Clarification Requests 20191

Teams who have received their Team Alias may submit requests for clarification of the case, e.g. of factual ambiguities, if the States have ratified a particular convention, etc. The case committee will be reluctant to respond to requests that ask for a legal conclusion. There are two (2) rounds of clarifications, Round 1 in June and Round 2 in August (please observe the deadlines on the schedule). In each round, each team may submit up to five (5) requests. Each request may contain one (1) question only. Please review below the requests submitted by all teams to avoid duplicate questions (and conserve your team's five requests).

Round 1

Did the Communications Authority of the Republic of Tyrea execute an ordinance blocking FriendsLook even before the deadline for development of the new algorithm had come to an end?

When were the Claimants forced to shut down their operations in Tyrea?

Req. No: 33 “Unofficial” measures taken by Claimants
Which “unofficial” measures taken by Claimants are confirmed by evidence and what is the precise evidence on each of them?

Req. No: 34 Consequences of measures taken by Tyrea
What were the actual consequences of measures taken by Tyrea against social media platforms?

Req. No: 35 Possibility to bring collective claims under Tyrean legislation
Did Tyrean legislation provide for collective claims at the time of conclusion of ICSID Convention and BIT?

Req. No: 36 Difference between the Claimants
Are SpeakUpMedia, Whistler and FriendsLook different in terms of operating principles?

Req. No: 37 Effect of measures taken by Tyrean government on other social media in Tyrea
Did the measures taken by Tyrean government affect other social media in Tyrea, either local or foreign (if any)?

Req. No: 89 Algorithm
How much time did the algorithm take to produce output for one user?

What is the definition of ‘investor’?

Did the websites that weren’t blocked receive a penalty for algorithm inefficiency?

Req. No: 42 blocking of websites
Did the social/civil unrest stop or reduce in anyway after blocking the websites?

Are the numbers in the Damages Report correct?

Req. No: 32 blocking of websites
Did the Government block the three websites (Friendslook, Whistler, SpeakUp Media) temporarily or permanently?

Does the agreement between the Third Party Funders (TPF) and the Claimants result in the TPF sharing in any economic benefit accruing to the Claimants from any Award in this proceeding?

Regarding Para 25 of the Uncontested Facts were any of the “unofficial measures” confirmed by evidence additional to the Exhibits previously files in this case?

Following the “blocking” of the Claimants’ webpages, how significantly, if at all, how significantly did the violence referred to in Paragraph 21 of the Uncontested Facts decline?

Req. No: 25 OTHER BITS
Has Tyrea changed its treaty status in either of its BITs with Novanda (28 Mar 2000) or Kitoa (20 Jan 2001)?

Are there any other non-Tyrean social media platforms currently operating inside Tyrea?

Req. No: 87 Formal constitutional process
Whether a formal constitutional process was followed and debate conducted by Tyrean political organs for denunciation of the ICSID convention? And whether the discussion was made public so that it would have come to the claimant's knowledge, before the official denunciation?

Req. No: 81 Claimants' advertisements
If a Tyrean company decides to put an ad on Claimant's website, will the ad still be available on the international version of the website, regardless of the blocking?

Req. No: 82 Claimants' business operations in Tyrea
Was claimant's office in Tyrea still operates daily regardless of the non-activity of their websites?

Req. No: 84 Claimants' profits
Does the 2018 projected profits include profits made from January to March?

Req. No: 85 Respondent's Damages calculation
Does the proven expenditure refer to Claimants’ initial investment or simply the cost incurred by Claimants in 2018?

Req. No: 86 Claimant's Discount rate Calculation
What are the risks incorporated in the 5% discount rate?

Req. No: 63 Claimants' WACC Calculation
What risks are incorporated in Mr Alonzo's WACC calculation and their own percentage respectively?

Req. No: 64 Cost Requested in Provisional Measure
In page 38, par. 12, Tyrea requested that the Tribunal “grant the requested provisional measures and award Tyrea all the costs in connection herewith”. Does the “cost” in this case refer to costs relating to the arbitration proceeding or compensation for damages incurred as an effect of the Claimants’ publication?

Req. No: 65 Claimants' Exhibit 7 Calculation
Why does the Claimants' expert report only include the operational cost of the claimants' investment until the time of the blocking in 2018 while the revenue was projected until the end of 2018?

Req. No: 66 Interest on the Damage
How much interest are the Claimants requesting for their damages claim?

Req. No: 119 Respondent State member of UN or a party to any other treaty?
Is the Respondent State (Tyrea) is a party to any international treaty or the UN?

Req. No: 120 Respondent State's relation with Union of Kitoa
Does the Respondent State (Tyrea) share any special relationship with the Union of Kitoa in the form of special treaties or historical significance?

Req. No: 62 Para no 1675,
what are the unofficial provisional measure referred here and which authority has confirmed it, under what basis

Req. No: 83 Pg. 4, Para 140
"order to the national internet service providers" are there other internet service providers (except national internet service providers) as well operational in Tyrea? If yes what is there market cover and operation?

Req. No: 4 typo on the BIT
1. In the paragraph 1685, the art. 1 (b) of the BIT Tyrea-Novanda has two sections with the same roman number (i). Is this a typo or both sections are numbered with the same roman number

Req. No: 5 Claimants structure
What was the purpose of this office, to serve which objectives?

Req. No: 6 Claimants structure
2. Regarding the facts of paragraph 105, did the local office of Friendslook have stuff? Did it have more than one employee?

Req. No: 7 Companies affected by the media blocking
3. Did the rest of the social media companies in Tyrea comply with the new measures? And if not, did they face blocking, as in the case of Claimants?

Req. No: 3 Truthseeker
What is the corporate structure of Truthseeker?

Req. No: 16 Claimants's operations in Tyrea
In line 736-738, when did the Claimants decide to wind down all operations in Tyrea and why did they do it?

Req. No: 8 Notification of blocking and negotiations
Did the Claimants try to negotiate with the Respondent about the blocking of their websites, before and after it happened?

Req. No: 9 Calculation of projection for 2018
How is the projection of revenues, costs and profits for 2018 calculated in the expert report on damages?

Req. No: 10 Influence of Claimants over website contents
Do Claimants have any influence over the published content of the websites and digital newspapers cited in para. 3 of the Request for Provisional Measures?

Req. No: 11 Origins of sponsored adds
Is there are information about the origins of the sponsored adds, allegedly directed against the Respondent, on FriendsLook platform as mentioned in para. 2 of the Request for Provisional Measures?

Req. No: 12 Implementation of the algorithm
Was the Respondent aware of the difficulties associated with the use of the algorithm (e.g. language difficulties) and the time period required for effective implementation?

Req. No: 113 Notice of Dispute Prior to Denunciation
Was there any communication between the parties prior to Tyrea’s submission of the Notice of the ICSID Convention Denunciation on 05/01/2018?

Req. No: 115 Specific provisional measures requested
What are the specific provisional measures Respondent is requesting from the Tribunal?

Req. No: 116 Audience of Tyrea's social media platforms
What are the respective audience numbers and influence capacity of the different social media platforms operating in Tyrea?

Req. No: 117 Claimants' business plans
Did the Claimants adopt the detailed business plan referred to by Professor DiMarco?

Req. No: 118 Data protection legislation in Tyrea
What is the Data protection Law in Tyrea?

Req. No: 102 Notice of Dispute as consent prior to the Request for Arbitration
Did the Claimants submit a notice of dispute prior to file the Request for Arbitration?

Req. No: 103 Blocking of other social media platforms
In paragraph 145 the Claimants argue that the Respondent did not block other social media networks. If true, was it because those platforms were able to develop the algorithm within the term required or because they did not show the prejudicial content that the Claimants do?

Req. No: 105 BITs Drafting History
Is there any element in the drafting history of the BITs showing that Tyrea was willing to agreed to multiparty arbitrations?

Req. No: 104 Government Representatives
What was the hierarchy of the Tyrean Government Representatives who stated that social platforms would be encouraged?

Req. No: 14 Vienna Convention on the Law of Treaties
Are Tyrea, Novanda and Kitoa parties to the Vienna Convention on the Law of Treaties.

Req. No: 59 Domestic Laws
Were the domestic procedural laws of Tyrea, Novanda and Kitoa familiar with multiparty proceedings at the time when each of them became a party to the ICSID Convention and consented to the BITs.

Req. No: 50 FriendsLook shares
Were FriendsLook shares' value in NASDAQ affected by the blocking?

Req. No: 51 Enactment of Law 0808-L
Was Law 0808-L enacted in accordance with the Tyrea's legislation?

Req. No: 52 Claimants business worldwide
Have Claimants been successful with similar projects in other countries with similar social and economic conditions?

Req. No: 53 2015 Claimants’ financial statements
What were the 2015 Claimants’ financial statements?

Req. No: 54 Taxes in Tyrea
Did Claimant’s pay taxes in Tyrea over the amounts received by running ads?

Req. No: 93 The deadline days
In paragraph 15 of uncontested facts, "the new decree reduced the deadline for compliance with the new requirements to 45 days”. However, in paragraph 11 of the request for arbitration, “Respondent slashed the 60-day period to 40 days”. Why are there conflicts between them (45 days & 40 days)?

Req. No: 95 The Compensation
In Summary of the damage report of Claimant, how do the numbers of the Lost Profits come from? Why are they different from those in Line 550?

Req. No: 97 Judicial review
Is there a judicial review procedure in Tyrea and is it accessible to foreign investors?

Req. No: 98 Respondent measure
Did Respondent take any other measures to manage the ethnic conflicts?

Req. No: 100 Denunciation
Did Claimants know about the denunciation when they filed the request for arbitration??

Req. No: 67 Funding the the claim
Would the Claimants have been capable of funding their claims separately?

Req. No: 68 Arbitrary conduct
If the Claimants had been successful at developing and implementing the algorithm even after they had been shut down, would Respondent have reinstated the social media platforms.

Req. No: 70 Damages calculation
Is there any data on the Claimants' previous financial performance when entering a new market?

Req. No: 72 Membership of the Vienna Convention
Are all the states involved signatories to the Vienna Convention on the Law of Treaties?

Req. No: 112 Social media
How media savvy are the people of Tyrea? Can they distinguish between fake news and serious journalism and do the Claimants provide any service to assist people in making that distinction?

Req. No: 73 Establishment of "Wink"
When was the local company „Wink“ established?

Req. No: 75 Alternative methods and calculation
When answering the issue of damages in para. 6.2(e) of Procedural Order No. 1, If DCF is found not appropriate to calculate the damages, by proposing another method is it necessary to do the calculation as well?

Req. No: 77 Caculation and "stage 2" of proceeedings
Does the “stage 2” mentioned in para. 6.4 of Procedural Order No. 1 include the method for quantification of damages mentioned in para. 6.2(e) of Procedural Order No. 1?

Req. No: 78 Deadlines for submissions
Are the dates mentioned in para. 7.1 of Procedural Order No. 1 correct or do we follow the deadlines displayed on the website?

Req. No: 27 Nature of social media platforms not blocked
It is important to know be whether those social media platforms which have not been blocked by the Tyrean Government are nationals of the state or investors just like those which have been banned?

Req. No: 28 Decision on jurisdictional objections
The denunciation was sent on the 5th of January 2018 with immediate effect and the Request for Arbitration was submitted on 29th of June, 2018. If it is possible, we would like to know if the Tribunal decided on the jurisdictional objections?

Req. No: 29 Claimant’s planned expansion were reported or not
Did the claimants previously report their planned expansion to the government?

Req. No: 30 Human rights agreements ratified by the Respondant
Do we know if there are any international agreements on human rights that Tyrea has ratified?

Req. No: 31 Ratification and conclusion of BIT
According to page 58 the BIT was concluded on 15 December 2000. However, on p 48 we are informed that the same agreement was ratified on 10 December 2000. Is it possible that such an agreement can be ratified before it is actually concluded?

Req. No: 94 Assessment of damages
Did the Claimants continue to work on the algorithm after the issuance of the Decree?

Req. No: 96 Claimant’s shareholding
What are the major shareholders of Claimants and, as the case may be, are Claimants owned by the same shareholders?

Req. No: 17 Effect of the Social Media Blocking
Did the violence in Tyrea deescalate after the blocking of Claimants social media websites?

Req. No: 18 Compliance with the Presidential Decree
Did all the unblocked social media platforms comply or attempt to comply with the Decree?

Req. No: 19 Nature of Truth Seeker
Page 51 para 13 mentions that Truth Seeker had a feature that “corrected facts in case they were incorrect”. Which party was in charge of identifying the accuracy of these statements and subsequently correcting it?

Req. No: 20 Nature of the Decree
Was the Respondent’s act of blocking the Claimants’ social media platforms a temporary or permanent solution?

Req. No: 21 Effect of the Decree
After the Claimants’ platforms were blocked, did the other unblocked social media platform increase in their popularity?

Req. No: 109 Political situation
Has the political situation in Tyrea worsened in the meantime? If so, have other platforms used by radicals been blocked as well?

Req. No: 110 Hashtags
Do all the social media (FriendsLook, Whistler, SpeakUp, Wink and TruthSeeker) support hashtags?

Req. No: 121 Projected Cash Flow
What is the projected cash flow and actual cash flows used to reach the amounts of $17M, 9M, and 8.5M?

Req. No: 122 Projected Expense
What was the projected expense of claimants for 2018?

Round 2

Req. No: 135 Domestic legislation of States of Investors
Does the domestic legislation of Federation of Novanda and Union of Kitoa provide for multi-party arbitration or collective claims?

Req. No: 177 Statements regarding future denunciation
Did Tyrean officials make any public statements regarding Tyrean intention to denounce ICSID Convention before sending a notice of denunciation to the World Bank?

Req. No: 178 Tyrea Country Risk Rate
What was the country risk rate for Tyrea as of the valuation date?

Req. No: 179 Tyrean World Expo Bid
Did Tyrea make a bid for hosting World Expo specifically in the year of 2025, taking into account the fact that WorldExpo 2025 will be hosted by Japan as was decided on 23 November 2018?

Req. No: 180 Tyrean Independence and BITs
Was Tyrea independent in 2000s when Tyrea-Kitoa and Tyrea-Novanda BITs were signed?

Req. No: 181 Liability of other social media in Tyrea
Were Wink and TruthSeeker subjects to punishment in the form of fine under Tyrean Criminal Code for non-compliance with the Law 0808-L?

Req. No: 182 Projections for 2018
Were the projections for 2018 already discounted, and if so, what was the risk premium (including country risk and other political, economic, financial risks) incorporated in the projections?

Req. No: 183 Costs to be incurred by Claimants in March - December 2018
What were the costs to be incurred by Claimants in March - December 2018 and why are they not reflected in the projections for 2018?

Req. No: 185 Scope of the argument regarding the damages
What is the scope of the argument regarding the damages for the loss of opportunity for market expansion?

Req. No: 186 Procedural order of implementing the blocking: negotiations, notification, judicial review
Are there any provisions in the Respondent’s law on the need to provide notice or negotiations or simply any notifying procedure prior to implementation of severe measure (permanent blocking) as well as provisions on a procedure for appealing this measure?

Req. No: 188 Study on the implementation of the algorithm by social media
What was the content of «investigating the matter» in the line 1625 of the Record («On 28 February, 1 March and 2 March 2018, the TCA, after investigating the matter, issued the ordinance blocking the Claimants’ websites»)?

Req. No: 207 Truthseeker
Has Truthseeker made an algorithm?

Req. No: 209 Saraid Parlante's witness statement
Is the witness statement by Ms Saraid Parlante the same as the affidavit in Claimant Exhibit 6?

Req. No: 211 Truth behind Tyrea's claims
Are the claims Tyrea makes in its Request for Provisional Measures true?

Req. No: 162 Multi-party arbitration
Did Tyrea, Novanda and Kitoa ratify the New York Convention 1958?

Req. No: 163 Penal Code
What is the type of offence established in Art. 117 of the Tyrean Penal Code?

Req. No: 164 Blocking
Is there any technical and/or procedural possibility to cease the blockings of a website under Art. 117 of the Tyrean Penal Code?

Req. No: 165 Provisional measures
Were new articles published after December 2018?

Req. No: 166 Blocking
How TCA assesses the effectiveness of the algorithms?

Req. No: 168 Calculation of WACC
What are the percentages of the components of the WACC calculation e.g. the Country Risk?

Req. No: 169 Domain name
Did Tyrea block/eliminate the domain names of the Claimants' websites in the domain register?

Req. No: 170 Internet access in Tyrea
How is the access to the internet in Tyrea? Are there differences between cities and rural areas?

Req. No: 171 Damages report of the Claimants
There are still numbers in the damages report that do not add up, could they be revised?

Req. No: 151 Licenses
Has Tyres issued any licenses or other official permissions for the operation of the Claimant's activity?

Req. No: 152 Population Distribution
What are the percentages of rural and urban population in Tyrea?

Req. No: 153 Internet Access
What percentage of the Tyrean population has access to the internet?

Req. No: 154 Law 0808-L
Has any Tyrean Judge pronounced or taken any decision regarding the implications of Law 0808-L on Tyrean privacy rights?

Req. No: 155 Unofficial Measures
Regarding the Claimant's Unofficial Measures (Uncontested Fact 25) which measures have been confirmed by evidence?

Req. No: 174 Claimants' defence on the allegations under the request for Provisional Measure
Does Claimant have any contrasting evidence with regards to Respondent's allegations under their request for Provisional Measure?

Req. No: 175 Notification of Tyrea's Denunciation
When Tyrea submitted its written notice of denunciation, did the ICSID secretariat also inform other Contracting Parties under ICSID Convention concerning the denunciation?

Req. No: 176 Claimants' source of Capital
Does Claimants' source of Capital consist of debt?

Req. No: 132 BIT
In Article 12 (1) of the BIT, the phrase, 'within reasonable lapse of time' is mentioned. Can you please suggest, if there is any particular time frame of the same? e.g. number of days, weeks or months.

Req. No: 244 time of penaltis
Was there any indication on the time the penalties were meant to be effective? (e.g 00:00 hs 28th February)

Req. No: 245 2. Case-by-case assessment
What did Respondent consider when blocking under a "fair case-by-case assessment?

Req. No: 246 Other platforms compliance
Did Truth-Seeker and Wink comply with all the requirements of Law No-0808?

Req. No: 247 Tyrea’s economy
Since last year, did Tyrea's economy had a negative economic growth rate?

Req. No: 140 Experience with multi-party arbitration
Is the present case the first instance of multi-party arbitration in which Tyrea is taking part?

Req. No: 141 Claimants' links with news on other media
Does Tyrea have any evidence that the Claimants have any influence over the content on other social media, as cited in paragraph 3 of Request for Provisional Measures, or that they have directly incited the news?

Req. No: 142 Investigation before blocking
How was the investigation by the TCA conducted before the blocking of Claimants' social media?

Req. No: 143 Impact on advertisers
How did the advertisers, advertising on Claimants' social media in numerous countries, respond to the restriction of the territorial reach of their advertisements following the blocking in Tyrea?

Req. No: 144 Activities of TruthSeeker and Wink
Did TruthSeeker implement a working algorithm and did Wink try to repair its failed algorithm?

Req. No: 210 Political risk monitoring
Have Claimants ever hired a company/employees to conduct Political Risk Analysis?

Req. No: 212 Sponsored Content Terms and Conditions.
Did the sponsored content purchased by the press violate Claimants’ advertising services Ts&Cs?

Req. No: 213 Confidentiality order
Has the tribunal issued, or does it intend to issue, a confidentiality order, or address the confidentiality of materials in PO3?

Req. No: 216 Permament or temporary blocking of websites
Was the Blocking implemented by the Ordinances issued by the Communications Authority of the Republic of Tyrea on 28.02.2018, 01.03.2018 and 02.03.2018 permanent or temporary?

Req. No: 222 Compliance with Respondent's measures by locals
To what extent did Wink and Truthseeker comply with the measures required in Decree N.0578/201-D?

Req. No: 137 Country Risk Premium
What was the country risk premium used in the Claimants' computation of lost and expansion profits?

Req. No: 138 Managing the ethnic conflict
Paragraph 15 of the Clarifications cited certain measures taken by Tyrea to manage the ethnic conflict. Were these measures taken before or after the blocking of Claimants’ platforms? If they were only done after the blocking, what were the measures taken before the blocking?

Req. No: 139 Backlash from Tyrean Press and Citizens
After the promotion and publication of the masa media campaign of Claimants against Tyrean Government, what is the reaction of Tyrean Citizens and the Independent Press?

Req. No: 240 Full Reproduction of the Media Law
What are the full contents of the Media Law?

Req. No: 241 Consultation
Did FriendsLook and Whistler also request for consultation with Respondent regarding the new requirements and the reduced deadline?

Req. No: 192 Estimated Profits
Why did Claimants limit their Tyrea branch profit projection to 2018, instead of making further projections into 2019 and beyond?

Req. No: 196 Disclosure of Documents
Who disclosed the Request for Arbitration and Ms. Parlante's witness statement, and the Response to the Request for Arbitration?

Req. No: 197 Media Speculation
Was there any media speculation that was in favor of the Respondent?

Req. No: 214 Claimants engaging lobbyists
How successful or effective were the Claimants when they engaged lobbyists to pressure Tyrean authorities to revoke the measure?

Req. No: 129 Criterion
What were the criterion applied by the Republic of Tyrea to decide which social networks were “less popular and convenient” and therefore should not be blocked in order to prevent the spread of hate speech?

Req. No: 130 Minister of Telecommunications, Information Technology and Mass Media of Tyrea
Was there any sort of threat made by the tyrean Minister to the SpeakUp Vice President, Mrs. Parlante, during the meeting described in her affidavit?

Req. No: 131 Claimants and the new plataforms mentioned in the Respondent's request for provisional measures
Is there any sort of relationship, either social or commercial, between the Claimants and the new platforms mentioned in the Respondent’s request for provisional measures (page 36 and 37) as examples of the media campaign?

Req. No: 156 Confidentiality agreements
Have the parties entered into any agreement regarding the confidentiality of documents produced in the arbitral proceedings by the opposing party?

Req. No: 157 Media campaign
Have Claimants paid for the publications made by the media which portray Respondent as an opressor of free speech?

Req. No: 158 Domestic law
Does Tyrean legislation provide for any special regulation to investment related disputes?

Req. No: 159 Passing of Law 0808-L
Did Respondent conduct any public hearings before passing Law 0808-L?

Req. No: 160 Claimants' Financial Records
What were Claimants’ financial numbers (revenues, costs, profits or losses) for the year of 2015?

Req. No: 215 Specific feature of Tyrean language
Is there any Tyrean language corpus available to Claimants?

Req. No: 227 Transparancy
Are Tyrea, Novanda, Kitoa United Nations members?

Req. No: 218 Claimants' actions
Is there any evidence showing that the public relations firm has anything to do with the articles?

Req. No: 221 WACC
Why did Claimants' expert give no explanation on the method to calculate WACC?

Req. No: 225 Third party funding
Are there any agreements among the three common shareholders of Claimants, Expedia, FinanceHub and TurboFin, such as acting in a concerted deal?

Req. No: 187 Insurance
Do the Claimants have any Insurance? If yes, for what all circumstances?

Req. No: 189 Population
What is the population of Alcadia and Larnacia?

Req. No: 228 Effect on Economy and foreign investment post blockage
Following the blocking of the Claimants’ websites, how significantly, if at all, did the economy and foreign investments get affected?

Req. No: 234 damages
why do respondents damage calculation on value expenditure not corresponding with claimants direct damages value

Req. No: 233 Calculation of damages
Respondent in their damage report has proposed value expenditure method, but their value calculation is different from the Claimant’s ‘direct damages’. How to resolve this inconsistency

Req. No: 235 Nature of Wink
What was the specific feature of the short links on wink that it was beyond the purview of the algorithm as other websites allso allowed sharing of links

What are all the activities that the claimants' pursue in Tyrea? Are these merely the online contracts or some other activities are also revenue generating

Req. No: 146 Damages from Media Propaganda
Has Tyrea already suffered any damages from the media propaganda started by the Claimants?

Req. No: 147 Damages Calculation
How are the damages based on proven expenditure (2,654,125 for FriendsLook plc, 1,482,040 for Whistler, 1,162,000 for SpeakUp) calculated in the Respondent’s expert report?

Req. No: 198 Technical feasibility of the filtering algorithm
Regardless of any time limits, is it technically feasible to design a fully effective filtering algorithm that achieves the requirements under Law 0808-L ?

Req. No: 199 Quotation of the Response to the Request for Arbitration
Did the newspapers ‘’ have access to the full Response to the Request for Arbitration?

Req. No: 208 Content of “Unofficial Measures”
What further evidence – outside the existing record – is there to confirm the Claimants’ recourse to “unofficial measures” in parallel to the dispute?

Req. No: 220 Request for Provisional Measures
May the Respondent explicitly detail the order it wishes for the Tribunal to make in its memorial when addressing the Request for Provisional Measures?

Req. No: 231 Binding nature of the Requested Damages
Are the Parties bound by the presentation of their claims in the Expert Reports or is it open to them to make rectifications and amendments to their case on quantum in their Memorials to the extent necessary?

Req. No: 148 Damages
Is it correct that Claimants' expert report calculate damages for the entire 2018?

Req. No: 149 Filtering
What is the precise mechanism for testing the efficacy of filtering programs used by Claimants?

Req. No: 150 Tyrean language
What are the specific features of Tyrean language?

Req. No: 172 Facts from provisional measures
Does it follow from para.6.5 on p.42 of the Procedural Order #1 that the parties cannot rely upon any facts mentioned in the Request for Provisional measures?

Req. No: 173 VPNs
In light of the PO2 statement that "it is known that VPNs are not widely used in Tyrea", does the situation change after the blocking of Claimants' media platforms?

Req. No: 191 The third party funder
Does the third party funder have any interest in the preset dispute or any relationship with Claimants?

Req. No: 193 Algorithm
Were all platforms mentioned in the uncontested facts obliged to develop and implement the same algorithm?

Req. No: 194 Algorithm
Have other social platforms provided an algorithm specified in the Law 0808- L?

Req. No: 200 Law 1125-L
What is the exact content of Law 1125-L?

Req. No: 201 Tyrean market
In which economic sector is the Tyrean market based?

Req. No: 202 “Pro” Features of the platforms
What are the “pro” features of the paid-subscription accounts in each of the Claimants’ platforms, given that in para. 14 in the Request for Arbitration it states “ad-blocking” while para. 7 of the facts states “personalised content and advertising”?

Req. No: 204 Discussions of Law 0808-L
When did the discussions for the adoption of Law 0808-L initiate?

Req. No: 205 Tyrea's government
How many times has the government changed since 2013?

Req. No: 133 Third party contracts
Can we have, or is there a contract of the third party agencies and the claimants

Req. No: 134 Clarification on sum computation
Is the total for SpeakUp Media really $26,094,600.00 and not $27,094,600.00?

Req. No: 203 Respondent’s classification in the UNHRC
How is Respondent classified in the reports of the UNHRC (UN human rights Committee) regarding freedom of speech and property’s right?

Req. No: 206 Respondent’s investment in social networks
Does Respondent indicate to be investing or to invest in the future of its social network ?

Req. No: 236 Denunciation of other BITs
Has Respondent denounced any BITs specifically?

Req. No: 237 Costs for implementation of algorithms
Have the costs for implementing the algorithm been subsidized?

Req. No: 238 Social situation in other countries
Are the Minyars and the Tatyars in Alcadia and Larnacia also facing the same situation as the one in Respondent?

Req. No: 243 Legal framework of Tyrea
Was the legal framework concerning media a major factor while deciding to invest in Tyrea?

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