Respondent (R III, para. 101) has raised procedural objections against Claimant's argument that the MFN
provisions of Article 3 of the UK-Soviet BIT, taken together with the Denmark-Russia BIT, provide a ground for this
Tribunal's jurisdiction. In particular, Respondent argues that this second ground was not mentioned in the Claimant's
Request for Arbitration, but only later in Claimant's First Memorial dated 28 February 2007.