61 1. Considerations related to the Content of Article 5.1 of the American Convention, and the Work of Women Human Rights Defenders 216. The Commission has ruled on the specific scope of the duty to prevent and protect set forth in Article 5.1, with regard to the work of human rights defenders.273 The Inter-American system has broadly defined who should be considered as a human rights defender including “any person who in any way promotes or strives for the protection and fulfillment of the human rights and fundamental liberties recognized at the national and international levels.”274 The IACHR has found that the members of organizations that work for the advancement of human rights such as the Women’s Association of Las Independencias, and the Community Action Board, are covered under the definition of human rights defenders.275 217. The States’ obligation to respect and ensure under Article 5(1) is all encompassing, and includes physical and psychological assaults, threats, and harassment used in order to diminish the physical and mental capacity of human rights defenders.276 The State can be found internationally responsible for infringing the right to personal integrity by not adopting reasonable measures to prevent these assaults against human rights defenders; by not diligently and seriously investigating the incidents that come to its attention; and by not punishing those responsible for the crimes.277 218. Both the Court and the Commission have established that this duty to protect and prevent can be applicable in certain circumstances to acts perpetrated by state actors, third parties, or private individuals. Said international responsibility is contingent upon knowledge of a situation of real and immediate risk – to an individual or a group of particular individuals – and on a reasonable chance of preventing or avoiding said risk.278 Even though an act, omission, or event of a private individual may have the legal consequence of violating specific human rights of another private individual, such a violation is not automatically attributable to the State, rather it must be viewed in light of the particular circumstances of the case, and the fulfillment of said obligations to ensure rights.279 The Commission 273 IACHR, Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II.124 Doc. 5 rev 1, March 7, 2006, par. 47. 274 The IACHR has discussed in its analysis Article 1 of the United Nations Declaration of the Rights and Duties of Individuals, Groups and Promoting and Protecting Human Rights and Fundamental Liberties (hereinafter “the UN Declaration on Defenders”). See IACHR, Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II.124 Doc. 5 rev. 1, March 7, 2006, par. 13. In this regard, the UN High Commissioner for Human Rights has determined that in order to be considered a defender, the person must protect or promote any right or rights on behalf of persons or groups of persons, which includes the promotion and protection of any civil or political, economic, social or cultural right. See, Office of the High Commissioner for Human Rights, Fact Sheet No. 29: Human Rights Defenders: Protecting the Right to Defend Rights. Geneva 2004. Available at: http://www.ohchr.org/Documents/Publications/FactSheet29sp.pdf. 275 IACHR, Second Report on the Situation of Human Rights Defenders in the Americas (2011), pars. 208-232. 276 IACHR, Second Report on the Situation of Human Rights Defenders in the Americas (2011), par. 40; IACHR. Second Report on the Situation of Human Rights Defenders in the Americas (2011), OEA/Ser.L/V/II.124 Doc. 5 rev. 1, March 7, 2006, par. 47. 277 IACHR, Second Report on the Situation of Human Rights Defenders in the Americas (2011), par. 43. 278 IA Court of HR, Case of the Massacre of Pueblo Bello v. Colombia. Judgment of January 31,2006. Series C No. 140, pars. 123 and 124; European Court of Human Rights, Kiliç v. Turkey, judgment of March 2000, Application No. 22492/93, pars. 62-63; Osman v. the United Kingdom, judgment of October 28, 1998, Reports of Judgments and Decisions 1998-VIII, pars. 115116. 279 IA Court of HR, Case of Valle Jaramillo et al v. Colombia. Merits, Reparation and Costs. Judgment of November 27, 2008. Series C No. 192, par. 78.