2 3. According to the facts described by the Commission, the State arbitrarily deprived Mr. Ivcher Bronstein, naturalized Peruvian citizen, majority shareholder, Director and President of Channel 2-Frecuencia Latina (hereinafter “Channel 2”, “the Channel” or “Frecuencia Latina”) of the Peruvian television network of his nationality title, in order to remove him from the editorial control of the said channel and restrict his freedom of expression, which he manifested by denouncing grave violations of human rights and acts of corruption. 4. The Commission therefore requested the Court to call on Peru to restore and guarantee to Mr. Ivcher the enjoyment of all his rights and, in particular that it should: a. Order that Mr. Ivcher Bronstein’s Peruvian nationality title be reinstated and that the full and unconditional recognition of his Peruvian nationality be restored, with all attendant rights and prerogatives. b. Order that Mr. Ivcher Bronstein’s enjoyment and exercise of his right to own shares in Compañía Latinoamericana de Radiodifusión S.A. be restored along with all his prerogatives as a shareholder in and administrator of that company. c. Order that Peru must guarantee Mr. Ivcher Bronstein’s enjoyment and exercise [of] his right to freedom of expression and, in particular, that the acts of harassment and persecution against him, including the acts against his family and his company [should] cease. d. Order that the Peruvian State must adopt the necessary legislative and administrative measures to make full reparation and compensate Mr. Ivcher Bronstein for all the material and moral damages that the acts of its administrative and judicial organs have caused him. The Commission also petitioned the Court to order the State to adopt the necessary legislative and administrative measures to avoid a recurrence of events of this nature, and to investigate and punish those responsible for the violations of the fundamental rights of Mr. Ivcher Bronstein. Lastly, the Commission requested that the State be ordered to pay the costs and reimburse the expenses incurred by the alleged victim in litigating this case, in both the domestic courts and the interAmerican system, including reasonable fees for his representatives. II COMPETENCE OF THE COURT 5. The Court is competent to hear the instant case. Peru has been a State Party to the American Convention since July 28, 1978, and recognized the obligatory jurisdiction of the Court on January 21, 1981. III PROCEDURE BEFORE THE COMMISSION 6. On June 9, 1997, the Peruvian Congressman, Javier Díez Canseco, advised the Commission that Mr. Ivcher Bronstein might possibly be deprived of his Peruvian nationality. On July 16, 1997, the Dean of the Lima Bar Association, Vladimir Paz de la Barra, filed a petition with the Commission alleging that the State had revoked Mr. Ivcher’s Peruvian citizenship.