The term is used to describe not only the massacre in Simele, but also the killing spree that took place in 63 Assyrian villages in the Dohuk and Mosul districts which led to the deaths of between 5,000[209] and 6,000[210][211] Assyrians. The Simele massacre inspired Raphael Lemkin to create the concept of genocide.[212] In 1933, Lemkin delivered a presentation to the Legal Council of the League of Nations conference on international criminal law in Madrid, for which he prepared an essay on the Crime of Barbarity as a crime against international law. The concept of the "crime of barbarity" evolved into the idea of genocide, and it was based on the Simele massacre and the Armenian Genocide, and it later included the Jewish Holocaust.[213]