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Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft



Eric Killian

Ron Orrungroj

Mayoor Savla

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

1) Introduction

2) The Battle in the Courts

3) Fair Use?

4) Question of Jurisdiction

5) Is the DMCA a Fair Law?

6) Ethical Dilemmas

7) Social Issues

8) Conclusion

9) References

The E-book

• Allows users to download the text of a book onto a

computer via the Internet.



Advantages: Disadvantages:

• Cheaper to publish and • Large number of format

distribute. incompatibility issues

• Instant worldwide distribution • Can be duplicated easily,

over the Internet hard to prevent.

• Many books now available in

a smaller volume

• Added function features

Adobe’s Ebook

• Has digital rights management (DRM)



• Less restrictive than most other readers in the

market with permissions

June 22, 2001: Advanced eBook

Processor (AEPBR) Released

• Elcomsoft announces its new software

which removes password encryptions and

usage restrictions from eBooks.

• The software was reverse engineered by

employee Dmitry Sklyarov



• Available for download from a web-server Dmitry Sklyarov

located in Chicago, Illinois



• Sold at RegNow website located in

Issaquah, Washington.

Advanced eBook Processor (AEBPR)



Windows program that allows you to remove both

password encryption and usage restrictions from Adobe

Acrobat PDF files and eBooks.



• lost and destroyed passwords

• unable to edit and print password-protected PDF files

• backup copies of eBooks that are protected with various

protection schemes enabling them to be readable with any

PDF viewer (such as on another OS)

• Loadable onto small, portable devices.

 Airplanes

 Hotels

… The Plot Thickens

• About a week after the initial announcement, Adobe updated its eBook

software to prevent the Advanced eBook Processor from working, but

ElcomSoft updated its own software on the same day to be functional with

the Adobe software once again.



• One week later, Adobe requests that ElcomSoft stop selling the Advanced

eBook Processor with a threat of legal action citing the Digital Millennium

Copyright Act (DMCA).



• Elcomsoft complies with the request and its website is disabled and its US

distributor stopped the sale of the AEBPR based on a similar request from

Adobe.



• Elcomsoft claims that PDF is an "absolutely insecure" format for eBooks,

at least in cases where the protection of the content is a primary concern.

However, it continues to distribute a free demonstration version.

July 16, 2001: Dmitry is arrested

After speaking at the DEF CON

9 convention about eBook

security, Dmitry was arrested by

FBI officials as he was preparing

to leave his hotel.



Charged With:

 Trafficking in and offering to the public, a software program

that could circumvent technological protections on copyrighted

material, under section 1201(b)(1)(A) of the U.S. Copyright

Act.



 Aiding and abetting his employer, ElcomSoft Co. Ltd.

Episode IV: A New Hope

July 23, 2001

• After much public outcry over

the arrest and detainment, Adobe

meets with the Electronic

Frontier Foundation (EFF) and

reverses its position by

requesting Sklyarov's release.



August 6, 2001

• After being in jail for about three weeks,

Sklyarov is released on bail of $50,000 and

relinquishes his passport.

Episode V: DMCA Strikes Back

August 28th, 2001

• Sklyarov and ElcomSoft

were indicted by a U.S.

Grand Jury on five counts

of violating the DMCA.

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

 Introduction

The Battle in the Courts

The Charges (1)

Dmitry Sklyarov and

ElcomSoft face:



• Four counts of

circumvention offenses,

and aiding and abetting

circumvention offenses,

under section 1201 of the

DMCA, and



• One charge of conspiracy.

The Charges (2)

• Dmitry Sklyarov and ElcomSoft are NOT accused of

infringing any copyrights. ElcomSoft claims that its

AEBPR software cannot be used by anyone except for

people who have already lawfully purchased the right to

view the e-Books from e-Book retailers.



• Dmitry and ElcomSoft were charged with distributing

software that can read encrypted Adobe e-books in a

manner not intended by the publishers.



• Charges are filed by the U.S. government, consequently

this is a criminal prosecution. The government must prove

that Dmitry and ElcomSoft acted willfully and for the

purposes of commercial advantage or private financial

gain.

The DMCA

Digital Millennium Copyright Act – 1998



• Prevents circumventing “measures that prevent unauthorized

access to a copyrighted work” but does not forbid

circumventing “measures that prevent unauthorized copying of

a copyrighted work”.

• Does not address copyright violation, but rather the distribution

of tools and software or information that can be used for

copyright infringement as well as for legitimate non-infringing

uses, such as fair use.

• Section 1201 divides technological measures into two

categories:

– Measures that prevent unauthorized access to a copyrighted work

– Measures that prevent unauthorized copying of a copyrighted work



The law prevents circumventing the first category of technological measure

but not the second.

Are Dmitry and Elcomsoft Guilty?

AEBPR software-

Pros:

• Printing eBooks protected with passwords

• reading them on other operating systems

• text to speech translation software

Cons:

• make illegal copies of the copyright protected

eBook and distribute them.



The intent of the software was only for legal copies of

Ebooks, so should ElcomSoft be penalized for

distribution of a tool that can be used for both

legitimate and infringing purposes?

Should an individual be charged

when working for a company?



• Can an employer and an employee conspire

for financial gains?



• Electronic Frontier Foundation (EFF)

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

 Introduction

 The Battle in the Courts

Fair Use?

Fair Use

• Allows people to make copies of a work for

personal use, education, criticism, socially

beneficial use.



• Fair use provides the breathing space to avoid an

irreconcilable conflict between copyright law and

the first amendment’s guarantee of free speech.

Does the AEBPR follow the

“Fair Use” doctrine?

• ElcomSoft’s AEBPR software allows users who

have bought an eBook more fair rights uses.



• However, ElcomSoft made commercial gains of

their AEBPR software.



• Though the AEBPR could be misused, it was

intended for fair use.

Does Adobe’s E-book restrict

“Fair Use”?

• Adobe and the publishers used DRM

schemes to protect their intellectual

property, but in doing so restricted fair

use of the e-book.



• Though copyright law may allow for “fair

use”, media companies and publishers

may use code in order to protect their

content. And, presently there are no laws

governing code that prevents “fair use”.

Fair Use cont.

• Was ElcomSoft justified in creating the AEBPR

software in order to provide “fair use”?



• Currently unable to adequately and accurately

differentiate between copies made in good faith

and in accordance with the fair use doctrine vs.

file replication conducted to make money.

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

 Introduction

 The Battle in the Courts

 Fair Use?

Question of Jurisdiction

Both Sides of Jurisdiction

• No other country has copyright laws as restrictive as the DMCA.

• International copyright law has always taken into account the

individual’s rights to make use of materials purchased in a fair and

reasonable way.

• In Russia it is illegal to design a scheme that prevents private citizens

from making copies of media for their own use.

• So, Legally, what Elcomsoft did was not wrong in Russia, but was

being illegally distributed here.

• According to the indictment, Sklyarov and ElcomSoft are on trial for

importing their product into the U.S. and selling it in the U.S. for

commercial gain.

Questions of Jurisdiction

• Where does the extent of U.S. law begin, and Russian law end with

regards to software available on the Internet?

• Can the U.S. have jurisdiction?

• Do the Russians need to oblige by U.S. law?

• Would the U.S. Government be able to charge ElcomSoft under the

DMCA, if their servers were located in England and their payments

were processed through German based credit card companies?

• How would regulation change under such a scenario?



• i.e. Lessig’s Gambling Server Example.

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

 Introduction

 The Battle in the Courts

 Fair Use?

 Question of Jurisdiction

Is the DMCA a Fair Law?

DMCA - A Fair Law? (1)

• Case – Judicial test of the DMCA. Movie studios

and record labels are leaning on DMCA to protect

their copyrights.



• Code (encryption) restricts various uses of digital

works and DMCA enforces those restrictions.



• Copyright Law designed to grant limited control

to authors – DMCA provisions override this

principle – and erode public’s right to freedom.

DMCA - A Fair Law? (2)

• DMCA has not addressed the issue of “fair use” in a digital

environment

– Cannot distinguish between copies made in good faith vs.file

replication conducted to make money.

• Examples:

– Regular Books vs. e-books

– Guns vs. AEBPR

• An Internet generation has transpired since the passing of

the DMCA –

– Need to address copyright issues in cyberspace balancing between

the need to protect intellectual property vs. protecting academic

inquiry.

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

 Introduction

 The Battle in the Courts

 Fair Use?

 Question of Jurisdiction

 Is the DMCA a Fair Law?

Ethical Dilemmas

Ethical Issues | Elcomsoft

• Failed to notify Adobe about their efforts to exploit the security flaw in

Adobe’s PDF reader software.

- Did Elcomsoft have an Ethical obligation to inform Adobe?



• meant to provide “fair use” of the digital content in the eBook reader

but their software would hurt the commercial interests of Adobe.

- Was ElcomSoft in the wrong for exploiting Adobe’s software, or was

Adobe unethical in limiting its users “fair use” rights with their reader?

Ethical Issues | Elcomsoft

• Should ElcomSoft have released the software as shareware and

allowed everyone to use it?

• Does ElcomSoft ethically deserves financial compensation for this

product?

• Is ElcomSoft wrong because this product could potentially be misused

by someone who is corrupt?

• Was ElcomSoft wrong for creating the software, or for merely

distributing it in an area where the law does not allow the software

because of its DMCA violating nature?

• Did Dmitry have an ethical obligation to the Programmers Code of

Ethics to not exploit the flaws in a product?

Ethical Issues | Adobe

• Just because Adobe is shielded under the watchful arms of

the DMCA, does that give the right to control how it's

users can view their books?



• Should software companies be allowed to govern fair use,

or should that control lie in the government?



• Security Technology: Is Adobe wrong in telling its

customers that e-Books provide them sufficient security or

did ElcomSoft manage to break a strong security

protection?

Ethical conclusion

Should people have the right to freely view and move around

their eBooks, or should that power lie hands of the Publisher?



Yes to people?

Adobe should be allowing them to do this and therefore,

Adobe would be acting unethically by limiting the eBook

purchasers rights and not allowing them the choice of

having strong password protection and encryption.



Yes to publisher?

ElcomSoft should not be selling this product without

Adobe’s knowledge since it exploits their software, and the

eBook viewers would be breaking certain understood

responsibilities they have to Adobe in the use of their

software.

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

 Introduction

 The Battle in the Courts

 Fair Use?

 Question of Jurisdiction

 Is the DMCA a Fair Law?

 Ethical Dilemmas

Social Issues

Effects on Research Community (1)

• The U.S. has been a major hub for research.

Researchers and scientists at universities and

commercial institutes have always been able to

pursue new ideas since they have the freedom of

speech.



• Dmitry’s arrest in Las Vegas, has made scientists

and researchers question their ability to be able to

freely present their knowledge. The research

community is skeptical of traveling to the U.S. to

present their findings.

Effects on Research Community (2)

• The rise of the Internet has allowed for instant

dissemination which the publishers and authors would like

to exploit.

– Need to protect intellectual property in order for them to have any

incentive to promote various arts and sciences.



• Research in security and encryption technologies, depend

upon the right to crack and report.



• Software providers are similar to providers of anti-virus

software and firewalls – not a solution but a process of

constantly updating to stay ahead of the hackers.

Case Study:

Adobe (& U.S. Govt.) vs. ElcomSoft

 Introduction

 The Battle in the Courts

 Fair Use?

 Question of Jurisdiction

 Is the DMCA a Fair Law?

 Ethical Dilemmas

 Social Issues

Conclusion

Status of the Case

• May 8th, 2002 - ElcomSoft’s request to dismiss the

criminal charges for violations of the DMCA was

denied.

– DMCA does not eliminate fair use or impair fair use rights of

anyone. Users may find it more difficult to engage in certain fair

uses with regard to e-books, but nevertheless, fair use is still

available.

– Despite acknowledging a lack of clarity in the congressional record

surrounding the adoption of the DMCA, the judge ruled that due

process was not violated. Plain meaning of the DMCA statute was

to ban circumvention tools completely because Congress had

assumed that "most uses" of the tools would be for unlawful

infringement rather than fair or non-infringing uses.

What Next?

• DMCA of 1998 needs is undergoing the judicial

process in the courts of law.

– Needs to re-address circumvention tools that can be used

for unlawful infringement as well as non-infringing purposes.

– Needs to strike a better balance





• Internet has brought the world a lot closer than we

were.

– Copyright laws are going to have to take into account ethical

and legal differences amongst nations in order to protect

intellectual property. International treaties and agreements

will play a much more significant role in controlling illegal use

of technology.

References

[1] Planet eBook: Index of ElcomSoft, Dmitry Sklyarov, Adobe, U.S.

Government and DMCA-related articles from around the Web

http://www.planetebook.com/mainpage.asp?webpageid=170

[2] EFF "Intellectual Property: Digital Millennium Copyright Act

(DMCA): U.S. v. Sklyarov" Archive

http://www.eff.org/IP/DMCA/US_v_ElcomSoft/

[3] Free Dmitry Sklyarov (this contains info about him, and his statements

to the courts) http://www.freesklyarov.org/

[4] Other useful links http://ezhe.ru/ElcomSoft/

[5] Commentary: Stealing is Stealing, No Matter How Noble the Cause,

by Gene Gable http://www.seyboldreports.com/ebooks/010816-

gene.html

[6] Adobe FAQ: ElcomSoft Legal Background

http://www.adobe.com/aboutadobe/pressroom/pressreleases/200108/El

comSoftqa.html

References Con’t

[7] The Digital Millennium Copyright Act of 1998, U.S. Copyright Office

Summary, Dec 1998.

[8] ElcomSoft Executive Responds to Federal Charges Against Dmitry

Sklyarov

http://ElcomSoft.com/statement0829.html

[9] Analysis of Sklyarov’s Indictment by Anton Chterenlikht

http://uk.eurorights.org/issues/sklyarov/innocent.shtml

[10] ElcomSoft supporters miss the point by Mike Letts

http://www.seyboldreports.com/ebooks/features/010724-

ElcomSoft.html

[11] The DMCA, Technological Enforcement and Dmitry Sklyarov by

Dave Amis, August 12, 2001

http://www.netfreedom.org/news.asp?item=166

[12] Code and Other Laws of Cyberspace by Lawrence Lessig


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