[Transcribed from a copy of the original. Typos may be mine or may be in the original. For example, sections IV. and III. are reversed in the original. An independently-prepared copy of this document is online at http://www.techlawjournal.com/courts/loudon/81123op.htm if you wish to determine whether errors are in the original or in the transcription. Please notify jellicle@inch.com of any errors found. M.S.]



IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division

 
MAINSTREAM LOUDOUN, et al.     )

                               )

                Plaintiffs     )

        v.                     ) Case No. CA-97-2049-A

                               ) 

BOARD OF TRUSTEES OF THE       )

LOUDOUN COUNTY LIBRARY, et al. )

                               )

Defendants.                    )
 


                                MEMORANDUM OPINION
 
                                    BACKGROUND

              At issue in this civil action is whether a public library may

         enact a policy prohibiting the access of library patrons to certain

         content-based categories of Internet publications. Plaintiffs are

         a Loudoun County non-profit organization, suing on its own behalf

         and on behalf of its members, and individual Loudoun County

         residents who claim to have had their access to Internet sites

         blocked by the defendant library board's Internet policy. They,

         along with plaintiff-intervenors ("intervenors"), individuals and

         other entities who claim that defendant's Internet policy has

         blocked their websites or other materials they placed on the

         Internet, allege that this Policy infringes their right to free

         speech under the First Amendment.  Defendant, the Board of Trustees

         of the Loudoun County Library, contends that a public library has

         an absolute right to limit what it provides to the public and that

         any restrictions on Internet access do not implicate the First

         Amendment.

              The background of this action is fully summarized in this

         Court's April 7, 1998 Memorandum Opinion and will not be repeated

         in depth here. On October 20, 1997, defendant passed a "Policy on

         Internet Sexual Harassment" ("Policy") stating that the Loudoun

         County public libraries would provide Internet access to its

         patrons subject to the following restrictions: (l) the library

         would not provide e-mail, chat rooms, or pornography; (2) all

         library computers would be equipped with site-blocking software to

         block all sites displaying: (a) child pornography and obscene

         material;1 and (b) material deemed harmful to juveniles; (3) all

         library computers would be installed near and in full view of

         library staff; and (4) patrons would not be permitted to access

         pornography and, if they do so and refuse to stop, the police may

         be called to intervene. See Pls. Ex. 1. It is the second

         restriction in the Policy that lies at the heart of this action.

              To effectuate the second restriction, the library has

         purchased X-Stop, commercial site-blocking software manufactured by

         Log-On Data Corporation.  While the method by which X-Stop chooses

         sites to block has been kept secret by its developers, see Pls. Ex.

         16, Dep. of Michael S. Bradshaw ("Bradshaw Dep.") at 12-13, it is

         undisputed that it has blocked at least some sites that do not

         contain any material that is prohibited by the Policy.2

              If a patron is blocked from accessing a site that she feels

         should not be blocked under the Policy, she may request that

         defendant unblock the site by filing an official, written request

         with the librarian stating her name, the site she wants unblocked,

         and the reason why she wants to access the site. See Intervs. Ex.

         21, Request to Review Blocked Site. The librarian will then review

         the site and manually unblock it if he determines that the site

         should not be blocked under the Policy. There is no time limit in

         which a request must be handled and no procedure for notifying the

         patron of the outcome of a request.  See Pls. Ex. 18, Deposition of

         Cindy Timmerman at 93-94. All unblocking requests to date have

         been approved.  See Def. Ex. 15, Decl. of Douglas Henderson

         ("Henderson Decl.") at ¶ 18.

              Plaintiffs and intervenors both allege that the Policy, as

         written and as implemented, violates their First Amendment rights

         because it impermissibly discriminates against protected speech on

         the basis of content and constitutes an unconstitutional prior

         restraint.  In response, defendant contends: (1) intervenors do not

         have standing; (2) the Policy does not implicate the First

         Amendment and is reasonable; (3) the Policy is the least

         restrictive means to achieve two compelling government interests;

         and (4) the library has statutory immunity from this action.

            In the motions now before the Court, plaintiffs, intervenors,

         and defendant each ask the Court to grant summary judgement in

         their favor.  Intervenors also ask the Court to permit them to

         substitute for three of their parties.3


                                   ANALYSIS

         I. Standing

              Defendant alleges that all of the intervenors lack standing.

         Intervenors include three websites (the Safer Sex Page, Banned

         Books Online, and the Books for Gay and Lesbian Teens/Youth page),

         two non-profit corporations with websites (the American Association

         of University Women and the Renaissance Transgender Association),

         one for-profit corporation with a website (The Ethical Spectacle)

         one newspaper columnist whose articles are published on a website

         (Rob Morse, writer for the San Francisco Examiner), and an artist

         whose work is published on a website (Sergio Arau). See February

         6, 1998 Mot. Intervene as Pls.

              A. Non-Jural Persons

              Defendant argues that the three website intervenors lack

         standing because they are non-jural entities, being neither

         individual persons nor corporations. While intervenors assert that

         these three entities do have standing as alleged in their

         complaint, they have filed a Motion to Substitute Parties to

         resolve this dispute. In each case, they wish to replace the web

         page with the individual who owns and operates it. Specifically.

         intervenors would substitute Christopher Filkins for The Safer Sex

         Page, John Ockerbloom for Banned Books Online, and Jeremy Meyers

         for Books for Gay and Lesbian Teens/Youth. These individuals are

         jural entities with a clear First Amendment interest in

         communicating the speech they have published via these sites.

              Defendant contends that the Motion to Substitute Parties

         should be denied for two reasons.  First, defendant alleges it

         would be prejudiced by adding these individuals as named

         intervenors at this late stage of the proceedings. All three

         individuals, however, were named in the original complaint and

         there has been no problem deposing them or obtaining discovery from

         and about them. Defendant cannot point to any specific actual or

         potential prejudice to its case and we find that there would be

         none. Second, defendant contends that the real party in interest

         in this litigation is the ACLU, which represents the Renaissance

         Transgender Association, and that the dismissal of the website

         intervenors would still leave the Renaissance Transgender

         Association as an adequate nominal party through which the ACLU

         could pursue this action. Defendant has not presented a single

         piece of evidence to substantiate this allegation or to demonstrate

         that these individuals have not asserted a real injury-in-fact that

         could be redressed by this Court. Therefore, intervenors' motion

         to substitute parties will be granted, which moots defendant's

         argument that these three intervenors do not have standing because

         they are non-jural entities.

              B. Websites Never Blocked

              Defendant next alleges that five of the intervenors, John

         Ockerbloom d/b/a Banned Books Online, the American Association of

         University Women, The Ethical Spectacle, Robert Morse, and Sergio

         Arau, have no standing because there is no evidence in the record

         that their websites were ever blocked. To the contrary,

         intervenors have submitted the Declaration of Alpna Cassidy Sehgal,

         a staff attorney for the ACLU. See Intervs. Decl. N ("Sehgal

         Decl.") In the Declaration, Sehgal alleges that she visited the

         Rust Branch at the Loudoun County Public Library on February 2,

         1998 and, as a result of the Policy, was denied access, in whole or

         in part, to the websites of each of the intervenors.  See id. at ¶¶

         2, 9-12, 14-16, 20.

              Defendant first alleges that the Sehgal Declaration should be

         disregarded pursuant to the lawyer-witness rule. Intervenors

         respond that the lawyer-witness rule prohibits an attorney who may

         be called as a witness only from acting as an advocate at trial 

         and not from assisting with trial preparation.  See. e.g., Culebras

         Enterprises Corp. v. Riviera-Rios, 846 F. 2d 94 (1st Cir.

         1988) (finding that lawyers who did substantial pretrial work did

         not violate lawyer-witness rule because they were not "advocates at

         trial"). Intervenors' statement of the law is correct. It is

         undisputed that Sehgal has not and will not act as an advocate in

         this action.  We find no reason to disregard her declaration.

              In the alternative, defendant contends that there is a

         material factual dispute as to whether these five sites were ever

         blocked. Defendant alleges that it attempted to access the sites

         of all eight intervenors on February 6, 1998, using a library

         computer employing the X-Stop software, and that only The Safer Sex

         Page, the Books for Gay and Lesbian Teens/Youth page, and the

         Renaissance Transgender Association page were blocked at that time.

         See Def. Ex. 15, Def. Answer to Intervs. Sec. Interrogs.  Defendant

         asserts that this evidence contradicts Sehgal's declaration and,

         therefore, creates a dispute as to a material fact.  Defendant's

         own witnesses, however, demonstrate the dynamic nature of the

         Internet, see Henderson Decl. at ¶ 14, and X-Stop, their filtering

         software. See Bradshaw Dep. at 49-51.  It is entirely possible

         that these sites were blocked on February 2 but not blocked four

         days later.4 Therefore, we find than the Sehgal declaration is

         unrebutted evidence that the sites, in whole or in part, were

         blocked by defendant on February 2, 1998, and therefore that these

         intervenors will not be denied standing on this basis.

              C. Websites That Were Unblocked

              As noted above, defendant concedes that it blocked three of

         the intervenors sites, The Safer Sex Page, the Books for Gay and

         Lesbian Teens/Youth page, and the Renaissance Transgender

         Association page, as of February 6, 1998 even though these sites

         admittedly did not violate the Policy. See Def. Ex. 18, Def.

         Answer Intervs. Sec. Interrogs.  It is undisputed that by May 1998

         defendant had unblocked these three sites, see id., and there is no

         evidence that any of intervenors' sites have been blocked since

         then.  Defendant asserts that none of the intervenors have standing

         to sue now because their sites are no longer blocked, they do not

         contain "any material that would even be considered a candidate for

         blocking," and "there is no reason to expect that any of these web

         sites will ever be candidates for blocking under the Internet

         Policy." Def. Mem. Support Motion Summ. J. at 6, 8.  Therefore,

         defendant contends, intervenors cannot meet the burden of

         demonstrating that they have an "injury that could be redressed if

         the requested relief is granted." Lujan v. Defenders of Wildlife,

         504 U.S. 555, 561 (1992); see also, Simon v. Eastern Ky. Welfare

         Rights Org., 426 U.S. 26, 45-46 (1976) (stating that a plaintiff

         must demonstrate a "likelihood that the requested relief will

         redress the alleged injury").

              In response, intervenors allege that they have standing to sue

         it there is a legitimate fear that the policy will be enforced

         against them, or if defendant, having blocked intervenors' speech

         on one occasion, is likely to do so again. See ACLU v. Reno, 929

         F. Supp. 824, 851 (E.D. Pa. 1996), aff'd, 117 S. Ct. 2329 (1997)

         (holding that plaintiffs had standing to bring pre-enforcement

         facial challenge against the Communications Decency Act).  One way

         to demonstrate that a defendant is likely to block intervenors'

         speech is to show that it retains unfettered discretion in

         enforcing the Policy.  See 11126 Baltimore Boulevard Inc. v.

         Prince George's County, 58 F.3d 988, 993-94 (4th Cir. 1995)

         (finding a facial challenge to an ordinance restricting speech

         appropriate where a plaintiff alleges the ordinance does not

         contain "specific standards to guide the decisionmaker" or

         "appropriate procedural safeguards to ensure a prompt resolution").

              Intervenors also argue that "'voluntary cessation of allegedly

         illegal conduct does not deprive the tribunal of the power to hear

         and determine the case.'" Commonwealth of Virginia v. Califano,

         631 F.2d 324, 326 (4th Cir. 1980) (quoting United States v. W. T.

         Grant Co. 345 U.S. 629, 632 (1953)). In W. T. Grant, the Supreme

         Court warned that courts must "beware of efforts to defeat

         injunctive relief by protestations of repentance and reform,

         especially when abandonment seems timed to anticipate suit, and

         there is a probability of resumption." Id. at 632 n.5. The Court

         further explained that a voluntary cessation of wrongful activity

         would only moot an action if "the defendant can demonstrate that

         there is no reasonable expectation that the wrong will be

         repeated. Id. at 633. To do otherwise, the Court opined, would

         leave the defendant "free to return to his old ways." Id. at 632.

              Defendant has failed to carry its burden of demonstrating that

         the wrong will not be repeated. Douglas Henderson, defendant's

         Director of Library Services, has acknowledged that the content

         and imagery on websites frequently changes. See Henderson Decl. at

         ¶ 14 (acknowledging "the changing nature of the WorldWideWeb"). In

         addition, the materials from one website also may be transferred to

         another website located at a different address. See Intervs. Decl.

         A, Decl of Sergio Arau ("Arau Decl.") at ¶ 5. Such changes could

         lead X-Stop to block even previously unblocked material.

         Therefore, intervenors are justified in having a reasonable

         expectation that they may be blocked again in the future.

              Furthermore, defendant's concession that none of the

         intervenors' websites contain or likely will ever contain material

         that violates the Policy does not prevent intervenors from having

         standing given defendant's admissions that X-Stop blocks websites

         that do not violate the Policy and that defendant does not even

         know what websites X-Stop blocks or how it selects them. See

         Henderson Decl. at ¶ 18 (stating that defendant is aware that X-Stop

         blocks websites that defendant would not block "if we knew

         about them"), Bradshaw Dep. at 12-13 (stating that Log-On Data

         Corp. has refused to provide defendant with the criteria it uses to

         censor websites); Pls. Ex. 2. Dep. of Douglas Henderson ("Henderson

         Dep."), at 494 (stating that defendant has never seen a list of the

         blocked sites).  On this record, because defendant cannot

         "demonstrate that there is no reasonable expectation that the wrong

         will be repeated," and because a declaratory judgment would provide

         intervenors with relief, we find that the fact they are currently

         unblocked does not prevent intervenors from having standing to

         pursue this action.5

              D. Banned Books Online

              Defendant next claims that one of the intervenors, John

         Ockerbloom d/b/a Banned Books Online, lacks standing because

         defendant has never blocked his website.  Ockerbloom admits chat

         there is no evidence that defendant has ever blocked his website,

         but asserts that he has standing because defendant blocked a link6

         from his website to a website providing the text of E for Ecstasy,

         a book about the history of the drug MOMA. See Sehgal Decl. at ¶

         15. Ockerbloom alleges that part of the mission at his website is

         to provide users with access to censored materials, such as E for

         Ecstacy.  Therefore, blocking access to one of the links is a

         concrete injury to his free speech rights.

              The extent to which free speech protection reaches links on

         the Internet has not been directly addressed by any court. In more

         traditional contexts, individuals are frequently found to have

         standing to challenge restrictions on speech in which they have a

         sufficient interest even where that speech is not originally

         theirs. For example, owners of adult bookstores can challenge

         censorship of books they intend to sell,7 owners of adult movie

         theaters have standing to protest censorship of movies they intend

         to show,8 and library patrons have standing to challenge library

         policies restricting their exercise of the First Amendment right to

         receive information.9 In essence, intervenor Ockerbloom has sought

         to intervene in this action because he claims to have an interest

         in the E for Ecstacy page, material he explicitly and purposely has

         made available for use by others.

              While this argument is initially appealing its consequences

         would be unmanageable. Because of the ease of establishing links

         to any and every site on the Internet, if we find that Ockerbloom

         has standing in this case it would be impossible to prevent anyone

         from asserting standing to protest alleged Internet-related First

         Amendment harms wherever, whenever, and to whomever they occur.

         For example, by virtue of the ACLU having placed links to each of

         the intervenors' web pages on its own Internet site, see Def. Ex.

         18, thereby asserting an interest in the speech of the intervenors,

         it would be able to assert the rights of each intervenor in a

         lawsuit brought only in its own name. Such a result would make a

         mockery of traditional standing principles. Therefore, we find

         that John Ockerbloom d/b/a Banned Books On-Line, does not have

         standing and should be dismissed from this action.

              E. Sergio Arau

              Defendant also asserts that intervenor Sergio Arau does not

         have standing because he does not have any material published on

         the Internet to block. Arau responds that some of his work was

         blocked as of February 2, 1998, see Sehgal Decl. at ¶ 20, and that

         similar artwork and music of his are currently available on the

         Internet, although at a new website. See Arau Decl. at 5; Arau

         Decl. Ex. 7. Defendant has not rebutted this evidence. Therefore,

         we find that Arau's work is currently displayed on the Internet,

         that it is potentially at risk of being blocked again by defendant,

         and that he has standing to pursue this action.

              F. Robert Morse

              Lastly defendant argues that intervenor Robert Morse, a

         columnist for the San Francisco Examiner, does not have standing

         because he gave up any First Amendment right in his columns by

         ceding the intellectual property rights in those columns to his

         newspaper.  Morse counters than there is no legal support for the

         proposition that by relinquishing intellectual property rights in

         his work an individual also surrenders his First Amendment interest

         in that work. Indeed, authors and journalists who have given up

         the copyright to their work can still be sued for defamation

         resulting from that work and can still offer the First Amendment as

         a defense to such lawsuits. See. e.g., Masson v. New Yorker, 501

         U.S. 496, 499 (1991) (noting that "[t]he First Amendment protects

         authors and journalists who write about public figures"). We find

         no legal or logical support for defendant's position and,

         therefore, find that Morse has standing to intervene in this

         action.

         II. Immunity

              Defendant has requested that we reconsider our previous

         finding that it is not immune from this litigation pursuant to a

         provision of the 1996 Communications Decency Act granting absolute

         immunity to good faith users of filtering software. See 47 U.S.C.

         § 230(c)(2)(A). In our previous opinion, we found that § 230

         provides immunity from actions for damages; it does not, however,

         immunize defendant from an action for declaratory and injunctive

         relief. We see no reason to stray from our earlier decision, which

         is the law of this case. If Congress had intended the statute to

         insulate Internet providers from both liability and declaratory and

         injunctive relief, it would have said so.

         IV. Strict Scrutiny Standard

              Defendant has also requested that we reconsider our earlier

         findings (1) than the Policy implicates the First Amendment and (2)

         that the appropriate standard of review is strict scrutiny.

              A. Implicating the First Amendment

              Defendant first contends than the Policy should really be

         construed as a library acquisition decision, to which the First

         Amendment does not apply,10 rather than a decision to remove library

         materials. Plaintiffs and intervenors contend that this issue has

         already been decided by this Court and is the law of the case. See

         Mainstream Loudoun v. Board of Trustees of the Loudoun County

         Library et al., 2 F. Supp. 2d 783, 794-95 (E.D. Va. 1998) ("[T]he

         Library Board's action is more appropriately characterized as a

         removal decision"; "[W]e conclude that [Pico] stands for the

         proposition the First Amendment applies to, and limits, the

         discretion of a public library to place content-based restrictions

         on access to constitutionally protected materials within its

         collection.").

              We addressed the acquisition/removal argument at length in our

         previous decision and defendant has not presented a single new

         argument or authority to support its position. Indeed, defendant's

         own expert, David Burt, undercuts its argument by acknowledging

         that "[f]iltering cannot be rightly compared to 'selection', since

         it involves an active, rather than passive exclusion of certain

         types of content." Def. Ex. 21, Rep. of David Burt ("Burt Rep.")

         at 15. Therefore. we decline to reconsider our earlier ruling on

         this issue.

              B. Forum Analysis

              Next, defendant contends that even if the First Amendment does

         apply, we should apply a less stringent standard than strict

         scrutiny. Specifically defendant argues that because the library

         is a non-public forum, the Policy should be reviewed by an

         intermediate scrutiny standard, examining whether it is reasonably

         related to an important governmental interest. Citing Kreimer v.

         Bureau of Police, 958 F.2d 1242 (3d Cir. 1992), defendant argues

         that public libraries are non-public fora and therefore, content-

         based speech regulations are not subject to the strict scrutiny

         standard. Rather, it asserts such regulations need only be

         "reasonable and viewpoint neutral" to be upheld. Def. Brief in

         Opp. at 34-37 (citing International Soc'y for Krishna

         Consciousness, Inc. v. Lee, 505 U.S. 672, 694 (1992) (Kennedy, J.

         concurring)). Plaintiffs and intervenors respond that defendant

         has misread Kreimer and moreover that the library is a limited

         public forum in which content-based regulations are subject to

         strict scrutiny.

              Defendant concedes that the Policy is a content-based

         regulation of speech and that content-based regulations of speech

         in a limited public forum are subject to strict scrutiny. Def.

         Brief in Opp. at 36-37. The only issue before us, then, is whether

         the library is a limited public forum or a non-public forum. In

         Perry Education Ass'n v. Perry Local Educators' Ass'n, 460 U.S. 37,

         45-46 (1983), the Supreme Court identified three categories of fora

         for the purpose of analyzing the degree of protection afforded to

         speech. The first category is the traditional forum, such as a

         sidewalk or public park. These are "places which by long tradition

         or by government fiat have been devoted to assembly and debate".

         Id. at 45. Second is the limited or designated forum, such as a

         school board meeting or municipal theater. This category consists

         of "public property which the State has opened for use by the

         public as a place for expressive activity". Id. The last category

         is the non-public forum, such as a government office building or a

         teacher's mailbox, which is not "by tradition or designation a

         forum for public communication." Id. at 46. It is undisputed that

         the Loudoun County libraries have not traditionally been open to

         the public for all forms of expressive activity and, therefore, are

         not traditional public fora.

              A limited public forum is created when the government

         voluntarily opens a particular forum to the public for expressive

         activity. See id. at 45. The government can create a limited

         public forum for all, some or only a single kind of expressive

         activity. See, e.g., Kreimer, 958 F.2d at 1259 (finding that the

         government had made the public library a limited public forum for

         the expressive activity of "communication of the written word")

         Even though it is not required to operate such a forum, once the

         government does so it "is bound by the same standards as apply in

         a traditional public forum " Perry, 460 U.S. at 46.  Therefore,

         content-neutral time, place and manner regulations on the

         expressive activity or activities allowed are permissible if

         narrowly tailored to serve a significant government interest while

         leaving open ample alternative channels of communication, see

         Kreimer, 958 F.2d at 1262. Any content-based restriction, however,

         must be "narrowly drawn to effectuate a compelling state interest."

         Perry, 460 U.S. at 46.

              The only court to have examined whether a public library

         constitutes a limited public forum is the Third Circuit in

         Kreimer.11 In determining that the public library constituted a

         limited public forum,12 the court considered three factors:

         government intent; extent of use; and nature of the forum. See id.

         at 1259. We agree that these are the crucial factors in

         determining whether a forum is a limited or a non-public forum.

              1. Government Intent

              The record establishes than the Loudoun County government,

         through defendant library board, intended to create a public forum

         when it authorized its public library system. In a resolution it

         adopted in 1995 and reaffirmed last year, defendant declared that

         its "primary objective . . . [is] that the people have access to

         all avenues of ideas." See Pls. Ex. 5, Loudoun County Library

         Board of Trustees Resolution, Freedom For Ideas - Freedom From

         Censorship, May 15, 1995 ("May 15 Resolution"). Furthermore, the

         same resolution states that the public interest requires "offering

         the widest possible diversity of views and expressions" in many

         different media, not diminishing the library collection simply

         because "minors might have access to materials with controversial

         content," not excluding any materials because of the nature of the

         intormation or views within, and not censoring ideas. Id. We find

         that defendant intended to designate the Loudoun County libraries

         as public fora for the limited purposes of the expressive

         activities they provide, including the receipt and communication of

         information through the Internet.13

              2. Extent of Use

              As to the extent of use the government has allowed, defendant

         has designated the library for the use of "the people" and has

         declared that "[l]ibrary access and use will not be restricted nor

         denied to anyone because of age, race, religion, origin, background

         or views. Id. Defendant has opened the library to the use of the

         Loudoun County public at large and has significantly limited its

         own discretion to restrict access, thus indicating that it has

         created a limited public forum. See Kreimer, 958 F.2d at 1260

         (finding that the extent of use inquiry favored concluding that the

         library was a limited public forum because the library "does not

         retain unfettered discretion governing admission").

              3. Nature of the Forum

              The final consideration is whether the nature of the forum is

         compatible with the expressive activity at issue. While the nature

         of the public library would clearly not be compatible with many

         forms of expressive activity, such as giving speeches or holding

         rallies, we find that it is compatible with the expressive activity

         at issue here, the receipt and communication of information through

         the Internet.  Indeed, this expressive activity is explicitly

         offered by the library.

              All three of these factors indicate that the Loudoun County

         libraries are limited public fora and, therefore, that defendant

         must "permit the public to exercise rights that are consistent with

         the nature of the Library and consistent with the government's

         intent in designating the Library as a public forum." Id. at 1262.

         The receipt and communication of information through the Internet

         is consistent with both.

              Because the Policy at issue limits the receipt and

         communication of information through the Internet based on the

         content of that information, it is subject to a strict scrutiny

         analysis and will only survive if it is "necessary to serve a

         compelling state interest and is narrowly drawn to achieve

         that end." Perry, 460 U.S. at 45 (citing Carey v. Brown, 447 U.S.

         455, 461 (1980)).14

              C. Renton/Time, Place and Manner

              Defendant also argues in the alternative that the strict

         scrutiny standard should not apply because the Policy is more

         appropriately viewed as a time, place, and manner restriction

         pursuant to City of Renton v. Playtime Theatres. Inc., 475 U.S. 41

         (1986), than as a traditional content-based restriction on speech.

         Plaintiffs respond that this analysis is inapplicable to the

         Policy, which is designed to address the primary effects of

         Internet speech and which defendant admits restricts speech based

         on content.

              In Renton, the Supreme Court found that a zoning ordinance

         prohibiting adult movie theaters from locating within 1000 feet of

         residential neighborhoods, churches, and specific other structures

         was a content-neutral time, place, and manner restriction because

         it could be justified without reference to the content of the

         speech in the theaters. The city justified the ordinance as

         necessary to address the secondary effects of adult theaters in

         certain neighborhoods, namely preventing crime, protecting retail

         trade, maintaining property values, and preserving the quality of

         the neighborhoods, districts, and Life. See id. at 48. The Court

         found that none of these secondary effects were related to the

         content of the movies shown at the theaters. Therefore, the Court;

         found the ordinance to be constitutional.  See id. at 54.

              In a subsequent decision clarifying what it meant by

         "secondary effects," the Supreme Court held that "[r]egulations

         that focus on . . . [l]isteners' reactions to speech are not the

         type of 'secondary effects' we referred to in Renton."  Boos v. 

         Barry, 485 U.S. 312, 321 (1988).  More recently in construing the

         Communications Decency Act, the court stated that "content-based

         blanket restrictions on speech . . . cannot be 'properly analyzed

         as a form of time, place, and manner regulation'" Reno v. ACLU, 117

         S. Ct. 2329, 2342 (1997).

              Defendant contends than the Policy is designed to combat two

         secondary effects: creating a sexually hostile environment and

         violating obscenity, child pornography, and harm to juveniles laws.

         Neither of these are secondary effects and neither can be justified

         without reference to the content of the speech at issue. The
 
         defendant's concern that without installing filtering software,

         Internet viewing might lead to a sexually hostile environment is

         solely focused on the reaction of the audience to a certain

         category of speech. As the Supreme Court noted in Boos, this is

         not a secondary effect. The defendant's second concern is the

         possible violation of various criminal statutes that address

         materials deemed to be obscene, involve child pornography, or are

         harmful to juveniles. These criminal statutes define prohibited

         speech only by and because of its content. Far from addressing

         secondary effects of speech, these statutes focus on the very

         speech itself.

              Indeed, the Fourth Circuit has recently observed that content-

         neutrality is a prerequisite to the constitutionality of time,

         place, and manner restrictions on expressive conduct on public

         grounds. See United States v. Johnson, No. 97-5023, 1998 WL

         781215, *3 (4th Cir. Oct. 28, 1998).  Therefore, defendant's

         admission that the Policy discriminates against speech based on

         content indicates that it would not be constitutional even if it

         were a time, place, and manner restriction.

         III. Constitutionality of the Policy

              Defendant contends that even if we conclude that strict

         scrutiny is the appropriate standard of review, the Policy is

         constitutional because it is the least restrictive means to achieve

         two compelling government interests:  "1) minimizing access to

         illegal pornography; and 2) avoidance of creation of a sexually

         hostile environment . . . ." Def. Brief in Opp. at 25. Plaintiffs

         and intervenors respond that there is no evidence that the Policy

         is necessary to further these interests nor that it is the least

         restrictive means available.  Moreover, they argue that the Policy

         imposes an unconstitutional prior restraint on speech.

              A content-based limitation on speech will be upheld only where
 
         the state demonstrates that the limitation "is necessary to serve

         a compelling state interest and that it is narrowly drawn to

         achieve that end." Perry Educ. Ass'n. v. Perry Local Educators' Ass'n,

         460 U.S. 37, 45 (1983) (citing Carey v. Brown, 447 U.S. 455,

         46l (1980)).   This test involves three distinct inquiries: (l)

         whether the interests asserted by the state are compelling; (2)

         whether the limitation is necessary to further those interests; and

         (3) whether the limitation is narrowly drawn to achieve those

         interests.

         A. Whether the Defendant's Interests Are Compelling

              Defendant argues that both of its asserted interests are

         compelling.  Although plaintiffs and intervenors argue that these

         interests were not really the motivating factors behind the Policy

         and that they are not furthered by the Policy, they do not argue

         that the interests themselves are not compelling. For the purposes

         of this analysis, therefore, we assume that minimizing access to

         illegal pornography15 and avoidance of creation of a sexually
 
         hostile environment16 are compelling government interests.

         B. Whether the Policy is Necessary to Further Those Interests

              To satisfy strict scrutiny, defendant must do more than

         demonstrate that it has a compelling interest; it must also

         demonstrate that the Policy is necessary to further that interest.

         In other words, defendant must demonstrate that in the absence of

         the Policy, a sexually hostile environment might exist and/or there

         would be a problem with individuals accessing child pornography or

         obscenity or minors accessing materials that are illegal as to

         them. Defendant "must demonstrate that the recited harms are real,

         nor merely conjectural, and that the regulation will in fact

         alleviate these harms in a direct and material way." Turner Broad.

         Sys., Inc. v. FCC, 512 U.S. 622, 664; see also Johnson.  865 F.

         Supp. at 1439 ("[S]imply alleging the need to avoid sexual

         harassment is not enough[;] . . . the defendant[] must show that

         the threat of disruption is actual, materia1, and substantial.").

         The defendant bears this burden because "[t]he interest in

         encouraging freedom of expression in a democratic society outweighs

         any theoretical but unproven benefit of censorship." Reno v. ACLU,

         117 S. Ct. 2329, 2351 (1997).

              The only evidence to which defendant can point in support of

         its argument that the Policy is necessary consists of a record of

         a single complaint arising from Internet use in another Virginia

         library and reports of isolated incidents in three other libraries

         across the country. In the Bedford County Central Public Library

         in Bedford County, Virginia, a patron complained that she had

         observed a boy viewing what she believed were pornographic pictures

         on the Internet. See Pls. Ex. 15 at 4-7. This incident was the

         only one defendant discovered within Virginia and the only one in

         the 16 months in which the Bedford County public library system had

         offered unfiltered public access to the Internet. After the

         incident, the library merely installed privacy screens on its

         Internet terminals which, according to the librarian, "work great".

         Id. at 4.

              The only other evidence of problems arising from unfiltered

         Internet access is described by David Burt, defendant's expert, who

         was only able to find three libraries that allegedly had

         experienced such problems, one in Los Angeles County,17 another in

         Orange County, Florida,18 and one in Austin, Texas.19 See Burt Rep.

         at 14. There is no evidence in the record establishing that any

         other libraries have encountered problems; rather, Burt's own

         statements indicate that such problems are practically nonexistent.

         See Burt Dep. at 253-55 (acknowledging that an e-mail requesting

         information about sexual harassment complaints relating to Internet

         use that he sent to "several thousand" librarians did not yield a

         single serious response). Significantly, defendant has not pointed

         to a single incident in which a library employee or patron has

         complained that material being accessed on the Internet was

         harassing or created a hostile environment. As a matter of law, we

         find this evidence insufficient to sustain defendant's burden of

         showing that the Policy is reasonably necessary. No reasonable

         trier of fact could conclude that three isolated incidents

         nationally, one very minor isolated incident in Virginia, no

         evidence whatsoever of problems in Loudoun County, and not a single

         employee complaint from anywhere in the country establish that the

         Policy is necessary to prevent sexual harassment or access to

         obscenity or child pornography.

         C. Whether the Policy is Narrowly Tailored to Achieve the Compelling Government Interests

              Even if defendant could demonstrate that the Policy was

         reasonably necessary to further compelling state interests, it

         would still have to show that the Policy is narrowly tailored no

         achieve those interests. The parties disagree about several issues

         relating to whether the Policy is narrowly tailored: (1) whether

         less restrictive means are available; (2) whether the Policy is

         overinclusive; and (3) whether X-Stop, the filtering software used

         by defendant, is the least restrictive filtering software

         available.20 

         1. Whether Less Restrictive Means Are Available

              Defendant alleges than the Policy is constitutional because it

         is the least restrictive means available to achieve its interests.

         The only alternative to filtering, defendant contends, is to have

         librarians directly monitor what patrons view.  Defendant asserts

         this system would be far more intrusive than using filtering

         software. Plaintiffs and intervenors respond that there are many

         less restrictive means available, including designing an acceptable

         use policy, using privacy screens, using filters that can be turned

         off for adult use, changing the location of Internet terminals,

         educating patrons on Internet use, placing time limits on use, and

         enforcing criminal laws when violations occur.

              In Sable Communications of Calif., Inc. v. FCC, 492 U.S. 115,

         126 (1989), the Supreme Court noted that "[t]he Government may . . .

         regulate the content of constitutionally protected speech in

         order to promote a compelling interest if it chooses the least

         restrictive means to further the articulated interest." In Sable

         the Court declared unconstitutional a statute banning all

         "indecent" commercial telephone communications.  The Court found

         that the government could not justify a total ban on communication

         that is harmful to minors, but not obscene by arguing that only a

         total ban could completely prevent children from accessing indecent

         messages. Id. at 128. The Court held that without evidence that

         less restrictive means had "been tested over time," the government

         had not carried its burden of proving that they would not be

         sufficiently effective. Id. at 128-29.

              We find that the Policy is not narrowly tailored because less

         restrictive means are available to further defendant's interests

         and, as in Sable, there is no evidence that defendant has tested

         any of these means over time.  First, the installation of privacy

         screens is a much less restrictive alternative that would further

         defendant's interest in preventing the development of a sexually

         hostile environment. See Pls. Ex. 15 at 4, Letter from Tom Hehman

         to Douglas Henderson (stating that privacy screens "work great").

         Second, there is undisputed evidence in the record that charging

         library staff with casual monitoring of Internet use is neither

         extremely intrusive nor a change from other library policies. See

         e.g., id.  (noting no problems with the library staff being

         responsible for "'shooing' people away from sites we know are

         objectionable, just as we always have with prepubescent boys

         giggling over gynecological pictures in medical books"); see

         generally Pls. Ex. 15 (providing the Internet use policies of other

         Virginia libraries, many of which threaten loss of library

         privileges or prosecution for accessing illegal sites). Third,

         filtering software could be installed on only some Internet

         terminals and minors could be limited to using those terminals

         Alternately, the library could install filtering software that

         could be turned off when an adult is using the terminal. While we

         find that all of these alternatives are less restrictive than the

         Policy, we do not find that any of them would necessarily be

         constitutional if implemented. That question is not before us.

         2. Whether the Policy Is Overinclusive

              Defendant contends that the Policy is neither overinclusive

         nor underinclusive because it is the least restrictive means

         available.  Defendant also asserts that we should not focus on the

         specifics of what the Policy does and does not cover because that

         would detract from the broader issue of "whether a public library

         can or cannot filter obscene materials on its public Internet

         terminals and, if so, under what criteria and procedures." Def.

         Brief in Opp. at 4.   In other words, the defendant asks this Court

         to consider a hypothetical situation that is not before us. The

         federal courts, however, may not provide advisory opinions; we may

         rule only on the Policy before us. Defendant cannot save its

         Policy by asking the Court to decide hypothetical questions for

         which there is no case or controversy.

              In examining the specific Policy before us, we find it

         overinclusive because, on its face, it limits the access of all

         patrons, adult and juvenile, to material deemed fit for juveniles.

         It is undisputed that the Policy requires that "[i]f the Library

         Director considers a particular website to violate . . . [the

         Virginia Harmful to Juveniles Statute], the website should be

         blocked under the policy for adult as well as juvenile patrons."

         Pls. Ex. 10, Def. Resp. to Pls., First Req. for Admiss. 35. It has

         long been a matter of settled law that restricting what adults may

         read to a level appropriate for minors is a violation of the free

         speech guaranteed by the First Amendment and the Due Process Clause

         of the Fourteenth Amendment. See Reno v. ACLU, 117 S. Ct. 2329,

         2346 (1997) ("It is true that we have repeatedly recognized the

         governmental interest in protecting children from harmful materials

         but that interest does not justify an unnecessarily broad

         suppression of speech addressed to adults.") (citations omitted);

         Butler v. Michigan, 352 U.S. 380, 383 (1957) (restricting adults to

         what is appropriate for juveniles is "not reasonably restricted to

         the evil with which it is said to deal").

              At issue in Reno was a federal statute, the Communications

         Decency Act ("CDA"), which established a criminal penalty for

         providing on the Internet material deemed harmful to minors

         although not obscene with the knowledge that such material could be

         accessed by minors. The Supreme Court found that because there was

         no way for an Internet provider to block minors from accessing such

         material, this statute effectively prohibited such material from

         being displayed at all. Reno at 2347. The Court held that

              [i]n order to deny minors access to potentially harmful
              speech, the CDA effectively suppresses a large amount of
              speech that adults have a constitutional right to receive
              and to address to one another. That burden on adult
              speech is unacceptable if less restrictive alternatives
              would be at least as effective in achieving the
              legitimate purpose that the statute was enacted to serve.

         Id. at 2346. Because we have found that less restrictive

         alternatives are available to defendant and that defendant has not

         sufficiently tried to employ any of them, see III.C.1., the

         Policy's limitation of adult access to constitutionally protected

         materials cannot survive strict scrutiny.

         3.Whether X-Stop Is the Least Restrictive Filtering Software

              Defendant claims that X-Stop is the least restrictive

         filtering software currently available and, therefore, the Policy

         is narrowly tailored as applied. Our finding that the Policy is

         unconstitutional on its face makes this argument moot. A facially

         overbroad government policy may nevertheless be saved if a court is

         able to construe government actions under that policy's narrowly

         along the lines of their implementation, if the policy's text or

         other sources of government intent demonstrate "a clear line" to

         draw. See Reno, 117 S. Ct. at 235O-51. We find no such clear line

         here. Defendant has asserted an unconditional right to filter the

         Internet access it provides to its patrons and there is no evidence

         in the record that it has applied the Policy in a less restrictive

         way than it is written. See Def. Resp. to Pl First Req. Admiss. 17

         (denying that X-Stop does not block access to soft core

         pornography, which is protected).  Therefore, our finding that the

         Policy is unconstitutional on its face makes any consideration of

         the operation of X-Stop moot.

         V. Prior Restraint

              Plaintiffs and intervenors allege that even if the Policy were

         to survive strict scrutiny analysis, the Court would have to find

         in unconstitutional under the doctrine of prior restraint because

         it provides neither sufficient standards to limit the discretion of

         the decisionmaker nor adequate procedural safeguards. Defendant

         responds that the Policy is not a prior restraint because it only

         prohibits viewing certain sites in Loudoun County public libraries,

         and not in the whole of Loudoun County.

              Preventing prior restraints of speech is an essential

         component of the First Amendment's free speech guarantee. See

         Freedman v. Maryland, 380 U.S. 51, 58 (1965). "Permitting

         government officials unbridled discretion in determining whether to

         allow protected speech presents an unacceptable risk of both

         indefinitely suppressing and chilling protected speech." 11126

         Baltimore Boulevard, Inc. v. Prince George's County, 58 F.3d 988,

         994 (4th Cir. 1995).  In 11126, the Fourth Circuit found that

              [t]he guarantee of freedom of speech afforded by the
              First Amendment is abridged whenever the government makes
              the enjoyment of protected speech contingent upon
              obtaining permission from government officials to engage
              in its exercise under circumstances that permit
              government officials unfettered discretion to grant or
              deny the permission. . . . Such discretion exists when
              a regulation creating a prior restraint on speech fails
              to impose adequate standards for officials to apply in
              rendering a decision to grant or deny permission or when
              a regulation fails to impose procedural safeguards to
              ensure a sufficiently prompt decision.

              [The following procedural safeguards have been required
              by the Supreme Court:] "(1) any restraint prior to
              judicia1 review can be imposed only for a specific brief
              period during which the status quo must be maintained;
              (2) expeditious judicial review of that decision must be
              available; and (3) the censor must bear the burden of
              going to court to suppress the speech and must bear the
              burden of proof once in court."

         Id. at 996 (quoting Freedman, 380 U.S. at 58-60 (1965)).  In other

         words, even unprotected speech cannot be censored by administrative

         determination absent sufficient standards and adequate procedural

         safeguards.  See Southeastern Promotions, Ltd. v. Conrad, 420 U.S.

         546, 562 (1975) ("Whatever the reasons may have been for the

         board's exclusion of the musical, it could not escape the

         obligation to afford appropriate procedural safeguards.  We need

         not decide whether the . . . production is in fact obscene.").

              Defendant argues that prior restraint cases are limited to

         situations in which a government tries to restrict all speech

         within its jurisdiction. Because Loudoun County residents are

         still permitted to obtain unfiltered Internet access in their homes

         or offices, defendant asserts, this situation is distinguishable

         from those cases. We find no legal support for this argument. See

         Reno, 117 S. Ct. at 2349 ("'[O]ne is not to have the exercise of

         his liberty of expression in appropriate places abridged on the

         plea that it may be exercised in some other place.'") (quoting

         Schneider v. New Jersey, 308 U.S. 147, 163 (1939)); Southeastern

         Promotions, 420 U.S. 546. In Southeastern Promotions, a

         municipality had denied the use of a public facility for the

         production of the musical "Hair", which it deemed obscene. The

         Court found that "it does not matter . . . that the board's

         decision might not have had the effect of total suppression of the

         musical in the community. Denying use of the municipal facility

         under the circumstances present here constituted the prior

         restraint." 420 U.S. at 556.

              It is undisputed that the Policy lacks any provision for prior

         judicial determinations before material is censored. See Pls. Ex.

         10, Def. Res. to Pls. First Req. for Admiss. 31.  We find that the

         Policy includes neither sufficient standards nor adequate

         procedural safeguards.  As to the first issue, the defendant's

         discretion to censor is essentially unbounded.  The Policy itself

         speaks only in the broadest terms about child pornography,

         obscenity, and material deemed harmful to juveniles and fails to

         include any guidelines whatsoever to help librarians determine what

         falls within these broad categories. See Pls. Ex. 12, Def. Answer

         to Pls. First Req. for Interrogs. 3 ("[T]here is no information

         beyond the Policy itself that constitutes the 'criteria' used for

         unblocking specific sites.").  There are no standards by which a

         reviewing authority can determine if the decisions made were

         appropriate.

              The degree to which the Policy is completely lacking in

         standards is demonstrated by the defendant's willingness to entrust

         all preliminary blocking decisions -- and, by default, the

         overwhelming majority of final decisions21 -- to a private vendor, Log-On 
 
         Data Corp.  Although the defendant argues that X-Stop is the best 

         available filter, a defendant cannot avoid its constitutional

         obligation by contracting out its decisionmaking to a private

         entity. Such abdication of its obligation is made even worse by

         the undisputed facts here. Specifically, defendant concedes that

         it does not know the criteria by which Log-On Data makes its

         blocking decisions.  See Bradshaw Dep. at 12-13 (stating that Log-

         On Data has refused to provide defendant with the criteria it uses

         to block sites). It is also undisputed that Log-On Data does not

         base its blocking decisions on any legal definition of obscenity or

         even on the parameters of defendant's Policy. See Bradshaw Dep. at

         36-37 (agreeing that "there is neither any attempt nor the ability

         by [Log-On Data] to apply a legal test"). Thus, on this record, we

         find that the defendant has not satisfied the first prong of prior

         restraint analysis, establishing adequate standards.

              In addition, the Policy also fails to include adequate

         procedural safeguards. The three minimum procedural safeguards

         required are (1) a specific brief time period of imposition before

         judicial review; (2) expeditious judicial review; and (3) the

         censor bearing the burden of proof. The Policy, even including the

         alleged protections of the unofficial 'unblocking policy', is

         inadequate in each of these respects.22 First, the Policy itself

         contains no provision for administrative review, no time period in

         which any review must be completed, and no provision for judicial

         review. See Pls. Ex. 1, Policy. Under the unofficial 'unblocking

         policy', a library patron who finds herself blocked from an

         Internet site she believes contains protected speech is required to

         request in writing that the librarians unblock the specified site.

         See Pls. Ex. 4, Internet Procedures at ¶ 13. If the librarian

         determines that the site does not fall within the policy's

         prohibitions, he will unblock it, although there is no systematic

         way in which this is done. See Henderson Dep. at 368-71. There is

         no time period during which this review must occur and there is no

         provision for notifying the requesting patron if and when a site

         has been unblocked. See id.; Timmerman Dep. at 93-94 (stating that

         neither patrons nor staff are informed when the defendant unblocks

         a site).

              The second required procedural safeguard is expeditious

         judicial review after the administrative decision is made. There

         is no provision whatsoever in the Policy for judicial review of any

         blocks. See Pls. Ex. 1. Policy. This makes the question of who

         carries the burden of proof in any judicial review proceeding, the

         third required procedural safeguard, moot. Because the Policy has

         neither adequate standards nor adequate procedural safeguards, we

         find it to be an unconstitutional prior restraint.

         VI.  Severability

              While neither party addresses the issue, the Policy includes

         a provision that if a part of it is overruled, "remaining portions

         remain in effect." Pls. Ex. 1 at 2. In Reno, the Supreme Court

         severed provisions of the CDA, declaring its prohibition of

         "indecent material" unconstitutional but allowing the prohibition

         on obscene material to remain in effect "because [obscene

         materials enjoy[] no First Amendment protection." l17 S. Ct. at

         2350. The CDA, however, unlike the Policy, did not operate as an

         unconstitutional prior restraint; rather, it provided for criminal

         penalties only after a judicial determination that obscene material

         had been furnished. Because we have concluded that section 2 under

         the heading "Internet Services Provided" constitutes an

         unconstitutional prior restraint on speech, and that section 2

         permeates the rest of the Policy, we hold that defendant's Policy

         on Internet Sexual Harassment is unconstitutional.

         VII. Conclusion

              Although defendant is under no obligation to provide Internet

         access to its patrons, in has chosen to do so and is therefore

         restricted by the First Amendment in the limitations it is allowed

         to place on patron access. Defendant has asserted a broad right to

         censor the expressive activity of the receipt and communication of

         information through the Internet with a Policy that (1) is not

         necessary to further any compelling government interest; (2) is not

         narrowly tailored; (3) restricts the access of adult patrons to

         protected material just because the material is unfit for minors;

         (4) provides inadequate safeguards for restricting access; and (5)

         provides inadequate procedural safeguards to ensure prompt judicial

         review. Such a policy offends the guarantee of free speech in the

         First Amendment and is, therefore, unconstitutional.

              For these reasons, the intervenors' Motion to Substitute

         Parties will be GRANTED; the plaintiffs' and intervenors' motions

         for Summary Judgment will be GRANTED; and the defendant's Motion

         for Summary Judgment will be GRANTED as to the standing of John

         Ockerbloom d/b/a Banned Books On-Line and DENIED in all other

         respects. Defendant will be permanently enjoined from enforcing

         its Policy on Internet Sexual Harassment. An appropriate order

         will issue.

              The clerk is directed to forward a copy of this Memorandum

         Opinion to counsel of record.

              Entered this 23rd day of November, 1998.


                                                         /signed/     
                                                    Leonie M. Brinkema
                                                    United States District Judge     

         Alexandria, Virginia



1 Although plaintiffs and intervenors have refused to admit that the Internet contains child pornography and obscene materials, defendant has provided unrebutted evidence strongly suggesting that such materials can be found there. For purposes of this opinion we will assume that such materials are accessible through the Internet. See Def. Exs. 4-14; see also Reno v. ACLU, 117 S. Ct. 2329, 2336 (sexually explicit material on the Internet includes text, pictures, and chat and 'extends from the modestly titillating to the hardest-core.'") (citing ACLU v. Reno, 929 F. Supp. 824, 844 (E.D. Pa. 1996)). 2 Defendant admits to having blocked The Safer Sex Page, the Books for Gay and Lesbian Teens/Youth page, and the Renaissance Transgender Association page, even though it recognizes that none of them contain prohibited material. See Def. Ex. 18, Def. Answer to Intervs. Sec. Interrogs. 3 We have also considered the Amici briefs filed by the Commonwealth of Virginia and the National Organization for Women-Dulles, et. al., on behalf of defendant. Because we find that the issues raised in these briefs were adequately covered in the briefs submitted by the parties, we do not address them specifically in this Opinion. 4 Indeed, one of the websites defendant did find to be blocked on February 6, 1998, the Books for Gay and Lesbian Teens/Youth page, had not been blocked four days earlier when Sehgal had tried to access it, although links from it to other websites were blocked. See Sehgal Decl., ¶ 11. 5 Even absent the above analysis, intervenors would likely have standing to pursue this action as a challenge to a government action that is "capable of repetition, yet evading review." See, e.g., Morse v. Republican Party of Virginia, 116 S. Ct. 1186, 1213 n.48 (1996). If defendant could evade court challenges to its Policy by unblocking the protected speech only of entities that filed lawsuits against it, it would be able to continue indefinitely its unconstitutional censorship against most of the now 80,000 websites it currently blocks. See Pls. Ex. 13, Dep. of Def. Expert David Burt ("Burt Dep."), at 222. 6 "Links" are text, icons, or images located on a web page that allow the user by the click of a mouse, to switch to another specific document "located anywhere on the Internet." See Reno v. ACLU, 117 S. Ct. 2329, 2336 (1997); see also ACLU v. Reno, 929 F. Supp. 824, 836-37 (E.D. Pa. 1996) (finding that links "are short sections of text or image which refer to another document. Typically the linked text is blue or underlined when displayed, and when selected by the user, the referenced document is automatically displayed, wherever in the world it actually is stored. Links for example are used to lead from overview documents to more detailed documents, from tables of contents to particular pages, but also as cross-references, footnotes, and new forms of information structure. . . . These links . . . are what unify the Web into a single body of knowledge, and what makes the Web unique."). 7 See 11126 Baltimore Boulevard v. Prince George's County, 58 F.3d 994 (4th Cir. 1995). 8 See Drive In Theatres Inc. v. Huskey, 435 F.2d 228 (4th Cir. 1970). 9 See Kreimer v. Bureau of Police, 958 F.2d 1242 (3d Cir. 1992). 10 Defendant has consistently relied on Board of Education v. Pico, 457 U.S. 853, 889 (1982) (Burger, J. dissenting) ("[T]here is not a hint in the First Amendment, or in any holding of this Court, of a 'right' to have the government provide continuing access to certain books.") . Pico, however, was limited to the context of school libraries. It is notable that even Justice Rehnquist's dissent in that case explicitly recognized the difference between school libraries, which serve unique education purposes, and public libraries, which are "designed tor freewheeling inquiry." Pico, 457 U.S. at 915 (Rehnquist, J. dissenting). 11 At issue in Kreimer was a First Amendment challenge to content-neutral library rules that addressed only conduct, not access to specific materials. The rules: (l) required persons who were not engaged in "reading, studying, or using library materials" to leave the library; (2) prohibited patrons from engaging in various forms of behavior that would harass or annoy other patrons; and (3) required patrons "whose bodily hygiene is offensive so as to constitute a nuisance to other persons" to leave the library. Kreimer, 358 F.2d at 1262-64. 12 Defendant's assertion that the Kreimer court found the public library to be a non-public forum is simply wrong. See Kreimer, 958 F.2d at 1262 ("Hence, as a limited public forum, the Library is obligated only to permit the public to exercise rights that are consistent with the nature of the Library and consistent with the government's intent in designating the Library as a public forum."). 13 This includes both the right to provide information and the right to receive information. See Kreimer 958 F.2d at 1250-55 (citing, inter alia, Martin v. City of Struthers, 319 U. S. 141 (1943); Lamont v. Postmaster General, 381 U.S. 301 (1965); Griswold v. Connecticut, 381 U.S. 479, 482 (1965) ("The right of freedom of speech and press includes not only the right to utter or to print but the right to distribute, the right to receive, the right to read . . . ")). 14 In Kreimer, the Third Circuit determined that none of the regulations at issue were subject to strict scrutiny review because none of them were content-based limitations on the kind of expressive activity permitted in the library. Kreimer, 958 F.2d at 1262 ("Significantly, the parties do not contend that any of the challenged regulations purport to restrict First Amendment activities on the basis of content or viewpoint."). 15 See Protection of Children Against Sexual Exploitation Act, 18 U.S.C. §§ 2251-2260 (1984 & Supp. 1998) (criminalizing activities related to child pornography); 18 U.S.C. § 1465 (1984 & Supp. 1998) (criminalizing transportation of obscene materials in interstate commerce). However, to the extent defendant's concern is with its own criminal liability, the Fourth Circuit has clearly stated that service providers are not liable "for information originating with a third-party user of the service." See Zeran v. America Online Inc., 129 F.3d 327, 330 (4th Cir.1997). 16 We note, however, that the legal concept of a sexually hostile work environment has traditionally been limited to the employment context, see e.g. Title VII of the Civil Rights Act of 1964, 42 U.S.C §§ 2000e et. seq. (1994); Johnson v. Los Angeles Fire Dept., 865 F. Supp. 1430, 1439 (C.D. Cal. 1994) ("There is no doubt that the prevention of sexual harassment is a compelling government interest."), and, more recently, the education context, see Gebser v. Lago Vista Independent School District, 118 S. Ct. 1989, 2000 (1998). 17 Quoting a newspaper article, Burt reported that library computers "are regularly steered to online photos of naked women, digitized videos of sex acts and ribald chat-room discussions." causing legitimate researchers to have to wait in line while others read "personal ads or X-rated chat rooms." Burt Rep. at 14 (quoting Public Libraries Debating How to Handle Net Porn, August Chron., July 3, 1997). 18 Burt alleges that filters had to be installed in Orange County libraries after patrons were accessing hard-core porn sites "for hours on end." Id. (quoting Pamela Mendels, A Library That Would Rather Block Than Offend, N.Y. Times, Jan. 18, 1997). 19 The Austin library installed filters after two incidents. In the first, a librarian caught a patron printing child pornography on the library printer. In the second incident, at a different branch, an adult patron was caught teaching children how to access pornography on the Internet. See id. at l4-l5 (citing Mark Smith, Meeting the Pressure to Filter, Tex. Library J., Feb. 1997). 20 Although they dispute the legal conclusion to be drawn from the facts in the record, the parties do not dispute the facts themselves. Therefore, summary judgment remains the appropriate vehicle for resolving this dispute. 21 Defendant claims that the library staff has reviewed "more than 172" websites, see Henderson Decl. at ¶¶ 9-10, out of the approximately 80,000 that X-Stop currently blocks. See Burt Dep. at 222. 22 The defendant relies on the undisputed evidence that it has not denied any of the eleven unblocking requests it has received thus far to save the Policy. See Henderson Decl. at ¶ 16. This is insufficient because, as we noted in our previous opinion, "forcing citizens to publicly petition the Government for access to" disfavored speech has a "severe chilling effect." Mainstream Loudoun, 2 F. Supp. 2d at 797 (citing Lamont v. Postmaster General, 381 U.S. 301, 307 (1965)); see also Elrod v. Burns, 427 U.S. 347, 373-74 (1976) ("[T]he loss of First Amendment freedoms, for even minimal periods of time, unquestionably constitutes irreparable injury."). At least one patron has stated that he failed to request access to a blocked site he believed was improperly blocked because he was "intimidated to have to go through that procedure." Pls. Ex. 19. Kropat First Decl. at ¶ 7.