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THE CONCEPTS OF "CYBERTERRORISM" AND THE PROBLEMS OF ITS
DEFINITION
The article discusses the main approaches to the definition of cybercrime, the essence and features of cyberterrorism, which determine the directions of combating these crimes. The necessity and relevance of cooperation within the framework of international organizations is due to the global spread of this type of crime. Ensuring information security in general is one of the priority areas of activity of regional associations and the entire international community. International cooperation on cybersecurity should be systematic, comprehensive and consistent, but it will be effective and successful only with the participation of all states.
In this regard, providing adequate forms of countering the dissemination of information prohibited by law, including in social networks, has become an urgent need.
Keywords: terrorism, crime, globalization, telecommunication technologies, Internet, terrorist organizations, social networks, globalization, extremism, international counteraction.
The lack of a universally accepted definition of terrorism is an obstacle in describing the nature of cyberterrorism without referring to conventional terrorism. Generally, a common definition is required for two reasons: firstly, to definitively determine the status of customary law pertaining to the use of force in relation to acts of terror; and secondly, to criminalize such acts1, i.e. to prevent terrorism, to condemn it, and to punish it. Worth noting is also that international demand to extradite a terrorist offender far exceeds pressure to extradite a common criminal.2
The various suggestions made by academics on how to define this concept are only partially overlapping and range from those including social aspects (terrorism is motivated by "egoism, intolerance, lack of dialogue and inhumanity, greed and
1 See also Clive Walker, The Legal Definition of "Terrorism" in United Kingdom Law and Beyond, 2007 PUB. L. 331, 336 (2007).
2 LAWRENCE T. GREENBERG ET AL., INFORMATION WARFARE AND INTERNATIONAL LAW 21-33 (1998), cited in Daniel M. Creekman, A Helpless America? An Examination of the Legal Options Available to the United States in Response to Varying Types of Cyber Attacks from China, 17 AM. U. INT'L. L. REV. 663 (2002)
Said Saidakhrarovich Gulyamov
Alikhontura Ibodullokhon ugli Khojiamonullokhonov
4th year student of Tashkent State University of Law
Doctor of Law, Professor
ABSTRACT
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accountability") or psychological ones ("terrorism is a tactic to coerce behavioral change in an adversary")4 to very thorough legal approaches ("one must distinguish between attitude [and] methods"5 of terrorism).
What distinguishes cyberterrorism from conventional terrorism is the use of (mostly internet-based) computer networks. 6In essence, it is the use of electronic links in order to carry out terrorist attacks, usually involving programs created for that purpose. These programs can be delivered to their destination either through Internet, portable storagedevices (such as USB cards), wireless radio signals, or other similar means.
Cyberterrorism should be viewed separately from the terrorist use of the Internet,
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which involves such aspects as communication, recruitment, funding, organization of
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physical attacks, propaganda (also in the form of "hacktivism"), incitement to terrorism, and apology of terrorism. At the same time, certain cyber-operations (e.g., intrusions into critical infrastructure databases to collect information on vulnerable targets) can further cyberextremists' cause,9 but are not acts of cyberterrorism on their own. Scholars like Conway (who builds on Anderson's suggestion), also propose dividing cyber-attacks into Internet "use" (expression of ideas and communication), "misuse" (disrupting or compromising websites or infrastructure), "offensive use" (using Internet to cause damage or engage in theft), and "cyberterrorism." The term "cyberterrorism" itself predates 9/11,10 although lack of universal definitions of "cyber-attack" and "terrorism" has resulted in every expert having his own understanding of the term. The confusion has been exacerbated by the media which has the tendency of randomly characterizing minor cyber-attacks as "cyberterrorism."11
As in the case of "terrorism", academics have proposed a wide array of possible
3 PAUL MEDHURST, GLOBAL TERRORISM: A COURSE PRODUCED BY THE UNITED NATIONS INSTITUTE FOR TRAINING AND RESEARCH 1 (2000), cited in Harry R. Jackson, Understanding Terrorism (unpublished thesis, Peace Operations Training Institute), available at http://media.peaceopstraining.org/theses/jackson.pdf.
4 Laurence Andrew Dobrot, The Global War on Terrorism: A Religious War?, STRATEGIC STUD. INST. 6 (2007), available at http://www.strategicstudiesinstitute.army. mil/pdffiles/pub822.pdf.
5 Jean-Marc Sorel, Some Questions About The Definition of Terrorism and The Fight Against its Financing, 14 EUR. J. INT'L L. 365, 371 (2003); see also G.A. Res. 51/210, 1 2, U.N. Doc. A/RES/51/210 (Dec. 17, 1996) ("Reiterates that criminal acts intended or calculated to provoke a state of terror in the general public, a group of persons or particular persons for political purposes are in any circumstance unjustifiable . . . .").
6 See S.S. Raghay, Cyber Security in India's Counter Terrorism Strategy, INTEGRATED DEFENSE STAFF 2 (Sept. 15, 2012), ids.nic.in/art_by_offids/Cyber security in india by Col SS Raghav.pdf.
7 James A. Lewis, The Internet and Terrorism, 99 AM. SOC'Y INT'L L. 112, 114 (2005) ("One of the characteristics of terrorist websites is their ability to manage rapid changes of Internet addresses. When authorities force a site to move, informal networks based on chatrooms or e-mail inform the group's supporters of the new network address.")
8 See Elina Noor, The Problem with Cyber Terrorism, 2 SOUTHEAST ASIA REGIONAL CTR. FOR COUNTER-TERRORISM 51, 52 (2011)
9 Roland Heickero, Terrorism Online and the Change of Modus Operandi, SWEDISH DEFENCE RESEARCH AGENCY 7 (Sept. 15, 2012), http://www.unidir.ch/pdf/ conferences/pdf-conf334.pdf
10 Sam Berner, Cyber-Terrorism: Reality or Paranoia?, 5 S. AFR. J. INFO. MGMT. 1, 1 (2003).
11 Taliharm, supra note 7, at 63.
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definitions that could cover this concept. The suggestions include those concentrating on the disruptive and destabilizing nature of cyberterrorism, limiting it only to individuals and non-state perpetrators, focusing on wider psychological effects (fear), malware writing process, involving attacks on critical national infrastructures, and
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attacks damaging networks themselves. There have also been opinions expressed that
the concept of cyberterrorism has no right to exist at all, since terrorism requires a 1
physical attack.
Taking all these factors into account, from a legal perspective, the best definition that would describe the notion of (conventional) cyberterrorism today is: the use of electronic networks taking the form of a cyber-attack to commit a) a substantive act criminalized by the existing legal instruments prohibiting terrorism, or b) an act of terrorism under international customary law.
To put this definition into context, it is essential to establish who the possible perpetrators are and what objects are likely to be targeted when it comes to cyberterrorism.
Referring to the legislation of the Republic of Uzbekistan, it should be noted that the term cyberterrorism is not legally defined, although it is freely used by everyone. This circumstance is recognized as the most problematic factor in detecting and combating an attack in cyberspace. However, there is a law of the Republic of Uzbekistan "On Cybersecurity", which was adopted by the Legislative Chamber of the Republic of Uzbekistan on February 25, 2022. This regulatory document defines "cybercrime", a set of crimes carried out in cyberspace using software and technical means, with the aim of seizing information, changing it, destroying or hacking information systems and resources.14
The term "terrorism" itself is enshrined in Article 2 of the Law of the Republic of Uzbekistan "On combating terrorism". There is no more detailed definition in any legal documents.
Referring to the decisions of UN experts, the concept of "cybercrime" includes any illegal act committed in an electronic network or using it15. Cyberterrorism is a serious global problem, the essence of which has been little studied.
12 Gabriel Weimann, Cyberterrorsim: The Sum of All Fears?, 28 STUD. IN CONFLICT & TERRORISM 129, 130 (2005), cited in Clive Walker, Cyber-Terrorism: Legal Principle and Law in the United Kingdom, 110 PENN ST. L. REV., 625, 634 (2006).
13 J. P. I. A. G. Charvat, Cyber Terrorism: A New Dimension in Battlespace, CENTRE OF EXCELLENCE DEFENCE AGAINST TERRORISM 7 (2009), available at http:// www.ccdcoe.org/publications/virtualbattlefield/05_CHARVAT_Cyber%20Terrorism.pdf
14 The Law of the Republic of Uzbekistan dated April 15, 2022 No. ZRU-764 On Cybersecurity. [electronic resource] -The mode is available: https://lex.uz/en/docs/5960609
15 Crimes related to the use of a computer network / Tenth UN Congress on the Prevention of Crime and the Treatment of Offenders //A/CONF. 187/10.
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The Council of Europe Convention on Cybercrime played an important role in determining which acts can be regarded as cybercrime16. It was adopted on November 23, 2001 in Budapest. The Convention entered into force on 1 July 2004. It is the only binding international instrument in this field.
The Convention divided such crimes into five groups.
Firstly, these are crimes against the confidentiality, integrity and availability of computer data and networks (articles 2-6).
Secondly, offenses related to the use of computer tools (Articles 7-8). Here we are talking about fraud in cyberspace, by entering, changing, destroying or blocking data, or other similar interference with a computer system for profit.
Thirdly, offences related to the content of data (article 9). Much attention is paid to offenses related to child pornography. The paragraphs of the convention explain in detail what actions should be prosecuted by law. These are: 1) the production of child pornography for the purpose of distribution through a computer system; 2) the offer or provision of child pornography through a computer system; 3) the distribution or transmission of child pornography through a computer system; 4) acquisition of child pornography through a computer system for yourself or for another person; 5) possession of child pornography located in a computer system or on computer data carriers.
Fourth, offenses related to the violation of copyright and related rights (Article 10). The establishment of a crime in this area should be based on compliance with the obligations imposed by the Paris Act of 24.07.71 (with the amendment. dated 02.10.79), the Berne Convention for the Protection of Literary and Artistic Works, the WIPO Copyright Treaty and the WIPO Agreement on Trade-Related Aspects of Intellectual Property.
And the last one is an attempt, complicity or incitement to commit a crime (articles 14-23).
However, not all countries of the world have adopted this Convention, which again confirms the lack of a single concept of what can be considered an act of cyberterrorism and what actions should be taken to prevent or combat it.
Many countries have not signed this convention because of an article that assumes universal access to all data stored on computers, which allows special forces to conduct operations in cyberspace of other countries. The authorities considered this a violation of sovereignty and a threat to the security of the state.
16 The Council of Europe Convention on Cybercrime of November 23, 2001 - [Electronic resource]. - Available from the URL: http://online .zakon.kz/Document/?doc_id=30170556#pos=7;-93
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According to F.According to Williams, the Internet is one of the key tools of criminals, and its anonymity creates an ideal space for committing any illegal acts. He also notes that the main trend of cybercrime is the growth of cyber extortion. They can be carried out through the destruction or, conversely, the publication of some information data, the destruction of websites, electronic systems, which can bring great criminal profit. He calls "money laundering" another trend. The Internet provides significant opportunities to move money, intercept electronic payments, and carry out illegal transactions.
A very important point for the predestination of the act of cyberterrorism itself is the establishment of the subject and object of this crime, which characterize the type, structure and factors of cybercrime. The subjects of crime in cyberspace can be States or certain governments, non-State actors, united corporations, as well as individuals.
States as a subject of cyberterrorism in cyberspace.
Controversy regarding possible direct state involvement in conventional acts of terrorism seems less actual when viewed within the context of cyber-space.
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While the Draft Comprehensive Convention remains deadlocked on this issue, neither of the eighteen existing legal instruments foresee state responsibility for an act of terrorism, so one must turn to international customary law for guidance.
Initially, state terrorism, which can even be the cause of anti-state extremism, has been included in the discussions regarding the definition for three reasons: firstly, due to a historically different meaning of this concept; secondly, because states cause wider destruction in comparison to non-state actors; and finally, since certain forms of
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violence against civilians occur as part of the counter-terrorism campaigns.
"State terrorism" may be divided into two categories: internal and external. Within historical context, "internal state terrorism" entailed the use of force against its own civilian population to weaken the morale and destroy willingness to resist the government's will, while "external state terrorism" targeted foreign populations.19 Situations where a state uses cyber-attacks against its civilians are very unlikely, as they would be very inefficient: firstly, physical "punishment" is easier to carry out and it creates more fear (e.g., it is much easier to order the soldiers to shoot down a civilian airplane than to use cyber-attacks against it), and secondly, a significant part of civilian infrastructure usually belongs to the state itself. In situations where governments do not
17 Compare the western draft ("the activities undertaken by the military forces of a State in the exercise of their official duties, inasmuch as they are governed by other rules of international law, are not governed by this Convention") with the OIC version
18 See generally RICHARD JACKSON, LEE JARVIS, JEROEN GUNNING & MARIE BREEN SMYTH, TERRORISM: A CRITICAL INTRODUCTION (2011).
19 DONALD J. HANLE, TERRORISM: THE NEWEST FACE OF WARFARE 164 (Yonah Alexander ed., 1989).
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have effective control over some part of their territory due to foreign occupation or civil war, Geneva Conventions would automatically apply and state violence would have to be viewed within the framework of international humanitarian law (this will be further discussed in a separate sub-chapter below). The notion of "external state terrorism," on the other hand, is unlikely to crystallize in customary law in the future, since customary norms arise from state behavior and require their acceptance.
It would seem that a majority of countries today believe a state cannot be a perpetrator of conventional terrorism, as evidenced by the large number of signatories to the existing twelve conventions and their protocols without reservations regarding this
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matter (with minor exceptions20). Therefore, the theory of state terrorism that may be viable in relation to conventional extremism does not apply in cyber-space.
This does not rule out the possibility of indirect state involvement in the form of state-sponsored cyberterrorism. It must be said that allowing their territories to be used
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for acts against the rights of other states is illegal according to the ICJ , while the Friendly Relations Declaration imposes a duty upon countries "to refrain from organizing, instigating, supporting or participating in acts of civil strife or terrorist acts
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in another State or acquiescing in . . . such acts . . . ." If one country organizes, actively supports, or contributes to the commission of one or more terrorist offences
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through cyber-space, it can be said to be a state-sponsor of cyberterrorism. Non-State Actors as a subject of cyberterrorism in cyberspace.
Non-state actors have been consistently viewed as groups capable of perpetrating acts of terror and this status nowadays stems from the international
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customary law. This is evidenced by a number of the UN Security Council documents , the Resolution 1526 reiterating its condemnation of the Al-Qaida network and other associated terrorist groups for criminal terrorist acts, the Resolution 1530 condemns the bomb attacks in Madrid, Spain, committed by the terrorist group ETA. Moreover, the Resolutions 1963, and 1989 expressing concern at the increase in incidents of kidnapping and hostage-taking committed by terrorist groups.
Currently there are over one hundred international terrorist organizations ranging from small groups designated as such by a few states (Fianna Eireann, Harkat-
20 See International Convention for the Suppression of Terrorist Bombings, Dec. 15, 1997, S. TREATY DOC. NO. 106-6 (1998). Cuba refers to "state terrorism" in its respective reservations to
21 See Corfu Channel (Merits), 1949 I.C.J. 4, 22 (Apr. 9)
22 See Declaration on Principles of International Law Concerning Friendly Relations and Co-Operation Among States in Accordance with the Charter of the United Nations, G.A. Res. 2625 (XXV), Principle 1, t 9, U.N. Doc. A/8082 (Oct. 24, 1970)
23 Allen D. Walker, Applying International Law to the Cyber Attacks in Estonia 13 (Apr. 2008) (unpublished graduation requirement report) (on file with the Air Command and Staff College, Air University, Maxwell Air Force Base, Alabama).
24 See generally S.C. Res. 1989, U.N. Doc. S/RES/1989 (June 17, 2011); S.C. Res. 1988, U.N. Doc. S/RES/1988 (June 17, 2011); S.C. Res. 1963
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ul-Jihad-al-Islami, People's Mujahedin of Iran) to groups widely recognized as terrorist organizations (Al-Qaeda, Lashkare-Taiba, Asbat al-Ansar). In the modern world, there are plenty of cyber safe havens where these groups can operate without fear of direct
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reprisal. The success of counter-terrorist operations is likely to encourage these nonstate actors to turn to cyberterrorism and some groups, having lost their physical sanctuary in key areas, have turned to the sanctuary of cyberspace.26
In 1999, the Center for the Study of Terrorism and Irregular Warfare at the Naval Postgraduate School in Monterey defined three levels of organizations' cyberterrorism capability:
1. Simple-Unstructured: The capability to conduct basic hacks against individual systems using tools created by someone else. The organization possesses little target analysis, command and control, or learning capability.
2. Advanced-Structured: The capability to conduct more sophisticated attacks against multiple systems or networks and possibly, to modify or create basic hacking tools. The organization possesses an elementary target analysis, command and control, and learning capability.
3. Complex-Coordinated: The capability for coordinated attacks capable of causing mass-disruption against integrated, heterogeneous defenses (including cryptography). Ability to create sophisticated hacking tools. Highly capable target
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analysis, command and control, and organization learning capability.
In 2002 evidence showed that Al-Qaeda considered a cyber-attack against a dam,28 and in 2005 the group planned to bring down the entire internet traffic in the UK. The Real IRA declared "the future lay in cyberterrorism rather than car bombs" and supporters of the Liberation Tigers of Tamil Eelam in the past have spammed Sri
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Lankan embassies with emails meant to disrupt their communications.29 Though cyberterrorism has not yet caused any casualties, these examples demonstrate that existing terrorist groups are interested in inflicting damage through cyber-space and in cyberterrorism per se. The low level of their technical expertise ("simple-unstructured")
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can be, and sometimes is, compensated by recruiting technically-skilled individuals 30to
25 See generally Kenneth Geers, Cyber Weapons Convention 26 COMPUTER L. & SEC. REV. 547 (2010).
26 Gabriel Weimann, Cyberterrorism: How Real Is the Threat?, U.S. INST. OF PEACE, Dec. 2004, at 1, 11.
27 BILL NELSON, RODNEY CHOI, MICHAEL IACOBUCCI, MARK MITCHELL & GREG GAGNON, CYBERTERROR: PROSPECTS AND IMPLICATIONS, at IX (1999), cited with approval in Dorothy E. Denning, Cyberterrorism: Testimony before the Special Oversight Panel on Terrorism, Committee on Armed Services, U.S. House of Representatives, GEORGETOWN UNIV. (May 23, 2000), http://www.cs.georgetown.edu/~denning/infosec/ cyberterror.html
28 Shima D. Keene, Terrorism and the Internet: A Double-Edged Sword, 14 J. MONEY LAUNDERING CONTROL 359, 364-65 (2011).
29 Denning, supra note 64
30 Andrew Rathmell, Cyber-Terrorism: The Shape of Future Conflict?, 6 J. FIN. CRIME 277, 279 (1999).
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improve the terrorists' capabilities in this regard.
Entire groups of cyber-criminals can work together and even merge with known terrorist organizations if they share similar radical views, religious or socio-political
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interests, in order to engage in cyberterrorism. Alternatively, extremists can obtain knowledge and necessary programs from hacker teams for a fee.
Corporations as a subject of cyberterrorism in cyberspace.
Corporations have long been objects of cyber-attacks, eventually leading to their heavy investment in information technology (IT) security . This, in turn, resulted in them having the most advanced cyber-defense (and logically, cyber-offense) capabilities, which exceed those of many states. In a world that moves away from
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"statecentrism," the know-how, relative autonomy of operations, significant funding and a structured team of experts make corporations a potential perpetrator of cyberterrorist acts. Though their cyber-attacks are likely to target competitors, 34companies (especially multilateral corporations) may be interested in destabilizing a country's (or the entire world's) economy for profit, or they may be guided by the extremist views of their leadership.
Unlike terrorist organizations, corporations are often pressured to be more
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transparent, and to have a legal personality within their host state. Though this does not preclude criminal behavior, this makes them a special category of non-state actors ("any person") that can be held legally responsible for offenses criminalized by existing anti-terrorism conventions. In other words, aside from the leadership of the corporation and members of the IT team that was directly involved in cyberterrorism, it is possible to prosecute the company itself, if the respective legal systems permit it. Individuals as a subject of cyberterrorism in cyberspace.
Finally, like the independent cyber-criminal groups, individual persons may engage in acts of terrorism online, if motivated by money, prestige or ideology.36 These one-man cyberterrorists (so to say, "cyber-Breiviks") who have the knowledge
31 CLAY WILSON, BOTNETS, CYBERCRIME, AND CYBERTERRORISM: VULNERABILITIES AND POLICY ISSUES FOR CONGRESS 18 (2008).
32 Compare this to smaller enterprises, some of which, in the words of U.S. adviser on cybersecurity Richard Clarke, "spend more on coffee than on cyber-security." See Robert Lemos, Security Guru: Let's Secure the Net, ZDNET.COM (Feb. 19, 2002, 12:25 PST), http://www.zdnet.com/news/security-guru-lets-secure-the-net/120859
33 TOBY BLYTH, CYBERTERRORISM AND PRIVATE CORPORATIONS: NEW THREAT MODELS AND RISK MANAGEMENT IMPLICATIONS 24 (1999).
34 Jason Barkham, Information Warfare and International Law on the Use of Force, 34 N.Y.U. J. INT'L L. & POL. 57, 104 -05 (2001) (discussing information warfare as a new type of weapon).
35 United Nations Conference on Trade and Development, Geneva, Switz., 2004, Disclosure of the Impact of Corporations on Society: Current Trends and Issues, UNCTAD/ITE/TEB/2003/7 (Aug. 26, 2004).
36 Suleyman Ozeren, Global Response to Cyberterrorism and Cybercrime: A Matrix for International Cooperation and Vulnerability Assessment (Aug. 2005) (dissertation prepared for philosophy doctorate, University of North Texas) (on file with author).
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'in
necessary to conduct online attacks37 work alone, and, like their less sophisticated counterparts, can be divided into categories revealing their motivations: psychopathic terrorists (individuals who seek satisfaction in the need to control), religious and political ethno-geographic terrorists (struggling for a "group-cause"), and retributional terrorists (persons who suffered an atrocity against themselves, their family, or
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community). In addition, cyberterrorism includes other categories of persons which are not typical to traditional extremism, such as the greed-prompted (offering to wage cyberterrorism for a fee) or "rebels" (who protest against the entire world order; this
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category includes teenage cyber-criminals as well).
As mentioned previously, the existing treaty regime pertaining to terrorism allows for the prosecution of individuals for terrorism (and cyberterrorism as its sub-category). It should be noted though that states may have an interest in avoiding prosecution of "talented" cyberterrorists, if those cyberterrorists act in the interests of the state. Due to the lack of cyber-experts, they can even be seen as limited state assets.40 Obviously this approach would be a violation of a country's legal obligations, and could possibly be seen as state-sponsorship of cyberterrorism.
List of used resources
1. The Law of the Republic of Uzbekistan dated April 15, 2022 No. ZRU-764 On Cybersecurity. [electronic resource] - The mode is available: https://lex.uz/en/docs/5960609
2. Crimes related to the use of a computer network / Tenth UN Congress on the Prevention of Crime and the Treatment of Offenders //A/CONF. 187/10.
3. The Council of Europe Convention on Cybercrime of November 23, 2001 -[Electronic resource]. - Available from the URL: http://online .zakon.kz/Document/?doc_id=30170556#pos=7;-93
4. Clive Walker, The Legal Definition of "Terrorism" in United Kingdom Law and Beyond, 2007 PUB. L. 331, 336 (2007).
5. LAWRENCE T. GREENBERG ET AL., INFORMATION WARFARE AND INTERNATIONAL LAW 21-33 (1998), cited in Daniel M. Creekman, A Helpless America? An Examination of the Legal Options Available to the United States in Response to Varying Types of Cyber Attacks from China, 17 AM. U. INT'L. L. REV.
37 Sean M. Condron, Getting it Right: Protecting American Critical Infrastructure in Cyberspace, 20 HARV. J.L. & TECH. 404, 404-06 (2007) (discussing the growing threat of cyber attacks).
38 Raymond H. Hamden, The Retributional Terrorist: Type 4, in 2 THE PSYCHOLOGY OF TERRORISM: CLINICAL ASPECTS AND RESPONSES 174 (Chris E. Stout ed., Greenwood 2002)
39 Arun Kr. Singh & Ahmad T. Siddiqui, New Face of Terror: Cyber Threats, Emails Containing Viruses, 1 ASIAN J. TECH. & MGMT. RES. (2011) (discussing the new face of terror).
40 JEFFREY CARR, INSIDE CYBER WARFARE 29 (2009)
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663 (2002)
6. PAUL MEDHURST, GLOBAL TERRORISM: A COURSE PRODUCED BY THE UNITED NATIONS INSTITUTE FOR TRAINING AND RESEARCH 1 (2000), cited in Harry R. Jackson, Understanding Terrorism (unpublished thesis, Peace Operations Training Institute), available at http: //media.peaceopstraining. org/theses/j ackson.pdf.
7. S.S. Raghay, Cyber Security in India's Counter Terrorism Strategy, INTEGRATED DEFENSE STAFF 2 (Sept. 15, 2012)
8. Elina Noor, The Problem with Cyber Terrorism, 2 SOUTHEAST ASIA REGIONAL CTR. FOR COUNTER-TERRORISM 51, 52 (2011)
9. Roland Heickerö, Terrorism Online and the Change of Modus Operandi, SWEDISH DEFENCE RESEARCH AGENCY 7 (Sept. 15, 2012)
10. Sam Berner, Cyber-Terrorism: Reality or Paranoia?, 5 S. AFR. J. INFO. MGMT. 1, 1 (2003).
11. RICHARD JACKSON, LEE JARVIS, JEROEN GUNNING & MARIE BREEN SMYTH, TERRORISM: A CRITICAL INTRODUCTION (2011).
12. DONALD J. HANLE, TERRORISM: THE NEWEST FACE OF WARFARE 164 (Yonah Alexander ed., 1989).
13. International Convention for the Suppression of Terrorist Bombings, Dec. 15, 1997, S. TREATY DOC. NO. 106-6 (1998).
