Archive for the 'Intellectual Property' Category

ISP Swears They Won’t Sell Your Browser History

Congress voted to take away your privacy rights when it comes to how internet service providers (ISPs) may use your data, and President Trump signed it into law. Just recently they officially repealed Obama era privacy regulations out of the FCC which required ISTs to get permission before selling a customer’s data–their browsing history, how long you spend on a given site, how often you visit a given site, app usage, email addresses, etc.

As you can imagine, removing these protections has resulted in a bit of a panic over how ISPs will proceed under these new rules. In an attempt to alleviate some of those fears, several of the largest ISPs have made statements promising not to sell the browsing history of individual clients. However, it’s hard to avoid that they have worded their promises very specifically in every case-so specifically that their promises almost amount to nothing. Let’s a take a look at the words of the biggest ISPs and what exactly they have (and haven’t) promised as well as what that means after the repeal of these privacy protections.

From The Horse’s Mouth

As mentioned, the rule changes had big ISPs quick to release statements to reassure their customers. Comcast released a statement saying “We do not sell our broadband customers’ individual web browsing history. We did not do it before the FCC’s rules were adopted, and we have no plans to do so.” Verizon’s Chief Privacy Officer told their users  “Verizon does not sell the personal web browsing history of our customers. We don’t do it and that’s the bottom line.”  An AT&T Vice President said “AT&T’s privacy protections are the same today as they were five months ago when the FCC rules were adopted. [We] will not sell your personal information to anyone, for any purpose. Period.”

These certainly sound promising, but they are very carefully worded. They promise not to sell “individual browsing history” or “personal information.”  However these promises, especially individual browsing history–perhaps intentionally–hit only the tip of the iceberg when it comes to how ISPs could and almost certainly will collect your data and metadata. The ISPs notably did not promise not to sell aggregate data (the most commonly way of selling metadata) or promise not to review and use the history for their own marketing-both potentially invasions of your privacy. Aggregate data is where they collect your browsing information, strip identifying information, then sell it along with the data of many other users–this is used for targeted advertising among other things. What’s more, once data is sold, those who buy it have no compunctions about how they must make use of that data.

This is far from a new concept, and at least one ISP has commented in the past that your browsing habits are already being collected and sold “by virtually every site you visit on the internet.”  This is true, the biggest websites-the Facebooks, Googles, and Amazons of the world-gather and sell staggering amounts of data from their users.

However, as true as it is, the situation with ISPs is fundamentally different. ISPs have the ability to monitor you literally the entire time you use the internet–something no website can boast. The difference in the level of intrusion between an ISP and any website is a matter of degrees. No website could hope to have the sheer level of access to your internet activity that an ISP has–which is literally all of it. What’s more, you can choose to go to a website–even sites as ubiquitous as Google have alternatives which do not track your internet use such as DuckDuckGo. Over half of people in the U.S. have only one choice of internet provider–a large part of the argument behind treating the internet as a utility like electricity or water. This means that your options would be to either have every action you take on the internet potentially monitored and monetized or have no internet whatsoever.

ISP’s Seem to Be Forgetting Their Own History

The promises of the ISPs are also a bit hollow in light of their own past behavior regarding your data. Not so long ago, AT&T was in hot water for misleading customers by describing an opt-in agreement providing consent to track and sell its users browsing history as a “discount.” Comcast was in the news less than a year ago saying that it should be able to sell its users’ browsing information.

Back in 2014, Verizon got in trouble for including an HTTP header for its mobile customers which allowed third-party advertising companies to gather information on your browsing habits-even if you used a private browsing mode or cleared your cookies. Even after her own recent statements reassuring customers, Verizon’s Chief Privacy Officer acknowledged that Verizon intends to use your browsing habits in ways other than outright sharing your personal browsing history–specifically targeted advertising and selling data in aggregate as mentioned above.

The States May Come to Your Rescue

In this day and age, the internet is basically a necessity. While Verizon’s transparency is at least to be applauded, the very idea that your every internet action could be tracked and sold–with the alternative of never using the internet–is unlikely an attractive prospect to many. However, there has already been a move towards bridging the gap created by the recently repealed privacy protections through state law. Just a few days back Minnesota passed a law requiring ISPs to receive express written consent from a user before harvesting any of your data.

Whether this trend will spread remains to be seen, the changes to your privacy protections all still fresh. Keep an eye on state legislature, it seems likely that protecting your browser history will quickly become a hot button issue.

Tesla is in Hot Water Over Self-Driving Cars

When you about technologies of today which were once thought of as the realm of science fiction you think about 3-D printing, you think the levels we’ve reached with AI, and on that note–you think of self-driving cars.  From the silver screen to reality, the past couple years have seen enormous leaps forward in the technology behind autonomous vehicles.  That surge in technology, however, has been accompanied by a surge in lawsuits as states scramble to figure out laws to properly regulate how self-driving cars can be made, handled, and sold.  Uber has seen many a legal challenge-mostly due to their unwillingness to purchase permits-as they have rolled out self-driving cars. When Google was first testing their self-driving technology, they narrowly missed traffic tickets after a police pulled their test car over.  The reason?  The new car was only safe to drive at below 25 miles per hour so it was going 24 in a 35 zone-the officer didn’t end up giving the car a ticket.  Now, having just barely entered the market, it seems like it’s Tesla’s turn to potentially face some legal hot water over the technology.

Tesla unveiled its self-driving technology back in 2014.  However, it wasn’t until October of last year that cars with the feature were actually sold.  The feature has been dubbed Autopilot 2 and costs about $5,000 extra.   Just a few days ago, a class action lawsuit was initiated against Tesla.  The suit alleges that Tesla’s driverless technology is so unsafe as to violate consumer protection and unfair practices laws.  As the technology becomes more commonplace, lawsuits like these were nearly inevitable.  With that in mind, let’s take a look at the lawsuit against Tesla and the state of the law when it comes to driverless cars.

TeslaIs Autopilot Dangerous?

The lawsuit, brought in Federal Court in California’s Northern District, includes plaintiffs from Colorado, New Jersey, and Florida.  It includes allegations of violations of consumer protection laws of all three of those states.

The lawsuit accuses Tesla of many illegal practices.  It alleges that they are selling “vaporware,” a colloquial term for software that is advertised but non-existent.  The lawsuit alleges the Tesla advertised many upcoming safety and functionality features of their self-driving software that simply never materialized. They also say that salesmen at Tesla dealerships told plaintiffs that features that were upcoming were already part of the software.  Instead of the software they were promised, the lawsuit alleges that the using the Autopilot 2 software as is is dangerous-comparing the function to the quality of driving one would expect from a drunk driver.  They point to a specific review of the software which described the car serving across double yellow lines and nearly hopping the curb.  They point to other reviews which describe sudden hard stops at 50 MPH.  They describe plaintiffs as flabbergasted to learn that their cars couldn’t yet change lanes or exit the freeway without assistance, despite apparently being told this function was available in Tesla marketing materials.  They also describe individual experiences of plaintiffs where their cars behaved erratically while on autopilot mode.

Based on this, the lawsuit accuses Tesla of false and misleading advertising-something protected against in essentially every consumer protection statute; along with false advertising, and protections against defective products.  The statutes in the case follow the usual requirements for a claim of false advertising: knowingly making false representations about a product, with the capacity or tendency to deceive the consuming public and convince them to buy the product, with the intent to get people to buy that product.

The lawsuit also charges Tesla with violations of the Motor Vehicle Safety Act (requiring immediate action from manufacturers where a safety defect poses an unreasonable risk of death or injury in an accident) and fraud by concealment (the deliberate hiding or suppression of an important fact with the intent to deceive).

So basically, the lawsuit is saying that the marketing materials of Tesla’s Autopilot 2 feature drastically overstated what the software was actually capable of-both as initially delivered and by missing self-imposed deadlines to provide improved functionality-instead giving buyers a product so incomplete as to be dangerous to use.  If true, this is a classic case of consumer fraud.  However, as you might imagine, Tesla has a very different description of the situation.

First and foremost, Tesla says that the lawsuit misrepresents many of the facts as to both their advertising and the functionality of Autopilot 2.  In fact, they say that many of the features that are said to be unavailable in the lawsuit actually are available and that the features that the plaintiff’s thought would be there were clearly labeled as upcoming in marketing materials

With such diametrically opposed versions of the facts, it’s hard to say exactly what the chances are of a lawsuit like this.  As you might imagine, both side’s versions of the facts are likely to hand them a swift victory.  Should the plaintiffs win, their lawsuit asks for Tesla to purchase back their cars and provide unspecified amounts of damages-likely an amount determined by the individual consumer fraud statutes-for their advertising practices.  We’ll have to see how the facts shake out before making a prediction one way or another.  Tesla’s website does indeed have descriptions of many elements of Autopilot 2 as upcoming.  However, the question is what these particular clients were told and the particular marketing materials they were provided.  What’s more, while Tesla did miss a number of deadlines for improving Autopilot 2 to bring the product into parity with other self-driving vehicles, their marketing materials do seem to say that they cannot always hold to deadlines due to the extensive work and regulatory approval required for self-driving cars.  However, it’s still too early to say exactly who is going to come out on top here.

The Law on Driverless Cars

Part of the problem with lawsuits surrounding autonomous vehicles is that the law is still trying to catch up to technology somewhat.  That being said, there has been a boom in laws regulating self-driving cars.  Not so long ago, Michigan passed some of the most comprehensive-although quite lenient-laws on the issue seen to date.

This is far from the only set of laws regulating self-driving cars.  California, Arizona, Alabama, Pennsylvania, Virginia, Nevada, Utah, North Dakota, Louisiana, Tennessee, Florida, Massachusetts, Washington D.C., and Virginia all have laws or executive orders in place regulating the use of autonomous vehicles to some extent.  In September of 2016, even the federal government–through the National Highway and Transportation Safety Administration–released an updated set of suggestions providing guidance for states in making laws.

Tesla, and other manufacturers of self-driving cars, are entering a market ahead of its time; but the laws are catching up.  More and more legislation is being introduced to figure out how to handle these kind of vehicles.  However, as this lawsuit suggests, we need to make sure that the technology is there and up to snuff before it reaches the public.  As it stands, both sides are so far apart that it’s hard to take much in the way of facts away from the pleadings and their response.  At a minimum, we can see that it is a technology in progress and-like any technology in process-we have to be careful how we implement it to ensure the safety of the public.

Trump Repeals Internet Privacy

For someone who ran for President on a platform promising to “Make America Great Again,” he sure has done a lot of things to make Americans feel like we’ve moved backward, not forward. Since January 20th, President Trump has turned away refugees, encouraged the defunding of Planned Parenthood, and acted personally and professionally sexist toward women. His new bill that he quietly signed into law repeals internet privacy rules passed last year by the Federal Communications Commission (“FCC”) under the Obama administration. It seems like another huge step backward.

TrumpWhat Did the Internet Privacy Law Do?

Adopted on October 27, 2016 and issued on November 2, 2016, the FCC established a rule that protected the privacy of customers of broadband and other telecommunication services. It also gave broadband customers more choices, transparency, and security over their personal data. The rule empowered users to decide how data was used and shared by broadband providers. In other words, it forced internet service providers (Comcast, Xfinity, AT&T, and Verizon, to name a few) to ask consumers before it collected certain personal information.

Why Is the Privacy Rule Important?

The rule has not gone into effect yet, and it won’t go into effect now that Trump has repealed it. However, the law was intended to require more transparency by internet service providers. Companies use data to target advertising. This is known as data mining, sometimes known as data or knowledge discovery. It is the process of analyzing data and summarizing it into useful information. The information is then sold from the internet service providers to specific companies that target their advertising to the consumer based on their data.

That was complicated, so let me give you an example. I’m a new mom and my internet service provider can ascertain this information through my search habits. Let’s say they sell that information to Babies R’ Us, Carter’s, and other baby stores, who then sends me coupons for various deals on car seats, baby toys, and diapers. My internet service provider just profited off of invading my privacy.

Why We Haven’t Heard about the Law

Trump has been acting like a bull in a china shop, signing controversial executive orders with big hoopla and making unfounded allegations about his predecessor President Obama. Why, then, have we heard very little about his decision to repeal the internet privacy law, especially when it has such a huge effect on the American people?

It seems that the Trump administration tries to sneak anything controversial or unpopular quietly into law. That way, there’s less backlash.

Should We Be Worried about Net Neutrality?

In 2014, the FCC released a plan that would have allowed internet service providers such as AT&T, Comcast and Verizon to charge more depending on what the consumer uses. For instance, instead of providing things like Facebook and Youtube for free so long as you have internet access, big companies want to sell package deals that allow one access to Facebook and Youtube only if they use their company and buy a particular package. The proposal was met with so much resistance that it was shelved.

Net neutrality is the principle that treats all websites and services the same. Specifically, it prevents certain internet service providers from charging more for specific content. It prevents companies like Comcast from charging users for a package subscription to Netflix and Hulu.

People are concerned that Trump’s repeal is just one step away from the end of net neutrality, and they should be concerned. Trump is a well-known businessman. His failed Trumpcare attempted to create huge tax breaks for the super wealthy. He’s appointed cabinet members who primarily favor big business. It should come as no surprise that this President may attack net neutrality when he has consistently shown preferential treatment toward big business at the expense of “the little people.”

Net Neutrality: Is This the End?

Towards the end of last month, FCC Chairman Ajit Pai began to take steps to block elements of an order from Obama administration dealing with privacy and net neutrality–the effects of which were set to take effect at the beginning of this month.  Since then, with many already sounding the death knell for net neutrality, the FCC has softened its stance slightly but many remain concerned about the future of net neutrality as a policy as Mr. Pai continues to take steps with the potential to weaken the steps the Obama administration took.

We’ve explored the Obama administrations strides in strengthening net neutrality and an open internet in the past–from the FCC’s Open Internet Order in February of 2015 to last October’s vote limiting the amount of information, types of information and manner in which your internet service provider (ISP) can mine your personal data.  Both of these changes were opposed by Mr. Pai when they were introduced.

Since the advent of the Trump Administration, and the appointment of Mr. Pai, there has been a notable pivoting towards deregulation of ISPs.  With this mind, let’s take a look at what the regulations being affected do, and what their likely future will be.

The FCC’s Approach to Net Neutrality and What it Means?

The Open Internet Order is almost certainly the single most substantial advancement towards net neutrality our government has taken in a decade–finally providing a means of actually enforcing net neutrality as a concept.  Net neutrality, for those unfamiliar with the term, is the concept that internet providers should treat all data on the internet equally—regardless of source.  All information passing through broadband networks and backbone networks should be given equal priority to the extent possible without effecting function.  For instance, text on a website can have data packets arrive in any order while video and audio must arrive in a specific order and in a timely fashion to function—net neutrality doesn’t require companies to ignore the concerns of functionality.

net neutralityWhat net neutrality does is prevent blocking of content, throttling content (intentionally slowing down some content or speeds up others), and paid prioritization where some services are stuck in a “slow lane” because they do not pay a special fee. Essentially, it keeps ISPs in the business of charging users for internet connection as opposed to charging edge providers for users while the people buying internet service from them suffer.

The Open Internet Order, a 183-page behemoth, changed the classification of ISPs to that of a public utility such as telephone services–often known as common carrier status.  It also sets forth five rules that ISPs must abide by:

  1. ISPs “may not block access to legal content, applications, services, or nonharmful devices.” In other words, ISPs can’t block access of any legal user to any legal website.
  2. ISPs can’t throttle, or slow down, the delivery of any legal internet traffic.
  3. ISPs can’t make a company pay to give its data packets priority delivery or prioritize the delivery of data from their own services.
  4. ISPs can’t adopt practices which would harm consumers or people providing services on the internet.
  5. ISPs must offer transparent specifics on how they run their broadband networks.

The policy also provides for an exception for reasonable management of a broadband network. ISPs are allowed to prioritize data so as to keep things running smoothly, but cannot use this for their own commercial advantage.

Getting to this point, however, was quite an uphill battle, both in the courts and within the FCC itself. The FCC initially proposed much weaker regulations.  However, the combination of a call from then-President Obama for stronger rules, 4 million comments filed with the FCC, and protesters who went so far as to sit in the FCC Chairman’s driveway and demand a stronger policy, all came together to convince the FCC to pass the final version of the Open Internet Order.

This progress seemed to come to a standstill after a February 24th statement from the FCC declaring that Mr. Pai had taken steps to block the privacy rules mentioned above–changes which were set to go into effect at the beginning of this month.  This statement was widely taken as a first step towards rolling back the clock on net neutrality and common carrier status for ISPs–many speculated an ultimate goal of deregulating the market as much as possible.  Indeed, the language of the statement included commentary noting that Mr. Pai intended to “harmonize the FCC’s privacy rules for broadband providers with the [Federal Trade Commission]’s standards for others in the digital economy.”  This was taken as an implication that Pai aimed to remove common carrier status from ISPs–treat them the same as others in the digital economy.  This would basically neuter the Open Internet Act by undermining the legal premise on which it applies authority to ISPs in the first place.

The Future for Net Neutrality

The fears of those in support of net neutrality, an end to net neutrality as a concept, does not appear to be in the cards at this point.  Instead the likely outcome, based on the comments coming out of the FCC and those reporting on the FCC, is a substantial weakening of the Open Internet Order.

It is still unclear exactly what form this would take.  However, it has been implied that it would likely to see changes allowing ISPs to prioritize data in certain situations–basically creating carveouts to the general rule.  There’s no particular indication as to what these carveouts might include, but it is easy to imagine a situation where exceptions could swallow the rule.

A large part of why Mr. Pai is likely to take this approach is that the Open Internet Order is already final and has endured the rigors of fierce court challenges; precedent is on its side.  This means that just killing the rule would be fairly difficult for the FCC.  If the rule was to be fully stripped away, it would most likely involve an act of Congress explicitly doing so.  However, Congress and the Trump administration do not seem to be making such legislation a priority.

The argument against net neutrality and the Open Internet Order has always been that it takes away ISP’s motivation to improve the speed and capacity of their networks–although precious little evidence of this has actually been produced.  Frankly, the dangers of allowing ISPs to control access on the internet seem far greater.  The Open Internet Order doesn’t seem to be on the chopping block, but we’ll have to see if what we’re left of the Open Internet Order will actually accomplish what it set out to do.

President Trump Strips Privacy for Non-Citizens

With the furor over President Trump’s immigration ban reaching fever pitch around the nation, conversation around his many other executive orders has died down substantially–especially considering how many we’ve seen in the last few weeks.  However, these many orders have ushered in sweeping changes.  Among these changes, buried in one of these many orders, is a drastic change from recent years in how the protections of the Privacy Act apply to immigrants, refugees, and those abroad.

On January 25th, Trump issued an executive order titled “Enhancing Public Safety in the Interior of the United States.”  The order is primarily focused on changing policies as to how immigration laws would be enforced.  However, embedded within the order was a section which strips many of privacy rights.

Section 14 of the order, titled “Privacy Act,” reads as follows: “Agencies shall, to the extent consistent with applicable law, ensure that their privacy policies exclude persons who are not United States citizens or lawful permanent residents from the protections of the Privacy Act regarding personally identifiable information.”

The changes have the potential to remove privacy protections from not only green card, visa holders, and would be immigrants–but also citizens of every other county.  Thus, this order has led to serious concerns both in terms of the dangers created for some by this loss of rights and the potential to shatter treaty agreements with the EU undermine companies big and small doing business abroad that requires data collection.  In order to explore both these concerns, let’s first look at privacy rights and what exactly the Privacy Act itself does.

PrivacyUnderstanding the Privacy Act and Privacy Rights

The Supreme Court has ruled that the constitutional right to privacy is implied through a combination of the 1st and 14th Amendments.  However, the exact breadth of this right is a bit more amorphous.  The privacy rights you have are mostly a product of combination of federal statutes and state law–most notably in Alaska, Arizona, California, Florida, Hawaii, Illinois, Louisiana, Montana, South Carolina and Washington where the right to privacy is guaranteed by the state constitutions.  Among the federal statutes guaranteeing privacy rights, the U.S. Privacy Act of 1974 provides some of the broadest protections.

The Privacy Act prevents government agencies from disclosing personally identifiable information about U.S. citizens and lawful permanent residents without the consent of the person whose information they are disclosing.  Personally identifiable information is a concept which has seen many different definitions under the law.  However, here it can be understood to refer to information that, alone or in conjunction with other information, could be used to contact, identify, or find any given person.  The Privacy Act also allows a person to request access to information on them and request corrections to any mistakes.  There are a number of (occasionally quite broad) exceptions to these protections such as when the information is disclosed for law enforcement purposes, national security purposes, census taking, or congressional investigations.

While the Privacy Act doesn’t require the inclusion of people other than U.S. citizens or lawful permanent residents, since 2007 it has been the policy of the Department of Homeland Security and other agencies to extend its protections more broadly and include non-citizens.   In 2014, a policy directive signed by President Obama also imposed limits on the ability of U.S. agencies to use intelligence collected in bulk “whatever their nationality and regardless of where they may reside.”  Trump’s order rolls back the clock on these changes–and governments abroad have taken notice.

Privacy Shield: Potential Problems for Businesses Big and Small?

Among the governments keeping an eye on our changes in privacy policy, the EU is certainly going to be keeping a particularly close eye.  This is because, in the wake of the Edward Snowden leaks and many complaints to the European Court of Justice (ECJ) of privacy violations by companies such as Facebook, the ECJ decided in 2015 that the Safe Harbor arrangement between the EU and US was no longer valid.  These Safe Harbor Privacy Principles allowed U.S. companies whose business involved storing the data of EU citizens to operate without fear of lawsuit so long as they enacted policies complying with the principles.  Without these protections, over 1,500 businesses–including many of our largest tech giants–were left in legal limbo.

With so many businesses and so many jobs at risk, the U.S. was quick to begin negotiations to establish a new agreement setting up a framework of privacy policies within the U.S. that could restore the protections the Safe Harbor Privacy Principles provided.  Last year, these negotiations finally culminated into an agreement known as the EU-US Privacy Shield.

The Privacy Shield hinges on agreements by the U.S. to provide a certain level of privacy protection to EU citizens.  Trump’s order would, at least at first glance, remove these protections–at least when it comes to the Privacy Act.  This has understandably led to concern and outcry from businesses worried that order has, in its haste, torpedoed the Privacy Shield and their businesses along with it.

Fortunately, this is not the case.  The reason being that the order acts “consistent with applicable law;” as it must because executive orders do not have the power to overturn laws enacted by Congress.  When it comes to the Privacy Shield, that applicable law is the Judicial Redress Act.  This Act specifically extends the protections of the Privacy act to citizens of 26 countries, including the EU, and provides access to U.S. courts should they need to sue over any violations.  The order cut it close however–the protections of the Judicial Redress Act were signed into effect by the previous Attorney-General just three days before Trump took office and only truly became law on February 1st of this year.

EU officials have made statements announcing that the Privacy Shield is not affected by rights under the Privacy Act–instead relying on the Judicial Redress Act.  However, they have made it very clear that Trump’s executive order has raised alarm bells and that they will be keeping a close eye on how privacy rights develop within the U.S.  This means that, even though this particular order hasn’t set businesses adrift just yet, if your business operates internationally through the internet–specifically if it services EU citizens–it’s going to be very important to keep an eye for any developments when it come to Privacy Shield protections.

Dreamers in Danger

While the Privacy Shield may not be in danger, the order certainly strips privacy protections from many individuals.  In some cases, this loss of protection has created a particularly awful situation–the potential to turn a dream into a nightmare.

Dreamers is a term commonly used for those who would be granted citizenship under the Development, Relief, and Education for Alien Minors Act or DREAM act.  The act, which would have provided a path to legal citizenship to younger illegal immigrants brought to the U.S. as child, has been introduced in Congress several times but has never succeeded in becoming law.  However, in 2012, President Obama implemented the Deferred Action for Childhood Arrivals (DACA) program through a policy directive.  The directive allowed those who might have applied for citizenship under a DREAM act to instead apply for a stay on deportation.  The act also provided those who applied to receive a social security number and apply for a work visa.  Those who applied under the directive where called Dreamers and over 700,000 people benefitted from DACA.

However, applying for DACA requires an applicant to provide quite a bit of personal information–from addresses and phone numbers to what school the young person attends.  Under Trump’s executive order, all protections on this information have been stripped away.  Immigration and Customs Enforcement need only ask to access information provided in hopes of obtaining a visa and turn that information towards deporting those people.

Uncertain Orders Affecting Sweeping Areas of Law

President Trump’s order has, much like his immigration ban, applied broad strokes to complicated areas of law and left the public puzzling over its exact breadth and struggling to pick up the pieces.  For example, it’s still unclear whether this order is meant to revoke privacy rights for people around the country with dual citizenship.  As time passes, lawsuits will certainly develop to figure out the exact boundaries of this order.  However, for now, we are simply left to assume the broadest possible interpretation–stripping privacy rights from an enormous number of people–from foreign students to refugees to dreamers.