For the foregoing reasons, the Claimant respectfully requests that the Arbitral Tribunal issue an award:
|(i)||Ordering the Respondent to pay USD 110,000 to the Claimant.|
|(ii)||Ordering the Respondent to pay the Claimant interest on any amounts awarded to Claimant at the rate of 15% per annum, from the day following the service of this Request for Arbitration until final payment of any awarded amount;|
|(iii)||Ordering the Respondent to reimburse the Claimant for all costs the Claimant incurs in this arbitration including the fees and expenses of the arbitrators, the KCAB administrative expenses,|
|(iv)||Ordering further relief as the Arbitral Tribunal deems appropriate.|
The Claimant is a Korean Corporation engaged in sea and air freight forwarding business. The Claimant and the Respondent
executed "Sea and Air Cargo Transportation Agency Contract("Agency Agreement") on November 01,
199# (see the attached Exhibit A-1),
Based on this "Agency Agreement", the Claimant and the Respondent had transported sea
and air cargo reciprocally and had settled the freight charge accounts within 1 month.
The Respondent failed to make payment on the accounts outlined below and had no special reasons.
The exact calculation is as follows:
- Accounts amount: US$20,620.12
- Period: from June 1996 to December 1996
The Claimant met the Respondent in Manila on June 14, 1997 and verified the amount owed and the detail statement for cargo
business. The Respondent and the Claimant agreed that the Respondent would pay to the Claimant US$20,620.12 before
September 30, 1997 and that all disputes arising from the Respondent's inability to fulfill the above obligations would be resolved
by arbitration. (see the attached Exhibit A-2)
The Respondent did not pay the freight charge. Accordingly, the Claimant requested arbitration to be conducted by the Korean
Commercial Arbitration Board as set forth in the Purport.
1) The Statement of Claim must be signed by the representative of the Party or the person in charge who submitted the Power of
2) It is recommended to write an enumerated list of exhibits so that the Arbitrator can mention any individual piece of evidence
in the award.