Amendment and various court decisions (e.g. Near v. Minnesota) give very broad rights to anyone to publish a newspaper or other publication, and severely restrict government efforts to close down or censor a private publication. In fact, when censorship attempts are made by government agencies, they are either done in clandestine fashion (to keep it from being known the action is being taken by a government agency) or are usually ordered stopped by the courts when judicial action is taken in response to them. A publication must, in general, be committing a crime (for example, reporters burglarizing someone's office to obtain information about a news item); violating the law in publishing a particular article or issue (printing obscene material, copyright infringement, libel, breaking a non-disclosure agreement); directly threatening national security; or causing or potentially causing an imminent emergency (the "clear and present danger" standard) to be ordered stopped or otherwise suppressed, and then usually only the particular offending article or articles in question will be banned, while the newspaper itself is allowed to continue operating and can continue publishing other articles. In the U.S. the term "underground newspaper" generally refers to an independent (and typically smaller) newspaper focusing on unpopular themes or counterculture issues. Typically, these tend to be politically to the left or far left. More narrowly, in the U.S. the term "underground newspaper" most often refers to publications of the period 1965–1973, when a sort of boom or craze for local tabloid underground newspapers swept the country in the wake of court decisions making prosecution for obscenity far more difficult. These publications became the voice of the rising New Left and the hippie/psychedelic/rock and roll counterculture of the 1960s in America, and a focal point of opposition to the Vietnam War and the draft. Origins The North American countercultural press of the 1960s drew inspiration from predecessors that had begun in the 1950s, such as the Village Voice and Paul Krassner's satirical paper The Realist. Arguably, the first underground newspaper of the 1960s was the Los Angeles Free Press, founded in 1964 and first published under that name in 1965. 1965–1973 boom period According to Louis Menand, writing in The New Yorker, the underground press movement in the United States was "one of the most spontaneous and aggressive growths in publishing history." During the peak years of the phenomenon, there were generally about 100 papers currently publishing at