Summary

I. BACKGROUND TO THE DISPUTE

1. Yukos Capital S.a.r.L ("Claimant") Is a limited liability company Incorporated in Luxembourg, It is managed by TMF Corporate Services S.A. ("TMF") which acts as corporate services provider to Claimant.

2. OAO Samaraneftegaz ("Respondent') is an open joint stock company incorporated in Russia. It had transferred all powers of Its executive bodies to Yukos Exploration and Production Closed Joint Stock Company / CJSC Yukos EP / ZAO Yukos EP ("Yukos EP") which acted as the management company for Respondent (see items 39 to 41 infra).

3. The Parties were both indirect subsidiaries of Yukos Oil Company. Claimant's function was to provide financing to other companies in thl' Yukos group. Respondent was one of the operating companies in the group.

4. In July 2004, Claimant and Respondent concluded two agreements by virtue of which Claimant undertook to grant to Respondent interest bearing loans. Based on these agreements, Claimant paid to Respondent a loan of 1,700,000,000 Russian Rubles and a loan of 715,890,000 Russian Rubles (COllectively, the "Loan Agreements" or "Loans"). Respondent neither paid interest on these Loans nor repaid the principal amount of the Loans when Claimant sought repayment of the principal amounts pursuant to an acceleration clause in the Loan Agreements.

5. On 2 November 2005, the Parties signed an Addendum to each of the Loan Agreements ("Addendum" or, in the plural, "Addenda"). These Addenda defined New York law as the substantive law applicable to the Loans and subjected disputes arising out of the Loan Agreements to the Rules of Arbitration of the International Chamber of Commerce ("ICC").

...