Plaintiffs Association of Community Organizations for Reform Now, Friends of the Philadelphia City Institute Library, and the Pennsylvania Alliance for Democracy are nonprofit organizations whose members include individuals who access the Internet at public libraries that receive E-rate discounts or LSTA funds for the provision of public Internet access.  We note for the purpose of associational standing that the interests that these organizations seek to protect in this litigation are germane to their purposes.  Plaintiffs Emmalyn Rood, Mark Brown, Elizabeth Hrenda, C. Donald Weinberg, Sherron Dixon, by her father and next friend Gordon Dixon, James Geringer, Marnique Tynesha Overby, by her next friend Carolyn C. Williams, William J. Rosenbaum, Carolyn C. Williams, and Quiana Williams, by her mother and next friend Sharon Bernard, are adults and minors who use the Internet at public libraries that, to the best of their knowledge, do not filter patrons’ access to the Internet.  Several of these plaintiffs do not have Internet access from home.  Emmalyn Rood is a sixteen-year-old who uses the Multnomah County Public Library.  When she was 13, she used the Internet at the Multnomah County Public Library to research issues relating to her sexual identity.  Ms. Rood did not use her home or school computer for this research, in part because she wished her searching to be private.  Although the library offered patrons the option of using filtering software, Ms. Rood did not use that option because she had had previous experience with such programs blocking information that was valuable to her, including information relating to gay and lesbian issues.

Plaintiff Mark Brown used the Internet at the Philadelphia Free Library to research breast cancer and reconstructive surgery for his mother who had breast surgery.  Mr. Brown’s research at the library provided him and his mother with essential information about his mother’s medical condition and potential treatments. 3.  Web Publisher Plaintiffs Plaintiff Afraid to Ask, Inc., based in Saunderstown, Rhode Island, publishes a health education Web site, www.AfraidtoAsk.com.  Dr. Jonathan Bertman, the president and medical director of Afraid to Ask, is a family practice physician in rural Rhode Island and a clinical assistant professor of family medicine at Brown University.  AfraidtoAsk.com’s mission is to provide detailed information on sensitive health issues, often of a sexual nature, such as sexually transmitted diseases, male and female genitalia, and birth control, sought by people of all ages who would prefer to learn about sensitive health issues anonymously, i.e., they are “afraid to ask.”  As part of its educational mission, AfraidtoAsk.com often uses graphic images of sexual anatomy to convey information.  Its primary audience is teens and young adults.  Based on survey data collected on the site, half of the people visiting the site are under 24 years old and a quarter are under 18.  AfraidtoAsk.com is blocked by several leading blocking products as containing sexually explicit content.