01005768 Case File No. 002/19-09-2007/ECCC/TC E313 dismisses the argument to the contrary advanced by the Accused.530 178. Attack - An attack is a course of conduct involving the commission of a series of acts of violence.531 It is not limited to the use of armed force, encompassing any mistreatment of the civilian population including that reflected by the underlying offences in Article 5 of the ECCC law.532 An attack on a civilian population is a separate concept from that of an armed conflict.533 An attack may precede, outlast or continue through an armed conflict, without necessarily being part of it.534 179. Widespread or systematic - The term “widespread” refers to the large-scale nature of the attack and the number of victims, while the term “systematic” refers to the organised nature of the acts of violence and the improbability of their random occurrence.535 A systematic attack is commonly expressed as a pattern of crimes involving the non-accidental repetition of similar criminal conduct on a regular basis.536 A widespread attack may refer either to the “cumulative effect of a series of inhumane acts or the singular effect of an inhumane act of extraordinary magnitude.”537 Proof that the attack was either “widespread” or “systematic” is sufficient to establish liability.538 Only the attack, not the individual acts for which the accused is responsible, must be widespread or systematic.539 A single act or a limited number of acts can qualify as a crime against humanity provided that they are not isolated or random and all other conditions are met.540 180. The KHIEU Samphan Defence submits that the actus reus of crimes against humanity also requires the existence of a State or organisational plan or policy. 541 The NUON Chea Defence similarly submits that the existence of a state policy or plan was 530 [KHIEU Samphan] Submissions Regarding the Applicable Law, E163/5/9, 18 January 2013, para. 8; NUON Chea’s Closing Submissions in Case 002/01, E295/6/3, 26 September 2013, para. 214 (adopting IENG Sary’s submissions). 531 KAING Guek Eav Trial Judgement, para. 298; Nahimana et al. Appeal Judgement, para. 918. 532 KAING Guek Eav Trial Judgement, para. 298; Kunarac et al. Appeal Judgement, para. 86. 533 KAING Guek Eav Trial Judgement, para. 299; Tadić Appeal Judgement, para. 251. 534 KAING Guek Eav Trial Judgement, para. 299; Kunarac et al. Appeal Judgement, para. 86. 535 KAING Guek Eav Trial Judgement, para. 300; Kunarac et al. Appeal Judgement, para. 94. 536 Blaškić Appeal Judgement, para. 101. 537 KAING Guek Eav Trial Judgement, para. 300; Blaškić Trial Judgement, para. 206. 538 KAING Guek Eav Trial Judgement, para. 300; Kunarac et al. Appeal Judgement, para. 93. 539 KAING Guek Eav Trial Judgement, para. 301; Kordić and Čerkez Appeal Judgement, para. 94. 540 Kordić and Čerkez Appeal Judgement, para. 94. 541 Submissions Regarding the Applicable Law, 18 January 2013, E163/5/9, paras 10, 12, 68. Case 002/01, Judgement, 7 August 2014 - Public 101