On October 1, 2018, the International Court of Justice ruled [3] in Obligation to Negotiate Access to the Pacific Ocean (Bolivia v. Chile) that Chile was not obligated to negotiate sovereign access to the Pacific Ocean for Bolivia. As noted in the press release [4], Bolivia argued that Chile had an obligation to negotiate in order to reach an agreement giving Bolivia sovereign access to the ocean, citing several discussions between the states over a number of years that Bolivia argued showed Chile had bound itself to negotiations that would lead to the access point. Bolivia brought eight legal bases to support its claim: bilateral agreements; Chile’s declarations and other unilateral acts; acquiescence; estoppel; legitimate expectations; provisions of the Charter of the Organization of American States (OAS); resolutions of the OAS General Assembly; and the cumulative effects of the instruments, acts, and conduct. The Court noted that the states “have a long history of dialogue, exchanges and negotiations aimed at identifying an appropriate solution to the landlocked situation of Bolivia following the War of the Pacific and the 1904 Peace Treaty,” but found that Chile did not have “the obligation to negotiate with Bolivia in order to reach an agreement granting Bolivia a fully sovereign access to the Pacific Ocean.”