler imposed on Germany allowed him to control the actions of the military. On November 7, 1938, a young Polish Jew named Herschel Grynszpan attacked and shot German diplomat Ernst vom Rath in the German embassy in Paris. Grynszpan's family, together with more than 12,000 Polish-born Jews, had been expelled by the Nazi government from Germany to Poland in the so-called ""Polenaktion"" on October 28, 1938. Joseph Goebbels ordered retaliation. On the night of November 9, the SS and SA conducted "the Night of Broken Glass" (""Kristallnacht""), in which at least 91 Jews were killed and a further 30,000 arrested and incarcerated in Nazi concentration camps. After the start of the war, and the conquest of numerous European countries, the Jewish population was put into ghettos, from which they were shipped to death camps where they were murdered.


title: Racial policy of Nazi Germany

text: After the promulgation of the Nuremberg Laws, the "Reichsvertretung der Deutschen Juden" (Representation of the German Jews) announced the following:


title: Racial policy of Nazi Germany

text: Nazi Germany began persecution of the Romani as early as 1936 when they began to transfer the people to municipal internment camps on the outskirts of cities, a prelude to the deportation of 23,000 Gypsies to concentration camps. "Pure-blooded" Gypsies were considered by the Nazis to be Aryan. Roughly ten percent of Gypsies were considered to be racially pure.


title: Racial policy of Nazi Germany

text: However, although many laws during Nazi Germany persecuted the Gypsies, a specific "Gypsy Law", although talked about often, was never enacted by the Nazis.


title: Racial policy of Nazi Germany

text: In "Mein Kampf", Hitler described children resulting from marriages to African occupation soldiers as a contamination of the Aryan race "by Negro blood on the Rhine in the heart of Europe." He thought that "Jews were responsible for bringing Negroes into the Rhineland, with the ultimate idea of bastardizing the white race which they hate and thus lowering its cultural and political level so that the Jew might dominate." He also implied that this was a plot on the part of the French, saying the population of France was being increasingly "negrified".


title: Racial policy of Nazi Germany

text: The number of black people in Germany when the Nazis came to power is variously estimated at 5,000 to 25,000. According to the United States Holocaust Memorial Museum, Washington, D.C., "The fate of black people from 1933 to 1945 in Nazi Germany and in German-occupied territories ranged from isolation to persecution, sterilization, medical experimentation, incarceration, brutality, and murder. However, there was no systematic program for their elimination as there was for Jews and other groups."


title: Racial policy of Nazi Germany

text: Prior to Hitler coming to power, black entertainers were popular in Germany, but the Nazis banned jazz as "corrupt negro music".


title: Racial policy of Nazi Germany

text: Of particular concern to the Nazi scientist Eugen Fischer were the "Rhineland Bastards": mixed-race offspring of Senegalese soldiers who had been stationed in the Rhineland as part of the French army of occupation. He believed that these people should be sterilized in order to protect the racial purity of the German population. At least 400 mixed-race children were forcibly sterilized in the Rhineland by 1938. This order only applied in the Rhineland. Other African Germans were unaffected. Despite this policy, there was never any systematic attempt to eliminate the black population in Germany, though some blacks were used in medical experiments, and others mysteriously disappeared.


title: Racial policy of Nazi Germany

text: According to Susan Samples, the Nazis went to great lengths to conceal their sterilization and abortion program in the Rhineland. Hans Massaquoi describes his experience as a half-African in Hamburg, unaware of the Rhineland sterilizations until long after the war. Samples also points to the paradoxical fact that African-Germans actually had a better chance of surviving the war than the average German. They were excluded from military activity because of their non-Aryan status, but were not considered a threat and so were unlikely to be incarcerated. Samples and Massaquoi also note that African-Germans were not subjected to the segregation they would have experienced in the United States, nor excluded from facilities such as expensive hotels. However, they both state that downed black American pilots were more likely to become victims of violence and murder from German citizens than white pilots.


title: Racial policy of Nazi Germany

text: As early as 1925, Hitler suggested in "Mein Kampf" that the German people needed "Lebensraum" ("living space") to achieve German expansion eastwards ("Drang nach Osten") at the expense of the "inferior Slavs". Hitler believed that "the organization of a Russian state formation was not the result of the political abilities of the Slavs in Russia, but only a wonderful example of the state-forming efficacity of the German element in an inferior race."


title: Racial policy of Nazi Germany

text: Nazi ideology viewed the Slavic peoples as non-Aryan " Untermenschen" ("sub-humans"), who were targeted for enslavement, expulsion and extermination. The racial status of Slavs during the Third Reich was inconsistent over time. Hitler viewed the Slavs as "a mass of born slaves who feel the need of a master". Nazi propaganda portrayed the Germanic peoples as "heroes" in contrast to the Jewish and Slavic "sub-humans". Nazi propaganda depicted Eastern Europe as racially mixed "Asiatic" that was dominated by the Jews with the aid of Bolshevism. The Nazis considered some people in Eastern Europe to be suitable for Germanization (they were presumed to be of German descent); if they were considered racially valuable they were to be re-Germanized and forcefully taken from their families to Germany and raised as Germans.


title: Racial policy of Nazi Germany

text: The final version of "Generalplan Ost", essentially a grand plan for ethnic cleansing, was divided into two parts: the "Kleine Planung" ("Small Plan"), which covered actions which were to be taken during the war, and the "Grosse Planung" ("Big Plan"), which covered actions to be undertaken after the war was won (to be carried into effect gradually over a period of 25–30 years). The Small Plan was to be put into practice as the Germans conquered the areas to the east of their pre-war borders. The individual stages of this plan would then be worked out in greater detail. In this way, the plan for Poland was drawn up at the end of November 1939.


title: Racial policy of Nazi Germany

text: The plan envisaged removal of the majority of the population of conquered counties, with very small and varied percentages of the various conquered nations undergoing Germanisation, expulsion into the depths of Russia, and other fates, the net effect of which would be to ensure that the conquered territories would be Germanized. Himmler declared during the Germanization process that no drop of German blood would be lost or left behind to mingle with any "alien races". The "Wehrbauer" ("soldier-peasants") would settle in a fortified line to prevent civilization arising beyond and threatening Germany.


title: Racial policy of Nazi Germany

text: The Nazis issued the Polish decrees on 8 March 1940 which regulated the working and living conditions of Polish laborers (Zivilarbeiter) used during World War II in Germany. The decrees set out that any Pole "who has sexual relations with a German man or woman, or approaches them in any other improper manner, will be punished by death." The Gestapo were extremely vigilant about sexual relations between Germans and Poles and pursued any case relentlessly where this was suspected. There were similar regulations used against the other ethnic groups brought in from Eastern Europe, including the death penalty for sexual relations with a German person. During the war, hundreds of Polish and Russian men were executed for their relations with German women.