Timothy K. Armstrong, Fair Circumvention (2008)
“ Perhaps Congress meant to require a certain minimum strength of access control—that is, perhaps Congress meant to say to the courts: a technological protection measure must not only protect access to a work, but must meet some minimal standard of efficacy in doing so; a trivial cipher will not suffice. [219] But the text might equally well support another reading, one that would preclude inquiry into the strength of an access control measure. ”
