I. PROCEDURAL HISTORY

1. On 6 September 2007, the International Centre for Settlement of Investment Disputes received a Request for Arbitration against the Bolivarian Republic of Venezuela dated 6 September 2007 from (i) three U.S. (Delaware) companies, i.e., Mobil Corporation, Mobil Cerro Negro Holding, Ltd. and Mobil Venezolana de Petróleos Holdings, Inc., (ii) two Bahamian companies, i.e., Mobil Cerro Negro, Ltd. and Mobil Venezolana de Petróleos, Inc. and (iii) one Dutch company Venezuela Holdings, B.V.

2. On the same day, the Centre acknowledged receipt of the request for arbitration pursuant to Rule 5 of the ICSID Institution Rules and transmitted a copy to Venezuela and to the Venezuelan Embassy in Washington, D.C.

3. The Request for Arbitration, as supplemented by the Claimants’ letters of 28 September 2007, was registered by the Secretary-General of ICSID on 10 October 2007 pursuant to Article 36(3) of the ICSID Convention. On the same day, the Secretary-General, in accordance with Rule 7 of the Institution Rules, notified the Parties of the registration and invited them to proceed to constitute a tribunal as soon as possible.

4. By letter dated 7 January 2008, the Claimants confirmed the Parties’ agreement regarding the constitution of the tribunal, according to which the tribunal would be composed of three arbitrators, one appointed by each Party and a third presiding arbitrator appointed by agreement of the Parties with the assistance of the first two appointed arbitrators.