I. INTRODUCTION

1. Claimant, the Renco Group, Inc. (''Claimant" or "Renea"), respectfully submits this Opposition to the Preliminary Objection Under Article 10.20(4) dated February 20, 2015 asserted by Respondent, 1 the Republic of Peru ("Respondent" or "Peru") pursuant to Procedural Order No. 1 dated August 22, 2013 ("P.O. No. 1 ").

2. For over a year, the Parties engaged in a lengthy process to determine which objections Peru could bring under Article 10.20( 4) of the United States-Peru Trade Promotion Agreement signed on April 12, 2006 (the "Treaty").2 Per agreement between the Parties, as reflected in the schedule attached as Annex A to P.O. No. I, Renco filed its Memorial on Liability on February 20, 2014. Thereafter, on March 21, 2014, again in accordance with the agreement reached and reflected in Annex A to P .0. No. I, Peru filed its Notice of Intention to File Preliminary Objections Pursuant to Article 10.20(4) of the Treaty (the "Notice of lntention").3

3. In its Notice of Intention, Peru listed all of the preliminary objections that it proposed to bring under Article 10.20(4), and as the Tribunal required, Respondent's Notice of Intention described its proposed preliminary objections in sufficient detail so that Claimant could assess whether or not it believed that the objection properly fell within the mandatory ambit of Article 10.20(4).

4. From March through October 2014, the Parties made extensive written submissions concerning whether any of these objections fell within the scope of Article 10.20(4). The Parties' submissions included written comments on the U.S. Government's submission dated September 10, 2014 interpreting the scope of Article 10.20(4).4