I. INTRODUCTION

A. Request for Arbitration

1. On 16 February 2010, Tidewater Inc., Tidewater Investment SRL, Tidewater Caribe, C.A., Twenty Grand Offshore, L.L.C., Point Marine, L.L.C., Twenty Grand Marine Service, L.L.C., Jackson Marine, L.L.C. and Zapata Gulf Marine Operators, L.L.C. (together ‘Tidewater’ or ‘Claimants’) filed a Request for Arbitration under the ICSID Arbitration Rules against the Bolivarian Republic of Venezuela (‘Venezuela’ or ‘Respondent’).

2. The dispute concerns the Claimants’ investment in marine support services to the oil industry in Venezuela. Venezuela’s national oil company Petróleos de Venezuela, S.A. (‘PDVSA’) engaged private companies to provide support to the oil industry in the country. One of these private companies was Tidewater Marine Service, C.A. (‘SEMARCA’), a company constituted under the laws of Venezuela. SEMARCA contracted with PDVSA and two other national or semi-national companies, PDVSA Petróleo, S.A. (‘PDVSA Petróleo’) and PetroSucre, S.A. (‘PetroSucre’) to provide support both at Lake Maracaibo and offshore in the Gulf of Paria.

3. Prior to February 2009, SEMARCA was owned by Tidewater Caribe, C.A. (‘Tidewater Caribe’), a company incorporated in Venezuela, which in turn was owned by Tidewater Marine International, Inc. (‘Tidewater Marine’), a company incorporated in the Cayman Islands. That company was in turn owned by Tidewater Inc. (a company incorporated in the United States of America). In addition, a number of other United States — and Cayman Islands — incorporated subsidiaries of Tidewater Inc. performed contracted services for SEMARCA, and owned a number of vessels and other assets in Venezuela. Tidewater had owned SEMARCA and provided marine support services in the country since 1958.