Summary

I. Introduction

1. (China Heilongjiang International Economic & Technical Cooperative Corp., Heilongjiang), and (Qinhuangdaoshi Qinlong International Industrial Co. Ltd., Qinlong) (collectively, the Claimants), all of which have been established according to the laws of the People's Republic of China (the PRC), hereby file a Request for Arbitration against Mongolia, in accordance with the Agreement between the Government of the Mongolian People's Republic and the Government of the People's Republic of China concerning the Encouragement and Reciprocal Protection ofInvestments signed on 26 August 1991 (the Treaty), and the Foreign Investment Law of Mongolia (the FIL).

2. The Treaty and the FIL provide protection to PRC investors for investments made in Mongolia. The Claimants are qualifying PRC investors, which have made qualifying investments in Mongolia, including through their direct interests in a Mongolian company, Tumurtei Huder LLC (Tumurtei Ltd). Tumurtei Ltd was the lawful holder of a mining licence issued on 28 January 1998 (the 939A Licence), over an iron ore deposit located in Twnurtei, Khuder sub-province. Selenge province, in Mongolia (the Tunlllrtei mine). The 939A Licence was, however, revoked by Mongolia in September 2006, in breach of Mongolia's obligations under the Treaty and the FIL, thus depriving the Claimants of their investment. In accordance with the requirements of Article 8 of the Treaty, the Claimants sent a notice of dispute to the Mongolian government (the Government) on 26 December 2006. No written response was received, and despite continuing efforts to resolve the matter through negotiations, as well as a further letter from Freshfields Bruckhaus Deringer dated 9 October 2009, no settlement has been achieved in the six-month cooling-off period imposed by the Treaty, and indeed, in the past three years.