previously called “initial review.” In particular, in Article 31 of the Commission’s 1980 Rules of Procedure, this differentiation can be seen in paragraph “c” which establishes that “[i]f it accepts, in principle, the admissibility of the petition, [the Commission, acting initially through its Secretariat] shall request information from the Government of the State in question and include the pertinent parts of the petition.” Furthermore, as of the Commission’s 2000 Regulations, the initial review stage is expressly differentiated from the admissibility stage. During this first stage, the Executive Secretariat of the Commission may, inter alia, request the petitioner or his representative to complete the information presented, and decide to process petitions that comply with the requirements established in Articles 29 41 and 28 42 of the Commission’s 1980 and 2000 Regulations, respectively. Once it has been decided to process the petition, the admissibility proceeding begins and the pertinent part of the petition are forwarded to the State in question. This procedure was decided by the Commission, based on the provisions of Article 39 43 of the Convention, as well as Articles 22 44 and 23 45 of the Commission’s Statute. 36. In the instant case, the Court notes that this initital review stage lasted three years and ten months, which was the time that the Commission took to forward the petition to the State, which constitutes an excessive delay. Based on the State’s argument, the Court will proceed to analyze whether this constituted a violation of Argentina’s right of defense. sessions, held from October 28 to November 13, 2009, and modified on September 2nd, 2011 and during the 147th Regular Period of Sessions, held from 8 to 22 March 2013, for entry into force on August 1st, 2013. 41 Article 29 of the 1980 Rules of Procedure of the Commission established that: “[p]etitions addressed to the Commission shall include: (a) the name, nationality, profession or occupation, postal address, or domicile and signature of the person or persons making the denunciation; or in cases where the petitioner is a nongovernmental entity, its legal domicile or postal address, and the name and signature of its legal representative or representatives; (b) an account of the act or situation that is denounced, specifying the place and date of the alleged violations and, if possible, the name of the victims of such violations as well as that of any official that might have been appraised of the act or situation that was denounced; (c) an indication of the State in question which the petitioner considers responsible, by commission or omission, for the violation of a human right recognized in the American Convention on Human Rights in the case of States Parties thereto, even if no specific reference is made to the article alleged to have been violated; (d) information on whether the remedies under domestic law have been exhausted or whether it has been impossible to do so. 42 Article 28 of the 2000 Rules of Procedure of the Commission indicated the following: “[p]etitions addressed to the Commission shall include the following information: (a) the name, nationality, and signature of the person or persons making the denunciation; or in cases where the petitioner is a non-governmental entity, the name and signature of its legal representative or representatives; (b) whether the petitioner desires his identity to be kept from the State; (c) the address to receive correspondence from the Commission and, if applicable, telephone and facsimile number, and e-mail address; (d) an account of the act or situation that is denounced, specifying the place and date of the alleged violations; (e) if possible, the name of the victim, as well as that of any public authority that might have been appraised of the act or situation that was denounced; (f) an indication of the State that the petitioner considers responsible, by act or omission, for the violation of a human right recognized in the American Convention on Human Rights and other applicable instruments, even if no specific reference is made to the article alleged to have been violated; (g) compliance with the time frame established in Article 32 of these Regulations; (h) the steps taken to exhaust domestic remedies or whether it has been impossible to do so in accordance with Article 31 of these Regulations; (i) an indication of whether the denunciation has been submitted to any other international proceedings in accordance with Article 33 of these Regulations. 43 Article 39 of the Convention establishes that: “[t]he Commission shall prepare its Statute, which it shall submit to the General Assembly for approval. It shall establish its own Regulations.” 44 Article 22 of the Commission’s Statute stipulates: “1. The present Statute may be amended by the General Assembly. 2. The Commission shall prepare and adopt its own Regulations, in accordance with the present Statute. 45 Article 23(1) of the Commission’s Statute indicates that: “[i]n accordance with the provisions of Articles 44 to 51 of the American Convention on Human Rights, the Regulations of the Commission shall determine the procedure to be followed in cases of petitions or communications alleging violation of any of the rights guaranteed by the Convention, and imputing such violation to any State Party to the Convention.” 16