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.” 33. This is why the duty to create mechanisms other than criminal laws has been established in this regard, so that public officials may obtain a rectification or reply when their honor or good name has been harmed. This protection has a direct link to the precedent of Álvarez Ramos and can be understood as a protection for the exercise of journalism in accordance with the anti-SLAPP laws insofar as it prohibits the use of criminal law to require the protection of the honor or good name of public officials, and establishes that the civil sanctions must be proportionate. 34. This additional protection of freedom of expression – which can be especially relevant in cases in which the authorities use judicial measures to silence political opponents – excludes the possibility of a criminal sanction in certain situations and is applicable to the instant case in relation to subsequent liability under civil law. V. CONCLUSION 35. In conclusión, based on the importance of the work of journalists in relation to freedom of expression and its contribution to the democratic debate that protects and promotes the rule of law, I would like to underscore: (1) the prohibition of prior censorship; (2) the existence of subsequent liability; (3) the incompatibility with the Convention of applying criminal law to protect the honor of public officials (supra, paras. 13, 14 and 15); (4) the use of the right of rectification or reply (Art. 14 of the American Convention; (5) in the case of civil liability, the need for this to be applied in cases of extreme negligence or malice, and also proportionately, so that it avoids a chilling effect or censorship of journalists. 36. Regarding civil liability, it is important that the analysis of proportionality also include an analysis of the pecuniary amounts established in the judgment to ensure that they do not entail measures that dissuade democratic discussion. 37. The general and open standards concerning non-contractual liability, such as article 1045 of the Costa Rican Civil Code, should be analyzed in cases of the subsequent liability of journalists in relation to the protection of the honor of public officials in matters of public interest and with reference to acts relating to their functions, carrying out a strict control of conventionality in keeping with the parameters I have tried to develop in this opinion. Ricardo C. Pérez Manrique Judge Pablo Saavedra Alessandri Secretary