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The brevity of this chapter is no reflection of the growing importance of international investment treaty arbitration. However, many such arbitrations are heard under the ICSID Convention Regulations and Rules. These do not specify a seat, as the rules of law pursuant to which the arbitration is conducted derive from the ICSID Convention as interpreted under principles of public international law. Accordingly the 1996 Act does not apply to ICSID arbitrations. It is thus beyond the scope of this book. It is only if the seat is expressed or chosen to be London, for example, if the UNCITRAL Rules apply, that such arbitrations are held in London.
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