Cryptocurrency and Language Policy in Non-English Dominant Countries
An Essay by Ray Steding
ICOs are democratizing funding and spawning the next wave of innovation from young hungry entrepreneurs all over the world who will eventually contribute back to their local communities for a better future" --the founder of fundyourselfnow.com
Cryptocurrency and Language Policy in Non-English Dominant Countries
Thomas Ricento in Language Policy & Political Economy (2015) presents many of the issues that pertain to language policy in non-English dominant nations. This paper describes the ways that cryptocurrencies and blockchain technologies relate to Ricento's observations, his concerns and his conclusions. Its purpose is to provide non-technical academics with enough credible information about cryptocurrencies so they may properly conceptualize the impact of cryptocurrencies on language. Despite media often portraying cryptocurrencies as fad-like and nefarious, cryptocurrencies and blockchain technologies are rapidly changing socio-economics and must be included in language policy discussions. Since the claims that I make require some knowledge of technical terms, I include a glossary of relevant definitions.
Cryptocurrencies and blockchain technologies offer additional components of influence into the debate about language policy and economics. Thomas Ricento, throughout his book, attempts to provide direction for language policy research. He implies the purpose of his book by stating that "there is not enough understanding of how the interests and values of transnational corporations, and the policies of states and international organizations that support those interests and values, may influence the trajectory and fate of languages . . . in the absence of clearly articulated views on political economy, with empirical evidence to support those views, we may have fewer tools--that is, theories and associated research methods-- with which to argue in support of the maintenance of minority languages and cultures and societal multilingualism" (Ricento 27).
The relationship between cryptocurrencies and blockchain technologies and Ricento's concerns follow. The author advocates for a critical analysis of global English, using a political, economic approach that takes into account historical factors over time. he refutes neoliberal ideology backing English as a lingua franca. Ricento cites, Arcand and Grin 2013, saying that "in fact societal multilingualism, generally, controlling for other potentially moderating factors, correlates with increased trade, and English per se has no special or unique effect in that regard" (Ricento 3). Although not stated, another factor related to increased trade is the connection between well-educated people in their mother-tongue language and cryptocurrencies and blockchain technologies. He notes that "an important corollary of a world systems approach [to political economy] is that global economic, political, cultural, and historical trends are not uniform over time, there are perturbations, cycles, anomalies, and uneven effects from common sources" (Ricento 4). Like the Internet, another notable perturbation is the rapid disruption of the current world economic order by cryptocurrencies and blockchain technologies. The author points out that "researchers have focused on particular effects (or potential effects) in particular geographic and historical contexts and then generalize their findings" (Ricento 3). Internet access to cryptocurrencies render their effects globally, and their design serves economically specific needs within localized domains. Additionally, he interprets language scholar Robert Phillipson's call for the '"equality for the speakers of all languages'" and for '"economic democratization "'as a call for a fundamental reformation of the current world economic order (and not for finding an alternative to the role played by English in global economic activity), which, [he] believes is highly relevant to the status of local languages" (Ricento 29).
Cryptocurrencies and the decentralization of national monetary systems into global currencies such as Bitcoin essentially remove economic borders which is a "fundamental reformation of the world economic order"(Ricento 29). They connect the unbanked with financial technologies. They lessen the role played by English in local economic activity by enhancing economic activity in mother tongue languages and thereby supplement the preservation of local languages and cultures. As such, they work in conjunction with Ricento's views on political economy and language policy to help preserve multiculturalism and multilingualism. Thus, cryptocurrencies and blockchain technologies are highly relevant to "the status of local languages".
In addition to political economy which seeks to implement informed governmental language policy, cryptocurrencies and blockchain technologies make it somewhat less important for policymakers to secure benefits provided through nationally/regionally based forms of communitarianism that Ricento subscribes to (Ricento 33, 35). Blockchain technologies disintermediate the need for governments “to secure and distribute fairly the liberties, and economic resources individuals need to lead freely chosen lives"--communitarianism--and cryptocurrencies allow for the creation of blockchain based economic zones that operate under common law and thereby lessen the need for acquiring a lingua franca or national language.
A broader conceptualization of cryptocurrency must include the ever-present philosophy behind open source software as defined by Richard Stallman, a visionary and founder of open source software programs. According to the GNU.org website on September 27, 1983, Stallman wrote, “Starting this Thanksgiving I am going to write a complete Unix-compatible software system called GNU (for Gnu's Not Unix), and give it away free to everyone who can use it.” In a copyrighted article in 1996 Stallman defined Free Software:
“Free software” means software that respects users' freedom and community. Roughly, it means that the users have the freedom to run, copy, distribute, study, change and improve the software. Thus, “free software” is a matter of liberty, not price . . . as in freedom . . . We campaign for these freedoms because everyone deserves them. With these freedoms, the users (both individually and collectively) control the program and what it does for them. When users don't control the program, we call it a “nonfree” or “proprietary” program. The nonfree program controls the users, and the developer controls the program; this makes the program an instrument of unjust power. (Stallman)
Stallman’s operating system combined with the Linux kernel developed by Linus Torvalds's open source project became known as Linux. Stallman’s philosophy gave birth to the thousands of open source software projects that quickly developed the Internet into a freely distributed information system. The fact that open source software such as Linux and the Apache Web Server software power Google and Facebook, and the fact that Linux is used in over one billion Android cellphones, combined with the fact that Apple’s operating system comes from an open source version of Unix called FreeBSD verifies the transformative social power of open source software.
The combination of proprietary corporate interests with open source software historically parallels today’s cryptocurrencies and blockchain technologies. Bitcoin moves Stallman’s philosophy from the free flow of information to the world of finance and implies the free flow of capital. In 2008 a paper published under the pseudonym Satoshi Nakamoto titled “Bitcoin: A Peer-to-Peer Electronic Cash System” Nakamoto wrote: “What is needed is an electronic payment system based on cryptographic proof instead of trust, allowing any two willing parties to transact directly with each other without the need for a trusted third party” (Nakamoto). By the beginning of 2009, the open source Bitcoin network arrived via a posting to a cryptography mailing list by Nakamoto:
Bitcoin v0.1 released
Satoshi Nakamoto Fri, 09 Jan 2009 17:05:49 -0800
Announcing the first release of Bitcoin, a new electronic cash
system that uses a peer-to-peer network to prevent double-spending. It's completely decentralized with no server or central authority. (Nakamoto)
The phrase “completely decentralized with no server or central authority” is the focus of debate between banking professionals and the fintech community, and it exists because of the virtue of Stallman’s philosophy and open source software. One of open source software's most notorious features is that it is faceless. It is not anyone but everyone. According to Bitcoin.org the website that was registered by Satoshi Nakamoto and Marttie Malmi "[b]itcoin is controlled by all Bitcoin users around the world. Developers are improving the software, but they can't force a change in the rules of the Bitcoin protocol because all users are free to choose what software they use" (Bitcoin.org).
Various coin or token-based payment systems for online gaming predated Bitcoin. By combining open source software with cryptography, Bitcoin spread to become the first global digital currency. The blockchain ledger, a type of hacker-proof cryptographic distributed database of transaction record keeping is trustless; it requires no third party such as a bank to verify that currency transactions take place. Although cryptocurrencies do carry a small transaction fee, like open source software they are easily distributed and available. Many open source cryptocurrency projects are controlled by democratic voting rights based on the number of coins held. Accordingly, Antshares, (re-branded as Neocoin), referred to their coins as shares. In addition to the value of the coin most coins return a share of the coin's market profitability to their holders' Cryptocurrencies’ rapid acceptance as an investment vehicle and thus their increase in capitalization, results from their trustless quality, low transaction fees and their availability of open source code for other developers to build on.
Bitcoin now has the stamp of approval of the world's largest futures exchanges. According to cnbc.com, “in April, [Japan] passed a law recognizing bitcoin as legal tender (Graham). In, Stockholm, Coinshares, a professional cryptocurrency investment company comprises two exchange-traded bitcoin notes (COINXBT & COINXBE), which according to zerohedge.com, "means that the NASDAQ [Stockholm] now has two crypto-assets listed, Bitcoin and Ether, making it the only established exchange with multiple crypto-investment vehicles" (Durden). Additionally, the Chicago Board of Options Exchange began futures trading on December 10, 2017, and the Chicago Mercantile Exchange began trading Bitcoin futures on December 18, 2017" (Osipovich). Meanwhile, the Tokyo Financial Exchange is working on Bitcoin futures trading (Sakai).
The growth rate of cryptocurrencies and the flow of capital entering into the cryptocurrency and blockchain technologies exceeds the flow of capital into Internet technologies during the height of the 1999 stock market bubble, which suggests that these new technologies will transform society in more substantial ways. A chart from Vanguard Group, published October 5, 1999, shows fund assets grew at a rate of 35% from $2,161 billion in 1994 to $6,030 billion in Oct 1999 (Bogle). Much of the money flowed into Internet stocks. The flow of money into cryptocurrencies far exceeds the rate of 35%. Should the current rate continue for another year, the total cryptocurrency market capitalization will exceed six trillion dollars putting it at a value of 13.9 trillion dollars.
According to a paper from the Cambridge University Judge Business School, Centre for Alternative Finance, titled “Global Cryptocurrency Benchmarking Study” by Dr Garrick Hileman & Michel Rauchs (2017), “[t]he total cryptocurrency market capitalisation has increased more than 3x since early 2016, reaching nearly $25 billion in March 2017” (Hileman and Rauchs 16). As of this writing, according to coinmarketcap.com, nine months later in December 2017 the total market capitalization of approximately 1000 different cryptocurrencies stands at $592,026,737,519 (CoinMarketCap). The value, greater than one-third of all Federal Reserve Notes in circulation, increased approximately 23.6 times in one year. Roughly at the same rate of the overall market, Bitcoin increased 2356.47% over the last year to a price per coin of $19,500.
Explosive growth comes with the backing of financial institutions. Frank Chaparro, of Business Insider, writes in an article posted on August 30, 2017, that "there are now more than 50 hedge funds dedicated to cryptocurrencies" (Chapparo). Additionally, cryptocurrencies are decentralized, meaning that no financial institution is required to send money from one person to another and the cost of exchange is typically no more than a debit card $3 fee. Unlike the Internet bubble, the low cost of entry allows even the poor to purchase cryptocurrencies. The poor as well as the rich benefit while prices continue their climb.
Although the growth rate appears to mirror the growth of the Internet during the tech boom, it is important to distinguish the difference between the growth of technology for the distribution of information and the growth rate of the distribution of capital. Whereas the control over information distribution relates to the inability of corporations and governments to persuade citizens through media and politics to particular and questionable neoliberal narratives of benefit, the distribution of capital is inseparable from socio-political power structures and treads upon the very foundation of neoliberal policy. What does it mean, to imply that neoliberal policies help to provide economic justice in third world nations when the capital from first world nations begins to flow transparently across borders directly into the pockets of third world citizens and for that matter into the pockets of lower and middle-class citizens of developed nations? More likely than not, as poor countries benefit from cryptocurrencies and blockchain technologies, citizens will begin to question the benefits of being subjected to multi-national corporations and neoliberal policies. A recent ICO--Initial Coin Offering--of a project called Airswap announced 85% [of its coins] sold out [to ‘9,447 people from 135 countries’] in the first minute, and the rest [of the ICO] was sold over the course of 15 minutes” (Airswap). The attention of central bankers who traditionally control the flow of capital takes note of the rapid expansion of cryptocurrency throughout the world.
The MIT licensing of the Bitcoin code by Satoshi establishes the dynamic interplay between the forces of corporate hegemony and the forces of the open source community. The MIT open source licensing permits banking and any private corporations as well as anybody to make alterations to the open source code and turn it into proprietary code. On the issue of the MIT license on Sept. 12, 2010, Satoshi stated, "If the only library is closed source, then there's a project to make an open source one. If the only library is GPL [General Public License], then there's a project to make a non-GPL one . . . I think the fear of a closed-source takeover is overdone" (Nakamoto). This is not to say that banks aren't attempting to control Bitcoin.
The fear about the MIT license Satoshi mentioned and brushed off is the source of the rhetoric heard between banking industry professionals and the proponents of open source. Ben Bernanke, former Chair of the Board of Governors of the Federal Reserve System in 2015 said that Bitcoin is "interesting from a technological point of view," he made the typical statements often heard in media about Bitcoin being a "vehicle for illicit transactions, drug selling" and terrorist financing and that [government] "oversight will reduce the appeal" (Phillips). According to Zerohedge, “Bernanke told an audience at Ripple's Swell event in Toronto today [Oct. 16, 2017] that: ‘. . . new technology like blockchain or electronic currencies can be used to improve’ global payments, and added that Ripple's technology is ‘promising" as they work with regulators’” (Durden). Ripple, a banking backed cryptocurrency, openly trades on cryptocurrency exchanges along with Bitcoin and others. Bernanke’s rhetoric persuades negatively toward open source cryptocurrency and emphasizes regulation through the proprietary "Ripple" cryptocurrency.
The interplay of claims against each other is the result of a dialogical technical process wherein each side takes what the other puts out as a quality feature, incorporates it into their systems, and then often denounces the other based on ideological reasons. This process as vocalized in Bernanke's comments concerning Bitcoin echo “Microsoft operating system chief Jim Allchin's statement [in August 2001], ‘Open source is an intellectual-property destroyer. I'm an American, I believe in the American Way. I worry if the government encourages open source, and I don't think we've done enough education of policymakers to understand the threat’" (Pahati). His concerns came at a time when Linux represented Microsoft’s biggest competitor. Of note here is that Microsoft incorporated open source software code into its operating system and OpenOffice is an open source version of Microsoft Office.
Cryptocurrencies, blockchain technologies, and proprietary solutions are likely to coexist long into the future. Their mutually beneficial relationship is not always contentious, and the rhetoric often advertises the benefits. An article by Pete Harris (Dec. 7, 2017) on Distributed.com, a blockchain consultant/journalist, writes the following about the relationship between open source blockchain and propriety tech. "IBM is marrying both its blockchain offering (based on the open-source Hyperledger Fabric codebase) and its Watson AI platform for a range of industries. One early project involves Everledger, which is applying blockchain technology to track the provenance of luxury items, including diamonds" (Harris). Everledger provides specific wording about its technology: "At Everledger, we assert transparency by building on both the public blockchain and private blockchains . . . Everledger is [a] proud contributor of the Hyperledger community, committed to advancing open source collaboration and working alongside the brightest minds in the blockchain space" (Everledger). These historical and current examples of the relationships of open source and proprietary software lead me to expect that the dynamic will not change despite the rhetoric.
As the debate between those that want to regulate and those who believe in trustless (self-regulating) cryptocurrencies continues Startup Societies implement common law, blockchain technologies, and cryptocurrency usage. The neoliberal ideology behind China's economic zones of the 1980s evolved beyond China to become the Special Economic Zones of today's Startup Societies. They are a kind of a mix between neoliberalism and communitarianism that focuses on a return on investment as much as how the individual benefits. According to Michael Strong, Startup Societies are at the bleeding edge of technology but he envisions a time when “we will see thousands and thousands of governments [within economic zones], and communities, and cultures, and societies, that allow everybody on earth, seven billion, eight billion, nine billion to have an exponentially better quality of life.” Strong goes on to explain that “zones result in greater economic liberalization in China, Ireland, to some extent India, Mauritius, and arguably in a number of other countries.” He talks about how Dubai and Abu Dhabi have installed common law systems in economic zones that operate outside of the traditional Sharia legal system, how Honduras allows for common law to operate within economic zones, and how other nations are working to set up common law systems in economic zones. His argument is that bad governments and legal structures are directly responsible for poverty and “keep people unnaturally poor.” He thinks that “we can develop software in terms of [educational] governance and law that can outperform Hong Kong and Singapore.” Strong advocates for blockchain developers and more common law attorneys. Additionally, in support of promoting the power of cryptocurrencies and decentralization, the Startup Societies Foundation highlights decentralizing value, regulation, energy, and commodities via blockchain technologies. Their Special Economic Zones provide areas in which it is not necessary for the participants that benefit economically to learn a foreign language.
Language Policy documents convincing evidence that multiculturism and multilingualism are more beneficial to a community than not. Suzanne Romaine, another author within Language Policy to which Ricento refers, shows that students who are proficient in literacy and numerical skills in their mother-tongue are better able to live and secure the health of their children than those that are forced by governmental language policy to learn English in grade school (Ricento 262). Romaine claims that "[p]roviding quality education to the poorest requires teaching them through the language they understand best" (Ricento 259). The author presents "economic arguments supporting the view that it is those without access to education in their language who are in fact the ones most damaged" (Ricento 259). And, she finds that "contrary to conventional wisdom, the more highly developed children's mother tongues are, the more prepared they will be to acquire second languages successfully" (Ricento 260). While language policy scholars work toward providing a political, economic, communitarian, solution of which Ricento advocates and which literary language policy scholars currently engage in, cryptocurrencies and the blockchain are rapidly coming in to fill the micro-payment niche and bringing modern finance to those that need it most.
Cryptocurrencies support multiculturalism and multilingualism in that they offer anyone with a mother-tongue capable cellphone, including the deaf, the ability to participate in new cryptocurrency and blockchain technologies based economies for as little as the cost of the phone. Patrick Byrne CEO and chairman of Overstock.com explains that technologists are rapidly working towards a blockchain based central banking system in a box. During an interview with Chris Martenson of PeakProsperity.com Byrne said he expected a system which gives any nation the ability to distribute a national blockchain based currency to its citizens via a cell phone to be completed in September 2017. Byrne explains the crisis that cryptocurrency readily resolves:
[A] great problem in development economics for 25 years has been this discussion over the unbank[ed] . . . [O]nly 15% have bank accounts . . . . [H]ere the West has been allegedly trying to help the poor . . . by saying, ‘here are our institutions.’ And, you’re going to build your own banks and financial system that looks like our institutions . . . [t]hat’s the advice we’ve been giving for half a century. [S]o the idea was they’re going to build their own banking systems, their own capital markets modeled after the U.S.’s. (Byrne)
Byrne goes on to say blockchain technology provides these same functions: “You can have a whole functioning payment system just with everybody using their cell phones without having to have the bank accounts . . . It means that these countries can develop without copying us and build over decades these central institutions that we’ve been recommending. (Byrne).
Additionally, if cell phones are available in languages that enable participation in the fintech global economy and students are proficient in their mother-tongue language, then the requirement of a lingua franca is lessened. The same opportunities of cheap labor and business become available to the local population, and that is one reason discussions about language policy must include cryptocurrencies and blockchain technologies.
Foreign entrepreneurs such as Byrne aren't the only ones interested in cryptocurrency. Google trends show the countries ranking the highest in searching for the word "Bitcoin" as being South Africa at 100% and Nigeria at 87%. Ghana comes in at 70%. The U.S. ranks as 55%, with Australia at 75%. (Google Trends). Currently, M-Pesa is the most widely used mobile service for monetary transactions to, from, and within Nigeria. M-Pesa stands for mobile money, and it provides the unbanked with a much lower cost of transferring money from one place to another than Western Union or other available services (Redman). Whereas M-Pesa provides a solution to the problem of transferring money another problem is Nigeria's shilling; the money that various transfers through M-Pesa are remitted in. As the following statistics on inflation rates show from African nations in 2017, Bitcoin may better serve as a medium of exchange: "South Sudan 182.18%, Democratic Republic of the Congo 41.67%, Libya 32.81%, Angola 30.92%, Sudan 26.9%, Egypt 23.54% Yemen 20%, Burundi%,,Mozambique 17.96%, Sierra Leone 16.92% and Nigeria 16.31% (Statista). Bitwalla announces on their website that, in their "efforts to provide fast, cheap, and reliable money transfer solutions to everyone, [they] have just launched a solution to send Bitcoin to Nigeria and Uganda. Bitpesa another money transfer company in the past brought Bitcoin transfer and purchase ability to Nigerians and Ugandans but discontinued due to difficulties with a money transfer operator. "Bitpesa has since been making other connections to help with the African remittance service by partnering with other financial institutions in Japan, China and more" (Redman).
While language policy scholars such as Ricento argue for governmental policy to protect multiculturalism, and culture and multilingualism, the perturbations of cryptocurrencies and blockchain technologies bring change the world economic order such that peoples' lives benefit without the need to learn a foreign language. Whether or not Startup Societies or blockchain driven Special Economic Zones become an influence on income equality over the next decades, the fact that capital is flowing into cryptocurrencies and blockchain technologies at an ever-increasing rate, both from the top and the bottom of the global social spectrum of people that invest in cryptocurrencies, implies to some extent the decentralization of the role of government, and the lessening of the forces behind learning a lingua franca or national language for upward mobility also lessen. Through the process of decentralization--localizing economic prosperity--the need for communitarianism to preserve economically beneficial local languages diminishes.
Glossary of Technical Terms
Bitcoin n. (a proprietary name for) a digital payment system introduced in 2009, having its own
unit of account; the unit of account of this system.
Blockchain n. "a peer-to-peer network that sits on top of the internet—was introduced in
October 2008 as part of a proposal for bitcoin, a virtual currency system that eschewed a central authority for issuing currency, transferring ownership, and confirming transactions. Bitcoin is the first application of blockchain technology" (Iansiti).
Blockchain "[T]he cryptographic technology that underlies bitcoin, called the “'blockchain'”, has
applications well beyond cash and currency. It offers a way for people who do not know or trust each other to create a record of who owns what that will compel the assent of everyone concerned. It is a way of making and preserving truths.
It is the blockchain that replaces [the need for a] trusted third party. A database that contains the payment history of every bitcoin in circulation, the blockchain provides proof of who owns what at any given juncture. This distributed ledger is replicated on thousands of computers—bitcoin’s “'nodes'”—around the world and is publicly available. But for all its openness it is also trustworthy and secure. This is guaranteed by the mixture of mathematical subtlety and computational brute force built into its “consensus mechanism”—the process by which the nodes agree on how to update the blockchain in the light of bitcoin transfers from one person to another.
Other applications for blockchain and similar “'distributed ledgers'” range from thwarting diamond thieves to streamlining stockmarkets: the NASDAQ exchange will soon start using a blockchain-based system to record trades in privately held companies. The Bank of England, not known for technological flights of fancy, seems electrified: distributed ledgers, it concluded in a research note late last year, are a “'significant innovation” that could have “far-reaching implications” in the financial industry'" (The Economist).
Communitarianism the principal task of government is to secure and distribute fairly the liberties and economic resources individuals need to lead freely chosen lives. (Communitarianism)
Cryptocurrency n. A digital currency in which encryption techniques are used to regulate the
generation of units of currency and verify the transfer of funds, operating independently of a central bank.
Distributed Ledger A distributed ledger is a consensus of replicated, shared, and synchronized
digital data geographically spread across multiple sites, countries, and/or institutions.
Users of Distributed Ledger Technology (DLT) significantly benefit from the efficiencies and economics by creating a more robust environment for real-time and secure data sharing. Contrary to common belief, the Bitcoin blockchain is not the only distributed ledger, in fact, many other users of Distributed Ledger Technology use different methodologies to achieve the same consensus (e.g. Ripple, MultiChain, HyperLedger Project).
Decentralization n. The action or fact of decentralizing; decentralized condition; esp. in Polit.,
the weakening of the central authority and distribution of its functions among the branches or local administrative bodies.
"Copyright (c) 2009-2017 The Bitcoin Core developers
Copyright (c) 2009-2017 Bitcoin Developers
Permission is hereby granted, free of charge, to any person obtaining a copy
of this software and associated documentation files (the "Software"), to deal
in the Software without restriction, including without limitation the rights
to use, copy, modify, merge, publish, distribute, sublicense, and/or sell
copies of the Software, and to permit persons to whom the Software is
furnished to do so, subject to the following conditions:
The above copyright notice and this permission notice shall be included in
all copies or substantial portions of the Software.
THE SOFTWARE IS PROVIDED "'AS IS'", WITHOUT WARRANTY OF ANY KIND, EXPRESS OR
IMPLIED, INCLUDING BUT NOT LIMITED TO THE WARRANTIES OF MERCHANTABILITY,
FITNESS FOR A PARTICULAR PURPOSE AND NONINFRINGEMENT. IN NO EVENT SHALL THE
AUTHORS OR COPYRIGHT HOLDERS BE LIABLE FOR ANY CLAIM, DAMAGES OR OTHER
LIABILITY, WHETHER IN AN ACTION OF CONTRACT, TORT OR OTHERWISE, ARISING FROM,
OUT OF OR IN CONNECTION WITH THE SOFTWARE OR THE USE OR OTHER DEALINGS IN
THE SOFTWARE" (Github).
Open Source Software "The Open Source Definition is the definition propounded by the Open
Source Initiative, used to describe which licenses qualify as "Open Source" licenses. The Open Source Initiative also certifies licenses as OSI Certified to indicate that they fall within the Open Source Definition . . . open source licenses must permit non-exclusive commercial exploitation of the licensed work, must make available the work's source code, and must permit the creation of derivative works from the work itself" (St. Laurent).
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