Summary

Petitioner Hidrógeno Cadereyta, S.A.P.I. de C.V. ("Hidrocadereyta" or "Petitioner"), by and through its attorneys, alleges as follows in support of its Petition to Recognize and Enforce a Foreign Arbitral Award pursuant to the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, 21 U.S.T. 2517 (the "New York Convention"), the Inter-American Convention on International Commercial Arbitration of January 30, 1975, 1438 U.N.T.S. 245 (the "Panama Convention"), and Chapters 2 and 3 of Title 9 of the Federal Arbitration Act (the "FAA"). This Petition concerns a foreign arbitral award dated December 22, 2023 (the "Award"), rendered in the arbitration (the "Arbitration") between Petitioner and Pemex Transformación Industrial ("Pemex Tri"). As the Award indicates, Pemex Tri was formerly known as Pemex Refinación. The Award was served on Hidrocadereyta on February 17, 2023. On March 14, 2023, Hidrocadereyta filed a Request for Correction of the Award, and on June 16, 2023, the arbitral tribunal (the "Tribunal") subsequently issued an addendum (the "Addendum"), which modified and finalized the Tribunal's determination. The Addendum was served on Petitioner of July 10, 2023. The Award, as supplemented and finalized by Addendum (collectively, the "Final Award"), is the subject of this Petition.

In March 2025, Pemex Tri was dissolved by operation of Mexican law, with Petróleos Mexicanos ("Pemex") assuming all rights and obligations of Pemex Tri. As a result, Pemex is the named respondent in this proceeding and is referred to herein as the "Respondent" (Petitioner and Respondent are referred to individually as a "Party" and collectively as the "Parties").

The Arbitration, captioned Hidrógeno Cadereyta, S.A.P.I. de C.V. vs. PEMEX Transformación Industrial, was seated in Mexico City, Mexico and conducted under the 2012 Rules of the International Chamber of Commerce ("ICC Rules").