instance, the United Nations Security Council adopted Resolution
1816 in June 2008 permitting states to use "all necessary means to
repress acts of piracy and armed robbery" in Somali waters.
Resolution 1838 in October 2008 called for nations to intensify
their efforts to combat piracy in Somalia, and Resolution 1851 in
December 2008 expanded Security Council approval of anti-piracy
efforts to include operations on land.