"The amici curiae are journalism membership and trade
associations, online publications, and academic institutions which
are concerned that the District Court's opinion, should it be
affirmed, will significantly chill freedom of the online press by
stifling one of its important features, linking. Amici curiae
believe that if online journalism is to thrive, courts must allow
it the unqualified First Amendment protection afforded its print
counterparts, a result already mandated by the Supreme Court. The
District Court's subjective test to determine "linking liability,"
which departs from previously unquestioned freedom of the press
principles, is a dangerous precedent; it allows Congress to
authorize prior restraints on whole classes of information
published on the World Wide Web, the publication of which is
constitutionally protected in all other media."
"The amici curiae represent the broad range of journalistic
interests and are eminently qualified to speak to the Court on
The Online News Association...
The Reporters Committee for Freedom of the Press...
The Newspaper Association of America (NAA)...
The Student Press Law Center...
The Pew Center on the States...
The Silha Center for the Study of Media Ethics and Law...
The College of Communications, California State University,
"Amici curiae are keenly aware that this case presents the
issue of linking liability for the first time and that this holding
may be the model for how future courts consider freedom of the
online press hereafter. The importance of this case to amici curiae
and the entire online journalism community cannot be
overstated. Amici curiae urge that this court honor the
Supreme Court's endorsement of the World Wide Web as a "dynamic,
multifaceted, category of communication" and exercise extreme
caution so that the still-evolving field of online journalism is
not substantially hindered at this critical stage in its