On October 15, 2015, the European Court of Human Rights ruled [3] in Perinçek v. Switzerland that the conviction of a Turkish politician for statements made in Switzerland about the Armenian people in the Ottoman Empire was a violation of Article 10 (freedom of expression) of the European Convention on Human Rights [4] (Convention).  Mr. Perinçek had stated, “[T]his is the truth, there was no genocide of the Armenians in 1915” and had characterized the actions by Turkish forces as “a battle between peoples and we suffered many casualties.” The Court acknowledged that the Armenian community “identifies itself in particular through its history, marked by the events of 1915” and noted that “the negative stereotyping of an ethnic group [is] capable . . . of having an impact on the group’s sense of identity” and could thus affect their “private life” under Article 8 § 1 of the Convention. Having identified two separate rights implicated by this case, the Court set out to balance Mr. Perinçek’s right to freedom of expression and the Armenians’ right to the protection of their dignity. The Court concluded that a criminal penalty had been unnecessary to protect the Armenian community’s rights. In particular, the Court relied on the following elements in its analysis: “[T]hat the applicant’s statements bore on a matter of public interest and did not amount to a call for hatred or intolerance, that the context in which they were made was not marked by heightened tensions or special historical overtones in Switzerland, that the statements cannot be regarded as affecting the dignity of the members of the Armenian community to the point of requiring a criminal law response in Switzerland, that there is no international law obligation for Switzerland to criminalise such statements, that the Swiss courts appear to have censured the applicant for voicing an opinion that diverged from the established ones in Switzerland, and that the interference took the serious form of a criminal conviction.”