3 (d) “On March 29, 2007, the Minister of the Public Power for Telecommunications and Informatics notif[ied] Communication No. 0424, of a merely declarative nature, to RCTV; it confirmed the decision of the National Executive to declare the termination of the license”; […] “however, it deliberately omitted Article 3 of [Decree 1,577], which recognizes the right to an extension for a further 20 years to license holders who respect the Law in the exercise of their rights as license holders”; (e) “The declarations of the […] Minister of the Public Power for Telecommunications and Informatics confirmed that the National Executive’s decision and the instructions [...] given by the President of the Republic to [the said] Minister were designed to prevent […] RCTV from continuing to operate as an free VHF television station as of May 28, and [allegedly] was an political sanction of its independent and critical editorial line; (f) “The real reason […] for the decision […] not to renew the license was to penalize the exercise of freedom of expression by the management, journalists and other personnel”; (g) “The announcement and […] the formal communication that the elimination of RCTV was merely pending expiry of the allotted time” was a general and imminent threat to the freedom of expression of the those who work in the area of social communication; also, “it was a violation of the right to work of the said employees, as well as [a violation] of the right of society to receive information freely”; (h) The alleged “threats and governmental decisions concerning an immediate shutdown on May 27 this year […] also harmed the mental and moral integrity of the employees of RCTV.” The “threat does not terminate there, but has an impact on all society.” These “threats […] contradict (or at least clearly ignore) the opinion of the [Commission] on the adverse effects of the annulment and/or non-renewal of the license on the exercise [of the] right to freedom of expression [of the] victims [of the] case currently […] before the Inter-American Court and which previously resulted in the adoption […] of provisional measures, which had been ordered for [their] protection, the expansion of which [is requested] urgently in the [abovementioned brief]; (i) The “decision of the State to close down RCTV through the non-renewal of its license and the [alleged] lack of judicial protection […] places [the beneficiaries] in a situation of extreme gravity and urgency that requires the intervention of the international judicial protection organ, to avoid irreparable damage to them, to the other RCTV journalists and to Venezuelan society. […] The Court should therefore adopt measures to preserve the rights of the parties in dispute, ensuring that the judgment on merits is not prejudiced by their actions pendente lite,” and (j) The provisional measures “requested of [the] Court [would] also irreplaceably fulfil a protective objective. In that context, the Court’s provisional measures [would be] the only and final legal remedy provided [to them] by the Convention to protect [their] human rights in the face of the [alleged] imminence of their being violated.” In this brief, the representatives asked the Court to order the State to take the following provisional measures: