We will claim far greater damages than $2 billion if we go to arbitration. The arbitration claim is only limited to any mining limitations in the MOA. Any other limits are artificial and imposed by Venezuela in violation of the BIT. Indeed, the translated version states th lack of limits, Crystallex has been granted the exclusive right to develop the Las Cristinas 4, 5, 6 and 7 deposits"

I haven't read the entire MOA for a long time, but I do not recall any limitations in the there on how much we extract, thus any limitation on profits to some specific amount of gold is not legally correct. Any advice to the contrary is very poor advice.

Another argument that I would make is that profits should NOT be discounted based on the idea that gold prices will continue to rise and that in essence provides the discounting factor.

Bottom line, I would be looking for a huge number, giving the arbs the opportunity to cut the award for whatever reason to just $3-4 billion or so. In my experience, arbs do like to pick a number in the middle, so clearly we would start VERY high.