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Cross-Country Comparison of Internet Censorship: A Literature Review

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 Policy & Internet, Vol. 10, No. 2, 2018

Cross‐Country Comparison of Internet Censorship: A

Literature Review
Vasilis Ververis , Sophia Marguel, and Benjamin Fabian

Internet censorship is a widely studied and important field of research with implications for society,
politics, and business. However, little focus has been spent on cross‐country comparisons of online
content control. This article aims at reducing this research gap by performing a comparative literature
review of Internet censorship practices in France, Turkey, and Iran. The historic development and
current status of each country is studied, focusing on censorship levels, institutional characteristics,
legislative environments, and current challenges. The assessment discloses several similarities and
differences across the countries and allows for the identification of five key driving forces for online
content control across France, Turkey, and Iran; namely, the ruling system, institutional setup,
national identity, technical ability, and political opportunity. These findings will support future
research and political debate on the freedom of expression and unrestricted access to content.

KEY WORDS: Internet censorship, literature review, cross‐country analysis, France, Turkey, Iran

网络审查是一个被广泛研究的重要研究领域, 它对社会、政治和商业都具有意义。然而, 很少有研

究聚焦于网络内容管控的跨国家比较。本文旨在通过完成一项针对法国、土耳其和伊朗的网络审
查实践的比较文献综述, 以减少该研究空白。研究了每个国家的历史发展和当前情况, 聚焦于审查
程度、制度特征、立法环境和当前挑战。评估披露了各国的相似点与不同点, 并识别了法国、土
耳其和伊朗网络内容管控的五个关键驱动力, 分别是统治体系、制度设置、国家认同、技术能力
和政治机遇。这些研究发现将有助于有关言论自由和不受限内容获取的未来研究和政治辩论。
关键词： 网络审查, 文献综述, 跨国家分析, 法国, 土耳其, 伊朗

La censura en Internet es un campo de investigación importante ampliamente estudiado con

implicaciones para la sociedad, la política y los negocios. Sin embargo, se ha prestado poca
atención a las comparaciones entre países del control de contenido en línea. Este artículo tiene
como objetivo reducir esta brecha en la investigación al realizar una revisión bibliográfica com-
parativa de las prácticas de censura en Internet en Francia, Turquía e Irán. Se estudia el desarrollo
histórico y el estado actual de cada país, centrándose en los niveles de censura, las características
institucionales, los entornos legislativos y los desafíos actuales. La evaluación revela varias
similitudes y diferencias entre los países y permite la identificación de cinco fuerzas impulsoras
clave para el control de contenido en línea en Francia, Turquía e Irán: el sistema de gobierno, la
configuración institucional, la identidad nacional, la capacidad técnica y la oportunidad política.

doi: 10.1002/poi3.228
© 2019 Policy Studies Organization
2 Policy & Internet, 00:00

Estos hallazgos respaldarán futuras investigaciones y debates políticos sobre la libertad de ex-
presión y el acceso sin restricciones al contenido.
PALABRAS CLAVE: Censura en Internet, revisión de literatura, análisis entre países, Francia,
Turquía, Irán

Introduction

The Internet has revolutionized the way people get information, educate
themselves, communicate, decide, conduct business, and enjoy entertainment
(Zarras, 2016), as well as allowing new forms of political protest and activism
(Hellmeier, 2016). Almost half of people (47 percent) worldwide now use the In-
ternet (ITU, 2016a). What makes the Internet unique and universal is that digital
content ignores the existing geographical boundaries. This decentralized structure
allows for anyone who is active online to gain (but also offer) information, re-
gardless of their location (Mueller, 2010). Since its existence, states and regulatory
agencies have tried to gain control over the flow of information within their ter-
ritories (Akdeniz, 2010; Goldsmith & Wu, 2006; Mueller, 2010), with policymakers
trying to block access to content deemed controversial or illegal, and monitoring
personal communication online (Zarras, 2016).
Bambauer describes that censoring content online has developed in three epochs.
In the early days of the medium, restricting access to content online through techno-
logical constraints was considered impossible (Bambauer, 2013). Slowly, by the end of
the 1990, controlling content online became technically feasible through the systematic
screening of information. This practice developed further and was mostly applied by
repressive regimes until around 2005, establishing the predominant causality of fil-
tering equals authoritarian government (Bambauer, 2013). In the third epoch of In-
ternet censorship, blocking techniques have spread to liberal democracies as they try to
restrict access to undesirable information (Ververis et al., 2015). Today, censorship has
become an almost omnipresent phenomenon in democracies and authoritarian
countries alike (Bambauer, 2013), evolving into a global norm applied across all ruling
systems (Breindl & Kuellmer, 2013; Pearce et al., 2017).
Reasons for blocking the content are diverse. Governments base their censorship
decisions on their cultural, historical, religious, constitutional, political, moral values
(Akdeniz & Altiparmak, 2008), ideological grounds (Hellmeier, 2016), political or
religious reasons to pornography, extremism, gambling, anonymity, privacy or
intellectual property rights (Pearce et al., 2017). Platforms such as Facebook, Twitter,
and Google shape political debates, and allow for organizing and coordinating
protests within the younger generation (Zarras, 2016). Their common use by political
activists mean that social media are among the prime targets for government‐
mandated censorship (Dick, 2012). Internet forum owners and platform providers
have responded to censorship by increased monitoring and control of user‐generated
content on their websites (Shklovski & Kotamraju, 2011).
Following, we will summarize different Internet censorship technologies. In-
ternet blocking and filtering techniques exist, the most common based upon our
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 3

literature survey are: (i) Border Gateway Protocol (BGP) tampering. Routers use
BGP to direct across administrative boundaries on the Internet. BGP tampering, can
withdraw a local network’s visibility from the BGP network view, thus making it
unreachable to outside networks; (ii) Domain Name System (DNS) hijacking. ISPs
are in control of the DNS servers being used by their clients. Since they can ma-
nipulate their DNS servers’ responses, they can redirect the requesting clients to a
bogus location to a server they control where they run a web server that displays a
censorship notification message to the users or just a technical error message; (iii) IP
blocking. This technique blocks access destined to a specific IP address or range of
addresses by discarding networks packets. It is very effective but also very prone to
cause collateral damage as network services share one IP address; (iv) Deep Packet
Inspection (DPI), an advanced form of censorship performed by special appliances
can look into the data payload of every network packet and thus manipulate, block
them from reaching their destination, redirect them to a different server and change
the server response (Ververis et al., 2015).
Most academic studies have focused their investigations on the state of Internet
censorship within a single country (Pearce et al., 2017). We aim to address this
research gap by conducting a cross‐country analysis of factors driving Internet
censorship in three countries—France, Turkey, and Iran—so as to represent the
global span of the research field. Different levels of Internet censorship, ruling sys-
tems, and levels of academic exploration are reflected in this selection. Most studies
have focused on countries, which heavily censor content online, such as China or
Iran (Mueller, 2010). To represent this research focus and include an electoral the-
ocracy, we chose to include Iran. Another research focus is countries with author-
itarian regimes, which exert higher censorship than liberal democracies (Dick, 2012;
Dick et al., 2012; Mueller, 2010). Turkey is a rare example of a secular democracy that
is sliding toward authoritarianism (Esen & Gumuscu, 2016; Sarfati, 2017) evidenced
by efforts to control content online (Yesil et al., 2017). Studies examining online
content control in liberal democracies are generally under‐represented (Mueller,
2010). We have included a democracy in our selection to bridge this research gap.
Rather than follow the general focus on the United States and the United Kingdom
(Mueller, 2010) we chose France as an interesting case, representing censorship
activities under civil law in continental Europe.
Our literature review was guided by the following research questions:
1. What are the key historic developments in Internet censorship in France, Turkey, and
Iran and what is the current state of online content control in these countries?
2. What are the key driving forces in Internet censorship across France, Turkey, and Iran?

Literature Review Method

The review type implemented is the systematized literature review (SLR)

(Paré et al., 2015), that search for, appraise and synthesize research evidence to pool
all known knowledge on a particular subject. To ensure a structured approach that
4 Policy & Internet, 00:00

systematically and reliably captures all relevant literature for this review, we
adopted the twelve‐step guideline by Kable et al. (2012).
We will search two academic databases for this review: Web of Science
and io‐port.net. Both fulfill a wide range of favorable characteristics, they are
well‐established, multidisciplinary, comprise a wide variety of peer‐reviewed ar-
ticles, and are up‐to‐date. In addition, both databases follow a strict evaluation
process of articles listed, thus ensuring reliability and credibility for the research
consulted for this article (Fiz Karlsruhe GmbH, 2011; Thomson Reuters, 2017).
To develop effective search limits, we applied a two‐step approach under Kable
et al. (2012). These limits, together with the search terms, tested for result accuracy
within the two databases by examining the first twenty articles corresponding to
each search term and search limit. In a second stage, we disregarded certain search
limits as unfitting after the relevance test had shown that they did not help in finding
the most accurate results. On this basis, we selected the following final search limits
for the review: (i) peer‐reviewed journal articles. Published articles will be considered
preferably as they have already passed the strict evaluation processes of scientific
journals. To ensure that also current developments in the field can be reflected upon,
we will consider academic papers still in review process; (ii) articles written in or
translated into the English language. As publications in English are the international
standard for high impact research on the subject, we will include only those pub-
lications; (iii) publications between January 1, 2007 and April 1, 2017. The time frame
chosen for this review reflects that Internet censorship is a dynamic field of research.
The developments are so rapid that this search limit ensures the focus on up‐to‐date
publications. We will make sporadic exceptions of this limit for publications covering
historic events in Internet censorship; (iv) search within the title, keywords, and
abstract. To reduce the risk of falsely omitting relevant literature, we will apply the
search terms to the title, keywords, and abstracts of potential articles.
We perform the study selection of relevant literature based on specific inclusion
and exclusion criteria. The inclusion criteria contain primary studies directly or
partly related to the research questions, peer‐reviewed articles published in es-
tablished journals and verifiable, reliable sources discussing the current status of
the research topic. Similarly, the exclusion criteria used in the SLR deduct duplicate
studies, sources where full text is not available or without verifiable authorship and
studies unrelated to the research topic.
We use a similar two‐step approach to develop effective search terms and their
variations and tested for relevance within the two databases chosen. We dis-
regarded numerous search terms as unfitting after the relevance test showed that
those did not add new or relevant results. On this basis, we planned the following
final search terms: (i) Internet censorship; (ii) “Internet freedom”; (iii) “Internet
filter*”; (iv) Internet content AND censor*. The first term was deliberately not set
into quotes to capture all publications related to Internet censorship, both in the
title, keywords and abstract. We summarize the statistics of the actual search
process in Table 1, presenting the total number of articles found within the selected
databases and the details of the duplication removal process.
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 5

Table 1. Literature Search Statistics

Web of Science io‐port.net

Search step
Search hits: Internet censorship 217 46
Search hits: “Internet freedom” 23 6
Search hits: “Internet filter*” 32 12
Search hits: Internet content AND censor* 4 6
Identified articles—all search terms 276 70
Overall identified articles—both databases 346
Articles removed due to duplicates 21 22
Refined articles after removal 255 48
Identified articles at the end of actual search 303

Prior to the search process, we conducted a pilot search with the given search
terms and search limits to refine the search terms and limits and perform the final
search process. Upon completion of the search process, we assessed the relevancy
of all articles against the criteria for inclusion and exclusion by following a three‐
step process developed by Bettany‐Saltikov (2010).
First, a relevance assessment takes place by screening the title of each article.
Then studying the abstracts of the selected studies identified further irrelevant
research. At this point, we excluded studies with unavailable full text and without
verifiable authorship. Finally, we were screening all articles in full length. In
every step of the search process, we dismissed any articles classified as irrelevant
or invalid from the pool of literature. At the end of the search process, we
identified 51 articles relevant for the SLR. Figure 1 illustrates the complete search
and selection process.

Findings of the Literature Review

Internet Censorship in France

Information exchange and news coverage have long been exempted from state
control and censorship in liberal democracies (Dick et al., 2012), because of the
long‐standing vow freedom of expression and privacy rights, defended online and
offline (Breindl & Kuellmer, 2013). However, since the Gayssot law (1990), France
has restricted certain content from being published online or offline such as hate
speech, defamation, racist, anti‐Semite, and xenophobic expressions, or any na-
tional, racial, or religious discrimination (Wright & Breindl, 2013). Publishing
material considered inappropriate for a young public has been unlawful since 1949,
and a 2011 modification of the law forbids publication of certain pornographic
material, drugs usage, and any content promoting discrimination, violence, crime,
or hate. They have also approved several laws in the past decades punishing the
violation of France’s very strict privacy protection guidelines, which include the
right to one's image (Breindl and Kuellmer, 2013).
While the government promoted an open‐access policy for the Internet and
valued its informational and economic potential, it is gradually introducing online
6 Policy & Internet, 00:00

Figure 1. . Search and Selection Process.

content regulations (Wright & Breindl, 2013). Pressure to ISPs for content regu-
lations rose, as officials introduced technical measures blocking requirements into
the legislation (Breindl & Kuellmer, 2013). The first blocking mechanisms adopted
Freedom of Communication Law in 2000 (Breindl & Kuellmer, 2013). By 2005,
France had introduced regulations requiring ISPs to remove content classified as
illegal or inappropriate, otherwise facing prosecution (Subramanian, 2012).
The main regulations on online content control came with two laws: the
HADOPI (2009) and the LOPPSI 2 (2011) laws (Breindl & Kuellmer, 2013). HADOPI
law targeted Internet activities not complying with France’s strict copyright laws
and protection of creative work enabling the ban of users violating these laws
(Wright & Breindl, 2013). They classified the law unconstitutional, although
reintroduced in amended form as HADOPI 2 (Breindl & Kuellmer, 2013). LOPPSI 2
law added several questionable security measures to the ones introduced after the
terror attacks of 2001 in the United States, and 2005 in London and Madrid,
agreeing to block websites without a court order. In 2008 and 2009, two laws
enacted allowed access blocking to child abuse material, racial violence, and ter-
rorism that advanced the Internet filtering regulations. Despite harsh criticism by
the civil society and activist groups, the constitutional court ruled all measures as
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 7

proportionate in balancing public order and freedom of communication (Wright &

Breindl, 2013).
The Intelligence Act (July 2015) altered the legal basis for online content
control and used as a direct government response to the Charlie Hebdo shootings
(January 2015), albeit the law was long planned (Tréguer, 2016b). The law allows
for circumventing traditional criminal procedures and permits extra‐judicial cen-
sorship of content and blocking of websites for terror‐related content. It allows
computer hacking as a method for information gathering (up to 30 days) and where
intelligence cannot be gathered by other authorized means (Tréguer, 2016a).

Current Status in France

Internet Availability and Access. Access to Internet services in France is available to

82.6 percent of households. The share of fixed‐broadband subscriptions lies at 41.3
percent, and 74.7 percent for the mobile broadband subscriptions with a high
overall Internet penetration rate, of 84.7 percent (ITU, 2016b). They do not force
ISPs to lease bandwidth from a monopoly holder. The regulatory authority for the
telecommunications industry is the ARCEP (ARCEP, 2017). For content deemed
unlawful, the competent authority is the Central Office for the fight against Crime
related to Information and Communication Technology (OCLCTIC). Blocking
procedures implemented by the OCLCTIC are overseen by the French data pro-
tection agency CNIL (Mchangama, 2016).

Content Limitations and Removal. Within recent years, restrictions concerning online
content have been tightened in France, and the state of emergency legislation,
introduced after the terror attacks of January and November 2015 (Charlie Hebdo
and the coordinated Paris attacks) and the attack in Nice (July 2016), have ex-
panded the power and legislative means of ministers and state authorities over
online content (Mchangama, 2016). A law adopted in February 2015 allows for new,
far‐reaching administrative measures to block websites for any content inciting or
sympathizing with terrorism, or child abuse material, without a court order
(Human Rights Watch, 2015; Mchangama, 2016), and they can be ordered to be
taken offline (O’Connell, 2017). OCLCTIC maintains a blocklist of websites con-
taining unlawful material and can request administrators and editors to remove the
content. If the request is not complied with within 24 hours, OCLCTIC can request
ISPs to block the website (Lehn, 2017).
CNIL publishes reports about censored content within France, aiming to pro-
vide a certain transparency for the issue (2016), however, there is no publication
listing websites subject to withdrawal of content, blocking, or de‐listing (Lehn,
2017). The official numbers reported for March 2015 to February 2016 show that the
OCLCTIC passed 1439 removal requests; 1286 of these for pro‐terrorist content and
153 for child abuse material. The authority issued 312 administrative blocking or-
ders, blocking 68 websites for terrorism‐related content and 244 websites for dis-
playing child abuse material (CNIL, 2016).
8 Policy & Internet, 00:00

While the Ministry of the Interior has published information about blocked
websites and ways to appeal (CNIL, 2016), judicial oversight of the blocking
of websites remains absent (Human Rights Watch, 2015). This form of censorship
shifts responsibilities about blocked content from the government to private
entities, such as ISPs, by exerting formal or informal pressures. This offers
the possibility for the government to bypass the judiciary and political opposition
in their censoring decisions, and pressures intermediaries to act on its behalf
(Bambauer, 2013).

Internet Censorship in Turkey

Internet censorship in Turkey has been extensively researched, reflecting that

the country has a history of blocking content online, with great incongruity be-
tween the censorship measures observed in Turkey and the perception of Turkey as
a secular democracy (Yalkin et al., 2014). Traditional measures to control pub-
lications (including penal procedure and press codes) have proved inadequate to
regulate the Internet, and the Turkish government added a part to the existing
penal code on Internet and computer crime in 2004, establishing legal grounds of
blocking websites and imposing unknown responsibilities to the country's ISPs.
Authorities could now send blocking orders to ISPs, which have to comply by
restricting access to accused websites. They issued such provisions that required
court orders by law without prior court approval (Akdeniz & Altiparmak, 2008;
OSCE, 2010).
As blocking orders were not systematically applied (and only infrequently),
the Internet in Turkey remained a free medium until 2005 (ONI, 2010). In 2006,
online child abuse material triggered a public debate about unregulated access to
online content, and the political elite seized the opportunity by promising new
drastic regulations to keep the Internet “clean” of such content and protect children
and family values (Akgul & Kirlidog, 2015).
In 2007, and despite widespread concern from opposition parties and human
rights activists, law 5651 on the “Regulation of Publications on the Internet and
Suppression of Crimes Committed on such Publications” (OSCE, 2010) came into
effect. It remains the most important single law on Internet censorship in Turkish
history, laying the legislative grounds for extensive online content control to follow
(Akgul & Kirlidog, 2015). Official processes now allow the state to filter content,
block access to websites, and establish criminal liability for persons posting content
online that is deemed unlawful (ONI, 2010). The law lists eight catalogued crimes
that it deems illegal to publish about online (Akgul & Kirlidog, 2015), namely:
suicide, child abuse, obscenity, prostitution, gambling, crimes against Atatürk,
drug use, and substance abuse.
For the TIB to issue a blocking order, “sufficient suspicion” of breaching the
law was considered acceptable though the law did not provide clarification on the
term (OSCE, 2010). Law 5651 offered a technical right to object to a ban in court,
however, the procedures usually lead to long legal battles during which the
blocking of content remains in place (Akgul & Kirlidog, 2015). The enactment of the
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 9

law led to a sharp increase in censorship activities within Turkey. Popular social
networking sites such as YouTube, blogging platforms, and alternate news sites
have been regularly blocked since 2007, under the claim that they host unlawful
content (ONI, 2010).
Additional laws restricting freedom online and amendments to law 5651 have
broadened the scope for censorship. They deem violations of privacy rights
unlawful, and private persons gained the right to request the removal or blocking
of content from a court (Sen, 2014). In response to these laws, the authorities have
established a systematic blocking and filtering of online content (Akgul &
Kirlidog, 2015). Internet censorship increased in Turkey, peaking during political
protests like the Occupy Gezi marches (2013) (Ilhan, 2015), and important times
such as the general elections in 2015, or the failed military coup of 2016 (Freedom
House, 2016c).

Current Status in Turkey

Internet Availability and Access. Access to Internet services in Turkey is at an average

level in international comparison: 69.5 percent of households have Internet access.
The share of fixed‐broadband subscriptions of residents lies at a low level of 12.4
percent. However, an additional 50.9 percent of Turkish residents have mobile
broadband subscriptions. In 2015, the average overall Internet penetration rate was
53.7 percent (ITU, 2016b).
Turkey’s aspirations to join the European Union (EU) have been a major driver
for reforms and liberalization in the telecommunications sector, and it has achieved
substantial steps to reform the telecommunications laws and open the market. The
2005 privatization of the state‐owned, monopoly provider Türk Telecom was a
major step. Since then, the number of ISPs has grown steadily (ONI, 2010). As of
2016, the ICT market is partly open, with limited competition. Any provider eager
to offer its service still needs to apply for a license from the Turkish authorities
(ICTA, 2016). Newly founded companies may face entrance barriers due to a lack of
political ties or economic power (Freedom House, 2016a). As for established ISPs,
TTNET, a subsidiary of the partly state‐owned Türk Telecom, is the largest ISP in
the country with a current market share of 71.2 percent. Moreover, 359 additional
ISPs provide ICT services as of May 2016, though the majority perform as resellers
for Türk Telecom (ICTA, 2016).
In 2016, there were several reports of severe restrictions to connectivity within
certain parts of the country (Sozeri, 2016). Regional Internet disruptions represent
an extreme form of Internet censorship, disrupting access to part or all of a coun-
try’s population by either powering down, physically disconnecting crucial
equipment, or installing software and hardware aimed at interfering with Internet
routing or network packet forwarding mechanisms (Dainotti et al., 2014). Con-
nectivity was disrupted in the aftermath of terror attacks within Turkey, with
restrictions lasting for up to 60 hours in the eastern and south‐eastern parts of the
country (Sozeri, 2016).
10 Policy & Internet, 00:00

Content Limitations and Removal. Given neither the TIB nor any official authority in
Turkey publishes statistics on blocked websites (Akgul & Kirlidog, 2015), re-
searchers have in the past relied on the unofficial statistics provided by the in-
dependent non‐governmental organization EngelliWeb (Engelliweb, 2016).
As of May 2016 statistics from EngelliWeb list 111,011 blocked websites.
A dramatic increase in blocked websites of 67,226 within three years
(Engelliweb, 2016). Blocking measures mainly concern civil code‐related
complaints and intellectual property rights violations, but blocking also
takes place for political, social, and religious reasons, LGBTQI issues, ethnic
minorities reports, and in response to sharing of election polls, content related
to the Kurdish conflict, anti‐Muslim publications, and terror‐related material.
Journalists and activists are the target of state‐imposed blocking of content
without juridical orders (Freedom House 2016c), especially in 2016 in response
to terror‐related incidents (Engelliweb, 2016).
Between June 2015 and May 2016, the TIB issued 94 percent of blocking orders,
with the rest coming from Turkish courts. In most cases, the owners of targeted
websites were neither informed of the blocking, nor given enough time to comply
with such requests (Engelliweb, 2016). Blocking orders issued by the TIB and the
country’s courts are not transparent—even though the courts publish blocking
notices, they do not provide information on the reasoning behind their judgments
(Dag Medya, 2015). Affected website owners therefore have trouble understanding
the reasons behind their blocked websites and whether the order issued by a court
or the TIB will result in a significant hurdle for any appeal process (Akgul &
Kirlidog, 2015).
After trying to make filtering compulsory for all users in 2011 (Akgul & Kirlidog,
2015), the ICTA now instructs ISPs to promote and offer parental control filters—
restricting access to Facebook, YouTube, and educational websites—which have been
criticized for being arbitrary and discriminatory. The ICTA introduced mandatory
filters to control Internet access at all primary education institutions and public bodies
throughout the country (Reporters Without Borders, 2016).
The government maintains a set of around 6000 individuals who are instructed
to manipulate online discussions and counter government critics on social media.
As such, journalists and bloggers have experienced orchestrated harassment online,
leading to a high level of self‐censorship among Turkish journalists and bloggers
(Ilhan, 2015). Despite this tense environment, digital activism continues to play a
significant role in the country (Freedom House, 2016c). Turkish residents rely on
online publications as their primary source of information for domestic issues not
covered by the mainstream media (Ilhan, 2015).

Internet Censorship in Iran

Iran runs one of the largest, most sophisticated, and well‐researched censor-
ship systems worldwide. That said, little knowledge exists about the technology
and network topology behind the country’s censorship system (Anderson, 2012),
since investigating the network from within Iran is considered dangerous (Aryan
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 11

et al., 2013; Pearce et al., 2017). In contrast to France and Turkey, the Iranian
constitution does not guarantee freedom of speech, but rather allows restriction of
a broad range of topics relating to religious and political expression (Aryan et al.,
2013), resulting in the establishment of a tight censorship control over print
media, radio, and television (Baldino & Goold, 2014). Iran was the second country
in the Middle East after Israel to gain Internet access, in 1993 (Rahimi, 2003).
During the period of economic difficulty following the Iran–Iraq war, Internet
usage was state‐promoted as an opportunity for scientific and technological
progress, allowing unregulated access to the commercial and educational sectors
(Rahimi, 2003). Iran followed a liberal approach toward private ISPs, which were
free to operate, even despite provoking the state by advertising uncensored
services (Sreberny & Khiabany, 2010).
In 2000, the conservative rulers worried about the amount of freedom the
Internet provided, and online content restrictions were introduced by the author-
ities (Sreberny & Khiabany, 2010). Selected reformist newspapers were shut down,
and a 2001 decree ordered Internet cafés and ISPs to be placed under state control;
obliging the latter to remove anti‐government or anti‐Islamic content from their
servers (Rahimi, 2003).
Extensive Internet regulation was a difficult task, and the conservative
authorities faced wide‐ranging challenges to their control of information (Sreberny &
Khiabany, 2010). New regulatory authorities therefore imposed a large‐scale
filtering program at the ISP level in 2001, to allow nationwide regulation of online
content (Sreberny & Khiabany, 2010). They required domestic commercial ISPs to
connect through the state‐controlled Telecommunications Company of Iran, resulting
in the authorities gaining a central point of control for implementing Internet filters,
as they now designed the infrastructure around a state‐controlled network gateway
(ONI, 2009). In addition to introducing new authorities and legislation, the govern-
ment have encouraged the development of domestic tools for Internet filtering to
reduce reliance on western‐manufactured technologies. This proved successful: by
2009, Iran was using its own technology to apply its aggressive filtering system
(ONI, 2009).
In a new wave of tightening access restrictions in 2006, the Ministry of
Communications and Information technology (MICT) prohibited ISPs from
providing Internet connections to households and public Internet access points
over 128 kilobytes per second, throttling down data transfer rates in order to
prevent users from downloading multimedia content, therefore, restricting access
to media sources beyond state‐controlled television and radio. Rate limiting of
broadband services faced intense opposition, even within parliament, but was
nevertheless enacted (Deibert et al., 2008). In 2008, a bill was passed that instructed
ISPs to brief law enforcement if unlawful content was published on their servers,
and forced them to keep content deemed unlawful as evidence and restrict access to
it. ISPs not abiding by the law faced heavy fines and risked temporary or perma-
nent suspension (ONI, 2009).
The controversial presidential elections of 2009 triggered another series of
censorship measures, leading to an increase in political discussions online. The
12 Policy & Internet, 00:00

“Green Movement” mainly drove this, which pressed for regime change (Baldino &
Goold, 2014). Therefore, another key regulation concerning Internet freedom was
passed, amending the strict press law to regulate all Internet publications (ONI,
2009), including blogs and popular websites such as Facebook, which was blocked
in 2009 (Freedom House, 2016b).
Henceforth, ISPs and users were subject to speech restrictions on over 20 dif-
ferent subjects, including insulting Islam, religious leaders and institutions, creating
national discord, promoting drug use, obscenity, and immoral behavior. Reports
showed that there was systematic filtering for political reasons, such as voicing
dissident views, human and women’s rights issues, and websites offering cir-
cumvention tools to bypass censorship (ONI, 2009). One of the technical im-
plementations of network filtering in Iran has been realized by routing all Internet
traffic through proxy servers, allowing the network filtering infrastructure to target
specific websites and block individual keywords from search‐engine queries, such
as queries containing the keyword “women” (ONI, 2009).
The Supreme Council of the Cultural Revolution (SCRC) laid the legal and in-
stitutional grounds for the Iranian filtering program (Aryan et al., 2013). The criteria
for illegal websites and domains were set by the inter‐agency Committee in Charge
of Determining Unauthorized websites (CCDUS),which was overlooked by the
SCRC. Members of the committee included representatives of the Ministry of Culture
and Islamic Guidance, the Ministry of Intelligence, the Ministry of National Security,
and the Tehran Prosecutor General (ONI, 2009). The Information Technology
Company of Iran (ITC), which was part of the MICT, implemented the filtering
decisions. In addition, the Tehran Prosecutor General and any court could issue
blocking orders (ONI, 2009). In 2009, an entity called the Islamic Revolutionary
Guard Corps (IRGC) gained majority control over the ITC, thus becoming respon-
sible for applying Iran's filtering regime (Sreberny & Khiabany, 2010). Even though
the IRGC was deemed a non‐governmental organization, its heads were all military
veterans, occupying key positions within the country (Baldino & Goold, 2014), and
controlling most companies in the ICT sector (Sreberny & Khiabany, 2010).
With all these measures, the authoritarian Iranian regime has built an intense
centralized censorship infrastructure over the years (Aryan et al., 2013), expanding
its technical abilities to target, trace, block, filter online content, track down digital
opposition, and monopolize network infrastructure (Baldino and Goold, 2014).

Current Status in Iran

Internet Availability and Access. Internet access in Iran is poor—in 2016, only 52.2
percent of Iranian households had Internet access. The share of fixed‐broadband
subscriptions of residents lies at a low 10.9 percent, with an additional 20.0 percent
having mobile broadband subscriptions. There is a low overall Internet penetration
rate, with 44.1 percent of individuals using the Internet in 2015 (ITU, 2016b).
Iran has a central Internet backbone, administrated by the public
Telecommunications Infrastructure Company (TIC) (Small Media, 2015). As a
state‐owned entity operating under the ICT Ministry, it guarantees authorities
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 13

full control over the country’s Internet backbone. Commercial ISPs can only
purchase bandwidth from the TIC, and at marked‐up price, Internet access in
Iran is expensive, with low‐quality services.
There is no independent authority for the ICT market in Iran and ISPs need to
register with the ICT Ministry and gain approval for licensing (Communications
Regulatory Authority, 2013). The Iranian security apparatus controls third‐party
ISPs and heavily monitors Internet activities (Small Media, 2015, Sreberny &
Khiabany, 2010). They detected several restrictions with TIC restricting access to
content online and severe network throttling, as it has control over all inbound and
outbound network traffic (Small Media, 2015).

Content Limitations and Removal. Heavy restriction of access to websites and filtering
of content is prevalent in Iran (Anderson, 2013, Aryan et al., 2013, Baldino & Goold,
2014, Pearce et al., 2017). According to Pearce et al. (2017) Iran has the second
highest average amount of filtering out of 180 countries analyzed, ranking only
behind China. The topics triggering censorship include international news coverage
of sensitive topics, political opposition, online activities of ethnic and religious
minorities, as well as human, digital, and woman’s rights groups (Baldino & Goold,
2014, Wojcieszak & Smith, 2014). Most times, and against the rule of law, the
blocking is carried out without publishing an explanation why the content was
blocked or who issued the blocking order (Freedom House, 2016b). Rather than
shutting down networks, which raises attention and provokes protests, the Iranian
authorities throttle the network connection speeds, aimed at disabling access to and
distribution of multimedia content. This newer form of censorship is gaining
popularity among officials as a less detectable but still a very effective way of
limiting online connectivity (Anderson, 2013).
Facebook and Twitter have been blocked since 2009, with no easing of the
restrictions in sight (Freedom House, 2016b). Instant messaging applications are
also targeted by the authorities (Freedom House, 2016b), with many popular ap-
plications (such as the messaging application Viber) blocked (Dehghan, 2016).
Users adapted to the opportunistically encrypted and heavily moderated mes-
saging service Telegram, making it the most popular communication tool in Iran
next to WhatsApp as of 2016 (Dehghan, 2016). Both applications face current
blocking threats, as officials have issued respective requests to the authorities. They
associate these new measures with the refusal of Telegram to install spying and
censorship capabilities, as requested by the Iranian government in 2015 (BBC
Persia, 2015). Following this, temporary disruptions were recorded for the appli-
cation, many perceived as a threat to the application’s management. Telegram’s
CEO agreed to remove selected user accounts related to the Islamic State, as well as
a channel promoting the boycott of the 2016 elections (Bozorgzadeh, 2016). To
attract Iranian users to domestic services, which are much easier to control, the
government supports domestic social network and mobile application developers
by providing free bandwidth and hosting services (Freedom House, 2016b).
The centralized filtering system of Iran is still in place, affecting the entire
network in the country (Baldino & Goold, 2014). Private ISPs must use the
14 Policy & Internet, 00:00

government‐provided bandwidth or route their traffic through government‐issued

filtering boxes (Aryan et al., 2013), which monitor unencrypted network traffic,
scan for banned text strings, such as particular keywords or domain names, and
block access within hours. This procedure results in the over‐blocking of websites
(Aryan et al., 2013).
To circumvent the heavy access restrictions imposed by state authorities, Iranian
users reach blocked content by accessing websites over encrypted connections and
using circumvention tools such as proxy servers, web proxies, virtual private net-
works, or by using the Tor network to increase their anonymity online and bypass
the government‐imposed nationwide filtering. However, the use of circumvention
technologies requires advanced technical knowledge and is thus only helpful to a
few users within the country. Baldino and Goold (2014) and Wojcieszak and Smith
(2014) show that familiarity with these technical tools is at least high within the
Iranian youth. When asked about their ability to apply circumvention tools, 22
percent reported it as excellent, 34 percent as good, and another 34.4 percent as fair.
This represents a much greater familiarity with and comfort of using these tools than
the public, interviewed people reported the Internet as their most important source
of information, despite heavy content controls.
All these measures are accompanied by widespread arrests and heavy prose-
cutions of journalists, activists, bloggers, and ordinary citizens. A perception of
omnipresent surveillance among digital activists and the state actively applies in-
timidation to those producing critical content online. This results in an extensive
level of self‐censorship practiced among the aforementioned in Iran, especially
concerning political topics (Baldino & Goold, 2014). Despite this harsh environment
and the fact that many users have already abandoned their online activities,
blogging remains popular in Iran (Freedom House, 2016b). The government pub-
lishes regime propaganda online and encourages blogging among its own sup-
porters to counter critical voices, referred to as the “cyber army” of the Iranian
regime (Baldino & Goold, 2014).

Analysis and Discussion

Internet censorship is a controversial topic in the society (Mou et al., 2016).

On one hand, people argue that access to harmful content such as child abuse
material or hate speech should be prevented (Bambauer, 2013, Wu & Koo, 2001),
social norms protected, and public order and security ensured through state‐
mandated censorship activities (Breindl & Kuellmer, 2013). This view has led to
almost every country worldwide performing a certain degree of censorship online
(Hellmeier, 2016). However, many observers perceive any form of censorship on-
line as a threat to the fundamental rights of freedom of speech and privacy
(Bambauer, 2013), and consider it to be a governmental abuse of power (Li, 2009).
Free, unlimited, and uncensored access to the Internet is considered by many to be
a basic human right (Zarras, 2016).
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 15

Cross‐Country Similarities and Differences

When comparing the historic development of France, Turkey, and Iran, it be-
comes apparent that while Turkey and Iran have for many years applied extensive
information controls (Akgul & Kirlidog, 2015; Baldino & Goold, 2014), France is
new to the field of Internet censorship (Mchangama, 2016; Tréguer, 2016a)—partly
because it has a different ruling system to Turkey and Iran. The country has a long‐
standing commitment to freedom of expression, and faced strong political oppo-
sition when trying to introduce online content control (Breindl & Kuellmer, 2013;
Dick et al., 2012; Mchangama, 2016). What the governments in all three countries
have in common is that they all exercise Internet censorship to some (albeit
varying) degree. They are united in compromising the personal freedom and basic
human rights of their citizens (Baldino & Goold, 2014; Human Rights Watch, 2015;
Ilhan, 2015). Even though France engages in a lower level of Internet censorship
than Turkey and Iran, our literature review confirms that all three political regimes
exercise censorship online (Dick et al., 2012).
More similarities are apparent when we compare the organizational structures
through which they execute censorship. All three countries have build an extensive
body of governmental authorities and different formal organizations assigned with
implementing political decisions on content control online (Akgul & Kirlidog, 2015;
Baldino & Goold, 2014; Mchangama, 2016). None of the states have an independent
supervisory authority to take on the important task of controlling governmental
organizations (Ilhan, 2015; Sreberny & Khiabany, 2010; Tréguer, 2016a). Although
France comes operationally closest to an independent supervision (CNIL, 2016;
Freedom House, 2016a), the structures still do not satisfy the requirements of in-
dependent control (Breindl & Kuellmer, 2013; Tréguer, 2016a; Wright & Breindl,
2013). In addition, France, Turkey, and Iran make the private sector (most notably
ISPs) responsible for the execution of Internet censorship decisions by government
agencies. In all countries, they consequently exert high political pressure onto ISPs
and commercial content providers to follow official requests (Akgul & Kirlidog,
2015; Baldino & Goold, 2014; Mchangama, 2016). This approach opens a gate for
potential abuses and whether it is legally accountable and legitimate, since in most
cases ISPs operate without a clear legal framework (Bambauer, 2013; Wright &
Breindl, 2013). This is because existing legal frameworks often fail in providing
objective benchmarks as to what content is inadequate or illegal (Hellmeier, 2016).
While there is a general congruence in that existing national laws and the
respective constitutions pose certain limitations to freedom of speech online, these
limits apply to largely varying topics in each country (Akdeniz & Altiparmak, 2008;
Aryan et al., 2013; Breindl & Kuellmer, 2013). Apart from all three states prohibiting
the publication of child pornographic content, as well as general content deemed
harmful to a young public, terror‐related publications and certain political ex-
pressions, differences arise for other subjects deemed illegal and the motivation
behind imposing limitations to freedom of speech (Akdeniz & Altiparmak, 2008;
Aryan et al., 2013; Breindl & Kuellmer, 2013; Wright & Breindl, 2013). While the
focus in France lies on preventing discrimination in any form (Wright & Breindl,
16 Policy & Internet, 00:00

2013), Turkey and Iran apply restrictions on alleged insults or criticism of political
leaders or expressing opposition to religious issues (Akdeniz & Altiparmak, 2008;
Aryan et al., 2013). And while at least France and Turkey are officially bound by the
basic democratic principles of openness, transparency, and accountability, only
France respects public debate, opposition, and online activism against new legis-
lations (Akdeniz, 2010) as obliged by the European Convention on Human Rights
in their legislative (Breindl & Kuellmer, 2013). Turkey is on a path away from
democratic principles, which is reflected in its deteriorating degree of Internet
freedom (Freedom House, 2016c). In addition, both countries are having trouble
with safeguarding their (semi‐)democratic principles and rights because of the far‐
reaching state of emergencies active in both states (Mchangama, 2016; Yesil et al.,
2017). This is prevalent for any legislation introduced, and censorship activities
exercised in connection with terror‐related incidents (Human Rights Watch, 2015;
Yesil et al., 2017).
As already discussed, the current legislation in Turkey and Iran is far more
tolerant of restricting freedom of speech online than the legal environment in
France (Akgul & Kirlidog, 2015; Aryan et al., 2013; Baldino & Goold, 2014; Ilhan,
2015; Sreberny & Khiabany, 2010). This results in many more topics triggering
state‐imposed censorship in Turkey and Iran compared to France, as confirmed by
Kelly et al. (2016). In Table 2 we summarize the findings for the research period
June 2015 to May 2016, illustrating that Turkey and Iran censor many more topics
than does France. Out of ten subjects identified to provoke state‐imposed censor-
ship worldwide, France censors one topic, Turkey nine, and Iran all ten (Kelly
et al., 2016).
From the censored topic categories of Table 2 we can derive that Turkey dis-
tinguishes itself from Iran in terms of topic control only in not censoring “Social
Commentary” this topic is defined as a non political content and includes economic,
environmental, cultural, or educational issues (Kelly et al., 2016). This confirms
earlier findings that Turkish authorities censor politically and religiously related
content online (Akgul & Kirlidog, 2015; Sen, 2014; Yalkin et al., 2014). Interpreting
these findings further requires pointing out that the category “conflict” is defined by
Freedom House as “discussion or reporting on local or international instances of
violence, conflict, or terrorism” (Kelly et al., 2016). In particular, the censorship ap-
plied to content that is associated in any form with terrorism has exploded within the
past years, in France and Turkey (CNIL, 2016; Freedom House, 2016a, 2016c;
Mchangama, 2016). Both countries have experienced heavy spikes in censorship
activities right after terror‐related incidents (O’Connell, 2017; Toksabay, 2017; Tré-
guer, 2016b; Yesil et al., 2017).
In this context, we can see from the literature that the ruling actors in all three
countries are taking an opportunity in socially and politically disturbing times to
introduce new and harsher measures toward controlling the Internet. These
disturbances include threats to national security (especially terror attacks), child abuse
material scandals, or social unrest as a form of political opposition (Akgul & Kirlidog,
2015; Aryan et al., 2013; Baldino & Goold, 2014; Mchangama, 2016; Tréguer, 2016b; Yesil
 Table 2. Topics Censored Online in France, Turkey, and Iran Between June 2015 and May 2016

Ethnic and Overall

Topics Criticism of Political Social Mobilization for LGBTQI Religious Topics
Censored Authorities Corruption Conflict Opposition Satire Commentary Blasphemy Public Causes Issues Minorities Censored

France X 1
Turkey X X X X X X X X X 9
Iran X X X X X X X X X X 10

Source: Kelly et al. (2016).

Table 3. Key Internet Controls Applied in France, Turkey, and Iran Between June 2015 and May 2016

New law or Blogger or ICT

New law or Directive User Arrested, Technical
Political, Pro‐Government Directive Increasing Imprisoned, or in Attacks Against
Type of Social, or Localized or Commentators Increasing Surveillance or Prolonged Government Overall
Key Social Media or Religious Nationwide Manipulate Censorship or Restricting Detention for Critics or Key
Internet Communication Content ICT Online Punishment Anonymity Political or Social Human Rights Controls
Control Apps Blocked Blocked Shutdown Discussions Passed Passed Content Organizations Applied

France X X 2
Turkey X X X X X X 6
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship

Iran X X X X X 5

Source: Kelly et al. (2016).

17
18 Policy & Internet, 00:00

et al., 2017). This legitimizing of widespread censorship in the name of national security
or other current events has been criticized in the literature (Hellmeier, 2016).
When analyzing the means applied to control online content in France, Turkey,
and Iran, we can observe further similarities and differences. Again reflecting upon
data collected by Kelly et al. (2016), it is apparent that France is at a different stage
in exercising Internet censorship compared to Turkey and Iran, as exemplified in
Table 3 for the period June 2015 to May 2016 (Kelly et al., 2016), which is congruent
with the findings of the literature.
While Turkey and Iran already apply various technical and non‐technical
measures to achieve their desired level of censorship online, France focuses on
changing its legal framework to lay the grounds for an increasing degree of content
control (Akgul & Kirlidog, 2015; Baldino & Goold, 2014; Mchangama, 2016).The data
shows that Turkey and Iran apply an overwhelming amount of identical censorship
techniques, also described by researchers (Akgul & Kirlidog, 2015; Aryan et al., 2013;
Baldino & Goold, 2014; Ilhan, 2015; Sen, 2014; Sreberny & Khiabany, 2010; Woj-
cieszak & Smith, 2014; Yalkin et al., 2014). As already discussed, the technical means
applied lead to regular restrictions to connectivity in Iran (Baldino & Goold, 2014;
Freedom House, 2016b) and extensive connectivity disruptions in Turkey (Akgul &
Kirlidog, 2015; Freedom House, 2016c; Sozeri, 2016).
A further important aspect to analyze is the level of transparency provided by
governments and official institutions within the three countries. France exercises
the highest transparency in the comparison and shares a minor degree of official
publications on censored content with Iran. France's government publishes official
statistics on the number of websites blocked and the country’s courts provide
reasoning behind their decisions (CNIL, 2016; Lehn, 2017; Mchangama, 2016;
O’Connell, 2017). However, there is no detailed publication listing all blocked
websites (Lehn, 2017). Iran ensures a certain transparency for their censorship ac-
tivities by at least instructing users that certain content is blocked and by which
entity through official publications and ad hoc information (Aryan et al., 2013;
Baldino & Goold, 2014). Turkey however acts different, and provides no official
information on censorship activities—neither to those affected by censorship
measures nor to the public (Akgul & Kirlidog, 2015; Yesil et al., 2017).

Key Driving Factors in Internet Censorship

Ruling System

The form of government is a decisive factor for the extent of Internet censorship
applied in the three countries. The democratic structures in France, including an
effective opposition and widespread public debate, present a strong counterweight
against the introduction and exertion of new forms of censorship in the country
(Breindl & Kuellmer, 2013). In addition, the country is internationally integrated
into a larger union of democratic states and thus subject to international agree-
ments, which value freedom of expression (Wright & Breindl, 2013). All this poses
effective limitations to governmental censorship efforts. In contrast, the author-
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 19

itarian ruling castes in Turkey and Iran can govern the country without fierce
political opposition (Baldino & Goold, 2014; Yesil et al., 2017), thus allowing for the
steady introduction of new censorship measures despite societal criticism.

Institutional Setup

Another key factor for the degree of Internet censorship applied in the three
countries is the institutional setup, which reflects the ruling system. In France,
strong separation of powers is present and constitutional control mechanisms are in
place (Breindl & Kuellmer, 2013; Wright & Breindl, 2013). Checks and balances are
valued on all institutional levels, even though some supervisory authorities fail to
act objectively in all cases (Human Rights Watch, 2015). This institutional setup
poses limits on the power of the government in exercising Internet censorship. The
separation of powers in Turkey and Iran is, however, limited (Akgul & Kirlidog,
2015; Baldino & Goold, 2014; Yesil et al., 2017) resulting in less institutional control
of government, and allowing for unregulated Internet censorship.

National Identity

National identity is a key factor in the extent of online content control in all
three countries, determining what topics trigger censorship activities, and with the
historic and religious identity shaping the constitutional regulation of freedom of
expression (Akgul & Kirlidog, 2015; Baldino & Goold, 2014; Wright & Breindl,
2013). This in return defines the basis on which the governing class can or cannot
introduce censorship measures. Prevalent cultural and moral values determine
accepted limitations imposed on free speech (Akdeniz, 2010) and thus opposition to
censorship in society.

Technical Ability

Technological advances and resources influence censorship applied across all

countries. Higher degrees of professionalism on government levels allow for a
more sophisticated and thus less detectable application of state‐imposed censorship
activities (Anderson, 2013; Pearce et al., 2017). In addition, higher degrees of do-
mestic technological savvy allow for a censorship application that is less dependent
on foreign technology (Aryan et al., 2013). The technical abilities of governments
also influence the effectiveness of circumvention techniques available to bypass
state‐imposed censorship measures (Subramanian, 2012). Hence, the degree of
governmental technological savvy drives the overall degree of online content
control and its factual enforceability across all three states.

Political Opportunity

We identify the fifth driver as a political opportunity. This reflects that

the political elite in all three countries seizes unstable times, political crisis, social
20 Policy & Internet, 00:00

unrest, or current external threats—such as threats to national security—to

push through harsher legislation limiting freedom of expression (Baldino &
Goold, 2014; Tréguer, 2016b; Yesil et al., 2017). Rough times are partially used
to lever the controlling institutions and factors installed in each country
(Mchangama, 2016; Yesil et al., 2017). This is prevalent for the current situations
in France and Turkey, which continue to govern under the state of emergency
legislation.

Conclusion

The analysis revealed that Turkey and Iran share many similarities in the ex-
ecution of Internet censorship, while showing many differences to France. While
Iranian citizens have long faced and continue to face a high level of censorship
activities (Aryan et al., 2013; Baldino & Goold, 2014; Freedom House, 2016b),
Turkish citizens are challenged by a censorship level that is rising at an alarming
pace (Akgul & Kirlidog, 2015; Freedom House, 2016c; Yesil et al., 2017). In contrast
to Turkey and Iran, France’s overall degree of Internet censorship is low, with its
Internet being categorized as “free” (Freedom House, 2016a). However, when
studying the most recent development toward substantially higher levels of cen-
sorship in the country and reflecting upon its status as a liberal democracy (Human
Rights Watch, 2015; Mchangama, 2016; Tréguer, 2016a), this development is just as
alarming.
Several questions came up that could not be answered by the available liter-
ature. Since Internet censorship is a wide and dynamic field, we note three main
ideas for future research.
There is a lack of intensive research and data available on Internet cen-
sorship in France compared to Turkey and Iran. However, since the environ-
ment for online freedom is changing at the moment, developments in France
(and other democracies) should be closely monitored. Our research has noted
the lack of academic research on cross‐country comparisons and the tracking
of developments over a longer period of time in the literature. Further
cross‐country analysis over time could contribute to understand the inter-
relations between censorship activities in different countries. Investigating and
comparing the Internet topology in several countries for critical connection
points that could be used for censorship and its circumvention could provide
another empirical line of investigation (Baumann & Fabian, 2013; Cowie, 2009;
Yacobi‐Keller et al., 2019).
Overall, considering that we live in a world where free speech is at its lowest
level in 10 years (Mchangama, 2016), academics should continue their important
work and efforts in bringing transparency to this alarming trend.

Vasilis Ververis, HU Berlin, Berlin, Germany [ververis@kth.se].

Sophia Marguel, HU Berlin, Berlin, Germany.
Benjamin Fabian, HU Berlin, Berlin, Germany.
Ververis/Matguel/Fabian: Cross‐Country Comparison of Internet Censorship 21

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