109 c) They requested full reparation of the “right to property of the RCTV employees who are victims in this case owing to the pecuniary damage caused as a result of losing their employment” owing to the non-renewal of the RCTV concession. They indicated the amount for each person and indicated that this “should be adjusted to the date on which payment is made.” 399. In the case of the request for compensation for non-pecuniary damage, the representatives indicated that “the closure of RCTV owing to non-renewal […] of the concession by the State […] caused the victims a series of adverse psychological effects, anguish, suffering and other non-pecuniary harm.” They asked the Court to grant the sum of US$25,000 to each victim in this case for non-pecuniary damage. 400. Regarding the request for compensation for pecuniary damage, the State submitted the following arguments: a) It underscored that, “in its Merits Report, the Commission established that the property of the shareholders had not been harmed” and, therefore, it agreed with the Commission and would not submit other arguments on the presumed damage to property. b) It rejected “the protection of interests of legal persons [in] this jurisdiction” in “relation to the petitioners’ request for reparations for pecuniary damage.” Regarding the concessions, the State argued that they are granted by “sovereign States for those assets that are in the public domain, [and] the purpose and length of all of them are [limited] pursuant to domestic law; in other words, anyone who becomes a concessionaire by receiving from the State the right to exploit a specific asset, in this case the radioelectric spectrum, has prior knowledge of the duration of this concession and knows that he is subject to the State’s authority with regard to the concession, and that the State can revoke it at any time based on social or collective interest, or even decide not to renew it.” Consequently, it argued that “the State’s actions cannot be penalized, by making pecuniary claims against it, when it is exercising its sovereign right to organize the radioelectric spectrum in accordance with the National Telecommunications Plan.” The State affirmed that “it is a blatant abuse to ask the Inter-American Court […] to require reparation for the RCTV shareholders based on a percentage of their shares for the financial prejudice caused by the devaluation of the company.” Furthermore, it asked the Court to recall that “the RCTV shareholders have radio concessions in Venezuela and RCTV had been making a profit in the country from 1953 to 2007, that is for 54 years.” c) It shared the opinion of the Commission when it concluded that “the petitioners have not presented sufficient evidence of a direct effect on the personal property of the shareholders presented as victims as a result of the State’s seizure of RCTV’s tangible assets.” Consequently, the State concluded that it was exempt from providing compensation for damage to the property of the RCTV shareholders and that it owed nothing in relation to the interim measure granting it the RCTV assets. d) In addition, it affirmed that “the employment situation of the personnel who worked for [RCTV] cannot be attributed to the State, because the employment relationship is established between the employer and the employee and is governed by the Organic Labor Law.”