16.
Lastly, the Respondents’ preliminary response noted that the Cyber Department also acts
to protect the integrity of Knesset elections. Thus, for example, in the last elections (for the 21st
and 22nd Knessets), which took place after the Department was established, it was agreed – with
the joint consent of the Central Elections Committee and the Attorney General – that reports would
be sent to internet platform operators in regard to accounts of computer-generated fictitious users
(“bots”), particularly when the identity of the person operating them (if there is one) is unknown,
and in regard to fraudulent user accounts or human impersonators. All of the above was carried
out in special circumstances and under restrictive conditions established “with great caution”. It is
important to note in this regard that in all that concerns voluntary enforcement actions connected
to the election process, the Department’s referrals concern technological actions prohibited by the
criminal law, and not publications that, by virtue of their content, amount to prima facie offenses,
and for the enforcement of restraining orders by virtue of sec. 17B of the Election (Means of
Propaganda) Law, 5719-1959.
17.
There would not appear to be any disagreement among the parties as to the dimensions and
effectiveness of the activities of the Cyber Department. As noted in the Cyber Department’s
reports, upon which the parties rely: in 2016, the Department sent 2,241 reports, regarding which
76.5% of the publications were removed (in whole or in part); in 2017, reports were sent
concerning 12,351 publications, regarding which 88% of the publications were removed; in 2018,
reports were sent concerning 14,283 publications, of which some 92% of the reported publications
were removed; in 2019, 19,606 reports were sent, regarding which some 90% of the reported
publications were removed. It should be noted, as the Petitioners argue in their response, that it
cannot be inferred from this that the data reflects the number of reports or requests for removal of
content, inasmuch as it is possible that each said report comprised more than one link to harmful
content (in fact, the 2015 Summary Report notes that, at times, each such report includes tens and
even hundreds of links).
The above data also demonstrate the widening of the phenomenon of prohibited content on
the networks.
As for the identity of the internet platform operators to whom the Respondents send
requests – the Cyber Department’s reports show that in 2018, 87% of the reports were sent to
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