FDI 2023 Problem

FDI Moot™ CENTER FOR INTERNATIONAL LEGAL STUDIES
FDI MOOT CASE 2023
FOREIGN DIRECT INVESTMENT

INTERNATIONAL ARBITRATION MOOT
Global Orals: 2-5 November 2023
The 2023 case was elaborated by the Case Committee consisting of Vera
Bykova, Facundo Marcone, Alisa Protasova, Ewa Tokarewicz, and Mishael M.
Wambua, under the supervision of the FDI Moot’s Review and Advisory Boards.
TABLE OF CONTENTS
REQUEST FOR ARBITRATION ................................................................................................ 1

CLAIMANT’S EXHIBIT C1 - Blueprint of the MK-1 Beetle - Modular UGV .......................... 9
CLAIMANT’S EXHIBIT C2 - Blueprint Variants of the MK-1 Beetle - Modular UGV .......... 10
CLAIMANT’S EXHIBIT C3 - Claimant’s Tax Compliance Certificate ................................... 11
CLAIMANT’S EXHIBIT C4 - Purchase Agreement of 8 June 2021......................................... 12
CLAIMANT’S EXHIBIT C5 - Law Decree 134_2022 on Restrictive Measures against the
Federation of Albion ................................................................................................................... 14
CLAIMANT’S EXHIBIT C6 - MK Robotics Press Release of 16 January 2021 ...................... 18
CLAIMANT’S EXHIBIT C7 - Model of the end-user compliance statement included in MK
Robotics purchase agreements as of 20 January 2022 ................................................................ 20
CLAIMANT’S EXHIBIT C8 - Twitter Statement of Head of Committee on International Trade
of 15 December 2022 .................................................................................................................. 21
CLAIMANT’S EXHIBIT C9 – Martineek Herald Article of 19 December 2022...................... 22
CLAIMANT’S EXHIBIT C10 - Asset Purchase Agreement of 24 December 2022 .................. 23
CLAIMANT’S EXHIBIT C11 - Investor News article of 24 November 2022 .......................... 28
RESPONSE TO THE REQUEST FOR ARBITRATION .......................................................... 29
RESPONDENT’S EXHIBIT R1 - Law Decree 53/2007 on the Control of Foreign Trade in
Defence and Dual-Use Material .................................................................................................. 35
RESPONDENT’S EXHIBIT R2 - Results of joint investigation on MK Robotics former owner
..................................................................................................................................................... 44
RESPONDENT’S EXHIBIT R3 - Young & Coopers Report of 20 December 2021................. 46
RESPONDENT’S EXHIBIT R4 - Global Armament Review- Inspecting Awbari drones: FTPG
Technology findings of 28 November 2022................................................................................ 49
RESPONDENT’S EXHIBIT R5 - VaryalëNews - Successful first flight of the Qertel-ASP UAV
of 27 November 2022.................................................................................................................. 54
RESPONDENT’S EXHIBIT R6 - VaryalëNews - UGVs shape modern warfare in the Wadaihi-
Karamanlean conflict: the “Beetle War” of 14 January 2022 ..................................................... 56
RESPONDENT’S EXHIBIT R7 - Minutes of the Parliament meeting of 23 December 2022 .. 59
RESPONDENT’S EXHIBIT R8 - Press Release of Parliament of Martineek of 27 December
2022 ............................................................................................................................................. 60
RESPONDENT’S EXHIBIT R9 - Statement of the Secretary of the Treasury Paul Bäumer of 30
December 2022 ........................................................................................................................... 61
PROCEDURAL ORDER NO. 1 ................................................................................................. 62
Letter of Resignation of Dumbledore, Black & Partners ............................................................ 68
Exhibit DBP_1 - Amnesty International Journal, Women’s Rights Worldwide: Newsflash, by
Fariba Adelkhah of 18 October 2023. ......................................................................................... 70
Exhibit DBP_2 - Narnian Arbitration Review, Dumbledore Black & Partners: the last global
law firm representing Martineek, by Cosmo Oberson of 25 October 2023 ................................ 71
2
Exhibit DBP_3 - Decision of the Council of the Narnian Bar Association No. 1228 of 12
October 2023 ............................................................................................................................... 72
Claimant’s Objections to Respondent’s Counsel Resignation ............................................ 74
Respondent’s Letter Concerning the Counsel Resignation ......................................................... 76
PROCEDURAL ORDER NO. 2 ................................................................................................. 78
Statement of Uncontested Facts .................................................................................................. 81
AGREEMENT ON ENCOURAGEMENT AND RECIPROCAL PROTECTION OF
INVESTMENTS BETWEEN THE REPUBLIC OF MARTINEEK AND THE FEDERATION
OF ALBION................................................................................................................................ 87
3
THE INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES
REQUEST FOR ARBITRATION
In a dispute between
DELOREAN TECHNOLOGIES LLC

(Claimant)
and
THE REPUBLIC OF MARTINEEK

(Respondent)
20 April 2023
Claimant Counsel for Claimant

DeLorean Technologies LLC Adila LLP
112 Charles Street, Medtown, Anasa Plaza, 311 Bond Avenue
ME 2231 KJ 8972
Federation of Albion Federation of Albion
1
I. SUBMISSION OF THE DISPUTE TO ARBITRATION
1. In accordance with Article 36 of the Convention on the Settlement of Investment Disputes

between States and Nationals of Other States (the “ICSID Convention”) and Article 12 of the
5 Agreement on Encouragement and Reciprocal Protection of Investments between the Republic
of Martineek and the Federation of Albion (the “BIT”), DeLorean Technologies LLC
(“Claimant”) hereby respectfully submits this Request for Arbitration (the “Request”) to the
International Centre for the Settlement of Investment Disputes (“ICSID”), to initiate the
following arbitration against the Republic of Martineek (“Martineek” or “Respondent”).
10
II. THE PARTIES
2. Claimant, DeLorean Technologies LLC, is a multinational automotive manufacturer

incorporated under the laws of the Federation of Albion (“Albion”). Claimant is the leading
15 automotive company in Albion – and one of the largest in the world. DeLorean Technologies
LLC is primarily engaged in the manufacture and distribution of automotives but has a wide
business portfolio and interests that go beyond automotive manufacturing and distribution.
3. Claimant notifies the Secretary-General that as contemplated by Rule 2 of the ICSID Arbitration
Rules, the following advocates shall represent Claimant:
20 Adila LLP
Anasa Plaza, 311 Bond Avenue
KJ 8972
Federation of Albion
25 4. Claimant respectfully requests that all communications in this arbitration be channelled through
its advocates.
5. Claimant has provided the Minister of Justice and Minister of Foreign Affairs of Respondent
with advance courtesy copies of this Request.
30 III. SUMMARY OF THE DISPUTE
a) Claimant’s investment
6. A raft of major reforms in Martineek in 1993 not only improved Respondent’s legal framework
for economic and social development, but also allowed Martineek to emerge as a global leader in
2
35 the robotic industry.
7. Over the last decade, to raise its global competitiveness and drive its digital manufacturing,
Respondent made significant efforts to attract foreign investments in the robotics industry. The
endorsement of FDI priority spheres, as well as the revision of the investment agreements with
third states resulted in one of the most investor-friendly regimes for investments in technical
40 innovations.
8. Keen to ride this investment wave, Claimant acquired 100% percent of the issued and
outstanding shares of MK Robotics, a Martineekean company focused on the development of
autonomous vehicles on July 9, 2020. MK Robotics was a leading start-up company in robotic
innovation in Martineek specialized in unmanned ground vehicles for civilian and commercial
45 use.
9. MK Robotics needed capital to expand its industries and grow. Thus, the acquisition by
Claimant had a positive impact on the development of its business. Another benefit derived from
this strategic acquisition was the development of business relationships between Respondent and
other companies in Albion.
50 10. The prime product of MK Robotics was the remotely operated MK-1 “Beetle” modular
unmanned ground vehicle (“MK-1 UGV”).1 The modular characteristic allowed the vehicle to
adapt to user-needs, thus providing flexible solutions for the commercial and public service
sector ranging from civil engineering to fire and rescue applications.2 This proficiency was
enabled by the sophisticated technological specifications that allow for modification of the
55 MK-1 UGV through attachment of tools or equipment in order to complete task-specific
commands. Given the wide-range of task-specific commands that the MK-1 UGV can complete,
attachments were sold on-demand, based on customer tastes and preferences, with it. The
principal attachments sold were for surveillance, civil engineering, mining, transport, fire
and rescue, and hazardous materials handling.
60 11. Claimant invested significant resources in research and development to expand further uses of its
technology in areas such as space exploration. Access to the Albionese market increased the
annual sales of MK Robotics by 25%. In the following quarterly earnings call presentations of
2020, MK Robotics reported a considerable growth in earnings due to the more than 200
unmanned ground vehicles sold.
65 12. Respondent not only considered Claimant to have made a valid investment but also considered
Claimant to be a trusted business partner. Claimant’s business activities were audited by
1
Exhibit C_1 - Blueprint MK-1 Beetle - Modular UGV.
2
Exhibit C_2 - Blueprint Variants of the MK-1 Beetle - Modular UGV.
3
Respondent’s tax authorities, which certified that Claimant complied with its fiscal obligation.3
Moreover, as part of its business activities, Claimant entered into several commercial sale
agreements with Respondent or its agencies, such as the sale agreement of commercial drones4
70 Yet, Respondent then turned around when the relationship was no longer beneficial to it.
b) Respondent’s measures towards Claimant’s investment
13. Despite an already broad catalogue of internal laws and regulations relating to operations such as
those conducted by Claimant, starting in 2022, Respondent started to introduce new regulatory
75 measures, which began to impact Claimant’s operations negatively.
14. In February 2022, Respondent issued Screening Law 24/2022 (“Screening Law”) identifying
critical technology, biomedicine, and dual-use military items as sectors of strategic importance
and imposing screening procedures for FDIs in these sectors. Claimant complied with the
Screening Law’s notification requirement and provided all necessary information about its
80 investment in MK Robotics.
15. Also in February 2022, Martineek enacted Ordinance 66/2022, modernising Law 53/2007
(“Dual-Use Regulation”), which included under the dual-use classification certain unmanned
vehicles and certain equipment and components related to unmanned vehicles.
16. Most of Claimant’s products were subject to the dual-use regime; some were not and did not
85 require an authorization. Thus, Claimant initiated the filings to obtain authorizations and
consultations to comply with the regime, for example, for the MK-1 UGV.
17. However, Respondent’s regulatory spree did not end in February 2022. In December 2022,
despite the positive impact of Claimant’s investment on Respondent’s robotics industry, citing
concerns related to Albion’s obtainment of critical technology as well as the emergence of
90 information about the use of technologies manufactured in members of the Future Technology
Partners Group (“FTPG”) in military conflicts, Responded introduced a new sanctions regime
with Law Decree 134/20225 freezing Claimant’s assets and prohibiting principal business
operations of MK Robotics as a manufacturer of dual-use goods. This was done in disregard of
Claimant’s policy of only producing vehicles and electronic components for commercial and
95 civilian purposes.
18. Among the reasons on which Responded relied in imposing sanctions were the alleged
involvement of Claimant in the “Albion first” strategy, disfavoured by Respondent.
3
Exhibit C_3 - Claimant’s Tax Compliance Certificate.
4
Exhibit C_4 - Asset Purchase Agreement of 8 June 2021.
5
Exhibit C_5 - Law Decree 134/2022 on Restrictive Measures against the Federation of Albion.
4
Additionally, Respondent also cited the past use of the Beetle vehicle in the Wadaihi-
Karamanlean conflict and the use of Claimant’s electronic components in some drones
100 manufactured in Karamanli. Respondent’s reasoning is misleading and incorrect.
19. Firstly, Albion’s development of the “Albion First” program and its strategy to improve its
future technologies sector does not have any relation to Claimant’s activities. Investors’ rights
under the BIT cannot be affected by the political or diplomatic relations between the two States.
20. Secondly, and in any case, Respondent’s concerns as to technology linkage backed-up
105 by “Albion First”, as indicated in the Sanctions Law, lack evidentiary bases. Moreover,
following the adoption of the Screening Law and Claimant’s provision of all relevant
information about its investment, the authorities of Martineek did not show any concern related
to Claimant’s investment.
21. Thirdly, regarding the use of the MK-1 UGV and the electronic components found in
110 Karamanlean drones, Claimant complied with Respondent’s Dual-Use Regulation. Claimant
obtained the licenses for the export of several components as required by the regulation.
The components that Respondent referred to sanction Claimant were neither considered critical,
nor required an export license as determined by the Export Control Office.
22. Once it was publicly known that MK Robotics’ drones were used in military activities, Claimant
115 instructed MK Robotics to reject the misuse of its drones.6 Claimant made its best efforts
to avoid the misuse of its vehicles. MK Robotics implements a strict policy by contractual
commitments to prevent its products from being diverted to unauthorized military use.7
It is regrettable that those components were used for military purposes, but Claimant cannot be
held liable if buyers of its components illicitly resell the goods or misuse them.
120 23. Finally, the real motives of Respondent’s measures towards Claimant and the rupture of trade
relations with Albion as its biggest trading partner remain unclear. After years of Martineek's
reliance on open markets and on foreign investment to keep expanding its high-tech industry,
Albionese high-tech companies have become powerful direct competitors for Respondent’s
national enterprises: “national interests” may merely serve to aid Martineek industries that are
125 falling behind.
c) Consequences of Respondent’s measures
24. Starting in December 2022, the reports of possible sanctions became frequent and vastly
6
Exhibit C_6 - MK Robotics Press Release of 16 January 2022.
7
Exhibit C_7 - Model of the end-user compliance statement included in MK Robotics purchase
agreements as of 20 January 2022.
5
impacted the market. While many companies, including Claimant, were closely monitoring the
130 situation, on 15 December 2022 these concerns were voiced by Respondent’s official -
Mr. Organa, a very influential politician of Nation’s Voice party and Head of the Committee on
International Trade.8 His statement, urging Martineek’s government to impose sanctions, caused
big waves in the industry. Moreover, respectable newspapers such as Martineek Herald reported,
that the plans for the decisions on sanctions were also confirmed independently by another
135 influential politician of Nation’s Voice, who intends to remain anonymous.9 Claimant, aware of
Respondent’s plans to freeze the assets of the sanctioned companies, as voiced by Mr. Organa,
attempted to sell most of its assets before they would be blocked or severely decrease in value.
Other impactful companies in Martineek also sold their assets as soon as Mr. Ortega’s statement
went public.10
140 25. On 20 December 2022, Claimant invited bids for the assets to be sold. However, as the whole
market already knew about the planned sanctions, the offers received from private companies
were vastly lower than the actual market price of the assets.
26. Being forced to save as much of its investment as possible before it was completely destroyed
by Respondent, Claimant reluctantly decided to sell the drone branch of its Company amounting
145 to 70% of the assets, for a purchase price of $25.480.000,00,11 amounting to a 60% discount
in relation to its market value as of 20 November 2022.12
27. In January 2023, Claimant filed an official request to the Martineek government asking for
concrete reasons for its inclusion on the sanctions list and demanding that Respondent unblock
Claimant’s assets. After receiving a response that this information could not be disclosed for
150 national security reasons and after four months of fruitless discussions, Claimant submits this
request for arbitration.
28. Claimant seeks damages in the amount of the difference between the amount Claimant received
for the sale of its sold assets and their market value estimated as of 20 November 2022, together
with pre-award and post-award interest at a rate to be determined, as well as any taxes payable
155 on the awarded amount, fulfilling line with the full reparation principle.
IV. JURISDICTION OF THE ARBITRAL TRIBUNAL
8
Exhibit C_8 - Twitter Statement of Head of Committee on International Trade of 15 December 2022.
9
Exhibit C_9 - Martineek Herald’s Article of 19 December 2022.
10
Exhibit C_9.
11
Exhibit C_10 - Asset Purchase Agreement of 24 December 2022.
12
Exhibit C_11 - Investor News article of 24 November 2022.
6
29. Article 25(1) of the ICSID Convention provides that:
160 “The jurisdiction of the Centre shall extend to any legal dispute arising directly out of an
investment, between a Contracting State (or any constituent subdivision or agency of a
Contracting State designated to the Centre by that State) and a national of another Contracting
State, which the parties to the dispute consent in writing to submit to the Centre. When the parties
have given their consent, no party may withdraw its consent unilaterally.”
165 30. Both Martineek and Albion are Contracting States to the ICSID Convention having acceded to
the Convention in February and June 1993 respectively, and Claimant is a national of Albion.
31. In early 2013, Martineek and Albion ratified the BIT on 28 June 2013.
32. By submitting this Request for Arbitration, Claimant accepts Respondent’s standing offer to
arbitrate made in Article 12(c) of the BIT:
170 Article 12
2. In the event that such dispute cannot be settled as provided for in paragraph 1 of this Article
within three (3) months from the date of a written application for settlement, the investor in
question may submit at its choice the dispute for settlement to one of the following fora:
[...]
175 c. the International Centre for Settlement of Investment Disputes (ICSID), for the implementation
of an arbitration procedure, under the Washington Convention of 18 March, 1965, on the
Settlement of Investment Disputes between State and National of other State, if this had entered
into force for both of the Contracting Parties to the dispute, or, alternatively, in accordance with
the ICSID Additional Facility Rules, if the Washington Convention has entered into force only
180 for one the Contracting Parties.
V. REQUEST FOR RELIEF
33. In light of the foregoing, as a preliminary indication of the relief sought, Claimant asks that the
185 Arbitral Tribunal:
i. DECLARE that the Sanctions Law is in violation of Article 5 of the Agreement on

Encouragement and Reciprocal Protection of Investments between the Republic of
Martineek and the Federation of Albion;
ii. ORDER Respondent to pay Claimant damages in the amount of the market value of its
190 frozen assets estimated as of 20 November 2022 and the difference between the payment
received for the sale of its sold assets and their market value estimated as of 20
November 2022, together with pre-award and post-award interest at a rate to be
determined, as well as any taxes payable on the awarded amount;
iii. ORDER Respondent to bear the costs of these arbitration proceedings;
195 iv. ORDER any other appropriate relief that may be deemed proper in serving the ends of
justice.
34. Claimant hereby respectfully reserves its right to subsequently amend or supplement the reliefs
7
sought in this trial up to and including the oral stage.
200 VI. CONSTITUTION OF THE TRIBUNAL
35. Pursuant to Article 11 of the BIT, and Article 37 of the ICSID Convention, Claimant requests
ICSID to appoint a tribunal of three (3) arbitrators. Accordingly, Claimant herewith appoints, as
one of the arbitrators:
205 Tamara Guterman

KJ 8973
Tokata, Atlandia
210 36. In light of the above, DeLorean Technologies LLC respectfully requests the Secretary-General to
register this Request for Arbitration against the Republic of Martineek pursuant to Article 36(3)
of the ICSID Convention.
215
On behalf of Claimant
attn. Martha Black
***
220
8
CLAIMANT’S EXHIBIT C1 - Blueprint of the MK-1 Beetle - Modular UGV
9
CLAIMANT’S EXHIBIT C2 - Blueprint Variants of the MK-1 Beetle - Modular UGV
10
CLAIMANT’S EXHIBIT C3 - Claimant’s Tax Compliance Certificate

MARTINEEK For General Tax Questions
M REVENUE AND Contact MRAC Call Centre
CUSTOMS Tax Compliance Certificate Tel: +2x1 (020) 4999 854
CA AUTHORITY Cell: +2x1(0711)099 253
www.mrac.go.me Email: [email protected]
Taxpayer PIN : P011737492W Certificate Date: 31/12/2022

Name and Address :
DeLorean Technologies LLC Certificate Number:

112 Charles Street, Medtown, MRACWON1314743512
ME 2231
225 This is to confirm that DeLorean Technologies LLC, Personal

Identification Number P011737492W has filed relevant tax
returns and paid taxes due as provided by Law.
This Certificate will be valid for twelve (12) months up to
31/12/2023.
230
235 This certificate is issued on the basis of information available with the authority as at the
Caveat: This certificate is issued on the basis of information available with the authority as
at the certificate date mentioned above. The Authority reserves the right to
withdraw the certificate if new evidence materially alters the tax compliance status
of the recipient.
240 Disclaimer : This certificate is system Generated and therefore does not require signature. You may confirm validity of
this certificate on the iTax Portal by using the TCC Checker. This certificate confirms your compliance status
for a period of five years preceding the date of issue. The certificate may however be with withdrawn on
grounds of outstanding debt affecting periods prior to this.
11
245 CLAIMANT’S EXHIBIT C4 - Purchase Agreement of 8 June 2021
Agreement for Sale

PARTIES:
Seller
Name: DELOREAN TECHNOLOGIES LLC
Legal form: LIMITED LIABILITY COMPANY
Country of incorporation and register number: ALBION A.77892l
Address: l I2 Charles Street, Medtown, ME 223i Federation of Albion.
Represented by: Abdalla Mashaka, Director.
Buyer
Name: REUBLIC OF MARTINEEK

Legal form: GOVERNMENT
Country of incorporation and register number: N/A
Address: Ministry of Interior and National Administration of the Govemment of Martineek
Oloitoktok Road, Govemment Lane, 5 3841, Siaya, Martineek
Represented by: Mzilikazi Msinzi, Director.
Hereinafter: “the Parties”
l. Goods
1. Subject to the terms agreed in this contract, the Seller shall deliver 20 MK-I MODULAR
VEHICLES (“BEETLES”) (hereinafier: “the Goods”) to the Buyer.
2. Description of the Goods:
Colou r Red
Technology specifications [m'emwna”y Ommedl
special Feature [intentionally omitted]
(attachments)
Brand [intentionally omitted]

Connectivity Technology [intentionally omitted] _
Model Name M428fdw ‘

3. Quantity of the Goods: TWENTY (20)
4. Inspection of the Goods:
Organisation Responsible [intentionally omitted]
Inspection Quamy and [intentionally omitted]
Quantity
Place [intentionally omitted]
A l-Q.
12
Date ] Upon delivery
2. Delivery
[ intentionally omitted]
3. Price
[intentionally omitted]
4. Payment conditions
5. Documents
6. Non-performance of the Buyer’s obligation to pay the price at the
agreed time
7. Non-performance of the Seiier’s obligation to deliver the Goods at
the agreed time
8. Lack of conformity
9. Transfer of property
10. Avoidance of contract
I l. Force majeure
12. Entire agreement
13. Notice
l4. Dispute resolution procedure
15. Applicable law and guiding principles
Buymt>Q€F\iB.Ltr °-t’ Vfilwetl Se||e,,Q;].Q[gqg'__]fl"lfl0]fll6.S LLC
Date: Date: O8 “Igor, "393!
Q§{;,,,e, ‘/EILIIIB-7-I ]—€v~t7.| A]3jgl|q
Signatu ' ‘ Signature:

t1i"f~
2
13
CLAIMANT’S EXHIBIT C5 - Law Decree 134_2022 on Restrictive Measures against the

250 02.01.2023 Official Journal of the Republic of Martineek L 675
LAW DECREE 134/2022
of 30 December 2022
ON RESTRICTIVE MEASURES AGAINST THE FEDERATION OF ALBION
255 THE PRESIDENT OF THE REPUBLIC OF MARTINEEK,
Having regard to the joint understanding of the Heads of Future-Technology Partners

Group (“FTPG”) reached during the extraordinary meeting, which was held on 2 December
2022,
Having regard to the agreement reached at the Parliament’s session on 26 December 2022,
260 Finding the Albion is increasingly exploiting Martineek’s capital and resources to be further
used in military conflicts, including through the “Albion first” national strategy of obtaining
Martineek’s technologies,
Considering this to be a threat to peace and security in the region, as well as to national
interests, foreign policy, and economy of the Martineek,
265 Recalling that FTPG States have been called upon to apply enhanced due diligence and
effective countermeasures to protect their jurisdictions from the Albion illicit activity,
Encouraging FTPG States to adopt restrictive measures similar to those provided for
herein, in order to maximize their impact,
Respecting the right to an effective remedy and fair trial, the right to property, and the right
270 to the protection of personal data,
HAS ADOPTED THIS LAW DECREE:
Article 1
1. It shall be prohibited to directly or indirectly sell, supply, transfer or export to Albion

arms and related material of all types.
14
275 2. It shall be prohibited to engage in any transactions related to direct or indirect sale,
supply, transfer, or export of dual-use items for military use or to military end-users
originating in FTPG States, as well as technologies and data on components used in such
items, with a legal person, entity or body owned or controlled directly or indirectly by
Albion nationals or entity established in Albion.
280 3. It shall be prohibited to provide technical or financial assistance related to goods and
technology set out in paragraph 2.
Article 2
1. The purchase or sale of provision of investment services for or assistance in the

issuance of, or other dealings with, “transferable securities” or money-market
285 instruments with respect to legal persons or entities listed in Annex I or persons or
entities acting on their behalf or at their direction shall be prohibited.
2. Transactions made by Martineek citizens or in Martineek are prohibited if they involve

transferring, paying, exporting, withdrawing, or otherwise dealing in the property or
interests in property of an entity or individual listed in Annex I.
290 Article 3
1. The funds and economic resources owned or controlled by any natural or legal person
listed in Annex I shall be frozen.
2. The frozen assets shall include but not be limited to: (1) financial assets, including
payment instruments, deposits with financial institutions, balances on accounts,
295 publicly and privately traded securities and debt instruments, including stocks and
shares, interest, dividends or other income on or value accruing from or generated by
assets, credit, claims on money, performance bonds, documents showing evidence of an
interest in funds or financial resources; (2) assets of every kind, whether tangible or
intangible, movable or immovable, which are not funds but may be used to obtain funds,
300 goods or services (i.e. economic resources).
3. Property and interests in property of individuals or entities directly or indirectly owned

by one or more targeted persons are considered blocked.
4. By way of derogation from paragraph 2 and 3 the competent authorities, may authorize
the release of certain frozen funds or economic resources, if such funds or economic
305 resources are:
a. necessary to satisfy the basic needs
15
b. intended exclusively for payment of reasonable professional fees or

reimbursement of incurred expenses associated with the provision of legal
services
310 c. intended exclusively for payment for routine holding or maintenance of frozen
funds or economic resources
d. from an account of a diplomatic or consular mission or an international

organization
Article 4
315 1. The measures imposed by Article 1(2) and Article 1(3) should not affect the exports of
dual-use goods and technology for non-military use and/or for non-military end-users.
2. Notwithstanding the prohibitions on the transactions listed in Article 1(2)(3),

Martineek’s Sanctions Review Board may authorize certain transactions provided that:
a. contracts for delivery of such items, technologies or assistance include

320 appropriate end-user guarantees; and
b. Albion has committed not to use or transfer such items, technologies or

assistance for military advancement.
Article 5
1. For the purposes of this regulation, (a) “Ownership” implies possession of more than
325 50% of the proprietary rights in a legal person or entity or having majority interest in it;
(b) “Control” implies having the right or exercising the power to appoint or remove a
majority of the members of the administrative, management or supervisory body of
legal person or entity; having the right to exercise a dominant influence over a legal
person or entity; controlling alone a majority of shareholders’ or members’ voting rights
330 in that legal person or entity.
Article 8
1. The measures referred to in this Law Decree shall be reviewed at regular intervals and
335 at least every 12 months.
Article 9
16
1. This Law Decree shall enter into force on the date of its publication in the Official
Journal of the Republic of Martineek.
340
The President of the Republic of Martineek,
Erich Paul Remark
REPLIBI(I)%
I\»'IAR'I"I N E E K
ANNEX I
[excerpt]
IDENTIFYING DATE OF
NAME REASONS
INFORMATION LISTING
[…]
13. DeLorean Technologies 112 Charles Street, Involvement in 30.12.2022

LLC Medtown, ME 2231 the “Albion First”
program;
Federation of
Involvement of the
Albion
Beetle vehicle in
the Wadaihi-
Karamanlean
conflict; export of
electronic
components that
were used to craft
military drones
[…] […] […] […] […]
345
17
CLAIMANT’S EXHIBIT C6 - MK Robotics Press Release of 16 January 2021
$1 -T MK HlZJE5lIJTlt3E5
350
é-t;""b.1
MK Robotics repudiates the involvement of the MK-1 Modular Vehicle in military
conflicts
MK Robotics recognizes the importance of sincere and fair information disclosure, and
fulfils its responsibilities to investors, analysts and stakeholders. The company also
355 understands the necessity of establishing long-term relationships of trust, and of
earning the trust and esteem of its customers, partners and governments. To achieve
these goals, the MK Robotics continuously provides all information it deems essential.
We are grateful for the success of our project and to be recognized as a global leader
in the development of unmanned ground vehicles. This achievement was only possible
360 due to the faith of our developers, partners, stakeholders and to our customers that
purchased our vehicles and are confident with our brand.
Our mission is to provide innovative solutions for challenging environments. Our

drones are made to fulfil a higher purpose – to improve lives. Despite our goal to
develop products for commercial and civil purposes, it is a regret that our vehicles are
365 being used in international armed conflicts. Particularly, the MK-1 modular vehicle,
also commonly known as the “Beetle”.
The Beetle vehicle is particularly popular overseas, and we are concerned about the
flow of vehicles from Martineek to overseas immediately after their release due to the
possibility of them being exported to certain regions where security regulations are in
370 place. We believe there is a risk of violating foreign law, and depending on the export
destination, it may lead to major problems that threaten global security.
Although it is impossible for the company to control indirect or illegal channels

through which our vehicles could be misappropriated, stolen or re-sold by
independent third parties, MK Robotics will make its best efforts to avoid the misuse of
375 its vehicles. We are committed to complying fully with the laws and regulations of each
country or region where we operate, and require our dealers and distributors to do the
same.
Procedures and contractual commitments will be added to prevent our products from
being diverted for unauthorised military use. MK Robotics decides to implement a
380 strict policy to not sell its unmanned vehicles to potential purchasers who may use or
modify them for military activities. Further, MK Robotics will implement a new policy
that buyers of the MK-1 modular vehicle have to sign a contract promising not to resell
the vehicle within a year. Dealers will be required to pay damages if their customers
resell Beetles.
385 MK Robotics will support inquiries into international supply chains and the flow of
capital and goods to controversial conflicts.
18
Hereby, MK Robotics states that its operations follow the principles of continuous
improvement and respect for humanity. These principles boost productivity and foster
innovation. We want to lead the future, enriching lives around the world. We are
390 committed to quality, ceaseless innovation, and to the protection of global welfare. We
will meet challenging goals by engaging the talent and passion of people who believe
there is always a better way.
We settled the following key elements of our corporate vision that reflect the future
strategic direction of the business:
395 I. Respect for the value of human life as top priority

II. Global leadership in the civil and commercial use of unmanned drones
III. Exceptional quality, innovation, and respect for the planet
IV. Engagement with talented and passionate partners that share our principles
400 Contacts:
Media Relations Investor Relations
[email protected] [email protected]
For more information, please visit delorean-group.com
405
19
CLAIMANT’S EXHIBIT C7 - Model of the end-user compliance statement included in

MK Robotics purchase agreements as of 20 January 2022
[…]
4. The items described in Section B [(drone or electronic component) with model number
(serial number)] supplied or serviced, by MK Robotics to (name of client):
a. shall only be used for the purposes described in section B [End-Use (business type) –
(specific activity)] and that the items are intended for final use in the country named in
Section A4 [name of the country];
b. shall only be used for civil, public or commercial end-use;
c. shall not be used in any military activity or for military end-use;
[…]
e. shall not be used for any purpose connected with any illicit purposes, such as, but not
limited to, human rights violations;
[…]
5. Purchaser hereby agrees that it will not sell, offer to sell, or otherwise transfer any
ownership interest in the items prior to the first anniversary of the date hereof. Purchaser
further agrees that MK Robotics may seek injunctive relief to prevent the transfer of the
items or demand payment from Purchase of all value received as consideration for the
sale or transfer;
6. This End-User Statement shall be construed and enforced in accordance with the laws
of the State of Albion. The parties expressly agree that the UN Convention on the
International Sale of Goods shall not apply to this Agreement.
[…]
410
20
CLAIMANT’S EXHIBIT C8 - Twitter Statement of Head of Committee on International

Trade of 15 December 2022
Bail Organa 9
@BOrganaOfioia|
I'm so done with the diplomatic B.S. '.-' Nobody wants

to say it out loud but we should stop biting our tongues
Cause the writing is on the wall. Martins-ek should
impose sanctions ASAP as soon as possible and all
assets should be banned... There I said it!! '
Now get to work
3:04 AM ‘ Dec 15, 2022
32.4K Retweets 1.3K Quote Tweets 98.8K Likes
Q U, Q7 Iii
21
415 CLAIMANT’S EXHIBIT C9 – Martineek Herald Article of 19 December 2022
W ()L. XXIX N(). 83 MONDAY, DECEMBER 19, 2022
MARTINEEK HERALD
...is what happens currently on the market after a statement made by

Bill Ortega confirmed rumors circulating for the last weeks - the
sanctions are close and investors know it. But what can they do?
ll was a bold move by the Head oi‘ the

Committee on lnternational Trade. ln
a Tweet posted ycslcrday. Bail Ortega,
a prominent and influential politician
of Nation's Voice, confirmed long-
standing rumors of upcoming sanctions
on dual-use technologies branch,
causing a panic among investors on the
stock lnarket. The tweet sent
shockwaves throughout the financial
world as traders and investors
scrambled to react to the news.
The details of the sanctions have yet to

be released, but the mere confirmation
tech colnpan) in l\’la|'l.ineel<. Nlore colnpanies consider selling
of their existence has already had a
their assets in tear of sanctions, including such players as
significant impact on the market. Since
MK Robotics.
the statement of Urgana went public,
multiple companies are frantically The statement. of Ortega was issued after weeks of‘ investors,
selling their assets, leading to sharp market experts, and lawyers anticipating the possibility of
drops in value across various sanctions. Though no draft legislation was published yet. it
industries. The sudden influx of sell seelns that sanctions are inevitable now as illartineek Herald
orders has caused a volatile situation in received a confirmation of the plans for the decisions on
the stock market, as prices fluctuate sanctions from a different influential politician of Nation's
rapidly in response to the news. Voice. who intends to remain anonymous.
Among the companies that panic sell Ortega's words sparked intense speculation and concern
their assets are such technological among market analysts, who are now closely monitoring the
giants as Toleonio INC, J\\ianu Tech situation and trying to gauge the full impact that the
and men Bailc_y illolors — lhc biggest sanctions will have on the economy.
22
CLAIMANT’S EXHIBIT C10 - Asset Purchase Agreement of 24 December 2022
ASSET PURCHASE AGREEMENT

420
AMONG
MK ROBOTICS SRL
(SELLER)
Ag
425
AND
V
MIMIC TECH LLC
(BUYER)
430
DECEMBER 24, 2022
This Asset Purchase Agreement (“Agreement”) is made

and effective as of the 24 December 2022 (“Effective Date”)
435 by and between Mimic Tech LLC, with a principal address
of 28 Sykes Street, Waleston, WS 1032 Federation of
Albion (“Buyer”), and MK ROBOTICS SRL, with a principal
address of 09675 Fratti Street, 73 Republic of Martineek
(“Seller”).
440 WHEREAS, Buyer wishes to buy and Seller wishes to sell
Q
to Buyer the Assets (as hereinafter defined); and
WHEREAS, the parties wish to memorialize the terms and

conditions of the purchase and sale of the Assets in a
written agreement.
445
/‘$9 \
NOW, THEREFORE, for and in consideration of the terms
and conditions provided below and other good and valuable
consideration, the receipt and sufficiency of which is
hereby acknowledged, each of the parties hereto hereby
agree as follows:
450
1. Sale and Purchase of Assets. At the “Closing” as
hereinafter defined and subject to the terms and
conditions of this Agreement, Seller agrees to sell
Q
and Buyer agrees to purchase all of the following
455 assets related to the “MK-1 Beetle” manufacturing
branch owned by Seller as more specifically defined
below (collectively, the “Assets”):
23
(a) real property listed in Schedule 1 [not

reproduced for confidentiality reasons]
460 including buildings, structures, improvements
and fixtures located thereon;
(b) machinery, equipment, tools and other items as

listed in Schedule 2 [not reproduced for
confidentiality reasons];
Ag
465 (c) inventories and supplies of raw materials,
works-in-process, finished goods;
470
(d) rights and incidents as of the “Closing” in
(i) contracts for the purchase or sale, supply
or provision,
materials,
including
energy
of
operating,
merchandise,
supplies
land
or
steam,
services,
management
resource management; (ii) contracts for the
purchase or lease of equipment or computer
and
V
hardware; (iii) contracts relating to
475 franchise, distributorship or sale agency
Q$
arrangements; (iv) personal property leases;
(v) computer software licenses; (vii) all open
Q
purchase and sales orders;
(e) trade accounts and notes receivable arising

480 out of the sale or other disposition of goods
or services;
(f) deferred and prepaid charges;
(g) cash equivalents, letters of credit or other

forms of security used to secure workers’
485 compensation obligations.
2. Excluded assets. For greater certainty and

transparency, Seller and Buyer jointly confirm that
all assets, business lines, properties, rights,
contracts and claims of Seller or any Subsidiary,
490 including but not limited to the list below, are not
subject of the agreement and their ownership is not
transferred:
(a) manufacturing know-how employed by Seller,
including intellectual property licenses;
24
$1‘
495 (b) cash, cash equivalents, bank deposits, investment
accounts other than workers’ compensation security
V
referred to in 1(g);
(c) Seller’s right, title and interest in trademarks,

trade name, logos thereto, together with all
500 patents and invention records listed on Schedule 3
[not reproduced for confidentiality reasons];
(d) claims, defenses, causes of action, choses in

action or claims of any kind that are available to
or being pursued by Seller or any of its
505 subsidiaries whether as plaintiff, claimant,
counterclaimant or otherwise;
(e) books and records, files, papers, disks, plans,
$0?
catalogues, sales and promotional materials,
Q
supplier and customer lists, price lists,
510 historical research, environmental and engineering
data and all other printed and written materials
related to the Business.
(f) any other assets business lines, properties,

rights, contracts and claims of Seller or any
515 Subsidiary, unrelated to the “MK-1 Beetle”
manufacturing brunch owned by Seller.
This Agreement constitutes a sale of certain assets of

Seller only and is not a sale of any stock in any entity
comprising of all or any part of the Seller or a sale of
520 any assets not explicitly included in Schedules 1-3. Buyer
is not assuming and shall not be responsible for the
payment of any liabilities or obligations of the Seller or
the shareholders of Seller whatsoever, including but not
limited to any collective bargaining agreement or other
525 agreement, benefits, plans or arrangements affecting
employees or suppliers.
3. Purchase Price. Buyer shall pay the Seller, as the

total purchase price for the Assets an amount equal
530 to Twenty-Five Million Four Hundred Eighty
Thousand Dollars ($25.480.000,00) (“the Purchase
Price”). The Purchase Price shall be paid to Seller as
follows:
-$5.000.000,00 as a deposit paid on December 26, 2022
25
535 -$20.480.000,00 balance paid on January 31, 2023.
The balance of the Purchase Price shall be paid in

immediately available funds.
4. Closing. The consummation of the transaction described

540 in this Agreement (the “Closing”) shall take place on
or before December 24th, 2022, (the “Closing Date”),
at the principal business office of Buyer or Buyer’s
attorney or other designee, or on such other date and
location as shall be mutually agreeable to Buyer and
545 Seller. At the Closing, Seller shall evidence the
transfer of title of the Assets, and Buyer shall
deliver the Purchase Price as provided above.
550
5. Miscellaneous.
a. Casualty prior to Closing. If prior to Closing Date

any of the Assets shall be damaged by any casualty, the
555 Buyer shall have the option (i) of terminating this
Agreement without liability, or (ii) to waive diminution in
value and close under this Agreement, buying the Assets “as
is,” in which event the Buyer shall be entitled to receive
the proceeds of any insurance paid to Seller by reason of
560 such loss or damage.
b. Governing Law. This Agreement shall be construed

and enforced in accordance with the laws of the State of
Albion. The parties expressly agree that the UN Convention
565 on the International Sale of Goods shall not apply to this
Agreement.
c. Effect of Agreement. This Agreement sets forth the

entire understanding of the parties. It shall not be
570 changed or terminated orally. All the terms and provisions
of this Agreement shall be binding upon and inure to the
benefit of and be enforceable by the successors and assigns
of the parties.
575 d. Severability. If any provisions of this Agreement

shall for any reason be held invalid, then the invalidity
26
of such specific provision shall not be held to invalidate

any other provisions of this Agreement which shall,
therefore, remain in full force and effect.
580
§\/vv
e. Notices. Any notice or other communications
required or permitted hereunder shall be sufficiently given
if sent by hand delivery, facsimile transmission, overnight
V
mail or registered or certified mail, postage prepaid, with
585 return receipt requested, addressed as follows:
IN WITNESS WHEREOF, the parties hereto have duly executed

590 this Agreement on the date first above written.
BUYER
Mimic Tech LLC

595 an Albion Limited Liability Company
By: /s/ Kimberly Wexler

Name/Title: Kimberly Wexler/Manager
600 SELLER
Q
MK ROBOTICS SRL
\
a Martineek Limited Liability Company
605
Board QQO
By: /s/ Gustavo Fring
Name/Title: Gustavo Fring/Chairman of the
Q
27
610 CLAIMANT’S EXHIBIT C11 - Investor News article of 24 November 2022
STOCK MARKET
Investor News
MK Robotics’ valuation growing steadily after a

615 successful Q3
BEN SAVORY
10:11 AM ET 24/11/2022
The champagne has been popping in the MK Robotics’ headquarters as the recent
620 reports as of 20 November 2022 show that the projected profits of the iconic automotive
company are steadily growing after the successful third quarter. The current valuation of
MK Robotics’ is $91.000.000 with further expectations of increase in the upcoming
months.
According to recent financial reports, MK Robotics’ Q3 sales and profits have exceeded
625 expectations, with the company reporting a significant increase in both domestic and
international sales. This has led to a surge in the company’s stock price, with investors
taking notice of MK Robotics’ renewed success and strong financial outlook.
MK Robotics’ Q3 performance is being attributed to a number of factors, including the

company’s recent launch of a new commercial drone model, as well as securing several
630 contracts with state entities for the sale of their equipment.
"We are thrilled to see such strong growth in our business," said MK Robotics CEO
John Demarco. "We have always believed in the potential of our brand and our
products, and it's gratifying to see that belief being reflected in our financial
performance."
635 With its growing valuation and strong financials, MK Robotics’ is well-positioned for
continued success in the coming years. The company plans to continue investing in
research and development, as well as expanding its manufacturing capabilities, in order
to meet the growing demand for its automotives.
"We are excited to see where this growth takes us in the future," Demarco said. "We
640 look forward to continuing to innovate and push the boundaries of what’s possible in the
automotive industry."
28
THE INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT

DISPUTES
645
650 DELOREAN TECHNOLOGIES LLC
Vs.

655
_______________________________________________________________
RESPONSE TO THE REQUEST FOR ARBITRATION
5 June 2023
660 _______________________________________________________________
665
Respondent
Ministry of Justice of the Government of Martineek
Oloitoktok Road, Government Lane
5 3841,
670 Siaya, Martineek
Counsel for Respondent

Dumbledore, Black & Partners
675 1207, Kingdom of Narnia, Ville de la Liberté,
Chemin Ilya Yashin, 7
29
I. INTRODUCTION
680 1. This Response to Claimant’s Request for Arbitration (the “Response”), together with its
Exhibits, is submitted on behalf of the Republic of Martineek (“Respondent”).
2. In this Response, unless otherwise stated, Respondent adopts the abbreviations used in
Claimant’s Request for Arbitration. Unless otherwise stated, capitalized terms shall have the
meanings given to them in the Request.
685 3. Unless expressly admitted, each paragraph of the Request is denied by Respondent.
II. RESPONDENT’S POSITION ON JURISDICTION

4. Respondent respectfully submits that the Tribunal lacks jurisdiction to adjudicate this
dispute because Claimant has no protected investment under the BIT.
5. The parties to the BIT have explicitly conditioned the making of a legitimate investment
690 upon satisfaction of the legality requirement contained in the BIT. Thus, the investment shall
be made in accordance with all laws and regulations in force in the host state. It follows,
therefore, that absent fulfilment of this requirement, there shall be no legitimate investment
in a host state, and an arbitral tribunal shall lack the jurisdiction to entertain any claim
brought under such circumstances.
695 6. Claimant’s investment was not made in accordance with internal laws as it did not comply
with the authorisation requirement of the Dual-Use Regulation.1
7. Article 28 of the Dual-Use Regulation provides that:
Any natural or legal person who carries out the activities described herein,
shall apply for authorization of any transaction with a foreign person or
700 entity that results in a change in ownership or control of the company, or
transfer of assets as listed in paragraph 1 (a) of Article 2, to the Council of
Ministers before the transaction is made, along with any relevant
information on the proposed acquisition, the purchaser, and the scope of
operations.
705 8. The acquisition of 100% shares in Martineek company engaged in the exportation of several
dual-use items - MK Robotics, by Claimant’s company, was not authorized by the
government contrary to Article 28 of the Dual-Use Regulation.
9. The foreign investor shall adopt an adequate level of due diligence to ensure compliance
with host state laws while making the investment. In spite of this, Claimant did not conduct
710 any due diligence, ignoring a forged authorization to sell shares provided by the previous
owner of MK Robotics - Dr. Farnsworth. Claimant failed to perceive evidence of this serious
1
Exhibit R_1 - Law Decree 53/2007 on the control of foreign trade in defence and dual-use material.
30
misconduct: Dr. Farnsworth already had a criminal record for falsifying documents; no
authorisation record exists in official databases; the authority signing the authorization
decision never applied an electronic signature, as was stated in the document provided by
715 Dr. Farnsworth.2
10. Thus, Claimant’s investment was not made in accordance with the law of the host state, and
Claimant has no protected investment under the BIT.
11. Based on these grounds, the arbitral tribunal lacks jurisdiction to hear any dispute between
Claimant and Respondent or any complaints which Claimant purports to have in relation to
720 Respondent.
III. MERITS OF THE DISPUTE

12. Over the past two years, Respondent and its allies faced a twofold increase in investment
flows from companies incorporated in Albion, that are taking over innovative entities in the
field of technologies, pushing technology transfer, and obtaining cutting-edge technologies
725 and know-how, leading to public concerns. According to the results of the Young & Coopers
Report, Martineek’s economy is negatively affected by investments from Albion that sooner
or later will squeeze out other small shareholders in high-tech companies.3
13. Despite indeed welcoming the technological development initiative of Albion, the home
State of Claimant, the “Albion first” program raises concerns towards internal and
730 international stability of critical technologies linkages and the use of tech components of
FTPG companies in military conflicts. According to the Global Armament Review, several
Albionese companies acquired dual-use goods from FTPG’ companies that ended up in the
Avaikian Republic, an embargoed country.4
14. Further, these acquisitions of drone technology and components from FTPG’ companies
735 were affected at the same time that Albion launched its development of drones for defence.
Albion partnered in a joint military project with the Avaikian Republic and its companies for
the development of a military Unmanned Aerial Vehicle (“UAV”).5
15. Claimant’s investment manufactured dual-use goods that were used for military purposes.
The following actions purported under Claimant’s control of MK Robotics prove the
740 involvement of Claimant in business related to military goods.
2
Exhibit R_2 - Results of the Joint investigation on the MK Robotics former owner.
3
Exhibit R_3 - Young & Coopers Report of 19 December 2021, YC 15/2021.
4
Exhibit R_4 - Global Armament Review - Inspecting Awbari drones: FTPG Technology findings of 28
November 2022.
5
Exhibit R_5 - VaryalëNews - Successful first flight of the Qertel-ASP UAV of 27 November 2022.
31
16. Firstly, the use of the MK-1 UGVs in the Wadaihi-Karamanlean conflict. This event was so
impactful to the war theatre that the conflict was dubbed the “Beetle Wars”.6
17. Secondly, Claimant’s electronic components were used to manufacture UAVs used for
Awbari militias’ attacks.7 This is because of the spread and resale of drone components
745 produced in Martineek for the manufacture of UAVs in the Avaikian Republic. These trades
were conducted by Albionese companies that purchased the goods from MK Robotics and
Claimant.
18. While no sanctions were planned to be introduced by Respondent during most of December
2022, which is evidenced by the minutes of the Parliament’s Standing Committee on
750 National Defence of Martineek meeting on 23 December 2022,8 the situation changed just
two days later. On 25 December 2022, a drastic drone strike in the Wadai Sultanate killed 14
civilians and caused major injuries to over 50 people. The investigation launched on 26
December 2022 showcased that debris of FTPG tech components produced by Martineek
was present at the place of the strike. Urged by the public outcry and protests calling the
755 region to react, Respondent undertook measures to impose sanctions that were supposed to
limit the escalation of violence.
19. On 27 December 2022, at an extraordinary meeting of the Martineekean Parliament, it was

decided that sanctions were indeed necessary to stop technology linkage that was crucial for
the State’s national interests and to prevent its further use in military conflicts.9 By enacting
760 the Sanctions Law, Respondent imposed protective measures that are, by nature, not
supposed to deprive the targeted investor of its assets. The motivation for the sanctions was
expressed by the Department of the Treasury.10
20. Moreover, by recognizing the freedom of a State to protect its national interest, as indicated
in the BIT as well as in the Screening Law 24/2022 that identifies the high-tech sector as a
765 key strategic interest of the State, Respondent has the discretion to adopt measures to
prevent any threat to its national interests.
IV. ALLEGED DAMAGES

21. In response to Claimant’s compensation claims, Respondent strongly rejects any alleged
responsibility for Claimant’s financial incompetence. At the time of sale of assets, the
6
Exhibit R_6 - VaryalëNews Article “UGVs shape modern warfare in the Wadaihi-Karamanlean
conflict: the “Beetle War”of 12 January 2022.
7
Exhibit R_7 - Global Armament Review - “Inspecting Awbari drones: FTPG Technology findings” of
28 November 2022.
8
Exhibit R_8 - Minutes of the Parliament meeting of 23 December 2022.
9
Exhibit R_9 - Secretary of State’s Press Release of 27 December 2022.
10
Exhibit R_10 - Statement of the Secretary of the Treasury Paul Bäumer of 30 December 2022.
32
770 investment was not impacted by sanctions in any way, which were not even planned yet, as
evidenced by the official records.
22. Claimant’s involvement in the Wadaihi-Karamanlean conflict resulted in heated political

debate both in Albion and Martineek. Since the beginning of December 2022, multiple
politicians, journalists, and influencers have expressed their opinions on how the
775 governments should proceed. No government representative of Martineek has ever made any
statement regarding a possible course of actions, simply because no such plans were
considered up until 27 December 2022, where the sanctions were jointly proposed by
representatives from all parties in the Martineekean parliament.
23. However, as the media and the market are governed by their own rules, rumours continued
780 and other public figures spoke up. Amongst them were multiple politicians of both the ruling
and the opposition parties, presenting their own personal views. One of them was Mr. Bail
Organa, member of the Nation’s Voice party, who on 15 December 2022 supported the
vague idea of sanctions. However, as it was his own personal opinion, which he stated
clearly in a TV interview the next day, the statement was officially and loudly denounced by
785 the leader of the Nation’s Voice party, Mr. Howard Hamlin, on 17 December 2022 during a
press conference. Mr. Hamlin stated that “Mr Organa's statement was his own personal
opinion, currently the government does not plan to introduce any specific actions related to
sanctions”.
24. In any case, the statement of Mr. Organa was his own personal opinion not made in an
790 official governmental capacity and should not be attributed to Respondent itself.
25. The lack of any intention to introduce sanctions is evidenced by the minutes of the
Parliament’s Standing Committee on National Defence of Martineek meeting that took place
after Claimant sold its assets, on 23 December 2022. The minutes showcase that in response
to the question about possible sanctions asked by one of the members of the Parliament, the
795 Chair stated that “no sanctions or equivalent measures are being considered by the
Government and the Government’s stance on this matter had not change”.11
26. Despite Respondent’s efforts to limit misinformation, the false report of planned sanctions
circulated on the market, enabled by speculators and people hoping to create chaos. Their
actions resulted in Claimant following the speculations and going along with the rumours by
800 selling its assets on 25 December 2023.
27. Even if the Tribunal would find any liability on Respondent’s side, the market value of
Claimant’s investment should be valued at the time of the sale, being 25 December 2022.
11
Exhibit R_8.
33
Therefore, no compensation is due from Respondent in any case.
V. PROCEDURAL MATTERS
805 28. Respondent agrees that the Tribunal should consist of three arbitrators.
29. Respondent nominates Dr. Xenon Bloom to serve as an Arbitrator, whose details are as
follows:
Dr. Xenon Bloom,

Mart-Re House,
810 Kabarsiran Avenue,
9 2278,
Iten, Hans.
VI. RELIEF SOUGHT

30. Respondent respectfully requests the Arbitral Tribunal to:
815 i. DECLARE that the Tribunal lacks jurisdiction over the dispute because
Claimant does not have a protected investment under Article 9 of the BIT and
dismiss Claimant’s claims;
ii. In the event the Tribunal finds that it has jurisdiction over the dispute,
DECLARE that Respondent’s actions do not amount to expropriation of
820 Claimants’ investment within the meaning of Article 5 of the BIT and reject
Claimant’s claims;
iii. ORDER that even if the Tribunal deems Respondent liable for a breach of
Article 5 of the BIT, the relevant date of valuation of Claimant’s assets for the
purposes for establishing their fair market value is the date of the sale and with
825 regards to the assets that were not sold by Claimant, Claimant still remains their
sole owner, therefore no damages should be awarded; in any case no taxes
payable on the awarded amount should be awarded.
iv. ORDER Claimant to compensate all costs and fees incurred by Respondent in
relation to the proceedings.
830 31. Respondent reserves its right to further develop its arguments.
On behalf of Respondent
Advocate Dr. Zan Zendegi
34
835 RESPONDENT’S EXHIBIT R1 - Law Decree 53/2007 on the Control of Foreign Trade in
Defence and Dual-Use Material
29.12.2007 Official Journal of the Republic of Martineek L 425

840
LAW DECREE 53/2007
of 28 December 2007
ON THE CONTROL OF FOREIGN TRADE IN DEFENCE AND DUAL-USE MATERIAL
THE PRESIDENT OF THE REPUBLIC OF MARTINEEK,
845 Considering the necessity to bring its legislation into line on the external trade in defence
equipment and dual-use products and technologies,
Considering the increasing complexity of international trade in defence equipment and

dual-use products and technologies that makes it necessary for the public authorities to
take decisive action in order to respond effectively to the various aspects of concerns and
850 the various commitments that Martineek makes in this field,
Considering the political and social demand for control of the trade in defence material and
dual-use products and technologies,
Respecting the legitimate demands of legal arms trade, an element intimately linked to the
national defence and law enforcement activities and the fight against crime by
855 governments,
Recalling that Martineek has a duty to ensure that its exports are consistent with existing
commitments in accordance with international law and in a way that guarantees that such
exports do not promote the violation of human rights, fuel armed conflict or contribute
significantly to poverty,
860 Considering that the arms trade is increasingly globalised, including final assembly from
components produced in other countries, the delocalisation of final production, the
emergence of non-traditional exporting countries subject to fewer controls, the
proliferation in countries where human rights are not respected and which are subject to
arms embargoes, make it necessary for the international community to make an effort to
865 achieve effective control of the arms trade that is adapted to the new reality and the
establishment of international law standards.,
HAS ADOPTED THIS LAW DECREE:
35
Article 1
1. The purpose of this Law is to contribute to better regulation of the foreign trade in
870 defence material, and dual-use products and technologies, and other related material to
prevent their diversion to illicit markets and to combat their proliferation, while
complying with international commitments in this respect and guaranteeing the
general interests of national defence and foreign policy.
2. For these purposes, the Law regulates the control procedure for transfers of defence
875 material, dual-use products and technologies, other related material, including those
carried out in free zones and warehouses and the linking to the customs warehousing
regime, as well as brokerage, licensed production agreements and technical assistance.
3. The provisions of this Law shall apply to any natural or legal person who habitually or
occasionally carries out on the territory of the Martineek Republic the activities
880 described herein, in relation to the transfer of materials, products or technologies
subject to control.
Article 2
1. For the purposes of this Law, the following definitions shall apply:
a. ‘dual-use items’ means items, including software and technology, which can be
885 used for both civil and military purposes, and includes items which can be used
for the design, development, production or use of nuclear, chemical or
biological weapons or their means of delivery, as well as all items which can be
used for both non-explosive uses and assisting in any way in the manufacture
of nuclear weapons or other nuclear explosive devices;
890 b. ‘export’ means:
i. an export procedure within the meaning of Article 160 of the Customs Code;
ii. a re-export within the meaning of Article 161 of the Customs Code; or
iii. transmission of software or technology by electronic media, including by

fax, telephone, electronic mail or any other electronic means to a destination
895 outside the customs territory of Martineek; it includes making available in an
electronic form such software and technology to natural or legal persons or to
partnerships outside the customs territory of Martineek; it also includes the
oral transmission of technology when the technology is described over a voice
transmission medium;
36
900 c. ‘exporter’ means:
i. any natural or legal person or any partnership that, at the time when the
export declaration or the re-export declaration or an exit summary declaration
is accepted, holds the contract with the consignee in the third country and has
the power to determine the sending of the items out of the customs territory of
905 Martineek; where no export contract has been concluded or if the holder of the
contract does not act on its own behalf, exporter means the person who has the
power to determine the sending of the items out of the customs territory of
Martineek; or
ii. any natural or legal person or any partnership that decides to transmit
910 software or technology by electronic media, including by fax, telephone,
electronic mail or by any other electronic means to a destination outside the
customs territory of Martineek or to make available in an electronic form such
software and technology to natural or legal persons or to partnerships outside
the customs territory of Martineek. Where the benefit of a right to dispose of
915 the dual-use item belongs to a person resident or established outside the
customs territory of Martineek pursuant to the contract on which the export is
based, the exporter shall be considered to be the contracting party resident or
established in the customs territory of Martineek;
d. ‘technical assistance’ means any technical support related to repairs,

920 development, manufacture, assembly, testing, maintenance, or any other
technical service, and may take forms such as instruction, advice, training,
transmission of working knowledge or skills or consulting services, including
by electronic means as well as by telephone or any other verbal forms of
assistance;
925 e. […]
f. ‘individual export authorisation’ means an authorisation granted to one

specific exporter for one end-user or consignee in a third country and covering
one or more dual-use items;
g. ‘global export authorisation’ means an authorisation granted to one specific

930 exporter in respect of a type or category of dual-use items which may be valid
for exports to one or more specified end-users and/or in one or more specified
third countries;
37
Article 3
1. An administrative authorisation shall be required for the export of dual-use items

935 listed in Annex I.
2. Pursuant to Article 4, 5, 9 or 10, an authorisation may also be required for the export to
all or certain destinations of certain dual-use items not listed in Annex I.
3. Applications for authorisation shall be accompanied by the control documents, with the
necessary inclusion of non-re-export clauses, to be determined by regulation, so as to
940 ensure sufficient guarantees that the destination and end use of the materials, products
and technologies comply with the limits of the corresponding authorisation.
Applications for authorisations shall also include information on the countries of
transit and methods of transport used. This information shall be extended in brokering
operations to the financing used.
945 4. For each authorisation, the desirability of establishing mechanisms for verification,
monitoring and collaboration between governments shall be assessed.
Article 4
1. An authorisation shall be required for the export of dual-use items not listed in Annex
I if the exporter has been informed by the competent authority that the items in
950 question are or may be intended, in their entirety or in part:
a. for use in connection with the development, production, handling, operation,

maintenance, storage, detection, identification or dissemination of chemical,
biological or nuclear weapons or other nuclear explosive devices or the
development, production, maintenance or storage of missiles capable of
955 delivering such weapons;
b. for a military end-use if the purchasing country or country of destination is

subject to an arms embargo; for the purposes of this point, ‘military end-use’
means:
i. incorporation into military items listed in the military list;
960 ii. use of production, test or analytical equipment and components therefor, for
the development, production or maintenance of military items listed in the
military list; or
38
iii. use of any unfinished products in a plant for the production of military
items listed in the military list;
965 c. for use as parts or components of military items listed in the national military
list that have been exported from the territory of Martineek without
authorisation or in violation of an authorisation.
2. Where an exporter is aware that dual-use items which it proposes to export, not listed
in Annex I, are intended, in their entirety or in part, for any of the uses referred to in
970 paragraph 1 of this Article, the exporter shall notify the competent authority. That
competent authority shall decide whether or not to make the export concerned subject
to authorisation.
3. All exchanges of information required pursuant to this Article shall take place in
accordance with the legal requirements concerning the protection of personal
975 information, commercially sensitive information or protected defence, foreign policy
or national security information. Such exchanges of information shall be made via
secure electronic means.
Article 5
1. The Ministry of Trade and Industry has the right to annul an export authorisation or to
980 modify the terms of it if any information provided in the application has been found
incorrect or if any circumstances have changed after the authorisation was granted so
that international commitments or obligations binding on Finland call for such a
measure.
985 [intentionally omitted]
Article 9
1. Penalties for actual or attempted intentional violations of any provisions contained in
or issued under sections 3 and 4 of this Law are imposed in chapter 46, sections 1 - 3
of the Penal Code.
990 2. Any person who out of inadvertence fails to meet his notification obligation under
section 4(2), shall be liable, for omission to notify export of dual-use goods, to fines or
to imprisonment.
3. An authority can refrain from proceeding to action against a suspect, if the act, with
regard to its negative impact and the guilt of the culprit as apparent from the act, can
39
995 be judged insignificant as a whole and if public interest does not require proceedings
to be instituted.
Article 16
1000 1. The competent authority acting in accordance with this Law, may refuse to grant an
export authorisation and may annul, suspend, modify or revoke an export
authorisation which it has already granted.
1005 Article 27
1. Exporters of dual-use items shall keep detailed registers or records of their exports, in
accordance with the law or practice in force in Martineek. Such registers or records
shall include in particular commercial documents such as invoices, manifests and
transport and other dispatch documents containing sufficient information to allow the
1010 following to be identified:
a. a description of the dual-use items;
b. the quantity of the dual-use items;
c. the name and address of the exporter and of the consignee;
d. where known, the end-use and end-user of the dual-use items.
1015 2. The registers or records and the documents referred to in paragraph 1 shall be kept for
at least five years from the end of the calendar year in which the export took place.
They shall be produced, on request, to the competent authority.
Article 28
1020 1. Any natural or legal person who carries out the activities described herein, shall apply
for authorization of any transaction with a foreign person or entity that results in a
change in ownership or control of the company, or transfer of assets as listed in
paragraph 1 (a) of Article 2, to the Council of Ministers before the transaction is made,
1025
40
along with any relevant information on the proposed acquisition, the purchaser, and
the scope of operations.
1030 The President of the Republic of Martineek,
Wolfgang Borchert
REPLIBIJIC
OF
i\»’lAR'l'l N E E K
1035 ANNEX I - THE DUAL-USE ITEM LIST
41
ANNEX II - THE DUAL-USE ITEM WATCH LIST FOR CONVENTIONAL WEAPON
1040 CATCH-ALL CONTROLS
The items listed in the figure below are examples of those which do not fall under the List
controls, but which have a particularly strong possibility of being used for the
development, and proliferation., of conventional weapons.
Particularly careful screening is required before exporting or transferring these items to

1045 ensure that they will not be diverted to uses of concern.
As of 22 February 2022
Items
Ni or Ti alloy Electronic computers or components thereof
Sintered magnet Telecommunication transmission equipment or

components thereof
Equipment to manufacture item 2 Phased array antennas

above, or parts thereof
Hydraulic fluids containing Telecommunication jamming equipment or

phosphate/cresol ester, tris components thereof
(dimethylphenyl) phosphate, or
trinormalbutyl phosphate
Organic fiber, carbon fiber, or Position detecting equipment using electromagnetic

inorganic fiber interference observation technology without sending
out electromagnetic waves such as radio waves
Bearings or components thereof 16. Optical detectors, coolers therefore, or

equipment using optical detectors
Machine tools listed below, or Optical fibers for use in sensors

components thereof
(a) Numerically controlled machine

tools
(b) Machine tools for generating

optical quality surfaces (excluding
numerically controlled machine tools)
(c) Dimensional inspection or

measuring system (including machine
tools having such capabilities)
42
Secondary cells Laser oscillators or components thereof
Waveform digitizers Magnetometers, underwater electromagnetic field

sensors, magnetic gradiometers, or components
thereof
10. Electronic parts mounting robots Gravity meters
Radars or components thereof Accelerometer or components thereof
Gyroscopes or components thereof Inertial navigation systems, other equipment using

inertial forces, or components thereof
Gyro-astro compasses, devices that Underwater cameras or components thereof

derive position or orientation by
means of automatically tracking
celestial bodies or satellites,
electromagnetic wave receivers for
global navigation satellite systems,
components thereof, or airborne
altimeters
Air-independent power systems Self-contained diving equipment (open-circuit types)

or components thereof
Gas turbine engines or components Rocket propulsion systems or components thereof

thereof
Equipment for the manufacture of the Air vehicles or components thereof

items listed in 29) or 30) above or
components thereof
Vibration testing equipment, wind Flash X-ray machines

tunnels, environmental testing
equipment for the development or
testing of rockets or air vehicles, or
components thereof
43
1050 RESPONDENT’S EXHIBIT R2 - Results of joint investigation on MK Robotics former

owner
REPUBLIC
or
i\i-'lAl{'l'lNl*Il*ll{ i
FECC
1055 Press release
The Council of Ministers of Martineek Republic
1060 and
Financial and Economic Crimes Commission
Results of Joint investigation
1065
The Council of Ministers of Martineek Republic together with the Financial

and Economic Crimes Commission has completed an investigation into Dr.
Farnsworth, the former owner of the MK Robotics SRL, Fratti Street, 73
Republic of Martineek.
1070 The investigation revealed that while being the major shareholder of MK
Robotics from 2018 to 2020, Dr. Farnsworth had been fabricating corporate
documents and governmental permissions, including licenses, sales
authorizations, Board of Directors decisions to avoid taxes, regulatory
compliance, misrepresent financial information to secure loans, conceal
1075 transactions.
The copies of documents found during the investigation reviled the forged
governmental approval of 100% shares sale of MK Robotics to the foreign
investor DeLorean Technologies LLC (112 Charles Street, Medtown, ME
2231, Federation of Albion) in 2020, that has never been authorized by the
1080 Council of Ministers.
All fabricated documents were created by copying official wording and

replacing the names of the counterparties, as well as substituting the
44
original hand signatures with electronic ones. As evidence of this

fraudulent activity, the Council of Ministers and the Financial and Economic
1085 Crimes Commission present the following example of a signature used by
Dr. Farnsworth:
RI-IP1 IiI(-55; 3 THE DOCUMENT IS SIGNED

\lAl('l'l X lil-‘.l\' V WITH DIGITAL SIGNATURE
Certificate: laajn000O0tu000D000l]U340Z346
Owner: Ralph Kentookec
Date: 30.11.1020
As a result of the investigation, Dr. Farnsworth has been found to have

committed a criminal offense, criminal prosecution has already started.
1090 Financial and Economic Crimes Commission will continue to investigate

and prosecute any individuals or companies engaging in fraudulent
activities: “We remind the public that fabricating documents is a serious
crime and will not be tolerated”.
1095
The Council of Ministers of Martineek Republic
Secretariat
30 November 2022
1100
45
RESPONDENT’S EXHIBIT R3 - Young & Coopers Report of 20 December 2021
YOUNG & COOPERS REPORT SERIES
1105 Martineek, 20.12.2021, YC 20/2021
Second Annual Report on FDI inflows in the Future-Technology Partners Group

(FTPG) countries
[- Report extract-]
1110
1. The Report is based on an empirical analysis of FDI inflows from 2018 to 2021 and
provides transparency around operations involving foreign capital in the FTPG
countries (“Annex 1”), including data on the origin of investments and targeted
economic sectors (“Annex 2”).
1115 2. When making forecasts, the report relies on investors’ official statements, financial
plans, government policy documents and reports by 4 FTPG countries.
3. It contributes to the accountability of the FTPG in an area where, given the security
interests at stake, transparency regarding individual transactions is neither possible nor
appropriate.
1120 [intentionally omitted]
5. Conclusions:
● In 2021, FDI inflows rebounded from COVID-19 and reached record growth as
compared to 2020.
● The upward trend in cumulated inflows of foreign transactions in the FTPG confirms
1125 the openness of FTPG countries to foreign investments, despite the slow-down caused
by the COVID-19 pandemic, with an average rise of acquisitions.
46
● Martineek companies were at the centre of takeovers, with 33 completed FDI deals in
2020 and 78 in 2021. Initially acquired 4% of the voting rights in major high-tech
companies is currently reaching 35%. Yet, the interest of foreign investors in FTPG
1130 technology sectors from 2020 has evidently changed.
● Year-on-year data by foreign jurisdiction shows an increase in investment flows from

Albion and Atlandia companies targeting the region's high-tech and energy sectors
respectively.
● Strict Albion capital control and the concentration of investment activities in core
1135 industry sectors negatively influenced Martineek economy in 2021. Martineek’s failure
to increase innovation and productivity in the last years, put some of its industries at
the risk of being overwhelmed by Albion competitors.
● According to financial plans of Albion investors, further significant growth in

investment in research and development, as well as a complete takeover by squeezing
1140 out the remaining small shareholders should be expected.
Annex 1.
Acquisitions
'0
D 413
33
28
Nusmberufdea
is '
14 1,)
1|] “
_|‘
a El a
2018 2019 2020 2021
I Martineelc I Numenor I Quinchau I Hans
Annex 2.
1145
47
High-Tech Sector FDI Inflow to FTPG's (in billion USD)

I Non-State-Controlled Companies I State-Controlled Companies
125
100 1
T5 i
b'onUSD
50 i
|"|l 0W|'1
25 1
g i
Albion Atlandia Kynara ZOF3\I'i3
Energy Sector FDI Inflow to FTPG's (in billion USD)

I Non-State-Controlled Companies I State-Controlled Companies
EU
40
USD
on
nb
20
nflow
U
Albion Atlandia Kynara Zorairia
48
1150 RESPONDENT’S EXHIBIT R4 - Global Armament Review- Inspecting Awbari drones:

FTPG Technology findings of 28 November 2022
Global
Armament
Review
1155 Inspecting Awbari drones: FTPG Technology findings - 28/11/22
Background
1. Karamanlean-Awbari unmanned aerial vehicles (“UAV”) have been terrorising the

Wadai Sultanate during the last few months. A closer look at these drones has shown
1160 that most of its parts were made in the States of the Future-Technology Partners
Group (“FTPG”), despite strict regulations on export controls.
2. This report summarizes the investigation carried out by the Global Armament Review
(“GAR”) which shows how dual-use components manufactured in the FTPG region
were diverted and ended up in Awbari UAVs. Drones used to target Wadaihi
1165 infrastructure and missile defence systems in kamikaze attacks. The development of
the Awbari UAV program seems to be supported by the Aviation Industries Research
Centre of the Avaikian Republic. Although there are no direct confirmations, the
results of this investigation prove the close relation between them.
3. In September 2022, GAR documented five UAVs, and two UAV engines, in the
1170 possession of Wadaihi defence forces. These aircraft allegedly entered the country
overland from Karamanli. The new Karamanlean Government denied any involvement
with such attacks and stated their commitment to the ceasefire agreement signed
with the Wadai Sultanate. The Awbari Resistance Movement (“ARM”), the political
movement and guerrilla group operating in the southern provinces of Karamanli,
1175 claimed responsibility for the UAV attacks. The Democratic Republic of Karamanli
rejects ARM’s territorial claims. The conflict has also affected several foreign investors
involved in the cannabis industry in the southern provinces.
Documentation and Component Analysis
UAV Comparisons
1180 4. On May 2022, ARM forces presented the Cuāuhtli-1 UAV, which they claimed to have
designed and manufactured. Investigations by GAR provide reasons for concluding
that ARM forces did not manufacture the Cuāuhtli-1.1 The Cuāuhtli-1 is a first-
generation and rudimentary UAV. This model of UAV appears to be a type within the
Pākehā UAV models, produced by the Aviation Industries Research Centre of the
1
See the blueprint attached at the end of this Report for technical and physical characteristics of the
Cuāuhtli-1. This contribution was made by @m.buchard, the Head Engineer of U.S. Robots and
Mechanical Men, Inc.
49
1185 Avaikian Republic. The Cuāuhtli-1 is smaller and primitive but identical to the
Pākehā-V UAV. They share an almost identical design, dimensions, and construction
characteristics. Thus, GAR concluded that the Cuāuhtli-1 is a variant of the Pākehā-V
UAV and not of Awbari design and construction.
5. GAR compared the physical characteristics and internal components of three
1190 Cuāuhtli-1 UAV provided by the Wadaihi defence forces. The electronic components
showed a relatively high degree of precision in their fabrication. The marking and
assemblage of the components had been industrially produced and made under
quality- controlled processes. Also, several internal components match those found
in Avaiki UAVs. GAR found evidence that the engine and internal components of the
1195 Cuāuhtli-1 are almost identical to those of the Pākehā-V.
6. The only difference with the Pākehā-V is that the Cuāuhtli-1 has a hybrid frame that
is poorly constructed and crafted with both industrially produced parts and crudely
moulded materials. GAR suspects that the hybrid frame is domestically produced by
Awbari militias. This is because the UAV frames are difficult to transport discreetly
1200 while the commercially produced internal components are small and easy to traffic.
7. The Awbari militias have assembled Cuāuhtli-1 UAVs by using imported parts, or a
combination of imported and domestically manufactured components. This domestic
production of UAVs has scaled due to the growing domestic capabilities and to the
acquisition of developed material from external sources.
1205 Tracing of internal components
8. In cases where markings on the components were visible and identifiable, GAR
instigated formal tracing processes with the producers to comprehend the supply
chains of the products. The following sections examine the components for which
GAR investigated.
1210 9. Briefly, each of the Cuāuhtli-1 UAVs documented was made of commercial and dual-
use components such as electronic parts, satellite compasses, GPS modules,
microprocessors, servomotors and engines produced in Albion, Corellia, Kuat, and in
the FTPG States. There is no evidence that any of the companies identified in this
report were responsible for support or supply to Awbari militias operating in
1215 southern provinces of the Democratic Republic of Karamanli, or any other
transgression. GAR sent several trace requests to the identified companies. Some
companies have responded but almost all were incapable of providing information
on their components’ onward supply chains.
10. GAR found that the Numenorean Engineering Corporation sold satellite compass
1220 modules as part of a delivery to Republic Sienar Systems, an Albionise distributor,
which exported the modules in August 2021 to a partner company, Holowan
Satellites, a major Albionise satellite component distributor. At the time of export,
there were no restrictions on transfers of such items to the Avaikian Republic and
Holowan Satellites declared the intended end customer to be Cygnus Spaceworks, a
1225 Avaikian producer of civilian satellite trackers. Cygnus Spaceworks’ order was
subsequently cancelled. However, the modules were sold to a Avaikian manufacturer,
50
SedriMotors, and unnamed third parties. GAR could not establish a connection
between key personnel or ownership structures of these companies. GAR is waiting
for a response from SedriMotors.
1230 11. In response to additional trace requests, three other companies from Martineek and
Quinchao, responded that some of the UAV’s components were fakes. In October
2022, the Martineekean company Industrial Automaton stated that Core-3PO
microprocessors labelled ‘Tripio’ were counterfeit. Similarly, Martineekean Electronics
denied producing the electronic part that bears its name.
1235 12. GAR analysed the electronic circuits of servomotors and engines in all the Cuāuhtli-1
UAVs and found that the electronic components were produced by the Martineekean
company MK Robotics. In response to a GAR trace request, MK Robotics stated that
it sold the electronic components to the former Albionese company Hoersch-Kessel
Drive in Albion in April 2022. Recently, this company received Avaikian capital and
1240 changed its name to BlasTech Industries, a civilian electronics distributor. BlasTech
Industries declared that the prospective end customer of MK Robotics’ components
was a company serving mining companies in Avaikia. No evidence was found of
these alleged mining companies. Weeks later, these components were mentioned in
a sale between the Sonn-Blas Corporation, an Avaikian provider of imported
1245 electronic components, to one of its major clients for aerial surveillance systems, the
Avaiki Ministry of Defence.
13. GAR found that the Sonn-Blas Corporation was liquidated in September 2022. The
Office of Corporations provided evidence that two of its directors were citizens linked
to political and security agencies of the Avaikian government. GAR considers that
1250 these findings do not constitute proof that the company was acting on behalf of the
Avaikian State. GAR ascertains that one end user—an Avaikian manufacturer of
military UAVs—received MK Robotics electronic components in August 2022.
14. Drone components documented by GAR’s investigators show how commercial
products manufactured in the FTPG have been diverted for use in drone production.
1255
Gaps In Dual-Use Controls
15. MK Robotics informed GAR that some of its electronic components were also
shipped to BlasTech Industries in May 2022; that it was not subject to export
licensing; and that the company had no information on any transfer to the Sonn-Blas
1260 Corporation. MK Robotics confirmed to GAR that BlasTech Industries is no longer a
customer. While the FTPG members sanctioned Sonn-Blas Corporation in 2021, there
is no suggestion that BlasTech Industries is bound by these measures or has acted
unlawfully in transacting.
16. MK Robotics alleged that the Martineekean authorities had not sent formal letters to
1265 the companies to inform them that the exports of these goods were unauthorized.
Instead, Martineekean authorities had told MK Robotics in informal awareness-
raising letters, about the Avaikian Republic’s procurement efforts and those exports
of unlisted dual-use items would be likely subject to catch-all controls.
51
17. Most of the components found in the analysed drones were manufactured in the
1270 FTPG States. Remarkably, the production marks of FTPG components found in the
UAVs show that they were produced between 2020 and 2021. Some components
were produced earlier but GAR managed to identify export documentation that
prove that they were exported after 2020.
1275 Conclusion
18. The use of these UAVs demonstrates the ARM forces’ ability to employ low-cost
technology against the Wadaihi infrastructure and military assets. Their use of
Pākehā-V UAVs supports allegations that the Avaikian Republic continues to bolster
the capacity of ARM forces through the transfer of new technology and advanced
1280 weaponry. The militia group can conduct increasingly sophisticated asymmetric
operations similar to those carried out by professional armies.
19. Up to date, several UAVs continued to threaten Wadai. The last UAVs targeted civil
infrastructure which caused damage to the power grid and left millions of
Wadaihians without electricity.
1285 20. Further, the proliferation of these vehicles reached conflicts around the globe.
Pākehā UAV models have been identified in the Tyrean uprising in 2021. Also,
footage provided by the survivors of the sinking of HMS Escafeld shows that the
Athabascan vessel was hit by an unidentified UAV. After an analysis of the videos, it
could be determined that the kamikaze UAV was similar to the Cuāuhtli-1 despite
1290 some differences in the frames. Still, the confirmation will come after the discovery of
HMS Escafeld’s wreck and the search of the AUV’s debris.
21. GAR is committed to determine the illicit transfer of military material into war zones.
It is important to mention that the use of these components in these UAVs does not
imply any wrongdoing on the part of the manufacturers.
1295 22. It is important to analyse the production of these UAVs and the supply routes used
by their manufacturers. The initial step is documenting non-state groups’ capacity to
obtain and use commercially available components for lethal means and their lines of
supply. This is the key element for identifying the parties responsible for their supply.
1300
52
53
RESPONDENT’S EXHIBIT R5 - VaryalëNews - Successful first flight of the Qertel-ASP UAV of 27

November 2022
VaryalëNews Drones | Warfare | Land | Naval | Space | Cyber | Global |

Leadership GloLeadership
Successful first flight of the Qertel-
1305 ASP UAV Trending Now
27 November 2022
1. Kaminoan Labs
presents Experimental
The Qertel-ASP UAV is an Albionese-Avaikian project
Unit Clone Force 99 to its
contracted to Albionese Aerospace Industries and investors
SedriMotors for modification, production, and operation by the
2. Albion launches
1310 Albionese Air Force.
peacekeeping operation
in the Wadaihi-
This joint development is a significant milestone in the
Karamanlean border
relations between the Albionese and Avaikian Defense
Ministries. The first Qertel-ASP UAV, produced by Albionese 3. Galen Erso,
Numenorean scientist
Aerospace Industries, has completed its first successful flight
and Nobel laureate
1315 in Albionese skies in preparation for its delivery to the focused on
Albionese Air Force. crystallography and
energy enrichment
The agreement between the respective ministries was signed disappears
in August 2020. The agreement outlines the leasing of a
4. Director Krennic
number of UAVs as well as maintenance and training services. demoted after
1320 As such, Albionese Air Force personnel are training together investigation on
with Avaikian UAV pilots in a military base in Angmar, Albion. electronic components
acquisitions
The UAV was designed according to the needs and
5. Vice-Admiral Horatio
requirements of the Albionese Ministry of Defense. The Thrawn was severely
Qertel-ASP UAV is a medium altitude, and multi-mission wounded during the
1325 aircraft. It is based on the Avaikian Pākehā UAV models, which attack on the HMS
is in operational use in the Avaikian Air Force. The Qertel-ASP Escafeld
UAV was designed and created in record time and
incorporates advanced technology to outmatch any other
military UAV.
54
1330 Qertel-ASP UAV Blueprint prepared by @m.buchard, Head Engineer of U.S. Robots and Mechanical Men, Inc.
https://www.VaryalëNews.com/drone/2022/11/27/Successful-first-flight-of-the-Qertel-ASP-UAV/
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55
RESPONDENT’S EXHIBIT R6 - VaryalëNews - UGVs shape modern warfare in the Wadaihi-

1335
Karamanlean conflict: the “Beetle War” of 14 January 2022
VaryalëNews Drones | Warfare | Land | Naval | Space | Cyber | Global |

Leadership GloLeadership
UGVs shape modern warfare in the
Wadaihi-Karamanlean conflict: the Trending Now
“Beetle War”
1. Vice Admiral Rampart
14 January 2022 launches Project War-
1340 After a year of a stalemate of trench warfare, the front line Mantle as a major
between the Wadaihi Sultanate and the Karamanli Kingdom is reform in the Avaikian
moving. While other conflicts saw the rise of unmanned aerial Army
vehicles, the Wadaihi-Karamanlean conflict is changing the 2. FTPG Defence
character of warfare by using unmanned ground vehicles, Leaders’ Summit to
1345 especially the introduction in battle of modified versions of the take place in Hans
MK-1 modular unmanned ground vehicle commonly known as
3. Albion launches
the “Beetle”. Each State acquired used Beetles and adapted
Drone & Space
them for warfare. The modified Beetles showed remarkable
Research Department
military performance. They outperformed both armoured under the supervision
1350 fighting vehicles and infantry in the desert and volcanic of Director Krennic
battlefield.
4. Avaikia strikes Nal
In the Battle of Dagorlad Hills, 24 W Hutta with its modern
adaihi modified Beetles faced 30 Karamanlean armoured Pākehā-III UAV
vehicles and 15 modified Beetles. Only 7 Wadaihi modified 5. Kamino establish
1355 Beetles survived the battle. This clash of Beetles gave the fund for cloning
name “Beetle War” to the Wadaihi-Karamanlean conflict. projects
In an interview with war correspondents, the Wadaihi Field
Marshal Mr. Gonzalo “Monty” Montiel stated: The Beetles are cheap and we’re not so
worried about losing them compared to losing human lives. We throw them into fierce
1360 fights under extreme conditions for our soldiers and they return victorious. Suddenly,
we’re winning the war thanks to them. Yet, we regret that the producer of the Beetles
declined to provide us with the necessary spare parts to repair damaged ones. We had
to request more units from our vendor, who replied ´15 units are ready, with 40 more
well on the way´. With these numbers ahead, victory will be ours”.
1365 Mr. Montiel did not disclose the vendor of the vehicles. Yet, it is believed that Yuri Orlov
could be the provider of such vehicles. The results of the investigations against Mr.
Orlov’s involvement in arms trafficking are still pending. However, there are proven
records of several cargo flights of Mr. Orlov’s planes landing in fields close to Wadaihi
frontiers.
56
1370 Regarding the rumours about a potential retreat of Wadaihian forces due to the fall of
Minas Ithil, Mr. Montiel only replied “All quiet on the western front”. The interview was
interrupted due to a UAV strike close to the location of the interview.
From the opposing side, a Karamanlean officer said that middlemen from Albion have
been smuggling the vehicles into his country. Yet, this source was not able to provide
1375 further information.
The so-called “War Beetles” were integrated with a remote weapon system and
electrical optical sensor system. These modifications transform the commercial drone
into an armed drone capable of firing cannons or launching missiles from its platform.
These “War Beetles” are able to find and engage larger air threats as well as ground
1380 targets, even if armoured, all without the operator being exposed to threats.
In Martineek the news about the novel military use of the Beetles was not well received
by the High Command. Martineekean military officials have asked MK Robotics to help
them determine how these States have managed to acquire a considerable number of
Beetles for the Wadaihi-Karamanlean conflict.
1385 MK Robotics replied that it does not know how Wadai or Karamanli obtained the Beetles
and is “supporting” the government effort to prevent Martineekean-made goods from
ending up in wars.
“We briefed the Ministry of Defense on MK Robotics’ supply chains and the procedures
that MK Robotics has in place to protect supply chain integrity,” said John Garman,
1390 public policy and communications Chief.
Garman added, “It is impossible for MK Robotics to completely control indirect or illegal
channels through which the vehicles could be misappropriated.”
“MK Robotics does not obtain any profit from these re-sales, but they are on notice now
and they should do more. On the one hand they want to be thought of as a responsible
1395 entity, but they need to export more because Martineek has a small domestic market.
You probably see Beetles in a few markets with feeble controls” said Brigadier General
Emiliano Martinez from Martineek. “They should be able to track how the Beetles got
there. I think they should disclose that, put a stop to that, and put policies and
procedures in places that are real and effective to make sure that we don’t see Beetles
1400 in foreign conflicts in the future.”
The deployment of Beetles in the Wadaihi-Karamanlean conflict proved their
effectiveness as war machines. They proved to be reliable and with a high performance
in harsh environments.
After this success, MK Robotics could have considered expanding their business into
1405 the defence industry. However, MK Robotics decided to expand its business to the
manufacture and sale of electronic components for commercial drones instead due to
the limited commercial demand of the Beetle UGVs. It seems that the purpose of the
company is set on values and not on profit.
57
The following blueprint provides further details on technical and physical characteristics
1410 of the military version of the MK-1 UGV. VaryalëNews appreciates the contribution made
by @m.buchard, Head Engineer of U.S. Robots and Mechanical Men, Inc.
https://www.VaryalëNews.com/drone/2022/01/14/UGVs-shape-modern-warfare-in-the-Wadaihi-Karamanlean-
conflict:-the-“Beetle War”/
Terms of Use | Privacy Policy | VaryalëNews| Newsletters | Contact us
58
1415 RESPONDENT’S EXHIBIT R7 - Minutes of the Parliament meeting of 23 December 2022
MINUTES OF PROCEEDINGS
Meeting No. 114

1420 Friday, 23 December 2022
Parliament’s Standing Committee on National Defence met in a

live session at 1:30 PM in the Plenary Hall, with the Chair,
Maxwell Smith, presiding.
1425 Members of the Committee present: [intentionally omitted].
At 1:41 PM, Maxwell Smith made an opening statement on the

current situation related to the development of the Wadaihi-
Karamanlean conflict.
1430 At 1:50 PM, James Gillen (Nation’s Voice) inquired about whether
there are any plans of the Government to get involved in the
conflict, directly or indirectly. Mr. Smith responded that no
such plans are being discussed within the Government and that
the conflict is of local nature without any ties to Martineek.
1435 At 2:03 PM, Martha Funhey (League of Workers) inquired about
whether the conflict posed any potential threat to Martineek’s
integrity or economy. Mr. Smith responded that while there is no
reason to predict any danger to the territorial integrity, the
economic impact of the conflict may be severe due to disrupted
1440 delivery chains in the region.
At 2:14 PM, Peter Hill (Nation’s Voice) inquired about whether
the Government of Martineek is considering the introduction of
any sanctions on Albionian entities whose equipment is being
exploited in the conflict, referring to Mr. Organa’s revoked
1445 statement of 15 December 2022. Mr. Smith responded that no
sanctions or equivalent measures are being considered by the
Government and the Government’s stance on this matter had not
change.
At 2:31 PM, the sitting was suspended.
1450 At 3:04 PM, the sitting resumed.
At 4:41 p.m., the Committee adjourned to the call of the Chair.

1455
Martin Doom
Clerk of the Committee
23/12/2022, 6:33 PM.
1460
59
RESPONDENT’S EXHIBIT R8 - Press Release of Parliament of Martineek of 27

December 2022
REPLIBLIC OF
[\-*IAR'l‘INEl~1K i
1465
PRESS RELEASE
27 DECEMBER 2022
1470 The Parliament of Martineek reaches an agreement on adopting sanctions

in response to the aggravation of the Wadaihi-Karamanlean conflict
An agreement concerning the adoption of sanctions in response to the aggravation of the

Wadaihi-Karamanlean conflict, proposed by the Marshall of the Parliament, Mr. Jeffrey Rooms,
1475 on 26 December 2022, was reached today during an extraordinary meeting of the Parliament.
Sanctions are to be introduced to prevent the further use in military conflicts of FTPG
technology produced by designated entities. Members of the Martineekean Parliament agreed on
the sanctions anonymously.
The sanctions are to be announced and implemented on 30 December 2022. Any further
1480 developments will be announced via a separate press release.
Marc J. Anthony
1485 Secretary of the State
60
RESPONDENT’S EXHIBIT R9 - Statement of the Secretary of the Treasury Paul Bäumer

of 30 December 2022
1490
PRESS RELEASE
Remarks by Secretary of the Treasury Paul Bäumer on the adoption of a sanctions
regime against Albion and Albionese companies
Today, the Remark Administration affirms Martineek’s unwavering support for peace through
1495 imposing sanctions, which will primarily avoid the further development of military weapons
with Martineekean technology. These measures will save countless lives from brutal and illegal
conflicts, in addition to bolstering security in Martineek and promoting global security and
peace.
This statement is to be neither an accusation nor a condemnation. We are the sons and
1500 daughters of a generation of men and women who, even though they may have escaped its
shells, were destroyed by the war. We are a generation no longer untroubled—we are no more
indifferent to war.
While we have watched foreign States and militias’ leaders continuing to support war efforts,
we saw the wounded and dying. While they taught that duty to one’s country is the greatest
1505 thing, we already knew that death-throes are stronger. These “leaders” do not realize that
above such shattered bodies there are still human faces in which life goes its daily round. Death
is not an adventure for those who stand face to face with it.
It is very queer that the unhappiness of the world is so often brought on by small men. A word
of command has made enemies; a word of command might transform them into friends again.
1510 Here, our word stands for peace. We want kids to become mediators and guides to the world
of maturity, the world of work, of duty, of culture, of progress—to the future and not to war.
These young generations that had begun to love life and the world had to shoot it to pieces.
The first bomb, the first explosion, burst in their hearts. They are cut off from activity, from
striving, from progress. They believe in such things no longer; they believe in war. War ruins
1515 generations for everything.
These generations affected by war know nothing of life but despair, death, fear, and fatuous
superficiality cast over an abyss of sorrow. We see how people are set against one another, and
in silence, unknowingly, foolishly, obediently, innocently slay one another. What affects us is
that they are doing it with Martineekean technology.
1520 During the last century, bombardments, barrages, curtain-fires, mines, gas, tanks, machine-
guns, hand-grenades held the horror of the world. The new century has proved to us that
components such as electronic parts, satellite compasses, GPS modules, microprocessors,
servomotors and engines have become missiles and drones used specifically for killing and
destroying. These small components when they fall under improper hands have become
1525 tainted. Many of these components that fall under these hands are of Martineekean
manufacture. Our pride, the jewels of our innovation, have become conductors of death.
Statement digitally signed by Paul Bäumer - Stanislaus Katczinsky - Joseph Behm on 30

December 2022 in Siaya, Martineek.
61
1530
INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES
ICSID Case No. ARB/21/37
1535
Claimant
v.
1540 THE REPUBLIC OF MARTINEEK
Respondent
1545 PROCEDURAL ORDER NO. 1
Members of the Tribunal

Richard Sanchez, President of the Tribunal
1550 Tamara Gueterman, Arbitrator
Dr. Xenon Bloom, Arbitrator
Secretary of the Tribunal

Jerry Smith
1555
4 July 2023
62
The first session of the Arbitral Tribunal was held on 3 July 2023 at the seat of the
Centre in Washington, D.C. Participating in the first session were:
1560
[intentionally not reproduced]
Following the session, pursuant to ICSID Arbitration Rules 19 and 20, this first
Procedural Order sets out the Procedural Rules that govern this arbitration.
1565
1. Applicable Arbitration Rules
These proceedings are conducted in accordance with the ICSID Arbitration Rules in
force as of 2023, and the Official Rules of the Foreign Direct Investment International
1570 Arbitration Moot, as agreed between the Parties. In case of an inconsistency between
the two, the latter shall prevail to the extent of the inconsistency.
2. Constitution of the Tribunal
1575 a. The Tribunal was constituted on 20 June 2023 in accordance with the ICSID
Convention and the ICSID Arbitration Rules. The parties confirmed that the Tribunal
was properly constituted and that no party has any objection to the appointment of any
Member of the Tribunal. The Arbitral Tribunal in this case consists of Tamara
Gueterman (arbitrator appointed by Claimant), Dr. Xenon Bloom (arbitrator appointed
1580 by Respondent), and Richard Sanchez (President appointed by the two arbitrators).
b. The Members of the Tribunal timely submitted their signed declarations in

accordance with ICSID Arbitration Rule 6(2). Copies of these declarations were duly
distributed to the Parties by the Centre.
1585
c. Contact details of each Member of the Arbitral Tribunal are as follows:
Tamara Guterman
1590 KJ 8973
Lokana, Albion
E-mail: [email protected]
1595 Dr. Xenon Bloom

Mart-Re House
Kabarsiran Avenue,
9 2278
63
Iten, Martineek
1600 E-mail: [email protected]
Richard Sanchez
Bookamo Ave 221
1605 110 Stud Drive
Balitown, Nihonkoku
E-mail: [email protected]
3. Fees and Expenses of Tribunal Members

1610
4. Representation of the Parties
1615 Each party shall be represented by its counsel (below) and may designate additional
agents, counsel, or advocates by notifying the Tribunal and the Tribunal Secretary
promptly of such designation.
For Claimant:
1620 Adila LLP
KJ 8972
1625 For Respondent:

1207, Kingdom of Narnia, Ville de la Liberté,
Chemin Ilya Yashin, 7
1630 5. Place of Proceeding
5.1 Washington, D.C., shall be the place of the proceeding. It was decided that the
Tribunal may hold hearings in Lucknow, India or at any other place that it considers
appropriate if the Parties so agree.
1635 5.2 The Arbitral Tribunal may meet at any location that it considers appropriate for
deliberations.
6. Procedural Language
64
1640 English is the procedural language of the arbitration.
7. Hearings
7.1 Having considered the Parties’ respective proposals on the organization of the
1645 pleadings, the Tribunal determines the following organization of the hearings.
7.2 Although the issues raised by the Parties in their respective submissions would
typically be addressed in two or more separate stages of these proceedings, for the
purposes of these Proceedings, they shall be dealt with together in the “Main Stage”
1650 followed by a stage for costs and, as appropriate in accordance with the Arbitral
Tribunal’s findings in the Main Stage, for quantum (“Quantum and Costs Stage”).
7.3 The “Main Stage” will address the following issues:
1655 i) Whether the Tribunal has jurisdiction over this dispute in light of Article 9 of the
Agreement on Encouragement and Reciprocal Protection of Investments between
the Republic of Martineek and the Federation of Albion;
ii) Whether the challenged measures violate Article 5 of the Agreement on
Encouragement and Reciprocal Protection of Investments between the Republic
1660 of Martineek and the Federation of Albion, and
iii) If the Tribunal finds a violation of Article 5 of the Agreement on Encouragement
and Reciprocal Protection of Investments between the Republic of Martineek and
the Federation of Albion and find Respondent liable for the breach, what is the
appropriate date of valuation of the investment for the purposes of quantification
1665 of damages.
7.4 The hearings in the “Main Stage” shall be held in Lucknow on 2-5 November 2023.
7.5 During “Stage 1” the Tribunal will hold a hearing on the issues of Jurisdiction,
1670 Liability, and Damages, and subsequently decide on Jurisdiction, Liability and
Damages.
7.6 “Stage 2” will address the quantum of damages, if any, as well as the costs of the
proceedings and their allocation among the parties.
1675
7.7 As agreed between the Parties and the Tribunal, the evidence that may be relied on
in the arbitration will be limited to (i) facts and assertions contained in the Request for
Arbitration and the Response to it, the “Statement of Uncontested Facts” as will be
agreed to between the parties, and appended to a Procedural Order (with no admission
1680 being made by either of the Parties as to correctness of the inferences from facts
asserted by the other Party in its respective submission); (ii) publicly available
65
information; and (iii) responses to the questions presented by the Parties’ counsel in
accordance with the procedure described below:
1685 i) By 1 June 2023 factual questions that require clarification shall be posted in
accordance with the procedure described at
https://fdimoot.org/teams/clareqs.php;
ii) The Parties shall then confer and seek to agree as soon as practicable on the
responses to those questions. The Parties’ agreed responses shall be appended to
1690 the case file at https://fdimoot.org/problem.pdf;
iii) By 15 August 2023 another set of factual questions may be posted in
accordance with the same procedure referenced above. The responses to those
questions shall be appended as described above.
1695 8. Provisional Timetable of the Proceedings
8.1 “Stage 1” of the Proceedings:
i) Only one round of written submissions shall be made by the Parties. The
1700 Claimant’s Memorial on Jurisdiction, Liability and Damages is to be submitted
to the Tribunal no later than 12 September 2023; the Counter-Memorial on
Jurisdiction, Liability and Damages is to be submitted to the Tribunal by
Respondent no later than 19 September 2023. The Tribunal may direct the Parties
to submit Skeleton Briefs if it finds them necessary for the proper consideration
1705 of the issues in dispute.
ii) Considering that it is appropriate to hold hearings in the present case, both Parties
are invited to attend the hearings scheduled in Lucknow on 2-5 November 2023.
8.2 “Stage 2” of the Proceedings: The Tribunal will schedule the second stage of the
1710 proceedings and set the provisional timetable for its conduct in consultation with the
Parties after the Tribunal issues the Partial Award on Jurisdiction, Liability and
Remedies.
9. Good Faith
1715
The Parties accept that they have a duty to arbitrate in good faith, which includes an
obligation to cooperate with the opposing parties and the Tribunal. The Parties further
agree that the Tribunal may direct any Party to do all such things during the
proceedings as may be reasonably needed to enable an Award to be made properly,
1720 fairly and efficiently.
[signed]
66
1725 Richard Sanchez

President of the Tribunal
[signed] [signed]
Tamara Gueterman Dr. Xenon Bloom
Arbitrator Arbitrator
67
1730
1735 To: Richard Sanchez, President of the Tribunal

Tamara Gueterman, Arbitrator
Dr Xenon Bloom, Arbitrator
CC: Jerry Smith, Secretary of the Tribunal
Ministry of Justice of the Republic of
1740 Martineek
Adila LLP
From: Dumbledore, Black & Partners

1745 27 October 2023
Letter of Resignation of Dumbledore, Black & Partners

By this Letter, Dumbledore, Black & Partners (“DBP Law”) respectfully asks the Tribunal to
allow its resignation from representing Respondent in the case Delorean Technologies LLC v.
the Republic of Martineek.
1750 As thousands of advocates around the world, we have been deeply chagrined by the detention of
our colleague and consœur, Ms. Alia Azadi, who has been defending the right of women to
choose their profession freely.1 It has become impossible to represent the country that so
blatantly violates fundamental human rights and freedoms.
We draw the Tribunal’s attention to the fact that all other major international law firms resigned
1755 from representing Respondent in other high-stake cases in support of their colleague and
consœur Ms. Azadi. The leading world arbitration news portal NAR (Narnian Arbitration
Review) published an article singling out Dumbledore, Black & Partners as “the last firm
continuing to represent the Republic of Martineek in international proceedings after the
detention of Ms. Azadi who, as of today, remains in detention and has no access to her
1760 representative”.2
Moreover, the Bar Association of the Kingdom of Narnia, which governs the conduct of all
attorneys of DBP, issued an opinion, according to which members of the Narnian Bar
1
Exhibit DBP_1, Amnesty International Journal, Women’s Rights Worldwide: Newsflash, by Fariba
Adelkhah of 18 October 2023.
2
Exhibit DBP_2, Narnian Arbitration Review, Dumbledore Black & Partners: the last global law firm
representing Martineek, by Cosmo Oberson of 25 October 2023.
68
Association have the right to resign from cases in which they represent the Republic of
Martineek, unless it would severely prejudice the interests of justice.3
1765 Based on the foregoing, DBP respectfully asks the Tribunal to allow its resignation from the
present case. DBP is willing to present its position at the hearing, should the Tribunal consider it
necessary. DBP is also willing to address the Tribunal on procedural steps it could take,
including modification of the timetable of these proceedings, to prevent any due process
implications for Respondent over the course of the next stages in these proceedings.
1770 Sincerely Yours,
Dr. Zan Zendegi, Partner at Dumbledore, Black & Partners
3
Exhibit DBP_3, Decision of the Council of the Narnian Bar Association No. 1228 of 12 October 2023.
69
Exhibit DBP_1 - Amnesty International Journal, Women’s Rights Worldwide: Newsflash,

by Fariba Adelkhah of 18 October 2023.
1775
Amnesty International Journal
Women’s Rights Worldwide: Newsflash

Fariba Adelkhah
18/10/2023
1780 On 9 October 2023, the prominent Martineekean human rights advocate, Ms. Alia
Azadi, was detained right in the courtroom of the Constitutional Court of the Republic of
Martineek.
On 15 September 2023, the Parliament of the Republic of Martineek adopted the law
(“Law 1609”), according to which women are not allowed to have access to certain
1785 professions, including, most notably, the professions of lawyer, university educator and
doctor. The penalty for not complying with the law, for instance, for appearing before
courts or Martineekean-seated tribunals is up to 5 years in prison. The law applies
retroactively even to those women who are already practising members of the Bar
Association.
1790 Thousands of women took to the streets of Carouge, the capital of Martineek, to
peacefully protest against this law. To no avail. The law entered into force on 22
September 2023.
Ms. Alia Azadi, one of a few prominent female advocates in Martineek, brought a
petition before the Constitutional Court of Martineek to recognize this law as
1795 unconstitutional. Ms. Azadi took the floor to make her opening statement. The twelve
judges of the Constitutional Court, all male, gave her a warning that she is not allowed
to appear before the Court, according to the Law 1609.
Despite the warning, Ms. Azadi addressed the Court: “I am risking my freedom today,
because a whole generation of Martineekean girls, half of the population of our country,
1800 is about to be silenced. As Amal Clooney once said: ‘The worst thing that we can do as
women is not stand up for each other’…”. After barely two sentences of her opening
statement, Ms. Azadi was arrested. She is facing up to 5 years in prison and she was
not allowed access to her legal representative.
70
Exhibit DBP_2 - Narnian Arbitration Review, Dumbledore Black & Partners: the last
1805 global law firm representing Martineek, by Cosmo Oberson of 25 October 2023
Dumbledore Black & Partners: the last global law

1810 firm representing Martineek
Cosmo Oberson
25 October 2023
The detention of Ms. Alia Azadi during her opening statement before the
1815 Constitutional Court of Martineek has shaken the world.
Legal professionals around the globe have expressed almost unanimous

condemnation of the attack on the legal profession. Leading public
international lawyer Dr. Estelle LeClaire and the law firm Palestini, Kohen &
Partners have withdrawn from Martineek’s counsel team in a set of state-
1820 to-state disputes before the International Court of Justice. A range of other
law firms followed suit in a range of investment arbitration disputes
against the Republic of Martineek.
Dumbledore, Black & Partners is the last firm continuing to represent the
Republic of Martineek in international proceedings after the detention of
1825 Ms. Azadi who, as of today, remains in detention and has no access to her
representative. We contacted the partners of DBP: they refused to
comment on the issue.
71
Exhibit DBP_3 - Decision of the Council of the Narnian Bar Association No. 1228 of 12
1830 October 2023
Ilu11|I1 Ber Assnulaiinl
THE DECISION OF THE COUNCIL OF THE NARNIAN BAR ASSOCIATION N. 1228
On the Request for Clarification Regarding the Termination of

Representation of the Republic of Martineek
1835 1. The Narnian Bar Association has received multiple requests from Narnian law firms on
whether resignation from representing the Republic of Martineek after the detention
of Ms. Alia Azadi is consistent with the Rules of Professional Conduct adopted by the
Narnian Bar Association, mandatory for all its members.
2. In response to these requests, the Narnian Bar Association issues the present decision
1840 N. 1228 providing clarification on the matter of resignation.
3. According to the Narnian Bar Association’s Rules of Professional Conduct, resignation is

required and/or allowed in the following cases:
Rule 16.1
(a) Except as stated in paragraph (c), a lawyer shall not represent a client or, where
1845 representation has commenced, shall withdraw from the representation of a client if:
(1) the representation will result in violation of law or the Rules of Professional
Conduct;
(2) the lawyer's physical or mental condition materially impairs the lawyer's
ability to represent the client; or
1850 (3) the lawyer is discharged.
(b) Except as stated in paragraph (c), a lawyer may withdraw from representing a client
if:
(1) withdrawal can be accomplished without material adverse effect on the
interests of the client; or
1855 (2) the client knowingly and freely assents to the termination of the
representation; or
(3) the client persists in a course of action involving the lawyer's services that
the lawyer reasonably believes is criminal or fraudulent; or
(4) the client insists upon taking action that the lawyer considers repugnant,
1860 imprudent, or contrary to the advice and judgment of the lawyer, or with which
the lawyer has a fundamental disagreement; or
(5) the client has used the lawyer's services to perpetrate a crime or fraud; or
72
(6) the client fails substantially to fulfill an obligation to the lawyer regarding
the lawyer's services and has been given reasonable warning that the lawyer
1865 will withdraw unless the obligation is fulfilled; or
(7) the representation will result in an unreasonable financial burden on the
lawyer or has been rendered unreasonably difficult by the client; or
(8) the client insists upon presenting a claim or defense that is not warranted
under existing law and cannot be supported by good faith argument for an
1870 extension, modification, or reversal of existing law; or
(9) other good cause for withdrawal exists.
(c) A lawyer must comply with applicable law requiring notice to or permission of a
tribunal when terminating a representation. When ordered to do so by a tribunal, a
lawyer shall continue representation notwithstanding good cause for terminating the
1875 representation.
(d) Upon termination of representation, a lawyer shall take steps to the extent
reasonably practicable to protect a client's interests, such as giving reasonable notice to
the client, allowing time for employment of other counsel, surrendering papers and
property to which the client is entitled and refunding any advance payment of fee or
1880 expense that has not been earned or incurred. The lawyer may retain papers relating to
the client to the extent permitted by other law.
4. The Narnian Bar Association notes that, in this particular case, resignation from
representing the Republic of Martineek to show support for the rights of advocates and
to condemn violations of these rights falls under the provisions of Rule 16.1(b)(9):
1885 “other good cause for withdrawal exists”.
5. However, utmost attention should be paid by counsel for the Republic of Martineek to
ensure that they comply with Rules 16.1(c) and 16.1(d).
6. To conclude, members of the Narnian Bar Association as well as Narnian based law
firms have the right to resign and no longer represent the Republic of Martineek, unless
1890 it would severely prejudice the interests of justice described above.
The decision taken unanimously [Signature of the Chair]

by the Council of the Narnian Bar
Association on 12 October 2023
73
1895
To: Richard Sanchez, President of the Tribunal
1900 CC: Jerry Smith, Secretary of the Tribunal

Ministry of Justice of the Republic of
Martineek
1905
From: Adila LLP
Date: 30 October 2023
Claimant’s Objections to Respondent’s Counsel Resignation

1910
Dear Members of the Tribunal,
Claimant hereby requests the Tribunal, in light of the underlying duty of the arbitrators
to conduct proceedings efficiently, to reject the request by counsel for Respondent,
Dumbledore, Black & Partners, to resign at a very late stage of the proceedings, right
1915 before the hearing is about to take place.
First, the current proceedings have already been delayed on multiple occasions by
multiple requests by Respondent for extensions to file its legal submissions. If the
Tribunal grants DBP’s request, it will cause further significant delays in the
proceedings: the proceedings will have to be postponed and Respondent will have to
1920 find another counsel. It will take months for another counsel to get acquainted with the
voluminous case file containing more than 3000 pages of legal submissions and more
than 800 factual and legal exhibits. This would significantly undermine Claimant’s
interest in bringing this case to an end and receive its full compensation without any
delay.
1925 Second, none of the reasons cited by DBP justify its resignation but would lead to
significant disruption in the proceedings and violate the right of both Parties to prompt
and efficient resolution of the dispute.
74
The Tribunal enjoys broad discretion and flexibility in the conduct of arbitral
proceedings, provided that a fair, equitable and efficient process is observed.
1930 Claimant reserves its right to present its arguments on this issue in full during the
scheduled hearing.
Sincerely Yours,
Dr. Maria Eismont, Counsel for Claimant
1935 [signature]
75
_]USTlTSM|N|STERlET
1940
To: Richard Sanchez, President of the Tribunal

1945 CC: Jerry Smith, Secretary of the Tribunal
Adila LLP
From: Ministry of Justice of the Republic of Martineek

31 October 2023
1950
Respondent’s Letter Concerning the Counsel Resignation
Dear President, Members of the Tribunal,
The Ministry of Justice of the Republic of Martineek expresses its regret in respect of the undue
1955 pressure the international community has put on its counsels in all major international
proceedings, which undermines Respondent’s due process rights.
The Republic of Martineek has always valued the services provided by DBP and its sudden
resignation, if accepted, would lead to significant costs and expenses. It would be difficult, if not
impossible, to find another law firm in the forthcoming weeks who would agree to represent
1960 Martineek and would be able to acquaint itself expeditiously with thousands of pages of case
materials and evidence. This would cause to Respondent a lot of unjustified expenses and will
unduly prolong the proceedings.
Respondent trusts that the Tribunal will resolve this issue bearing in mind its underlying duties.
Due to the lack of immediately available legal counsel in the Ministry of Justice who could
1965 represent Respondent in the upcoming hearing, Respondent will abstain from making oral
submissions on this issue. Given DBP’s willingness to address the Tribunal on modifications of
procedures that should be made in the event their resignation is accepted, Respondent does not
object to the Tribunal hearing only the positions of Respondent’s Counsel and Claimant during
the oral hearing on this issue.
76
1970 In case the Tribunal accepts the resignation of DBP, Respondent will file a request to postpone
the subsequent stages of the proceedings until at least November 2024 to find another counsel
and allow the new counsel to acquaint itself with all the materials of the case.
Kind regards,
1975 Dolores Umbridge, Vice-Minister of the Ministry of Justice
[signature]
77
INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES
1980 ICSID Case No. ARB/21/37
1985 Claimant
v.
Respondent
1990
PROCEDURAL ORDER NO. 2
1995 Members of the Tribunal

Richard Sanchez, President of the Tribunal
Dr. Xenon Bloom, Arbitrator
2000 Secretary of the Tribunal

Jerry Smith
1 November 2023
78
2005 Pursuant to ICSID Arbitration Rule 27, this second Procedural Order sets out the
Conduct of the Proceedings of this arbitration.
The Parties have agreed upon a Statement of Uncontested Facts, as produced below. The
Tribunal appreciates the effort done by the Parties for working together amicably to
provide the Tribunal with the undisputed facts.
2010 With respect to the letter of the counsel for Respondent dated 27 October 2023 asking
the Tribunal to allow its resignation from representing Respondent in the case and the
submissions made by Claimant and Respondent on this issue, the Tribunal has made the
following decisions.
1. The Tribunal has decided to deal with the issue of counsel resignation as a first
2015 preliminary issue during the oral proceedings. All previous arrangements notified
in Procedural Order No. 1 remain in force.
2. The Tribunal will hear the arguments of Respondent's counsel first, followed by
the arguments of Claimant. The Tribunal has taken note of Respondent’s
Ministry of Justice’s position expressed in writing.
2020 3. For the purposes of the oral hearings in Lucknow, India, on 2-5 November 2023,
the Tribunal will hear all four issues (i.e. counsel resignation, jurisdiction, merits
and the date of valuation) in the same hearing. If the counsel resignation is
accepted, it will be effective for the next stages of the proceedings, i.e. for the
filing of one or more rounds of post-hearings submissions, should the
2025 proceedings include this stage, as well as Stage 2 of the proceedings.
4. Therefore, the “Main Stage” will address the following issues:
a. Whether the Tribunal shall grant the request for resignation by counsel
for Respondent;
b. Whether the Tribunal has jurisdiction over this dispute in light of Article
2030 9 of the Agreement on Encouragement and Reciprocal Protection of
Investments between the Republic of Martineek and the Federation of
Albion;
c. Whether the challenged measures violate Article 5 of the Agreement on
Encouragement and Reciprocal Protection of Investments between the
2035 Republic of Martineek and the Federation of Albion, and
d. If the Tribunal finds a violation of Article 5 of the Agreement on
79
Encouragement and Reciprocal Protection of Investments between the

Republic of Martineek and the Federation of Albion and find
Respondent liable for the breach, what is the appropriate date of
2040 valuation of the investment for the purposes of quantification of
damages.
[signed]
2045 Richard Sanchez
President of the Tribunal
[signed] [signed]
Tamara Gueterman Dr. Xenon Bloom
Arbitrator Arbitrator
80
Statement of Uncontested Facts

2050
1. This dispute arises from certain measures undertaken by the Republic of Martineek
(“Respondent”, “Martineek”) against DeLorean Technologies LLC (“Claimant”), a
multinational automotive manufacturer incorporated under the laws of the Federation of Albion
(“Albion”).
2055 2. Martineek is an island State with a developed economy located in the Belfalas archipelagic
region (the “Archipelago”). The Archipelago is composed of several islands including the States
of Numenor, Quinchao, Navarino, Hans, Tortuga, and Martineek.
3. After a range of major reforms in 1993 aimed at improving the legal framework for economic
development, over the years, Martineek gradually evolved into a country with a high standard of
2060 living and rapid industrial development.
4. Albion is a country located in Puelmapu, the second largest continent in the world. Puelmapu is
the nearest landmass to the Archipelago. Albion represents one of the biggest economies
globally with a developed industrial sector focusing on manufacturing of basic electronic goods.
5. In 2013, Martineek and Albion terminated the 1993 Agreement on Encouragement and
2065 Reciprocal Protection of Investments between the Republic of Martineek and the Federation of
Albion and replaced it with a revised Agreement on Encouragement and Reciprocal Protection
of Investments between the Republic of Martineek and the Federation of Albion (the
“Martineek-Albion BIT”). The Martineek-Albion BIT was ratified on 28 June 2013. Martineek
and Albion are Member States of the International Centre for the Settlement of Investment
2070 Disputes (“ICSID”) having acceded to the ICSID Convention in February and June 1993,
respectively.
6. In late 2016, with technological advances in the Archipelago, Martineek became one of the
world's leading manufacturers of industrial robots. By 2018, this sector accounted for more than
13% of the national workforce and received more than USD 15 billion in state aid. On 3 March
2075 2018, the Martineekean Ministry of Economic Affairs issued a list of priority spheres to attract
foreign investment. Among other economic sectors listed was the robotic industry.
7. In October 2018, in a bid to promote regional cooperation, Martineek led the formation of the
Future-Technology Partners Group (“FTPG”) consisting of the Archipelago leaders in high
technologies together with Numenor, Nihonkoku, Quinchao and Hans.
2080 8. In December 2018, the FTPG launched “To infinity and beyond”, an economic development and
innovation strategy. The aim was to consolidate FTPG technological leadership in the incipient
fourth industrial revolution. Over a 15-year period, the goal was to drive digital manufacturing
forward by adopting information technology and the internet of things to connect the
Archipelago’s small- and medium-sized companies to global production networks, which, in
2085 turn, would help them become more efficient and globally competitive.
9. In June 2020, Albion’s economy was severely impacted by the COVID-19 pandemic. Albion
placed export restrictions on a range of goods in different sectors, including the technology
sector, which led to a fall in production across industries. Faced with a tough economic reality,
81
companies had to trim their workforce by undertaking massive layoffs. Several foreign investors
2090 left the State and sold their manufacturing facilities to local businessmen. The Albionese
Government strived to revive its economy without incurring inflation. Thus, the Albionese State
developed a new public-driven, national strategy, “Albion first”, to expand its economic
outreach and become the leading State for future technologies in a decade.
10. Albionese leaders strategically defined seven key industry sectors in this regard. These included
2095 next-generation information technology; high-end numerical control machinery and robotics;
aerospace and aeronautical equipment; maritime engineering equipment and high-tech maritime
vessel manufacturing; energy saving and new energy vehicles; biomedicine and high-
performance medical devices; and innovative defence technologies.
11. Albion’s strategy relied on the development of cutting-edge, advanced technologies. Albion
2100 invested in research and development from State and industry sources, accumulation of
intellectual property, setting up of distinct technical standards, and leveraging access for foreign
players to Albion’s market in exchange for their technologies.
12. To strengthen its technological competitiveness both domestically and globally, Albionese
leaders decided to take part in innovative and future-oriented companies located abroad.
2105 Through these steps, Albion stimulated its national development of technologies by enhancing
the purchase of foreign know-how through acquisitions. “The financial support of Albion gives a
clear direction for future development in our manufacturing innovation,” said Mr. Lionel Tusk,
a renowned Albionese businessman.
13. The FTPG member States publicly welcomed the new path taken by Albion towards innovation.
2110 However, media reports of high-level internal meetings among FTPG members noted their
concern that Albion could become a direct value-added competitor to the FTPG States.
14. The eminent academic, Dr. Emmett Brown, remarked: “If Albion achieves these goals, it will put
pressure on FTPG member States as well, since Albion will become a serious competitor in a
whole series of industries where today FTPG has an edge. The industrialised nations will feel
2115 the competition coming from Albion. Martineek will likely be affected with more acquisitions due
to its flexible corporate law regime and relaxed foreign exchange regulations.”
15. Between 2020 and 2021, the investment flow from Albion to Martineek and other FTPG
member States increased twofold. Companies incorporated in Albion were taking over
innovative entities in the field of technologies, acquiring intellectual property, key research, and
2120 making technological advances. Subsequently, several well-known businesses in the
Archipelago were taken over by investors from Albion.
16. Among the landmark acquisitions in Martineek during 2020, Claimant acquired 100% of the
shares of MK Robotics. MK Robotics was a Martineekean leading start-up in robotic innovation
owned by an ingenious engineer Dr. Farnsworth. The company specialised in unmanned ground
2125 vehicles for civil and commercial use as well as engaged in the exportation of several dual-use
items.
17. After negotiations on the terms of the deal, besides the purchase price and payment structure, the
parties agreed to conduct “seller due diligence” before finalizing the purchase agreement. Dr.
Farnsworth performed due diligence evaluating financial health, operational efficiency, legal
82
2130 compliance, and market position of MK Robotics. Subsequently, Claimant's in-house council
reviewed the reports presented and did not identify any major red flags.
18. The general public in Martineek was concerned about the impact of losing the leading robotic
company of Martineek to an investor from Albion. To quell the negative press, MK Robotics and
its new owner published a plan to invest significant resources in research and development and
2135 promised to keep the core company functions in Martineek.
19. In the quarterly earnings that followed the acquisition, MK Robotics reported considerable
growth in the earnings due to the more than 200 automated vehicles sold mostly in Albion, and
Martineek.
20. However, the forecast of the company portended a reduction in the future sales of the MK-1
2140 “Beetle” modular vehicle. The reduction was expected due to the slow growth of market demand
for the vehicles. The company decided to expand its business to the production of electronic
components for smaller ground and aerial drones while expanding market opportunities for its
MK-1 modular vehicle. Simultaneously, the company intended to develop further uses of its
technology in areas such as space exploration in a branch in Albion.
2145 21. In July 2020, the Wadai Sultanate initiated a military operation against the Karamanli Kingdom.
The cause of the conflict was an ill-defined disputed border in the Ered Mithrim region. Despite
initial advances by Wadaihi forces, the operation reached a stalemate and both belligerents were
forced to engage in attrition warfare. The war efforts and the loss of vital infrastructure severely
damaged the economy of Wadaihi. The conflict had a negative impact in the sales of several
2150 companies located in the FTPG members which had Wadaihi companies as main clients.
22. Meanwhile, a widely discussed topic, “Albion first” became a subject of non-governmental
international organisations and financial consulting investigations. Most of the results pointed
out that since Albion’s development in critical high-tech sectors was behind the Archipelago,
Albionese leaders pushed a strategy of foreign acquisitions and forced technology transfer
2155 agreements for obtaining cutting-edge technologies and know-how. The results whipped up the
Archipelago’s public and media with growing concerns about sensitive data linkages and the
military development of Albion. Subsequently, a Young & Coopers report indicated that 184
Albionese companies took over FTPG companies during 2020-2021, compared to 45 Albionese
companies that landed in prior years. During these two years, Albion indirectly invested more
2160 than USD 100 billion in FTPG companies.
23. Claimant and MK Robotics were got caught in the scrutiny of the press especially due to the use
of the MK-1 “Beetle” vehicle in the Wadaihi-Karamanlean conflict. The Beetle outbreak in the
Wadaihi-Karamanlean conflict was not well received by FTPG members, especially by
Martineek. Most units sold in Martineek were confirmed to still be on Martineekean soil. The
2165 situation with the units sold in Albion and in other markets was the opposite. Several units could
not be traced by MK Robotics or the original buyers and an important number of units were
never presented for service or for actualization.
24. These developments were met with growing concerns from politicians and the business
community in the FTPG region. FTPG members started to question their industrial strategy and
2170 relation with Albion due to the increasing investments in the high-tech sectors by Albionese
State-owned enterprises.
83
25. In January 2022, at the annual FTPG meeting, the member States’ representatives expressed
concerns with the increased foreign presence in strategic high-tech industries due to the
development of the “Albion first” program. They agreed to tighten the FDI policy towards
2175 sensitive technological sectors and to develop a cooperation mechanism to share information on
FDIs entering any FTPG States, if such investments posed a potential threat to the national
interests of those member States.
26. To limit the use of FTPG technologies for military purposes, member states also enacted several
restrictive measures, including a trade embargo, against the Avaikian Republic and several
2180 Avaikian companies. The Avaikian Republic is a leading producer of military weapons,
conventional and non-conventional. Avaikian weapons were found in almost every war conflict
in the world and were often used against civilians.
27. Following these events, in February 2022, Respondent amended its legal framework to address
these concerns.
2185 28. First, in February 2022 Martineek issued a Screening Law 24/2022 identifying critical
technology, biomedicine and dual-use items as sectors of strategic importance and imposing
screening procedures for FDIs in these sectors. The Law provides for notifying the government
of any transaction made by foreign investors in the covered sectors, including providing
information on an investment plan, as well as the right of the State to impose conditions on or
2190 veto such a transaction.
29. Second, Martineek enacted Ordinance 66/2022 modernising Law 53/2007 on the control of
foreign trade in defence and dual-use material. This amendment aimed to respond effectively to
evolving security risks and emerging technologies. The amendment included under the dual-use
classification certain controlled unmanned vehicles with technical specifications and some
2195 technical and related equipment and components related to drones.
30. A ceasefire was signed on 28 February 2022 concluding the Wadaihi-Karamanlean conflict. The
borders were established. The Wadaihi forces had to withdraw from the occupied territories in
Karamanli, however, Wadai Sultanate retained the Azanulbizar valley, a sacred valley for the
Awbari people. An approximately 1,500-strong Albionese peacekeeping force from the
2200 Albionese Defence Forces was deployed to observe and maintain the ceasefire.
31. Despite the regulatory scrutiny, Martineek continued to be the focus of Albionese investors.
Although Albionese investors had more than USD 20 billion worth in acquisitions pending,
during 2022, no transactions were identified as posing a threat to Martineek security in strategic
sectors under the Screening law. In late 2022, two more acquisitions of the largest robotics
2205 companies in the Archipelago added fire to the Archipelago’s tensions with Albion. The
acquisitions were made by three Albionese medium-sized enterprises with no current know-how
in robotics. One of the Albionese companies was a seamless pipe manufacturer and another one
was a manufacturer of rubber and plastic products. The statement of the intent of acquisition
pointed out that the companies wanted to enter into robotics to diversify their business and
2210 expand their market.
32. On 28 November 2022, an investigation of the Global Armament Review about the armament
used in the Wadaihi-Karamanlean conflict discovered, in the debris of unmanned aerial vehicles,
tech components from products of FTPG companies. Several FTPG States, including Martineek,
84
initiated a joint investigation which revealed the use of Martineekean critical technology with
2215 Albionese armament manufacturers.
33. To maintain the public trust and protect the interests of national stakeholders, Martineek also
conducted its internal investigation revealing various instances of misconduct by the former
owner of the MK Robotics, including the fabrication of documents. Among other findings, the
investigation concluded that to demonstrate compliance with Law 53/2007 Dr. Farnsworth
2220 forged the signature of a governmental official and created the false authorization decision on
the sale of MK Robotics shares to Claimant. In fact, this transaction has never been authorized
by the government. The official press release with investigation results was published and
publicly available.
34. On 2 December 2022, Respondent initiated an extraordinary FTPG meeting. Citing security
2225 concerns relating to Albion’s unprincipled ways to obtain critical technology and the emergence
of information about the use of FTPG technologies in military conflicts. FTPG States, including
Respondent, issued a joint statement titled “Addressing the threat from high-tech investments”
and agreed to develop a list of restrictive measures towards Albion.
35. On 15 December 2022, in the midst of heated discussions on the use of FTPG technologies in
2230 armed conflicts, Mr Bail Organa, a powerful politician of Nation’s Voice, Respondent’s ruling
party, who was currently holding the position of the Head of Committee on International Trade,
made a Twitter statement worded as following: “Martineek should impose sanctions as soon as
possible and all assets should be banned. There I said it.". Shortly after, on 17 December 2022,
this statement was denounced by Mr Howard Hamlin, the leader of the Nation’s Voice party.
2235 Hamlin stated on a press conference that “Mr Organa’s statement was his own personal opinion
and the government does not plan introducing any specific actions related to sanctions yet”.
36. Immediately after that, reports and rumours of Respondent’s plans to impose sanctions related to
the strategic state interests started to appear all over the media and on the internet. Claimant,
afraid of the possible sanctions, attempted to sell a major part of its assets as soon as possible
2240 before they were frozen or severely decrease in value. To do so, on 20 December 2022, Claimant
announced that it was willing to sell particular assets and invited bids. However, as the prospect
of imposition of sanctions was a common knowledge at this point, the offers received from
private companies operating in the same business sector were severely lower than expected by
Claimant.
2245 37. On 25 December 2022 a drone strike took place in a northern village of the Wadai Sultanate, less
than 150 kilometres away from the border with Karamanli. In the strike, 14 civilians were killed
and over 50 were seriously injured. Initial investigations conducted immediately on the next day
found debris of electronic components of products of FTPG companies, including some that
likely were produced by companies from Martineek. From the debris, a trademark of MK
2250 Robotics could be discerned from one of the electronic components. The strike shocked public
opinion and was broadly covered by the media, mostly due to the number of casualties and
because the video footage from the strike was taped by one of the observers. It triggered public
outcry and debate on neighbouring States stepping in indirectly to curb the violence.
38. On 27 December 2022, the Martineekean parliament organised an extraordinary meeting. During
2255 the meeting it was decided that sanctions are to be introduced in order to prevent the further use
of FTPG technology produced by designated the entities in military conflicts.
85
39. On 30 December 2022, Respondent enacted the Sanctions Law that entailed imposition of
economic sanctions on Albion to stop critical technology linkage and prevent their further use in
military conflicts. The Sanctions Law prohibited to directly or indirectly engage in transactions
2260 for sale, supply, transfer or export dual-use items for military use or to military end-users
originating in FTPG States, as well as technologies and data on components used in such items
with Albion entities.
40. The Sanctions Law listed Claimant as a targeted entity based on the involvement of the Beetle
vehicle in the Wadaihi-Karamanlean conflict and on the discovery of similar components of MK
2265 Robotics in the vehicles used to attack Wadai. According to the Law, Claimant’s assets were to
be subject to freezing. Moreover, the business operations of MK Robotics were affected by
Sanctions Law as a manufacturer of dual-use goods despite its stated policy of only producing
vehicles for commercial and civil purposes.
41. In January 2023, Claimant filed an official request to the Martineek government asking for the
2270 detailed reasons for its inclusion on the sanctions list and demanding that its assets be unblocked.
After 6 months of unfruitful discussions, on 20 April 2023, Claimant submitted its request for
arbitration to the ICSID Secretariat.
42. After the receipt of Claimant’s Request for Arbitration, Respondent retained the law firm
“Dumbledore, Black & Partners” (“DBP Law”). DBP Law has represented Respondent in these
2275 proceedings since the very beginning: it collected evidence, built the case strategy, and drafted
all the necessary procedural documents and submissions. However, shortly before the scheduled
hearing, DBP Law filed with the Tribunal its Letter of Resignation, in which it indicated its
intention to resign from the case.
43. According to this Letter, DBP Law can no longer represent Respondent after the arrest of the
2280 prominent Martineekean lawyer and human rights defender, Ms. Alia Azadi. Ms. Azadi has been
detained right in the courtroom of Martineekean Constitutional Court, where she pleaded against
the recent decision adopted by Respondent’s Parliament to prohibit access to women to a range
of professions, including the profession of lawyer.
86
2285 AGREEMENT ON ENCOURAGEMENT AND RECIPROCAL

PROTECTION OF INVESTMENTS BETWEEN
THE REPUBLIC OF MARTINEEK AND THE FEDERATION OF ALBION
The Republic of Martineek and the Federation of Albion, hereinafter referred to as the Parties;
2290 DESIRING to establish favourable conditions to enhance economic co-operation between two
countries, in relation to investment by nationals and companies of one Party in the territory of
the other Party;
ACKNOWLEDGING that agreement upon the treatment to be accorded such investment will
stimulate the flow of private capital and the economic development of the Parties;
2295 REAFFIRMING their commitment to promote internationally recognized worker rights and
principles of corporate social responsibility;
REAFFIRMING their commitment to sustainable development and to promote the development
of international economic cooperation in such a way as to contribute to sustainable development
in its economic, social and environmental dimensions;
2300 WILLING to duly protect the intellectual property rights of their investors and
RECOGNISING that the provisions of this Agreement preserve the right of the Parties to
regulate within their territories in order to achieve legitimate policy objectives, such as public
health, safety, environment, public morals, financial stability, social or consumer protection, and
the promotion and protection of cultural diversity;
2305 HAVE agreed as follows:
Article 1
For the purposes of this Agreement:
"Investment" means any kind of asset that an investor of one Contracting Party owns or
2310 controls, directly or indirectly, in the territory of the other Contracting Party, in accordance with
the laws and regulations of the aforementioned party, irrespective of the legal form chosen. For
the purposes of this Agreement, an investment includes a certain duration, the commitment of
capital or other resources, and the assumption of risk. Without limiting the generality of the
foregoing, the term “investment” shall include in particular, but not exclusively:
2315 a. an enterprise;
b. movable and immovable property, and any ownership rights in rem, including real
guarantee rights on a property of a third party, to the extent that it is connected with
an investment;
c. shares, debentures, equity holdings and any other instruments of credit;
2320 d. re-invested incomes and capital gains or any service rights having an economic
value as integral part of an investment;
e. intellectual property rights, including copyright and related rights, trade-mark
rights, rights in geographical indications, patent rights, rights in industrial designs
and other intellectual and industrial property rights, know-how, trade secrets, trade
2325 names and goodwill;
87
f. any economic right accruing by law or by contract and any license and franchise
granted in accordance with the provisions in force on economic activities, including
the right to prospect for, extract and exploit natural resources;
g. turnkey, construction, infrastructure, management, production, concession, revenue-
2330 sharing, and other similar contracts;
h. any increase in value of the original investment;
i. claims to money or claims to performance under a contract;
j. credits to sums of money or credits to performance under any order, judgment,
arbitral award or under any settlement when such orders, judgments, arbitral awards
2335 or settlements relate to an investment.
Any alteration of the legal form chosen for the investments shall not affect their classification as
investments.
For greater certainty, “claims to money” does not include:
i. claims to money that arise solely from commercial contracts for the sale of goods or
2340 services by a person in the territory of a Contracting Party to another in the territory
of the other Contracting Party;
ii. the domestic financing of such contracts; or
iii. any order, judgment, or arbitral award related to sub-paragraph (k) or (l), as it lacks
the characteristics of an investment.
2345 “Control” means, in relation to any undertaking, being:
a. entitled to exercise, or control the exercise of (directly or indirectly) more than 50
per cent of the voting power at any general meeting of the shareholders, members or
partners or other equity holders (and including, in the case of a limited partnership,
of the limited partners of, or, in the case of a trust, of the beneficiaries thereof) in
2350 respect of all or substantially all matters falling to be decided by resolution or
meeting of such persons; or
b. entitled to appoint or remove:
i. directors on the board of directors or its other governing body (or, in the
2355 case of a limited partnership, of the board or other governing body of its
general partner) who are able (in aggregate) to exercise more than 50
per cent. of the voting power at meetings of that board or governing
body in respect of all or substantially all matters; and/or
ii. any managing member of that undertaking;
2360 iii. in the case of a limited partnership, its general partner; or
iv. in the case of a trust, its trustee and/or manager; or
c. entitled to exercise a dominant influence over that undertaking (otherwise than

solely as a fiduciary) by virtue of the provisions contained in its constitutional
2365 documents or, in the case of a trust, trust deed or pursuant to an agreement with
other shareholders, partners, members (or beneficiaries) of that undertaking.
“Investor” means:
i. a natural person having the nationality of a Contracting Party according to its laws;
or
88
2370 ii. an undertaking constituted on the territory of a Contracting Party in accordance with
the laws of that Party, and having its head office, as well as real business activities, on
the territory of that Party; or
iii. an undertaking controlled directly or indirectly by a person under a) or b) and
constituted on the territory of a Contracting Party in accordance with the laws of that
2375 Party; and that is making or has made an investment in the territory of the other
Contracting Party in accordance with the law of the latter.
"Territory" means the part of a land area, internal and territorial waters, air space above them,
the sea area outside the territorial waters, including the seabed and subsoil on which the
Contracting Party exercises sovereign rights, and subject to its jurisdiction, according to
2380 international law.
“Activities connected with an investment” means, inter alia, the organization, control,
operations, maintenance and disposal of companies, branches, agencies, offices or other
organizations for the conduct of business; the access to the financial markets; the borrowing of
funds; the purchase, sale and issue of shares and other securities and the purchase of foreign
2385 exchange for imports necessary for the conduct of business affairs; the marketing of goods and
services; the procurement, sale and transport of raw and processed materials, energy, fuels and
production means and the dissemination of commercial information.
[Intentionally not reproduced]
2390 Article 2
1. Each Contracting Party shall encourage the investors of the other Contracting Party to invest
in its territory and shall create and maintain in its territory, in conformity with its legal order,
a favorable legal environment, capable of guaranteeing the investors of generally stable and
equitable conditions for investment.
2395 2. Neither Contracting Parties shall set any conditions for the operation, expansion or
continuation of investments, which might imply taking over or imposing any obligations on
export production and specifying that goods must be procured locally or similar conditions.
Article 3
2400 1. Each Contracting Party, within its territory, shall offer to investors of the other party and to
covered investments, treatment no less favourable than the treatment accorded to its own
investors and their investments, or to investors of any third State and their investments, with
respect to the expansion, conduct, operation, management, maintenance, use, enjoyment and
sale or disposal of their investments in its territory.
2405 3. “Treatment” referred to in paragraph 1 does not include procedures for the resolution of
investment disputes between investors and States provided for in other international
investment treaties and other trade agreements.
4. Investment shall at all times be accorded fair and equitable treatment and shall enjoy full
protection and security.
2410 5. Neither Party shall in any way impair by arbitrary or discriminatory measures the
management, operation, maintenance, use, enjoyment, acquisition, expansion, or disposal of
investments.
89
Article 4
2415 1. The Contracting Parties reaffirm their right to regulate within their territories to achieve
legitimate policy objectives, such as the protection of public health, social services, public
education, safety, the environment including climate change, public morals, social or
consumer protection, privacy and data protection, or the promotion and protection of cultural
diversity.
2420 6. For greater certainty, the mere fact that a Contracting Party regulates through general
measures, including through a modification to its laws, in a manner which negatively affects
a covered investment or interferes with an investor’s expectations, including its expectations
of profits, does not amount to a breach of an obligation under this Agreement, as long as this
is non-discriminatory, reasonable and proportionate.
2425
Article 5
1. Neither Party shall nationalise or expropriate a covered investment either directly or
indirectly through measures having an effect tantamount to nationalisation or expropriation
except for a public purpose; in a non-discriminatory manner; upon payment of prompt,
2430 adequate and effective compensation; and in accordance with due process of law and the
general principles of treatment provided for in Article 4.
2. The compensation referred to in paragraph 1 shall amount to fair market value of the
investment expropriated, shall be made without delay, be effectively realizable and be freely
transferable in a freely convertible currency. This includes any form of currency that exists
2435 digitally or virtually and uses cryptography to secure transactions. In case there is an undue
delay with payment of the compensation for expropriation, this compensation shall include
interest according to the legislation of the respective Contracting Party.
Article 6
2440 This Treaty shall not preclude the application by either Party of measures necessary for the
maintenance of public order, the fulfilment of its obligations with respect to the maintenance or
restoration of international peace or security, and the protection of its own national security.
Article 7
2445 1. Each Party shall permit all transfers relating to a covered investment to be made in a freely
convertible currency, without restriction or delay and at the market rate of exchange
prevailing on the date of transfer with regard to the currency to be transferred. Such transfers
include:
2450 a. contributions to capital to maintain, develop or increase the investment;

b. profits, dividends, capital gains, interest, royalty payments, management fees,
technical assistance and other fees or returns derived from the investment;
c. proceeds from the sale of all or any part of the investment or from the partial or
complete liquidation of the investment;
2455 d. payments made under a contract entered into by the investor, or its covered
investment, including payments made pursuant to a loan agreement;
90
e. earnings and other remuneration of personnel engaged from abroad and

working in connection with an investment;
f. payments made pursuant to Articles 5;
2460 2. Neither Party may require its investors to transfer, or penalise its investors for failing to
transfer, the income, earnings, profits or other amounts derived from, or attributable to, their
covered investments in the territory of the other Party.
3. Notwithstanding paragraphs 1 and 2, this Article shall not be construed as preventing a Party
from applying in an equitable and non-discriminatory manner, and not in a way that would
2465 constitute a disguised restriction on trade and investment, its laws and regulations relating to:
a. bankruptcy, insolvency, bank recovery;

b. issuing, trading, or dealing in financial instruments;
c. financial reporting or record keeping of transfers where necessary to assist law
2470 enforcement or financial regulatory authorities;
d. criminal or penal offenses, deceptive or fraudulent practices;
e. ensuring compliance with orders or judgments in judicial or administrative
proceedings;
f. social security, public retirement or compulsory savings schemes.
2475
Article 8
Subject to the requirement that such measures are not applied in a manner that would constitute
arbitrary or unjustifiable discrimination between investments or between investors, Articles 5
shall not be construed to prevent a Party from adopting or enforcing measures necessary:
2480 a. to protect public morals;
b. to protect human, animal or plant life or health;
c. to ensure compliance with laws or regulations which are not inconsistent with
the provisions of this Agreement including those relating to:
2485 i. the prevention of deceptive and fraudulent practices or to deal with the
effects of a default on contracts;
ii. the protection of the privacy of individuals in relation to the processing
and dissemination of personal data and the protection of
confidentiality of individual records and accounts;
2490 iii. safety.
Article 9
An investor shall be bound by the laws and regulations in force in the host state and shall refrain
from exercising restrictive practices and from trying to achieve gains through unlawful means.
2495
Article 10
Where a Party experiences serious balance of payments or external financial difficulties, or
threat thereof, it may adopt or maintain restrictive measures with regard to transfers. Such
measures shall:
91
2500 a. be consistent with other international obligations of the Party, and with the Articles
of the Agreement of the International Monetary Fund;
b. not exceed those necessary to deal with the difficulties addressed under this
paragraph;
c. be temporary and phased out progressively;
2505 d. avoid unnecessary damage to the commercial, economic and financial interests of
the other Party;
e. be non-discriminatory compared to third countries in like situations.
A Party maintaining or having adopted measures referred to in this paragraph shall promptly
notify them to the other Party.
2510
Article 11
1. The Parties shall cooperate on issues covered by this Agreement.
2. To this end, the Parties shall establish a Committee, which shall meet once a year or at the
request of a Party.
2515 3. The Committee shall:
a. supervise and facilitate the implementation and application of this Agreement

and further its general aims;
b. consider any matter of interest relating to an area covered by this Agreement
2520 c. establish its own procedures.
Article 12
1. Any dispute which may arise between one of the Contracting Parties and an investor of the
other Contracting Party, from a covered investment including disputes relating to the amount
2525 of compensation, shall as far as possible be settled through consultation and negotiation.
2. In the event that such dispute cannot be settled as provided for in paragraph 1 of this Article
within three (3) months from the date of a written application for settlement, the investor in
question may submit at its choice the dispute for settlement to one of the following fora:
2530 a. the competent Court of the Contracting Party,

b. an ad hoc Arbitration Tribunal, in compliance with the Arbitration Rules of the
UN Commission on International Trade Law (UNCITRAL) as in force at that
time, unless another set of rules is agreed by the parties to the dispute;
c. the International Centre for Settlement of Investment Disputes (ICSID), for the
2535 implementation of an arbitration procedure, under the Washington Convention
of 18 March, 1965, on the Settlement of Investment Disputes between State and
National of other State, if this had entered into force for both of the Contracting
Parties to the dispute, or, alternatively, in accordance with the ICSID Additional
Facility Rules, if the Washington Convention has entered into force only for one
2540 the Contracting Parties.
92
3. In case of arbitration proceeding sub (b) or (c) above, an investor may only submit a claim if
the investor itself or any entity directly or indirectly controlled by it, or by which it is in turn
directly or indirectly controlled, withdraws or discontinues any existing proceeding before a
2545 tribunal or court under domestic or international law with respect to a measure alleged to
constitute a breach of this Agreement, as well as it waives its right to initiate any claim or
proceeding of the same kind with respect to a measure alleged to constitute such a breach.
The investor shall apply this provision in good faith and avoid double proceedings for the
same kind of substantial claims.
2550 4. In the event that the Investor, the investment or the State have already been satisfied under
domestic law on a claim substantially reproducing that to be addressed under this article, the
disputing Party is forbidden from proposing an arbitration.
5. In case of arbitration proceeding sub (b) or (c) above, all arbitrators appointed by the
disputing parties shall be independent, serve in their individual capacities and not be affiliated
2555 with the government of either of the Contracting Parties. All arbitrators shall have specialized
knowledge of or experience in public international law and international investment law, or in
the settlement of disputes under international investment agreements. The arbitrators shall
comply with arbitrators’ codes of conduct adopted by the Parties in Annex I (Code of
conduct).
2560 6. The UNCITRAL Rules on Transparency in treaty-based Investor-State Arbitration (the
“UNCITRAL Transparency Rules”) shall apply to disputes under this Agreement.
7. When rendering its decision, the Tribunal shall apply this Agreement as interpreted in
accordance with the Vienna Convention on the Law of Treaties, and other rules and
principles of international law applicable between the Parties. Where the Tribunal is required
2565 to ascertain the meaning and effects of the provisions of domestic law as a matter of fact, it
shall follow the prevailing interpretation made by the courts or authorities of that Party.
8. Upon the entry into force between the Contracting Parties of an international agreement
providing for a multilateral investment tribunal and/or a multilateral appellate mechanism
applicable to disputes under this Agreement, and irrespective of Article 15, the relevant parts
2570 of this Agreement shall cease to apply.
Article 13
1. In case a dispute arises between the Contracting Parties on any alleged breaches in this
Agreement, relating to its interpretation and application, this shall, as far as possible, be
2575 settled amicably through consultation and negotiation.
4. In the event that the dispute cannot be settled within six months from the date on which one
of the Contracting Party notifies the other Contracting Party in writing, the dispute shall at the
request of one of the Contracting Parties, be laid before an ad hoc Arbitration Tribunal as
provided for in this Article.
2580 5. The Arbitration Tribunal shall be constituted in the following manner: within two months
from the moment on which the request for arbitration is received, each of the two Contracting
Parties shall appoint a member of the Tribunal. The President shall be appointed within three
months from the date on which the other two members are appointed, by agreement of the
Contracting Parties.
2585 6. If, within the period specified in paragraph 3 of this Article, the appointment has not been
made, each of the two Contracting Parties may invite, in default of other arrangements, the
President of the International Court of Justice to make an appointment. In the event that the
President of the Court is a national of one of the Contracting Parties or if, for any reason, it is
93
impossible for him/her to make the appointment, the application shall be made to the Vice
2590 President of the Court. If the Vice President of the Court is a national of one of the
Contracting Parties or, for any reason, is unable to make the appointment, the most senior
member of the International Court of Justice, who is not a national of one of the Contracting
Parties, shall be invited to make the appointment.
7. The Arbitration Tribunal shall rule with a majority vote, and its decision shall be binding.
2595 Each Contracting Parties shall pay the cost of its own arbitrator and of its representative at the
hearings. The President’s cost and any other cost shall be divided equally between the
Contracting Parties. The Arbitration Tribunal shall lay down its own procedure.
Article 14
2600 By mutual consent, the Contracting Parties may amend this Agreement, or may jointly issue an
interpretative note of any provision thereof. Any such amendments and additions will be
executed by a separate protocol, which is an integral part of this Agreement, and will enter into
force as provided by Article 16 of this Agreement.
2605 Article 15
1. A Party may deny the benefits of this Agreement to an investor of another Party that is an
enterprise of such Party and to investments of such investor if investors of a non-Party own or
control the enterprise and the denying Party:
2610 a. does not maintain diplomatic relations with the non-Party; or

b. adopts or maintains measures with respect to the non-Party that prohibit
transactions with the enterprise or that would be violated or circumvented if the
benefits of this Agreement were accorded to the enterprise or to its investments.
2615 2. A Party may deny the benefits of this Agreement to an investor of another Party that is an
enterprise of such Party and to investments of such investors if investors of a non-Party own
or control the enterprise and the enterprise has no substantial business activities in the
territory of the Party under whose law it is constituted or organised.
2620 Article 16
1. This Agreement, its amendments and additions shall enter into force on the date of
receiving the last written notification confirming the implementation by the Contracting
Parties of all internal procedures necessary for its entry into force.
2. This Agreement will remain in force for the period of ten years. Thereafter, it will be
2625 automatically extended for further periods of five years, unless one of the Contracting
Parties notifies in writing to the other Contracting Party within a minimum of six months
prior to the expiration of the current period of validity, its intention to terminate it.
3. In case of investments made prior to the expiry date of this Agreement, the provisions of
this Agreement shall remain active for a further period of five (5) years from the date of the
2630 termination of this Agreement.
94
4. In witness thereof the undersigned Representatives, duly authorized by their respective

Governments, have signed the present Agreement.
2635 DONE in Siaya, Martineek on 21 January 2013 in two originals each in English.
For the Republic of Martineek

Minister of Foreign Affairs
Joseph Miles
2640 [signature illegible]
For the Federation of Albion

Minister of International Trade and Economy
Bethany Wu
2645 [signature illegible]
ANNEX I. CODE OF CONDUCT FOR ARBITRATORS

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95

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FDI Moot™ CENTER FOR INTERNATIONAL LEGAL STUDIES

FDI MOOT CASE 2023

FOREIGN DIRECT INVESTMENT

Global Orals: 2-5 November 2023

REQUEST FOR ARBITRATION ................................................................................................ 1

THE INTERNATIONAL CENTRE FOR SETTLEMENT OF INVESTMENT DISPUTES

REQUEST FOR ARBITRATION

DELOREAN TECHNOLOGIES LLC

THE REPUBLIC OF MARTINEEK

Claimant Counsel for Claimant

I. SUBMISSION OF THE DISPUTE TO ARBITRATION

1. In accordance with Article 36 of the Convention on the Settlement of Investment Disputes

II. THE PARTIES

2. Claimant, DeLorean Technologies LLC, is a multinational automotive manufacturer

30 III. SUMMARY OF THE DISPUTE

35 the robotic industry.

b) Respondent’s measures towards Claimant’s investment

c) Consequences of Respondent’s measures

IV. JURISDICTION OF THE ARBITRAL TRIBUNAL

29. Article 25(1) of the ICSID Convention provides that:

V. REQUEST FOR RELIEF

i. DECLARE that the Sanctions Law is in violation of Article 5 of the Agreement on

sought in this trial up to and including the oral stage.

200 VI. CONSTITUTION OF THE TRIBUNAL

205 Tamara Guterman

attn. Martha Black

CLAIMANT’S EXHIBIT C1 - Blueprint of the MK-1 Beetle - Modular UGV

CLAIMANT’S EXHIBIT C2 - Blueprint Variants of the MK-1 Beetle - Modular UGV

CLAIMANT’S EXHIBIT C3 - Claimant’s Tax Compliance Certificate

Taxpayer PIN : P011737492W Certificate Date: 31/12/2022

DeLorean Technologies LLC Certificate Number:

225 This is to confirm that DeLorean Technologies LLC, Personal

245 CLAIMANT’S EXHIBIT C4 - Purchase Agreement of 8 June 2021

Agreement for Sale

Name: REUBLIC OF MARTINEEK

Hereinafter: “the Parties”

Brand [intentionally omitted]

Model Name M428fdw ‘

Date ] Upon delivery

Buymt>Q€F\iB.Ltr °-t’ Vfilwetl Se||e,,Q;].Q[gqg'__]fl"lfl0]fll6.S LLC

Date: Date: O8 “Igor, "393!

Q§{;,,,e, ‘/EILIIIB-7-I ]—€v~t7.| A]3jgl|q

Signatu ' ‘ Signature:

CLAIMANT’S EXHIBIT C5 - Law Decree 134_2022 on Restrictive Measures against the

250 02.01.2023 Official Journal of the Republic of Martineek L 675

LAW DECREE 134/2022

ON RESTRICTIVE MEASURES AGAINST THE FEDERATION OF ALBION

255 THE PRESIDENT OF THE REPUBLIC OF MARTINEEK,

Having regard to the joint understanding of the Heads of Future-Technology Partners

HAS ADOPTED THIS LAW DECREE:

1. It shall be prohibited to directly or indirectly sell, supply, transfer or export to Albion

1. The purchase or sale of provision of investment services for or assistance in the

2. Transactions made by Martineek citizens or in Martineek are prohibited if they involve

3. Property and interests in property of individuals or entities directly or indirectly owned

a. necessary to satisfy the basic needs

b. intended exclusively for payment of reasonable professional fees or

d. from an account of a diplomatic or consular mission or an international

2. Notwithstanding the prohibitions on the transactions listed in Article 1(2)(3),

a. contracts for delivery of such items, technologies or assistance include

b. Albion has committed not to use or transfer such items, technologies or

Erich Paul Remark

13. DeLorean Technologies 112 Charles Street, Involvement in 30.12.2022

[…] […] […] […] […]

CLAIMANT’S EXHIBIT C6 - MK Robotics Press Release of 16 January 2021