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Next, there are the sheepish Internet filterers: Turkey has taken a much more subtle approach than China, and has even shown responsiveness to public demands for Internet freedom, but nevertheless its online censorship policies continue with considerable obfuscation. The Turkish government has had an uneasy relationship with an open Internet, being far more tolerant than some of its regional neighbors but much more restrictive than its European allies. It is impossible to get a completely unfiltered connection to the Internet in Turkey—an important distinction between Turkey and Western countries. YouTube was blocked by Turkish authorities for more than two years after the company refused to take down videos that officials claimed denigrated the country’s founder, Mustafa Kemal Atatürk. (In keeping with a 1951 law that criminalizes public insults to Atatürk, YouTube agreed to block the videos for the Turkish audience, but the government wanted them removed globally from the platform worldwide.) This ban was highly visible, but subsequent censorship has been more covert: Some eight thousand websites have been blocked in Turkey without public notice or official government confirmation.

The sheepish model is popular with governments that struggle to strike a balance between divergent beliefs, attitudes and concerns within their population. But by pursuing this path, the government itself can become the enemy if it goes too far, or if its machinations are exposed. To give a recent example from Turkey: In 2011, the government announced a new nationwide Internet filtering policy featuring a four-tier system of censorship, in which citizens would have to choose the level of filtering they wanted (from the most to least restrictive: “child,” “family,” “domestic” and “standard” levels). The Information and Communications Technologies Authority (known by its initials in Turkish as BTK) said the scheme was intended to protect minors and promised that people who chose the “standard” level would encounter no censorship. Many people skeptical of BTK’s record on transparency balked. In fact, the plan generated such an outcry among the population that thousands of people in more than thirty cities around Turkey took to the streets to protest the proposed changes.

Under pressure, the government dialed back its plan, ultimately instituting just two content filters—“child” and “family”—which users could adopt voluntarily. But the controversy didn’t end there. Media-freedom groups reported that their own tests of the censorship system revealed a more aggressive filtering framework than BTK would admit. In addition to the expected banned terms having to do with pornography or violent content, they found that ordinary news websites, content that was culturally liberal or Western (e.g., anything including the word “gay,” or information about evolution) and keywords related to the Kurdish minority were all blocked under the new system. Some activists argued that blocking information about Kurdish separatist organizations with the “child” filter was evidence of the state’s nefarious intent; the international media watchdog group Reporters Without Borders called the Turkish policy “backdoor censorship.”

The Turkish government responded to some of the public concerns about the new system. When a Turkish newspaper reported that educational websites about scientific evolution were blocked while content from a prominent Turkish creationist were not, the authorities eliminated the block immediately. But there is little to no transparency around what content is censored under these policies, so the government is forced to react only when such discrepancies are brought to light by citizens. The sheepish model of Internet filtering, then, combines a government’s ability to evade accountability with its willingness to take constructive action when pressure mounts. This approach would appeal to countries with growing civil societies but strong state institutions, or for governments without reliable bases of support but enough concentrated power to make such unilateral decisions.

The third approach, politically and culturally acceptable filtering, is employed by states as diverse as South Korea, Germany and Malaysia. This is limited and selective filtering around very specific content, based in law, with no attempt to hide the censorship or the motivations behind it. Outliers within the population might grumble, but the majority of citizens often agree with the filtering policies for reasons of security or public well-being. In South Korea, for example, the National Security Law expressly criminalizes public expressions of support for North Korea in both physical and virtual space. The South Korean government regularly filters Internet content affiliated with its northern neighbor—in 2010 it was reported that the government blocked some forty websites associated with or supportive of the North Korean regime, took down a dozen accounts with potential ties to Pyongyang on social-networking sites like Facebook and Twitter, and forced website administrators to delete more than forty thousand pro–North Korea blog posts.

Germany has strong anti-hate-speech laws that make Holocaust denial and neo-Nazi rhetoric illegal, and consequently the government blocks websites within Germany that express those views. And Malaysia, despite promising its citizens that it would never censor the Internet—going so far as to codify it in its Bill of Guarantees—abruptly blocked access to file-sharing sites like Megaupload and the Pirate Bay in 2011, claiming that the sites were in violation of another law, the country’s Copyright Act of 1987. In a statement, the Malaysian Communications and Multimedia Commission defended the move, writing, “Compliance with the law is not to be construed as censorship.” Many Malaysians disagreed, but the block remained politically and legally acceptable.

Of the three models, activists will pray that the third approach becomes the norm for states around the world, but this seems unlikely; only countries with highly engaged and informed populations will need to be this transparent and restrained. Since most governments will make such decisions before their citizens become fully connected, they will feel little incentive to proactively promote the kind of free and open Internet exhibited by countries in the “politically acceptable model.”

The trends we see today will continue in ways that are, for the most part, fairly predictable. All governments will feel as if they’re fighting a losing battle against an endlessly replicating and changing Internet, and balkanization will emerge as a popular mechanism to address this challenge. The next stage in the process for many states will be collective editing, states forming communities of interest to edit the web together, based on shared values or geopolitics. Collective action—be it in the physical or virtual world—will be a logical move for many states that find they lack the resources, the reach or the capability to influence vast territories. And even with balkanization, cyberspace is still a lot of ground to cover, so just as some states leverage each other’s military resources to secure more physical ground, so too will states form alliances to control more virtual territory. For larger states, collaborations will legitimize their filtering efforts and deflect some unwanted attention (the “look, others are doing it too” excuse). For smaller states, alliances along these lines will be a low-cost way to curry favor with bigger players and simultaneously gain some useful technical skills and capacity that they might lack at home.

Collective editing may start with basic cultural agreements and shared antipathies among states, such as what religious minorities they dislike, how they view other parts of the world or what their cultural perspective is on historical figures like Vladimir Lenin, Mao Zedong or Mustafa Kemal Atatürk. In the online world, shared cultural and normative sensibilities create a gravitational pull among states, including those who might not otherwise have reason to band together. Larger states are less likely to engage in this than smaller ones—they already have the technical capabilities—so it will be a fleet of smaller states, pooling their resources, that will find this method useful. If some member countries in the Commonwealth of Independent States (CIS), an association of former Soviet states, became fed up with Moscow’s insistence on standardizing the Russian language across the region, they could join together to censor all Russian-language content from their national Internets and thus limit their citizens’ exposure to Russia altogether.