owing to the publication of an article that referred to the alleged misappropriation of funds by a former congressman. The Court divided its application of Article 13 to the case into two parts: first, it classified the statements made by Mr. Álvarez as speech on matters of public interest; 14 then, it examined the subsequent criminal liability attributed to him. Regarding such liability, the Court has consolidated the following understanding: [...] in the case of speech that is protected because it concerns matters of public interest, such as the conduct of public officials in the performance of their duties, the State’s punitive response through criminal law is not conventionally appropriate to protect the honor of an official. Indeed, the use of criminal law against those who disseminate information of this nature would directly or indirectly constitute intimidation which, in the end, would limit freedom of expression and impede public scrutiny of unlawful conduct, such as acts of corruption, abuse of authority, etc. Ultimately, this would weaken public control over the State’s powers, causing grave damage to democratic pluralism. In other words, in the hypothesis outlined previously, the protection of honor using criminal law, which may be legitimate in other cases, is not consistent with the Convention. 20. Thus, I note that the Court has gone beyond analyzing the possible incompatibility with the Convention of the definition of specific offenses, and has examined the adequacy of criminal law, per se, to regulate freedom of speech on matters of public interest. This represents the culmination of its understanding, developed since the case of Herrera Ulloa, that the chilling effect of criminal law is a significant limitation to the exercise of freedom of expression, and that the importance of upholding open discussion on matters of public interest may, in certain cases, make criminal sanctions incompatible with the environment necessary for the pluralistic discussion that should be cultivated in democratic societies. 21. Nevertheless, after indicating the inadequacy of criminalizing speech that falls within this category, the Court underlined that “[t]his does not mean that journalistic conduct cannot produce liability in another legal sphere, such as in civil law, or require rectification or a public apology, for example, in cases of possible abuses or excesses of bad faith.” 15 The consideration of these alternative measures is particularly valuable if we take into account that the Convention itself establishes the right of reply in its Article 14. 22. In the subsequent case of Palacio Urrutia et al. v. Ecuador (2021), the Court reiterated the progress made in its case law that was consolidated in Álvarez Ramos, in addition to referring back to the criteria identifying discourse as part of the public debate, it indicated that the use of criminal law to sanction the dissemination of information of this nature was not compatible with the Convention and underscored the existence of less onerous, and therefore preferable, alternatives. 16 It is also worth emphasizing the Court’s acknowledgement of the chilling effect of the imposition of sanctions on Mr. Palacio Urrutia and the El Universo newspaper, which extended to all its journalists and employees. 17 Taking into account that, at the date of the judgment, Ecuador had already amended the definition of crimes against honor, the Court acknowledged the progress made, but indicated that the interpretation of the new provisions must be aligned with the rules of interpretation that it 14 To this end, the Court defined the elements as follows: a subjective element (the person concerned is a public servant); a functional element (the person carried out the reported acts in his official capacity), and a material element (the matter was of public relevance). 15 IACtHR. Case of Álvarez Ramos v. Venezuela. Judgment of August 30, 2019, §124 16 IACtHR. Case of Palacio Urrutia v. Ecuador. Judgment of November 24, 2021, §118-119. 17 Ibid., §§123-124