 A second memorandum, the "Combined Techniques Memo" found that the techniques did not constitute torture, even when used in combination.Bradbury's memoranda found the CIA's practices to be lawful if applied in accordance with specified conditions.Later in May, Bradbury signed a third memo, the "Article 16 Memo", which contained the opinion that the CIA's use of these techniques did not violate the Article 16 of the United Nations Convention against Torture, which forbids "other acts of cruel, inhuman or degrading treatment or punishment which do not amount to torture".