On December 4, 2015, the European Court of Human Rights ruled in Zakharov v. Russia that the system for secret surveillance of mobile phones in Russia violated Article 8 (right to respect for private life and correspondence) of the European Convention of Human Rights (Convention). According to the press release, Roman Zakharov, a Russian national and subscriber of several mobile service providers, filed for an injunction in a Russian court, arguing that “pursuant [to a not generally accessible regulation] the mobile network operators had installed equipment which permitted the Federal Security Service . . . to intercept all telephone communications without prior judicial authorization.” The court denied his request, finding that he had not provided proof that his communications had in fact been intercepted and ruling that “[i]nstallation of the equipment to which he referred did not in itself infringe the privacy of his communications.” The Court ruled that the legal framework for surveillance measures did not contain “adequate and effective guarantees against arbitrariness and the risk of abuse.” Specifically, the Court found the legislation lacked clarity regarding the categories of people and types of offenses which are subject to surveillance, as well as clear provisions on duration and termination of the measures and procedures for storage and disposal of the collected data. Additionally, the Court ruled that any remedies to challenge surveillance measures were undermined by the difficulties in obtaining proof that they had actually taken place. The Court also addressed the procedures for authorizing surveillance, noting that “Russian courts do not verify whether there is a reasonable suspicion” and “sometimes . . . authorise interception of all telephone communications in the area where a criminal offence has allegedly been committed, and on occasions without mentioning the duration of the authorised interception.” It concluded that “[t]he need for safeguards against arbitrariness and abuse appears therefore to be particularly great” as the Russian system “allows the secret services and the police to intercept directly the communications of each and every citizen without having to show an interception authorisation to the communications service provider.” Finally, the Court decided that the supervision of surveillance measures did not conform with “requirements under the European Convention that supervisory bodies be independent, open to public scrutiny and vested with sufficient powers and competence to exercise effective and continuous control.”