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Published online by Cambridge University Press: 27 February 2017
1 Haji-Bagherpour v. The United States of America, AWD 23-428-2 (Jan. 26, 1983) (Chamber Two).
2 See Harza Engineering Co. v. The Islamic Republic of Iran, AWD 19–98–2 (Dec. 30, 1982) (Chamber Two) (“the phrase ‘expropriations or other measures affecting property rights’ has broad meaning under international law”).
3 The dissent also noted that the majority’s interpretation of “other measures” was not supported by the U.S. pleadings in Haji-Bagherpour, supra note 1, since that case “arose in a different context and the Award of Chamber Two was made without ‘addressing the issue at hand’ in this case.”