and checked to see whether (1) they were able to successfully post the material, (2)
whether it remained posted 24–48 hours later, and (3) whether they could view the
posted content from a Chinese ISP without using circumvention software.
Results varied widely. One of the blogging service providers tested blocked 60 of 108
tested texts. Another blocked only one. MacKinnon was unable to find a single text
blocked by all blogging providers, though she concluded that current news topics,
which she terms ‘‘sudden incidents’’ were far more likely to be blocked than other sensitive topics. She observes, ‘‘The wide variation in levels of censorship confirms that
censorship of Chinese user-generated content is highly decentralized, and that implementation is left to the Web companies themselves.’’
While many countries block access to social media sites, 11 the vast majority of these
blocked sites are managed and hosted in the United States. China’s unusual approach
of filtering access to sensitive sites and requiring social media providers to censor their
users reflects the large number of social media companies based in China, catering to a
huge domestic market. The history of filtering and censorship in China may have led
to an especially effective model. Since many popular online publishing platforms are
filtered by Chinese ISPs, Chinese netizens have gravitated to hosts located in China.
Because these sites provide interfaces in Chinese, they are easier to use than U.S.-based
sites. And while these sites engage in censorship to avoid government sanctions, most
users will not notice the censorship until they try to post about sensitive topics.
It is somewhat surprising that we have not seen other countries that filter the Internet by means of ISPs implement China’s model of platform-based censorship. However, Chinese companies have taken leadership in the social media world, while
leading platforms for social media in many other countries that filter the Internet are
located outside national control, generally within the United States.
OSP-Based Censorship in the United States
There is no evidence that the U.S. government is demanding censorship of OSPs in
the same way that the Chinese government has attempted to control social
media. However, unclear U.S. laws may have led to situations in which U.S.-based
OSPs have removed user accounts, effectively silencing those users, based on legal
misinterpretations.
Brenda Burrell is used to worrying about censorship. As one of the cofounders
of Kubatana, a civil-society organization based in Harare, Zimbabwe, she works with
human rights organizations whose members are routinely harassed and imprisoned
for speaking in public or online. In a blog post, she notes that she is used to fielding
questions about what might happen if the Mugabe regime shut down her Internet
operations. But on February 6, 2009, she was surprised to hear from BlueHost, an
American Web-hosting company, that Kubatana’s Web site, along with the Web sites
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