This is an application to set aside the Award on Jurisdiction and Liability dated 17 March 2015 (the “Award”) made by an Arbitral Tribunal constituted under Chapter 11 of the North American Free Trade Agreement (“NAFTA”), concerning an arbitration arising between William Ralph Clayton, William Richard Clayton, Douglas Clayton, Daniel Clayton (the “Claytons”) and Bilcon of Delaware, Inc. (“Bilcon”) and the Government of Canada (“Canada”) in Permanent Court of Arbitration Case No. 2009-04. The Award is a final award with respect to liability and jurisdiction. The damages phase of the arbitral proceeding is pending.

The applicant, the Attorney General of Canada, makes application for:

 1. An Order setting aside the Award;

 2. An Order granting the applicant its costs of this application; and

 3. Such further and other relief as counsel may advise and as to this Honourable Court may seem just.