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After the OSC granted review, DOC submitted a second ''amicus curiae'' brief to address the merits of the case. That second brief, in summation, stated:
<blockquote>
There is no basis on which the father can hope to prevail in the face of overwhelming protections offered to Misha/Jimmy by the Washington, Oregon, and U.S. Constitutions, and moreover, in face of the protections offered by international treaties, in particular, the ICCPR. The Supreme Court has stated that "a child, merely on account of his minority, is not beyond the protection of the Constitution." There are no material facts at dispute that require further hearings on the child’s fundamental rights.<ref name="docbrief2">{{REFdocument
|title=BRIEF ON THE MERITS OF ''AMICUS CURIAE'', DOCTORS OPPOSING CIRCUMCISION
|url=https://pool.intactiwiki.org/images/2007-07-31_BoldtAmicusBriefMerits.pdf