OOO MEMO v. RUSSIA JUDGMENT business reputation of a citizen are accordingly applicable to the protection of the business reputation of a legal person”. On 1 October 2013 the new amendments to Article 152 entered into force, expanding it to eleven paragraphs instead of seven. Paragraph 7 became paragraph 11 and was amended to read as follows: “[p]rovisions of this Article on the protection of business reputation of a citizen, except for the provisions on compensation for non-pecuniary damage («моральный вред»), are respectively applicable to the protection of business reputation of a legal person.” 20. At the material time, there was no domestic courts’ jurisprudence explaining whether a public authority could bring claims to protect its business reputation under Article 152 of the Civil Code of the Russian Federation. 21. Pursuant to Ruling no. 16 of 15 June 2010 by the Plenary Supreme Court of Russia, in cases concerning regulations in respect of freedom of expression and mass media outlets, courts are required to strike a balance between their rights and the rights of others or other constitutional values. The question of an alleged abuse of media freedom should be decided by taking into account the wording of the article and the context in which the impugned statements were made, together with the purpose, genre and style of the article and whether the statements could be deemed to constitute an expression of opinion in the field of political discussion or to draw attention to the discussion of socially significant issues. II. COUNCIL OF EUROPE MATERIALS 22. The Report on Honouring of obligations and commitments by the Russian Federation by the Committee on the Honouring of Obligations and Commitments by Member States of the Council of Europe (Monitoring Committee) of the Parliamentary Assembly of the Council of Europe of 3 June 2005 (doc. 10568) stated, in so far as relevant, as follows: “392. ... the possibility of filing lawsuits against media and journalists by public authorities should be abolished as the latter per se cannot possess any dignity, honour, or reputation. 393. Therefore, we urge the Russian authorities to reform its defamation legislation, inter alia: ... to rescind additional defamation protection for public officials, to introduce a clear ban on public bodies to institute civil proceedings in order to protect their ‘reputation’ (without hindrance to the right of public officials to litigate in their private capacity), to clearly establish that no one should be liable under defamation law for the expression of an opinion (‘value judgements’), to prioritise non-pecuniary forms of redress over pecuniary remedies, and to enhance protection of journalists’ sources of information.” 23. Human Rights Comment by the Council of Europe Commissioner for Human Rights “Time to take action against SLAPPs” [Strategic Lawsuits against Public Participation] of 27 October 2020 reads, in so far as relevant, as follows: 6