The Cameroon government‘s shutdown of internet services violates all three requirements for permissible restrictions of free expression outlined in Article 19: The first criterion requires that the measure be imposed pursuant to a law that (i) is accessible to the public, (ii) is formulated with sufficient precision to enable an individual to regulate his or her conduct accordingly, and (iii) provides adequate safeguards against unfettered discretion for the restriction of freedom of expression on those charged with its execution.30 The internet disruption in the Anglophone regions was unacknowledged by the Cameroonian government until services were restored three months later, and it was not publicly justified through any Cameroonian law. Additionally, it broadly affected all users in the Northwest and Southwest regions including Francophones and Anglophones who did not participate in protests. The telecommunications companies charged with executing the government‘s secret shutdown order enjoyed complete discretion, given that no public oversight, transparency, or accountability could challenge the unpublished order or its execution. The second criterion requires that the restriction be for the purpose of respecting the rights or reputations of others, or for the purpose of protecting national security, public order, public health or public morals.31 Research indicates that imposing internet blackouts when people are protesting does not increase safety. Rather, it stops important information from reaching citizens — like how to find areas of safety or contact emergency services.32 It also prevents people from documenting human rights violations such as the disproportionate use of force by the police or military.33 Moreover, the failure to explain or acknowledge shutdowns creates the perception that they are designed to suppress reporting, criticism or dissent. In the case of Cameroon, this served only fuel tensions in the region by exacerbating the marginalization of Anglophones. The final criterion mandates that the limitation be strictly necessary to achieve a legitimate aim and that it be proportionate to the interest to be protected.34 The African Commission, in Zimbabwe Lawyers for Human Rights & Associated Newspapers of Zimbabwe v. Zimbabwe,35 has set out three guiding questions that must be asked when determining whether a measure is proportionate: ―[Were] there sufficient reasons to justify the action? Was there a less restrictive alternative? Was the decision-making process procedurally fair? Were there any safeguards against abuse? Does the action destroy the essence of the rights guaranteed by the 30 32 33 UN Human Rights Committee, General comment no. 34, Article 19, Freedoms of opinion and expression, 12 September 2011, UN Doc. CCPR/C/GC/34 , par. 25. 31 See also African Court on Human and Peoples‟ Rights, Konaté v. Burkina Faso, App. No. 004/2013 (2014), par. 134. Monique Kwachou, „Cameroon: Life in No-Internet Cameroon‟ (All Africa, 1 March 2017) Bijan Stephen, „How Black Lives Matter Uses Social Media to Fight the Power‟ (Wired, November 2015) 34 UN Human Rights Committee, General comment no. 34, Article 19, Freedoms of opinion and expression, 12 September 2011, UN Doc. CCPR/C/GC/34 , par. 22. 35 African Commission on Human and Peoples' Rights, Zimbabwe Lawyers for Human Rights & Associated Newspapers of Zimbabwe v. Zimbabwe, Communication No. 284/03.