A U.S. court ruled that key provisions of the USA PATRIOT Act targeting material support of terrorist organizations remain unconstitutionally vague despite recent revisions by Congress. The "material support" statutes, particularly troubling to nonprofit organizations, prohibited U.S. citizens or organizations from providing material support or resources to designated "foreign terrorist organizations," regardless of the nature or intent of the support. In the 42-page decision, U.S. District Court Judge Audrey Collins concluded that "the terms 'training' and 'expert advice or assistance' in the form of 'specialized knowledge' and 'service' are impermissibly vague under the Fifth Amendment." In 2004, Judge Collins became the first judge to declare any part of the USA PATRIOT Act unconstitutional, ruling that the definitions of material support were insufficiently defined and could be construed to encompass First Amendment-protected activities. Yet the procedural history of the issue dates back to the 1996 Antiterrorism and Effective Death Penalty Act (AEDPA), which provided the foundation for the USA PATRIOT Act's material support statutes. In its December revision of the AEDPA/USA PATRIOT Act, Congress attempted to address Collins' objections by passing the Intelligence Reform and Terrorism Prevention Act (IRTPA). Judge Collins found that Congress' revisions still fall short of solving the problem of vagueness: "Even as amended, the statute fails to identify the prohibited conduct in a manner that persons of ordinary intelligence can reasonably understand." Plaintiffs in the case included five organizations and two U.S. citizens seeking to provide support to the lawful, nonviolent activities of the Partiya Karkeran Kurdistan (PKK) and the Liberation Tigers of Tamil Eelam (LTTE), both of which were designated "foreign terrorist organizations" in 1997. Each group undertakes political organizing and advocacy efforts and provisioning of social services and humanitarian aid, apart from their military engagement with government forces. The PKK is a political organization representing Kurdish people in Turkey. While military activities are part of their campaign for Kurdish self-determination, they also provide vital social services and aid to Kurdish refugees and victims of human rights abuses. The plaintiffs sought to provide the PKK with "support," such as training in the use of humanitarian and international law for the peaceful resolution of disputes and instruction on petitioning for relief before representative bodies such as the United Nations. The second organization, the LTTE, represents the interests of Tamils in Sri Lanka, who also face discriminatory treatment and human rights abuses, according to human rights organizations. In the wake of the tsunamis of December 2004, the plaintiffs sought to provide emergency relief and "expert training" to the LTTE, in such areas as effectively presenting claims for tsunami-related aid and negotiating peace agreements with the Sri Lankan government to facilitate the distribution of aid. While the injunction against enforcement of the specified sections applies only to the two organizations named in the suit, it viewed by many advocates as a vital first step toward greater protection of the rights of individual philanthropists and U.S.-based organizations involved in international outreach efforts. "I'm pleased that the court has recognized that people have a right to support lawful, non-violent activities of groups the secretary of state has put on a blacklist," said David Cole, the Georgetown University Law professor who argued the case on behalf of the Humanitarian Law Project. However, the ruling was a mixed victory. In addition to its limited application to the two named organizations, the ruling concluded that the term "personnel" was sufficiently clarified in the IRTPA revision. The ruling also concluded that there were no due process violations in current procedure for terrorist financing prosecution, and that the government need not prove intent to perpetuate violence or illegal activities on the part of those suspected of supporting designated terrorist groups.