12. See, Jon Auerbach, Fences in Cyberspace; Governments Move to Limit Free Flow of the Internet, Boston Globe, Feb. 1, 1996, at 1(surveying "digital Balkanization" of the Internet through government censorship and filtration); Seth Faison, Chinese Cruise Internet, Wary of Watchdogs, N.Y. Times Feb. 5, 1995, at A1; see also infra, note 20 (describing German government's attempts to interrupt German citizens' access to certain Usenet discussion groups; see generally Anne Wells Branscomb, Jurisdictional Quandaries for Global Networks, in Global Networks: Computers and International Communication 83, 103 (exploring efforts to exercise jurisdictional control over electronic information services).