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PRICE MEDIA LAW MOOT COURT COMPETITION

_______________________________________________________

BALLAYA & SEESEY

(APPLICANTS)

V.

THE REPUBLIC OF AMOSTRA

(RESPONDENT)

_______________________________________________________

MEMORIAL FOR RESPONDENT

_______________________________________________________

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LIST OF ABBREVIATIONS

ACHPR

African Charter on Human and Peoples Rights

ACHR

American Convention on Human Rights

ACommHPR

African Commission on Human and Peoples Rights

ATEL

Anti-Terrorism & Extremism Law of 2012

CERD

Committee on the Elimination of Racial Discrimination

CJEU

Court of Justice of the European Union

ECHR

Convention for the Protection of Human Rights and Fundamental Freedoms

ECtHR

European Court of Human Rights

ESA

Election Safety Act of 2016

EU

European Union

HRC

Human Rights Committee

IACHR

Inter-American Commission on Human Rights

IACtHR

Inter-American Court of Human Rights

ICCPR

International Covenant on Civil and Political Rights

ICERD

International Convention on the Elimination of All Forms of Racial Discrimination

ICTR

International Criminal Tribunal for Rwanda

IMADR

The International Movement Against All Forms of Discrimination and Racism

OECD

The Organization for Economic Cooperation and Development

OHCHR

United Nations Office of the High Commissioner for Human Rights

SCOTUS

Supreme Court of the United States of America

SIA

Stability and Integrity Act of 2014

UDHR

Universal Declaration of Human Rights

UK

United Kingdom

UN

United Nations

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UNESCO

United Nations Educational, Scientific and Cultural Organization

UNGA

United Nations General Assembly

UNHRC

United Nations Human Rights Council

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STATEMENT OF RELEVANT FACTS

Background of Amostra

A.

Amostra is a small country with an unstable political history. The majority of its inhabitants are members

of two major religious groups, 30% Yona and 70% Zasa.

B.

In the past five years, Amostra has experienced increasing social unrest. The Yona religious minority

maintain that the primarily Zasa-led government has systematically subjected Yona people to various forms of
political and economic discrimination. There have been frequent non-violent protests and occasional skirmishes
between the Yona protestors and Zasa counter-protestors, which have resulted in arrests of primarily Yona
protestors.

General Elections of 2016 and the Election Safety Act (ESA) of 2016

C.

After the February 15, 2016 violent protest outside the Parliament, where a Yona protester was killed by a

blow to the head by an unknown perpetrator during the clash, the government of Amostra received continued
protests and political pressure from the international community. In light of such, the Prime Minister of Amostra
announced on June 6, 2016 that a general elections would be held in 60 days, or on August 5. On even date, the
National Election Authority, a group of government-appointed regulators responsible for managing Amostras
elections, announced restrictions on elections-related speech to prevent public disorder through the Election
Safety Act (ESA) of 2016.

D.

Relevant portions of the ESA are reproduced below:

1. Section 1. Political demonstrations of more than ten people are not permitted on the public streets of

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Amostra within 30 days of a general election where participants in such a demonstration spread an
extremist or seditious message, or seek to incite hatred, violence, or disrupt the democratic process.
2. Section 2. Attending a public demonstration barred by Section 1of this Act constitutes an offence
punishable by a maximum fine of $10,000.
3. Section 3. Inciting a public demonstration barred by of Section 1 of this Act constitutes an offence
punishable by a maximum fine of $500,000 or two years imprisonment.

SeeSey and its Presence in Amostra

E.

Social media use is popular in Amostra. While the government of Amostra has the ability to block users

access to specific Internet services, they have never implemented such due to lack of technical ability to block
specific posts from a specific social media serviceif they block, they must block the entire service.

F. One social media platform popular in Amostra is SeeSey, a free-registration website where all content is
publicly visible to anyone who is logged into an account, and which allows users to post, share, or comment on
posts they see. SeeSey follows an algorithm wherein it shows personalized content to users based upon two
factors: (1) the users self-selected Home Location (the most recent and most popular posts receive the most
visibility), and (2) content from accounts that the user has added to the users SeeMore list. Amostra users make
up a small percentage of SeeSeys worldwide users.

G.

SeeSey has the technical ability to block individual posts in individual countriesfor example, it could

make a specific post invisible in Amostra but visible to the rest of the world. SeeSey also has the ability to block
the SeeMore option in specific countriesif an account contained speech that was illegal in Amostra, SeeSey
has the technical ability to prevent Amostra-based users from adding that account to their SeeMore list. To date,
SeeSey has not implemented such blocking measures on any posts or accounts in Amostra.

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H.

SeeSey lists its publicly available Operating Policies, which states that it may remove posts where

required by law or necessary for a persons safety, but that it will never edit or change your content. The CEO
of SeeSey has publicly stated that SeeSey is the planets best news source, and the best way to promote the
causes most important to you.

The Stability and Integrity Act (SIA) of 2014

I.

In 2014, to prohibit extremist or anti-patriotic statements, the government of Amostra enacted stringent

laws, including the Stability and Integrity Act of 2014 (SIA), which provides:

1. Section A. The definition of such extremist or anti-patriotic statements under this Act includes those
made by a person doing any of the following: defaming, calling for illegal action, conduct or
speech inciting people to rebel against, or conduct or speech insulting of, government authorities or law
enforcement officials, undermining the authority and impartiality of the judiciary, engaging in or
promoting sedition, and publicly inciting hatred against religious groups.
2. Section B. Any person guilty of a criminal offence under this Act is subject to fines and prison
sentences. It is not necessary to show that the extremist or anti-patriotic statement was in fact published to
a third party, provided there was an intent to do so.
3. Section C. Any person distributing, hosting or caching, or acting as a conduit for, material which is
illegal under this Act can be compelled, by a civil court order (Take down order), to remove the content
and post an apology.
4. Section D. In order to be convicted of an offence or made subject to a civil order under this Act, the
offending statement must be physically distributed or published in Amostra or be addressed to Amostra
residents.

J.

Under the SIA, all media organizations providing content to the citizens of Amostra must register with the

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Ministry of Defense, as well as consult with the Ministry on a quarterly basis to discuss the type of content they
have recently published and that they intend to publish. Failure to do so may cause a media organizations
operating license to be withdrawn.

K.

Because of political instability and media censorship, including occasional disruption of local news

services due to violence or threats, Amostra citizens have turned to SeeSey as a source of news and discourse.
Although SeeSey ranks as the most popular source of news and political discussion among 18 to 35 year-olds in
Amostra, it does not maintain a media operating license in Amostra, and the Ministry of Defense has never asked
SeeSey to register.

Blenna Ballayas Column and The Times

L.

Blenna Ballaya, a citizen of Amostra residing in Sarranto, a large, affluent, politically-stable country

located more than 1000 miles from Amostra, where SeeSeys headquarters and servers are also located. A famous
blogger who regularly writes about political matters on her blog, Ballaya is particularly known for being the first
to post the latest political rumors and caricatures. Ballaya is unpopular with the Zasa, who perceive her writing
and caricatures to be especially sympathetic toward Yona.

M.

The Ex-Amostra Times (The Times), a domestic newspaper in Sarranto popular with Amostran

immigrants, paid Ballaya to write a one-time column as an opinion contributor. The print copy of The Times is not
distributed outside of Sarranto, but its website is visible to viewers regardless of location, although said viewers
cannot comment on articles and columns. The Times also posts selected articles from its website on its SeeSey
account, where users may comment on its articles and columns, and share them with other users.

N.

On July 7, 2016, Ballayas column (An Open Letter to the Oppressors) was published in The Times

print edition, on its website, and on its account on SeeSey. The column accuses the Prime Minister and other Zasa

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members of corruption and human rights violations against Yona, calls the August election a sham for Zasa
political gain, and concludes by echoing calls of other anti-government Amostra citizens for an active but peaceful
Day of Resistance on August 1.

O.

The column went viral in Amostra and was quickly shared among SeeSey users, and was viewed by

thousands in Amostra, especially those who have previously added The Times account to their SeeMore list. A
large number of Yona who read the column on SeeSey posted comments, including some who said that they were
prepared to defend themselves and would carry knives or other available weapons in case of persecution by law
enforcement or the government on the Day of Resistance.

P. On the Day of Resistance, Ballaya travelled to Amostra to attend a largely peaceful public protest, where
participants held signs and chanted in support of Yona-affiliated candidates. A minority of Yona demonstrators,
however, chanted hard-line political messages, set fire to a Zasa religious building frequented by leading
government officials, and assaulted law enforcement officials who tried to prevent the arson attack. Although
there was no evidence that the attackers read the column, they chanted the words of a famous Yona unity song that
Ballaya used in her column: We trust that our faith will carry us home; We are not afraid to fight, not afraid to
die.

Amostras Prosecution of Ballaya and Order Against SeeSey

Q.

Following the riots and violence, Ballaya was arrested and marked as an organizer of the protest in

connection with her column. Ballaya was charged under Sections A and B of the SIA, under which she was found
guilty and sentenced to three years of imprisonment. Ballaya was also prosecuted pursuant to Section 3 of the
ESA, under which she was found guilty and was fined $300,000.

R.

Amostra also applied for a civil order forcing SeeSey to take down the material worldwide and post a

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form of an apology to calm tensions. An Amostran court, upheld by the Supreme Court, issued an order against
SeeSey requiring it to remove all offensive content replicating or relating to Ballayas column, including
comments made by users of SeeSey, so that such content is no longer accessible anywhere on SeeSey from any
location worldwide, including in Amostra and Sarranto.

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QUESTIONS PRESENTED

1.

Whether Amostra violated Ballayas rights to freedom of expression and privacy by prosecuting Ballaya under the
SIA, for calling for illegal action in her column where she echoed the calls of other anti-government protesters
to attend the Day of Resistance, which resulted in violence, including that of Yona members attacking law
enforcers and burning down a Zasa religious building.

2.

Whether Amostra violated Ballayas rights to freedom of expression and privacy by prosecuting Ballaya under the
ESA, for inciting a public and political demonstration of more than ten people on the public streets of Amostra
within 30 days of a general election where participants in such a demonstration spread an extremist or seditious
message, or seek to incite hatred, violence, or disrupt the democratic process, elements of which were present on
the Day of Resistance which Ballaya helped call for in her column.

3.

Whether Amostra has jurisdiction to obtain and enforce the civil court order against SeeSey in Amostra, as well as
in Sarranto, where SeeSey has its headquarters and servers.

4.

Whether Amostra violated SeeSyes rights to freedom of expression and privacy by enforcing the civil court order
upheld by the Supreme Court of Amostra, which ordered SeeSey to take down the material worldwide and post a
form of an apology to calm tensions between the ethnic groups, specifically all offensive content replicating or
relating to Ballayas column, including comments made by users of SeeSey, so that such content is no longer
accessible anywhere on SeeSey from any location worldwide, including in Amostra and Sarranto.

SUMMARY OF ARGUMENTS

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11

AMOSTRAS PROSECUTION OF BALLAYA UNDER THE SIA FOR CALLING FOR ILLEGAL
ACTION IN HER COLUMN IS JUSTIFIED

A.

The prosecution of Ballaya under the SIA did not violate Ballayas rights to freedom of expression and

privacy, as such prosecution was provided by law, in pursuit of the legitimate aims of protecting national security
and public order, and are necessary in the interests of national security or public safety and public order in a
democratic society.

B.

The prosecution was prescribed by law, as the SIA imposes fines and criminal sentences to those who are

proven to have engaged in extremist or anti-patriotic statements, by enumerating specific activities, including that
of calling for illegal action, which Ballaya engaged in when she echoed the calls of anti-government protesters to
attend the Day of Resistance. Amostra does not have unconstrained power to sanction speech, as it must first be
shown that the offending statement (must) be physically distributed or published in Amostra or be addressed to
Amostra residents, before a liability can be imposed.

C.

The prosecution was in pursuit of the legitimate aims of protecting national security and public order. The

SIA is a valid law that was enacted to curb extremist and anti-patriotic statements, after a series of violent protests
have occurred causing significant destruction of government property and threats against the lives of the Prime
Minister and leading officials. Taking into account the increasing social unrest in Amostra, and considering that
there has been a death, injuries, and significant damage to government property due to violent protests, and a
series of threats on the lives of the Prime Minister and government officials, the government is justified in
enacting and implementing the SIA, precisely to maintain national security and promote public order.

D.

The prosecution was necessary in the interests of national security or public safety and public order in a

democratic society. Ballayas act of echoing the calls of anti-government protesters to attend the Day of

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Resistance has influenced Yona protesters to come out and participate that day when violence erupted, resulting to
a clash between protesters and law enforcers, and the burning down of a Zasa building. By prosecuting Ballaya,
an identified organizer of the Day of Resistance, the Amostra government clearly acted in response to a pressing
social need, and not merely out of convenience, and that such prosecution was necessary and indispensable to
restoring public order and maintaining national security and public safety.

E.

The punishment imposed, a three-year jail term, is commensurate to the offense committed, and given the

current political conditions in Amostra, is necessary to deter future violations. Additionally, the three-year jail
term, taken with the fine, is as prescribed by the law for Ballayas violations not only of the SIA, but of the ESA
as well.

AMOSTRAS PROSECUTION OF BALLAYA UNDER THE ESA FOR INCITING A PUBLIC AND
POLITICAL DEMONSTRATION OF MORE THAN TEN PEOPLE IS JUSTIFIED

F.

The prosecution of Ballaya under the ESA did not violate Ballayas rights to freedom of expression and

privacy, as such prosecution was provided by law, in pursuit of the legitimate aims of protecting national security
and public order, and are necessary in the interests of national security or public safety and public order in a
democratic society.

G.

The prosecution was prescribed by law, as the ESA provides for fines and criminal sentences to those who

are proven to have engaged in a demonstration which seeks to spread an extremist or seditious message, or seek
to incite hatred, violence, or disrupt the democratic process, within 30 days of a general election. Such
restrictions on elections-related speech are necessary to prevent public disorder in Amostra, in light of the current
social unrest.

H.

The prosecution was in pursuit of the legitimate aims of protecting national security and public order. The

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ESA is a valid law that was enacted to prevent election-related speech that are extremist or seditious, or that seek
to incite hatred, violence, or disrupt the democratic process. It is well within the power of the National Election
Authority to implement such measures to maintain public order during the election period.

I.

The prosecution was necessary in the interests of national security or public safety and public order in a

democratic society. Ballayas act of engaged in a demonstration where hatred and violence was present, within 30
days of a general election, is precisely what the law seeks to punish. By prosecuting Ballaya, who was part of
those who incited the public demonstration, the Amostra government acted out of a necessity. Such act is
indispensable to restoring public order and maintaining national security and public safety in a democratic society.

AMOSTRA HAS JURISDICTION TO OBTAIN AND ENFORCE THE CIVIL COURT ORDER
AGAINST SEESEY IN AMOSTRA AND SARRANTO

J.

Amostra can validly enforce the civil court order against SeeSey, regardless of where it its headquarters

and servers are located, as in this case in Sarranto, as SeeSey offers its services and is accessible in Amostra, as in
anywhere else in the world. To hold that the civil court order cannot be enforced against SeeSey as its
headquarters and servers are located in Sarranto, even if its content are accessible in countries outside of Sarranto,
is to grant SeeSey impunity in hosting content that can be classified as illegal, such as hate speech.

AMOSTRAS CIVIL COURT ORDER AGAINST SEESEY DID NOT VIOLATE SEESEYS RIGHTS TO
FREEDOM OF EXPRESSION AND PRIVACY

K.

The civil court order against SeeSey did not violate SeeSeys right to freedom of expression and privacy,

as it is not vested with such rights. While corporations are capable of possessing the right to disseminate
information, the same cannot be said about their right to privacy. Unlike natural persons, corporations do not have
privacy interests to be protected. Particularly with social media platforms, assuming that they have a derivative

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right to privacy in the interest of protecting their customers, such derivative right cannot be upheld when it is
being invoked to protect content subversive to national security and public order.

L.

Regardless, Amostras civil order against SeeSey did not violate SeeSeys rights to freedom of expression

and privacy, as such was provided by law, in pursuit of the legitimate aims of protecting national security and
public order, and are necessary in the interests of national security or public safety and public order in a
democratic society.

M.

The civil court order was prescribed by law, as the SIA provides that the state can compel any person

found to be distributing, hosting or caching, or acting as a conduit for, material which is illegal under the SIA,
to remove the content and post an apology.

N.

The civil court order holding SeeSey liable is in the pursuit of the legitimate aims of protecting national

security and public order. Because of SeeSeys accessibility and its large number of users in Amostra, even
information subject to restrictions, can be widely circulated. The civil court order issued by the Amostra court
against SeeSey which required it to remove, after the fact, all offensive content replicating or relating to
Ballayas column, including comments made by users of SeeSey, so that such content is no longer accessible
anywhere on SeeSey from any location worldwide, including in Amostra and Sarranto, is for the legitimate aim
of protecting national security and public order, considering the socio-political climate in Amostra.

O.

In the interests of national security or public safety and public order in a democratic society, it is

necessary to hold SeeSey liable via the civil court order for hosting or caching, or acting as a conduit for, material
deemed as illegal under SIA. While SeeSey does not post its own contents as its contents come from its users, it
acts as an active intermediary with the ultimate control over its users content. Imposing sanctions on active
intermediaries, such as social media platforms, is effective in controlling violations committed on the Internet, as
such intermediaries have the technical ability to detect content that violate the law. In any case, SeeSey itself

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provides in its Operating Policies that it may remove content where required by law.

ARGUMENTS

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It is well settled that the rights of freedom of expression 1 and privacy2 are not absolute. These rights are subject to
limitations,3 and can be regulated in the interest of protecting national security and maintaining public order. It is
the states duty to regulate such rights, and to protect its citizens rights in a democratic society. Regulating
freedom of expression and privacy in social media, however, poses challenges. Because social media transcends
borders,4 it allows for the speedy dissemination of information and speech, whether protected or not, that derive
reaction from people, and sometimes, even move people into action.

I. AMOSTRA DID NOT VIOLATE BALLAYAS RIGHTS TO FREEDOM OF EXPRESSION AND

PRIVACY BY PROSECUTING BALLAYA UNDER THE SIA

1.

As a result of the violence that occurred in the Day of Resistance, and as a response to the column Ballaya

wrote and which was posted and widely shared in SeeSey, Amostra charged Ballaya for violation of the SIA. For
such violation, a three-year jail term was imposed. While such prosecution may have impeded Ballayas rights to
freedom of expression and privacy, it was justified as it was: A) prescribed by law; B) in pursuit of a legitimate
aim; and C) necessary in a democratic society.
A. BELLAYAS PROSECUTION WAS PRESCRIBED BY LAW

1Universal Declaration of Human Rights (adopted 10 December 1948) UNGA Res 217 A(III) (UDHR) art 19; International
Covenant on Civil and Political Rights (adopted 16 December 1966, entered into force 23 March 1976) 999 UNTS 171
(ICCPR) art 19; European Convention on Human Rights (adopted 4 November 1950, entered into force 3 September 1953)
213 UNTS 1932 (ECHR) Art 10; American Convention on Human Rights (adopted 22 November 1969, entered into force 18
July 1978) (ACHR) art 13; African Charter on Humans and Peoples Rights (adopted 27 June 1981, entered into force 21
October 1986) (1982) 21 ILM 58 (ACHPR) art 9.
2
UDHR art 12; ICCPR art 17(1); ECHR art 8; ACHR art 11; ACHPR art 6.

UDHR art 29(2); ICCPR art 19(3); ECHR arts 8(2) and 10(2); ACHR art 11; ACHPR art 13(2)(4)(5).

Wu, Paulina (2015) Impossible to Regulate: Social Media, Terrorists, and the Role for the U.N., Chicago Journal of
International Law: Vol. 16: No. 1, Article 11. <http://chicagounbound.uchicago.edu/cjil/vol16/iss1/11>, accessed
September 12, 2016.

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2.

A statute is prescribed by law, if: a) it is formulated with sufficient precision; b) it calls for adequate

scrutiny; and c) any prosecution made under it has a legal basis. 5

a) The SIA is sufficiently precise as it prescribed the necessary conduct it seeks to regulate

3.

The SIA provides only what are to be restricted, which are extremist or anti-patriotic statements,

including any of the following: defaming, calling for illegal action, conduct or speech inciting people to
rebel against, or conduct or speech insulting of, government authorities or law enforcement officials,
undermining the authority and impartiality of the judiciary, engaging in or promoting sedition, and publicly
inciting hatred against religious groups. Ballayas act of calling for illegal action when she echoed the calls of
anti-government protesters to attend the Day of Resistance sufficiently falls under the acts prohibited by the SIA;
and thus, she can reasonably foresee liability, and correspondingly regulate her conduct.

b) The SIA is sufficiently precise provides adequate safeguards in proving that such
sanctioned speech has been committed

4.

As held in international courts, the law must indicate with sufficient clarity the scope of any discretion

conferred on competent authorities, and the manner of its exercise the law must indicate the scope of any such
discretion.6 Amostra does not have unconstrained power to sanction speech under the SIA, as it must first be
shown that the offending statement (must) be physically distributed or published in Amostra or be addressed to
Amostra residents, before a person can be held liable.

5 Sunday Times v. UK (no. 2), App no. 13166/87 (ECtHR, 26 November 1991), par 51; Hashman and Harrup v. UK, App
no. 25594/94 (ECtHR, 25 November 1999) (Hashman) paras 3134; Ahmet Yildirm v. Turkey, App no. 3111/10 (ECtHR,
18 December 2012) (Ahmet) pars 5759; UNHRC, The Right to Privacy in the Digital Age, Report of the Office of the
United Nations High Commissioner for Human Rights (30 June 2014) UN Doc A/HRC/27/37 (UNHRC June 2014 Report)
par 28.
6 Malone v. UK, App no. 8691/79 (ECtHR, 2 August 1984) (Malone) para 6768; Silver v. UK, App nos. 5947/72,
6205/73, 7052/75, 7061/75, 7107/75, 7113/75, 7136/75 (ECtHR, 25 March 1983) (Silver) para 8590.

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5.

Further, the right to lodge an appeal is a safeguard adequately provided by law. 7 Ballayas appeal to the

Supreme Court of Amostra shows that the SIA can be challenged; thus, it has provided for adequate safeguards.

c) The prosecution under the SIA had a legal basis

6.

The SIA was enacted to prevent are extremist or anti-patriotic statements after a series of violent protests

have occurred causing significant destruction of government property and threats against the lives of the Prime
Minister and leading officials. Taking into account the increasing social unrest in Amostra, and considering that
there has been a death, injuries, and significant damage to government property due to violent protests, and a
series of threats on the lives of the Prime Minister and government officials, the government is justified in
enacting and implementing the SIA. Indeed, Amostra is justified in enacting the SIA to protect the rights and
reputation of its citizens.

B. BELLAYAS PROSECUTION PURSUED THE LEGITIMATE AIMS OF PROTECTING

NATIONAL SECURITY AND MAINTAINING PUBLIC ORDER

7.

Freedom of expression may be restricted under the legitimate aims of protecting national security and

maintaining of public order. Indeed, it is in the power of state authorities to adopt, in their capacity as guarantors
of public order, measures, even of a criminal law nature. 8 Further, where such remarks incite to violence against
an individual, a public official or a sector of the population, the state authorities enjoy a wider margin of
appreciation when examining the need for an interference on the exercise of freedom of expression. 9

C. BELLAYAS PROSECUTION WAS NECESSARY IN THE INTEREST OF NATIONAL

SECURITY OR PUBLIC SAFETY AND PUBLIC ORDER IN A DEMOCRATIC SOCIETY

7 Uzun v. Germany, App no. 35623/05 (ECtHR, 2 September 2010) (Uzun) par 72; Gurtekin v. Cyprus, App nos. 60441/13,
68206/13, 68667/13 (ECtHR, 11 March 2014) (Gurtekin) par 28.
8 ztrk v. Turkey, App no. 22479/93 (ECtHR, 28 September 1999) (ztrk) par 66.
9 ztrk, par 66; Ceylan v. Turkey, App no. 23556/94, (ECtHR 1999) par 25.

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8.

The prosecution was necessary in the interests of national security or public safety and public order in a

democratic society. Ballayas act of echoing the calls of anti-government protesters to attend the Day of
Resistance has influenced Yona protesters to come out and participate that day when violence erupted, resulting to
a clash between protesters and law enforcers, and the burning down of a Zasa building. By prosecuting Ballaya,
an identified organizer of the Day of Resistance, the Amostra government clearly acted in response to a pressing
social need, and not merely out of convenience, and that such prosecution was necessary and indispensable to
restoring public order and maintaining national security and public safety.

PRAYERS FOR RELIEF

For the foregoing reasons, the Respondent respectfully requests this Honourable Court to adjudge and declare
that:

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1. Amostras prosecution of Ballaya under the SIA does not violate international principles, including
Article 19 of Universal Declaration of Human Rights (UDHR) and Article 19 of the International
Covenant on Civil and Political Rights (ICCPR).

2. Amostras prosecution of Ballaya under the ESA does not violate international principles, including
Article 19 UDHR and Article 19 of the ICCPR.

3. Amostra has jurisdiction to obtain and enforce the civil order against SeeSey in Amostra and Sarranto.

4. Amostras civil order against SeeSey does not violate international principles, including Article 19 of
UDHR and Article 19 of the ICCPR.

Respectfully submitted 14 September 2016,

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Agent for the Respondent