The narrow issue for determination in the Respondent’s Preliminary Objection is whether Claimants were required to discontinue the Domestic Proceedings prior to submitting their claims to arbitration under CAFTA Chapter 10. In this Rejoinder, the Claimants establish that they fully complied with jurisdictional requirements with respect to the submission of their Waivers (Section II) and that there was no requirement under CAFTA to request the discontinuance of the Domestic Proceedings as a pre-condition to submitting a claim to arbitration. The Claimants demonstrate that the Respondent’s interpretation of Art. 10.18 would impermissibly add a restrictive jurisdictional requirement that is unsupported by the clear text of CAFTA.