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114 The Appellate Body began its analysis by noting that in a previous WTO case, the Appellate Body observed that the International Law Commission (the "ILC") describes a subsequent agreement within the meaning of Article 31(3)(a) of the Vienna Convention as "a further authentic element of interpretation to be taken into account together with context." According to the Appellate Body, by referring to "authentic interpretation," the ILC reads Article 31(3)(a) as referring to agreements bearing specifically upon the interpretation of the treaty

After being admitted to hospital with pneumonia in 2017, Clarkson then suffered what he described as really bad coronary artery problems at the end of 2024