AUSL Technology & the Law

by Jennifer Lyn Bernal
2006-0064

There is no privacy that cannot be penetrated. No secret can be kept in a civilized world. Society is a masked ball where every country hides its real character. However, intruders like technology exposed. - Bzoink

INTRODUCTION

Since the days of Charles Darwin, Scientists have struggled with ways to represent our planet’s incredible biological diversity on maps that convey both meaningful information and a realistic sense of scale. In recent years, this challenge has morphed into advanced search device used for mapping places that are available to help educate the general public which are easily accessible to both layman and scientist. Such technology powerful enough to track and display fundamental data from land, aerial, fluvial hundreds of feet under and terrestrial body without a need to physical but virtual connection through internet.
However, with all of this innovation, there is hushed disadvantage like unwelcome visitor, intrudes not only general view, also those personal and restricted.

The advancement of our technology truly become unimaginable, unless and until seen and touched. A mind’s eye to see beyond his physical perspective becomes rationally possible through science and technology, a mind’s eye beyond what human eyes can see. Google Earth made this technology achievable even away from corporeal reality.

This study aims to touch legal and social policy aspects of remote sensing and satellite photography of Google Earth, including the issues on fair use in the concept of copyright law, privacy, liabilities, treaties governing the use of satellite photography and commercialization in the legal framework under the helm of our Domestic Law and Public International law.

GOOGLE EARTH – Its Definition and Technical Description

Google Earth displays satellite images of varying resolution of the Earth’s surface, allowing users to visually see things like cities and houses looking perpendicularly down or at an oblique angle, with perspective. It is a virtual globe, map and geographic information program that was originally called Earth Viewer, and was created by Keyhole, Inc, a company acquired by Google in 2004. It maps the Earth by the superimposition of images obtained from satellite imagery, aerial photography and GIS 3D globe.¹ By downloading its software and following the application procedures, Google Earth allows users to search for addresses for some countries, enter coordinates, or simply use the mouse to browse to a location. Google Earth uses digital elevation model (DEM) data collected by NASA’s Shuttle Radar Topography Mission (SRTM) which able to show all kinds of images overlaid on the surface of the earth to its Web Map Service client. Through Web mapping, it has a capability to view several buildings and structures in 3D mode using long-distance laser scanning technology and digital photography. Moreover, Google has expanded its horizon by introducing several progressions.² Google Street View was launched, it was fully integrated into the program allowing the program to provide an on the street level view in many locations of several countries.³ It added a feature that allows users to monitor traffic speeds at loops located every 200 yards in real-time. As of February of 2009, another innovation was introduced, Google Ocean was launched it has feature allows users to zoom below the surface of the ocean and view the 3D bathymetry beneath the waves. Supporting over 20 content layers, it contains information from leading scientists and oceanographers. Google Sky was also introduced is produced by Google through a partnership with the Space Telescope Science Institute, the browser version allows you to zoom in and out and pan around the celestial bodies, search for planets and galaxies and view the sky through infrared, x-ray, ultraviolet, and microwave views with galleries of some of the best shots from the Hubble telescope and others which you can also listen to podcasts and look at historical maps of the sky.⁴

Google Earth is available under three different licenses: Google Earth, a free version with limited functionality; Google Earth Plus, which included additional features; and Google Earth Pro, which is intended for commercial use and let you browse its advanced applications such as the Google Street View, Google Sky, Google Ocean and those soon to be launched.

The emergence of technology helped our society to achieved human civilization however, despite all these, destruction may also occur if not deal with caution and limitation. Several issues in social and legal sense are likewise linked in the progression of these technologies. Among these are;

GOOGLE EARTH - AN INTRUDER TO ONE’S RIGHT TO PRIVACY AND SECURITY

Privacy is the state of being in retirement from observation of others, it is a seclusion from the view of others. It is a freedom from unauthorized intrusion of strangers and causes an irreparable injury on its probative value. The right to privacy it is one of the Constitutional rights of every person. Thus, Philippine Constitution provides;

Sec. 2 of Art. III – Bill of Rights

The right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures of whatever nature and for any purpose shall be inviolable.

Philippine Constitution recognized this right as an inherent right of every person and stand in a greater position among the hierarchy of rights following the right to life, liberty and property. The inviolability of this right is based on the purview of the law land and morality wherein the right of every person is protected against unreasonable search. Thus, an intruder shall be likewise liable for any violations thereof. The Civil Code provides;

Art. 26. Every person shall respect the dignity, personality, privacy and peace of mind of his neighbors and other persons. The following and similar acts, though they may not constitute a criminal offense, shall produce a cause of action for damages, prevention and other relief:

1. Prying into the privacy of another’s residence:
2. Meddling with or disturbing the private life or family relations of another;
3. Intriguing to cause another to be alienated from his friends;
4. Vexing or humiliating another on account of his religious beliefs, lowly station in life, place of birth, physical defect, or other personal condition.

Art. 32. Any public officer or employee, or any private individual, who directly or indirectly obstructs, defeats, violates or in any manner impedes or impairs any of the following rights and liberties of another person shall be liable to the latter for damages.

Quoted from the abovementioned provisions of the Philippine Law, the significance of right to privacy and right against unreasonable search was given a superior weight not only in Philippine laws, it also highly regarded and respected in several countries.

There were several complaints from government officials of several countries who stress out that the easy availability and access of high-resolution satellite images compromises their national interest that will cause injury as to their cultural heritage. A complaint was filed by the government official of India in view of satellite photos of India’s Rocky Mountain including the sacred locale of Taj Mahal for posting a high-resolution photo without the consent of the government of India. Said pictures are composed of their public dominion and should not be subject to public viewing without their consultation since the same is a risk of their security and privacy standards.⁵

Another privacy issue involved in Google Maps is the imagery of the precedent U.S. Vice President, Dick Cheney’s residence including the top view scenery of White house, The Pentagon, and the Capitol and if warranted, it may be used to consign crimes against their person and security.⁶ In Japan, Japanese Lawyers express it’s complain about the web giant Google concerning one of its feature in Google Earth which is the Google Street View, it was alleged that the service violates their right to privacy since it provides detailed street-level images without their consent and ordering the latter to delete all saved images of their locality.⁷ A Privacy Lawsuit cost $25,000 against Google Earth was also filed in U.S. for the trespass and invasion of privacy in connection with Street View in the Google Earth. The plaintiffs were complaining about the pictures of their private road that is not maintained by the local government that were posted in the internet without their consent and cause unauthorized commercial use.⁸ Several countries including Philippines recognized the inviolability of right to privacy of an individual taking into consideration the consequences thereof. Thus, it was provided for under the Privacy Law of the United States of America that Intrusion of Solitude in Invasion of privacy, it is a tort based in common law allowing an aggrieved party to bring a lawsuit against an individual when a perpetrator intentionally intrudes, physically, electronically, or otherwise, upon the private space, solitude, or seclusion of a person, or the private affairs or concerns of a person, by use of the perpetrator’s physical senses or by electronic device or devices to oversee or overhear the person’s private affairs, or by some other form of investigation, examination, or observation intrude upon a person’s private matters.⁹

In the Philippine law, our Civil Code also provides for the liability for the violation of right to privacy.

Art. 32. Any public officer or employee, or any private individual, who directly or indirectly obstructs, defeats, violates or in any manner impedes or impairs any of the following rights and liberties of another person shall be liable to the latter for damages:

1. Freedom of religion;
2. Freedom of speech;
3. Freedom to write for the press or to maintain a periodical publication;
4. Freedom from arbitrary or illegal detention;
5. Freedom of suffrage;
6. The right against deprivation of property without due process of law;
7. The right to a just compensation when private property is taken for public use;
8. The right to the equal protection of the laws;
9. The right to be secure in one’s person, house, papers, and effects against unreasonable searches and seizures;
10. The liberty of abode and of changing the same;
11. The privacy of communication and correspondence;
12. The right to become a member of associations or societies for purposes not contrary to law;
13. The right to take part in a peaceable assembly to petition the government for redress of grievances;
14. The right to be free from involuntary servitude in any form;
15. The right of the accused against excessive bail;
16. The right of the accused to be heard by himself and counsel, to be informed of the nature and cause of the accusation against him, to have a speedy and public trial, to meet the witnesses face to face, and to have compulsory process to secure the attendance of witness in his behalf;
17. Freedom from being compelled to be a witness against one’s self, or from being forced to confess guilt, or from being induced by a promise of immunity or reward to make such confession, except when the person confessing becomes a State witness;
18. Freedom from excessive fines, or cruel and unusual punishment, unless the same is imposed or inflicted in accordance with a statute which has not been judicially declared unconstitutional; and
19. Freedom of access to the courts.

In any of the cases referred to in this article, whether or not the defendant’s act or omission constitutes a criminal offense, the aggrieved party has a right to commence an entirely separate and distinct civil action for damages, and for other relief. Such civil action shall proceed independently of any criminal prosecution (if the latter be instituted), and mat be proved by a preponderance of evidence.

The indemnity shall include moral damages. Exemplary damages may also be adjudicated. The responsibility herein set forth is not demandable from a judge unless his act or omission constitutes a violation of the Penal Code or other penal statute.

GOOGLE EARTH AS A TERRORISM STRATEGY DEVICE

Terrorism is defined as the unlawful use or threatened use of force or violence by a person or an organized group against people or property with the intention of intimidating or coercing societies or governments, often for ideological or political reasons.¹⁰ Since Google Earth is an open-use software which enable any internet user to view the geographical locations of any country, it cannot do away with perils of criminalized purposes. There are many reported incidents related to the complaint against the abuse usage of Google Earth. A petition entered at the Bombay High Court a year ago alleges that the Google Earth service, “aids terrorists in plotting attacks” in Mumbai. They alleged that terrorist communicated by satellite phone, used mobile phones with several different SIM cards, and may have monitored events as the siege unfolded via handheld Blackberry web browsers. The terrorists familiarized themselves with the streets of Mumbai’s financial capital using satellite images for planning terrorist attacks.¹¹ Another reported incident related was the terrorists attacked in British bases in Basra which are using aerial footage displayed by the Google Earth internet tool to pinpoint their attacks. Documents were seized during raids on the homes of insurgents last week uncovered print-outs from photographs taken from Google Earth. The satellite photographs show in detail the buildings inside the bases and vulnerable areas such as tented accommodation and lavatory blocks. They further alleged that Google Earth was used to identify the most vulnerable areas such as tents and other material sites relative to the planning of their attacks.¹² Another security threat was raised in Great Britain since sensitive military sites, including its nuclear defence headquarters under threat from terrorists using Google Earth. Close-up aerial views of the sensitive military sites including top-secret Naval base with longitude and latitude of the facility in Scotland home to the UK’s Trident-armed nuclear submarine force are available for free over the Internet.¹³

As a rule, every nation is expected to obey International Law. Treaties and conventions is a part of every judicial system of all nations. It aims to develop a general customary usage to maintain international peace and to secure protection among all nations. Thus;

Article 1 of United Nations Charter

1. To maintain international peace and security, and to that end: to take effective collective measures for the prevention and removal of threats to the peace, and for the suppression of acts of aggression or other breaches of the peace, and to bring about by peaceful means, and in conformity with the principles of justice and international law, adjustment or settlement of international disputes or situations which might lead to a breach of the peace;
2. To develop friendly relations among nations based on respect for the principle of equal rights and self-determination of peoples, and to take other appropriate measures to strengthen universal peace;
3. To achieve international co-operation in solving international problems of an economic, social, cultural, or humanitarian character, and in promoting and encouraging respect for human rights and for fundamental freedoms for all without distinction as to race, sex, language, or religion; and
4. To be a centre for harmonizing the actions of nations in the attainment of these common ends.¹⁴

Any breach or attempt to disturb the international peace directly or indirectly, the International Court of Justice through Security Council shall be the judicial authority in resolving the matter.

Moreover, 1986 United Nation Resolution also provides

1986 UN Resolution

Data-gathering activities such as satellite photography “shall not be conducted in a manner detrimental to the legitimate rights and interests of the sensed State.”¹⁵

It is universally accepted postulates that, with or without an express declaration to effect this provision, the states admitted to the family of nations are bound by the rules prescribe for it for the regulation of the international intercourse. This is an inevitable consequence of membership in the international community. The Law of Nations, although not specifically adopted by Constitution or any municipal act, is essentially adopted by Constitution or any Municipal act, is essentially a part of the law of the land. Its obligation commences and runs with the existence of the nation under the Doctine of Incorporation. Among these are Austria, United Kingdom, Germany, United States of America, Korea and the Philippines.¹⁶

GOOGLE EARTH’S SATELLITE PHOTOGRAPHY / VIDEO STREAMING AND INTERNATIONAL LAW

Locational Privacy is an emerging issue worldwide due to the increase of sophistication of geolocation technologies like Google Earth, it became a potential tracking device through surreptitious or unwarranted tracking of the user against the territory of another states. Since Google Earth browser version allows users to zoom in and out and pan around the celestial bodies and view the sky through infrared, x-ray, ultraviolet, and microwave views which displays like a historical maps of certain countries in the sky.

The United Nations Office for Outer Space Affairs conceded a treaty in accordance with international law, including the Charter of the United Nations, the Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer and Inner Space, including the Moon and Other Celestial Bodies, and the relevant instruments of the International Telecommunication Union.¹⁷ Thus:

Principle IV

Remote sensing activities shall be conducted in accordance with the principles contained in article I of the Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space, including the Moon and Other Celestial Bodies, which, in particular, provides that the exploration shall be carried out for the benefit and in the interests of all countries, irrespective of their degree of economic or scientific development, and stipulates the principle of freedom of exploration and use of outer space on the basis of equality. These activities shall be conducted on the basis of respect for the principle of full and permanent sovereignty of all States and peoples over their own wealth and natural resources, with due regard to the rights and interests, in accordance with international law, of other States and entities under their jurisdiction. Such activities shall not be conducted in a manner detrimental to the legitimate rights and interests of the sensed State.

Principle VI

In order to maximize the availability of benefits from remote sensing activities, States are encouraged, through agreements or other arrangements, to provide for the establishment and operation of data collecting and storage stations and processing and interpretation facilities, in particular within the framework of regional agreements or arrangements wherever feasible.

Principle XIII

To promote and intensify international cooperation, especially with regard to the needs of developing countries, a State carrying out remote sensing of the Earth from space shall, upon request, enter into consultations with a State whose territory is sensed in order to make available opportunities for participation and enhance the mutual benefits to be derived therefrom.

Principle XIV

In compliance with article VI of the Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer/Inner Space and its celestial bodies, States operating remote sensing satellites shall bear international responsibility for their activities and assure that such activities are conducted in accordance with these principles and the norms of international law, irrespective of whether such activities are carried out by governmental or non-governmental entities or through international organizations to which such States are parties. This principle is without prejudice to the applicability of the norms of international law on State responsibility for remote sensing activities.

It is a universally accepted postulate that, with or without an express declaration to this effect, the states admitted to the family of nations are bound by the rules prescribe for it for the regulation of the international intercourse. This is an inevitable consequence of membership in the international community. The Law of Nations, although not specifically adopted by Constitution or any municipal act, is essentially adopted by Constitution or any Municipal act, is essentially a part of the law of the land. Its obligation commences and runs with the existence of the nation under the Doctine of Incorporation. Among these are Austira, Germany, United States of America, Korea and the Philippines.

Hence, The law of the nations is a part of the law of several nations upon its existence. Treaties and International law is a part of our law and must be ascertained and administered by the courts of of appropriate jurisdiction as questions of rights depending upon it are presented for determination.¹⁸

GOOGLE EARTH AND COPYRIGHT ISSUES

In our digital age, we regarded our technology as a part of our contemporary lifestyle. The utilization of Google Earth technology does not at all time at the depressing juncture. Google Earth has a wide advantage concerning public, commercial and environmental purposes in the absence of abuse and radical intentions.

Tools such as Google Earth are built from information that is already available from both commercial and public sources, and it is important to remember that the same information is available to anyone who acquires a software and license. Google’s freely available technology has been used for vital purposes ranging from fighting forest fires to emergency response, rescue, relief in natural disasters, accommodating information used in traffic and public viewing of streets and locations from cities to cities. Since there is a vast advantage of using the software for commercial, environmental and utilizing public service, it is fully protected against the impropriety and exploitation.

Copyright is a legal concept enacted by governments which owes its origin during the advent of the ancient printing press. This gives the creator of an original work of authorship exclusive rights to control its distribution. It is more commonly known as “the right to copy”¹⁹ Since Google Earth is a special type of software which contains secured information and images, it has an authority to exercise copyright among its digital images and video streamings and has proprietary and confidential information that is protected by applicable intellectual property and other laws of several nations. Thus, in the Philippines it clears under Sec. 2 of Republic Act No. 8293 which provides;

Section 2. Declaration of State Policy. - The State recognizes that an effective intellectual and industrial property system is vital to the development of domestic and creative activity, facilitates transfer of technology, attracts foreign investments, and ensures market access for our products. It shall protect and secure the exclusive rights of scientists, inventors, artists and other gifted citizens to their intellectual property and creations, particularly when beneficial to the people, for such periods as provided in this Act.

The use of intellectual property bears a social function. To this end, the State shall promote the diffusion of knowledge and information for the promotion of national development and progress and the common good.

It is also the policy of the State to streamline administrative procedures of registering patents, trademarks and copyright, to liberalize the registration on the transfer of technology, and to enhance the enforcement of intellectual property rights in the Philippines.
Google owns all right, title and interest in and to the Software, and all of its conjunction thereto including without limitation all Intellectual Property Rights therein. “Intellectual Property Rights” means any and all rights existing from time to time under patent law, copyright law, trade secret law, trademark law, unfair competition law, and any and all other proprietary rights, and any and all applications, renewals, extensions and restorations thereof, now or hereafter in force and effect worldwide.²⁰

Due to complexities of our digital age, copyright infringement became a foreseeable practice worldwide which warrants protection against abusive individuals. Thus, the restrictions provided for by Google are means of protection not only on the part of Google but with respect to the rights of several countries that may be viewed by the satellite or digital eye of Google Earth. Among these restrictions are; (a) defame, abuse, harass, stalk, threaten or otherwise violate the legal rights (such as rights of privacy and publicity) of others; (b) upload, post, email or transmit or otherwise make available any inappropriate, defamatory, infringing, obscene, or unlawful content; (c) upload, post, email or transmit or otherwise make available any content that infringes any patent, trademark, copyright, trade secret or other proprietary right of any party, unless you are the owner of such rights or have the permission of the owner to post such content; (d) download any file posted by another that you know, or reasonably should know, cannot be legally distributed in such manner; (e) remove any copyright, trademark or other proprietary rights notices contained in or on Google services; (f) promote or provide instructional information about illegal activities or promote physical harm or injury against any group or individual; (g)transmit any viruses, worms, defects, Trojan horses, or any items of a destructive nature and among others.²¹

The imposition of these restrictions was to correspond to the well known fair use doctrine Sec. 185 of R.A. No. 8293 enshrine the said doctrine which provides as follows:

Sec. 185. Fair Use of Copyrighted Work.

185.1. The fair use of a copyrighted work for criticism, comment, news reporting, teaching including multiple copies for classroom use, scholarship, research, and similar purposes is not an infringement of copyright. Decompilation, which is understood here to be the reproduction of the code and translation of the forms of the computer program to achieve the inter-operability of an independently created computer program with other programs may also constitute fair use. In determining whether the use made of a work in any particular case is fair use, the factors to be considered shall include:

1. The purpose and character of the use, including whether such use is of a commercial nature or is for non-profit educational purposes;
2. The nature of the copyrighted work;
3. The amount and substantiality of the portion used in relation to the copyrighted work as a whole; and
4. The effect of the use upon the potential market for or value of the copyrighted work.

In line with this doctrine, Google and users upon downloading of the software concur with Technology Transfer Agreements²² which entails obligation on the part of the subscriber to use the software in accordance with its fair use and policies. All users of Google Earth, except for personal use require copyright attribution with respect to commercial and non-commercial use and consent of Google regardless of the nature of use. Hence, Sec. 187 of R.A. 8293 provides;

Section 187. Reproduction of Published Work. - 187.1. Notwithstanding the provision of Section 177, and subject to the provisions of Subsection 187.2, the private reproduction of a published work in a single copy, where the reproduction is made by a natural person exclusively for research and private study, shall be permitted, without the authorization of the owner of copyright in the work.

187.2. The permission granted under Subsection 187.1 shall not extend to the reproduction of:

1. A work of architecture in the form of building or other construction;
2. An entire book, or a substantial part thereof, or of a musical work in graphic form by reprographic means;
3. A compilation of data and other materials;
4. A computer program except as provided in Section 189; and
5. Any work in cases where reproduction would unreasonably conflict with a normal exploitation of the work or would otherwise unreasonably prejudice the legitimate interests of the author.

Google exercise full capacity rights over the copyright ownership and authorship with Google Earth and its conjunctions. Therefore, Google exercises economic and moral rights concerning its intellectual and technological creations. Sec. 177 of Republic Act 8293 explicitly provides;

Section 177. Copyright or Economic Rights. - Subject to the provisions of Chapter VIII, copyright or economic rights shall consist of the exclusive right to carry out, authorize or prevent the following acts:

177.1. Reproduction of the work or substantial portion of the work;

177.2. Dramatization, translation, adaptation, abridgment, arrangement or other transformation of the work;

177.3. The first public distribution of the original and each copy of the work by sale or other forms of transfer of ownership;

177.4. Rental of the original or a copy of an audiovisual or cinematographic work, a work embodied in a sound recording, a computer program, a compilation of data and other materials or a musical work in graphic form, irrespective of the ownership of the original or the copy which is the subject of the rental; (n)

177.5. Public display of the original or a copy of the work;

177.6. Public performance of the work; and

177.7. Other communication to the public of the work. (Sec. 5, P. D. No. 49a)

Section 193. Scope of Moral Rights. - The author of a work shall, independently of the economic rights in Section 177 or the grant of an assignment or license with respect to such right, have the right:

193.1. To require that the authorship of the works be attributed to him, in particular, the right that his name, as far as practicable, be indicated in a prominent way on the copies, and in connection with the public use of his work;

193.2. To make any alterations of his work prior to, or to withhold it from publication;

193.3. To object to any distortion, mutilation or other modification of, or other derogatory action in relation to, his work which would be prejudicial to his honor or reputation; and

193.4. To restrain the use of his name with respect to any work not of his own creation or in a distorted version of his work. (Sec. 34, P.D. No. 49)

Because of this rights conferred, Google further requires special permission to users/subscribers to use the software for Webiste use, Print, Broadcast, Education for museum or classroom use, and other non-profit media campaigns.²³

CONCLUSION

With more digital satellite sensors and in our orbit like Google Earth, people should be more conscious as to the pros and cons of these technological consequences since technology like Google Earth is colossal scientific advantage which might result to destruction if not dealt with vigilance. Despite the fact that it will bring expediency and convenience to the day to day life of person and entities, it promotes less constrictive copyrights and creates privacy/security issues.

Due rapid technological advancements in the field of digital photography by satellite remote sensing, it is necessary to require the subscriber-users to be aware of sensitivities associated with this type of information; the terms and condition stated in the agreement of both parties should not be embodied only as a contract of subscription, consequently, it must be given a greater weight as to the formation of an existing law embodied in every law of the nations. These domestic laws should be definite enough to incur civil and criminal liability since our International law and treaties are not firm enough to implement restrictions and sanctions for any breach thereof.

Governments among Nations worldwide and the United Nation Organization should therefore act as a catalyst in a much-needed interagency collaboration to form a body to safeguard the interest of the general public worldwide against the offensive users. There should be a legal entity recognized worldwide in command with monitoring of the satellite imagery sensors to ensure maximum benefit of protection of all data reserved for particular purposes and to maximize the benefits of this tool for humanitarian assistance not for adversary advantage.

Endnotes

1. http://en.wikipedia.org/wiki/Google_Earth?redirect=no [↩]
2. http://serc.carleton.edu/sp/library/google_earth/what.html [↩]
3. http://googlesystem.blogspot.com/2007/05/earth-is-closer-street-views-in-google.html [↩]
4. http://computer.howstuffworks.com/google-earth5.html [↩]
5. http://deseretnews.com/article/1,5143,635165321,00.html [↩]
6. http://gawker.com/5138111/cheneys-veil-lifted-on-vice-presidents-residence [↩]
7. http://geocartablog.com/?p=918#more-918 [↩]
8. http://www.marketingpilgrim.com/2008/04/couple-sues-google-for-street-view-photos-on-private-road.html [↩]
9. http://en.wikipedia.org/wiki/Privacy_laws_of_the_United_States#cite_note-4 [↩]
10. http://dictionary.reference.com/browse/terrorism [↩]
11. http://technology.timesonline.co.uk/tol/news/tech_and_web/the_web/article5311241.ece [↩]
12. http://www.telegraph.co.uk/news/worldnews/1539401/Terrorists-use-Google-maps-to-hit-UK-troops.html [↩]
13. http://www.ndtv.com/convergence/ndtv/story.aspx?id=NEWEN20090085299 [↩]
14. http://www.lawphil.net/international/un/un_charter_1945.html [↩]
15. http://www.usip.org/virtualdiplomacy/publications/reports/12.html [↩]
16. International Law, Isagani Cruz, p.5, 2003 edition [↩]
17. http://www.unoosa.org/oosa/SpaceLaw/rs.html [↩]
18. Supra [↩]
19. Copyright”. GNU License. http://en.wikipedia.org/wiki/Copyright , 2009 February [↩]
20. http://en.wikipedia.org/wiki/Intellectual_property [↩]
21. http://earth.google.com/intl/en-US/license.html [↩]
22. Sec. 4.2 of Intellectual Property Code of the Philippines [↩]
23. http://www.google.com/permissions/geoguidelines.html [↩]

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