new article 110 of the Argentine Criminal Code. Furthermore, this Court takes note that, in any case, according to the Appellate Chamber, the criminal sanction imposed on Messrs. Mémoli had been completed, so that application of the new law to the criminal conviction imposed on them would not be appropriate. 159. Based on the above considerations, the Court concludes that the State did not fail to comply with the principle of legality and retroactivity, and therefore did not violate Article 9 of the Convention, in relation to Article 1(1) thereof, to the detriment of Messrs. Mémoli. 160. Finally, the Court observes that the representatives’ arguments regarding the supposed violation of political rights are based on the State’s supposed responsibility for the violation of the freedom of expression of Messrs. Mémoli, because these arguments refer to the alleged effects of the criminal conviction, as well as the supposed failure to apply the law retroactively. Since the Court has found that the State did not violate Articles 13 and 9 of the American Convention, therefore, the Court considers that it is not in order to analyze the alleged violation of Article 23 of the Convention. IX REASONABLE TIME AND RIGHT TO PROPERTY, IN RELATION TO THE OBLIGATION TO RESPECT AND ENSURE RIGHTS 161. In this chapter, the Court will examine the violations alleged by the Commission and the representatives, as well as the corresponding argument of the State, with regard to: (i) the violation of the reasonable time and of the right to property, and (ii) the other violations of due process alleged by the representatives. A. Violation of reasonable time and the right to property in the civil proceeding for damages A.1) Arguments of the Commission and of the parties 162. The Commission concluded that there had been a violation of the principle of a reasonable time in the civil proceeding that would also suppose a violation of the right to freedom of expression. In this regard, it noted that “the civil proceeding against Carlos and Pablo Mémoli was filed on December 29, 1997, and as of this date [that of the Merits Report], has not been decided in first instance.” The Commission indicated that “even though the long delay in settling the case is partly attributable to the pleadings of the petitioners, the conduct of the judicial authorities has also contributed to this situation.” The Commission added that “the existence of a precautionary measure that imposed a severe restriction on the rights of the victims required the judicial authorities to take all necessary measures to complete the case promptly and diligently.” In this regard, it indicated that “the application of a general injunction on property in the context of a civil suit that has not been decided within a reasonable time has lost its precautionary nature and become a punishment.” 163. The Commission also indicated that “civil proceedings in the area of freedom of expression should be strictly proportionate so as not to have a inhibiting effect on speech, [which] is particularly important in matters relating to issues of public interest.” In this regard, it observed that “the civil suit against Carlos and Pablo Mémoli for the sum of 90,000 Argentine pesos, together with the general injunction on property that has been in effect for more than 15 years, has not only given rise to the fear of possible civil sanctions, 61