'2. Directions concerning Communications, Notifications, the Filing of Submissions, Statements and Reports

2.1. Without prejudice to what is set forth in the Terms of Reference, all written notifications and communications arising in the course of this arbitration shall be deemed to have been validly made to each Party where they have been transmitted by (i) delivery against receipt, or (ii) courier service with notice of dispatch by facsimile, or (iii) facsimile transmissions confirmed by courier service or by e-mail:

(i) for Claimants, to: . . .

(ii) for Respondents, to: . . .

(iii) for the Arbitrators: to their respective address as set out under par. 10 of the Terms of Reference deemed to be reproduced in this Order.

2.2. All written notifications and communications between the Parties relating to this arbitration or between the Parties or either of them and the arbitrators shall be made by one of the above-mentioned means to the respective addressees as set forth or referred to supra.

Notifications and communications to the Arbitral Tribunal shall be simultaneously sent with enclosures to all three arbitrators and to the opposing Party.

2.3. Written notifications and communications by the Parties shall be sent simultaneously as follows:

(a) each Party shall send one copy directly to each arbitrator and to the Secretariat of the International Court of Arbitration (ICC);

(b) each Party shall deliver to counsel for the other Party three copies of all submissions to the Tribunal (within the meaning of Section 3) and of all Witness Statements / Expert Reports (within the meaning of Sections 5 and 6);

(c) each Party shall deliver to counsel for the other Party three copies of all documentary evidence (within the meaning of Section 4) and other materials submitted to the Tribunal;

(d) two copies of the submissions and documentary evidence addressed to Claimants will be sent to . . .;

(e) one copy of the submissions and documentary evidence addressed to Respondents will be sent to . . .

2.4. The date of dispatch pursuant to § 2.1 supra shall, for all purposes, be deemed to be controlling for compliance with any time limit.

2.5. Any binder containing a submission within the meaning of Section 3, documents within the meaning of Section 4 and Witness Statements / Expert Reports within the meaning of Sections 5 and 6 shall be numbered consecutively in arabic numerals. The number of each binder submitted by Claimants shall be preceded by the letter "C"; the number of each binder submitted by Respondents shall be preceded by the letter "R".

3. Written Submissions

3.1. Claimants shall file a Submission on the Application for Provisional Measures, including all factual and legal arguments in support thereof, stating the mode of proof of its allegations, with Witness Statements / Expert Reports, if any, on or before the date mentioned in 1.6 (a) supra.

3.2. Respondents shall file a Submission on the Application for Interim Measures, including all factual and legal arguments in support thereof, stating the mode of proof of its allegations, with Witness Statements / Expert Reports, if any, on or before the date mentioned in § 1.6 (a) supra.

3.3. Claimants shall file a Response to Claimants' Submission referred to under § 3.1 supra with responsive Witness Statements / Expert Reports, if any, on or before the date mentioned in § 1.6 (b) supra.

3.4. Respondents shall file a Response to Respondents' Submission referred to under § 3.2 supra with responsive Witness Statements / Expert Reports, if any, on or before the date mentioned in § 1.6 (b) supra.

3.5. The paragraphs of all Written Submissions shall be numbered consecutively and the Submissions shall include a table of contents.

4. Documentary Evidence

4.1. The Submissions and Responses referred to under §§ 3.1 to 3.4 supra shall be accompanied by, to as large an extent as possible, the documentary evidence and the testimonial evidence relied upon by Claimants and Respondents, respectively, including the legal authorities relied upon by it.

4.2. The documents shall be submitted in the following form:

(a) exhibits shall be contained in separated binder (spiral bound volumes, arch files or equivalent), each exhibit having a divider bearing on the tab the exhibit's identification number;

(b) the exhibits shall be numbered consecutively throughout these proceedings;

(c) the number of each exhibit containing a document submitted by Claimants shall be preceded by the letter "C"; the number for each exhibit containing a document submitted by Respondents shall be preceded by the letter "R"; documentary exhibits attached to the Request are identified as C-1 to C-12; documentary exhibits attached to the Answer are identified as R-1 to R-22; the letter from Respondent Counsel to . . . dated . . . is identified as R-23;

(d) a Party shall be permitted to submit within one exhibit several documents relating to the same subject matter, provided that each page within such exhibit is numbered separately and consecutively:

(e) each binder containing exhibits shall be prefaced by a list of exhibits, setting forth for each exhibit :

(i) the exhibit number,

(ii) its date, and

(iii) a brief description of the exhibit;

(f) a party shall submit, together with its written submission referred to in §1.6 supra, respectively, a table of contents of the documents it submits in conjunction with the submission and a list containing the exhibit number, date and a brief description of the subject matter of each document.

4.3. All documentary evidence submitted to the Arbitral Tribunal shall be deemed authentic and complete, including evidence submitted in the form of copies, unless a Party disputes its authenticity or completeness.

4.4. On or before the date mentioned in § 1,6 (c) supra, the Parties shall jointly provide the Arbitral Tribunal with a Joint Chronological Index of all the documentary evidence submitted by the Parties in the course of this arbitration.

4.5. The Arbitral Tribunal may, upon a specific and precise motion made by one Party, instruct the Parties to file any documentary evidence in their possession or under their control, which the Tribunal will deem relevant. Any such motion shall identify the document(s) with a reasonable degree of specificity and shall establish the relevance of the document(s) for the settlement of the dispute. The Tribunal shall draw inference as it shall deem appropriate, taking all prevailing circumstances into account, in case any Party fails to proceed with the filing as instructed.

4.6. If documentary evidence which a Party is directed by the Arbitral Tribunal to file contains proprietary information or trade secrets, that Party shall so indicate to the Tribunal and to the other Parties. In that case, the Arbitral Tribunal shall determine, after consultation with the Parties, the appropriate measures to be implemented in order to respect the proprietary nature of the information while, to the extent possible, allowing the production of such evidence for the purpose of the arbitral proceedings.

4.7. The use of demonstrative exhibits (such as charts, tabulations, etc.) is allowed at the Witness Hearing and the Hearing for Oral Presentation, provided that no new evidence is contained therein. Each Party shall number its demonstrative exhibits consecutively ("C-demo...", "R-demo..."). A hard copy of any such exhibit shall simultaneously be provided by the Party submitting such exhibit to the other Party and to each member of the Tribunal.

5. Evidence of Fact Witnesses

5.1. If a Party wishes to adduce evidence by witnesses / experts in respect of its contentions, it shall so indicate in the submissions mentioned [above]. If a Party intends to adduce testimonial evidence, it shall submit written Witness Statements / Expert Reports together with the above-mentioned submissions, in accordance with the provisions of this Section.

5.2. Parties are at liberty to submit additional and / or responsive Witness Statements and / or Expert Reports on or before the date mentioned [above].

5.3. Any person may be a witness, including a Party's officer or director.

5.4. Each Witness Statement shall:

(a) contain the name and address of the witness, his or her relationship to any of the Parties (if any), and a description of his or her qualifications;

(b) contain the evidence that the Party presents of that witness;

(c) contain appropriate captions or internal references indicating with reasonable specificity the factual and legal issues to which it is relevant;

(d) be signed by the witness and give the date and place of signature.

5.5. The Witness Statements shall be in sufficient detail so as to stand as examination in chief of the witness (in the meaning of § 7.5 (c), infra) at the Witness Hearing.

5.6. With their Response mentioned [above], each Party shall notify the other Party, with a copy to the Arbitral Tribunal, of:

(a) the names of the witnesses of the other Party whom that Party wished to cross-examine at the Witness Hearing, and

(b) the names of the employees or agents of the other Party for whom there are no Witness Statements but whom the non-employing Party wishes to examine at the Witness Hearing.

The non-employing Party shall identify the specific subject matters on which examination is proposed to be taken of any witness as to which there is no Witness Statement.

5.7. Where the witness duly summoned to appear at the Hearing is not able to attend for valid reasons, the Arbitral Tribunal shall in principle not be entitled to consider his written statement, except if extraordinary circumstances so warrant. In such event, the Arbitral Tribunal shall hear the Parties and decide by taking into account all relevant circumstances, including the Parties' legitimate interests.

5.8. Witnesses who are affiliated with a Party shall be treated in the same manner as witnesses not affiliated with a Party, without prejudice to the relevance, weight and materiality of the evidence offered by a witness affiliated to a Party.

5.9. Each Party shall advance the costs connected with the evidence by its witnesses, including the cost of preparing the Witness Statements and attendance at the Witness Hearing, without prejudice to the decision of the Arbitral Tribunal as to which Party shall ultimately bear those costs and to what extent. A non-employing Party shall also advance the costs relating to the attendance at the Witness Hearing of witnesses it calls pursuant to § 5.6 (b) supra, without prejudice to the decision of the Arbitral Tribunal as to which Party shall ultimately bear those costs and to what extent.

6. Evidence of Expert Witnesses

6.1. The provisions of Section 5 of this Order are applicable, mutatis mutandis, to expert witnesses.

7. Witness Hearing

7.1. The Witness Hearing shall take place in Stockholm at the location determined by the Arbitral Tribunal.

7.2. The Witness Hearing shall take place on the date of the Hearing on the First Phase . . .

7.3. The Witness Hearing shall proceed as follows:

(a) opening Statement by Claimants,

(b) opening Statement by Respondents,

(c) examination of Claimants' witnesses,

(d) examination of Respondents' witnesses.

7.4. In its Opening Statement, each Party shall explain briefly how the testimony of the witnesses called by it will support its case and may comment briefly on the Witness Statements submitted by the other Party. Such Opening Statement shall last between 30 to 60 minutes.

7.5. The procedure for examining witnesses at the Witness Hearing shall be the following

(a) the Arbitral Tribunal shall have the right to examine the witnesses and to interject questions during the examinations by Counsel; the Arbitral Tribunal shall ensure that each Party has the opportunity to re-examine a witness with respect to questions raised by the Tribunal;

(b) each witness giving oral evidence shall first be examined by the Party producing the witness ("examination in chief") then by the other Parry ("cross-examination"), and subsequently by the first Party ("re-examination");

(c) the examination in chief shall, in principle, be limited to 10 to 30 minutes for fact witnesses, depending on the importance of the evidence, and 30 minutes for expert witnesses;

(d) the scope of the re-examination shall be limited to matters that have arisen in the cross-examination;

(e) the Arbitral Tribunal shall at all times have complete control over the procedure in relation to a witness giving oral evidence, including the right to recall a witness and to impose reasonable limits, on its own motion or at the request of a Party, on the right of a Party to conduct an examination in chief, a cross-examination or re-examination if it appears to the Tribunal that such examination or evidence is unlikely to serve any further relevant purpose.

7.6. Witnesses of fact will not be heard under oath but the chairman shall draw their attention to the fact that the Tribunal requests them to tell the truth, the entire truth and nothing but the truth and shall ask them to confirm that they will comply with this request.

7.7. Witnesses of fact may be present in the hearing room during the Opening Statements and Oral Arguments but not during the examination of other witnesses of fact, unless the Parties agree otherwise. . . .

7.8. In the event an officer or an employee of a Party is to be called as witness, the Arbitral Tribunal shall determine, after consultation with Counsel, whether that person may be present in the hearing room during the testimony of other witnesses. . . .

7.9. Expert witnesses may be present in the hearing room during the entire hearing.

7.10. The directions set forth in § 7.7 to 7.9 supra are applicable unless the Arbitral Tribunal, taking into account specific circumstances, shall direct otherwise.

7.11. The Hearing shall be transcribed by court reporters (same day transcript), the costs of which are to be advanced by each Party in equal share, without prejudice to the decision of the Arbitral Tribunal as to which Party shall ultimately bear these costs and to what extent.

8. Hearing for Oral Argument

8.1. The Hearing for Oral Argument shall take place in Stockholm on 22 November 2004 (23 November being a reserve day) unless combined with the Witness Hearing as provided under § 1.7 supra.

8.2. The principle of equal time for each Party shall be observed for the Hearing for Oral Argument.

9. Tribunal appointed expert

9.1. The Arbitral Tribunal may appoint one or more experts on its own initiative or at the request of a Party. Before appointing an expert or fixing his terms of reference, the Arbitral Tribunal shall hear the Parties on the issue. The expert appointed by the Arbitral Tribunal shall in principle submit a written report and, at the request of one of the Parties or of the Arbitral Tribunal, may be asked to appear at a hearing to be heard in person; each Party shall be entitled to examine the expert.

10. Translations - Interpretation

10.1. English language translations shall be provided of evidentiary documents, Witness Statements and Expert Reports not originally written in English.

10.2. Legal texts (statutory texts, case law and scholarly writings) in a language other than English need only be translated insofar as their relevant parts are concerned, unless otherwise requested by the Arbitral Tribunal, on its own motion or at the request of a Party.

10.3. Translations shall always be simultaneously submitted with the original text to the Arbitral Tribunal and the opposite Party.

10.4. Any Party that intends to present oral evidence in a language other than English shall be responsible for providing simultaneous interpretation of such evidence into English.

10.5. Costs of any translation or interpretation are to be advanced by the Party providing it, without prejudice to the decision of the Arbitral Tribunal as to which Party shall ultimately bear those costs and to what extent.

10.6. The requesting Party shall be responsible for providing translation of documents produced by the other Party at its request or pursuant to an order of the Tribunal.'