This case concerns a dispute regarding the application of certain tax laws by the United Mexican States (hereinafter “Mexico” or “the Respondent”) to the export of tobacco products by Corporación de Exportaciones Mexicanas, S.A. de C.V. (“CEMSA”), a company organized under the laws of Mexico and owned and controlled by Mr. Marvin Roy Feldman Karpa (hereinafter “Mr. Feldman” or “the Claimant”), a citizen of the United States of America (“United States”). The Claimant, who is suing as the sole investor on behalf of CEMSA, alleges that Mexico's refusal to rebate excise taxes applied to cigarettes exported by CEMSA and Mexico's continuing refusal to recognize CEMSA's right to a rebate of such taxes regarding prospective cigarette exports constitute a breach of Mexico's obligations under the Chapter Eleven, Section A of the North American Free Trade Agreement (hereinafter “NAFTA”). In particular, Mr. Feldman alleges violations of NAFTA Articles 1102 (National Treatment), 1105 (Minimum Level of Treatment), and 1110 (Expropriation and Indemnification).1 Mexico denies these allegations.