In 2001, computer programmer Dmitry Sklyarov and his
firm, ElcomSoft, became the first defendants charged
with violating criminal provisions of the 1998 Digital Millennium
Copyright Act (DMCA),16 which are intended
to prevent the circumvention of technological protections
on copyrighted material.17 Sklyarov had cracked
the technological protection measure used by Adobe Sys-violations.”22 According to Aron, given the tax scheme
then in force in Russia, “[t]ax evasion was the only strategy
that allowed an entrepreneur to pay salaries and
invest in his business.”23