State's position that the application of Mr. Abubaker and others before the Council had also been decided since the Commission's ruling on Admissibility. Therefore, according to the Respondent State, the Complainants' allegations have been considered by the Ethiopian judiciary and the Council and as a result all domestic remedies have been effectively and sufficiently exhausted. 221. The Respondent State also submitted that most of the issues raised by the Complainants fall outside of the parameters permitted by the Commission which require the Complainants to address those alleged violations of the African Charter within the context of the charges brought under the Anti-Terrorism Proclamation No. 652/2009 and presented by the Council but were not considered due to delay. The Respondent State requested the Commission to dismiss all the Complainants' arguments that were not included in their original complaint or do not fall within the narrowly-tailored grounds on which the Complaint was deemed admissible. Alternatively, or in addition, the Respondent State requested the Commission to dismiss the Complaint on its merits for failure to State violations of the African Charter. Accordingly, the Respondent State requested the Commission to dismiss the reliefs sought by the Complainants. Amicus Curiae Brief Submissions 222. By a letter dated the 19th May 2017, the Commission received Amicus Curiae brief submissions from Messrs. Vanderbilt International Law Practice Lab which was submitted pursuant to Rule 99(1) of the 2010 ROP. 223. The Amicus Curiae's submissions sought, in the main, to address the following issues: First, that the Anti-Terror Statute does not meet international and regional standards for defining and criminalizing acts of terrorism; and second, that the Anti-Terror Statute violates the African Charter. 224. In support of its first argument that the Anti-terror statute does not meet international and regional standards for defining and criminalizing acts of terrorism, the Amicus Curiae submitted that: (a) The Anti-terror Statute is overly Broad and includes a huge array of offenses which do not meet commonly accepted definitions of terrorism; (b) Article 3 of the Anti-Terror Statute is imprecise and fails to provide adequate notice of what acts will constitute an offence; and (c) The Anti- Terror Statute criminalizes protected activities, such as exercise of freedoms to of religion, expression, association and assembly. 225. The Amicus Curiae submitted that Article 3 of the Anti-Terror Statue defines "Terrorist Acts" in a way that is overly broad because it includes a huge array of offences which do not give rise to commonly accepted definitions of "terrorism". The Amicus Curiae also submitted that the Anti-Terrorism Proclamation No. 652/2009 is ambiguous and fails to provide adequate notice of what acts will constitute an offence and unjustly criminalizes protected activities, such as the exercise of the rights to freed,.9lIlS:~....._ religion, expression, association, and assembly. 226. Under the second issue, the Amicus Curiae submitted that States which African Charter are obligated to "recognise the rights, duties, freedoms in