As under the E rate program,  an administrator, supervisor or other authority may

disable a technology protection measure . . . to enable access for bona fide research or

other lawful purposes.   CIPA   1712 (codified at 20 U.S.C.   9134(f)(3)).  Whereas

CIPA's amendments to the E rate program permit disabling for bona fide research or

other lawful purposes only during adult use, the LSTA provision permits disabling for

both adults and minors.

B.  Identity of the Plaintiffs

1.  Library and Library Association Plaintiffs

Plaintiffs American Library Association, Alaska Library Association, California

Library Association, Connecticut Library Association, Freedom to Read Foundation,

Maine Library Association, New England Library Association, New York Library

Association, and Wisconsin Library Association are non profit organizations whose

members include public libraries that receive either E rate discounts or LSTA funds for

the provision of Internet access.  Because it is a prerequisite to associational standing, we

note that the interests that these organizations seek to protect in this litigation are central

to their 

raison d'etre

.  

Plaintiffs Fort Vancouver Regional Library District, in southwest Washington

state; Multnomah County Public Library, in Multnomah County, Oregon; Norfolk Public

Library System, in Norfolk, Virginia; Santa Cruz Public Library Joint Powers Authority,

in Santa Cruz, California; South Central Library System ( SCLS ), centered in Madison,

Wisconsin; and the Westchester Library System, in Westchester County, New York, are

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