17 67. Historically, the Court has held that it is necessary to take three elements into account to determine whether or not a period of time is reasonable: a) the complexity of the matter, b) the procedural 86 activity of the interested party, and c) the conduct of judicial authorities. In recent years the Court has deemed it appropriate to specify, additionally, that in said examination of reasonableness, the effect caused by the duration of the proceedings on the juridical situation of the person involved therein must be taken into account, bearing in mind, among other elements, the matter in dispute. If the passage of time has a significant bearing on the juridical situation of the individual, the proceedings should be carried out 87 more diligently so that the case is decided as soon as possible. 68. In the instant case, the petitioners repeatedly denounced that the civil case stemming from their criminal conviction continues on the docket of the trial court even though it was initiated in December 1997. According to assertions of the petitioners, this delay has had severe consequences on their juridical situation, taking into account particularly that since March of 1996, the Argentinean courts have issued on several occasions a “general injunction [against sale and encumbrance] of assets” of Carlos and Pablo Memoli, in order to ensure their capacity to pay an eventual damages award in the context of the civil case. According to the petitioners, this general injunction of assets has allegedly caused their “civil death,” in light of the fact that it leaves them unable “to sell [their] property or […] freely acquire or dispose of it,” nor “be entitled to hold a radio frequency […] because one must have assets to 88 be able to gain access to one according to the radio broadcasting law.” 69. Pursuant to the scope of the admissibility report in this case, the Commission must limit itself to deciding whether in this process the right to a fair trial that is enshrined in Article 8.1 of the Convention has been respected, particularly whether the process has been resolved within a reasonable period of time based on the criteria set forth above. According to that report, the Commission must also determine whether particular characteristics of the civil proceedings, such as the period of time it has been pending, and the attachment on assets in effect for 15 years, have had a disproportionate effect on the right to freedom of expression of the petitioners. 70. The Commission notes that the civil proceeding against Carlos and Pablo Memoli was filed on December 29, 1997, and as of the present date, has not been resolved in the first instance. It further notes that the matter in question is not particularly complex, inasmuch as there are no significant disputes on the facts between the parties, and the evidence is for the most part readily accessible. With regard to the procedural activity of the parties and the conduct of the judicial authorities, the Commission has not been able to engage in an exhaustive examination on these topics due to the fact that it has not had access to the complete case file. Some conclusions can be drawn, however. The Commission notes that by March 2001, both parties to the case had submitted a number of briefs setting forth their claims on the facts and the law. Subsequently, references are made in the proceedings to pleadings of the petitioners, which allegedly caused delay in the case; in 2008, for example, the Supreme Court of Justice of the Province of Buenos Aires established as fact that “the continual [filing of] motions and appeals by continuation Preliminary Objections, Merits, Reparations and Costs. Judgment August 12, 2008. Series C No. 186, par. 148, and IA Court of HR, Case of Salvador Chiriboga Vs. Ecuador. Preliminary Objections and Merits. Judgment May 6, 2008. Series C No. 179, par. 59. 86 Cfr. IA Court of HR, Case of Genie Lacayo Vs. Nicaragua. Merits, Reparation and Costs. Judgment January 29, 1997. Series C No. 30, par. 77, available at: http://www.corteidh.or.cr/docs/casos/articulos/seriec_30_esp.pdf; IA Court of HR. Case of Bayarri Vs. Argentina. Preliminary Objections, Merits, Reparation and Costs. Judgment October 30, 2008. Series C No. 187, par. 107, available at: http://www.corteidh.or.cr/docs/casos/articulos/seriec_187_esp.pdf, and IA Ct. of HR, Case of Heliodoro Portugal Vs. Panama. Preliminary Objections, Merits, Reparations and Costs. Judgment August 12, 2008. Series C No. 186, par. 149. 87 IA Court of HR. Case of Valle Jaramillo et al Vs. Colombia. Merits, Reparation and Costs. Judgment November 27, 2008. Series C No. 192, par. 155, available at: http://www.corteidh.or.cr/docs/casos/articulos/seriec_192_esp.pdf. Also see IA Court of HR. Case of Anzualdo Castro Vs. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment September 22, 2009. Series C No. 202, par. 156, available at: http://www.corteidh.or.cr/docs/casos/articulos/seriec_202_esp.pdf; IA Court of HR. Case of Kawas Fernandez Vs. Honduras. Merits, Reparation and Costs. Judgment April 3, 2009 Series C No. 196, par. 112, available at: http://www.corteidh.or.cr/docs/casos/articulos/seriec_196_esp.pdf. 88 Communication of the petitioners January 15, 2009 (received January 23, 2009).