ENGELS v. RUSSIA JUDGMENT or terrorist material. The requirement to take it down had breached principle 8 in section 3 of the Information Act, which prohibited preferential treatment of particular information technologies. The second part of section 15.1(5), on which the interference had been based, did not meet the foreseeability requirement. It allowed courts to pronounce any content illegal, without specifying the nature or category of such content. Website owners, such as the applicant, could not have known in advance whether a particular publication would lead to a take-down order or blocking of the website. The legal framework governing blocking orders lacked precision and permitted wholesale blocking of access to a website on the grounds that it contained some offending material. The applicant pointed out that Russian legislation provided website owners with no safeguards against abuse. (c) Third-party interveners 21. The UN Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression, an independent expert mandated by the Human Rights Council to report on the extent, nature and severity of restrictions and violations of freedom of expression, submitted that individuals should be allowed to enjoy freedom of expression in online space to the same extent as they enjoyed it offline. States frequently adopted anti-extremism laws that were so broad as to give authorities excessive discretion to restrict online expression, contrary to the lawfulness requirement. Such legislation prioritised restrictions on, rather than protection of, free expression as the primary State responsibility, and failed to define precisely limitations on online expression and justifications for those limitations. The wholesale blocking of websites rarely, if ever, satisfied the criteria for permissible limitations on freedom of expression, taking into account that permissible restrictions should be content-specific and should not target websites solely because they were critical of the government or political system. 22. ARTICLE 19, a global campaign for freedom of expression, the Electronic Frontier Foundation, a legal and policy organisation safeguarding privacy in the digital world, Access Now, a global civil-society organisation defending the digital rights of users at risk, and Reporters without Borders, an organisation defending freedom of the press, emphasised that any law providing for blocking powers should specify the categories of content that could be lawfully blocked. The blocking of information about virtual private networks (VPN) and similar technologies could never be justified because such technologies were contentneutral and blocking interfered with access to all content which might be obtained using those technologies. Accordingly, the blocking of such technologies was inherently incapable of being defined by reference to categories of legitimately proscribed content. Even where blocking was permissible, the law should provide for the following minimum standards: (i) blocking should be ordered by a court or an independent adjudicatory body; (ii) interested parties should be given the opportunity to intervene in proceedings in which a blocking order was sought; (iii) all victims of blocking orders should have the right to challenge, after the fact, the blocking order; and (iv) anyone attempting to access the blocked website should be able to see the legal basis and reasons for the blocking order and information about avenues of appeal. 23. The European Information Society Institute, a Slovakia-based non-profit organisation focusing on high-technology law, submitted that any blocking 6