Multi-level Encryption Patent Survives 101 Challenge in District Court – Lexology (registration)

Introduction

On May 23, 2017, the District Court for the Eastern District of Virginia (District Court) denied a motion for summary judgment that the patent claims asserted in a lawsuit brought by TecSec, Inc. (TecSec) are invalid under 35 U.S.C. 101.[1]

In the lawsuit, TecSec accused Adobe Systems, Inc. (Adobe) of infringing four related patents[2] directed to a multi-level encryption system that allows encrypted objects [to] be nested within other [encrypted] objects . . . resulting in multiple layers of encryption.[3] Representative Claim 1 from the 702 Patent is reproduced below:

Click here to view the image.

1. A method for providing multi-level multimedia security in a data network, comprising the steps of:

A) accessing an object-oriented key manager;

B) selecting an object to encrypt;

C) selecting a label for the object;

D) selecting an encryption algorithm;

E) encrypting the object according to the encryption algorithm;

F) labelling the encrypted object;

G) reading the object label;

H) determining access authorization based on the object label; and

I) decrypting the object if access authorization is granted.

Patent Eligibility Inquiry

The eligibility inquiry under 35 U.S.C. 101 proceeds in two steps.[4] First, the court determines whether the patent claim at issue is directed to one of the patent-ineligible concepts (e.g., abstract idea, law of nature, or natural phenomenon) (step one).[5] If the claim is not directed to a patent-ineligible concept, the inquiry ends.[6] Otherwise, the court determines whether the claim includes any additional elements that transform the nature of the claim into a patent-eligible application (step two).[7] If a claim is found to be directed to a patent-ineligible concept in step one and also lack any additional elements that transform the nature of the claim into a patent-eligible application in step two, the claim is ineligible for patent protection under 101.[8]

Arguments before the District Court

Adobe argued that the claims in the asserted patents are directed to the abstract idea of managing access to objects using multiple levels of encryption.[9] According to Adobe, Claim 1 of the 702 patent provides no guidance at all as to how to encrypt an object, how to nest objects, or any specific type of object that the process may operate on and is thus abstract because it provides no restriction on how the result is accomplished.[10]

TecSec contended that Adobe failed to properly perform the step one analysis by overgeneralizing the claims, failing to tie the identification of the abstract idea to the claim language at issue, and oversimplifying the claims and downplaying the inventions benefits.[11] Further, TecSec argued that there is no risk of preemption because there are other ways to manage access to objects using multiple levels of encryption that do not require an [object-oriented key manager] component along with the recited encryption and labelling steps.[12]

District Courts Discussion

Siding with TecSec, the District Court found that the claims in the asserted patents are not directed to an abstract idea, law of nature, or natural phenomenon.[13] According to the District Court, the patent claims provide a solution to a computer-centric problem that would not exist but for the ubiquity of computer technology.[14] Rejecting Adobes contention that the claims are reducible to putting a sealed envelope (single-level encryption) into a second sealed envelope (multi-level encryption) for extra security, the District Court stated that the claims provide a specific solution that allows multiple users in multiple locations [to access] information at different security levels from a central repository.[15]

Further, the District Court noted that the asserted patents preempt systems which make use of the specific method of an object-oriented key manager without foreclos[ing] all forms of multi-level security.[16] Having determined that the patent claims are not directed to an abstract idea, the District Court ended the patent-eligibility analysis and denied Adobes motion for summary judgment.[17]

Takeaways

This case illustrates that (i) a solution that is necessarily rooted in computer technology as illustrated in DDR[18] and (ii) evidence of no preemption as illustrated in McRO[19] both continue to play an important role in helping patent owners survive 101 challenges. When drafting claims, patent applicants should carefully consider how the claims solve a computer-specific problem without preempting all possible ways of solving such a problem.

On the other hand, patent challengers should emphasize how the problem solved by the claims is a conventional one, and not one that exists only because of the Internet or the computer technology. Additionally, patent challengers should point out why the claims impermissibly preempt an entire field of ideas. Here, Adobe presumably had some difficulty arguing that TecSecs claims cover all types of multi-level encryption because Adobe also had to argue that its multi-level encryption system did not infringe the asserted claims. In such cases, patent challengers may want to, if possible, formulate the abstract idea in a way that does not include their own products.

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Quantum satellites demonstrate teleportation and encryption – physicsworld.com

Physicists in China have achieved the first quantum teleportation from Earth to a satellite, while their counterparts in Japan are the first to use a microsatellite for quantum communications. Both achievements suggest that practical satellite-based quantum communications could soon be a reality.

Jian-Wei Pan of the University of Science and Technology of China in Hefei and colleagues used China's $100m Quantum Experiments at Space Scale (QUESS) satellite to receive a quantum-teleported state. This was done over a distance of 1400km from a high-altitude (5100m) ground station in Tibet to QUESS. This is more than 10 times further than the 100km or so possible by sending photons through optical fibres or through free space between ground-based stations.

Described in a preprint on arXiv, the process involves creating photons that are quantum-mechanically entangled and then transmitting them to QUESS. Last month, Pan and colleagues reported the distribution of quantum entanglement over 1200km using QUESS.

Meanwhile, Masahide Sasaki and colleagues at the National Institute of Information and Communications Technology in Japan have shown that quantum information can be transmitted to Earth from a 5.9kg photon source called SOTA which is on board a 48kg Japanese microsatellite called SOCRATES.

Writing in Nature Photonics, Sasaki's team reports that they were able to receive and process the information at a ground station in Japan using a quantum key distribution (QKD) protocol. QKD is uses principles of quantum mechanics to ensure that two parties can share an encryption key secure in the knowledge that it has not been intercepted by a third party.

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Quantum satellites demonstrate teleportation and encryption - physicsworld.com

The New Open Source Business Model: Trading Code for Personal Data – The VAR Guy

How do companies make money with open source software? Increasingly, the answer is that they use open source programs to collect personal information from users. Here's how this new open source business strategy is changing the channel.

For most of the thirty-three year history of free and open source software, companies that developed open code relied on a set of conventional business models. They revolved around strategies like "freemium" pricing, redistributing of open source software through channel partnerships, creating foundations and selling support services.

These are the strategies that sustained old-guard open source companies like Red Hat and Canonical. They allowed them to generate revenue from software that they gave away for free.

There's a new generation of companies that are investing in open source, and they're migrating toward a new business model. They support open source development and give away software, then use that software to collect data valuable from users.

Take Google, for example. Google is a lead contributor to several important open source projects, from the Chromium Web browser to Kubernetes, a container orchestrator.

While not all of these open source programs directly feed Google's data-collection initiatives, some of them (like Chromium, the basis for Google's Chrome browser) do. And in general, there is little arguing that data collection is at the heart of Google's business strategy. Much of the money that Google infuses into the open source ecosystem to support development is paid for with users' private data.

Google's not alone. Baidu, Google's Chinese twin, is now doing something very similar. The search and cloud hosting company is releasing an open source driverless car platform with the goal of advancing data collection.

Even Canonical -- which for most of its history has stuck with traditional open source revenue-generation strategies like selling support services -- has experimented with a program that collects users' data inside Ubuntu Linux. The company abandoned that strategy last year, but it's evidence all the same of the idea that personal data can make freely redistributed software profitable.

It's a safe bet that selling support services and other conventional business models will remain central to the open source world going forward. It's perhaps only very large companies that stand to benefit from trading open code for users' data.

But the latter trend is here to stay, too -- which means open source will now have a new cost for many of its users.

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Eli Lake: Now Julian Assange cares about privacy? – TwinCities.com-Pioneer Press

Julian Assange has had it with CNN. Since July 4, the founder of WikiLeaks has tweeted multiple times in support of Donald Trumps latest battle with the media: Gif-Gate.

Like many controversies in Washington these days, this one involves a tweet. Last week Trump tweeted a gif that portrayed him putting fake wrestling moves on a body with the CNN logo for its head.

Assanges interest in this is all about CNNs response. On July 5, the networks master internet sleuth, Andrew Kaczynski, tracked down the Reddit user who came up with the Trump-CNN wrestling video. But because the maker apologized on the forum, CNN decided not to name him. That said, CNN reserves the right to publish his identity should any of that change.

That last sentence has inspired some pearl clutching among Trumps supporters. The alt-right has accused CNN of blackmailing some poor Reddit user who just likes trolling the media.

Now it should go without saying that this is a very thin reed. According to CNN, the Reddit user voluntarily apologized for the gif and other memes that were racist and anti-Semitic. Also, CNN never threatened to disclose reams of private information on the Reddit user, just his name. But such is the nature of these social media kerfuffles in the age of Trump. Both sides try to maximize grievance. CNN accuses the president of inciting violence. Trumps supporters accuse CNN of mafia tactics.

Whats interesting here is how Assange responded. When Trump goes low CNN goes lower: threatens to dox artist behind CNN head video if he makes fun of them again, he tweeted, referring to the online tactic of posting someones personal details on the web. For two days, Assange continued along these lines, speculating that CNN may have even violated the law in censoring this artist.

Doxxing, as its known, usually applies to an online persona who wishes to remain anonymous. But the concept is closely related to the kind of thing Assange himself has been doing since he founded WikiLeaks, publishing the private communications of public figures.

Methinks the WikiLeaker doth protest too much. After all, Assanges organization posted the personal emails of John Podesta, Neera Tanden and other Democrats. And while some of those emails had legitimate news value, most of them didnt. Did the public really have a right to know Podestas risotto recipe?

The hacked emails WikiLeaks disclosed last year are different from the State Department cables provided to the organization by Chelsea Manning. While some of those cables endangered U.S. government sources in dangerous places, government documents in our republic belong to the people. The same cannot be said for the personal emails of Democratic operatives, who are exercising their right to political participation.

Assange is hardly alone as a participant in this new threat to online privacy. I wrote articles based on the hacked emails WikiLeaks published, as have many other journalists. Anonymous, the online hacker group, has doxxed people before as well. But Assange, as an advocate for radical transparency, has done much to usher in this new era.

And this new era should trouble us. In the 20th century, the state was the greatest threat to the individuals privacy. But in the internet era, where so much of our lives is online, this threat has been democratized. Individuals today pose a threat to privacy in a way we used to think was the sole province of the NSA and FBI. At any moment, an email, text or browsing history could be hacked and posted on the web for all to see. In an instant, our private lives can become public.

More recently, foreign governments have become threats to our privacy. Four U.S. intelligence agencies assess that Russia orchestrated a campaign to advantage Trump in the election through hacking and leaking the emails of leading Democrats. The Russians used this tactic in 2014 in combination with their special forces, when RT, the Kremlin-funded network, would post audio recordings of U.S. diplomats.

We are already starting to see imitators. Wall Street Journal reporter Jay Solomon lost his job because emails and texts were leaked to the Associated Press that made it appear that he sought a business relationship with one of his sources. Solomon has said he never entered into such a relationship. On the eve of the Gulf crisis over Qatar, the Emirati ambassador to Washington had his Hotmail account hacked and his emails posted on the web.

None of this is to say that there is not news value to some of these disclosures. Its always a balance. The problem is that people like Assange never cared about this balance until now. For years he believed the publics right to know outweighed the privacy rights of his victims. Today he argues the privacy of an online troll outweighs the publics right to know who exactly is making the memes the president tweets in his war against CNN.

Eli Lake is a Bloomberg View columnist. He was the senior national security correspondent for the Daily Beast and covered national security and intelligence for the Washington Times, the New York Sun and UPI.

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As Investors Turn to Cryptocurrencies, Gold Suffers – Investopedia

Investors looking to make an investment in an exciting new area are increasingly turning to cryptocurrencies. It's no wonder why: Bitcoin, the leading digital currency by market capitalization, has gained nearly 200% since the beginning of 2017. Ethereum, the next biggest currency, has gained more than 3,000% over the same period. (See also: Why Ethereum Prices Reached Record Highs.)

There are new currencies added to the list every month, and a sharp uptick in the number of initial coin offerings, or ICOs, means there are many other new startups and ventures related to the burgeoning crypto industry as well. As investors move to place their assets in the digital realm, demand in other areas seems to be drying up. In fact, gold may have been the most heavily impacted by the recent gains in the cryptocurrency world.

Cryptocurrency supply has actually dropped fairly significantly in recent months, according to a report by Business Insider. The rate of Bitcoins added to the market has more than halved in the past 12 months, from a rate of 9.3% to 4.4%.

If mining continues to slow down, Bitcoin won't reach its theoretical maximum number of 21 million Bitcoins until the year 2045, if not later. As supply has dwindled, prices have continued to rise.

It seems that the opposite may be true for gold. Gold production has climbed significantly since 2009, now sitting at 3,100 metric tons. This constitutes a record high level of production of the precious metal.

Tom Lee, managing partner and head of research for Fundstrat Global Advisors, indicated in a letter to clients that "cryptocurrencies are cannibalizing demand for gold. Bitcoin is arguably becoming a scarcer store of value. Investors need to identify strategies to leverage this potential rise in cryptocurrencies."

What could the future look like for the prices of Bitcoin and gold? Fundstrat's research indicates that prices for the cryptocurrency could climb by about eight times over the next five years, with Bitcoin prices reaching $20,000 during that time.

If the scenario turns out more bullish, Fundstrat believes Bitcoin could surge to more than $55,000 by 2022. What would happen to gold during that period? "Our model shows gold's value being relatively static against a rise in Bitcoin," Lee suggested.

Lee believes that if central banks begin to invest in Bitcoin and other digital currencies, that could speed up the process by which Bitcoin takes the place of gold in the international markets.

"Already central banks have looked into this possibility. In our view, this is a game changer, enhancing the legitimacy of the currency," he wrote. Of course, there are also analysts who believe a potential crash or bubble collapse is imminent in the cryptocurrency space, so only time will tell what will happen. (See also: Goldman Sachs Takes Bearish View on Bitcoin.)

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As Investors Turn to Cryptocurrencies, Gold Suffers - Investopedia

Is Solar-Powered Cryptocurrency Mining the Next Big Thing … – Investopedia

Cryptocurrency mining is a difficult and costly activity. Miners must pay to build rigs capable of vast amounts of processing power, and then the rigs themselves must be powered with large quantities of electricity. It's all a careful balance between how much the operation costs and how much profit it is able to generate. (See also: What Happens to Bitcoin After All 21 Million are Mined?)

With mining operations for Ethereum, one of the leading digital currencies on the market today, taking up the same share of electricity as that of a small country, miners have to be careful that they aren't spending more than they are making. Because of that, some mining operations have begun to look to solar-powered rigs, set up in the desert, in order to reduce mining costs and make the largest profit possible. (See also: Chinese Investment in Bitcoin Mining is Enormous.)

Mining operations with the tools and resources to be able to set up solar-powered rigs in the desert are finding that it is a good investment. Once you have paid for the solar panel system itself, the cost of mining is virtually free. Getting rid of a hefty electric bill which typically weighs down mining operations leaves more room for profit.

The Merkle recently documented a mining operation focused on Bitcoin in this manner. The setup has been running successfully for almost a year and currently uses 25 separate computing rigs. The process has been so profitable, in fact, that the miner running the operation plans to increase the number of computers to 1,000 this fall.

In the case of this particular desert miner, the individual mining rigs cost about $8,000. This cost has included all solar panels, power controls, batteries, and the Antminer S9 ASIC processor. When fully operational, each miner brings in a profit of about $18 per day.

Of course, a cheap mining operation is only part of the equation. In order for miners to make a tidy profit, the price of the cryptocurrencies they are generating must remain high.

In the case of the mining operation in question, Merkle suggests that Bitcoin prices must stay above $2,000 in order for the operation to be profitable. Considering that the price of most cryptocurrencies is highly volatile, and that drops of 205 or more have occurred in many individual days, this keeps a certain element of risk present in any mining operation.

It seems likely that more and more miners will turn to areas in which renewable energy is easily accessed. Iceland has already become a popular destination for Bitcoin miners thanks to its fast, virtually limitless internet. Miners looking to move to the desert should be cautious for other reasons, though: mining in the heat can cause rigs to break down more easily.

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Is Solar-Powered Cryptocurrency Mining the Next Big Thing ... - Investopedia

How Cryptocurrencies Really Work – Popular Mechanics

Money is changing. Just a few years ago saw the invention of Bitcoin, the world's first cryptocurrency, and today there are thousands of these cryptocurrencies being used by people all around the world including variants like Ethereum and Litecoin.

But what is a cryptocurrency? How does it work? There has been no shortage of explainers during Bitcoin's rise, but this new one from Youtuber 3Blue1Brown explains the whole process from the bottom up to give you an understanding of cryptocurrency as if you had invented it yourself:

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In a typical currency, such as U.S. dollars, transactions are handled either through exchanging cash or via electronic transfers. These electronic transfers are managed by large banks that we trust to keep our money safe and our transactions honest.

To create a cryptocurrency like Bitcoin, we first have to take the responsibility of keeping track of transactions away from banks and manage it ourselves. The first step is to create a ledger of everyone's payments to everyone else. This ledger will keep track of who owes money to who and records everyone's payments to each other.

The next step is to prevent people from cheating by adding transactions that one party much not agree on. One easy way to solve that problem is by requiring both people in the transaction to sign off on the payment. Each participant can add their "digital signature" using public/private key encryption so that everyone knows the transaction is legitimate.

But there's one last problem: Who owns the ledger? In a traditional currency system a bank would maintain it, but we're supposed to be building a currency that doesn't need banks. Instead, everyone has their own ledger, and all transactions are made public so everyone updates their ledger at the same time.

In this way, everyone can safely exchange money without worrying about whether the people handling it are trustworthy. Instead of trusting a central bank or a government to insure our transactions, we can simply use cryptography to force everyone to play fair. While cryptocurrencies are still in the early stages, in a few years they might be the preferred way to make payments all over the world.

Source: 3Blue1Brown

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How Cryptocurrencies Really Work - Popular Mechanics

Cryptocurrency ATB Coin Offers Investors a Crypto-Lottery for the $20.000 Grand Prize. Only 2 Days Left! – CryptoCoinsNews

This is a sponsored story. CCN does not endorse, nor is responsible for any material included below and isnt responsible for any damages or losses connected with any products or services mentioned in the material below. CCN urges readers to conduct their own research with due diligence into the company, product or service mentioned below.

In less than 2 days, we will congratulate ATB Coin Crypto-Lottery winners. The Grand Prize fund of $20.000 is to be shared between 5 randomly chosen investors. The process and the results of lottery will be announced on a special page on ATB Coin website. The lottery will be held at 6 p.m. on July 11th for registered users who invest a minimum 200 ATB. For each 200 ATB, the investor gets one lottery ticket. The larger the amount invested, the greater the chance to win.

Prize funds are:

During the ICO, which still remains open today, the newly introduced cryptocurrency ATB Coin has already attracted 1700+ investors. Such an interest in this cryptocurrency is due to the numerous advantages of ATB Coin that is going to be the most secure, fast, and flexible, according to analysts. The strongest features of ATB Coin allow it to stand ahead of competition:

Being the one cryptocurrency combining the newest technologies, ATB Coin has all chances to overcome well-known inefficiencies within government central banks and other cryptocurrencies. Join ATB Coin, invest now in cryptocurrency of the future!

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REPORT: Manafort Coordinated With Wikileaks To Dump Clinton Emails – IR.net

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Posted By: Arthur Jones July 11, 2017

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As if these last two days hadntcaused the White House to go into panic mode enough, a new report from former White House Staffer, Claude Taylor, indicates that Paul Manaforts ties to Wikileaks may have been much tighter than initially thought. Manafort has had his name come up multiple times when discussing possible Trump campaign collusion with Russia, including just this past weekend when a New York Times Report indicated that he, along with Donald Trump Jr. and Jared Kushnermetwith a Russian attorney to discuss damaging information about the DNC and Clinton. If Taylors sources are accurate, then the depth of Manaforts involvement, in what seems to certainly appear to be collusion, may have expanded quite a bit.

Taylor, who claims to be in contact with an individual close to the Mueller investigation, just tweeted the following bombshell:

Breaking: Source with knowledge of investigation says there is solid proof that Manafort coordinated with Wikileaks in dumping HRC emails.

We assume that the emails that Taylors source is referring to are the John Podesta emails that leaked in November of last year. These emails happened to include messagesto andfrom Clinton herself. Manafort, who served as Trumps campaign manager for several months between May 19, 2016 and August 18, 2016, was never rumored to have any communication with Wikileaks, however another Trump campaign associate, Roger Stone, admitted to not only having a relationship with Wikileaks and Julian Assange, but also claimed to have communicated with Guccifer 2.0, the hacker who allegedly stole the DNC emails.

Considering that Roger Stone had supposedly convinced Donald Trump to hire Manafort to be his campaign manager, it would not seem out of the question for Manafort to have communicated and coordinated the release of such emails via Wikileaks.

When you combine this story with the fact that a GOP operative named Peter W. Smith claimed to have been working with those in the Trump campaign to access the missing Clinton emails from Russian hackers, the story seems to certainly have legs.

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REPORT: Manafort Coordinated With Wikileaks To Dump Clinton Emails - IR.net

Chelsea Manning: ‘The Wealthy’ Don’t Pay Taxes, So We Must Force Them To, or Something – Townhall

Between attacking President Trump's important and robust (if somewhat hypocritical) defense of Western civilization in Warsaw, and defending Linda Sarsour's call for 'jihad' against the Trump administration (coupled with a dangerously wrong-headed anti-assimilation jeremiad), many on the hard Left continue to showcase seriously misaligned moral compasses. The degree to which elements of the Democratic base have embraced and celebrated Chelsea Manning is further evidence of this phenomenon. Yesterday, Manning tweeted a stupefyingly ignorant pronouncement that generated thousands of likes and shares on social media:

Where to begin? Let's go point by point:

(1) Taxation is a sharing of responsibility in a number of ways, though it's quite difficult to swallow a lecture on shared civic responsibility from someone who was convicted and sentenced to a lengthy prison sentence for violating his oath and breaking the law when he leaked (Manning identified as a man at the time of his treacherous acts) a massive trove of national security secrets in a profoundly irresponsible manner. A refresher from David French:

Bradley Manning was no ordinary leaker. When he dumped hundreds of thousands of military and diplomatic secrets into the public domain, he violated every single tenet of the warrior ethos. He abandoned the mission. He accepted defeat and, through his data dumps, worked to facilitate it. He quit on his comrades, acting with utter, callous disregard for their lives. His message to his unit and to his nation was clear: He would disobey lawful orders and risk killing his comrades to, in his words, stimulate worldwide discussions, debates, and reforms...In such a case, commanders have a sacred obligation to protect their soldiers. Its a matter of maintaining a bond with the men and women they lead. There can be no tolerance of true betrayal, and the military to its credit sought a severe sentence for Manning, attempting to make the punishment fit his crime. It fought for life imprisonment, and ultimately obtained a 35-year sentence that itself was an act of unreasonable mercy.

Incidentally, how many of the liberals who have been in high dudgeon for months over Wikileaks' role in helping Russia interfere in the US election were unperturbed by Manning's partnership with Julian Assange to expose American secrets? It's almost as if reflexive partisans on both sides of the ideological divide determine their views on Wikileaks based upon the immediate political implications of the material it releases.

(2) Taxation is also a form of legal theft, wherein -- despite Harry Reid's bizarre spin -- the government coercively confiscates a portion of its citizens' income. This view is not held "only" by the wealthy. Some of the most fanatical libertarians and objectivists in America are by no means well-to-do, and some of the richest people on the planet are enthusiastically pro-taxation statists. Google a group of insufferably self-righteous left-wingers who call themselves the "patriotic millionaires," if you're so inclined.

(3) "They don't pay taxes" is just a much dumber version of the standard "fair share" argument liberals make in support of imposing an ever-heavier tax burden upon high income earners and businesses. It's risibly false to assert that the wealthy don't pay taxes, and therefore need to be "made" to do so. The rich not only pay taxes, they pay more than their fair share of them. From my myth-busting post on this subject, published this past spring:

The top one percent of US wage-earners make less than one-fifth of the total income in the United States, yet pay close to 40 percent of all federal income taxes, and more than one-quarter of all federal taxes...The top 20 percent of US wage-earners ("the rich," broadly defined), make just over half of total US income, yet pay close to 90 percent of all federal income taxes, and approximately 70 percent of the total federal tax bill. It is flat-out wrong to say that the wealthy aren't paying their fair share; they're statistically paying a disproportionately high percentage of federal taxes.

To frame this in terms that Chelsea Manning might understand, because "the wealthy" pay roughly 70 percent of the overall federal tax bill, this group proportionally provided about $35,000 of the estimated $50,000 gender-reassignment treatment and surgery (nearly the median household income in America) she received courtesy of taxpayers while incarcerated for betraying her country. As an expression of her gratitude, Manning now demands that the government -- whose laws she flagrantly, willfully and unapologetically broke, only to be released by President Obama -- forcibly extract more money from law-abiding taxpayers, as lefties cheer her on. It's enough to rouse an exasperated writer to devote an entire essay to refuting a stupid tweet from a minor, ignominious celebrity. Sometimes, Donald Trump's victory in middle America isn't a mystery that's especially difficult to untangle.

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Chelsea Manning: 'The Wealthy' Don't Pay Taxes, So We Must Force Them To, or Something - Townhall