These arbitration proceedings are brought by a private investor against the host state under
Article 8 of the IPPA (“Disputes between an Investor and the Host Contracting Party”). These are not
proceedings between two states brought under the quite separate provision for inter-state arbitration
under Article 9 of the IPPA (“Disputes between the Contracting Parties”). The Claimant's claim against
the Respondent is brought independently of the United Kingdom as its home state; so this is not a
claim made or supported by the United Kingdom espousing the Claimant's claim as its national. This
distinction, much elided in the Respondent's First Memorial, cuts across all three Issues.