Albuquerque, and what is now the huning castle neighborhood is a very old, and even ancient, place
Land use definition and regulation” existed in Albuquerque long before Coronado traveled through the area in 1540.
The area through which he traveled was used and settled, and had been for thousands of years by people and ‘pueblo’ peoples that had a very simple, yet sophisticated, understanding of the nature of the land, of housing and agriculture, and what it took to maintain sustainability and ensure and allow progress and growth, and at the same time maintain a sense of place, and a reasonable human centeredness and purpose.
The fact that these land use laws were not written, or not written in a way that was easily understandable to an outsider, in no way diminishes the fact that they existed. Any knowledgeable or educated person is aware that in traditional societies land use laws are inherently culturally based, an awareness of the ‘rules’ is inculcated from birth, grows with maturity, often reaching a pinnacle in old age.
Unlike most modern land use and zoning approaches that can be based on greed and competition, the ‘native way’ made rules based on intelligent cooperation, mutual respect, and a disciplined self-restraint. There was a profound consciousness of consequences, intended or not.
The result was land use regulation that transcended the distance between forest and field, dwelling and mountaintop. Distinctions were not made between “semi-natural habitats” and man-made kiva spiritual places. The idea of “certain land cover types” was meaningless in an organized society that constantly viewed everything as “a whole,” and felt connected and united and at peace with that whole.
Neocolonialism, like colonialism before it, is based on invasion and conquest, the imposition of the will of outsiders on the affairs of a people, the people, already there.
The first Spanish conquest of what is now Albuquerque and New Mexico represented, perhaps more than anything else, the overthrowing and usurpation of existing land use laws. Under the reign of the new occupiers most old land uses became forbidden, as new controls over house and home, public spaces and places, and even rights of trade and travel were suddenly changed.
New roads and byways were built, old ones occupied and re-purposed. Inherent to the new land use laws was the creation of a class-structure that had not existed before. A new society that paid homage to wide wealth differences rapidly replaced one based on more equitable means. In 1607 Santa Fe became the first legal “town” in New Mexico, established pursuant to the Spanish law municipal land use regulations.
During the ‘pueblo revolt‘, starting in 1680, efforts were made to restore the old and original ‘pueblo’ land use laws. These provisions included ‘landscaping’ and ‘agricultural regulations’. The usurpers became the usurped and were driven off the land, but behind them remained a mixed bag of the old and the new land use practices. One hundred and forty years of colonial influence, occupation, and periodic terror had forged a new generation that had substantially forgotten the importance and value of the old ways.
1692 through 1696 is considered the period of the Spanish reconquest of New Mexico. The period is marked by both efforts at reconciliation and astonishing cruelty and brutality. It was a literal war regarding land use supremacy. In the end a great portion of the original native population fled, rather than submit to the new foreign ways and foreign laws involving life style and land use.
On May 29, 1704, Francisco Cuervo y Valdes, was appointed to be Governor of New Mexico. He was not able to reach Santa Fe, from Mexico City, until late April, 1705. When Governor Cuervo arrived in Santa Fe he was informed that an area known as Bosque de Dona Luisa was being threatened by marauding members of the Apache tribe (“Chilmos | West side Apaches, Jilas | Sangre de Cristo Apaches and said faraones | pharoahs”).
His solution was to ask Spanish families to move, in mass, into the area. Thirty-five families responded favorably, and these two hundred and fifty-two persons, an average family size of 7.2 persons, were provided an armed escort of ten men to accompany them to the Bosque de Dona Luisa area.
Bosque de Dona Luisa is the pre-arrival name for the area now known as ‘Old Town‘ in Albuquerque, New Mexico.
Several months later, on a date in 1705 that still goes unrecorded, pursuant to his best recollection of what was proscribed by His Majesty in the Royal Laws of the Recopilación, Book IV, Title VII, Governor Cuervo founded the ‘town’ of Albuquerque. Pursuant to law the town was a four league tract of land located one league in each direction from the center point of the town. One Spanish league (legua) is equal to approximately 2.6 miles. It is described as the distance a man can walk in one hour.
Hence, the founding of Albuquerque was based on walkability. And since a normal man could not walk on water the Town of Albuquerque Grant was described as covering a tract bounded:
“On the north, by the lands of Diego Montoya; on the east, by the Sandia Mountains; on the south, by the tract of land known as Las Lagunitas; and on the west by the Rio Grande.”
It might be noted that, in this case, the toe of the Sandia Mountains is considered to be just beyond where University Avenue is today. Las Lagunitas is approximately Gibson Boulevard. The lands of Diego Montoya begin near Griegos Road.
The principal land use regulation regarding a Spanish town grant was the necessity of a church. In turn the church was required to be invested with certain objects pursuant to what may be regarded as required code. The church was required to have a dwelling for the Religious Minister, also required pursuant to code were Royal Houses, other houses for settlers, corrals, acequias, and fields for agriculture.
The center of the Town of Albuquerque Grant was considered to be outside of the church grounds, but directly in front of the church. In time a central Town Plaza was laid out, a fence built around it to keep out roaming animals, and a flag pole was erected. The flag pole was situated in the center of the plaza at Old Town, a location now noted as a bandstand. The top of the cupola is where the flagpole once stood, and is the legal, or quasi-legal, center of Albuquerque.
In May of 1883, thirty-seven years after the American occupation, Deputy Surveyor John Shaw, in a preliminary survey found that the Town of Albuquerque Grant covered 17,361.06 acres of land, which included land which was located on the west side of the river that was traditionally considered part of the Town of Atrisco Grant.
The American surveyor disregarded the fundamental basis of the Town of Albuquerque Grant by applying foreign (expert, newcomer) survey practices to a land use properly defined by very obvious walkable realities, i.e. for much of the year one could not walk west across the river.
Unfortunately, the American confusion was not the first peril in establishing an orderly development code for Albuquerque. The first problem was that Governor Cuervo, operating from memory, and not performing adequate research, failed to follow the law that required him to obtain approval of the Viceroy before formally founding a town grant.
Attorney General of New Mexico Juan de Ulibarri had inspected the area, and found that the suitability (code compliance) of the town-site was sufficient, but Francisco Fernandez de la Cueva Enríquez, Duke of Albuquerque, and thirty-fourth Viceroy of New Spain, had not been properly notified pursuant to law.
On the New Mexico end, the Cabildo of Santa Fe reported the founding of the Villa of Albuquerque to the Council of the Indies on February 23, 1706. The formation of the new villa was formally certified by Fray Juan Alvarez, Commissary of the Holy Office of the Inquisition, Custodian and Ecclesiastical Judge Ordinary of the Province, in a letter to the Viceroy on April 16, 1706.
And, in a letter to the Viceroy dated April 24, 1706 Governor Cuervo, after six to eight months of delay, finally informed the Vicroy that the establishment of the Town of Albuquerque Grant was, in modern parlance, “a done deal:”
“the Villa of Albuquerque. is in a good site, keeping in mind what is proscribed by His Majesty in his Royal Laws of the Recopilación, Book IV, Title VII, and there are now thirty-five families settled there, comprising 252 persons, large and small.”
Two days later, Governor Cuervo sent a larger and more formal report to the Viceroy in an effort to justify his precipitous action in the founding of the Villa of Albuquerque.
On April 26, 1706, he wrote:
“And so, enjoying this peace and the happy time offered by the truces, as well as enjoying the experience which I have acquired in this kingdom, wishing that it be more extended, I ordered that one of the best sites of the Rio del Norte (the real name for Rio Grande) be peopled, below the posts of Bernalillo and Alameda. This place was inspected by the said General Juan de Ulibarri, Sargeant Major Procurador General and Rexedor of this Kingdom. He found it to be the most fitting and convenient of all places for the establishment of people and a new villa. Having publicized it, many families of the other jurisdictions offered themselves to go there, carrying at least some large and small cattle. For their security, I decided that a group of ten soldiers of this presidio should go in a squad with their families to escort and guard them, because the place is the main frontier of the barbarous nations of the Chilmos, Jilas and said faraones. The command of the troop was given to a commander with full military experience. I do not doubt, very Excellent Lord, that in a short time this will be the most prosperous Villa for its growth of cattle and abundance of grains, because of its great fertility and for having given to it, the spiritual and temporal things, the patron saints that I have chosen, namely the very glorious apostle of the Indies, San Francisco Xavier, and Your Excellency, with those names the town has been entitled Villa of Albuquerque de San Francisco Xavier del bosque. The Villa was sworn, taking into account the things ordered by His Majesty in his royal laws of the seventh title, fourth book of the Recopilación. There have been settled thirty-five families and within them two hundred and fifty-two persons. The church has been finished and is quite large. Also, part of the dwelling of the religious minister has been finished, and also the other houses of the inhabitants, with their corrals and irrigation ditches flowing. Everything has been done with good will, to the liking, and to the relief and convenience of the said inhabitants.”
The letter speaks for itself. The Governor is ebullient in his flattery, false representations, and efforts at emphasis of what he did right, ignoring the fundamental wrong of not asking permission before the establishment of the new (really not legal) community. No modern bureaucrat or politician could do more, or massage it better.
The controlling law regarding land use regulations, Recopilación de los Leyes de las Indias, authorized town grants of four square leagues of land provided that:
- not less than thirty white (non-native) persons settle.
Note: The Governor had incorrectly understood this to mean families, not individuals.
- the new town grant be not less than five leagues from any other such settlement and be not in prejudice to the interest of any Indian Pueblo.
- the seventh law of this book provided that, when it was proposed to form a settlement or community of not less than ten white persons, the necessary extent of territory should be granted them.
Note: This “seventh law” well illustrates that contradictory land use code provisions are often de facto to land use codes. The first requirement is “30” people, the seventh requirement states that if there are “10” people the grant should be granted.
The Viceroy’s attorney, Jose Antonio de Espinosa, was asked by the Viceroy to look into the whole Albuquerque affair. In a report dated July 25, 1706, attorney, Jose Antonio de Espinosa stated:
“Governor Cuervo says he founded a villa which he called Albuquerque, which lacks a bell, ornament, chalice, vinegar cruets and albas. And, although before founding it, he should have consulted Your Excellency, however, since it is already founded, and since it is evident from the autos that he has been successful in the government, his action can be permitted and order can be given so that he may he helped with the ornaments and other things which the royal law grants once to the new towns, and orders the said governor not to build any other town.
On July 30, 1706, the Royal Audiencia in Mexico City approved the founding of the Villa of Albuquerque, with conditions, and resolved to provide church furnishings as required by code. Inasmuch as there was before the Royal Audiencia a royal decree ordering that a villa be founded in the name of San Felipe, the patron saint of King Philip V, the Audiencia ordered that the Villa of Albuquerque be renamed in compliance with the royal decree. As a consequence, the villa was renamed San Felipe de Albuquerque.
The Resolution of the Audiencia states:
“On the fourth point in which the said Governor refers to having … founded a Villa which he called Albuquerque, and that it has no bell, altar furniture, chalice, nor vessels: It was unanimously resolved that as it is already founded it shall be aided as a favor, and that there shall be sent to it on the first opportunity the bell, altar furniture, chalice and vessels as asked for, this assignment being in accordance with the royal law for new settlements, and he being ordered not to make others without informing His Excellency, and consulting with him in regard to his reasons for the same, in order that he may send him orders as to what he shall do, His Excellency adding that as he has a royal order that a villa shall be founded with the name of San Felipe in memory of his royal Majesty, the said Governor is ordered to call it so for the future and that this resolution be recorded in the archives of the Villa of Santa Fe.”
On July 12, 1846, a little more than a month prior to U.S. General Stephen Watts Kearny’s conquest of New Mexico, German born botanist, Friedrich Adolph Wislizenus passed through the town, and described San Felipe de Albuquerque as follows:
“San Felipe de Albuquerque is a town as large as Santa Fe, stretched for several miles along the left bank of the Rio del Norte, and if not a handsomer, is at least not a worse looking place than the capital .… The country around Albuquerque appears to be well cultivated. Though the soil is sandy, and apparently not fertile, by irrigation they produce abundant crops, often twice a year …. The fields are without fences. A canal by which water from the river is led into the plain, provides by its ramifications (elevated ditch banks) the whole cultivated ground with the means of irrigation.”
Note: The code expectation that town fields be fenced was not being complied with. The result was the unnecessary burden of building a municipal fence around the central plaza to control the unlawfully roaming random animals from interfering with the quiet enjoyment of the central municipal public place.
U.S. General Stephen Watts Kearny, with a hand full of fellow officers, and the rather rag-tag ‘Mormon Battalion‘, that often included accompanying wives and children, “conquered” New Mexico without so much as a fight. The ‘Batallion’ walked into Santa Fe, stayed for awhile, then moved on, first south, then west, on the road to California, in the days when there really was no road to California.
Left in the wake of the new occupation of New Mexico by yet another foreign power was, once again, the issue of permissible land use.
The rights and responsibilities, sometimes concommittal (not committing, not revealing the purpose), to the use of land in San Felipe de Albuquerque, in New Mexico, in fact in the whole of the newly ceded territories, were not limited to the laws regarding town grants.
The Treaty of Guadalupe Hidalgo (Tratado de Guadalupe Hidalgo), officially entitled the Treaty of Peace, Friendship, Limits and Settlement between the United States of America and the Mexican Republic, was not finalized and signed until February 2, 1848, after long and difficult negotiations.
Articles VIII and IX of the U.S. Senate approved treaty ensured safety of existing property rights of Mexican citizens living in the transferred territories.
Pursuant to the treaty an Act to Establish the Offices of Surveyor General of New Mexico, Kansas, and Nebraska, to grant donations to actual settlers therein, and for other purposes, Chap. 103, Sec. 8, 10 Stat. 308 (1854) was passed by the the United States Congress on July 22, 1854.
The last clause of Section 8 of the Act, reserved all lands covered by a pending claim from sale or other disposal by the government until final action on the claim was taken by Congress.
Since the entire area of the Town of Albuquerque Grant was in dispute, for various reasons, the land use issues and land rights awaited final disposition pursuant to Acts of Congress.
In April, 1881, the New Mexico and Southern Pacific Railroad, a subsidiary of the Atchison, Topeka and Santa Fe Railroad, reached its division point in the E/2 of Section 20, Township 10 North, Range 3 East, N.M.P.M.
This point was located about a mile and a half southeast of the original Town of Albuquerque, within the Town of Albuquerque Grant.
A new settlement began to develop around its shops, which soon became the business district of the present City of Albuquerque.
Demands for clear land titles prompted Ambrosio Armijo and nine others, designated as President and Commissioners of the City, to petition U.S. Surveyor General Henry M. Atkinson, on July 25, 1881:
“for themselves and on behalf of the divers other persons who occupied certain lots and plots of land lying within a four league tract of land, located one league in each direction from the flag pole situated in the center of the plaza at Old Town, to petition Surveyor General Henry M. Atkinson for the confirmation of the concession, which commonly was known as the Town of Albuquerque Grant, to the heirs, successors, and legal representatives of its original inhabitants.”
“while the petitioners were unable to locate the instrumento de fundicion of the villa, it was well known historically, and conceded by all persons, to have been in existence for at least one hundred and seventy-five years.”
The ‘President and Commissioners of the City’ filed a number of documents from Archives which made references to such a grant. They also showed that Albuquerque was one of the most populous and politically important settlements in New Mexico, and, therefore, it could be presumed that it had received a grant by operation of law, under Book IV, Title 5, Law 6 of the Recopilación de Los Leyes de los Indias.
Oral testimony also was introduced showing that the town was in existence prior to and at the time the United States acquired jurisdiction over New Mexico.
Researchers have diligently searched for the instrumento de fundicion of San Felipe de Albuquerque in the United States, Mexico and Spain for years. Lansing B. Bloom has stated that it “seems to be lost beyond any hope of recovery.”
[Bloom, “Albuquerque and Galisteo, Certificate of Their Founding, 1706,” X New Mexico Historical Review 49 (1935).]
On September 5, 1882, U.S. Surveyor General Henry M. Atkinson, in Opinion 14, stated:
“I have no doubt that a grant originally existed to this town, as the numerous documents on file in this office suggest, a portion of which are referred to in the petition of claimants bear evidence of the fact in their reference to the same, and the records of the office as well as the testimony taken in the case clearly establish the fact that the town was in existence in 1846 and 1854.
The instructions of the Commissioner of the General Land Office to the Surveyor General of August 21, 1854, set forth in substance that, where proof is made of the existence of a town at the period when the United States took possession it may be considered prima facie evidence of the existence of a grant to such town and to the individuals under whom the lot-holders claim.
In view of all the facts, I am of the opinion that the inhabitants of the town of Albuquerque have a just and lawful claim for the land petitioned for, and I approve to the inhabitants of said town the claim for four square leagues having the center of the flagstaff and adobe monument surrounding the same in the middle of the main plaza or square about the center of the old town of Albuquerque as the center of said tract, unless it may be subsequently shown that the mutual point is elsewhere, and having as its exterior boundaries north and south and east and west lines through the respective termini of lines one Spanish league in each direction north, south, east and west, from the central point.
The prayer of the petitioners that the grant be approved to the heirs, successors, and legal representatives of the original settlers or grantees cannot be granted, as no evidence of title appears in any specific individuals, but the inhabitants of the town are by operations of the laws and instructions cited entitled to the grant.
The claim is hereby approved and recommended for confirmation by Congress to the inhabitants of the Town of Albuquerque.”
De Witte Stearns and Thomas G. Douglas, were honorably discharged soldiers. Each attempted to locate a soldier’s homestead upon a vacant portion of the grant. These applications respectively covered the NE/4 of Section 20, Township 10 North, Range 3 East, N.M.P.M.
Their homestead applications were rejected on the ground that the land had been withdrawn during the pendency of the adjudication of the Town of Albuquerque Grant.
They petitioned for a land use rehearing on December 8, 1882, in which they pointed out that the lands in question were sandy, sterile, and had not been used by the inhabitants of Albuquerque prior to the coming of the railroad. They alleged that:
“since there never had been an actual grant to the town and there could he no grant by operation of law insofar as the lands in question were concerned, since such lands were within five leagues of the Town of Pajarito Grant, which was older than Albuquerque, such lands were vacant and should not have been withdrawn from entry.”
Surveyor General Henry M. Atkinson rejected their petition on December 15, 1882, stating that Spanish law authorized a four league grant to towns, and, under the instructions to his office dated August 21, 1854, he was directed to take the existence of a town prior to the acquisition of New Mexico as prima facie evidence of a grant to it.
In connection with their allegation that the existence of an older town, within a distance of five leagues of San Felipe de Albuquerque, Atkinson held that:
“since the Town of Pajarito had not presented a claim, he could not take cognizance of its grant.”
Atkinson also noted that the last clause of Section 8 of the Act of July 22, 1854 reserved all lands covered by a pending claim from sale or other disposal by the government until final action on the claim was taken by Congress. Therefore, he denied their request to reopen the case.
This decision was appealed to the Commissioner of the General Land Office.
On July 10, 1883, N. C. McFarland, Commissioner of the General Land Office, dismissed the appeal on the ground that there was no provision under law for a direct appeal from a report of the Surveyor General to Congress on a private land claim.
On March 8, 1892, since Congress had not acted upon the claim prior to the creation of the Court of Private Land Claims, the City of Albuquerque, a municipal corporation, and so-called “successors in interest” to the Villa of Albuquerque (sic) (avoiding the lawful term San Felipe de Albuquerque), filed suit against the United States in the newly created Court of Private Land Claims:
“seeking the confirmation of a four square league tract of land which its predecessor, the Villa of Albuquerque, allegedly had acquired by operation of law.”
The government, in its answer, denied the existence of an implied grant on the ground that Spanish law did not authorize the granting of land to a town or villa which was within four leagues of another town. It noted that there were a number of older towns and a pueblo within that distance.
On April 25, 1892, the case came up for trial, and the court, on the same day, confirmed the claim to the city in trust for the use and benefit of its owners on the ground that the city was entitled to a four square league tract as a matter of law.
The decree expressly provided that the confirmation was not to prejudice the rights of the Town of Atrisco to any lands within the grant lying west of the river.
The government appealed the decision to the United States Supreme Court, which, in a decision dated October 17, 1898, reversed the Court of Private Land Claims’ decision on authority of its decision in the Santa Fe case and remanded the claim for further proceedings. The Supreme Court in the Santa Fe case rejected the theory that Spanish law proprio vigore conferred upon every Spanish villa or town a grant of four square leagues of land.
Following the reversal of the decision of the Court of Private Land Claims, further proceedings were initiated in that Court by the City of Albuquerque, assuring that a grant had been made to the Villa in 1705 by Governor Cuervo covering a tract bounded:
“On the north, by the lands of Diego Montoya; on the east, by the Sandia Mountains; on the south, by the tract of land known as Las Lagunitas; and on the west by the Rio Grande.”
The quasi-legal (since it was based on land in dispute) ‘City of Albuquerque’ has now reversed course, and is claiming the “walkable definition” that precluded the issue involving the surveyor’s decision that involved the Town of Atrisco Grant.
The situation is now further complicated by the realization that established Pueblo(s) also existed prior to the Town of Albuquerque Grant that would have made, do to their proximity, the establishment of ‘Albuquerque’ (sic) illegal pursuant to applicable land use law, law sustained by the Treaty of Guadalupe Hidalgo.
The city asserted that the grant papers had been lost or destroyed, and, in an effort to account for their loss, noted that in 1727 Martin Hurtado, Alcalde of the Villa of Albuquerque, could not produce the instrument when Governor Juan Domingo de Bustamante asked to see it in connection with an investigation he was conducting in connection with certain charges against Hurtado that he had allegedly made three local land grants within the Town of Albuquerque Grant without consulting the Villa.
On February 18, 1901, before any further action was taken in the suit before the Court of Private Land Claims, Congress, confirmed the grant in trust to the City of Albuquerque. The proceedings before the Court of Private Land Claims were dismissed on July 9, 1901.
The issue of whether Congress acted in error, or in violation of the Treaty of Guadalupe Hidalgo has never been settled. The issue regarding the extent of the grant “to Atrisco” has never been settled. The issue of what “in trust” means, regarding land use within the grant has never been settled.
The issue of the violation of native American (Pueblo peoples) rights regarding the very establishment of ‘Albuquerque’ has never been settled. The issue of reparations for the apparent unlawful “taking” of Pueblo lands has not been settled.
The actual property rights, and land use rights of heirs in interest that live in the Huning Castle Neighborhood pursuant to the neighborhoods inclusion in the Town of Albuquerque Grant has not been settled.
The rights of heirs or assigns to legal proceedings based upon protected rights regarding legal proceedings, as they pertain to property use and property rights has NEVER been addressed or settled. The simple fact is that the wrongfully imposed “common law” provisions of the American court system do not comport with the Spanish law traditions mandated, or clearly implied, by the Treaty of Guadalupe Hidalgo.
In 1928, the Albuquerque City Commission proposed a zoning code to regulate land uses in Albuquerque, pursuant to the pending Huning Castle Addition subdivision residential project. This proposal was never adopted into law, resulting in the adoption of Huning Castle Addition property covenants as an alternative method in which to specify allowable land and property use.
The City of Albuquerque first established a zoning ordinance in 1953. However, the legaility of the ordinance was successfully challenged in court, and the ordinance was determined to be invalid.
On March 27, 1959, fifty-eight (58) years ago, Albuquerque adopted its first valid zoning ordinance.
In 1965, a new zoning ordinance was adopted that completely replaced the 1959 zoning code ordinance. This new 1965 zoning ordinance adopted, for the first time, parking requirements, but only for new buildings.
The term Comprehensive City Zoning Code dates from the mid-1970’s; the term was not used before that time.
Since the adoption of the Comprehensive City Zoning Code the code has been amended.
In 1975 a significant revision of the Comprehensive City Zoning Code was initiated. The revisions were published in an edition dated January 1, 1976.
Six new zone categories were added, and for the first time, signs became regulated city wide. Landscaping requirements were imposed on non-single family developments, and usable open-space was required for multi-family developments.
A 1994 revision of the zoning code laid the groundwork for removing the Preface from the zoning code. Ten (10) pages of illustrative maps were reduced to just six (6) pages.
The February 2013 edition of the zoning code was the last edition to be available in a hard-copy format. This edition still contained the Preface, and a very useful 2 page Index.
The May 1, 2014, online “Mayor Berry” version of the zoning code eliminated the Index.
The term Integrated Development Ordinance (circa 2015) introduces the word “Development” into the zoning code, implying that the purpose of the code is to develop properties rather than to protect and maintain them.
In September of 2017, in a bill before the Albuquerque City Council, it is proposed that both the Comprehensive City Zoning Code and the various city sector plans be eliminated. These documents would be replaced by a 500 page Integrated Development Ordinance / IDO that contains no Preface, no Index, and no legal citations. Final passage of the IDO is expected in November of 2017.
Corrections, additions and/or comments are welcome. Please email firstname.lastname@example.org
Please refer to MENU for more information pertinent to copyright notification and additional website content.