OOO FLAVUS AND OTHERS v. RUSSIA JUDGMENT though the media registration certificate issued to grani.ru had not been formally revoked. The Russian authorities’ demands on the applicants had been unforeseeable and inconsistent. The Prosecutor General had requested the blocking of entire websites on account of calls for participation in unauthorised mass gatherings. A copy of the Prosecutor General’s request had not been communicated to the applicants. Roskomnadzor’s initial notifications had not specified which content had been deemed problematic. In subsequent proceedings, Roskomnadzor had advanced the argument that the websites featured calls for engaging in extremist activities. Since the applicants had not been notified about specific material that contained prohibited information, they had not been able to remove such content and avoid the blocking measure. Contradictory and ever-changing demands by the authorities had not allowed website owners to foresee whether the publication of a particular article would lead to a blocking measure and whether the authorities would block only that article or the entire website. 23. The Russian law did not provide owners of online media with any procedural safeguards capable of protecting them against arbitrary interference. There was no prior review of the blocking measure by a judge or other independent decision-making body. The decision was made by officers of the Prosecutor General’s office without any input from media experts. The law did not provide for a judicial review of that decision prior to its implementation, or an assessment of its necessity and proportionality. In practice, it afforded unrestricted discretion to the Prosecutor General in blocking matters, which was contrary to the rule of law in a democratic society. 24. The applicants claimed that the true objective which the Russian authorities had pursued by blocking access to their websites had been to prevent dissemination of independent viewpoints on important social and political events, and actions by the opposition and civic movement. Even assuming that the authorities had genuinely pursued a legitimate aim of safeguarding public order and the websites had contained illegal content, no attempts had been made to achieve a balance between the applicants’ right to impart information and the need to maintain public order. Throughout the many years of their existence, the applicants’ websites had published tens of thousands of articles on social and political issues, and those archives had become inaccessible overnight to users in Russia (the applicants referred to the Court’s position on the importance of Internet archives in Times Newspapers Ltd v. the United Kingdom (nos. 1 and 2), nos. 3002/03 and 23676/03, § 45, ECHR 2009). Blocking access to websites of popular online media, including their vast archives, in order to ban a few articles – or one image in the case of www.kasparov.ru – was clearly disproportionate. It had a considerable chilling effect on journalists and civil activists who used online media to voice critical opinions in a public discussion about the state of affairs in Russia. 8