24 SAVVA TERENTYEV v. RUSSIA JUDGMENT the applicant’s comment was likely to encourage violence capable of putting the Russian police officers at risk. 79. Turning to the question of a potential impact of the impugned text, the Court is mindful that it was posted on a publicly accessible Internet blog. With regard to online publications, it has previously held that user-generated expressive activity on the Internet provides an unprecedented platform for the exercise of freedom of expression (see Delfi AS v. Estonia [GC], no. 64569/09, § 110, ECHR 2015). In the light of its accessibility and its capacity to store and communicate vast amounts of information, the Internet plays an important role in enhancing the public’s access to news and facilitating the dissemination of information in general. It is furthermore true that the risk of harm posed by content and communications on the Internet to the exercise and enjoyment of human rights and freedoms is certainly higher than that posed by the press, as unlawful speech, including hate speech and calls to violence, can be disseminated as never before, worldwide, in a matter of seconds, and sometimes remain persistently available online (ibid., §§ 110 and 133). At the same time, it is clear that the reach and thus potential impact of a statement released online with a small readership is certainly not the same as that of a statement published on mainstream or highly visited web pages. It is therefore essential for the assessment of a potential influence of an online publication to determine the scope of its reach to the public. 80. In the present case, the applicant posted his comment on an individual blog of his acquaintance, Mr B.S. The domestic courts limited their relevant assessment with finding that that blog “was more popular than [the applicant’s one]”, with the result that the impugned text, which remained available without restrictions for one month, was “made accessible to a larger readership” (see paragraph 22 above). The courts, however, do not appear to have ever attempted to assess whether Mr B.S.’s blog was generally highly visited, or to establish the actual number of users who had accessed that blog during the period when the applicant’s comment remained available. 81. The Court observes in the above connection that the applicant’s comment had remained online for one month before the applicant, who found out the reasons for a criminal case against him, removed it (see paragraph 15 above). Although the access to the impugned statement had not been restricted, it drew seemingly very little public attention. Indeed, even a number of the applicant’s acquaintances remained unaware of it, and, it appears it was only the criminal prosecution of the applicant for his online publication that prompted the interest of the public towards his comment (see paragraph 18 above). It is also important to note that, at the time of the events under examination, the applicant does not appear to have been a well-known blogger or a popular user of social media (see Magyar Helsinki Bizottság v. Hungary [GC], no. 18030/11, § 168, ECHR 2016), let alone a

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