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During the 1990s, environmental activists became interested in trade issues for the first time. Whereas GATT, the General Agreement on Tariffs and Trade, had previously been the province of trade specialists, a new poster popular among environmentalists depicted the monster 'GATTzilla', devouring the earth, dolphins, and democratic institutions. This case describes the conflict between environmental and trade values as it is manifested in various multilateral institutions and treaties: GATT, especially after its controversial ruling on a United States dolphin protection law; NAFTA, the North America Free Trade Agreement, for which environmental matters have become an unexpected stumbling block; the European Community, as it tries to harmonize member regulations; and multilateral treaties such as CITES (the convention on trade in endangered species), the Montreal Protocol on ozone-depleting substances, and attempts to protect tropical timber.