STATEMENT OF ISSUES

ISSUE 1: WHETHER CII AND UAPL ARE PERMITTED TO HAVE A FOREIGN SEAT OF
ARBITRATION BEING TWO KATALONIAN PARTIES UNDER CLAUSE 20 OF THE
FBA.

ISSUE 2: WHETHER USPL CAN ENFORCE THE AWARD UNDER SECTION 48 OF THE
ARBITRATION AND CONCILIATION ACT, 1996 OR THROUGH THE ENFORCEMENT
OF FRENCH ORDER UNDER SECTION 44A OF CODE OF CIVIL PROCEDURE, 1908.

ISSUE 3: WHETHER IBC ENJOYS SOVEREIGN PROTECTION/IMMUNITY FROM THE

JURISDICTION OF KATALONIAN COURTS.

ISSUE 4: WHETHER THE SUM STIPULATED IN CLAUSE 19 OF FREINDSHIP AND

COOPERATION AGREEMENT (FCA) ARE IN NATURE OF PENALTY OR LIQUIDATED
DAMAGES.