facts, and the monetary consequences that have a causal nexus with the facts of the case sub judice.”352 a) Arguments of the parties 310. The Commission asked the Court to order the State to make reparation “for the consequences of the violations at the individual and the community level” and that, when determining the pecuniary damage and other claims made by the representatives, it consider the worldview of the Sarayaku People, and the effect on the People and on its members of being prevented from using, enjoying and being able to avail themselves of their territory and, among other consequences, from carrying out their traditional subsistence activities.” 311. The representatives asked the Court to determine, in equity, compensation for pecuniary damage, to be paid directly to the Sarayaku People, for the damage caused to their territory and their natural resources;353 the effects of the suspension of production activities by the Sarayaku during the six months that the “state of emergency” lasted;354 the effects of the actions undertaken to defend their territory,355 and the economic impact of the restrictions to their freedom of movement on the Bobonaza River.356 312. The State argued that the damage caused to the Sarayaku People’s territory and its natural resources, as well as expenses incurred by its members to move around, had not been proved and that no reports or inspections had been submitted to support the request It claimed that the supposed lack of tourists was due “to the position taken by the leaders against the work of the 352 Cf. Case of Bámaca Velásquez v. Guatemala. Reparations and Costs. Judgment of February 22, 2002. Series C No. 91, para. 4, and Case of González Medina and family members v. Dominican Republic, para. 310. 353 This item includes: (a) “The opening of seismic trails and seven heliports in the territory destroying large tracts of forest”; (b) “The destruction of caves, water sources and underground rivers required for drinking water for the community”; (c) “The cutting down of trees and plants of significant cultural, environmental and subsistence food value for the Sarayaku”; (d) “Environmental pollution, waste and garbage left behind by workers in the territory,” and (e) “Abandonment of extremely dangerous explosives on the surface and subsoil of the Sarayaku territory, which still remain today.” 354 This item includes: (a) loss of earnings owing to the impossibility of planting and selling their agricultural products, which meant that they had to purchase products in the markets. According to the representatives, the losses incurred from not being able to plant the cassava crop that year alone amounted to US$64,000 (sixty-four thousand United States dollars). Also, in order to supplement their diet because of the food shortages caused by the scarcity of game and fish owing to the seismic survey activities, each of the 160 families in the community had to spend US$34 (thirty-four United States dollars) a month during the six months of the state of emergency and US$8.50 (eight United States dollars and fifty cents) during the eight months that followed; (b) interruption of the community’s other production activities, such as building canoes, houses and handcrafts; (c) serious impacts on the Sarayaku community tourism, reducing the direct income received by those responsible for the project from tourists from their expenditure on food, accommodation and jungle tours offered by community guides. They also claimed that each tourist paid US$15 (fifteen United States dollars) for admission to the territory. They alleged that, on average, about 200 tourists a year entered the Sarayaku territory, a source of income that was interrupted for two years; in other words, following the conflict they had failed to receive a total of US$6,000 (six thousand United States dollars) destined for a community fund, and (d) some of the Sarayaku development projects were lost, such as fish farming and the community economics program. In their final arguments brief, the representatives stated that “[a]ccording to the new census mentioned above, it is estimated that Sarayaku has 206 nuclear families and not 160 as indicated in the pleadings and motions brief,” and that “the Sarayaku have reviewed the calculations for the losses incurred on their farms (chacras), given the inclusion of some incorrect facts in the pleadings and motions brief.” They have therefore presented a new request that includes loss of earnings due to their inability to grow and sell their agricultural products, which resulted in the need to buy products in the market. The amount that the representatives are requesting that the Court establish in equity for this item is US$618,000 (206 families x two farms each x 150 quintals of cassava x US$10 per quintal). 355 According to the arguments presented, the defense of the territory entailed numerous expenses for the Sarayaku leaders, who had to travel to different places within and outside the country. They added that the community tourism business had gone bankrupt. 356 The representatives claimed that this restriction entailed additional transportation costs because the Sarayaku members could only travel by air for urgent matters, which increased the community’s expenses as each plane trip costs an average of US$250 (two hundred and fifty United States dollars). They added that the restrictions to freedom of movement had also hampered the following activities: (a) entry of tourists; (b) marketing of Sarayaku products in the cities; (c) entry of basic commodities from the city, which had to be brought in by plane, greatly increasing the costs; (d) entry of goods for Sarayaku stores, and (e) because it was presumably impossible for Sarayaku members to travel by river, they had to travel by plane to leave Sarayaku, which increased transportation costs. 84