REQUEST FOR ARBITRATION

Claimants Emmis International Holding, B.V., Emmis Radio Operating, B.V., MEM Magyar Electronic Media Kereskedelmi és Szolgáltató Kft., Accession Mezzanine Capital, L.P. and Danubius Kereskedőház Vagyonkezelő Zrt. (henceforth, the Claimants) hereby submit to arbitration administered by the International Centre for Settlement of Investment Disputes (ICSID) the following dispute with the Republic of Hungary (the Respondent or the Republic):

I. SUMMARY OF THE DISPUTE1

1. This dispute concerns the Respondent’s unlawful expropriation of the Claimants’ investments in Hungary and related measures. The Claimants made large investments in nationwide FM-frequency radio-broadcasting licenses in Hungary at and/or after the launch of the Sláger and Danubius radio stations in 1997. In acquiring, managing and operating those investments, the Claimants relied on guaranteed legal protections for their rights and interests, including the commitment to treat their investments fairly and strictly in accordance with Hungarian law.