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					Sarah Resnick

Access to Moving Image Collections

Instructor Sarah Ziebell-Mann

15 December, 2006

The Post 9/11 Landscape and its Affect on Libraries and Archives: An Examination

                                    of the USA PATRIOT Act

I.     Libraries, the ALA, and National Security Strategies During Times of War:

       A Brief History

       There is an historical precedence for security related strategies affecting access to

information during times of war. Throughout the twentieth century, authorities called

upon libraries and librarians to act in the interests of national security in ways that

undermined the librarian‟s role as guardian of intellectual freedom (Starr). During both

World Wars and the Cold War period, libraries and librarians were called upon both to

suppress information in their collections, and to assist in the surveillance and information

collection of their patrons.

       World War I brought increasingly restrictive information controls in addition to a

near-complete stifling of dissent. Guidelines for text suppression focused on those

potentially beneficial to the enemy. Censored texts ranged from materials on explosives

(Starr) to those whose explicit portrayals of war might affect soldier morale (Lipscomb

335). Fearful of confrontations with state councils of defense and citizens groups
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threatening funding and employment loss, librarians offered little resistance to

government restrictions. Furthermore, having been founded in 1876, the American

Association of Libraries (ALA) was a relatively new professional organization, and

librarians were eager to define a culturally significant purpose for librarianship (Starr).

        Librarians also took initiative beyond official government requests, complying

with the spirit of the war effort in addition to its legal requirements. For instance, some

library boards endorsed the removal or segregation of German-language books, and more

than one librarian actually burned German texts (Starr). Prominent librarians assisted in

compiling the Army Index of books allowed at camp libraries (Lipscomb 335), and some

librarians eagerly adopted these lists as deselection guidelines for public libraries (Starr).

        As World War II broke out in 1939, the ALA adopted the first Library‟s Bill of

Rights. The Bill stated that libraries should select reading matter for its community value

and interest, and not for the identities or views of the writers, and provide a balance of

perspectives and opinions to the community. The passage of the bill began the process of

establishing the defense of intellectual freedom as a primary tenet of librarianship

(Lipscomb 336). The effect of the Bill however, was not immediate. By 1939, Librarian

of Congress Archibald MacLeish decided that in addition to being a professional

opportunity to promote librarianship‟s importance to society, it was also the library‟s

civic duty to support the government‟s war efforts: librarians must accept a responsibility

for the survival of democracy (Starr). ALA Executive Director Carl Milam took a similar

approach, issuing a “declaration calling for every library to become a war information

centre” (Starr).
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       Into this context arrived the 1942 Code of Wartime Practices, a government order

outlining military barred materials such as troop movements, identity and sailing

schedules of ships, industrial production, weather, movements of the president, and

wartime rumor. Librarians were not only instructed to remove all information related to

munitions and cryptology, but to report to the Federal Bureau of Investigation all those

requesting materials of that nature. The Secretary of State disseminated the order through

the ALA, and compliance was common (Starr). Additionally, the Office of Facts and

Figures, a propaganda agency headed by MacLeish, asked individual libraries to collect

intelligence on public perceptions of the war, a task that many librarians were eager to

perform (Starr).

       In the early stages of the Cold War and McCarthyism, what began as a Soviet

book purge spread to all materials viewed as anti-American, and librarians, forced to

respond to pressure from powerful citizen groups, considered book removal, reshelving

and labeling (Starr). In 1948, the ALA adopted a strengthened Library Bill of Rights

asserting that libraries challenge the censorship of books in order to best provide public

information and education. Five years later, President Dwight D. Eisenhower, giving the

commencement address at Dartmouth College, urged his listeners “not to join the book

burners” and not to fear going to the library and reading every book (Starr).

       Government intrusion on library policy quieted until a 1983 incident in which two

FBI agents entered a Columbia University library asking about suspicious patrons with

eastern European accents. The agents asked not only what books the patrons checked out

but also inquired about database search histories and reference questions (“The USA

PATRIOT Act”). The story broke in the media revealing the FBI‟s Library Awareness
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Program to the public. The program aimed at identifying Soviet spies in research

libraries in the 1970s and 1980s, and tried to control access to “sensitive but unclassified”

information such as National Technical Information Service (NTIS) reports.

       The ALA‟s Freedom of Information Council‟s (IFC) Newsletter on Intellectual

Freedom asked librarians around the country to report related incidents, and compiled

them into a summary which described the various FBI inquiries. Some of the activities

they considered suspicious included “swapping documents with other library patrons,

speaking a foreign language, or requesting texts on „underground tunneling, military

installations, or technological breakthroughs” (Starr). The IFC committee also advised

librarians to protect users‟ privacy and the First Amendment right to receive information,

citing the ALA‟s 1970 policy statement on the „Confidentiality of Library Records,‟ and

the ALA‟s 1981 „Statement on Professional Ethics‟ (Starr). The ALA‟s denunciation of

the FBI and the Library Awareness Program asserted the pursuit of intellectual freedom

as a critical aspect of librarianship, a pursuit worthy of defending in the years to come,

including the most recent assault brought about by the introduction of the USA


II.    The USA PATRIOT Act and the Provisions That Affect Libraries and


       The `Uniting and Strengthening America by Providing Appropriate Tools

Required to Intercept and Obstruct Terrorism Act, or USA Patriot Act, of 2001 was

enacted in the wake of the September 11th, 2001 terrorist attacks on New York City. The

Act was designed “to deter and punish terrorist attacks in the United States and around
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the world [and] to enhance law enforcement investigatory tools […]” (The USA

PATRIOT Act). The Act contains more than 150 sections and amends over 15 federal

statutes, including laws governing criminal procedure, computer fraud, foreign

intelligence, wiretapping, and immigration. Although the Act underwent amendments in

March of 2006, the following discussion will address the PATRIOT Act in its initial


        While the 2001 Act has no provisions that mention the library or archive as such,

many of its amendments, including sections 215, 206, 214 and 215 – all modifications of

the Foreign Intelligence Surveillance Act (FISA) – as well as sections 505 and subsection

358(g) – which revise conditions pertaining to the use of a National Security Letter –

compromise the practice and promotion of intellectual freedom in the library and archive.

        Section 215 grants the Federal Bureau of Investigation and other law enforcement

agencies the unprecedented authority to obtain search warrants for business, medical,

educational, library and bookstore records without first establishing probable cause.

Authorities need only claim that the desired records may be related to an ongoing

terrorism investigation or intelligence activities to obtain a warrant (“The Impact of the

USA PATRIOT Act”). Under this section, authorities can potentially subpoena

circulation or other library patron records, and review the reading and research habits of

unassuming Americans. Moreover, section 215 includes a “gag order,” forbidding any

person or institution to whom an order is directed from disclosing the existence of that

order. FISA’s secret court proceedings further compound the implications of the section,

eliminating public debate and oversight from the proceedings in addition to due process.
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          Other PATRIOT ACT amendments apply to electronic communications, placing

public library terminals at risk for government surveillance. Sections 206 for instance,

permit the use of “roving wiretaps” to monitor electronic communications. Previously, a

wiretap order targeted to a person was confined to a particular computer or telephone.

The new law allows the court to order a wiretap valid anywhere in the United States; the

tap may “rove” wherever the target does, and this may potentially include library

computers (“The USA PATRIOT Act and Patron Privacy”). Sections 214 and 216

extend the authority to monitor telephones in a criminal investigation to include routing

and addressing information for Internet traffic (“The Impact of the USA PATRIOT

Act.”). Whereas incoming and outgoing phone numbers have long been available, now

the same low standard permits email headers and URLs as well (“The USA PATRIOT


          Section 505 expands the circumstances for use of a National Security Letter

(NSL). Five statutory provisions vest the FBI with the authority to issue written

commands, or NSLs, which are comparable to administrative subpoenas. Created in the

1970s, these letters seek customer and consumer transaction information in national

security investigations from communications providers, financial institutions, and credit

agencies, and may issued without a court order. Initially, FBI use of an NSL required

that the desired records pertain to a foreign power or the agent of a foreign power (Doyle,

21 March 2006). The PATRIOT Act eliminated this requirement; instead, requests for

NSLs must be “relevant to an investigation to protect against international terrorism or

foreign spying” (Doyle 3). Additionally, subsection 358(g) broadens use of the NSL
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beyond the FBI to include any government agency investigation or analyzing

international terrorism1 (Doyle 3).

       Since many libraries use online service to track patron borrowing and the

circulation and cataloging of library materials, as well as to provide Internet access to

library patrons, the vast majority of libraries around the country may be considered

“electronic communication service providers” under the NSL statutes (“Suit

Challenges”). Libraries that rely on online service maintain sensitive information about

library patrons, and authorities could potentially trace a patron‟s Internet reading habits,

search histories, and online purchases, in addition to the subject headings, senders, and

recipients of a patron‟s email messages (Gellman). Moreover, similar to section 215,

recipients of an NSL are barred from disclosing the letter or its contents.

III.   The USA PATRIOT Act: Infringing the Rights of Library Users

       Many librarians and archivists feel this new use of library records is antithetical to

their mission. These laws implicate librarians and archivists in an attack on values they

hold dear: unfettered access to information, promotion of intellectual freedom and the

right to free expression. Underlying these tenets is the right to privacy, often understood

as essential to the exercise of free speech, free thought, and free association. The

PATRIOT Act laws violate privacy rights of individuals by requiring that libraries issue

  The expanded use of National Security Letters coincides with an unannounced decision
to deposit information collected by them into government data banks, and to share those
private records in the federal government and beyond. In 2003, President Bush reversed
a long-standing policy requiring agents to destroy their files on innocent American
citizens, companies and residents when investigations closed. In 2005, Bush signed an
Executive Order expanding access to those files for “state, local and tribal” governments
and for “appropriate private sector entities,” which are not defined (Gellman).
                                                                                  Resnick 8

patron information without the traditional constitutional safeguards, namely, a judge

finding probable cause to believe that the individual has committed a crime or intends to

do so (Strossen). As the ALA points out in its statement on privacy, “Once individuals

recognize or fear that their privacy or confidentiality is compromised, true freedom of

inquiry no longer exists” (“Privacy”). Individuals realizing they are potentially under

observation are less likely to seek out information flagged as seditious or subversive,

even for use in legitimate circumstances.

       In January 2003, the ALA Council adopted its “Resolution on the USA Patriot

Act and Related Measures That Infringe on the Rights of Library Users.” Its official

statement of position asserts that although the Association affirms the responsibility of

the U.S. government to “protect and preserve the freedoms at the foundation of

democracy,” the Association opposes “any use of government power to suppress the free

and open exchange of knowledge and information or to intimidate individuals exercising

free inquiry.”

       The statement further urges librarians and administrators to undertake the

following: educate users, staff and communities about the process for compliance with

the USA Patriot Act; defend and support user privacy and free access to information;

publicize information about library surveillance; and, implement patron privacy and

record retention policies that collect personally identifiable information only when

necessary to fulfill the mission of the library. The ALA forwarded the adopted

resolution to the President of the United States, the Attorney General, the Members of

both Houses of Congress, the library community, and others as deemed appropriate

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       Librarians across the U.S. have since adopted a number of strategies to protect

patron privacy in the library, among them shredding Internet sign-in logs, discarding

circulation records for books already returned, and blanket-deleting Internet caches,

which hold a record of all web sites visited by a given computer. A number of libraries

posted warnings similar to the following sign distributed by the ACLU of Florida:

“Attention. Under Section 215 of the federal USA Patriot Act records of the books and

other materials you borrow from this library may be obtained by federal agents” (Bell).

Others – without stating whether or not tracking software was in place – posted warnings

near public computer terminals informing users that the library cannot guarantee that

others aren‟t secretly viewing information the patron visits on the Internet (Meagher and

Seidman 5). And, in a clever attempt to circumvent the Act‟s provisions of secrecy, some

libraries have adopted a policy of hanging notices in library entry ways stating “The FBI

has not visited here today,” with the understanding that these signs would be removed

upon an FBI visit (Price).

       While the library community and the ALA have openly expressed their opposition

to the PATRIOT Act amendments and have actively developed recommendations that

address the Act‟s application to libraries, little has been written or undertaken by the

archival community; notwithstanding, many of the library community‟s discussions are

applicable to archives as well (Trinkaus-Randall 9). There are however, some areas

where library guidelines do not cover all of the concerns associated with archives, namely

with regards to record maintenance. As Peter B. Hirtle points out in “The USA

PATRIOT Act and Archivists,”
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       “the archival code of ethics teaches us that we should be respectful of patron

       privacy, but our commitment has always been less than that of our library

       colleagues. No archivist feels that individuals should be able to consult and

       archive anonymously[…] Furthermore, archivists seldom discard records of

       archival use, preferring to preserve them in case of theft” (Hirtle).

This distinctive approach to privacy and confidentiality may explain the initial hesitancy

of the archival community to join the ALA in speaking out against the Act.

       In October 2003, the Manuscript Repositories Section (MRS) of the Society of

American Archivists (SAA) issued a request to the SAA Executive Council members to

concur with the resolutions adopted by the ALA Council in January of 2002, and January

of 2003. The document also outlines concerns specific to archive and manuscript

repositories, noting that for security reasons, many archival institutions must keep patron

records indefinitely in case of theft or damage to manuscript materials. These include

patron registration forms, sign-in records acknowledging the archive‟s rules and

regulations, and call slips that record materials requested by researchers (Trinkaus-

Randall 10).

       Whereas libraries advocate short retention periods for patron records, many

archivists believe the security concerns outweigh the potential breach of confidentiality.

Donor records and correspondence are another area of concern with which libraries are

not forced to contend. The MRS document recommends that archivists alert potential

researchers and donors that their records and correspondence may be subject to disclosure

under the PATRIOT Act (Manuscript Repositories Section).
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       In January of 2004, with the 2005 PATRIOT Act renewal on the horizon, the

SAA issued its official Statement on the Renewal of the USA PATRIOT ACT. The

statement acknowledges the SAA‟s support of the ALA and other groups from archives

and records management communities in expressing concern over the extent to which the

PATRIOT Act impinges on the privacy rights of American citizens. Specifically, the

statement addresses both section 215 and section 505 as examples to illustrate its

concern. The statement calls on the United States Congress to re-examine the USA

PATRIOT Act and to make the revisions necessary to “enhance the Act‟s effectiveness as

a tool in combating terrorism, and to ensure that none of this comes at the expense of the

civil liberties that Americans cherish.”

IV. Invoking the Patriot Act on Libraries and Archives

       As Charles Doyle notes in “Libraries and the USA PATRIOT Act,” the extent to

which the PATRIOT Act has been used to secure patron information and other library

records is somewhat unclear. Press accounts of library patron investigations often fail to

distinguish simple FBI requests, grand jury subpoenas, criminal search warrants, from

PATRIOT Act directives (5). Furthermore, the secrecy and gag provisions that

accompany this new authority render it near impossible to accurately assess the Act‟s

breadth of use within the library.

       In 2005, an ALA study revealed that there were at least 137 formal requests or

demands for information since the passage of the PATRIOT Act in October 2001. In

addition, the survey found that 66 libraries had received requests for information without
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a legal order (Lichtblau). The $300 000 study surveyed 1, 500 public libraries and 4,000

academic libraries, and used anonymous responses to address legal concerns. However,

the study does not directly answer how or whether any PATRIOT Act amendments have

been used to request library records. The ALA was constrained from asking direct

questions to avoid implicating librarians in a criminal violation of a secrecy order


           In 2002, the House Judiciary Committee asked the Attorney General if and how

many times section 215 had been used against libraries, bookstores, or newspapers

(“Libraries”). The Attorney General‟s office responded with the following statement:

           “If the FBI were authorized to obtain the information [from a library, bookstore,

           or newspaper] the more appropriate tool for requesting electronic communication

           transaction records would be a National Security Letter (NSL). The number of

           times the Government has requested or the Court has approved request under this

           section since passage of the PATRIOT Act, is classified, and will be provided in

           an appropriate channel” (Office of the Attorney General).

           In September of 2003, Democracy Now reported that Attorney General John

Ashcroft had revealed in a confidential memo to FBI Director Robert Mueller that the

“number of times [the provision] has been used to date is zero” (Ashcroft qtd. in

“Ashcroft Declassifies”). According to the American Civil Liberties Union (ACLU)

however, Ashcroft later admitted to using section 215, and in 2005 revealed the section

had been implemented 35 times (The American Civil Liberties Union). Yet, this

statement does not clarify if, and when the section was used to request information from a

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       By comparison, in November 2005 the Washington Post reported that the

government issues more than 30, 000 NSLs a year, a hundredfold increase over historic

norms (Gellman), giving credence to the Attorney General‟s statement noted above. And

unlike with section 215, there is in fact one confirmed case of government use of the NSL

to request information from libraries, despite the gag order. September 1st 2005, The New

York Times first reported in August the ACLU had sued the federal government in United

States District Court in Connecticut after federal agents served an NSL to a Connecticut-

based organization that is a member of the American Library Association. The order

demanded the organization surrender “all subscriber information, billing information and

access logs of any person” who used a specific computer at a library branch (Cowan).

The organization refused the order and instead filed suit. Due to NSL‟s accompanying

gag order, the case was under seal and the plaintiff identities could not be revealed2.

       The ACLU took on Doe vs. Gonzales in order to challenge the constitutionality of

the NSL and its secrecy ban as a violation of the First Amendment. On behalf of the

Library group, the ACLU argued that because of the ban, the Library group would be

unable to speak out as an interested party against the Act in the discussions leading up to

its pending renewal, set for reauthorization 31 December 2006. Given the circumstances,

the ACLU also argued that time was especially of the essence. United States District

Judge Janet C. Hall agreed with the Library group‟s plea, and ruled in 2005 that the order

of silence should be lifted. But, the federal government appealed the decision, ultimately

  The November 2005 Washington Post article however, revealed the name of one NSL
recipient as George Christian of Windsor, an employee of Library Connection, Inc. The
Post established the plaintiff identities by comparing unsealed portions of the file with
public records and information from parties with no knowledge of the FBI demand
                                                                                Resnick 14

prevented the group from weighing in on how the PATRIOT Act should be rewritten


       The Library group‟s forced silence continued until March 2006, when Congress

amended the PATRIOT Act by providing a mechanism for court review of NSLs and

their accompanying gag order. The government announced shortly afterward that it no

longer opposed the injunction in the Connecticut case, and thereby dropped its insistence

of the gag order. In light of this concession, the United States Second Circuit Court of

Appeals in Manhattan dismissed the government‟s appeal of the Connecticut injunction

as moot (“Section 215”), and allowed a lower court judge‟s revocation of the

nondisclosure order to stand (Cowan). The secrecy ban was finally lifted in April 2006,

and the four librarians involved in the case have since identified themselves publicly.

V. Where Does the Act Stand Now?

       In early March 2006 – despite passionate opposition by publishers, booksellers,

librarians and other civil rights supporters – Congress renewed the most controversial

provisions of the USA PATRIOT ACT. As Neema Trivedi points out in her commentary

“‟Patriot‟ Act Reforms Are Defeated,” compromise legislation that moved towards

restoring free expression and privacy rights written late in 2005, was squashed after four

Senate Republicans experienced a change of heart. The Act was renewed with some

alterations, although Trivedi argues that the renewal includes ostensible reforms may not

effect much change once put into practice.
                                                                                 Resnick 15

       For instance, the compromise bill sought to clarify that recipients of section 215

gag orders could challenge them in the FISA court. As passed however, the law requires

that recipients wait one year before bringing such a court challenge. The Electronic

Frontier Foundation points out that this is actually a step backwards, since the lawsuit

brought by the ACLU already demonstrated that these gag orders could be successfully

challenged in court. Now, however, recipients of a request for information under section

215 must wait an entire year before challenging the secrecy provision (EEF qtd. in

“‟Patriot‟ Act Reforms Are Defeated”).

       The PATRIOT Act renewal also makes explicit that both section 215 orders and

NSLs can be challenged in court. A new section of the criminal code provides challenges

to both NSL production demands and gag orders in federal district courts. But, as Trivedi

suggests, if the gag order challenge is filed within one year, the government must only

certify that “disclosure might „endanger the national security…or interfere with

diplomatic relations‟ and the court must treat that assertion as conclusive” (“‟Patriot‟ Act

Reforms Are Defeated”). Trivedi then points out that essentially the same rule applies

even if the challenge is brought after the passage of one year.

       Lastly, an NSL amendment provides that a library is not considered “a wire or

electronic communication service provider” for purposes of the NSL law, unless it is

providing an “electronic communication service.” According to Trivedi, this clarification

merely suggests that Congress prefers the FBI to use section 215 rather than the NSL if it

wants to obtain library patron information (“‟Patriot‟ Act Reforms Are Defeated”).
                                                                             Resnick 16

       Despite the renewals of key provisions in the USA PATRIOT Act, efforts to limit

the government‟s search and surveillance powers continue. Libraries and Archives across

the United States continues to be part of this struggle…

                                       Works Cited

The American Civil Liberties Union. “Citing Improvements to Law, ACLU Withdraws
    Section 215 Case But Vows to Fight Individual Orders.” 27 October 2006.
    Accessed 26 November 2006. <>

The American Library Association. “Privacy: An Interpretation of the Library Bill of
    Rights.” 19 June 2002. Accessed 26 November 2006. <

The American Library Association. “Resolution on the USA Patriot Act and Related
    Measures That Infringe on the Rights of Library Users.” 29 January 2003. Accessed
    26 November 2006. <

“Ashcroft Declassifies Number of Records Sought Under Patriot Act After Calling
    Critics „Hysterical.‟” Democracy Now Online. 18 September 2003. Accessed 9
    December 2006. <>

Bell, Maya. “Florida ACLU Warns Library Users: Records Subject to Patriot Act
     Scrutiny.” Knight Ridder Tribune Business News. 31 July 2003: 1. ProQuest. New
     York University Library. 13 December 2006 <>

Cowan, Alison Leigh. “Four Librarians Finally Break Silence in Records Case.” The
   New York Times. 31 May 2006: B3. Lexis-Nexis. New York University Library. 26
   November 2006. <>

Doyle, Charles. “National Security Letters in Foreign Intelligence Investigations: A
    Glimpse of the Legal Background and Recent Amendments.” CRS Report for
    Congress. 21 March 2006. Accessed 6 December 2006.
                                                                             Resnick 17

Doyle, Charles. “Libraries and the USA PATRIOT Act.” CRS Report for Congress. 26
    February 2003. Accessed 26 November 2006. <

Gellman, Barton. “The FBI‟s Secret Scrutiny.” The Washington Post Online. 6
    November 2005. Accessed 13 December 2006.

Hirtle, Peter B. “The USA PATRIOT Act and Archivists.” Address to Meeting of New
     England Archivists. 15 August 2004. Accessed 12 December 2006.

Kranich, Nancy. “The Impact of the USA PATRIOT Act.” The Free Expression Policy
    Project. 5 May 2003. Accessed 9 December 2006. <

Lichtblau, Eric. “F.B.I., Using Patriot Act, Demands Library‟s Records.” The New York
    Times. 26 August 2005: A11. Lexis-Nexis. New York University Library. 26
    November 2006. <>

Lipscomb, Carolyn E. “Access to Information in War.” Journal of the Medical Library
    Association. 90.3(2002): 335-337. Accessed 22 November 2006 .

Manuscript Repositories Section of the Society of American Archivists. “Patriot Act
   Statement.” Manuscript Repositories Section Newsletter. 9 October 2003. Accessed
   26 November 2006. <>

Meagher, Bill and Peter Seidman. “Patriot Act reactions; Local measures protect privacy
   of library users.” Pacific Sun. 41.38 (2003): 5. ProQuest. New York University
   Library. 13 December 2006 <>

Minow, Mary. “The USA PATRIOT Act.” Library 1 October 2002.
   Accessed 12 December 2006. <

Minow, Mary. “The USA PATRIOT Act and Patron Privacy on Library Internet
   Terminals.” Law Library Resource Exchange. 15 February 2002. Accessed 26
   November 2006. <>

O‟Connor, Anahad. “Librarians Win as U.S. Relents on Secrecy Law.” The New York
   Times. 13 April 2006: B1. New York University Library. 26 November 2006. <>

Office of the Attorney General. “Attachment to a letter from Assistant Attorney General
    Daniel J. Bryant to Chairman F. James Sensenbrenner, Jr.” 26 August 2002. Posted
                                                                               Resnick 18

    17 October 2002. Accessed 12 December 2006.

Price, David. “Prostrate to the Patriot Act: Librarians as FBI Extension Agents.”
     CounterPunch. 5 March 2003. Accessed 13 December 2006.

Starr, Joan. “Libraries and National Security: An Historical Review.” First Monday:
     Peer-Reviewed Journal on the Internet. 9.12(2004). Accessed 20 November 2006.

Strossen, Nadine. “Keynote Address to the Society of American Archivists 68th Annual
     Meeting.” The Society of American Archivists. 5 August 2004. Accessed 13
     December 2006. <>

“Suit Challenges Constitutionality of National Security Letters.” Tech Law Journal. 24
    August 2005. Accessed 11 December 2006. <

Trinkaus-Randall, Gregor. “The USA PATRIOT Act: Archival Implications.” Journal
    of Archival Organization. 3.4 (2005):7-23. Accessed 12 December 2006

Trivedi, Neema. “‟Patriot Act‟ Renewal Stalls in Congress.” The Free Expression Policy
    Project. 10 February 2006. Accessed 9 December 2006. <

Trivedi, Neema. “Section 215 of the USA PATRIOT Act and National Security Letters:
    An Update (October 2005).” The Free Expression Policy Project. March 2006.
    Accessed 9 December 2006. <

[Created for NYU-MIAP
Access to Moving Image Collections, H72.1803 / Assignment 4
Instructor: Sarah Ziebell Mann
Created: 12/15/06
Modified: 3/5/07]

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