According to the Special Rapporteur, the State's due diligence obligation under international human rights law consists of preventing, investigating, punishing acts of violence against women, protecting women from violence, and providing an effective remedy and reparation to victims of violence. For human rights law, the standard serves as a tool for rights holders to hold duty bearers accountable by providing an assessment framework for ascertaining what constitutes effective fulfilment of the obligation, and for analysing the actions or omissions of the duty bearer. This is especially important if the potential infringement comes through a duty bearer's failure to act, as it can be difficult for rights holders to assess if an omission constituted a violation of their right without some normative basis for the appraisal. Cotton Field") v. Mexico (Judgement of 16 November 2009), concerning the abduction, sexual violence and killing of two children and a woman by non-State actors, was one of hundreds of similar cases of disappearance, rape and murder of predominantly migrant women and girls that had occurred in Ciudad Juarez, Mexico.