Third, the damages Claimant seeks are depending on an Assessment at odds Together with the statements in Claimant’s Reply that Yukos' tax assessments were not them selves expropriatory measures. Since the supplemental expert report of Professor James Dow shows, LECG’s calculation of damages, on which Claimant relies, is based on the exact same

Even assuming quod non that this Tribunal has jurisdiction in excess of Claimant’s assert, there was no expropriation for which Claimant could recover. Being an Preliminary issue, Claimant by itself expressly disclaims an expropriation of the Yukos shares. Claimant in its place seeks, according to a misreading of Posting 5(2) of the UK-Soviet Lit