1. THE PARTIES

1.1. The Applicant is the Spanish national federation for canoe kayak, Federación Española de Piragüismo.

1.2. The Respondent is the international federation for canoe kayak.

2. FACTS

2.1. Place Assignment

2.2. In August 2011 and again 8 June 2012, the Federación Española de Piragüismo (FEP, also the Applicant), claims to have requested of the Respondent that the place given up by Slovakia should have been assigned to the Spanish K2 1000m team of Javier Hernanz Agueria and Diego Cosgaya Noriega. In response to this request, the Respondent’s Secretary General, Simon Toulson stated that “the ICF’s view is not the same.” The 8 June 2012 was the second request to the Respondent, the receipt of which was acknowledged by the FEP as it quoted from the email in its application. There was no further correspondence on this subject.

2.3. Russian Place

2.4. On 30 June 2012, the Applicant claims that the Russian Canoe Federation posted online a list of athletes who would compete in various boats and events at the London 2012 Olympic Games, which list differed from the list otherwise presented for the Games. The Applicant does not advise on what date the Russian Federation’s list was presented or to whom, nor its exact contents.

2.5. On 6 July 2012, the FEP sent a request to the Respondent entitled “Complaint quota places RUS”, seeking the place for K2 1000m that it claimed the Russian athletes Ilya Medvedev and Anton Ryahov should release to its athletes. On the same day, the Secretary General of the Respondent, Mr. Simon Toulson replied that the request was denied.

2.6. On 9 July 2012, the FEP disputed the decision of the Respondent with a supplemental email. On the same day, the Respondent’s Secretary General responded, again rejecting the request with explanations.

2.7. On 10 July 2012, the FEP sent another email to the Respondent stating among others “We firmly believe it is within our right to bring our K2 1000, but you are denying us that right. Therefore, with our Government’s support as well as that of our Olympic Committee, we shall impart all the necessary legal actions in order to solve this situation, and even if we are denied to participate in the London Games, we shall follow the sport via till the TAS” and again the Secretary General responded on 11 July reiterating its position in more detail.

2.8. On 12 July 2012, the FEP acknowledged receipt of the email of 11 July and again raised objections to the Respondent’s position.

2.9. On 18 July 2012, the FEP corresponded again with the Respondent and the Respondent replied that the letter of Mr. Toulson of 11 July was the final response.