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Malevolence Tempered by Incompetence: Trump’s Horrifying Executive Order on Refugees and Visas

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The malevolence of President Trump’s Executive Order on visas and refugees is mitigated chiefly—and perhaps only—by the astonishing incompetence of its drafting and construction.

NBC is reporting that the document was not reviewed by DHS, the Justice Department, the State Department, or the Department of Defense, and that National Security Council lawyers were prevented from evaluating it. Moreover, the New York Times writes that Customs and Border Protection and U.S. Citizen and Immigration Services, the agencies tasked with carrying out the policy, were only given a briefing call while Trump was actually signing the order itself. Yesterday, the Department of Justice gave a “no comment” when asked whether the Office of Legal Counsel had reviewed Trump’s executive orders—including the order at hand. (OLC normally reviews every executive order.)

This order reads to me, frankly, as though it was not reviewed by competent counsel at all.

CNN offers extraordinary details:

Administration officials weren't immediately sure which countries' citizens would be barred from entering the United States. The Department of Homeland Security was left making a legal analysis on the order after Trump signed it. A Border Patrol agent, confronted with arriving refugees, referred questions only to the President himself, according to court filings.

. . .

It wasn't until Friday -- the day Trump signed the order banning travel from seven Muslim-majority countries for 90 days and suspending all refugee admission for 120 days -- that career homeland security staff were allowed to see the final details of the order, a person with the familiar the matter said.

. . .

The policy team at the White House developed the executive order on refugees and visas, and largely avoided the traditional interagency process that would have allowed the Justice Department and homeland security agencies to provide operational guidance, according to numerous officials who spoke to CNN on Saturday.

Homeland Security Secretary John Kelly and Department of Homeland Security leadership saw the final details shortly before the order was finalized, government officials said.

Friday night, DHS arrived at the legal interpretation that the executive order restrictions applying to seven countries -- Iran, Iraq, Libya, Somalia, Syria, Sudan and Yemen -- did not apply to people who with lawful permanent residence, generally referred to as green card holders.

The White House overruled that guidance overnight, according to officials familiar with the rollout. That order came from the President's inner circle, led by Stephen Miller and Steve Bannon. Their decision held that, on a case by case basis, DHS could allow green card holders to enter the US.

As I shall explain, in the short term, the incompetence is actually good news for people who believe in visa and refugee policies based on criteria other than—let’s not be coy about this—bigotry and religious discrimination. The President has created a target-rich environment for litigation that will make his policies, I suspect, less effective than they would have been had he subjected his order to vetting one percent as extreme as the vetting to which he proposes to subject refugees from Bashar al-Assad and the bombing raids of Vladimir Putin.

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Indeed, even as I write these words, the ACLU has already succeeded in petitioning a federal court for a class-wide stay of deportations of immigrants and refugees trapped in airports by Trump’s order. And a federal judge in Virginia has issued a temporary restraining order preventing the removal of green card holders detained in Dulles International Airport and requiring that these legal residents of the United States have access to counsel.

In the broader sense, however, it is most emphatically not good news to have a White House that just makes decisions with no serious thought or interagency input into what those decisions might mean. In fact, it’s really dangerous.

Let’s start with the malevolence of the document, which Amira Mikhail summarized and Adham Sahloul analyzed earlier today. I don’t use the word “malevolence” here lightly. As readers of my work know, I believe in strong counterterrorism powers. I defend non-criminal detention. I’ve got no problem with drone strikes. I’m positively enthusiastic about American surveillance policies. I was much less offended than others were by the CIA’s interrogations in the years after September 11. I have defended military commissions.

Some of these policies were effective; some were not. Some worked out better than others. And I don’t mean to relitigate any of those questions here. My sole point is that all of these policies were conceptualized and designed and implemented by people who were earnestly trying to protect the country from very real threats. And the policies were, to a one, proximately related to important goals in the effort. While some of these policies proved tragically misguided and caused great harm to innocent people, none of them was designed or intended to be cruel to vulnerable, concededly innocent people. Even the CIA’s interrogation program, after all, was deployed against people the agency believed (mostly correctly) to be senior terrorists of the most dangerous sort and to garner information from them that would prevent attacks.

I actually cannot say that about Trump’s new executive order—and neither can anyone else.

Here’s how the order describes its purpose:

Section 1. Purpose. The visa-issuance process plays a crucial role in detecting individuals with terrorist ties and stopping them from entering the United States. Perhaps in no instance was that more apparent than the terrorist attacks of September 11, 2001, when State Department policy prevented consular officers from properly scrutinizing the visa applications of several of the 19 foreign nationals who went on to murder nearly 3,000 Americans. And while the visa-issuance process was reviewed and amended after the September 11 attacks to better detect would-be terrorists from receiving visas, these measures did not stop attacks by foreign nationals who were admitted to the United States.

Numerous foreign-born individuals have been convicted or implicated in terrorism-related crimes since September 11, 2001, including foreign nationals who entered the United States after receiving visitor, student, or employment visas, or who entered through the United States refugee resettlement program. Deteriorating conditions in certain countries due to war, strife, disaster, and civil unrest increase the likelihood that terrorists will use any means possible to enter the United States. The United States must be vigilant during the visa-issuance process to ensure that those approved for admission do not intend to harm Americans and that they have no ties to terrorism.

In order to protect Americans, the United States must ensure that those admitted to this country do not bear hostile attitudes toward it and its founding principles. The United States cannot, and should not, admit those who do not support the Constitution, or those who would place violent ideologies over American law. In addition, the United States should not admit those who engage in acts of bigotry or hatred (including "honor" killings, other forms of violence against women, or the persecution of those who practice religions different from their own) or those who would oppress Americans of any race, gender, or sexual orientation.

Color me skeptical that this is the real purpose. After all, if this is the real purpose, then the document is both wildly over-inclusive and wildly under-inclusive. On the over-inclusive side, it will keep tens of thousands of innocent refugees who have been subject to unspeakable violence outside of the protection of the United States on the vanishingly small chance that these people might be terrorists—indeed, to make it impossible for them even to apply for refugee admission if they are Syrian. It will prevent untold numbers of people about whom there is no whiff of suspicion from coming here as students, as professionals, as tourists. It overtly treats members of a particular religion differently from other people.

On the underinclusive side, the order wouldn’t have blocked the entry of many of the people responsible for the worst recent terrorist attacks. There is, in fact, simply no rational relationship between cutting off visits from the particular countries that Trump targets (Muslim countries that don’t happen to be close U.S. allies) and any expected counterterrorism goods. The 9/11 hijackers, after all, didn’t come from Somalia or Syria or Iran; they came from Saudi Arabia and Egypt and a few other countries not affected by the order. Of the San Bernardino attackers (both of Pakistani origin, one a U.S. citizen and the other a lawful permanent resident), the Orlando shooter (a U.S. citizen whose parents were born in Afghanistan), and the Boston marathon bombers (one a naturalized U.S. citizen, one a green card holder who arrived in Massachusetts from Kyrgyzstan), none came from countries listed in the order. One might argue, I suppose, that the document is tied to current threats. But come now, how could Pakistan not be on a list guided by current threat perception?

What’s more, the document also takes steps that strike me as utterly orthogonal to any relevant security interest. If the purpose of the order is the one it describes, for example, I can think of no good reason to burden the lives of students individually suspected of nothing who are here lawfully and just happen to be temporarily overseas, or to detain tourists and refugees who were mid-flight when the order came down. I have trouble imagining any reason to raise questions about whether green card holders who have lived here for years can leave the country and then return. Yes, it’s temporary, and that may lessen the costs (or it may not, depending on the outcome of the policy review the order mandates), but temporarily irrational is still irrational.

Put simply, I don’t believe that the stated purpose is the real purpose. This is the first policy the United States has adopted in the post-9/11 era about which I have ever said this. It’s a grave charge, I know, and I’m not making it lightly. But in the rational pursuit of security objectives, you don’t marginalize your expert security agencies and fail to vet your ideas through a normal interagency process. You don’t target the wrong people in nutty ways when you’re rationally pursuing real security objectives.

When do you do these things? You do these things when you’re elevating the symbolic politics of bashing Islam over any actual security interest. You do them when you’ve made a deliberate decision to burden human lives to make a public point. In other words, this is not a document that will cause hardship and misery because of regrettable incidental impacts on people injured in the pursuit of a public good. It will cause hardship and misery for tens or hundreds of thousands of people because that is precisely what it is intended to do.

To be sure, the executive order does not say anything as crass as: “Sec. 14. Burdening Muslim Lives to Make Political Point.” It doesn’t need to. There’s simply no reason in reading it to ignore everything Trump said during the campaign, during which he repeatedly called for a ban on Muslims entering the United States.

Even while he was preparing to sign the order itself, he declared, "This is the ‘Protection of the Nation from Foreign Terrorist Entry into the United States.’ We all know what that means." Indeed, we do. This document is the implementation of a campaign promise to keep out Muslims moderated only by the fact that certain allied Muslim countries are left out because the diplomatic repercussions of including them would be too detrimental.

Many years ago, the great constitutional law scholar Charles Black Jr., contemplating the separate but equal doctrine, asked:

does segregation offend against equality? Equality, like all general concepts, has marginal areas where philosophic difficulties are encountered. But if a whole race of people finds itself confined within a system which is set up and continued for the very purpose of keeping it in an inferior station, and if the question is then solemnly propounded whether such a race is being treated "equally," I think we ought to exercise one of the sovereign prerogatives of philosophers—that of laughter.

I think we can, without drawing any kind of equivalence between this order and Jim Crow, make a similar point here: Is this document a reasonable security measure? There are many areas in which security policy affects innocent lives but within which we do not presumptively say that the fact that some group of people faces disproportionate burdens renders that policy illegitimate. But if an entire religious grouping finds itself irrationally excluded from the country for no discernible security benefit following a lengthy campaign that overtly promised precisely such discrimination and exactly this sort of exclusion, if the relevant security agencies are excluded from the policy process, and if the question is then solemnly propounded whether the reasonable pursuit of security is the purpose, I think we ought to exercise one of the sovereign prerogatives of philosophers—that of laughter.

So yes, the order is malevolent. But here’s the thing: Many of these malevolent objectives were certainly achievable within the president’s lawful authority. The president’s power over refugee admissions is vast. His power to restrict visa issuances and entry of aliens to the United States is almost as wide. If the National Security Council had run a process of minimal competence, it could certainly have done a lot of stuff that folks like me, who care about refugees, would have gnashed our teeth over but which would have been solidly within the President’s authority. It could have all been implemented in a fashion that didn’t create endless litigation opportunities and didn’t cause enormous diplomatic friction.

How incompetent is this order? An immigration lawyer who works for the federal government wrote me today describing the quality of the work as “look[ing] like what an intern came up with over a lunch hour. . . . My take is that it is so poorly written that it’s hard to tell the impact." One of the reasons there’s so much chaos going on right now, in fact, is that nobody really knows what the order means on important points.

Some examples:

  • Sec. 3(c) bans "entry"—which to the best of my knowledge has had no meaning in the Immigration and Nationality Act (INA) since the passage of the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) in 1996. Pre-IIRIRA law did use the term “entry,” but that is no longer the case.
  • Section 3(g) talks of waivers on a case-by-case basis for people who are otherwise denied visas or other benefits under the immigration laws pursuant to the order. If a person needs a waiver to obtain "other benefits," does that mean that nationals of the seven countries are denied any benefit under the INA without a waiver, benefits such as naturalization, adjustment of status, or temporary protected status, even if they are already in the US?
  • On its face, the order bars entry of both immigrants and non-immigrants. Again, as entry is not defined, and no one was given any time to draft implementing guidance or to clarify any points, it’s no surprise that Customs and Border Protection doesn’t seem to know how to apply it to lawful permanent residents (LPRs). The INA, at section 101(a)(13)(C), says that green card holders will not be deemed as seeking admission absent the factors enumerated therein—factors that do not include an executive order banning entry. Yet Reuters and The Guardian are both reporting quotations from a DHS public relations official, stating that the order does apply to LPRs. If that interpretation lasts, look for DHS to get its ass handed to it on a platter in federal court—a defeat it will richly deserve.
  • Another big mystery is how the order will apply to asylees. Will people even be allowed to apply? On the one hand, the right to seek asylum is right there in the INA. But to apply for asylum, you have to be interviewed by a U.S. Citizen and Immigration Services officer to determine if you have a credible fear of persecution. Is that interview a benefit under the act? And if so, is it barred? From what I hear, right now anyway, Customs and Border Protection is not allowing anyone to claim asylum and have a credible fear interview.

I could go on, but you get the point. This order is a giant birthday present to the ACLU and other immigration litigators. And godspeed to them in going after it—which, as I noted above, they are already succeeding in doing.

But the incompetence actually does not stop at running a process that causes legal chaos and probable manhandling by the federal courts.

Consider, for example, the likely diplomatic fallout. In his first week in office, Trump has managed to create a major rift with Mexico, our peaceable neighbor to the south with whom we have no earthly reason to be spatting and haven’t had bilateral problem this serious since Pancho Villa. Trump’s new order seems certain to raise tensions with other countries too—and not just the countries whose nationals it targets (Iran, for example, which today restricted travel by U.S. nationals in retaliation; a great many U.S. citizens have family in Iran and now can’t visit them).

Because the order applies to dual nationals, where a person is a citizen of one restricted country and one non-restricted country, it appears to bar entry to hundreds of thousands of citizens of the U.K. and Canada—including a British Member of Parliament and a Canadian-Iranian consultant who lives in the United States but now can no longer safely travel to her business’s headquarters in Toronto without being blocked from reentry. British Prime Minister Theresa May wasn’t showing a lot of spine today over the matter, but what happens when she starts getting political blowback at home for the not standing up to the U.S. over its treatment of her nationals?

And Canadian Prime Minister Justin Trudeau is already making noise. He tweeted today:

In some ways, the most stunning incompetence in the document appears in one of the least discussed sections: The section at the end that mandates reporting on the nefarious terrorist activities of foreigners in the United States. This section requires regular reports from DHS on terrorism-related offenses by foreign nationals, and gender-based violence and honor killings by foreign nationals (because remember, Mexico sends us their rapists and Muslims all kill their daughters when they date Americans).

The White House appears to have included this section because the Trumpists think it will show that large numbers of foreigners are coming to the United States and committing acts of terrorism here. But that is delusional, and the data will not show that—as I suspect someone at DHS would have pointed out had they had the chance. Here’s Politifact summarizing the extant data on the citizenship status of the authors of terrorist attacks in the United States: 

The New America Foundation, a Washington think tank that promotes data-driven research for social and economic policy, did an analysis of "homegrown extremism" since 2000. The foundation compiled data on 499 extremists, who either adhered to jihadist ideology inspired by al-Qaida or were motivated by right- or left-wing political beliefs. This database includes attacks as well as those accused of terrorism-related offenses, such as plotting attacks or fundraising. 

New America found that about 64 percent of the extremists were U.S.-born citizens and 80 percent were either American-born or naturalized citizens. The database shows eight out of 499 extremists were illegal residents; all eight were jihadists.

A New York Times analysis cited by many experts we interviewed found that half of the jihadist attacks since 2001 were committed by men born in the United States. Many others were naturalized citizens. Some were noncitizens but were traveling legally, such as Richard Reid, the attempted shoe bomber in Miami in 2001, who didn’t need a visa because he was from Britain.

Overall, databases of terrorist acts in the United States show that many were committed by Americans or naturalized citizens, though some high-profile incidents have involved legal immigrants.

"Empirically, domestic terrorism is carried out by citizens—not immigrants—with right-wing terrorism, racial hate crimes, and the sovereign-citizen movement making up a majority of domestic terrorist incidents," said Joel Day, assistant professor of security and global studies at the University of Massachusetts Lowell. "Other domestic incidents have indeed been carried out by those who came here through legal channels.’’

In other words, the executive order sets up a reporting mechanism that will almost certainly falsify its own premise.

I would wax triumphant about the mitigating effect of incompetence on this document, but alas, I can’t do it. The president’s powers in this area are vast, as I say, and while the incompetence is likely to buy the administration a world of hurt in court and in diplomacy in the short term, this order is still going take more than a few pounds of flesh out of a lot of innocent people.

Moreover, it’s a very dangerous thing to have a White House that can’t with the remotest pretense of competence and governance put together a major policy document on a crucial set of national security issues without inducing an avalanche of litigation and wide diplomatic fallout. If the incompetence mitigates the malevolence in this case, that’ll be a blessing. But given the nature of the federal immigration powers, the mitigation may be small and the blessing short-lived; the implications of having an executive this inept are not small and won’t be short-lived. 

Topics: 
Benjamin Wittes
Benjamin Wittes is editor in chief of Lawfare and a Senior Fellow in Governance Studies at the Brookings Institution. He is the author of several books and is co-chair of the Hoover Institution's Working Group on National Security, Technology, and Law.
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Saturday, January 28, 2017, 10:54 PM
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this is quite the dissection
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William Eggleston, the Pioneer of Color Photography

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Wolfgang Tillmans

Wolfgang Tillmans

Augusten Burroughs’ strange and sad profile of photographer William Eggleston for T, the New York Times Style Magazine:

WE LEAVE THE OFFICES of the Eggleston Trust and go to his apartment. The first thing one sees upon entering is a bright red plastic sign with a yellow border, printed with capitalized white sans-serif text. It warns, “THE OCCUPANT OF THIS APARTMENT WAS RECENTLY HOSPITALIZED FOR COMPLICATIONS DUE TO ALCOHOL. HE IS ON A MEDICALLY PRESCRIBED DAILY PORTION OF ALCOHOL. IF YOU BRING ADDITIONAL ALCOHOL INTO THIS APARTMENT YOU ARE PLACING HIM IN MORTAL DANGER. YOUR ENTRY AND EXIT INTO THIS APARTMENT IS BEING RECORDED. WE WILL PROSECUTE SHOULD THIS NOTICE BE IGNORED. THE EGGLESTON FAMILY.” It is a devastating thing to see. Heartbreaking. I was also an alcoholic for decades, the kind who had shakes and saw spiders. I’m not even through the hallway and my mind is racing from “I want that sign” to “What kind of doctor prescribes alcohol for an alcoholic? Where was he when I was drinking?”

I ask if his drinking ever got in the way of his photography. “I’ve never been able to take a picture after a drink,” he says. “It just doesn’t work. Maybe — I don’t know what it is. It’s not like I’m too drunk to take a picture. I just — the whole idea of it just goes away after one or two drinks.” Eggleston perches atop the bench in front of his Bösendorfer concert grand piano. An active ashtray and a sweating tumbler of icy bourbon on a burn-marked coaster sit inside the piano directly on the frame. He reaches for the glass and takes several small, noisy sips and his body visibly relaxes. I know his relief, exactly. “I’m gonna get this drink down,” he tells me. And as soon as he does he wants another. He suggests that I pour one for myself and join him but I tell him that I don’t drink anymore, that once I start I can’t ever stop. He replies, “Well, I can stop, but I’ll admit I want another one.”

The profile is accompanied by a short film by Wolfgang Tillmans:

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Fujifilm working on square format Instax camera and film

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Fujifilm has announced that it's developing a 1:1 format instant film and accompanying Instax camera for release in spring of 2017. The film itself will measure 85.6mm x 72mm, while the image itself will measure a square 62x62mm. That's the extent of the information released at this point, though Fujifilm has created a teaser page for Instax Square.

Press release

New Square Format for instax Series
A new format that drastically enhances the potential of photographic expression of instax

PHOTOKINA 2016, COLOGNE, GERMANY, September 19, 2016—FUJIFILM Corporation (President: Kenji Sukeno) is pleased to announce that its next generation format “instax SQUARE format film” and “instax SQUARE camera” are currently under development.

With its 1:1 aspect ratio, square format photography is ideal for both portraits and landscapes, and has long been the format of choice for users enhancing their artistic expression. In recent times, the popularity of square format has increased to such an extent that it has become the de facto standard of smartphone cameras and timeline photos on social media platforms.

Fujifilm believes that the instax square format has the potential to drastically evolve the role and presence of instant photography. By adding this new format to the existing mini and wide, a new dimension will be added to the wealth of possibilities of instax photographic expression, users will have a wider choice, and instax cameras and films will be able to respond to a broader range of photographic subjects and situations than ever before.

In addition to the new square format film, a new camera which is able to fully express the attractions of square format photos is also under development. Further details are available at the below website.

instax SQUARE Special content (http://instax.com/square/)

Availability:
Spring 2017

Features:
“instax SQUARE format film”:
Image size: Height 62mm x Width 62mm
Photo size: Height 85.6mm x Width 72mm
“instax SQUARE format camera”: TBD

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What Happens in the Brains of Blind People Who Do Math

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Young woman writing on blackboard, close-up of hand (focus on hand)

The brain, neuroscientists have long known, has a pretty remarkable ability to rewire and adapt itself on the fly — one of the most notable things about it is its plasticity. But just because researchers know that it has this capability doesn’t mean they’ve come anywhere close to fully understanding...More »

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Netflix’s spooky 12-minute film noir only makes sense to engineers and developers

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And Netflix is giving it away for free.

Netflix released a eerie original film noir this month called Meridian that combines a classic detective tale with bizarre visuals, loud special effects, and creepy imagery. The 12-minute film got 1.5 stars and a few reviews on Netflix. But it wasn’t made for casual viewers. It was released for developers and engineers.

Director Curtis Clark likely had artistic reasons for adding the film’s strange effects. But those elements are primarily there because they tend to trip up video codecs, or software that compresses and decompresses digital video, and other elements of the streaming pipeline.

Netflix is giving away the project for free on Xiph.org, which houses a collection of test media, so hardware manufacturers, codec developers, and even competitors like Amazon can experiment with it, Variety reported. They can test the performance of their algorithms and the way streams look on different devices using the footage, which is listed under the Creative Commons 4.0 license. It’s part of how Netflix is pushing Hollywood to think more like Silicon Valley.

“It’s a weird story wrapped up in a bunch of engineering requirements,” Chris Fetner, Netflix’s director for content partner operations, told the publication.

Take, for example, the opening scene in which Captain Mac Foster of the Los Angeles Police Department discusses a string of missing persons cases with one of his detectives, played by Reid Scott from HBO’s Veep. The lighting may give off a typical film noir feel, but the range of shadows and light make the shot difficult to encode, or compress into different versions that can be played on TVs, desktop, tablets, mobile phones, and other devices.

The cigar smoke in the frame is also challenging to encode. Smoke, flame, and water are notorious codec breakers, said Matt Smith at Brightcove, which provides online video tools and services. He published a blog post on Meridian yesterday.

When a video frame is encoded, each pixel in the frame is represented as a square, Smith explained in an interview with Quartz. If the background in a shot is solid black and doesn’t change from frame to frame then the video codec doesn’t have to do anything to those pixels. But, when objects move or light is introduced, it takes a lot of computational power to encode each frame. You could end up with something called macroblocking, which is when objects or areas of a video image appear as small squares and lose their detail.

The lighting in the following scene also messes with the light balance in the shot.

And this rock, which couples patterns in the rock face with varying levels of light and brightness, is a good test for video complexity and compression, Smith said.

This trippy shot near the end of the short film combines all of these elements—a stained glass window with a range of light and brightness, the reflection rippling in the water below, and the film noir effect on the cliff—in one “whopper of a scene,” Smith said.

The film has top notch specs, so developers and engineers are working with highest quality Netflix streaming currently offers. It was shot in 4K HDR video with 60 frames per second with a peak brightness level of 4000 nits and Dolby Atmos audio, Variety reported.

Netflix has released other tools that can be used by the industry. It has more than 150 open-source projects and a handy streaming speed index that can be used to shame internet-service providers into offering faster service.

Like the speed index, the Meridian test footage could also potentially benefit Netflix in the long run. It allows hardware manufacturers, software developers, and others to see how they can best work with Netflix streaming. The master files available on Xiph.org are in a format that Netflix wants its content partners to use—Interoperable Master Format (IMF)—and has instructions on how Netflix should alter the film for different regions. (The company operates in 190 countries around the world, and alters its programming with subtitles and other elements for different markets.)



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The BBC polled critics on the greatest films of the 21st century...

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The BBC polled critics on the greatest films of the 21st century so far:

25. Memento (Christopher Nolan, 2000)
24. The Master (Paul Thomas Anderson, 2012)
23. Caché (Michael Haneke, 2005)
22. Lost in Translation (Sofia Coppola, 2003)
21. The Grand Budapest Hotel (Wes Anderson, 2014)
20. Synecdoche, New York (Charlie Kaufman, 2008)
19. Mad Max: Fury Road (George Miller, 2015)
18. The White Ribbon (Michael Haneke, 2009)
17. Pan’s Labyrinth (Guillermo Del Toro, 2006)
16. Holy Motors (Leos Carax, 2012)
15. 4 Months, 3 Weeks and 2 Days (Cristian Mungiu, 2007)
14. The Act of Killing (Joshua Oppenheimer, 2012)
13. Children of Men (Alfonso Cuarón, 2006)
12. Zodiac (David Fincher, 2007)
11. Inside Llewyn Davis (Joel and Ethan Coen, 2013)
10. No Country for Old Men (Joel and Ethan Coen, 2007)
9. A Separation (Asghar Farhadi, 2011)
8. Yi Yi: A One and a Two (Edward Yang, 2000)
7. The Tree of Life (Terrence Malick, 2011)
6. Eternal Sunshine of the Spotless Mind (Michel Gondry, 2004)
5. Boyhood (Richard Linklater, 2014)
4. Spirited Away (Hayao Miyazaki, 2001)
3. There Will Be Blood (Paul Thomas Anderson, 2007)
2. In the Mood for Love (Wong Kar-wai, 2000)
1. Mulholland Drive (David Lynch, 2001)

See the full top 100.

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