situations where multiple entities have contributed to an injury arising from an internationally wrongful act.” 19 For its part, in the case of Goiburú v. Paraguay, the Court has clarified that to ensure the effectiveness of the collective guarantee mechanisms established in the Convention, [...] States Parties to the Convention should collaborate with each other to eliminate the impunity of the violations committed in this case by the prosecution and punishment of those responsible. 20 Although we could not issue a judgment finding Chile or Uruguay responsible, since these States have not fully participated in the proceedings, I believe that it is feasible to advance in terms of the cooperation of the States with the Court within the framework of Article 58 of the Rules of Procedure, which grants the Court broad evidentiary powers. 21 Along these lines, the Court should have made progress in requesting information from these States that could have made it possible to advance in determining the international, interstate, and cross-border nature of the facts of this case. A separate discussion is the possibility of determining the international responsibility of several States in making inter-State cooperation decisions that produce acts that end up violating human rights in other countries. Although the American Convention does not expressly address it, nor do the Rules of 19 Maarten Den Heijer, Procedural Aspects of Shared Responsibility in the European Court of Human Rights, 4 J. OF INT’L DISP. SETTLEMENT 361, 362 n.3 (2013) 20 Inter-American Court. Case of Goiburú et al. v. Paraguay. Merits, reparations and costs. Judgment of September 22, 2006. Series C No. 153, para. 166 21 Article 58. Procedure for Taking Evidence The Court may, at any stage of the proceedings: a. Obtain, on its own motion, any evidence it considers helpful and necessary. In particular, it may hear, as an alleged victim, witness, expert witness, or in any other capacity, any person whose statement, testimony, or opinion it deems to be relevant. b. Request the Commission; the victims or alleged victims, or their representatives; the respondent State; and, if applicable, the petitioning State to submit any evidence that they may be able to provide or any explanation or statement that, in the Court’s opinion, may be useful. c. Request any entity, office, organ, or authority of its choice to obtain information, express an opinion, or deliver a report or pronouncement on any given point. Such documents may not be published without the authorization of the Court. d. Commission one or more of its members to take steps in the advancement of the proceedings, including hearings at the seat of the Court or at a different location. e. If it is impossible to proceed according to the terms established in the previous paragraph, the Judges may commission the Secretariat to take necessary steps in the advancement of the proceedings.

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