Regional Jurisprudence: In Velásquez-Rodríguez v. Honduras, the IACtHR held that the State has the duty to take reasonable steps to prevent human rights violations and to conduct a serious investigation of those that occur within its jurisdiction. The Court also emphasized that “[a]n illegal act which violates human rights and which is initially not directly imputable to a state … can lead to international responsibility of the state, not because of the act itself, but because of the lack of due diligence to prevent the violation or to respond to it as required by the convention.”238 In SERAC and CESR v. Nigeria, the African Commission on Human and Peoples’ Rights held that States have a duty to protect right holders by the use of legislation and other measures against potential abuses committed by others. 239 There is a duty to create a framework in which right holders can realize their rights against abuses by third parties. In SERAP v. Federal Republic of Nigeria, the Court of Justice of the Economic Community of West African States found that Nigeria had a duty to protect the human rights of its most vulnerable rights holders that were affected by oil companies’ abuses. 240 In Kalender v. Turkey, the ECtHR found that Turkey had not put in place the appropriate safety measures and also had failed to investigate a corporation for potential liability in causing the death of an individual in connection to the lack of safety standards.241 D. States in which a business is domiciled, as well as States in which the victims reside have obligations to prevent a business from abusing or impairing human rights There is wide-ranging recognition by international human rights treaty monitoring bodies and by courts that a State’s human rights obligations may extend beyond its borders. These are set out in the Maastricht Principles on Extraterritorial Obligations of States in the Area of Economic, Social and Cultural Rights, which provide: a) Principle 3: “[a]ll States have obligations to respect, protect and fulfil human rights, including civil, cultural, economic, political and social rights, both within their territories and extraterritorially.” b) Principle 4: “[e]ach State has the obligation to realize economic, social and cultural rights, for all persons within its territory, to the maximum of its ability …” c) Principle 25(a)(d): “States must adopt and enforce measures to protect economic, social and cultural rights through legal and other means, including diplomatic means, in each of the following circumstances: a) the harm or threat of harm originates or occurs on its territory… d) there is a reasonable link between the State concerned and the conduct it seeks to regulate.” 238 Maastricht Principles Drafting Group brief, at pgs. 5-6 (citing Velásquez Rodríguez v. Honduras, Judgment, Inter-Am. Ct. H.R, (Ser. C) No.4, ¶ 174 (July 29, 1988)). 239 Maastricht Principles Drafting Group brief, at pgs. 5-6 (citing The Social and Economic Rights Action Center and the Center for Economic and Social Rights v. Nigeria, African Commission on Human and Peoples’ Rights, App No.155/96, ¶ 46 (Oct. 27, 2001)). 240 Maastricht Principles Drafting Group brief, at pgs. 5-6 (citing SERAP v. Federal Republic of Nigeria, The Court of Justice of the Economic Community of West African States (ECOWAS), Judgment, N° ECW/CCJ/JUD/18/12 (Dec. 14, 2012)). 241 Maastricht Principles Drafting Group brief, at pgs. 5-6 (citing Kalender v. Turkey, App. No.4314/02, Eur. Ct. H. R. (Dec. 15, 2009)). 50