I. SUMMARY

1. Through the undersigned legal representatives, Mr Bidzina Ivanishvili submits this final Notice of Dispute to the Government of Georgia. The dispute arises from the illegal treatment of his investments in two Georgian commercial banks: JSC Cartu Bank and JSC Progress Bank.

2. On 7 October 2011, Mr Ivanishvili announced his intention to form an opposition party challenging the current Georgian Government in the nation's October 2012 parliamentary elections. Within days, the Georgian Government began a sustained campaign of intimidation, expropriation and other unlawful conduct towards Mr Ivanishvili and his assets, coordinated across all arms of the State: the Executive, the Legislature, the Judiciary and even the Central Bank: the National Bank of Georgia.

3. Georgia's campaign against Mr Ivanishvili has been an attack on many fronts. The President revoked his Georgian citizenship. State officials falsely accused him of money laundering and pressured customers to abandon and defraud his bank. At the same time, Parliament rewrote Georgian law for ulterior purposes to allow any bank's security interests to be superseded by government tax claims, throwing every secured transaction in Georgia into disarray. Georgian tax and enforcement authorities then enforced the new laws only against JSC Cartu Bank – one of 19 commercial banks in Georgia – in a targeted and discriminatory plan that stripped Mr Ivanishvili's bank of assets worth more than GEL 190,000,000 (US$ 114.6 million). The Georgian courts later rubber-stamped these systematic abuses of State power.