Always get the police fingerprint results

CILIP Institute and Journal

by Detlef Nogala

At the end of our century, DNA analysis has assumed the status that the ordinary fingerprint had at the end of the previous one. The police seem to be holding an instrument in their hands that not only accelerates the investigation and transfer of criminals and makes them more "judicially stable", but also allows clarification to become promising, especially in difficult cases where there is a lack of specific suspects. This gain in police intelligence is countered by the administrative and civil law costs of increasingly frequent mass search tests and forensic DNA databases.

The biological facts on which the genetic fingerprint ’is based are almost part of the general knowledge of the average newspaper reader: For us - like all living beings - the blueprint of our cells and their functional structure are inscribed in the respective deoxyribonucleic acid (DNA). The DNA has to be imagined as a twisted, rope ladder-like concatenation of four different amino bases. However, this strand does not consist solely of ‘blueprints’ for the respective cell structure, but for the most part (approx. 90%) of sections which, from today's point of view, are regarded as Sicht non-coding ’, i.e. without specific genetic information. In these blind ’sections between the genes, certain combinations of the amino bases are repeated in a characteristic way - differently depending on the individual. If it is now possible to extract these typical sections from the DNA strand, one can use certain detection methods to quantify how much of it is present in one individual in contrast to others - based on every cell in the body that carries hereditary information. In 1985, the working group around the English molecular biologist Alec J. Jeffrey 'invented' such a detection method and thus the 'genetic fingerprint' as a means of identification: It was now possible to say with a very high degree of probability which traces (containing body cells) 'belonged' to which individual . It is true that serological methods were used previously in forensics, with the help of which certain statements about the probability of involvement in the crime could be made from traces of body fluids. But with the discovery that in addition to the ‘classic’ fingerprint, each body cell in principle individualizes ’its carrier (apart from identical twins), a new era of identification technology that could be used by the police had dawned. Drops of blood, tiny scraps of skin, saliva (on cigarette butts), genital secretions or hair found at the scene of the crime were from now on (under favorable conditions) important evidence or even potential wanted drugs.

The euphoria about this discovery could hardly be stopped at first, and some experts already saw times approaching when a perpetrator who did not succeed in leaving the crime scene biologically `` trace '' would settle down on the spot and respond to the arrival of the Police could wait. [1] This optimism was based, among other things, on claims by companies such as ec Lifecode ’and Cellmark Diagnostics’, which set out to commercialize the genetic fingerprint ’shortly after Jeffrey's discovery. With the new method, it is said, one can clearly identify an individual from the entire world population. Renowned specialists in the USA at that time were of a completely different opinion with regard to validity and reliability. [2] The scientific debate about how reliable the genetic fingerprint is was led with the participation of the FBI with methods that were not always entirely flawless, [3] but finally ended with the universal recognition of the originally used, elaborate RFLP (restriction fragment length polymorphism) . [4] However, the fundamental confirmation of the suitability of the ‘genetic fingerprint’ for differentiating and identifying people in no way meant that this procedure would lead to a correct or comprehensible result in every case, i.e. would endure in criminal proceedings. This bitter experience, for example, went to the police department and the Los Angeles prosecutor's office in the trial of O.J. Simpson do: Though DNA analysis of crime scene leads weighed heavily on the celebrity, the defense succeeded in presenting these clues as meaningless - as tainted, as the result of a conspiracy. There were indeed such conspiracies. The chief serologist of the crime laboratory of the West Virginia State Police was able to prove that between 1979 and 1989 he had manipulated test results of DNA analyzes and brought them to court as an expert to the disadvantage of the accused. [5]
Since DNA analysis has been scientifically recognized, the dispute has turned more to the correct standardization and error-free execution of the investigation - from the recording of traces to the laboratory processes to the presentation of the results in the judicial reports themselves. [6] This point is all the more so more important because in the meantime the original RFLP process has been largely replaced by the so-called PCR process (polymerase chain reaction). [7] Here, parts of the DNA are artificially 'amplified', i.e. multiplied. This means that even the smallest amounts of DNA can be processed for the genetic fingerprint. In this way one could prove that people spoke to one another with a slightly damp pronunciation. [8] Australian criminologists even claim the art of being able to create DNA analyzes of ‘traditional’ fingerprints. With the current state of the art it is assumed that in extreme cases a single intact body cell is sufficient for a DNA analysis. And even this is no longer absolutely necessary if what is known as mitochondrial DNA (a type of DNA fragment outside the cell nucleus) can be used instead. [10] However, compared to the initial method, one loses statistical discriminatory power, and the method is much more sensitive to conscious or accidental contamination of the trace material with foreign DNA. [11] The objections to DNA analysis at the level of criminal proceedings have therefore shifted from fundamental questioning to the problem of the reliability and traceability of trace treatment from the crime scene to the laboratory. [12]
Apart from the conventional fingerprint, there is hardly any other criminal evidence technique that has spread as rapidly and with as much echo in the public as the "genetic fingerprint".

DNA analyzes in criminal investigations

The rapid international spread of the genetic fingerprint in police crime laboratories can be explained first of all by the fact that the police wanted to make the enormous identification potential of the new procedure available as quickly as possible. Initially, only specialized laboratories could carry out the analyzes, and the process was very expensive. But the success stories of solved cases did not fail to appear. One could successfully convict blackmailers by subjecting saliva residues on the back of postage stamps to a DNA test; [13] Saliva residues on discarded cigarette butts are said to have led to the Falcone attackers.
Completely new horizons opened up, especially with regard to the investigation of sexual and violent crimes. From the practice of the BKA, Schmitter vividly describes the benefits of DNA analysis in clearing up various cases, whereby he attaches particular importance to the finding that suspects could also be exonerated with the help of the new procedure. [14] While skeptical lawyers already saw the "genetic inquisition" approaching us with the DNA analysis at the beginning of the 90s, [15] clarified colleagues set about demanding the use of their clients in criminal proceedings. Although the police use of the genetic fingerprint logically focuses on the conviction of suspects, the relief function cannot be completely ignored in this specific case. This aspect becomes particularly clear in a study by the US Department of Justice, in which 28 cases are documented in which persons sentenced to partially life imprisonment could be excluded as perpetrators through subsequent DNA tests. [16]
A significant part of the public acceptance of the ‘genetic fingerprint’ is due to the role that this procedure has been assigned in the investigation of sexual and other violent crimes. Against the real feelings of insecurity and revenge that such acts - even if often staged in the media - generally trigger, doubts in principle of criminal procedure or data protection law have just as little been able to assert themselves as warnings about the potentially threatening risks of an over-exploring the human genome. [17] The DNA analysis is presented in the public and in the political discussion above all as an efficient instrument for the prevention of the most serious crimes and in this capacity it has also been accepted by the data protection officers. [18]
In police practice, however, there is pressure to clarify in all departments, and so one is moving towards using the ‘genetic fingerprint’, not least because of the now more cost-effective laboratory process, for investigations into lighter crimes. In Göttingen, for example, the police wanted to match skin particles from a glove that was found near a window pane, which was probably thrown in for political motives, with that of a young woman who was suspected of having committed a crime. [19] The British police took DNA samples from 911 suspects in one fell swoop in 1995 in the course of ‘Operation Bumblebee’ during a large-scale raid against suspected burglars. [20] In the area of ​​burglary in particular, the ‘genetic fingerprint’ is seen as a promising educational tool in the German police debate. The Rhineland-Palatinate State Criminal Police Office set up a DNA database as early as 1996, which initially served primarily to investigate serial break-ins by "Eastern European criminals" and was later expanded to include other serial offenses in the area of ​​property crime. Case traces of capital and sexual crimes, which are now also stored, have not played a significant role so far. [21] The Bund Deutscher Kriminalbeamter is now also calling for the "genetic fingerprint" to be routinely used to investigate break-ins. [22]

DNA analytical mass searches

Because of the long and complex procedures and the high costs, in the first few years the genetic fingerprint was primarily a means of comparing their DNA profile with the crime scene evidence in cases in which there were specific suspects. However, it had become clear early on that DNA analysis could not only serve as an investigative tool, but also as a new kind of tool under certain circumstances Wanted items was useful. In those cases where a genetic fingerprint could be obtained from crime scene traces, but the circle of potential suspects could not be narrowed down to a few people. In 1986/1987, a good year after Jeffrey's publication, a "mass genetic search" was carried out for the first time in the English town of Enderby, which has a population of 5,000, following the murder of a schoolgirl. All adult male residents were asked to provide a DNA sample. The perpetrator could not initially be identified, he later betrayed himself by divulging that he had persuaded a friend to hand in ‘his’ sample. The action proved, however, that such a complex search procedure could in principle be carried out successfully. A little later, this police measure had its premiere in the local Münsterland, albeit on a smaller scale. Since then, genetic mass searches have been used on various occasions and reached their preliminary quantitative peak in the summer of 1998 in the search for the murderer of two girls in the Lower Saxony districts of Cloppenburg and Emsland. All around 18,000 male residents between the ages of 18 and 30 were asked to voluntarily have a saliva sample taken, the genetic profile of which was to be compared with traces found at the crime scene. [23] Although several thousand test subjects did not appear for the test, a "hit" was determined after 75 days and an urgent suspect was arrested. [24] In fact, in this case, the investigators had "more luck than method", [25] since the murderer could have hidden himself among those who did not take part for a longer period of time. In 1996 the Federal Constitutional Court decided that in a murder case, in principle, anyone who cannot prove his innocence in any other way can be obliged to have a DNA sample - even if the police's suspicion grid is very unspecific. It is by no means certain that such mass searches will always lead to success: In order to clarify the so-called 'Festplatz Murder', the police in Baden-Württemberg had to take blood samples for DNA analyzes from 595 male festival visitors between the ages of 17 and 70 but after three years give up hope of being able to further narrow the circle of the 12 main suspects. [26]
The accumulation of such mass tests and their application even in the case of smaller offenses can lead to a decline in acceptance of these procedures and protests to occur - as in Warrington, England. In this case, the police wanted to carry out genetic tests on around 100 mostly underage schoolgirls in order to solve the death of a newborn child found in a garbage can. [27]
Not to be neglected is the enormous expenditure of time and money that such genetic mass searches entail. The logical consequence that the police internationally has drawn from this is the establishment of databases with DNA samples.

Establishment and dissemination of national DNA databases

In police use, the wird genetic fingerprint ’changes from an investigation and search tool to a surveillance technology in the broader sense only through the establishment of so-called forensic DNA databases. The USA has been a pioneer in this new use of the ‘genetic fingerprint’. In 1990, Virginia became the first state to open a DNA registry to assist with rape investigations. The range of traces of crime that could be stored was rapidly expanded, and just a year later, 13 US states had passed laws requiring convicted criminals to submit DNA samples to the databases for further use by the police. The reason for this was, among other things, studies by the Ministry of Justice, according to which half of all rape perpetrators were conspicuous again with the same offense within three years. [28]
CODIS (Combined DNA Index System) is the name of the FBI's composite system for all DNA databases in the US states. It was built in 1993; It went into operation in October 1998 with online connections from all countries. A number of practical problems are hidden behind this notification of execution. [29] Almost all states have passed laws that regulate the collection of DNA samples from convicted criminals (mostly in the case of sexual or violent crimes), but the handling of the crime and convicted categories can vary from state to state. In some cases, young people are not registered or the samples are only taken when they are released from prison. Only 36 of the individual state DNA registers are in effective operation. Most of them have capacity problems when processing the samples. For 1996 and the first half of 1997, 165,000 convicts were eligible to submit DNA samples. However, samples were only taken from 80,000; of these, only 45,000 have been deformed. DNA-compatible samples existed only in 22,000 of the approximately 250,000 reported rapes annually, 6,000 had not yet been analyzed. [30] These figures illustrate the logistical problems that a national forensic DNA register will face if this forensic investigation procedure is first extended to routine and other areas of crime. The state of California has therefore also set up a modern system in which the annual sample throughput can be designed for 30,000 using robot automation. [31]
The real motherland of a huge national DNA database is Great Britain. This is where the genetic fingerprint ’was discovered, and this is where the first genetic mass search’ in history took place.As a result, a ‘Royal Commission on Criminal Justice’ recommended the establishment of a national DNA database as early as 1993, in which all those convicted of serious criminal offenses should be included. The police should be authorized to take DNA samples when arrested and to store them. [32] The facility opened on April 10, 1995 and was initially geared to processing 650 samples per day at a cost of £ 40 each. At the turn of the millennium, the full capacity of five million records should be reached. [33] The ‘National DNA Database’, organized as a recognition service and operated by the ‘British Forensic Science Service’, is said to achieve a hit rate of 300 to 500 per week. [34] The propagated track record of this European pioneering model was used by BKA experts to plead for a not too restrictive interpretation of crime categories when setting up a German DNA database. Of all hits between April ‘97 and January ‘98, just under 3% related to capital, sexual and other serious crimes; the majority of the ‘hits’, however, related to burglary and car theft (approx. 95%). [35] Obviously, the quantitatively most important criminalistic benefit of DNA databases lies in the area of ​​property crime, which is also referred to in the practice of the LKA Rhineland-Palatinate. With reference to the Rhineland-Palatinate and British experience, Kube and Schmitter from the BKA are optimistic that “the DNA analysis file will be successful. These are certainly also related to the acceptance of the DNA analysis file in the population and in police practice (...) The public and practice will only adopt a corresponding attitude towards a DNA analysis file if initial successes occur, which is precisely what they do Inclusion of serious property crimes presupposes ”. [36] Does one have to conclude from this that the DNA database demanded and introduced in the Federal Republic as an indispensable instrument in the fight against child murderers will prove to be primarily a means of combating property crime in everyday police operations?
On March 17, 1997, the ‘Criminal Procedure Amendment Act - DNA Analysis’ (StVÄG) came into force in the Federal Republic of Germany. [37] This law made the legal disputes over the legal admissibility of the ‘genetic fingerprint’ in German criminal proceedings, which had lasted for years, all of a sudden obsolete. Only the Greens complained timidly (but suspecting) that this law had not explicitly put a stop to the establishment of DNA databases. On the other hand, practitioners from the police quickly came forward with the complaint that this law was basically superfluous, since it was a "law of no confidence in the expert" and restricted police investigations. A national DNA file based on the British model is needed. [38] While until about 1996 a key position in forensic medicine and the BKA was still reserved about the possibility of a central DNA database for criminals, [39] this attitude changed with the pressure to educate people through a series of sex murders of children on the police. At the beginning of 1997, the new BKA President Kersten raised the alarm and immediately requested DNA databases against sex criminals. [40] A year later, this demand in response to recent child sex crimes ’had become a government priority. [41] It was only a short process before the Federal Minister of the Interior, Kanther, issued an order to set up the database on April 17, 1998 [42], but it was accompanied by a great deal of political tam-tam. Protests by the data protection officer were of no use. [43]
On June 19, 1998, the Federal Council passed the "DNA Identity Determination Act". [44] With this, the gene file was correctly placed on a corresponding legal basis in terms of the procedure. In the case of “criminal offenses of considerable importance”, suspects and convicts can be compelled to surrender a DNA sample, provided that there is a risk of recurrence. The formula codes of the samples are saved in the file.
The Federal Republic of Germany is the fourth European country after Great Britain (1995), the Netherlands (1997) and Austria (1997) to have set up its own nationwide DNA database for forensic purposes. Belgium, Finland, France, Norway, Sweden and Switzerland are expected to follow suit shortly. [45] A ‘European harmonization’ is not only being sought by the ‘European DNA Profiling Group’ (EDNAP), a European association of forensic medicine laboratories, but also by the Council of EU Interior and Justice Ministers. [46] Europol is likely to play a role in this.

Prospects for a strange surveillance technology

A central argument with which critics have fought both the use of the 'genetic fingerprint' in the investigation process and the establishment of a DNA database is the reference to the potential danger that one not too distant day the DNA analysis will no longer be used alone Identity determination, but also to decipher all possible hereditary dispositions and dispositions of people.
In view of the advances in biotechnology and genetic engineering, such a fear cannot be completely dismissed out of hand. But humans are social beings, and the idea of ​​being able to explain deviant behavior solely on the basis of genes is absurd. The fact that forensic doctors can simply secretly investigate the personality genes on the basis of the DNA sample is not infrequently perceived by them as an "unquestionably dishonorable" allegation. [47] Nevertheless, there are currents in criminology that indulge in such a biological image of man. The danger of such an image of man does not consist in the fact that a gene for evil would actually be found in man. Rather, what is dangerous about biological criminology is the ideological and political impact it can have. It not only consolidates stereotypical notions of crime and offenders, it could also support those groups who demand the broadest possible coverage of the population through genetic mass tests.
First of all, forensic medicine is not interested in a “genetic inquisition”, but in the more extensive use of genetics to identify people. This is where the real potential for criminological liegt progress ’lies, which is currently not (yet) covered by the legal basis: For example, it is easy to determine during the analysis whether the tracer’ is male or female. The age should also possibly be readable from the DNA in the future. [48] ​​Much more interesting for the investigators, however, are the undisputed properties of our genes to determine the biological phenotype. The triggering gene for redhead is now known. It is also alleged that "from a trace found at the crime scene (...) it can be read with a high degree of probability whether it comes from a European, a black African or an Asian". [49] According to the police opinion, these are by no means areas of personality worthy of protection, but simply indications to limit the search efforts. Once the identification procedures are feasible, this option will become an urgent request from the police for legal approval.
Even the most extensive DNA databases for convicted criminals and acute suspects remain half a task if one cannot avoid the spectacular, time-consuming and costly mass genetic tests in the worst-case scenario. Here, too, the British were ahead of their time and thought about a acht people's DNA ’collection and storage at an early stage. As early as November 1992, the then London police chief Peter Imbert demanded that every male resident should submit a DNA sample in order to be able to get the growing number of sexual attacks against women under control. [50] With the firm intention of not being fooled by anyone in matters of law and order, such considerations were presumably taken up by the strategists of the (at that time still acting as an opposition) 'New Labor Party' and around the goal of combating social abuse expanded. [51] This idea cannot be considered completely absurd on the island, because it was not until May of this year that the chairman of the Police Superintendents Association of England and Wales wanted to make this proposal palatable again to the new Interior Minister Straw. [52] However, it cannot be completely ruled out that these are impulses of typically British humor. After all, it is also reported that a genetic fingerprint is extracted from dog poo in one of the villages in order to be able to prosecute masters for lack of supervision and contamination. In any case, laboratory capacities for such escapades seem to be available - how else could the crime laboratory of the Tayside police force offer companies to carry out DNA analyzes as a precautionary measure. Only in this way could you be sure that in the event of a kidnapping case abroad and the sending of cut fingers or ears, it was actually your employee and not someone else who suffered? [54] In the United States, concerned parents are offered home DNA kits for the same purpose.
The fact that forensic DNA analysis has long been tailored to the security needs of normal city dwellers and thus to a broad market is proven by the advertising for the brand new ‘Anti-mugging flesh sampler’. This safety utensil for around $ 60 is a combination of an alarm siren and a metal tip designed as a probe: if you are attacked, you try to scratch something on the opponent's skin with the tip, whereupon small scraps are picked up and stored inside. These cell samples from the attacker are then used for later DNA analysis with subsequent arrest. [55]

Detlef Nogala is a criminologist at the Max Planck Institute for International and Foreign Criminal Law in Freiburg and in the advanced and contact course in criminology at the University of Hamburg.
[1] Herrera, R.J .; Tracey, M.L.Jr .: DNA Fingerprinting. Basic Techniques, Problems, and Solutions, in: Journal of Criminal Justice 1992, pp. 237-248 (238)
[2] e.g. Ford, S .; Thompson, W.C .: A question of identity. Some reasonable doubts about DNA fingerprinting, in: The Sciences 1990, pp. 37-43. Neufeld, P.J .; Colman, N .: When Science Takes the Witness Stand, in: Scientific American, May 1990, pp. 46-50
[3] see the article by Giannelli, P.C .: The DNA Story: An Alternative View, in: The Journal of Criminal Law and Criminology 1998, No. 1, pp. 380-422
[4] Lander, E.S .; Budowle, B .: DNA Fingerprinting Dispute Laid to Rest, in: Nature 1994, No. 371, p. 735. Lander was an early reviewer, Budowle FBI DNA specialist.
[5] Giannelli loc. Cit. (Footnote 3), pp. 412ff.
[6] see Kube, E .; Deinet, W .; Rieger, B .: On material evidence in the German criminal process, in: Spektrum der Wissenschaft 1997, special number 2, pp. 100-102
[7] Since 1995 the BKA has only used the PCR method. For this: Schmitter, H .: The ‘Genetic Fingerprint’, in: Federal Criminal Police Office (Hg.): Festschrift for Horst Herold on his 75th birthday, Wiesbaden 1998, pp. 397-426
[8] Electronic Telegraph v. 8/31/1996
[9] van Oorschot, R.A.H .; Jones, M.K .: DNA Fingerprints from Fingerprints, in: Nature 1997, No. 387, p. 767
[10] Werrett, D .: DNA-The New Weapon in the Fight Against Crime, in: Police & Government Security Technology, October 1997
[11] for criticism of the PCR technique see telepolis v. 11/12/1998
[12] see Giannelli loc. Cit. (Fn. 3)
[13] Electronic Telegraph v. June 25, 1996
[14] see Schmitter loc. Cit. (Footnote 7), p. 408ff.
[15] Rademacher, Ch .: Prevention of the genetic inquisition, in: Zeitschrift für Rechtssppolitik 1990, no. 10, pp. 380-384
[16] Connors, E. et al .: Convicted by Juries, Exonerated by Science - Case Studies in the Use of DNA Evidence to Establish Innocence After Trial, US Department of Justice, NIJ Research, Washington D.C. 1996
[17] see Nogala, D .: Forensic DNA Analysis - Notes on the Criminological Significance of Genetic Information and its Legal Assessment, in: Kriminologisches Journal 1997, No. 4, pp. 292-305
[18] Press release by the data protection officer v. April 22, 1998
[19] young world v. 11/22/1997
[20] The Guardian v. 3.5.1995
[21] Wenzel, R .: Reacts to series of burglaries with a DNA file, in: Kriminalistik 1998, H. 6, S. 419f.
[22] the daily newspaper v. May 28, 1998
[23] ‘Murder investigations: GEN mass test in Lower Saxony’, in: Kriminalistik 1998, no. 5, p. 360
[24] The world v. 2.6.1998
[25] the daily newspaper v. 2.6.1998
[26] Karioth, D .: The physical examination of the accused according to §§ 81a, 81e and 81f StPO new version with special consideration of the so-called genome analysis, in: Die Polizei 1997, issue 7, pp. 195-202 (200 )
[27] BBC News, Radio 1 v. 2.4.1998
[28] Charles, D .: Convicts ’DNA prints added to US police files, in: New Scientist No. 1787 BC 9/21/1993
[29] in the following see Weedn, W.v .; Hicks, J.W .: The Unrealized Potential of DNA Testing, in: National Institute of Justice Journal, December 1997, pp. 16-23
[30] ibid., P. 18th
[31] ‘Lab corners criminals with speedier DNA analysis’, CNN v. May 23, 1996
[32] Hamer, M .: "Time to bank on gene profiles", in: New Scientist No. 1881, 1993, p. 10
[33] Newham, J .: World's first DNA database in Great Britain, in: Kriminalistik 1996, no. 10, pp. 646-647
[34] Kube E .; Schmitter, H .: DNA analysis file, in: Kriminalistik 1998, H. 6, S. 415-418
[35] ibid., P. 417
[36] ibid.
[37] Federal Law Gazette I p. 534
[38] Huber, F .: The ‘DNA Law’ ñ A fiasco constructed for forensic medicine and forensics, in: Kriminalistik 1997, no. 11, pp. 733-736 (733f.)
[39] Süddeutsche Zeitung v. 12/12/1996
[40] ‘DNA databases against sex criminals required’, in: Kriminalistik 1997, H. 2, S. 92
[41] Süddeutsche Zeitung v. January 24, 1998
[42] see ‘The current keyword: DNA analysis file’, in: Zeitschrift für Innere Sicherheit 1998, no. 3, pp. 172-174
[43] Resolution of the 53rd Conference of Data Protection Officers v. 17./18. April 1998
[44] BR Drs. 389/98
[45] Information from Schneider, P.M .: DNA-Databases for Offender Identification in Europe - The Need for Technical, Legal and Political Harmonization, in: Second European Symposium on Human Identification, Innsbruck, Austria, June 9-12, 1998
[46] Justice and Home Affairs Council resolution of 9.6.1997, Official Journal of the EC C193 v. June 24, 1997, p. 2
[47] Brinkmann, B .: draft laws for DNA analysis (interview), in: Kriminalistik 1996, H. 8-9, S. 597-598 (598)
[48] ​​ibid., 597
[49] Huber loc. Cit. (Fn. 38), p. 735
[50] quoted in Lincoln, P.J .: DNA on Trial, in: The Police Journal, Oct. 1993, pp. 411-416
[51] Electronic Telegraph v. July 22, 1996
[52] Electronic Telegraph v. 6.5.1998
[53] Electronic Telegraph v. February 15, 1996
[54] Electronic Telegraph v. January 14, 1997
[55] Electronic Telegraph v. May 21, 1998