In March 2017, the Landgericht Würzburg, a First Instance Court in Germany, refused to grant an injunction forcing Facebook to take down a selfie showing the Claimant, a Syrian refugee, with the German Chancellor Angela Merkel which showed up in anonymous posts on Facebook, falsely accusing him of taking part in several terrorist attacks in Berlin in 2016. The Court reasoned that Facebook was not the perpetrator nor a participant in the alleged defamation of the Claimant and had not in any way manipulated the content, which would have made it legally responsible for the distribution. The Court also said that, under the European Union's electronic commerce rules (implemented in Germany's Telemedia Law, Telemediengesetz) Facebook, as a ‘hosting provider' was not obliged to ‘proactively' search for and remove content unless the content is reported and is clearly unlawful. Following the report, Facebook had used geo-blocking to prevent access within Germany and Austria which was a sufficient measure for the handling of reported unlawful content.