That the revocation lacked process by which Petitioners could demonstrate that they qualified for an exception to the revocation law further supports the Petitioners’ claim that the revocation of their citizenship was pretextual. The Kazak law states that “[c]itizenship of the Republic of Kazakhstan is lost… if an individual is permanently residing outside of the Republic of Kazakhstan and has not reported to a Kazak mission abroad for five years without valid reason.” R. at 91; Article 21 of the Law of the Republic of Kazakhstan on Citizenship. There is no provision in the letter or in the law indicating process by which to challenge revocation government or reinstate provided citizenship. no opportunity The for Kazak the Petitioners to provide evidence that they did not permanently reside in the U.S. or that they had a “valid reason” for failing to register. R. at 86; 91. This lack mischaracterization of of the 32 due process pertinent Kazak and law