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The amicus curiae brief argues that the Mexican state was obligated to deny the environmental permit for the Don Diego project due to severe risks to the marine ecosystem of the Golfo de Ulloa and the human rights of local fishing communities. The authors contend that the project, which involves dredging 91,000 hectares of the seabed to extract 7 million tons of phosphate rock annually, would cause irreversible biodiversity loss and contaminate the area with radioactive elements like uranium and thorium. They assert that the precautionary principle and international treaties—including the UN Convention on the Law of the Sea and the American Convention on Human Rights—mandate the protection of the environment and the right to work and health for the 128 families of the Puerto Chale Cooperative and other regional residents.

The brief provides legal analysis to the Inter-American Court of Human Rights regarding Colombia's request for an advisory opinion on the impact of large-scale projects on the marine environment, specifically in the Greater Caribbean Region. It asserts that state jurisdiction extends to acts or omissions with foreseeable extraterritorial effects and advocates for the 'principle of systemic integration' to align human rights protections with international environmental standards.