Operation Genesis would cover these issues, because the protective nature of provisional measures was meaningless once the Court has delivered a judgment, and f) Based on the foregoing, the State asked that the Court reject the request for provisional measures that had been presented and reiterated that it was maintaining rigorously all the mandates, orders, actions and measures that had been implemented in the context of the preventive measures before the Commission. 13. The note of the Secretariat of April 8, 2013, in which, on the instructions of the President of the Court, the representatives and the Inter-American Commission were given until April 22, 2012, to present their observations on the said report of the State. 14. The brief of April 22, 2013, in which the representatives presented their observations on the State’s report. They indicated the following: a) The State’s argument which considers the provisional measures “unjustified” because an order on preventive measures has been in existence since 1997 is unsubstantiated, because the preventive measures granted by the Commission were awarded owing to the forced displacements produced by Operation Genesis between February 24 and 27; b) The existence of preventive measures has a different factual framework from that of the provisional measures that are being requested, because the latter respond to new facts and risk factors related to the processing of the contentious case. In addition, the judgment on merits that the Inter-American Court may eventually deliver does not refer to the facts that are the grounds for the request for provisional measures, which are designed to avoid irreparable damage; c) The threats and harassment that have been recorded by both the representatives and the Commission have increased as a result of the litigation of the contentious case of Operation Genesis before the Court. In the opinion of the representatives, these criminal acts are related to their status as plaintiffs and their purpose is to detain the actions to reclaim the rights of the proposed beneficiaries; d) The State had made no mention of the risk factors that are faced by the beneficiaries of the preventive measures, and had not indicated the specific measures that it was taking to respond to the paramilitary checkpoints located in Tumaradó, which have resulted in a serious threat to the life and integrity of the proposed beneficiaries, because these checkpoints have blocked the entry of food and limited the mobility of the inhabitants; e) The measures that have been approved, according to the State, have not been implemented effectively. In particular, the provision of collective boats has not materialized owing to the impossibility of travelling to Turbo for safety reasons, and f) The material measures granted, although they represent a protection mechanism, are limited in nature, because they are not complemented by other appropriate measures that would prevent the irreparable damage of which the proposed beneficiaries could be victims. 15. The brief of April 23, 2013, in which the Commission presented its observations on the State’s report. It alleged that the State’s arguments on the presence of members of the security forces is general in nature, and failed to include a concise explanation of the relationship between the territorial control operations in the area and the harassment and threats by paramilitary groups. In the Commission’s opinion, the lack of information about the presence of the paramilitaries in the area, and the Government’s efforts to combat the 57th Front of the FARC, was an indication of the ineffectiveness of the measures mentioned by the State. The Commission indicated that the preventive measures adopted since 1997 are of a general nature; thus, they have different implications than those of provisional measures, which are designed to deal with “a more specific and concrete situation of risk, directly related to leadership and special visibility, suffered by some people as members of CAVIDA or participants in the contentious case.” 16. The brief of May 9, 2013, in which the representatives presented additional information on the request for provisional measures. The representatives referred to supposed incidents that 10