Section 24 of that Law, in clear terms, limits freedom of expression on the Internet or the use of any computer device and imposes fines from 10,000,000 Naira (ten million Naira) to 25, 000,000 Naira (twenty-five million) and makes provision for penalties of three (3) to ten (10) years in prison. 27. The Defendant State denies the facts claimed by the Applicant and puts the Applicant to the strictest proof of the facts contained in point 4.4. of the declaration of facts. 28. The Defendant states, in a specific response to paragraphs 4.4 of the Applicant's declaration of facts, that: (a) It never intimidated, harassed, jailed or tortured any member of the press for exercising their freedom of expression, within the law, including the Applicant's members, associates and employees. (b) It never violated the freedom of expression of any citizen on the Internet or anywhere. (c) It always maintained the rule of law, while recognizing and giving effect to the human rights of its citizens, including those of the Applicant. (d) That it legally uses its Cybercrime (Prohibition and Prevention) Act objectively, in accordance with its domestic laws and those of the International Community, without any arbitrary use. 29. That section 24 of the Cybercrime (Prohibition, Prevention, etc.) Act has never been used and will never be used as a tool to violate freedom of expression and press, legally guaranteed under the rights of the African Charter on Human and Peoples' Rights, the ECOWAS Revised Treaty and the 1999 Constitution of the Federal Republic of Nigeria (as amended). 30. The Defendant further maintained that the case brought by the Applicant revolves around the legality or not of Section 24 of the Cybercrime (Prohibition, Prevention, etc.)Act, 2015, which provides as follows: 8

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