begging the question of whether a cyber operation that affects this right may qualify as a countermeasure or, instead, is precluded on the basis that the right is ‘fundamental’, as that term is understood with respect to Article 50(1)(b). The International Group of Experts could achieve no consensus on this point. A further issue is the extraterritorial applicability of human rights norms. As discussed in Rule 34, whether or how human rights apply extraterritorially is unsettled and controversial.
