the prohibition of any monopoly with respect to them, whatever form it takes, and the guarantee of protection of journalists’ freedom and independence.” 144 93. In this sense, in view of the importance of media pluralism for the effective guarantee of the right to freedom of expression, and taking into account the provisions of Article 2 of the Convention, the Court considers that States are internationally obliged to establish laws and public policies that democratize access and guarantee the pluralism of media or information in the different areas of communication, such as, for example, the press, radio, and television. 145 This obligation includes the duty of States to establish adequate measures to prevent or limit the existence and formation of monopolies and oligopolies. However, the Court warns that the adoption of measures to guarantee pluralism in the media must be achieved on the basis of full respect for the American Convention, such that States must refrain from engaging in conduct that affects human rights, such as subjecting people to criminal proceedings without guarantees of due process, or carrying out direct or indirect acts that constitute undue restrictions on the freedom of expression for the media or their journalists. 94. Furthermore, the Court has highlighted that the professional exercise of journalism cannot be differentiated from freedom of expression, on the contrary, both are obviously intertwined, since the professional journalist is not, nor can be, anything other than a person who has decided to exercise freedom of expression in a continuous, stable and remunerated way. 146 In this regard, the Court has considered that, for the press to be able to develop its role of journalistic control, it must not only be free to impart information and ideas of public interest, but it must also be free to gather, collect and evaluate this information and ideas. This implies that any measure that interferes with the journalistic activities of people who are fulfilling their role will inevitably obstruct the right to freedom of expression in its individual and collective dimensions. 147 95. In relation to the above, the Court considers that the recurrence of public officials resorting to judicial channels to file lawsuits for crimes of slander or insult, not with the objective of obtaining a rectification but to silence the criticisms made regarding their actions in the public sphere, constitutes a threat to freedom of expression. This type of process, known as "SLAPP" (strategic lawsuit against public participation), constitutes an abusive use of judicial mechanisms that must be regulated and controlled by the States, with the aim of allowing effective exercise of freedom of expression. In this regard, the Human Rights Council has expressed its concern in the face of the strategic recourse to justice, “by business entities and individuals using strategic lawsuits against public participation to exercise pressure on journalists and stop them from critical and/or investigative reporting”. 148 96. This Court also considers that media pluralism and diversity constitute substantial requirements for an open and free democratic debate in society. This requires the following: (A) on the part of the State, compliance with the duty to respect and adopt decisions and policies that guarantee the free exercise of freedom of expression and 144 Advisory Opinion OC-5/85, supra, par. 34. 145 Cf. Case of Granier et al. (Radio Caracas Televisión) v. Venezuela, supra, par. 145. Cf. Advisory Opinion OC-5/85, supra, par. 72 to 74, and Case of Bedoya Lima et al. v. Colombia, supra, par. 107. 146 147 Cf. Case of Bedoya Lima et al. v. Colombia, supra, par. 107. United Nations Human Rights Council. The safety of journalists. Resolution approved October 6, 2020, A/HRC/45/L.42/Rev.1, Preamble. 148 34