 Around 2004 there was a debate whether public-domain software can be considered part of the FOSS ecosystem, as lawyer Lawrence Rosen argued in the essay "Why the public domain isn't a license" that software could not truly be given into public domain, a position that faced opposition by Daniel J. Bernstein and others.In 2012, the status was finally resolved when Rosen changed his mind and accepted the CC0 as open-source license, while admitting that contrary to previous claims copyright can be waived away, backed by a Ninth circuit's decision.Before the Berne Convention Implementation Act of 1988 (and the earlier Copyright Act of 1976, which went into effect in 1978) works could be easily given into the public domain by just releasing it without an explicit copyright notice and no copyright registration.