On May 20, 2014, an arbitral tribunal (the Tribunal) convened under the terms of a bilateral investment treaty between the Kingdom of the Netherlands and the Czech and Slovak Republic (the Treaty), and operating under UNCITRAL Rules, found [3] that it did not have jurisdiction over a claim brought by Achmea B.V. against the Slovak Republic because Achmea B.V. had failed to state a prima facie case. Notwithstanding this, the Tribunal held that there was a “dispute,” which was also a requirement for jurisdiction to exist, because “it suffices if it is established that there is a conflict of legal views between the Parties.”