Jackie Jones, Jeanne Sarson, and Linda MacDonald 39 Special Rapporteur Manfred Nowak (2008) stated that intent is implied with acts of gender-spe­ cific torture, and that the purpose element is always fulfilled when acts of gender-based discrim­ ination are involved. He also confirmed that it is a State’s duty to prevent torture in the private sphere. When some manifestations of women’s victimization at the hands of non-State actors are compared to torture inflicted by State actors, the two are remarkably similar. With regard to State involvement, Special Rapporteur Juan Mendez (2016) refers to international criminal law develop­ ments which have determined that torture can occur when the State had no role in its perpetration and where the State did not fail to exercise due diligence obligations, with the “characteristic trait of the offence [being] found in the nature of the act committed rather than in the status of the person who committed it” (para. 52) (Prosecutor v. Kunarac et al. and Prosecutor v. Semanza footnote cited in Mendez, 2016). The following chart illustrates the points made by Nowak, Mendez, and others (Marshall, 2005). Acts of State and non-State torturers are similar, and it is not the status of the person that deter­ mines whether they are a torturer, but rather, it is the acts they commit. The chart below describes and compares three groups of women and the torture inflicted against them: 1. 100 Mexican women arrested, jailed, and tortured by security forces, police, army and navy members (Amnesty International, 2016); 2. 100 Asian and African women who immigrated to the United Kingdom (UK) tortured mainly by State actors, but also by non-State actors (Smith, & Boyles, 2009), and 3. Women known by the Canadian authors, beginning in 1993, who detail being born into non-State torturing families who trafficked and exploited them to like-minded others. These women are from Canada, the United States, the UK, Western Europe, Australia, and New Zealand. Mexican women Psychological abuse, humil­ iation, harassment, insults, misogynistic put-downs, called derogatory names, threats, stripped naked African and Asian women UK immigrants Women known by Canadian authors Humiliation, forced nakedness Psychological torture, humil­ iation, harassment, insults, misogynistic put-downs, called derogatory names, threats, stripped naked, stalked