Complete list of ACLU v. Reno Plaintiffs and their Affidavits

Document Date: March 19, 1997


The American Civil Liberties Union (ACLU), headquartered in New York City, is a nationwide, nonpartisan organization of nearly 300,000 members dedicated to defending the principles of liberty and equality embodied in the Bill of Rights.

In addition to its legal advocacy to uphold the Bill of Rights, the ACLU has long devoted considerable resources to public education about civil liberties. Since 1993, the ACLU’s public education efforts have included extensive online resources that offer electronic copies of ACLU publications, reports, court briefs, news releases, and other materials related to the ACLU’s legal, legislative, educational and advocacy work. The ACLU maintains its online presence through America Online and through the World Wide Web. Many of the ACLU’s online databases contain material with sexual subject matter or vulgar language. Examples include copies of ACLU court briefs in cases involving obscenity, arts censorship, and discrimination against gays and lesbians. Indeed, the ACLU has posted the text of George Carlin’s “seven dirty words” comic monologue which the Supreme Court ruled “indecent” in the 1978 Pacifica case, and which the Court itself reproduced as an appendix to its opinion.

The ACLU also hosts unmoderated online discussion that allows citizens to express their uncensored views on a variety of civil liberties issues and to interact with ACLU staff or featured speakers. Many of the communications in these groups have sexual content or vulgar language; for example, a discussion of masturbation in the context of the firing of former Surgeon General Jocelyn Elders; a discussion of the content of Howard Stern’s best-selling book, Private Parts; a discuss ion of why the word “fuck” has such expressive power; and a discussion of the defense of pornography and other erotic expression under the First Amendment.

Through its online resources, the ACLU also distributes information to and receives information from its affiliates, clients, members and the public, regarding how women can obtain abortions or abortifacient drugs, when doctors can perform abortions, the legal restrictions on obtaining and performing abortions in different states, and other information pertaining to specific abortion procedures.

Internet: World Wide Web: & America Online: keyword: ACLU

ACLU Affidavit


The AIDS Education Global Information System (AEGIS) is a nonprofit corporation based in California that operates a free computer bulletin board system (BBS) with one of the largest online archives in the world of information on HIV and AIDS.

AEGIS offers vital information about HIV and AIDS to people in many parts of the world who have no other access to educational material about the disease. Documents available from the AEGIS bulletin board include materials from the Centers for Disease Control, Gay Men’s Health Crisis, AIDS Treatment News, and Body Positive Online Magazine. AEGIS also sponsors online discussion groups for people with AIDS or HIV, in Dutch, French and German in addition to English. Persons with HIV/AIDS use these online forums to share experiences with other victims of the disease.

Medical, social welfare, and other public interest professionals also use the online forum to distribute information about the disease and to answer questions posed by users. Many people, including those who fear that they may be infected with HIV/AIDS, use AEGIS to get information about the disease because they can do so anonymously.

BBS: 714-248-2836

AEGIS Affidavit


BIBLIO BYTES, based in Hoboken, New Jersey, produces electronic books for sale over the World Wide Web, including romance novels, erotica, classics, adventure, and horror stories, some of which contain sexually explicit or vulgar language. BIBLIO BYTES requires a credit card for the purchase of its electronic books.

Current titles which contain this type of language include Harlan Ellison’s collection of short stories, Love Ain’t Nothing But Sex Misspelled, and John Anderson’s book Panaflex X, a fictional account of a woman trying to get out of the pornography industry.

BiblioBytes Affidavit


ClariNet, headquartered in San Jose, California, publishes an electronic newspaper available on the World Wide Web, including news articles, columns, financial information and a humor section, with 1.2 million paying subscribers.

The news articles are taken from the same wire services from which print newspaper obtain their stories, but, unlike some print newspapers, ClariNet rarely censors the articles. ClariNet has occasionally published articles that use the common Anglo-Saxon four-letter words. It has also published articles that explicit describe rapes and sexual assaults, sometimes more graphically than the same stories in most print newspapers. ClariNet also publishes a humor section accessible through its Web page, with jokes that include some vulgar language or sexually explicit material.

Internet: & rec.humor.funny (Usenet)

ClariNet Affidavit


Critical Path AIDS Project, Inc., based in Philadelphia, Pennsylvania, is an AIDS treatment and prevention information project that offers AIDS treatment and safer sex information via a free computer bulletin board, electronic mailing lists, and a page on the World Wide Web. Critical Path is also an Internet Service Provider, providing free access to the Internet for both organizations and individuals in the Philadelphia area.

Critical Path’s online resources include AIDS prevention and treatment information, which reach youths and adults at risk for AIDS in some of the most underserved communities in the nation. This information will soon be offered in eight different Asian languages. Critical Path also offers Web subsites to such nonprofit groups as We the People (a large multiracial organization of HIV-positive individuals), Prevention Point (a needle exchange program), Fight the Right (a political action network); and will soon be providing a subsite to the Youth Health Empowerment Project, a safer sex outreach organization specifically targeted to teenagers.

The Critical Path AIDS Project Web page links directly or indirectly to thousands of databases on all 50 states and countries all over the globe. In the fall of 1995, Critical Path was receiving about 10,000 access requests per day from all over the world for information on its system.


Critical Path Affidavit


Computer Professionals for Social Responsibility (CPSR) is a nonprofit national corporation based in Palo Alto, California. CPSR has 22 chapters in 14 states and approximately 1,550 members.

As technical experts, CPSR members provide the public and policy makers with realistic assessments of the power, promise, and limitations of computer technology. As concerned citizens, CPSR members direct public attention to critical choices concerning the application of computing and how those choices affect society.

CPSR maintains a site on the World Wide Web, hosts several on line discussion groups and maintains a number of listservs. CPSR’s Web site is linked to a number of other Web sites, gophers and computer networks that contain information that is of medical or health value but that might be considered indecent or patently offensive. One of the listservs, Cyber Rights, includes discussions of issues of censorship and the application of indecency rules to cyberspace that use strong language and/or quote matters that have been censored. Other listservs and discussion groups also discuss issues of censorship and contain strong language.

CPSR believes that it is important that social responsibility be promoted among young people who are learning to use online resources and that access to the CPSR resources would advance this goal.


CPSR Affidavit


The Electronic Frontier Foundation (EFF), based in San Francisco, California, is a nationwide, nonpartisan organization of approximately 3,500 paying individual members that is committed to defending civil liberties in the world of computer communications, to developing a sound legal framework for that world, and to educating government, journalists and the general public about the legal and social issues raised by this new medium.

Founded in 1990, EFF maintains extensive online resources both on forums it runs with online service providers and through its own World Wide Web “home page.” These resources include articles, court cases, legal papers, news releases, newsletters, and excerpts from public discussions related to EFF’s legal, legislative, educational and advocacy work. EFF also maintains eight mailing lists, both for specific civil liberties and activist activities, and for informing the public about its activities. The primary mailing list has a subscriber base of about 7,500 individuals, and the Web page receives between 70,000 and 80,000 hits per day (a hit is an instance of individual access).

Since virtually all interactions on the Internet or other computer networks have a significant communicative element to them, EFF’s policy positions and the discussion forums it sponsors strongly emphasize freedom-of-speech concerns, including concerns about the contours of obscenity law and liability and about the scope of the Federal Communications Commission’s jurisdiction to regulate so-called “indecency.”


EFF Affidavit


Electronic Privacy Information Center (EPIC), based in Washington, D.C., is a non-profit research organization that collects and distributes information concerning civil liberties and privacy issues arising in the new communications media. EPIC is a project of the Fund for Constitutional Government, also based in Washington.

EPIC’s electronic resources, disseminated through a website and through a listserver mailing list, include materials concerning free speech, censorship, and privacy issues, some of which contain sexually explicit speech or vulgar language. For example, the EPIC web site contains the text of the Supreme Court’s opinions in FCC v. Pacifica Foundation, and Cohen v. California, both of which contain common “four-letter words.” The web site also contains poems written by subscribers to America Online which were censored by AOL management because of “vulgar or sexually oriented language.”


EPIC Affidavit


Jonathan Wallace, a resident of New York City, publishes an online monthly newsletter The Ethical Spectacle, under the pen name Jonathan Blumen. The newsletter, available through the World Wide Web, examines the intersection of ethics, law and politics in society.

Past issues have included articles on human experimentation by the Nazis at Auschwitz, and the morality of pornography. An upcoming issue will excerpt the writings of James Joyce, Henry Miller, William Burroughs, and other authors whose works include explicit sexual content and vulgar language.


Ethical Spectacle Affidavit


Human Rights Watch, based in New York City, is a leading international human rights organization that monitors human rights abuses in over 70 countries. HRW uses online services to communicate with human rights activists in the field and to distribute its human rights reports worldwide through a gopher site on the Internet. The organization has found online communication to be a powerful new way for human rights activists and dissidents to communicate and organize away from the watchful eyes of repressive governments.

Human Rights Watch’s online resources include testimony from victims of forced trafficking in prostitution in Thailand and India, reports on systematic rape in Bosnia, and reports of sexual abuse of female prisoners in the United States. These and other reports contain graphic language and subject matter. For example, a July, 1995 report on slavery in Pakistan described tortures that are used to intimidate bonded laborers, such as beating of the genitals and rape. Removal of material considered “indecent” or “patently offensive” from direct victim testimony in HRW’s reports would diminish its effectiveness in advocating for an end to human rights abuses.

Internet: gopher://gopher

Human Rights Watch Affidavit


The Journalism Education Association, headquartered in Manhattan, Kansas, is one of the largest national organizations of high school journalism teachers and publication advisors. Founded in 1924, JEA has almost 1600 members, who increasingly use online communications as part of instruction in high school journalism classes or as a research and teaching tool for students who write for school publications.

JEA members attempt to give students the skills to enable them to engage in independent online research, which might include for example, evidence of war crimes in Bosnia which might include graphic descriptions of rape.

JEA serves journalism educators through opposing censorship of student expression, creating aids for curriculum and instruction, involving minority students, promoting the use of technology, and organizing other professional activities.

JEA Affidavit


Declan McCullagh, doing business as Justice On Campus, operates a nonprofit online information clearinghouse on issues of student free speech, through a web server located at the Massachusetts Institute of Technology in Cambridge, Massachusetts. McCullagh, who lives in Pittsburgh, Pennsylvania, also maintains a list for people interested in censorship issues called “fight-censorship.” The list includes many journalists (New York Times, WP, Time, Newsweek, Boston Globe, Philadelphia Inquirer, Wired Magazine). To subscribe, send mail to

Justice on Campus receives about 150 visits to its Web site daily. Although the site is housed on a private computer attached to the MIT network, McCullagh maintains editorial control over communications posted on the site. Justice on Campus has been recognized as serving an important educational purpose, and its materials are assigned reading in one course at the Massachusetts Institute of Technology. The “fight-censorship” subscriber list includes explicit material that has been subject to censorship by others.

E-mail: Internet:

Justice on Campus Affidavit


Brock Meeks, a resident of Fredericksburg, Virginia, is the columnist and editor of CyberWire Dispatch (CWD), a popular and irreverent online political news column available on the World Wide Web and through a computer subscription program called a listserv. He is the Washington correspondent for Wired magazine and also writes a column for HotWired, the online publication.

As editor and publisher of CWD, Meeks addresses many political and cyberspace issues, including Congressional action to regulate and censor the Internet. CWD often employs vulgar and graphic language to make a point about government censorship efforts.


CyberWire Dispatch Affidavit


The National Writers Union, based in New York City, is a 4,200-member labor union for freelance writers founded in 1983. Its members include investigative journalists, trade book authors, technical writers, political cartoonists, poets, textbook authors, and multimedia contributors.

NWU maintains a site on the World Wide Web, as well as an online archive of NWU-related documents, and offers two online mailing lists to which any person, whether or not an NWU member, can subscribe. Some of the material on the NWU’s various Web sites and mailing lists contain sexually explicit subject matter or vulgar words — for example, heated debates about homosexuality, and back issues of the NWU’s newsletter, which include explicit articles about censorship, obscenity and indecency law, and gay rights.

Many NWU members use computers to communicate with each other via private e-mail, to exchange information, and to post literary work, some of which is sexually explicit or contains vulgar words. For example, one NWU member, Robert B. Chatelle, maintains a Web page that contains links to erotic fiction that he has written.

Internet: and

NWU Affidavit


PLANNED PARENTHOOD FEDERATION OF AMERICA (PPFA) is the leading national voluntary health organization in the field of reproductive health care. PPFA and its 157 affiliates engage in public education and advocacy concerning safe and legal access to all reproductive health services, including abortion; and its affiliates provide these services.

PPFA operates a site on the World Wide Web that provides a broad range of information relating to reproductive health. PPFA’s site also provides educational and graphic information about all facets of reproductive health, from contraception to prevention of sexually transmitted infections, to finding an abortion provider, to information about which Planned Parenthood affiliates have been providing abortions through the use of the drug mifespristone.

The educational information includes illustrations of how to place a condom on a penis, and of male and female genitalia. The information PPFA presents is intended to be accessible to minors who seek it; and therefore frequently employs vernacular terminology, such as “cum” when referring to semen or ejaculation.

PPFA’s Web site also provides an e-mail service, through which users can address questions to PPFA on subjects such as abortion, contraception, prevent of sexually transmitted infections, and sexuality. PPFA responds with complete information.


PPFA Affidavit


Queer Resources Directory (QRD), with computer distribution points throughout the United States, the United Kingdom, New Zealand, and Israel, is one of the largest online distributors of gay, lesbian and bisexual resources on the Internet.

QRD is accessed approximately one million times a month and is distributed through several co-servers around the world. QRD contains links to online media, events, cultural information, business, legal, political and workplace issues, and gay, lesbian and bisexual organizations. The topics covered include parenting, families, marriage, youth organizations, religion, and HIV/AIDS. Some of the material is sexually explicit, for example, discussions of safer sex and human sexuality, and publications such as Hothead Paisan (a satiric comic book about the adventures of a homicidal lesbian terrorist) and Cuir Underground (a magazine covering events and people in the leather and fetish community).

QRD believes that its online materials are valuable to gay and lesbian teenagers who are struggling with feelings of confusion or isolation, as well as to straight youth who want information about homosexuality. It also believes that it is essential that people be able to access its system anonymously.


Queer Resource Directory Affidavit


Stop Prisoner Rape, Inc. (SPR) is a nonprofit organization based in New York City dedicated to combating the problem of prisoner rape. SPR maintains an extensive and award-winning World Wide Web site that contains, among other things, graphic and uncensored accounts of actual rapes, written by the victims themselves. The accounts are usually presented in the form of letters written in “street language” and using a vocabulary which might be considered “indecent” or “offensive.”

The purpose of SPR is to provide education, information and advocacy regarding sexual assaults in the nation’s prisons, jails, and juvenile institutions. It provides encouragement and advice to survivors, as well as counseling, information and legal support. In 1995, “Impact Online,” which gives awards for outstanding nonprofit Internet sites, named the Stop Prisoner Rape site as one of the 30 best nonprofit sites on the Web and the best for prison issues. In January 1996, Internet by Point Survey designated the site as one of the “Top 5% of the Web.” The SPR site receives about 5,000 electronic visits a week.

SPR believes it is essential to allows minors, who are among the most likely victims of rape behind bars, to continue to access this site. A significant portion of the SPR site includes recollections of individuals who were raped as minors while incarcerated with adults or in juvenile detention centers. The sharing of these experiences is invaluable to the many minors who have been imprisoned or who may be considering a lifestyle which would greatly increase their risk of incarceration. Facing up to the realities of sexual assault and the particular targeting of youths for rape may induce second thoughts, the group believes, about future criminal activities.


Stop Prisoner Rape Affidavit


John Troyer, a resident of San Francisco, California, maintains The Safer Sex Page, a large archive on the World Wide Web containing educational information on safe sex. The Safer Sex Page is accessed by more than 35,000 people around the world every week.

The Safer Sex Page includes a wide array of sex education materials from dozens of sources; brochures including graphics, audio and video. Some of the resources are written specifically for the site and are based on information from groups such as the Centers for Disease Control, the U.S. Department of Health and Human Services, and the Los Angeles Gay and Lesbian Community Services Center.

The Safer Sex Page also includes an online discussion group; past topics on sexual subjects have included masturbation, condom brands, and how to talk to a partner about safer sex. Teenagers are an important audience for the resources offered through the Web page and online discussion group. Many teenagers are sexually active, or consider becoming sexually active before they reach adulthood. The Safer Sex Page believes these minors are entitled to information that could save their lives.

Sign up to be the first to hear about how to take action.