 Some theorists have also denied the first two publicity requirements above that civil disobedients need to act openly and non-anonymously. Some argue that publicity is compatible with covertness and anonymity, so long as agents claim responsibility for their actions after the fact (Greenawalt 1987, 239; Brownlee 2012, 160; Scheuerman 2018, 43–5). For instance, Edward Snowden’s leaks of classified information about the National Security Agency (NSA)’s massive surveillance programs constitute acts of civil disobedience in this view because, although Snowden obtained and leaked the documents covertly, he eventually claimed responsibility and sought to publicly justify his actions (Scheuerman 2014, 617–21; Brownlee 2016, 966). In this view, the only publicity requirement is (iv) that agents take self-identifying responsibility for their actions after the fact. The other requirements of publicity-as-visibility – openness, non-anonymity, and advance warning – can in fact detract from or undermine the attempt to communicate through civil disobedience and are therefore not necessary to identify civil disobedience. Given, however, that there is often widespread reluctance to regard as “civil” covert and anonymous acts of disobedience such as assistance to undocumented migrants or anonymous hacktivism, other thinkers accept (i), (ii), and (iv) as standard requirements of publicity-as-visibility and deem covert acts to be uncivil without pre-judging their degree of justifiability (Delmas 2018a, 44–5).