On November 26, 2015, the European Court of Human Rights (Court) ruled in Annen v. Germany that a prohibition on the distribution of anti-abortion leaflets near a clinic violated an activist’s freedom of expression. According to the press release, Mr. Annen had been distributing leaflets in the vicinity of a day clinic that performs abortions and had alleged that the doctors were performing “unlawful abortions.” The leaflets also contained a reference to the Holocaust, as well as information for his website “babycaust.de” where he listed “abortion doctors” with their names and addresses. The leaflet further stated, in smaller letters, that abortion is not criminally punishable and allowed by the German legislator. Two doctors from the clinic won an injunction in German civil court, which ordered Mr. Annen to stop distributing leaflets in the vicinity of the clinic and remove the doctor’s names and addresses from his website. The Court disagreed with the German court’s decision, and focused on the distinction in German criminal law between lawful abortions and unlawful, but not criminal abortions. It concluded “that the applicant’s statement . . . was at least not in contradiction with the legal situation with regard to abortion in Germany” and the statement that there was no criminal liability was sufficiently clear, even to a layperson. Further, the Court refused the interpretation that Mr. Annen had equated abortion with the Holocaust and thereby violated the doctor’s personality rights. Rather, the Court found that singling out the two doctors had “enhanced the effectiveness of his campaign” and found that “the applicant’s statement according to which the killing of human beings in Auschwitz had been unlawful, but allowed, and had not been subject to criminal liability under the Nazi regime, may also be understood as a way of creating awareness of the more general fact that law may diverge from morality.”