The above notwithstanding, the fil ing deadline for an appeal filed by WADA  shall be the later of:   (a) Twenty -one (21) days after the last day on which any other party having a right to appeal could have appealed, or    67  [Comment to Article  13.3: Given the different circumstances of each anti -doping rule violation investigation and Results Management process, it is not feasible to establish a fixed time period for ITTF  to render a decision before WADA may intervene by appe aling directly to CAS.