Summary

PETITION TO RECOGNIZE ARBITRATION AWARD

Petitioners Chevron Corporation ("Chevron") and Texaco Petroleum Company ("TexPet," and together with Chevron, "Petitioners") hereby petition this Court for an order confirming, recognizing and enforcing the compensatory obligations of a final and binding arbitration award issued in The Hague, the Netherlands, on November 17, 2025, by an international tribunal (the "Tribunal") administered by the Permanent Court of Arbitration ("PCA") in favor of the Petitioners and against the Respondent, the Republic of Ecuador ("Ecuador" or "Respondent"), in PCA Case No. 2009-23 (the "Arbitration"). The award, as corrected by a decision of the Tribunal dated February 5, 2026 (the "Track III Award,"), was issued following arbitration proceedings conducted in accordance with the treaty between the United States of America and the Republic of Ecuador Concerning the Encouragement and Reciprocal Protection of Investment (the "Bilateral Investment Treaty" or "BIT") and under the 1976 Arbitration Rules of the United Nations Commission on International Trade Law ("UNCITRAL Rules").

The Track III Award arises out of a 17-year-long arbitration conducted by the duly constituted Tribunal, in which both Petitioners and Respondent actively participated. The Tribunal previously issued six awards on jurisdiction and on the merits, all of which were upheld by the courts of the arbitral seat in the Netherlands. The Track III Award, which determined that Ecuador should compensate Petitioners in an amount exceeding $215 million plus post-award interest, is well reasoned, issued by a properly constituted Tribunal, and based on voluminous legal submissions, witness testimony, and expert reports. In fact, the Track III Award is over 1,000 pages long. There is no valid reason why the Track III Award should not be recognized by this Court.

Petitioners respectfully request that the Court recognize and enforce the compensatory obligations of the Track III Award under the United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards, June 10, 1958, 21 U.S.T. 2517, 330 U.N.T.S. 38 (the "New York Convention"), and its implementing statute 9 U.S.C. § 201 et seq., and enter judgment for Petitioners in the amount of the present value of the Track III Award as of the date of judgment, including accrued post-award interest.

In support of this Petition, Petitioners respectfully state as follows:

...

Chevron Corporation (USA), Texaco Petroleum Company (USA) v The Republic of Ecuador - PCA Case 2009-23

OGEL:

• Decision on Correction of Fourth Partial Award on Track III - 05 February 2026
• Note of Dissent - Horacio Grigera Naón - 05 February 2026
• Third Interim Award on Jurisdiction and Admissibility - 27 February 2012
• Second Interim Award on Interim Measures - 16 February 2012
• Partial Award on Threshold Issues of Track III - 30 June 2021
• Note of Dissent by Dr Horacio Grigera Naon - 12 March 2015
• Fourth Interim Award on Interim Measures - 07 February 2013
• First Partial Award on Track I - 17 September 2013
• First Interim Award on Interim Measures - 25 January 2012
• Decision on the Respondent's Request for Interpretation under Article 35 of the UNCITRAL Arbitration Rules - 06 November 2018
• Fourth Partial Award on Track III - 17 November 2025
• Note of Partial Dissent by Dr. Horacio Grigera Naon - 17 November 2025
• Interim Award - 1 December 2008
• Second Partial Award on Track II - 30 August 2018
• Second Interim Award on Interim Measures 16 February 2012
• First Interim Award on Interim Measures 25 January 2012
• Third Interim Award on Jurisdiction and Admissibility - 27 February 2012
• Notice of Arbitration - 2009

TDM:

• Decision on Correction of Fourth Partial Award on Track III - 05 February 2026
• Note of Dissent - Horacio Grigera Naón - 05 February 2026
• Third Interim Award on Jurisdiction and Admissibility - 27 February 2012
• Second Interim Award on Interim Measures - 16 February 2012
• Partial Award on Threshold Issues of Track III - 30 June 2021
• Note of Dissent by Dr Horacio Grigera Naon - 12 March 2015
• Fourth Interim Award on Interim Measures - 07 February 2013
• First Partial Award on Track I - 17 September 2013
• First Interim Award on Interim Measures - 25 January 2012
• Decision on the Respondent's Request for Interpretation under Article 35 of the UNCITRAL Arbitration Rules - 06 November 2018
• Fourth Partial Award on Track III - 17 November 2025
• Note of Partial Dissent by Dr. Horacio Grigera Naon - 17 November 2025
• Interim Award - 1 December 2008
• Second Partial Award on Track II - 30 August 2018
• Second Interim Award on Interim Measures 16 February 2012
• First Interim Award on Interim Measures 25 January 2012
• Third Interim Award on Jurisdiction and Admissibility - 27 February 2012
• Notice of Arbitration - 2009