A. Introduction

1. I am James Dow, Professor of Finance at London Business School. I have previously served as Research Dean, Chair of the Finance subject area, and Director of the Institute of Finance and Accounting at London Business School, as Professor of Economics and Head of Department at the European University Institute, as Assistant Professor of Economics at the University of Pennsylvania, and as Editor of the Review of Economic Studies. I have extensive experience in valuation, which I have taught at London Business School since 1989. I submitted expert evidence on behalf of the Russian Federation on issues of damages and valuation in the underlying arbitration proceedings at issue here. My current curriculum vitae is attached as Annex 1 to this Report.

2. Counsel for the Russian Federation have asked me to review the methodology used by the Tribunal to award Claimants over USD 50 billion in damages. In this Report, I have specifically been requested not to address all of the flaws in the Tribunal’s methodology. Rather, I have been asked to focus only on those flaws (a) that departed in significant respects from the parties’ submissions and as to which I was not afforded an opportunity to be heard, (b) that resulted in the awarding of damages that have no economic basis, and (c) that had a substantial impact on the amount of damages awarded. In order to provide the necessary background and context for my discussion of these flaws, I have in a few cases referred to matters as to which I did have an opportunity to be heard. In light of my instructions, I have expressly noted where my conclusions relate to a methodology that the Tribunal developed on its own and as to which I did not have an opportunity to express my views.

3. In preparing this report, I reviewed: