Summary

IN THE MATTER OF THE ARBITRATION ACT 2012

AND IN THE MATTER OF THE FOREIGN ARBITRAL AWARDS ENFORCEMENT ACT (1997 REVISION)

AND IN THE MATTER OF AN ARBITRATION BETWEEN (1) BRIZENICA D.O.O. and (2) PROCRO ACQUISITIONS LIMITED (CLAIMANTS) AND (1) FOUR SEASONS HOTELS LIMITED (2) FS ZAGREB B.V. and (3) FOUR SEASONS HOTELS AND RESORTS B.V. (RESPONDENTS)

BETWEEN:

(1) Four Seasons Hotels Limited
(2) FS Zagreb B.V.
(3) Four Seasons Hotels and Resorts B.V.

AND

ProCro Acquisitions Limited

1. This is the Skeleton Argument of: (i) Four Seasons Hotels Limited ("FSHL"), (ii) FS Zagreb B.V. ("FS Zagreb"), and (iii) Four Seasons Hotels and Resorts B.V.

("FSHR") (together the "Plaintiffs") filed in support of the Ex Parte Originating Summons dated 11 May 2026 [HB/1/1-3].

2. The summons concerns the Plaintiffs' application (the "Application") under section 5 of the Foreign Arbitral Awards Enforcement Act 1997 [AB/9/26] (the "FAAEA"), Order 73 of the Grand Court Rules (the "GCR") [AB/10/37-43] for leave to enforce an arbitration award dated 1 May 2025 (the "Award"), as amended by an addendum dated 29 August 2025 (the "Addendum", and together with the Award, the "Final Award").

3. The Final Award was issued following an arbitration administered by the International Chamber of Commerce (the "ICC"), with case reference ICC Case No. 27321/AB/CPB/FJT (the "Arbitration").

4. The Plaintiffs seek to enforce the Final Award against ProCro Acquisitions Limited, a Cayman Islands company (the "Defendant").

...

H. CONCLUSION

48. For the reasons set out above, the Plaintiffs submit that the requirements for an ex parte order granting recognition and leave to enforce the Final Award are satisfied.

49. The Plaintiffs respectfully request that the Court grant an ex parte order in the terms of the Draft Order found at [HB/2/4-7] and such Order may be granted following the Court's determination on the papers.

50. The Plaintiffs reserve the right to file supplemental submissions on costs.

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