RUBINS v. LATVIA JUDGMENT 11 41. Alternatively, the Government contended that the present application was incompatible with the provisions of the Convention in that freedom of expression had been invoked in disregard of Article 17 of the Convention. In particular, the Government argued that the approach adopted in the Court’s case-law concerning Holocaust denial and related issues should not be interpreted in too formalist and restrictive a manner. In support of this argument the Government contended that the impugned email addressed to the applicant’s employer had contained blackmail and undisguised threats and that such statements were not covered by the protection afforded under Article 10 of the Convention. 42. The applicant contested the Government’s objections and argued firstly that his dismissal had come after he had drawn his employer’s attention to shortcomings in the University’s management. Secondly, the applicant contended that the information to which he referred in the impugned email and which was later published was true and was of public interest. 2. The Court��s assessment 43. At the outset the Court will address the Government’s argument that Article 10 is not applicable because the complaint essentially concerned an employment dispute. 44. In this connection the Court first observes that it is not disputed between the parties that the University was a public-law body (see Lombardi Vallauri v. Italy, no. 39128/05, § 38, 20 October 2009). Even assuming that in its employment relationships the University acted in the area of private law, the Court has previously held that in the sphere of private-law relationships the responsibility of the authorities would nevertheless be engaged if the facts complained of stemmed from a failure on their part to secure to the applicants the enjoyment of the right enshrined in Article 10 of the Convention (see Palomo Sánchez and Others v. Spain [GC], nos. 28955/06, 28957/06, 28959/06 and 28964/06, § 60, ECHR 2011). 45. Turning to the question of whether such conditions existed in the present case, the Court observes that the applicant’s dismissal was mainly based on an email of 20 March 2010 in which he proposed two ways of settling his dispute with the University and asked the Rector to agree to one of the options before the meeting of the constituent assembly took place (see paragraph 13 above). The applicant also referred to several existing problems at the University (point 8 of the email) and informed the Rector of his intention to inform the members of the assembly about the problems if no agreement was reached (point 10 of the email). The applicant’s employer considered that the above email amounted to serious misconduct, a finding that was upheld by the domestic courts. The Court considers that, even before entering into an analysis as to whether there was interference with