I. INTRODUCTION

1. Guaracachi America, Inc. (Guaracachi America, or GAI), a company incorporated in the United States of America, and Rurelec PLC (Rurelec), a company constituted under the laws in force in the United Kingdom (collectively, the Claimants) submit this Statement of Claim in support of their claims against the Plurinational State of Bolivia (Bolivia, or the Government). The present Statement of Claim is submitted pursuant to Article 20 of the 2010 Arbitration Rules of the United Nations Commission on International Trade Law (the UNCITRAL Rules) and paragraph 12 of the Tribunal’s Terms of Appointment and Procedural Order No. 1 dated 9 December 2011.

2. Guaracachi America and Rurelec bring these claims as US and UK investors, pursuant to the Treaty between the Government of the United States of America and the Government of the Republic of Bolivia Concerning the Encouragement and Reciprocal Protection of Investment (the US Treaty)1 and the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the Republic of Bolivia for the Promotion and Protection of Investments (the UK Treaty) (together, the Treaties).2