WOODHULL FREEDOM FOUNDATION et al v. UNITED STATES OF AMERICA et al

Filing 5

MOTION for Preliminary Injunction by HUMAN RIGHTS WATCH, ERIC KOSZYK, JESSE MALEY, THE INTERNET ARCHIVE, WOODHULL FREEDOM FOUNDATION (Attachments: #1 Declaration of K. D'Adamo, #2 Declaration of R. Levy, #3 Declaration of D. Pokempner, #4 Declaration of E. Koszyk, #5 Declaration of J. Maley, #6 Declaration of B. Kahle, #7 Declaration of A. Lutnick, #8 Declaration of A. Levy, #9 Declaration of K. Mehlman-Orozco, #10 Text of Proposed Order)(Corn-Revere, Robert)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
WOODHULL FREEDOM FOUNDATION,
HUMAN RIGHTS WATCH, ERIC KOSZYK,
JESSE MALEY, a/k/a ALEX ANDREWS, and
THE INTERNET ARCHIVE,
Plaintiffs,
v.
THE UNITED STATES OF AMERICA
and JEFFERSON B. SESSIONS, in his
official capacity as ATTORNEY GENERAL
OF THE UNITED STATES,
Defendants.

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Case No. _______________

DECLARATION OF BREWSTER KAHLE
Pursuant to 28 U.S.C. § 1746, I, BREWSTER KAHLE, hereby declare as follows:
1.

The facts contained in the following affidavit are known to me of my own

personal knowledge, and if called upon to testify, I could and would competently do so.
2.

I am a computer engineer, advocate of universal access to knowledge, digital

librarian, and founder of the Internet Archive, a 501(c)(3) organization located in San Francisco,
California. (http://archive.org).
3.

I am a member of the National Digital Information Infrastructure and Preservation

Program of the Library of Congress, and in 2012, I was inducted into the Internet Hall of Fame
for having made “significant contributions to the development and advancement of the global
Internet” (http://internethalloffame.org/about).
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