 Jess Melvin argues that atheists were victims of genocide under the legal definition of the term during the 1965–66 Anti-PKI extermination campaign (PKI were the Communist Party of Indonesia) as the Indonesian army proscribed the destruction of "atheist" and "unbelievers" collectively for their association with communism, and according to Matthew Lippmann and David Nersessian atheists are covered as a protected group in the genocide convention under "religious group.