Summary

1. This arbitration was commenced by Claimants' filing of a Notice of Arbitration and Statement of Claim dated May 3, 2012. Respondents served a Statement of Defense dated June 4, 2012. No counterclaims were asserted. Claimants responded with a Reply to Statement of Defense dated July 2, 2012. The International Centre for Dispute Resolution ("ICDR") confirmed appointment of the three members of the Tribunal by letter dated July 10, 2012.

2. Claimant CIMC Raffles Offshore (Singapore) Limited ("CROL"), formerly known as Yantai Raffles Shipyard Ltd., is a company incorporated under the laws of Singapore. CROL is an integrated offshore builder that engineers, constructs, and commissions state-of-the-art oil platforms, drill rigs, and support vessels. Claimant Yantai CIMC Raffles Offshore Limited ("YCROL"), formerly known as Yantai Raffles Offshore Limited, is majority owned and operated by CROL. YCROL is incorporated in China and operates the country's largest offshore construction yard. (Claimant's Pre-Hearing Submission, ¶ 7)("Cl. P-H Submission")

3. Respondent Schahin Holding S.A. ("Schahin Holding") is a holding company incorporated in Brazil. Schahin Holding owns and manages offshore drilling rigs and vessels through subsidiary entities. Respondent Schahin Engenharia, S.A. ("Schahin Engenharia") is a company incorporated in Brazil. Respondent Sea Biscuit International Inc. ("Sea Biscuit") is an international company organized under the laws of the British Virgin Islands, Respondent Black Gold Drilling LLC ("Black Gold") is organized under Delaware law and is a wholly-owned subsidiary of Sea Biscuit. Respondent Baerfield Drilling LLC ("BDL") is a company registered in Delaware and is a wholly-owned subsidiary of Black Gold and a second-tier subsidiary of Sea Biscuit. Respondent Soratu Drilling LLC ("SDL") is a company registered in Delaware and is a wholly-owned subsidiary of Black Gold and a second-tier subsidiary of Sea Biscuit. (Cl. P-H Submission, ¶ 8) Respondents are part of Grupo Schahin, or Schahin Group, which is headquartered in Brazil and is controlled by brothers Milton Taufic Schahin, Salim Taufic Schahin, and Rubens Taufic Schahin. Each of the Respondents is separately incorporated and maintains its own accounts, books and records. Rubens Taufic Schahin has no involvement in the overseas entities, including Respondents Sea Biscuit, Black Gold, BDL and SDL. The Schahin Group, which employs more than 6,500 people and has been operating in the Brazilian market for more than 45 years, is active in the engineering, oil and gas, real estate development, telecommunications, and energy sectors in Brazil. (Respondents' Memorial in Response to Claimants' Pre-Hearing Submission, 6)("Resp. Memorial")

...