a lethal dose of radioactive polonium-210, possibly passed to him in aerosol form sprayed directly onto his food. Targeted killing Targeted killing is the intentional killing by a government or its agents of a civilian or "unlawful combatant" who is not in the government's custody. The target is a person asserted to be taking part in an armed conflict or terrorism, by bearing arms or otherwise, who has thereby lost the immunity from being targeted that he would otherwise have under the Third Geneva Convention. Note that it is a different term and concept from that of "targeted violence", as used by specialists who study violence. On the other hand, Georgetown University Law Center Professor Gary D. Solis, in his 2010 book The Law of Armed Conflict: International Humanitarian Law in War, wrote, "Assassinations and targeted killings are very different acts." The use of the term "assassination" is opposed, as it denotes murder (unlawful killing), but the terrorists are targeted in self-defense, which is thus viewed as a killing but not a crime (justifiable homicide). Abraham D. Sofaer, former federal judge for the US District Court for the Southern District of New York, wrote on the subject: When people call a targeted killing an "assassination", they are attempting to preclude debate on the merits of the action. Assassination is widely defined as murder, and is for that reason prohibited in the United States ... U.S. officials may not kill people merely because their policies are seen as detrimental to our interests... But killings in self-defense are no more "assassinations" in international affairs than they are murders when undertaken by our police forces against domestic killers. Targeted killings in self-defense have been authoritatively determined by the federal government to fall outside the assassination prohibition. Author and former U.S. Army Captain Matthew J. Morgan argued that "there is a major difference between assassination and targeted killing... targeted killing [is] not synonymous with assassination. Assassination... constitutes an illegal killing." Similarly, Amos Guiora, a professor of law at the University of Utah, wrote, "Targeted killing is... not an assassination." Steve David, Professor of International Relations at Johns Hopkins University, wrote, "There are strong reasons to believe that the Israeli policy of targeted killing is not the same as assassination." Syracuse Law Professor William Banks and GW Law Professor Peter Raven-Hansen wrote, "Targeted killing of terrorists is... not unlawful and would not constitute assassination." Rory