At the beginning, there was confusion. The peoples of the world, those represented at the time in the GATT’s building Green Room, adjacent to the Director-General’s office and beyond, quarreled over how to put order in the informal international trading system. Eight years long, from Punta de l’Este, Uruguay (1986) to Geneva (1994) they discussed, until, at last, light prevailed over darkness. They avoided the Tower of Babel fate where the difference of languages brought confusion and ultimately destruction. Out of confusion at the end of the Uruguay Round instead, there came meeting of the mind, but it took time. As St. Augustin famously stated, “Light will more easily come out of error than out of confusion.”

But a system, especially a legal system, needs not only rules but a coherent conceptual ordering. One man stood out, to provide the legal tools. It was John Jackson (1932-2015). As the first and foremost proponent of the *General Agreement on Tariffs Trade* (*GATT 1947*) as a legal framework and not just a commercial arrangement,<fnref n="1" /> as it had been indeed conceived back in 1947, he was best placed to develop the conceptual framework under which to analyze and nurture the new creature, the World Trade Organization (WTO). To accompany its birth, almost as a midwife, and later, its consolidation in legal terms, he left Ann Arbor to commute untiringly between Washington, Geneva, Brussels, public offices and academic meetings, shaping and spreading the new gospel. He has been rightly labelled as one of the chief architects of the WTO and its dispute settlement procedure.

There had been however a precursor, although most of those living today have not had a chance to meet him. Like John the Baptist before the actual preaching of the New Testament by Jesus that person had been Robert (Bob) Hudec (1935-2003). The decisive role of these two *American* legal minds in establishing the basis of the international rule-based trading system, and convincing those in power in Washington that “it was good for America” must not be forgotten. The same must be said as to John’s influencing entire generations of students and scholars in the field.<fnref n="2" />

And here comes the Trinity, or, if one prefers, the Evangelists of the New Law, side by side with John Jackson, and following his steps. Not twelve of them but just three: Frieder Roessler, Ernest Ulrich (Ulli) Petersmann, and last, as to age only, Gabrielle<fnref n="3" />.

Frieder (1939-2024) had been the first lawyer in the GATT Secretariat, in 1973, since even before the times of Arthur Dunkel, the Director-General of GATT from 1980 to 1993, from the Tokyo Round Agreements to the dawn of the WTO, whose final text was largely based on his “Dunkel Draft”. Frieder’s hiring, as he wrote later, was accompanied by the skepticism of the staff (why would we need a lawyer?).<fnref n="4" /> I well remember when he welcomed me in the building when I first came as a young professor with a group of students from the University of Bergamo, where I was teaching at the time, in 1985, at the eve of the Uruguay Round. From head of the Legal Affairs Division of the GATT, which was created only in 1989, he went on, sailing trouble waters as he was calmly able to, becoming the first Director of the WTO Legal Affairs Division until 2001, where his legal (and diplomatic) role cannot be understated.

Then there was Ulli. Initially, his principal home, besides at various universities, was predominantly the GATT building, where he also had started as an advisor in the early 1970s. A building that at the time looked more like an old Swiss hotel in need of refurbishing, as a newspaper wrote, than as the premises of an international organization. Progressively, he moved practically full-time to academia, first in Geneva and later at the European University Institute in Florence. But he kept for many years a small office in the GATT building as an advisor to the Legal Affairs Division, advising panels, and as a panelist himself. His commitment as an author towards advocating a rule-based trading system with a constitutional and human rights dimension has influenced also the non-believers.<fnref n="5" />

And finally enters Gabrielle at last, walking on the steps of, and dialoguing with these so powerful mentors. Her presence in the building has been constant, extending from September 1994, when the GATT was about to give way to the WTO, up to our days, 2025. Thus, she also was present at the birth of the current system and has witnessed and nurtured its grow and various crises.

From that time on, being received in her office overlooking the lake, chatting with her in the cafeteria or discussing in meeting rooms was a constant feature, a safe-harbour for lawyers from all sides. She was equally always available to assist researchers and students, eager to be introduced to this arcane word of which she was like an oracle hence the link with La Madonna). With her seriousness, competence, but also with a constant *sourire*and *une certaine légèreté* (hence the link with Monna Lisa and her enigmatic smile).

Her experience at the Legal Affairs Division was precious; she did not appear in a formal role but as “Counselor” and became in due time an *éminence grise*, even before liaising with the Division from the cabinet of DG Pascal Lamy. Add to this, her teaching at the University of Geneva and at the Graduate Institute and her lecturing around the word, at ease of course with French and English, coming as she does from Quebec.

By the way, this is the place to ask oneself how come all these Canadian lawyers found their way to in top legal positions within the WTO have been ladies: Debra Steger, first Director of the Appellate Body Secretariat; Valerie Hughes, who followed her (after the intermezzo of Peter van den Bosche and before the reign of Werner Zdouc), not to forget the multitasked Victoria Donaldson.

Coming back to Gabrielle, in view of her almost constant presence at 154 rue de Lausanne, it does not come as a surprise that when I joined the Appellate Body in 2001 (she was already a feature in the house) our encounters were frequent, of course if only social, besides in corridors and elevators, she at the second floor, me on the third one. I will not trace here the bio of Gabrielle. I will only focus on two key moments.

First, the conference in her honour at Université Laval in Quebec City in mid-September 2015, a very well-attended gathering. In a certain sense, she brought back thereby her experience and her Geneva world to her native town. I will not recall the conference itself, but rather her hospitality to a few friends-colleagues in the following weekend at her family`s wooden country house on the hill overlooking the estuary of the St. Laurent River. What a privilege to share with her mother and family the barbecue *en pleine air*. But the high point was the boat tour on the river itself, where it merges in big waves and strong currents into the deep bay. There, we could admire the dance of the whales, joyful in herds, maybe because they were aware that she was there, protecting them from hunting and hampering, thanks to the shield of Article XX (b) and (g) *GATT 1947*. Not so lucky were their cousins, the seals, whose protection, in the same Canada, has to compete with another non-trade value, that of the culture of traditional hunters.<fnref n="6" />

The other key feature was the publishing in 2015 by Cambridge, in its WTO series, of the seminal collective book which she edited not only painstakingly, but I would say with loving care: *A History of Law and Lawyers in the GATT/WTO*. An impressive book, which evolved out of a conference held in 2012 to celebrate the thirtieth anniversary of the establishment of the Legal Affairs Division. Forty-three dense contributions by key protagonists of the legal developments at 154 rue de Lausanne, since the initial steps, from Frieder Roessler’s small first office, to the prominence of the legal dimension of the WTO Agreements and the blossoming of the dispute settlement system.

Looking backwards, one realizes that the emphasis of the book is on the central role of the panel phase of disputes and that of the Legal Affairs Division, an essential role notwithstanding the unwarranted criticism by some late-comers.<fnref n="7" /> An indispensable function which, thanks to being deployed under the radar, has shielded the Secretariat of the panels from the wrath of the US against that of the Appellate Body and its director.

This focus on the panel stage and the Legal Affair Division, notwithstanding that it includes several contributions by former and acting Appellate Body members in it, is contrary to the common wisdom of emphasizing the central role of the Appellate Body in the dispute settlement system, as concerns the legal interpretation of the WTO Agreements. In a way, the book was a response to and a completion of a previous collective volume in the same series: *The WTO at Ten: The Contribution of the Dispute Settlement System*.<fnref n="8" /> The focus on the role of panels in the 2015 book anticipated the current phase, where the WTO, in particular the dispute settlement system, manages to go on notwithstanding the difficulties caused by the absence of the appellate phase, due to the well-known blockage of the Appellate Body by the US.<fnref n="9" />

Ten years after this monumental work, we still expect a lot from Gabrielle. Her role as midwife for new generations of *aficionados* of the WTO legal system is not over.

<footnote n="1">John Howard Jackson, *World Trade and the Law of GATT. A Legal Analysis of the General Agreement on Tariffs and Trade* (Indianapolis: Bobbs-Merrill, 1969). In that very year I first met John in Brussels, having lunch together in a Café at the Grande Place, my former mentor at Columbia Law School, Richard Gardner, having made the connection.</footnote>

<footnote n="2">Shortly after I was appointed to the Appellate Body in 2001, at a conference at Georgetown University, a participant expressed his surprise at hearing that I had been appointed though I had not been a disciple of John at the University of Michigan (where he had taught from 1966 to 1997, before moving to Georgetown).</footnote>

<footnote n="3">Other evangelists followed in their steps: in North America, Michael Trebilcock, Joel Trachtman, Jim Bacchus, Bill Davey, Petros Mavroidis and Jennifer Hillman; in Europe, Thomas Cottier, Hélène Ruiz Fabri, Peter van den Bossche, Joost Pauwelyn and myself; in the Far East, Harry Gao. No Judas among them. The members of the Sanhedrin of the wicked ones, the persecutors of the apostles of the new and true doctrine, are rather to be found in Washington DC. The fight between the carriers of the Light (multilateralism, market access, non-discrimination) and the Princes of the Darkness (protectionism, unilateralism, power above the law) still rages and may rage for ever.</footnote>

<footnote n="4">Frieder Roessler, “The role of law in international trade relations and the establishment of the Legal Affairs Division of the GATT” in Gabrielle Marceau, ed, *A History of Law and Lawyers in the GATT/WTO: The Development of the Rule of Law in the Multilateral Trading System* (Cambridge: Cambridge University Press, 2015) 161.</footnote>

<footnote n="5">See Christian Joerges, Ernst-Ulrich Petersmann, *Constitutionalism, Multilevel Trade Governance and International Economic Law* (Oxford: Hart Pub, 2011); Marise Cremona et al, *Reflections on the Constitutionalisation of International Economic Law: Liber Amicorum for Ernst-Ulrich Petersmann* (Leiden: Brill Nijhoff, 2014).</footnote>

<footnote n="6">*European Communities—Measures Prohibiting the Importation and Marketing of Seal Products* (2014), WTO Doc WT/DS400/AB/R (Report of the Appellate Body), online: <docs.wto.org> [perma.cc/9TLP-FS3S].</footnote>

<footnote n="7">Joost Pauwelyn & Krzysztof Pelc, “WTO Rulings and the Veil of Anonymity” (2022) 13:2 Eur J Intl L 527.</footnote>

<footnote n="8">Giorgio Sacerdoti, Alan Yanovich and Jan Bohanes, *The WTO at 10: The Contribution of the Dispute Settlement System* (Cambridge: Cambridge University Press, 2006).</footnote>

<footnote n="9">Giorgio Sacerdoti, Niall Moran, *International Trade and Investment Dispute Settlement: From Rise to Crisis and Reform*, (Abigdon and New York: Routledge, 2025).</footnote>