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Journal of Business Continuity & Emergency Planning Volume 12 Number 1

Corporate risk from extremist groups

John Sancenito Received (in revised form): 6th March, 2018 Information Network Associates, Inc., 5235 North Front Street, Harrisburg, PA 17110, USA Tel: +1 717 599 5505; E-mail: [email protected]

John Sancenito, CPP is President of Information Network Associates, Inc. Mr Sancenito is a retired police officer and former county detective with the Criminal Investigation Division of the Cumberland County Pennsylvania District Attorney’s Office. He is the former Chairman o f the Pennsylvania Insurance Fraud Prevention Authority Advisory Committee and a former member of the Pennsylvania Auto Theft Prevention Authority Advisory Committee. Mr Sancenito has consid­ erable expertise on domestic extremist groups and tactics and is an expert on animal rights and environmental extremism. He also lectures regularly on extremist groups, insider threats, workplace violence and domestic terrorism networks. He is also an author, columnist and news media consultant on security matters.

A bstract

Corporations are increasingly being targeted by activist groups seeking to influence their business decisions. Activists target companies for a variety of reasons. Some feel companies have too much power over their lives; some feel companies put profits over people; and others feel the compa­ nies’ actions exploit people, animals and/or the environment. Some companies are targeted simply because they have a business relationship with a targeted company. While most activists use peaceful protests as a way of voicing their opinions, others resort to criminal activity to influence corporate decisions. Radical extremists use tactics o f intimidation, threats and criminal activity to achieve their goal. Activist campaigns

typically follow leaderless resistance models in which a number of organisations or individuals move against a targeted industry or company. These groups operate autonomously but share ideas, information and research. Preparation and planning is the difference between compa­ nies that endure an activist campaign and those that are unable to recover fully. The prepara­ tion process should include the following steps: (1) evaluate risk and exposure, (2) conduct a vulnerability assessment, (3) do advanced plan­ ning, and (4) engage in intelligence monitoring.

Keywords: extremism, animal rights, insider threat, infiltration, risk, terrorism

INTRODUCTION On the morning of 7th September, 2005, executives from Life Sciences Research Incorporated were enjoying breakfast at the New York Stock Exchange (NYSE). There was a celebratory buzz in the air as their company, doing business as Huntingdon Life Sciences (HLS), was moments away from being publicly traded on the NYSE. Their excitement quickly turned to disbelief when the NYSE’s pres­ ident, Catherine Kinney, walked into the room and announced ‘There’s no way to sugar-coat this. The New York Stock Exchange will not be listing Life Sciences Research this morning’.1 The reason for the postponement was thousands of e-mails (some of them threatening)

John Sancenito

Journal o f Business Continuity & Emergency Planning Vol. 12, No. 1, pp. 17-26 © Henry Stewart Publications, 1749-9216

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Corporate risk from extremist groups

targeting the NYSE from activists all over the world, as part of an international cam­ paign protesting the fact medical research conducted at HLS involved live animals. Two executives of the NYSE-Euronext in the Netherlands later had their cars burned and homes vandalised in protest.

Businesses continuity and emergency plans typically cover a wide range of threats; however, the risk from activist groups is largely underestimated or overlooked completely in most plans. No businesses, however large or small they may be, are immune from activist campaigns. Activist groups have disrupted business operations and caused substantial financial impact to companies around the world. Some busi­ nesses have been unable to recover and have permanently closed due to activist pressure. Companies that fail to plan for activist influence do so at their own peril.

ACTIVIST GROUPS AND MOTIVATIONS There are many activist groups that are attempting to bring about changes in society or increase awareness for their

cause. Some activist groups target the government sector or society in general over civil or foreign policy. These groups typically do not single out companies but may attack them as targets of opportunity (usually during riots) not because they oppose their business or industry. This paper focuses on activist groups that target campaigns against the corporate sector. Table 1 includes examples of activist groups and their core beliefs.

Activists are generally motivated by a perception of injustice and a compulsion to correct it. They are dissatisfied and frustrated with a lack of progress toward their intended goal and advocate for like- minded individuals to engage in vigorous action to achieve it. They have a deep- rooted conviction they cannot stand by while perceived atrocities are occurring. They feel their cause is just and feel com­ pelled to act out to correct the unfairness they feel. This same perception of having the moral high-ground allows them to justify, in their minds, extreme measures to achieve their goal.

Propaganda issued by activist groups is intended to invoke an emotional response

Table 1: Activist groups and their core beliefs

Field o f activism Cove beliefs Examples

Freedom of information

Information should be public; Opposed to patients, copyright and intellectual property; want the internet to be free from regulation

Hacktivists, Anonymous, WikiLeaks

Anarchists Opposed to large companies with perceived control over people

Anarchist Black Cross, International Anarchist Federation, Occupy Movement

Animal rights Animals deserve equal rights as humans and should not be used for food, clothing, research or entertainment

Animal Liberation Front, People for the Ethical Treatment o f Animals, Humane Society o f the United States

Environmental Preservation and protection o f the environment and natural resources

Earth Liberation Front, Sea Shepard Conservation Society, Greenpeace, Earth First!, Anti-Fracking

Anti-GM O Opposed to genetically modified crops GM O Free, GM O Awareness, Millions against Monsanto

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and compel others to take immediate action by joining a cause or providing financial support. Companies targeted by activ­ ists are demonised, along with employees, suppliers and financial supporters.

LEADERSHIP RESISTANCE Extremist groups, unlike their above­ ground counterparts, follow a leaderless resistance model in which there is no central hierarchy or organisational struc­ ture. Activists may share a common goal but they decide independently which tactics they will employ. This structure makes it difficult for a movement to be stopped, even if individuals are arrested or civil injunctive orders are obtained. Social media and online forums are used to post research and share ideas on how to achieve their objective. Individuals or small groups act autonomously while communicating with a larger group of others attempting to achieve the same goal. Social media and online forums are used for individuals to share ideas and post research or intel­ ligence on an intended target.

TIERS OF ACTIVISM Activists can generally be divided into three distinct tiers: mainstream groups, grassroots collectives and underground extremism. All three of these tiers may be involved in the same campaign; however, their tactics and methods differ greatly.

• Mainstream groups: Mainstream groups have large memberships and operating budgets. They are typically registered nonprofit organisations that operate nationally or internationally. The tactics of these groups include lob­ bying activity, social media campaigns, product boycotts, e-mail/letter writing and attempts to change public opinion. If these groups engage in protest activity,

they are typically peaceful events. Occasional acts of civil disobedience will occur, if they can obtain sufficient media coverage.

• Grassroots collectives: Grassroots groups are made up of a small number of activ­ ists organised locally. The tactics of these groups include protests, office disrup­ tions and demonstrations at the personal residences of employees from a targeted company. Protests organised by these groups may be rambunctious and often include subtle or veiled threats. Acts of civil disobedience, such as occupying space and/or chaining themselves to doors or vehicles, may also occur. These groups change names often, particu­ larly when served with cease-and-desist orders or injunctions.

• Underground extremists: A very small percentage of activists may act indi­ vidually or in small groups to engage in criminal activity (direct action). Tactics may include vandalism, theft and arson. These groups are not well funded and rely on household goods or easily acquired items to build improvised incendiary devices (IID) or improvised explosive devices (IED). These groups sometimes claim credit for crimes they commit under a general moniker, such as the Earth Liberation Front. This is done to intimidate and provide a sense the group is much larger and omni­ present. It also is intended to invoke fear based on previous criminal acts claimed under the same name.

Each of these distinct tiers may be involved in the same campaign simultane­ ously, while operating independently. A company targeted by activists may have to manage threats from one, two, or all three elements during a campaign against them. Mainstream groups tend to identify companies to target and alert the activist movement as to the company’s perceived

Corporate risk from extremist groups

wrongdoing. Grassroots collectives may realise a targeted company has an office in their city and organise protests against it. Underground activists may decide the only way to influence the company is to inflict economic damage and act to burn delivery vehicles owned by the company.

TERTIARY TARGETING Tertiary targeting is a tactic used by activists to increase their influence on a company. In addition to targeting the company and its employees directly, the company’s affiliates are targeted. The tactic involves targeting of vendors, suppliers, inves­ tors, board members, affiliated companies and financial pillars. A company, non­ profit organisation, government agency or an individual could be singled out for targeting because of a relationship or perceived relationship with another organ­ isation they are attempting to influence.

The same tactics, including criminal activity, are used against tertiary targets in an attempt to pressure the targeted company into making concessions. This tactic has been extremely effective in forcing companies to make concessions to activists’ demands. Activists may target a company simply because a board member is affiliated with a targeted company. A national office supply company was targeted for selling office supplies to a tar­ geted company, insurance companies for providing insurance, and banks because they processed a targeted company’s loans.

DIRECT ACTION While most activists engage in lawful activities, some movements have extrem­ ists who become frustrated with the lack of progress and decide more forceful methods are necessary to bring about change. Statistics are difficult to identify as the motivation behind these crimes may

go unnoticed by law enforcement agen­ cies. For instance, a vandalism incident at a butcher shop may not be recognised as being part of a larger campaign.

Information Network Associates, Inc. (INA), an international risk management and security consulting firm, moni­ tors extremist groups around the world. Statistical data compiled by INA comes from open source research, such as news reports and activist websites. Information provided by INA, illustrated in Figure 1, represents 1,520 direct action attacks related to animal rights between 2012 and 2017.

The vast majority o f these incidents involved minor vandalism, banner drops and animal liberations. There were also some serious crimes committed during this period, including nine bombings, 78 cyber attacks, 100 arson attacks and six claims of product tampering.

Figure 1 illustrates only one such movement (animal rights extremism) but exemplifies the tactics and impact of radical extremist groups. Underground extremists operate as a subculture in most activist movements. Some of the more heinous crimes committed by radicalised activists include the following:

• 19th October, 1998, Vail, CO, USA: An arson attack at the Two Elks Lodge on Vail Mountain caused US$12m damage. The Earth Liberation Front claimed credit, stating it was done to protect the habitat of the lynx.2

• 21st May, 2001, Seattle, WA, USA: A firebomb exploded at the University of Washington, Center for Urban Horticulture causing an estimated US$4m in damage. The attack was claimed by activists operating under the banner of the Earth Liberation Front. The motive for the arson was a perception genetically modified trees were being grown.3

• 23rd August, 2003, Emeryville, CA, USA: Two pipe bombs filled with

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Sancenito

Figure 1 Direct action related to animal rights 2012-2017 Data compiled by Information Network Associates, Inc. (www-ina-inc.com)

ammonium nitrate were detonated at the offices of the Chiron Corporation. A similar bomb was left at the nearby Shakely Corporation a few days earlier. A secondary device did not detonate but was likely intended for first responders. Responsibility was claimed by Revolutionary Cells Animal Liberation Brigade. The motivation for the attack was Chiron’s and Shakely’s business relationship with British animal-testing company Huntingdon Life Sciences.4

• 27th July, 2009, Chur, Switzerland: The gravesite of the mother of the Chief Operating Officer of the Novartis Corporation, one of the world’s largest pharmaceutical companies, was des­ ecrated and the remains were stolen. Activists attempted to blackmail the company, stating the remains would only be returned if Novartis ended its business relationship with Huntingdon Life Sciences.5

• 2010—2014, Bristol, UK: A series of 50 bombings over a four-year period tar­ geted a variety of targets, including the

Tesco, Barclays Bank, Santander Bank, energy companies EDF and E.ON, a police firing range, and private secu­ rity firms G4S and Serco. Radio and television transmitting masts were also destroyed. The total cost was more than ^20m .6 The bombings were claimed by the Informal Anarchist Federation (FAI).

Activist campaigns typically escalate over time but some attacks are not preempted by sustained campaigns. Sometimes, however, companies are attacked without prior warning or simply because of their industry. Sophisticated attacks require a longer planning cycle that includes surveil­ lance of the intended target. Less serious attacks require less planning and may be targets of opportunity.

Many small businesses are extremely vulnerable to attacks by activists. Fur clothing stores, for example, are suscep­ tible to activists entering the facility and spraying red paint on the merchandise. Many fur stores have gone out of business

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Corporate risk from extremist groups

after repeated activist attacks. Others had to modify their business model to allow store access by appointment only.

INFILTRATION Activists often attempt to gain employment with a targeted company or with industry sectors. Insider threats can be particularly damaging as companies tend to trust their employees and most protective measures are designed for external threats. According to data compiled by Information Network Associates, Inc. (www.ina-inc.com), from 1981 to 2017 there were at least 334 documented infiltrations of companies or nonprofit organisations by activists. The number is assuredly much higher as they may not publicise acts of sabotage or theft that may subject them to criminal prose­ cution. The strategy in most cases involves taking video/photographs intended to expose industry practices and sway public opinion. Documents that show business affiliations or intellectual property are also taken in some cases.

Animal agriculture and animal-related research programmes are frequently infil­ trated by activist groups. The economic and reputational damage is extremely impactful and some companies have been driven out of business as a result. Video gathered during infiltrations of chicken farms has led many national retailers to cancel contracts with egg and poultry sup­ pliers. In some cases, these actions have changed public opinion to the point that legislation has been enacted to change industry practices.

These insider threats are particularly difficult to prevent due to the fact a that traditional background check is unlikely to identify an individual’s radical beliefs or affiliations with extremist movements. Vendors and contractors also pose a risk and yet most companies do not require stringent checks for non-employees.

In most cases, infiltrations may not be in violation of criminal laws. Some states however have specific laws making this activity illegal if committed against agricultural and/or research industries. In most cases, infiltrators willingly sign and knowingly violate employer confidenti­ ality and intellectual property agreements. The sponsoring organisation typically defends or provides legal representation to the infiltrator in legal proceedings. Civil tort actions may be initiated against the individual or the sponsoring organisa­ tion; however, most targeted organisations never pursue legal recourse.

IMPACT OF ACTIVIST CAMPAIGNS Activist campaigns can have major opera­ tional, economic and reputational impacts to affected companies. The exact cost is unknown as most companies never report these figures. The impact can be quantita­ tive, such as property damage or loss of stock value. There are also many non- quantitative costs such as:

• loss of customers; • loss of investor confidence; • loss of stock value; • increased security; • legal fees; • time responding to government/

regulators; • loss of employee confidence; • loss of focus; and • reputation damage.

The full impact of activist campaigns can be best understood by examining some actual case studies.

Case study; Huntingdon Life Sciences Huntingdon Life Sciences (HLS) was a British research facility that used animal models for medical research. The company had facilities in several European cites, as

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well as one US facility. HLS endured one of the most intensive activist campaigns in history; enduring more than 15 years of intense and sometimes violent actions.

Animal rights activists conducted a series of undercover infiltrations at HLS facilities in the UK and USA. In 1997, People for the Ethical Treatment of Animals (PETA) sponsored an infiltration against HLS at its East Millstone, NJ facility. Legal action was initiated by HLS against PETA and an out-of-court settlement was reached. Grassroots activists organised a campaign under the name Stop Huntingdon Animal Cruelty (SHAC). The campaign initially started in the UK but spread to the USA and the rest of the world.

Tertiary targeting was utilised to attack any company with a perceived business relationship with HLS. Activist created web­ sites and used the internet and social media to post information on targets, including home addresses and phone numbers of employees. Activists targeted banks affili­ ated with the company, even launching a distributed denial of service attack that brought down the online banking system for Washington Mutual Bank. They attacked Marsh Insurance Company, using smoke flairs in the ventilation systems to force the evacuation of two high-rise office buildings in downtown Seattle. One by one, companies doing business with HLS ended their business relationships due to intimidation, fear and coercion.

The SHAC campaign led HLS to move its corporate headquarters to the USA where it could better conceal its finan­ cial investors. The campaign against HLS resulted on hundreds of criminal acts against the company and its associates. Some of these crimes included:

• physical assault on the Managing Director of HLS by masked men armed with axe handles as he left his home on his way to work;7

• thousands of threatening letters, pack­ ages, e-mails and phone calls;

• millions of dollars in damaged property including vandalism, vehicles burned, private residences spray-painted and windows smashed;

• numerous arson attacks, including the vehicles and property of at least two pharmaceutical company executives;

• a yacht owned by a financial investor was sunk in a New York harbour;

• the stock listing was delayed by the New York Stock Exchange;

• several product contamination claims, including baby nappy ointment, neces­ sitating product recalls;

• the desecration of and theft of remains from the grave of the mother of a phar­ maceutical company’s CEO; and

• two pipe bomb explosions at two nearby companies in California, along with a secondary device, which did not explode, possibly intended for the first responders.

The SHAC campaign took the value of HLS from a high of around US$35 per share to the verge of bankruptcy before it voluntarily delisted to become privately held. In addition, this highly effective terror campaign affected hundreds of companies around the world. SHAC caused many companies to capitulate to its demands and end business relationships with HLS. Arrests of key leaders by law enforcement around the world eventually crippled the campaign, and it officially ended in 2014.

Case study: POM Wonderful In 2006, juice company POM Wonderful (POM) was targeted by PETA due to its sponsorship of medical research involving animals. POM was initially defiant, claiming the research it funded was to determine the health benefits of pome­ granate juice. A spokesperson for the company said ‘We’re interested in science

Corporate risk from extremist groups

and human health, and not in political correctness’.8 The company was quick to rethink its position, after an intensive pres­ sure campaign by activists.

PETA took to social media to influence POM and other animal rights activists joined in. The resulting campaign led to calls for consumer boycotts o f POM products, retail outlets refusing to carry its products, and protest activity and har­ assment of corporate executives. The campaign culminated when extremists claiming to be from the Animal Rights Militia conducted an internet hoax claiming it had contaminated 487 bottles of POM Wonderful Juice at stores on the eastern seaboard of the USA. The group claimed those who drank the contami­ nated juice would experience diarrhoea, vomiting and headaches.9

Less than 60 days after it started, the campaign ended with POM capitulating to activists’ demands, agreeing to cease all animal-related research. Animal rights activ­ ists claimed the campaign as a major victory.

PREPAREDNESS The largest o f corporations can be brought to their knees by activist campaigns; however, many do not fully understand their exposure and most lack effective busi­ ness continuity plans to address the risk.

Social media channels provide plat­ forms for activists to organise activities, recruit new members and influence public opinion. This expands the membership base and sphere o f influence far beyond what they were capable o f in the past. Companies concerned about their public image are particularly vulnerable.

Preparation and planning make the dif­ ference between companies that endure an activist campaign and those that are unable to recover fully. The preparation process should include the following steps: (1) evaluate risk and exposure, (2) conduct a

vulnerability assessment, (3) do advanced planning, and (4) engage in intelligence monitoring.

Evaluate risk and exposure The first step in the process is to fully evaluate the company’s risk and exposure. Companies in controversial industries typ­ ically have a fundamental understanding of the risks affiliated with their business model. Other companies, however, may have to understand their customer base. For instance, an investment capital firm might not realise a construction company in which it has invested has a contract with an energy company to build natural gas pipelines.

Board member affiliation should also not be overlooked. A board member for a one company could also serve on the board of another company that is being targeted. Activists may attempt to pressure the board member by targeting all related companies.

Market research into controversial issues and competitors in similar industries may reveal insight into potential risk. What caused the company to be targeted? Who targeted them and how? How was the company affected? What did they do right/wrong? Analysing historical inci­ dents is an effective way to predict future corporate risk. It is important to under­ stand the methods, tactics and geographic reach of potential adversaries. It is even more important to learn from the mistakes o f others.

Conduct a vulnerability assessment The next step is to evaluate the company’s vulnerabilities and resiliency to endure an activist campaign. Conduct assessments of physical security measures, policies and procedures, and online exposure. Assess the degree to which the company would be prepared for the tactics employed by activists:

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• Physical security vulnerability assessment: Evaluate security measures, including access control, intrusion detection, video systems, landscaping, architec­ ture, lighting and barriers.

• Policies and procedures: Review and update emergency procedures, protest/ demonstration action plans, visitor pro­ cedures, mail/delivery practices, hiring practices and background checks.

• Online exposure: Evaluate the company’s online exposure and understand what information is publicly available about the company. Review company web­ sites, literature and social media accounts for wording, services or issues others may feel are controversial. Evaluate which employees are publicly linked to the company and what information is available about key individuals. Are their home addresses easily obtained? Do they have public social media profiles that can be exploited by activists? Do activists have the ability to post negative com­ ments on company social media pages?

Do advanced planning Planning for the risk of activist campaigns should be included in emergency plans for the organisation. It may not be necessary to have a specific plan that deals only with the threat of activist attention. It may be sufficient to address this risk within other existing plans, such as physical security measures that are necessary to prevent general crime in the community. Crisis communication plans can include areas that directly relate to potential activist issues.

Creating a security culture within the organisation is an essential part of man­ aging risk. Security awareness programmes should be behaviour-focused and secu­ rity principles should be embedded in all standard operating procedures. A lasting security culture can only be achieved if it is supported by the highest level of the organisation.

Companies should also be aware of local ordinances and state laws regarding public assembly. The most important thing is to know what is considered public space and what is private space. There are typi­ cally set-back distances from roadways and footpaths that are considered public space. Knowing and marking private space can be helpful in enforcing trespass violations. Some other laws to be aware of include:

• Permits: Are permits or police notifica­ tion required for public protests? Are there size or time restrictions?

• Masks: Can full face masks be worn in during protests?

• Residential picketing: Are there restric­ tions on residential (home) protests?

• Noise amplification: Do local ordinances restrict the use of or time of noise amplification devices, such as bullhorns or air horns?

Establishing relationships with law enforcement agencies in advance may help companies understand the role and actions local police will/will not take. Communication with local officials, especially during times of controversy, is essential.

Engage in intelligence monitoring Risk from activist campaigns requires the continuous monitoring of activist groups. Only through monitoring activist activity can a company make informed deci­ sions on risk and business relationships. A fundamental understanding of activist campaigns, groups and influence is neces­ sary to guide businesses.

Monitoring for references to the company, its brands and key employees are typical areas of business intelligence func­ tions. Monitoring and analysis of activist websites, forums, blogs, list-servers and social media platforms are also necessary to manage risk.

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Corporate risk from extremist groups

Online m onitoring programmes should be well managed to avoid legal and ethical pitfalls. Precautions should be taken w hen visiting and m onitoring activist activity as many sites will track the IP addresses o f those who visit their sites. These sites may also contain malware. Special browsers are necessary to m onitor activity on the dark web. Online m onitoring should only be passive as interacting w ith activists may be unethical and have serious regulatory implications.

SUMMARY The single most important right shared by individuals in a free society is the right to peacefully assemble and protest perceived injustices. The vast majorities o f activists are peaceful and law-abiding individuals and should be treated accord­ ingly. However, a small num ber o f radical activists are willing to engage in criminal conduct to achieve their goal.

Managing the risk o f activist groups requires awareness and advanced planning. All businesses should evaluate the likeli­ hood o f being targeted by activists and the impact to the organisation.

N o business is beyond the reach o f activist groups as activists sometimes target companies due to business relationships.

Analysis o f activist campaigns and industry-related controversies and similar companies is necessary. Due diligence investigations are necessary to determine exposure. Insider and external threats cannot be overlooked. Creating a security culture within any organisation is neces­ sary to protect people, property and data.

R eferences

(1) Burbank, L. (2005) ‘Biomedical research firms NYSE listing held’, available at: https://www.npr.org/ templates/story/ story.php?storyId=4928781 (accessed 3rd March, 2018).

(2) Associated Press (2006) ‘2 plead guilty in 1998 arson of Vail ski resort; attack caused US$12m in damage’ USA Today, 14th December, available at: http:// usatoday30.usatoday.com/news/ nation/2006-12-14-vail-arsons_x.htm (accessed 3rd March, 2018).

(3) Bernton, H. and Clarridge, C. (2006) ‘Earth Liberation Front members plead guilty in 2001 firebombing’, Seattle Times, 5th October, available at: https:// www.seattletimes.com/seattle-news/ earth-liberation-front-members-plead- guilty-in-2001-firebombing (accessed 8th March, 2018).

(4) Rodriguez, M. (2003) ‘Suspect is sought in bombings’, Los Angeles Times, 10th October, available at: http://articles. latimes.com/2003/oct/10/local/ me-warrantlO (accessed 5th March, 2018).

(5) Huckman, M. (2010) ‘Animalistic behavior against Novartis’, CNBC 3rd August, available at: https://www.cnbc. com/id/32286665.

(6) Rose, D. (2014) ‘Dark force of the Bristol bomber’, Daily Mail, 31st May, available at: http://www.dailymail.co.uk/ news/article-2644814/Who-Bristol- anarchist-responsible-50-attacks-4-years. html (accessed 8th March, 2018).

(7) Kelso, P. (2001) ‘Animal lab boss attacked’, Guardian, 23rd February, available at: https://www.theguardian. com /uk/2001 / feb/24/paulkelso 1 (accessed 5th March, 2018).

(8) Pepperdine Graphic (2017) ‘PETA’s case against POM not so “wonderful”’, 18th January, available at: http:// p epp erdine-graphic. com/p etas-case- against-pom-not-so-wonderful/ (accessed 5th November, 2017).

(9) Animal Liberation Press Office (2006) ‘POM Wonderful Juice contaminated by Animal Rights Militia’, 14th December, available at: https:/ / animallib eratio npressoffic e. org/NAALPO/2006/12/19/ pom-wonderful-juice-contaminated- by-animal-rights-militia/ (accessed 18th June, 2018).

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