The States Parties to the present Convention, Desiring to promote international trade and investment through enhanced judicial co-operation,

Believing that such co-operation can be enhanced by uniform rules on jurisdiction and on recognition and enforcement of foreign judgments in civil or commercial matters,

Believing that such enhanced co-operation requires in particular an international legal regime that provides certainty and ensures the effectiveness of exclusive choice of court agreements between parties to commercial transactions and that governs the recognition and enforcement of judgments resulting from proceedings based on such agreements,

To Claimant Maria Victoria Altmann, also acting on behalf of Peter John Gerald Bentley, formerly Peter Heinz Bloch-Bauer; Michael Bentley; Lisa Turner, née Bentley; Susan Kololian, née Bentley; Barbara Hislop, née Bentley; Joan Ball, née Bentley; Francis Gutmann; Nelly Auersperg, née Gutmann; George Bentley; Trevor David Mantle; Elizabeth Jarvis, née Prentice, formerly Elizabeth Pick; and Marietta Hurst, née Prentice, formerly Marietta Pick represented by E. Randol Schoenberg

The Claimant, Methanex Corporation (“Methanex“), initiated this arbitration against the Respondent, the United States of America (the “USA“), on 3rd December 1999 under Chapter 11 of the North American Free Trade Agreement (“NAFTA“), as a Canadian investor. As formulated in its Original Statement of Claim of 3rd December 1999, Methanex claimed compensation from the USA in the amount of approximately US$ 970 million (together with interest and costs), resulting from losses caused by the State of California's ban on the sale and use of the gasoline additive known as ‘ ‘MTBE'’ (methyl tertiary-butyl ether) which was then intended to become legally effective on 31st December 2002. MTBE is a synthetic, volatile, colourless and organic ether, with a turpentine-like taste and odour. Methanex was (and remains) the world's largest producer of methanol, a feedstock for MTBE. It has never produced or sold MTBE.