1. The Investor submits this Response to the Second Article 1128 Submissions made by the Government of the United States and by the Government of the United Mexican States on June 12, 2015.1

2. The Second Article 1128 Submissions of the United States and of Mexico with respect to the Bilcon Award re‐opened matters previously canvassed by the non‐disputing Parties and otherwise argued by the disputing parties in the Mesa arbitration. The Second US Article 1128 Submission re‐argues the first US Article 1128 Submission too.

3. We note that neither Mexico, nor the United States, takes issue with the unanimous interpretations provided by the Bilcon tribunal on the issues of state responsibility, attribution and on jurisdiction.

4. This Response will address the following points raised in both submissions:

a) The Proper Approach to the Interpretation of the Treaty;

b) National Treatment; and

c) The International Law Standard of Treatment.