I. THE PARTIES’ REQUESTS

1. The Claimant requests the Tribunal to order that Singapore be the place of arbitration.1

2. The Respondent requests the Tribunal to order that London, United Kingdom be the place of arbitration.2

II. BACKGROUND OF THE DISPUTE

3. According to the Notice of Arbitration, the dispute arises from the enactment and enforcement by the Respondent of the Tobacco Plain Packaging Act 2011 and the effect it has on investments in Australia owned or controlled by the Claimant. The Claimant alleges, inter alia, that “[t]he plain packaging legislation bars the use of intellectual property on tobacco products and packaging, transforming [the Claimant’s wholly owned subsidiary] from a manufacturer of branded products to a manufacturer of commoditized products with the consequential effect of substantially diminishing the value of [the Claimant’s] investments in Australia.”3