John William Nelson's Comments

• Jul 01, 2021 @ 09:03am

  Re: Re:

  on Did The Supreme Court Just Take A Sledge Hammer To Copyright's Statutory Damages?

  This is correct—standing is a feature of federal court. The mantra you learn in law school is that "federal courts are courts of limited jurisdiction." They seek to limit how and when they can hear cases. Some state judiciaries have adopted concepts of concrete harm and redressability similar to the federal concept, but this is not as common as of yet. (The US Chamber of Commerce, corporations, and Federalist Society adherents are pushing for this, however—it limits how and when and the scope of lawsuits they might face for hurting, harming, harassing, or killing people through negligence or recklessness.) Notably, Copyright cases must be brought in federal court as Copyright is a creature of federal law (and the US Constitution). This could be modified (Trademark cases can be heard in state court; patents, however, must also be in federal court), but it has not yet been and is unlikely to be for a number of reasons. In contrast, Fair Credit Reporting Act (FCRA) cases like the one in Ramirez can be heard in state courts, including state courts with lower standing thresholds than federal court. This is the likely result of cases like Spokeo v. Robbins and TransUnion v. Ramirez—consumer protection class actions will shift to state court litigation. In fact, I can see it already happening in my practice (primarily the FDCPA), and I have indeed myself brought more actions in state court so as to avoid more complex standing analysis.

• Jul 01, 2021 @ 08:57am

  Re: Re: Concrete Harm can still be alleged by loss of control

  on Did The Supreme Court Just Take A Sledge Hammer To Copyright's Statutory Damages?

  Ah. This is a good question. The answer is the favorite and most important thing to all Federalist Society and US Chamber of Commerce adherents—money. You can redress an injury through judicial relief with money. Loss of control can be remedied by compensation for the lost value of that control. There is also a possibility of an equitable remedy—the destruction of all copies in possession of the offending defendant might be imposed, or an injunction prohibiting the defendant from acquiring copies. (The best way to remember legal remedies versus equitable remedies is that legal remedies result in money changing hands; equitable remedies result in actions being taken, or prohibited. Most courts prefer legal remedies because equitable remedies smack a bit more like compulsion to act, which offends First Amendment sensibilities and then the later-acquired disaffection towards slavery.) You are correct that there is no putting the genie back in the bottle. At the same time, there is no bringing a dead person back to life, but we do have wrongful death lawsuits that seek to provide some form of judicial relief through monetary compensation for the loss of someone's life. There is a lot to get into as to the concepts of judicial philosophy, moral rights, property rights, the power of the courts and government to compel, etc wrapped up in this question. The short answer, however, is money.

• Jun 30, 2021 @ 03:11pm

  Concrete Harm can still be alleged by loss of control

  on Did The Supreme Court Just Take A Sledge Hammer To Copyright's Statutory Damages?

  I regularly litigate in federal courts regarding consumer cases similar to FCRA cases. (I litigate over FDCPA claims; Fair Debt Collection Practices Act claims.)

  Ramirez is a bad case for consumer law in many ways. Not the least of which is that it seems to gut the ability of consumers to bring class action claims for widespread violations of consumer laws by a company like TransUnion. This can truly limit how well these folks comply with federal consumer protections.

  However, Ramirez actually strengthens the argument that in non-class, individual cases the ability to allege the concreteness element of standing is more broad than many Federalist Society and US Chamber of Commerce friendly judges otherwise believe.

  In short—a concrete harm does not need to be monetary, but can include emotional harms, invasions of privacy, and loss of control over property.

  Moreover, those same Federalist Society and Chamber of Commerce judges seem more than willing to find economic harms in areas in which they agree with—I.E. copyright protections (because property rights)—than in areas in which they disagree—I.E. consumer protections.

  TLDR—all a copyright owner will be required to plead in a federal copyright violation case to show concreteness of harm is to plead that by making use of, distributing, or copying the protected work the Defendant otherwise deprived the Plaintiff—copyright owner of the ability to control its property, including its distribution, and to otherwise monetize that control and distribution.

  This is a LOW bar, despite how they keep trying to raise it for consumer law cases.

  The Spokeo Inc v. Robins case was the predecessor to the TransUnion v. Ramirez case: (https://en.wikipedia.org/wiki/Spokeo,_Inc._v._Robins).

  Really, the key to these cases—and some others—is a conservative judiciary chipping away at the ability of folks to bring class actions.

  There are, however, unintended consequences to this. For example, look for the various stories about how some lawyers have taken advantage of arbitration fee-shifting and brought voluminous and valid arbitration claims for which the large company that forced the arbitration on a consumer or employee must now pay the lion's share, or even 100% of, the arbitration fees.

  (To give you an idea, federal court filings cost $402 for plaintiffs, nothing for defendants to answer. Arbitrations, on a consumer fee track, on average cost the company enforcing the arbitration—think Wells Fargo, Bank of America, or AT&T—a minimum of $5k PER EACH ARBITRATION, and sometimes ongoing arbitration fees, with arbitrators charging $500+ per hour. Double-edged swords.)

  Still, I don't see Ramirez—sadly—affecting copyright trolls. It definitely hurts the class-side of consumer cases, but copyright cases are not brought as class actions and Ramirez actually makes it arguably easier for individual plaintiffs to meet the Article III standing requirement, including for concreteness.

• Mar 24, 2021 @ 10:05am

  Re: Re: Legal scholarship's citation and student review is not t

  on It's The End Of Citation As We Know It & I Feel Fine

  Like all good kvetches, rants, or other polemical screeds, they grow in power and length in proportion to the odiousness of the work seeking to be avoided through the inherent procrastination represented by the polemical work. In my case, drafting and reviewing extensive discovery requests in a document intensive case in federal litigation. In all seriousness, having experienced both sides of the legal scholarship coin—student review and legal scholar—and watching the process in other areas of academia, American legal scholarship is doing just fine. I can tell you quite truthfully that I would not trade the general quality of legal scholarship, or the publication process, for what other social scientists go through in their fields. A unified set of journals, streamlined application processes, reviewers who actually care about their reviewing work, reviewers who actually engage with the submitted material meaningfully instead of advancing their own positions or recommending self-serving citations—my friends in academia publishing in other social scientists look across the fence and see our grass as much greener. As to citations—my European colleagues can joke all they want about the thickness of our citations. American law journals are useful to practitioners here. Truly. I use them regularly in my practice. European lawyers do not say the same. In fact, they laugh at their legal academy as out of touch, and presume as a matter of first principles that nothing in a law journal will help them in their day-to-day practice. I don't think this is a state for the legal academy to envy, or seek to emulate. Even in the academic realm, however, I can say having to write legal academic papers and works both here and across the pond that it is far easier to delve deeply into issues using American legal academic works as opposed to their European counterparts. Moreover, when I applied American citation approaches grounded in true Bluebook principals to my European works, reviewers who joked at the pub previously about American citation habits responded glowingly to the thoroughness of discussion they helped provide in minimal space, not even understanding how ironic their appreciation for the approach was despite their prior jokes. Finally, while I think paper impact scores are important and relevant, and can be good tools to give high-level analysis of research impact and utility, in the end the value of good legal scholarship may not always be apparent until years later. To this day I regularly pull and find law journal articles from decades ago that provide insight into the development of an arcane legal area. In legal scholarship in the US I find that the good works stand on the shoulders of titans past, and the ability to see those titans through citations and find other directions those works might lead is invaluable. If you cannot tell, this is a particular grinding axe for myself. There are, actually, peer-review journals in American legal scholarship. They are high quality journals, generally, and difficult to get an article placed in them. The value of works in those journals tends to be higher because of the obvious network effects, but because they are good quality. But these are few in part because of the structure of post-graduate legal study in the U.S. (How many research assistants do the average law professor have versus professors in other social sciences? I can tell you it is lower for law.) At the same time, they truly are labors of love and dedication for those law professors who contribute. In the end, I'd take the quality of the American legal academy against any international law academy, and indeed most social science academies in the US and internationally as well. It does have its issues. Sure. But as both a sometimes-scholar and a currently all-time practitioner, the value and quality of the US law scholarship is clear, measurably, and above that of other areas. The only thing missing is a renaissance on more practice-focused common law and statutory law surveys coupled with analysis. These roles have been offloaded to BigLaw white papers and the Thomson-Reuters and Wolters-Kluwers of the world, locked in proprietary databases, or sent off to the realm of special interest organizations. Which is a shame. Because the more theoretical and philosophical works benefit from the more grounded works, just as the more-grounded works benefit from the more philosophical. So to the law-and-economic, or other law-and-field works. Now, if you'll excuse me, I have complaints to draft designed to overcome Spokeo Article III objections from Federalist-inspired, US Chambers of Commerce-backed judges preach law and economics but ignore the value of internalizing externalities despite their shrines to Coase.

• Mar 23, 2021 @ 12:26pm

  Legal scholarship's citation and student review is not the probl

  on It's The End Of Citation As We Know It & I Feel Fine

  I'd like to shut down the lazy attack on legal scholarships' supposedly twinned failures: (1) substantial citation and (2) student instead of peer review.

  First, legal citation is not the problem. Poor writing is the problem. If you do much in any social sciences field—history, political science, social studies, and others—then you will run into good and poor writing. Law is no different.

  When I studied and wrote legal scholarship in England I would often hear my European colleagues mock American legal scholarship for its citation propensity. I would hear jokes about reading a page with one sentence on it and the rest covered in footnotes. However, they miss the point.

  Legal citations are important. They are intended to point readers to other sources that either support or contrast positions, provide either additional arguments or primary source material, and are key to any legal researcher being able to delve deep into an issue.

  More often than not the break in legal research on a topic can result from finding a work that only tangentially touches on the subject you are looking for, but includes a reference to the argument you need with citations to works that more fully expound upon it.

  Citations, therefore, are not necessarily for the work immediate. They are intended for that immediate work, but also for others and the body of legal scholarship as a whole.

  Having had to do research in legal scholarship and other areas of scholarship, I can say that legal scholarship—especially American legal scholarship—has a more richly-woven, and well connected, tapestry of knowledge that truly benefits any serious legal scholar.

  In contrast, history and political science are more often found wanting, lacking, redundant, and pedantic in the quality and utility of their citations.

  This does not mean, however, that all legal scholarship is written well, or that all citations in said scholarship are done well. As with any area, there are the good and great works, and the poor and terrible ones.

  However, any lawyer or legal scholar should have the skills to be able to quickly skim the legal citations in a work in order to parse out the ones they need based on the signals used in each cite and (where they exist) the parentheticals added to the end of each explaining that cites' purpose.

  This may take some training, but if you have not received it after three years of law school then perhaps legal scholarship is not up your alley. (And, really, it usually comes in the form of one 1-3 hour class in your first semester that is not solely focused on this one aspect of legal scholarship.)

  Legal citations are more clear, more useful, and more beneficial to their scholarly body than any other social science field I've dealt with.

  (NOTE—Most legal scholarship uses footnotes, not inline citations. Most legal filings will use inline citations, although that is also changing. This makes even the most riddled-with-citations work more readable, any the reader can easily read the prose while ignoring the footnotes if they so desire.)

  Second, as to the issue of student-reviewed versus peer-reviewed scholarship—I can tell you now that top law students gunning for good grades and accolades spend far more time on the review, selection, revision, editing, and polishing of legal scholarship than peer-reviewed journals in other areas.

  I've been through the student reviewed process on both ends. I have numerous friends and colleagues who go through the peer-reviewed process in their fields. (Including the legal fields in Europe and elsewhere.)

  Frankly, the overall quality of top-notch journals is the same. To claim that a third-year law student that is in the top of their class is not competent to sort through legal scholarship and choose well is utter and absolute hogwash perpetuated by legal academic dandies who have never worked a day in their lives as lawyers and instead yearn for some reason to be treated as social sciences in other fields. (This is especially ridiculous because the folks they want to be like often get paid by their respective institutions far less, except for the fools who somehow do think law should be treated as a science and they treated like physicists or chemists or biologists. And, well, those folks are amazingly obtuse.)

  Having had to clean up mess written by some fairly well-regarded legal academics during my law journal days, and seeing some of the trash published by peer-reviewed journals in other fields, I can safely say that student-reviewed journals are a strength of the legal academia rather than a weakness.

  That is not to say all peer-reviewed works should shift to student-reviewed works. Hardly.

  Law schools in the US train lawyers—professionals who have professional doctorates. The structure of the academic process is fundamentally different than the one faced by, say, a history or political science PhD. One simple difference is the lack of a dissertation. In replace of that, most schools have at least one law journal that only accepts its best students—either from a rigorously judged writing contest, or based on grades, or some combination thereof.

  In short, law journals are staffed often by the top 5%, 10%, 15%, 20% of students who are top-quality legal writers in their own right. These students run the journals, and while burdened with difficult coursework, are not burdened by a large and complex dissertation process.

  This works in law. This will not work in history, political science, or other social science areas.

  However, neither is the student-reviewed process wrong. Nor is the peer-reviewed process wrong.

  Both have their strengths and weaknesses.

  Finally, as to the topic of this article—once again, if a trained lawyer can't sort through citations in case law or articles when skimming a work, then I'd truly worry about hiring them for your case. This is a key and core part of the process of learning to be a lawyer in law school—how to research, how to argue, how to synthesize disparate works into your own arguments. These skills should also be reflected in the professors who so-often write legal academia.

  I'm not sure the value here.

  This is a tool, not a revelation nor a revolution.

  Heck, it sounds like this is just a variation on Shephardizing: https://www.lawinsider.com/dictionary/shephardizing

  In the end, though, this is an algorithm meant to save time. And we all know, with algorithms, garbage in equals garbage out. Plus, assumptions in the design can lead to noise, or errors, in the output.

  "ScholarSift tells authors which articles they should be citing, and tells editors whether an article is novel."

  Really, now? Well, I'm glad someone can tell me who to cite, and whether an article is novel. Because, you know, I didn't go get a law degree, or hell, an undergraduate degree, for that purpose.

  I'll note, finally, that the author is a law professor. It really does make me sad that this law professor seems to hate his field so much, or think so little of the students he teaches, that he believes his colleagues and those students can't use their own mind and skills to determine whether an article is novel, or how and when to cite a work.

  I guess, in the end, we can just let the AIs write our articles: https://www.theguardian.com/commentisfree/2020/sep/08/robot-wrote-this-article-gpt-3

  All hail laziness, all hail our robot overlords.

  Good grief, Charlie Brown. Good grief, indeed.

  (Also, in the spirit of this kvetch, get off my dang lawn you kids!)

• Nov 17, 2020 @ 07:59pm

  Motion to Dismiss stage is very early; this means little

  on Federal Court Says State Regulation That Compels Production Of Code May Violate The First Amendment

  This is at the motion to dismiss stage. This is early. This stage is at the Answer stage of a lawsuit—the first thing defendants do after being served with the lawsuit.

  All this means is that the lawyers for the plaintiffs are competent enough to draft a complaint that ticks all the elemental boxes and provides enough facts to support those elements.

  It is important to understand that, at this stage, the court is NOT stating that the alleged facts are true. In fact, if you the "Legal Standard" section starting on Page 2 of the opinion, they CANNOT make an opinion on the facts. At this stage, all the facts in the Complaint are viewed as true and accurate for the purposes of the motion.

  Don't get me wrong—this may be a case that deserved to be kicked at this stage—but many judges will let discovery proceed and let this issues be resolved at summary judgment.

  To really prevail, the defendants needed to show that EVEN IF all of the facts alleged were true, there STILL was no claim to be had. The judge decided that the facts were sufficient, if true, to raise a claim for infringing the plaintiff's first amendment rights.

  Still, having had to deal with motions to dismiss in my own cases, and having judges find that the copious facts alleged in my complaint were not sufficient—or overlooking some facts and highlighting others in finding insufficiency—I can tell you a judge likely COULD have granted the motion.

  This may come down to political and legal ideology. Or it could come down to views on the roles of motions to dismiss versus motions for summary judgment versus trial. Or it could be the judge is no fan of the legal team presenting arguments because of antics in past cases.

  Litigation, sadly, is no science. And judges are not legal computers. Or, if they are, then the AIs have been trained on widely divergent datasets.

• Oct 17, 2017 @ 01:23pm

  Gawker didn't lose because of libel; it lost because of invasion of privacy

  on The 'Gawker Effect' Is Chilling Investigative Reporting Across The US

  The Gawker case was not about libel. It was about invasion of privacy. Not to say the that defending a spurious libel claim is cheap; I know Techdirt has first-hand experience in this. However, the risk of a terrible verdict is hitting in a libel claim is far lower than in an invasion of privacy claim, especially when that claim is over invasive videos such as sex tapes.

• Oct 10, 2017 @ 05:14pm

  If Harder sues, those NDAs will be pierced . . .

  on Harvey Weinstein Tries Every Possible Response To Explosive NY Times Story

  An NDA can't survive a subpoena or court order compelling testimony. If Harder sues, then it opens up the doors for all those NDAs to be pierced and the stories to begin coming out.
  
  Harder puts his clients at more risk with his antics, not less. I am not impressed with his litigation skills. His business and moneymaking skills? Yes. His skills in getting sugar daddies like Peter Thiel to pay for cases under the table? Yes. But the truest litigators mitigate risks for their clients.

• Sep 12, 2017 @ 07:35am

  Republicans want to gut regulations, then gut consumer protection laws

  on Comcast Continues To Insist Its Sneaky, Misleading Fees Are Just The Company's Way Of Being 'Transparent'

  What kills me is that the so-called "small government" and "pro-free market" Republicans want to gut regulations, and then gut consumer protection laws.
  
  Regulations often level the playing field for consumers who otherwise don't have the market power to punish local monopolies, such as utilities like broadband service providers, to prevent abusive market practices.
  
  The economic argument against government oversight, however, is that it is inefficient. The free market should be used to provide punishment for abusive practices. The problem is that broadband providers often have monopolistic positions, sometimes created by legal regulation in some jurisdiction. Yet, Republicans don't want to address this issue and create an actual free market.
  
  One way to counter this is to create private rights of action through consumer protection laws. Many states, and the federal government, have consumer protection laws which can be used by individual or classes of consumers to obtain relief from abusive practices. In economic parlance, this is one method of forcing an economic system to internalize otherwise external harms and provide feedback to the system so that pricing can properly adjust within the market. (Market competition also provides this, but in some situations competition does not exist, and other forms of feedback and redress are needed.)
  
  However, Republicans want to gut the Consumer Financial Protection Bureau. They wish to gut other consumer protection laws, such as the FDCPA and various protections granted under FTC regulations. They want to curb the rights of consumers to bring self-help lawsuits by allowing companies to require arbitration or prohibit class actions.
  
  The Republicans are not looking at this in a holistic manner. They essentially want big business to win, and consumers to lose, with no balance between the powers. This harms not just consumers, however, as over time it harms big business as well. Over time the value of a business venture will degrade if not renewed with new ideas, output, and efficiency. Monopolies reduce new ideas, reduce output increases, and promote inefficiencies.
  
  Then again, looking at who backs the Republicans generally (looking at you U.S. Chamber of Commerce) none of this is really a surprise.

• Aug 10, 2017 @ 08:24pm

  This is terrible; I've used both SSRN and BePress and this is depressing

  on Elsevier Continues To Build Its Monopoly Solution For All Aspects Of Scholarly Communication

  I have my scholarly works on both BePress and SSRN.
  
  Both serve similar but slightly different purposes. SSRN is more for sharing scholarly works within the Social Science community, and it plays an important role. (Or did; we'll see if it wanes.) Tenure can literally ride on how popular a work is on SSRN.
  
  BePress tried to do what SSRN did. However, it never quite caught on as much. This was in part because it was always more commercial, whereas SSRN was always more "academic-y" (until it sold out, much to the dismay of many academics!).
  
  What BePress did differently, however, was allow academics to host a mini biography-style page of their work—a collected works page—which could be separate from their University or work profile.
  
  It also allowed Universities to automate collected work pages for their professors, which was nice for the University IT team.
  
  BePress is also one of the main ways in which law review submissions were made by aspiring or well-established legal scholars. (I've been out of the market practicing for a few years; things may have changed.) This led to BePress offering Journals (not just legal Journals) ways to manage and handle the submission workflow process, from submissions, review, acceptance/rejection, edits, revisions, and finally publishing (including a web publishing platform).
  
  This was changing rapidly when I was last involved with a Journal on the editing side (yikes, almost a decade ago!), so I don't know where it is now.
  
  In short, both BePress and SSRN allowed Universities and Academics to showcase their academic works in different ways. BePress was a bit more polished, commercial, and outward facing. SSRN was a bit more simple and academic-facing/focused. However, both play (or played) an important role, and it sucks to see BePress sucked up.
  
  There are open source solutions as well, but they are not as good or widely adopted, and a pain to manage for non-IT scholarly editors.
  
  Ah well. Everything awesome is coopted by megacorporations. Even academia.

• Sep 04, 2015 @ 02:36pm

  Property doesn't last forever . . .

  on Can You Really Be A Copyright Expert If You Think Copyright Should Last Forever?

  The premise seems to be that intellectual property, i.e. copyright, should last forever like property.
  
  Except property law does not allow for property to last forever. It requires constant maintenance in the law or it becomes abandoned.
  
  Any decent property law scholar knows this.
  
  Utter fail.

• Aug 11, 2015 @ 05:30am

  Wow-prosecutors should be sacked

  on St. Louis County Charges Journalists Who Covered Ferguson Protests With Trespassing

  What are the prosecutors doing here? I hope this goes Streisand on them, especially after the 1 year anniversary of the shooting just passed.
  
  Note to self: Avoid St. Louis, period. The rules of law and common sense do not apply there.

• Jul 24, 2015 @ 08:14am

  Re: Access?

  on State Of Georgia Sues Carl Malamud For Copyright Infringement For Publishing The State's Own Laws

  I had no problem accessing the PDF directly here:
  http://www.archive.org/download/gov.uscourts.gand.218354/gov.uscourts.gand.218354.1.0.pdf
  
  This is the "suing Malamud" link above.
  
  You can then save the PDF somewhere else, or print it. Just FYI.

• Jul 24, 2015 @ 08:12am

  Re: Re: Re: Ignorance is a pre-requisite for being in government in GA

  on State Of Georgia Sues Carl Malamud For Copyright Infringement For Publishing The State's Own Laws

  Here is an article on whether and when ignorance of the law is an excuse, and is not an excuse:
  http://www.heritage.org/research/reports/2013/06/ignorance-of-the-law-is-no-excuse-but-it-is-reality
  
  It looks at crimes that are malum in se versus those that are malum prohibitum. Good quick read as far as these things go.

• Jul 24, 2015 @ 07:42am

  Re: Ignorance is a pre-requisite for being in government in GA

  on State Of Georgia Sues Carl Malamud For Copyright Infringement For Publishing The State's Own Laws

  Ignorance of the law is not an excuse.
  
  However, ignorance of the law, and reason, and logic, are pre-requisites for being members of the General Assembly and for most state-wide and local-government offices.

• Jul 24, 2015 @ 07:40am

  Re: Only federal works cannot be copyrighted

  on State Of Georgia Sues Carl Malamud For Copyright Infringement For Publishing The State's Own Laws

  The explicit prohibition against government works being copyrighted in the Copyright Act only applies to federal works, not state government works.
  
  There is case law supporting an extension to state works on various grounds, however.

• Jul 24, 2015 @ 08:39am

  Motions in Limine; not properly used here

  on Malibu Media Seeks Order Forbidding Defendants From Discussing 'Copyleft' Blog Content

  A pre-emptive use of a motion in liming (which this is, even if not styled as such) can be useful.
  
  However, a blanket ban on use of this material is not proper. The material should be excluded if it is not relevant or is hearsay (or both), but that determination probably can't be made until much later in the case.

• Jul 24, 2015 @ 07:02am

  Standing is an issue

  on State Of Georgia Sues Carl Malamud For Copyright Infringement For Publishing The State's Own Laws

  Not sure what law or resolution has granted the Code Revision Commission authority to represent the General Assembly of Georgia or the State of Georgia. I don't think they have legal standing.
  
  Also, not sure how they hold the copyright to this, and while I haven't pulled the full filing, have they shown that the alleged copyrighted works were registered prior to filing?
  
  This case is a crock. This law firm and their lawyers should be ashamed. Unfortunately, I run into too many shameless lawyers in my litigation work.

• Jun 12, 2015 @ 11:07am

  We are all criminals . . .

  on Virginia Teenager Charged With Providing 'Material Support' For ISIS Through Tweets, Blog Posts About Privacy And Bitcoin

  Whenever the Crown desires to designate us as such.

• Jun 12, 2015 @ 06:57am

  I see what you did there . . .

  on Senate Quickly Says 'No Way' To Mitch McConnell's Cynical Ploy To Add Bogus Cybersecurity Bill To NDAA

  I see what you did there with your "Patriot Act games" refere
  
  Sadly the only Patriot Games meme photo I could find in a pinch:
  One does not simply hunt Harrison Ford in the Patriot Games.

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