JJ, you are correct on all statements.

Other arbitrations are irrelevant to ours, our arbitration is governed by the BIT and none of the other cases could be cited as precedent, and none have any relevance to our outcome.

Collecting an award is a trivial matter unless a country has no international commerce. Unfortunately, Hugo sells lots oil and all the proceeds are available to pay a judgment whether or not Hugo likes it. There is literally no way to structure his oil sales to stop a judgment, his only choice would be to completely stop all sales -- even China enforces ICSID judgments.

Certainly, billions are available -- Don perhaps you missed the brief quote that I included in a post from the law review article describing how lost profits are expected in international disputes under the ICSID -- notably written by a member of our arbitration panel. The dollar amount just depends on the job done by our lawyers and experts.