I INTRODUCTION

A Request for Arbitration

1. On 16 February 2010, Tidewater Inc., Tidewater Investment SRL, Tidewater Caribe, C.A., Twenty Grand Offshore, L.L.C., Point Marine, L.L.C., Twenty Grand Marine Service, L.L.C., Jackson Marine, L.L.C. and Zapata Gulf Marine Operators, L.L.C. filed a Request for Arbitration under the ICSID Convention against the Bolivarian Republic of Venezuela (Venezuela or Respondent).

2. On 8 February 2013, the Tribunal delivered its Decision on Jurisdiction in which it held that it has jurisdiction only in respect of the claims made by Tidewater Investment SRL (First Claimant) and Tidewater Caribe, C.A. (Second Claimant) (together Tidewater or Claimants) pursuant to Article 8 of the Agreement between the Government of Barbados and the Government of the Republic of Venezuela for the Promotion and Protection of Investments 1994 (Barbados BIT). In light of that Decision, Claimants filed an Amended Request for Arbitration (Request) on 1 March 2013.

3. The dispute concerns the Claimants’ investment in marine support services to the oil industry in Venezuela. The factual background to the dispute is summarised in Part I C below.