On May 29, 2002, the shareholders of National Cotton Company (“NCC”) — Champion Trading Company, a Delaware (USA) incorporated company, Ameritrade International, Inc., another Delaware (USA) incorporated company, together with James T. Wahba, John B. Wahba and Timothy T. Wahba — submitted to the International Centre for Settlement of Investment Disputes (“ICSID” or “the Centre”) a Request for Arbitration directed against the Arab Republic of Egypt.