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COVID19 Technology Trends Affecting the Spread of the Pandemic 

The Next Steps for Primordial Black Hole Research

This paper is available on arxiv under CC 4.0 license. Authors: (1) Muzhaffar Hazman, University of Galway, Ireland; (2) Susan McKeever, Technological University Dublin, Ireland; (3) Josephine Griffith, University of Galway, Ireland. Table of Links Abstract and Introduction Related Works Methodology Results Limitations and Future Works Conclusion, Acknowledgments, and References A Hyperparameters and Settings B Metric: Weighted F1-Score C Architectural Details D Performance Benchmarking E Contingency Table: Baseline vs. Text-STILT 6 Conclusion In this work, we addressed the challenge of training multimodal meme sentiment classifiers on a limited number of labelled memes by incorporating unimodal sentiment analysis data. We did so by proposing the first instance of STILT that applies unimodal intermediate tasks to a multimodal target task. Specifically, we tested image-only and text-only sentiment classification as intermediate tasks in training a meme sentiment classifier. We showed that this approach worked – unimodal text improved meme classification performance to a statistically significant degree. This novel approach allowed us to train a meme classifier that outperforms meme-only finetuning with only 60% as many labelled meme samples. As possible explanations for our observations, we discuss apparent similarities and differences in the roles of image and text modalities between unimodal and multimodal sentiment analysis tasks. Acknowledgments This work was conducted with the financial support of the Science Foundation Ireland Centre for Research Training in Digitally-Enhanced Reality (d-real) under Grant No. 18/CRT/6224; and the provision of computational facilities and support from the Irish Centre for High-End Computing (ICHEC). References Christian Bauckhage. 2011. Insights into internet memes. Proceedings of the International AAAI Conference on Web and Social Media, 5(1):42–49. Efrat Blaier, Itzik Malkiel, and Lior Wolf. 2021. 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In De-Factify @ AAAI 2022. First Workshop on Multimodal Fact-Checking and Hate Speech Detection, CEUR Workshop Proceedings. AAAI. Jason Phang, Thibault Fevry, and Samuel R. Bowman. ´ 2019. Sentence encoders on stilts: Supplementary training on intermediate labeled-data tasks. arXiv preprint, arXiv:1811.01088. Mohammad Taher Pilehvar and Jose Camacho-Collados. 2019. WiC: the word-in-context dataset for evaluating context-sensitive meaning representations. In Proceedings of the 2019 Conference of the North American Chapter of the Association for Computational Linguistics: Human Language Technologies, Volume 1 (Long and Short Papers), pages 1267–1273, Minneapolis, Minnesota. Association for Computational Linguistics. Clifton Poth, Jonas Pfeiffer, Andreas Ruckl ¨ e, and Iryna ´ Gurevych. 2021. What to pre-train on? Efficient intermediate task selection. In Proceedings of the 2021 Conference on Empirical Methods in Natural Language Processing, pages 10585–10605, Online and Punta Cana, Dominican Republic. Association for Computational Linguistics. Christopher Potts, Zhengxuan Wu, Atticus Geiger, and Douwe Kiela. 2021. DynaSent: A dynamic benchmark for sentiment analysis. In Proceedings of the 59th Annual Meeting of the Association for Computational Linguistics and the 11th International Joint Conference on Natural Language Processing (Volume 1: Long Papers), pages 2388–2404, Online. Association for Computational Linguistics. Shraman Pramanick, Md Shad Akhtar, and Tanmoy Chakraborty. 2021a. Exercise? i thought you said ’extra fries’: Leveraging sentence demarcations and multi-hop attention for meme affect analysis. Proceedings of the International AAAI Conference on Web and Social Media, 15(1):513–524. Shraman Pramanick, Shivam Sharma, Dimitar Dimitrov, Md. Shad Akhtar, Preslav Nakov, and Tanmoy Chakraborty. 2021b. MOMENTA: A Multimodal Framework for Detecting Harmful Memes and Their Targets. In Findings of the Association for Computational Linguistics: EMNLP 2021, pages 4439–4455, Punta Cana, Dominican Republic. Association for Computational Linguistics. Yada Pruksachatkun, Jason Phang, Haokun Liu, Phu Mon Htut, Xiaoyi Zhang, Richard Yuanzhe Pang, Clara Vania, Katharina Kann, and Samuel R. Bowman. 2020. Intermediate-task transfer learning with pretrained language models: When and why does it work? In Proceedings of the 58th Annual Meeting of the Association for Computational Linguistics, pages 5231–5247, Online. Association for Computational Linguistics. Alec Radford, Jong Wook Kim, Chris Hallacy, Aditya Ramesh, Gabriel Goh, Sandhini Agarwal, et al. 2021. Learning transferable visual models from natural language supervision. In International Conference on Machine Learning, pages 8748–8763. PMLR. Sathyanarayanan Ramamoorthy, Nethra Gunti, Shreyash Mishra1, S Suryavardan, Aishwarya Reganti, Parth Patwa, Amitava Das, Tanmoy Chakraborty, Amit Sheth, Asif Ekbal, and Chaitanya Ahuja. 2022. Memotion 2: Dataset on sentiment and emotion analysis of memes. In De-Factify @ AAAI 2022. First Workshop on Multimodal Fact-Checking and Hate Speech Detection, CEUR Workshop Proceedings. AAAI. Elad Segev, Asaf Nissenbaum, Nathan Stolero, and Limor Shifman. 2015. Families and Networks of Internet Memes: The Relationship Between Cohesiveness, Uniqueness, and Quiddity Concreteness. Journal of Computer-Mediated Communication, 20(4):417–433. Lanyu Shang, Yang Zhang, Yuheng Zha, Yingxi Chen, Christina Youn, and Dong Wang. 2021. AOMD: An Analogy-Aware Approach to Offensive Meme Detection on Social Media. Inf. Process. Manage., 58(5). Chhavi Sharma, Deepesh Bhageria, William Scott, Srinivas PYKL, Amitava Das, Tanmoy Chakraborty, et al. 2020. SemEval-2020 task 8: Memotion analysisthe visuo-lingual metaphor! In Proceedings of the Fourteenth Workshop on Semantic Evaluation, pages 759–773, Barcelona (online). International Committee for Computational Linguistics. Shivam Sharma, Mohd Khizir Siddiqui, Md. Shad Akhtar, and Tanmoy Chakraborty. 2022. Domainaware self-supervised pre-training for label-efficient meme analysis. In Proceedings of the 2nd Conference of the Asia-Pacific Chapter of the Association for Computational Linguistics and the 12th International Joint Conference on Natural Language Processing (Volume 1: Long Papers), pages 792–805, Online only. Association for Computational Linguistics. Limor Shifman. 2014. The cultural logic of photo-based meme genres. Journal of Visual Culture, 13(3):340–358. Pranaydeep Singh, Aaron Maladry, and Els Lefever. 2022. Combining language models and linguistic information to label entities in memes. In Proceedings of the Workshop on Combating Online Hostile Posts in Regional Languages during Emergency Situations, pages 35–42, Dublin, Ireland. Association for Computational Linguistics. Shardul Suryawanshi, Bharathi Raja Chakravarthi, Pranav Verma, Mihael Arcan, John Philip McCrae, and Paul Buitelaar. 2020. A dataset for troll classification of TamilMemes. In Proceedings of the WILDRE5– 5th Workshop on Indian Language Data: Resources and Evaluation, pages 7–13, Marseille, France. European Language Resources Association (ELRA). Cagri Toraman, Furkan S¸ahinuc¸, and Eyup Yilmaz. 2022. Large-scale hate speech detection with crossdomain transfer. In Proceedings of the Thirteenth Language Resources and Evaluation Conference, pages 2215–2225, Marseille, France. European Language Resources Association. Alex Wang, Jan Hula, Patrick Xia, Raghavendra Pappagari, R. 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Innovative Strategies in Meme Sentiment Analysis: The Impact of Unimodal Training

If you don’t know, I write a newsletter called Above Average, where I talk about the second-order insights behind everything that is happening in the big tech. If you are into tech and want to be above average, . subscribe to it I have always admired Scott Galloway's newsletter, No Mercy, No Malice. One unique thing Scott does with his newsletter is that he hired his friend George Hahn to convert the newsletter into a podcast, which is published every week in his podcast feed . here I don’t have a friend like George Hahn, but I know AI voices have become very life-like with recent advances. So I thought, why not convert my newsletter into a podcast? So, I played around and wrote a script to use Open AI’s text-to-speech API to convert my newsletter post into its audio version. To follow along and use this script, you need Open AI credits and an Open AI Secret Key. Here is the code I used. from openai import OpenAI


client = OpenAI()
client.api_key = 'YOUR SECRET KEY'
txt = """1/ Google is the dark horse in AI

Only Google can mess up a good thing multiple times. Google has struggled to play the perception game that has turned against it after the launch of ChatGPT and with Sathya’s offense on all things AI.

Google released an impressive Gemini AI preview series and the success lasted for two days. Before media started to observe that the demo is not so much as a demo but series of well constructed prompts. Or a series of good demos complied to one great demo.

This is obviously putting Google back again in the perception wars of AI. The keyword here is perception.

If everything is perception & marketing than nothing in the world will be a surprise. In case of Google in AI, don’t let the perception confuse you. Google is still the dark horse in AI. Google was talking about AI in every Pixel device launch since last 5 years while the tech industry and VCs were saying that Crypto is the next big thing.

The day to day news cycle exists to take your attention and make you click & confuse you. AI is a continuous innovation not a discontinuous one. Google has strong fundamentals in AI and the AI cycle is much longer than 12 months of ChatGPT. Google has shipped more AI products via Gmail, Google Search, Ads and most importantly Google Pixel than any other company. So just because Google has failed to market itself doesn’t mean its a loser in AI.

Google is still a dark horse in AI."""

response = client.audio.speech.create(
    model="tts-1",
    voice="onyx",
    input=txt,
)

response.stream_to_file("output.mp3") The newsletter post I took in this example is from . Here is the output . this edition result it generated The result was not as good as George Hahn’s voice, but it’s much better than most of the audio book out there. This idea can be expanded further to create a product that takes a new newsletter when published, converts it automatically to a podcast, and publishes it in the podcast feed. George Hahn as a Service. AI PRODUCT ALERT: That’s it for day 1 of AI. Follow me on for the latest updates on 100 days of AI or . Twitter bookmark this page Also published . here

100 Days of AI Day 1: From Newsletter to Podcast, Leveraging AI for Audio Transformation

We had now reached Switzerland

CYRUS SACRIFICES HIMSELF FOR THE SAKE OF THE “ALIENS”

Barchester Towers by Anthony Trollope is part of the HackerNoon Books Series. You can jump to any chapter in this book . Oxford—The Master and Tutor of Lazarus here Oxford—The Master and Tutor of Lazarus Mr. Arabin, as we have said, had but a sad walk of it under the trees of Plumstead churchyard. He did not appear to any of the family till dinner-time, and then he seemed, as far as their judgement went, to be quite himself. He had, as was his wont, asked himself a great many questions and given himself a great many answers; and the upshot of this was that he had sent himself down for an ass. He had determined that he was much too old and much too rusty to commence the manoeuvres of love-making; that he had let the time slip through his hands which should have been used for such purposes; and that now he must lie on his bed as he had made it. Then he asked himself whether in truth he did love this woman; and he answered himself, not without a long struggle, but at last honestly, that he certainly did love her. He then asked himself whether he did not also love her money, and he again answered himself that he did so. But here he did not answer honestly. It was and ever had been his weakness to look for impure motives for his own conduct. No doubt, circumstanced as he was, with a small living and a fellowship, accustomed as he had been to collegiate luxuries and expensive comforts, he might have hesitated to marry a penniless woman had he felt ever so strong a predilection for the woman herself; no doubt Eleanor's fortune put all such difficulties out of the question; but it was equally without doubt that his love for her had crept upon him without the slightest idea on his part that he could ever benefit his own condition by sharing her wealth. When he had stood on the hearth-rug, counting the pattern and counting also the future chances of his own life, the remembrances of Mrs. Bold's comfortable income had certainly not damped his first assured feeling of love for her. And why should it have done so? Need it have done so with the purest of men? Be that as it may, Mr. Arabin decided against himself; he decided that it had done so in his case, and that he was not the purest of men. He also decided, which was more to his purpose, that Eleanor did not care a straw for him, and that very probably she did care a straw for his rival. Then he made up his mind not to think of her any more, and went on thinking of her till he was almost in a state to drown himself in the little brook which ran at the bottom of the archdeacon's grounds. And ever and again his mind would revert to the Signora Neroni, and he would make comparisons between her and Eleanor Bold, not always in favour of the latter. The signora had listened to him, and flattered him, and believed in him; at least she had told him so. Mrs. Bold had also listened to him, but had never flattered him; had not always believed in him; and now had broken from him in violent rage. The signora, too, was the more lovely woman of the two, and had also the additional attraction of her affliction—for to him it was an attraction. But he never could have loved the Signora Neroni as he felt that he now loved Eleanor; and so he flung stones into the brook, instead of flinging in himself, and sat down on its margin as sad a gentleman as you shall meet in a summer's day. He heard the dinner-bell ring from the churchyard, and he knew that it was time to recover his self-possession. He felt that he was disgracing himself in his own eyes, that he had been idling his time and neglecting the high duties which he had taken upon himself to perform. He should have spent this afternoon among the poor at St. Ewold's, instead of wandering about at Plumstead, an ancient, love-lorn swain, dejected and sighing, full of imaginary sorrows and Wertherian grief. He was thoroughly ashamed of himself, and determined to lose no time in retrieving his character, so damaged in his own eyes. Thus when he appeared at dinner he was as animated as ever and was the author of most of the conversation which graced the archdeacon's board on that evening. Mr. Harding was ill at ease and sick at heart, and did not care to appear more comfortable than he really was; what little he did say was said to his daughter. He thought that the archdeacon and Mr. Arabin had leagued together against Eleanor's comfort, and his wish now was to break away from the pair and undergo in his Barchester lodgings whatever Fate had in store for him. He hated the name of the hospital; his attempt to regain his lost inheritance there had brought upon him so much suffering. As far as he was concerned, Mr. Quiverful was now welcome to the place. And the archdeacon was not very lively. The poor dean's illness was of course discussed in the first place. Dr. Grantly did not mention Mr. Slope's name in connexion with the expected event of Dr. Trefoil's death; he did not wish to say anything about Mr. Slope just at present, nor did he wish to make known his sad surmises; but the idea that his enemy might possibly become Dean of Barchester made him very gloomy. Should such an event take place, such a dire catastrophe come about, there would be an end to his life as far as his life was connected with the city of Barchester. He must give up all his old haunts, all his old habits, and live quietly as a retired rector at Plumstead. It had been a severe trial for him to have Dr. Proudie in the palace, but with Mr. Slope also in the deanery he felt that he should be unable to draw his breath in Barchester close. Thus it came to pass that in spite of the sorrow at his heart, Mr. Arabin was apparently the gayest of the party. Both Mr. Harding and Mrs. Grantly were in a slight degree angry with him on account of his want of gloom. To the one it appeared as though he were triumphing at Eleanor's banishment, and to the other that he was not affected as he should have been by all the sad circumstances of the day—Eleanor's obstinacy, Mr. Slope's success, and the poor dean's apoplexy. And so they were all at cross-purposes. Mr. Harding left the room almost together with the ladies, and then the archdeacon opened his heart to Mr. Arabin. He still harped upon the hospital. "What did that fellow mean," said he, "by saying in his letter to Mrs. Bold that if Mr. Harding would call on the bishop, it would be all right? Of course I would not be guided by anything he might say, but still it may be well that Mr. Harding should see the bishop. It would be foolish to let the thing slip through our fingers because Mrs. Bold is determined to make a fool of herself." Mr. Arabin hinted that he was not quite so sure that Mrs. Bold would make a fool of herself. He said that he was not convinced that she did regard Mr. Slope so warmly as she was supposed to do. The archdeacon questioned and cross-questioned him about this, but elicited nothing, and at last remained firm in his own conviction that he was destined, , to be the brother-in-law of Mr. Slope. Mr. Arabin strongly advised that Mr. Harding should take no step regarding the hospital in connexion with, or in consequence of, Mr. Slope's letter. "If the bishop really means to confer the appointment on Mr. Harding," argued Mr. Arabin, "he will take care to let him have some other intimation than a message conveyed through a letter to a lady. Were Mr. Harding to present himself at the palace, he might merely be playing Mr. Slope's game;" and thus it was settled that nothing should be done till the great Dr. Gwynne's arrival, or at any rate without that potentate's sanction. malgré lui It was droll to observe how these men talked of Mr. Harding as though he were a puppet, and planned their intrigues and small ecclesiastical manoeuvres in reference to Mr. Harding's future position without dreaming of taking him into their confidence. There was a comfortable house and income in question, and it was very desirable, and certainly very just, that Mr. Harding should have them; but that at present was not the main point; it was expedient to beat the bishop and, if possible, to smash Mr. Slope. Mr. Slope had set up, or was supposed to have set up, a rival candidate. Of all things the most desirable would have been to have had Mr. Quiverful's appointment published to the public and then annulled by the clamour of an indignant world, loud in the defence of Mr. Harding's rights. But of such an event the chance was small; a slight fraction only of the world would be indignant, and that fraction would be one not accustomed to loud speaking. And then the preferment had, in a sort of way, been offered to Mr. Harding and had, in a sort of way, been refused by him. Mr. Slope's wicked, cunning hand had been peculiarly conspicuous in the way in which this had been brought to pass, and it was the success of Mr. Slope's cunning which was so painfully grating to the feelings of the archdeacon. That which of all things he most dreaded was that he should be outgeneralled by Mr. Slope; and just at present it appeared probable that Mr. Slope would turn his flank, steal a march on him, cut off his provisions, carry his strong town by a , and at last beat him thoroughly in a regular pitched battle. The archdeacon felt that his flank had been turned when desired to wait on Mr. Slope instead of the bishop, that a march had been stolen when Mr. Harding was induced to refuse the bishop's offer, that his provisions would be cut off when Mr. Quiverful got the hospital, that Eleanor was the strong town doomed to be taken, and that Mr. Slope, as Dean of Barchester, would be regarded by all the world as conqueror in the final conflict. coup de main Dr. Gwynne was the who was to come down upon the Barchester stage and bring about deliverance from these terrible evils. But how can melodramatic be properly brought about, how can vice and Mr. Slope be punished, and virtue and the archdeacon be rewarded, while the avenging god is laid up with the gout? In the mean time evil may be triumphant, and poor innocence, transfixed to the earth by an arrow from Dr. Proudie's quiver, may lie dead upon the ground, not to be resuscitated even by Dr. Gwynne. Deus ex machina dénouements Two or three days after Eleanor's departure, Mr. Arabin went to Oxford and soon found himself closeted with the august head of his college. It was quite clear that Dr. Gwynne was not very sanguine as to the effects of his journey to Barchester, and not over-anxious to interfere with the bishop. He had had the gout, but was very nearly convalescent, and Mr. Arabin at once saw that had the mission been one of which the master thoroughly approved, he would before this have been at Plumstead. As it was, Dr. Gwynne was resolved on visiting his friend, and willingly promised to return to Barchester with Mr. Arabin. He could not bring himself to believe that there was any probability that Mr. Slope would be made Dean of Barchester. Rumour, he said, had reached even his ears, not at all favourable to that gentleman's character, and he expressed himself strongly of opinion that any such appointment was quite out of the question. At this stage of the proceedings, the master's right-hand man, Tom Staple, was called in to assist at the conference. Tom Staple was the Tutor of Lazarus and, moreover, a great man at Oxford. Though universally known by a species of nomenclature so very undignified, Tom Staple was one who maintained a high dignity in the university. He was, as it were, the leader of the Oxford tutors, a body of men who consider themselves collectively as being by very little, if at all, second in importance to the heads themselves. It is not always the case that the master, or warden, or provost, or principal can hit it off exactly with his tutor. A tutor is by no means indisposed to have a will of his own. But at Lazarus they were great friends and firm allies at the time of which we are writing. Tom Staple was a hale, strong man of about forty-five, short in stature, swarthy in face, with strong, sturdy black hair and crisp black beard of which very little was allowed to show itself in shape of whiskers. He always wore a white neckcloth, clean indeed, but not tied with that scrupulous care which now distinguishes some of our younger clergy. He was, of course, always clothed in a seemly suit of solemn black. Mr. Staple was a decent cleanly liver, not over-addicted to any sensuality; but nevertheless a somewhat warmish hue was beginning to adorn his nose, the peculiar effect, as his friends averred, of a certain pipe of port introduced into the cellars of Lazarus the very same year in which the tutor entered it as a freshman. There was also, perhaps, a little redolence of port wine, as it were the slightest possible twang, in Mr. Staple's voice. In these latter days Tom Staple was not a happy man; university reform had long been his bugbear, and now was his bane. It was not with him, as with most others, an affair of politics, respecting which, when the need existed, he could, for parties' sake or on behalf of principle, maintain a certain amount of necessary zeal; it was not with him a subject for dilettante warfare and courteous, commonplace opposition. To him it was life and death. The of the university was his only idea of life, and any reformation was as bad to him as death. He would willingly have been a martyr in the cause, had the cause admitted of martyrdom. status quo At the present day, unfortunately, public affairs will allow of no martyrs, and therefore it is that there is such a deficiency of zeal. Could gentlemen of £10,000 a year have died on their own door-steps in defence of protection, no doubt some half-dozen glorious old baronets would have so fallen, and the school of protection would at this day have been crowded with scholars. Who can fight strenuously in any combat in which there is no danger? Tom Staple would have willingly been impaled before a Committee of the House, could he by such self-sacrifice have infused his own spirit into the component members of the hebdomadal board. Tom Staple was one of those who in his heart approved of the credit system which had of old been in vogue between the students and tradesmen of the university. He knew and acknowledged to himself that it was useless in these degenerate days publicly to contend with "The Jupiter" on such a subject. "The Jupiter" had undertaken to rule the university, and Tom Staple was well aware that "The Jupiter" was too powerful for him. But in secret, and among his safe companions, he would argue that the system of credit was an ordeal good for young men to undergo. The bad men, said he, the weak and worthless, blunder into danger and burn their feet; but the good men, they who have any character, they who have that within them which can reflect credit on their alma mater, they come through scatheless. What merit will there be to a young man to get through safely, if he be guarded and protected and restrained like a schoolboy? By so doing, the period of the ordeal is only postponed, and the manhood of the man will be deferred from the age of twenty to that of twenty-four. If you bind him with leading-strings at college, he will break loose while eating for the bar in London; bind him there, and he will break loose afterwards, when he is a married man. The wild oats must be sown somewhere. 'Twas thus that Tom Staple would argue of young men, not, indeed, with much consistency, but still with some practical knowledge of the subject gathered from long experience. And now Tom Staple proffered such wisdom as he had for the assistance of Dr. Gwynne and Mr. Arabin. "Quite out of the question," said he, arguing that Mr. Slope could not possibly be made the new Dean of Barchester. "So I think," said the master. "He has no standing, and, if all I hear be true, very little character." "As to character," said Tom Staple, "I don't think much of that. They rather like loose parsons for deans; a little fast living, or a dash of infidelity, is no bad recommendation to a cathedral close. But they couldn't make Mr. Slope; the last two deans have been Cambridge men; you'll not show me an instance of their making three men running from the same university. We don't get our share and never shall, I suppose, but we must at least have one out of three." "Those sort of rules are all gone by now," said Mr. Arabin. "Everything has gone by, I believe," said Tom Staple. "The cigar has been smoked out, and we are the ashes." "Speak for yourself, Staple," said the master. "I speak for all," said the tutor stoutly. "It is coming to that, that there will be no life left anywhere in the country. No one is any longer fit to rule himself, or those belonging to him. The Government is to find us all in everything, and the press is to find the Government. Nevertheless, Mr. Slope won't be Dean of Barchester." "And who will be warden of the hospital?" said Mr. Arabin. "I hear that Mr. Quiverful is already appointed," said Tom Staple. "I think not," said the master. "And I think, moreover, that Dr. Proudie will not be so short-sighted as to run against such a rock: Mr. Slope should himself have sense enough to prevent it." "But perhaps Mr. Slope may have no objection to see his patron on a rock," said the suspicious tutor. "What could he get by that?" asked Mr. Arabin. "It is impossible to see the doubles of such a man," said Mr. Staple. "It seems quite clear that Bishop Proudie is altogether in his hands, and it is equally clear that he has been moving heaven and earth to get this Mr. Quiverful into the hospital, although he must know that such an appointment would be most damaging to the bishop. It is impossible to understand such a man, and dreadful to think," added Tom Staple, sighing deeply, "that the welfare and fortunes of good men may depend on his intrigues." Dr. Gwynne or Mr. Staple were not in the least aware, nor even was Mr. Arabin, that this Mr. Slope, of whom they were talking, had been using his utmost efforts to put their own candidate into the hospital, and that in lieu of being permanent in the palace, his own expulsion therefrom had been already decided on by the high powers of the diocese. "I'll tell you what," said the tutor, "if this Quiverful is thrust into the hospital and Dr. Trefoil does die, I should not wonder if the Government were to make Mr. Harding Dean of Barchester. They would feel bound to do something for him after all that was said when he resigned." Dr. Gwynne at the moment made no reply to this suggestion, but it did not the less impress itself on his mind. If Mr. Harding could not be warden of the hospital, why should he not be Dean of Barchester? And so the conference ended without any very fixed resolution, and Dr. Gwynne and Mr. Arabin prepared for their journey to Plumstead on the morrow. About HackerNoon Book Series: We bring you the most important technical, scientific, and insightful public domain books. This book is part of the public domain. Anthony Trollope (2002). Barchester Towers. Urbana, Illinois: Project Gutenberg. Retrieved October 2022 https://www.gutenberg.org/cache/epub/3409/pg3409-images.html This eBook is for the use of anyone anywhere at no cost and with almost no restrictions whatsoever. You may copy it, give it away or re-use it under the terms of the Project Gutenberg License included with this eBook or online at , located at . www.gutenberg.org https://www.gutenberg.org/policy/license.html

Oxford—The Master and Tutor of Lazarus

The Widow's Suitors

The Stanhope Family

Everyone’s favorite punching bag, Section 230 of the Communications Decency Act of 1996, made its way to the Supreme Court this week in . Gonzalez v. Google The case confronts the scope of Section 230, and in particular examines whether platforms are liable for algorithms that target users and recommend content. Gonzalez The stakes are high: Recommendation algorithms underpin much of our experience online (search! social media! online commerce!)—so the case spawned dozens of , hundreds of webinars and tweet threads, and new wrinkles for people who love the internet. So basically, it’s my idea of a good time. friend-of-the-court briefs Marie Kondo: "I'm so excited because I love mess" On that note: Hi! I’m Nabiha Syed, CEO of The Markup and a media lawyer by training. I like unanswered questions and moments where we confront the messiness of our lives as mediated by technology. The sprawling two hour and 41 minute oral argument in pulled a lot of threads, some of which were clarifying and others that were, well, about thumbnails and rice pilaf. ( .) My takeaway is that the court is unlikely to gut Section 230, but it might nibble at its scope in chaotic ways. Gonzalez Seriously To help make sense of it all, I turned to two of my favorite legal scholars and old colleagues of mine from the Yale Information Society Project: James Grimmelmann, professor at Cornell Law School and Cornell Tech, and Kate Klonick, law professor at St. John’s University and fellow at the Berkman Klein Center at Harvard. Here’s what they had to share, edited for brevity and clarity. Nabiha: Let’s take a minute to revisit the history and legislative intent of Section 230: What was it meant to incentivize? : It seems paradoxical, but Section 230 was intended to internet platforms to moderate the content they carry. Several court decisions in the years before Section 230 was enacted had created a perverse legal regime in which the more effort a platform put into moderating harmful content, the stricter a standard it would be held to. James encourage By creating a blanket immunity, Section 230 ensured that platforms can remove the harmful content that they find without worrying that they will be held liable for the harmful content that they miss. In the years since then, the consensus about Section 230’s purpose has shifted a bit. The leading theory now is that Section 230 prevents “ .” Without some kind of immunity for user-posted content, platforms will overmoderate. Anytime content has even the slightest whiff of harmfulness or illegality, platforms will take it down to avoid legal risk. collateral censorship Lots of socially valuable content will be taken down along with the actually harmful stuff, throwing the baby out with the bathwater. On this theory, Section 230 reflects a belief that there is more good content out there than bad content, and that platforms will settle on moderation policies that keep their users happy even without the threat of liability. It is a constant surprise to me that Section 230 has become this black hole for big tech agita, and I think it’s most constructive to focus on its . Kate: history and legislative intent In the mid-1990s, there was a bit of a moral panic over the amount of pornography that was available on the internet, fueled by a (since debunked) article in the Georgetown Law Journal and things like this classic Time magazine cover: That caused Congress to start what would be called in modern-terms a “Make the Internet Decent Again” campaign. The result was the Communications Decency Act (CDA)—which was a very broad piece of legislation that tried to bring “decency” to the internet. At the same time, courts heard different types of tort claims against internet companies for speech posted on their sites—and the rulings are all over the place. essentially told online intermediaries that they were liable, and said that they weren’t. The result was a lot of confusion. One decision another one If platform providers were liable for people said on their platforms, they should just take down everything but the sweetest of cat photos. And if they liable for anything people said on their platforms, then why even bother spending resources taking down swastikas or other offensive content? anything weren’t Fast-forward a bit: The CDA is passed (including Section 230, which essentially makes online intermediaries immune from tort liability), and it is almost immediately challenged on First Amendment grounds. That case, , was heard by the Supreme Court in 1997, and it struck down all of the CDA for First Amendment reasons for Section 230, which survived. Reno v. ACLU except Shortly thereafter, in , the 4th Circuit broadly construed the immunity for platforms—which became precedent for courts all over the United States for the last 25 years. So that’s the story of how we got Section 230, kept Section 230, and then strengthened Section 230. Zeran v. AOL Nabiha: The argument revealed some confusion over what counts as publishing—namely, whether it includes recommending, endorsing, organizing, prioritizing, or presenting information. Why is it so important to get this scope right? And what does this mean for search? Gonzalez If I post a video to YouTube, where other people view it, it is obvious that is the kind of activity that Section 230 protects. But on Tuesday the justices went around in circles for two and a half hours trying to figure out what else fits in that category. James: They seemed to agree that a straightforward search engine, like Google or Bing, should also be covered: It provides a filtered list of websites that are relevant to the user’s query. They had a harder time with when a site makes recommendations, which also provide a filtered list of relevant content. The problem in both cases is that without giving some kind of immunity, it is not clear that the feature could exist. It might be possible to imagine a YouTube without recommendations; it is not possible to imagine a Google Search without search results. Even worse, there’s not a sharp dividing line between search and recommendation; Google and Bing use lots of signals besides the user’s query (e.g., geographic location and search history). I think the goal of legal policy in this area should be to , but the arguments on Tuesday focused more on what platforms do than on what users want. help users find what they want Without giving some kind of immunity, it is not clear that [filtering features] could exist. It might be possible to imagine a YouTube without recommendations; it is not possible to imagine a Google Search without search results. James Grimmelmann The plain meaning of Section 230’s publishing definition is already given in the statute, specifically, 47 USC § 230(f)(4)—and full disclosure, I was on an centered on this point. It literally includes the words “pick, choose, analyze, or digest content.” Did they know in 1996 that we’d be contemplating the scale of targeting that modern algorithms allow? Kate: amicus brief No, of course not. But they explicitly considered that would exist to play that curation role of picking, choosing, analyzing, or digesting content. And this isn’t a constitutional issue. If that meaning has changed, it’s not the court’s job to change it. That’s Congress’s job. something Nabiha: At various points, the justices danced with the idea of “neutral” algorithms and “neutrality” as a way to approach the question presented. I find the idea of a neutral algorithm slightly absurd, but you do see an analysis of “neutral tools” pop up in Section 230 jurisprudence. What’s going on here? There are definitely contexts in which strict neutrality is coherent and defensible. Offline, public accommodation laws require neutral, even-handed treatment: Madison Square Garden can’t kick you out of a Mariah Carey concert because of your race or because you . James: work for a law firm the owner doesn’t like Online, network neutrality laws (where they exist) require ISPs to treat traffic from different sites identically. These work because there’s a clear definition of what neutrality means: Anyone can buy a ticket and be seated. At the content layer, strict neutrality is often either incoherent or unimaginably awful. I happen to like a chronological feed, but if you follow thousands of people on Twitter, a strictly chronological feed is impossible to keep up with. A would have to rank every website the same, which is impossible, or use some kind of completely arbitrary criterion, like page size or alphabetical order. . truly neutral search engine That doesn’t work When people—including Supreme Court justices and tech billionaires who genuinely should know better—float this idea of “neutrality,” I think one of two things is going on. Sometimes they’re reasoning by analogy from offline contexts, without realizing how pervasive indispensable algorithmic ranking is online. And sometimes they have in mind a weaker notion of neutrality, one in which the platform doing the ranking is -neutral: It doesn’t try to press any particular agenda on its users. viewpoint Unfortunately, while viewpoint neutrality can be an appealing goal when it comes to First Amendment law and speech regulation by governments, it doesn’t work in the content-moderation space because there are viewpoints embedded in almost every widely used content moderation practice. “Death threats are bad” is a viewpoint. And even viewpoint-neutral moderation policies, like “don’t send unsolicited fundraising emails that users didn’t sign up for and don’t want” can look discriminatory in application if it turns out that one of the two major political parties disproportionately sends . spammy fundraising emails Your instinct is right, and I’m going to cheat and borrow from what , summarizing the oral arguments: “ and always discriminate.” Eric is exactly right here, and I hope these questions start to deconstruct some of the technology myths that we’ve been suffering under for the last 20 years: Kate: professor Eric Goldman wrote Gonzalez Algorithms are never neutral . “AI is biased”—no, humans who build it contain bias and the human data it trains on contains bias. The AI just reflects that back to us. Describing technology as the origin of intent “Neutral tools” is exactly this idea. Technology is objective or neutral. This reminds me a lot about the brief hope in the early 2000s as fMRIs came into regular use that we could “solve” questions of intent or culpability in the law by being able to see how a brain “worked”—of course we can’t, even seeing how a brain works or that a tumor “made” someone do something doesn’t mean we don’t have to ask the hard philosophical questions about what to about it. We can fix algorithms with transparency. do Nabiha: The magic (and the mayhem) of Section 230 is that it redirects liability to an individual speaker, rather than a third party who is amplifying that speech. In the absence of 230, do you foresee courts limiting third-party liability on First Amendment grounds? In the absence of Section 230, two things would happen. James: First, courts would have to ask whether the First Amendment does some of the same work that Section 230 does. While the full breadth of Section 230 probably isn’t constitutionally required, some degree of protection probably is. For the same reason that requires actual malice in defamation claims brought by public figures, it’s hard to see how strict liability against platforms could be constitutional. Unless they have some fair reason to know that particular content is illegal, it strains basic notions of justice to hold them liable for it. New York Times v. Sullivan Second, courts would also have to work through the details of specific crimes and torts. Defamation, invasion of privacy, wire fraud, promotion of unregistered securities, the practice of medicine without a license … you name it, the courts would have to figure out how it applies to platforms. The existence of Section 230 has prevented the development of substantive law of platform liability. If Section 230 goes away, the courts would have to invent it, in a hurry. In a lot of cases, they might well end up with rules that protect platforms much of the time. The same policy reasons that support Section 230 currently would still be good policy reasons not to hold platforms liable for every harmful piece of content users post. You can interpret that as meaning that Section 230 isn’t indispensable; it could be repealed without breaking the internet. But I think it would be more accurate to say that Section 230 is a load-bearing wall. If it’s demolished, something else will need to hold up that weight. Nabiha: It’s 2023, so of course AI has entered the chat. What are the implications of this case for generative AI? If the Supreme Court holds that algorithmic recommendations aren’t protected by Section 230, then generative AI is likely to be categorically ineligible for Section 230. That has to be a scary prospect for the companies currently giving users access to chatbots that meet the DSM-5 criteria for multiple serious mental disorders. James: If the Supreme Court rules for Google, matters will be more complicated. In some ways these AIs simply replicate patterns in their training data; in other ways, they synthesize outputs that can’t be traced back to specific third-party training data. It wouldn’t be a bad thing if the courts had to work this out, one case at a time, over the course of several years. Generative AI is really complicated, and we barely understand how it works and how it will be used. Taking time to work out the legal rules gives us more of a chance of getting them right. Nabiha: Predictions are a fool’s game, but what’s your gut say about the future of Section 230—in one emoji? Kate: 💬 James: 🤞 The fun doesn’t stop here. The Supreme Court will rule on the case by this summer. Gonzalez And if there’s one thing we can bet on, the coming months will see more twists and turns in the laws that affect the internet. If getting into the nerdy, legal bits of technology is something you’re interested in, and you have additional questions you’d like answered, send them to me at . newsletter@themarkup.org If we get enough questions, we’ll answer them in a future issue. And you can always reach out to me at . nabiha@themarkup.org Finally, if you’re interested in diving deeper into what Kate and James have worked on, Kate writes a newsletter called , which you can subscribe to if you like reading about free speech, law, and technology. And James literally wrote textbook on internet law, which . The Klonickles the you can get here Thanks for reading! Always, Nabiha Syed Chief Executive Officer The Markup By Nabiha Syed Also published here Photo by on Henry & Co. Unsplash

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