 Villa further states that "Other Losses" wrongly cites a March CCS directive to Eisenhower, claiming that it directs Eisenhower to not take any prisoners after Victory in Europe (V-E) Day, when in fact, the directive states that those taken after V-E day should not be designated as "Prisoners of War" under the Geneva Convention.In fact, JCS 1067 required Eisenhower to continue to take prisoners after V-E Day.Moreover, if Bacque truly believes that Eisenhower was supposed to stop taking prisoners, Villa states that Bacque does not explain how Eisenhower could have gotten away with taking 2 million prisoners after this date without CCS action.