There is active debate on the fairness issues raised by non-publication, and the utility of non-publication in the light of computerization of court records. It has been argued that the behavior of judges and litigants indicates that "unpublished" does not mean "unimportant" and that technology has affected the storage costs, research costs and intellectual costs associated with publication of opinions. A "shadow body of law" has developed, leading to concerns about unfair use and access. It has been argued that the "hidden" conflict between published and unpublished decisions is hard to square with fundamental principles of equal justice. Unpublished decisions have also been criticized as an abdication of responsibility, in that it frees judges from the responsibility of preparing publication-worthy opinions in every case.