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According to Professor Akhavan, “the divided opinion of the Grand Chamber, and the alarming increase in extremist violence in Turkey, is the clearest indication that the question of racist hate speech against Armenians is far from resolved, and that it will require constant vigilance. What is clearly established by the Judgment, however, is unanimity among all seventeen judges, that the Armenians did in fact suffer massacres and mass deportations at the hands of the Ottoman Empire from 1915 onwards, irrespective of its legal characterization one way or another."

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