I. INTRODUCTION

1. The Claimant has failed to prove that it is entitled to any of its costs in this arbitration. Its request for costs is based on unsupported allegations with respect to various procedural matters that have already been decided by the Tribunal in Canada's favour. for this reason alone, the Claimant's request should be denied in its entirety regardless of the outcome of this arbitration. In addition, the Claimant's request should also be rejected on other grounds. In particular, the Claimant asks that the Tribunal award it costs to which it is not entitled under the UNCITRAL Arbitration Rules, for which it has not pro.vided the required supporting detail, and which are excessive and unreasonable. As Canada explained in its Submission on Costs, Canada should be awarded all of its costs in this arbitration, including both its share of the Tribunal's fees and expenses, and the reasonable costs of its legal representation and assistance. 1

II. THE CLAIMANT IS NOT ENTITLED TO ANY COSTS IN THIS ARBITRATION

2. The Claimant argues that it should be awarded its costs in this arbitration because Canada's conduct resulted in prolonged proceedings and required additional costs to be incurred? However, the arguments that it offers in support of these claims are frivolous and merely ask the Tribunal to reconsider issues that have already been decided in Canada's favour. The Claimant may disagree with the decisions of the Tribunal, but that is no justification for asking that it be awarded its costs. In short, the Claimant should not be entitled to any costs in this arbitration regardless of the outcome.