7 ms·

You shouldn't even be expected to geoblock. If I'm operating a Web site in country A, I should not have to care about country B's laws unless I am taking specif

by Hizonner 11mo ago

You shouldn't even be expected to geoblock. If I'm operating a Web site in country A, I should not have to care about country B's laws unless I am taking specific action intended to attract users in country B in particular. That's doesn't mean just to target the whole world, either. If you don't want your citizens to access something in another country, take it up with your citizens. It was obvious from the minute that idiots started creating IP location databases in the first place that people would demand that they be used like that... and those demands seem to be winning out.

mlhpdx 11mo ago
I don’t agree that choosing to host a website without limiting the audience is innocent. It’s a choice, and has been the default for a long time, but it means one has chosen to speak outside the borders of their own country and that comes with rules, like them or not.
- landl0rd 11mo ago
  No, one has chosen to make something available for contact within one country. One is not actively himself reaching across borders to do so. One cannot reasonably be required to take any affirmative action to fulfill the whims of a foreign government. Also, Britain isn't important enough to make this stick against e.g. an American. If someone writes me a letter asking a question about material that is prohibited in his own country, that is not my problem. It is his responsibility to comply with local law and that of local government to seize material that is illegal there. They cannot deputize me to act, unpaid and without consent, on their behalf.
  - gpm 11mo ago
    What is having your web server send IP packets with an IP address addressed to an overseas address to your ISP who you have signed a contract with to have them deliver those packets to the designated address if not actively reaching across borders? That's what happens when you respond to a request after all. (Up to very minor nits, e.g. you might be paying a cloud provider instead of an ISP).
    - landl0rd 11mo ago
      It is a reply. I am not responsible for checking the locality of an IP address. Indeed, I can never do so with one hundred per cent accuracy. It is Not My Problem. Governments that expect some content or other blocked can damn well do it themselves, in their own legal system. They cannot compel someone else to spend his time, talent, or treasure to enforce their petty rules. If they go after one of their own for requesting something from me, whatever. If they block me, whatever. I suppose they're within their rights to do that. The federal government "deputizing" or trying to chill private actors out of speech, out of doing business, etc. is a violation of Americans' first amendment rights; so held SCOTUS last year. No way in h--- are we letting some tinpot foreigner do so.
      - refulgentis 11mo ago
        “ Governments that expect some content or other blocked can damn well do it themselves, in their own legal system” What you are describing is exactly what is going on here. OFCAM’s final action, if taken, is blocking at ISP level. All of the legal stuff is happening in the UK system. I’m just sort of curious for your thoughts after learning that. (Also, I’m curious about the SCOTUS decision, I.e. which one? I used to be a law nerd and got a kick out of reading oral arguments for the first time in years this week, would appreciate more material)
        landl0rd 11mo ago
        No, it's also able to do things like issue fines, which they have, although American law is not amenable to actually collecting those if their assets are all here. I don't really care if british choose to block something on british soil. Murthy v. Missouri was generally a loss; 6-3 with Justice Barrett for the majority ruling states lacked standing, which is consistent with the Roberts court's informal policy of dodging. Alito dissented, joined by Thomas and I think Gorsuch, and that is worth a read. The more important one was NRA v. Vullo, a unanimous opinion from Sotomayor. Gorsuch wrote a concurrence as did I believe one other justice.
        11mo ago
  - aDyslecticCrow 11mo ago
    If someone writes you a letter than they have your family hostage, and to route 50.000 dollars thorough bitcoin to not have them killed, with a AI generated video as proof; are they scott free because they're not based in the US?
    - Hizonner 11mo ago
      First of all, this is about Web sites, and that's not a valid analogy. Web sites don't spontaneously send you letters, let alone kidnap you. You only get content you actively asked for. Second, where is the person writing the letter from? Mars? They're going to have a hard time finding a place where kidnapping and extortion are legal. Third, the letter would in fact presumably be aimed at a specific person in a specific country... as would the kidnapping.
      - aDyslecticCrow 11mo ago
        Websites absolutely spontaneously send letters, or advertising flyers. The company could be from china or Russia with little interest in diplomatic pandering for such a small incident. Providing a user a service in exchange for payment is also aimed at a specific person in a specific country. heck, if no laws can be applied across borders, it could be a website selling the service of fake extortion letters. And don't mix up "difficult to enforce" with "legal". Constantly changing domains and hiding who is behind the service are efforts to avoid being caught by very real and enforced laws.
  - HPsquared 11mo ago
    The client requests content from a server. The server may be abroad. It's the same as ordering goods from abroad, only much faster. I wonder what the law is for importing goods that are illegal in the destination country.
    - em-bee 11mo ago
      whatever the laws are, they are the responsibility of the importer, not the producer.
    - kelnos 11mo ago
      It's really the same principle. For physical goods that are crossing borders, but are illegal in the destination country, their customs officials can seize the goods. For data packets on the internet, the destination country is free to block them if they find them objectionable.
- HotGarbage 11mo ago
  Yeah, nah, the internet is pull not push. If a citizen of country A seeks material from country B that's legal in B but illegal in A that's on them.
  - patrickmay 11mo ago
    This is the key point. No site is sending material to the UK unsolicited. People in the UK are initiating the download of information they find of interest. If the UK government has a problem with that, it's on them to block the downloads on their side. UK laws have no power outside the UK.
- Hizonner 11mo ago
  > I don’t agree that choosing to host a website without limiting the audience is innocent. "Innocent"? That's a strange word to choose. Who cares what's "innocent"? > It’s a choice, and has been the default for a long time, but it means one has chosen to speak outside the borders of their own country and that comes with rules, like them or not. ... or it means one has chosen to speak inside the borders of their country, and people outside those borders have chosen to import that speech. Web sites don't lob speech at you willy-nilly. The bottom line is that that standard is impractical to implement, illiberal in its effects, and just generally a bad idea. For that matter, it's also at odds with most of the ways the world treats trade in physical goods.
- Alex2037 11mo ago
  are your websites compliant with Russian, Chinese, and Iranian laws and online regulations?
  - kstrauser 11mo ago
    Beat me to it. This is my go-to analogy for people who don't understand the problem. I am 100% certain I've violated North Korean law by posting mean things about Dear Leader. I couldn't care less. If I were to find myself in NK, I'm sure I'd care a lot, but that's not going to happen, so I don't. If I'm not afraid of violating NK law — because I'll never, ever be there — then the same logic holds for the laws of every other country I won't be visiting.
- _DeadFred_ 11mo ago
  If you choose to call my automated joke line running off of an answering machine in my home, do I have to follow your country's laws or my own?
- snickerbockers 11mo ago
  It actually doesn't lmao.
- kelnos 11mo ago
  That's absurd. If I put up a website that I believe is lawful in my own country, I'm not even thinking about people in other countries. If people from elsewhere access it, it's up to them to ensure that the content on my site complies with their local laws. If the government of their country believes that accessing my website is a problem for their residents, then the onus is on them to sort it out on their own, without my involvement. They are perfectly capable of ordering ISPs that operate inside their borders to block my website from their customers. The fact that Ofcom hasn't just done something like this in the case of SaSu, 4chan, etc., shows that they are not actually interested in "online safety"; they're making political statements and are trying to throw their weight around like the bullies they clearly are.
OptionOfT 11mo ago
If I recall correctly, this is how the GDPR works. If someone to who the GDPR applies to visits a website, a website cannot record any information about them, regardless of whether that website actually is based in the EU, which is why certain US websites block traffic from the EU. Source: https://gdpr.eu/companies-outside-of-europe/ https://gdpr.eu/companies-outside-of-europe/ 1. This Regulation applies to the processing of personal data in the context of the activities of an establishment of a controller or a processor in the Union, regardless of whether the processing takes place in the Union or not. 2. This Regulation applies to the processing of personal data of data subjects who are in the Union by a controller or processor not established in the Union, where the processing activities are related to: (a) the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or (b) the monitoring of their behaviour as far as their behaviour takes place within the Union. 3. This Regulation applies to the processing of personal data by a controller not established in the Union, but in a place where Member State law applies by virtue of public international law. E.g. the website in this article https://news.ycombinator.com/item?id=45819635 https://news.ycombinator.com/item?id=45819635 does not work when you visit it with a European IP address. You get an error 451.
N0RMAN 11mo ago
I don’t understand the IP location criticism at all. At least for my experience across Europe all locations that are being reported by the common databases are within 250km of the actual customer.
- Hizonner 11mo ago
  The criticism is that it exists, which invites abuse. Being more accurate would be worse.
  - refulgentis 11mo ago
    When you put it that way, well, it made me chuckle. (The irony!)
- matt-p 11mo ago
  Maybe this is very european of me but 250KM is outrageously far. Dublin to Belfast is like 130KM. If it says they're in Seville (in Spain) within <200KM they could also be in Portugal, Morocco, or Gibraltar. If it says you're in Brussels within <200KM you could also be in France, England, Germany, Netherlands, Lux. If you're in Vienna (Austria), you could also be in Germany, CZ, Slovakia, Hungary, Slovenia or Croatia. Maybe you're in Vilnius? You could also be in Latvia, Poland, Russia or Belarus. Comedically far.
  - rstuart4133 11mo ago
    It's short by Australian standards. I was born 1000km away. It's a 12 hour drive. I've done it numerous times. It was a regular thing when I was young. Uni students have been know to drive for a drink at the pub at the next Uni north (at the time) over the weekend for a lark. That's 2000km, one way. A serious undertaking by Australian standards is a drive to Perth. That's 5000km in a straight line, but of course you can't drive in a straight line to Perth. I met a guy once who was the last leg of circumnavigating Australia on his push bike. It had taken him years, and it looked like it. I've never seen someone so wirey, so obviously fit. Yet he rode at a slow measured pace. That was no doubt a habit forced by the trailer his bike towed. I guess the trip was around 15,000km.
owl_vision 11mo ago
what happens if an IP address is not in the geo db? For example: 2606:4700::6811:
- ChocolateGod 11mo ago
  You check the country the ASN behind the IP belongs to.
  - greyface- 11mo ago
    RIRs don't prohibit out-of-region use of IP addresses or ASNs registered in their region. The country an IP is registered in is not necessarily the country it's being used in.
    - ranger_danger 11mo ago
      And they are routinely used in exactly this confusing fashion.
  - matt-p 11mo ago
    ASN is even worse, honestly. If I'm behind starlinks AS then I'm American? AWS, I'm also American? Level 3? American. Colt leased line in my office in Madrid, apparently I'm English.
    - teekert 11mo ago
      You are whatever your VPN exit node is.
- inemesitaffia 11mo ago
  SOFTNET EUROPE CORP. 6811 Ayala Avenue, Makaty City, Metro Manila, Philippines
aDyslecticCrow 11mo ago
> If I'm operating a Web site in country A, I should not have to care about country B's laws Not defending UK's idiotic laws, but this doesn't hold. If you cannot regulate websites outside of the country of origin, then no internet regulation can hold for any subject. Openly selling stolen personal credentials or botnet usage? Piracy? Reselling personal information without disclosure? So there are effectively three options for internet regulation; - Require websites to operate region by region with IP blocks for any non-target market. This is much of EU law is applied. If you put an effort to not serve EU costumers, you can skip following EU rules. "comply or leave" - Any country can regulate any website regardless of origin, like the UK seems to push for. This is an insane proposal and could easily create geopolitical disputes. Great firewall and banning VPNs would be the only proper way to achieve what they seem to aim for.... which i wouldn't put past them by now. - Give up regulating the internet entirely. Some level of regulation is valuable so I don't think this will ever work. There are simply some things illegal and deplorable enough to require laws.
- iamnothere 11mo ago
  If country B doesn’t like it, block the site in question. You’re not going to extradite US site operators, period. Find another approach.
  - mlhpdx 11mo ago
    That’s what they’re doing
    - iamnothere 11mo ago
      No, they are making threats about the site in country A while the site has voluntarily blocked all of country B, with country B saying that this isn’t enough, despite the operators in country A being out of jurisdiction and making an effort to comply regardless. Country B is basically saying that the site in country A is not allowed on the internet at all.
    - pirates 11mo ago
      It’s not at all what they’re doing, and claiming so is either extreme ignorance of the situation or deliberately lying.
vessenes 11mo ago
Preston talks about this in an earlier blog post. It's a matter of UK law and, I'd bet, many countries, that they have the sovereign right to legislate about matters in and outside their borders. "If Parliament says smoking in Paris is illegal, it is illegal." What's different today than when that doctrine was conceived of is: data goes everywhere, communications are decentralized, international cooperation around especially data allows nations to enforce their own rules outside their own borders by treaty. What was known and not said when Parliament might have outlawed smoking in Paris is that there was literally nothing they could do to enforce such a law. Today the governments have options, hence the fight here. And many other places.
- Hizonner 11mo ago
  > It's a matter of UK law and, I'd bet, many countries, that they have the sovereign right to legislate about matters in and outside their borders. Basically all countries take that position legally. But there are norms and customs about how often you exercise it (as well as practical questions of power). Extraterritorial regulation of Web sites is unfortunately in the process of being established as normal, but it's a bad norm. Not as bad as drone striking anybody who lights a cigarette in Paris (which could be made legal), but a bad norm nonetheless.
  - HPsquared 11mo ago
    What happens if two foreign countries try to impose mutually exclusive laws?
    - conartist6 11mo ago
      Then they kiss
    - londons_explore 11mo ago
      For many years, Google solved this by saying the laws of country X only applied in the country specific domain of Google. They now seem to have backtracked on that and are using either the country the request came from or the country the account was set up from (both using IP geolocation)
nine_k 11mo ago
If you operate a website outside UK and that's it, you may not care. But if you offer paid servies, collect money from UK citizens, you must have a business representation in the UK, which is bound by UK laws, can be fined, dragged to a court, etc. If you have this vulnerability, or you don't but your holding company has other web properties that do, the UK government has a way to make you listen and comply.
- deleted 11mo ago
  [deleted]
- EGreg 11mo ago
  Why don't people just build decentralized smart contracts these days? Why worry about all these liabilities?
  - llbbdd 11mo ago
    Because crypto is a liability itself and nobody normal likes interacting with it.
    - AnthonyMouse 11mo ago
      Is there no way to improve the user experience for this? Company A sells cryptocurrency in country A. Company B is a payment processor in country B. You in country A go to the country B merchant's website and enter your card info to buy something. Your card gets charged by company A to buy cryptocurrency, the merchant gets the money through company B and the transfer of cryptocurrency from company A to company B happens in software on a server somewhere and the user doesn't have to do anything. Why is this either not happening or not sufficient?
      - EGreg 11mo ago
        You are right and HN has no answer other than “crypto is bad”. We are building exactly this at Intercoin. I hate that most of crypto is zero-sum games. https://intercoin.org/currencies.pdf https://intercoin.org/currencies.pdf Also Stripe is launching Tempo blockchain, USDC is launching Arc blockchain. Cool things are coming!
hilbert42 11mo ago
"You shouldn't even be expected to geoblock." I read the article and I remain confused. I've just come to this story after seeing it on HN so I might have misunderstandings from being unaware of the background. Also, I neither reside in the US nor UK so I'd have not seen local media reports. In short, I gather UK's Ofcom is threatening a US web site for online content that is lawful within the US's jurisdiction and unlawful in the UK as it contravenes the UK's Online Safety Act. I am bewildered that Preston Byrne has even bothered to acknowledge Ofcom's correspondence let alone respond to it as the UK (Ofcom) has no jurisdiction over actions of any entity or person within the continental US—or for that matter the actions of those outside its borders unless, say, covered by treaty, etc. That Preston Byrne responded to Ofcom seems strange given the fact that he is not only a lawyer but also head of legal and compliance at Arkham law firm, thus he ought to be aware that is client is shielded from UK law by virtue that the UK has no jurisdiction on US territory. If I'd been Byrne I'd not have even acknowledged Ofcom's correspondence with a 'fuck off/cease and desist' reply but filed it in the trash can. (If there's some mitigating matter I've missed here let me know.) It's clear to me the the UK's Online Safety Act stops at its borders so the UK has full responsibility for blocking websites that are physically outside its jurisdiction, similarly blocking or stopping its citizens from accessing accessing them. It seems to me many of the younger internet fraternity are unaware that there's longstanding precedent for how such matters are handled. Back in the days of the Cold War before the internet some countries used to broadcast propaganda on HF/shortwave radio bands to those that were their political enemies and recipient countries would attempt to jam the broadcasts so their citizens would not be able to listen to them. For example, Communist USSR, China etc. would jam the BBC or the US's VOA (Voice of America). Simply, if a country did not want its citizens to listen to the broadcasts of another country it was its responsibility to jam the incoming signals. It seems to me all that has actually changed since then is that nowady the unwanted broadcasts come via internet circuits. Frankly, Ofcom has an unmitigated hide to threaten people who are acting lawfully within the US. That said, it's not unexpected, in recent decades the UK's been acting like a petulant bully, it seems to have forgotten that without it's empire it can no longer enforce its bullyboy tactics. BTW, the matter of what content is or is not acceptable online is completely separate issue from Ofcom's behavior. Personally, from what I've gathered I'd find content on the SaSu website unacceptable and I can understand why many in the UK want it blocked but bypassing another country's sovereign authority is not the correct way to go about it.
Danjoe4 11mo ago
That's the current status quo. The UK can't sue you, extradite you, or really do anything. Assuming that your service providers are US based and you follow US law, they can pound sand. In practice, the US is the only country powerful enough to enforce its laws extraterritoriality. The UK trying to enforce its internet laws on me? An American citizen? Funny joke
- dreamcompiler 11mo ago
  As long as you don't set foot on British soil you'll be fine. But that's less simple than it sounds. Don't book a flight that connects in the UK, sure. But what if your NYC-to-Munich flight has engine trouble and needs to make an emergency landing in London? You are screwed: You'll be pulled off the plane and taken to jail. Will the US embassy get involved? Of course. Will they get you released? Maybe, but it's not guaranteed. And you are in for a bad time regardless.
  - Danjoe4 11mo ago
    The UK knows their place. They could do that but they won't. Also, they'll have trouble even finding who the business operator is. The US allows pseudonymous business structures and their subpoena request will be thrown out on a 1st amendment defense.
    - anywerds 11mo ago
      I can only imagine the storm that would emerge if the morning the UK ever attempted to arrest an American for self-expression inside or outside the USA. That is how you get some Democracy delivered.
      - nathanlied 11mo ago
        Just the UK? Not, say, Iran? https://en.wikipedia.org/wiki/Michael_R._White_(U.S._veteran)#Sentencing_and_allegations https://en.wikipedia.org/wiki/Michael_R._White_(U.S._veteran... Or maybe China, for a US citizen who posted while on US soil, in a US website? https://www.reuters.com/world/exclusive-american-barred-leaving-china-returned-us-before-biden-xi-meeting-2021-11-18/ https://www.reuters.com/world/exclusive-american-barred-leav... Seems a little inconsistent, this delivery of Democracy.
jackjeff 11mo ago
The UK has no problem asking their ISPs to block the Pirate Bay. Why can’t OFCOM do this? I don’t understand the attempt to pursue this in a foreign country. It’s fairly obvious that what they’re doing are not considered crimes in the US and politically it looks bad from Trump and his administration. And also, until 5 mins ago I had no idea this site existed. Now I do. Seems to achieve the polar opposite as I’m in the UK and browsing a dangerous forbidden site now. Wooooo

mlhpdx 11mo ago

I don’t agree that choosing to host a website without limiting the audience is innocent. It’s a choice, and has been the default for a long time, but it means one has chosen to speak outside the borders of their own country and that comes with rules, like them or not.

landl0rd 11mo ago
No, one has chosen to make something available for contact within one country. One is not actively himself reaching across borders to do so. One cannot reasonably be required to take any affirmative action to fulfill the whims of a foreign government. Also, Britain isn't important enough to make this stick against e.g. an American. If someone writes me a letter asking a question about material that is prohibited in his own country, that is not my problem. It is his responsibility to comply with local law and that of local government to seize material that is illegal there. They cannot deputize me to act, unpaid and without consent, on their behalf.
- gpm 11mo ago
  What is having your web server send IP packets with an IP address addressed to an overseas address to your ISP who you have signed a contract with to have them deliver those packets to the designated address if not actively reaching across borders? That's what happens when you respond to a request after all. (Up to very minor nits, e.g. you might be paying a cloud provider instead of an ISP).
  - landl0rd 11mo ago
    It is a reply. I am not responsible for checking the locality of an IP address. Indeed, I can never do so with one hundred per cent accuracy. It is Not My Problem. Governments that expect some content or other blocked can damn well do it themselves, in their own legal system. They cannot compel someone else to spend his time, talent, or treasure to enforce their petty rules. If they go after one of their own for requesting something from me, whatever. If they block me, whatever. I suppose they're within their rights to do that. The federal government "deputizing" or trying to chill private actors out of speech, out of doing business, etc. is a violation of Americans' first amendment rights; so held SCOTUS last year. No way in h--- are we letting some tinpot foreigner do so.
    - refulgentis 11mo ago
      “ Governments that expect some content or other blocked can damn well do it themselves, in their own legal system” What you are describing is exactly what is going on here. OFCAM’s final action, if taken, is blocking at ISP level. All of the legal stuff is happening in the UK system. I’m just sort of curious for your thoughts after learning that. (Also, I’m curious about the SCOTUS decision, I.e. which one? I used to be a law nerd and got a kick out of reading oral arguments for the first time in years this week, would appreciate more material)
      - landl0rd 11mo ago
        No, it's also able to do things like issue fines, which they have, although American law is not amenable to actually collecting those if their assets are all here. I don't really care if british choose to block something on british soil. Murthy v. Missouri was generally a loss; 6-3 with Justice Barrett for the majority ruling states lacked standing, which is consistent with the Roberts court's informal policy of dodging. Alito dissented, joined by Thomas and I think Gorsuch, and that is worth a read. The more important one was NRA v. Vullo, a unanimous opinion from Sotomayor. Gorsuch wrote a concurrence as did I believe one other justice.
        11mo ago
- aDyslecticCrow 11mo ago
  If someone writes you a letter than they have your family hostage, and to route 50.000 dollars thorough bitcoin to not have them killed, with a AI generated video as proof; are they scott free because they're not based in the US?
  - Hizonner 11mo ago
    First of all, this is about Web sites, and that's not a valid analogy. Web sites don't spontaneously send you letters, let alone kidnap you. You only get content you actively asked for. Second, where is the person writing the letter from? Mars? They're going to have a hard time finding a place where kidnapping and extortion are legal. Third, the letter would in fact presumably be aimed at a specific person in a specific country... as would the kidnapping.
    - aDyslecticCrow 11mo ago
      Websites absolutely spontaneously send letters, or advertising flyers. The company could be from china or Russia with little interest in diplomatic pandering for such a small incident. Providing a user a service in exchange for payment is also aimed at a specific person in a specific country. heck, if no laws can be applied across borders, it could be a website selling the service of fake extortion letters. And don't mix up "difficult to enforce" with "legal". Constantly changing domains and hiding who is behind the service are efforts to avoid being caught by very real and enforced laws.
- HPsquared 11mo ago
  The client requests content from a server. The server may be abroad. It's the same as ordering goods from abroad, only much faster. I wonder what the law is for importing goods that are illegal in the destination country.
  - em-bee 11mo ago
    whatever the laws are, they are the responsibility of the importer, not the producer.
  - kelnos 11mo ago
    It's really the same principle. For physical goods that are crossing borders, but are illegal in the destination country, their customs officials can seize the goods. For data packets on the internet, the destination country is free to block them if they find them objectionable.
HotGarbage 11mo ago
Yeah, nah, the internet is pull not push. If a citizen of country A seeks material from country B that's legal in B but illegal in A that's on them.
- patrickmay 11mo ago
  This is the key point. No site is sending material to the UK unsolicited. People in the UK are initiating the download of information they find of interest. If the UK government has a problem with that, it's on them to block the downloads on their side. UK laws have no power outside the UK.
Hizonner 11mo ago
> I don’t agree that choosing to host a website without limiting the audience is innocent. "Innocent"? That's a strange word to choose. Who cares what's "innocent"? > It’s a choice, and has been the default for a long time, but it means one has chosen to speak outside the borders of their own country and that comes with rules, like them or not. ... or it means one has chosen to speak inside the borders of their country, and people outside those borders have chosen to import that speech. Web sites don't lob speech at you willy-nilly. The bottom line is that that standard is impractical to implement, illiberal in its effects, and just generally a bad idea. For that matter, it's also at odds with most of the ways the world treats trade in physical goods.
Alex2037 11mo ago
are your websites compliant with Russian, Chinese, and Iranian laws and online regulations?
- kstrauser 11mo ago
  Beat me to it. This is my go-to analogy for people who don't understand the problem. I am 100% certain I've violated North Korean law by posting mean things about Dear Leader. I couldn't care less. If I were to find myself in NK, I'm sure I'd care a lot, but that's not going to happen, so I don't. If I'm not afraid of violating NK law — because I'll never, ever be there — then the same logic holds for the laws of every other country I won't be visiting.
_DeadFred_ 11mo ago
If you choose to call my automated joke line running off of an answering machine in my home, do I have to follow your country's laws or my own?
snickerbockers 11mo ago
It actually doesn't lmao.
kelnos 11mo ago
That's absurd. If I put up a website that I believe is lawful in my own country, I'm not even thinking about people in other countries. If people from elsewhere access it, it's up to them to ensure that the content on my site complies with their local laws. If the government of their country believes that accessing my website is a problem for their residents, then the onus is on them to sort it out on their own, without my involvement. They are perfectly capable of ordering ISPs that operate inside their borders to block my website from their customers. The fact that Ofcom hasn't just done something like this in the case of SaSu, 4chan, etc., shows that they are not actually interested in "online safety"; they're making political statements and are trying to throw their weight around like the bullies they clearly are.

OptionOfT 11mo ago

If I recall correctly, this is how the GDPR works. If someone to who the GDPR applies to visits a website, a website cannot record any information about them, regardless of whether that website actually is based in the EU, which is why certain US websites block traffic from the EU. Source: https://gdpr.eu/companies-outside-of-europe/ https://gdpr.eu/companies-outside-of-europe/ 1. This Regulation applies to the processing of personal data in the context of the activities of an establishment of a controller or a processor in the Union, regardless of whether the processing takes place in the Union or not. 2. This Regulation applies to the processing of personal data of data subjects who are in the Union by a controller or processor not established in the Union, where the processing activities are related to: (a) the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the Union; or (b) the monitoring of their behaviour as far as their behaviour takes place within the Union. 3. This Regulation applies to the processing of personal data by a controller not established in the Union, but in a place where Member State law applies by virtue of public international law. E.g. the website in this article https://news.ycombinator.com/item?id=45819635 https://news.ycombinator.com/item?id=45819635 does not work when you visit it with a European IP address. You get an error 451.

N0RMAN 11mo ago

I don’t understand the IP location criticism at all. At least for my experience across Europe all locations that are being reported by the common databases are within 250km of the actual customer.

Hizonner 11mo ago
The criticism is that it exists, which invites abuse. Being more accurate would be worse.
- refulgentis 11mo ago
  When you put it that way, well, it made me chuckle. (The irony!)
matt-p 11mo ago
Maybe this is very european of me but 250KM is outrageously far. Dublin to Belfast is like 130KM. If it says they're in Seville (in Spain) within <200KM they could also be in Portugal, Morocco, or Gibraltar. If it says you're in Brussels within <200KM you could also be in France, England, Germany, Netherlands, Lux. If you're in Vienna (Austria), you could also be in Germany, CZ, Slovakia, Hungary, Slovenia or Croatia. Maybe you're in Vilnius? You could also be in Latvia, Poland, Russia or Belarus. Comedically far.
- rstuart4133 11mo ago
  It's short by Australian standards. I was born 1000km away. It's a 12 hour drive. I've done it numerous times. It was a regular thing when I was young. Uni students have been know to drive for a drink at the pub at the next Uni north (at the time) over the weekend for a lark. That's 2000km, one way. A serious undertaking by Australian standards is a drive to Perth. That's 5000km in a straight line, but of course you can't drive in a straight line to Perth. I met a guy once who was the last leg of circumnavigating Australia on his push bike. It had taken him years, and it looked like it. I've never seen someone so wirey, so obviously fit. Yet he rode at a slow measured pace. That was no doubt a habit forced by the trailer his bike towed. I guess the trip was around 15,000km.

owl_vision 11mo ago

what happens if an IP address is not in the geo db? For example: 2606:4700::6811:

ChocolateGod 11mo ago
You check the country the ASN behind the IP belongs to.
- greyface- 11mo ago
  RIRs don't prohibit out-of-region use of IP addresses or ASNs registered in their region. The country an IP is registered in is not necessarily the country it's being used in.
  - ranger_danger 11mo ago
    And they are routinely used in exactly this confusing fashion.
- matt-p 11mo ago
  ASN is even worse, honestly. If I'm behind starlinks AS then I'm American? AWS, I'm also American? Level 3? American. Colt leased line in my office in Madrid, apparently I'm English.
  - teekert 11mo ago
    You are whatever your VPN exit node is.
inemesitaffia 11mo ago
SOFTNET EUROPE CORP. 6811 Ayala Avenue, Makaty City, Metro Manila, Philippines

aDyslecticCrow 11mo ago

> If I'm operating a Web site in country A, I should not have to care about country B's laws Not defending UK's idiotic laws, but this doesn't hold. If you cannot regulate websites outside of the country of origin, then no internet regulation can hold for any subject. Openly selling stolen personal credentials or botnet usage? Piracy? Reselling personal information without disclosure? So there are effectively three options for internet regulation; - Require websites to operate region by region with IP blocks for any non-target market. This is much of EU law is applied. If you put an effort to not serve EU costumers, you can skip following EU rules. "comply or leave" - Any country can regulate any website regardless of origin, like the UK seems to push for. This is an insane proposal and could easily create geopolitical disputes. Great firewall and banning VPNs would be the only proper way to achieve what they seem to aim for.... which i wouldn't put past them by now. - Give up regulating the internet entirely. Some level of regulation is valuable so I don't think this will ever work. There are simply some things illegal and deplorable enough to require laws.

iamnothere 11mo ago
If country B doesn’t like it, block the site in question. You’re not going to extradite US site operators, period. Find another approach.
- mlhpdx 11mo ago
  That’s what they’re doing
  - iamnothere 11mo ago
    No, they are making threats about the site in country A while the site has voluntarily blocked all of country B, with country B saying that this isn’t enough, despite the operators in country A being out of jurisdiction and making an effort to comply regardless. Country B is basically saying that the site in country A is not allowed on the internet at all.
  - pirates 11mo ago
    It’s not at all what they’re doing, and claiming so is either extreme ignorance of the situation or deliberately lying.

vessenes 11mo ago

Preston talks about this in an earlier blog post. It's a matter of UK law and, I'd bet, many countries, that they have the sovereign right to legislate about matters in and outside their borders. "If Parliament says smoking in Paris is illegal, it is illegal." What's different today than when that doctrine was conceived of is: data goes everywhere, communications are decentralized, international cooperation around especially data allows nations to enforce their own rules outside their own borders by treaty. What was known and not said when Parliament might have outlawed smoking in Paris is that there was literally nothing they could do to enforce such a law. Today the governments have options, hence the fight here. And many other places.

Hizonner 11mo ago
> It's a matter of UK law and, I'd bet, many countries, that they have the sovereign right to legislate about matters in and outside their borders. Basically all countries take that position legally. But there are norms and customs about how often you exercise it (as well as practical questions of power). Extraterritorial regulation of Web sites is unfortunately in the process of being established as normal, but it's a bad norm. Not as bad as drone striking anybody who lights a cigarette in Paris (which could be made legal), but a bad norm nonetheless.
- HPsquared 11mo ago
  What happens if two foreign countries try to impose mutually exclusive laws?
  - conartist6 11mo ago
    Then they kiss
  - londons_explore 11mo ago
    For many years, Google solved this by saying the laws of country X only applied in the country specific domain of Google. They now seem to have backtracked on that and are using either the country the request came from or the country the account was set up from (both using IP geolocation)

nine_k 11mo ago

If you operate a website outside UK and that's it, you may not care. But if you offer paid servies, collect money from UK citizens, you must have a business representation in the UK, which is bound by UK laws, can be fined, dragged to a court, etc. If you have this vulnerability, or you don't but your holding company has other web properties that do, the UK government has a way to make you listen and comply.

deleted 11mo ago
[deleted]
EGreg 11mo ago
Why don't people just build decentralized smart contracts these days? Why worry about all these liabilities?
- llbbdd 11mo ago
  Because crypto is a liability itself and nobody normal likes interacting with it.
  - AnthonyMouse 11mo ago
    Is there no way to improve the user experience for this? Company A sells cryptocurrency in country A. Company B is a payment processor in country B. You in country A go to the country B merchant's website and enter your card info to buy something. Your card gets charged by company A to buy cryptocurrency, the merchant gets the money through company B and the transfer of cryptocurrency from company A to company B happens in software on a server somewhere and the user doesn't have to do anything. Why is this either not happening or not sufficient?
    - EGreg 11mo ago
      You are right and HN has no answer other than “crypto is bad”. We are building exactly this at Intercoin. I hate that most of crypto is zero-sum games. https://intercoin.org/currencies.pdf https://intercoin.org/currencies.pdf Also Stripe is launching Tempo blockchain, USDC is launching Arc blockchain. Cool things are coming!

hilbert42 11mo ago

"You shouldn't even be expected to geoblock." I read the article and I remain confused. I've just come to this story after seeing it on HN so I might have misunderstandings from being unaware of the background. Also, I neither reside in the US nor UK so I'd have not seen local media reports. In short, I gather UK's Ofcom is threatening a US web site for online content that is lawful within the US's jurisdiction and unlawful in the UK as it contravenes the UK's Online Safety Act. I am bewildered that Preston Byrne has even bothered to acknowledge Ofcom's correspondence let alone respond to it as the UK (Ofcom) has no jurisdiction over actions of any entity or person within the continental US—or for that matter the actions of those outside its borders unless, say, covered by treaty, etc. That Preston Byrne responded to Ofcom seems strange given the fact that he is not only a lawyer but also head of legal and compliance at Arkham law firm, thus he ought to be aware that is client is shielded from UK law by virtue that the UK has no jurisdiction on US territory. If I'd been Byrne I'd not have even acknowledged Ofcom's correspondence with a 'fuck off/cease and desist' reply but filed it in the trash can. (If there's some mitigating matter I've missed here let me know.) It's clear to me the the UK's Online Safety Act stops at its borders so the UK has full responsibility for blocking websites that are physically outside its jurisdiction, similarly blocking or stopping its citizens from accessing accessing them. It seems to me many of the younger internet fraternity are unaware that there's longstanding precedent for how such matters are handled. Back in the days of the Cold War before the internet some countries used to broadcast propaganda on HF/shortwave radio bands to those that were their political enemies and recipient countries would attempt to jam the broadcasts so their citizens would not be able to listen to them. For example, Communist USSR, China etc. would jam the BBC or the US's VOA (Voice of America). Simply, if a country did not want its citizens to listen to the broadcasts of another country it was its responsibility to jam the incoming signals. It seems to me all that has actually changed since then is that nowady the unwanted broadcasts come via internet circuits. Frankly, Ofcom has an unmitigated hide to threaten people who are acting lawfully within the US. That said, it's not unexpected, in recent decades the UK's been acting like a petulant bully, it seems to have forgotten that without it's empire it can no longer enforce its bullyboy tactics. BTW, the matter of what content is or is not acceptable online is completely separate issue from Ofcom's behavior. Personally, from what I've gathered I'd find content on the SaSu website unacceptable and I can understand why many in the UK want it blocked but bypassing another country's sovereign authority is not the correct way to go about it.

Danjoe4 11mo ago

That's the current status quo. The UK can't sue you, extradite you, or really do anything. Assuming that your service providers are US based and you follow US law, they can pound sand. In practice, the US is the only country powerful enough to enforce its laws extraterritoriality. The UK trying to enforce its internet laws on me? An American citizen? Funny joke

dreamcompiler 11mo ago
As long as you don't set foot on British soil you'll be fine. But that's less simple than it sounds. Don't book a flight that connects in the UK, sure. But what if your NYC-to-Munich flight has engine trouble and needs to make an emergency landing in London? You are screwed: You'll be pulled off the plane and taken to jail. Will the US embassy get involved? Of course. Will they get you released? Maybe, but it's not guaranteed. And you are in for a bad time regardless.
- Danjoe4 11mo ago
  The UK knows their place. They could do that but they won't. Also, they'll have trouble even finding who the business operator is. The US allows pseudonymous business structures and their subpoena request will be thrown out on a 1st amendment defense.
  - anywerds 11mo ago
    I can only imagine the storm that would emerge if the morning the UK ever attempted to arrest an American for self-expression inside or outside the USA. That is how you get some Democracy delivered.
    - nathanlied 11mo ago
      Just the UK? Not, say, Iran? https://en.wikipedia.org/wiki/Michael_R._White_(U.S._veteran)#Sentencing_and_allegations https://en.wikipedia.org/wiki/Michael_R._White_(U.S._veteran... Or maybe China, for a US citizen who posted while on US soil, in a US website? https://www.reuters.com/world/exclusive-american-barred-leaving-china-returned-us-before-biden-xi-meeting-2021-11-18/ https://www.reuters.com/world/exclusive-american-barred-leav... Seems a little inconsistent, this delivery of Democracy.

jackjeff 11mo ago

The UK has no problem asking their ISPs to block the Pirate Bay. Why can’t OFCOM do this? I don’t understand the attempt to pursue this in a foreign country. It’s fairly obvious that what they’re doing are not considered crimes in the US and politically it looks bad from Trump and his administration. And also, until 5 mins ago I had no idea this site existed. Now I do. Seems to achieve the polar opposite as I’m in the UK and browsing a dangerous forbidden site now. Wooooo