iii. Payment of damages in the amount of twenty (20) million CFA Francs per worker, that is, a total amount of two hundred million (200,000,000) CFA Francs for the ten (10) workers as reparation for moral and material damages; iv. Issuance of work certificates for seventy-one (71) persons, including the eleven (11) people expressly mentioned in this Application, subject to a penalty of one hundred thousand (100,000) CFA Francs per person and per day of delay; v. Severance medical visits for the workers concerned subject to a penalty of one hundred million (100,000,000) CFA Francs) for the ten (10) former employees; vi. Payment of half of the entitlements mentioned upon the delivery of judgment by this Court. 17. For its part, the Respondent State prays the Court to: i. Declare that it lacks jurisdiction rationae materiae; ii. With respect to form, declare the Application inadmissible; iii. On the merits, declare the Applicants ill-founded in their claims, purposes and submissions; dismiss the claims outright, and iv. Order the Applicants to pay costs. V. JURISDICTION 18. The Court notes that Article 3 of the Protocol provides that: 1. The jurisdiction of the Court shall extend to all cases and disputes submitted to it concerning the interpretation and application of the Charter, this […] Protocol, and any other relevant human rights instrument ratified by the States concerned. 2. In the event of a dispute as to whether the Court has jurisdiction, the Court shall decide. 5