! E L M E N T SE "#! $!%&' &( "#! )!*(+, !"#$%&!'(&!"' &)$ $#*+,&!*" *- &)$ .$""/ .0$%% ("1 &)$ $22(",$+ 3),03) 2,01$0% ALSO FEATURING • The Digital Pandemic • The Force on the Front!"# $%&#'(')&$)!# '#*#)'+" ,-$'%). -/ 0-*!-% +-..#(#-. +/ ' 0 2 0 21 · 1 &* 2 % ! 1 7 · / -- 2 ! 1 !"##"$% #&'&(!(%& Elements, the undergraduate research journal of Boston College, showcases the varied research endeavors of fellow undergraduates to the greater academic community. By fostering intellectual curiosity and discussion, the journal strengthens and a)rms the community of undergraduate students at Boston College. ! Elements Spring 2021 "#$%&' We would like to thank Boston College, the Institute for the Liberal Arts, and the O(ce of the Dean for the College of Arts and Sciences for the financial support that makes this issue possible. )*!'"+,%' - .,%"/+0*"+,%' If you have any questions, please contact the journal at bcurjelements@gmail.com. All submissions can also be sent to bcurjelements@gmail.com. Visit our website at www.bc.edu/elements for updates and further information. .,1!/ Seymour, M. (2019, December 3). concrete buildings during foggy weather. Unsplash. Retrieved January 18, 2022, from https://unsplash. com/photos/3e5CkkHo-X0. 2!/+,3+.+"4 Elements is published twice an academic year in the fall and spring semesters. The information provided by our contributors is not independently verified by Elements. The materials presented represent the personal opinions of the individual authors and do not necessarily represent the views of Elements or the Boston College community. Elements, Undergraduate Research Journal, Volume 17, Issue II, Fall 2021 Boston College, 140 Commonwealth Avenue, Service Building 103, Chestnut Hill, MA 02467 Printed by EaglePrint, 140 Commonwealth Avenue, Chestnut Hill, MA 02467 Copyright © 2022 by the Trustees of Boston College !5!6!%"' '"$77 !"#$%&'-#(-)*#!+ ,#)*-!.- /-./%(# 0%-((- )*%! ,-(-1#(1 !"#$%& &#.!2 ',#$* .-2%3$ !"#$%& "-(#!. )-# $&!-'3&!& ,-"!.#(! 4*-(1 *3,-(#$#!' 5-&#(- "!.-(!2 '%)#-. ')#!()!' 6 (-$3&-. ')#!()!' ,!.#''- ,-% +-)3.$2 -"7#'%& 0-'%( )-7-..-&# Dear Readers, The Jesuit tradition and liberal arts education of Boston College is often lauded as one of the most versatile and e8ective ways to cultivate critical thinking, ethical reasoning, and intellectual dexterity—among a vast array of other skills so desirable to employers and the world in general. And yet, we are asked time and again the same question facing many undergraduate student research journals: “Beyond the educational benefit of practicing post-graduate work, where is the value in undergraduate research?” A per- fectly valid response lies in the assertion that there is no well-defined chasm between inexperience and expertise that students leap across on the day of their graduation. Rather, each student undergoes a gradual accumulation of knowledge which can be competently utilized in real-world applications at any point throughout their college education, and this process, when taken in consort with fresh perspective, can yield incredible results. Taken further within the context of Element’s environment, students exposed to the con- cept of cura personalis—literally “care for the whole person”—likewise have the capability to inquire intellectually, to search for the truth in all things, and to passionately use their knowledge in service to others. Indeed, the research present in this issue demonstrates the well-rounded intellect of its authors who, through careful analysis, o8er enriched interpretations of— and in some cases potential solutions to—some of the most pertinent is- sues of our time. In our cover article, “‘The Demon of Belfry’: The Penny Press, the Em- manual Church Murders, and Gilded Age Sexuality”, Sean Stebbins delves into the changing perspectives on sexuality in the nineteenth century docu- mented in the news coverage of the Emmanuel Baptist Church murders during the Gilded Age. In the attempt to find reason for the gruesome de- tails and motivations of the murders, the press demonstrated how media can have a profound impact on the cultural perceptions of the time. Our first feature article “Ireland Re-Imagined: Irish Commemoration during the Decade of Centenaries” by Czar Sepe reviews how the Decade of Cente- naries comprises the di8ering recollections of Ireland’s history from vari- ous communities of people and a modern response to those historical nar- ratives from the Irish government. This story shows how the personalized values of history are influenced by how it is recorded in time. Will Riherd’s article “Neuromorphic Computing” brings to light a new con- cept in technology that is inspired by the human brain. This innovative re- structuring of computer operations illustrates the potential of interdisci- plinary solutions in the future. The article “Wrestling with Giants: Antitrust Measures in the Technology Sector” by Luc Riordan analyzes the current economic and political interplay in the trend toward monopolization in the technology industry and the need to evaluate the extent to which these com- panies can operate under law. In Caroline Cohen’s article “Nutrition’s Miti- gating E8ects on the Pathogenesis of Alzeimer’s Disease,” she details the physical e8ects that food can have on the brain and how a balanced diet with a focus on antioxidants and n-3 fatty acids can support long-term brain health. Additionally, the issue contains Daniel Fu’s “Trump’s China Con- tainment Strategy” that scrutinizes President Donald Trump’s approach to China’s growing presence on the global stage and the ongoing necessity for attention by future leaders. And lastly Siobhan Pender’s “The Force on the Front” probes the anti-Semitic motivations of the police force that aligned with the growing Christian Front in Brooklyn, New York from 1938 to 1940. Pender identifies the consequences of action and inaction by those who take on leadership roles in law enforcement. The range of perspectives and topics in this issue serve to highlight the vast and unique society that we live in. Whether it struggles to define the bound- aries of the technology industry or document the complex relationships and tensions in history, society has been challenged to think more about the is- sues deeply embedded and engrained in our system. These articles provide a well-written and well-crafted deep examination of these issues; an intro- spective challenge that requires us to understand the roles of aspects in our society that create these issues. This edition of Elements is a nod to those that want to illuminate and bring forth the di(cult assumptions in our so- ciety; ones that through shared understanding can create constructive dis- course. Happy Reading! Sincerely, Michaela Balboni, Joanna Choe Editors in Chief !3+",/’' %,"! .,%"!%"' IRELAND RE!IMAGINED Czar Sepe Grasping Historical Perceptions for the Decade of Centenaries 10 28 42 50 56 THE DIGITAL PANDEMIC Ryan Cattich Averting Negative Externalities of Disinformation Through Platforms NEUROMORPHIC COMPUTING Will Riherd Explaining how Projected SNN Training will Largely Impact our Interactions with Technology THE DEMON OF BELFRY Sean Stebbins Investingating the Evolution of the Penny Press and the Emmanuel Church Murders WRESTLING WITH GIANTS Luc Riordan Probing the Pertinence of Antitrust Law for Big Techs AUTHOR BIOGRAPHIES LIST OF ARTWORK 86 79 65 94 99 FOOD FOR THOUGHT Caroline Cohen Researching Nutrition’s Mitigating E8ects on the Pathogenesis of Alzheimer’s Disease THE CONTINUING CONTAINMENT Daniel Fu Evaluating the Trump administration’s China Containment Strategy on Eastern Regions and Beyond THE FORCE ON THE FRONT Siobhan Pender Analyzing the Police Sympathy for the Christian Front Movement in Brooklyn from 1938-1940 !"#$%&'’( '#)%'# *+ )#&,#&%"!#( (2012-2022) )*--#-*"%,#( .!(,*"!)%$ -!$#(,*&#( ,.%, $#' ,* ,.# )*/&,"0’( !&'#1#&'#&)# +"*- 2"#%, 3"!,%!& %&' ,.# )"#%,!*& *+ ,.# "#1/3- $!) *+ !"#$%&'. .*4#5#", (!&)# ,.# %'5#&, *+ ,.# !"!(. &%,!*&, !,( .!(,*"0 .%( %$4%0( 3##& % )*&,#(,#' (1%)#— 4.#"# *11*(!&2 1*$!,!)%$, (*)!%$, %&' )/$,/"%$ 2"*/1( &#- 2*,!%,# 3#,4##& .!(,*"!)%$ &%""%,!5#(—,* $%0 )$%!- ,* % ‘,"/#’ !"!(. .!(,*"0. ,.!( 1%- 1#" 1"#(#&,( ,.# )*-1#,!&2 .!(,*"!*2"%1.!#( !&5*$5#' !& ,.# !"!(. 2*5#"&-#&,’( '#- )%'# *+ )#&,#&%"!#( %&' !'#&,!+!#( ,.# (*)!*-1*$!,!)%$ %2#&'% 3#.!&' (,%,# )*--#-*"%,!*&(. % .!(,*"!)%$ %&%$0(!( *+ ,.# )*--#-*"%,!*&( ,.%, ,**6 1$%)# !& ,.# 2010( 1"*5#( ,.%, (*)!*-1*$!,!)%$ )*&(!'#"%,!*&( +%),*"#' !& ,.# 4%0 !"#$%&'’( +*/&'!&2 4%( 1*","%0#' 30 ,.# 2*5#"&-#&,, ,.# 1/3$!), %&' )!5!$ (*)!#,0. *5#"%$$, ,.!( 1%1#" )*&)$/'#( ,.%, ,.# !"!(. 2*5#"&-#&,’( ).!#+ %!-( 4#"# ,* (,"!6# % )*&)!$!%,*"0 ,*&# 4!,. &*",.#"& !"#$%&', ‘)"*4'-*/,’ *11*(!&2 .!(,*"!)%$ &%""%,!5#(, %&' 1"*7#), !"#$%&'’( #)*&*-!) 1"*2"#(( ,."*/2. ,.# !"!(. 1"*)$%-%,!*&. #",.#$#((, %)%'#-- !) .!(,*"!%&( %&' ,.# 1/3$!) !&,#"5#&#' !& ,.!( *,!%,!*& ,* )"#%,# "#-!-%2!&#' .!(,*"!#( *+ !"#$%&'. !"#$%&' "#-!(%)!&#' Grasping Historical Perceptions for the Decade of Centenaries )8%" (#1# “It is apparent that commemoration is intrinsically linked with the past. Nevertheless, commemoration is manifested in the present, and is subject to a society’s values, whether it is nineteenth-century nation-building or twenty-first century traumatic healing.” Ireland’s ‘Decade of Centenaries’ (DOC) can be character- ized as a negotiation between competing historical inter- pretations and present socio-political concerns. In particu- lar, themes of inclusion, transnationalism, and intersectionality colored commemoration events. To fur- ther explore this, the paper will provide the conceptual framework of a ‘negotiation’ of historical memory. Then, it will analyze the DOC Expert Advisory Group’s mission, the First World War and Easter Rising commemorations, the online platform Century Ireland, and the #WakeThe- Feminist movement. Overall, the Irish Government brought certain needs to the negotiating table: (1) a concil- iatory tone with Northern Ireland (NI), (2) a ‘crowding-out’ of opposing historical narratives, and (3) a projection of Ireland’s progress in relation to the Irish Proclamation. In the end, the Government was somewhat successful in this negotiation. With the intervention of academic historians and the public, the DOC accommodated ‘re-imagined’ his- tories of Ireland, outside of the state’s initial scope. In order to delve into the DOC commemorations, it is es- sential to provide a conceptual schema for commemora- tion as a negotiation between historical narratives and cur- rent socio-political needs. Pierre Nora challenges the traditional separation between history and memory by proposing lieux de mémoire. Such crossover spaces include commemoration, in which both “memory attaches itself to sites,” while “history attaches itself to events” (Nora, 1989). Further, Eric Hobsbawm comments on the rise of state commemoration during the nineteenth-century, as “…rul- ers…rediscovered the importance of ‘irrational’ elements in the maintenance of the social fabric…” of newly formed nation-states (Hobsbawn, 1983). Accordingly, this top- down concept is challenged in the twenty-first century, considering the idea of historical victimhood, which Guy Beiner notes that “…public remembrance of victims tend to be exclusive and monopolistic, denying the trauma of others and ranking one’s own su8ering above theirs” (Beiner, 2007). It is apparent that commemoration is in- trinsically linked with the past. Nevertheless, commemo- ration is manifested in the present, and is subject to a soci- ety’s values, whether it be nineteenth-century nation-building or twenty-first century traumatic healing. What is unique to today’s notion of commemoration is that it can no longer be imposed solely by the state, rather, a dialogue must take place between historical memories throughout a broad spectrum of society. Politics must be considered in the Irish context because “…commemora- tive rituals have become historical forces in their own right” (McBride, 2001). As this ‘lieux’ is limited because of financial constraints, physical space, and public will, a so- ciety must prioritize what is and is not remembered. Therefore, commemoration becomes a multi-faceted ne- gotiation between di8ering historical narratives on one hand and di8ering socio-political interests on the other. From this viewpoint, the Expert Advisory Group (EAG) was tasked to navigate the centenary of Ireland’s founda- tional years. In 2012, the DOC programme was launched, designed to be “…broad and inclusive, highlighting the economic and social conditions of the period, [and] the shifts in cultural norms and the experience of the Irish abroad” (Decade of Centenaries, 2020). A year earlier, the EAG was established to advise the Government on how to approach the decade, chaired by Dr. Maurice Manning. It is noteworthy that a respected Irish academic and politi- cian was appointed to this role. The EAG, supplementing the DOC’s statements, argued that “commemoration will be measured and reflective, and will be informed by a full acknowledgement of the complexity of historical events and their legacy…” and “…of the multiple identities and tra- ditions which are part of the Irish historical experience” (Department of Culture, Heritage, and the Gaeltacht, 2015). This spirit of inclusion is molded by past commem- orations of the 1916 Easter Rising, most notably the fiftieth anniversary of the Rising in 1966, which will be discussed later. Moreover, attempts to create a shared history come in the aftermath of the 1998 Good Friday Agreement, in 12 !"!#!$%& : : &'()$* 2021 which there came a strong imperative to maintain peace on the island. This is reflected in Northern Ireland’s ap- proach to the decade, in which Paul Mullan explains that “by embracing the nuances and complexity of past events, a new understanding can emerge that may help mitigate the potential for further conflict” (Mullan, 2018). Clearly, the notion of inclusion, as well as transnationalism and intersectionality in public commemoration, arose as a re- sult of a fear of conflict and Ireland’s past experiences with historical commemoration. Was the DOC successful in orchestrating their expressed goals? A marker of the DOC’s success in tackling the issues of inclusion and transnationalism is the commemoration of the First World War and leading up to the Battle of the Somme in 2016. Until the beginning of the twenty-first century, the war was overlooked by Irish society, in what historian F.X. Martin decried as a ‘national amnesia.’ How- ever, Keith Je8ery focuses on contemporary trends in First World War commemoration, such as the fact that it “…be- gan to be drawn into a wider, more general commemora- tion of all Irish people who had died for war,” rather than a unionist-dominated narrative prevalent in recent history (Je8ery, 2013). The war, through the unionist lens, legiti- mized NI’s place in the British Empire. With its ultimate sacrifice at the Battle of the Somme, Ulster unionists in- corporated First World War commemoration as a key part of their heritage. Meanwhile, Northern Irish nationalists viewed the war with contempt because of unionism’s fer- vent embrace of it. During the ‘Troubles’—a thirty-year sectarian conflict in Northern Ireland pitting Protestant unionists against Catholic nationalists—these antipathies were heightened so much so that Remembrance Day was a target for Provisional IRA attacks, namely the 1987 En- niskillen bombing. Though some loyalists sco8 at the ‘greening’ of Great War history, both Irish and Northern Irish state o(cials em- barked on a transnational e8ort to paint a reconciliatory picture. First, it started with joint commemorations in con- tinental battlefields, like in Messines in 2014, which “… demonstrated the power of using foreign locations as ‘safe’ spaces for Irish First World War commemoration,” as Ca- triona Pennell contends (Pennell, 2017). Placed in a broad- er European historical context, the Republic can better grapple with its role in the war. Irish President Michael D. Higgins, in an interview on RTÉ News, notes the Repub- lic’s duty is to “be able to take all of the experience of its citizens into account” (Century Ireland, 2014). Ireland’s participation in the events is premised in the wider Euro- pean context and in the inclusion of all Irish people. As for the Irish, “there has been an unprecedented and sustained public engagement…” as “…a way of dealing with the insta- bility of the present and future” (Pennell, 2017). By the 2010s, the public welcomed the new consensus of ‘re-dis- covery’ and reconciliation as a new historical motif that colored public commemoration. In e8ect, this phenome- non cannot be explained wholly by a ‘top-down’ theory of commemoration but also with a give-and-take between levels of society. Indeed, this sense of shared loss culminated in the state commemorations of the Battle of the Somme on 10 July 2016. In the Republic’s state ceremony at Islandbridge, all Irish regimental flags, including the 36th Ulster Division, were displayed. In addition, representatives of the Northern Irish Government, like the Secretary of State and the Deputy First Minister, laid wreaths representing both unionist and nationalist traditions. In Belfast City Hall, the Irish Minister for Social Protection laid a wreath at the Cenotaph on behalf of the Irish Government (Century Ireland, 2016). The reciprocity of representation signals the island’s attempt to reinforce the inclusive narrative of a shared loss, in which all can relate to the horror of the Somme’s carnage. James Evershed, on the other hand, posits that “the ‘sharedness’ of the Irish government’s "#$ %&""'$ () "#$ *(++$ ,(+-,: "#$ *"(./ () 0-'''-&+ +,)&12$&3 13 !"#$%&' "#-!(%)!&#' approach to commemoration…has not engender[ed] any meaningful reflection on the violence of [Britain’s] imperial heritage…” (Evershed, 2019). This critique is not unfounded. For example, the Creative Centenaries graphic novel, The Battle of the Somme, depicts the heroism of Billy McFadzean in the trenches. Supported by the Northern Ireland Department of Culture, Arts and Leisure, the graphic novel focuses on Ulster’s pride and hints at the triumphalist tone that both states supposedly sought to dampen this time around. Thus, the concept of a shared historical loss shone through in First World War commemorations, following the EAG’s inclusive and globalized vision, and a brokered consensus between the Republic and Northern Ireland on historical reconciliation was widely accepted. After the First World War commemorations, the DOC reached its peak with its remembrance of the 1916 Easter Rising and the Irish Republic’s proclamation. There are two inherent historical issues with the commemoration of the Rising; (1) it was orchestrated in direct opposition to the United Kingdom, of which Northern Ireland is still part of, and (2) that it was an undemocratic, violent rebel- lion that ultimately achieved its goal of independence, which violates today’s political norms. Nonetheless, the Rising is central to the Irish state’s founding narrative. In this regard, how will the DOC programme adhere to its core tenets of inclusivity, intersectionality, and transna- tionalism? Rising commemoration has been marred by allegations that they were partisan in the past. For in- stance, the Rising’s fiftieth anniversary in 1966 was com- memorated in a patriotic, militarized manner. The highly- politicized events linked Irish president Éamon de Valera, the last surviving Rising leader, with his Government as they wished to cement their legacy as the bearer of Irish independence. Some even argue that the commemora- tions stirred the forces that would cause the Troubles a few years later. The southern Government chose to forgo o(- cial commemoration during the late-twentieth century un- til the ninetieth anniversary in 2006—eight years after the Good Friday Agreement. Hence, there were credible con- cerns about commemorating the centenary of Easter 1916. From the onset, the EAG unequivocally stated that al- though they outlined a commemoration based on a multi- plicity of traditions and identities, “…the State should not be expected to be neutral about its own existence” (Depart- ment of Culture, Heritage, and the Gaeltacht, 2015). The group acknowledged that there is a limit to the principles of inclusion, especially to the events of the Rising. Though it may be a noble attempt to de-politicize the Rising, the EAG soon came under government pressure to integrate the peace process into commemorations. According to the Irish Times, the advisory committee “…‘point blank’ re- fused a government request to use the Northern Ireland peace process as a frame of reference” (McGreevy, 2016). However, Roisín Higgins attests to the innate politics of Rising commemorations, as “Easter 1916 came to repre- sent a moment of possibility against which all subsequent realities could be measured or on which they could be blamed” (Higgins, 2016). For their part, the EAG’s resis- tance to the political interventions still did not prevent the Government, nor other political actors from bringing com- memoration to the bargaining table. Of course, Higgins’ insight on the ideas proclaimed dur- ing the Rising as a ‘measuring-stick’ of progress is evident throughout several aspects of the DOC. In particular, RTÉ’s dramatic production of “Centenary The Proclama- tion” projected what seems to be an accomplishment of the ideas enshrined in the document, showcasing the Irish people’s diversity and the diaspora community. Beginning with the unfurling of the tricolor by two descendants of leaders in the Rising, the video pans into the scenic coun- tryside and lush farmland of the island. As di8erent people read parts of the proclamation, one notices the wide-rang- ing locations of the people reading it. There is certainly no coincidence that a man with an American accent, who is assumed to be Irish-American, reads “…and supported by her exiled children in America…”(RTÉ-Ireland’s National Public Service Media). In essence, Higgins’ analysis strikes at the heart of why so many resources were a8orded to the Easter Rising commemoration. For the state, remember- ing the Easter Rising meant remembering how far Ireland has come since its foundation and in the realization of its ideals. Portraying a progressive, prosperous nation able to “For the state, remembering the Easter Rising was meant to remember how far Ireland has come since its foundation, in the realization of its ideals.” 14 !"!#!$%& : : &'()$* 2021 embrace its history and heritage, the Irish Government was keen on underscoring the DOC’s tenets of inclusivi- ty, transnationalism, and intersectionality. In Northern Ireland, the Rising commemorations were not as simple and proved to be a complicated negotiation between competing political actors. As demonstrated in the First World War commemorations, both the Republic and NI were committed to what John Brewer describes as “ethical remembering,” based on “truth, tolerance and trajectory” (Brewer, 2016). This is hard to do for the Ris- ing in NI, especially for unionists, because the event’s meaning is against the rationale behind the formation of the Northern Irish state. Alvin Jackson contextualizes the unionist historical interpretation, concluding that the Rising “…was not just about the safely distant history of the neighbouring state, it was also interlinked with the contemporary history and experience of Northern Ire- land,” although this was not always the case (Jackson, 2018). This is why unionists have more trouble acknowl- edging the event, as “…they feel that honoring the sacri- fices of the ‘martyrs’ of the Rising could, in fact, signal some agreement with their aim of extricating all of Ire- land from the United Kingdom” (Hancock, 2019). On the other hand, Sinn Féin—the leading republican politi- cal party—is not exempt from scrutiny, as Landon Han- cock points out that they “…tried to use their willingness to acknowledge [the Somme] as a platform to insist upon unionist recognition of the importance of the Easter Ris- ing…” (Hancock, 2019). Thus, the NI republican move- ment e8ectively pin unionists against a wall when they could claim that their unionist counterparts are not hold- ing up to the parity of esteem—their end of the bargain. Meanwhile, Northern Irish minority republican groups created their own commemorative spaces to rea(rm their legitimacy as the “true” heir to Easter 1916. Bren- dan Ciarán Browne shares incredible insight on the re- publican groups’ divergent Rising commemorative prac- tices, which is surprising for an event that seemed to unify the republican cause. As an example, he accounts of the groups’ choreographed dance in the Belfast repub- lican cemetery. Interestingly, “…rather than have any ‘of- ficial’ discussion between group hierarchies…the events are organised in deference to the historical precedent set in previous years” (Browne, 2016). One can view this as a gentleman’s agreement with the ultimate aim of “…em- bedding an historical narrative and about keeping the unique and distinct republican politics of the individual groups alive in the public arena” (Browne, 2016). This is the identity-rea(rming element of commemoration, piv- otal to these marginalized groups’ sense of solidarity. There is no need for understanding the other side when nationalist commemoration is the lifeblood of these politi- cal groups. In this case, republican actors were crowded out of commemoration by the state, so they negotiated a partition of alternative commemorative space amongst themselves. Although the DOC was a complicated a8air in the Irish and Northern Irish political spheres, the decade accomplished great strides in an intersectional and interdisciplinary study of Irish history, whether from state- sponsored events or grassroots activism. Century Ireland, formed in conjunction with Boston College, RTÉ, and the )-45.$ 2: 6.(,'&+&"-(3 () "#$ -.-*# .$65%'-, 15 !"#$%&' "#-!(%)!&#' Irish Government, provided an innovative tool in Irish history’s public engagement. This approach towards digital history “[tried] to capture the full extent of how lives were lived in Ireland those years and not simply give the narrative of the major political and military happenings,” as Mike Cronin explains (Cronin, 2017). The website o8ers podcasts, video interviews, archival photos, and its signature weekly newspaper, which reports on the week’s events from a century ago (Century Ireland, 2020). Lauded by the Government and cultural organizations, Century Ireland received a warm reception by the Irish public, as deep interest in “every day” history during this period was cultivated. Remarkably, this project demonstrates an acute awareness of its own historical significance, that “it will undoubtedly be seen as a product of its time, but one that o8ers…a contemporary record of commemoration” (Cronin, 2017). Another example of the DOC’s intersectional approach is its initial failure to be adequately intersectional, as high- lighted by the #WakingTheFeminists (#WTF) movement. After the Abbey Theatre’s 2016 “Waking the Nation” reper- toire featured only male Irish playwrights, a grassroots campaign mobilized to protest the lack of representation of women in Irish arts in general. A resurgence of Irish feminism in culture took hold as #WTF organizers suc- cessfully forced a nationwide reconsideration of women’s role in Irish society. How can the DOC, trumpeting inclu- sive thematic histories, be so blind to the fact that its own advisory group is made up of a disproportionate number of men? Oona Frawley explains this phenomenon through Irish academia’s proclivity for “oblivious remembering,” which “…lacks awareness of or dismisses the systemic bi- ases present in its institutional and/or o(cial approaches to the past” (Frawley, 2021). As a result of this pushback, Irish institutions introspectively looked at its governing structures, ultimately increasing the number of women in decision-making positions, including in the EAG. On the whole, this bottom-up e8ort pushed state-sponsored com- memoration to democratize and better represent the Irish experience, to the benefit of a more nuanced understand- ing founded upon the Irish Proclamation’s notion of equality—of “Irishmen and Irishwomen.” Lastly, the popularization of public historical engagement during the DOC should be embraced by historians, who serve as the sentinels for good history. Diarmaid Ferriter, an EAG committee member, viewed “…that in relation to commemoration, ‘we [the EAG] have a duty to prevent hi- jacking by the government or anyone else’” (Ferriter, 2018). In his opinion, historians are not mere fact-check- ers, they also carry ethical obligations to maintain integri- ty. However, Dominic Bryan adamantly disagrees with Fer- riter’s claims, saying that “the danger of using commemoration as a moment for historical engagement is that you collude with a statement of political identity…” (Bryan, 2016). Instead, he argues that social scientists, like anthropologists and political scientists, better explain com- memoration. Unfortunately, Bryan’s picture of history is outdated and generalized, rooted in the nineteenth-centu- ry historical method. Contemporary academic history is specialized, with themes of labor, cultural, and gender his- tory emerging as proper historical spheres. In addition, Irish public historians have demonstrated a consistent commitment to “…create about a meaningful and consid- ered state programme…” and “…to highlight and expose political abuses of the commemorations…,” which drasti- cally contrasts with Bryan’s simple characterizations (Fer- riter, 2018). After all, it would not be fair to base criticism of modern anthropology on its imperialistic, racist origins. On the contrary, public historians must be at the forefront of commemoration, serving as sentinels against propagan- da. It must be understood that “public commemoration is futile unless driven by the conviction that it will bring so- cial dividends…,” or, simply put, that history cannot be apolitical (Fitzpatrick, 2013). Even so, this should not deter historians from supporting or critiquing events publicly. The DOC has renewed public interest in Irish history, and local communities took the lead in most ceremonies. This democratized history, aided by increased open access to archival material, has made history personal for many. Given this public platform, historians have a moral duty in twenty-first century commemoration to mold a historically-educated society. 16 !"!#!$%& : : &'()$* 2021 Professional historians, therefore, should provide the con- textual roadmap for the public’s understanding of the cen- tenary so that people can be guided in their historical pur- suits. Given this public platform, historians have a moral duty in twenty-first century commemoration to mold a historically educated society. In conclusion, the Decade of Centenaries has been a nego- tiation between varying historiographies and multiple so- cio-political actors. The first half of the decade has proven that public commemoration conforms to present Irish val- ues, namely, an emphasis on inclusion, intersectionality, and transnationalism. Its multi-faceted approach, encom- passing Irish culture and transnationality brings nuance to Irish history. The DOC, at times, failed to reflect its aspi- rations accurately, but the historians and the people pushed back and won. Nevertheless, the DOC has benefit- ted Ireland, not because Irish history has been re-exam- ined or re-discovered but because it has been re-imagined. /!7!/!%.!' ‘About Century Ireland’, Century Ireland; https://www.rte. ie/centuryireland/index.php/about-century-ireland/. Last checked 29 April 2020. Guy Beiner, Between Trauma and Triumphalism: The Eas- ter Rising, the Somme, and the Crux of Deep Memory in Modern Ireland’ in Journal of British Studies, 46, no. 2 (2007), pp. 366-89. David W. Blight, ‘The Memory Boom: Why and Why Now?’ in Pascal Boyer and James V. Wertsch (eds.), Memory in Mind and Culture (New York, 2009), pp. 238-51. John Brewer, ‘How to mark the Easter Rising in Northern Ireland’, The Conversation, 5 April 2016. Brendan Ciarán Browne, ‘Choreographed Segregation: Irish Republican Commemoration of the 1916 Easter Ris- ing in ‘Post-Conflict’ Belfast’ in Irish Political Studies, 31, no. 1 (2016), pp. 101-21. Dominic Bryan, ‘Ritual, Identity and Nation: When the Historian Becomes the High Priest of Commemoration’ in Richard S. Grayson and Fearghal McGarry (eds.), Re- membering 1916: The Easter Rising, the Somme and the Politics of Memory in Ireland (Cambridge, 2016), pp. 24- 42. Mike Cronin, ‘Irish History Online and in Real Time: Cen- tury Ireland and the Decade of Centenaries’ in Éire-Ire- land, 52, no. 1&2 (2017), pp. 269-84. ‘Decade of Centenaries’, Department of Culture, Heritage and the Gaeltacht; https://www.decadeofcentenaries.com/ about/. Last checked 27 April 2020. Jonathan Evershed, ‘A War That Stopped a War? The Nec- ropolitics of (Northern) Ireland’s First World War Cente- nary’ in Global Discourse, 9, no. 3 (2019), pp. 537-56. Diarmaid Ferriter, ‘1916 in 2016: Personal Reflections of an Irish Historian’ in Irish Historical Studies, 42, no. 161 (2018), pp. 161-74. David Fitzpatrick, ‘Historians and the Commemoration of Irish Conflicts, 1912-23’ in John Horne and Edward Madi- gan (eds.), Towards Commemoration: Ireland in War and Revolution, 1912-1923 (Dublin, 2013), pp. 126-33. Oona Frawley, ‘Naming Names: Countering Oblivious Re- membering in the Decade of Commemorations’ in Oona Frawley (ed.), Women and the Decade of Commemora- tions (MS: Indiana University Press, forthcoming), pp. 1-28. Landon E. Hancock, ‘Narratives of Commemoration: Iden- tity, Memory, and Conflict in Northern Ireland 1916-2016’ in Peace and Change, 44, no. 2 (2019), pp. 244-65. Roisín Higgins, ‘“The Irish Republic Was Proclaimed by Poster”: The Politics of Commemorating the Easter Ris- ing’ in Richard S. Grayson and Fearghal McGarry (eds.), Remembering 1916: The Easter Rising, the Somme and the Politics of Memory in Ireland (Cambridge, 2016), pp. 43-61. Eric Hobsbawn, ‘Mass-Producing Traditions: Europe, 1870-1914’ in Eric Hobsbawm and Terence Ranger (eds.), The Invention of Tradition (Cambridge and New York, 1983), pp. 263-307. ‘Initial Statement by Advisory Group on Centenary Com- memorations’, Department of Culture, Heritage and the Gaeltacht; https://www.chg.gov.ie/app/uploads/2015/07/ 17 !"#$%&' "#-!(%)!&#' Advisory_Group_Statement.pdf. Last checked 26 April 2020. Alvin Jackson, ‘Mrs Foster and the Rebels: Irish Unionist Approaches to the Easter Rising, 1916-2016’ in Irish His- torical Studies, 42, no. 161 (2018), pp. 143-60. Keith Je8ery, ‘Irish Varieties of Great War Commemora- tions’ in John Horne and Edward Madigan (eds.), Towards Commemoration: Ireland in War and Revolution, 1912- 1923 (Dublin, 2013), pp. 117-25. Peter Leary, ‘Negotiating Ireland’s “Decade of Centena- ries” in the New Age of Brexit’ in History Workshop Jour- nal, 85 (2018), pp. 295-301. Ian McBride, ‘Memory and National Identity in Modern Ireland’ in Ian McBride (ed.), History and Memory in Modern Ireland (Cambridge and New York, 2001), pp. 1-41. Ronan McGreevy, ‘Historians said no to politics in 1916 commemorations’, Irish Times, 11 Aug 2016. Paul Mullan, ‘The Decade of Centenaries and a Methodol- ogy for Engaging with “Di(cult Heritage”’ in Elizabeth M. Crooke and Tom Maguire (eds.), Heritage after Conflict: Northern Ireland (Abingdon and New York, 2018), pp. 34- 48. Pierre Nora, ‘Between Memory and History: Les Lieux de Mémoire’ in Representations, no. 26 (1989), pp. 7-24. Catriona Pennell, ‘Choreography by the Angels? Ireland and the Centenary of the First World War’ in War and Soci- ety, 36, no. 4 (2017), p. 263. ‘RTÉ News, 11 Aug 2014: President Michael D. Higgins on the Commemoration of WW1’, Century Ireland; https:// www.youtube.com/watch?v=ydPBxBM5IEs. Last checked 27 April 2020. ‘RTÉ News, 1 July 2016: Somme Commemorations’, Cen- tury Ireland; https://www.youtube.com/ watch?v=vPxjM8Vx-hk. Last checked 27 April 2020. ‘RTÉ One: Centenary The Proclamation’; https://www. youtube.com/watch?v=ERCVSDileo0. Last checked 28 April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’% '#!6!"*+ '3:$0(!)$% %$( -'#(/ !" 1996. !"# $%&%!'( )'*$#+%, Averting Negative Externalities of Disinformation Through Platforms #2*" 0*((!0/ “This is the cost of disinformation” – Atul Gawande, responding to nurse Jodi Doering’s story of her COVID-19 patients’ denial of their condition1 1. INTRODUCTION Eight months into a global pandemic and it appears the spread of the novel coronavirus is supplemented by the spread of disinformation. One story, in particular, illus- trates just that – South Dakota ER nurse Jodi Doering re- counts a few days’ worth of COVID-19 patients in a Twit- ter thread: “The ones that stick out are those who still don’t believe the virus is real…They tell you there must be an- other reason they are sick. They call you names and ask why you have to wear all that ‘stu8’ because they don’t have COVID because it’s not real” (Orth, 2020). How did we get here? Doering’s story draws a destitute parallel to developing countries. Despite e8ective remedies like mosquito nets and deworming pills, people in developing countries ne- glect to use them at large, partly citing a lack of available information, or misinformation more generally (Pulford et al., 2011). In the United States, with an abundance of readily accessible information at our fingertips, how are we, too, in a position where people neglect reality? Outside of the externalities inherent in a pandemic, widespread disinformation hinders and undermines the very integrity and the accuracy of fact. Disinformation has the potential to influence civic engagement, election results, and, most unfortunately, downstream health outcomes. In search of a remedy, we must begin at the root of the problem: sec- tion 230 of the Communications Decency Act. In so doing, the evaluations and recommendations in this paper contribute to a literature on the e8ects of media and disinformation on behavior and health outcomes (Bursz- tyn et al., 2020; Banerjee et al., 2019a; Bursztyn et al., 2019; La Ferrara, 2016; DellaVigna and La Ferrara, 2015; La Ferrara et al., 2012; Chiang and Knight, 2011; Jensen and Oster, 2009). Prior work has revealed that media ex- posure can increase hate crimes (Muller and Schwarz, 2018; Bursztyn et al., 2019) and mass killings (Yanagiza- wa-Drott, 2014); it can also a8ect domestic violence (Card and Dahl, 2011; Banerjee et al., 2019b), fertility choices (La Ferrara et al., 2012; Kearny and Levine, 2015), and respons- es to natural disasters (Long et al., 2019). Related to this analysis is contemporaneous work calling for a reinterpretation and a reassessment of section 230 of the Communications Decency Act as it stands today. Lotty (2020) argues the current interpretations of the scope of section 230 immunity wrongfully deny individuals who have been sexually harassed or assaulted an opportunity to hold online services accountable for causing or exacerbating their harms (Lotty, 2020). Thus, Lotty prescribes a necessary revision to section 230 to better align with contemporary views regarding the role of the internet user and the responsibility of technology companies to deter sexual misconduct. In a similar vein, Sloss (2020) responds to the Myanmar military carrying out brutal attacks via Facebook against Rohingya Muslim communities in Rakhine State in 2017. Going further than Lotty, Sloss argues for a statutory exception in 230 to permit civil suits against internet companies on account of their alleged complicity in genocide, war crimes, or crimes against humanity (Sloss, 2020). With a civil liability exception, Rohingya plainti8s could then bring a state tort law claim against Facebook alleging that Facebook was negligent in permitting its platform to be utilized to spark mass violence against the Rohingya in Myanmar. As the law stands today, such a case would be immediately nullified under the current federal preemption defense to state tort law claims. Irrespective of the study, the written law, or the lack there- of, section 230 most certainly demands a statutory modifi- cation – a modification which provides a positive incentive for companies to internalize the risk prevention of dis- seminating misinformation on their platforms. The re- mainder of this paper proceeds as follows. In section 2, I provide a brief history of the Communications Decency Act, followed by a substantive overview of the clauses un- der section 230. In section 3, I present a platform-by-plat- form analysis of their prior and current e8orts to prevent the spread of disinformation. In section 4, I introduce po- tential amendments to the current legislation, present no- table downstream implications, and provide empirical evi- dence of disinformation as a negative externality to society. Section 5 concludes. 2. HISTORY 2.1 Inception of The Communications Decency Act Introduced in February of 1995 by Senator James Exon, the federal Communications Decency Act (CDA) was cre- ated to combat a growing issue of extensive pornography and obscenity on the internet (Cannon, 1996). As passed, the CDA extends the “antiharassment, indecency, and an- tiobscenity” restrictions currently placed on telephones to 20 !"!#!$%& : : &'()$* 2021 interactive computer service providers (“ICSPs”). The bill was promptly met with opposition from some lawmakers and interest groups who opposed the idea of interfering with the Internet, along with concerns that the act was a “violation of free speech and … of the right of adults to communicate with each other” (Cannon, 1996). Opposing the CDA on the basis of these concerns, coupled with the 1995 New York Supreme Court decision Stratton Oakmont v. Prodigy Services Co., representatives Christopher Cox and Ron Wyden proposed the “Cox-Wyden Amendment” to Exon’s bill, some parts of which would ultimately become section 230 of the CDA as it stands today. In Stratton Oakmont, the court held that an online bulletin board service provider could be held liable for defamatory content posted by users on its platform, given that the web- site proactively monitored, screened, and removed o8en- sive user content, thereby serving as an editor and pub- lisher of all posted content and assuming legal responsibility for it (Stratton Oakmont v. Prodigy Services Co., 2018). By contrast, a 1991 New York case, Cubby, Inc. v. CompuServe, Inc., held that an ICSP that did not regulate third-party user content evaded liability for libel since it did not know of and had no editorial control over posted de- famatory material. Astonishingly, Stratton Oakmont as- serted that an online service that does nothing by means of monitoring for problematic content can never be legally responsible for the content of its users; in addition, a ser- vice that takes good-faith steps to screen such content sub- jects itself to liability (Ardia, 2010). As a direct response, the Cox-Wyden Amendment was pro- posed to encourage online services to take proactive mea- sures to improve online safety and regulate objectionable content without fear of increased liability (Ardia, 2010). Thus, this amendment allowed private ICSPs to address the problem of online indecency, while concurrently up- holding the Representatives’ policy goal of fostering the “vibrant and competitive free market that presently exists for the Internet and other interactive services” (Stratton Oakmont v. Prodigy Services Co., 2018). Subsequently, Congress passed the Telecommunications Act of 1996, which included the Communications Decency Act and the Cox-Wyden Amendment – legislation presently regarded as section 230 of the CDA (Ardia, 2010). 2.2 Section 230 of the Communications Decency Act Section 230 of the Communications Decency Act is the most significant piece of legislation regarding internet regulation, praised by commentators for allowing the In- ternet as we know it today to prosper. This statute largely restricts the scope of potential liability for interactive com- puter service providers based on content transmitted by third-party users of the service and an ICSP’s good-faith actions to limit access to objectionable material transmit- ted by users. The ICSP definition extends to “any informa- tion service, system, or access software provider that pro- vides or enables computer access by multiple users to a computer service,” which includes most websites and In- ternet-based apps (Stratton Oakmont v. Prodigy Services Co., 2018). As written, section 230 bears the name “Protection for pri- vate blocking and screening of o8ensive material” (Strat- ton Oakmont v. Prodigy Services Co., 2018). Section 230(b) lists the policy objectives, which include: promoting the continued development of the Internet, preserving the free market that is the Internet, spurring technological innova- tion that maximizes user control, eliminating “disincen- tives for the development and utilization of blocking and filtering technologies,” and guaranteeing the enforcement "[Section 230 of the Communications Decency Act] largely restricts the scope of potential liability for interactive computer service providers based on content transmitted by third-party users of the service and an ICSP's good faith actions to limit access to objectionable material transmitted by users." 21 !"# $%&%!'( )'*$#+%, of federal online security laws (Stratton Oakmont v. Prodi- gy Services Co., 2018). Section 230(c) sheds light on what constitutes “Good Samaritan” neutral actors and publish- ers online. Below the heading “Protection for ‘Good Sa- maritan’ blocking and screening of o8ensive material,” section 230(c)(1) states: “No provider or user of an interac- tive computer service shall be treated as the publisher or speaker of any information provided by another informa- tion content provider” (Stratton Oakmont v. Prodigy Ser- vices Co., 2018). Successively, section 230(c) safeguards civil liability for any “provider or user of an interactive computer service” given “any action voluntarily taken in good faith to restrict access to or availability of material that the provider or user considers to be obscene, lewd, lascivious, filthy, excessively violent, harassing, or otherwise objectionable,” irrespec- tive of if such material is protected by the constitution (Stratton Oakmont v. Prodigy Services Co., 2018). Overruling Stratton Oakmont, this legislation issues ICSPs that make bona fide e8orts to monitor and screen content immunity from legal actions based on user content gener- ated or transmitted on their platforms. Nevertheless, the Act explicitly does not permit ICSP immunity from liabil- ity for specific o8enses: violations of federal criminal law, communications privacy law, intellectual property law, and federal sex tra(cking law (Stratton Oakmont v. Prodigy Services Co., 2018). However, not included in the legislation: what constitutes such bona fide voluntary action, which explicit actions separate platforms from publishers, and how these specif- ic, yet ambiguous policy goals can be e!ciently achieved.1 At present, courts are progressively interpreting section 230 to broadly restrict the scope of potential civil and state law liability for ICSPs, thus fostering a safe environment for web-based corporations against a multitude of claims. How those companies do so is, evidently, up to them. 3. PLATFORM-BY-PLATFORM EVALUATION As of now, technology companies and media platforms are left to self-regulate, experimenting on their own with vari- ous moderation strategies and models of platform gover- nance. Essentially, individual companies are tasked with not only aligning their platform objectives with the needs of their users but to promote the principles of the common good as well. 3.1 Twitter In an interview with Boston College Magazine, Colin Crow- ell, former vice president of global public policy and corpo- rate philanthropy at Twitter, discusses the ramifications of Twitter flagging one of Donald Trump’s tweets for the first time (Figure 1). Signaling a new approach to combatting disinformation, Crowell asserts that “navigating the emerging and evolving online terrain of disinformation to protect the integrity of vital civic conversations, without succumbing to excessive censorship, is critical to safe- guarding the internet as a vibrant platform for human ex- pression” (Tempera, 2020). Here, Crowell echoes Twitter CEO Jack Dorsey’s overarching commitment to serving the public conversation. Although Twitter does not have an explicit policy on general disinformation, Twitter does present specific guidelines and policies on the following areas: violent threats policy, glorification of violence policy, platform manipulation, synthetic and manipulated media policy, and, most notably, civic integrity policy. According to Crowell, “when you have a platform as large as Twitter, it is important to recognize when there is a need to help users understand what they are viewing with additional context,” and Twitter’s civic integrity policy does just that (Tempera, 2020). Updated in October of 2020 ahead of the presidential election, Twitter asserts they will “label or remove false or misleading information about how to participate in an election or other civic process” (Twitter, 2020). This policy includes but is not limited to posting or sharing content that may suppress participa- tion or mislead people about when, where, or how to par- ticipate in a civic process. Further, Twitter explicitly com- mits to removing and labeling false or misleading information intended to intimidate or dissuade people from participating in a civic process, in conjunction with any intent to undermine public confidence in an election. On the same webpage, Twitter includes the subheadings: “What is not a violation of this policy?”; “Who can report violations of this policy?”; and “What happens if you vio- late this policy?” (Twitter, 2020). Thus, Twitter makes it abundantly clear both the ramifications and the qualifica- tions of their policy violations in an e8ort to transparently combat negative externalities to society. But is Twitter do- ing to prevent the spread of disinformation with this ap- proach? In defense of Twitter’s civic integrity policies, Crowell praises the decision to take action. The flagging feature, according to Crowell, “provide[s] a screen that [says], basi- 22 !"!#!$%& : : &'()$* 2021 cally, this tweet is in violation of Twitter rules, but it is re- maining on the service in the public interest,” as figures like Donald Trump are democratically elected heads of state (Tempera, 2020). Firmly, Crowell asserts that “Twit- ter can and should take action when online speech risks o9ine harm,” touching on negative societal externalities like disenfranchising voters and downplaying risks of CO- VID-19 (Tempera, 2020). Previously, Twitter only had the binary choice of either removing a tweet or leaving it up; now, Twitter allows journalists and the public to comment, links access to factual information, and takes steps to limit the ability of content to reach viral spread (Tempera, 2020). In accordance with section 230, simply flagging tweets does not invoke publisher status on Twitter’s be- half; however, Twitter begins to stray from the comfort of the “neutral actor” position.2 The existence of such policy pages represents an act in good faith on part of Twitter to screen for objectionable content, thus shielding them from civil and state liabilities. Nevertheless, Twitter is well within its right as an ICSP to prohibit attempts to use its services to manipulate or disrupt civic processes, along with distributing false or misleading information. 3.2 Facebook In a testimony before the United States Senate Committee on the Judiciary, Facebook CEO Mark Zuckerberg verbal- izes Facebook’s mission to “‘give people the power to build community and bring the world closer together’” (Testi- mony of Mark Zuckerberg Facebook, Inc., 2020). Zucker- berg touts that Facebook removed false claims about civic processes and displayed more than 150 million warnings on posts, after review by independent third-party fact- checkers (Testimony of Mark Zuckerberg Facebook, Inc., 2020). However, in response to Twitter’s fact-check labels, Zuckerberg takes a di8erent approach, “[believing] strong- ly that Facebook shouldn’t be the arbiter of truth,” in an interview with Fox News (Halon, 2020). Nevertheless, Facebook, too, makes an explicit commitment to stop the spread of misinformation. Under the heading, “Working to Stop Misinformation and False News,” Facebook makes its objectives clear in foster- ing accurate information on its platform. Specifically, fo- cus is given to three areas: disrupting economic incen- tives, building new products, and helping people make more informed decisions (Facebook, 2020). Citing finan- cial motivations behind fake news, Facebook commits to removing the economic incentives for tra(ckers of misin- formation – doing so through third-party fact-checking or- ganizations, strict enforcement of their policies, and apply- ing machine learning to assist response teams (Facebook, 2020). Reinforcing Zuckerberg’s stance against becoming arbiters of truth, Facebook is “building, testing and iterat- ing on new products to identify and limit the spread of false news,” engaging with their community “Oversight Board” to elicit help in fact-checking (Facebook, 2020). In doing so, Facebook is explicitly making bona fide e8orts to screen for misinformation, upholding an impartial posi- tion, rather than a publisher position in working with ex- ternal, unbiased groups. Through the “News Integrity Ini- tiative,” Facebook is pulling together over 25 funders and participants, including tech industry leaders, academic institutions, non-profits, and third-party organizations, to help people make informed judgments about what they read online.35 As a result of this initiative, Facebook posi- tions itself to advance global news literacy, bolster trust in journalism, and better inform the public conversation. Irrespective of hate speech and promotion of violence vio- lations, Facebook takes a hands-o8 approach to content moderation. Per the “Community Standards” page, Face- book makes its position clear: “We want to help people stay informed without suppressing productive public debate,” justifying the rationale behind not removing fake news from the Platform (Facebook, 2020). Rather, Facebook makes good faith e8orts to reduce the circulation of mis- information by adjusting their algorithms so as to “display [ fake news] further down in the news section,” thus avert- ing viral spread (Facebook, 2020). Essentially, Facebook encourages users to decide for themselves what to read, "Voluntary action superseded by profit in no way advances the e"ort on combatting the spread of misinformation; thus, there must be a disincentive to the 1 step forward, 2 steps back approach." 23 !"# $%&%!'( )'*$#+%, what sources to trust, and what content to post, all the while attempting to not overstep their boundaries as a neu- tral actor. 3.3 YouTube In the time leading up to the 2020 presidential election, a YouTube ad likening Democratic nominee Joe Biden to Venezuelan socialism circulated in the state of Florida (Donald J. Trump, 2020). Despite a published fact-check by the Associated Press, YouTube showed the ad more than 100,000 times in the eight days leading up to the election (Merrill & McCarthy, 2020). Trump went on to win the state of Florida by roughly 375,000 votes – the largest margin in a presidential election there since 1988 – and carried about 55% of the Cuban American vote (Mer- rill & McCarthy, 2020). In retrospect, this ad illustrates key gaps in the policing of misinformation by Google, the par- ent company of YouTube; while nominally prohibiting false claims in advertising, Google rarely takes down po- litical ads (Google, 2020). However, YouTube takes a more nuanced approach to this issue. Per the “How does YouTube combat misinforma- tion” page, YouTube engages a range of practices: remov- ing content in violation of policies, raising up authoritative sources for news and information, and reducing recom- mendations of borderline content and harmful misinfor- mation (YouTube, 2020). In an attempt to satisfy the vol- untary action conditions of section 230, YouTube algorithms go as far as to not proactively recommend con- tent that comes close to violating Community Guidelines; thus, taking action to limit the spread of disinformation. To determine what qualifies as “harmful” misinformation, YouTube states that they consult “external human evalua- tors” and experts to determine whether content promotes unsubstantiated conspiracy theories, or inaccurate infor- mation – reviewing “hundreds of thousands of hours” of video each day (YouTube, 2020). Unarguably, YouTube explicitly makes commitments and takes action to remove objectionable content, within their rights as an ICSP. De- spite these articulated commitments, no capacity exists in which YouTube can be held accountable for defaulting on their expressed promises on deterring misinformation. Circling back to the YouTube ad; if the Associated Press fact-check does not qualify as an external expert evaluation on unsubstantiated conspiracy theories, what does? Negat- ing their own policy, company spokeswoman Charlotte Smith claims that the campaign ad “does not violate our policies…and we’re not going to attempt to adjudicate ev- ery claim or counterclaim” on the platform (Merrill & Mc- Carthy, 2020). Albeit not a direct violation of section 230, this event underscores the urgent need for companies to be held accountable for what spreads on their platforms, rather than merely relying on an honor system for e(cient platform governance. Given people watch over a billion hours of video any given day on YouTube, financial incen- tives could be a driving force behind the platform falling short of enforcing its policies (“Press - Youtube”, 2020). In 2020 alone, the Trump campaign spent $106 million – $37.2 million in the last month of the campaign – on both YouTube and Google search ads alone (Thompson, 2020). Incalculable, however, is the e8ect running these ads had on disenfranchising and dissuading potential Latin Amer- ican voters in the state of Florida. With tens of millions of dollars in prospective ad revenue on the line, the clauses currently set forth under section 230 do little to counter any perverse commercial incentives at companies like YouTube. Thus, although YouTube makes voluntary ef- forts to publish their commitments like Twitter and Face- book, the commitments themselves appear vague and un- corroborated by decisive action. 3.4 Google In 2019, Google was heavily criticized in a 2019 Senate Investigation for its role in spreading misinformation during the 2016 presidential election (Wells, 2019). In October of that same year, a Senate Intelligence Committee released a report describing just how fast misinformation can spread on the platform; just days after the 2016 election, a false news story claiming that Trump had won the popular vote ranked higher on Google than accurate stories (Cassady, 2020). Although a mixed bag in its history with politics, Google’s present-day initiatives to combat the spread of misinformation are centered around fact-checking. Specifically, the “Google News Initiative” (GNI) is support- ing “First Draft,” a nonprofit protecting communities from harmful misinformation, with a $6.5 million grant (Mantzarlis, 2020). With an immediate focus on coronavi- rus information, the funding goes directly to fact checkers fighting misinformation around the world. In response to misinformation circulating about COVID-19, Google is supporting journalism fellowships at Stanford University to “collate data from around the world and help journalists tell data-driven stories that have [an] impact in their com- munities” (Mantzarlis, 2020). Additionally, Google says it 24 !"!#!$%& : : &'()$* 2021 has made Google Trends data available in “localized pages with embeddable visualizations,” in an e8ort to help jour- nalists understand and meet people’s information needs around the world. However, despite the promise of these initiatives, they appear reactionary. In March of 2020, the Global Disinformation Index found that 1,400 sites spreading COVID-19 misinformation earned a collective $76 million in ad revenue, with the vast majority coming from Google (Figure 2). Thus, Google seemingly under- stands the dilemma: they can take down a conspiracy theo- rist’s YouTube channel for making false claims about CO- VID-19; however, continuing to run ads on the website negates the entire purpose. Voluntary action superseded by profit in no way advances the e8ort on combatting the spread of misinformation; hence, there must be a disin- centive to the “1 step forward, 2 steps back” approach.3 4. PROPOSALS AND IMPLICATIONS Passing judgment on the regulation of free speech entails a balancing act, as Zuckerberg calls it, “‘of competing eq- uities’” (Testimony of Mark Zuckerberg Facebook, Inc., 2020). In some cases, the right thing to do from a safety or security viewpoint is not the most ideal for privacy or free expression; thus, there will always be somewhat of a trad- eo8 between disappointing people and promoting the common good.4 Deciding upon such tradeo8s is anything but straightfor- ward and passing down this moderation to individual companies raises much ambiguity surrounding the en- forcement of section 230. Given the relative ease of switch- ing between platforms, augmentation of the statute is of the uttermost importance – working with technology com- panies, rather than against them. 4.1 Statutory recommendations First, Congress should create a statutory exception in sec- tion 230(c) that permits civil liability against any ICSP’s complicity in the spread and circulation of disinformation. Not uncommon, last year lawmakers passed a bill that added a new exception to section 230 that positions plat- forms to be liable for any third-party content that facilitates sex tra(cking (Romano, 2018). In addition to modifications in this clause, section 230(c) must unambiguously specify what constitutes “any volun- tary action taken in good faith” to provide clear guidance to all ICSPs on the explicit steps they must take (Stratton Oakmont v. Prodigy Services Co., 2018). Parallel to Sloss (2020) in his push to hold companies ac- countable for complicity in mass genocide, a statutory ex- ception that withdraws civil liability could also work in internalizing the negative externalities of disinformation. Under section 230(c), such an exception to liability would arise in the case that a company fails to prevent transmis- sion of inaccurate information if that information: a) would be understood by ordinary readers as incitement or inducement to mislead or suppress people of factual infor- mation and the written law; and b) there is a significant risk that any recipient of the inaccurate information is ex- posed to harm. The statute should also include a duty for companies to remove such content within the 24-hour time frame since the content’s inception. Nevertheless, the statute should continue to preserve immunity from civil liability for any company that makes a reasonable, bona fide e8ort to comply with content removal, but is unable to do so for a justifiable reason. To do so, however, such bona fide e8orts must be clearly defined in section 230(c). Between Facebook and Twitter alone, the approaches to taking preventative steps in combatting misinformation are noticeably di8erent. On the one hand, flagging viola- tions and linking them to factual journalism raises con- cerns of anti-conservative social media bias; however, there is currently no evidence to support this exists (In- gram, 2019). On the other hand, allowing users to simply decide for themselves what to read does little by means of taking tangible, good faith steps in countering false infor- mation. Ideally, it is the work of journalists to hold those in power accountable and to provide context to readers; however, given the scale of platforms like Twitter and Facebook, the clauses in section 230 must recognize the need to take action. Thus, to define what proper good faith action is in practice, the legislation should mandate as- pects of both the Twitter and Facebook approaches in out- lining what such voluntary steps look like for all ICSPs. The approach should: require companies to take action to "There will always be somewhat of a tradeo" between disappointing people and promoting the common good." 25 !"# $%&%!'( )'*$#+%, limit the ability of disinformation to go viral through algo- rithmic modifications, flag inaccurate information linked to third-party fact checks, and allow content to be seen such that people can debate it, support it, refute it, or dis- sect it, and do so publicly.5 4.2 Consequential incentives An exception to section 230 that withdraws liability from companies that perpetuate disinformation could have a preventative e8ect by providing a positive incentive for companies. Typically, the mens rea for civil liability is a neg- ligence standard, rather than specific intent. Such a negli- gence standard would incentivize companies to adopt sen- sible measures to inhibit third parties from violating their community guidelines and policies on misinformation. In fact, given the global reach of major platforms like Twitter, Facebook, and Google, these companies arguably have greater power to prevent negative externalities to society than do some national governments. One could argue that ICSPs do not need additional incen- tives to limit users from posting inaccurate information because they have already taken steps to address the prob- lem. For example, after hearing about violence in Myan- mar, Facebook removed accounts associated with the Myanmar military and hired Burmese language speakers to monitor content (Ellis-Peterson, 2018). However, Face- book did not take such actions until after users in Myan- mar already used the platform to spark genocidal violence (Stecklow, 2018). Thus, a federal statute subjecting compa- nies to potential civil liability would incentivize compa- nies to act proactively to prevent harms before they occur, rather than issuing reactionary responses. To avoid liabili- ty, companies would need, among other things, to hire teams to specifically monitor objectionable content; hence, the liability risk provides a financial incentive for compa- nies to incur that cost to avoid future adverse judgments. Without such an incentive, ICSPs would neglect to incur the costs of risk prevention until after it is too late. Additionally, we can leverage aspects of behavioral theory in order to “nudge” platform users into taking their own steps in combatting the spread of disinformation.6 In the introduction to their book Nudge, Thaler and Sunstein present a nudge as “any aspect of choice architecture that alters people’s behavior in a predictable way without for- bidding any Options” (Thaler & Sunstein, 2008). Such an intervention closely mirrors what Twitter already does: flagging tweets in violation of its community guidelines, nudging users to follow the link to accurate information. As Thaler and Sunstein put it, “Putting the fruit at eye level counts as a nudge. Banning junk food does not” (Thaler & Sunstein, 2008). Twitter, through flagging, plac- es accurate information at eye level, rather than banning it altogether. Along with linking accurate information, Twit- ter can also leverage advancements in machine learning in order to curate feed algorithms in such a way that pres- ents information in an objective, unbiased manner. In to- tality, such behavioral nudges demand more in the way of freedom of choice and less so in the way of government constraint and compulsion. 4.3 “Revoke 230” is not the solution As recently as December 2020, President Trump threat- ened to veto an annual defense bill unless Congress re- voked section 230 of the CDA (Brandom, 2020). Just one year prior, in December of 2019, now president-elect Joe Biden, in an interview with The New York Times, said “‘sec- tion 230 should be revoked, immediately should be re- voked, number one’” (The New York Times Editorial Board, 2020). Given the Communications Decency Act is now over 20 years old, lawmakers are trying to amend the statute to best align with present-day needs; simply put, all-out revoking section 230 is not the solution. Above all, section 230 serves one main purpose: protecting ICSPs from the liability for the speech of others on their platforms. If it were to be revoked, former Twitter VP Crowell suggests doing so “creates a dilemma for the com- panies because they would have to over censor and start taking down anything that might remotely run a liability risk,” noting it would cause a ripple e8ect in the timeli- ness of the internet (Tempera, 2020). Thus, before any content could be posted on an ICSP, it would essentially "Revise, revoke, repeal — whatever ‘R’ word you choose — the debate over the future of section 230 boils down to one, simple idea: the law exists to protect people." 26 !"!#!$%& : : &'()$* 2021 have to be approved by lawyers, having the involuntary e8ect of making the largest companies more powerful. Larger companies, like Twitter and Facebook, have the fi- nancial means to a8ord legal teams; as Crowell puts it, “it would really create a mess” (Tempera, 2020). Section 230, albeit not perfect, is essential to allowing plat- forms to exist while still within their discretion to do some moderation. Protecting everything from Facebook and YouTube to the recently rebranded 8chan, the central point of section 230 is to provide platforms with the certainty that they can adopt specific, good faith moderation prac- tices that users deem necessary without fear of liability. Without this statute as it stands today, the entire internet environment would look vastly di8erent, some platforms shutting down and others stopping moderation altogether. 4.4 Empirical evidence for a negative societal externality “We’re not just fighting an epidemic; we’re fighting an info- demic” – Dr. Tedros Ghebreyesus, WHO Director-Gener- al70 Reforming section 230 to account for disinformation draws reasonable skepticism. Notably, Matthew Waxman, a professor at Columbia Law School and specialist on na- tional security law, states that “Disinformation is a broad category that’s tough to define, and resulting liability for its harms is very uncertain,” suggesting that there is some ambiguity to the negative externalities (Inside Cybersecu- rity, 2020). Waxman’s skepticism is mainly centered around disinformation as it relates to foreign campaigns; however, domestic disinformation “campaigns” pose real, calculable e8ects on the health and safety of U.S. citizens. Bursztyn et al. (2020) presents the e8ects of news cover- age of COVID-19 by the two most widely viewed cable news shows in the United States, Hannity and Tucker Carl- son Tonight, on viewers’ behavior and downstream health outcomes (Bursztyn, 2020). Carlson warned viewers about the severity of COVID-19 from early February, while Hannity originally dismissed the associated risks before incrementally adjusting his position in late February. Via constructed epidemiological models, as exhibited in Ap- pendices C and D, di8erent e8ect sizes provide empirical evidence that misinformation is an important mechanism driving the observed e8ects on increased cases and deaths. Given notable, inherent externalities in a pandemic, mis- information may have detrimental e8ects far beyond those on viewers themselves by a8ecting disease transmission trajectories in the broader population (Bursztyn, 2020). Although confined to television networks, this study sheds light on the potential e8ects media platforms have by dis- seminating misinformation, as exacerbated during a pan- demic. Hence, misinformation on mass media of any kind can and does have empirically calculable consequenc- es to society at large. 5. CONCLUSION Revise, revoke, repeal – whatever ‘R’ word you choose – the debate over the future of section 230 boils down to one, simple idea: the law exists to protect people. How can we, as lawmakers and policy drafters, orient the clauses of sec- tion 230 such that the statute exists to protect all people? Looking forward, Congress must: a) enact a statutory ex- emption in section 230(c) that permits civil liability for any platform’s complicity in the spread or harboring of disinformation; and b) unambiguously define and recom- mend good faith steps all ICSPs can put into practice. Integral to the main objectives of a section 230 modifica- tion is to ensure more reliable and truthful content ap- pears, spreads, and lives on online platforms. It would be wrong to assume this is solely a debate over the future of free speech; thus, pleas to revoke section 230 in its totality are both unsubstantiated and grounded in misaligned pri- orities. Platforms like Facebook and Twitter, for example, are aggressively taking action to suppress the spread of disinformation; however, they are plagued by the subjec- tivity of their own policy decisions. Hence, there exists a deep desire for heightened collaboration and information sharing between the tech and social media industries and the U.S. government. In the very near future, the path of least resistance in determining how the internet should be governed is to solve these tensions and ambiguities to- gether as a society, in a way people feel is both reasonable and equitable. To do so, lawmakers must continue to invite input from technology companies, citing their individual moderation approaches, as well as input from the public in order to make progressive strides in the forthcoming year. 27 !"# $%&%!'( )'*$#+%, '*225!6!%"$/4 $22!%3+: Appendix A Figure 1: May 26, 2020 tweets made by Donald J. Trump Notes: Pictured above is the first instance of Twitter flag- ging tweets made by the President of the United States. Marked with the label “Get the facts about mail-in ballots,” users, upon clicking, are taken to a “Twitter Moments” page, which links articles and tweets from journalists and experts that debunk misinformation claims. Brad Parscale, the Trump Campaign manager, labeled this action as a bla- tant display of Twitter’s political bias.75 Appendix B Figure 2: Share of ad revenues generated from COVID-19 disinformation sites Notes: The top three companies shown (Google, OpenX, and Amazon) generate 95% of the ad revenues to the site in the sample. Google ad services alone delivers $3 out of every $4 that these sites earn in ad revenues. Important to note: for Google, the ad shares and revenues for Google AdSense/AdX and Google DFP have been combined. Appendix C Figure 3: Reduced-form and 2SLS estimates of e8ect of dif- ferential viewership on cases and deaths (extended) Notes: Figure 3 displays day-by-day reduced form (Panel A) and 2SLS (Panel B) estimates on log one plus cases and log one plus deaths. Panela A portrays day-by-day e8ects of the instrument, FoxShared, on log deaths and log cases, conditional on state fixed e8ects and a large set of con- trols: Fox News’ and MSNBC’s share of cable in January 2018, Fox News’ share of television in January 2020, the population density of the country, the log of the country’s 6&3$' & 6&3$' % 28 !"!#!$%& : : &'()$* 2021 total population, the number of predicted TV’s turned to non-Fox channels during Hannity, Tucker Carlson To- night, and The Ingraham Angle, the population-weighted latitude and longitude, the percent in the country living in rural areas, the percent white, Hispanic, and black, the percent over the age of sixty-five, the share of men and women lacking high school degrees, the share of men and women lacking college degrees, the fraction of the popula- tion lacking health insurance, an age-adjusted measure of the average physical health in the county from 2018, the percent under the federal poverty line, log median house- hold income, the unemployment rate, the 2016 Republi- can vote share, and the log total number of votes cast in 2016. Panel B presents day-by-day e8ects of the standard- ized di8erence in viewership of Hannity vs. Tucker Carl- son Tonight, instrumented by FoxShared and controlling for state fixed e8ects and the same set of covariates as in Panel A. Standard errors are clustered at the DMA level and report 95 percent confidence intervals. Appendix D Figure 4: Implied COVID-19 curves Notes: Panel A of Figure 4 plots, in black, the logarithm of (one plus the) mean number of cases in each day across all counties. In gray, the figure plots the implied counterfac- tual values (based on the 2SLS estimates) for a county with one standard deviation higher viewership di8erence between Hannity and Tucker Carlson Tonight. Panel B replicates Panel A, taking log one plus deaths as the out- come rather than log one plus cases. This is presented with 95 percent confidence intervals on the counterfactual estimates. Standard errors are clustered at the DMA level. 6&3$' & 6&3$' % 29 !"# $%&%!'( )'*$#+%, !%3%,"!' 1. Here, “e!ciency” denotes the completion of the core objectives: promoting further development, preserving the free market of ideas, allowing for innovation concurrent with user control, and to do so in a manageable, secure way. But, in a way least reminiscent of George Orwell’s “Big Brother” in 1984, yet still prevents the negative exter- nalities of disinformation. 2. Important to note, commercial entities should not have the role of determining what constitutes fact over falsehood online. Linking factual articles to tweets gives rise to a multitude of ethical consid- erations regarding information and perspective biases, beyond the scope of this paper. 3. Evaluating platforms like Reddit and Yelp, for example, are key for future study on this issue, yet are outside the scope of this paper. 4. Again, ethical considerations arise when the onus falls upon companies, or any governing body, to determine the “right” thing to do. In a way, defaulting to the indivudual companies on platform moderation serves to limit the role and presence of government in our everyday lives. 5. For possible future study, it would be of importance to evaluate the various court interpretations of the term “publisher,” as it either relates or di"ers from the term “platform” in both legal provisions and court decisions. 6. #e nuances behind both qualitative and empirical behavioral theory are crucial to examine in the context of this topic; however, they exist outside the scope of this paper. /!7!/!%.!' “An Update on Our Political Ads Policy,” November 20, 2019. https://blog.google/technology/ads/update-our-po- litical-ads-policy/. Ardia, David. “Free Speech Savior or Shield for Scoun- drels: An Empirical Study of Intermediary Immunity un- der Section 230 of the Communications Decency Act.” Loyola L.A. Law Review 43, no. 2 (2010): 373,410. The New York Times Editorial Board. “Opinion | Joe Biden Says Age Is Just a Number.” The New York Times, January 17, 2020, sec. Opinion. https://www.nytimes.com/interac- tive/2020/01/17/opinion/joe-biden-nytimes interview. html. Brandom, Russell. “Trump Calls for Last-Minute 230 Re- peal as Part of Defense Spending Bill.” The Verge, Decem- ber 2, 2020. https://www.theverge. com/2020/12/2/22037118/trump-section-230-repeal- ndaa-rider facebook-twitter-moderation. Bursztyn, Leonardo. “Misinformation During a Pandem- ic.” The Becker Friedman Institute of the University of Chicago, June 17, 2020. Cannon, Robert. “The Legislative History of Senator Ex- on’s Communications Decency Act: Regulating Barbar- ians on the Information Superhighway.” Federal Commu- nications Law Journal 49, no. 1 (November 1996): 52–94. Cassady, Daniel. “Google Announces Measures to Crack Down On Misinformation Ahead Of Presidential Elec- tion.” Forbes. Accessed December 16, 2020. https://www. forbes.com/sites/danielcassady/2020/07/31/google-an- nounces-measures to-crack-down-on-misinformation- ahead-of-presidential-election/. Twitter. “Civic Integrity Policy,” October 2020. https:// help.twitter.com/en/rules-and policies/election-integrity- policy. Communications Decency Act, 47 U.S. § 230 (2018). Facebook. “Community Standards,” 2020. https://www. facebook.com/communitystandards/false_news. Inside Cybersecurity. “FCC Seeks Input on Regulatory Re- view of ‘Section 230’ Liability Protection; Issues Touch on Countering Disinformation,” August 4, 2020. https://in- sidecybersecurity.com/share/11499. Ghebreyesus, Tedros. “Speech at the Munich Security Conference.” Munich, Germany, 2020. Lotty, Alexandra. “Apps Too: Modifying Interactive Com- puter Service Provider Immunity under Section 230 of the Communications Decency Act in the Wake of ‘Me Too.’” Southern California Law Review 93, no. 4 (Spring 2020): 855–921. Mantzarlis. “COVID-19: $6.5 Million to Help Fight Coro- navirus Misinformation.” Google, April 2, 2020. https:// blog.google/outreach-initiatives/google-news-initiative/ covid-19- 65-million-help-fight-coronavirus-misinforma- tion/. Merrill, Jeremy, and Ryan McCarthy. “Trump Won Florida After Running a False Ad Tying Biden to Venezuelan So- cialists.” Electionland, November 12, 2020. 30 !"!#!$%& : : &'()$* 2021 “Press - YouTube.” Accessed December 16, 2020. https:// www.youtube.com/intl/en GB/about/press/. Global Disinformation Index. “Research – GDI.” Accessed December 16, 2020. https://disinformationindex.org/re- search/. Sloss, David. “Section 230 and the Duty to Prevent Mass Atrocities.” Case Western Reserve Journal of International Law 52, no. 1/2 (Spring 2020): 199–212. Stratton Oakmont, Inc v. Prodigy Services Co. (Supreme Court, Nassau County, New York 1995). Tempera, Jacqueline. “Behind the Scenes.” Boston College Magazine, Fall 2020. Thaler, Richard, and Cass Sunstein. Nudge: Improving Decisions About Health, Wealth, and Happiness. Yale University Press, 2008. Thompson, Alex. “Trump Deploys YouTube as His Secret Weapon in 2020.” Politico, September 6, 2020. https:// www.politico.com/news/2020/09/06/trumpyoutube election-comeback-408576. Volz, Georgia Wells, Robert McMillan and Dustin. “Senate Faults Google, Other Tech Giants for Role in Russian Elec- tion Meddling.” Wall Street Journal, October 8, 2019, sec. Politics. https://www.wsj.com/articles/senate-report- seeks-to-curb-possible russian-influence-in-2020-elec- tion-11570556521. Working to Stop Misinformation and False News | Face- book Media. “Working to Stop Misinformation and False News,” 2020. https://www.facebook.com/formedia/blog/ working-to-stop-misinformation-and-false news. YouTube - How YouTube Works. “YouTube Misinforma- tion - How YouTube Works.” Accessed December 16, 2020. https://www.youtube.com/howyoutubeworks/our- commitments/fighting misinformation/. Zuckerberg, Mark. “Testimony of Mark Zuckerberg Face- book, Inc.” Testimony presented at the Hearing Before the United States Senate Committee on the Judiciary, No- vember 17, 2020. https://www.judiciary.senate.gov/imo/ media/doc/Zuckerberg%20Testimony.pdf. Pulford, J., Hetzel, M. W., Bryant, M., Siba, P. M., & Muel- ler, I. (2011). Reported reasons for not using a mosquito net when one is available: a review of the published litera- ture. Malaria journal, 10(1), 1-10. Gawande, A. [@Atul_Gawande]. (2020 November 16) This is the cost of disinformation. It’s not only about the reality of deaths but also health & economic damage. MI stats on COVID hospital patients: Typical survivor age = 50-70. At 60 days, 40% either lost their job or were still too sick to work. http://acpjournals.org/doi/10.7326/M2… [Tweet]. Twitter. https://twitter.com/atul_gawande/status/132840 9592959823875?lang=en Orth, J. [@JodiOrth]. (2020 November 14) I have a night o8 from the hospital. As I’m on my couch with my dog I can’t help but think of the Covid patients the last few days. The ones that stick out are those who still don’t believe the virus is real. The ones who scream at you for a magic med- icine and that Joe Biden is [Tweet]. Twitter. https://twitter. com/JodiOrth/status/1327771329555292162 Halon, Y. (2020, May 28). Zuckerberg knocks twitter for fact-checking Trump, says private companies shouldn’t be ‘The arbiter of truth’. Fox News. Retrieved 2020, from https://www.foxnews.com/media/facebook-mark-zucker- berg-twitter-fact-checking-trump Donald J. Trump. (2020, October 20). Salga a Votar [Vid- eo]. YouTube. https://www.youtube.com/ watch?v=BtA1i0ujGrQ About. First Draft. (2022, January 12). Retrieved 2020, from https://firstdraftnews.org/about/ Romano, A. (2018, April 13). A new law intended to curb sex tra(cking threatens the future of the internet as we know it. Vox. Retrieved 2020, from https://www.vox.com/ culture/2018/4/13/17172762/fosta-sesta-backpage-230-in- ternet-freedom Ingram, M. (2019, August 8). The myth of social media anti-conservative bias refuses to die. Columbia Journalism Review. Retrieved 2020, from https://www.cjr.org/the_ media_today/platform-bias.php Ellis-Peterson, H. (2018, August 27). Facebook removes accounts associated with Myanmar military. The Guard- ian. Retrieved 2020, from https://www.theguardian.com/ 31 !"# $%&%!'( )'*$#+%, technology/2018/aug/27/facebook-removes-accounts- myanmar-military-un-report-genocide-rohingya Stecklow, S. (2018, August 15). Special reports from Re- uters journalists around the world. Reuters. Retrieved 2020, from https://www.reuters.com/investigates/spe- cial-report/myanmar-facebook-hate/ 25 32 !"!#!$%& : : &'()$* 2021 !" #$% &'(% )& !"(*%'+!",-. -'*,% ()/01#'#!)"'- 2%/'"2+ '"2 #$% !/0%"2!", $'-# #) /))*%’+ -'3, #$% +%/!()"21(#)* !"21+#*. $'+ 4%%" &)*(%2 #) *%-%5'-1'#% #$% #*'2!- #!)"'- ()/01#!", 0'*'2!,/. (%"#*'- #) #$!+ *%-%5'-1'#!)" $'+ 4%%" #$% ")5%- 2%5%-- )0/%"# )& "%1*)/)*0$!( ()/01#!",–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xplaining how Projected SNN Training will Largely Impact our Interactions with Technology 3!-- *!$%*2 “Neuromorphic computing...is, at its core, the novel attempt to replicate the brain in silicon.” INTRODUCTION The human brain’s e(ciency has long fascinated scientists. From dynamically remapping neural connections to strategically limiting its conductive operations, the brain is able to process information at an unparalleled baseline state of 20 watts. It is no surprise that computer engineers at Intel and IBM are imagining a new era of computing inspired directly by neurobiology. While nascent in development, neuromorphic computing represents a fundamental digression from the way we think about traditional computers. It is, at its core, the novel attempt to replicate the brain in silicon—one that researchers hope will result in dynamic, strategically e(cient, massively parallel systems that will redefine the way we interact with technology. OVERVIEW, HITORY, AND STATUS Overview and History Neuromorphic computing can be generalized as a method of computer engineering that is inspired directly by the human brain.1 Neuromorphic computing was originally conceived in the 1980s by Caltech electrical engineering and computer science professor, Carver Mead.2 It seeks to match the brain’s e(ciency and adaptability with an asyn- chronous approach to computer processing that funda- mentally digresses from the traditional von Neumann computer architecture (i.e., the original separation of the central processing unit and memory on a chip).3 Rather than isolating these functions, neuromorphic computing combines processing and storage on individual “neurons.” The resulting neurons are then characterized by both inde- pendence and connectivity: neurons are capable of firing independently of others, though they are selectively con- nected to neighboring neurons in the network.4 The out- come is parallel, asynchronous processing with an e(- cient flow of information.5 Neuromorphic computing, therefore, mirrors the brain in three key ways: 1) a consoli- dation of processing and memory, 2) selective mapping of neurons, and 3) massive parallelism. It is important to note that neuromorphic computing is a hardware solution to meet a software demand. Specifically, neuromorphic chips are designed for the e(cient perfor- mance of spiking neural networks (SNNs)—a novel algo- rithmic approach that deviates from typical artificial neural networks (ANNs). SNNs are unique in that they 1) are not characterized by fully connected layers and 2) incorporate a temporal component; each “neuron” connects sparsely, and information is processed via a neuron’s spike and the timing of each spike.6 The key result of the SNN architec- ture is that the network does not move one layer at a time (Pfei8er and Pfeil). A given spike can propagate to higher layers without waiting for lower layers to be evaluated in their entirety, meaning salient information reaches the output layer quicker.7 While there are arguments over whether SNNs are preferred over traditional deep learning models, this paper focuses on the fact that event-driven, asynchronous SNNs stand in stark contrast to the sequen- tial and central processing of data characterized by the tra- ditional von Neumann architecture. In other words, SNNs do not run well on existing computer hardware, resulting in the need for a novel chip specifically designed for SNNs. Current Status While the original concept of neuromorphic computing emerged in the 1980s, the recent rise in neuromorphic re- search is largely the result of the perceived end of Moore’s Law and the increasingly large computational demands of advanced software.8 Intel has emerged as a key player in such research, introducing its neuromorphic test chip, Loihi (pronounced Lo-ee-hee), in 2017.9 Despite remaining in the research phase, Intel has made significant progress incorporating the Loihi chip into progressively large neu- romorphic systems. The largest to date is Intel’s 2019 Po- hoiki Springs with 768 chips.10 Intel has also established the Intel Neuromorphic Research Community (INRC)—a collaborative, interdisciplinary consortium of academic, government and industry organizations to advance neuro- morphic research. The goal is to provide access to the Loihi test chip in order to refine and progress the company’s re- search into a scalable, commercially viable product. PREDICTIONS Short Term (0-5 Years) In the near future it is expected that 1) resources dedicated to neuromorphic research will increase, 2) neuromorphic computing will continue to show promising results in novel edge applications, and 3) the field will remain limit- 34 !"!#!$%& : : &'()$* 2021 ed on the algorithmic front. In terms of research and re- sources, in October of 2020, Intel announced a three-year contract with Sandia National Laboratories (a government nuclear research lab) to advance neuromorphic computing beyond edge applications to progressively complex compu- tational problems. The result will be the development of increasingly large neuromorphic systems with the intent of integrating over one billion neurons. Creating a system with such neural capacity exhibits moderate uncertainty in the short-term. Given a) the progress Intel has made when it comes to scaling Loihi and b) the di(culty of integrating an increasingly large number of neurons, the project has an uncertainty factor of around two on the low- and high- end (i.e., the system will be developed within one half to two times the expected implementation time frame). Neu- romorphic computing will also experience strong research in edge applications (particularly energy e(cient robotics) as members of the INRC continue to deploy Loihi in real- time audio and video processing tests.11 While Gartner predicts that traditional computing will hit a wall in 2025 (specifically mentioning neuromorphic computing as the leading technology for a shift in the com- puting paradigm), it is unlikely that a robust commercial product will be available within the next five years due to software limitations. Unlike traditional ANNs, SNNs lack a learning algorithm when it comes to parameter optimi- zation: it is impossible to use gradient descent given the non-di8erentiable nature of spiking neurons (Soni).12 Yann LeCun, the head of AI at Facebook, is a leading skep- tic when it comes to neuromorphic implementation, writ- ing that it is “premature to build a chip” when SNNs face a fundamental training challenge.13 There is also skepticism regarding the performance of the underlying SNNs; spe- cifically, skeptics point to the fact that SNNs do not outper- form ANNs (e.g. Convolutional Neural Networks) when it comes to traditional tests of image recognition (Pfei8er and Pfeil).14 Medium Term (5-10 Years) While SNNs currently face learning challenges, it is expected that within the next five to ten years, researchers will develop novel and e(cient approaches to SNN training. Current advancements have largely been focused on implementing a form of transfer learning (i.e., a process by which parameters are optimized in one “place” and transferred to a new “place”). In March of 2019, Terry Sejnowski of The Salk Institute of La Jolla and his team were able to train a standard recurrent neural network (RNN) via gradient descent methods and transfer the learned parameters to an SNN (Tiernan, “Neuromorphic computing finds new life”). While parameter transferring is a step in the right direction, Sejnowski admits that the next step—learning the SNN itself—is still “in the early days,” but that there is “going to be another big shift, which will probably occur within the next five to ten years.” Given both the di(culty and current progress of SNN training, there is moderate uncertainty regarding how quickly development will occur on the algorithmic front, with a general uncertainty factor of one and one-half to two times on the high-end. If an e(cient learning rule is established, it is possible we will begin to see commercially viable neuromorphic chips within the decade, allowing for complex, energy e(cient tasks on the “edge” (e.g., smartphones). Such commercial implementation, however, is highly dependent on the economic feasibility of widespread production, an aspect of neuromorphic chip development that is still in its infancy. Long Term (10+ Years) Although the future of SNN training and the economic practicality of neuromorphic hardware is uncertain in the near-term, it is possible that beyond 2030 we begin to wit- ness a shift in the current computing paradigm. Such a shift would be characterized by the wide-spread use of neuromorphic chips in energy-constrained edge devices (e.g., mobile devices, computers, robotics, etc.). Sejnowski predicts that once the software is developed and the hard- ware is “su(ciently cheap,” the implementation of such chips will be “ubiquitous...like sensors in phones.” Abu Sebastian, Principal Research Sta8 Member at IBM Zu- rich, predicts that neuromorphic computing will play a vi- tal role in the future feasibility of autonomous vehicles, making the point that you cannot “collect a frame, pass it &."-)-,-&' */3&6*$* %&*$1 (3 )$..(-$'$,".-, "533$' 753,"-(3* (!"#$%&'( ") *+,+-&.+/ !"--"0') 35 !"#$%&%$'()* *%&'#+)!, through to a deep neural net, and wait for the response when you’re traveling down a freeway at 70 miles an hour” (Greengard). The long-term draw of neuromorphic com- puting, is energy-e(cient, on-board processing that is ap- plicable to a wide range of technologies, from autonomous vehicles to independently operating interstellar spacecraft. Neuromorphic chips are also poised to play a large role in future medical devices and artificial body parts that can benefit from increasingly fast, on-site processing. While neuromorphic architecture could become ubiqui- tous beyond 2030, it is important to note the false dichoto- my between standard computer architecture and neuro- morphic hardware.15 The promise of neuromorphic chips lies in the creation of an adaptive system capable of the e(cient processing of highly noisy, increasingly complex, spatio-temporal data, not the high-speed processing of pre- dictable, deterministic processes (Greengard). It is short- sighted, therefore, to view neuromorphic computing as a fundamental alternative to traditional computing: the two technologies are complementary to each other, excelling in tasks suited to their specific design. It is also important to note the uncertainty surrounding the long-term ubiquity of neuromorphic computing, namely, that there is a three- way race between neuromorphic computing, high perfor- mance computing, and quantum computing (Vorhies).16 Given the advancements of competing fields, it is possible the technology is outperformed before it is commercially viable (either by existing competitors or a novel approach yet to be developed). The future of computing, then, is largely undecided, with the only certainty being that our current computing paradigm will shift in response to the impending halt to Gordon Moore’s 1965 prediction. IMPLICATIONS Consumers and AI Integration Despite uncertainties regarding the path of computing, a future characterized by the widespread adoption of neuro- morphic technology would have significant implications on the way consumers interact with digital devices. Peter Suma, co-CEO of Applied Brain Research, imagines a world in which neuromorphic technology enables an ex- treme integration of artificial intelligence into our daily lives (Ferry). Suma describes a future in which a technol- ogy like Siri transcends basic voice commands (i.e., a Siri that listens and sees all of your conversations and interac- tions). If you were to ask Siri what idea your friend Melissa came up with regarding your wife’s birthday gift, the e(- cient, continuous, on-board processing of data made pos- sible by neuromorphic computing would enable Siri to re- call the conversation with your friend the week prior, bringing up both the idea and a variety of similar, person- alized ideas. The salient point in Suma’s eyes is that the e(ciency of neuromorphic chips would enable the local storage of information, resolving widespread privacy con- cerns regarding consumer data. From autonomous vehi- cles to smart homes and edge devices, Suma’s point is clear: the promise of neuromorphic technology is a future characterized by the extreme integration of artificial intel- ligence into our daily lives. Semiconductor Industry Research scientist at Hewlett Packard Enterprise, Suhas Kumar, summarizes the state of computing as a “huge rush to find something” that can continue the improve- ment in computer science that we have witnessed the past half century. Semiconductor manufacturers, therefore, are faced with a critical choice of whether to invest in risky chip research to compete in a future characterized by ad- vanced computing technologies. While IBM has seen suc- cess with its TrueNorth system, Intel has exhibited the strongest commitment to neuromorphic research, evi- denced by its continued progress in creating increasingly scalable neuromorphic systems. Intel’s competitors are also faced with the challenge of determining the type of research they wish to undertake (i.e., whether they believe high performance or quantum computing will ultimately outperform the neuromorphic approach). Regardless, the challenge is clear: the computing industry will witness a shift in the coming decades, and the companies that lead this shift will capitalize on the widespread adoption of their novel technology. “The promise of neuromorphic chips lies in the cration of an adaptive system capable of the e!cient processing of highly noisy, increasingly complex, spatio-temporal data” 36 !"!#!$%& : : &'()$* 2021 Large Technology Firms Beyond the semiconductor industry, large technology companies (e.g., Google, Facebook, Amazon, etc.) are faced with the decision to embark upon internal research regarding computing hardware. As deep learning process- es continue to surpass the capabilities of existing technol- ogy, companies with large workloads and available capital are faced with the decision of whether to invest internally in chip development. In February of 2019, Facebook’s Yann LeCun briefly described “internal activities” the firm was taking to address the growing computational divide, referencing Google’s Tensor Processing Unit as another example of the type of internal e8orts large technology firms are capable of taking (Tiernan, “Facebook’s Yann Le- Cun”). While the future is uncertain, it is clear there is a demand for change, and the feasibility of neuromorphic hardware should figure prominently in the minds of firm leaders who are considering undertaking or continuing in- ternal development activities. CONCLUSION From computer science and biology to mathematics, phys- ics, and electrical engineering, neuromorphic computing is a cross-disciplinary challenge that requires a fundamen- tal rethinking of the way computers operate. Neuromor- phic research, however, is progressing: firms like Intel are leading the charge in chip development, and the success of their e8orts will have large-scale implications on consum- ers, the semiconductor industry, and technology firms alike. It is vital, therefore, that business leaders consider the possibilities and threats of this novel technology, un- derstanding that the future computing paradigm will be decided by innovative firms who are rethinking current processes. !%3%,"!' 1. The term neuromorphic means “taking the form of the brain” (Fulton III). Intel (a leader in neuromorphic research) summa- rizes neuromorphic technology as “chips that function less like traditional computers and more like the human brain” (“Intel Newsroom–Neuromorphic Computing”). 2. It can be argued that the original notion of neuromorphic computing was first proposed in Alan Turing’s 1948 paper, Intel- ligent Machinery. However, the concept is typically attributed to Carver Mead’s 1989 Analog VLSI and Neural Systems, a paper in which Mead argued that chips with an increasingly dense col- lection of transistors could best communicate via a replication of the brain’s neural wiring. 3. The downside of traditional computer architecture is typically referred to as the von Neumann bottleneck—the notion that despite increases in processing speed, processors are forced to remain idle while data is transferred to and from the memory of a chip, resulting in increased latency. 4. Neuromorphic chips employ analog circuitry to transfer elec- trical signals between “neurons.” The idea is that the system will be able to modulate the amount of electricity flowing between nodes, mimicking the fact that brain signals naturally have vary- ing degrees of strength. 5. A key emphasis of neuromorphic computing is the selective mapping of neural connections. In order to operate at maximum e(ciency, the brain uses only the specific neurons and synapses necessary to perform a given task. Neuromorphic systems, therefore, seek to emulate this e(ciency by strategically and selectively forming connections between neighboring neurons. 6. Each “spike” in an SNN is a single-bit impulse that is analo- gous to an action potential in a naturally occurring neuron. A given node in the network is capable of spiking only if a state variable exceeds a given threshold. 7. In fully-connected ANNs, all nodes compute and send their output to the next layer at each time step, even if nothing has sig- nificantly changed, making the overall network computationally expensive. Conversely, SNNs employ neurons that process input separately and are only connected to local neighbors, implying that the entire layer does not need to be calculated for informa- tion to proceed to the next layer. 8. In 1965 Intel’s co-founder Gordon Moore predicted that the number of transistors that could be placed on an integrated circuit would double every two years while costs remain constant / decline. 9. Loihi comprises 128 neuromorphic cores, 131,000 “neurons”, and 130 million “synapses” (connections). The chip is named after an active submarine volcano o8 the coast of Hawaii that is set to emerge one day. The idea is that neuromorphic computing is analogously “emerging” and will eventually break the “surface” of the current computing environment. 10. In December 2018 Intel announced the creation of Kapoho Bay, Intel’s smallest neuromorphic system consisting of two Loihi chips. In July of 2019 Intel was able to scale Loihi into their 64-chip Pohoiki Beach, representing the neural capacity of 8 mil- lion neurons. Most recently, Intel debuted its 768-chip Pohoiki Springs with a collective neural capacity of 100 million neurons. The chips reside in a chassis the size of five standard servers and is provided to members of the Intel Neuromorphic Research Community via a cloud-based system. Intel hopes it will emerge as a “tool for researchers to develop and characterize new neuro- inspired algorithms for real-time processing, problem solving, adaptation and learning” (“Intel Newsroom–Pohoiki Springs”). 11. In July of 2020 the National University of Singapore ran an event-driven, visual-tactile perception test on Intel’s Loihi chip 37 !"#$%&%$'()* *%&'#+)!, as well as various GPU systems to compare power consump- tion (Russel). The Loihi test chip slightly outperformed the GPU systems (in inferences per second) at significantly lower power consumption. It is important to note that Loihi’s strong performance is largely the result of the entire system (in this case, robotic sensors, data formats, algorithms, and the Loihi architecture) being “re-engi- neered in an event-based paradigm” (Mike Davies, Director of Neuromorphic Research at Intel. See Russel). Put simply, when the system is consistent with Loihi’s event-based architecture, neuromorphic hardware outperforms traditional GPU’s when it comes to energy e(ciency. 12. Existing deep learning algorithms depend on stochastic gradient descent and error backpropagation to e(ciently “learn” a given ANN. Since SNNs operate in discontinuous, non-di8er- entiable spikes, it is impossible to apply existing learning rules directly to SNN training (Pfei8er and Pfeil). 13. At the 2019 International Solid State Circuits Conference in San Francisco, LeCun heavily criticized neuromorphic comput- ing in his opening keynote address. While Intel’s Mike Davies agrees that there is a lot of progress to be made on the algorith- mic front, which he claims is “holding back the field,” Yann’s criticism resulted in a fireback from Davies citing the e(cacy of neuromorphic chips in a December report produced by Applied Brain Research of Waterloo, Ontario. Davies’s fireback was met with a detailed Facebook post by LeCun outlining the issues he sees with neuromorphic hardware, specifically citing the lack of an e(cient training algorithm. 14. It is important to point out that SNNs are not optimized for performance on existing AI Benchmarks (e.g., ImageNet). Just how the brain is not optimized (but capable of) classifying an image that is quickly flashed on the retina, SNNs struggle with the typical frame-based test of software accuracy. The evaluation of SNNs, therefore, requires benchmark testing that emphasizes the functionality of spiking networks—i.e., “making decisions based on continuous input streams while moving in the real world” (Pfei8er and Pfeil). 15. Dan Hutcheson, CEO of VLSI Research (an independent market analysis and consulting firm that tracks the semiconduc- tor industry), describes the false dichotomy as follows: “Today’s computers are very good at what they do. They will continue to outperform neuromorphic computing systems for conventional processing tasks. The technologies are complementary and so they will coexist.” Adam Stieg, associate director of the California NanoSystems Institute at the University of California at Los An- geles, further describes how “conventional von Neumann-based computing systems” perform very well with “high-speed, pre- dictable, deterministic processes,” but struggle with increasing complexity. The promise of neuromorphic computing, therefore, is the opening up of “an entirely new and unexplored area of computing”—one that allows us to “do things with computers that we couldn’t have imagined in the past” (See Greengard). 16. High-performance computing (HPC) can be generalized as a process of optimizing chip architecture for existing deep learn- ing algorithms (Vorhies). The majority of attention is currently placed on HPC, with large technology firms beginning to enter the chip manufacturing field by developing their own propri- etary chips (e.g., Google’s Tensor Processing Unit) (Tiernan, “Facebook’s Yann LeCun”). Conversely, quantum computing is analogous to neuromorphic computing in that it represents a rethinking of existing computer architecture. Rather than operat- ing in bits (0 or 1), quantum computing employs quantum bits (qubits) that can be set to 0, 1, or both simultaneously (Cho). /!7!/!%.!' Best, Jo. “Neuromorphic Computing Could Solve the Tech Industry’s Looming Crisis.” ZDNet, 5 Oct. 2020, ` www.zdnet.com/article/neuromorphic-computing-could- solve-the-tech-industrys-looming-crisis/. Blain, Loz. “Intel’s Neuromorphic Loihi Chip Is Rapidly Learning to Discern Smells.” New Atlas, 17 Mar. 2020, ne- watlas.com/science/intel-neuromorphic-loihi-smells/. Cho, Adrian. “The Biggest Flipping Challenge in Quan- tum Computing.” Science, The American Association For The Advancement of Science, 9 July 2020, www.sci- encemag.org/news/2020/07/biggest-flipping-challenge- quantum-computing. Davies, Mike, et al. “2018 CES: Neuromorphic Computing Mimics the Human Brain.” Youtube, Intel Newsroom, 8 Jan. 2018, www.youtube.com/ watch?v=gXNCz26UhyY&feature=emb_title. Ferry, Je8. “The Future of AI Is Neuromorphic.” Circuit Insight, www.circuitinsight.com/programs/55035.html. Fulton III, Scott. “What Neuromorphic Engineering Is, and Why It’s Triggered an Analog Revolution.” ZDNet, 8 Feb. 2019, www.zdnet.com/article/what-neuromorphic- engineering-is-and-why-its-triggered-an-analog-revolu- tion/. 38 !"!#!$%& : : &'()$* 2021 Greengard, Samuel. “Neuromorphic Chips Take Shape.” Communications of the ACM, 1 Aug. 2020, cacm.acm. org/magazines/2020/8/246356-neuromorphic-chips- take-shape/fulltext. Hamblen, Matt. “Intel Shares Pohoiki Springs Chassis with AI Researchers.” FierceElectronics, 18 Mar. 2020, www.fierceelectronics.com/electronics/intel-shares-pohoi- ki-springs-chassis-ai-researchers. Irving, Michael. “Artificial Synapses Fill the Gaps for Brainier Computer Chips.” New Atlas, 23 Jan. 2018, newat- l a s . c o m / n e u r o m o r p h i c - c h i p - m i t / 5 3 0 8 1 / ? i t m _ source=newatlas. Jhonsa, Eric. “Intel Teams with Uncle Sam to Research Chip Packages, ‘Neuromorphic’ Systems.” TheStreet, 2 Oct. 2020, www.thestreet.com/investing/intel-teams- with-uncle-sam-to-research-chip-packages-neuromorphic- systems-loihi-foveros-emib. LeCun, Yann. ISSC Keynote Address. Facebook, 23 Feb. 2019, https://m.facebook.com/story.php?story_fbid=1015 5808247852143&id=722677142. Molter, Tim. “A Brief History of Neuromorphic Comput- ing.” Knowm.org, 4 Apr. 2015, knowm. org/a-brief-history-of-neuromorphic-computing/. Muir, Dylan. “Putting the Neural Back into Networks.” Me- dium, 15 Jan. 2020, medium.com/neuromorphic-intelli- gence/putting-the-neural-back-into-networks-f0fd- b19a5efd. Norman, Jeremy M. “Carver Mead Writes the First Book on Neuromorphic Computing.” Carver Mead Writes the First Book on Neuromorphic Computing : History of In- formation, 25 Oct. 2020, www.historyofinformation.com/ detail.php?id=3900. Panetta, Kasey. “Gartner Top 10 Strategic Predictions for 2021 and Beyond.” Smarter With Gartner, 21 Oct. 2020, www.gartner.com/smarterwithgartner/gartner-top- 10-strategic-predictions-for-2021-and-beyond/. Pfei8er, Michael, and Thomas Pfeil. “Deep Learning With Spiking Neurons: Opportunities and Challenges.” Fron- tiers in neuroscience vol. 12 774. 25 Oct. 2018, doi:10.3389/ fnins.2018.00774. Ray, Tiernan. “Facebook’s Yann LeCun Says ‘Internal Ac- tivity’ Proceeds on AI Chips.” ZDNet, 18 Feb. 2019, www. zdnet.com/article/facebooks-yann-lecun-says-internal-ac- tivity-proceeds-on-ai-chips/. Ray, Tiernan. “Intel’s Neuro Guru Slams Deep Learning: ‘It’s Not Actually Learning’.” ZDNet, 23 Feb. 2019, www. zdnet.com/article/intels-neuro-guru-slams-deep-learning- its-not-actually-learning/. Ray, Tiernan. “Neuromorphic Computing Finds New Life in Machine Learning.” ZDNet, 1 July 2019, www.zdnet. com/article/neuromorphic-computing-finds-new-life-in- machine-learning/. Rouse, Margaret. “What Is Neuromorphic Computing?” SearchEnterpriseAI, TechTarget, 11 Feb. 2020, searchen- terpriseai.techtarget.com/definition/neuromorphic-com- puting. Russell, John. “Get a Grip: Intel Neuromorphic Chip Used to Give Robotics Arm a Sense of Touch.” HPCwire, 17 July 2020, www.hpcwire.com/2020/07/15/get-a-grip-intel- neuromorphic-chip-used-to-give-robotics-arm-a-sense-of- touch/. Soni, Devin. “Spiking Neural Networks, the Next Genera- tion of Machine Learning.” Medium, Towards Data Sci- ence, 16 July 2019, https://towardsdatascience.com/spik- ing-neural-networks-the-next-generation-of-machine- learning-84e167f4eb2b Vorhies, William. “The Three Way Race to the Future of AI. Quantum vs. Neuromorphic vs. High Performance Computing.” Data Science Central, Tech Target, 14 Nov. 2017, www.datasciencecentral.com/profiles/blogs/the- three-way-race-to-the-future-of-ai-quantum-vs-neuromor- phic-vs. Wiggers, Kyle. “Intel Debuts Pohoiki Springs, a Powerful Neuromorphic Research System for AI Workloads.” Ven- tureBeat, 18 Mar. 2020, venturebeat.com/2020/03/18/in- tel-debuts-pohoiki-springs-a-powerful-neuromorphic-re- search-system-for-ai-workloads/. “Neuromorphic Computing - Next Generation of AI.” In- tel–Neuromorphic Computing, Intel, 2020, www.intel. com/content/www/us/en/research/neuromorphic-com- puting.html. 39 !"#$%&%$'()* *%&'#+)!, “Intel and Sandia National Labs Collaborate on Neuromor- phic Computing.” Intel Newsroom, Intel, 2 Oct. 2020, newsroom.intel.com/news/intel-sandia-national-labs- neuromorphic-computing/. “Intel Scales Neuromorphic Research System to 100 Mil- lion Neurons.” Intel Newsroom, Intel, 18 Mar. 2020, newsroom.intel.com/news/intel-scales-neuromorphic-re- search-system-100-million-neurons/. “Intel’s Pohoiki Beach, a 64-Chip Neuromorphic System, Delivers Breakthrough Results in Research Tests.” Intel Newsroom, Intel, 15 July 2019, newsroom.intel.com/ news/intels-pohoiki-beach-64-chip-neuromorphic-sys- tem-delivers-breakthrough-results-research-tests/. “Loihi - Intel.” WikiChip, 15 July 2019, en.wikichip.org/ wiki/intel/loihi. 40 !"!#!$%& : : &'()$* 2021 !"# $#%%& $'#((’( (#%()!*+%), -+.#')/# +0 !"# 1895 #11)%2#, -"2'-" 12'3#'( (-+1- 1*!!#3 4& ()% 0')%-*(-+ 1#3*-), (!23#%! !"#+3+'# 32'')%!) "*/",*/"!#3 !"#*' +4(#(- (*+% 5*!" 3#.*)%! (#62),*!& )%3 /'2#(+1# .*+,#%-#. -+%!#1$+')'& %#5($)$#'( -+%- !*%2),,& -*!#3 32'')%!’( ,)-7 +0 '+1)%!*- (2--#((, "*/",*/"!#3 "*( $#-2,*)' 1#3*-), 4)-7/'+2%3, ($#-2,)!#3 )4+2! "*( *%!*1)!# '#,)!*+%("*$ 5*!" "*( 1+!"#', )%3 #1$")- (*8#3 !"# 1)*3#%"++3 +0 "*( !5+ &+2%/ 0#1),# .*-!*1(—),, 5"*,# #%/)/*%/ *% 5")! (-"+,)' 7)'#% "),!2%%#% !#'1( !"# “$+'%+/')$"& +0 .*+,#%-#.” (-"+,)'( ").# %+! (200*-*#%!,& (!23*#3 "+5 %#5($)$#'( )%3 +!"#' 1#3*) 32'*%/ !"*( !*1# '+1)%!*-*8#3 !')3*!*+%), (#62), '#,)!*+%("*$( 5"*,# (*12,!)%#+2(,& 0#!*("*8*%/ .*+,#%-#—#($#- -*),,& *0 !")! .*+,#%-# 5)( (#62), *% %)!2'#. !"*( $)$#' 5*,, )'/2# !")! ')$*3,& -")%/- *%/ -+%-#$!*+%( +0 (#62), %+'1)!*.*!& 32'*%/ !"# /*,3#3 )/#—)%3 !"# -+%0,*-! 4#- !5##% '#$'#(#%!)!*.#( +% 4+!" (*3#( +0 !")! 0*#'-# 3#4)!#—1)%*0#(!#3 !"#1(#,.#( *% !"# *1$,*-*!,&, )%3 +0!#% !*1#( #6$,*-*!,& (#62),*8#3 -+.#')/# +0 32'')%!. !"# $#%&' &( !"# )#*(+, Investigating the Evolution of the Penny Press and the Emmanuel Church Murders (#)% (!#44*%( “…prosecutors charged Durrant with the murders of both women, sending San Francisco into a frenzy. Newspapers nationwide picked up the story, marveling at the ferocity—and significantly, the sexual brutality—of the so-called “Demon of the Belfry” On April 3, 1895, William Henry Theodore Durrant— Theo, as his friends called him— made his way down 21st Street in San Francisco, California. A young student at Cooper Medical College, now Stanford Medical School, was heading to the Emmanuel Baptist Church, at which he was a Sunday school teacher. He was accompanied by 21-year-old Blanche Lamont, a fellow parishioner, and friend. Eventually arriving in the early afternoon, the pair entered the building one after the other. Though Durrant left the church at around 5 PM, Lamont was not seen again. Nine days later, Durrant entered the church with another parishioner—21-year-old Minnie Williams—be- fore eventually leaving to attend a friend’s house party a few hours later. Williams, too, had disappeared. As word began to spread throughout the city of the two young wom- en’s disappearance, suspicion turned on Durrant. Several witnesses had seen Theo enter the church with both wom- en, and rumors of the young man’s purported romantic failures began to spread. On April 13th, as a few women of the church decorated for the upcoming Easter holiday, one of them opened a cup- board—finding the unclothed and mutilated body of Min- nie Williams. It was only a matter of hours before police had reached the church’s belfry, finding Blanche Lamont’s rotting, naked body draped across the floor, her blood- stained head stu8ed between two wooden planks. Police arrested Durrant just two days after discovering the bod- ies. Doctors confirm both women were raped just before or even after death, and prosecutors charged Durrant with the murders of both women, sending San Francisco into a frenzy. Newspapers nationwide picked up the story, mar- veling at the ferocity—and significantly, the sexual brutal- ity—of the so-called “Demon of the Belfry.” The rise of the American penny press reached its height during the Gilded Age as newspapers across the country pumped out story after story detailing thrilling criminal investigations, daring feats of athleticism, astonishing technological innovations, and most profitably: chilling murders. The penny press’s sensational coverage of Theo- dore Durrant highlighted their obsession with deviant sexuality and gruesome violence. Contemporary newspa- pers continually cited Durrant’s lack of romantic success, highlighted his peculiar medical background, speculated about his intimate relationship with his mother, and em- phasized the maidenhood of Lamont and Williams—all while engaging in what scholar Karen Haltunnen terms the “pornography of violence.” This paper will argue that rapidly changing conceptions of sexual normativity during the Gilded Age—and the conflict between representatives on both sides of that fierce debate—manifested them- selves in the implicitly, and often explicitly, sexualized cov- erage of Durrant. CONTEXTUALIZING THE EMMANUEL CHURCH MURDERS While there is no scholarly study of Theodore Durrant, there are books and articles that help contextualize his murders of Blanche Lamont and Minnie Williams and their obsessively sexual reportage. Jesse Battan’s articula- tion of the linguistic and political divide between Victorian moralists and members of the Free Love movement, for example, counteracts traditional notions of the Gilded Age as an era dominated by sexual repression. As John D’Emilio and Estelle B. Freedman point out in their com- prehensive history of American sexuality Intimate Matters, Americans during the late nineteenth-century were far more accepting of non-traditional sex than they had been in prior decades as forces opposed to sexual suppression (like the Free Lovers) became significantly more promi- nent and birthrates across the country steadily declined1. In her study of late-nineteenth-century sexuality, Freed- man argues that during the Gilded Age, sex became less associated with procreation and more related to personal pleasure—a reality that engendered immense hostility on both sides of this new sexual divide2. The conflict between tradition and liberation played out in all facets of American 42 !"!#!$%& : : &'()$* 2021 society. However, it was especially pronounced in the pen- ny press, which often made light of bizarre or eccentric sexual behavior to sell more newspapers. In the early days of the Durrant case, the press obsessed over his rumored lack of romantic success as some harbin- ger of wrongdoing. Oliver Chan and Kathleen Heide’s re- search on sexual homicide somewhat vindicates this suspi- cion, revealing that most sexual murders of adult women happen at the hands of adult men seeking sex, as Durrant was.3 James Alan Fox and Jack Levin’s study of patterns common to di8erent instances of “multiple homicide[s]” confirms that the desire for sex is often a chief motivation for crimes of passion4. Contemporary newsmen also sug- gested Durrant’s status as a medical student—particularly his supposed interest in studying “female diseases”—all but proved his complete guilt. Herbert Kinnell’s insightful research on potential connections between the medical field and serial homicide reveals several unambiguous re- calities relevant to this thesis: people interested in death seem to gravitate to the medical field5. Erich Fromm’s psy- chological inquiry into motivations for violence further reveals the numerous links between necrophilia, which many of Durrant’s classmates stated he had, and violence6. As the penny press at the time lacked access to this body of research, they indicated that the dominant force behind their relentlessly sexual coverage was likely a battle over sexuality at the time rather than well-sourced psychology. Contrasting these sexual accusations with the ones later hurled at famous dancer, and Durrant’s sister, Maud Allen speaks to the gendered dichotomy of sexual discourse in the late nineteenth-century. Toni Bentely’s comprehensive review of numerous dancers reveals how the male audi- ence commanded Allan to “cover up” during many of her performances despite her growing popularity among women, illustrating this gendered divide7. Lacy McDear- mon’s research detailing how Allan’s career ended because of a highly publicized scandal involving a British parlia- mentarian who accused her of countless sexual “vices” il- lustrates the broader battle over sexuality during the Victo- rian Era—and the ways in which media sensationally exploited this battle to their own advantage with incidents involving both men and women8. Newspapers often speculated about the unknowns of Dur- rant’s murders in graphic detail, continually engaging in what Karen Haltunnen calls the “pornography of violence.”9 Americans, she notes, developed a keen inter- est in horror and death during the mid-nineteenth century that accelerated in later decades, peaking during the Gild- ed Age with thrilling stories of murder and violence being published daily in newspapers across the nation. Haltun- nen explains that as interest in violence grew, so too did its “pornography,” with books, newspapers, and other media detailing brutal crimes—like the Emmanuel Baptist Church murders—in increasingly graphic detail. THEODORE DURRANT, ROMANTIC FAILURE Newspapers that covered the Durrant story obsessed over his perceived romantic failures in several di8erent ways but did so initially by exploring his failed attempts at an intimate relationship with both his victims: Blanche Lamont and Minnie Williams. An early report from the San Francisco Call explained how the two women “received a lover’s attention from Durrant,” with journalists already hinting at some sort of failed attempt at courtship10. When an acquaintance of Williams’s informed readers that she had “‘indignantly repulsed’” a marriage proposal from Durrant early last summer, the penny press confirmed its sexualized narrative11. Reporters soon seized upon the claims of Blanche Lamont’s aunt, Mrs. C. G. Noble, who testified to “the frequency of Durrant’s visits at her house and his attentions to her niece,” and lauded her assertion that Durrant had also “proposed marriage to Blanche last December, but had been refused when the girl learned he was engaged to another woman.”12 Papers also empha- sized Durrant’s supposed suggestion to Noble (before be- ing arrested) that they search for Lamont’s body together “in a house of ill-fame”—a brothel13. In the early days of his case, the penny press established Theodore Durrant as a %'&,#$ '&+(3" &" #$,'&, +(3"&3& 0-"# #$. *"51$3"*, 1893 (!"#$%&'( ") *+,+-&.+/ !"--"0') 43 !"# $#%&' &( !"# )#*(+, sexually-deprived romantic failure who murdered to fulfill his brutal perversions, an inhuman monster so despicable he was even inclined to visit brothels while pretending to search for the bodies of women he killed. While some were later proven to be accurate , these relatively unfounded ini- tial characterizations illustrate Gilded Age fetishizations of sexual violence. Another element of the penny press’s obsession over Dur- rant’s romantic failures relates to his physical appearance, which strongly suggested his guilt. The San Francisco Call, for example, diplomatically described how a murderer (not necessarily Durrant) “will not be generally attractive to other men, [who] will have a feeling of utmost repugnance for him […]. For women, especially girls, he will be found to have a peculiar fascination, but he will lack the skill to use it shrewdly”—characteristics newspapers claimed Durrant happened to have14. A later story from The India- napolis Journal contended that Durrant’s “dominant” facial characteristics “are vanity and sensuality,” and that the shape of his head “would indicate not only extreme sensu- ality, but that its owner would be inconsistent, changing the object of his admiration frequently.”15 Months later, once Durrant’s trial had begun, newspapers still editorial- ized about how Durrant’s “clean-shaven lips reveal the coarse sensuality of his mouth,” continuing to tie his phys- ical features with sexual criminality16. Contemporary newspapers’ fascination with Durrant’s physical fea- tures—and their claims that those features somehow il- lustrate all manner of romantic perversions—reflect the intensifying Gilded Age sexual divide between those com- mitted to traditional conceptions of heteronormativity and those seeking to change them. Newspapers also explored Durrant’s attitude toward wom- en, casting him as an aggressively sexual (if often unsuc- cessful) womanizer who frequently solicited their compa- ny. The Salt Lake Herald, for instance, charged that “Durrant was more than passionately fond of women, and at every opportunity sought their society,” but that “he con- fined himself to the purer and better girls of his circle of acquaintances,” like Lamont and Williams, who the press continually deified17. Others stunned readers with highly sexualized headlines like “The Man was as Licentious as He Was Pious,” “Insulter of Women,” “His Baseness was Boundless,” or even “No Woman was Safe.”18 And some newsmen unambiguously blamed Durrant’s murders on his womanizing personality, with one paper directly stat- ing that “no other motive for the crime can be assigned [than] passionate jealousy, which is known to have a won- derful power to transform the most peaceable into fiendish brutes.”19 Again, Durrant’s actual romantic proclivities— he often (though not always) did live up to his reputation in the press—are not entirely relevant. More significant is that the late nineteenth-century penny press exploited his rape and murder of two women to publish implicitly and explicitly sexual content for their readers, exposing the rap- idly changing conceptions of sexuality during that time. While the press continually covered Durrant’s perversions in a general fashion, they did analyze some of his specific romantic failures from time to time, most notably with a woman named Lucile Turner. On one soon-to-be infamous occasion, Durrant accosted Turner, another parishioner at the Emmanuel Baptist Church like Lamont and Williams, and asked “if she had never been examined. She was somewhat surprised at his question and answered no. Durrant then said she ought to be and that he could do it.”20 Turner’s testimony engrossed journalists covering Durrant, and they referred to it throughout their coverage of the case21. The press also took special care to note Dur- rant’s unusual apprehension during Turner’s testimony, a break from what they characterized as his typically unfeel- ing demeanor: “During Miss Turner’s examination,” one paper noted, “Durrant looked very pale and anxious, and has not shown such pronounced symptoms since his arrest.”22 For contemporary journalists, the Turner inci- dent was a goldmine. It o8ered readers licentious details “Months later, once Durran’ts trial had begun, newspapers still editorialized about how Durrant’s ‘clean-shaven lips reveal the coarse sensuality of his mouth,’ continuing to tie his physical features with sexual criminality.” 44 !"!#!$%& : : &'()$* 2021 day after day and perfectly conformed to their already well- established narrative of a sex-deprived monster whose ro- mantic failures had triggered a murderous rampage—the perfect story for an American populace that craved scan- dalous sexual details like never before. The Lucile Turner episode presented the penny press with a profitable window into one of Durrant’s specific roman- tic failures, but they relentlessly published details about his generally “poor luck” with women, too. The Call, for instance, reported the vague remarks of several di8erent people throughout the course of the case, all of whom re- marked things like “’ from what I knew of Durrant he was not of the kind of men who are very successful in making love to young women.’”23 Another man o8ered his investi- gative services and insisted that he had “’ located three young women who claim to have been taken into the church by Durrant and compelled to leave the edifice on account of his improper conduct.’”24 Other papers, like The Arizona Republican, discussed an instance in which Dur- rant escorted another young parishioner to a room in the Emmanuel Baptist Church, left her there for a few min- utes, “and returned entirely nude,” further feeding into the sexual narrative25. Newsmen often followed detectives at- tempting to track down women rumored to be former lov- ers of Durrant, like one case in which investigators trav- eled to neighboring San Jose “looking for a young lady who is said to have received insulting proposals from The- odore Durrant, who selected Emmanuel church as the place for his attempt.”26 Even the strategy of Durrant’s own lawyers hinged on the same kinds of sexual details being published by the press. The Salt Lake Herald reported less than a month after Durrant’s arrest that the defense would try to demonstrate his innocence by proving that “he did not have a reputation as a lady-killer; that another member (now an ex-member) had; that this person was one whom all the young ladies of the church distrusted; that he fre- quently took liberties with them; that upon one occasion he was alone with a young lady in the vestry and that his actions were such as to cause her to have a serious hysteri- cal attack.”27 The barrage of details about Durrant’s roman- tic ineptitude with a variety of women solidified his initial image in the penny press as a sexual freak driven to mur- der. But that barrage also underscored the penny press’s obsession with the most erotic aspects of his character pos- sible rather than with the main bulk of evidence in an ap- parent e8ort to appeal to their sex scandal-driven readers. INVESTIGATING DURRANT’S PAST While they did devote much of their sexual reporting to his romantic mishaps, the press also examined other aspects of Theodore Durrant’s past through a sexual lens, begin- ning with his time at Cooper Medical College. “Durrant was looked upon as queer when at college,” one Call report notes, going on to explain how even though he “was fond of the society of women he declared the year he entered college that his relations with them had never been intimate.”28 Newsmen also jumped on comments from fel- low students admitting that “he spoke strangely about women from time to time and read much on subjects which are safest in the hands of hard headed specialists,” indicating a “trend of mind which dwells upon the morbid.”29 Other papers directly linked Durrant’s medical schooling with his sexual perversions, one story describing how some faculty at Cooper believed “Durrant was a9ict- ed with psycho-mania sexualis, a not unknown though in- frequent mental disease,” another simply inquiring, “Dur- rant studied surgery. Did he study murder at the same time?”30 A particularly scathing assessment of Durrant’s character out of The New York Tribune went even further: “Medical experts who have studied Durrant’s case unite in declaring that he is an abnormal crank, whose perverted "#$(1(. 15..&3"’* +54*#(" (!"#$%&'( ") +0%&$0&% /$!1+2&) 45 !"# $#%&' &( !"# )#*(+, nature has been stimulated by the study of sexual crimes. His medical college associates say that in private talk about women he revealed a foul imagination, and that his fondness for discussing topics that are usually ignored, even between men, gave him the reputation of being an erotic maniac. As assistant superintendent of the Emmanuel Sunday-school he performed all his duties in an irreproachable way, but since his arrest it is known that he insulted several young women and that he was in the habit of making weekly visits to the local [brothel].”31 Rather than focusing on Durrant’s bungled attempts at ro- mance, these reports confirm newspapers’ narrative of his sexual perversions by approaching them from an altogeth- er di8erent angle—medicine. They exemplify the penny press’s fixation upon Durrant the sexual maniac rather than Durrant the murderer and illustrate the growing di- vide between forces opposed to and supporting changing conceptions of sexual norms during the Gilded Age. Contemporary newsmen further directed their readers’ attention to rumors that Durrant committed the murders, as one paper put it, “for the purpose of medical investigation,” fueling sexualized narratives of his crimes even further.“32It is known that Durrant was an ardent medical student and took a great interest in diseases of women,” one report from The Herald read, “and being unable to conduct his investigations in any legitimate manner, murdered the girls for that purpose.”33Journalists turned to his suggestion to Miss Lucile Turner “that she allow him to make a medical examination of her, [him] telling her that he knew of a good place in the church where it could be done without anyone being the wiser” to link an already well established aspect of their coverage to these rumors34. Ironically, even by publishing dismissals of such reports, newspapers gave them more credence, one article outlining in great detail the rumor “that Blanche Lamont was lured to the church by Durrant’s promise to perform a criminal operation on her to save her from disgrace” before briefly admitting that “the city autopsy physician [stated] the rumor was without foundation.”35 Ultimately, the more analysis the penny press devoted to Durrant’s supposed medically-motivated investigative appetites, the more they became part of the story. Newsmen recognized this fact and intensified the practice anyways, reflecting their preoccupation with the sexual aspects of the Emmanuel Baptist Church murders before all others. Another part of Durrant’s past scrutinized by newspapers relates to his actual academic performance at Cooper Med- ical College, which most outlets depicted as suspiciously strong. “[Durrant] read textbooks, crammed science for his examinations and is said by his family to have read little or none of the lighter literature of the day” alleged one story from the Call, hinting at Durrant’s supposed peculiarity.”36His standing in none of his classes fell below 97 percent” read another out of The Herald, the author conconcedes that “Theodore Durrant is the last man whom anybody would suspect of committing a murder.”37 Even in jail, as multiple outlets discussed, “Durrant is studying medical books and says upon his release he will continue his course until graduation”—an interest that surely bordered on an obsession38. Newspapers’ juxtaposi- tion of these details chronicling Durrant’s academic suc- cess with the aforementioned side e8ects of studying mod- ern medicine constitutes another example of their sexualization of the Emmanuel Church murders. While not as explicit as lengthy tirades explaining Durrant’s many perversions, these kinds of oblique associations nonetheless contributed to the penny press’s erotic narra- tive of Durrant and his crimes. Outside of his actual experience as a medical student, newspapers littered their stories with a variety of psycho- sexual speculation regarding Durrant’s past behavior, all of which conveniently played into their depiction of him as a romantically deprived carnal maniac. Durrant’s main in- $++&35$' %&6"-*" ,#5.,#, 0#$.$ 15..&3" +5.1$.$1 "0( 0(+$3 6&.-*#-(3$.* -3 1895 (!"#$%&'( ") "3&0') 1+'%"$() 46 !"!#!$%& : : &'()$* 2021 terest, as newsmen had already established, was his medi- cal studies—but one story claimed that because he “was very much interested in his studies and work, fond of de- scribing the horrors of a dissecting room,” he had in fact lost “any feeling of reverence for the human body.”39 When the city’s autopsy physician concluded his report, several stories almost excitedly noted the fact “that the murdered girl had been outraged [raped] prior to the murder,” adding an entirely new element to the existing sexual narrative40. Other stories made light of “expert” opinion linking Dur- rant’s academic interests with seal violence, like that of police surgeon Summers, who claimed medical backing for the theory that there were “‘men whose animal pas- sions could not be aroused without the sight of blood,’” and insisted that “’the post mortem examination clearly proves that the victims were killed and afterwards outraged.’”41 An incredibly early report from The Herald— released mere days after Durrant’s arrest—testified to his “Jekyll-Hyde character”: “In Emanuel church he was noted for his religious fervor. Other residents of the Mission dis- trict say he was a frequenter of saloons, played cards and billiards in wine rooms, nightly visited with other youths saloons with side entrances for women. His classmates at the medical college say that Durrant was blasphemous and flippant in conversation, especially about women.”42 Re- porters gravitated towards the most outrageous and openly erotic elements of the Durrant case in an unprecedented way, and often without much evidence. The uniformity of their narrative—and the fact that papers favored the sexu- ally eccentric over the accurate—underscores the ways in which the changing sexual values and attitudes of the Gild- ed Age impacted reportage of Durrant. SCRUTINIZING DURRANT’S PRESENT Another angle in the penny press’s coverage of the Dur- rant case sought to examine not his past, but his present. More specifically, his behavior following his arrest. Jour- nalists initially directed this kind of reporting at Durrant’s deportment in court and jail, which they claimed illustrat- ed his guilt in the same implicitly sexual manner his ro- mantic failures had. Articles marveled at Durrant’s lack of emotion throughout the legal proceedings, especially when the evidence was stacked against him. One report noted that “whether their testimony is strong against him or only inferentially accusing, his expression is the same. […] He talks very little to his lawyers, pays absolutely no attention to the crowd […], and watches the proceedings with unconcern.”43 Other papers mentioned his “calm, imperturbable expression,” his “stolid indi8erence,” or his “air of unconcern,” hinting at an almost unnatural level of disinterest in his fate.44 Reports discussing Durrant’s be- havior in jail were no di8erent—“Durrant keeps up his wonderful composure,” one article observed, adding that at “about 10 o’clock yesterday morning several students, the majority being ladies […] paid him a visit.”45 To the American penny press, Durrant’s lack of emotion in court and jail, his already well-established sexual perversions, and the fact that women flocked to see him throughout the legal proceedings (despite his apparent guilt) confirmed his status as a carnally-motivated villain that defied every traditional conception of sexuality. Many newspapers’ vilification of Durrant’s deportment in the courtroom reached entirely new heights during discus- sions of violence, especially when that violence was sexual in nature. Newspapers described how Durrant “showed no emotion” during descriptions of Minnie Williams’s brutal rape and murder, sitting “calm and unconcerned” with “about the same degree of interest that is manifested by the Sphinx as it gazes over the sands of Egypt.”46 Descrip- tions like these hardly stood out. According to many news- men, the person in whom the evidence “produces the least mental perturbation is the prisoner itself,” this particular “To the American penny press, Durrant’s lack of emotion in court and jail, his already well-established sexual perversions, and the fact that women flocked to see him throughout the legal proceedings (despite his apparent guilt) confirmed his status as a carnally-motivated villain that defied every traditional conception of sexuality” 47 !"# $#%&' &( !"# )#*(+, author choosing to revoke Durrant’s humanity by simply referring to him as “it.”47 The same article cast Durrant as “an enigma, a monster of crime and depravity”—a man whose sexual crimes were so heinous he no longer de- serves that title48. These reports continually ostracized Durrant in truly remarkable ways. However, their main objective was to single out the sexual nature of his crimes as the thing that held the most significance. By portraying Durrant as a violent sexual freak who listened to recitals of savagery “with no more emotion than he would display at a college lecture,” the penny press solidified their unabash- edly erotic narrative to please their voracious readers’ yearning for that kind of content in ways Americans had not in prior decades49. In addition to their use of his cold demeanor as evidence of sexual impropriety, the penny press also examined Dur- rant’s many female admirers as a means of amplifying the sexual undertones of their reporting. The first incident dis- cussed by the national press occurred on April 24th, short- ly after Durrant’s arrest, when “a female crank” claiming to be “a Gypsy queen” talked briefly with Durrant in his cell before announcing to a pool of reporters “‘he is not the man.’”50 The episode sparked visits from women around the Bay Area, a development which journalists seized upon. “Women are Daft Over Durrant” declared one Silver Blade headline, its author marveling at how “the county jail is besieged with women daily, anxious to see Durrant and leave flowers for him.”51 Other articles reviewed the young women “who seem to regard [Durrant] as something of a hero,” visiting his jail cell “to gape at him through the bars.”52 Stories of his female admirers perfectly played into the already well-grounded sexual nature of his crimes, with Durrant now appearing as some sort of hypnotic force with unnatural sexual charisma—at least enough to convince “foolish women,” as one author lamented, of his innocence53. Such stories typified the sexualization of the Emmanuel Baptist Church murders, exposing yet more instances of the penny press’s obsession with the most erotic elements of his crimes. Gilded Age newsmen further pointed to Durrant’s close relationship with his mother as evidence of his guilt thanks to some kind of troubled upbringing, often implying pos- sible sexual impropriety. One Call report, attempting to find a justification for Durrant’s imperturbability in the courtroom, guessed that “the proximity of the mother of the defendant may have something to do with his easy manner.”54 What began as a series of seemingly innocent remarks about a mother and her son’s close relationship quickly spiraled out of control with speculative innuendo soon dominating all discussion of Durrant’s mother. A story out of The Louisiana Populist, for example, found that “his mother is his staunchest advocate, just as was the aged mother of [infamous murderer and medical student] Carlyle Harris, whose history in some respects resembles that of Durrant’s.”55 Another story from The Seattle Post- Intelligencer speculated that a young miscreant out of Spo- kane, Washington named Karl Gerul8—“the son of a pros- titute [and] a born criminal”—compared quite fittingly with “[monstrosities] like Tom Blanck or Theodore Dur- rant,” other criminals said to have troubled upbringings56. Newspapers’ scrutiny of Durrant’s relationship with his mother indeed stemmed from, at least in part, nineteenth- century conceptions of women as mothers (and therefore the primary architects of their children’s future behavior). But articles discussing their interactions, especially given the totality of their licentious coverage, unquestionably took on some sexual undertones, another reality that ex- poses the penny press’s fetishization of sexual violence. Significantly, papers’ coverage of Durrant’s mother active- ly excluded his father from nearly all discussion of his crimes. One article from the Call took this exclusion to al- most comical levels—after briefly mentioning Durrant’s father’s entrance into the courtroom, the author remarked that “all eyes were turned in that direction to see if the mother of the prisoner would follow.”57 Of their interac- tions in the courtroom, one journalist alluded to an unusu- ally intimate relationship, writing: “The mother of the pris- oner was, naturally, the object of a good deal of curiosity. But very few in the courtroom had seen her before, and “What began as a series of seemingly innocent remarks about a mother and her son’s close relationship quickly spiraled out of control with speculative innuendo soon dominating all discussion of Durrant’s mother.” 48 !"!#!$%& : : &'()$* 2021 were anxious to see how she was bearing up under the or- deal of her son’s imprisonment and approaching trial. Those who expected to see red eyes and tears and agony was depicted upon the face of the unfortunate woman were disappointed. Her eyes were bright, there were no traces of tears, and no agony was reflected in the counte- nance of the prisoner’s mother. She was calm—more than calm—talking to her son and smiling cheerfully upon him during the entire day in court.”58 The author followed this passage with a single line mentioning the presence of Dur- rant’s father. Again, while much of this undue focus on Durrant’s mother can undoubtedly be attributed to nine- teenth-century conceptions of women as the parents re- sponsible for raising children, the penny press’s conscious exclusion of his father from the conversation underscored the implicitly sexual narrative they established from the very beginning of his case. ROMANTICIZING LAMONT AND WILLIAMS Though they devoted the vast majority of their coverage to Theodore Durrant himself, newspapers sexualized the Emmanuel Baptist Church murders in another way: by emphasizing the maidenhood of his victims. Blanche Lamont in particular, received much praise from the press, who frequently reiterated her womanhood. The day after her disappearance, for example, the Call published a story concerning “a beautiful girl” that had59 gone missing, establishing her femininity from the outset. A subsequent report alleged Lamont “had a filled-in frame and was a ro- mantic,” paving the way for later stories that outlined Dur- rant’s exploitation of those characteristics60. Indeed, after Durrant’s arrest, papers highlighted witness testimony to this e8ect. One acquaintance, Dr. Vogel, told the Call that “‘Blanche was such a good girl that she thought everybody was as good as she was and she might have been taken advantage of.’”61 An early assessment from The Herald epitomized journalists’ portrayal of Lamont, the innocent victim of an erotic maniac, describing her as a “slender, graceful, well dressed, brown-haired, accomplished […]. She was simply a very pretty girl, romantic, according to some of her school friends, intensely matter-of-fact accord- ing to her relatives.”62 Emphasizing Lamont’s femininity alone would not necessarily have constituted a sexualiza- tion of the murders. But given that reporters juxtaposed such fawning descriptions of romantic purity with grue- some ones outlining sexual brutality, they clearly sought to create an apparent dichotomy between Durrant and his victims with sex at its center. The penny press subjected Minnie Williams to similar treatment. However, given her temperamental di8erences from Lamont, they highlighted distinct aspects of her char- acter that could have (in their narrative) contributed to her murder. However often reporters brought up Blanche Lamont the romantic— “the picture of the girl in the Fire- side Companion stories who has adventures among the traps of a great city,” according to one report from The Herald—they just as often brought up Minnie Williams the vulnerable63. Shortly after her disappearance, for in- stance, the Call wrote that Minnie Williams, “frail, weak, [and] inexperienced,” had vanished64. Whereas reporters had argued Lamont’s confident personality and extensive romantic experience could have gotten her into trouble with potential wrongdoers, with Minnie Williams, they claimed the opposite: her romantic, and, yes, sexual “inex- perience” made her an easy target for predators like Dur- rant. From opposing, nearly contradictory angles, Gilded Age newsmen had identified both women’s unique sus- ceptibilities that had contributed to their murder—doing so through an exclusively sexual lens. Newsmen usually published stories discussing each vic- tim individually, but they likewise sought to uphold their joint maidenhood by grouping Lamont and Williams to- gether from time to time. Some San Franciscans accom- plished this job for them. Judge Conlan, the justice presid- ing over Durrant’s case, personally informed the San Francisco Call of the unfortunate nature of his crimes: “’[Jack the Ripper’s] crimes had for their victims women of bad character,’”65 he argued, suggesting it was Lamont and Williams’s sexual purity that made Durrant’s murders all the more unacceptable. If, like Jack the Ripper, he had simply murdered prostitutes, perhaps the public outcry would not have been so severe. The Call further summa- rized the remarks of a Rev. Mr. Boynton (of San Francisco’s First Baptist Church), who launched into a protracted ti- rade during one sermon that instructed women of the city to “promise themselves ‘I will not go anywhere, under any pretext whatever, unless accompanied by my father or my brother. I will not enter anyplace where there are not others.”66 Opinions like those of Conlan and Boynton dominated reporting on Durrant’s murders, at least dur- ing discussions of his victims. And while they certainly exposed the misogynistic conceptions of womanhood that pervaded late nineteenth-century America, they also exem- plified the kind of sexual division the press sought to estab- lish between Durrant, the savage, and Lamont and Wil- liams, the romantically vulnerable. 49 !"# $#%&' &( !"# )#*(+, THE “PORNOGRAPHY OF VIOLENCE” Another phenomenon present in nearly all newspaper cov- erage of the Durrant case is something historian Karen Haltunnen terms “the pornography of violence”—that is, nineteenth-century America’s widespread fetishization of violence through its “pornography” in books, papers, and other media—all of which featured descriptions or images of vicious crimes in increasingly graphic detail67. The pen- ny press’s coverage of the Emmanuel Church murders embodied this pornography to the extreme. An early report from the San Francisco Call detailed how a “knife had been driven again and again and again into [Minnie Williams’s] breast” before delving into the minutiae of Durrant’s vio- lent acts in later coverage68. Durrant “cut her wrist so that she would bleed to death, and to complete the murderous work, had driven a knife to her heart and in a bestial fury slashed her breasts,” one story out of The Wichita Daily Eagle read, concluding that “the stabbing and slashing was done after the girl was dead.”69 Ironically, the violent por- nography cultivated more violent pornography, much of this variety speculative. Call reporter John McNaught, for example, informed his readers of the (unquestionably ra- cialized) divide between what he called the “brute” and the “fiend,” the latter of which Durrant must be: “There are just two classes of criminals who outrage women and murder them. One of these is the low, brutish criminal whose lust and ferocity are tempered by an intellect hardly su!cient to lift him above the level of a gorilla. The second is the man of intellect whose intelligence is distorted by a species of sexual madness growing out of some perverse diabolism of nature. All criminal history attests that only these two classes often, the brute and the fiend, commit crimes of this kind.”70 As violent speculation ran wild, other stories began con- demning the Emmanuel Baptist Church itself, one report from The Anaconda Standard claiming “a stain of human blood marks its history.”71 The author, apparently horrified, went on to detail how one of the church’s former pastors “killed a newspaper proprietor,” while another, he added rather abruptly, “blew out his brains.”72 Such absurd de- scriptions epitomized the pornography of violence pro- duced by Durrant’s murders, with newsmen devising ever- more outlandish reports to satisfy the insatiable public. While newspapers certainly fetishized all types of violence in the Durrant case, they especially did so if that violence was sexual in nature. In the immediate aftermath of the murders, newsmen raved whenever the police released shocking details, as in one Call report which gawked at their discovery that the murderer had shoved “a portion of [Lamont’s] underclothing” down her throat73. Indeed, such outrageously sexual details sent both newspapers and readers into a frenzy. Another Call story almost gleefully recounted how Lamont’s dress “had been unbuttoned and then torn from the body through impatience,” leaving her lying on the floor of the church’s belfry “absolutely nude.”74 Reporters even complained of a lack of excitement as the months went on—(authorities had finished collecting most of the facts over the course of April and May 1895)— the volume of licentious details released on a weekly basis waning accordingly. The Herald, for example, lamented that “as the trial progresses interest in it seems to lag,” somberly describing how “the crowd of morbidly curious people who have assembled at the courtroom door day af- ter day is growing less” as newspapers ran out of new Dur- rant-related “pornography” to distribute. However, such sobering realities failed to dissuade the penny press, which found entirely new, and unconventional ways to fe- tishize the murders. One facet of this unorthodox approach involved reporting on the astonishing July 1895 development concerning a San Francisco playwright who planned to dramatize Durrant’s murders in his theatrical production. Manager of San Francisco’s Alcazar theater W. R. Daily, reported The “Another visual assessment out of The Louisiana Populist depicted two versions of Durrant posing as Robert Louis Stevenson’s infamous villain Dr. Jekyll and Mr. Hyde, complemented by illustrations of a knife embedded in a skull” 50 !"!#!$%& : : &'()$* 2021 Oregon Mist, “closed arrangements with Richard C. White to make a dramatization of the Durrant case,” adding that “Mr. Daily believes that there is plenty of material in the story of the Emmanuel church murders.”75 Lacking substantive coverage as Durrant’s attorneys took their time selecting jurors, the penny press milked the theatrical development for weeks. Reporters amplified the divide between those eager to see the performance and others, like the pastors discussed in one Herald report, who believed the play would “demoralize the community.”76 As it became increasingly clear the play would not end up being performed, The Dalles Times-Mountaineer went so far as to entertain the theory that “if the fiend Durrant is acquitted of the charge against him he will be engaged at a remunerative salary to play the leading role in the play based on upon the heinous crimes.”77 In short, the penny press spent nearly a month producing new “pornography” by fetishizing the outrage over a theatrical production, the play itself a fetishization and pornographic o8shoot of Theodore Durrant’s violent crimes. Such absurdities exemplified the pornography of violence produced by the penny press in their obsessive coverage of the Emmanuel Church murders. Another way the penny press fetishized the murders when they lacked new developments involved publishing read- ers’ violent poetry. The Call, for instance, published a “re- markable” poem by a man named George King, who put his unique spin on the church murders: “Into the church they were decoyed by some fiend, but I won’t speak his name. / There to commit the bloody deed, he understood the game. […] There he did assault her [Williams] in a fiendish way, / Then took her life by strangling, that’s what the Coroner’s jury say. […] The perpetrator of the deed did it in cold blood, / More than human nerves he had, his business he understood. […] Young girls all take warning by the two innocent girls’ sad fate, / And be aware of all false young men, with them don’t stay out late. […] Mothers all take warning by this sad a"air, / Guard your girls day and night, of them take good care, / For if you don’t some day you may rue it when it is too late, / So remember well and bear in mind the two innocent girls’ fate.”78 Newspapers littered their discussions of the church mur- ders with similarly targeted poetry, highlighting the man- ner in which they relentlessly pumped out, or at the very least gave voice to Durrant “pornography.” Newspapers further accompanied their reportage with various gruesome illustrations that escalated their pornog- raphy of violence for voracious readers to new levels, visu- ally. The Dalles Times-Mountaineer, for instance, positioned several illustrations of Blanche Lamont’s rotting, naked corpse, the blood-stained floor of Emmanuel Baptist Church, and one of the knives used to stab Minnie Wil- liams next to their discussion of Durrant’s romantic fail- ures, rather heavy-handedly establishing their belief (or rather, lack thereof) in his innocence.79 Another visual as- sessment out of The Louisiana Populist depicted two ver- sions of Durrant posing as Robert Louis Stevenson’s infa- mous villain Dr. Jekyll and Mr. Hyde, complemented by illustrations of a knife embedded in a skull. At the bottom of the drawing, a snake slithered past Durrant’s feet.80 Be- cause the cost of photography precluded most news outlets from using it during the late nineteenth-century, the pen- ny press took an illustrative approach instead. Their quest to reveal the most licentious and sensational details of the Emmanuel Church murders- they produced yet another variety of violent pornography that overshadowed the en- tirety of their coverage of Durrant. MAUD ALLAN, DURRANT’S FATE, AND CONCLUSION Durrant’s sister, erotic dancer Maud Allan, su8ered simi- lar treatment at the hands of the press a few years later af- ter a brief (but successful) career in Europe. Whereas Dur- rant’s accusers often straddled the line between implicitly “Ultimately, print coverage of “the Demon of the Belfry” and his crimes during the Gilded Age underscores the ways in which media dramatically shapes public perception, an enduring reality that continues throughout the contemporary United States” 51 !"# $#%&' &( !"# )#*(+, !%3%,"!' 1. John D’Emilio and Estelle B. Freedman, Intimate Matters: A History of Sexuality in America, (Chicago: University of Chicago Press, 2013), 300. 2. Estelle B. Freedman, “Sexuality in Nineteenth-Century America: Behavior, Ideology, and Politics,” Reviews in American History 10, no. 4 (1982): 196–215, www.jstor.org/stable/2701827. 3. Oliver Chan and Kathleen M. Heide, “Sexual Homicide: A Synthesis of the Literature,” Trauma, Violence & Abuse 10, no. 1 (2009): 31-54, http://www.jstor.org/stable/26636179. 4. James Alan Fox and Jack Levin, “Multiple Homicide: Patterns of Serial and Mass Murder,” Crime and Justice 23 (1998): 407- 455, http://www.jstor.org/stable/1147545. 5. Herbert G. Kinnell, “Serial Homicide by Doctors: Shipman in Perspective,” BMJ: British Medical Journal 321, no. 7276 (2000): 1594-1597, http://www.jstor.org/stable/25226531. 6. Erich Fromm, War Within Man: A Psychological Inquiry into the Roots of Destructiveness (Philadelphia: Peace Literature Service, American Friends and Service Committee, 1963), 7-23. 7. Toni Bentley, Sisters of Salome, (New Haven: Yale University Press, 2002), 49-84. 8. Lacy McDearmon, “Maud Allan: The Public Record,” Dance Chronicle 2, no. 2 (1978): 85-105, http://www.jstor.org/ stable/1567472. 9. Karen Haltunnen, Murder Most Foul: The Killer and the American Gothic Imagination (Cambridge: Harvard University Press, 2001), 60-90. 10. “Blacker Grows the Cloud Over Emmanuel Baptist Church,” San Francisco Call, 15 April 1895, 3. The newspapers used for this essay come from the Library of Congress’s website, Chronicling America, at chroniclingamerica.loc.gov. 11. “Forging the Links On Him,” The Salt Lake Herald, 17 April 1895, 1. 12. “Not a Missing Link,” Rock Island Argus, 5 May 1895, 2. 13. “Durrant’s Examination,” The Dalles-Times Mountaineer, 4 May 1895, 2. 14. Weaving a Web Round Theodore Durrant,” San Francisco Call, 16 April 1895, 3. 15. The Frisco Mystery,” The Indianapolis Journal, 26 April 1895, 1. 16. “Durrant in the Courtroom,” The Herald, 23 July 1895, 1. 17. “Forging the Links On Him,” The Salt Lake Herald, 17 April 1895, 1. and explicitly defining his sexual misdeeds, critics of Allan and her rumored homosexuality showed no such hesita- tion. They characterized Allan and her rumored sexual “degeneracy” as the antithesis of Lamont and Williams, idols of traditional nineteenth-century womanhood81. Scholars Toni Bentley and Lacy McDearmon have chroni- cled Allan’s very open vilification in the British and Ameri- can press because of those accusations, exposing the gen- dered dichotomy of sexual discourse in the Victorian era—and how the media theatrically exploited this dis- course with events involving both men and women82. Eventually, interest in the Emmanuel church murders and their licentious details waned. After a media storm follow- ing the jury’s ruling, which found Durrant guilty of mur- der on November 23, 1895, public interest moved else- where. The court sentenced Durrant to death by hanging, and police transported him to San Quentin prison just north of San Francisco shortly after the conclusion of his trial—decisions which won much media praise. Though he maintained his innocence and appealed the court’s rul- ing several times, (generating the occasional article in the San Francisco Call, The Herald, or other papers that had covered his case), he was ultimately executed at San Quen- tin on January 7, 1898, with his mother by his side. The late nineteenth-century penny press’s overtly sensual coverage of the Emmanuel Baptist Church murders influenced Theodore Durrant’s conceptions, his crimes, and his victims in a sexual way, and was itself the product of changing conceptions of sexuality during the Gilded Age. Both entire newspapers and individual journalists romanticized Blanche Lamont and Minnie Williams, whom they cast as icons of traditional sexuality, while simultaneously fetishizing Durrant’s violence— particularly its sexual aspects. Their emphasis on his romantic failures, scrutiny of his academic career, and sentimentalization of his victims all contributed to the development of his extraordinary image in the American public’s mind: not a murderer driven to kill in traditional ways by traditional means, but a sexual deviant hell-bent on destroying traditional notions of sensuality. Again, such representations influenced Theodore Durrant’s public knowledge in specific, but they also—and more importantly— influenced the public’s conceptions of sexuality more generally. Ultimately, print coverage of “the Demon of the Belfry” and his crimes during the Gilded Age underscores how media dramatically shapes public perception, an enduring reality that continues throughout the contemporary United States. 52 !"!#!$%& : : &'()$* 2021 18. “New Evidence Against Durrant,” The Seattle Post- Intelligencer, 21 August 1895, 3; “Insulter of Women,” The Indianapolis Journal, 21 August 1895, 2; “His Baseness was Boundless,” The Salt Lake Herald, 21 August 1895, 2. 19. “Further Testimony in Regard of the Crime for which Durrant is Held,” The Dalles Times-Mountaineer, 20 April 1895, 2. 20. “Blood Stained Church,” The Herald, 15 April 1895, 1. 21. “Durrant Murder Case,” The Record-Union, 24 April 1895, 1. 22. “Miss Turner Weaves a Web,” The Salt Lake Herald, 24 April 1895, 1 23. “Blacker Grows the Cloud Over Emmanuel Baptist Church,” San Francisco Call, 15 April 1895, 3. 24. “Pawned a Ring Like Blanche Lamont’s,” San Francisco Call, 3 August 1895, 14. 25. Weaving a Web,” The Arizona Republican, 17 May 1895, 1. 26. “Durrant’s Trial Continued Until Tomorrow Morning,” The Herald, 24 July 1895, 1. 27. “Seeking to Stem the Tide,” The Salt Lake Herald, 6 May 1895, 1. 28. “Weaving a Web Round Theodore Durrant,” San Francisco Call, 16 April 1895, 3. 29. “Review of Durrant,” The Louisiana Populist, 21 June 1895, 4. 30. Ibid., 4; “Forging the Links On Him,” The Salt Lake Herald, 17 April 1895, 1. 31. “The Church Murders,” The New York Tribune, 21 April 1895, 22. 32. “Looks Dark for Durrant,” The Herald, 16 April 1895, 1. 33. Ibid., 1. 34. “Further Testimony in Regard of the Crime for which Durrant is Held,” The Dalles Times-Mountaineer, 20 April 1895, 2. 35. “Footgear is Found,” The Wichita Daily Eagle, 23 April 1895, 1. 36. “Their Request Denied,” San Francisco Call, 1 May 1895, 5. 37. “Blood Stained the Church,” The Herald, 15 April 1895, 1. 38. “Durrant Runs a Big Blu8,” The Salt Lake Herald, 10 May 1895, 1. 39. “Blood Stained the Church,” The Herald, 15 April 1895, 1. 40. “The Examination Resumed,” The Dalles Weekly Chronicle, 4 May 1895, 1. 41. “Looks Dark,” Arizona Weekly Citizen, 20 April 1895, 3. 42. “Looks Dark for Durrant,” The Herald, 16 April 1895, 1. 43. “Told on the Witness Stand,” The Herald, 24 April 1895, 1. 44. “Durrant Murder Case,” The Record-Union, 24 July 1895, 1; “Miss Lamont’s Death,” The Indianapolis Journal, 2 May 1895, 5; “Same Old Bravado,” The Salt Lake Herald, 30 May 1895, 1. 45. “A Bloody Shoe is Found in the Church,” San Francisco Call, 21 April 1895, 6. 46. “Key Carried by Durrant,” The Salt Lake Herald, 23 April 1895, 1; “Blood-Stained Coat is Found in Berkeley,” San Francisco Call, 23 April 1895, 5. 47. “Theo Durrant is Again Before the Bar,” San Francisco Call, 24 April 1895, 5. 48. Ibid., 5. 49. “Murder of Miss Williams,” The Record-Union, 20 April 1895, 1. 50. “The Trial Continues,” The Daily Morning Astorian, 24 April 1895, 1. 51. ”Women are Daft Over Durrant,” The Silver Blade, 27 July 1895, 2. 52. “The Durrant Examination,” The Record-Union, 25 April 1895, 1. 53. Ibid., 3. 54. “The Durrant Jurors, San Francisco Call, 24 July 1895, 14. 55. “Review of Durrant,” The Louisiana Populist, 21 June 1895, 4. 56. “Notable Dead,” The Seattle Post-Intelligencer, 24 April 1895, 8. 57. “Durrant Moves for Change in Venue,” San Francisco Call, 23 July 1895, 15. 58. “Durrant is Denied Change of Venue,” San Francisco Call, 26 July 1895, 14. 59. “The Mystery of a Girl,” San Francisco Call, 10 April 1895, 14. 60. “Blacker Grows the Cloud Over Emmanuel Baptist Church,” San Francisco Call, 15 April 1895, 3. 61. “Must Stand Trial,” San Francisco Call, 3 May 1895, 5. 62. “Blood Stained the Church,” The Herald, 15 April 1895, 1. 63. Ibid., 1. 64. “Blacker Grows the Cloud Over Emmanuel Baptist Church,” San Francisco Call, 15 April 1895, 3. 65. “Must Stand Trial,” San Francisco Call, 3 May 1895, 5. 66. “Clews Still Lead to Durrant,” San Francisco Call, 18 April 53 !"# $#%&' &( !"# )#*(+, 1895, 5. 67. Haltunnen, Murder Most Foul, 60-90. 68. “Blacker Grows the Cloud Over Emmanuel Baptist Church,” San Francisco Call, 15 April 1895, 3. 69. “Goes Into More Detail,” The Wichita Daily Eagle, 21 April 1895, 1. 70. “Clews Still Lead to Durrant,” San Francisco Call, 18 April 1895, 5. 71. “Verdict of the Jury,” The Anaconda Standard, 20 April 1895, 1. 72. Ibid., 1. 73. “Stuck Down in the Shadow of the Altar,” San Francisco Call, 14 April 1895, 6. 74. “Blacker Grows the Cloud Over Emmanuel Baptist Church,” San Francisco Call, 15 April 1895, 3. 75. “To Dramatize the Murders,” The Oregon Mist, 19 July 1895, 1. 76. “Durrant in the Courtroom,” The Herald, 23 July 1895, 1. 77. “No Title,” The Dalles Times-Mountaineer, 10 August 1895, 2. 78. “In Cell Twenty-Eight,” San Francisco Call, 5 May 1895, 5. 79. “Further Testimony in Regard of the Crime for which Durrant is Held,” The Dalles-Times Mountaineer, 20 April 1895, 2. 80. “Review of Durrant,” The Louisiana Populist, 21 June 1895, 4. 81. Lacy McDearmon, “Maud Allan: The Public Record,” Dance Chronicle 2, no. 2 (1978): 85-105, http://www.jstor.org/ stable/1567472. 82. Toni Bentley, Sisters of Salome, (New Haven: Yale University Press, 2002), 49-84. /!7!/!%.!' Bentley, Toni. Sisters of Salome. New Haven: Yale Univer- sity Press, 2002. “Blacker Grows the Cloud Over Emmanuel Baptist Church.” San Francisco Call, April 15, 1895. “Blood Stained Church.” The Herald, April 15, 1895. “Blood-Stained Coat is Found in Berkeley.” San Francisco Call, April 23, 1895. “A Bloody Shoe is Found in the Church.” San Francisco Call, April 21, 1895. Chan, Heng-Choon (Oliver), and Kathleen M. Heide. “Sex- ual Homicide: A Synthesis of the Literature.” Trauma, Vio- lence, & Abuse 10, no. 1 (2009): 31–54. https://doi. org/10.1177/1524838008326478. “The Church Murders.” The New York Tribune, April 21, 1895. “Clews Still Lead to Durrant.” San Francisco Call, April 18, 1895. D’Emilio, John, and Estelle B. Freedman. Intimate Mat- ters: A History of Sexuality in America. University of Chi- cago Press, 2013. “To Dramatize the Murders.” The Oregon Mist, July 19, 1895. “The Durrant Examination.” The Record-Union, April 25, 1895. “Durrant’s Examination.” The Dalles-Times Mountaineer, May 4, 1895. “Durrant in the Courtroom.” The Herald, July 23, 1895. “Durrant is Denied Change of Venue.” San Francisco Call, July 26, 1895. “The Durrant Jurors.” San Francisco Call, July 24, 1895. “Durrant Moves for Change in Venue.” San Francisco Call, July 23, 1895. “Durrant Murder Case.” The Record-Union, April 24, 1895. “Durrant Runs a Big Blu8.” The Salt Lake Herald, May 10, 1895. “Durrant’s Trial Continued Until Tomorrow Morning.” The Herald, July 24, 1895. 54 !"!#!$%& : : &'()$* 2021 “The Examination Resumed.” The Dalles Weekly Chroni- cle, May 4, 1895. “Footgear is Found.” The Wichita Daily Eagle, April 23, 1895. “Forging the Links On Him.” The Salt Lake Herald, April 17, 1895. Fox, James Alan, and Jack Levin. “Multiple Homicide: Pat- terns of Serial and Mass Murder.” Crime and Justice 23 (1998): 407–55. https://doi.org/10.1086/449274. Freedman, Estelle B. “Sexuality in Nineteenth-Century America: Behavior, Ideology, and Politics.” Reviews in American History 10, no. 4 (1982): 196–215. https://doi. org/10.2307/2701827. “The Frisco Mystery.” The Indianapolis Journal, April 26, 1895. Fromm, Erich. War Within Man: A Psychological Enquiry Into the Roots of Destructiveness; A Study and Commen- tary. Philadelphia: Peace Literature Service of the Ameri- can Friends Service Committee, 1963. “Further Testimony in Regard of the Crime for which Dur- rant is Held.” The Dalles Times-Mountaineer, April 20, 1895. “Goes Into More Detail.” The Wichita Daily Eagle, April 21, 1895. Halttunen, Karen. Murder Most Foul: The Killer and the American Gothic Imagination. Cambridge: Harvard Uni- versity Press, 2001. “His Baseness was Boundless.” The Salt Lake Herald, Au- gust 21, 1895. “In Cell Twenty-Eight.” San Francisco Call, May 5, 1895. “Insulter of Women.” The Indianapolis Journal, August 21, 1895. “Key Carried by Durrant.” The Salt Lake Herald, April 23, 1895. Kinnell, Herbert G. “Serial Homicide by Doctors: Ship- man in Perspective.” BMJ: British Medical Journal 321, no. 7276 (2000): 1594–97. https://doi. org/10.1136/bmj.321.7276.1594. “Looks Dark.” Arizona Weekly Citizen, April 20, 1895. “Looks Dark for Durrant.” The Herald, April 16, 1895. McDearmon, Lacy. “Maud Allan: The Public Record.” Dance Chronicle 2, no. 2 (1978): 85–105. https://doi.org/10.1080/01472527808568721. “Miss Lamont’s Death.” The Indianapolis Journal, May 2, 1895. “Miss Turner Weaves a Web.” The Salt Lake Herald, April 24, 1895. “Murder of Miss Williams.” The Record-Union, April 20, 1895. “Must Stand Trial.” San Francisco Call, May 3, 1895. “The Mystery of a Girl.” San Francisco Call, April 10, 1895. “New Evidence Against Durrant.” The Seattle Post-Intelli- gencer, August 21, 1895. “No Title.” The Dalles Times-Mountaineer, August 10, 1895. “Not a Missing Link.” Rock Island Argus, May 5, 1895. “Notable Dead.” The Seattle Post-Intelligencer, April 24, 1895. “Pawned a Ring Like Blanche Lamont’s.” San Francisco Call, August 3, 1895. “Review of Durrant.” The Louisiana Populist, June 21, 1895. “Same Old Bravado.” The Salt Lake Herald, May 30, 1895. “Seeking to Stem the Tide.” The Salt Lake Herald, May 6, 55 !"# $#%&' &( !"# )#*(+, 1895. “Stuck Down in the Shadow of the Altar.” San Francisco Call, April 14, 1895. “Their Request Denied.” San Francisco Call, May 1, 1895. “Theo Durrant is Again Before the Bar.” San Francisco Call, April 24, 1895. “Told on the Witness Stand.” The Herald, April 24, 1895. “The Trial Continues,” The Daily Morning Astorian, 24 April 1895, 1. “Verdict of the Jury.” The Anaconda Standard, April 20, 1895. “Weaving a Web.” The Arizona Republican, May 17, 1895. “Weaving a Web Round Theodore Durrant.” San Francisco Call, April 16, 1895. ”Women are Daft Over Durrant,” The Silver Blade, 27 July 1895, 2. 56 !"!#!$%& : : &'()$* 2021 !" !# $%&$'#"!(%)*+' ",)" ",' -(./)%!'# ",)" ,(+0 ",' /$*+!- '1' "(0)1 )2' .(#"+1 32(. ",' "'-,%(+(41 #'-"(2. 42(5!%4 2)/!0+1 32(. ",' 1990# )%0 (%5)20#, ",' -$2- 2'%" +')0'2# !% ",' 3!'+0 %(5 #'' ",'.#'+6'# )" ",' -'%"'2 (3 -(%-'2%# (6'2 .(%(/- (+1 )%0 "2$#" 3(2.!%4 !##$'# ",)" ,)6' +'0 "( 2'%'5'0 !%"'2'#" 32(. ",' $# )""(2%'1 4'%'2)+’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robing the Pertinance of Antitrust Law for Big Law +$- 2!(20)% +%"/,3*."+,% Of the ten most valuable companies in the world as of No- vember 3rd 2020, seven are technology companies, with five of those seven based in the United States and leaders in their respective sub industries. Google, through Alpha- bet Inc., Facebook and Microsoft are three of these compa- nies that have come under scrutiny for allegations of mo- nopolistic or monopoly-forming behavior that could violate competition law of the United States in order to benefit themselves to an outsized degree. As the age of industrial power in the United States has waned, these types of com- panies have risen to take the place of the JP Morgans and Standard Oils, at least in the eyes of consumer groups and trust-busting minded politicians of Capitol Hill. However, the fears of these groups are not entirely unfounded. Dat- ing back to the earlier telecoms boom and the rise of AT&T, there have been fears of a growth of a new age of Robber Barons in the technology field that could come to domi- nate competition, forming their own trusts and ensuring that control of their markets is uncontested. Dissent appears in this topic over whether or not so-called ‘high technology’ should be considered to fall under the purview of antitrust law, and there was considerable op- position to United States v. Microsoft Corp. in the academic world, with a combined 240 economists from institutions across the country coming together to warn of the dangers of overzealous enforcement of antitrust measures. Wor- ried that this prosecutorial appetite would hamper innova- tion, scholars wrote an open letter that demonstrated the complexity of the issue and raised the question of how far to go when it came to e8orts to protect competition and consumers from monopolistic tendencies. In this paper, I intend to lay out a brief history of antitrust in the United States and how it relates to the technology industry, focusing on a few major cases that relate to ongo- ing investigations being conducted by the Department of Justice and Federal Trade Commision today. I will attempt to show the damages that monopolies can have on an economy, relating these to actions undertaken by certain companies before discussing the merits and demerits of enforcement and current laws enforced in the present day. The issue at hand is not solely an economic one, as even being perceived as a monopoly can prove to be detrimental to a company’s image, adding increased social costs to real or perceived economic costs. Greater scrutiny and an in- crease in bureaucratic oversight can hamper development as more resources are dedicated to litigation, fact finding, and lobbying to counteract these developments. Ultimate- ly, there seems to be little agreement on the facts of anti- trust measures going forward, with a general fear of ‘big tech’ and concerns over innovation incentives and protec- tionism weighing down the progress of the issues. Criticism of antitrust action is not likely to recede whether it be related to increased or decreased measures, but as the United States raises new concerns regarding the nature of companies in the the technology field like Facebook and Google, there is likely to be increased discussion that re- lates to how far to go with the current and following rounds of antitrust action undertaken. However, the end goal will likely always remain the same in the technology industry and the general idea underpinning all antitrust regulation: ensure innovation and a lower barrier to entry is protected while making sure that no one individual or cartel can ex- ert undue control over the market. #+'",/4 Monopolization and anti-competitive actions have spanned the history of the United States, dating back to the progres- sive era and the Robber Barons who dominated much of the early industrialization of the North American conti- nent. More recently, there have been serious instances where the issue of monopolization was brought to the forefront of the legal and political world, based on the un- derstanding of the Sherman Act of 1890. The Sherman Act sought to ensure that no one company, or grouping of companies, could accrue so much power that they were able to dictate the nature in which trade, primarily with foreign powers but also across state boundaries,to allow for free competition and avoid the as- sociated costs that could arrive with a coercive monopoly in the United States. Trust Busting and enforcement of the antitrust laws in the United States were prominent in the Progressive Era of the early 1900s. Theodore Roosevelt was particularly prominent in this e8ort and presided over one of the larg- est antitrust e8orts of the era with the Northern Securities Co. case ruled to have violated competition law in 1904. The case held that the merger of the Great Northern and Northern Pacific railroads was unlawful as it would have created an e8ective monopoly over railroad tra(c in the Western half of the United States, and at the time would have become the single largest company in the world. The major consideration underpinning the judgement was the 58 !"!#!$%& : : &'()$* 2021 assertion that by combining these two railroads under a single holding, they would cease to be in competition with each other and would therefore constitute the creation of a restraint on interstate commerce (Northern Securities Co. v. United States, 1904). More recently, technology companies have become the tar- get for much of the antitrust action undertaken in the last forty or so years. AT&T became a target in the case in 1982, breaking up the company’s local holdings into separate Re- gional Bell Operating Companies. It was suspected that AT&T was using profits from Western Electric in order to subsidize the operation of their telecoms network. Eventu- ally a settlement was reached where the company was found to be in breach of US antitrust law and was ordered to divest from their network of Bell companies and relin- quish control of the Yellow Pages, creating the regional bell operating company system (Enis & Sullivan, 1985). Twenty years later, Microsoft came under attack for what was perceived to be acting in an uncompetitive manner. Much of the complaint, filed by the US attorney general and twenty other states’ attorney generals, was based on the belief that the bundling of Microsoft programs into their operating system was in the pursuit of a monopoly. This act was alleged to give away a Microsoft-created product for free in order to further the control of the market that they already enjoyed. Specifically, Microsoft was alleged to have forced the inclusion of Internet Explorer into the Windows suite, claiming it was an integrated feature of Windows and not an extra product that they were bundling into the separate Windows product. The court held that the bundling of Microsoft’s own browsing program was indeed a violation of the Sherman Act and therefore anti-competitive. Judge Jackson ordered the breakup of Microsoft into software development and operating system development components, but this was later reversed by an appeals court (United States v. Microsoft Corp., 2000). After this we see the continuation of antitrust laws in technology and telecoms focused on software and programs with the more recent filings against both Facebook and Google. In the past few months, the CEOs of Amazon, Facebook, Twitter and Google all appeared before Congress in order to testify over their practices in the virtual space and whether or not these actions have constituted a violation of US competition law. In a 2010 article, Fortune stated that, “it’s safe to say social networking is Facebook” demonstrating just how prominent that company in particular is in the popular imagination (Kevin Kelleher, 2010). However, popular image is not the only aspect in which these companies are seen as juggernauts of industry. As with Microsoft becoming involved in action by the federal government, recent months have seen the growth of the Department of Justice and Federal Trade Commission interest in pursuing action against both Facebook and Microsoft under the provisions of the Sherman Act. In complaints issued on October 20, 2020 and December 9, 2020 respectively, the federal government seems to be increasing their interest in antitrust action. Citing both the 1974 and 1998 cases against AT&T and Microsoft, Deputy Attorney General Rosenstein called the suit against Google, “[an enforcement of ] the Sherman Act to restore the role of competition and open the door to the next wave of innovation … in digital markets” (O(ce of Public A8airs, DoJ, 2020). Additionally, and more recently, the filing of a suit against Facebook may be one of the largest and most expansively supported actions taken by the FTC in technology antitrust cases. Supported by an investigation from “attorney gener- als of 46 states, the District of Columbia and Guam” the complaint issued on December 9, 2020 describes the anti- competitive actions of Facebook as including the strategic acquisitions of growing competitors WhatsApp and Insta- gram (O(ce of Public A8airs, FTC, 2020). It also focuses on platform conduct that required companies developing applications that could interface with Facebook to refrain from creating any competing products, e8ectively locking the developers into subservience to Facebook’s own appli- cations. The complaint specifically cites the case of Vine, a social media app launched by Twitter, that was denied ac- cess to friends lists originating from Facebook due to the perceived threat the new application represented (O(ce of Public A8airs, FTC, 2020). This suit is not without merit, as Consumer Watchdog submitted a complaint to the FTC alleging anti-competitive practices in Facebook’s gaming department, requiring that developers using Facebook as a social aspect of their games exclusively use Facebook Cred- its. Consumer Watchdog estimated this would bring in $2.1 billion in 2011 alone (Simpson, 2011). $%$54'+' From an economic theory standpoint, the issues present in monopolization cases are clear. Monopolization is harmful by nature due to the incentives to maximize the individual profit of monopolists rather than producing at the free market equilibrium. As shown by even the most basic economics textbook, a monopolist will not produce at the intersection of the supply and demand curves, but will 59 !"#$%&'() !'%* )'+(%$ instead produce at a point where marginal revenue equals marginal costs, creating a market where a smaller quantity of goods are produced for a higher price than we would see in even a marginally more competitive market. Addition- ally, monopolized markets will see issues arise with con- sumer and producer surplus. As the number of suppliers drops to a single one and pro- duction shifts back on the price-quantity scale, we will see a combined increase in producer surplus with a similar, but not equal, decrease in consumer surplus along with the deadweight loss of this monopolized market. There- fore, we can see that there is a clear and basic need for ac- tion to be taken against monopolizers, since the presence of these market practices leads to not only a decrease in the well-being of consumers but also for society as a whole in the deadweight loss. All this for the benefit of just an indi- vidual company or consortium. As it relates to technology companies, there are some eco- nomic concerns that arise as the government looks to pre- vent the formation of monopolies in the market- chief among these being the network e8ects that are so promi- nent in the technology industry. In the Department of Jus- tice suit against Microsoft in 1994, competitors of Micro- soft submitted a brief with a warning of the network e8ects that were far more prominent in technology than in almost any other market (Elzinga et al., 2001). The economic sec- tion of this brief argued that by allowing Microsoft to grow to such an extent, that the simple nature of their products would lock users into their use, which could lead to the crowding out of potentially superior technology. Monopolization in the technology market is not just about the nature of the market itself, nor is antitrust law limited to simply growing too large through that. The Sherman Act outlaws assaults on competitive practices, and this concern in the tech industry was raised by Cornell and Cessna when discussing the e8ects that acquisitions can have on the technology market. Citing the idea of ‘Killer Acquisitions’, the article talks about predatory practices in mergers and acquisitions that are outlined in the Sherman Act as anti-competitive actions (Cornell & Cessna, 2019). According to their article in Competition Law International, these acquisitions can be termed ‘acquihires’ due to their goal of taking in talented workers while denying the ac- quired firms the ability to present new products to the market. Data from 2020 may support this assertion of strategic and anti-competitive acquisitions, with a total of 406 mergers and acquisitions in the technology service sector in 2020 with a combined value of over $114 billion. As seen in Graph 2, the technology sector had the second largest number of mergers and acquisitions behind only commercial services but outperformed all over sectors in value by at least $70 billion. In fact, the only sector com- ing anywhere near that number being the health services industry with only $41.8 billion in value from 108 transac- tions. This suggests that the technology market is seeing vast consolidation of valuable companies that completely outpaces the rates of consolidation of other industries. Linking this back to the concerns of network e8ects brought to the forefront in the 1994 case, there is a clear concern here that domination of the technology market can lead to the dumbing down of the field with inferior products, with market share protected only by the size of the networks and financial power given to them and the use of said power to absorb smaller firms that may threat- en their dominance. Even though the fears of monopoly are clear in the already mentioned Microsoft case, there is a key factor that does cast some doubt on how truly anti-competitive Microsoft was in their actions leading up to the suit. An open letter, published by The Independent Institute and run in both the Washington Post and New York Times, decried the suit 4.&6# 1: 4.&6# -''5*".&"-34 "#$ *#-)"* -3 6.-,$ &31 85&3"-"/ *566'/ &* & +&.9$" ,#&34$* ).(+ & 6$.)$,"'/ ,(+6$"-"-:$ +&.9$" "( & ".5$ +(3(6('/. (!"#$%&'( ") '/(4"$."%"$5.5+%1#6.+") 60 !"!#!$%& : : &'()$* 2021 brought against Microsoft as nothing more than action that would benefit none but the company’s competitors. The letter, signed by 240 economists from across the Unit- ed States, claimed that by allowing the action to go for- ward, the government would in e8ect be hampering the innovation of the technology industry that had driven Mi- crosoft to its position of dominance in the market. The sig- natories claimed that consumers saw falling prices rather than rising, suggesting that monopoly power was not be- ing exerted by Microsoft and that the dominance of Bill Gates’ company could be attributed to the free markets and dynamism of technology. This dynamism was also credited with driving competitors of the company in 1994 to provide the economic brief mentioned earlier. Decrying actions that were being taken as protectionist, the letter warned that too much government overreach into the mar- ket would invariably lead to a situation where “Successful innovators are penalized, scale economies are lost, and competition is thwarted, not enhanced. Instead of prevent- ing prices from rising, antitrust protectionism keeps pric- es from falling” (The Independent Institute, 1999). In terms of the formal determination of what is a monop- oly, the United States has a relatively robust understanding that allows for market domination but likely not complete control. “A rough rule of thumb in the United States is that a 90% share of a well-defined relevant market is a mo- nopoly, 66% may be a monopoly, and 33% clearly is not.” (Waller, 2012, p. 1776) As it pertains to both Google as a search engine, it is almost certainly a monopoly. Over the last 10 years, Google has maintained between 86% and 92% of the global search engine market, making it by definition a monopoly or near monopoly by the stan- dards of the United States, while in the United States alone, there is less clear evidence of this with market share maintained only a little over 60%. Since 2008 we can see that it did peak at 68.8% in January of 2016, but this would only make it a likely monopoly by US standards. 4.&6# 2: 4.&6#* *#(0-34 "#$ 35+%$. &31 :&'5$ () +$.4$.* &31 &,85-*-"-(3* -3 *$'$,"$1 -315*".-$*. (!"#$%&'( ") '%/%+'%/) 4.&6# 3: 4.&6#* *#(0-34 4'(%&' *$&.,# $34-3$ +&.9$" *#&.$ &31 1(+$*"-, 5* *$&.,# 85$./ *#&.$ %/ *$'$," *$&.,# $34-3$*. (!"#$%&'( ") '%/%+'%/) 61 !"#$%&'() !'%* )'+(%$ When we consider the growth of Microsoft market share in search query handling, which peaked in July 2020 at 25.9%, it becomes questionable as to how strong is Google’s monopoly over this aspect of technology. In 1994, the antitrust case against Microsoft was driven in part by evidence brought to the judge by Gary Reback, an attorney for some of Microsoft’s competitors. The evidence consist- ed of a 96-page amicus brief that provided details he claimed was pertinent to the case (Elzinga et al., 2001, p. 637). The clients represented by Reback were kept confi- dential, which raises some questions regarding the incen- tives for antitrust action in the technology sphere, espe- cially when you consider that Reback was also involved in lobbying for such action against Microsoft before the suit was brought (Elzinga et al., 2001, p. 637). Fighting against calls to break up Microsoft in 1995, the Department of Jus- tice had called the attempt a remedy that might advance the interests of Microsoft’s competitors but would invari- ably act against the interests of the public. They claimed that the actions of Microsoft had brought benefits to the technology sector as a whole, increasing the rate of innova- tion and providing a lower barrier to entry for new firms (Elzinga et al., 2001, pp. 640–641). Table 1 includes the findings from Corptech as to the num- ber of software firms in the market around the time of the suits against Microsoft. While Microsoft may have shown dominance in the market, it is clear that they could not have been acting as an e8ective monopoly with firm for- mation occurring in such a way. By allowing for suits that target industry drivers, there is ample incentive for compa- nies to latch on to these actions if it will reduce the market share of their competitors. As discussed before, a concern with the technology industry is the presence of strong net- work e8ects that could drive monopolization. Yet, should monopolization be avoided, hindering companies for fear of these e8ects could hamper the growth of the industry as a whole in favor of what would ostensibly become a cartel that controls development for their own needs. Potential monopolization in technology has not only created vast economic reserves for the companies suspected of the practices but has also given them vast lobbying power and a reputation in the eyes of the American public as preda- tory corporations that seek nothing more than the exten- sion of their monopoly power in the market. Graph 4 displays a breakdown of just how pervasive the idea of monopolization in the technology industry has be- come in the United States. Indeed the attitudes expressed here are not only held by the average public, but also by academics. Discussing the classification of social media in 2013, Adam Thierer referenced academic Zeynep Tufecki and her categorization of Facebook and Google as poten- tial “social utilities” that are at risk of becoming corpora- tized regardless of their nature as “essential to one’s social existence” (Thierer, 2013, p. 254). However, this approach to classifying social media is warned against in the article, regardless of the beliefs of academics. Thierer argues that while networks like Facebook and Twitter provide strong networked services, they are not the endpoint of social me- dia interaction, pointing out that applications like Friend- ster and MySpace have faded from the spotlight despite being dominant (Thierer, 2013, p. 275). So far, antitrust law has seemed to work well as a measure against monopolization in technology, as it allows for the flexibility of the government in whether to break up com- "&%'$ 1: ,(.6(.&"$ "$,#3('(4/ -3)(.+&"-(3 *$.:-,$*, ,(.6"$,# 1&"&%&*$, 5365%'-*#$1 "&%5'&"-(3 (2000) 4.&6# 4: "#$ %.$&91(03 () (6-3-(3 .$4&.1-34 %.$&9-34 56 ‘%-4 "$,#’ %/ 6('-"-,&' &))-'-&"-(3 -3 "#$ 53-"$1 *"&"$* (!"#$%&'( ") '%/%+'%/) 62 !"!#!$%& : : &'()$* 2021 panies-as was the case with AT&T-or to allow companies to continue to exist as they were with simple changes to their own business practices-as was the case with Microsoft in 1994. However, in his testimony to Congress in October of 2020, Bill Baer of the Brookings Institute warned of un- derenforcement of antitrust measures (Baer, 2020). He claimed that the standards for antitrust action were far too high and had led to consolidation of firms in markets that would have been quashed in the 1990s. Highlighting the overturned decision against Microsoft in 2001, he stated that antitrust action is “too cautious, too worried about ad- verse e8ects of ‘over enforcement’ (so called Type I errors)” (Baer, 2020) and that consequently the minimum stan- dard for enforcement was higher than the given black let- ter law standard of a preponderance of evidence. This fear of error is present in Elzinga et al.’s article on the cases against Microsoft, stating, “as in medicine, antitrust rem- edies must be considered for their side e8ects. The anti- trust parallel to the hippocratic oath’s “do no harm” is “don’t make it worse.” (Elzinga et al., 2001, p. 689). Baer went on to decry current antitrust law as omitting the pre- sumption that certain behaviours were likely to lead to the reduction of competition. This would then allow defen- dants in any antitrust case to simply claim that they were only acting in the same way that any other company would in their position. Baer’s final criticism on antitrust actions as of 2020 was not the law itself but the lack of resources available to those enforcing it. In fact, his assertion was not so much a call to action but a call to observation: “But sec- ond, more resources would allow for after-action studies of what happened in markets where the agencies decided not to bring enforcement actions or where the courts rejected an antitrust challenge. Developing that data would allow the antitrust enforcers to demonstrate to the courts what happens when there is under-enforcement” (Baer, 2020). This evaluation of the current state of law could avoid the pitfalls of the Type 1 errors he mentioned earlier in his testimony, as further understanding of how the market re- acts to actions considered potentially anti-competitive could allow for a more concrete understanding of the ways in which these actions a8ect the market. This can avoid either the problem of overenforcement or underenforce- ment that has damaged antitrust action over time. .,%.5*'+,% $%3 +625+.$"+,%' So far, the only unifying factor that we can see in antitrust law today is that there is little consensus on where it should go in the future. As discussed, there have been calls for the breakup of larger companies, particularly for Microsoft in the cases brought against them by the federal government between 1990 and 2001. All the while, there has also been pushback against this kind of bureaucratic involvement in the market from economists that credit control over the market to the dynamism of technological development and the natural flow of economic cycles. Yet what can be agreed upon likely is that there is too much that is currently unclear in antitrust measures as it pertains to technology. Some broad conclusions can be drawn about the state of the technology market to give future policy makers an idea of what they are dealing with. Looking back to the analysis section, we can see that this sector of the economy is po- tentially the single greatest value creator of any market in which economic activity currently takes place. That pro- vides lawmakers with a clear dilemma with regulation. Ob- viously the government would want to encourage growth of economic activity in this field, as more activity provides more jobs and higher tax income from profitable compa- nies and employed citizens. However, this kind of market also incentivizes practices that the government may deem unwanted. The Department of Justice complaint filed this year details the practices said to be used by Google to en- sure its dominance in such a valuable market, claiming the use of exclusivity agreements and irreversible pre-in- stallations of their own products on devices regardless of the desires of customers. So a balance must be struck that must prevent exploitation but, as the Independent Insti- tute warned in 1999, does not result in restrictions that muzzle innovation in the field. “...a balance must be struck that must prevent exploitation but, as the Independent Institute warned in 1999, does not result in restrictions that muzzle innovation in the field.” 63 !"#$%&'() !'%* )'+(%$ Additionally, there is a worry that over-enforcement of these actions as the opening of cases into a competitor by the government may provide a perverse incentive for companies to submit evidence or lobby the government to break up individual companies that have gained a dominant spot simply because of their business acumen, technology, or just random chance that the Sherman Act does allow for in a competitive market. Legislators and regulators must therefore be wary of being overzealous in their approach to the topic at hand, lest they create a less competitive market in search of just the opposite. Antitrust law can be tricky for these reasons and the success of the technology industry may be down to the laissez-faire approach the government in the United States has taken, as opposed to the stricter regulation that befalls the European markets. The public perception of companies in the technology sector does leave the average viewer wondering what can be done to restore trust in the technology sector and allow for the innovation that has led to such a growth of economic activity. The most prominent of ideas that could be implemented to answer the problem may be by protecting personal data as a way to reduce the control that large companies exert, particularly on social media. The largest concern about so- cial media control has to do with the level of control to which they exert over the choice of platform. With the ac- quisition of Instagram and WhatsApp, Facebook was able to allow users to port their data from one platform to an- other, expanding their network between these three apps and creating a closed system that was mutually beneficial between them. Twitter data cannot be shared across these apps and in a similar way, Google can port data between devices that use their search engine and create a history and profile from a user’s queries. E8ectively, these compa- nies control a user’s data that they input into their network and can e8ectively lock them in using that data as a ‘sunk- cost’. If a user has spent so much time on one platform or network, why would they switch over to another that re- quires them to build a completely new profile? No matter if the technology on this new network is superior, they simply do not have the interconnectivity that the original network provides. The MIT Technology Review suggests that this policy of data regulation is the best way forward and indeed implies a breakup of technology companies would be more ine(cient and costly than simply regulating their practices (Chen, 2019). By removing a user’s data from the control of social media giants, the government could successfully eliminate much of the detrimental lock-in network e8ects of ‘big tech’ and provide a jumping o8 point for increased innovation. Instead of exclusive access to data that user’s provide to technology companies, the government could legislate to give control of said data back to consumers or mandate that data be considered an integral part of the online persona of internet users. These users would then be able to lend out that data to platforms and remove it at will. By doing so, technology companies would simply be purveyors of platforms for the data, turning the market from one driven by the collection and control of data to one that would again reward technology and innovation rather than consolidation. This does raise some questions about what kind of data could be shared across platforms and how those platforms could use said data. However, by forcing data to be shared between platforms the advertising market could be opened up as more suppliers enter the market and the barrier to entry for new firms in the social and technology space would be lowered by the newfound prevalence of data in the market. Ultimately we would hope to see this policy boost the rate of innovation in the technology sector as mentioned, but some will be at a disadvantage, even as the market would likely grow. Facebook, Twitter, Google, and other technol- ogy giants would naturally see their market dominance decrease, particularly in social media , as Google seems well insulated in the search engine market. Depending on what legislation or amendments to the Sherman Act are passed, there would likely be litigation that challenges the nature of the data in a similar way to the 2000 Microsoft case, potentially claiming said data as a feature of the prod- ucts and not separate entities over which they exert un- competitive control. However, should a hands-o8 approach be taken, as suggested in Bill Baer’s testimony to the House Committee on the Judiciary, a more scientific ap- proach could lead to more concrete standards of what ac- tions truly lead to monopolistic consolidation. Ultimately, the nature of the technology sector is unlikely to change drastically with new antitrust measures undertaken. Based on previous cases, if the court rules against Facebook and Google, there will likely be a challenge and potential settle- ment that allows for the maintenance of the companies but forces them to release data that they previously held exclusively and orders them to refrain from exclusivity deals, such as Google’s deal with Apple as cited in the DoJ complaint of this year (O(ce of Public A8airs, DoJ, 2020). Ultimately, Americans may dislike “Big Tech,” but many 64 !"!#!$%& : : &'()$* 2021 believe they cannot live without it. Facebook and Google are unlikely to disappear in the same way that Microsoft is still a major player in the technology industry. However, should more e8ective standards be determined, we should hope to see a new growth in technology innovation that may upset the power of the established juggernauts. /!7!/!%.!' Baer, B. (2020, October 1). Proposals to Strengthen the Antitrust Laws and Restore Competition Online [Testimo- ny]. Chen, A. (2019, June 7). How to regulate Big Tech without breaking it up. MIT Technology Review. https://www.tech- nologyreview.com/2019/06/07/135034/big-tech-monopo- ly-breakup-ama zon-apple-facebook-google-regulation-pol- icy/ Cornell, T., & Cessna, A. (2019). Do not pass go: A new card in US antitrust enforcement of the tech titans. Com- petition Law International (IBA), 1502. Elzinga, K. G., Evans, D. S., & Nichols, A. L. (2001). UNIT- ED STATES v. MICROSOFT: REMEDY OR MALADY. George Mason Law Review, 9. Enis, B., & Sullivan, T. (1985). The AT&T Settlement: Legal Summary, Economic Analysis, and Marketing Implica- tions. Journal of Marketing, 49(1), 127–136. Kevin Kelleher. (2010, November 19). How Facebook learned from MySpace’s mistakes. Fortune. https://for- tune.com/2010/11/19/how-facebook-learned-from- myspaces-mistakes/ Northern Securities Co. V. United States, (Supreme Court of the United States 1904). O(ce of Public A8airs, DoJ. (2020, October 20). Justice Department Sues Monopolist Google For Violating Anti- trust Laws. https://www.justice.gov/opa/pr/justice-depart- ment-sues-monopolist-google-violating-antitr ust-laws O(ce of Public A8airs, FTC. (2020, December 9). FTC Sues Facebook for Illegal Monopolization. Federal Trade Commission. https://www.ftc.gov/news-events/press-re- leases/2020/12/ftc-sues-facebook-illegal-mono polization Simpson, J. (2011). Consumer Watchdog Says Facebook Credits Used In Online Games Violate Antitrust Law; Asks Federal Trade Commission To Intervene | Consumer Watchdog. Consumer Watchdog. https://www.consumer- watchdog.org/newsrelease/consumer-watchdog-says-face- book-cr edits-used-online-games-violate-antitrust-law- asks-fed The Independent Institute. (1999, June 2). An Open Letter to President Bill Clinton From 240 Economists on Anti- trust Protectionism. Washington Post. Thierer, A. (2013). THE PERILS OF CLASSIFYING SO- CIAL MEDIA PLATFORMS AS PUBLIC UTILITIES. Catholic University Journal of Law and Technology, 21. United States v. Microsoft Corp., (United States District Court, District of Columbia June 7, 2000). Waller, S. W. (2012). SOCIAL NETWORKS AND THE LAW: ANTITRUST AND SOCIAL NETWORKING. North Carolina Law Review, 90. 65 !"#$%&'() !'%* )'+(%$ !"#$ %&%'( )'$*(#+'$ !"' *,--'*!#,- +'!.''- !"' /,,)$ .' '&! &-) ,0( +(&#- "'&1!". #! &$$'$$'$ !"' 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"'#2"!'-') ,7#)&!#8' $!('$$ /,0-) #- &) +(&#-$. !"' 4#-) &-) )&$" )#'!$ "&8' +,!" +''- $",.- !, )#4#-#$" &1- 3"'#4'(’$ #-*#)'-*'$, +0! !"' 4#-) )#'! %(,8'$ #!$'1/ !, +' 4,(' #4%&*!/01 !"&- !"' )&$" )0' !, #!$ $%'*#/#* '4%"&$#$ ,- !"' *,-$04%!#,- ,/ /,,)$ "#2" #- &-!#,7#)&-!$. !""# !"$ %&"'(&% Researching nutrition’s mitigating e!ects on the Pathogenesis of Alzheimer’s Disease *&(,1#-' *,"'- %*"/+"+,%’' 3!"!/6+%$"+,% ,7 ,1!/$55 #!$5"# Food has e8ects on your body and overall health that may not be completely obvious from the outside. Many people believe that regardless of food choices, having a smaller body frame means being healthy. However, nutrition re- search has shown that certain nutrient groups have vari- ous e8ects on the body, including the brain, that prevent or promote the development of diseases and other health problems. Following a nutrient-specific diet plan over one’s lifespan can serve as a preventative measure for the development of Alzheimer’s disease (AD). Numerous studies suggest that guided consumption of vitamin C, vi- tamin E, antioxidants, and essential fatty acids can miti- gate the progression of amyloid-beta plaques, tau tangles, and oxidative stress, thus constituting a preventative and therapeutic, non-pharmaceutical approach to tackling AD. $5;#!+6!/’' /+'& 7$.",/' $%3 .,66,% 0/$+% $0%,/6$5+"+!' The hallmark brain markers found in AD patients are pri- marily tau tangles and amyloid-beta plaques. The pres- ence of both of these lead to the impairment of memory that characterizes the illness. The accumulation of beta- amyloid protein forms these plaques and triggers both synaptic and memory loss, therefore facilitating AD devel- opment (Nakandakari et al., 2019). Tau tangles are com- posed of aggregated tau proteins that interfere with cellu- lar mechanisms, ultimately causing the cell to die (ibid). The diminishing size of the brain is a result of neuronal and synaptic death, which are more strongly correlated with the memory loss in AD than beta-amyloid plaques and tau tangles (Samadi et al., 2019). Slowing the progres- sion of plaques and tangles would elicit cessation, or at least slowing, of the development of the illness and is something that nutrition can feasibly do. In addition to these precursors, obesity is a main risk fac- tor for AD (Szczechowiak et al., 2019). This is widely un- known, for it is not typically mentioned among the com- monly known health risks associated with obesity such as diabetes, hypertension, and atherosclerosis. Given the ris- ing rate of obesity today, the associated risk of Alzheimer’s with obesity should be made known to the public. The cur- rent lack of awareness stems directly from the common disassociation made by consumers between what they eat and their health beyond body weight. Food is meant to nourish and fuel the body, but when food choices are made ignorantly, they may lead to unexpected risks. 7$" .,%'*62"+,% $<