had required. 18 23. The Court has also integrated into its understanding of criminal measures some concerns regarding the frequency with which public officials use the courts to file complaints for libel or slander in order to silence or inhibit criticism of their actions in the public sphere, in the context of so-called “SLAPP proceedings” (Strategic Lawsuit Against Public Participation). In this regard, the Court gives special importance to the establishment of measures other than criminal prosecution to protect the honor of public officials, such as rectification and reply. In their concurring opinion, Judges Mac-Gregor Poisot and Pérez Manrique stressed that, despite being a measure of reparation in that specific case, the solution should serve as a basis for actions that States can take to avoid incurring international responsibility in the future. 19 24. Examination of the aforementioned precedents allows us to identify the evolution of this Court’s understanding of the issue which has culminated in the judgment adopted in the instant case. 25. There is a clear and growing tendency to increasingly restrict the use of criminal solutions to protect conduct relating to the exercise of freedom of expression, and this has already been consolidated in Álvarez Ramos and Palacio Urrutia with regard to matters of public interest. 26. This reduction of the scope of criminal protection is compatible with the tendency observed by other OAS and UN human rights treaty bodies. Among other significant approaches to the issue, it is worth stressing that, for more than ten years, the IACHR Special Rapporteurship for Freedom of Expression has been warning Member States about the inappropriateness of using criminal law to restrict freedom of expression – including specific recommendations to the State of Costa Rica. 27. In reality, the censure of and reservations regarding the use of criminal law as an instrument to restrict freedom of expression is not limited to the Inter-American Court. 28. In her 2009 Annual Report, the Special Rapporteur for Freedom of Expression of the Inter-American Commission on Human Rights, referring to the recommendations made by the Inter-American Court in the judgment in the case of Herrera Ulloa, reiterated to the Costa Rican State the importance of reforming its existing domestic laws to avoid the disproportionate application of criminal law to those who, while exercising their right to freedom of expression, denounce public officials. 20 In the 2018 Annual Report, the Special Rapporteur recalled that the protection of a person’s reputation should only be guaranteed through civil sanctions, 21 in order to restrict the criminalization of conducts that jeopardize those rights only and exclusively to exceptional circumstances when there is an evident and direct threat of lawless violence. Also, in this regard, in the 2019 Annual Report, the same Special Rapporteur recommended that all Member States “eliminat[e] the use of criminal proceedings to inhibit free democratic debate about all issues of public interest.” 22 29. In this understanding, the IACHR elaborated a Declaration of Principles on Freedom of Expression in October 2000. 23 Principle 11 establishes that: 18 Ibid., §§177-179 19 Ibid. Concurring opinion of Judges Eduardo Ferrer Mac-Gregor Poisot and Ricardo Pérez Manrique, §11. 20 IACHR, Special Rapporteurship for Freedom of Expression. Annual Report, 2009, §160. 21 IACHR. Special Rapporteurship for Freedom of Expression. Annual Report, 2018, §371. 22 IACHR, Special Rapporteurship for Freedom of Expression. Annual Report, 2019, p. 272. 23 IACHR. Declaration of Principles on Freedom of Expression. Adopted by the Inter-American Commission on Human