4 requests made by the beneficiaries – that is, means of communication, cellular telephones, an armored car to use in Bogotá, a car without armor for getting around in the field, and video cameras in the headquarters – were approved on January 19, 2010 even though some of these measures have yet to be implemented. 3. The arguments presented by the Commission as grounds for its request for provisional measures, namely: a) “to verify the situation of extreme gravity and urgency as required by Article 63(2) of the American Convention so that the Court may order provisional measures in kind for the existence of cycles of threats, acts of aggression, and accusations against the [ICJP], as well as the continuing nature of acts of persecution, intimidation, and harassment against them”; b) “[t]he nature of the objects threatened – that is, the lives and right to humane treatment of the members of the [ICJP], as well as their capacity to continue their work in defense of human rights – constitutes an extreme example of irreparable consequences that [the] request for provisional measures seeks to avoid. This does not just reflect the potential for a violation of the fundamental right to life, but also exposes the rest of the human rights defender community to a situation of extreme vulnerability and risk”; c) “although it is true that the State […] has adopted some strong protective measures, they have not been a sufficient response in the face of the real and imminent risk posed, nor are they enough to protect the lives and right to humane treatment of the beneficiaries. The continuity of threatening actions, accusations, intimidation, surveillance, and general harassment, as well as the lack of an effective response in relation to the clarification of legal suits over the criminal activities of some state security organs effectively mean that, to date, the beneficiaries remain in a situation of serious gravity, vulnerability, and defenselessness, while their lives and right to humane treatment are at risk of imminent harm”; d) by virtue of the constant practice of the Tribunal on the use of prima facie assessment criteria and the application of presumptions as to immediate needs for protection, the Commission considers that the Court currently has sufficient proof to fairly invoke the mechanism for provisional measures, and e) “it is of utmost importance that the agents of the system protect the public interest through the available mechanisms. In the present [matter…] the proper mechanism to protect this interest is that of provisional measures […].” 4. On the basis of the above, the Commission indicated that “the provisional measures that the Court eventually dictates must include an unequivocal call to the State of Colombia for it to desist from engaging in any act that may put the beneficiaries at further risk, including the immediate cessation of all unfounded accusations and intelligence activities on the part of state agents and associated individuals, as well as prohibiting access [to all concerning] information gathered and revealed by way of these activities.” In particular, the Commission asked Court to require that the State:

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