Must genocide be earned out by governments, or do private acts also count? The sociologist Irving Horowitz distinguished private acts 'assassination', and defined genocide as 'a structural and systeman, destruction of innocent people by a state bureaucratic apparatu-However, there is a complete continuum from purely government killings (Stalin's purges of his opponents) to purely private Uhngs (Brazilian land development companies hiring professional Indian killers). American Indians were killed by private citizens; and th eJJS army alike, while the Ibos in Northern Nigeria were killed both bys«* mobs and by soldiers. In 1835 the Te Ati Awa tribe of ^w Zealand Maoris succeeded in a bold plan to capture a ship, load it with supplies invade the Chatham Islands, kill 300 of the occupants (another Polynesian, 1900–1950 group called the Morioris), enslave the remainder, and thereby take over the islands. By Horowitz's definition, this and many other equally well-planned exterminations of one tribal group by another do not constitute genocide, because the tribes lacked a state bureaucratic apparatus. If people die en masse as a result of callous actions not specifically designed to kill them, does that count as genocide? Well-planned genocide includes that of Tasmanians by Australians, that of Armenians by Turks during the First World War, and (most notably) those committed by the Nazis during the Second World War. At the other extreme, when the Choctaw, Cherokee, and Creek Indians of southeastern US states were forced to resettle west of the Mississippi River in the 1830s, it was not President Andrew Jackson's specific intent that many Indians should die en route, but he also did not take the measures that would have been necessary to keep them alive. Their numerous more deaths were instead merely an inevitable result of forced marches in winter with little or no food or clothing.