Request and Statement of Claim (HEAP Track, Memorial) (ICC Rules) by OLL
REQUEST AND STATEMENT OF CLAIM
ICC Case No.: [Case No.]
IN THE MATTER OF AN ARBITRATION UNDER THE ICC RULES OF ARBITRATION (2026) (HIGHLY EXPEDITED ARBITRATION — APPENDIX VI)
BETWEEN
[Claimant's name]
[Claimant's address]
("Claimant")
— and —
[Respondent's name]
[Respondent's address]
("Respondent")
Submitted on behalf of the Claimant by: [Representative's title and name]
Date: [date]
This template numbers every paragraph, including optional ones, as though included. Delete any paragraph or clause that does not apply to this filing and renumber sequentially before submission.
Preliminary Notes
"HEAP" is ICC's own shorthand for the Highly Expedited Arbitration Provisions (Appendix VI), also referred to as "Highly Expedited Arbitration" in Article 33 of the main Rules.
Availability. HEAP is opt-in only, with no monetary threshold restricting its application — unlike the Expedited Procedure's default-application threshold under the Standard track (see Appendix V). Under HEAP, the Tribunal is a sole arbitrator, the award is due within 3 months of the initial CMC, the Tribunal may refuse document production requests entirely, and the Tribunal may decide the case on the documents alone, without an oral hearing.
Merged Filing. This single document constitutes both the Request for Arbitration and the Statement of Claim, filed together as one filing event. There is no separate, later-filed Statement of Claim under this track. Because Appendix VI requires the full legal and factual basis — and, to the extent possible, the evidence relied on — to be filed with the Request, this document is necessarily drafted in full-argument form; there is no abbreviated facts-only variant under HEAP.
Confirm the Parties have opted into Highly Expedited Arbitration pursuant to Appendix VI/Article 33 before using this template — HEAP is never the default track.
Introduction
This Request and Statement of Claim is submitted together, pursuant to Appendix VI/Article 33, given the Parties' opt-in to HEAP.
This document includes the full legal and factual basis and, to the extent possible, the evidence relied on — not a bare Request.
Section index: (I) the Parties; (II) Jurisdiction and HEAP Eligibility; (III) Factual Background; (IV) Legal Grounds; (V) Loss and Quantum; (VI) Relief Sought; (VII) Evidence Relied On; (VIII) Exhibit Schedule.
The Parties
The Claimant is [Claimant's name], [description].
The Respondent is [Respondent's name], [description].
Jurisdiction and HEAP Eligibility
The Tribunal has jurisdiction pursuant to the arbitration agreement at [clause reference], seated at [seat of arbitration].
HEAP eligibility is confirmed: there is no monetary threshold restricting opt-in, and the Parties have elected sole-arbitrator determination with a 3-month award deadline from the initial CMC.
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