Parents, Families, and Friends of Lesbians and Gays, Inc. et al v. Camdenton R-III School District et al

Filing 52

MOTION for leave to file excess pages filed by Mark S. Sableman on behalf of All Plaintiffs. Suggestions in opposition/response due by 10/14/2011 unless otherwise directed by the court. (Attachments: # 1 Proposed Reply in Support of Motion for Preliminary Injunction, # 2 Exhibit 1, # 3 Exhibit 1A, # 4 Exhibit 1B, # 5 Exhibit 1C, # 6 Exhibit 2A (CD received by Clerk's Office w/ indication from filer that copy was provided to chambers), # 7 Exhibit 2B, # 8 Exhibit 3, # 9 Exhibit 4, # 10 Exhibit 5, # 11 Exhibit 6, # 12 Exhibit 7, # 13 Exhibit 8, # 14 Exhibit 9, # 15 Exhibit 10)(Sableman, Mark) Modified on 9/29/2011 (James, Carrie).

The Blue Coat WebFilterTM database contains Web site ratings representing billions of Web pages, published in more than 50
languages, and organized into useful categories to enable customers to better monitor, control, and secure theIr Web traffic,

Blue Coat WebFiltor is supported by Blue Coat's powerful WebPulse cloud community. WebPulse accurately categorizes up
to 98% of unrated objectionable sites in real-time to better enforce customer policy and makes that information immediately
available to all customers (see Blue Coat WebFilter data sheet for more details). The following is an alphabetical listing and
description of the categories currently used by Blue Coat WebFilter to classify Web sites.

CATEGORI ES1

Abortion
Sites that provide information or
arguments in favor of or against abortion,
describe abortion procedures, offer holp
in obtaining or avoiding abortion, or
provide information on the effects, or tack
thereof, of abortion.

Adult/Mature Content
Sites that contain material of adult nature
that do not necessarily contain excessive
violence, sexual content, or nudity. These
sites include very profane or vulgar
content and sites that are not appropriate
for children.

Alcohol
Sites that offer for sate, promote, glorify,
review or in any way advocate the use or
creation of alcoholic beverages, including
but not limited to beer, viine, and hard
liquors. This does not include sites that
sell alcohol as a subset of other products
such as restaurants or grocery stores.

Alternative Sexuality!
Lifestyles

Art/Culture
Sites that nurture and promote cultural
understanding of fine art including bul
not limited to sculpture, paintings and
other visual art forms, literature, music,
dance, ballet, and performance art and
the venues or foundations that support,
foster or house them such as museums,
galleries, symphonies and the like. Sites
that provide a learning environment
or cultural awareness outside of the
strictures of formalized education such
as planetariums are included under
this heading.

Auctions
Sites that support the offering and
purchasing of goods between individuals.
This does not include classified
advertisements.

Audio/Video Clips
Sites that provide streams or downi.oads
of audio or video clips - typically 15
minutes or less in length. This also
includes sites that provide downioaders
and players for audio and video clips.

Sites that provide information, promote,
or cater to alternative sexual expressions
in their myriad forms, Includes but is
not limited to the full range of nontraditional sexual practices, interests,
orientations or fetishes. This category
does not include sites that are sexually
gratuitous in nature which would typically
falL un.der the Pornography category, nor
does it include lesbian, gay, bisexual,
transgender or any sites that speak to
one's sexual identity.

Blogs/Personal Pages

Alternative Spirituality/Belief

Sites that provide or advertise trading
of securities and management of
investment assets (online or offline), This
also includes insurance sites as well
as sites that offer financial investment
strategies. quotes. and news.

Sites that promote and provide
information on alternative spiritual and
non-religious beliefs such as atheism,
agnosticism, wilchcrafi, and Satanism.
Occult practices, voodoo rituals or any
other form of mysticism are represented
here. This includes sites that endorse
or offer methods, means of instruction,
or other resources to affect or influence
real events through the use of spells,
incantations, curses and magic
powers. The category includes sites
that discuss ordeal with paranormal
or unexplained events.

Categories and theroefinlions asot July 6,2011

Sites that primarily offer access
to personal pages and blogs. This
classification includes but is not limited
to content that shares a common domain
such as Web space made available by
an ISP or some other hosting service.
Personal home pages and blogs tend to
be dynamic in nature and their content
may vary from innocuous to extreme.

Brokerage/Trading

Business/Economy
Sites devoted to business firms,
business information, economics,
marketing, business management and
entrepreneurship. This does not include
sites that perform services defined in
another category (such as information
technology companies, or companies
that sell travel services). This does not
include shopping sites.

Charitable Organizations

Sites that fotor volunteerisni
for charitable causes. This also
encompasses non-profit associations
that cultivate philanthropic or relief
efforts. Does not include organizations
ihal attempt to influence legislation as
a significant portion of their activities

or organizations that campaign for,
contribute to, or affiliate with political
organizations or candidates.

Chat/Instant Messaging
Sites that provide chat, text messaging
)SMS1 or instant messaging capabilities
or client downloads.

Child Pornography
Sites that includes visual depiction
of a minor engaging in sexually
explicit conduct.

Computers/Internet
Sites that sponsor or provide information
on computers, technology, the Internet
and technology-related organizations
and companies.

Content Servers
Servers that provide commercial
hosting for a variety of content such as
images an.d media files. These servers
are typically used in conjunction with
other Web servers to optimize content
retrieval speeds.

Dynamic DNS Host
Sites that utilize dynamic DNS services
to map their domain names to dynamiC
iP addresses,

Education
Sites that offer educational information,
distance learning, or trade school
information or programs. This also
includes sites that are sponsored by
schools, educational facilities, faculty, or
alumni groups.

Email
Sites offering web-based email services,
such as online email reading and mailing
list services.

Exhibit B

BtueQCoat

Blue Coat WebFitter URL Categories

Entertainment

Greeting Cards

Intimate Apparel/Swimsuit

Sites that provide information on or
promote mass entertainment media
including but not limited to film, film
trailers, television, home entertainment.
music, comics, entertainment-oriented
periodicals, reviews, interviews, fan
clubs, and celebrity gossip. This also
includes wedding or other photography
sites of a non-adult nature.

Sites thai facilitate the sending of
electronic greeting cards, animated
cards, or similar electronic messages
typically used to mark an event
or occasion.

Sites that contain images or offer the sale
of swimsuits or intimate apparel or other
types of suggestive clothing. This does
not include sites selling undergarments
as a subsection of other products offered.

Hacking

Job Search/Careers

Sites that distribute, promote, or provide
hacking tools and/or information which
may help gain unauthorized access to
computer systems and/or computerized
communication systems. Hacking
encompasses instructions on illegal or
questionable tactics, such as creating
viruses, distributing cracked or pirated
software, or distributing other protected
intellectual property.

Sites that provide assistance in finding
employment and tools for locating
prospective employers.

Extreme
Sites that are extreme in nature and are
not suitable for general consumption.
This includes sites that revel and glorify
in gore, human or animal suffering,
scatological or other aberrant behaviors.
perversities or debaucheries. It includes
visual or written depictions deemed
to be of an unusually horrific nature.
These are salacious sites bereft of
historical context, educational value or
artistic merit created solely to debase,

dehumanize or shock. Examples would
include necrophilia, cannibalism, scat
and amputee fetish sites.

Financial Services
Sites that provide or advertise banking

services (online or offline) or other types
of financial information, such as loans.
This does not include sites that offer
market information, brokerage or
trading services.

For Kids
Sites designed specifically for children.
This category is typically used in
conjunction with other categories - it is
not a stand-alone category.

Gambling
a user can place a bet or
participate in a betting pool, participate
in a lottery, or receive information,
assistance, recommendations, or training
in such activities. This category does not
include sites that seli. gambling-related
products/machines or sites for offline
casinos and hotels, unless they meet one
of the above requirements.

Sites where

Games
Sites that support pi.aying or downloading
video games, computer games, or
electronic games. Also inci.udes sites
that support or host online sweepstakes
and giveaways.

Government/Legal
Sites sponsored by or that provide
information on government, government
agencies and government services such
as taxation and emergency services.
This includes sites that discuss or
explain laws of various governmental
entities. This also includes sites that
advertise legal services, lawyers for hire,
adoption services, information about
adoption, immigration information, and
immigration services.

Health
Sites that provide advice and information
on general health such as fitness
and well-being, personal health or
medical services, drugs, alternative
and complementary therapies, medical

information about ailments, dentistry,
optometry, general psychiatry, self..help,
and support organizations dedicated to a
disease or condition.

Hum or/Jokes
Sites that primarily focus on comedy,
jokes, fun, etc. This may include sites
containing jokes of adult or mature
nature. Sites containing humorous Adult!
Mature content also have an Adult!
Mature category rating.

LGBT
Sites that provide information regarding,
support, promote, or cater to ones sexual
orientation or gender identity including
hut not limited to lesbian, gay, bisexual,
and transgender sites, This category does
not include sites considered sexually
gratuitous in nature that would typically
fail under the Pornography category.

Malicious Outbound
Data/Botnets
Sites to which botnets or other maiware
(as defined in the Malicious Sources
category] send data or from which
they receive command-and-control

instructions. Includes sites that contain
serious privacy issues, such as "phone
home' sites to which sottware can
connect and send user information,
Usually does not include sites that can be
categorized as Malicious Sources.

Malicious Sources

in conjunction with another category

Sites that host or distribute malware or
whose purpose for existence is as part
of the malware ecosystem. Malware is
defined as software that takes control
of a computer, modifies computer
settings, or collects or reports personal
information without the permission of
the end user. It also includes software
that misrepresents itself by tricking
users to download or install it or to enter
personal information. This includes
sites or software that perform driveby downloads; browser hijackers;
dialers; any program that modifies
your browser homepage, bookmarks,
or security settings; and keyloggers. It
also includes any software that bundles
maiware (as defined above] as part of
its offering. Information collected or
reported is 'personal' if it contains
uniquely identifying data, such as email
addresses, name, social security number,
P address, etc. A site is not classified as
malware it the user is reasonably notified
that the software will perform these
actions (e.g., ii alerts that it will send
personal information, be installed, or that
it will log keystrokes].

appropriate to the subject matter
(e.g.. gambling].

Media Sharing

Illegal Drugs
Sites that promote, offer, sell, supply,
encourage or otherwise advocate the
illegal use, cultivation, manufacture, or
distribution of drugs, pharrr.aceuticais,
intoxicating plants or chemicals and their
related paraphernalia.

Illegal/Questionable
Sites that advocate or give advice on
performing acts that are illegal or ol
questionable legality such as service
theft evading law enforcement, fraud,
burglary techniques, and plagiarism.
This also includes sites that promote
scams or that provide or sell legally
questionable educational materials such
as term papers.

Informational
Sites that provide content that is
informational in nature and does not
provide a way to directly act upon the
information (e.g., a site that provides
lottery results, but does not sell lottery
tickets]. This category is always used

Internet Telephony
Sites that facilitate Internet telephony or
provide internet telephony services such
as voice over IP jVO1P).

Sites that allow sharing of media (e.g.,
photo sharing] and have a low risk of
including objectionable content such as

adult or pornographic material.

BLueCCoat

Blue Coat WebFilter URL Categories

Military

Peer-to-Peer [P2PI

Religion

Sites that promote or provide information
on military branches or armed services,

Sites that' distribute software to facilitate
the direct exchange of files between
users. P2P includes software that
enables file search and sharing across
a network without dependence on a
central server.

category also includes news radio
stations and news magazines but does
not include sites that can be rated in
other categories.

Personats/Dating

Sites that promote and provide
information on conventional
or unconventional religious or
quasi religious subjects, as well as
churches, synagogues, or other houses
of worship. This does not include sites
about alternative forms of spirituality or
ideology such as witchcraft or atheist

Sites that promote interpersonal

beliefs [Alternative Spirituality/Belief).

N ewsg rou ps/Forums

Sites that are designed to appear as a
legitimate bank or retailer with the intent
to fraudulently capture sensitive data
e.g., credit card numbers, PIN numbers),

Sites that primarily focus on providing
information about and/or methods that
enable authorized remote access to
and use of a desktop computer or
private network.

Placehotde rs

Restaurants/Dining/Food

Sites that are under construction, parked

domains, search-bait or otherwise
generally have no useful value.

Sites that list, review, discuss, advertise,
and promote lood, catering, dining
services, cooking, and recipes.

Political/Activist Groups

Scam/Questionable/Illegal

Sites sponsored by or that provide
information on poi.itical parties, special
interest grOups, or any organization that'
promotes change or reform in public
policy, public opinion, soCial practice., or
economic activities.

Sites that promote scams or that provide

News/Media
Sites that primarily report information
or comments on current events or
contemporary issues of the day. This

Sites that primarily offer access to
newsgroups, messaging or bulletin
board systems, or group blogs where
participants can post comments,
hold discussions, or seek opinions or
expertise on a variety of topics.

Non-viewable
Servers with non-malicious, nonoffensive content or resources used by
applications, but not directly viewable by
web browsers. Includes but is not limited
to Web analytics sites (such as visitor
tracking and ranking sites) and content
filtering systems.

Nudity
Sites containing nude or seminude
depictions of the human body. These
depictions are not necessarily sexual
in intent or effect hut may include sites
containing nude paintings or photo
galleries of artistic nature, This category
also includes nudist or naturist sites that
contain pictures of nude individuals.

Online Meetings
Sites that facilitate online meetings or
provide online meeting, conferencing, or
training services.

Online Storage
Sites that provide secure, encrypted,
off-site backup and restoration of
personal dots. These online repositories
are typically used to store, organize and
share videos, music, movies, photos,
documents, and other electronically
formatted information. Sites that fit this
criteria essentially act as your personal
hard drive on the internet.

Open/Mixed Content
Sites with generally non-offensive
content but that also have potentially
objectionable content such as adult
or pornographic material that is not
organized so that it can be classified

separately. Sites that explicitly exclude
offensive content are not included in
this category.

Pay to Surf
Sites that pay users in the form of cash or
prizes for clicking on or reading specific
links, email, or Web pages.

relationships.

Phishing

Pornography

Remote Access Tools

or sell legally questionable educational
materials such as term papers. Also
includes sites that advocate or give
advice on performing acts that are illegal
or of questionable legality such as service
theft, evading law enforcement, fraud,
burglary techniques and plagiarism.

Sites that contain sexually explicit
material for the purpose of arousing a
sexual or prurient interest.

Search Engines/Portals

Potentiatty Unwanted
Software

Sex Education

Sites that are not malicious sources
but that host software with undesirabi.e
behavior or cause undesirable browser
behavior such as such as intrusive
adware, adware servers used
exclusively by intrusive sdware,
and browser hijackers.

Proxy Avoidance
Sites that provide information on how
to bypass proxy server features or gain
access to URLs in any way that bypasses
the proxy server. This category includes
any service which will allow a person to
bypass the Blue Coat fiLtering system,
such as anonymous surfing services,

Radio/Audio Streams
Sites that provide stream.s or downloads
of radio, music, or other audio content -.
typically more than 15 minutes in Length.

Real Estate
Sites that provide information on
renting, buying, or selling real estate or
properties. This also includes vacation
property rentais such as time-shares and
vacation condos.

Reference
Sites containing personal, professional,

or educational reference, including online
dictionaries, maps, censuses, almanacs,
library catalogues, genealogy-related
sites and scientific information.

Sites that support searching the Internet,
indices, and directories.
Sites that provide information
(sometimes graphic) on reproduction,
sexual development, sale sex practices,
sexuality, birth control, tips for better
sex, and sexual enhancement products.

Shopping
Sites that provide or advertise the means
to obtain goods or services with either
prices listed or a clear way to order.
This does not include sites that can be
classified in other categories (such as
vehicles or weapons).

Social Networking
Sites that enable people to connect with

others to form an online community.
Typically members describe themselves
in personal Web page profiles and form
interactive networks, linking them with
other members based on common
interests or acquaintances. Instant
messaging, file sharing and Web Logs
(blogs) are common leatures of Social
Networking sites. Note: These sites
may contain offensive material in the
community-created content. Sites in this
category are also referred toss 'virtual
communities" or "online communities".
This category does not include more
narrow'.y-focused sites, like those that
specifically match descriptions for
Personals/Dating sites or Business sites.

BtueQCoat

Blue Coat WebFilter URL Categories

Sites that prc.vido information on matters
of daily life. This includes but is not
limited to pet care, home improvement,
fashion/beauty tips, hobbies, and other
tasks that comprise everyday Life, it
does not include sites relating to
entertainment, sports, jobs, personal
pages, or other topics that already
have a specific category.

Software Downloads
Sites that are dedicated to the electronic
download of software for any type of
computer or mobile device, whether for
payment or at no charge.

Spam

Sites considered to have suspicious
content and/or intent that poses an
elevated security or privacy risk.
This categorization is determined by
analysis of Web reputation factors.
This also includes sites that are part
of the Web and email spam ecosystem.
If a site is determined to be clearly
malicious or benign, it wilt be placed in
a different category.

Sports/Recreation
Sites that promote or provide information
about spectator sports or recreational
activities. This does not include sites
dedicated to hobbies such as gardening,
collecting, board games, scrapbooking,
quilting, etc.

Violence/Hate/Racism
Sites that depict extreme physical harm
to people, animals, or property, or that
advocate or provide instructions on how
to cause such harm, This also includes
sites that advocate or depict hostility
or aggression toward, or denigrate an
individual or group on the basis of race,
religion, gender, nationality, ethnic origin,
or other involuntary characteristics, and
includes content that glorifies selfmutilation or suicide.

=

Weapons
Sites that sell, review, or describe
weapons such as guns, knives, or martial
arts devices, or provide information
on their use, accessories, or other
modifications. This does not include
sites providing information on BB guns,
paintball guns, black powder rifles, target
shooting, or bows and arrows, unless
the site also meets one of the above
requirements. Also does not include
sites that promote collecting weapons,
or groups that either support or oppose
weapons use.

Transtation

Web Advertisements

Sites that allow translation of text [words,
phrases, Web pages, etc.) between
various languages or that can be used to
identify a language.

Sites that provide online advertisemonts
or banners. This does not include
advertising servers that serve adult-

oriented advertisements.

TraveL

Web Applications
Sites with interactive, Web-based office!
business applications. This excludes
email, chat/IM or other sites that have a
specific content category.

Sites that promote or provide opportunity
for travel planning, including finding
and making travel reservations,
sharing of travel experiences (pro or
con), vehicle rentals, descriptions of
travel destinations, or promotions
for hotels/casinos or other travel
rotated accommodations. Mass transit
information including but not limited to
posting of schedules, fares or any other
public transportation-rotated data are
also included in this category.

Spyware/Matware Sources
Sites that host or distribute spvware
and other maiware or whose purpose
for existence is as part of the spyware
and maiware ecosystem. Spyware and
matware are defined as software that
takes control of a computer, modifies
computer settings, or collects or reports
personal information without the
permission of the end user. This includes
soI'tware that misrepresents itself by
tricking users to download or install it,
or to enter personal information. This

Web Hosting
Sites of organizations that provide
top-level domain pages. as well as Web
communities or hosting services.

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Sites that provide information on or
promote vehicles, boats, or aircraft,
including sites that support online
purchase of vehicles or parts.

Sites that offer for sate, promote, glorify,
review or in any way advocate the use or
creation of tobacco or tobacco related
products including but not limited to
cigarettes, pipes, cigars and chewing
tobacco. This does not include sites that
sell tobacco as a subset of other products
such as grocery stores.

Sites to which spyware Las defined in
the Spyware/Matware Sources category)
reports its findings or from which it alone
downloads advertisements. This does not
contain sites that serve advertisements
for other Web pages in addition to
spyware advertisements; only those sites
uniquely used by soyware. Includes sites
that contain serious privacy issues, such
as phone home" sites to which software
can connect and send user information;
and sites to which browser hijackers
redirect users. This usually does not
include sites that can he categorized as
Spyware/Malware Sources.

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Spyware Effects/Privacy
Concerns

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Sites that provide streams or downloads
of television, movie, or other video
contenttypically more than 15 minutes
in length.

Suspicious

Sites that are part of the spam
ecosystem, including sites linked in
unsolicited bulk electronic messages
and sites used to generate or propagate
such, messages.

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TV/Video Streams

includes sites that perform drive-by
downloads; browser hijackers; dialers;
any program that modifies your browser
homepage, bookmarks, or security
settings; and keytoggers. This also
includes any software that bundles
spyware (as defined above) as part of
its offering, information collected or
reported is 'personal if it contains
uniquely identifying data, such as email
addresses, name, social security number,
P address, etc. A site is not classified as
spvware if the user is reasonably notified
that the software wilt perform these
actions [e.g., it alerts that it wilt send
personal information, be installed, or that
it wilt log keystrokes).

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