1. The Tribunal, by Procedural Order No. 2 dated December 1, 2014, classified as "highly confidential" certain information described in Exhibit A to Annex A of said Procedural Order No. 2 (the "Protected Information), relied upon by the Claimant's expert, Roscoe Postle and Associates, Inc. ("RPA"), in preparing its expert report dated September 16, 2014 ("RPA Report).
2. By message of December 2, 2014, and pursuant to paragraph 10.3 of Procedural Order No. 1, the Secretary of the Tribunal requested the Parties to indicate by December 12, 2014, any redactions to Procedural Order No. 2 they considered necessary prior to its publication on the PCA's website.
3. By letter dated December 12, 2014, the Respondent requested that the Tribunal reconsider paragraphs 5, 6, 7 and 8 of the Protective Order attached to Procedural Order No. 2 (the "Protective Order") and order the Claimant to provide Bolivia's counsel and independent experts with the original version (native files) of the documents listed in Exhibit A of the Protective Order, including the GEMS database that was provided to RPA (the "Request"). The Respondent, while acknowledging that the information classified as "highly confidential deserves some degree of protection, argues that the conditions set forth in the Protective Order exceed those strictly necessary to protect the interests of South American Silver Limited ("South American Silver") and impose undue restrictions and burdens on the Plurinational State of Bolivia (`Bolivia7), which affect its ability to present its case in this arbitration. In addition, in the Request, the Respondent indicates, inter alia, that: