Offence, Democratic State duties & Theoterrorism
By Professor Paul Cliteur (University of Leiden)
January 7, 2016 Picture: Morteza Nikoubazl/REUTERS
This article is part of The Critique’s Great War Series Part II: Charlie Hebdo, Free Speech & Religious Violence Exclusive.
Now, two and a half decades later (and after the murder of Theo van Gogh, the Danish Cartoon Affair and Charlie Hebdo), it is possible to reflect on these three proposals. The first, giving up the paperback, did not happen. The second, a blasphemy trial, did not happen either and is unlikely to happen in the foreseeable future, because blasphemy laws have been abolished in Great Britain. The third suggestion, however, although not applied in the case of Salman Rushdie,proved to become the standard strategy in the western world for dealing with theoterrorist threat. People who incurred the wrath of theoterrorists have either sought a new identity, or they went into hiding, or they are living in a 24/7 security program, or they adopt a low profile in order to escape the attention of those who have sworn to kill them. This article aims to analyze some of the cases where we see this mechanism at work.
As a reaction to the violence exerted by Islamist theoterrorists an American journalist with the name Molly Norris proposed, on a Facebook page, to organize a “Everybody Draw Mohammed Day”. Norris was moved to do this after death threats had been made against the cartoonists Trey Parker (b. 1969) and Matt Stone (b. 1971). Parker and Stone had depicted the prophet Mohammed in the episodes two hundred and two hundred and one of South Park, an American animated sitcom broadcast on television. These aired in April 2010. Mohammed was featured as a character in a bear costume. On radical websites this sparked statements in which Parker and Stone were compared with Theo van Gogh. It was also declared that they could meet a similar fate.
In reaction to the threats to her fellow cartoonists, Norris launched the idea of an “Everybody Draw Mohammed Day” in May 2010, in support of free speech and the First Amendment. The idea was that if many people were to draw a picture of Mohammed targeting cartoonists, it would transcend the capacity of even the most resourceful terrorist organizations.
Norris attracted the attention of the radical Muslim cleric Anwar al-Awlaki (1971-2011) who issued a fatwa calling for her death. Al-Awlaki said in the June issue of “Inspire” (Al Qaeda’s propaganda magazine) that Norris was a “prime target” whose “proper abode is hellfire”. According to the Seattle Weekly, where Norris had worked, she had gone into hiding on the FBI’s recommendation. The Seattle Weekly also indicated that Norris’s cartoons would no longer appear in the alternative newspaper.
What the FBI recommended: make yourself less of a target
Now, what is interesting in this case is that the advice to “go ghost” was given by the U.S. Federal Bureau of Investigation. As the Seattle Weekly says: “On the insistence of top security specialists at the FBI”, Norris is, “moving, changing her name and essentially wiping away her identity”.
David Gomez, the FBI’s assistant special agent in charge of counter-terrorism in Seattle, commented: “We understand the absolute seriousness of a threat from an Al Qaeda-inspired magazine and are attempting to do everything in our power to assist individuals on that list to effectively protect themselves and change their behavior to make themselves less of a target”.
The quote raises some serious questions. We see that the special agent expresses his concern about the situation. He also explains that the FBI will do everything in its power to help the civilians who became the target of terrorist threats. But then Gomez continues with a remark about what the targets can do. He speaks of “change their behavior to make themselves less of a target”.
Does that really mean that the FBI expects the targets to change their behavior? But that would mean that the most effective strategy to protect yourself is complying with the wishes of the terrorizing organization. It means that the most effective strategy for Charlie Hebdo to become less of a target, is simply to stop making cartoons of the prophet. The most effective way for Salman Rushdie to become less of a target, is to stop writing books that might displease the islamists.
For Molly Norris this must have been a most precarious situation. Not only do you have to experience that you are attacked by a resourceful enemy, you also see that one of the most powerful organizations within your own state is basically waving the white flag. It is Molly Norris who is being helped to change her behavior, not the terrorists.
Also the word “everything” is important in this context. This appears to include to wipe away your identity, to “go ghost”. In other words, the state advises its citizens to wipe themselves away, because the state cannot protect them (or claims it cannot protect them) against terrorist attacks on the territory that the state claims to have under its control. This is not far from the scenario of facial surgery that Weatherby commented on in the 1990s with regard to Salman Rushdie.
“The state advises its citizens to wipe themselves away, because the state cannot protect them against terrorist attacks on the territory that the state claims to have under its control”
There is another aspect that needs to be highlighted. As we have seen, the decision to “go ghost” is, in the quote from Gomez, taken by the individual targeted (in this case: Norris herself). The FBI only “assists” individuals in that decision and helps them set up a new identity. The state claims that it only “helps” the individual in making decisions, but in reality there are no real alternatives left. And there are no alternatives left, because the state basically fails in fulfilling its primary function (in fact its raison d’être). The state has to guarantee the security of the citizens on the territory of the state. A state that cannot fulfill this basic function is no state or, what we call a “failed state”.
A contemporary manifestation of a failed state, is a state which dumps its citizens for the reason that the state feels no longer capable, or morally obliged, to protect them. This was well formulated by Ian Davidson in a commentary on the Rushdie Affair. “Mealy-mouthed expressions of distaste of The Satanic Verses merely served to make the Government look obsequious and cringing”. Rushdie had good reason to be fearful of the events, Davidson continues, because “he was in danger of being dumped by the British government”. “Being dumped by your own government”. That is a real prospect for some citizens nowadays, and this is one of the most cynic contemporary manifestations of state failure.
Now the epithet “failed state” is usually entertained when there are enough people who experience this “failing” in their daily lives. This is not the case with the restrictions of free speech. A substantial amount of people think they have nothing to do with the issue. It is Westergaard (the Danish cartoonist), Rushdie, Norris, the French cartoonists and others who experience the failing first-hand.
So “there is no more Molly”, Mark D. Fefer writes in the Seattle Weekly, commenting on this case. Molly Norris herself compared the situation of being a target of terrorist movements with cancer. It might be basically nothing, it might be urgent and serious, it might go away and never return, or it might pop up when you least expect it.
The precariousness of the situation was also brought to the fore by a commentator who wrote: “Yes, that’s where we are – the FBI is there to give cheeky Americans advice in not offending murderous Islamists”.
We also have to stress the importance of David Gomez’s words that the FBI assists individuals on the list of “Inspire” to “change their behavior to make themselves less of a target”. So apparently it is the citizens, targeted by terrorist organizations, who have to “change their behavior”. The state is only there for “assistance” in this process.
Public security for threatened politicians
A similar question is that of the public security for politicians threatened by theoterrorists. On 29 February 2008, on the Dutch talk-show Pauw & Witteman, the Dutch journalist Henk Hofland (b. 1927), speaking about the publication of Fitna, an anti-Islam film by the Dutch politician Geert Wilders (b. 1963), proposed the removal of Wilders’s personal security guards.
Hofland’s idea was the following. Wilders made the Dutch population less safe (according to Hofland, apparently, it was not primarily Al Qaeda that made the Netherlands unsafe, but Wilders). Why not force him into silence? Many people thought that perhaps not much would have been lost if the film had not been published. So why accept the risk of a terrorist attack?
In December 2012 a Dutch cabaret performer also played with the idea of removing Wilders’s security guards. Without security, people would think a little longer before they say something, the Dutch comic joked. The audience applauded vigorously at this suggestion.
In an analysis of this event, the novelist and columnist Nausicaa Marbe (b. 1963) asks what it is that makes people so happy about stopping security provisions for Wilders. Do they not know that this would mean secure death for the Dutch politician? And is this something to joke about, as the Dutch comedian had done? Marbe says that apparently the people were applauding something that is a broadly held view in Dutch society.
Marbe assesses what the consequences would be if this view were to be translated into state policy. Why protect the Pakistani girl Malala (b. 1997), who pleaded for education for women in Afghanistan and Pakistan and was subsequently targeted by the Taliban? Was this also her fault and should she suffer the consequences?
What the attitude of the FBI-agent, the journalist Hofland, the cabaret performer and many others, making similar remarks, seems to have in common, is that there is no reflection on the question where this would lead us if seriously practiced on a large scale.
The positions taken by our leaders
Now one might be tempted to say that we should not confer too much weight on the words of an individual FBI agent in the case of Molly Norris. But that would make us forget that the words by Gomez are no different from the advice that high ranking politicians like Barack Obama, Hillary Clinton, Ban Ki-moon and Martin Schulz seem to give in the cases where freedom of speech and theoterrorism are at loggerheads.
For instance president Obama appeared on “Good Morning America”, where he commented on the plans of the Quran-burning pastor Terry Jones (b. 1951).The president said on that occasion, that this stunt of Jones would be a “recruitment bonanza for al-Qaida.” Unfortunately, the president did not reflect on the effect his own remarks would have on the self-esteem of theoterrorists. What effect does it have when a president of the free world openly indicates that he wants to back down on the constitutional rights of the citizens of his country to please those who want to violently punish perpetrators of holy law?
Contemporary political leaders all seem to give the same advice to citizens in western states, viz. not to provoke the terrorists. And by doing that, they all forsake freedom of speech, freedom of religion, freedom of conscience, in short: the freedoms those organizations were supposed to protect. Would it be needlessly provocative to say that it seems that the United Nations, the European Parliament, and other institutions have been “hijacked” by people who have no respect at all for the founding principles of these organizations (although, paradoxically, talking about “respect” all the time, of course)?
“Contemporary political leaders all seem to give the same advice to citizens in western states not to provoke the terrorists. By doing that, they all forsake the freedoms those organizations were supposed to protect”.
The question is how far the terrorists will up the ante. When do we reach the point where political leaders in the western world will think the demands of terrorists are non-negotiable? Burning holy books is negotiable. Making cartoons of religious icons is, according to many people, negotiable. Writing novels also appeared negotiable – not only for many political leaders, but also for many of Rushdie’s colleagues, as we have seen. Broadcasting a spoof on the Iranian dictator Khomeini appeared to be negotiable a long time ago, when the Dutch authorities convinced the broadcast corporation to change its programming.
In September 2012 a screening of Tom Holland’s BBC documentary on the history of Islam was cancelled on security advice after the presenter was threatened. But will doing historical research into the origins of Islam at a university also be negotiable? Or only if the results are broadcast on TV? These are still open questions.
Maybe people like Rushdie, Westergaard, Wilders and Jones are already relics from the past, because only a few will be prepared to follow in their footsteps. As Andrew Anthony writes: “Who would dare to write a book like The Satanic Verses nowadays? And if some brave or reckless author did dare, who would publish it?”. Good point. Jeremy Waldron, writing about Rushdie in 1992, said: “Certainly, the threat to his life should be taken seriously. But how seriously should we take the ‘chilling effect’ that the threat might have on Rushdie’s subsequent writing, on his publishers and booksellers, and on other authors who might be tempted into similarly ‘offensive’ prose?”.
These were interesting questions in 1992, but now we have the answers, don’t we? Would Peter Carey of Penguin consider publishing a book like he published in 1988, if requested? The price is simply too high, so it seems. Perhaps the people mentioned were prepared to pay such a high price because in their cases there was no alternative at the time. Rushdie could never have followed Molly Norris and “go ghost”. You cannot survive as a “novelist ghost”. But many ordinary people who read the autobiographies of Wilders, Westergaard and Rushdie will conclude that go ghost is the most advisable strategy from a personal point of view (although not from the point of view of society as a whole perhaps).
But what about the social costs? What would happen if everybody followed the advice of the FBI-agent? What would happen if all governments were to draw back their financial support for the protection of people like Wilders and Rushdie? Would that not, basically, mean that the theoterrorists have won?
Ban Ki-moon or Obama think perhaps that giving in to the demands of the terrorists is a laudable development from the perspective of social harmony, communal cohesion and world peace, but this may be too sanguine. If there are no critics of religious terrorists left (because they all have been silenced), they may be emboldened. They will, as indicated, up the ante to a point where even Ban Ki-moon and Martin Schulz will think it too humiliating to comply with their demands. Perhaps the word “humiliating” may seem like somewhat of an exaggeration, if not down-right misleading. What can be “humiliating” in a request to choose our words with caution?
But that is to miss the point. What is “humiliating” is that we see world leaders grovel in the sand to appease the most violent forces in this world. The theoterrorists do not only succeed in intimidating world leaders, but even to have them formulate totally incredible excuses for their appeasement. They are led by fear, not by considerations of decency, respect and the ambition to engage in “dialogue”.
Future critics of religious terrorism will probably seek anonymity as much as possible. This is in fact what Nakoula Basseley Nakoula tried to do (and, initially, naively, as it turned out, thought he had done) when he placed his film on the internet in the United States. But he was hunted down, not by islamists but by American journalists who were very curious about the identity of the maker of a film that had caused so much havoc. As a result of these tensions the discussion inevitably shifts to whether people will have the opportunity to express anonymous criticism on the internet. Will this behaviour be safe in the Brave New World of the future?
Google as the final arbiter on the limits of free speech
In October 2012 The Jerusalem District Court rejected a petition filed by M.K. Taleb el-Sana (United Arab List) and a group of Arab complainants, demanding that Google remove the trailer for “Innocence of Muslims” from YouTube Israel. Google had blocked access to the video already in a number of Muslim countries, including Libya, Egypt, Indonesia and India. But the question is whether that will satisfy the Islamist radicals.
Probably not. They will probably demand that the film is removed from the internet altogether – also in the United States of America. This is all according to the terrorist aim to force a country, by violent means, to do or condone something they would not be likely to do without that violence. Political leaders in the western world will have to decide whether they are prepared to change their fundamental laws to bring these in accordance with terrorist wishes and demands.
The Rushdie Affair was an early manifestation of this tendency, but not the first. On 23 February 1987 the Dutch government requested the Dutch television not to broadcast a satire of the Iranian dictator Ayatollah Khomeini. In September 2012 the White House requested Google Inc. reconsider its decision to keep online the controversial YouTube movie clip that had ignited protests and killing in the Middle East. The internet company rejected this request by the American authorities. It was prepared to censor the video in India, Indonesia, Egypt and Libya, but not in the United States and other states where religious satire is not illegal.
Like in the Rushdie Affair, political freedom is not primarily upheld by the government, but by civil society: by publishing companies, internet companies and private individuals. Ironically, the state and the individual swap functions. The state, the organization whose primary function it is to uphold the basic liberties we are discussing, fails to take its responsibility seriously. It is the human individual, or a private organization, (Google) who takes up state-functions. And it is the private organization (Google) that has to remind the state of its own laws: “Sorry state, did you forget that you issued laws protecting free speech?”
One final word on free speech: the responsibility thesis
Now, let me close this article by trying to answer a sort of rebuttal of the argument developed in the previous paragraphs. It is often said that the line of argument developed in this article is based on some sort of “absolutist conception” of free speech. It is often said that this conception of free speech is mistaken, because with freedom comes responsibility, and simply shouting offensive language may be legal, it is certainly not a responsible thing to do. I call this “the responsibility thesis” [See Biggar, Cohen-Almagor & Jones for a qualified defence of this thesis].
The answer to this line of criticism is that the tenor of the argument developed in this article should not be mistaken for an unqualified or absolutist vindication of free speech. What it aims to be, is a reformulation of the scope of free speech, a different kind of thinking about free speech. This may best be described by a critique of the dominant attitude towards free speech among the western elite which is both (i) too wide and (ii) too restricted.
Why too wide? It is too wide in the sense that things are being condoned that are extremely dangerous for particular living people. Anyone who takes cognizance of what has been written about controversial political leaders, and public intellectuals, like Geert Wilders, Salman Rushdie, Kurt Westergaard and others, must understand that this can be highly inflammatory. To take the most controversial example: because of his criticism of Islam, Geert Wilders is extremely unpopular with the political elite in the Netherlands. And the way prominent politicians judge these Islam critics is difficult to disentangle from incitements to violence.
In the case of Pim Fortuyn (1948-2002) this is precisely what proved fatal. In a world where there are misguided individuals like the murderer of Fortuyn, or the murderer of Theo van Gogh, walking among us, one should be very cautious when the lives of particular living beings are at stake. Here the dominant position is too lenient towards free speech. There is too much free speech.
But the flipside is also true. In another context the dominant conception of free speech is too restricted. This is true when it comes to religious criticism. Many people nowadays entertain an extremely restricted conception of free speech when it comes to the critique of religious doctrines and religious icons. Discussing the peculiarities of Mohammed is, as Andrew Anthony and Brian Winston correctly testify, virtually impossible nowadays. This is strange. Mohammed is not a living person. He cannot be “harmed” by what people think and write about him in the same way that Napoleon, Socrates, Jesus Christ and Buddha cannot be harmed by what people think and write about them. The people who claim to be harmed by what other people write about their religious icon are believers. Theoterrorists claim to protect Mohammed or Allah, but what they in fact do, is protect their own ideas about Mohammed and Allah. The whole undertaking is much more self-seeking than it prima facie appears.
But how can it be justified that a group of people, believers, manage to elevate their own ideas about a moral and religious icon above criticism? Lutherans have not managed to accomplish this with Luther. Christians have not succeeded in attempts to stymie all discussions about the moral behavior of Christ. Mormons could not succeed in having the figure of Joseph Smith removed from critical inquiry. Fans of Mother Theresa have not been able to suppress Christopher Hitchens’s The Missionary Position: Mother Teresa in Theory and Practice (1995).Hindus have not succeeded in having Gita Mehta’s Karma Cola (1979) included on a list of forbidden books. Why should radical islamists succeed in suppressing all criticism?
This is an important subject and it requires extensive analysis. Even if solutions to this precarious question are not readily available, a clear and open presentation of the problem could be a step in the right direction.
We should at least consider what may be the long term effects of appeasing the most intolerant believers. Does that not imply that we unwittingly support and encourage fanaticism? If that were true, the most laudable motives of “respect”, “tolerance” and “dialogue” would in fact create a world with less respect, tolerance and dialogue. That would be sad.
The situation with regard to those who incur the wrath of the islamist theoterrorists is that some of them are dead (Van Gogh, the Japanese translator of Rushdie, the cartoonists of Charlie Hebdo), others went “ghost” (Molly Norris), another group is in a security regime (Westergaard, Rushdie, Hirsi Ali, Wilders) and some exercise self-censorship (the eleven Danish cartoonists apart from Westergaard).
And this all in a world that adopted the Universal Declaration of Human Rights in 1948, the International Convention on Civil and Political Rights in 1966, the European Human Rights Charter in 1950 and many national constitutions, all with provisions on freedom of speech.
Footnotes & References
 Weatherby, W.J., Salman Rushdie: Sentenced to Death, Carrol & Graf, New York 1990, p. 242.
 Weatherby, Ibid., p. 242.
 On November 2, 2004 the Dutch filmmaker Theo van Gogh was killed by a Dutch jihadist who got a lifelong prison sentence for that.
 The Danish Cartoon Affair was a direct outcome of the murder of Van Gogh. In 2005, the Danish newspaper Jyllands Posten wanted to test whether people would still dare to make a cartoon about the prophet Mohammed. See on this: Khader, Naser, and Rose, Flemming, “Reflections on the Danish Cartoon Controversy”, in:Middle East Quarterly, Fall 2007, pp. 59-66; Rose, Flemming, “Why I Published Those Cartoons”, in: Washingtonpost.com, Sunday, February 19, 2006; Rose, Flemming, The Tyranny of Silence: How one Cartoon ignited a Global Debate on the Future of Free Speech, Cato Institute, Washington, D.C. 2014.
 See on this: Charb, Lettre aux escrocs de l’islamophobie qui font le jeu des racistes, Les Échappés, Paris 2015 ; Fourest, Caroline, Éloge du blasphème, Bernard Grasset, Paris 2015.
 Or, to be more precise, not in the manner indicated. Rushdie did not change his identity.
 “Female cartoonist forced into hiding after doodling ‘Everybody Draw Mohammed Day’ picture”, in: The Daily Mail, 17 September 2010. See on Anwar al-Awlaki: Bennoune, Karima, Your Fatwa Does not Apply Here: Untold Stories from the Fight against Muslim Fundamentalism, W.W. Norton & Company, New York, London 2013, p. 24.
 An essential function of the state. See: Weber, Max, Staatssoziologie. Soziologie der rationalen Staatsanstalt und der modernen politischen Parteien und Parlamente, Mit einer Einführung und Erläuterungen herausgegeben von Johannes Winckelmann, Zweite, durchgesehene und ergänzte Auflage, Duncker & Humblot, Berlin 1966, p. 27.
 Only a state that manages to do this can be called sovereign. See: Bryce, James, “The Nature of Sovereignty”, in: Studies in history and jurisprudence, Volume II, reprint of the edition Oxford 1901, Scientia Verlag, Aalen 1980, pp. 49-111. “Um zu gewährleisten, dass die rechtlichen Normen sich widerspruchsfrei zu einer funktionsfähigen Gemeinschaftsordnung zusammenfügen, muss ein Organ in der Gemeinschaft die zentrale und oberste Regelungsgewalt (die ‘Kompetenzenhoheit’) haben. Unter ihrer Verfügungsmacht müssen alle anderen rechtlichen Regelungsbefugnissen (‘Kompetenzen’) in dieser Rechtsgemeinschaft stehen”, according to the German legal scholar Zippelius, Reinhold, Rechtsphilosophie, Verlag C.H. Beck, München 1982, p. 191.
 For instance because the state agrees with the terrorists that books by people like Rushdie are “provocations”. This was, basically, the position of Charles Taylor. See: Taylor, Charles, “The Rushdie Controversy”, in: Public Culture, Vol. 2, No. 1 (Fall 1989), pp. 118-122 and also the last part of Maclure, Jocelyn, and Taylor, Charles, Secularism and Freedom of Conscience, Harvard University Press, Cambridge, Mass. 2011. Even more surprising is perhaps Karl Popper’s position, as we see in: Popper, Karl, “Popper to the Society of Authors, 24 February 1989, and to Isaiah Berlin, 5 March 1989”, in: Karl Popper, After the Open Society, Selected Social and Political Writings, edited by Jeremy Shearmur and Piers Norris Turner, Routledge, London and New York 2008, pp. 202-204.
 Ian Davidson in The Financial Times, 9 March 1989.
 Davidson, Ibid.
 Fefer, Mark D., “On the Advice of the FBI, Cartoonist Molly Norris Disappears From View”, in: Seattly Weekly, 15 September 2010.
 Molly Norris quoted in Fefer, Ibid.
 Yoffe, Emily, “Molly Norris Disappears”, in: Slate, 23 September 2010.
 A similar discussion sprang up around Rushdie’s book, among others stimulated by the Prince of Wales who, Rushdie writes, complained about the costs of Rushdie’s protection. See: Rushdie, Salman, Joseph Anton: A Memoir, Jonathan Cape, London 2012, p. 370. His friend Ian McEwan answered journalists: “Prince Charles costs much more to protect than Rushdie and has never written anything of interest”. Rushdie, Ibid., p. 393.
 Marbe, Nausicaa, “Lynchcabaret”, in: De Volkskrant, 4 January 2013. The name of the cabaret performer is Theo Maassen (b. 1966).
 The fifteen year old Pakistani girl Malala Yousafzai was targeted by Islamic radicals and shot in the head. She recovered in the Queen Elizabeth Hospital in Birmingham, England, but even there British-based Islamic radicals were preparing to announce a fatwa on Malala for her promoting girls education. See: Crilly, Rob, “Islamic hardliners announce fatwa on Malala Yousafzai”, in: The Telegraph, 19 November 2012.
 Terry Jones was the pastor of Dove World Outreach Center, a small nondenominational Christian church located, until July 2013, in Gainesville, Florida, USA. He is an anti-Islam activist with one of his most controversial actions being the burning of a Quran.
 For a transcript of the interview, see “Opinion Roundup: Burning the Quran”, National Public Radio, September 9, 2010.
 Another case that attracted worldwide attention was the uploading on the internet of a fragment from a film: “Innocence of Muslims”(2012), made by a director under the nickname Nakoula Basseley Nakoula. The chairman of the European Parliament, Martin Schulz, the Secretary-General of the UN, Ban Ki-moon, the secretary of state of the USA, Hillary Clinton, they all commented on the poor quality of the fragment and criticized the maker for his irresponsible behavior. See: Cliteur, Paul, Herrenberg, Tom, and Rijpkema, Bastiaan, “The New Censorship: A Case Study of Extrajudicial Restraints on Free Speech”, in: Afshin Ellian and Bastiaan Rijpkema, eds., Freedom of Speech under Attack, Eleven, International Publishing, The Hague 2015, pp. 291-318; Herrenberg, Tom, “Denouncing Divinity: Blasphemy, Human Rights, and the Struggle of Political Leaders to defend Freedom of Speech in the Case of Innocence of Muslims”, in:Ancilla Iuris, 1, 2015, pp. 1-19.
 The documentary is based on Holland, Tom, In the Shadow of the Sword: The Battle for Global Empire and the End of the Ancient World, Little, Brown, London 2012. See on the cancellation: “Channel 4 cancels Islam documentary screening after presenter on security advice after its presenter was threatened”, in: The Telegraph, 11 September 2012.
 Anthony, Andrew, “How one book ignited a culture war”, in: The Observer, 11 January 2009. See also: Winston, Brian, A Right to Offend, Bloomsbury, London 2012, p. 10.
 Waldron, Jeremy, “Minority Cultures and the Cosmopolitan Alternative”, in:University of Michigan Journal of Law Reform, Vol. 25, 1992, pp. 751-793, at p. 765. Waldron took a very straightforward position in defending free speech in Waldron, Jeremy, “Rushdie and Religion”, first published under the title “Too important for Tact” in: The Times Literary Supplement, 10 March 1989, pp. 248 and 260, and reprinted in: Jeremy Waldron, Liberal Rights: Collected Papers 1981-1991, Cambridge University Press, Cambridge/New York 1993, pp. 134-143. In his more recent work he seems to have abandoned that position. See Waldron, Jeremy, The Harm in Hate Speech, Harvard University Press, Cambridge (Mass.), London 2012.
 See on this: Stewart-Halevy, Jacob, “Innocence of Muslims and the Value of Low Production”, in: Third Text, Vol. 27, No. 5, 2013, pp. 650-658; Herrenberg, Tom, “Politici, de vrijheid van meningsuiting en Innocence of Muslims”, in:Nederlands Juristenblad, 24 September 2013, pp. 2255-2259; Coll, Steve, “Innocence of Muslims”, in: The New Yorker, 10 January 2012, pp. 21-22.
 Podolsky, Philip, “Court rejects petition to block anti-Islam film trailer in Israel”, in: The Times of Israel, 15 October 2012.
 Cliteur, Paul, “The Rudi Carrell Affair and its Significance for the Tension between Theoterrorism and Religious Satire”, in: Ancilla Iuris, 2013: 15, pp. 15-41, full text: http://www.anci.ch/paul_cliteur
 Shih, Gerry, “White House ‘Innocence of Muslims’ request denied: Google will not remove film from YouTube”, in: Huff Post World, 25 October 2012.
 The Dutch attorney’s Gerard Spong and Oscar Hammerstein filed a complaint about incitement to hate and violence against Pim Fortuyn by the political elite of the Netherlands. See: Spong, Gerard, en Hammerstein, Oscar,“Vervolg ze tot in de hel”. De haat-zaai aangifte van Fortuyn, Uitgeverij Balans, Amsterdam 2003.
 Hitchens, Christopher, The Missionary Position: Mother Teresa in Theory and Practice, Verso, London and New York 1995.
 Mehta, Gita, Karma Cola: Marketing the Mystic East, Vintage Books, New York 1979. Although Penguin India Books removed Doniger, Wendy, The Hindus: An Alternative History, Penguin Books, London 2009 from the shelves because a controversy arose about the contents of the book.