1 AWD 180–64–1, slip op. at 21.

2 Id. at 31–32.

3 Id. at 32–33.

4 Id. at 36.

5 Id.

6 Id.

7 For background information on the Algiers Accords and the establishment of the Tribunal, see 77 AJIL 642 (1983).

8 Slip op. at 37.

9 Id. at 37–38. The sum of $265,000 was the amount claimed for legal costs relating to claimant’s action before the Tribunal. The total amount claimed for legal costs, including fees for prosecuting the related case in U.S. court, was $830,093.76.

10 Holtzmann stated that in his view, claimant’s costs of litigation in the United States should not be granted because, inter alia, such costs are not covered by Articles 38 and 40 of the Tribunal’s Rules.

11 Separate Opinion of Holtzmann, Howard M., AWD 180-64-1, slip op. at 7–8 Google Scholar.

12 The Chamber observed that in the past, the Tribunal has never awarded compound interest. AWD 180-64-1, slip op. at 31. Indeed, in one of the cases cited, the Tribunal stated that it is a “settled” rule of international law that compound interest is not allowable. Reynolds, R. J. Tobacco Co. and Iran, AWD 145–35–3 (Aug. 6, 1984)Google Scholar (Chamber 3).

13 See, e.g., International Schools Services, Inc. and Iranian Copper Industries Co., AWD 194-111-1 (Oct. 10, 1985) (Chamber 1) (awarding interest payment of 10%).