the Appellate Body decision was critiqued by environmentalists, the complaining parties, and (at least in private) some WTO trade law specialists. Earth Island Institute, the NGO which, through U.S. courts, compelled the United States to apply Section 609 to all countries, dubbed the decision A a death blow for sea turtles.40 The developing country complainants called the Appellate Bodys approach A dangerous, fearing that the ruling A will result in explosive growth in unilateral, discriminatory, trade-related environmental measures.41 Some trade law experts questioned the appropriateness of a WTO panel reviewing domestic legislative and administrative procedures.