ON THE FACTS CLAIMED BY THE APPLICANT: 8. In 2015, the Defendant issued a law, entitled “Cybercrime (Prohibition and Prevention, etc.) Act, 2015”, which has 59 articles. 9. In particular, Section 24 of that Act, in clear terms, limits freedom of expression on the Internet or the use of any computer device and imposes fines of 10,000,000 naira (ten million Naira) to 25,000,000 naira (twenty-five million Naira) and makes provision for penal sanction ranging from three (3) to ten (10) years in prison. 10. Since the enactment of the Act in 2015, the Defendant has religiously used the Cybercrime (Prohibition and Prevention, etc.) Act of 2015 to intimidate the Applicant, its members, associates and employees. 11. The information regarding the arbitrary use of the cybercrime (Prohibition and Prevention, etc.) Act of 2015, by the Defendant, is as follows: i. On August 8th, 2015, Abubakar Sidiq Usman was arrested. ii. On August 20th, 2015, Musa Babare Azare was arrested in Bauchi State by the Defendant for criticizing its Governor of State on Facebook and Twitter. He was taken to Abuja, where he was held for 36 hours. iii. On August 25th, 2015, Seun Oloketuyi was arrested and detained and brought before the Lagos Federal Supreme Court in charge of cybercrimes and held in prison, but later he was released on bail in a sum of 3,000,000 Naira. iv. On September 1st, 2015, Chris Kehinde Nwandu, President of the Guild of Professional Bloggers of Nigeria, was arrested for sharing a story on Facebook, brought to the Court, he was denied bail on three occasions, and remained in prison for 13 days. v. In September 2015, Emmanuel Ojo was brought to the Court for a publication made on Facebook, and was later also brought before the Supreme Federal Court. vi. In October 2015, Desmond Ike Chima, a blogger, was victim of cyber persecution by the Court of Justice and spent six months in prison before being released on parole. 3