NOTES

Terrorism, the Internet, and Propaganda:

A Deadly Combination

Ariel Victoria Lieberman*

INTRODUCTION
The Internet provides a relatively unregulated and unrestricted place where
terrorists can craft and disseminate propaganda through seemingly limitless
numbers of websites and social media platforms, tailoring their pitch so as to
target thousands of potential new recruits to join their organization and further
their cause. ISIS, in particular, produces the most technologically advanced
propaganda yet. Through sophisticated digital means, they have promoted the
idea that ISIS has successfully established a caliphate and recruited thousands
of new members to join the terrorist organization. ISIS films, which range from
minutes to hours long, use Hollywood-style production tricks and special effects
to portray ISIS terrorists as heroes and depict fighting for ISIS as akin to
playing in a real-life video game. These violent and gruesome depictions are
sent out alongside pictures and posts describing romantic, exciting encounters
and riches enjoyed by ISIS youth. ISIS propaganda combines the horrifying and
tantalizing to deliberately target young adults through social media, portraying
life in ISIS territory as glamorous and utopian, and its members as heroic and
desirable. Such propaganda fails to disclose the harsh realities of life in ISIS or
ISIS-perpetrated atrocities.
Efforts to thwart this propaganda in its many forms thus far have been
relatively unsuccessful. For instance, it has not been sufficient to suspend
pro-ISIS social media accounts; new pro-ISIS accounts quickly spring up to
replace them. Likewise, law enforcement efforts to stop potential ISIS recruits
at airports can only do so much; they cannot successfully prevent every
would-be recruit from traveling to join ISIS. Even the Material Support Statute
has its drawbacks as a tool for countering ISIS propaganda. Prosecuting individu-
als for promoting and distributing ISIS propaganda under the Statute, for
instance, may have the more harmful effect of chasing other terrorists to sites
that are more difficult for law enforcement to monitor. Lack of available time
and resources plays a role, too. Hence, Twitter might suspend the accounts of
only those users who have the most outrageous or highest quantities of postings,
leaving behind many dangerous but more scrupulous users. Furthermore, dissemi-

* Ariel V. Lieberman graduated with distinction from Georgetown University Law Center’s JD/LLM
program in National Security Law in May 2016. She is admitted to practice in Vermont and the District
of Columbia, and is currently an associate at Kirkland & Ellis in their International Trade and National
Security practice group in Washington, DC. © 2017, Ariel Victoria Lieberman.

95
96 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

nating propaganda on the Internet would not necessarily satisfy the terms of the
Material Support Statute, especially if the user cannot be shown to have
coordinated with ISIS.
This paper proposes a multi-faceted approach for combatting ISIS propa-
ganda focusing primarily on counter-propaganda measures that expose the
reality of living conditions in an ISIS society and poke holes in ISIS’s false veil
of legitimacy and power. Some such measures already have been taken. For
instance, the Center for Strategic Counterterrorism Communications – an initia-
tive within the U.S. Department of State – along with a small number of
individuals have tried to expose the truth behind ISIS and to ridicule the
organization. However, these measures have not proven to be particularly
effective. Such measures need to be plentiful enough to not get buried beneath
pro-ISIS propaganda. Counter-propaganda should avoid appearing biased and
utilize a credible communicator. It should target the powerful lures that attract
teenagers to ISIS. Furthermore, while counter-propaganda measures should aim
to flood social media, social media sites such as Twitter should use a more
discerning approach, e.g., they should be selective about suspending accounts
so as to avoid pushing pro-ISIS users onto encrypted communication platforms.
Law enforcement officials should also be selective: they must use care when
considering propaganda as a basis for prosecuting material support cases;
otherwise, they could undermine the Government’s legitimacy by prosecuting
untenable cases. However, suspensions and prosecutions may be useful in at
least temporarily preventing dangerous propaganda from reaching teenagers and
thus should not be completely abandoned.

I. WHAT IS PROPAGANDA?
Propaganda has been defined in many different ways and can take on a
variety of forms. For example, the United States military defines propaganda as
“[a]ny form of communication in support of national objectives designed to
influence the opinions, emotions, attitudes, or behavior of any group in order to
benefit the sponsor, either directly or indirectly.”1 Merriam-Webster defines
propaganda as a “dissemination of ideas, information, or rumor for the purpose
of helping or injuring an institution, a cause, or a person.”2 According to
Black’s Law Dictionary, propaganda is “the systematic dissemination of doc-
trine, rumor or selected information to promote or injure a particular doctrine,
view, or cause.”3 These definitions of propaganda are very broad and can
encompass a wide range of positive and negative activity. Thus, it is helpful to

1. Peter J. Smyczek, Regulating the Battlefield of the Future: The Legal Limitations on the Conduct
of Psychological Operations (PSYOP) Under Public International Law, 57 A.F.L.REV. 209, 215 (2005)
(citing Joint Chiefs of Staff, Joint Pub. 1-02, Department of Defense Dictionary of Military and
Associated Terms 427-428 (12 Apr. 2001)).
2. Propaganda, WEBSTER’S THIRD NEW INTERNATIONAL DICTIONARY (1961).
3. Propaganda, BLACK’S LAW DICTIONARY (10th ed. 2014).
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 97

break down the term propaganda into smaller, workable categories to under-
stand the various forms in which propaganda appears.
Propaganda can be categorized in a variety of ways. For example, propa-
ganda can be categorized according to the source of the message. “White
propaganda” refers to “messages issued from an open and acknowledged source,
targeting a specific audience and not hiding the source.”4 “Black propaganda”
refers to messages from an unknown source, often based on lies or fabrications.5
“Gray propaganda” is neither completely true nor completely false, and does
not specifically identify its source.6
International human rights literature categorizes prohibited propaganda as
either 1) defamatory propaganda, 2) subversive propaganda, or 3) propaganda
or incitement to aggressive war or genocide.7 Defamatory propaganda refers to
“communications that tend to ‘degrade, revile, and insult’ foreign states, their
institutions, leaders or other agents with the intent to disturb the peaceful
relations between states.”8 Subversive propaganda refers to “communications
intending to overthrow the political leader, or existing internal political order of
a state,” which violates the international norm of non-interference in the internal
affairs of a sovereign state.9 Propaganda or incitement to aggressive war or
genocide refers to communications “intending to implant in the minds of people
a disposition or desire to engage in or normalize unlawful violence.”10 Although
ISIS has engaged in all three of these types of propaganda, the one most
relevant to this paper is this third category of propaganda.
Propaganda can be effective at winning the hearts and minds of populations if
it is used effectively. However, if used ineffectively, and its origin made too
obvious, propaganda may result in unanticipated negative consequences for the
originating entity, referred to as blowback in the intelligence community.11
Thus, any counter-propaganda by the United States against ISIS, for example,
by planting a false story about its members, must be wary of the potential for it
to cause more harm than good. The potential for blowback is especially high in
the 21st century as twenty-four hour news and the Internet have made accessing
information faster and easier and more difficult for the government to prevent.

4. Smyczek, supra note 1, at 215.

5. Id.
6. Id.
7. See Sarabeth A. Smith, Note, What is Old is New Again: Terrorism and the Growing Need to
Revisit the Prohibition on Propaganda, 37 SYRACUSE J. INT’L L. & COM. 299, 303 (2010).
8. Id. (citing JOHN B. WHITTON & ARTHUR LARSON, PROPAGANDA: TOWARDS DISARMAMENT IN THE WAR
OF WORDS 62 (Public Affairs Press 1964)).
9. Id.
10. Id.
11. Stephen Dycus et al., NATIONAL SECURITY LAW 472 (5th ed. 2011).
98 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

A. Propaganda: History and Evolution

The use of propaganda has been documented throughout the history of
civilization.12 The ancient Greeks used the theater, games, and oratory to
promote ideas and beliefs.13 The pharaohs of Egypt controlled the news by
using carvings on temple walls to legitimize their reigns and rewrite failures
into successes.14 Genghis Khan, in order to lower enemy morale before an
attack, allegedly used spies to plant rumors of the Mongols’ huge numbers and
ferocity.15 By the 17th century, the term “propaganda” came into common usage
in Europe as a result of the Catholic Church’s missionary activities, whereby
church members sought to indoctrinate new adherents.16 Thus, in 1718, when
propaganda first appeared in the English language, it referred to that “which
ought to be propagated” in a religious sense.17
The twentieth century saw an upsurge of propaganda related to war and
political activity. The term “propaganda” came into common usage in the
United States as a result of World War I.18 During World War I, countries
involved in the conflict used propaganda to promote the righteousness and
importance of their causes; to win the support of nonbelligerent nations; to
weaken the enemy’s morale and efficiency; and to bolster the morale and
efficiency of their own nations.19 In the 1930s, Germany disseminated extensive
anti-Jew and pro-Nazi propaganda.20 During World War II, both Allied and Axis
countries crafted propaganda with scientific expertise never before seen. The
Cold War brought a barrage of anti-Soviet Union propaganda by the United
States, and anti-United States propaganda by the Soviet Union. In sum, propa-
ganda has been associated with religion, war, and politics, depending on when
and how it has been crafted and deployed.21
Currently, the United States President has the authority to conduct “global
broadcasting in any region in the President’s discretion to promote U.S. poli-
cies, achieve U.S. objectives, and promote Democracy.”22 Hence, the United

12. Smith, supra note 7.

13. The Story of Propaganda, AM. HIST. ASS’N, http://www.historians.org/about-aha-and-membership/
aha-history-and-archives/gi-roundtable-series/pamphlets/what-is-propaganda/the-story-of-propaganda (last
visited Mar, 24, 2015).
14. Egypt’s Golden Empire: Art and Architecture, PBS.ORG, http://www.pbs.org/empires/egypt/
newkingdom/architecture.html (last visited Apr. 20, 2015).
15. Smyczek, supra note 1, at 215.
16. AM. HIST. ASS’N, supra note 13.
17. Erin W. Fellows, Propaganda: History of a Word, 34 AM. SPEECH 182, 182 (1959).
18. The Story of Propaganda, supra note 13.
19. Fellows, supra note 17, at 182.
20. Allen W. Palmer & Edward L. Carter, The Smith-Mundt Act’s Ban on Domestic Propaganda: An
Analysis of the Cold War Statute Limiting Access to Public Diplomacy, 11 COMM. L. & POL’Y 1, 6
(2006).
21. Fellows, supra note 17, at 188.
22. Smyzcek, supra note 1, at 215 (citing National Security Directive 51, US Government Interna-
tional Broadcasting).
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 99

States relies on radio broadcasts abroad as one form of propaganda.23 For

example, Radio Free Afghanistan is a radio station used to promote the United
States and its democratic ideals in Afghanistan.24 However, until recently, this
authority did not extend to disseminating propaganda about the United States
domestically. Such propaganda was banned under the United States Information
and Educational Exchange Act of 1948 (Smith-Mundt Act). This Act prohibited
domestic dissemination of information and material about the United States
intended primarily for foreign audiences out of concern that the United States
would appear to be indoctrinating its own citizens; in light of Germany and
Japan’s harmful use of propaganda in WWII; and out of fear that possible
communist sympathizers had infiltrated the United States government and
would use domestic propaganda to advance a communist agenda.25 However,
the Smith-Mundt Act prohibition was rendered obsolete with the rise of the
Internet and twenty-four hour news, which made it nearly impossible for the
United States to prevent its citizens from easily accessing materials online.26
The Smith-Mundt Modernization Act of 2012 amended the 1948 Act to allow
the Secretary of State and the Broadcasting Board of Governors to engage in
previously prohibited domestic dissemination of information and materials
covered under the Smith-Mundt Act. It does not apply to any initiatives by the
Pentagon. The bill’s supporters argued that the removal of the domestic prohibi-
tion would enhance government transparency, bolster strategic communications
and public diplomacy, and help to counter the radical messages and undermine
the recruitment abilities of terrorist groups online.27
International law does not provide much guidance with respect to the legality
of propaganda. The International Covenant on Civil and Political Rights, Article
20(1), imposes an obligation on State Parties to prohibit propaganda for war.
Some states, including the United States, entered reservations to the Article,
reserving the right to seek, receive, and impart any information, even if it
constitutes war propaganda. The lack of a clear definition or articulation of the
prohibition’s scope further suggests that the Article did little to alter the
international perception of the legality of propaganda.28

B. How does Propaganda Work with Respect to Terrorism? Who is Susceptible

to Propaganda?
Individuals who engage in terrorism come from a wide variety of socioeco-
nomic backgrounds and possess a vast spectrum of individual characteristics.

23. Id. at 221.

24. Id.
25. See Jeremy Berkowitz, Comment, Raising the Iron Curtain on Twitter, 18 COMMLAW CONSPECTUS
269, 272 (2009).
26. Id. at 273.
27. US Ends Ban on Domestic Propaganda, RT.COM (Jul. 15, 2013, 6:32 PM), http://rt.com/usa/smith-
mundt-domestic-propaganda-121.
28. See Smith, supra note 7, at 327.
100 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

Furthermore, despite the fact that so many people are exposed to the conditions
sometimes associated with generating terrorism, such as presence in a conflict
zone or religious ideology, most individuals do not become radicalized to the
point that they engage in terrorism.29 However, certain predisposing risk factors
are associated with involvement in terrorism. These factors include: the pres-
ence of some emotional vulnerability, alienation, or disenfranchisement; dissatis-
faction with the one’s current life situation and the perception that conventional
political activity is useless to improve it; identification with certain perceived
victims; the belief that engaging in violence against the state is not inherently
immoral; and a sense of kinship with those experiencing similar issues.30 A
factor of particular importance is that recruits expect a sense of reward from
being involved with terrorism.31 This reward may come in the form of height-
ened status, respect, or authority within an individual’s immediate peer group,
broader racial movement, or wider religious community, or personal spiritual or
emotional reward.32 For example, suicide bombers typically believe that they
will be rewarded in the afterlife.33
Individual characteristics and motivations are not the only considerations
relevant to understanding why a given individual may become radicalized.
Instead of looking solely at predisposing risk factors, some researchers have
proposed assessing the common features associated with the development of a
terrorist.34 These features include, but are not limited to, “the gradual nature of
the relevant socialization processes into terrorism . . . . the supportive qualities
associated with that recruitment . . . . migration between roles . . . [and] the
importance of role qualities.”35
In certain communities, the relevant socialization process into terrorism
begins at a very young age, with propaganda playing a large role. For example,
there are accounts of Palestinian neighborhoods where graffiti glorifies suicide
bombers and calendars are illustrated with the “martyr of the month.”36 Role
models can serve as an important source of authoritative legitimacy for the
justification of violent action.37 Enhanced status among an immediate circle of
activists and the broader supportive community can be a powerful incentive for
sustaining commitment.38 For some individuals, a sense of approval from a
significant individual, such as a wife or brother, is a catalyst into more extreme

29. John Horgan, From Profiles to Pathways and Roots to Routes: Perspectives From Psychology on
Radicalization into Terrorism, 618 ANNALS AM. ACAD. POL. & SOC. SCI. 80, 83 (2008).
30. Id. at 84-85.
31. Id. at 85.
32. Id.
33. Id.
34. Id.
35. Id. at 84.
36. Id. at 88.
37. Id.
38. Id.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 101

behavior.39
Increased involvement in a terrorist organization typically follows a period of
gradual progression.40 An increased commitment to the group’s narrow, extrem-
ist society consequently results in more marginalization from conventional
society.41 Commitments are often solidified as life inside the terrorist organiza-
tion becomes more challenging and the individual convinces him or herself that
the need to “stick it out” is essential.42

II. THE IMPACT OF THE INTERNET ON TERRORIST PROPAGANDA

“We are in a battle, and more than half of this battle is taking place in the
battlefield of the media.”43 In 2005, Ayman al-Zawahiri, then al-Qaeda’s second-
in-command, allegedly wrote these words in a letter to Abu Musab al-Zarqawi,
the al-Qaeda leader in Iraq at the time.44 However, terrorists no longer have to
rely on the media to spread their propaganda. Instead, terrorists can use the
Internet to fulfill and even surpass the media’s functions.
The Internet has revolutionized terrorism in many ways. For example, activi-
ties that were once conducted face-to-face, such as fundraising or training, are
now conducted through websites and virtual training camps. Geospatial imag-
ery, such as Google Earth, can be used to study locations and plan potential
attacks. Hacking and cyber-attacks present the possibility that great harm can be
done to a country’s infrastructure from a computer halfway across the world.
Likewise, the Internet has emerged as a dangerous tool for terrorist propaganda
and recruitment purposes. There are at least nine key ways that the Internet has
changed the way that terrorists use propaganda.
First, social media allows terrorist groups to provide limitless content directly
to numerous websites or individuals, without having to go through a third
party.45 Traditionally, the media had a monopoly on covering and interpreting
terrorist incidents. Now, terrorists have the ability to instantly convey their
messages directly to their target audience. The terrorists can also tailor their
recruiting pitch, sending different messages to individuals based on their age,
gender, location, or other factors. For example, ISIS sends starkly different
messages to Muslims in the West than those closer to the Middle East.46 The

39. Id. at 89.

40. Id.
41. Id.
42. Id.
43. Simon Cotte, Why it’s so Hard to Stop ISIS Propaganda, THE ATLANTIC (Mar. 2, 2015),
http://www.theatlantic.com/international/archive/2015/03/why-its-so-hard-to-stop-isis-propaganda/
386216/.
44. Id.
45. Emily Goldberg Knox, Note, The Slippery Slope of Material Support Prosecutions: Social
Media Support to Terrorists, 66 HASTINGS L.J. 295, 300 (2014).
46. Scott Shane & Ben Hubbard, ISIS Displaying a Deft Command of Varied Media, NYTIMES.COM
(Aug. 30, 2014), http://www.nytimes.com/2014/08/31/world/middleeast/isis-displaying-a-deft-command-
of-varied-media.html.
102 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

messages to English speakers tend to highlight jihad as a means of personal

fulfillment and tend to be softer in nature than the messages in Arabic, and the
Arabic media messages tend to focus on jihad as a duty for all Muslims.47
Second, social media provides terrorist organizations with an efficient way to
recruit new members, spread propaganda, and spread their ideology to a large
audience with minimal effort.48 Physical geography is no barrier to communica-
tions between potential recruits and terrorists. Terrorists can create any number
of account names on social media platforms, making communication cheap,
easy, and almost impossible to stop. Twitter and other social media platforms
have attempted to thwart terrorist groups by suspending ISIS-supporting Twitter
accounts, only to find that the accounts are replaced quickly by other ISIS-
supporting accounts. Like the mythical Hydra, the suspension of an ISIS-
supporting Twitter account seems to yield two more ISIS-supporting accounts in
its place.
Third, social media “lowers the barrier of access” to terrorist propaganda.49
Social media platforms provide individuals with ways to easily reach terrorist
propaganda and terrorist users. Unlike terrorist websites, which typically require
individuals to intentionally locate the specific site, individuals may also stumble
across terrorist social media accidently.50 For example, an individual may click
on a link posted by a friend and unintentionally land on a jihadist forum.
Furthermore, smart phones have made it possible for individuals to constantly
have access to the Internet at almost all times and places. Thus, physical
location and time are no longer relevant constraints on an individual’s ability to
access terrorist information.
Fourth, Internet postings are not regulated as sources of news, and thus
terrorists can post inaccurate information with almost no oversight or regula-
tion.51 The Internet removes the ability to effectively prescreen content by
allowing for instantaneous broadcast of terrorist messages. Readers might con-
sider terrorist Internet postings to be factually correct, and the stories may go
unchecked.
Fifth, terrorists can use anonymity on the Internet to their advantage. The
anonymity of the Internet has been found to foster higher levels of violence in
people.52 Terrorists can encourage feelings of violence, drawing people to their
cause. Anonymity also allows the terrorists to evade detection by law enforce-
ment.53 Previously, if terrorists communicated by electronics, they were limited
to using telephones or radios, which were at risk of being monitored by

47. Id.
48. Knox, supra note 45, at 300.
49. Id.
50. Id.
51. Gregory S. McNeal, Cyber Embargo: Countering the Internet Jihad, 39 CASE W. RES. J. INT’L L.
789, 800 (2007-2008).
52. Id. at 795.
53. Id. at 796.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 103

electronic surveillance tools such as wiretaps.54 Now, individuals can make

countless usernames that mask their true identities on numerous platforms.
Sixth, terrorists can gain knowledge about social media in order to distort the
prevalence and ranking of their messages on search results. Social media, in
particular Twitter, allows terrorists to amplify their messages by posting links to
their propaganda and “hashtags” at an unnaturally fast pace, causing the post-
ings to place higher in search results and in content aggregated by third
parties.55 ISIS and al Qaeda reportedly both use “bots,” which are computer-
controlled Twitter accounts that automatically send out content in a similar
manner.56
Seventh, the Internet allows for multidirectional communication between the
terrorists and the potential recruits. Individual communication allows terrorists
to craft propaganda specifically tailored for certain types of individuals. Further-
more, interactive participation can foster a sense of cohesion and generate a sort
of virtual community between the terrorists and potential recruits, thereby
creating a sense of unity.57
Eighth, terrorist groups can use social media to search for and target individu-
als who might be particularly vulnerable to their ideology.58 For example, ISIS
utilizes social media platforms that are popular with teenagers to attract and
recruit young people, who are more susceptible to its propaganda. Terrorists can
craft their propaganda to appeal to certain vulnerable populations by portraying
their organization as the solution to individuals’ problems. Furthermore, terror-
ists can weed out less susceptible populations by blocking apparent nonbeliev-
ers from their communications.
Ninth, encryption allows terrorists to maintain private networks of communi-
cation without law enforcement oversight. Encrypted communications cannot
be easily accessed by law enforcement, and as such, recruitment efforts and
other terrorist activities can take place in relative secrecy. As more websites and
smartphone applications turn to encryption, its ability to hide such communica-
tions and actions will likely be a growing concern. In September 2014, Apple
and Google announced plans to strengthen encryption of data stored on smart-
phones using their operating systems.59 Two encrypted messaging applications,
WhatsApp and Kik, have been especially popular with ISIS. These applications
make it much more difficult for law enforcement to intercept communications
than would otherwise be possible on Twitter or Facebook. Furthermore, extrem-

54. Id. at 797.

55. J. M. Berger, The Evolution of Terrorist Propaganda: The Paris Attack and Social Media,
BROOKINGS (Jan. 27, 2015), http://www.brookings.edu/research/testimony/2015/01/27-terrorist-
propaganda-social-media-berger.
56. Id.
57. McNeal, supra note 51, at 795.
58. Knox, supra note 45, at 300.
59. Will Oremus, Obama Wants Tech Companies to Install Backdoors for Government Spying, SLATE
(Jan. 19, 2015, 9:30 AM), http://www.slate.com/blogs/future_tense/2015/01/19/obama_wants_backdoors_
in_encrypted_messaging_to_allow_government_spying.html.
104 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

ist propaganda that might be filtered out on Twitter due to its violent or graphic
nature can be transmitted freely through encrypted platforms.

A. The Internet and ISIS’s Propaganda Machine

The Islamic State, also known as “ISIS” or “ISIL,” is a violent extremist
group that espouses a return to a seventh-century caliphate (a unified Muslim
state run according to a strict interpretation of Islamic law). The group, which is
located in parts of Syria and Iraq, has been shockingly successful at spreading
its message through 21st century social media. In Summer 2014, ISIS started
using various social media platforms to post videos of hostage executions and
other atrocities, to recruit fighters, and to promote its claim of having success-
fully established a caliphate. ISIS propaganda tends to frame its campaign in
“epochal terms,” mounting a frontal assault on the national divisions and
boundaries in the Middle East that were drawn by Western powers after World
War I.60
ISIS represents the latest of three generations in an evolution of modern
jihadist propaganda. The first was the era of Osama bin Laden who relied on
video to spread his message. Bin Laden used a single static camera to film his
long-winded rhetoric in highly formal Arabic.61 These videos then had to be
smuggled to Al Jazeera or other television networks in order to be aired.62 The
second generation was represented by Anwar al-Awlaki, the American-born
cleric killed in a drone strike in Yemen in 2011.63 Al-Awlaki was a YouTube
star, had a blog and a Facebook page, and helped produce a full-color English-
language magazine called Inspire.64 The third generation is represented by ISIS
and its full-fledged embrace of the most current communications technology.
ISIS boasts thousands of Twitter accounts spreading its message in several
different languages, videos with Hollywood-like effects, and an adept command
of various other social media platforms and Internet websites.
An example of ISIS’s revolutionary approach to propaganda can be found in
its use of hostages in film. Hostages first appeared in propaganda videos in the
1980s: when Western hostages held in Lebanon were forced to appear on
camera, mainly to provide proof of life and communicate their captors’ de-
mands.65 Al Qaeda took the tactic further and began killing of hostages on
camera. In 2014, the newly renamed “Islamic State” group, in an even more
sophisticated approach, produced professional-looking English-language videos
of hostages being killed.

60. Shane & Ben Hubbard, supra note 46.

61. Id.
62. Id.
63. Id.
64. Id.
65. A Short History of ISIS Propaganda Videos, HUFFINGTON POST (Mar. 11, 2015), http://www.
huffingtonpost.com/2015/03/11/isis-propaganda-videos_n_6846688.html.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 105

ISIS has gone so far as to establish the “Al Hayat Media Center” in which
generates media specifically aimed at non-Arabic speakers, particularly younger
viewers. Its output resembles that of mainstream broadcasts,66 though their
videos are distinguished by glossy identifying marks: either a teardrop-shaped
logo of Arabic script materializing from a digital cascade of water67 or a black
and white ISIS flag in the corner of the screen.68 The Center makes videos in
several different languages and formats, including everything from minute-long
Twitter-friendly “mujatweets” to hour-long Hollywood-style documentaries show-
casing special effects and action scenes.69 It also publishes audio content and
Dabiq, an English-language PDF magazine.70 Al Hayat Media’s programming
includes a jihadi-type travel show called “Eid Greetings from the Land of
Khilafah,” filmed in Raqqa, Syria, which features ISIS fighters from Western
countries proclaiming how happy they are to be there.71 The show ends with the
sign-off: “I wish you were here.”72 “The Flames of War,” ISIS’s feature-length
film, glorifies ISIS’s “military heroism” with gruesome footage and poetic
verse.73 The more violent images of the film have been edited into a rapid-fire
action montage accompanied by a recruitment hymn.74 This film, like other ISIS
creations, implies that warfare is a real-life game of “Grand Theft Auto.”75
These films include little evidence of ISIS atrocities such as abduction, rape,
destruction of mosques, persecutions, crucifixions, and the whipping of women
who were caught without a hijab.76
The ISIS propaganda machine produces as many as 90,000 posts on Twitter,
YouTube, Facebook, and many other social media platforms every single day.77
Twitter, the San Francisco-based social media network, has more than 288
million active users worldwide,78 and is by far the most popular platform for
ISIS propaganda. Recently, Twitter has tried to thwart ISIS threats, propaganda,
and recruiting efforts by suspending accounts linked to the group, but these
efforts have not stopped ISIS sympathizers from maintaining thousands of

66. Steve Rose, The ISIS Propaganda War: A Hi-Tech Media Jihad, THE GUARDIAN (Oct. 7, 2014),
http://www.theguardian.com/world/2014/oct/07/isis-media-machine-propaganda-war.
67. Id.
68. Id.
69. Id.
70. Id.
71. Id.
72. Id.
73. Id.
74. Id.
75. Id.
76. Id.
77. Calls Mount for Shutdown of ISIS Propaganda Machine as London Girls Vanish, CBS NEW
YORK (Feb. 20, 2015, 5:17 PM), http://newyork.cbslocal.com/2015/02/20/calls-mount-for-shutdown-of-
isis-propaganda-machine-as-london-girls-vanish/.
78. Rick Gladstone & Vindu Goelmarch, ISIS Is Adept on Twitter, Study Finds, N.Y. TIMES (Mar. 5,
2015), http://www.nytimes.com/2015/03/06/world/middleeast/isis-is-skilled-on-twitter-using-thousands-
of-accounts-study-says.html?_r⫽1.
106 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

active accounts on the social network.79 Twitter’s efforts against ISIS have led
to death threats against the social media company’s leaders and employees.
In a recent paper, J.M. Berger and Jonathon Morgan of the Brookings
Institute presented a demographic snapshot of ISIS supporters on Twitter by
analyzing a sample of 20,000 ISIS-supporting Twitter accounts.80 They found,
amongst other things, that between September and December 2014, an esti-
mated 46,000 Twitter accounts were used by ISIS supporters, and at least 1,000
ISIS-supporting Twitter accounts were suspended during this time.81 Embedded
location metadata revealed that approximately one in five ISIS supporters
selected English as their primary language when using Twitter, and three
quarters of users selected Arabic.82 Each ISIS-supporting account had an aver-
age of about 1,000 “followers” (individuals who subscribe to a given Twitter
user’s postings), far more than an average Twitter user would have.83 Further-
more, ISIS-supporting accounts were much more active than those of non-
supporting users.84 A relatively small group of Twitter users, overseeing between
500 and 2,000 accounts, post their “tweets” in concentrated bursts of high
volume, a tactic so effective that they are responsible for much of ISIS’s social
media success.85

B. Who is Joining ISIS?

“The International Centre for the Study of Radicalisation and Political Vio-
lence estimates that of the 20,000 or more foreign jihadists believed to have
gone to fight in Syria and Iraq, around 100 are from the United States, reports
one article.”86 The majority of ISIS recruits are men, but there are also quite a
few women.87 American recruits come from across the United States, and range
from teenagers to middle-aged adults with families and careers, petty criminals
to diligent students, and Islam converts to children of Muslim immigrants.88
Notes one observer, “Most of the American ISIS volunteers display an earnest
religious zeal, usually newfound.”89
Since 2013, twenty-nine people in the United States have been charged or
detained as juveniles on allegations of supporting ISIS, usually after trying to

79. Id.
80. J.M. Berger & Jonathon Morgan, The ISIS Twitter Census, BROOKINGS (Mar. 2015), http://www.
brookings.edu/research/papers/2015/03/isis-twitter-census-berger-morgan.
81. Id.
82. Id.
83. Id.
84. Id.
85. Id.
86. Cottee, supra note 43.
87. Scott Shane, Minneapolis to ISIS: An American’s Path to Jihad, NYTIMES.COM (Mar. 21, 2015),
http://www.nytimes.com/2015/03/22/world/middleeast/from-minneapolis-to-isis-an-americans-path-to-
jihad.html.
88. Id.
89. Id.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 107

travel to Syria to fight for the terrorist group. Two dozen other young Americans
are believed to either be with ISIS or to have been killed in the fighting.90 Three
teenage girls from Denver, ages 15, 16, and 17, were stopped in Germany in
October 2014, reportedly on their way to Syria to join ISIS.91 In mid-February,
three British schoolgirls, ages 15 and 16, were reported missing after taking a
flight to Turkey, apparently on their way to join ISIS.92
Teenagers who have been caught at airports attempting to leave the United
States to join ISIS have provided a variety of explanations for doing so. For
example, Shannon Conley, 19, was stopped by the F.B.I. in Denver.93 She
thought she could use her skills as a nurse’s aide to help ISIS fighters, and had
hoped to marry a Tunisian recruiter for ISIS whom she had met online.94
Mohammed Hamzah Khan, 19, was stopped with his younger brother and sister
in Chicago.95 Khan left his parents a letter saying he could not stay in the
United States because his taxes might be used to kill Muslims overseas.96 Some
young Americans who have successfully traveled to join ISIS have commented
about their new life on Twitter. For example, a Muslim convert from San
Francisco who calls herself “Chloe” appears to have married a Welsh fighter
who joined Nusra Front.97 She posts pictures of their cat along with expressions
of marital devotion, religious exclamations, and light-hearted remarks about her
life in Syria.98
President Obama and Secretary of State John Kerry have publicly recognized
that ISIS is targeting young people through its propaganda. According to
President Obama, it is crucial to shut down the ISIS propaganda machine that is
attracting the young recruits.99 In February 2015, at a Washington summit on
Countering Violent Extremism, President Obama stated that “[t]errorist groups
like al-Qaeda and ISIL deliberately target their propaganda in the hopes of
reaching and brainwashing young Muslims, especially those who may be
disillusioned or wrestling with their identity.”100 “The high-quality videos, the
online magazines, the use of social media, terrorist Twitter accounts – it’s all
designed to target today’s young people online,” said President Obama.101
Secretary of State John Kerry, while addressing a White House Summit, stated

90. FBI: ISIS message resonating with young people from U.S., West, CBS NEWS (Mar. 5, 2015, 8:15
PM), http://www.cbsnews.com/news/isis-targeting-young-people-from-u-s-western-countries-as-recruits/.
91. Id.
92. Id.
93. Id.
94. Id.
95. Id.
96. Id.
97. Id.
98. Id.
99. Id.
100. Kathy Gilsinan, Is ISIS’s Social Media Power Exaggerated?, THE ATLANTIC (Feb. 23, 2015, 7:05
AM), http://www.theatlantic.com/international/archive/2015/02/is-isiss-social-media-power-exaggerated/
385726/.
101. Id.
108 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

that “Those recruiting for ISIS are not looking for people who are devout and
knowledgeable about the tenants of Islam . . . [t]hey’re looking for people gull-
ible enough to believe that terrorists enjoy a glamorous lifestyle.”102
ISIS is recruiting more than just fighters: the group is using propaganda to
attract potential wives and professionals such as doctors, engineers, and accoun-
tants, as part of its plan to build a new “utopian” society.103 ISIS propaganda
varies, then, depending on the target audience, and is calculated to attract young
individuals to serve a variety of purposes, luring them in through a range of
deceptive strategies. While the group’s violent, outrageous propaganda draws
the most attention, the most dangerous propaganda may arguably be that which
attempts to glamorize and normalize life in ISIS as a way of recruiting
teenagers.104
The propaganda that targets potential jihadi brides tends to romanticize life in
ISIS. It presents ISIS as espousing gender equality and offering a positive place
for women and families. For example, in early March 2015, a Western “jihadi
bride” posted a picture in which she and other ISIS women posed around a
luxury BMW, brandishing guns much like their male counterparts.105 This
image, which suggests power and a sense of equality among male and female
militants, is in stark contrast with the situation revealed in recent ISIS docu-
ments that indicate that women are heavily monitored and treated as inferior to
men.106 Other pictures have attempted to portray ISIS as pro-family by showing
ISIS fighters enjoying an average family life and playing with children in the
sunshine.107 In 2014, at least 100 French women were recruited to join ISIS as
either jihadi brides or suicide bombers.108 The propaganda targeting women
likely played a large role in recruiting them.
Propaganda aimed at men also often portrays life in ISIS as utopian For
example, a fighter posted a picture on Twitter of himself and other young male
ISIS fighters in Raqqa, relaxing and laughing together, with the caption “broth-
ers enjoying a day in the sun.”109 Such propaganda attempts to normalize
militants and their daily activities in order to construct an idyllic image of life in

102. Rebecca Kaplan, ISIS Recruiting Teenagers: Why the Government is Sounding the Alarm, CBS
NEWS (Mar. 10, 2015, 6:00 AM), http://www.cbsnews.com/news/isis-recruiting-teenagers-why-the-
government-is-sounding-the-alarm/.
103. Eric Tucker, Islamic State Recruits More than Just Fighters, BOSTON GLOBE (Dec. 17, 2014),
http://www.bostonglobe.com/news/world/2014/12/16/islamic-state-recruits-more-than-just-fighters/Wu
34jcNUyj4HSiNqrDxIOI/story.html.
104. Heather Saul, The Most Dangerous ISIS Propaganda Yet?, THE INDEPENDENT (Mar. 20, 2015),
http://www.independent.co.uk/news/world/middle-east/the-most-dangerous-isis-propaganda-yet-
jihadi-brides-with-m5s-fighters-relaxing-and-children-playing-used-to-present-caliphate-as-a-utopia-
10121653.html.
105. Id. The article also describes, for example, a photograph of young men captioned “brothers
enjoying a day in the sun.”
106. Id.
107. Id.
108. Tucker, supra note 104.
109. Saul, supra note 105.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 109

ISIS.110 What’s more, this propaganda often appeals to foreign recruits, particu-
larly those from the West, who may be looking for signs that their new life will
still contain aspects of their present life that they may find hard to leave
behind.111 Teenagers have said that one of the main reasons they were drawn
into ISIS was the desire to be a part of the perceived “romanticism” of what
ISIS is building.112 ISIS propaganda suggests that these young adults can enjoy
the glamor and romanticism of their new society while still having the luxuries
of home.
In countries where basic necessities such as gas and flour are unavailable,
propaganda with a more materialistic focus is an effective recruitment tool.113
For instance, pictures suggesting financial gains for recruits can be persuasive to
a young person of no means. In fact, financially focused propaganda is a
powerful way to attract fighters who may not truly believe in the ideological or
theological message.114 Financial incentives have been blamed at least in part
for luring young British Muslims to join ISIS. In the UK, this demographic had
the highest level of unemployment in 2011.115 The lack of job prospects at
home, when combined with propaganda suggesting financial rewards, may
make it more likely that young adults will become radicalized.116
Another form of ISIS propaganda is that which speaks of creating a “pure”
Muslim race. Such propaganda has been compared to Nazi propaganda for its
emphasis on building a “master race.”117 Some potential new recruits have tried
to prove their worthiness as part of this “master race” by demonstrating their
faithful adherence to ISIS’s view of Islam. Examples of such responses can be
seen in certain Muslim teenagers’ fixation on only befriending or becoming
romantically involved with certain other types of Muslim individuals, and their
descriptions of their own “pure” familial lineage.

III. PROPOSALS FOR COUNTERING TERRORISM PROPAGANDA ON THE INTERNET

To effectively thwart ISIS in its online terrorist activities, the United States
should employ a multi-faceted approach that undermines and weakens the
group and its messages. This effort should consist of: (1) physically removing
the offending propagandists through the criminal justice process; (2) removing
offending propaganda on social media platforms; and (3) discrediting and
undermining the group through active counter-propaganda measures.

110. Id.
111. Id.
112. Caplan, supra note 103.
113. Saul, supra note 105.
114. Id.
115. Felicity Capon, ‘Perfect Storm’ For Teenagers Lured by Islamic State, NEWSWEEK (Mar. 19,
2015, 9:32 AM), http://www.newsweek.com/perfect-storm-british-teenagers-lured-islamic-state-
315022.
116. Id.
117. Id.
110 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

A. Charge Propagandists Under the Material Support Statute

Terrorist group supporters who publish propaganda about their organization
may be subject to criminal prosecution under 18 U.S.C. § 2339A for providing
material support to terrorists.118 The Act, known as the Material Support
Statute, was originally passed by Congress in 1994, in response to the bombing
of the World Trade Center in 1993, and updated by the USA Patriot Act of 2001,
in response to the terrorist attacks on 9/11. Section (b)(1) of the statute defines
material support or resources as “any property, tangible or intangible, or service,
including currency or monetary instruments or financial securities, financial
services, lodging, training, expert advice or assistance, safehouses, false documen-
tation or identification, communications equipment, facilities, weapons, lethal
substances, explosives, personnel (one or more individuals who may be or
include oneself), and transportation, except medicine or religious materials.”
The Act requires that the individual knows or intends that the material support
or resources be used in preparation for or in carrying out a specific crime
enumerated in the statute.
The United States Supreme Court opined on the Material Support Statute in a
case involving the Humanitarian Law Project (HLP), a United States based
human rights organization with consultant status to the United Nations. HLP
sought to “provide support for the humanitarian and political activities of the
PKK [(Partiya Karkeran Kurdistan)] and LTE [(Liberation Tigers of Tamil
Eelam)] in the form of monetary contributions, other tangible aid, legal training,
and political advocacy, but could not do so for fear of prosecution under the
material support provision of the Antiterrorism and Effective Death Penalty Act
(“AEDPA”).”119 PKK and LTE are foreign terrorist organizations (FTO). The
plaintiffs challenged the AEDPA provision – also known as the Material Sup-
port Statute – in federal court.120 Among other things, the plaintiffs claimed the
statute was invalid to the extent that it prohibited them from engaging in certain
activities, including training members of the organizations on how to peacefully
resolve disputes through the legal process and how to petition representative
bodies, such as the UN, for relief.121
The Supreme Court held the material support provision of the AEDPA to be
constitutional as applied to the particular forms of support that the plaintiffs
sought to provide to the designated organizations. First, the Supreme Court
found that Congress spoke to the necessary mental state for a violation of
§ 2339B when it mandated that the plaintiff be cognizant of the organization’s
connection to terrorism. The Court distinguished the Material Support Statute
from the statute at issue in Scales v. United States122 by finding that the statute

118. See 18 U.S.C. § 2339A (2012).

119. Holder v. Humanitarian Law Project, 561 U.S. 1, 10 (2010).
120. Id. at 10-11.
121. Id. at 14-15.
122. 367 U.S. 203 (1961).
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 111

did not criminalize mere membership in a designated foreign terrorist organiza-

tion, but instead prohibits providing “material support” to such a group.123 The
Court rejected the plaintiffs’ vagueness challenge to the statute, finding that the
statutory terms were not impermissibly vague as applied to the plaintiffs.124
Next, the Court found that the plaintiffs’ activities would fall within the scope
of “training” and “expert advice.”125 According to the Court, support meant to
“promot[e] peaceable, lawful conduct” could further terrorism by foreign groups
in multiple ways, including by freeing up resources within the group that may
be put to violent ends, helping lend to the legitimacy of foreign groups and thus
making it easier for those groups to recruit members, and undermining coopera-
tive efforts between nations to prevent terrorist attacks.126 The Court also found
it important that there were sensitive interests in national security and foreign
affairs at stake, which entitled Congress and the Executive Branch’s judgments
to significant weight.127
Finally, the Court found that the prohibition of particular forms of support
under the statute did not violate the plaintiffs’ freedom of speech.128 The Court
noted that the statute reaches only material support that is coordinated with or
under the direction of a designated foreign terrorist organization, so that indepen-
dent advocacy promoting the group’s legitimacy would not be prohibited.129
However, it was undisputed that the HLP’s advocacy was not independent, so
the Court did not elaborate further on the issue of coordination.
Thus, after Holder, as long as speech takes the form of expert advice or
assistance conveyed in coordination with or under the control of a designated
foreign terrorist organization, it can be considered material support for terrorism
under the Material Support Statute. A prosecution based on such material
support does not violate the First Amendment. However, the Supreme Court has
yet to rule definitively on what counts as coordination or control under the
statute.

1. United States v. Mehanna

In 2011, in United States v. Mehanna, the United States District Court for the
District of Massachusetts found United States citizen Tarek Mehanna guilty
under the Material Support Statute.130 Among other things, the government
charged that Mehanna had provided material support and attempted to provide
material support by translating al Qaeda propaganda into English and disseminat-

123. Humanitarian Law Project, 561 U.S. at 17–18.

124. Id. at 20.
125. Id. at 21.
126. Id. at 30-32.
127. Id. at 33-34.
128. Id. at 39.
129. Id. at 31.
130. 735 F.3d 32 (1st Cir. 2013).
112 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

ing it over the Internet.131 Mehanna allegedly provided a translation of the

pro-jihadi propaganda text called “39 Ways to Serve and Participate in Jihad” to
a jihadi website called Tibyan Publications, which published and distributed
it.132 The government also alleged that Mehanna flew to Yemen to undergo
military training at a terrorist camp, though he was unsuccessful in the en-
deavor.133 The trial record was replete with evidence that Mehanna had sup-
ported al-Qaeda. However, neither side argued that Mehanna translated the
materials at the request of al-Qaeda.134 Nevertheless, the government argued
that by associating with al-Qaeda operatives and promoting its jihadist speech,
Mehanna coordinated with the terrorist organization.135
To demonstrate that Mehanna violated the Material Support Statute as inter-
preted by Holder, the prosecution had to prove three elements.136 First, the
prosecution demonstrated that Mehanna knew either that the organization was
designated as a foreign terrorist organization or that it engaged in terrorist
activity. Even if Mehanna was not aware of al-Qaeda’s designation as a foreign
terrorist organization, they argued, he certainly knew it was engaged in terrorist
acts given that he had visited jihadist websites and online message boards and
had sent his friends links to a video tribute to the 9/11 hijackers.137 Second, the
prosecution demonstrated that Mehanna provided material support or resources
by advancing two theories. The first theory was that Mehanna attempted to
himself as “personnel” when he went to Yemen in 2004 to seek terrorist
training.138 Under the statute, “personnel” is defined as providing “one or more
individuals (who may be or include himself) to work under that terrorist
organization’s direction or control or to organize, manage, supervise, or other-
wise direct the operation of that organization.” There is no requirement that the
individual be an employee or even a member of the terrorist organization to
qualify as “personnel” under the statute. Alternatively, the government argued
that Mehanna provided material support when he provided “expert advice” in
the form of translating propaganda material into English, and that his transla-
tions enhanced the propaganda and helped to spread al-Qaeda’s message and aid
recruitment.139 Under the statute, “expert advice” refers to “advice or assistance
derived from scientific, technical, or other specialized knowledge.”

131. Nikolas Abel, Note, United States v. Mehanna, The First Amendment, and Material Support in
the War on Terror, 54 B.C. L. REV. 711, 731 (2013).
132. Id.
133. Id.
134. Mark Joseph Stern, Translating Terrorism, SLATE (Sep. 3, 2014, 6:49 AM), http://www.slate.com/
articles/technology/future_tense/2014/09/mehanna_at_the_supreme_court_is_translating_jihad_texts_a_
crime.html.
135. Id.
136. Christopher Pochon, Recent Development, Applying the Holder Standard to Speech that
Provides Material Support to Terrorism in United States v. Mehanna, 36 HARV. J.L. & PUB. POL’Y 375,
382 (2013).
137. Id. at 382.
138. Id. at 383.
139. Id. at 384.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 113

Third, the government demonstrated that Mehanna knowingly coordinated or

attempted to coordinate with al-Qaeda. The best evidence that Mehanna directly
coordinated with al-Qaeda came in the form of an email message he received
from a member of Tibyan Publications. The message used various code words
indicating that Tibyan Publications was working with al-Qaeda.140 After he
received the letter, Mehanna continued to translate al-Qaeda propaganda materi-
als.141 Mehanna was ultimately convicted and sentenced to seventeen and a half
years in prison.142
The convictions were upheld on appeal to the United States Court of Appeals
for the First Circuit. The Court found that the evidence was sufficient to ground
a finding that Mehanna had traveled to Yemen with the specific intent of
providing material support to al-Qaeda, knowing that this support would be
used in a conspiracy to kill persons abroad, and that while in the United States,
he conspired with others in a plan to kill persons abroad.143 Thus, by sustaining
the conviction on the basis of Mehanna’s activities in Yemen, the Court avoided
having to address the First Amendment issues raised by the theory that he had
provided material support by translating al-Qaeda propaganda. The Supreme
Court denied certiorari in the case.144 Thus, it remains an open question as to
what “coordination” means under the Material Support Statute and whether
assisting in the creation or dissemination of propaganda is sufficient to qualify
as material support.145

2. Twitter and Material Support

Holder and Mehanna pose interesting possibilities for the use of social media
to materially support a terrorist organization such as ISIS. For example, there is
a possibility that “retweets” on Twitter could amount to material support for
terrorism. On Twitter, a “retweet” is a reposting of someone else’s “tweet” or
Twitter posting.146 The retweet appears on the personal home timeline of the
user who retweets the post. A pro-ISIS Twitter user may choose to retweet an
ISIS member’s tweet, thus republishing the post for her “followers” to see and
making the post available on her personal page. Could a simple retweet be
viewed as enhancing and spreading ISIS propaganda? Consider Mehanna’s
case. Mehanna’s translation helped to spread al-Qaeda’s message to individuals
who otherwise would be unable to read it. Similarly, by retweeting a message, a
user assists the original tweeter by making the post available on his home

140. Id. at 385.

141. Id. at 385.
142. Andrew F. March, A Dangerous Mind?, N.Y. TIMES (Apr. 21, 2012), http://www.nytimes.com/
2012/04/22/opinion/sunday/a-dangerous-mind.html.
143. United States v. Mehanna, 735 F.3d 32,46 (1st Cir. 2013).
144. Mehanna v. United States, 135 S.Ct. 49 (2014) (mem.).
145. Lyle Denniston, Crime on the Internet: A Difficult New Question, SCOTUSBLOG (Aug. 14,
2014, 3:49 PM), http://www.scotusblog.com/2014/08/crime-on-the-internet-a-difficult-new-question/.
146. FAQs about Retweets, TWITTER, https://support.twitter.com/articles/77606-faqs-about-retweets-rt
(last visited Mar, 24, 2015).
114 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

timeline, thereby giving the tweeter’s message wider exposure. It would likely
not be an issue to establish that the user knew that ISIS was participating in
terrorist activities. However, it could be difficult to prove coordination, as it is
still unclear what amounts to coordination.
In another scenario, Twitter postings could amount to material support by
providing “personnel” to a terrorist group. In such a scenario, a Twitter user
could post ISIS propaganda that inspires another individual to join ISIS. Essen-
tially, the argument would be that the Twitter user’s propaganda recruited
another individual into ISIS, thus providing ISIS with personnel.
In Brandenburg v. Ohio, the Supreme Court held that “the constitutional
guarantees of free speech and free press do not permit a State to forbid or
proscribe advocacy of the use of force or law violation except where such
advocacy is directed to inciting or producing imminent lawless action and is
likely to incite or produce such action.”147 A pro-ISIS Twitter user may be
found to have incited “imminent lawless action” if the user’s postings can be
linked to the imminent terrorist activity of others; however, it is unclear how
imminent such terrorist activity would need to be to satisfy Brandenburg.
Furthermore, it is unclear if Brandenburg would even apply to a situation
involving personnel under the material support statute. As discussed earlier, the
Supreme Court in Holder found that the Scales case did not dictate that the
Material Support Statute’s prohibition on the plaintiff’s speech violated the First
Amendment because material support was different than mere association in a
group. Similarly, the Court may find that providing personnel under the Material
Support Statute excuses the speech from Brandenburg’s reach because material
support is something different than mere advocacy.
At a cyber-security conference in February 2015, John Carlin, Assistant
Attorney General for National Security, suggested that the Justice Department
could charge individuals under the Material Support Statute for pro-ISIS social
media postings.148 Carlin noted that the United States could use the statute to
prosecute individuals for providing “technical expertise” to a designated terror-
ist organization, and that spreading the word for ISIS may count as such
expertise. The possibility of using the Material Support Statute to prosecute
individuals for promoting ISIS on social media is controversial, and the likely
legality of such a prosecution has been hotly debated among legal professionals.
If possible, it could be a powerful deterrent and active measure to combat
pro-ISIS users.

147. 395 U.S. 444, 447 (1969).

148. Shane Harris, Justice Department: We’ll Go After ISIS’s Twitter Army, THE DAILY BEAST (Feb.
23, 2015), http://www.thedailybeast.com/articles/2015/02/23/justice-department-we-ll-go-after-isis-twitter-
army.html.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 115

B. Treat Private Internet Users as Unlawful Combatants

Propaganda is sometimes referred to as a psychological operation because it
can be used as a form of warfare designed to destabilize and undermine enemy
efforts and morale.149 Members of the armed services who are engaged in
psychological operations, which include propaganda efforts, are referred to as
combatants.150 Private internet users spreading false information or rumors in
order to undermine military or other national security interests may run the risk
of becoming unlawful combatants if their activities amount to psychological
operations.151

C. Wait for the Propaganda to Backfire

There is the possibility that ISIS’s propaganda will be its own undoing. For
example, ISIS appeared exceptionally inhumane when a 2014 ISIS video
purported to show Alan Henning, a British humanitarian aid worker, being
beheaded after his family and British leaders pleaded for his life.152 The
family’s calm, heartfelt, personal pleas stood in stark contrast to ISIS’s unapolo-
getically hateful rhetoric and actions.153 Furthermore, the execution took place
on the eve of the Islamic festival of Eid al-Adha, which celebrates the mercy of
god and is regarded as one of the most holy days on the Islamic calendar, which
made ISIS also appear un-Islamic.154 When ISIS shows itself to be so exception-
ally violent or un-Islamic, it runs the risk of alienating potential new recruits. It
also potentially discredits its own message by being self-contradictory about its
views on Islam and the normalcy or glamour of life in the “caliphate.”

D. Physically Stop ISIS Recruits from Joining ISIS

More than two dozen men and women have been stopped by the FBI and
charged before they could get on a plan to join the Islamic State.155 However,
social media posts and court records suggest that perhaps even more individuals
have successfully reached the group in Syria than have been stopped, and that at
least four Americans have died fighting for ISIS.156 Thus, while this option
should still be pursued when possible, it is insufficient by itself to stop every
would-be recruit from traveling to join ISIS.

149. Michael H. Hoffman, The Legal Status and Responsibilities of Private Internet Users Under the
Law of Armed Conflict: A Primer for the Unwary on the Shape of the Law to Come, 2 WASH. U. GLOBAL
STUD. L. REV. 415, 424 (2003).
150. Id.
151. Id.
152. Rose, supra note 66.
153. Id.
154. Id.
155. Shane, supra note 87.
156. Id.
116 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

E. Fight ISIS on the Ground

In December 2014, a US-led global coalition was formed to fight ISIS in Iraq
and Syria.157 Hundreds of airstrikes have allegedly hit ISIS targets since the
formation of this coalition.158 However, as long as reality supports ISIS’s
narrative that Sunni Muslims are being persecuted in Syria and Iraq at the hands
of the Assad regime and the Iranian-backed Shiite militias, then ISIS’s message
will continue to appeal to disaffected Sunnis within and outside the Muslim
world.159 Furthermore, as long as ISIS can claim that it is successfully establish-
ing its caliphate, their legitimacy will continue to go relatively unchallenged by
those who are lured by its claims of accomplishment. Thus, a change to the
current situation in ISIS-occupied areas is likely necessary to precipitate a
change in the efficacy of ISIS propaganda.

F. Shut Down ISIS Twitter Accounts

In September 2014, a Twitter account affiliated with the hactivist group
“Anonymous” declared a “full-scale cyber war against ISIS.”160 It has since
claimed responsibility for cyber-attacks against nearly 800 Twitter accounts, 12
Facebook pages, and more than 50 email addresses linked to ISIS.161 Anony-
mous reports user profiles it believes are associated with ISIS to the social
media companies, which in turn can take action by suspending the accounts.
Twitter has suspended thousands of pro-ISIS user accounts, but many of the
users have returned under new account names. Currently, Twitter policy re-
quires that individuals report a possible violation of the company’s policies
before they will look into possibly suspending an account.162 However, Twitter
began a trial policy in March 2015 that allows the site to scan for abusive and
offensive language, threats and harassment, and to then remove the abusive
posts.163 This new feature could render the user reporting requirement obsolete
and allow Twitter to be more proactive, rather than reactive in the fight against
terrorism.
However, some anti-terrorism law enforcement experts have questioned the
efficacy of taking down pro-ISIS Twitter accounts.164 Closing down Twitter
accounts can temporarily hinder users from spreading ISIS propaganda, but
most of them come back under new account names within a day or so of having

157. Hiba Zayadin, Fighting Words: Inside the Social Media War Against ISIS, MEDIASHIFT (Mar. 5,
2015), http://mediashift.org/2015/03/fighting-words-inside-the-social-media-war-against-isis/.
158. Id.
159. Cotte, supra note 43.
160. See Zayadin, supra note 157 (noting hactivist groups use hacking for advocacy purposes).
161. Id.
162. Victoria Woollaston, Twitter’s “Quality Filter” Set to Rid The Site of Abuse, DAILY MAIL (Mar.
25, 2015), http://www.dailymail.co.uk/sciencetech/article-3010827/Twitter-s-Quality-Filter-set-rid-site-
abuse-Tool-automatically-censor-tweets-contain-threats-offensive-language.html.
163. Id.
164. Zayadin, supra note 157.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 117

their accounts removed. Furthermore, law enforcement and intelligence services

find it advantageous to monitor these accounts for useful information. Eliminat-
ing them removes the possibility of gaining valuable data. Finally, a pro-ISIS
user might respond to losing an account on Twitter or other social media sites
by moving to platforms that are more difficult to monitor, such as encrypted
messaging services.

G. Create “Backdoors” for Electronic Devices

ISIS has been relatively careful to use social media and chat applications in a
way that avoids detection by American surveillance agencies such as the
National Security Agency.165 The use of encryption, such as is available on the
iPhone6, exacerbates this problem by putting the government at risk of not
being able to monitor terrorists and spies. Some individuals have suggested that
lawmakers should come up with a solution for ensuring government access to
encrypted communications.166 However, others have argued that such access
would constitute a “backdoor” to spy on people around the world, not just
terrorists or others deemed to be a threat.167 Further, there is debate among
American officials over whether this backdoor would be available only to the
United States government, or whether other governments should also receive
backdoor access to their citizens’ devices.168

H. Employ Active Counter-Propaganda Measures

The most effective strategy for combatting ISIS may be through active
counter-propaganda efforts that challenge and undermine the terrorist group.
These efforts should seek to portray the reality of life in ISIS-occupied areas,
poke holes in ISIS’s false veil of legitimacy, and provide a counter-narrative to
other lures drawing potential recruits into joining ISIS. Importantly, these
efforts should concentrate on addressing the “pull” factors or “lures” that attract
individuals to terrorism.
Strategies that embarrass and damage the reputations of a terrorist organiza-
tion can be highly effective in countering the terrorist group’s narrative and
making membership appear less attractive. For example, in 1987, a British
investigative journalist ran an undercover expose of the racketeering activities
of the Ulster Defence Association (UDA), a Loyalist terrorist organization from
Northern Ireland.169 The journalist set up and secretly filmed a meeting where a
UDA leader was shown having difficulty with simple arithmetic during his
calculation of an extortion demand on a supposed businessman.170 This documen-

165. Harris, supra note 148.

166. Id.
167. Id.
168. Id.
169. Horgan, supra note 29, at 90.
170. Id.
118 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

tary was a source of extreme embarrassment to the UDA and was likely a
powerful contributing factor to the group’s massive upheaval and permanent
reputational damage.171 Similarly, public displays of ISIS members engaging in
embarrassing activities could serve to undermine the perceived prestige of the
group’s adherents.
Another goal of counter-propaganda efforts should be to expose the realities
of life in ISIS occupied territories. The media can play an important role in
undermining ISIS propaganda that portrays the terrorist life as glamorous and
romantic by broadcasting stories of real-life hardships in ISIS and other terrorist
organizations. As a result, naive teenagers who might otherwise be drawn to
ISIS may be less-inclined to join the group if they knew the dangers of its
world.
The United States and other countries should also seek to provide a counter
narrative to undermine other aspects of the ISIS narrative. This includes efforts
to discredit ISIS claims of power, legitimacy, and moral righteousness. For
example, they could damage ISIS claims of power by widely publicizing
accounts of ISIS military defeats. Likewise, religious leaders could offer alterna-
tive interpretations of the terrorist group’s ideology that discredit their actions
and puncture their claims of moral and religious righteousness. Additionally,
countries should seek to publicize examples of inclusion and respect within
their own territories, so as to undermine the ISIS narrative that portrays Western
countries as hostile to those the group seeks to recruit. This could include posts
on social media outlets about prominent leaders of a variety of faiths working
together, advertisements about opportunities to connect with like-minded indi-
viduals in a non-hostile environment, and other similar efforts to demonstrate
the potential to feel connected and accepted without needing to turn to danger-
ous organizations.

1. Current Counter-Propaganda Efforts

The Center for Strategic Counterterrorism Communications (CSCC), located
in the U. S. Department of State, was founded in 2010 as the world’s first
government-sponsored enterprise – not run by an intelligence agency – to coun-
ter online jihadist propaganda.172 While she was Secretary of State, Hillary
Clinton described the CSCC’s mission as vital to diminishing the appeal of
terrorism, and noted that the CSCC was focused on “undermining terrorist
propaganda and dissuading potential recruits.”173 CSCC is at the forefront of
what is being referred to as the “war of narratives.”174 The CSCC’s digital
outreach team (DOT) crashes various online forums to “troll” ISIS sympathiz-

171. Id.
172. Cotte, supra note 43.
173. Id.
174. Id.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 119

ers and often jumps onto pro-ISIS Twitter hashtags.175 For example, in April
2014, DOT responded to the pro-ISIS hashtag #accomplishmentsofISIS by
using the same hashtag to post a series of sarcastic references to ISIS’s
accomplishments and links to YouTube videos detailing ISIS atrocities in
Syria.176
However, the CSCC is at a disadvantage because they have been unable to
match the shocking and outrageous videos of ISIS, the efforts of their dedicated
pro-ISIS Twitter users, or ISIS’s compelling narrative.177 Beheading videos are
shocking and repugnant, but they are also disturbingly fascinating and go viral
for this reason. CSCC videos do not go viral, and this is likely due to their less
shocking nature. Whereas ISIS’s videos have been characterized as “shock and
gore,” the CSCC’s videos have been described as “mock and bore.”178 ISIS has
a wide network of virtual supporters, referred to many as “fanboys,” who
disseminate the group’s online propaganda.179 ISIS refers to these individuals as
“knights of the uploading.”180 These “fanboys” are especially prevalent on
Twitter, despite the social media network’s efforts to ban them. The CSCC does
not have fanboys. Furthermore, and perhaps most crucially, ISIS has a strong,
compelling narrative. The CSCC does not have a narrative, or at least not one
remotely comparable in emotional strength and resonance to that of ISIS. ISIS’s
narrative is essentially that Muslims are being killed and that ISIS is the
solution. The CSCC’s narrative consists of warnings to not do what ISIS wants,
but it lacks a positive message of what to do instead. One of the greatest
challenges in counterterrorism is finding a narrative that directly speaks to a
similar kind of longing among potential terrorists and channels that longing into
nonviolent action.
Another current form of counter-propaganda comes from non-governmental
actors poking fun at terrorist organizations. For example, a group of young
Syrian refugees has been making short YouTube videos mocking ISIS.181 These
videos are useful for many reasons, including their potential ability to under-
mine ISIS’s power and make it appear less impressive, but also, very impor-
tantly, for having Middle Easterners communicate the satire. The men are
effectively saying that not all Middle Easterners support ISIS or are impressed
with the group.

175. Id.
176. Id.
177. Id.
178. Id.
179. Id.
180. Id.
181. Constanze Letsch, Laughing at ISIS: Syrian Video Artists Go Beyond Fear to Ridicule
Jihadists, THE GUARDIAN, (Mar. 12, 2015), https://www.theguardian.com/world/2015/mar/12/laughing-at-
isis-syrian-video-artists-jihadis-refugee-islamic-state.
120 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

2. Future Counter-Propaganda Efforts

This paper proposes the following criteria for successful counter-propaganda
attacks in the future:
1) Use a credible communicator.
In order to effectively discredit ISIS, the target audience must trust the source
of the communicated information. The effectiveness of any propaganda lies in
large part in the perceived credibility and relevant expertise of the communica-
tor and on the communicator’s perceived intentions.182 Hence, counter-
propaganda efforts must identify credible sources to serve as spokespersons.
The best candidates for this role perhaps would be distinct from the United
States Government, at least on the surface, in order to avoid assumptions of
bias. Such assumptions, in fact, may affect the impact of CSCC. Although this
program is useful for providing a factual challenge to ISIS’s claims, its message
may fall on deaf ears if the recipient already assumes the government is biased.
Alternative views that are linked to “the enemy” may be perceived as lacking
credibility.183
In addition, the communicator is more likely to be trusted if he is perceived
as having nothing to gain from his speech.184 Ideally, the counter-propaganda
information should come from a source with whom the target audience identi-
fies, such as a prior supporter of the given terrorist group. The communicator’s
perceived trustworthiness may also be influenced by factors such as having a
social background similar to the terrorists’. However, a large difference in age
(as in much older) or level of leadership may promote the communicator to an
“expert” status.185 Communicators who can effectively counter ISIS propa-
ganda might include individuals who were previously involved with the organi-
zation but then left it. With such firsthand experience, they could help to both
dispel the attractions and expose the realities of life in ISIS. Such a communica-
tor could particularly appeal to would-be recruits who are hesitant about joining
ISIS or who have already joined but may be thinking about leaving.
It is possible that former ISIS members will come forward on a volunteer
basis to work with CSCC. In addition, potential communicators may be found
through informant programs, whereby U. S. attorneys could offer incentives to
those facing terrorism prosecution in exchange for participation in the counter-
propaganda program. However, the government’s involvement must not become
so obvious as to render the communicator a mere agent of the state. Rather, it is
essential to maintain some appearance of legitimacy to preserve the effective-
ness of the message.

182. Id.
183. Id.
184. Id.
185. Id.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 121

2) Use factual information.

In order for the counter-propaganda to be perceived as neutral and honest,
and thus more credible and persuasive, it should be based on objective factual
information that cannot be dismissed as anti-ISIS propaganda. The example
provided earlier of the Irish terrorist who had difficulty doing simple arithmetic
provides an excellent illustration of the power of honest footage. By videotap-
ing an ISIS member in a similarly embarrassing situation, where he or she
appears to be incompetent or does something shameful, such footage may cast
the group in a negative light. Like the Irish terrorist, the ISIS terrorist caught on
tape can be a source of extreme mortification, especially if the video cannot be
disputed for its authenticity. Additionally, the group orchestrating the encounter
with ISIS should be sure to treat the ISIS member fairly. The resulting videotape
will be much more effective if the ISIS member is shown to be incompetent all
on his own rather than as a result of unfair treatment or a trick of filmography.
3) Undermine recruitment lures.
Counter-propaganda should target the incentives that have been most effec-
tive at recruiting individuals contemplating ISIS membership, taking into ac-
count different types of recruitment strategies. For example, there should be
counter-propaganda specifically aimed at young adult women. ISIS has been
successful in using its young female members to befriend and attract young
women recruits by having the group’s women portray their lives in ISIS as
romantic and pro-family. If possible, counter-propaganda should utilize young
women who are not openly anti-ISIS (so as not to appear biased), but who live
romantic and happy lives with their families. Counter-propaganda efforts should
also include factual reports of the dangerous reality of living in ISIS, so as to
dispute the ISIS reports of a glamorized utopian society.
4) Increase manpower.
To successfully counter the sheer prevalence of pro-terrorist propaganda,
counter-propaganda efforts need more staff to push anti-terrorist communica-
tions and information. ISIS has utilized “fanboys” and bots to push large
amounts of information and overwhelm Internet search engines and social
media platforms. Likewise, anti-ISIS measures also should employ bots and a
multitude of individuals who can push mass amounts of anti-ISIS information.
These counter-propaganda measures similarly need to be able to rise to the top
of search engine results and be prevalent on social media sites. Otherwise,
important counter-propaganda content will remain hidden behind the mountain
of pro-ISIS tweets and other communications.
Additionally, countries engaging in counter-propaganda work should reach
out to those already involved in similar endeavors – be they other countries or
individuals or organizations – in order to streamline and harness their efforts to
discredit ISIS. Currently, the counter-propaganda efforts of two or three individu-
als are too easily drowned out by the overwhelming tide of ISIS propaganda.
Consider, for instance, an Iraqi student group’s satirical video of ISIS. Despite
the group’s noble motivations, their efforts may be in vain if they achieve only a
122 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

minor online presence. Imagine instead, if a coalition of anti-ISIS governments

or individuals were to join forces in such numbers that they would create a
coalition comparable to the one behind the ISIS propaganda machine. If such a
coalition were to fight ISIS electronically, they would ensure that the voices of
their various members would be heard at a volume that would be nearly
impossible to achieve while acting alone.
5) Provide a compelling narrative.
Counter-propaganda needs to be exciting. The inescapable reality about ISIS
propaganda is that it is engrossing: ISIS films utilize Hollywood-style tricks and
impressive stunts; the group brands its propaganda with its flag and hymns; and
it boasts a captivating narrative. Unfortunately, as repellant as its beheading
videos are, they do garner a lot of attention. Anti-ISIS videos are struggling in
part because they lack attention-grabbing action and a compelling narrative.
Counter-propaganda officials should hire entertainment professionals to help
make their propaganda films more thrilling to watch.
Even more important, the narrative must grab the target audience. It should
not simply argue “do not join ISIS.” Instead, it should put forward some equally
compelling reason to “join us” – to drive individuals to want to be involved in
activities and social movements that are not ISIS-related. Take, for example,
teenagers who are drawn to ISIS by its promise of an accepting community.
Effective counter-propaganda for such young people might advertise the avail-
ability of social groups and other opportunities available close to home. For
recruits drawn to ISIS for religious reasons, counter-propaganda materials
might quote from religious leaders and other trusted figures who discredit the
group’s anti-Islamic violence and provide alternative interpretations.

CONCLUSION
The Internet has revolutionized terrorism forever. Terrorists exploit the Inter-
net’s vast resources and capabilities to further their causes in ways never before
possible. Recruitment, funding, publicity, and other essential organizational
needs are now conveniently met through the click of a button. The Internet-
savvy terrorist can simultaneously fill the roles of photographer, publicist,
fundraiser, and fighter. The previously unreachable potential new member can
now be fully recruited, from initial contact to travel arrangements, all without
ever having to leave his house.
One of the key ways that the Internet has transformed terrorism has been in
its effect on terrorist propaganda. The Internet allows terrorists to design and
deploy potentially limitless amounts of propaganda to millions of potential new
members with relatively few regulations or restrictions. Terrorists can utilize
anonymous user names and post to websites, social media platforms, chat
applications, and more, all while tailoring their message to attract a range of
different target audiences. ISIS has been remarkably adept at using various
media forms on many different Internet sites and social media platforms. So far,
efforts to thwart the ISIS propaganda machine have proven relatively fruitless.
2017] TERRORISM, THE INTERNET, AND PROPAGANDA 123

The evolution of terrorism propaganda via the Internet requires equally

advanced methods to effectively combat it. The reliance on antiquated Cold War
techniques that predate the rise of social media will not be sufficient to
adequately respond to the technologically equipped terrorist threat. In order to
effectively combat ISIS propaganda, anti-ISIS forces should draw upon the
psychological and sociological dynamics of propaganda, as well as the full
range of available resources. Successful programs and established research can
serve as the framework for future efforts, but they must be updated to fully
utilize the Internet’s capabilities and resources. Counter-propaganda measures
will continue to be ineffective against ISIS and other terrorist organizations
unless they fully address the enemy’s technological capabilities.
These measures should employ credible communicators and put forth factual
information in order for the target audience to trust it and absorb its message
rather than immediately dismiss it. Counter-propaganda also should focus on
undermining the most effective recruitment lures for new ISIS members. Creat-
ing such counter-propaganda will require the use of different types of communi-
cations and communicators so as to adequately address the range of motivators
and individuals targeted. Also, digital counter-propaganda s must rival terror-
ists’ online activity in prevalence and frequency so that it rises to the top of
search queries and helps to shape Internet use trends. These measures will
require an increase in manpower, as well as a concentrated effort at enhancing
counter-propaganda’s appeal to its target audiences. In particular, young Internet
users are more likely to be drawn to exciting, compelling stories than those that
are dull; this truth must be reflected in the content of counter-propaganda if it is
to effective.
It is also important that for the fight against terrorism to continue to rely on
other non-propaganda tactics, such as stopping teenagers at airports and prosecut-
ing individuals for providing material support to terrorism via digital means.
However, law enforcement and social media sites should be selective about
whom they target. Twitter and other social media sites should avoid suspending
so many user accounts that they inadvertently push ISIS supporters into using
communication platforms are difficult to monitor. Such social media sites
provide important intelligence information by allowing law enforcement and
intelligence officers to monitor the pro-ISIS users’ communications. Further-
more, the government should not prosecute individuals under the Material
Support Statute unless they are fairly certain of a conviction, because over-
prosecution may lead to distrust of the government. However, these options
should not be abandoned entirely, for their use may still help to temporarily
hinder terrorist activities. Occasional suspensions and prosecutions may remove
the most outspoken and persuasive ISIS sympathizers from the marketplace of
ideas, and may deter other users from disseminating ISIS propaganda online.
As technology evolves, so will its potential to be used for either good or evil.
The Internet is only the latest vehicle to be manipulated to serve terrorists’
agenda. Just as the handheld camera provided terrorists with a new way to
124 JOURNAL OF NATIONAL SECURITY LAW & POLICY [Vol. 9:95

speak to distant followers without ever having to meet, social media has
provided terrorists with an unprecedented ability to directly attract young
recruits and indoctrinate new followers through direct messaging, hashtags, and
more. Propaganda can now be deployed with relative ease and at little to no
expense, as anyone can open a Twitter account and share his or her views.
Future technology will inevitably bring with it new, innovative ways for terror-
ists to manipulate its qualities to serve their purposes. Counter-propaganda
efforts will likewise continue to need to evolve to match the ever-looming threat
of terrorism.