I. INTRODUCTION AND SUMMARY OF CLAIMANT’S CLAIMS

1. Pursuant to Article 15 of the Ley de Inversiones of El Salvador (“Investment Law”),1 Claimant Pac Rim Cayman LLC (“PRC”), on its own behalf and on behalf of its Enterprises, Pacific Rim El Salvador, S.A. de C.V. (“PRES”) and Dorado Exploraciones, S.A. de C.V. (“DOREX”) (collectively, the “Enterprises”), respectfully submits this Memorial on the Merits (“Memorial”) in support of its claims against Respondent, the Republic of El Salvador (“Respondent,” “El Salvador,” “GOES,” or the “Government”). PRC, PRES, and DOREX are collectively referred to herein as “Claimant.”

2. PRC is a limited liability company under the laws of Nevada, U.S.A. PRC is an environmentally and socially responsible mining company. It supports robust environmental protection and fair mineral royalty payments. PRC’s parent company, Pacific Rim Mining Corporation (“PRMC”), is a public company established under the laws of Canada. PRMC and its subsidiaries, including Claimant, are collectively referred to herein as “Pac Rim,” the “Pac Rim Companies,” or simply the “Companies.”

3. In the nearly four years that have passed since Claimant filed its Notice of Arbitration, this Tribunal has been presented with a myriad of facts, legal arguments, expert opinions, witness testimony, and documents – and will understand that Claimant is now providing even more detailed arguments with this submission. In light of this, and before proceeding forward with the merits of Claimant’s claims, it is helpful to take a step back from all of the controversy introduced by Respondent’s successive rounds of preliminary objections.