5 to the State, as follows: i. Initiate proceedings to allocate a free-to-air nationwide television frequency in which RCTV is able to participate, at a minimum, under conditions of equality. The process should be open, independent and transparent, apply clear, objective and reasonable criteria, and avoid any political consideration that discriminates on the basis of a media outlet’s editorial stance, in keeping with the standards set forth in [the] report; ii. Make reparation to the victims for the damage they sustained as a direct result of the due process violations, and iii. Adopt the measures necessary to guarantee that the process whereby radio and television frequencies are granted and renewed is compatible with the Venezuelan State’s international obligations vis-àvis freedom of expression, as established in th[e] report. d) Notification to the State. The Merits Report was notified to the State on November 28, 2012, granting it two months to report on compliance with the recommendations. On January 18, 2013, the State presented a brief in which it indicated that “its Constitution prevented it from complying with the three recommendations” made by the Commission. e) Submission to the Court. On February 28, 2013, the Commission submitted this case to the Court “in light of the need to obtain justice for the [presumed] victims given the failure to comply with the recommendations.” The Commission designated Commissioner Felipe González, the Special Rapporteur for Freedom of Expression, Catalina Botero, and Executive Secretary Emilio Álvarez Icaza as its delegates, and Elizabeth Abi-Mershed, Deputy Executive Secretary, and Silvia Serrano Guzmán, Executive Secretariat lawyer as legal advisers. II. PROCEEDINGS BEFORE THE COURT 3. Notification to the State and the representatives. The submission of the case was notified to the State and to the representatives of the presumed victims (hereinafter also “the representatives”) on June 10, 2013. 4. Brief with motions, pleadings and evidence. On August 12, 2013, the representatives presented their brief with motions, pleadings and evidence (hereinafter “the motions and pleadings brief”), pursuant to Articles 25 and 40 of the Court’s Rules of Procedure. In this brief, they agreed with the Commission’s allegations and added arguments on the presumed violation of Article 21 of the American Convention. 5. Answering brief. On December 10, 2013, the State presented its brief with preliminary objections, answering the submission of the case by the Commission and with observations on the motions and pleadings brief (hereinafter “the answering brief”). In this brief, the State filed three preliminary objections, one of which referred to the presumed “lack of impartiality” of certain judges of the Court and its Secretary. The State appointed Germán Saltrón Negretti, State Agent for Human Rights before the Inter-American and International Systems, as its Agent in this case, and the lawyers, María Alejandra Díaz Marín and Luis Britto García, as deputy agents. 6. On February 6, 2014, the Court issued an order3 in which, inter alia, it decided, with regard to the so-called “preliminary objection” filed by the State concerning the recusal of two of the judges and of the Court’s Secretary, that “the allegations of lack of impartiality in the functions performed by some of the judges of the Court presented as a preliminary objection, did not meet Cf. Case of Granier et al. (Radio Caracas Televisión) v. Venezuela. Order of the Inter-American Court of Human Rights of February 6, 2014. Available at: http://www.corteidh.or.cr/docs/asuntos/brewer_29_11_12.pdf 3