EFF takes on Texas' digital ID law.
David Bittner: Hello, everyone, and welcome to Caveat, N2K CyberWire's Privacy, Surveillance, Law, and policy podcast. I'm Dave Bittner, and joining me is my co-host, Ben Yelin, from the University of Maryland Center for Health and Homeland Security. Hey, Ben.
Ben Yelin: Hello, Dave.
David Bittner: On today's show, Ben discusses litigation related to a new online age verification law in Texas. I've got the story of Congress perhaps being on their way to passing a federal privacy bill. While this show covers legal topics, and Ben is a lawyer, the views expressed do not constitute legal advice or official legal advice on any of the topics we cover. Please contact your attorney. [ Music ] All right, Ben, before we jump into our stories here, I have a quick little bit of follow-up. You know, last week, we were talking about Scarlett Johansson.
Ben Yelin: Yeah.
David Bittner: And the --
Ben Yelin: Did she contact us?
David Bittner: Still no. Yeah, she's still not returning my emails.
Ben Yelin: One day. One day. I won't tell Colin Jost.
David Bittner: That's right. Exactly. I'd hate to get into some sort of kerfuffle with Colin Jost.
Ben Yelin: Yeah, I mean, he can really roast you on Weekend Update.
David Bittner: That's true. That's true. So we were talking about whether or not there was any sort of legal recourse if someone impersonates a voice, and we were saying that there really isn't, but it turns out that folks have been taken to court for this and prevailed. There's a story in the Washington Post in the time since we last recorded. Most of the story was about how the OpenAI folks provided documentation that they were not actually using Scarlett Johansson's voice, that they had hired another actress to provide the voice, and it was just a coincidence that it happened to sound like Scarlett Johansson. That's their story, and they're sticking to it, but in this article, they talked about a case back in the 1980s where Bette Midler, the famous entertainer, had sued Ford Motor Company because they had asked Midler to use her voice in ads, and she declined, so they hired an impersonator. And according to this article, an appellate court ruled in Bette Midler's favor, indicating that her voice was protected against unauthorized use, so that's interesting.
Ben Yelin: Yeah, I still wonder how different it would be in the context of artificial intelligence because it's just much more plausible that a voice generated through AI is not going to bear a close enough similarity to the original voice that it would be legal appropriation of that voice. Whereas if you have a direct impersonator, it might be more obvious to a jury or to a judge that it's a direct impersonation, but it is really interesting. I had not heard about that case.
David Bittner: Yeah.
Ben Yelin: Yeah.
David Bittner: Yeah. I remember, it's funny, I remember those ads from back in the day and thinking that it was Bette Midler as the voice, and it was not. So it worked.
Ben Yelin: Yeah. They tricked you. She does have a very distinctive voice. I mean, I mostly know her from Seinfeld, but, you know, I can definitely see how somebody might be fooled.
David Bittner: Yeah. Yeah. I wonder what the case -- I mean, it's so funny when you're dealing with famous people, right? Because it just seems like the law doesn't have to be quite so clear when it's a famous person --
Ben Yelin: Yeah.
David Bittner: -- who's been wronged.
Ben Yelin: I think there are so many opportunities for fair use for things like parody or if you're trying to stereotype, and it's not necessarily Bette Midler, but it's like a Bette Midler-type person who's doing an ad read, I just think there's more room for flexibility there, and I think with AI, you can kind of reverse engineer it so that the voice isn't close enough that it's totally obvious that you're taking somebody's voice. I think that's really what happened in the Scarlett Johansson case is they made it so that it was Johansson-esque, but not fully Johansson in a way that they think will shield them from liability, and it probably will.
David Bittner: Yeah. We'll see how it plays out. All right. So interesting bit of follow-up there. Why don't we jump into our stories here? What do you got for us, Ben?
Ben Yelin: So my story comes from the Electronic Frontier Foundation. They have filed an amici brief with the Supreme Court, Friend of the Court Brief, and this is a case called Free Speech Coalition Incorporated versus Ken Paxton in His Capacity as the Attorney General of Texas. So Texas passed a statute related to online age verification. It's a complicated statute, but the relevant part is that for any website where more than one-third of the content could be considered derogatory or not age-appropriate for people under the age of 18 years old, then for anybody to use that website, they have to go through an age verification process, which includes uploading a form of physical ID. The Fifth Circuit Court of Appeals, which is a very conservative circuit, as we've discussed, upheld this law, which was, I think, surprising, even despite its conservative bent. The concern expressed by the Electronic Frontier Foundation and other groups who are part of this Free Speech Coalition is that this is an overbroad restriction on the First Amendment rights of adults. So their main complaint in this case is that this could prevent adults not just from accessing pornography, which in most cases they have the right to do as consenting adults, but accessing other First Amendment-protected material because it happens to share a website with some type of content deemed inappropriate by the Texas legislature. That one-third rule is just kind of bizarre. I mean, they laid out a couple of examples in their briefs. Like let's say there was a high school sex-ed curriculum as part of some type of website. Even if that was just a small part of the website, if the legislature determined that that would be kind of something that would lead to prurient interests, then adults would have to, in order to access any part of that website, would have to upload a form of ID, which is pretty intrusive. I mean it's not just burdensome, scanning your ID, taking a picture, and uploading it. But obviously, that's a lot of very sensitive information. If you're uploading your driver's license to a pornography website, I'm not sure you can be very trusting of what that website is going to do with your personal information, and I don't think you should be.
David Bittner: Right. You can understand the motivation for wanting anonymity in that case as well.
Ben Yelin: Yeah, and the Supreme Court has long protected the right to anonymous free speech. So the Fifth Circuit was overly reliant, in my opinion, on a 1968 case called the Ginsburg case, and that was about requiring a form of photo identification for the purchase of pornographic materials in a brick-and-mortar bookstore. The reason that I don't think that precedence is particularly relevant here is you didn't have to show an ID to get into the bookstore. You had to show ID to buy the pornographic materials, if that makes sense. And what's happening here is the gate that's being put up is for the websites themselves, not just for the explicit images.
David Bittner: Interesting, right.
Ben Yelin: Right. So when we're talking about the First Amendment, we're talking about strict scrutiny, which means that any law has to have a damn good reason for existing, and the means have to be very narrowly tailored to achieving those ends, and the law cannot be overbroad, and it seems to me that by definition this law is overbroad. I think there are plenty of other ways of accomplishing, even if you grant that the State of Texas has a compelling interest in regulating this content and keeping children away from this content, there are other ways to achieve that goal. For example, only requiring photo identification or verification for a particular image or particular video, not just to enter a website where one third of the content is adult in nature.
David Bittner: Right. Yeah, I mean, it just seems unreasonable to me. I can imagine something like a medical website, you know, even if that website talked about reproduction or abortion or plumbing, all those kinds of things, folks wouldn't want their kids looking at that, but theoretically, you can imagine some folks wouldn't want their kids looking at that.
Ben Yelin: Right.
David Bittner: And they can make a case for that, but there's a whole lot of other useful information on that website that folks should have access to, and you could make the argument even children should have unrestricted access to.
Ben Yelin: Right. And so why put the gate -- yeah, and why put that gate up and create these burdensome verification requirements if most of the site is useful? I mean, that's going to end up suppressing a lot of speech. One thing that EFF compared this to is a service like Netflix. So let's say in order to use Netflix, you had to upload some type of age verification, your driver's license or your passport or whatever.
David Bittner: Right.
Ben Yelin: You would have to upload that whether you were going to watch X-rated content or children's movies, Disney G-rated stuff. That would not make sense. It just, from a practical perspective, it just doesn't seem like a wise policy option. And from a constitutional perspective, you can't burden First Amendment rights in a way that's going to prevent people from accessing such a vast wealth of material. There's just so much case law that makes that point. Now we do not develop laws in this country by fiat. It is up to the individual judges who are considering the facts of this case. Obviously, the Fifth Circuit felt differently. You can chalk that up to the Fifth Circuit being the Fifth Circuit, but we have a pretty conservative Supreme Court. So first, we have to determine whether the Supreme Court will take this case. Generally, it requires four justices believing that there's a relevant constitutional issue for them to take it up. That's what EFF is petitioning for at this point, is simply to get the case heard on the merits. I think there's a decent chance of that. You have the three liberal justices, and I'm sure one conservative might have some interest in adjudicating this question, although you can't be entirely sure, and then there's the case on the merits. And you just -- it's hard to know with any certainty on this Supreme Court, no matter how overbroad we think the law is, that they're going to hold it as unconstitutional. I will say there are some First Amendment absolutists on the Court, including somebody like Justice Gorsuch. I think he would find this law to be offensive to First Amendment precepts, and I would predict that he would overturn the Fifth Circuit, but that's just a prediction. So there's no way of knowing until the Supreme Court actually gets its hands on this case.
David Bittner: Do we know what Texas's intention is with this law here? I mean, is this primarily trying to limit access to pornography?
Ben Yelin: No, I mean, it's trying to limit access to pornography, particularly for minors. That's the reason for requiring age verification, but it creates a significant burden on adults. For one, a lot of people don't have government-issued identification. Now, I know this becomes a major political issue when we're talking about things like voting, but there are a lot of people who are kind of on the margins of society, or maybe they live in a big city and they don't need a car, so they don't have a driver's license.
David Bittner: Right.
Ben Yelin: These are adults, and you're inhibiting their First Amendment rights. So even though it is intended, age verification is to protect against minors, there are other ways to achieve the goal of verifying somebody's age, and I think the District Court in this case, when the litigation first started, both parties kind of stipulated that there were other methods that Texas could have used to effectuate these same goals, and they just didn't, and I think that's, frankly, very concerning from a First Amendment perspective.
David Bittner: I wonder if there are other technological solutions to this. I'm thinking of things like the way Face ID works on your iOS device, right?
Ben Yelin: Right.
David Bittner: Where you have this secure enclave that verifies you are who you are supposed to be based on how you previously scanned yourself in, and so on and so forth. But basically, all that happens with that secure enclave is the app queries it and says, hey, is this the person that it's supposed to be? Face ID does the scan, does its behind-the-scenes things, and just responds and says, yep, it is, and we're good here. So my point is, you know, could there be some sort of on-device age verification that didn't require uploading your information to a third party, where the third party just queries and says, hey, is this person over 18, and the device says, yep, we previously verified it, you're good to go. Off you go.
Ben Yelin: I mean, that would seem to make sense to me. Most of our devices use some form of biometrics. I know to log into my computer, I have to give them my fingerprint.
David Bittner: Right.
Ben Yelin: And so seemingly, there's some way of knowing that that fingerprint belongs to an adult and not a child, and I'm sure the device could submit that verification. But I think the State of Texas wanted to go further, whether this was for political purposes or just a genuine belief that minors have too much access to inappropriate material online, they went a step further and didn't provide biometrics as a sufficient tool to access these websites. It requires this form of ID uploading and verification.
David Bittner: Yeah, I guess my question, though, would that be -- what I'm describing here, would that be just kind of kicking the can down the road? In other words, for the person that you describe who may not have an ID, how are they -- does it just shift the burden that, well, they still can't verify their ID to their local device, so it doesn't really solve the problem?
Ben Yelin: Yeah, although I think it solves the problem in a couple of respects. One, as you mentioned, Face ID is secure in a way that uploading your ID to a website that's one-third inappropriate material for children might not be secure.
David Bittner: Right.
Ben Yelin: I think iOS and other operating systems have done a pretty good job of protecting the security of our biometric information. An ID also contains a wealth of other additional information that you would not want websites to have access to. So I think there would be a significant difference in the privacy concerns of sharing that information. But yeah, I mean, I do think there would still be some, I don't necessarily want to refer to it as equity when we're talking about pornography. But it's not just pornography, I mean, it's an over-inclusive definition that could include a lot of First Amendment protected material, like stuff that has artistic value or political value. So yeah, I still think that could be an access problem. If it's device-dependent, then we're restricting First Amendment protection to people who have those devices, and that also might be offensive to our First Amendment principles. There are limits to the right to access information, but those limits have to be narrowly tailored, given that the First Amendment creates this compelling interest. So if it's not sufficiently tailored, then I think it's an overbroad regulation on First Amendment speech and unconstitutional, but we'll see if the Supreme Court agrees.
David Bittner: The other thing that strikes me with this is that, you know, it's my understanding that the folks who sell online pornography or provide it or sell it, sample it, whatever, however you want to, provide access to it, right? They don't want underage people looking at their stuff. It is not in their best interest to do so. And so they are very overt about tagging the contents of their websites with the agreed-upon industry standard tags that say, hey, this is adult stuff.
Ben Yelin: Right. If you're not an adult, get the hell off of this website.
David Bittner: Right, and there are plenty of tools available to parents for filtering that sort of thing, either on the device. You can filter it with your DNS resolution services, you know, where you can say, I want everything, every time we look up a domain in our household, check to see if it's pornography or not, and if it is, don't resolve it. And that's one way to just keep it out of the house altogether.
Ben Yelin: Right, or something like safe search mode on Google --
David Bittner: Right.
Ben Yelin: -- accomplishes the same thing.
David Bittner: Now I'm not naive enough to think that, you know, you cannot -- the first thing your teenage kids are going to do is crowdsource a solution around this problem.
Ben Yelin: Right.
David Bittner: Like my wife and I joked that, you know, we may be able to outsmart our kids, but we cannot outsmart our kids and all of their friends combined.
Ben Yelin: Yeah.
David Bittner: So --
Ben Yelin: Yeah. There's the collective brain of -- brains of teenagers are probably going to beat the adults, especially as it relates to technology.
David Bittner: Right, yeah. But you get my point here that -- could that be a solution, as well, where you just have something, rely on those tools, the existing tools to allow -- to meter the access to this sort of content?
Ben Yelin: Yeah, and that's so relevant from a legal perspective, because the more of these alternatives that you can think of, the less constitutionally permissible this law is. Because I think what the State of Texas is going to try to argue in court and what they argued in the Fifth Circuit and what they'd argue at the Supreme Court is this is narrowly tailored. This is the only way that we can achieve our goal of keeping minors away from this content, and so if you have a multitude of examples of other methods one could use that would be less restrictive on the First Amendment rights of adults, that's going to cut against Texas's argument, and I think that's certainly reflected in the Electronic Frontier Foundation's brief. It's reflected in their argument, and I think it's something that this coalition of free-speech advocates is going to bring up in any court proceeding. There are sufficient alternatives. They will describe in detail those alternatives to try and break this sort of Texas argument that this should survive strict scrutiny.
David Bittner: So what's up next for this is we wait and see if the Supreme Court will take the case at all?
Ben Yelin: Yeah. So the Supreme Court has a calendar of when they're going to consider petitions. It's usually weekdays at 9:30. So if you're a real nerd about this stuff, some weekdays, usually it's like Mondays and Thursdays, they'll release the list of cases that they're accepting, which is called granting cert, granting certiorari. We'll see if they grant cert in this. For it to be heard during the next Supreme Court term, or to ensure that it's heard in the next Supreme Court term, we'd have to hear by the end of this current term, which would be the end of June, perhaps early July. They still could decide to take it up next year, but given that this is so ripe and we just got a relatively recent decision from the Fifth Circuit on this, I think it's more likely that if they're going to take up the case at all, they'll do so promptly, and then we'd have an oral argument sometime next year and a decision next spring, 2025.
David Bittner: What happens if the Supreme Court doesn't take it? Is that it, or is there any opportunity for appeal within Texas?
Ben Yelin: That's it.
David Bittner: That's it.
Ben Yelin: The Fifth Circuit Court of Appeals is the next-highest federal court. So to the extent that this is a federal case, which it is, if the Supreme Court denies certiorari, then the decision of the Fifth Circuit stands. So the Fifth Circuit upheld the statute. So opponents will be SOL on this one if the Supreme Court does not take it up.
David Bittner: They'll be buying their VPNs.
Ben Yelin: Yes. Although we do not advise residents of Texas to evade this law while it is in effect. Do we need another disclosure or disclaimer at the beginning of our podcast just on this particular issue?
David Bittner: Nah. VPNs are useful for all sorts of things.
Ben Yelin: Right?
David Bittner: All right.
Ben Yelin: Cannot confirm nor deny that.
David Bittner: We will have a link to that story in our show notes. All right. We're going to take a quick break here, and we will be right back after this message from our sponsor. [ Music ] My story this week comes from the folks over at CyberScoop. This is about potentially a federal privacy bill that has passed an important House subcommittee, which means it could be on its way to further consideration in the House itself.
Ben Yelin: Uh-huh.
David Bittner: So this is the House Energy and Commerce Subcommittee. They unanimously approved this proposal, which is called the American Privacy Rights Act, which aims to establish federal data privacy standards. Which, of course, you know, has been a longstanding gap in U.S. legislation when it comes to privacy. Nothing is for sure. This article points out that even members of the committee have raised concerns, and that it will surely be changed as it makes its way through the meat grinder that is the House of Representatives and Congress itself. But there's some interesting things in here. I mean, there's requirements for reporting, opt-out mechanisms for data brokers, and the transferring of privacy data for researchers, things like that. What do you make of this, Ben? Is this a beacon of hope here that this has made so far or not really?
Ben Yelin: I am skeptical. I am skeptical.
David Bittner: Yeah.
Ben Yelin: I'll also note something they included in this bill is what they call COPPA 2.0, which is the Children and Teens Online Privacy Protection Act. And this would institute new restrictions on how companies collect data on minors and teenagers. That has its own controversial aspects, and so if you have lawmakers that oppose just that provision, you might not be able to log roll it into this greater data privacy bill. So there's hope. I mean, it passed the subcommittee on a bipartisan, unanimous basis. It's going to go to the Full Energy and Commerce Committee, which is chaired by the representative, Cathy McMorris-Rogers, who is the primary sponsor of this bill in the House. But we've kind of been down this road before where these bills do well in committee, but for one reason or another, it's the next step of getting the bill from the committee to the floor and ensuring a floor vote. That's where things kind of fall apart. And they fall apart on a number of different issues. A big one that I'm looking out for is this issue of preemption. So this bill has a provision in it that would preempt data privacy laws, subject to certain exceptions from the 50 state legislatures. Maryland, our home state of Maryland, just joined the growing list of states who have passed online data privacy acts. And so I think representatives from those states would be concerned that the floor for data privacy is going to be lowered if this bill gets enacted, because this would supersede any state legislation that might be stronger or have more robust privacy protections. So that's what sunk a previous version of this effort at the end of 2022. Nancy Pelosi was still the Speaker of the House. She represents California. California had passed CCPA, and she didn't like this preemption aspect. As Speaker of the House, at the time, she could just kind of kill it. Sit on it and not bring it to the floor. I don't know, for example, what Speaker Mike Johnson thinks about all of this. I have no idea what his views are on federal data privacy legislation, but he wields a lot of power. If he decides he doesn't want to bring this to the floor, then there are steps that you could take to force a floor vote, but it certainly would not be easy. So I'm just very skeptical that this is the thing. Everything kind of has to go perfectly for this to be enacted into law, not to mention the sort of nebulous United States Senate, where you never know what's going to happen there. The rules are even more arcane and arbitrary. So it's a good first step. We'll leave it at that.
David Bittner: Well, I mean, it's a repeat good. It's like an echo, right? Because this isn't our first time trying to get something like this through, as you say. They keep chipping away at it.
Ben Yelin: Yeah, I mean, it's kind of like -- I was trying to think of a good metaphor for this. It's kind of like the Jenga Tower, where every piece has to be perfectly in balance for the tower to survive, and if you kind of poke at one of the pieces from any angle, the entire thing collapses. So everything has to go perfectly. You have to get 218 members to agree on everything, and then you have to get 60 senators to agree on everything. So if there's some provision of the bill that some members are determined to get rid of, then that throws the entire thing into jeopardy, and since that's happened so many times in the past, I just think I'll believe it when I see it. I'll believe it when we have a signing ceremony. The only way I could see this getting enacted this year is if it's pushed on some type of must-pass bill. We still need to pass appropriations bills by the end of September. So there's an opportunity there, and there might be other opportunities as we get into the lame-duck portion of the session at the end of the year. But besides that, I'm keeping on my skepticism hat, which I wear quite proudly.
David Bittner: This article -- well, I think justifiably so. This article points out that some of the lawmakers here are trying to push this through before the election. I guess they feel they have better chances for bipartisan momentum than they would after the election.
Ben Yelin: Yeah, I think there's sort of like a bit of an expectation on the Hill that Trump is going to win. I mean, he's ahead in the polls. I think he's more of a wild card when it comes to data privacy. Whereas I think President Biden would probably sign a bill like this. So yeah, I mean, I think there's a reason why there's more of an effort to get it done by the end of this year, just for that purpose. But there's no reason that if this fails, it couldn't be resurrected in some form in a future session of Congress. You just keep trying until you get it right, until you find that perfect coalition. I do think the preemption issue is going to be very difficult because you have a lot of states now, a growing list of states that have very robust privacy bills, and representatives from those states are going to be wary about having the federal government come in and preempt those laws. So I think that's going to be just a major, major sticking point.
David Bittner: But if you don't preempt the state laws, you take away one of the major motivations here, which is to not have the patchwork of laws from each state, right?
Ben Yelin: Right. It's kind of a -- this is kind of a game theory problem here where it might be better for the individual states to not have their laws preempted, but it would be better for everybody if we had universal standards.
David Bittner: Yeah.
Ben Yelin: So you just kind of have to figure out a way to craft a bill that doesn't set such a low floor that the states freak out because it's going to cut away at existing privacy protections, but it doesn't do too much that you lose the sort of broad coalition that agrees that we need some type of robust data privacy protection. So that's a really fine line. It's just a really difficult problem to solve, and that's why it hasn't been solved to this point yet.
David Bittner: It reminds me of the days back when folks were arguing about Obamacare, right? Not that folks have ever stopped arguing about Obamacare, but in the days when it was a hot topic of debate among folks, you would see people saying, and I'm going to make up a number here. They would say something like, you know, 70% of Americans are against Obamacare, or they'd say 70% of Americans don't approve of Obamacare, right? And you'd see that number, and you'd go, oh my goodness, you know, most people aren't for Obamacare. But then if you unpacked it, like half of those people thought it went too far, and half of those people thought it didn't go far enough, right?
Ben Yelin: Yeah, it's the old Goldilocks problem.
David Bittner: Right, right.
Ben Yelin: People will oppose this bill from so many different ideological angles that it's just -- it's really hard to find that perfect sweet spot.
David Bittner: Yeah.
Ben Yelin: In my experience, it tends to come together when legislators get desperate, and that's usually from must-pass pieces of legislation, which is how we got the TikTok ban. It happened because there was this bill that funds Ukraine aid and funds aid to Israel and to Taiwan. Because they attached the TikTok provision to that bill, I think people were like, I can't let the perfect be the enemy of the good. I support foreign aid to these countries. So I'm just going to vote for the whole thing, and that kind of creates a sense of urgency. But until we get to that point, why wouldn't an individual representative say, hey, I'm not voting for this until it meets my particular interest or the interests of my district or my state.
David Bittner: Right.
Ben Yelin: They have the full incentive to do that because I think they have every proper expectation that they can hold out for something better. Even if I don't necessarily think that's true, I can understand why they would think it's true.
David Bittner: Yeah. What a peculiar way to do the work of the people, right?
Ben Yelin: It sure is. I will say this, like and I'm not trying to toot my own horn or to diss other news sources, but I don't think there's enough implicit skepticism in especially non-political news sources about how hard it is to get something through Congress. I think articles like this and many others are like, hey, let's passed the subcommittee. We're on the glide path now.
David Bittner: Right.
Ben Yelin: I think every article should come with much more skepticism. Like, okay, this is one preliminary step. We have a lot of pitfalls. Like, let's hold our horses here. I feel like that's not as well reflected, especially in non-political sources, technology news sources, than it should be. And maybe we can start to change that here on this podcast.
David Bittner: That's right.
Ben Yelin: More skepticism, everybody.
David Bittner: The incredible influence that you and I wield when it comes to policy decisions and journalism writ large.
Ben Yelin: Oh, for sure. You need the Ben and Dave stamp of approval to get anything passed these days.
David Bittner: Sure, sure. Absolutely. All right. Well, we will have a link to that story in the show notes, and of course, we would love to hear from you. If there's something you'd like us to consider for the show, you can email us. It's caveat at N2K.com. [ Music ] And that's Caveat brought to you by N2K CyberWire. We'd love to know what you think of this podcast. Your feedback ensures we deliver the insights that keep you a step ahead in the rapidly changing world of cybersecurity. If you like our show, please share a rating and review in your podcast app. Please also fill out the survey in the show notes or send an email to caveat@n2k.com. We're privileged that N2K CyberWire is part of the daily routine of the most influential leaders and operators in the public and private sector, from the Fortune 500 to many of the world's preeminent intelligence and law enforcement agencies. N2K makes it easy for companies to optimize your biggest investment, your people. We make you smarter about your teams while making your teams smarter. Learn how at N2K.com. This episode is produced by Liz Stokes. Our executive producer is Jennifer Eiben. The show is mixed by Tre Hester. Our executive editor is Brandon Karpf. Peter Kilpe is our publisher. I'm Dave Bittner.
Ben Yelin: And I'm Ben Yellen.
David Bittner: Thanks for listening. [ Music ]
