46 Dictating the Internet: Code, which criminalizes the dissemination of information that could incite mutiny or otherwise cause members of the armed forces to disregard or fail in their duties (see below).125 As of April 2019, civil society organization Athan Myanmar documented that 185 cases had been formally filed under the Telecommunications Law, of which 93 percent invoked section 66(d), including 23 cases against 31 journalists.126 In a 2018 analysis, Athan found that more than half of the cases filed under the Telecommunications Law – 54 percent –related to the exercise of free expression, including cases relating to political criticism and news reporting.127 As of December 2017, civil society organization Free Expression Myanmar documented that half of the complainants who had filed cases against individuals under section 66(d) were representatives of the State or public officials.128 In a 2019 report, Athan noted that in the first six months of 2019 alone, 11 journalists had been charged for professional reporting – with 45 percent of charges brought against them under the Telecommunications Law and 15 percent brought under Myanmar’s Penal Code for alleged criminal defamation.129 Chapter XXI of Myanmar’s Penal Code – sections 499 and 500 – criminalizes defamation with up to two years’ imprisonment, a fine, or both.130 125 English translation of Myanmar Penal Code (‘Myanmar Penal Code’), Available at: http://www. burmalibrary.org/docs6/MYANMAR_PENAL_CODE-corr.1.pdf 126 Athan Myanmar, ‘ The Number of Cases Under the Telecommunications Law’, 9 April 2019, Available at: http://athanmyanmar.org/2019/04/09/the-number-of-cases-under-thetelecommunications-law/; Data from Say No to 66(d) campaign, Available at: https://www. saynoto66d.info/ 127 Athan Myanmar, ‘Mid-term report on Freedom of Expression’, October 2018, Available at: https:// equalitymyanmar.org/wp-content/uploads/2018/10/Mid-term-Report-on-Freedom-of-ExpressionEng-Version.pdf 128 Free Expression Myanmar, ‘66(d): No Real Change’, December 2017, p17, Available at: http:// freeexpressionmyanmar.org/wp-content/uploads/2017/12/66d-no-real-change.pdf 129 Athan Myanmar, ‘2019 Mid-year Report on Status of Freedom of Expression in Myanmar’, Available at: https://progressivevoicemyanmar.org/2019/09/02/2019-mid-year-report-on-status-offreedom-of-expression-in-myanmar/ 130 The Electronic Transaction Law has also been used to control online content. See ICJ, ‘ Myanmar: Briefing Paper on Criminal Defamation Laws’, 26 November 2015, Available at: https://www.icj. org/wp-content/uploads/2015/11/Myanmar-Criminal-Defamation-Laws-Advocacy-Position-paper2015-ENG.pdf