aim in a democratic society.66 The failure to meet any one of these requirements means that the measure imposed is contrary to the American Convention. 60. The IACHR and the Inter-American Court have consistently stated that the States have less room to impose restrictions on freedom of expression “whenever dealing with expressions concerning the State, matters of public interest, public officials in the performance of their duties, candidates for public office, private citizens involved voluntarily in public affairs, or political speech and debate.”67 61. Along these same lines, the Commission has held that the analysis of the proportionality of the restrictive measures must take account of: “(1) the greater degree of protection accorded to speech concerning the suitability of public officials and their performance, or of those who aspire to hold public office; (2) speech concerning political debate or debate on matters of public interest—due to the need for a broader degree of openness for the wide-ranging debate required in a democratic system and the citizen oversight inherent in it—and (3) the correspondingly heightened threshold of tolerance for criticism that State institutions and officials must demonstrate when confronted by the statements and opinions of persons exercising such oversight. In such cases, the demands of the protection of these individuals’ right to their honor and reputation must be balanced against the interests of an open debate on public affairs […] On the point, for example, the Inter-American Court in the case of Tristán Donoso v. Panama, recalled that “any expression regarding the suitability of an individual for holding public office or regarding the acts performed by public officials in the course of their duties enjoy greater protection, thus fostering democratic debate.”68 62. Indeed, democratic debate means allowing for the free circulation of ideas and information on the activities of public servants by the media, representatives and their political parties, and any person who wishes to express his or her opinion or provide information. It is especially important for everyone to be able to report and corroborate, through debate and the exchange of information and ideas, alleged acts of corruption attributable to State entities and employees.69 63. In this case, it is not disputed that the most restrictive or severe instrument available to the State— the criminal law—was applied, or that the alleged victim was sentenced to a term of imprisonment and the limitation of his political rights as a consequence of the exercise of his right to freedom of expression. Nor is it in question that the statements made by Tulio Alberto Álvarez concern a matter of public interest and the conduct of a public official, specifically, the reported misappropriation of funds from the Venezuelan National Assembly’s Workers’ and Retirees’ Savings Bank during the term of the then-president of the legislature; or that the contributions and withholdings owed to the Savings Bank when the petitioner’s column was published had reached a considerably high sum. 66 I/A Court H.R., Case of Herrera Ulloa v. Costa Rica. Preliminary Objections, Merits, Reparations and Costs. Judgment of July 2, 2004. Series C No. 107, para. 120; I/A Court H.R., Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111, para. 95; I/A Court H.R., Case of Palamara Iribarne v. Chile. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 135, para. 79, available at: http://www.corteidh.or.cr/docs/casos/articulos/seriec_135_ing.pdf; Case of Kimel v. Argentina. Merits, Reparations and Costs. Judgment of May 2, 2008 Series C No. 177, para. 54. See also: Annual Report of the Inter-American Commission on Human Rights, Annual Report 2009 of the Office of the Special Rapporteur for Freedom of Expression, p. 258, paras. 68-69, available at: http://www.oas.org/en/iachr/expression/docs/reports/annual/Informe%20Anual%202009%202%20ENG.pdf. 67 IACHR. Annual Report 2009. Report of the Office of the Special Rapporteur for Freedom of Expression. Chapter III (InterAmerican Framework on Freedom of Expression). OEA/Ser.L/V/II. Doc. 51. December 30, 2009. Para. 100; I/A Court H.R., Case of Ivcher Bronstein v. Peru. Judgment of February 6, 2001. Series C No. 74; I/A Court H.R., Case of Herrera Ulloa v. Costa Rica. Judgment of July 2, 2004. Series C No. 107; I/A Court H.R., Case of Ricardo Canese v. Paraguay. Judgment of August 31, 2004. Series C No. 111I/A Court H.R., Case of Palamara Iribarne v. Chile. Judgment of November 22, 2005. Series C No. 135; I/A Court H.R., Case of Kimel v. Argentina. Judgment of May 2, 2008 Series C No. 177; IACHR. 1994 Annual Report. Chapter V: Report on the Compatibility of “Desacato” Laws with the American Convention on Human Rights. OEA/Ser. L/V/II.88. doc. 9 rev. February 17, 1995. 68 IACHR. Annual Report 2009. Report of the Office of the Special Rapporteur for Freedom of Expression. Chapter III (InterAmerican Framework on Freedom of Expression). OEA/Ser.L/V/II. Doc. 51. December 30, 2009. Para. 101. 69 IACHR. Arguments before the Inter-American Court in the Case of Herrera Ulloa v. Costa Rica. Reprinted in: I/A Court H.R., Case of Herrera Ulloa v. Costa Rica. Judgment of July 2, 2004. Series C No. 107, para. 101.2 h).