50 101(2) With regard to the alleged violation of Article 13 represented by the conviction under criminal law and by the fact that Mr. Mauricio Herrera Ulloa was found guilty on four counts of the crime of publishing offenses constituting defamation, the Commission wrote that: a) When it imposed criminal penalties on Mr. Mauricio Herrera Ulloa in order to protect the honor and reputation of Mr. Przedborski, Costa Rica’s honorary consul, the State caused a chilling effect on freedom of expression, silencing the publication of news on matters of public interest that involve public officials. This is not the protection of reputation and honor of which Article 11 of the Convention speaks; b) the criminal laws on defamation, calumny and insult in Costa Rica serve a legitimate purpose; however, Article 13 of the Convention is violated when conduct involving public issues is penalized, as there is no pressing social need that justifies the criminal penalty. Enforcement of domestic privacy laws must conform to international standards, which require a proper balance between protection of privacy and honor and protection of freedom of expression; c) the State must abstain from censoring information regarding actions carried out by public officials or by private individuals voluntarily involved in public affairs when those actions are a matter of public interest. Such figures are expected to show greater tolerance for criticism, which implies that the degree of protection of privacy and reputation that public figures enjoy is not the same as the private citizen’s; d) Mr. Mauricio Herrera Ulloa provoked public debate about Mr. Przedborski, but the liabilities that the State subsequently imposed on him go well beyond the limits of Article 13(2) of the Convention; e) the criminal laws on defamation, offense and calumny were used to silence criticism of a public official and to censor the publication of articles related to his alleged illicit activities while in office, which is a violation of the Convention; f) the articles published in the European press concerning the alleged illicit activities of Costa Rica’s honorary consul, Mr. Przedborski, are of great public interest both in Costa Rica and in the international community; g) the standard the State applied in Mr. Herrera Ulloa’s conviction under Article 152 of the Penal Code, which criminalizes defamation, was based on objective rather than subjective honor; applying that standard, it criminally penalized someone who did “not take proper care to refrain [from publishing] when one is unsure whether the facts are correct.” This standard is an impediment to the free flow of ideas and opinions and flies in the face of international jurisprudence; h) “[f]reedom of expression is one of the most effective ways of denouncing and corroborating, through debate and a broad exchange of information and ideas, alleged acts of corruption attributable to State entities and State officials;”