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: