a sentence of this nature may also constitute an infringement of freedom of expression pursuant to Article 13 of the Convention. This was the situation in this case. 12 11. Secondly, and based on the above, the Court determined that, as a measure of reparation, the State should adopt legislative and other measures in order to make its domestic law compatible with the obligations established in the judgment. In particular, the State authorities had to carry out a control of conventionality to prevent the criminal law that protects honor from being applied in cases such as that of Mr. Palacio Urrutia. Additionally, legislative measures should be adopted so that criminal proceedings are not used by public officials to claim protection of their honor in cases where speeches of public interest were made that could have constituted insults or slander against them when they were carrying out their duties. This reparation measure, although it is applicable only in this specific case, is the logical consequence of criminal sanctions being outside the convention in the assumption analyzed in the case. 13 It is a solution that the judgment proposes in this specific case, but that must serve as a basis for actions that States could carry out in the future to avoid incurring international responsibility. 12. With the above in mind, we will now delve into two aspects that, although they have already been addressed in the previous paragraphs, are of special relevance for the future of the protection of freedom of expression in the region, 1) the importance of the anti-SLAPP measures, and 2) the scope of the protection of freedom of expression in the case of speeches of public interest. II. ANTI-SLAPP MEASURES: AN EFFECTIVE PRACTICE FOR THE PROTECTION OF FREEDOM OF EXPRESSION 13. The term “SLAPP” is an acronym for the expression “Strategic Lawsuit Against Public Participation”. This term refers to legal actions, whether of a criminal or civil nature, that are filed not to vindicate a just legal claim by a person whose honor or good name has been affected, but to punish or harass the defendant for participating in public life. Defendants facing so-called “SLAPP lawsuits” may include journalists and traditional media organizations, but also individuals and companies in other sectors who express opinions on issues of public interest, in the media, marketing, or any other form of participation in the marketplace of ideas. 14. The “strategy” of a SLAPP lawsuit is to burden the defendant with litigation costs so burdensome that they desist, cease or retract their speech, or face the threat of jail time or monetary damages so high that produce an effect of self-censorship and retraction of a statement. Given this, in some latitudes the creation of "anti-SLAPP" laws has been promoted. These laws seek to deter SLAPP lawsuits by increasing the legal protections available to defendants. These laws allow the defendants a remedy to dismiss lawsuits that lack legal basis, or that seek to indirectly censor those who issue statements that make a certain person or sector uncomfortable (such as a government official or a business group), especially when these issues include criticism of the government and are matters of public interest. 15. The Ontario legislation is a relevant example of the type of provisions that have been made to combat the SLAPP. In 2015, in an effort to address lawsuits aimed at silencing or Cf. Palacio Urrutia et al. v. Ecuador. Merits, Reparations and Costs. Judgment of November 24, 2021, par. 111-127. 12 Cf. Palacio Urrutia et al. v. Ecuador. Merits, Reparations and Costs. Judgment of November 24, 2021, par. 177-182. 13 4

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