First

submission
Turtonias prosecution of Peaps under the IA violates his FOE. Under this submission, I have two points:
First point. The prosecution fails to satisfy the 3-part test of Article 19 of the ICCPR.
Second. Assuming without conceding that the IA is valid, Peaps did not violate Section 1 (b) of the law.
For my first point, the prosecution of Peaps under the IA fails the standards provided by the 3-part test.

First, the prosecution and the IA are not prescribed by law.
To be prescribed by law, the IA must be sufficiently precise in its language, and therefore foreseeable.
Peaps is prosecuted and convicted under Section 1 (b) of the IA.
Applicants submit that Peaps could not have reasonably foreseen that he would be liable under these
provisions. To assist this Court, I shall illustrate two cases: Chipenzi and Article 373 of Mexican Penal
Code. In fact, it is so vague that the even the application of the standard knowledge cannot be properly
determined if it is applied to the spreading of false information or to the manner of incitement.

Second, the prosecution does not pursue a legitimate state aim.
Restriction on the ground of public order requires that there must be an actual danger to prevent. In the
case of, Brandenburg v. Ohio, it must direct an imminent lawless action. With the post of Peaps, such was
not present.

Third and lastly, the prosecution is not necessary in a democratic society because it does not
address a pressing social need. There is no direct connection with the post of Peaps and the violence that
ensued afterwards.

Second point. Assuming, but not conceding that the the IA is valid, Peaps did NOT.
First. Applicants submit that Peaps should not be liable because the post was never proven to be
false. Onus probandi incumbit actori. NY times v. Sullivan.

Second submission
Turtonias prosecution of Scoops under the IA violates Article 19 of the ICCPR.
Under this submission, I have two points:
First, the prosecution fails the three-part test.
Second, in any case, Scoops did not violate the IA.

For my first point, As applied to Scoops, the prosecution under the IA fails the three-part test.
Applicants would like to emphasize on the point that the IA does not pursue a legitimate state aim.
Bjork v. Iceland. Under the public figure doctrine, Kola is a public figure whose activities pertaining to her
use and abuse of power are essentially of public interest.
Applicants submit that the IA is not necessary in a democratic society because it is not the least intrusive
measure. Arbiters of truth.
Applicants also reiterate our earlier arguments that the post is protected political speech that contributes
to public debate as it concerns national security.

For my second point, Scoops did not violate the IA.
Assuming, without conceding that Peaps post is unlawful, Scoops immune from liability under
Section 3 of the IA.
First point, Scoops did not have actual knowledge of infringing nature of the post and was never
properly notified, legally speaking.
Second point, Scoops expeditiously remove the post upon the request of Kola, despite not having
able to properly assess its infringing nature.
Delf v. Estonia. UK and Denmark OSPs online evaluation period.