exempt from fulfilling the obligation of exhausting these remedies, and therefore the exception to exhaustion under domestic law set forth in Article 46.2 a) of the American Convention is applicable. C. Time-limits for submitting petitions 46. Article 46.1 b) of the Convention establishes that, for the petition to be declared admissible, it is necessary that it be lodged within a period of six months from the date on which the party alleging violation of his rights was notified of the final judgment that exhausted remedies under domestic law. In addition, Article 32.2 of the Rules of Procedures of IACHR establishes that “[i]n those cases in which the exceptions to the requirement of prior exhaustion of domestic remedies are applicable, the petition shall be presented within a reasonable period of time, as determined by the Commission.” Taking into account that, regarding the five petitions that been joined, the exception provided for in Article 46.2 a) of the Convention has been applied, the IACHR must examine whether or not these petitions were submitted within a reasonable period of time. 47. Petition 320-03 was submitted two months before the final judgment made by the Constitutional Court; petition 948-04 was filed at least six months after the final judgment of the Constitutional Court; and petitions 739-08 y 1065-08 were filed one to four months, respectively, after the petitioners, according to them, were notified of the final judgment of the Constitutional Court. Therefore, the Commission deems that the petitions were submitted on time, thus meeting the requirement established in Article 46.1 b). Regarding petition 822-08, it was submitted to the IACHR on July 14, 2008, six years eleven months after the CDM issued its resolution of nonrenewal. Taking into account this lapse of time, the Commission deems that this petition was not submitted within a reasonable period of time and therefore establishes that it does not meet this requirement of the Convention. D. Duplication of proceedings and international res judicata 48. Article 46.1 c) of the Convention provides that admissibility of the petitions is subject to the requirement that the subject of the petition “is not pending in another international proceeding for settlement,” and Article 47 d) of the Convention stipulates that the Commission shall not admit any petition that is substantially the same as a petition or communication previously studied by the Commission or by another international organization. In the petitions considered in the present report, the parties have not shown the existence of any of these two circumstances, nor can it be inferred from the case file. E. Characterization of the facts alleged 49. For admissibility purposes, all the Commission need establish is whether the petitions allege facts that tend to establish violations of the American Convention, as stipulated in Article 47 b) of the American Convention, whether the petition is “manifestly groundless” or is “obviously out of order,” in line with subparagraph (c) of the same article. The standard for evaluating these points of law is different from the standard for deciding the merits of a petition. The Commission must conduct a prima facie evaluation to determine whether the petition establishes grounds for the apparent or potential violation of a right guaranteed by the American Convention, but not to establish the existence of a violation. In the present stage, a summary review must be conducted, one that does not imply a prejudgment or prior opinion on the merits. 50. Likewise, neither the American Convention nor the Rules of Procedure of the IACHR require the petitioner to identify the specific rights that the State is allegedly violating in the case referred to the Commission, although the petitioners are entitled to do so. It pertains to the Commission, on the basis of System’s jurisprudence, to decide in its admissibility reports, what provision of the relevant inter-American instruments is applicable and could establish its violation if the allegations are proven on the basis of sufficient evidence. 51. The Commission considers that the allegations filed by the petitioner in connection with the nonrenewal to which they were subject and the absence of a judicial or administrative remedy to challenge it, could tend to establish a violation, to the detriment of the alleged victims of petitions 320-03,739-08 and 1065-