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the enemy force may recover to counterattack, consolidate a new defensive position, or assist thewar effort in other ways. 99 Retreat may also be a ruse. 100 Retreating enemy combatants mayhave the same amount of force brought to bear upon them as an attacking military force, and amilitary commander is under no obligation to limit force directed against enemy combatantsbecause they are, or appear to be, in retreat.5.5.6.3 Harassing Fires. Harassing fires against enemy combatants are notprohibited. (Such action is clearly distinguishable from attacks to terrorize or otherwise harm thecivilian population, which are, of course, prohibited.) Harassing fires are delivered on enemylocations for the purpose of disturbing enemy forces’ rest, curtailing their movement, or loweringtheir morale. 101 5.5.6.4 Attacks on Specific Individuals. Military operations may be directedagainst specific enemy combatants. 102 U.S. forces have often conducted such operations. 103consolidated, an attacking force is trained to fire upon the retreating enemy to discourage or prevent acounterattack.”).99 See FINAL REPORT ON THE PERSIAN GULF WAR 622 (“It is recognized by military professionals that a retreatingforce remains dangerous. The First Marine Division and its 4,000 attached U.S. Army forces and British RoyalMarines, in the famous 1950 march out of the Chosin Reservoir in North Korea, fighting outnumbered by a 4:1margin, turned its ‘retreat’ into a battle in which it defeated the 20 th and 26 th Chinese Armies trying to annihilate it,… .”).100 Refer to § 5.25.2 (Examples of Ruses).101 APPENDIX TO 1985 CJCS MEMO ON AP I 47 (“Harassing fires are delivered on enemy locations for the purpose ofdisturbing the rest, curtailing the movement, or lowering the morale of troops.”).102 See, e.g., Harold Hongju Koh, Legal Adviser, Department of State, Address at the Annual Meeting of theAmerican Society of International Law: The Obama Administration and International Law, Mar. 25, 2010, 2010DIGEST OF UNITED STATES PRACTICE IN INTERNATIONAL LAW 718 (“First, some have suggested that the very act oftargeting a particular leader of an enemy force in an armed conflict must violate the laws of war. But individualswho are part of such an armed group are belligerents and, therefore, lawful targets under international law. …Indeed, targeting particular individuals serves to narrow the focus when force is employed and to avoid broaderharm to civilians and civilian objects.”); 1956 FM 27-10 (Change No. 1 1976) 31 (“[The prohibition on killing orwounding treacherously reflected the Hague IV Regulations] does not, however, preclude attacks on individualsoldiers or officers of the enemy whether in the zone of hostilities, occupied territory, or elsewhere.”).103 For example, Barack Obama, Remarks by the President on Osama Bin Laden (May 2, 2011) (“Today, at mydirection, the United States launched a targeted operation against that compound [suspected of housing Osama BinLaden] in Abbottabad, Pakistan. A small team of Americans carried out the operation with extraordinary courageand capability. No Americans were harmed. They took care to avoid civilian casualties. After a firefight, theykilled Osama bin Laden and took custody of his body.”); George W. Bush, Remarks on the Death of Senior AlQaeda Associate Abu Musab Al Zarqawi, Jun. 8, 2006, 2006-I PUBLIC PAPERS OF THE PRESIDENTS 1099 (describinghow after “work[ing] tirelessly with their Iraqi counterparts to track down this brutal terrorist,” U.S. “specialoperation forces, acting on tips and intelligence from Iraqis, confirmed Zarqawi’s location” and killed him); JOHNMILLER, CARTWHEEL: THE REDUCTION OF RABAUL 44 (Office of the Chief of Military History, Department of theArmy 1959) (“American intelligence officers had discovered the exact time on 18 April [Admiral] Yamamoto[,Commander-in-Chief of the Japanese Combined Fleet,] was due to reach the Buin area … . [D]isposing ofYamamoto would advance the Allied cause, so the Commander, Aircraft, Solomons, was told to shoot him down[and did so successfully].”); Henry Pinckney McCain, Adjutant General of the U.S. Army, Telegram to GeneralFrederick Funston (Mar. 10, 1916), reprinted in PAPERS RELATING TO THE FOREIGN RELATIONS OF THE UNITEDSTATES WITH THE ADDRESS OF THE PRESIDENT TO CONGRESS DECEMBER 5, 1916 (Department of State 1925)201