a form of speech but it could be restricted due to its functionality (anti-circumvention that is prohibited per the DMCA) and not its content. The circuit court also considered Corley's fair use defense, as Corley argued that DeCSS allowed users to watch encrypted DVDs, which prior to that point had been impossible on Linux machines. The circuit court held that the specific facts of the present case were beyond the types of fair use that are permissible under the DMCA. According to the court, "the Appellants do not claim to be making fair use of any copyrighted materials, and nothing in the injunction prohibits them from making such fair use. They are barred from trafficking in a decryption code that enables unauthorized access to copyrighted materials." Impact and subsequent developments Both the district and circuit court rulings were controversial, and have been widely criticized by free speech advocates such as the American Civil Liberties Union and the Electronic Frontier Foundation, as well as the American Library Association, the author of The Boondocks, and others, due to upholding legal restrictions on expressive programming code. On the other hand, some media and content-owning organizations, such as the National Football League and Major League Baseball, supported the decisions. Corley initially planned to appeal the circuit court decision to the Supreme Court, but decided not to after consultation with his lawyers. Despite the courts' rulings, the DeCSS code is still widely available on the Internet. References Cryptography law United States copyright case law United States Court of Appeals for the Second Circuit cases 2001 in United States case law Universal Pictures litigation Digital Millennium Copyright Act case law DVD Copy Control Association 2600: The Hacker Quarterly