NISKASAARI AND OTAVAMEDIA OY v. FINLAND JUDGMENT 11 reputation or rights of others”. It noted that in such cases the Court may be required to verify whether the domestic authorities struck a fair balance when protecting two values guaranteed by the Convention which may come into conflict with each other, namely, on the one hand, freedom of expression protected by Article 10 and, on the other, the right to respect for private life enshrined in Article 8 (see Axel Springer AG v. Germany [GC], no. 39954/08, § 84, 7 February 2012; and MGN Limited v. the United Kingdom, cited above, § 142). 49. In Von Hannover v. Germany (no. 2) [GC], nos. 40660/08 and 60641/08, §§ 104-107, ECHR 2012) and Axel Springer AG v. Germany [GC] (cited above, §§ 85-88), the Court defined the Contracting States’ margin of appreciation and its own role in balancing these two conflicting Convention interests. The Court went on to identify a number of criteria as being relevant where the right to freedom of expression is to be balanced against the right to respect for private life (see Von Hannover v. Germany (no. 2) [GC], cited above, §§ 109-113; and Axel Springer AG v. Germany [GC], cited above, §§ 89-95), namely: (i) contribution to a debate of general interest; (ii) how well-known is the person concerned and what is the subject of the report; (iii) prior conduct of the person concerned; (iv) method of obtaining the information and its veracity; (v) content, form and consequences of the publication; and (vi) severity of the sanction imposed. Although this will usually represent the best manner of ensuring Convention compliance, it is not as such necessary that the national authorities, notably the courts, should make express reference to the Convention or cite this Court’s case-law, provided that in substance, be it in terms of national law, they sufficiently weigh in the balance, on the basis of the relevant criteria, the two conflicting Convention interests. Where the balancing exercise between the conflicting interests attaching to privacy and media freedom has been undertaken by the domestic courts in conformity with the criteria laid down in the Court’s case-law, the Court “would require strong reasons to substitute its own view for that of the domestic courts” (see, for example, Von Hannover v. Germany (no. 2) [GC], cited above, § 107). 50. Turning to the facts of the present case, it is to be noted that the first applicant was charged, prosecuted and convicted of defamation in his capacity as a journalist and that he was ordered, together with the applicant company, to pay damages and costs to the complainant who is also a journalist by profession. 51. The first applicant was convicted by the Appeal Court for having criticised the complainant on two separate internet discussion sites and in an article published in Seura magazine by calling him a liar and by accusing