The Geneva Chamber of Commerce ("CCIG"), founded in 1865, serves as a permanent and impartial institution overseeing international arbitrations. Today, it is one of seven Chambers of Commerce in Switzerland that has harmonized its arbitration services under the Swiss Rules of International Arbitration ("Swiss Rules"). Between 2004 and 2010, a total of 479 requests for arbitration were filed under the Swiss Rules, about half of which were administrated by the CCIG. These requests for arbitration involved parties mostly from Western and Eastern Europe (59%) and Switzerland (21%) but also from America, Asia, Africa and the Middle East (20%). Most of the disputes arose from the purchase and sale of goods; mergers and acquisitions; service contracts, distribution and agency issues; and matters in intellectual property. 105 cases were settled and 166 awards were rendered.

The Swiss Rules do not limit the remedies that parties can seek. Article 18(2)(d) of the Swiss Rules provides that a Statement of Claim shall include "[t]he relief or remedy sought," without specifying what such relief or remedy may consist of and without restricting parties in any way. Requests for the performance or the omission of a particular act do occur and have been granted by arbitral tribunals acting under the Swiss Rules.

Research relating to performance as a remedy was conducted based upon a review of arbitral awards since 2007 in cases administrated by the CCIG under the Swiss Rules. In the majority of cases, research showed that the parties sought monetary relief relating to, in particular, payment of goods, fees or rents; compensation for damages; and royalties. Often, such relief was coupled with a request for a declaration by the arbitral tribunal, for instance to confirm that the opposing party was in breach of its obligations.