3 10. The plurality of the media may be impaired by a direct action or intervention of the State, as indicated by the facts of this case. However, the Court clarified that violations may also occur without direct State intervention, as this judgment clearly reveals.13 In this regard, the Court emphasized criteria established in its consistent case law, indicating that “[t]his may occur, for example, when, owing to the existence of monopolies or oligopolies in the ownership of the media, a practice is established of ‘mechanisms aimed at preventing the communication and circulation of ideas and opinions.’”14 Thus, the Court endorsed the criteria contained in the Declaration of Principles on freedom of expression and incorporated this, establishing as an interpretive standard of international law that “[m]onopolies or oligopolies in the ownership and control of the communication media must be subject to anti-trust laws, as they conspire against democracy by limiting the plurality and diversity which ensure the full exercise of people’s right to information.”15 11. In keeping with the right to plurality of the media and news, the Court recalled the positive obligations of the States derived from this right and that other international courts have already determined with precision. This was clearly established by the European Court of Human Rights “in the case of Centro Europa 7 S.R.L. and Di Stefano v. Italy (2012), [in which it] indicated that, in addition to the negative duty of non-interference, the State has a positive obligation to put in place an appropriate legislative and administrative framework to guarantee effective pluralism and diversity. Also, when determining that the State had a positive obligation to ensure an appropriate legislative and administrative framework to guarantee effective pluralism, the Court referred to Recommendation CM/Rec(2007)2 of the Council of Ministers on media pluralism and diversity of media content, reaffirming that: “In order to protect and actively promote the pluralistic expressions of ideas and opinions as well as cultural diversity, member States should adapt the existing regulatory frameworks, particularly with regard to media ownership, and adopt any regulatory and financial measures called for in order to guarantee media transparency and structural pluralism as well as diversity of the content distributed.”16 12. In the context of this standard of analysis, and reiterating what it had already established in its consistent case law, the Inter-American Court strongly emphasized the positive obligation; in other words, the obligation of the States to guarantee the pluralism of the media: “the States have the international obligation to adopt the measures necessary ‘to give effect to’ the rights and principles established in the Convention, as stipulated in Article 2 of this inter-American instrument, and to this end they must establish laws and public policies that guarantee the pluralism of information and news on the different media, such as the press, radio and television.”17 13. Consequently, as a result of the international obligation of the States to guarantee the plurality of the media, they must adopt “the necessary measures,” which include “laws and public policies” that guarantee “the pluralism of information and news on the different media, such as the press, radio and television.” Thus, the enumeration of the possible ways to comply with this international obligation includes a key guiding concept which is that of “the necessary measures,” and the mention of “laws and public policies” should be understood as one of several ways available to comply with this general obligation. As in the case of the different international 13 Case of Granier et al. (Radio Caracas Televisión) v. Venezuela, para. 143. 14 Case of Granier et al. (Radio Caracas Televisión) v. Venezuela, para. 143. 15 Case of Granier et al. (Radio Caracas Televisión) v. Venezuela, para. 143. 16 Case of Granier et al. (Radio Caracas Televisión) v. Venezuela, para. 145, footnote 214. 17 Case of Granier et al. (Radio Caracas Televisión) v. Venezuela, para. 145.