59 considered that “Brazil’s efforts, either directly or through the state government, have been insufficient to ensure respect for the American Convention.” The obligation to adopt measures derived from Article 2 of the Convention is “strengthened and defined by Article 28 thereof,” provisions that, interpreted in accordance with Article 1(1) eliminate “the possibility of the State invoking the complexity of its structure in order to elude the obligations […] assumed.” The safeguard of the rights established in the Convention “eliminates any reference to the internal distribution of the jurisdictions or organization of the entities that compose a federation.” The federal states, as parts of the Federal State, “are also bound by the provisions of the international treaties” ratified by the latter. The Commission concluded that Article 28 of the Convention cannot be interpreted so that the obligation contained in the Federal Clause converts the protection of human rights into a decision that is purely discretional, subject to the will of each State Party. Based on the foregoing, it asked the Court to declare that the State had failed to comply with Article 28 of the American Convention. 216. The representatives submitted similar arguments and stated that, during the proceedings before the Commission, at a working meeting held on October 11, 2007, the State had advised that “it had been unable to establish contact with the Paraná authorities and, therefore, it could not [provide] information on compliance with the Commission’s recommendations.” They added that, in its brief submitted to the Commission of September 21, 2007, the State had indicated, among other matters, that it “acknowledges that it faces difficulties in dealing with the issue [of precise reparations ordered by the Commission], and had asked the state of Paraná to appoint a specific spokesman in order to make progress in the discussions on compliance with that recommendation. In addition, it was examining other ways of raising the awareness of the government of Paraná in order to discuss possible forms of reparation.” In addition, the representatives indicated that the State had affirmed that “it is important to stress the efforts made by the Federal Government to include the federated states in compliance with all the recommendations, […] in order to foster their responsibility and commitment to the inter-American system. The effort to convince the states is a permanent one, and occasionally it requires more time to bear fruit, as in this case.” Lastly, they claimed that this position of the State was maintained up until just before the public hearing before the Court and they mentioned an episode that occurred during the process to obtain a passport for the victim who testified as a witness before the Court. According to the representatives, this revealed the Federal State’s lack of interest in taking positive steps to resolve the problem and the absence of coordination between the State and the federal entities. They concluded that, based on its federal structure, the State “is repeatedly trying to excuse itself from its international responsibility for human rights violations.” 217. The State affirmed that Article 28 of the American Convention is merely a rule for interpretation and application of the Convention. Consequently, the Court was unable to examine an alleged violation of that Article. It had alluded to internal communication difficulties merely to explain why all the recommendations in the Commission’s Report on Merits had not been complied with immediately. The affirmations were “a demonstration of its good faith and transparency, erroneously considered a violation by the Commission and the representatives of the presumed victims.” Nevertheless, the affirmations did not prevent the State from complying partially with the Commission’s recommendations, with the collaboration of the authorities of the state of Paraná. Therefore, the State “rejects the use of declarations made during a working meeting as an argument to prove noncompliance with the Federal Clause.” It recalled that the said working meeting had not been scheduled and was held at the special request of the Commission. Brazil had been “unable to prepare itself and agreed to attend based simply on the State’s good faith; [moreover] it had not expected that this attitude of collaboration would be used maliciously by the petitioners.” The State was aware of its commitments to the inter-American system and had never tried to excuse itself from complying with the Commission’s recommendations.