I. INTRODUCTION 

1. The Slovak Republic hereby submits (i) its Application for Provisional Measures against Claimants seeking an order requiring Claimants to post security for the Slovak Republic’s costs in this arbitration (the “Slovak Republic’s Application”), and (ii) its Opposition to Claimants’ Application for Provisional Measures, which are now moot and unjustified in any event (the “Claimants’ Application”). 

2. Claimants are EuroGas Inc., registered by the Utah Division of Corporations as Entity No. 6050868-0142 (“EuroGas II”), and Belmont Resources, Inc. (“Belmont”) (together, the “Claimants”). The management of EuroGas II has previously been found by a U.S. federal court to have engaged in fraud, to have provided false testimony, and to have habitually reneged on its payment obligations. Both EuroGas II and its management are currently facing an additional complaint for fraud in U.S. federal court in Utah. And, as discussed below, it appears that Claimants have misrepresented their own status in this arbitration. 

3. Claimants are impecunious, carry out no business activity, and do not have the means to pay for the costs of these proceedings. The present claim is entirely funded by third parties. Any award in favor of the Slovak Republic will be against Claimants—not against the third-parties that are currently funding these proceedings. It therefore is necessary that the Tribunal grant the requested security for costs. Without that security, the Slovak Republic will suffer irreparable harm when the award on costs against Claimants is inevitably not honored.