114 Dictating the Internet: In July 2019, the trial of Ressa and Santos began in Manila.427 This case is one of 11 legal actions faced in total by Rappler, Ressa, and Rappler’s directors and employees. The news agency, which has been openly critical of the current government, has also been targeted for alleged tax evasion and alleged foreign control of a media company in violation of domestic law.428 Cambodia In Cambodia, prior to the national elections of 2018, the government issued an inter-ministerial order (prakas) allowing the Ministries of Information, Interior and Post and Telecommunications to monitor, block and shut down websites, social media pages or other information circulated online that would “cause social chaos and threaten national security”.429 This prakas was passed amidst a crackdown on independent media throughout the country leading up to the elections. This included the shutdown of more than 30 radio frequencies across the country, the release of the National Election Committee’s ‘Code of Conduct’ for journalists which prevented them from reporting news “affecting political and social stability”, the shutdown of a major independent newspaper – The Cambodia Daily – for alleged tax violations, and the sale of another key independent newspaper – Phnom Penh Post – to an investor with links to the Cambodian government, following which its editor-in-chief and some senior employees 427 Lian Buan, ‘A look into a libel trial: First witnesses up in Maria Ressa case’, Rappler, 23 July 2019, Available at: https://www.rappler.com/nation/236083-first-witnesses-maria-ressa-cyber-libel-case 428 See Lian Buan, ‘Maria Ressa arraigned for cyber libel; SC may be next option’, Rappler, 14 May 2019, Available at: https://www.rappler.com/nation/230577-maria-ressa-arraigned-cyber-libelsupreme-court-may-be-next-option-may-2019; Lian Buan, ‘Court of Appeals denies Rappler appeal in SEC case’, Rappler, 11 March 2019, Available at: https://www.rappler.com/nation/225347-courtappeals-denies-rappler-appeal-sec-case 429 Mech Dara, Hor Kimsay, ‘Three ministries set up web-monitoring group to look out for ‘fake news’’, Phnom Penh Post, 7 June 2018, Available at: https://www.phnompenhpost.com/national/threeministries-set-web-monitoring-group-look-out-fake-news; Cambodian Center for Human Rights, ‘Cambodian groups seek revocation of new online directive ahead of elections’, IFEX, 15 June 2018, Available at: https://ifex.org/cambodian-groups-seek-revocation-of-new-online-directiveahead-of-elections/