"The New York Times" has criticized PACER as "cumbersome, arcane and not free." In 2008, an effort led by Carl Malamud (who said that PACER is "15 to 20 years out of date" and that it should not demand fees for documents that are in the public domain) spent $600,000 in contributions to put a 50-year archive of records from the federal courts of appeals online for free. In a critical article, the magazine "Reason" described the system as "archaic as a barrister's wig."