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I. NAME AND ADDRESS OF THE DISPUTING INVESTORS
1. The name and address of each Claimant/Investor is listed in Annex 1, attached.
II. BREACH OF OBLIGATIONS
2. The Claimants allege that the United States has acted inconsistently with its obligations under Section A of Chapter 10 of the USPFTA, with respect to the following provisions:
i) Article 10.3 – National Treatment;
ii) Article 10.4 – Most-Favored-Nation Treatment; and
iii) Article 10.5 – Minimum Standard of Treatment.
3. In relevant part, the text of each applicable USPFTA provision is as follows: