On February 3, 2009, the International Court of Justice delivered a unanimous decision in the case between Romania and Ukraine concerning the delimitation of their maritime bound- ary in the Black Sea.1 The delimitation was carried out in the northwestern part of the Black Sea in the concavity formed by Romania's coast to the west and Ukraine's coast to the west, north, and east (see map). The adjacent coasts of the parties meet at their shared land boundary terminus on the River Danube delta. Ukraine's Serpents' Island lies approximately twenty nau- tical miles east of the Danube delta. The Court used the equidistance method to delimit a five- point boundary starting at Point 1: the intersection of the outer limits of the Romanian and Ukrainian (Serpents' Island) territorial seas agreed by the parties in their 2003 State Border Regime Treaty (2003 Treaty), which entered into force on May 27, 2004.2 Between Point 1 and Point 2, the boundary follows the twelve-nautical-mile territorial sea outer limit of Ser- pents' Island. Beyond Point 2 the maritime boundary is an equidistance line measured from the adjacent mainland coasts of Romania and Ukraine (Point 2-Point 3-Point 4) and then between the opposite mainland coasts of Romania and Ukraine's Crimean Peninsula (Point 4 -Point 5). South of Point 5 the boundary continues in a specified direction "until it reaches the area where the rights of third States may be affected" (para. 219).3