Curtailing Free Expression, Opinion and Information Online in Southeast Asia critical of the ruling Communist Party of Vietnam.316 There has been an increased crackdown on expression online, particularly by pro-democracy activists. In September 2019, Human Rights Watch noted that in the first nine months of 2019 alone, 11 individuals had been convicted and sentenced to prison for expression unwelcome by the government.317 In May 2019, an Amnesty International report documented at least 128 “prisoners of conscience”318 were being held in Vietnamese prisons. This number represented a spike from 97 such prisoners in 2018. Nearly 10 percent of detained persons had been prosecuted for comments made on social media platforms.319 Amnesty International’s report highlighted that the implementation of amendments to the Penal Code in January 2018 had resulted in increased prosecutions of online expression under the law, while the coming into effect of Vietnam’s Cybersecurity Law in January 2019 was likely to intensify surveillance and censorship of online expression.320 Of the 128 documented cases, 45 individuals were imprisoned for “aiming to overthrow the State”, more than 20 for “undermining national unity”, more than 15 for “conducting propaganda against the State” or “making, storing or disseminating” such propaganda, more than 15 for “disturbing public order” or “disrupting national security” and more than 10 for “abusing democratic freedoms to infringe on the interests of the State”. 321 An environmental activist was sentenced to life imprisonment for allegedly “aiming to overthrow the state”.322 316 Human Rights Watch, ‘World Report 2017: Vietnam – Events of 2016’, Available at: https://www. hrw.org/world-report/2017/country-chapters/vietnam; Al Jazeera News, ‘At least 128 prisoners of conscience in Vietnam: Amnesty’, 14 May 2019, Available at: https://www.aljazeera.com/ news/2019/05/128-prisoners-conscience-vietnam-amnesty-190513034714570.html; Mike Ives, ‘Tran Dai Quang, Hard-Line Vietnamese President, Dies at 61’, New York Times, 21 September 2018, Available at: https://www.nytimes.com/2018/09/21/obituaries/tran-dai-quang-dead.html 317 Human Rights Watch, ‘Vietnam: New Arrest for Facebook Postings’, 7 October 2019 (‘HRW, 7 October 2019’), Available at: https://www.hrw.org/news/2019/10/07/vietnam-new-arrestfacebook-postings; As of September 2019, freedom of expression monitor, The 88 Project, noted that 266 individuals remained in detention for expression of peaceful dissent; ICJ communications with partners. 318 Amnesty International, ‘Detention and Imprisonment’, Available at: https://www.amnesty.org/en/ what-we-do/detention/ . Amnesty International uses the characterization “prisoners of conscience” to refer to persons who have not used or advocated violence but is imprisoned because of who they are (based on sexual orientation, ethnic, national or social origin, language, birth, colour, sex or economic status) or what they believe (religious, political or other conscientiously held beliefs). 319 Amnesty International, ‘Prisoners of Conscience in Viet Nam’, 13 May 2019 (‘Amnesty, ‘Prisoners of Conscience in Vietnam’), Available at: https://www.amnesty.org/download/Documents/ ASA4103032019ENGLISH.pdf 320 Amnesty International, ‘Viet Nam: Surge in number of prisoners of conscience, new research shows’, 13 May 2019, Available at: https://www.amnesty.org/en/latest/news/2019/05/viet-namsurge-number-prisoners-conscience-new-research-shows/ 321 Amnesty, ‘Prisoners of Conscience in Vietnam’, p 6. 322 Amnesty, ‘Prisoners of Conscience in Vietnam’, pp 20, 21. 89