DEMAND FOR ARBITRATION

1. Pursuant to Article 3 of the Arbitration Rules of the United Nations Commission on International Trade Law (“UNCITRAL Rules”) and Articles 1116(1), 1117(1), and 1120(1)(b) of the North American Free Trade Agreement (“NAFTA”), claimant Detroit International Bridge Company (“DIBC” or “Claimant”), on its own behalf and on behalf of its enterprise The Canadian Transit Company (“CTC”), hereby demands and commences arbitration against respondent the Government of Canada (“Canada”).

2. This proceeding arises from a dispute between Claimant and Canada arising from Claimant’s ongoing investment in the Ambassador Bridge, a privately owned international toll bridge that connects Detroit, Michigan and Windsor, Ontario. Since the Ambassador Bridge opened for service on November 11, 1929, Claimant has owned the bridge, including the associated toll-collection rights, in its entirety.1 Claimant directly owns the relevant rights with respect to the U.S. side of the bridge, and Claimant’s wholly owned subsidiary CTC owns the relevant rights with respect to the Canadian side of the bridge.

3. The Ambassador Bridge includes a bridge span, customs and toll plazas, approach roads, duty-free shops, and other associated facilities on both sides of the border. The Ambassador Bridge is the busiest crossing between the United States and Canada, facilitating more than 27% of annual trade between the two countries.