On October 9, 2014, the International Criminal Court Appeals Chamber (the Court) dismissed [3] William Samoei Ruto and Joshua Arap Sang’s appeals [4] against the Trial Chamber’s decision requiring witnesses to appear before it and obligating the government of Kenya to facilitate the witnesses’ appearance.  According to the press release [5], “in the view of the Appeals Chamber, article 64(6)(b) of the Rome Statute expressly gives Trial Chambers the power to compel witnesses to appear before it, thereby creating a legal obligation for the individuals concerned.”  In their decision, the Trial Chamber “granted the Prosecutor's request to summon witnesses who were no longer cooperating or no longer willing to testify” and allowed witnesses to appear in situ or through a video-link.