KOREA OWES GALE MORE THAN USD $2 BILLION IN COMPENSATION (OCR-ed text may have errors)
75. Gale is entitled to compensation for (i) its expropriated profits and property from the Songdo project; (ii) Korea's impairment of Gale's ability to manage, maintain, use, and enjoy its investment in Songdo; (iii) compensation for the moral harm to Gale; and (iv) legal costs spent to resolve this dispute with Korea, as well as interest on all amounts owed.
76. Under customary international law, such compensation must "as far as possible, wipe out all the consequences ofthe illegal act and re-establish the situation which would, in all probability, have existed if that act had not been committed.
77. During arbitration proceedings, expert evidence will be adduced to substantiate Gale's damages, which are currently estimated at more than USD $2 billion.
VI. FINAL ATTEMPT AT AMICABLE SETTLEMENT
78. This Notice represents a final request for amicable settlement of Gale's dispute. If Korea remains unwilling to settle this matter, Gale will initiate arbitration proceedings under the FTA to ensure that its legal rights are respected and that Korea upholds its binding international obligations.