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This article begins to build a typology of litigation efforts by Russian NGOs at the European Court of Human Rights (ECtHR). It finds that the varied political and professional backgrounds of activists, as well as their international partnerships, shape how they approach the ECtHR. Despite similar training in ECtHR litigation, NGOs vary in their philosophies and goals of litigation. The author explores these variations by examining the cases of three leading Russian human rights NGOs in submissions to the ECtHR, comparing their approaches and suggesting explanations for differences among them.