601. Under the Denmark-Russia BIT, as there is not any limiting language, it is very crystal clear that its arbitration clause in Write-up 8 gives jurisdiction regarding the security granted in Write-up four of that BIT for expropriation. For that reason, by means of the MFN clause in Write-up 3 IPPA, the existing Tribunal does have jurisdiction in

Third, the damages Claimant seeks are based on an analysis at odds with the statements in Claimant’s Reply that Yukos' tax assessments were not them selves expropriatory steps. As the supplemental skilled report of Professor James Dow reveals, LECG’s calculation of damages, on which Claimant depends, is based on the same "retroactive" tax promi