Claimant, South American Silver Limited (“South American Silver” or, together with its predecessor, parents and subsidiary, the “Company”) hereby submits its Statement of Claim and Memorial in this arbitration proceeding against the Plurinational State of Bolivia (“Respondent”, “Bolivia” or the “Government” or the “State”) pursuant to Article 8 of 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, extended to Bermuda on December 9, 1992 (the “UK-Bolivia BIT” or the “Treaty”).

I. INTRODUCTION

1. This is a straightforward case of nationalization without compensation by the Government of Bolivia. At all pertinent times prior to the nationalization which commenced in July 2012, South American Silver, a Bermudan company, owned 100% of the shares of Compañía Minera Malku Khota (“CMMK”) through its Bahaman subsidiaries, Malku Khota Ltd., Productora Ltd. and GM Campana Ltd. CMMK is the Bolivian operating subsidiary of South American Silver Corp. (“SASC”, now TriMetals Mining Inc., “TriMetals”), a mining company focusing on the development and exploitation of silver mining projects in South America.

2. Prior to the nationalization, the Company’s business in Bolivia was established, extensive and its long-term prospects were bright. Since 1994, South American Silver and CMMK, and their predecessors, explored, discovered and developed vast mineral resources in Bolivia. In 2003, the Company identified promising silver mineralization near the village of Malku Khota in the Bolivian Province of Potosí. The Company subsequently engaged in extensive exploration efforts in the area, which led to the discovery of massive silver, indium and gallium deposits. Between 2003 and 2008, South American Silver, through CMMK, acquired or obtained title to ten mining concessions (together, the “Mining Concessions”) covering an area of 5,475 hectares centered on the Malku Khota mineral deposits (the “Project Area”).