"Speakers charged with international speech crimes have generally articulated the most extreme animus and conscious intent to harm, and gone beyond mere insult, libel and slander to incite others to commit mass atrocities. Moreover, their utterances usually occur in a context of an armed conflict, genocide and a widespread or systematic attack on a civilian population."
January 1, 1970
https://en.wikiquote.org/wiki/Incitement_to_genocide