Other Developments, Further Reading, and Coming Events (1 July 2021)

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Other Developments

  • The European Commission (EC) “adopted two adequacy decisions for the United Kingdom – one under the General Data Protection Regulation (GDPR) and the other for the Law Enforcement Directive.” The EC continued:
    • Personal data can now flow freely from the European Union to the United Kingdom where it benefits from an essentially equivalent level of protection to that guaranteed under EU law. The adequacy decisions also facilitate the correct implementation of the EU-UK Trade and Cooperation Agreement, which foresees the exchange of personal information, for example for cooperation on judicial matters. Both adequacy decisions include strong safeguards in case of future divergence such as a ‘sunset clause’, which limits the duration of adequacy to four years. 
    • Key elements of the adequacy decisions
      • The UK’s data protection system continues to be based on the same rules that were applicable when the UK was a Member State of the EU. The UK has fully incorporated the principles, rights and obligations of the GDPR and the Law Enforcement Directive into its post-Brexit legal system.
      • For the first time, the adequacy decisions include a so-called ‘sunset clause’, which strictly limits their duration. This means that the decisions will automatically expire four years after their entry into force. After that period, the adequacy findings might be renewed, however, only if the UK continues to ensure an adequate level of data protection. During these four years, the Commission will continue to monitor the legal situation in the UK and could intervene at any point, if the UK deviates from the level of protection currently in place. Should the Commission decide to renew the adequacy finding, the adoption process would start again.
      • Transfers for the purposes of UK immigration control are excluded from the scope of the adequacy decision adopted under the GDPR in order to reflect a recent judgment of the England and Wales Court of Appeal on the validity and interpretation of certain restrictions of data protection rights in this area. The Commission will reassess the need for this exclusion once the situation has been remedied under UK law.
  • The White House announced that President Joe Biden supports the “Bipartisan Infrastructure Framework, the largest long-term investment in our infrastructure and competitiveness in nearly a century – an investment that will make our economy more sustainable, resilient, and just.” This framework resulted from negotiations between Senate Democrats and Republicans on an infrastructure package and is a mix between new spending and the repurposing of already appropriated funding. The Biden Administration summarized the elements that include $65 billion for broadband and will allegedly:
    • Improve healthy, sustainable transportation options for millions of Americans by modernizing and expanding transit and rail networks across the country, while reducing greenhouse gas emissions. The Plan is the largest federal investment in public transit in history and is the largest federal investment in passenger rail since the creation of Amtrak.
    • Repair and rebuild our roads and bridges with a focus on climate change mitigation, resilience, equity, and safety for all users, including cyclists and pedestrians. The Bipartisan Infrastructure Framework is the single largest dedicated bridge investment since the construction of the interstate highway system.
    • Build a national network of electric vehicle (EV) chargers along highways and in rural and disadvantaged communities. The largest investment in EV infrastructure in history, the Bipartisan Infrastructure Framework will accomplish the President’s goal of building 500,000 EV chargers.
    • Electrify thousands of school and transit buses across the country to reduce harmful emissions and drive domestic manufacturing of zero emission vehicles and components.
    • Eliminate the nation’s lead service lines and pipes, delivering clean drinking water to up to ten million American families and more than 400,000 schools and child care facilities that currently don’t have it, including in Tribal nations and disadvantaged communities. The Plan is the largest investment in clean drinking water and waste water infrastructure in American history.
    • Connect every American to reliable high-speed internet, just as the federal government made a historic effort to provide electricity to every American nearly one hundred years ago. The Framework will also drive down prices for internet service and close the digital divide.
    • Upgrade our power infrastructure, including by building thousands of miles of new, resilient transmission lines to facilitate the expansion of renewable energy, including through a new Grid Authority. The Plan is the single largest investment in clean energy transmission in American history.
    • Create a first of its kind Infrastructure Financing Authority that will leverage billions of dollars into clean transportation and clean energy.
    • Make the largest investment in addressing legacy pollution in American history, a cleanup effort that will create good-paying union jobs and advance environmental justice.
    • Prepare more of our infrastructure for the impacts of climate change, cyber attacks, and extreme weather events. The Framework is the largest investment in the resilience of physical and natural systems in American history.
  • The House passed the “National Science Foundation for the Future Act” (H.R. 2225) by a 345-67 margin and the “Department of Energy Science for the Future Act” (H.R. 3593) by a 351-68 vote. These bills may form the House’s answer to the Senate’s “United States Innovation and Competition Act” (S.1260.) In a press release, Ranking Member Frank Lucas provided a short summary of the legislation:
    • Today, the House Science, Space, and Technology passed two landmark bills to double down on federal investment in American research and development. The bills significantly increase funding for the National Science Foundation (NSF) and the Department of Energy (DOE) Office of Science.
    • As amended, the NSF for the Future Act reauthorizes NSF’s work, providing $78 billion over the next five years and doubling down on basic research with a focus on emerging technologies like artificial intelligence, cybersecurity, and advanced manufacturing. It strengthens our domestic science, technology, engineering, and math (STEM) workforce and protects research from foreign theft. Additionally, the bill creates a new NSF directorate dedicated to improving how we apply discoveries in the lab to solving pressing national challenges from cybersecurity to climate change.
    • The DOE Science for the Future Act is the first reauthorization of the Office of Science, and it invests nearly $50 billion over five years to scale up next-generation energy technologies like bioenergy, carbon capture, and battery storage. It invests in upgrades to the facilities and equipment that our scientists and National Labs use to conduct complex research. It also improves our quantum computing abilities, helps address public health challenges, and builds our STEM workforce.
  • The United Kingdom’s (UK) Competition and Markets Authority (CMA) “has opened a formal probe into Amazon and Google over concerns that they have not been doing enough to combat fake reviews on their sites” per its press release. The agency stated:
    • In this next phase of the work, the CMA will gather further information to determine whether these two firms may have broken consumer law by taking insufficient action to protect shoppers from fake reviews.
    • The move comes after an initial CMA investigation, which opened in May 2020, and assessed several platforms’ internal systems and processes for identifying and dealing with fake reviews.
    • This work has raised specific concerns such as whether Amazon and Google have been doing enough to:
    • Detect fake and misleading reviews or suspicious patterns of behaviour. For example, where the same users have reviewed the same range of products or businesses at similar times to each other and there is no connection between those products or businesses – or where the review suggests that the reviewer has received a payment or other incentive to write a positive review.
    • Investigate and, where necessary, remove promptly fake and misleading reviews from their platforms.
    • Impose adequate sanctions on reviewers or businesses to deter them and others from posting fake or misleading reviews on their platforms – including those who have published these types of reviews many times.
    • The CMA is also concerned that Amazon’s systems have been failing adequately to prevent and deter some sellers from manipulating product listings – for example, by co-opting positive reviews from other products.
    • Fake and misleading reviews have the potential to impact on businesses’ star ratings and how prominently companies and products are displayed to consumers, changing their whole shopping experience.
    • If, after investigating, the CMA considers the firms have broken consumer protection law, it can take enforcement action. This could include securing formal commitments from the firms to change the way they deal with fake reviews or escalating to court action if needed. However, the CMA has not reached a view on whether Amazon and Google have broken the law at this stage.
    • This latest work builds on action taken by the CMA last year over the trading of fake reviews, which resulted in Facebook, Instagram and eBay removing groups and banning individuals for buying and selling fake reviews on their sites.
  • The National Security Agency (NSA) issued “a Cybersecurity Technical Report today that provides best practices and mitigations for securing Unified Communications (UC) and Voice and Video over IP (VVoIP) call-processing systems” according to the agency’s press release. The agency added that “[t]o complement the larger report, NSA published an abridged Cybersecurity Information Sheet to capture key takeways and introduce the steps organizations should take when securing their UC/VVoIP systems.” The NSA contended:
    • UC and VVoIP are workplace call-processing systems that provide a variety of collaboration tools as well as the flexibility to communicate using voice, video conferencing and instant messaging. The access to advanced call-processing features and centralization of management have made UC and VVoIP popular in enterprise environments, including National Security System, Department of Defense and Defense Industrial Base networks.
    • The IP infrastructure that enables UC/VVoIP systems also presents risks that were less prevalent in the prior generation of call centers. If UC/VVoIP systems are not properly secured, they are susceptible to the same malicious activity targeting existing IP systems through spyware, viruses, software vulnerabilities or other malicious means. Malicious actors could penetrate the IP networks to eavesdrop on conversations, impersonate users, commit toll fraud and perpetrate denial of service attacks. High-definition room audio and video could also be covertly collected.
    • To securely deploy UC/VVOIP systems, NSA provides best practices to use when preparing networks, establishing network perimeters, using enterprise session controllers and adding endpoints to deploy a UC/VVOIP system.
    • Methods to minimize the risk to UC/VVOIP systems include segmenting the networks to limit access to a common set of devices, ensuring timely patching, authentication and encryption of all signaling and media traffic, and verifying the security of devices before adding them to a network.
  • Representatives Doris Matsui (D-CA), Jim Langevin (D-RI), John Katko (R-NY) and Andrew Garbarino (R-NY) introduced the “Enhancing K-12 Cybersecurity Act” (H.R.4005), “a bill to strengthen cybersecurity at America’s K-12 schools by promoting access to information, better tracking cyberattacks nationally, and providing new cybersecurity resources.” They asserted:
    • This bill makes important K-12 cybersecurity improvements:
    • Cybersecurity Information Exchange
      • Directs the Cybersecurity and Infrastructure Security Agency (CISA) Director to establish a Cybersecurity Information Exchange to disseminate information, best practices, and grant opportunities to improve cybersecurity.
    • Cybersecurity Incident Registry
      • Establishes a Cybersecurity Incident Registry within CISA to track incidents of cyberattacks on elementary and secondary schools. Information submitted to the Registry is strictly voluntary and will help improve data collection to coordinate activities related to the nationwide monitoring of the incidence and financial impact of cyberattacks.
    • K-12 Cybersecurity Technology Improvement Program
      • Directs CISA to establish the K-12 Cybersecurity Technology Improvement Program to be administered through an information and analysis organization to deploy cybersecurity capabilities that will help address cybersecurity risks and threats to information systems of K-12 schools. This approach will capitalize on the existing services and expertise of organizations like MS-ISAC & others to ensure maximum impact of funds. The bill authorizes $10 million per year for FYs ‘22 & ‘23 to fund the Technology Improvement Program.
  • The Government Accountability Office (GAO) issued a report titled “Software Development: DOD Faces Risks and Challenges in Implementing Modern Approaches and Addressing Cybersecurity Practices”
    • The Department of Defense (DOD) relies heavily on the use of IT to protect the security of our nation. For FY 2021, the department requested approximately $37.7 billion for its unclassified IT investments. DOD plans to spend $12 billion on the 29 largest business IT systems between FY 2019 and FY 2022. However, since 1995, we have identified DOD’s efforts to modernize its business systems as high risk, in part due to long-standing challenges that the department faces in meeting cost, schedule, and performance commitments.
    • For its major business IT programs, DOD identified a range of program risk levels. However, our quantitative assessments reflected greater risk than reported by the department for almost half of the programs. Accordingly, programs could be understating risks, further increasing the chances of cost growth and schedule delays.
    • To DOD’s credit, the selected major business IT programs are taking a variety of software development and cybersecurity actions that can mitigate risks to cost and schedule. These actions and other ongoing efforts have the potential to improve how DOD acquires and manages its IT systems. However, the department does not yet have a specific plan for how it will provide automated oversight of IT programs and portfolios. DOD’s ability to oversee and manage these critical systems will be important to their success, as well as the department’s future capabilities.
    • As DOD continues to implement its numerous reform efforts, it has multiple opportunities to improve the performance of its IT systems, implement efficient and tailored oversight and management processes, and reduce risk across its systems.
    • The GAO recommended that the DOD:
      • The Secretary of Defense should direct the Chief Information Officer to revisit program risk ratings for its next submission to the federal IT Dashboard for the programs where the DOD CIO’s program risk ratings indicated less risk than GAO’s assessments of program risk. (Recommendation 1)
      • The Secretary of Defense should direct the Under Secretary of Defense for Acquisition and Sustainment, in consultation with appropriate internal and external stakeholders, to ensure the data strategies and data collection efforts for the business system and software acquisition pathways define, collect, automate, and share, with the appropriate level of visibility, the metrics necessary for stakeholders to monitor acquisitions and that are critical to the department’s ability to assess acquisition performance. (Recommendation 2)
  • The United States Court of Appeals for the Fourth Circuit found that an aerial surveillance program operated by the Baltimore Police Department violated the Fourth Amendment. The Fourth Circuit explained:
    • The Plaintiffs—a group of grassroots community advocates in Baltimore—moved to enjoin implementation of the Aerial Investigation Research (“AIR”) program, a first-of-its-kind aerial surveillance program operated by the Defendants—the Baltimore Police Department (“BPD”) and Commissioner Michael Harrison.
    • While appeal was pending, the program completed its pilot run and Baltimore City leadership decided not to renew its operation. Defendants deleted the bulk of the AIR data, only retaining materials that relate to specific investigations. Defendants then moved to dismiss this appeal as moot. Because Plaintiffs also sought to enjoin Defendants’ access to any data collected by the AIR program, and Defendants retain the data that proved fruitful, we hold that the appeal is not moot.
    • On the merits, because the AIR program enables police to deduce from the whole of individuals’ movements, we hold that accessing its data is a search, and its warrantless operation violates the Fourth Amendment. Therefore, we reverse and remand.
  • The Senate Judiciary Committee’s Competition Policy, Antitrust, and Consumer Rights Chair Amy Klobuchar (D-MN) wrote “Alphabet CEO Sundar Pichai and Amazon CEO Jeff Bezos requesting additional information on the companies’ approach to interoperability related to their digital voice assistants and connected home technology, as well as their use of data collected by connected home devices…[following] the companies’ testimony at a hearing last week on competition and the future of innovation related to connected home devices.” Klobuchar stated:
    • The Subcommittee also heard testimony that your companies may have sold speakers at below-cost prices as a way to secure a stronghold in the connected home of the future. Your witnesses provided general answers but did not provide details.
    • I therefore ask that you provide written answers to the following questions by July 2, 2021:
      • Last month, your companies both announced a commitment to an interoperability standard called “Matter.” Which of your existing connected home products will support third party devices that adhere to the Matter specification? Do you currently sell any connected home products, or have any in your development pipeline, that will not be Matter-compliant? For what period of time do you commit to support the Matter interoperability project, and who at your companies is responsible for determining whether to extend the length of your commitment to Matter?
      • What data do your digital voice assistants collect from connected home devices? Is that data used in any aspect of your advertising businesses? How long do you retain the data that your digital voice assistants collect? Do you combine data from digital voice assistants with data about people that you collect from other sources?
      • Have you ever sold connected speakers at below-cost prices? Are you aware of any connected speaker device being sold at a price below cost, regardless of manufacturer? Which of the connected speakers that you sell are profitable, and which are not?
  • The National Institute of Standards and Technology (NIST) published “a definition of “critical software” in a white paper as required by Executive Order 14028 “Improving the Nation’s Cybersecurity” as one of its assignments to enhance the security of the software supply chain. NIST stated:
    • The executive order (EO) directs the Cybersecurity & Infrastructure Security Agency (CISA) to develop a list of software categories and products in use or in the acquisition process which meet this definition of critical software.
    • To coordinate the definition with its eventual application, NIST solicited position papers from the community, hosted a virtual workshop to gather input, and consulted with CISA, the Office of Management and Budget (OMB), the Office of the Director of National Intelligence (ODNI), and the National Security Agency (NSA) to develop the definition, the concept of a phased implementation, and a preliminary list of common categories of software that would fall within the scope for the initial phase. Additional guidance on applying this definition for implementing the EO will be forthcoming from CISA and OMB. NIST worked closely with CISA and OMB to ensure that the definition and recommendations are consistent with their plans. 
    • NIST defined “EO-critical software” “as any software that has, or has direct software dependencies upon, one or more components with at least one of these attributes:
      • is designed to run with elevated privilege or manage privileges;
      • has direct or privileged access to networking or computing resources;
      • is designed to control access to data or operational technology;
      • performs a function critical to trust; or,
      • operates outside of normal trust boundaries with privileged access.

Further Reading

  • All the ways Amazon tracks you and how to stop it” By Matt Burgess — WIRED. Jeff Bezos has a hidden weapon: your data. While Amazon’s retail empire is built on a complex web of infrastructure and murky working practices, its selling success is based on an intricate knowledge of what millions of people buy and browse every day. Amazon has been obsessed with your data since it was an online bookshop. Almost two decades ago the firm’s chief technology officer, Werner Vogels, said that the company tries to “collect as much information as possible” so it can provide people with recommendations. And, as Amazon has expanded, so has its data collection operation. “They happen to sell products, but they are a data company,” a former Amazon executive told the BBC in 2020.
  • Google and Microsoft End Their Five-Year Cease-Fire” By  Dina Bass and Nico Grant — Bloomberg. Microsoft and Google have decided to stop playing nice. The two tech giants recently ended a years-long truce during which they agreed not to aim their substantial lobbying firepower against each other. With regulators around the world threatening to impose limits on the power of the biggest technology companies, the two rivals — which compete in web search, cloud computing and artificial intelligence — are now free to step up behind-the-scenes lobbying efforts and public complaints against one another. 
  • He Warned Apple About the Risks in China. Then They Became Reality.” By Jack Nicas — The New York Times. Doug Guthrie spent 1994 riding a single-speed bicycle between factories in Shanghai for a dissertation on Chinese industry. Within years, he was one of America’s leading experts on China’s turn toward capitalism and was helping companies venture East. Two decades later, in 2014, Apple hired him to help navigate perhaps its most important market. By then, he was worried about China’s new direction.
  • Russian lawmakers vote to force U.S. tech giants to open local offices” — Reuters. Russian lawmakers passed legislation on Thursday that would oblige U.S. tech giants to open offices in Russia by January 2022 or face punitive measures, part of a push by Russia to beef up what it calls internet “sovereignty”. Russia has cracked down on U.S. internet companies in recent months and slowed down Twitter’s internet traffic since March to punish it for not deleting what Moscow says is banned content.
  • Three Iraqi women explain how and why they stay anonymous online” By Sofia Barbarani — The Rest of the World. Ever since social media was introduced in Iraq, women here have turned to online anonymity in order to voice their opinions, thoughts, and feelings. For many, creating anonymous social media accounts on sites like Facebook and Instagram isn’t simply an extension of their offline lives — it’s a window into a public sphere and world they are often excluded from. 
  • Chinese apps could face subpoenas or bans under Biden order -sources” By Karen Freifeld — Reuters. President Joe Biden’s executive order aimed at safeguarding Americans’ sensitive data would force some Chinese apps to take tougher measures to protect private information if they want to remain in the U.S. market, according to people familiar with the matter. The goal is to keep foreign adversaries like China and Russia from gaining access to large amounts of personal and proprietary business information.
  • Expanding state surveillance: Organised crime and the PM’s push for more police powers” By Lisa Visentin — The Sydney Morning Herald. Flanked by top police officials in front of custom printed ‘Operation Ironside’ branding, Prime Minister Scott Morrison used a global organised crime sting to make the public case for stronger police powers. The foiling of cocaine shipments, murder plots, illegal weapons and the dirty money trade is a crowning moment for law enforcement but rarely does it fall within the purview of the highest political office.
  • Canon put AI cameras in its Chinese offices that only let smiling workers inside” By James Vincent — The Verge. Tech company Canon has come up with a downright dystopic way to tackle the problem of workplace morale: it’s installed cameras with AI-enabled “smile recognition” technology in the offices of its Chinese subsidiary Canon Information Technology. The cameras only let smiling workers enter rooms or book meetings, ensuring that every employee is definitely, 100 percent happy all the time. This depressing tale was highlighted in a report from The Financial Times on how Chinese companies are surveilling employees to an unsettling degree with the help of AI and algorithms. Firms are monitoring which programs employees use on their computers to gauge their productivity; using CCTV cameras to measure how long they take on their lunch break; and even tracking their movements outside the office using mobile apps.
  • “How the House’s Silicon Valley smackdown is dividing conservatives” By Emily Birnbaum — Politico. A set of bipartisan bills to rein in the power of the country’s largest tech companies is splintering the conservative movement, prompting a well-established set of Charles Koch-backed think tanks and advocacy groups to mobilize in defense of Facebook, Amazon, Apple and Google. The fight is pitting the politically powerful Koch network, which advocates for the government to stay out of business, against major tech antagonists on the right like News Corp. executive chair Rupert Murdoch, who has spent years working behind the scenes to knife Facebook and Google. The Kochs’ opponents also include conservative donor Rebekah Mercer, a major backer of both Donald Trump’s 2016 presidential campaign and the right-leaning social media network Parler.
  • This Agency’s Computers Hold Secrets. Hackers Got In With One Password.” By Ashley Southall, Benjamin Weiser and Dana Rubinstein — The New York Times. New York City’s Law Department holds some of the city’s most closely guarded secrets: evidence of police misconduct, the identities of young children charged with serious crimes, plaintiffs’ medical records and personal data for thousands of city employees. But all it took for a hacker to infiltrate the 1,000-lawyer agency’s network early this month was one worker’s pilfered email password, according to a city official briefed on the matter.
  • Bombshell Report Finds Phone Network Encryption Was Deliberately Weakened” By Lorenzo Franceschi-Bicchierai — Vice. A weakness in the algorithm used to encrypt cellphone data in the 1990s and 2000s allowed hackers to spy on some internet traffic, according to a new research paper. The paper has sent shockwaves through the encryption community because of what it implies: The researchers believe that the mathematical probability of the weakness being introduced on accident is extremely low. Thus, they speculate that a weakness was intentionally put into the algorithm. After the paper was published, the group that designed the algorithm confirmed this was the case.
  • Legal scholars are working on new rules for international hacking conflicts” By Joseph Marks — The Washington Post. Top international legal experts are beginning work on a five-year project to hammer out what’s in and out of bounds in international cyber conflict. The result will be the third version of a NATO-sponsored document called the “Tallinn Manual on the International Law Applicable to Cyber Operations.” The manual isn’t legally binding, but government lawyers in the United States and elsewhere are increasingly pointing to it as they debate which offensive hacks are legally defensible and when it’s appropriate to retaliate.
  • The Lazarus heist: How North Korea almost pulled off a billion-dollar hack” — The BBC. In 2016 North Korean hackers planned a $1bn raid on Bangladesh’s national bank and came within an inch of success – it was only by a fluke that all but $81m of the transfers were halted, report Geoff White and Jean H Lee. But how did one of the world’s poorest and most isolated countries train a team of elite cyber-criminals? It all started with a malfunctioning printer. It’s just part of modern life, and so when it happened to staff at Bangladesh Bank they thought the same thing most of us do: another day, another tech headache. It didn’t seem like a big deal.
  • LinkedIn blocks profiles from view in China if sensitive topics mentioned” By Helen Davidson — The Guardian. LinkedIn is blocking profiles from being viewed inside China if they mention politically sensitive topics such as the Tiananmen Square massacre, including benign references to academic study. In recent weeks, the professional networking site has written to several China analysts, alerting them to “prohibited content” on their profile pages.

Coming Events

  • On 1 July, Federal Trade Commission (FTC) will hold start holding open monthly meetings. The FTC announced this tentative agenda for its upcoming meeting:
    • Made in the USA Rule: The Commissioners will vote on whether to finalize the Made in the USA Rule. The rule would help ensure that consumers can confidently buy American, and that honest companies can realize the benefits of the Made in USA label.
    • Section 18 Rulemaking Procedures: The Commissioners will vote on whether to streamline the procedures for Section 18 rules prohibiting unfair or deceptive acts or practices. Section 18 rules allow the Commission to seek redress for defrauded consumers and penalties against firms that cheat.
    • “Statement of Enforcement Principles Regarding ‘Unfair Methods of Competition’ Under Section 5 of the FTC Act” (2015): The Commissioners will vote on whether to rescind the policy statement issued by the Commission in 2015 in order to better align with the requirements set out by Congress to condemn “unfair methods of competition.”
    • Enforcement Investigations: The Commissioners will vote on whether to approve a series of resolutions that will streamline investigations by Commission staff into specific industries or specific conduct. The resolutions would provide ongoing authority for a single Commissioner to approve the use of compulsory process in those investigations.
    • Public Comments
    • After conducting its business, the Commission will invite members of the public to share feedback on the Commission’s work generally and bring relevant matters to the Commission’s attention.
  • On 1 July, the House Veterans Affairs Committee’s Technology Modernization Subcommittee will hold a hearing titled “Review of the FY22 Veterans Affairs Information Technology Budget.”
  • On 27 July, the Federal Trade Commission (FTC) will hold PrivacyCon 2021.

© Michael Kans, Michael Kans Blog and michaelkans.blog, 2019-2021. Unauthorized use and/or duplication of this material without express and written permission from this site’s author and/or owner is strictly prohibited. Excerpts and links may be used, provided that full and clear credit is given to Michael Kans, Michael Kans Blog, and michaelkans.blog with appropriate and specific direction to the original content.

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