VLADIMIR KHARITONOV v. RUSSIA JUDGMENT such as LiveJournal, YouTube or Facebook. Access to his website had been restricted for a short period of time not exceeding three months. He had not shown that the owner of the offending website or the ISP had challenged the blocking decision. The Russian courts had correctly established that the measures taken by Roskomnadzor had sought to forestall circulation of unlawful information and that the relevant provisions of the domestic law had provided the applicant with a sufficient degree of protection against arbitrary interference. 28. Lastly, the Government cited the provisions of the British, French, German, Chinese and United States law relating to the suppression of child pornography and concluded that all States, without exception, provided for some form of filtering of Internet material. The Government also dismissed the submissions by third-party interveners as irrelevant to the subject matter of the present case. (c) Third-party interveners 29. Access Now, a global civil-society organisation defending the digital rights of users at risk, submitted that an assessment of proportionality of restrictions on freedom of expression, including website blocking, should include both substantive (what is blocked) and procedural (how it is blocked) elements. The level of safeguards must be appropriate to the nature of allegedly illegal content. Website blocking interferes with the core of the right to freedom of expression, and affected individuals must be notified and granted adequate remedies to challenge blocking measures. 30. ARTICLE 19, a global campaign for freedom of expression, and the Electronic Frontier Foundation, a legal and policy organisation safeguarding privacy in the digital world, emphasised that blocking access to entire websites was an extreme and disproportionate measure. It was analogous to banning a newspaper or television station, and was incapable of distinguishing between lawful and unlawful content. Any order to block access to content should be as narrowly targeted as possible and be the least restrictive means to deal with the alleged unlawful activity. It must take into consideration the overall effectiveness of the measure and the risks of “over-blocking” other lawful content, including by reference to the technologies available to comply with the order. The interveners cited judgments from European high courts, which concurred that blocking websites by IP address carried a greater risk of undesirable effects on third parties and of “over-blocking” (they cited the Antwerp Court of Appeals judgment of 26 September 2011 in VZW Belgian Anti-Piracy Federation v. NV Telenet, 2010/AR/2541; two United Kingdom High Court judgments, Dramatico Entertainment Limited & Ors v. British Sky Broadcasting Ltd & Ors (No. 2) [2012] EWHC 1152 (Ch), and Cartier International AG & Ors v. British Sky Broadcasting Ltd & Ors [2014] EWHC 3354 (Ch); and the Federal Court of Justice judgment of 26 November 2015 in the 9

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