Summary

Plaintiff ACF Renewable Energy Limited ("ACF"), by and through its undersigned counsel, alleges as follows for its Complaint against Defendant the Republic of Bulgaria ("Bulgaria"):

Nature of the Action

This is an action to recognize and enforce an arbitral award issued on January 5, 2024 in ICSID Case No. ARB/18/1 in favor of ACF and against Bulgaria (the "ICSID Award"). The ICSID Award was issued by an arbitral tribunal (the "Tribunal") following arbitration proceedings conducted in accordance with the Convention on the Settlement of Investment Disputes between States and Nationals of Other States (the "ICSID Convention"). Pursuant to Article 54 of the ICSID Convention and 22 U.S.C. § 1650a, ACF requests that this Court (1) enter an order recognizing and enforcing the ICSID Award and giving it the same full faith and credit as if it were a final judgment of a court of general jurisdiction of one of the several states, (2) enter judgment in ACF's favor and against Bulgaria in the amounts and currency denominations specified in the ICSID Award, and (3) grant any other and further relief that the Court may deem appropriate.