Dear Members of the Tribunal:

The Renco Group, Inc. (“Claimant” or “Renco”) makes this submission pursuant to Procedural Order No. 1, challenging the scope of preliminary objections that the Republic of Peru (“Respondent” or “Peru”) proposes to bring in these proceedings under Article 10.20(4) of the United States/Peru Trade Promotion Agreement (the “Treaty”), because all but one of Peru’s preliminary objections are beyond the scope of Article 10.20(4) of the Treaty and thus do not belong in the “Article 10.20(4) Phase” of these proceedings established to Procedural Order No.

1, Annex A.

I. Introduction and Overview

In its March 21, 2014 submission, Respondent raises the following six preliminary objections under Article 10.20(4) of the Treaty: