Summary

Petitioner AXT SOLUTIONS INC. f/k/a LOMBARD TRADING INTERNATIONAL CORP. ("Petitioner Lombard"), by and through the undersigned counsel, files this Petition to Confirm and Enforce A Foreign Arbitral Award and For Entry of Judgment ("Petition") against Respondent TOI Commodities S.A. ("Respondent TOI"), and alleges as follows:

PRELIMINARY STATEMENT

1. This is a proceeding to confirm and enforce a foreign arbitration award, issued and rendered by Grain and Feed Trade Association in ("GAFTA Tribunal"), in London England, dated December 22, 2025 ("GAFTA Award"), in an arbitration designated In the Matter of An Arbitration Pursuant to the Arbitration Rules No 125 of the Grain and Feed Trade Association between Claimants Lombard International Trading Corp vs. Respondents TOI Commodities, S.A. ("GAFTA Arbitration Proceeding").

2. The amount of the December 22, 2025 GAFTA Award in favor of Petitioner Lombard and against Respondent TOI is $21,939,946.53 and continuing interest from December 22, 2025, of 5% per annum compounded quarterly until fully paid.

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