[because] criminal law is the most restrictive and severe means to establish liabilities for illicit behavior, taking into account that the legal framework [should] provide [legal] certainty to its citizens.”76 66. The IACHR has emphasized that provisions curtailing freedom of expression must be drafted clearly, leaving no room for interpretation. It stated that, “even if there are specific judicial interpretations of such provisions, that is not a sufficient reason for them to be overly broad. Judicial interpretations may change, or not be followed strictly, and are not general in nature.”77 67. In the case of Kimel v. Argentina, the Inter-American Court found that the statutory definition of the criminal defamation offenses of calumnia and injuria violated Articles 13 and 9 the American Convention, in relation to Articles 1.1 and 2,78 because they were overly broad and ambiguous. Later, at the supervisory stage, the Court found that the State had complied with the judgment when it amended the statutory definitions of the offenses, specifying the element of intent and defining the scope of application of the criminal provision with the aim of protecting speech concerning matters of public interest, among others.79 In addition, in the case of Usón Ramírez v. Venezuela, the Inter-American Court found that a statutory definition of the offense of “slander, offense, or disparagement of the National Armed Forces,” which failed to clearly establish the elements of the crime and did not specify the criminal intent required of the perpetrator, violated Articles 9 and 13 of the American Convention, in relation to Articles 1.1 and 2,80 because the definition of the offense was vague, ambiguous, and imprecise.81 76 I/A Court H.R., Case of Usón Ramírez v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2009. Series C No. 207, para. 55. Cfr. I/A Court H.R., Case of Kimel v. Argentina. Merits, Reparations and Costs. Judgment of May 2, 2008 Series C No. 177, para. 63; I/A Court H.R., Compulsory Membership in an Association Prescribed by Law for the Practice of Journalism (Arts. 13 and 29 American Convention on Human Rights). Advisory Opinion OC-5/85 of November 13, 1985. Series A No. 5, paras. 39-40, available at: http://www.corteidh.or.cr/docs/opiniones/seriea_05_ing.pdf; Corte I.D.H., Case of Palamara Iribarne v. Chile. Judgment of November 22, 2005. Series C No. 135, para. 79; I/A Court H.R., Case of Herrera Ulloa v. Costa Rica. Judgment of July 2, 2004. Series C No. 107, para. 120; I/A Court H.R., Case of Tristán Donoso v. Panama. Preliminary Objection, Merits, Reparations and Costs. Judgment of January 27, 2009. Series C No. 193, para. 117; IACHR. 1994 Annual Report. Chapter V: Report on the Compatibility of “Desacato” Laws with the American Convention on Human Rights. Title IV. OEA/Ser. L/V/II.88. doc. 9 rev. February 17, 1995; IACHR. Report No. 11/96. Case No. 11.230. Francisco Martorell. Chile. May 3, 1996, para. 55; IACHR. Arguments before the Inter-American Court in the Case of Ricardo Canese v. Paraguay. Reprinted in: I/A Court H.R., Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111, para. 72. a). 77 IACHR. Arguments before the Inter-American Court in the Case of Ricardo Canese v. Paraguay. Reprinted in: I/A Court H.R., Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111, paras. 72. s) - 72.u). 78 The Inter-American Court examined the drafting of Article 109, which provided that “Defamation or the false imputation of a publicly actionable crime shall be punished with imprisonment from one to three years,” and Article 110, which stated that “Any person who harms another person’s honor or reputation shall be punished with a fine from 1,500.00 to 90,000.00 pesos or imprisonment from one month to one year,” and found that, “The lack of sufficient accuracy in the criminal legislation punishing defamation” was a violation of Articles 9 and 13.1 of the American Convention. I/A Court H.R., Case of Kimel v. Argentina. Merits, Reparations and Costs. Judgment of May 2, 2008 Series C No. 177, paras. 64-67. 79 I/A Court H.R., Case of Kimel v. Argentina. I/A Court H.R., Case of Kimel v. Argentina. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of May 18, 2010, paras. 30-35, available at: http://www.corteidh.or.cr/docs/supervisiones/kimel_18_05_10_ing.pdf; Cfr. Law 26.551, enacted on November 26, 2009, available at: http://infoleg.gov.ar/infolegInternet/anexos/160000-164999/160774/norma.htm. Pursuant to this reform, the respective articles of the Argentine Criminal Code provide: Article 109: Defamation or the false imputation to a specific person of a publicly actionable crime shall be punished with a fine of three thousand (3,000) to thirty thousand pesos (30,000). In no case will speech referring to matters of public interest or matters that are not affirmative be considered a defamation crime. Article 110: Any person who intentionally harms another person’s honor or reputation shall be punished with a fine of one thousand five hundred (1,500) to twenty thousand (20,000) pesos. In no case will speech referring to matters of public interest or matters that are not affirmative be considered a defamation crime. Nor will speech that harms another person’s honor be considered a defamation crime when it is related to a matter of public interest. 80 Article 505 of the Organic Code of Military Justice in force at that time provided that: “whoever slanders, offends, or disparages the National Armed Forces or any of its units shall be subject to three to eight years in prison.” Case of Usón Ramírez v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2009. Series C No. 207, paras. 56-57. 81 I/A Court H.R., Case of Usón Ramírez v. Venezuela. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2009. Series C No. 207, paras. 56-57.