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Police in Michigan, Wisconsin, and California can rummage through your cell phone data without a warrant (in Wisc. they technically need to prove "exigency", typically a triviality). In Mich. and Calif. citizens who refuse to allow the police to take their personal data can be arrested for obstructing an investigation.  (Source: Matt York, Associated Press)

Michigan State troopers are using a device that seizes all data from smart phones. They're regularly performing the scrapes during routine traffic stops. There's no public oversight of what happens to that data.  (Source: Cellebrite)

The question of whether state Supreme Courts can kill citizens' Constitutional freedoms is a one that will likely stir much debate and conflict. Ultimately, those wishing to push the nation towards a police state may find the Founding Fathers' ideas hard to kill, though.  (Source: Alan Moore/David Lloyd)
Cops in Mich., Wisc., and Calif. can inspect ANYTHING on your cell phone -- pictures, call history, and more

Whether it's real life historical regimes -- like Tojo's Imperial Rule Japan or Italian Nationalists -- or those in fictional works -- like George Orwell's Animal Farm or Alan Moore's V is For Vendetta -- the topic of a fascist police state is one that has simultaneously fascinated and frightened many.

In the United States, over the last decade police have enjoyed a growing set of warrantless powers in the name of justice.  In the last year, these powers expanded yet again, when police in California, Wisconsin, and Michigan began searching and seizing citizens’ cell phones -- without warrants. 

I. Police Seize Citizens' Smartphones

In January 2011, California's Supreme Court ruled 5-2 that police could conduct warrantless inspections of suspects' cell phones.  According to the majority decision, when a person is taken into police custody, they lose privacy rights to anything they're carrying on them.

The ruling describes, "this loss of privacy allows police not only to seize anything of importance they find on the arrestee's body ... but also to open and examine what they find."

In a dissenting ruling, Justice Kathryn Mickle Werdegar stated, "[The ruling allows police] to rummage at leisure through the wealth of personal and business information that can be carried on a mobile phone or handheld computer merely because the device was taken from an arrestee's person."

But California was not alone.  Michigan State Police officers have been using a device called Cellebrite UFED Physical Pro for the last couple years.  The device scrapes off everything stored on the phone -- GPS geotag data, media (pictures, videos, music, etc.), text messages, emails, call history, and more.

Michigan State Police have been reportedly regularly been scraping the phones of people they pull over.

In neighboring Wisconsin, the state Supreme Court has ruled that while such searches are generally illegal, their evidence can become admissible in court if the police demonstrate an exigency (a press need) for the information.

Essentially this ruling offers support for such searches as it indicates that they can give solid evidence and ostensibly offers no repercussions to law enforcement officials conducting the officially "illegal" procedure.

So far the only state to have a high profile ruling against the practice was Ohio.  The Supreme Court of Ohio ruled that warrantless smart phone searching violated suspects' rights.  The requested the U.S. Supreme Court review the issue, but the request was denied.

II. What Does the Constitution Say?

The United States Constitution ostensibly is the most important government document in the U.S.  It guarantees essential rights to the citizens of the U.S.

Some of those rights are specified in the Fourth Amendment, part of the original Bill of Rights.  It states:

The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized. 

The Constitution explicitly states that effects of a person cannot be unreasonably seized without a warrant.  

Of course courts must play the vital role of defining what a "reasonable" search is.  But by extending the limits of searches to deem nearly all searches "reasonable", no matter how tenuous the connection to a suspect's detainment, this and several other decisions have created an erosion of the protections in the amendment.

Essentially what court rulings in California, Michigan, and Wisconsin indicate is that the courts believe the Constitution is no longer valid, or that certain Constitutional freedoms can be specially selected for elimination.

III. Benefits and Dangers

Some police officers and politicians argue that there are obvious benefits of warrantless searches, including of cell phone data. Officers claim they can obtain evidence that could be destroyed, concealed, or otherwise go undiscovered if they had to go through the standard process of obtaining a warrant.

These groups argue, "if you have nothing to hide, you have nothing to worry about."

However, serious issues over the practice also seem apparent.  For example, police appear to be taking digital copies of the data on users' cell phones, in addition to the applicable evidence.  There is virtually no oversight or transparency into how this data is stored or managed. 

In short, citizens face a tremendous violation of privacy.  They have little recourse to take action against officers that abuse the obtained information for business or personal purposes, as there's few laws explicitly applicable such an issue.

The allowance also opens a gaping door to condoning police harassment of citizens.  It would be pretty easy for police to "detain" a targeted individual on questionable charges and seize their phone. 

IV. ACLU Fights Back

In Michigan and California, the American Civil Liberties Union (ACLU) is challenging these warrantless searches.

Particularly in Michigan, the case is becoming contentious as the state is refusing to give the ACLU information on the data it has obtained from users' cell phones.  The state has told the ACLU that it must pony up $544,680 USD to process the records, if it wants them.

The ACLU is outraged at that exorbitant demand.  Mark P. Francher, a Michigan staff attorney with the ACLU's Racial Justice Project, states, "Through these many requests for information we have tried to establish whether these devices are being used legally. It’s telling that Michigan State Police would rather play this stalling game than respect the public’s right to know."

V.  The Big Picture

Ben Franklin, in his notes to the Pennsylvania Assembly famously wrote, "They who can give up essential liberty to obtain a little temporary safety, deserve neither liberty nor safety."

Warrantless searches -- a critical component of any fascist police state -- were clearly deemed illegal by the founding fathers.

When combined with recent allowances of warrantless wiretapspolice arrests of people who photograph them, warrantless invasion of property, and warrantless tracking of citizens the resulting picture is somewhat alarming.

The police in the U.S. are being increasingly exempted from following due process and given freedom to follow their commanders' dictates -- whatever they may be.  Meanwhile the rights and freedoms of citizens is eroding at an equally rapid pace.

Some of these issues may end up at the U.S. Supreme Court, but the country as a whole needs to consider and address them, as well, in the meantime.

Update 1: April 21, 2011 6:55 p.m. -

The Michigan State Police have shared with us the following statement:

Recent news coverage prompted by a press release issued by the American Civil Liberties Union (ACLU) has brought speculation and caused inaccurate information to be reported about data extraction devices (DEDs) owned by the Michigan State Police (MSP).

To be clear, there have not been any allegations of wrongdoing by the MSP in the use of DEDs.

The MSP only uses the DEDs if a search warrant is obtained or if the person possessing the mobile device gives consent. The department*s internal directive is that the DEDs only be used by MSP specialty teams on criminal cases, such as crimes against children.

The DEDs are not being used to extract citizens' personal information during routine traffic stops.

The MSP does not possess DEDs that can extract data without the officer actually possessing the owner's mobile device. The DEDs utilized by the MSP cannot obtain information from mobile devices without the mobile device owner knowing.

Data extraction devices are commercially available and are routinely utilized by mobile communication device vendors nationwide to transmit data from one device to another when customers upgrade their mobile devices.

These DEDs have been adapted for law enforcement use due to the ever-increasing use of mobile communication devices by criminals to further their criminal activity and have become a powerful investigative tool used to obtain critical information from criminals.

Since 2008, the MSP has worked with the ACLU to narrow the focus, and thus reducing the cost, of its initial Freedom of Information Act (FOIA) request. To date, the MSP has fulfilled at least one ACLU FOIA request on this issue and has several far-lower cost requests awaiting payment to begin processing. The MSP provides information in accordance with the Freedom of Information Act. As with any request, there may be a processing fee to search for, retrieve, review, examine, and separate exempt material, if any.

The implication by the ACLU that the MSP uses these devices "quietly to bypass Fourth Amendment protections against unreasonable searches" is untrue, and this divisive tactic unjustly harms police and community relations.

Note, as the ACLU and this article state, the police have to ask a citizen to get their phone during an investigation.

The police department's accounting that the device is not used during traffic stops conflicts with local reports and local testimony.  It is unclear whether this is due to confusion in the department, officers breaking with protocol, or problems with eyewitness credibility.

The statement does not state whether or not charges of obstruction of justice can be filed against citizens refusing to part with their mobile devices.

It also makes it clear that the full body of the collected information has not been released, as the ACLU has accounted.

We will make more information available as we receive it.

Comments     Threshold

This article is over a month old, voting and posting comments is disabled

By Drag0nFire on 4/21/2011 2:34:09 PM , Rating: 5
Thinking ahead here. Would an encrypted smart phone be susceptible to these devices? I work in the medical field where a smart phone can contain all sorts of protected health information, dissemination of which is a violation of patient's rights. Would this information be subject to seizure by the police if I was pulled over for a traffic violation?

This disgusts me...

RE: so...
By koenshaku on 4/21/2011 2:46:03 PM , Rating: 5
Yeah I have to reconsider security and what I keep on my phone this is insane. I carry a filthy phone that assume the little three incorrect passcodes would wipe it never thinking about such a device as this. This country is going to the pits.

RE: so...
By vol7ron on 4/21/2011 9:39:17 PM , Rating: 2
Would this information be subject to seizure by the police if I was pulled over for a traffic violation?

The article says if you're detained. You're not detained if you're pulled over for a traffic stop.

Yeah I have to reconsider security and what I keep on my phone this is insane.
The day I found someone's iPhone, I started thinking about how easy it is to lose mine, or for someone to steal it. I instantly put on the password-lock (not passcode) and turned on the wipe on 10 failed attempts. Granted, this wouldn't be as nice if I could encrypt the drive, but it's a start to prevent prying morons from acquiring my life.

RE: so...
By Adonlude on 4/22/2011 11:38:37 AM , Rating: 5
Any time an officer stops you and you are not in a situation where you are "free to leave" you are detained. I suggest you start reading more about your rights... then buy guns.

RE: so...
By Mr772 on 4/22/2011 6:19:40 PM , Rating: 3
"An armed man is a citizen and unarmed man is a subject." ~anon

RE: so...
By mostyle on 4/26/2011 7:49:11 AM , Rating: 2
Beautiful, sir, beautiful.

RE: so...
By KeithP on 4/21/2011 2:52:46 PM , Rating: 4
You know what disgusts me? Someone carrying around my medical records, unencrypted, on a device that is easily lost or stolen. Isn't that HIPAA violation??

RE: so...
By Drag0nFire on 4/21/2011 3:00:48 PM , Rating: 1
I agree with you completely. That's why I asked whether the police device would be able to break the encryption. Alternately, I could have asked whether I would be required to break the encryption for the police officers.

Please read what I wrote before you comment.

RE: so...
By The Raven on 4/21/2011 7:13:59 PM , Rating: 2
The police device is irrelevant to his point. If the device is left back at the Gourmet Haus Staudt...bam! That stuff is out there waiting to get hacked (that is if the thing is even locked to begin with at the time of interception).

Just like if I carried your medical records around in a briefcase. Of course the brief case is easily busted open regardless of the locking mechanism. But on the other hand, I am assuming there is A LOT more than a briefcase worth of documents on the phone.

Wouldn't your question be, "What the heck is he doing with my records in his briefcase?"

Its not the perfect comparison but you get my point right?
If you want to carry the thing around the hospital that is one thing. But take it outside and that is unacceptable IMO.

RE: so...
By mdogs444 on 4/21/2011 9:56:33 PM , Rating: 2
If you want to carry the thing around the hospital that is one thing. But take it outside and that is unacceptable IMO.

Unfortunately that's not very realistic. I work in IT for a hospital and there are many reasons that people use laptops and other mobile devices for work and take them home from work. For example, all IT staff have laptops that we use at work and also take them home every night. Why? Well, for a few reason - we are always on call (whether we like it or not), we can work from home, and because leaving laptops around the remote offices that are cleaned by outsourced companies (environmental services of the hospital only clean the main hospital - we have 30+ off site buildings and clinics). There are many reasons for each department, but I'm sure you can figure that part out.

However, we do not allow any patient data to be stored on laptops or mobile devices....well, on 99% of them anyway. There is always a small 1% of exceptions where it is possible. For example you need to be able to during a network outage, power outage, and certain vendors require that you only use their hardware and no network storage (typically smaller vendors that don't have a large support staff). We put as many programs as possible on the network through means such as Citrix, App-V, thin clients, virtual desktops, etc. In cases where the software must be locally installed, then we can resort to running the databases on SQL or Oracle servers which run at the data center as opposed to the local machine.

In todays world, the amount of patient data residing on any mobile device is next to nothing - at my facility anyway. Typically, when there is data there, it happens by accident or by people who are not computer savvy.

Also, we have our USB ports disabled by devices, so external hard drives and USB memory sticks are not recognized by the OS and users do not have the ability to install drivers to support them. We don't even allow android phones, iphones, or ipods to be connected and synced to any machine on our domain.

RE: so...
By The Raven on 4/22/2011 11:01:50 AM , Rating: 2
So you're saying that Drag0nFire is spreading false information. Whew! That is reassuring. I'm not of the medical profession so I got to trust you on this lol.

The way you describe it, sounds resonably secure. Drag0nFire makes it sound like the next big wikileak in the making.

I could see the headline now: "Wikileaks reveal Obama has 2 months to live yet decides to run for reelection. Biden suddenly important."

RE: so...
By mdogs444 on 4/21/2011 9:34:45 PM , Rating: 2
Someone carrying around my medical records, unencrypted, on a device that is easily lost or stolen. Isn't that HIPAA violation??

No, its not a violation, unless your information is actually compromised. Obviously you've never worked in a hospital in an urban area. It's not just laptops and mobile devices that are at risk - there are people who run into clinics or the ER's and try to grab full sized desktop machines and run out the door. I would be more worried about those because many facilities still store patient data locally on hard drives because some vendors require you to run the system the way they give it to you or they will not support it - for example they will not support the system if the data lies on a NAS owned by the hospital and not the hard drive supplied by the vendor.

I work in the IT department as an analyst for a major hospital doing work in a field that goes hand in hand with what you're talking about.

We do several different things to prevent this from happening. For starters, every employee and vendor must have their own individual domain login account with passwords that must meet certain criteria and are forced to change every 90 days. All laptops are fully encrypted so that if they are stolen, they are pretty much rendered useless. Often times, they end up at a neighborhood pawn shop with a new hard drive and windows image on them or dumpster because the existing drive is useless.

Next, we do not allow any databases or patient information to be stored locally on laptops unless absolutely necessary - for example vendor software that is only sold running on their own supplied hardware and they will not support network storage as an option. All users have NAS shares that replace the local My Documents folders and the C: drives are locked down except for people with admin access - such as IT staff.

In as many cases as possible any software that needs to be accesses remotely from outside of the hospital is typically put on a virtual desktop, app-v, or citrix based solution so that the data is never stored locally. We are also starting to roll out thin clients as well. Keep in mind, you must also have a login and token to even get VPN access.

We currently are not supporting tablets like android or ipads, nor as we allowing android phones to sync with outlook calendars (and many other things like this) because of the security risks and ability for patient information to compromised.

I could go on forever with this stuff, but I assume you're catching my drift. Now, I cannot say that all places are as security and ahead of the curve like we are - most likely smaller doctors offices and the like are not. But in those things I mentioned above, we go well above and beyond what HIPPA standards are. And to make matters worse - HIPPA is so vague, that there really are no industry "standards" per say when it comes to many things that are available today like security, virtualization, encryption, etc.

RE: so...
By phantom505 on 4/21/2011 11:06:26 PM , Rating: 2
Yes it is against HITECH, which is basically a supplement to HIPAA. Generally speaking most systems I've seen are server based and nothing is stored on the satellite device. It's really not that common anyhow.

RE: so...
By JasonMick on 4/21/2011 3:07:25 PM , Rating: 2
Thinking ahead here. Would an encrypted smart phone be susceptible to these devices? I work in the medical field where a smart phone can contain all sorts of protected health information, dissemination of which is a violation of patient's rights. Would this information be subject to seizure by the police if I was pulled over for a traffic violation?

This disgusts me...

Depending on the kind of encryption you use, the answer is probably yes.

Of course if this kind of action is tolerated/promoted you could be arrested for obstructing justice by refusing to give officers your encryption keys.

RE: so...
By ClownPuncher on 4/21/2011 3:28:11 PM , Rating: 5
That's where a lawyer comes into play. Warrantless search and siezure is against Federal Law. Sue these states into bankruptcy, they deserve to be kicked out on the Union.

RE: so...
By SilthDraeth on 4/21/2011 4:36:06 PM , Rating: 2
They are bankrupt already...

Not that I disagree with you.

RE: so...
By drycrust3 on 4/22/2011 3:55:48 PM , Rating: 2
they deserve to be kicked out on the Union.

... but wasn't that what the American Civil War was about?

RE: so...
By Integral9 on 4/21/2011 4:51:08 PM , Rating: 2
the problem with that is they are already bankrupt; they got nothing to loose...

RE: so...
By Integral9 on 4/21/2011 4:51:57 PM , Rating: 2
i hate my proxy...

RE: so...
By ClownPuncher on 4/21/2011 5:07:17 PM , Rating: 2
If we sold those states to Mexico, I'm sure they would feel worse off.

RE: so...
By Jeffk464 on 4/21/2011 9:49:04 PM , Rating: 2
Mexico already owns the southern half of California.

RE: so...
By mdogs444 on 4/21/2011 10:00:21 PM , Rating: 4
Correction: Mexico doesn't want to own it because they don't want to own the debt. They just want Americans to own it and pay the entitlements for Mexicans.

RE: so...
By sgw2n5 on 4/22/11, Rating: 0
RE: so...
By mdogs444 on 4/22/2011 9:05:00 AM , Rating: 2

Lets see. I paid about $10,000 last year in federal income taxes. I didnt get any welfare, food stamps, section 8 housing assistance, medicaid, in-state tuition pricing for not being a citizen, or emergency department bills paid for by the taxpayer.

I pay FICA, SS, Medicare, state income tax, and local income tax.

So please, enlighten me as to these entitlements that I'm getting which are far greater than those "brown people" who don't pay into the pot....

RE: so...
By Jeffk464 on 4/22/2011 10:34:57 AM , Rating: 2
Indead, its mostly a factor of circumstance. They, on average, come to California with no education and poor english ability so they end up in low paying jobs. They have large families, so even discounting entitlements, it costs way more to educate their kids and pay for their medical costs, and high incarceration rates than what they put into the system in taxes. Sorry its a fact, the rest of California subsidizes the "cheap labor." Of coarse by say the 3rd generation they are more mainstream, its not really an issue of "brown people"

RE: so...
By ClownPuncher on 4/22/2011 1:02:11 PM , Rating: 2
If they are getting medicaid, food stamps etc., I would assume they would be paying taxes on their income. AFAIK, most illegals have fake papers and are not paid under the table.

RE: so...
By Jeffk464 on 4/22/2011 5:54:52 PM , Rating: 2
Their kids are their foot in the door for receiving all the benefits.

RE: so...
By ClownPuncher on 4/22/2011 7:30:08 PM , Rating: 2
Catholics have a lot of kids!

RE: so...
By Skywalker123 on 4/23/11, Rating: 0
RE: so...
By HrilL on 4/21/2011 4:34:43 PM , Rating: 3
Of course if this kind of action is tolerated/promoted you could be arrested for obstructing justice by refusing to give officers your encryption keys.

This is where the 5th amendment would come in. You don't have to incriminate yourself. So they shouldn't be able to charge you with obstructing justice if you refuse to break the encryption. It is clearly within your rights to plead the 5th.

RE: so...
By sprockkets on 4/21/2011 9:43:40 PM , Rating: 1
Won't work. This has been followed on, and I remember them saying that will be contempt of court or obstruction of justice. The password in it of itself is not incriminating.

RE: so...
By SilthDraeth on 4/22/2011 11:12:42 AM , Rating: 2
The password could in incriminating if it was something like


RE: so...
By HrilL on 4/25/2011 8:12:41 PM , Rating: 2
somehow I thought the 5th gave you the right to remain silent.

Under the U.S. Supreme Court decision in Berghuis v. Thompkins suspects retain their 5th Amendment right to remain silent , however, if a suspect waives this right and interrogation begins, the right to halt further interrogation by the police must be exercised explicitly, by revoking the prior waiver of this 5th Amendment right.

Thus you have the right to refuse your password by remaining silent.

RE: so...
By gorehound on 4/21/2011 4:45:31 PM , Rating: 2
it really sucks.and what can you do against the police or how do you fight back against the government.they have sold us out and gone against our constitution.

RE: so...
By ebakke on 4/21/2011 10:34:18 PM , Rating: 2
you fight back at the voting booth. choose wisely.

RE: so...
By ShaolinSoccer on 4/22/2011 12:21:37 AM , Rating: 2
Aren't some voting booths rigged?

RE: so...
By mostyle on 4/26/2011 7:55:57 AM , Rating: 2
Booths? Politics in general are rigged.

I gave up ages ago on the ideal that my vote matters. Now, let me have several million in the bank and that issue shifts. Even then it's not my vote.. It's my wallet.

Meh, just my humble opinion..

RE: so...
By Breathless on 4/21/11, Rating: 0
RE: so...
By Jeffk464 on 4/21/2011 9:39:04 PM , Rating: 2
Holly hell, I used to hate the ACLU but I tell you ever since 9-11 the government has been getting out of control with violating constitutional rights. I might have to change my mind and actually donate money to the ACLU.

RE: so...
By Jeffk464 on 4/21/2011 9:43:39 PM , Rating: 2
"They who can give up essential liberty to obtain a little temporary safety, deserve neither liberty nor safety."

I need this on Tshirts and bumper stickers.

RE: so...
By mdogs444 on 4/21/2011 10:02:22 PM , Rating: 2
Ok lets not push it. A blind squirrel finds an acorn once in a while too. The ACLU does 1 thing good for every 100 crackpot things. I agree with them in this certain case...but its the other 99 that scare the hell out of me.

RE: so...
By sgw2n5 on 4/21/2011 11:54:54 PM , Rating: 2
Citation needed...

What has the ACLU done that you do not like?

RE: so...
By DerekZ06 on 4/22/2011 12:32:06 AM , Rating: 2
They do it all the time in Columbus Nebraska. I've had several friends receive obstruction when refusing to hand over their cellphones. One person had it confiscated without warrant and was charged with assaulting a police officer as well.

A friend that was at a underage drinking party was busted. Had her phone, which was a blackberry protected by a passcode, confiscated for two days. In the mean time they cracked it and used that phone to issue out several more MIPs and a procuring charge based off of texts and pictures.

Granted it didn't hold up in court but what did happen was that the people in it were noted. The procurer 2 months later was in a self defense fight but took it to far and received assault. In court he had the same judge and the judge recognizing him gave him the harsher penalty of prison time, specifically mentioning the procuring citation he was never charged with.

Messed up world huh?

RE: so...
By DerekZ06 on 4/22/2011 12:35:00 AM , Rating: 2
Additionally to the phone evidence not holding up in court, the people cited with it still had to pay lawyer fees and take time out of their day. The officers know this and frequently the lawyer costs much more than the fine ever could. Basically they are fined way more but without an official record.

RE: so...
By Jeffk464 on 4/22/2011 10:39:13 AM , Rating: 2
No, no, no,go for a public appointed attorney and then it costs the county money for the harassment. But yeah I have heard of cops writing bad tickets just to screw with you, because if you fight it its going to be a huge hassle on your part and none on theirs.

RE: so...
By DerekZ06 on 4/22/2011 12:24:21 PM , Rating: 2
They love to write bad tickets. Not to long ago a kegger was busted and we ran. They only nailed 7 people that night. The 3 that stayed in the machine shed were held at gun and tazer point by 9 cops. (And cops wonder why people think their dicks)

The cops confiscated a camera from one of the 7 that night, they took it to the local schools to identify the people on it and came up with 35 total mips delivered by mail. The 3 in the machine shed were charged with 35 counts of procuring and mip.

As of now 3 people were charged with mips and the rest had to go through hassles. The ones charged with procuring are still in court proceedings but have it obviously dropped down to 3 counts. However the schools did punish and suspend many from school activities.

RE: so...
By Wiggy Mcshades on 4/24/2011 11:47:56 AM , Rating: 2
You have to prove you can't afford one, and if you are a dependent your legal gaurdian also has to prove they cannot afford a lawyer. It's not easy to get a public defender in reality. Also the public defenders make next to nothing, so you aren't really screwing anyone but yourself trying to get one.

RE: so...
By Reclaimer77 on 4/22/2011 7:22:08 PM , Rating: 2
This disgusts me...

Yup. Gotta love all the 'hope and change' we've been seeing...

RE: so...
By mostyle on 4/26/2011 8:01:43 AM , Rating: 2
'hope and change'

Buzz words for the blind. People don't want to be forced to look at the reality of a situation rather they would have the Pied Piper(sp?) play them a tune that suits exactly the tune they are wanting to hear.

Hence where we are today.. A situation that 'We shall NOT overcome.'

"Game reviewers fought each other to write the most glowing coverage possible for the powerhouse Sony, MS systems. Reviewers flipped coins to see who would review the Nintendo Wii. The losers got stuck with the job." -- Andy Marken

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