Mathias Holvoet | University of Amsterdam (original) (raw)

Papers by Mathias Holvoet

Journal of International Criminal Justice, 2022

In the context of international crimes, falsehoods — ranging from selective reporting of facts, d... more In the context of international crimes, falsehoods — ranging from selective reporting of facts, deliberate mischaracterization of events and adversaries, or even plain fabrication and lies — constitute a breeding ground in which incitement to commit violence can thrive. While disseminating such falsehoods does not constitute a direct call to commit physical violence, it nevertheless sows the seeds for mass atrocities. This article considers the outer limits of International Criminal Law (ICL) — defined by the principle of culpability — by enquiring whether campaigns of disinformation in the context of mass atrocities could ever give rise to individual responsibility. On the basis of the Fritzsche, Gvero and Mbarushimana cases, liability for disseminating disinformation might in principle be engaged before, during and even after the commission of such crimes. Recent concerns about the role of Facebook in Myanmar also pose the question whether social media companies or their personnel...

Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation h... more Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation have brought out exciting but difficult questions on the exact scope of crimes against humanity. Defence lawyers have challenged the jurisdiction of the ICC on the grounds that the post-electoral violence in Kenya did not constitute crimes against humanity. This issue has not only divided the Prosecution

International Criminal Law Review, 2020

Journal of International Criminal Justice , 2022

In the context of international crimes, falsehoods-ranging from selective reporting of facts, del... more In the context of international crimes, falsehoods-ranging from selective reporting of facts, deliberate mischaracterization of events and adversaries, or even plain fabrication and lies-constitute a breeding ground in which incitement to commit violence can thrive. While disseminating such falsehoods does not constitute a direct call to commit physical violence, it nevertheless sows the seeds for mass atrocities. This article considers the outer limits of International Criminal Law (ICL)-defined by the principle of culpability-by enquiring whether campaigns of disinformation in the context of mass atrocities could ever give rise to individual responsibility. On the basis of the Fritzsche, Gvero and Mbarushimana cases, liability for disseminating disinformation might in principle be engaged before, during and even after the commission of such crimes. Recent concerns about the role of Facebook in Myanmar also pose the question whether social media companies or their personnel may be liable for amplifying disinformation campaigns. Yet, overall, these cases show the unease of ICL in criminalizing disinformation contributing to atrocity crimes.

In 2009 the Palestinian Government, a non-State Party, lodged a Declaration (the "2009 Declaratio... more In 2009 the Palestinian Government, a non-State Party, lodged a Declaration (the "2009 Declaration") with the International Criminal Court (ICC) under Article 12(3) of the ICC Statute accepting the exercise of jurisdiction of the ICC for 'acts committed on the territory of Palestine since 1 July 2002.' 1 The purpose of the Declaration was to invite the Office of the Prosecutor (OTP) of the ICC to investigate claims of possible war crimes and crimes against humanity allegedly committed by Israeli Defense Forces (IDF) during the 2008-2009 Operation Cast Lead, as documented by the Goldstone Report. 2 However, in April 2012 the OTP declined to accept jurisdiction. It justified its decision based on the fact that Palestine had, at the time, only the status of an 'Observer Entity' at the United Nations (UN). For the OTP, it was up to the UN General Assembly (UNGA) or the Assembly of State Parties (ASP) of the ICC to determine whether Palestine could qualify as a state for the purposes of the ICC Statute. Until such determination was made, the OTP would be unable to proceed. 3

Fragmentation and Integration in Human Rights Law. Users' Perspectives, 2018

This contribution aims to better understand how and why International Criminal Law (ICL) is plura... more This contribution aims to better understand how and why International Criminal Law (ICL) is pluralistic and how this pluralism is at least partly the result of the contesting actions, interests and backgrounds of the various ICL users and the contexts in which they operate. Our hypothesis is that the adoption of a users’ perspective helps in understanding ICL pluralism. After a discussion of the various dimensions of pluralism in ICL, this chapter identifies the most important ICL users. Subsequently, through the example of the rules on policy requirement in the definition of crimes against humanity, the relevance of the users’ perspective will be demonstrated. The analysis will show how both the position and agenda of the user and the user’s context have a large impact on the application and interpretation of substantive ICL definitional elements such as the policy requirement. Finally, the chapter will argue, through the example
of the case against the former Chadian dictator Hissène Habré, that this pluralism can be overcome, as ICL is also often a collaborative and ingenious effort on the part of various users which are able to align their interests in the pursuit international criminal justice.

la CVDW. Liber Amicorum Chris Van den Wyngaert, 2017

International Criminal Law Review, 2020

This editorial aims to critically engage with some of the arguments made by the different authors... more This editorial aims to critically engage with some of the arguments made by the different authors participating in the special issue 'Introducing the Special Issue ‘Critical Perspectives on the Law and Politics of the Kosovo Specialist Chambers and the Specialist Prosecutor’s Office’ with regards to the many challenges the spo and the ksc are and will be facing as well as with the constructive suggestions that are made for both the SPO and KSC to attain at least some measure of success. The analysis will revolve around four different themes: first, the narrow mandate of the spo and ksc as being only competent to investigate, prosecute and adjudicate crimes committed by the Kosovo Liberation Army (kla), given how the scope of the Court has been circumscribed under Article 2(2) of the Law (section 1); the broader purposes some have claimed the spo and ksc ought to achieve, such as nurturing interethnic reconciliation between Kosovar Albanians and Kosovar Serbs (section 2); the distance between the spo and the ksc and Kosovo given the spo and ksc’s location in the Hague, its purely international staff and its application of international criminal legal concepts and procedures that are foreign to Kosovan criminal law and procedure (section 3) and, lastly, the mounting criticism the spo in particular is facing because of the long wait for the issuance of its first indictments (section 4).

International Crimes Database

Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation h... more Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation have brought out exciting but difficult questions on the exact scope of crimes against humanity. Defence lawyers have challenged the jurisdiction of the ICC on the grounds that the post-electoral violence in Kenya did not constitute crimes against humanity. This issue has not only divided the Prosecution and the defence, but also the judges of the Pre-Trial Chamber in the Kenya Situation and leading scholars on the law of crimes against humanity. The main bone of contention, which will form the subject of this brief, has been a specific contextual element in the ICC Statute definition, namely the requirement of a State or organisation behind a policy to commit crimes against humanity. The first part of this brief will give an appraisal on the emerging jurisprudence on the concept of an organisation pursuing a policy to commit crimes against humanity. Indeed, especially with the reference to the term 'organisational', the Rome Statute introduced a novel and extremely cryptic element to the definition of crimes against humanity. While no one disputes that State actors are the perpetrators par excellence of crimes against humanity and the notion of a 'policy' has been given content by jurisprudence of the ICTY, the question to what entities the term 'organisational' exactly

Tilburg Law Review

This contribution will focus on the facet of International Criminal Justice where the inuence of ... more This contribution will focus on the facet of International Criminal Justice where the inuence of global law is the most apparent, namely the hybrid or internationalized criminal tribunals. Since many of these tribunals have closed their doors or are in the advanced stage of the proceedings, the time is ripe for a preliminary evaluation. Furthermore, the future necessity and viability of hybrid tribunals will be assessed, both for crimes that fall within and without the jurisdictional regime established by the International Criminal Court (ICC).

International Criminal Law Review

In 2012, the International Criminal Court (ICC) celebrates its ten-year anniversary since its est... more In 2012, the International Criminal Court (ICC) celebrates its ten-year anniversary since its establishment. It is fair to say that the current age of the Court reflects its present maturity. At the time of writing, the Court has finally rendered its first verdict, by condemning the Congolese warlord Thomas Lubanga for the conscription of child soldiers after a rather wobbly trial that took 6 years. In May 2011, the Court faced another unprecedented challenge. Four witnesses transferred from the Democratic Republic of the Congo (DRC) to testify in the Lubanga and Katanga & Ngudjolo Chui (hereinafter: Katanga) trials, applied for asylum in the Netherlands. This matter, which was not anticipated in the Statute or secondary sources of ICC law, raises issues concerning the cooperation between the ICC, the Netherlands as host state and the DRC, and raises intriguing questions about the interaction of International Criminal Law and International Refugee Law.

Journal of International Criminal Justice

63 years after the adoption of the Refugee Convention, much uncertainty persists about the exact ... more 63 years after the adoption of the Refugee Convention, much uncertainty persists about the exact interpretation of the evidentiary 'serious reasons for considering' standard of proof to be applied for exclusion decisions under Article 1(F)(a) of the Refugee Convention. This uncertainty is to be deplored, because it creates unpredictability and puts allegedly criminal asylum seekers in an unequal position vis-à-vis each other, which may result in 'forum shopping'. To counter further fragmentation, the author argues that national courts and authorities, when deciding in cases of exclusion, should draw upon the 'reasonable grounds to believe' threshold for the issuing of an arrest warrant or summons to appear in the Rome Statute, which, prima facie, can be equated with the 'serious reasons for considering' standard.

Criminal Law Forum

In August 2015, the Assembly of Kosovo established the Specialist Chambers (SC) and the associate... more In August 2015, the Assembly of Kosovo established the Specialist Chambers (SC) and the associated Specialist Prosecutor’s Office (SPO) with the mandate of prosecuting international and trans-boundary crimes committed during and after the 1998–1999 Kosovo armed conflict. The objectives in this article assessing the SC are twofold. First, the aim is to provide a critical account of the process that led to the establishment of the SC. It will be inquired whether the decision to create yet another international criminal judicial institution was, from the perspective of judicial economy, the most defensible one. Arguments could be made for instance that the European Union Rule of Law Mission (EULEX) and the International Criminal Tribunal for the Former Yugoslavia (ICTY) would have been better-equipped institutions, given their expertise of the conflict and patterns of crimes under the jurisdiction of the SC. Secondly, the article will delve into some issues of substantive law of particular interest for the SC, namely the applicable law of crimes against humanity and the provisions in the Law establishing the SC under which to prosecute and adjudicate the practice of organ trafficking.

Drafts by Mathias Holvoet

Kosovo and Transitional Justice The Pursuit of Justice After Large Scale Conflict, 2021

This chapter analyses the International Criminal Tribunal for the former Yugoslavia’s (ICTY’s) in... more This chapter analyses the International Criminal Tribunal for the former Yugoslavia’s (ICTY’s) involvement in the investigation, prosecution and adjudication of international crimes committed during the 1998-1999 Kosovo war, as well as the reception and impact of the ICTY’s work in the societies involved. Such an inquiry is timely and warranted, as Kosovo has often been overlooked when the ICTY’s legacy is assessed. At a 2010 ICTY Legacy Conference, the ICTY President at the time Patrick Robinson acknowledged:

'One issue that was noted in the conference as a failing was the absence of Kosovo, resulting from a variety of factors…many asked how the Tribunal could consider its legacy vision in the region without hearing the voice of Kosovo. The Tribunal shares the concern (Robinson, 2011, p. 268).'

Ten years later, the lack of focus on Kosovo in ICTY legacy discussions seems unchanged. In a recent seminal publication on the ICTY’s legacy, Legacies of the International Criminal Tribunal for the Former Yugoslavia. A Multidisciplinary Approach (Stahn et al. 2020), the preeminent focus was on the ICTY’s relation with and impact on Bosnia-Herzegovina, Croatia and Serbia. This chapter aims to begin filling this significant gap in ICTY legacy literature.

This chapter is divided in four main sections. The first two sections take a fresh critical look at the investigatory practices of the Office of the Prosecutor (OTP) of the ICTY, the exercise of prosecutorial discretion concerning indictments and charging practices as well as the judgments laid down in cases related to the Kosovo war. Section three considers the reception of the ICTY’s practice in both Serbia and in Kosovo by Kosovar Albanians and Kosovar Serbs and its impact on relations between Kosovar Albanians and Serbs and on current debates on accountability for crimes committed during the war in both Kosovo and Serbia. The point will be made in this chapter that, while mistakes were undoubtedly made by the different organs of the ICTY, they cannot be blamed exclusively for the fact that justice for crimes committed during the Kosovo war has been frustrated. To conclude, the final section contends that, even if these factors would not have been present and the Tribunal had been able to deliver comprehensive and unobstructed justice, its work would have been negatively received by the societies involved, as psychological mechanisms of identity-protective reasoning almost inevitably lead to a widespread rejection of an international criminal tribunal and its factual account by target audiences and local constituencies.

Journal of International Criminal Justice, 2022

In the context of international crimes, falsehoods — ranging from selective reporting of facts, d... more In the context of international crimes, falsehoods — ranging from selective reporting of facts, deliberate mischaracterization of events and adversaries, or even plain fabrication and lies — constitute a breeding ground in which incitement to commit violence can thrive. While disseminating such falsehoods does not constitute a direct call to commit physical violence, it nevertheless sows the seeds for mass atrocities. This article considers the outer limits of International Criminal Law (ICL) — defined by the principle of culpability — by enquiring whether campaigns of disinformation in the context of mass atrocities could ever give rise to individual responsibility. On the basis of the Fritzsche, Gvero and Mbarushimana cases, liability for disseminating disinformation might in principle be engaged before, during and even after the commission of such crimes. Recent concerns about the role of Facebook in Myanmar also pose the question whether social media companies or their personnel...

Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation h... more Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation have brought out exciting but difficult questions on the exact scope of crimes against humanity. Defence lawyers have challenged the jurisdiction of the ICC on the grounds that the post-electoral violence in Kenya did not constitute crimes against humanity. This issue has not only divided the Prosecution

International Criminal Law Review, 2020

Journal of International Criminal Justice , 2022

In the context of international crimes, falsehoods-ranging from selective reporting of facts, del... more In the context of international crimes, falsehoods-ranging from selective reporting of facts, deliberate mischaracterization of events and adversaries, or even plain fabrication and lies-constitute a breeding ground in which incitement to commit violence can thrive. While disseminating such falsehoods does not constitute a direct call to commit physical violence, it nevertheless sows the seeds for mass atrocities. This article considers the outer limits of International Criminal Law (ICL)-defined by the principle of culpability-by enquiring whether campaigns of disinformation in the context of mass atrocities could ever give rise to individual responsibility. On the basis of the Fritzsche, Gvero and Mbarushimana cases, liability for disseminating disinformation might in principle be engaged before, during and even after the commission of such crimes. Recent concerns about the role of Facebook in Myanmar also pose the question whether social media companies or their personnel may be liable for amplifying disinformation campaigns. Yet, overall, these cases show the unease of ICL in criminalizing disinformation contributing to atrocity crimes.

In 2009 the Palestinian Government, a non-State Party, lodged a Declaration (the "2009 Declaratio... more In 2009 the Palestinian Government, a non-State Party, lodged a Declaration (the "2009 Declaration") with the International Criminal Court (ICC) under Article 12(3) of the ICC Statute accepting the exercise of jurisdiction of the ICC for 'acts committed on the territory of Palestine since 1 July 2002.' 1 The purpose of the Declaration was to invite the Office of the Prosecutor (OTP) of the ICC to investigate claims of possible war crimes and crimes against humanity allegedly committed by Israeli Defense Forces (IDF) during the 2008-2009 Operation Cast Lead, as documented by the Goldstone Report. 2 However, in April 2012 the OTP declined to accept jurisdiction. It justified its decision based on the fact that Palestine had, at the time, only the status of an 'Observer Entity' at the United Nations (UN). For the OTP, it was up to the UN General Assembly (UNGA) or the Assembly of State Parties (ASP) of the ICC to determine whether Palestine could qualify as a state for the purposes of the ICC Statute. Until such determination was made, the OTP would be unable to proceed. 3

Fragmentation and Integration in Human Rights Law. Users' Perspectives, 2018

This contribution aims to better understand how and why International Criminal Law (ICL) is plura... more This contribution aims to better understand how and why International Criminal Law (ICL) is pluralistic and how this pluralism is at least partly the result of the contesting actions, interests and backgrounds of the various ICL users and the contexts in which they operate. Our hypothesis is that the adoption of a users’ perspective helps in understanding ICL pluralism. After a discussion of the various dimensions of pluralism in ICL, this chapter identifies the most important ICL users. Subsequently, through the example of the rules on policy requirement in the definition of crimes against humanity, the relevance of the users’ perspective will be demonstrated. The analysis will show how both the position and agenda of the user and the user’s context have a large impact on the application and interpretation of substantive ICL definitional elements such as the policy requirement. Finally, the chapter will argue, through the example
of the case against the former Chadian dictator Hissène Habré, that this pluralism can be overcome, as ICL is also often a collaborative and ingenious effort on the part of various users which are able to align their interests in the pursuit international criminal justice.

la CVDW. Liber Amicorum Chris Van den Wyngaert, 2017

International Criminal Law Review, 2020

This editorial aims to critically engage with some of the arguments made by the different authors... more This editorial aims to critically engage with some of the arguments made by the different authors participating in the special issue 'Introducing the Special Issue ‘Critical Perspectives on the Law and Politics of the Kosovo Specialist Chambers and the Specialist Prosecutor’s Office’ with regards to the many challenges the spo and the ksc are and will be facing as well as with the constructive suggestions that are made for both the SPO and KSC to attain at least some measure of success. The analysis will revolve around four different themes: first, the narrow mandate of the spo and ksc as being only competent to investigate, prosecute and adjudicate crimes committed by the Kosovo Liberation Army (kla), given how the scope of the Court has been circumscribed under Article 2(2) of the Law (section 1); the broader purposes some have claimed the spo and ksc ought to achieve, such as nurturing interethnic reconciliation between Kosovar Albanians and Kosovar Serbs (section 2); the distance between the spo and the ksc and Kosovo given the spo and ksc’s location in the Hague, its purely international staff and its application of international criminal legal concepts and procedures that are foreign to Kosovan criminal law and procedure (section 3) and, lastly, the mounting criticism the spo in particular is facing because of the long wait for the issuance of its first indictments (section 4).

International Crimes Database

Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation h... more Challenges to the jurisdiction of the International Criminal Court (ICC) in the Kenya Situation have brought out exciting but difficult questions on the exact scope of crimes against humanity. Defence lawyers have challenged the jurisdiction of the ICC on the grounds that the post-electoral violence in Kenya did not constitute crimes against humanity. This issue has not only divided the Prosecution and the defence, but also the judges of the Pre-Trial Chamber in the Kenya Situation and leading scholars on the law of crimes against humanity. The main bone of contention, which will form the subject of this brief, has been a specific contextual element in the ICC Statute definition, namely the requirement of a State or organisation behind a policy to commit crimes against humanity. The first part of this brief will give an appraisal on the emerging jurisprudence on the concept of an organisation pursuing a policy to commit crimes against humanity. Indeed, especially with the reference to the term 'organisational', the Rome Statute introduced a novel and extremely cryptic element to the definition of crimes against humanity. While no one disputes that State actors are the perpetrators par excellence of crimes against humanity and the notion of a 'policy' has been given content by jurisprudence of the ICTY, the question to what entities the term 'organisational' exactly

Tilburg Law Review

This contribution will focus on the facet of International Criminal Justice where the inuence of ... more This contribution will focus on the facet of International Criminal Justice where the inuence of global law is the most apparent, namely the hybrid or internationalized criminal tribunals. Since many of these tribunals have closed their doors or are in the advanced stage of the proceedings, the time is ripe for a preliminary evaluation. Furthermore, the future necessity and viability of hybrid tribunals will be assessed, both for crimes that fall within and without the jurisdictional regime established by the International Criminal Court (ICC).

International Criminal Law Review

In 2012, the International Criminal Court (ICC) celebrates its ten-year anniversary since its est... more In 2012, the International Criminal Court (ICC) celebrates its ten-year anniversary since its establishment. It is fair to say that the current age of the Court reflects its present maturity. At the time of writing, the Court has finally rendered its first verdict, by condemning the Congolese warlord Thomas Lubanga for the conscription of child soldiers after a rather wobbly trial that took 6 years. In May 2011, the Court faced another unprecedented challenge. Four witnesses transferred from the Democratic Republic of the Congo (DRC) to testify in the Lubanga and Katanga & Ngudjolo Chui (hereinafter: Katanga) trials, applied for asylum in the Netherlands. This matter, which was not anticipated in the Statute or secondary sources of ICC law, raises issues concerning the cooperation between the ICC, the Netherlands as host state and the DRC, and raises intriguing questions about the interaction of International Criminal Law and International Refugee Law.

Journal of International Criminal Justice

63 years after the adoption of the Refugee Convention, much uncertainty persists about the exact ... more 63 years after the adoption of the Refugee Convention, much uncertainty persists about the exact interpretation of the evidentiary 'serious reasons for considering' standard of proof to be applied for exclusion decisions under Article 1(F)(a) of the Refugee Convention. This uncertainty is to be deplored, because it creates unpredictability and puts allegedly criminal asylum seekers in an unequal position vis-à-vis each other, which may result in 'forum shopping'. To counter further fragmentation, the author argues that national courts and authorities, when deciding in cases of exclusion, should draw upon the 'reasonable grounds to believe' threshold for the issuing of an arrest warrant or summons to appear in the Rome Statute, which, prima facie, can be equated with the 'serious reasons for considering' standard.

Criminal Law Forum

In August 2015, the Assembly of Kosovo established the Specialist Chambers (SC) and the associate... more In August 2015, the Assembly of Kosovo established the Specialist Chambers (SC) and the associated Specialist Prosecutor’s Office (SPO) with the mandate of prosecuting international and trans-boundary crimes committed during and after the 1998–1999 Kosovo armed conflict. The objectives in this article assessing the SC are twofold. First, the aim is to provide a critical account of the process that led to the establishment of the SC. It will be inquired whether the decision to create yet another international criminal judicial institution was, from the perspective of judicial economy, the most defensible one. Arguments could be made for instance that the European Union Rule of Law Mission (EULEX) and the International Criminal Tribunal for the Former Yugoslavia (ICTY) would have been better-equipped institutions, given their expertise of the conflict and patterns of crimes under the jurisdiction of the SC. Secondly, the article will delve into some issues of substantive law of particular interest for the SC, namely the applicable law of crimes against humanity and the provisions in the Law establishing the SC under which to prosecute and adjudicate the practice of organ trafficking.

Kosovo and Transitional Justice The Pursuit of Justice After Large Scale Conflict, 2021

This chapter analyses the International Criminal Tribunal for the former Yugoslavia’s (ICTY’s) in... more This chapter analyses the International Criminal Tribunal for the former Yugoslavia’s (ICTY’s) involvement in the investigation, prosecution and adjudication of international crimes committed during the 1998-1999 Kosovo war, as well as the reception and impact of the ICTY’s work in the societies involved. Such an inquiry is timely and warranted, as Kosovo has often been overlooked when the ICTY’s legacy is assessed. At a 2010 ICTY Legacy Conference, the ICTY President at the time Patrick Robinson acknowledged:

'One issue that was noted in the conference as a failing was the absence of Kosovo, resulting from a variety of factors…many asked how the Tribunal could consider its legacy vision in the region without hearing the voice of Kosovo. The Tribunal shares the concern (Robinson, 2011, p. 268).'

Ten years later, the lack of focus on Kosovo in ICTY legacy discussions seems unchanged. In a recent seminal publication on the ICTY’s legacy, Legacies of the International Criminal Tribunal for the Former Yugoslavia. A Multidisciplinary Approach (Stahn et al. 2020), the preeminent focus was on the ICTY’s relation with and impact on Bosnia-Herzegovina, Croatia and Serbia. This chapter aims to begin filling this significant gap in ICTY legacy literature.

This chapter is divided in four main sections. The first two sections take a fresh critical look at the investigatory practices of the Office of the Prosecutor (OTP) of the ICTY, the exercise of prosecutorial discretion concerning indictments and charging practices as well as the judgments laid down in cases related to the Kosovo war. Section three considers the reception of the ICTY’s practice in both Serbia and in Kosovo by Kosovar Albanians and Kosovar Serbs and its impact on relations between Kosovar Albanians and Serbs and on current debates on accountability for crimes committed during the war in both Kosovo and Serbia. The point will be made in this chapter that, while mistakes were undoubtedly made by the different organs of the ICTY, they cannot be blamed exclusively for the fact that justice for crimes committed during the Kosovo war has been frustrated. To conclude, the final section contends that, even if these factors would not have been present and the Tribunal had been able to deliver comprehensive and unobstructed justice, its work would have been negatively received by the societies involved, as psychological mechanisms of identity-protective reasoning almost inevitably lead to a widespread rejection of an international criminal tribunal and its factual account by target audiences and local constituencies.