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Wt ds285 r page 38 3.89 the united states stresses that it is antigua's burden to provide argumentation explaining what aspect of specific us measure s ; in antigua's view renders the measure s ; inconsistent with specific us obligations or commitments under the gats. since antigua has failed in all respects to sustain that burden, the united states cannot delve into any specific measure in detail. in the view of the united states, antigua explicitly seeks to shift its burden of proof onto the united states.187 it offers no basis for doing so except the complexity of us law an excuse that the appellate body has already rejected as a ground for allocating the burden of proof: "there is nothing in the wto dispute settlement system to support the notion that the allocation of the burden of proof should be decided on the basis of a comparison between the respective difficulties that may possibly be encountered by the complainant and the respondent in collecting information to prove a case."188 antigua admonished the panel that the united states "should not be allowed to in essence 'hide behind' the complexity and opacity of its own legal structure." to the contrary, the united states submits that the burden has always been on antigua to come out of hiding and say what specific measures it does or does not seek to challenge, and then to provide evidence and argumentation as to each measure. antigua has not only failed to do so, it has repeatedly refused to do so. 3.90 antigua submits that the biggest point of contention in respect of the measures is whether antigua and barbuda has submitted sufficient proof that the united states maintains "measures" that result in a complete prohibition or a "total ban" on the provision of gambling and betting services from antigua and barbuda into the united states. however, rather than asking the united states to assume any burden of proof, antigua's very basic point is that the united states has conceded this point of us law. given the clear and unambiguous concession of the united states on the complete prohibition the total ban antigua and barbuda believes that there is simply no sense in proving an already conceded point. in fact, under the laws of virtually every jurisdiction that antigua is aware of including the united states ; , a concession, such as that made in this case by the united states, would result in a stipulation of the conceded fact or issue precluding further discussion on the topic. the same concept holds true in the wto. as noted by the european communities189 , previous panels accepted similar such concessions as being accurate. moreover, the united states has conceded this point to antigua in consultations meeting on this matter, as well as in open session before the dispute settlement body in the context of this dispute on two occasions. despite its insistence that antigua should prove the point, the united states refers to its prohibition. in multiple public statements and position papers, the united states department of justice has unambiguously made this concession. and the united states clearly acts as if there is a prohibition hence some of the actions taken by the united states and referenced in section iii of the annex to antigua's request for consultations in this proceeding. indeed, antigua invites the united states to deny that concession before the panel. given the concession by the united states, antigua and barbuda strongly believes that a detailed discussion of all measures on a state and federal level is unnecessary and would prove difficult and, more importantly, wasteful. further, consultations between parties are intended not only to resolve disputes, but also to frame and refine the issues. 3.91 antigua notes that the united states apparently takes the position that a "measure" for purposes of wto dispute resolution must consist of a discrete "law on the books" and that "measures" can only be a number of such discrete laws. this is a clear misinterpretation of a well-settled area of wto jurisprudence which has established that many things government policies, procedures and actions included may constitute "measures." indeed, the gats itself defines "measures" expansively in article xxviii a ; . of course, if a measure were required to be a specific, discrete statute or regulation, members could easily evade the reach of the dispute settlement machinery of the wto through the use of informal policies and unwritten practices without any legislation or formal rulemaking at all. the point of the united states in this regard seems to be that the admitted "total and poker software. 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