2.1. According to the Claimants, a dispute has arisen between the Claimants and the Respondent under the Treaty between the Government of the United States of America and the Government of the Republic of Bolivia Concerning the Encouragement and Reciprocal Protection of Investment (the "US-Bolivia BIT") and 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 (the "UK-Bolivia BIT," and together with the US-Bolivia BIT, the "Treaties").

2.2. On November 24, 2010, the Claimants sent a Notice of Arbitration to the Respondent pursuant to Article IX of the US-Bolivia BIT and Article 8 of the UK-Bolivia BIT. The Notice of Arbitration was received by the Respondent on November 30, 2010.