380. Several submissions made to the Commission, beginning with the first
submission, have included areas in respect of which there was agreement
between the States concerned effecting the delimitation of their continental
shelf beyond 200 nm. However, unlike in the present case, in all those
situations delimitation has been effected by agreement between States, not
through international courts and tribunals.
381. In this respect, the Tribunal notes the positions taken in decisions by
international courts and tribunals.