Claimant, an Italian company, and Respondent, a Philippine company, entered into an Engineering, Procurement and Construction (EPC) Contract relating to a project to be built by Claimant and owned and operated by Respondent. The contract included a completion date, referred to as the 'Guaranteed Substantial Completion Date', which was initially set at 30 June 2000 and later deferred to 31 March 2001 by a written amendment (Amendment Agreement). Claimant initiated arbitration proceedings to obtain a further extension of the completion date on grounds of force majeure. With its Answer to the Request for Arbitration, Respondent moved to dismiss the claim of economic duress raised by Claimant in Supplement No. 2 to the Request for Arbitration.