A. THE PARTIES

1. The Claimants

1. The Claimants are Quiborax S.A. ("Quiborax"), a Chilean mining company, Mr. Allan Henry Isaac Fosk Kaplún ("Allan Fosk"), a Chilean national, and Non-Metallic Minerals S.A. ("NMM"), a Bolivian mining company (collectively, the "Claimants").

2. Quiborax, a corporation created under the laws of Chile, is a mining company dedicated in particular to the extraction of ulexite, a non metallic mineral, and to the manufacture of products derived from this mineral, including boric acid. It operates in the northern part of Chile, near the border with Bolivia, and it is mostly owned by members of the Fosk family. Allan Fosk is the Chief Financial Officer of Quiborax. NMM, a corporation created under the laws of Bolivia, is a mining company that operates in the Río Grande Delta in Bolivia. Who actually owns NMM is one of the issues lying at the heart of this jurisdictional dispute.

3. The Claimants are represented in this arbitration by Andrés Jana, Jorge Bofill, Johanna Klein Kranenberg, Ximena Fuentes, Rodrigo Gil, and Constanza Onetto of BOFILL MIR & ALVAREZ JANA.

2. The Respondent

4. The Respondent is the Plurinational State of Bolivia ("Bolivia" or the "Respondent").