consequences from the moment they were waged; some "CFOs [claimed] that they had to change policies because the company was unsustainable in this way." Similarly, in his statement, Mr. D'Amico also noted that the former President and those close to him began nineteen civil and criminal proceedings against the magazine. With regard to the personal consequences that came about due to the Judgment in question, Mr. D'Amico said that his assets were seized, reason for which, during a period of nineteen months, part of his salary was seized to cover the debts of the civil sentence. 74. Finally, the Court has established that the measure of further liability imposed domestically, did not satisfy the requirement that it be necessary in a democratic society and therefore it will not consider whether the amount of the civil penalty in this case was disproportionate or not. Notwithstanding the foregoing, the Court considers it appropriate to reiterate that the fear of a disproportionate civil sanction may clearly be as or more intimidating and inhibiting for the exercise of freedom of expression than a criminal sanction, as it has the potential to compromise the personal and family life of those who complain, or as in the present case, those who publish information about a public official, with the obvious and unmerited result of self-censorship for the affected and for other potential critics of the performance of a public official. 58 75. Based on the foregoing, the Court finds that there was no unreasonable or arbitrary interference in the private life of Mr. Menem in the terms of Article 11 of the American Convention, but rather, on the contrary, the challenged publications constituted a legitimate exercise of the right to freedom of expression under Article 13 of that treaty. As a consequence, the Inter-American Court concludes that the measure of further liability imposed in this case violated the right to freedom of thought and expression of Mr. Jorge Fontevecchia and Mr. Hector D'Amico, recognized in Article 13 of the American Convention, in relation to the obligation to respect that right, under Article 1(1) thereof. VI OBLIGATION TO ADOPT DOMESTIC LEGAL EFFECTS IN RELATION TO FREEDOM OF THOUGHT AND EXPRESSION A. Arguments of the parties 76. The Commission recalled that in its report on the merits, it did not rule on the violation of Article 2 of the American Convention, 59 "since in the litigation stage [before it] the petitioners' did not specify how or why Article 1071 bis of the Civil Code violated, per se, the [said treaty].’” Although in its final observations the Commission noted it looked "to the new evidence and allegations provided during the hearing stage," it maintained its position, and it did not allege a violation of that Article. 58 Cf. Case of Tristán Donoso V. Panamá, supra note 35, para. 129. 59 The article 2 of the American Convention on Human Rights establish that: Where the exercise of any of the rights or freedoms referred to in Article 1 is not already ensured by legislative or other provisions, the States Parties undertake to adopt, in accordance with their constitutional processes and the provisions of this Convention, such legislative or other measures as may be necessary to give effect to those rights or freedoms. 25