A rchive Date
[ 17-01-2004 ]
Category
[ Information Technologies ]
sub-Categoy
[ Computers ]
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[http://www.asc.upenn.edu/usr/chunter/iic.html
From Cultural Hegemony to the Culture of Code
Presented at the International Institute of Communications Annual Conference
St. Pete Beach, Florida
September 25 - 28, 2000
Copyright © - All Rights Reserved
September 2000
by Christopher D. Hunter
Ph.D. Candidate
Annenberg School for Communication
University of Pennsylvania
chunter@asc.upenn.edu
http://www.asc.upenn.edu/usr/chunter/
I would like to thank Dr. Gary Gumpert for inviting me to prepare this paper for the IIC's Young Professionals panel.
Introduction
In December 1996, the Association for the Defense of the French Language and the Association for the Future of the French Language, jointly filed suit against Georgia Tech Lorraine, the European extension of the Atlanta, Georgia-based Georgia Institute of Technology, for not having a French translation of it's English-language web site (Spicer, 1996).
The English only site was charged with being in violation of a 1994 French regulation, popularly referred to as the "loi Toubon" which requires that a French translation always be present in foreign-language advertising and product information.
The driving force behind the "loi Toubon" and its application to an English-language web site which just so happened to reside in France (although it could have just as easily resided on a server in Georgia and still been readily available to all French web users), is also one of the underlying themes addressed by the IIC's Cultural Identity Project. That theme of course is the idea of "global cultural hegemony," which posits that in an age of globalization, U.S. produced, English-language content will come to dominate helpless foreign cultures. This very argument was used in 1994 by then Culture Minister Jacques Toubon, in favor of the French language law that would eventually take on his name. At that time, Toubon argued that the Internet would result in France being "menaced by a new form of colonialism. The United States is in the process of taking the dominant position. If we do nothing, it will be too late. We will be colonized (in Swardson, 1996)." A similar argument was voiced by French President Jacques Chirac, who at a 1996 conference commented "If, in the new media, our language, our programs, our creations are not strongly presented, the young generation of our country will be economically and culturally marginalized (in Swardson, 1996)."
While these are indeed forceful statements against U.S. cultural/lingual domination of the Internet, and in favor of a form of cultural protectionism, are they based on sound theoretical and practical grounds? It would seem that at least with regards to the language diversity of the Internet, French predictions of colonization may prove wrong. Although English content still pervades the web -- 85% of web pages originate in the U.S. vs. only 15% from abroad (Cyveillance, 2000) -- this is rapidly changing. According to estimates by TechServer, by 2003 non-English language material will account for more than half of the content published on the web, much of this originating from international web servers (in NUA, 1999). In addition, by 2003 U.S. users will account for less than one-third of the worldwide population of Internet users (IDC, 1999). As more and more international users come online, the growth in foreign-based content will continue to explode. As such, the web may become the most lingually diverse medium in history.
Beyond the specifics of the Internet language debate, their are also deep theoretical problems with the notion that cultures will simply be overrun by U.S. produced content. In this paper, I will argue that the traditional concept of U.S. cultural hegemony, alternatively referred to as Cultural Domination (Schiller, 1976), McDonaldization (Ritzer, 1996), and McWorld (Barber, 1995), is outdated, and operates on the false premise that cultures are static and weak, and that U.S. content is powerful and carries only one possible meaning. One of the unfortunate consequences of such thinking is a simplistic anti-Americanism, which portrays Americans as uncultured, homogenized, commodity obsessed idiots. In calling for European cultural subsidies, Wolf Donner (1995) supplies just this sort of argument, noting that U.S. "hysteria" over the blockbuster 1993 film Jurassic Park "can perhaps be explained by American naiveté, enthusiasm for films on fashionable subjects, and an easily swayed public addicted to trends (143)."
Foreign nations fears of traditional forms (television programs, films, music) of English-language content, has also resulted in a relative blind spot to an entirely new type of culture, what I will call the "culture of code," which is subtly embedding U.S. values and norms into the hardware and software of the Internet, the very technology pushing globalization's dizzying ascent.
Unlike traditional forms of cultural content, which I will argue can be resisted, code presents a new set of challenges for foreign cultures wary that their values will be undermined. We will explore the power of the culture of code by examining how U.S. privacy norms, "coded" into the architecture of the Internet, are slowly undermining European's cultural expectation of strong privacy rights enforced through law.
The Trouble With Global Cultural Hegemony
Arguments espousing U.S. cultural hegemony have been around for about forty years. Beginning in the 1960s, foreign nations began to worry that massive flows of U.S. produced material, disseminated through newly liberalized telecommunications networks, would crowd out locally produced content, and in the process destroy unique national cultures and impose U.S. market norms. One of the chief academic proponents of this view was the neo-Marxist communications scholar, Herbert I. Schiller, who advanced the notion of (primarily U.S.) cultural imperialism:
The concept of cultural imperialism today best describes the sum of the process by which society is brought into the modern world system and how its dominating stratum is attracted, pressured, forced, and sometimes bribed into shaping social institutions to correspond to, or even promote, the values and structures of the dominating center of the system . . . The public media are the foremost example of operating enterprises that are used in the penetrative process . . . Directly or indirectly, the outcome is the same. The content and style of programming, however adapted to local conditions, bear the ideological imprint of the main centers of the capitalist world economy. (Schiller, 1976: 9-10)
A revised version of Schiller's cultural domination argument is now put forward by the likes of Benjamin Barbor and George Ritzer, who take McDonald's as the paradigmatic example of a U.S. marketing and entertainment machine which is conquering the world and manufacturing a desire for U.S. culture in all its forms, be it watching Dallas, eating a Big Mac, or wearing the latest version of Michael Jordan's new Nike sneakers. In his famous book Jihad vs. McWorld, Barber forecasts that the:
future is a busy portrait of onrushing economic, technological, and ecological forces that demand integration and uniformity and that mesmerize peoples everywhere with fast music, fast computers, and fast food -- MTV, Macintosh, and McDonald's -- pressing nations into one homogeneous global theme park, one McWorld tied together by communications, information, entertainment, and commerce. (1995: 4)
While the above arguments are certainly dramatic, they are supported by an overly simplistic notion of culture, and the false assumption that U.S. content has only one meaning that can not be resisted by foreign audiences.
Traditional cultural hegemony arguments assume that foreign cultures are static entities just waiting to be dominated by U.S. content. Unfortunately, very little effort is put into defining what a local or national culture actually is. As Morley and Robins (1995) comment, within the cultural hegemony argument, "cultural identity is treated as a black box. The only real issue that is raised concerns the vulnerability of cultural identity to attack from the exogenous forces of 'foreign' communications empires (71)."
By failing to examine the complexities of national culture, critics and culture ministers are blind to the equally hegemonic role which elites often play in negotiating what they think national culture should mean for all strata of a given nation, a process Higson (1989) refers to as "internal cultural colonialism." The dangers of divining what national culture "really" means for all citizens are well illustrated by cultural resistance movements by the Quebecois in Canada, the Basques in Spain, and most horrificly the utter disintegration of the former Yugoslavia.
The other major problem with cultural hegemony is that it assumes that U.S. content is embedded with a message of commercialism, instant gratification, and fast food, which simply can not be resisted by receiving cultures. However to prove such a "hypodermic needle" model of effect, one would have to show that "(1) there is a message incorporated in the program that is designed to profit American interests overseas, (2) that message is decoded by the receiver in the way it was encoded by the sender, and (3) that it is accepted uncritically by the viewers and allowed to seep into their culture (Liebes & Katz, 1990: 4)." However, a great deal of social science evidence shows that the exact opposite is true; that audience members are active in the process of interpretation and that they adapt foreign content to fit their cultural views, a process often referred to as "oppositional reading" or "reading against the grain (Hall, 1973; Morley, 1980; Fiske, 1987)."
The worldwide success of the television program Dallas in the 1980s was held up by many as the prime example of the homogenizing effects of U.S. media. However, a number of ethnographic studies showed that foreign cultures "read" the show in vastly different ways. Ien Ang (1985) found that Dutch women interpreted the program through their own feminist agenda in opposition to the supposedly embedded message of patriarchy. Eric Michaels (1988) showed how Australian Aboriginals reinterpreted Dallas through their notions of kinship in a way quite contrary to the show's intended meaning. Finally, Liebes and Katz (1990) found very different cultural interpretations of the show among Arab, Jewish, American, and Russian viewers. Further, Liebes and Katz point out that Dallas failed miserably in Japan and Brazil, a seemingly unexplainable event given the supposedly overwhelming power of U.S. content to bowl over other cultures.
Similar cultural reinterpretations and appropriations have been observed with the introduction of McDonald's into Asian nations. Contrary to McDonald's intended message of fast food (the average American spends about 11 minutes eating at a McDonald's), in Beijing, Seoul, and Taipei, McDonald's restaurants are seen as leisure centers where people can escape from the stresses of the urban environment. In Hong Kong, middle school students often sit in the restaurant for hours studying and gossiping. And throughout Asia, Ronald McDonald has been appropriated to fit with local customs and norms. As James Watson (1997) comments, "Who is to say that Mickey Mouse is not Japanese, or that Ronald McDonald is not Chinese (10)?" The point here is the McDonald's has been "Asianized" not that Asia has been "Americanized" by the mere presence of the successful U.S. fast food chain. Asian cultures adapted McDonald's to fit their needs and their cultures, thus showing that traditional notions of cultural hegemony and cultural domination are far to dismissive of cultures' ability to adapt, incorporate, and resist.
The Culture Of Code
While traditional types of content may be amenable to reinterpretation and resistance, a new form of culture, what I like to call the "culture of code," would seem to present a new challenge. By code, I mean the complex software underlying today's computer systems and networks like the Internet. Written predominantly in English and predominantly in the U.S. -- which controls 75% of the worldwide packaged software market (Carmel, 1997) -- a culture of code has arisen which embeds U.S. norms about contentious global policy issues like privacy rights, copyright protection, and free speech into the very architecture of global computing systems (Lessig, 1999).
Perhaps the best example of what I am referring to is Microsoft's Windows operating system. Window's is the product of a predominantly U.S. development effort, yet it is used on over 90% of the world's personal computers. As such, Microsoft has the power to literally embed its view of the world into the code which runs its software. Unlike Dallas which can be easily reinterpreted, when Windows presents a user with an error message, or accepts a privacy invasive cookie without notifying a user, their is little room for oppositional reading or resistance. Even worse, the underlying "text" of Windows, it's software code, is proprietary, secret, and hidden from view. As a result, even if a user wanted to adapt Windows to fit certain cultural norms, he/she would be unable to examine, reinterpret, and rewrite the underlying code.
An excellent example of the U.S. culture of code undermining foreign cultural values, is the ongoing debate between the U.S. and the European Union (EU) over the appropriate level of privacy protection which should be afforded to online users. From its inception as a U.S. military funded project, the Internet has been developed and shaped primarily by U.S. programmers. One of the uniquely American values that has become embedded in the Internet is that customer surveillance is necessary for the functioning of online advertising and e-commerce. These values have been coded into the net's architecture through the development of cookies and web bugs which create the ability to track users as they surf from site to site on the web. Such tools have resulted in a vast market for personal information and customer profiles generated through online transactions (Kang, 1998). No company better represents U.S. norms about privacy implemented through code than DoubleClick, which tracks web users across its network of thousands of popular sites through the use of cookies. In any given month, DoubleClick sets upwards of 50 million cookies on largely unsuspecting web users hard drives (Shen, 1999).
U.S. norms about data collection stand in sharp contrast to the European Union, which through its European Data Protection Directive, guarantees EU citizens an enforceable legal right to privacy. The Data Directive generally enshrines into law what are known as "Fair Information Practices" which include the right to know that personal data is being collected, to know what purpose such data will be used for, the right to access one's profile, the right to correct such information, and the right to seek legal redress if a company violates a consumer's privacy rights (Davies, 1998). Also within the Data Directive is an important rule known as Article 25 which prohibits EU member nations from doing business with other nations that do not provide an adequate level of privacy protection to EU citizens. This clause has threatened to create a trade war between the U.S. and the EU over the extent of appropriate privacy protections.
Given that the U.S. has no similar comprehensive privacy laws (Reidenberg, 1999), and that U.S. companies have developed an Internet e-commerce architecture which favors massive amounts of personal data collection, it is unsurprising that the U.S. Department of Commerce has been less than enthusiastic in its efforts to comply with the Data Directive. Beginning in October, 1998 when the Data Directive took effect, the U.S. and the EU have been attempting to negotiate an adequate level of privacy protection for EU citizens whose personal information is processed by U.S. companies. During the process of negotiations the EU agreed not to take action against U.S. companies which might be in violation of the Data Directive. While the EU took this position in 1998 because it felt an agreement would be reached within months, the negotiations have gone on for more than two years. Two years in which EU citizens have been denied their right to privacy when U.S. companies handle their data.
Rather than propose the passage of strong privacy rights through law, the U.S. has sought to formulate a bare minimum policy to satisfy EU concerns. The core U.S. proposal is what is known as "safe harbors" which would allow U.S. companies to certify that they follow a number of fair information practices, and therefore meet the EU's minimum threshold for privacy protection. However, throughout the negotiation process the U.S. safe harbor proposals have been extremely weak, particularly with regards to allowing EU citizens access to their data profiles, and giving citizens a meaningful form of redress for privacy violations (TACD, 1999). Despite these major differences between the strong legal protections guaranteed by the Data Directive, and the quite weak self-regulatory protections only promised by the U.S. safe harbor proposal, the EU gave tentative approval to safe harbor in May of this year. Justifying this seeming cave in to U.S. interests, an EU representative commented, "It's just not realistic to look for equivalent protection from the United States. Instead, this is a realistic approach (in Yackley, 2000)." Or in other words, the EU can not afford not to do business with the U.S. where dataveillence is coded into the architecture of e-commerce, and as a result we are willing to give up some of our citizens privacy rights! In this case, the U.S. culture of code clearly whittled away at the EU's cultural expectation of strong privacy rights enforced through law.
A similar situation can be seen with regards to the EU's support for a privacy protection technology known as the Platform for Privacy Preferences (P3P). Developed by the World Wide Web Consortium, the web's standards setting body, and an organization dominated by U.S. member companies like Microsoft, Netscape/AOL, DoubleClick, and the Direct Marketing Association, the technology allows web sites to describe their privacy policies in a machine readable format. Many supporters of P3P have held the technology up as an alternative to government privacy regulation such as the EU Data Directive. However, when the EU first examined P3P in 1998, it concluded that the technology was insufficient, noting that "Surprisingly, given the intention that P3P be applicable worldwide, the vocabulary has not been developed with reference to the highest known standards of data protection and privacy, but has sought to formalize lower common standards (European Commission, 1998)." While P3P has responded to some of the EU's concerns, it still remains a deeply flawed technology.
Despite these concerns, at least one EU member nation, Germany, is arguing that the technology should still be used. After noting the many shortcoming of P3P, a recent report by two German privacy regulators, found that "P3P should be used nevertheless (Grimm & Rossnagel, 2000)." Why would a country seeking to implement the highest privacy protection principles embodied in the Data Directive argue for implementation of a technology that the EU itself has found to formalize lower common privacy standards? Once again the answer would seem to be that the U.S. culture of code is eroding European cultural norms about strong privacy protection.
Conclusion
In summary, code is far more resistant to cultural reinterpretation than traditional forms of content like films or television shows which receive a disproportionate amount of attention in debates about U.S. global cultural hegemony. As a result, foreign nations would do well to refocus their critiques of globalization away from the supposedly corrupting effects of Dallas and McWorld and towards the values embedded in the culture of code.
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