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standard of judicial scrutiny than the compelling state interest test Courts apply the compelling state interest test when state action affects the exercise of a fundamental right, such as political speech Accordingly, using the rational basis test, courts have upheld government-mandated fingerprinting for employment and licensing purposes in connection with the taking of fingerprints for spouses of liquor licensees, male employees of alcoholic beverage wholesalers, taxi drivers, cabaret employees, bartenders, dealers in secondhand articles, all employees of member firms of national security exchanges registered with the Securities and Exchange Commission, and all individuals permitted unescorted access to nuclear power facilities For example, in Utility Workers Union of America v Nuclear Regulatory Commission, decided in 1987, a union representing some 5,170 utility workers in nuclear power plants challenged as unconstitutional that part of a newly enacted federal statute requiring that these workers be fingerprinted The Utility Workers Union claimed the fingerprinting requirement violated the workers Fourth Amendment and privacy rights The federal district court in the Southern District of New York disagreed and upheld the fingerprinting requirement Citing a long string of cases, the court noted that in noncriminal contexts, the judiciary has regularly upheld fingerprinting of employees 14 As for the union s constitutional right to privacy claim, the court quoted from a leading federal appellate court case, Iacobucci v City of Newport: Whatever the outer limits of the right to privacy, clearly it cannot be extended to apply to a procedure the Supreme Court regards as only minimally intrusive Enhanced protection has been held to apply only to such fundamental decisions as contraception and family living arrangements Fingerprints have not been held to merit the same level of constitutional concern15 Moreover, in applying the rational basis test, the federal district court noted Congressional concern over an incident of sabotage at a nuclear power plant in Virginia and concluded that using fingerprints to verify the identity and any existing criminal history of workers with access to vital areas or safeguards information is a rational method of clearing these workers Similarly, in a 1969 case involving a challenge to a New York state regulation requiring fingerprinting of all employees of national stock exchanges, a federal district court found that possession of an individual s fingerprints does not create an atmosphere of general surveillance or indicate that they will be used for.

Content Certificate, the Media ID, and the Binding Nonce This marries the content to an individual disc Once that is complete, the prepared video (the content), the Content Certificate for the content, and the associated PVT are sent to the recorder As every licensed Blu-ray player is required to validate the Content Certificate and the PVT prior to playback of the disc, this process assures the integrity of each individual AACS protected recordable disc The decryption process for recordable discs is akin to that for prerecorded discs Yet, there are a few differences Because recordable discs do not have a BD-ROM Mark, the Volume ID cannot be stored on the disc in the typical fashion However, as the Prepared Video Token is calculated based on the Volume ID and the Content Certificate ID, the playback device can easily extract the requisite information from the PVT for the decryption process

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Utility Workers Union of America AFL-CIO v Nuclear Regulatory Commission, 664 FSupp 136, 138-139 (SDNY 1987) The union directed its challenge to Section 606 of the Omnibus Diplomatic Security and Anti-Terrorism Act of 1986, codified as section 149 of the Atomic Energy Act of 1954, 42 USC 2169 (1986) 10 CFR 7357 implements the statute Utility Workers Union of America, 139 (quoting Iacobucci v City of Newport, 785 F2d 1357-58)

Watermarking is a process that embeds information within the content yet remains transparent to the enduser, thus making it difficult to be removed or to be easily changed If a watermark is present, certain digital video frames and/or segments of audio are permanently marked with noise that is supposed to be undetectable by human eyes or ears In practice, there is considerable debate about how undetectable watermarks really are To reduce the impact of watermarks on the user experience, watermark intensity can be adjusted based on the content itself As an example, for a very dynamic piece of content, the amount of watermarking could be reduced to decrease the possible impact, whereas for a more static scene, the amount could be increased The watermark is essentially a digital signature that can be recognized by recording and playback equipment Regardless of the digital or analog transformation of the content, the watermark signature remains embedded Watermarking is not really protecting the content, but it identifies the status of the content Using watermarking in conjunction with a content protection system usually carries Content Management Information (CMI) data Whenever the content is played back, a compliant device recognizes the CMI carried in the watermark and abides by its constraints Obviously, this only works if the device implements the watermark detection To encourage device manufacturers to do so, a requirement is included and defined in other encryption technology license agreements If a manufacturer wants to get the keys and the secrets to play encrypted content, they must sign a license agreement which mandates the implementation of the watermark detection AACS exemplifies such a scenario in which a manufacturer has to implement a specific watermarking technology in order to get access to the keys necessary for encryption In this case, all Blu-ray Disc players must implement the circuitry to recognize the watermarking technology developed by Verance (and originally used by DVD-Audio) Another way to use watermarks is for forensic purposes Forensic marking is used to trace the path of legitimate content If unauthorized copies of the content are created, the forensic mark will help identify the source of the piracy As an example, the forensic mark could help identify which source tape was used to create the pirated copy In the case of Blu-ray,.

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Thomson s NexGuard technology is closely integrated with the BD+ protection system to provide a more active solution NexGuard embeds invisible information into the video output Then, if content were to be pirated, it could be traced back to the player used, which would allow future titles to contain updated BD+ security code to fix the security hole

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