of human rights, the environment, and natural resources, with 13 environmentalists, 54 indigenous people, and 207 farmers and peasants extrajudicially killed since Duterte took office in 2016. Included in the targeting of environmental activists was American citizen, Brandon Lee, who was subjected to an assassination attempt on August 6, 2019. Brandon has been subjected to repeated threats and harassment by the Philippine military due to his advocacy relating to the land and rights of indigenous people in Ifugao province and the surrounding Cordillera region of the Philippines. While Brandon Lee survived the attack, he has been left paralyzed and his assailants have not been brought to justice. (8) It is widely recognized that the Duterte administration silences dissent and the press. The State Department’s 2019 Report states, Government harassment of some media outlets occurred, however, and polls suggested many Filipinos consider it dangerous to publish information critical of the administration. In May 2020, ABS-CBN, one of the Philippines’ two major sources of news, and an occasional critic of Duterte’s policies, was forced off air due to the denial of a franchise license by the Congress of the Philippines, at the behest of the Duterte administration. Similarly, Maria Ressa, a vocal critic of the Duterte administration, Times Magazine’s Person of the Year 2018 recipient, and founder of the digital news site Rappler was convicted of cyber libel in June 2020. In July 2020, the Duterte administration signed the Anti-Terrorism Act of 2020 into law. Countless Filipino and international commentators, including fifty U.S. Representatives have warned that the law will be used to further target critics and silence dissent. (9) The United States continues to arm state security forces of the Philippines. Despite clear documentation of abuses and international condemnation, in April 2020, the United States announced a pair of arms sales totaling $2,000,000,000 for items including hellfire missiles and attack