1. E.T.I. Euro Telecom International N.V. (the "Claimant"), a national of the Kingdom of the Netherlands, submits this Request for Arbitration (the "Request") to the Secretary-General of the International Centre for Settlement of Investment Disputes ("ICSID" or the "Centre") in accordance with Article 36, paragraph I of the Convention for the Settlement of Investment Disputes between States and Nationals of Other States (the "Convention").
2. As described below, the Request concerns a legal dispute between the Claimant and the Republic of Bolivia (the "Respondent"), under the terms of the Agreement on Encouragement and Reciprocal Protection of Investments between the Kingdom of the Netherlands and the Republic of Bolivia (the "BIT"),' arising directly out of the Claimant's investment in Empresa Nacional de Telecomunicaciones Entel S.A. (the "dispute"). Empresa Nacional de Telecomunicaciones Entel S.A. ("ENTEL") is the leading telecommunications services provider in Bolivia.