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Academic Plagiarism and the Limits of Theft

Stefan Senders

When students plagiarize, are they “stealing”? Or are they merely demonstrating their lack of engagement with “the academic community”? This essay traces one case of plagiarism from its inception in student writing to its resolution in administrative discipline. The student was brought before the Committee on Standards, a quasi-juridical board charged with determining the “guilt” or “innocence” of the student, and with suggesting appropriate discipline. Throughout the process, all parties—the student, professor, deans, and faculty-based disciplinary committee—held different views of what had occurred and what was at stake. Was plagiarism to be viewed primarily as a theft, as a breach of community norms, as a betrayal of the ethical foundation of the teacher-student relationship, or perhaps as a disciplinary misunderstanding?

Educators, it seems, make sense of student plagiarism in two ways.1 Some argue that students don't know how to cite sources or make “proper” use of texts; others assume students know full well what is expected of them, and that when they plagiarize, they cheat. The first approach sees plagiarism as a symptom of ignorance, a condition curable with education. The second approach sees plagiarism as simple fraud, an act sharing semantic space with cribbing, lying, and the stealing of test questions. Rebecca Moore Howard (“Plagiarism”), expanding the pedagogical position, has argued that plagiarism is a scare word, and that we should instead view it as one of a wide range of borderline textual practices that function as signs of social transition; students plagiarize, from this perspective, because they have not mastered the norms of scholarly writing and therefore do not see themselves as full participants in that community of writers. Despite such admonitions, however, most teachers assume that students do understand academic norms, but they simply choose not to recognize or act on them.

I am sympathetic to the argument that “plagiarism” is a product of socioliterary transition; I agree that if students felt more engaged, more participatory, in their scholarship and writing, they would be far less likely to plagiarize. But strangely, that argument doesn't make sense to my students, who say, almost in unison, that plagiarism is “taking the words of others,” that it is “a kind of stealing,” and that it is “bad.” Admittedly, when I have actually found students doing what I would consider “plagiarizing,” they frequently claim ignorance. Aware in the abstract, ignorant in the breech; makes sense to me.

I say that with some cynicism, of course. Plagiarism, my students say, is “bad,” but more importantly it “isn't worth it,” or it is “for cowards.” They tell me that plagiarism is “stealing,” yet they also tell me that they routinely, and illegally, download music. I question their claims about the “moral” wrongness of plagiarism, and I have concluded that my students are giving me what they think I want to hear—a legalistic doctrine that defines plagiarism as “stealing.”

My students do know that plagiarism is regarded as transgressive by the academic community; they also know a great deal about the details of academic norms—that paraphrase and websites need citation, that quotes must be exact, that even ideas must be referenced; they know that the dominant model for plagiarism is not cooperation or transitional textuality, but theft. But for all they do know, many of them don't believe. I think there is good reason for this. As Stuart Green argues, plagiarism fits well into the legal model of theft, so long as it is recognized that the “property” that is stolen is not the plagiarized language itself, but the credit due the author. That is, plagiarists don't “steal” words, but they do steal the rewards that attach to the public recognition of authorship, which are credit, prestige, and authority.

Among students, the societal norm that “stealing is wrong” does not appear particularly robust.2 Students routinely download files and music illegally, and they don't have much compunction about it. One student interviewed in a recent survey said, “There are so many people doing this that the risks are so low. . . . It's like shoplifting without the risk or retribution” (Wong). Clearly the issue here is not the applicability of a moral norm prohibiting theft, but an economic norm in favor of the calculation of profit and loss. But even for the students who think stealing is wrong, and I mean really wrong, plagiarism doesn't look like normal theft. From the perspective of the thief, stealing is a way to get things. You want bread, you steal bread; you want jewelry, you steal jewelry; you want music, you steal music. But when students plagiarize, they “steal” things, usually words, that they frequently don't want or care about, or even hold onto for long. From a legal perspective, there's not much difference between stealing something and keeping it, and stealing something and giving it away, but subjectively, the two practices apparently look quite distinct.

Students and “authors” do not participate in the same economy. If it isn't words and ideas, but is in fact credit that is being stolen, do students understand this? They do, of course, understand the idea of credit, but in most cases they consider that credit to be of a very different sort than that accumulated by a professional author. To put it another way, rarely, if ever, is an author deprived of credit when my students reproduce her work. Students do get something out of it: time, excitement, and the possibility of a better grade, but when students “steal” from professional authors, they receive only a form of token-credit, a token only valuable within the walls and rules of the house. Students think plagiarism is a bad thing because it can be dangerous to them—they might be caught. It's like a computer virus—the thing that worries them when they download illegal software. It is, moreover, a calculation, a playing of the odds, a game, and the theme song of the game is this: Practice “safe writing,” don't catch anything, don't get caught.

At my college, the faculty handbook positions plagiarism squarely in the discourse of the law. Listen to the resonance of courtroom drama (emphasis added):

All cases of suspected plagiarism or cheating, whether deliberate or seemingly inadvertent, must be so reported, in order to invoke the hearing procedure a student accused of plagiarism may request a Committee on Standards hearing. . . . If the student is exonerated . . . If suspended . . . [N]ormally, guilt or innocence of plagiarism or cheating is determined by the Committee on Standards and the dean primarily on the basis of the factual evidence submitted by the instructor. . . . A student's ignorance of what constitutes these offenses or of the rules concerning them is not considered to bear on this question. If a student is judged guilty, circumstances surrounding his or her action may be taken into consideration in determining appropriate penalties. (Hobart and William Smith Colleges)

The language is of cases, suspects, reports, hearings, accusation, innocence, guilt, exoneration, evidence, judgment, and penalty. The process, it appears, is invoked automatically. Even the mechanics of the appeal is crafted to have the look and feel of the law.

In three cases I have participated in, my account was taken first, and the student was asked if she had anything to say in response. The faculty members of the Committee on Standards then addressed questions to the student: Do you know what plagiarism is? Do you think what you did is plagiarism? Were you aware at the time that what you were doing was considered plagiarism? Where did the material that was not yours come from? Did you do what you did deliberately? Once the committee had heard the “evidence,” it asked us both to leave the room while they deliberated in secret before inviting us back to hear the “verdict.” What is striking about the process is the degree to which it is framed and elaborated as a judicial one. What is even more striking, however, is that while there is quasi-legal language, there is no law. There is no set code that governs the rules of evidence, the limits of plagiarism, the limits of accusation, or the reasonable extent of punishment. There is no direct or open appeal to precedent, and if members of the committee have any knowledge of past cases, it is purely accidental.

National estimates suggest that between 20 and 40 percent of college students cheat or plagiarize.3 Yet at my school, in 2004, only three cases came before the deans. Out of a student population of just under two thousand, that's a little more than one-tenth of 1 percent. It's possible that our school is special, and that the students don't cheat here, but it seems unlikely; according to the deans, most cases of plagiarism are “handled” by professors individually. I have learned, based on anecdotal evidence, that in my school plagiarism is quite widespread, but that it is rarely acknowledged, and even more rarely “prosecuted.”

In practice, then, our claims that “plagiarism is theft,” and the corollary that their prosecution is somehow “legal,” are undermined by the weakness of our legal theater. We are not convincing because, at least at a communal level, we don't believe that student plagiarism is theft.4 Our claims are inauthentic and false, and so, to the sharp eyes of our students, who have surely had plenty of practice in spotting just such inauthenticity in other authorities, we look foolish, not to mention hypocritical.

We can assume that if our students suspect us of hypocrisy, their suspicions are confirmed when we press them to work cooperatively on papers, to workshop and peer-edit, and to discuss their forming work freely in class and in our offices. We tell them to do it themselves, and to do it with others. It's an unhappy mix.

I have argued that the claim that plagiarism is theft, or stealing, may make sense among professionals, but it fails to do so among students or in the academic-pedagogical context generally. It fails because (1) norms concerning the morality of theft are changing, particularly among our student population; (2) subjectively, from the student's point of view, plagiarism does not meet the definition of theft, in that the plagiarist does not get what she steals; (3) to the extent that credit is stolen, the meaning of “credit” is not the same for professionals and students (thus students do not see themselves as “stealing” something that they could in fact steal) (4) our use of a quasi-legal theater to sustain an antiplagiarism norm has been ill-conceived, and it has therefore not been successful; and finally, (5) in our teaching we have not adequately articulated the relationship between ostensibly “original” work and “collaborative” work, and we have thus failed to displace the assumptive norm that originality is “better” than collaborative work. In such a context, it's no wonder that plagiarism might not seem like a big deal to students.

But plagiarism is a big deal to me, and it is to many teachers I know. It is important to me not because it is “criminal,” but because it undermines the intimacy that helps make teaching possible and rewarding. Plagiarism displaces that intimacy with a new form of relationship, one characterized by instrumentality, deception, and infidelity. Arguably, we have set the stage for such a disruption, but we nonetheless depend on pedagogical intimacy to make teaching work. From this perspective, plagiarism is not an act; it is a relationship, a social form that, while always transgressive and often disruptive, can on occasion offer teachers and students unanticipated opportunities.

My students, by and large, are well prepared and willing. But last year, after receiving a wave of papers from my first-year writing seminar, I noticed that the work I was receiving was surely plagiarized. We had been reading George Orwell's 1984, and the students had produced copious freewriting about the novel, engaged in peer-critique, and had chosen essay topics in consultation with me. The process was as much about topic choice and development as it was about the finer points of the essay.5

It wasn't hard to tell which papers had been written and which had been clipped, and I developed a functional, if somewhat cynical, approach to the preliminary triage. If a sentence had even a breath of grace, I checked to see if Google knew anything about it. My first inquiry brought up one student's paper as the first hit; he had simply cut and pasted it as a whole—almost whole; the omissions from the original were almost as telling as the plagiarism itself. The student removed from the essay the only passage that suggested even the slightest intellectual challenge. Once I had received, and identified, the first piece of plagiarism, I began filing through the papers on my desk, looking for sentences that seemed out of place. I was angry. I Googled a few and came up with hits. I began to get the picture: the papers had been assembled, half-written, pasted-down—they were plagiarized.

I was struck by my students' skepticism about their own writing and “voice.” They seemed so sure that they had nothing to say, and no voice to say it in, that I wouldn't notice that the papers weren't theirs. Their skepticism certainly clarified my task: to help them realize that they might have something to say and a way to say it. The disjuncture between the students' misperception of their own “voices,” specifically that they do not have them, and the perception of readers of their work, who perceive those voices clearly, suggests a kind of rhetorical self-negation, almost a blindness with respect to authorial self. Student plagiarism, from this perspective, might best be seen as a dysfunctional manifestation of a psycho-rhetorical disorder, a kind of displacement, a failure of identification in which the literary self is absent or unavailable.

I have many times been told that before accusing someone of plagiarism, I should be sure of my claim. The first paper was too blatant a misrepresentation to have been rooted in ignorance, but I suspected that I'd find more plagiarism, as it seemed plausible that some of it might have been somehow innocent, or at least ignorant. When I next met my class I had the students write a brief essay in answer to the question, “What is plagiarism?” I wanted a signed statement from each of them. There was no confusion; with only a couple of exceptions, the students agreed that plagiarism is “using someone else's words without attribution. Stealing someone else's words or ideas.” A few called it a “coward's way out,” and worried “it was something that could get you into big trouble” because “you could have plagiarized without your knowing what you've done.”6

I then told my class about the papers, and I let them know I was angry. I suggested that if any of them was worried about whether or not they'd plagiarized, that they should come see me. That day, as my office hours approached, students began lining up outside my door. In the end, twelve out of my thirty-four students came to meet with me. There was, it seemed, a lot to worry about. Most of the students were worried for no reason. A few had failed to cite properly, but it was clear to me that most of their failures were clumsy, not deceptive. One student, though, walked in my door, sat down, looked at the floor and said: “I did it. You were talking about me, right?” And it was true. We talked for a while. Why had he done it? He told me that he was stressed-out. He had been having trouble with his girlfriend. Some of his family members were sick. His team had been taking a lot of his time, and his courses had all somehow gotten backed up. He apologized and wondered what would happen. I told him to go, directly, to the deans.

The next student entered my office, smiled, and said that she thought I might have found some of her writing troubling. I agreed that I had (hers had been one of the papers I had first picked up), and I gave her my copy of her paper, on which I had marked a couple of passages I knew she had not written. She looked at the paper, sighed, and agreed that the passages were not hers, and that it hadn't been the right thing to do. But, she said, she hadn't exactly been clear about how to cite, and she didn't really think that what she had done was as bad as it appeared. She just hadn't known what to do. It was simple ignorance. I resisted the impulse to punish. “Fine,” I told her, “I will work with you. Why don't you take your paper back and cite each bit that isn't yours, and indicate which bits are yours. I've shown you how to cite (and don't worry, I'm not worrying about the little things) so you can go do it. We'll work in good faith.”

I soon received an e-mail with a new version of her paper attached. She had cited every passage I'd marked. It seemed like a good resolution, until I saw a suspiciously graceful phrase. Sure enough, she had cited the marked passages, but no others; the paper appeared to be a complex pastiche of pastes, patch writing, paraphrase, and unmarked quotations, and she was hoping to get out with the least trouble she could manage. I sent her an e-mail containing a single question mark and the Web address from “Sparknotes” from which some of the remaining material had come.

We agreed that she would identify all the material that she had written herself, and cite what she had taken from other sources. She would have to go before the Committee on Standards, which would decide on the consequences of her case. I recommended that she speak to the dean immediately. As it turned out, she had been brought before the Committee on Standards once before on a similar charge—she had been caught cheating on a science test. (She hadn't really cheated, she said.) Because my case was not her first offense, the penalties were likely to be more severe than usual, and might include expulsion; she was terrified and began to e-mail me multiple times a day. She was sure that if she were to be expelled her parents “would kill her,” and that she “couldn't accept it.”7

I suggested that she write a letter of appeal to the committee, in hopes of reducing her punishment. She latched onto the idea, and when I suggested that she start the process using the very production techniques we had discussed in class, she agreed enthusiastically. Which is to say, she became a writer, and I a writing teacher. She wrote:

I have begun loop writing on the points that we picked out of my freewriting. . . . I am thinking that I should continue loop writing this weekend and then have a rough draft of my appeal to forward you this weekend or show you Monday. Do you think we should meet another time or I should get this put together now that I have my strong points?

I having been working away at my appeal and doing lots of loop writing and I have a question about the order of my points in my appeal.

But it wasn't all good. There was also fear.

Professor H. spoke with a reliable source and was told, just like I was told, that I must write my appeal based on the four criteria from the handbook. As we both know, I really do not have anything to go on from there.

. . . I intend to turn in the appeal tomorrow, but am obviously very concerned. I have spoken with a couple of other professors for advice and to request letters of reference, and one thing they suggested was that I ask you directly to drop the charges. I feel awkward asking you this via email, . . . but, again, I do not think my violations warrant removal from school. I realize this would require a drastic step on your part, but I would be willing to make it up to you however you see fit, on my honor (which I can assure you remains intact). I realize you are trying to bring attention to this issue and think we could team-up to do so. I am at your mercy and would be greatly indebted to you if you would drop the charges.

. . . Please, can you give me another chance to prove to you and myself that I can change and get through what I have done.

The student stopped coming to class, but became intensely engaged in writing. She drafted proposals for antiplagiarism education programs, developed a Sapir-Whorf hypothesis for her own plagiarism, arguing that in mathematics scholars “plug in” formulas and variables without attribution, and because she saw herself as a math major, not a humanities major, she should reasonably be expected to follow the norms of mathematics. She wrote letters to other professors seeking advice and assistance, and she even asked me to write a letter on her behalf, which I did—with significant reservations and caveats (I would have been more supportive if she hadn't written to the dean to say that she “had not been dishonest”).

Eventually her case came up, and she and I were called to stand before the committee to explain the case. She came to the hearing, like any smart defendant, well dressed—in a respectable dark blue pantsuit—and she read a long prepared statement to the committee in which she argued that “something has to be done about the problem of plagiarism at this school,” and that she was the one who could help. The gesture was, in part, one of contrition, but one that at the same time confirmed a fundamental disruption of her ability to perceive her own ethos. Her statement was heard, and apparently ignored; because she had been found guilty of cheating once before, she was expelled—temporarily. The student and her mother, who had inquired about the potential for a lawsuit, eventually and reluctantly accepted her punishment. The student is now back on campus, doing fairly well, and the case appears resolved.

My student, then, despite all the pain and anguish that accompanied her “trial,” became, even if only for a few weeks, a writer, and she saw and worked with me in my role as a writing teacher. From a pedagogical perspective, the incident was a success; the student, once so disengaged from learning, had seen with near-blinding clarity the reasons for writing drafts, for conferencing, for editing, and for thinking hard about writing. There were other unexpected effects. Quiet students began to find their voices, and marginal writers became suddenly attentive to writing and to detail. In some cases it looked like simple fear; they were afraid that they would do something wrong and get nailed for it. But in others, it seemed that the intensity of our relationship had suddenly increased. Students and teacher were made more distant, but also brought closer together; the apparently “criminal” act became a pedagogical encounter. Plagiarism, to quote Howard (“Sexuality”)—with a slight shift in emphasis—did “cultural work.”

A number of my colleagues have suggested that plagiarism is the product of poor teaching, that it comes from lackluster classroom theater and vague assignments. While it is true that we can do a great deal to preempt transgression, it strikes me as odd that we should be expected to shoulder the burden alone. The best advice, clearly, is to teach with as much vigor and engagement as possible. Yet we also have to wonder why the vocabulary we share with our students is often so limited; why my students were so easily ready to feel and express remorse, but not to engage in intellectual inquiry, or to engage with the “academic community.”

The act of plagiarism brings into play new actors. The “academic community,” usually nothing more than a vague shadow to the student, suddenly appears to both faculty and student newly materialized. The college's handbook, the signal of bureaucratic authority, takes on new power as all parties turn to it for rule. And in its black-and-white text, where statements are phrased in the imperative mood (the student will receive a grade of F in the course), the players find thin guidance, as imperative text gives way to contingent reality. Each individual player will take on many roles. The teacher will become investigator, police, judge, and finally (perhaps) executioner. The student, once seen as a person of potential, will appear to the college and professor as a somewhat more fixed quality—a violator, a cheater perhaps, or in more friendly times, an ignoramus. The student's immediate context, usually invisible to all concerned, will take on heightened significance, and may emerge into light. The student will turn reprobate, criminal, fool, child, lawyer, and perhaps belligerent.

As the stage becomes crowded, the relationships among all the players will gain heightened significance, and they too will shift shape. Between student and teacher will emerge, perhaps, a newly charged Oedipal dynamic, as the urge to “kill the father” seems more and more apt. Perhaps the student will feel the need to confess, and if he does, then to whom shall he confess? So perhaps the professor, if she is warm, will become confessor and potential redeemer, or if she is cool will stand as accuser and interrogator, rejecting all confession as irrelevant. The professor, too, will have new social needs: what is her obligation to the “academic community,” and how is that community represented in the immediate circumstances of her collegiate surroundings? Who are the deans, and what role will they play in shaping her response? What does she owe them?

In her bad dreams all her students will hand in identical essays, each cut-and-pasted from the same foolish website, and in the morning or in class, she will look at them with suspicion. And perhaps she will feel angry, and even though she might attempt to hide that anger, judging it misplaced, she can hardly do so successfully, and the classroom will take on a new atmosphere, one potentially poisonous, but just as conceivably nurturing. Or, just as likely, she has learned that each case deserves to be heard and understood on its own merits, and she will wonder just how little do her students really know, and just how do they regard the school in which they study. Of course, she will feel some measure of affront, probably laced with humor, that her students thought she wouldn't notice! And then she would realize how little they understand about the subtlety of voice and rhythm, and how much work she has to do. She might go home to a companion, who will share her anger and outrage and humor, and she will find from the disruption of her classroom intimacy a new intimacy elsewhere.

Of course, it is just as likely that another professor will see the same paper differently, perhaps not notice anything wrong, or at very least not enough to make a stink about. After all, these things take time and energy, and they might not be worth it. And so this professor will distance herself from her classes, sensing, rightly, that something is off somehow, but that it isn't worth getting into. Thus the professor will begin to experience removal, or dismissal, and will feel, probably, a sense of increased interaction with her own self and work. She might feel more powerful than she did earlier, as she was able to detect the plagiarism and to determine the outcome of that detection without any interference from outside authorities.

From a legalistic perspective, plagiarism has a slippery quality, shifting as it does from theft to defamation to fraud to passing off (Green). From a social analytic perspective, however, it's much easier to assess. First, plagiarism is not simply an act, it is a categorical designation for a range of relationships, all of which center on a subjective sense of transgression. Only by analyzing the way the relationship of plagiarism takes shape can we say whether it is best fit by paradigms of “theft,” “fraud,” “infidelity,” or even excessive intimacy. Moreover, by viewing plagiarism as a relationship, we become more aware of its productivity, of the ways it shapes and refigures other identities and relationships. Plagiarism from this perspective comes to serve not merely as prohibition, but as an illumination of our pedagogical and administrative practices. When we cling to the juridical metaphor to define plagiarism, moreover, we become its slaves, and we might wish, finally, to be stolen away, liberated, plagiarized.


1. I owe special thanks to my students, and to Antonia Saxon, George Cooper, Allison Truitt, and Ann Russ for their discussion, comments, questions, and suggestions. I also owe what I hope are obvious intellectual debts to Rebecca Moore Howard and Stuart Green.

2. Many authors have made historical arguments to the effect that the moral prohibition against stealing has weakened in recent years. I have seen no evidence that either supports or refutes the claim. It is clear, however, that the prohibition is not as powerful as many people, particularly authorities and property owners, would like it to be.

3. McCabe and Trevino suggest that rates are even higher. Here I use conservative numbers, such as those used by the University of Illinois. Similar statistics are widely available on the Web.

4. We tend to recognize it as a transgression, but only very rarely do we imagine that a particular case of plagiarism involves theft from the author. It is often true that teachers experience plagiarism as a personal affront, or a breach of implicit contract, but in such cases the offense is not against an author, rather it is against the teacher.

5. Topics ranged from a discussion of hypnotism to an analysis of the Abu Ghraib prison scandal. Some students wanted to write about Orwell's dystopia and its “relation” to current U.S. politics. I discouraged them, suggesting that they would find it difficult to carve out much writing space from the dense critique available on the Web. Three chose to write on the topic against my advice, and of those students, two plagiarized. I later learned that there are extensive Web resources for students writing about any “classic” work. The available material ranges from complete essays to public advice boards. In the Orwell thread on “Sparknotes,” for example, students posted queries and comments such as these:

hey guys.

i need help with the following: i have to do a diary entry (winston's point of view). i still don't know what i should do it about. any suggestions? it's writer's block for me right now. i must write a minimum of 500 words max of 1,000. i must respect the language, style and setting.

any suggestions please email me @ . . .


Essay on Newspeak

posted by sonofdabitch on 6/5 4:23 PM

The topic of my essay is an explanation of Newspeak. I'll have to write more than 1000 words. The problem is that I can't find a lot of material on the topic besides the appendix. Can anybody give me some advice?

connecting to todays world

posted by petercom10 on 9/11 3:08 PM

if you want to connect newspeak to something similar in our current society, euphamisms are similar to newspeak in that it changes what you are saying by making your speech seem milder and politacally correct

6. Their responses, for all their uniformity, were suggestive. To see plagiarism as the “coward's way out” suggests a linkage to a guiding notion of masculinity—plagiarism is for pussies (for more on this line of inquiry, see Howard, “Sexuality”). The idea that plagiarism is something that could somehow sneak up on you suggests that students see it as part of a tactical tool-kit of teachers, who are in opposition to the student.

7. At one point she went so far as to draft a letter to the dean in which she said that she “could not accept expulsion.” I had to point out to her that she was in no position to accept or reject anything. The incident indicated (again) a profound ethos disruption, the rhetorical equivalent of a personality disorder.

Works Cited

Green, Stuart P. “Plagiarism, Norms, and the Limits of Theft Law: Some Observations on the Use of Criminal Sanctions in Enforcing Intellectual Property Rights.” Hastings Law Journal 54 (2002): 167–242.

Hobart and William Smith Colleges. Faculty Handbook., consulted May 15, 2007.

Howard, Rebecca Moore. “Plagiarism: What Should a Teacher Do?” Paper presented at the Conference on College Composition and Communication, Denver, March 2001.

Howard, Rebecca Moore. “Sexuality, Textuality: The Cultural Work of Plagiarism.” College English 62 (March 2000): 473–91.

McCabe, Donald, and Linda Trevino. “What We Know about Cheating in College.” Change 28, no. 1 (1996): 28–33.

“SafeAssignment: Easily Deter Plagiarism in Your Class Using SafeAssignment for Blackboard.” University of Illinois at Chicago., consulted June 2, 2006.

Wong, Brad. “Illegal Downloads Don't Pose Ethical Problem for College Students.” Seattle Post Intelligencer, June 30, 2005., consulted May 15, 2007.

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