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138 "[B]y treating paragraph 5.2 of the Doha Decision as a 'subsequent agreement' that establishes the meaning of the covered agreements, the Appellate Body report effectively eliminates the safeguards that Members have included in Article IX:2 of the WTO Agreement." 139 Second, the United States stated, by finding that a prima facie case under Article 2.12 of the TBT Agreement is establishing that the technical regulation allows less than six months between publication and effective date, the Appellate Body reversed the burden of proof for Article 2.12 claims

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3 Seidenberg AB, Caughey RW, Rees VW, Connolly GN

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