Dear Members of the Tribunal:

We have carefully reviewed the Decision on Jurisdiction and the Merits, dated September 3, 2013 (the “Decision”), and of course agree with certain important findings and conclusions that were reached by the three members of the Tribunal unanimously. For example, it is difficult to argue with the unanimous conclusion of the Tribunal that jurisdiction does not exist under Article 22 of the Venezuelan Law on the Promotion and Protection of Investments, a conclusion that excludes the bizarre US$10 billion claim of the parent entity, ConocoPhillips Company, for alleged loss of U.S. tax credits, which undoubtedly would have been rejected even if jurisdiction had existed. Likewise, we believe that the unanimous conclusion of the three arbitrators that all of the fiscal measures taken by the Republic were covered by Article 4 of the Netherlands-Venezuela bilateral investment treaty (the “Dutch Treaty”) and therefore excluded from this case is well founded. We also note that those non-discriminatory and reasonable measures would not have given rise to any claim even if Article 4 had not been applicable inasmuch as they were perfectly lawful exercises of the State’s sovereign powers.