On March 22, 2002, the International Centre for Settlement of Investment Disputes (“ICSID” or “the Centre”) received a request for arbitration against the Republic of Turkey (“Turkey” or the “Respondent”) from PSEG Global Inc. (PSEG), a company incorporated under the laws of New Jersey in the United States of America (USA); the North American Coal Corporation (“North American Coal”), a company incorporated under the laws of the state of Delaware in the USA; and Konya Ilgin Elektrik Üretim ve Ticaret Limited Sirketi (the “Project Company”), described in the request for arbitration as a special purpose limited liability company incorporated under the laws of Turkey and wholly owned through several subsidiaries by PSEG (together referred to as the “Claimants”).