May 29, 2020
Dear Senator Hawley,
Subject: Senate Bill S.1914 and Wikipedia
My name is Dr. Gary Null. I am a nationally respected expert in the fields of health, nutrition and alternative medicine. For over four decades I have hosted syndicated radio broadcasts, including ABC radio network, WOR, WMCA and Pacifica. I hold a doctorate in human nutrition and public health science and have authored over 40 books, including several New York Times best sellers.
I wish to extend my gratitude for you addressing the flaws in Section 230 of the Communications Decency Act and introducing Senate bill S.1914 that would remove immunity from large tech companies and pressure them with an external audit. I fully support your efforts.
Back in 1996, the Communications Decency Act was hailed as a landmark piece of legislation, with bipartisan support, to uphold Constitutional free speech as well as regulate indecency and pornography. It was also meant to protect internet providers from third parties engaged in these activities while using their platforms.
However, during the following decades, and with the escalation of social media firms such as Google, Twitter and Facebook and purported free information sites such as Wikipedia and RationalWiki, the Act's later amendment, Section 230 (ie, the Internet Freedom and Family Empowerment Act) -- which also received bipartisan support -- has been shown to be deeply flawed and has increasingly come under criticism. At the time of its passage, no one had anticipated the power social media would exert on the public to shape and promulgate biased and politically-motivated opinions. Although the internet giants rely upon Section 230 to protect themselves from libel and defamation, and avoid being held accountable for the consequences of wrongfully destroying the reputations and careers of individuals, they have also taken advantage of the same bill to engage in the very same libelous behavior under the guise of being non-partisan and neutral. Consequently numerous individuals in government, the sciences, medicine, entertainment, and the academies have suffered professional and personal injuries without any legislative or legal recourse to correct errors and falsehoods. Past court cases by individuals against online providers, including AOL, eBay, Google, Craigslist, etc, have overwhelming ruled in favor of the defendants and granted immunity under Section 230.
Although most attention has been given to the large internet providers and social media firms such as Google, Facebook, Twitter, etc, the internet's most visited website worldwide, other entities have not been properly scrutinized in an equal manner.
Although the S.1914 bill is an important step to correct the unanticipated flaws in Section 230, it unfortunately does not reach far enough and therefore it will fail to correct other forms of bias that are detrimental to public discourse and social health. Notable are:
- The bill is limited to biases "against a political party, candidate or viewpoint" and therefore overlooks other biases that infringe on Constitutional free speech and threaten public health
- The bill's definition of a "Covered Company" excludes "an organization described in section 501(c) of the Internal Revenue Code of 1986." Therefore large non-profit organizations, despite some having a history of political and other biases with an influential overreach similar to the largest social media firms would not be held libel for gross biases and distortion of facts.
We encourage the bill to be amended to include the larger 501(c) organizations that act as social media companies and have enormous influence over public opinion and shape biased perceptions. This would include the Wikimedia Foundation, albeit a 501(c) organization, that collaborates closely with large Silicon Valley social media firms.
We would also recommend the criteria for the types of bias be expanded to include prejudices that endanger public health. Google's parent company, Alphabet, is also a pharmaceutical company with a vested interest in shaping public opinion on matters of medicine and health. And there are deep financial and strategic connections between Google and the Wikimedia Foundation.
Google and Wikipedia are firmly united in their efforts to censor, flag and limit free speech. Both have a history of embracing biased liberal viewpoints. In January 2019 the firm donated $3 million to the Wikimedia Foundation, which brings the sum total of Google donations to $7.5 million during the past decade, according to the World Economic Forum. In principle, Wikipedia serves as a fact checker for Google after the latter's efforts to compete with Wikipedia failed. The collaboration between the two should not be perceived as altruistic. Google searches now readily go directly to Wikipedia where users encounter the similar biases that Google has been criticized for. Already, Google's YouTube relies on Wikipedia pages as a resource for political correctness and, in our estimation, biased opinions.
A recent study published in the Medical Journal of Australia identified serious errors in Dr. Google, Google's online health advice site. The researchers found that the advice and diagnoses had only a 36 percent accuracy. This is a serious threat to both national and global health at time when people and patients increasingly rely on the internet for information about existing conditions and undiagnosed symptoms.
This risk is equally true for Wikipedia, which now ranks number one on the internet for health information. Wikipedia is crowd-sourced meaning that anyone regardless of professional credentials can compose content on any subject. The Wikimedia Foundation has no vetting process by medical and health experts to validate the information millions of people access daily. A review analysis published by the American Osteopathic Association found that "Most Wikipedia articles representing the 10 most costly medical conditions in the United States contain many errors when checked against standard peer-reviewed sources. The authors conclude that "caution should be used when using Wikipedia to answer regarding patient care." Other studies in the medical literature have drawn similar conclusions; nevertheless, despite Wikipedia being ranked at the top most used site for the public's searches for medical information, it does not rank on any recommended online medical resource list within the profession. And yet, Google will be relying upon Wikipedia as a reliable resource for health topics.
Although the Foundation does not qualify under the bill's revenue requirements, it does so for the site's monthly usage. The bill limits companies that would be impacted by the bill to an outreach of 30 million monthly users in the US and/or 300 million worldwide. Wikipedia currently boasts 18 billion page views per month and 27 million registered users on its English edition. There are hundreds of millions more non-registered users.
It is imperative that members of the Senate undertake an investigation into the WikiMedia Foundation's actions and review the legitimacy of its protection from libel, defamation, biases, falsehoods and censorship under Section 230. Moreover, if the Foundation is acting accordingly, against its own stated policies of neutrality, it may very likely be in direct violation of IRS rules regarding its non-profit registration. If this is the case, then under the Communications Decency Act Wikipedia has violated Section 230 and amendments are warranted to include organizations such as Wikimedia so as to be held accountable. The Act was never expected to shield the social media industry from malicious libel, a privilege not allowed to television networks, radio stations. newspapers and magazines. In the case of the Foundation's non-profit registration, I believe an external audit is justified to determine whether the Google-Wikipedia algorithms and content removal practices are politically neutral and unbiased. There should be no exclusion that allows for obvious malicious libel.
After many hundreds of hours of research during the past two years, we have documented evidence of the WikiMedia Foundation's efforts to act with extreme bias against notable national and international figures and entire industries that curtail freedom of speech, public discourse and debate and pose serious dangers to public health.
For your review I am enclosing my person biography, a summary of our investigations and one of our more informative investigative articles about Wikipedia's violations of the Communications Decency Act, failure to adhere to its own rules for neutrality, and evidence of libelous actions.
Gary Null, PhD