Around 2004, lawyer Lawrence Rosen argued in the essay "Why the public domain isn't a license" software could not truly be waived into the public domain and can't therefore be interpreted as very permissive open-source license,[8] a position which faced opposition by Daniel J. Bernstein and others.[9] In 2012, the dispute was finally resolved when Rosen accepted the CC0 as an open-source license, while admitting that contrary to his previous claims, copyright can be waived away, backed by Ninth Circuit decisions.[10]