For years it has been the case that the Digital Millennium Copyright Act (DMCA) has had a chilling effect on, among other things, security research. That is because the intended chilling effect on copying things, such as music, also bleeds over to research and development of anything related to any device or code which is ‘protected’ under the DMCA. Legal scholars, technologists, and security researchers have argued that the DMCA – and in particular section 1201 of the Digital Millennium Copyright Act – is unconstitutional for this very reason.