there have been few audits of the implementation of the 2006 statement, clitoral surgeries on under-14s have increased since 2006, and "recent publications in the medical literature tend to focus on surgical techniques with no reports on patient experiences". A 2014 civil society submission to the World Health Organization cited data from a large German Netzwerk DSD/Intersexualität study: A 2016 Australian study of persons born with atypical sex characteristics found that "strong evidence suggesting a pattern of institutionalised shaming and coercive treatment of people". Large majorities of respondents opposed standard clinical protocols. A 2016 follow-up to the 2006 Consensus Statement, termed a Global Disorders of Sex Development Update stated, A 2016 paper on "Surgery in disorders of sex development (DSD) with a gender issue" repeated many of the same claims, but without reference to human rights norms. A commentary to that article by Alice Dreger and Ellen Feder criticized that omission, stating that issues have barely changed in two decades, with "lack of novel developments", while "lack of evidence appears not to have had much impact on physicians’ confidence in a standard of care that has remained largely unchanged." Another 2016 commentary stated that the purpose of the 2006 Consensus Statement was to validate existing practices, "The authoritativeness and “consensus” in the Chicago statement lies not in comprehensive clinician input or meaningful community input, but in its utility to justify any and all forms of clinical intervention." Recent developments Institutions like the Swiss National Advisory Commission on Biomedical Ethics, the Australian Senate, the Council of Europe, World Health Organization, and UN Office of the High Commissioner for Human Rights and Special Rapporteur on Torture have all published reports calling for changes to clinical practice and an end to harmful practices. In 2011, Christiane Völling won the first successful case brought against a surgeon for non-consensual surgical intervention. The Regional Court of Cologne, Germany, awarded her €100,000. In April 2015, Malta became the first country to recognize a right to bodily integrity and physical autonomy, and outlaw non-consensual modifications to sex characteristics. The Act was widely welcomed by civil society organizations. In 2017, Human Rights Watch and Interact Advocates for Intersex Youth published a report documenting the negative effects of medically unnecessary surgeries on intersex children in the US, as well as the pressure placed on parents to consent to the operations without full information. California State Legislature passed a resolution