I. INTRODUCTION AND SUMMARY OVERVIEW

1. Claimant, the Renco Group, Inc. (“Claimant” or “Renco”), respectfully submits this Supplemental Opposition to Peru’s Preliminary Objection Under Article 10.20(4) dated February 20, 2015,1 which the Republic of Peru (“Respondent” or “Peru”) filed pursuant to Procedural Order No. 1 dated August 22, 2013 (“Procedural Order No. 1”). This submission (“Supplemental Opposition”) should be read with Renco’s Opposition to Peru’s 10.20(4) Objection dated April 17, 2015 (“Opposition”), which together respond to Peru’s 10.20(4) Objection in full.

Procedural History

2. As the Tribunal will recall, after a lengthy process that lasted over one year, the Parties agreed to a schedule for the briefing of Peru’s proposed objections under Article 10.20(4) of the Treaty, and the schedule was attached as Annex A to Procedural Order No. 1. On March 21, 2014, Peru filed its Notice of Intention to File Preliminary Objections Pursuant to Article 10.20(4) of the Treaty (the “Notice of Intention”).2 In its Notice of Intention, Peru listed all of the specific 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 it believed that the objection properly fell within the mandatory ambit of Article 10.20(4).