Privacy and Security
Turnitin complies with the security standards of the US, EU and Switzerland
- We are fully committed to transparency and using technology responsibly, no matter what changes emerge from our rapidly evolving digital world;
- As we strive to create new possibilities in education, we hold ourselves to the highest ethical standards. We strive to adhere to the strictest privacy practices so that your trust is well-deserved; and
- Because your peace of mind is important to us, we guard your personal data with the utmost care. We use it only for lawful reasons.
Last Updated: 29th August 2018
Why we collect personal data
When you create an account with us, or when a student has their work processed by Turnitin, we process personal data (such as name, email address, job title, and school) so that we can correctly administer your account and provide you with the best customer service. All personal data we process is directly linked to a specific purpose, such as requesting access to our academic content database, or requesting web content (i.e. a newsletter, case study, video, etc.).
Protecting your data
We endeavor to keep your personal data safe and secure at all times. Depending on the Turnitin solution used, personal data is normally processed both in Europe and in the United States with robust technical and organizational safeguards in place to protect such personal data. Passwords are required to access your personal data, so please remember to keep your password confidential. Even with the best security systems, it is impossible to guarantee 100% protection from hackers and unauthorized third parties who capture information provided over public networks.
When a paper is submitted to Turnitin, it is compared against a vast, secure proprietary database of licensed source material, including millions of periodicals, academic journals, books, and web pages. Turnitin also maintains a separate repository of student papers. Each institution (at the discretion of his or her school administrator) can determine whether or not to include student papers in the repository and whether or not to give students the option to opt out. We can remove student papers from the standard repository at the request of a school administrator.
As a global company, one area of ongoing debate and development concerns the mechanisms put in place to monitor cross-border data transfers. For example, the Safe Harbor regime was dissolved as a global legal framework, and the new EU-US/EU-Swiss Privacy Shield has taken its place. Turnitin is fully committed to going through any reviews and certifications needed to meet new rules and requirements, no matter how complex. We have recently undergone an external audit to ensure that we uphold best practices for data privacy and protection and meet our customers’ evolving needs.
What’s most important
EU-US & Swiss-US Privacy Shield
Turnitin has certified its compliance with the EU-US and Swiss-US Privacy Shield Frameworks. We are committed to processing all personal data received from EU member countries and Switzerland, respectively, in accordance with the applicable Privacy Shield Framework. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the Privacy Shield website. See: www.privacyshield.gov
Under the Privacy Shield Frameworks, Turnitin is responsible for processing the personal data it receives, under each Privacy Shield Framework, as well as transfers to a third party acting on its behalf. Turnitin complies with the Privacy Shield principles for all onward transfers of personal data from the EEA, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Turnitin is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (for issues pertaining to Privacy Shield). In situations where public authorities make lawful requests for information, such as to meet national security or law enforcement requirements, Turnitin may be required to disclose personal data. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based, third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Model Contract Clauses
Where necessary, for data transfers outside the EEA, we utilise the Model Contractual Clauses of the EU Directive 95/46/EC, which meet the adequate mechanism requirements of all EU members, including Germany, Switzerland and Austria. In each case, we put in place appropriate technical and organisational measures to protect personal data.
2. Personal data
Because we provide education services, we are vocal advocates for safeguarding student data and privacy and want to make sure that parents, educators, and schools know this, which is why we took the Student Privacy Pledge, put forth by the Future of Privacy Forum (FPF) and the Software & Information Industry Association (SIIA).
Data We Collect
When an institution’s administrator or instructor creates an account with us, we ask for their personal data such as name, email, phone, and job title, so that we can correctly administer their account and provide them with the best customer service.
The type of information we request is connected to a specific purpose, namely to:
- Verify your identity and connection with a specific institution or company, to determine your eligibility to use our services or mobile application "Turnitin Feedback Studio";
- Download content from our website, such as demos, whitepapers, or webcasts;
- Provide receipt and confirmation of successful text uploads;
- Send important messages about our service, such as any changes to functionality;
- Send system emails, including account setup and password retrieval information, as well as digital receipts when you submit papers to the Turnitin Database; and
- Provide additional product and service support as needed.
When you use our services, the type of device you use and the version of your operating system is automatically collected. Turnitin collects information under the direction of its clients, and has no direct relationship with the individuals whose personal data it processes. Turnitin works with its clients to help them provide notice to their customers concerning the purpose for which personal data is collected.
Putting You in Control
We always give you the choice to opt out of email communication, with the exception of system emails, such as digital receipts and password reset information. In the context of processing student papers, Turnitin has no direct relationship with the individuals whose personal data it processes. Turnitin acknowledges that you have the right to access your personal information. An individual who seeks access or would like to correct, amend, rectify or erase data, or should direct his/her query to the institution that is Turnitin’s customer (the ‘data controller’). If the customer requests that Turnitin erases the data, we will respond within 30 calendar days. If you are an individual user who has questions or would like to make changes to your personal data, please contact the institution through which you use our service.
Upon lawful request, Turnitin will provide information about any personal data we process. At any time, customers may access, correct, change completely or anonymize the personal data that you have provided us by following these steps:
- Log in to your account using your username and password;
- Click the "User Info" link on the navigation bar to open your user profile and view or make changes to your personal data; and
- If you have any trouble or would like for us to make changes for you, please email firstname.lastname@example.org. To honor a change request, we will need the exact information you want changed, as well as information sufficient for us to identify the type of communication you received from us. Our Customer Support can also provide you with information about whether we hold, or process on behalf of a third party, any of your personal data. We respond to requests within 30 calendar days.
We may disclose your personal data in order to comply with a subpoena, court order, or similar legal process or government request when we are required by law to do so. If Turnitin is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal data, and choices you may have regarding your personal data. We will only disclose your personal data to a third party with your prior consent.
3. Tracking technologies
Social Media Features & Widgets
Our website includes social media features, such as the Facebook “Like” button, the “Share This” widget, or interactive mini-programs that run on our site. These features may collect your IP address, record which pages you visit on our site, and set a cookie to enable the feature to function properly. These features and widgets are sometimes hosted by a third party. Your interactions with these features are governed by the Privacy Pledge of the company providing the specific feature.
We do not serve ads on our site. We partner with a third party to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads on other sites, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you and to improve site functionality.
Our website offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal data from our blog or community forum, email us at email@example.com. In some cases, we may not be able to remove your personal data, in which case we will let you know if we are unable to do so and why. You may also post a comment on our blog with the use of a third-party application that may require you to register to post a comment. We do not have access or control of the information posted to the blog. You will need to contact or login into the third-party application if you want the personal data that was posted to the comments section removed. To learn how the third-party application uses your information, please review their privacy policies.
We always give you the choice to opt out of email communication, with the exception of system emails, such as digital receipts and password reset information.
- You have the opportunity to opt-out of receiving communications from us when we first request your personal data;
- You can opt out of receiving further communications by visiting our email preferences page; and
- You can modify your personal data anytime by logging in to your account, selecting "User Info," and making changes as desired.
You may also contact us at firstname.lastname@example.org and ask that we make changes on your behalf, but to honor your request, we will need the exact information you want changed, as well as information sufficient for us to identify the type of communication you received from us. Anytime you provide personal data to us, you determine whether or not we may disclose such information in a personally identifiable form to a third party or use it for purposes different from the purposes for which it was originally collected or subsequently authorized.
5. Transfer to third parties
Turnitin may transfer personal data to companies that help us provide our service. These companies are authorized to use your personal information only as necessary to provide these services to us. Transfers to subsequent third parties are covered by the provisions in this policy regarding notice and choice and the service agreements with our clients.
Our website includes links to other websites whose privacy practices may differ from ours. If you submit personal data to any of those sites, your information is governed by their privacy statements.
We endeavor to keep your personal data safe and secure at all times. Our data is stored in the EU or USA with robust physical, digital, and procedural safeguards in place to protect your personal data, including the use of SSL encryption, redundant servers and data centers, and sophisticated perimeter security. We continuously audit for security vulnerabilities and make software patching a priority. Passwords are required to access your personal data, so please remember to keep your password confidential. Even with the tightest security systems, no one can guarantee protection from hackers and unauthorized third parties who capture information provided over public networks.
|Cyber Essentials accredits a company's IT infrastructure ensuring that its firewalls, secure configurations, user access control, malware protection, and patch management are of a high enough standard to protect any data within the company. Turnitin obtained the Cyber Essentials certification at the request of several international customers. Turnitin successfully completed a third-party audit of the effectiveness of our basic security controls.|
SOC 2 Compliance
|SOC2 is an audit of a company's readiness to protect their user's privacy and the security of their data. The company must show protections for both the data itself and the physical security of the locations it is stored. Turnitin obtained the SOC2 certification to demonstrate our commitment to security, privacy, and availability. To obtain this certification, over 160 controls aligned to the SOC2 criteria were designed for Turnitin and audited for effectiveness. Turnitin successfully satisfied 100% of the controls audited.|
7. Data Integrity
We take every possible step to make sure that the personal data in our systems is relevant for its intended use, accurate, complete, and current. Turnitin will retain personal data we process on behalf of our clients for as long as needed to provide services to our client. We retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may stop using the services at any time. You do not need to specifically inform Turnitin when you stop using the Services. You may delete your account at any time by logging in to your account or by emailing us at email@example.com.
The Turnitin database includes academic papers submitted by students and educators, as well as licensed source material sourced from the Internet. When a teacher wants to check a student paper for plagiarism, a coded engine compares it to other content in the database to check for matches. The software leaves all judgment about intellectual property up to the instructor. In the instance where a paper indicates a strong match to content submitted to another institution, instructors may find it necessary to request to view the matching paper. This request can either be accepted or denied by an institution. Any paper information must be passed from instructor to instructor via email, and therefore, outside of the Turnitin product.
You will at all times retain 100% ownership of your intellectual property rights. Turnitin does not ever assert or claim copyright ownership of any works submitted to or through our service. Your property is YOUR property. We do not, and will not, use your intellectual property for any purpose other than to deliver, support, and develop our services, which are designed to protect and strengthen your copyright.
8. Changes to this policy
EU DATA PROTECTION COMPLIANCE
We work with customers all over the world, and processing your personal data lawfully in order to earn your trust is our top priority. We understand that data protection is essential for good customer service. At Turnitin, our objective is to operate transparently, with accountability, and consistently with the EU and US regulatory environment so that our valued customers feel secure and in control.
Turnitin is fully committed to the following practices to protect your data:
- We will never sell your data;
- We will never use your data for targeted advertising/profiling;
- We secure your data with strong encryption and security best practices in SOC2 certified data centers;
- We respect local privacy laws and work with legal experts to stay abreast of changes;
- When we collect data, we use it for a specific, stated purpose, to improve your experience and our service to you;
- If we need to send any of your data to a third-party, such as a language translation service provider, we require a contractual agreement that they handle and secure your data with the same high level of protection and care that we deliver; and
- We respect your right to retain ownership and control of your data, so that you can modify, update, or delete it as needed.
We currently meet the most stringent data protection laws across jurisdictions and are proactively reviewing every aspect of how we handle data and investing in operational measures to ensure that we continue to meet our customers’ requirements.
Today, Turnitin uses Model Contractual Clauses to meet varying, specific needs across the European Union (EU) for data privacy and protection. These are standardized contracts to certify that any data that is transferred out of the EU is adequately protected. This prevents our customers from having to request any additional authorization to use our service.
We are in good standing with all standards used to ensure that data is fully protected and are able to meet very specific requirements as needed. For example, in the EU (including in Germany, Austria, and Switzerland) we abide by Directive 95/46/EC to meet data protection requirements. The steps we take to maintain the integrity and confidentiality of personal data include:
- We strongly recommend that institutions provide notice to students that the Turnitin service, depending on the Turnitin solution used, involves data transfer to the United States, and we recommend that consent is obtained from the student as soon as possible;
- Universities are free to inspect or audit our services any time;
- All student work and any associated personal data is encrypted and kept secure at all times; and
- Students can keep their identity secret by using a pseudonym and by submitting papers in formats that contain little if any identifying metadata.
General Data Protection Regulation
The GDPR has legal effect in all EU Member States from 25 May 2018. The Data Protection Directive (Directive 95/46/EC) has been replaced by the GDPR. Although it is a regulation and immediately effective in all EU Member States, there are certain regulations within the GDPR that Member States will be able to legislate upon at a national level for specific reasons, therefore this policy may change accordingly from time to time.
The Legal Basis for Processing Personal Data
Turnitin primarily relies upon Article 6(1)(e) of the GDPR for its legal basis to process such data. Pursuant to this provision of GDPR, Turnitin relies upon the official authority of the Data Controller (the institution that is Turnitin’s customer) to process student data in such a way that anti-plagiarism checks may be made to satisfy the institution that the student’s work is their own.
Article 6(1)(f) of the GDPR also provides Turnitin with a lawful basis for processing. This is that it is in the legitimate interests of the Data Controller to process such data at their discretion.
Consent is not the primary basis for processing upon which Turnitin relies. However, the End-User Licence Agreement which Turnitin utilises with students will continue to be in place as a matter of best practice and transparency.
Key Aspects of the GDPR
The following are some notable aspects of the GDPR:
- The GDPR applies to all personal data processed;
- The GDPR makes it clear that when processing the personal data of EU nationals, data processors outside the EEA (including the US) must adhere to the GDPR and process only for lawful reasons;
- The GDPR requires much more accountability when processing personal data. Privacy must be embedded into everything (services, software, systems, and processes) by design and by default;
- Individuals’ rights have been strengthened; and
- To export data outside the EEA, EU Model Contractual Clauses will be favored, which Turnitin uses. Adherence to the EU/US and Swiss/US Privacy Shield is an EU recognised adequate measure for the legal transfer of data outside the EEA. Turnitin is Privacy Shield certified. See: www.privacyshield.gov
For more information on GDPR, visit go.turnitin.com/gdpr
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Acceptable Use Policy
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We respect and protect all personally identifiable information. For details please read our
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The parties agree that any and all disputes, claims, or controversies arising out of or relating to these terms and conditions that are not resolved by mutual agreement shall be submitted to final and binding arbitration before JAMS, or its successor, pursuant to the United States Arbitration Act, 9 U.S.C. Sec. 1 et seq. The arbitration shall take place in Alameda County, California, unless the parties otherwise agree in writing. Within fourteen (14) days thereafter, the arbitrator shall arrive at a final decision, which shall be reduced to writing, signed by the arbitrator, and mailed to each of the parties and their legal counsel. All decisions of the arbitrator shall be final, binding and conclusive on the parties and shall constitute the only method of resolving disputes or matters subject to arbitration pursuant to this the United States Arbitration Act, 9 U.S.C. Sec. 1 et seq. The arbitration shall take place in Alameda County, California, unless the parties otherwise agree in writing. Within fourteen (14) days thereafter, the arbitrator shall arrive at a final decision, which shall be reduced to writing, signed by the arbitrator, and mailed to each of the parties and their legal counsel. All decisions of the arbitrator shall be final, binding and conclusive on the parties and shall constitute the only method of resolving disputes or matters subject to arbitration pursuant to this Agreement; provided, however, nothing shall prohibit the parties from seeking injunctive relief and/or other equitable remedies in a court of competent jurisdiction. The arbitrator or a court of appropriate jurisdiction may issue a writ of execution to enforce the arbitrator's judgment. Judgment may be entered upon such a decision in accordance with applicable law in any court having jurisdiction thereof.
General Data Protection Regulation (GDPR)
This section applies where the GDPR applies to Turnitin’s processing of the personal data of data subjects in the EU. References to ‘Articles’ or ‘Chapters’ in this section are to the corresponding Articles or Chapters in the GDPR and italicised terms correspond to the definitions in the GDPR. This section is binding on Turnitin.
The controller hereby grants to Turnitin a general written authorisation to engage other processors in the provision of the services. Turnitin shall inform the controller of any intended changes to the processors allowing the controller the right to object to such changes.
The following information applies:
|Subject matter of the processing:||Processing of submissions (student or academic papers or proposed published texts) and their associated personal data pursuant to the purpose described below.|
|Duration of the processing:||Storage of the content of submissions is indefinite unless instructed otherwise by the controller.|
|Nature of the processing:||Collection, storage, retrieval, use (in the context of text matching functions).|
|Purpose of the processing:||To allow academic institutions / publishers to detect potential plagiarism in the academic / publishing sectors.|
|Type of personal data:||First name, surname, email address (academic), student ID number (if provided by controller), content.|
|Categories of data subjects:||Students, account administrators, instructors, authors.|
|Obligations of the controller:||The controller is obliged to comply with its general obligations under the GDPR, in particular to process the personal data it collects in accordance with Articles 5 and 6, and to comply with Articles 13, 14, 24, 30 and 32, and to comply with any actionable rights of the data subject.|
|Rights of the controller:||The controller may exercise its rights against the processor under the GDPR, in particular under Articles 28 and 32.|
Turnitin, as processor, confirms that it:
(a) processes the personal data only on documented instructions from the controller, including with regard to transfers of personal data to a third country or an international organisation, unless required to do so by Union or Member State law to which the processor is subject; in such a case, the processor shall inform the controller of that legal requirement before processing, unless that law prohibits such information on important grounds of public interest;
(b) ensures that persons authorised to process the personal data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
(c) takes all measures required pursuant to Article 32;
(d) respects the conditions referred to in paragraphs 2 and 4 of Article 28 for engaging another processor and shall, in the event that it engages another processor in the delivery of the service, ensure that the processor adheres to the same data protection obligations in accordance with paragraph 3 of Article 28;
(e) taking into account the nature of the processing, assists the controller by appropriate technical and organisational measures, insofar as this is possible, for the fulfilment of the controller's obligation to respond to requests for exercising the data subject's rights laid down in Chapter III;
(f) assists the controller in ensuring compliance with the obligations pursuant to Articles 32 to 36 taking into account the nature of processing and the information available to the processor;
(g) at the choice of the controller, deletes or returns all the personal data to the controller after the end of the provision of services relating to processing, and deletes existing copies unless Union or Member State law requires storage of the personal data; and
(h) makes available to the controller all information necessary to demonstrate compliance with the obligations laid down in Article 28 and allow for and contribute to audits, including inspections, conducted by the controller or another auditor mandated by the controller.
If you have questions, please email firstname.lastname@example.org.
We work with customers all over the world, and your trust is our top priority. We understand that data protection is essential for good customer service. At Turnitin, LLC, our objective is to operate transparently and consistently with the EU regulatory environment so that you, our valued customers, feel secure and in control.
Turnitin, LLC, which includes iThenticate, is fully committed to the following practices to protect your data:
- We will never sell your data.
- We will never use your data for targeted advertising.
- We secure your data with strong encryption and security best practices.
- We respect local privacy laws and work with legal experts to stay abreast of changes.
- When we collect data, we use it for a specific, stated purpose, to improve your experience and our service to you.
- If we need to send any of your data to a third party, such as a language translation service provider, we require a contractual agreement that they handle and secure your data with the same high level of protection and care that we deliver.
- We respect your right to retain ownership and control of your data, so that you can modify, update, or delete it as needed.
We currently meet the most stringent data protection laws across jurisdictions and are proactively reviewing every aspect of how we handle data and investing in operational measures to ensure that we continue to meet our customers’ requirements as data protection rules are reformed.
Today, Turnitin uses Model Clauses to meet varying, specific needs across the European Union (EU) for data privacy and protection. These are standardized contracts to certify that any data that is transferred out of the EU is duly protected. This prevents our customers from having to request any additional authorization to use our service.
We are in good standing with all standards used to ensure that data is fully protected and are able to meet very specific requirements as needed. For example, in Germany, Austria, and Switzerland, we abide by Directive 95/46/EC to meet data protection requirements. The steps we take to maintain the integrity and confidentiality of personal data include:
- We strongly recommend that institutions provide notice to students that the Turnitin service involves data transfer to the United States, and we recommend that consent is obtained from the student as soon as possible.
- Universities are free to inspect or audit our services any time.
- All student work and any associated personal information is encrypted and kept secure at all times.
- Students can keep their identity secret by using a pseudonym and by submitting papers in formats that contain little if any identifying metadata.
The 1995 laws that have been governing how personal data is protected in the EU were developed before smartphones and social media dominated our lives. For the past several years, negotiations have been underway to unify and simplify the laws and guidelines used to determine what obligations companies have to protect data crossing borders in the EU.
This year, the EU released the final version of the General Data Protection Regulation (GDPR), which will go into effect in 2018. Directive 95/46/EC will be replaced by Regulation (EU) 2016/679.
EU data protection timeline
1995: The Data Protection Directive creates the framework for personal data protection laws in each of the EU Member States.
2000: Safe Harbor decision to accommodate data transfers outside EU.
2012: The European Commission proposes a draft of the General Data Protection Regulation (GDPR).
2014: The European Parliament votes on amended GDPR draft.
2015: The European Council agrees on the final terms of GDPR. Safe Harbor is declared invalid.
2016: Final GDPR version published. EU-US Privacy Shield becomes the new mechanism for transatlantic data transfers.
2018: New regulations will go into effect.
Key differences in data protection rules
Turnitin fully and proactively supports the transition to simplified, more uniform application of the law as it applies to data protection in and outside of Europe. Following are some notable changes:
- The 1995 Directive had different interpretations for each member state, whereas the intent of the GDPR is to provide a regulatory tool that works at the EU level. So, the expectation is that there won’t be as many variations needed, and that data protection applies to all.
- There used to be ambiguity about what companies could do with personal data vs. anonymous identifiers. Germany doesn’t typically recognize anonymous data. New regulations apply to ALL data collected, with the intent being to make it harder to profile people.
- The GDPR makes it more clear that the U.S. must play by the EU’s rules and obtain valid, opt-in consent, using clear language, to use personal information.
- The GDPR requires much more accountability when processing information. Privacy must be embedded into everything (services, software, systems, and processes) by design and by default. The expectation is that the ability to erase data will be mandatory as well.
- Under the GDPR, public authorities and companies that depend on processing personal information will be required to hire a data protection officer (DPO), who will be responsible for making sure that legal data processes are upheld.
- Individuals’ rights are being strengthened. For example, cookie policies now should be much more clearly communicated and obvious.
- End users must be notified of data breaches within 72 hours. Under the 1995 Directive, there are no uniform rules applied across the EU.
- To export data, model clauses will be favored, which Turnitin uses. There is no real mention of Safe Harbor, but nothing prohibits it. Different model clauses can be used to meet specific privacy requirements.
- EU-US Privacy Shield
- Reform of EU Data Protection Rules
- European Commission – Protection of Personal Data
- Turnitin and GDPR
Turnitin agrees that students should own the copyright to their original work. A common misconception is that students relinquish their ownership rights when they submit papers to Turnitin. This simply isn’t true!
Students who submit papers to Turnitin retain the copyright to the work they created. A copy of submitted papers is retained in a Turnitin database archive to be compared with future submissions—a practice that helps protect and strengthen copyright ownership.
A U.S. District Court judge ruled that archiving student papers to assess the originality of newly-submitted papers constitutes a fair use under the U.S. Copyright Act, provides “a substantial public benefit" and helps protect the papers from being exploited by others. Read the summary judgement.
The summary judgment was unanimously affirmed by a U.S. Court of Appeals. Read the published decision.