Response to Notice of Arbitration (UNCITRAL Rules) by OLL
This document is a formal template for a Respondent to reply to a Notice of Arbitration under the UNCITRAL Arbitration Rules. It provides structured sections for jurisdictional comments, the respondent's version of the dispute, the appointment of arbitrators, and any potential counterclaims.
This document comes from OLL's library of vetted legal templates.
IN THE MATTER OF AN ARBITRATION UNDER THE ARBITRATION RULES OF THE UNITED
NATIONS COMMISSION ON INTERNATIONAL TRADE LAW
BETWEEN:
[NAME OF CLAIMANT]
(CLAIMANT)
-AND-
[NAME OF RESPONDENT]
(RESPONDENT)
RESPONSE TO THE NOTICE OF ARBITRATION
NOTE: OR RESPONSE TO THE NOTICE OF ARBITRATION AND COUNTERCLAIMS, IF APPLICABLE
[Respondent’s representative’s law firm]
[Respondent’s representative’s law firm]
[Respondent’s representative’s address]
[Respondent’s representative’s telephone]
[Respondent’s representative’s fax]
Legal representative for Respondent [Date of the Response]
NOTE: Respondent’s Response must be communicated to Claimant within 30 days of the receipt of the Notice of Arbitration pursuant to Articles 4(1) of the UNCITRAL Arbitration Rules
I. INTRODUCTION
This Response to Claimant’s Notice for Arbitration (hereinafter the “Response”), OPTIONAL: together with its Exhibits numbered R-1 to R-[•], is submitted on behalf of [Name of Respondent] (hereinafter “Respondent”) pursuant to Article 4 of the Arbitration Rules of The United Nations Commission on International Trade Law in force as from 15 August 2010 (the “UNCITRAL Arbitration Rules”).
In this Response, unless otherwise stated, Respondent adopts the abbreviations used in Claimant’s Notice of Arbitration.
Unless otherwise stated, capitalised terms shall have the meanings given to them in the Notice.
Unless expressly admitted, each paragraph of the Notice is denied by Respondent.
Pursuant to Article 4 of the UNCITRAL Arbitration Rules, this Response contains information concerning the following:
i. The name, description and address of each of the Parties (II);
ii. Respondent’s comments as to the arbitral tribunal’s jurisdiction (III);
iii. Respondent’s position as regards the nature and circumstances of the dispute (IV);
iv. Respondent’s comments concerning the composition of the arbitral tribunal (V);
v. Respondent’s comments as to the place of arbitration, the applicable rules of law and the language of the arbitration (VI);
vi. Respondent’s counterclaims [if applicable] (VII); and
vii. Relief sought (IX)
II. THE PARTIES
NOTE: ARTICLE 4(1)(A) UNCITRAL ARBITRATION RULES
A. Respondent
Respondent is [Name of Respondent], a company registered under the laws of [Name of country or jurisdiction], with its registered office located at [Complete address].
Insert brief description of Respondent’s business activity, industry sector, size of business, number of employees, market position, revenue, etc., as relevant.
Respondent’s address is:
[Respondent’s name]
[Respondent’s address in full]
[Attention: name of Respondent’s director]
[Respondent’s telephone number]
[Respondent’s fax number]
[Respondent’s e-mail]
Respondent’s representative to whom all correspondence should be sent in this arbitration, are:
[Respondent’s representative’s law firm]
[Name of the partner in charge of representing Respondent]
[Names of other lawyers]
[Respondent’s representative’s address]
[Respondent’s representative’s telephone number]
[Respondent’s representative’s fax number]
[Respondent’s representative’s e-mail]
B. Claimant
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