Summary

INTRODUCTION

1. Iraq Telecom Limited ("IT Ltd.") hereby files this Request for Arbitration pursuant to:

(a) Clause 48 of the shareholders' agreement dated 10 March 2011 entered into between International Holdings Limited ("International Holdings"), Korek Telecom Company LLC ("Korek"), Mr. Sirwan Saber Mustafa (also known and referred to herein as "Mr. Barzani"), Korek International (Management) Ltd. ("CS Ltd.") and IT Ltd. (the "IH SHA");

(b) Clause 34 of the amended and restated subscription agreement relating to Korek, dated 27 July 2011, entered into between International Holdings, Korek, Mr. Barzani, Mr. Jawshin Hassan Jawshin Barazany, Mr. Jiqsy Hamo Mustafa, CS Ltd., IT Ltd., Alcazar Capital Partners and Atlas Services Nederland B.V. (the "Subscription Agreement");

(c) Clause 3 of the letter agreement entered into on or around 27 July 2011 between Mr. Barzani, IT Ltd. and International Holdings (the "IraqCell Agreement"), which incorporates by reference Clause 34 of the Subscription Agreement; and

(d) the Rules of Arbitration of the International Chamber of Commerce (the "ICC" and the "Rules").

...