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14On December 14, 2001, Valvision submitted the requested response (C.sub 5).On December 21, 2001, Vision N.V. and Vision B.V. submitted their response(R.sub 5).Despite the request made by the Arbitral Tribunal that the parties refrain fromadditional exchanges, the parties filed the following submissions:- C.sub 6: Letter from Valvision's counsel <strong>of</strong> January 10, 2002, numberedC.sub 6 by the Arbitral Tribunal- R.sub 6: Letter from Vision N.V. and Vision B.V.'s counsel <strong>of</strong> January 24,2002, numbered R.sub 6 by the Arbitral Tribunal- C.sub 7: Letter from Valvision's counsel <strong>of</strong> January 31, 2002, numberedC.sub 7 by the Arbitral Tribunal- R.sub 7: Letter from VisionN.V.' and Vision B.V.'s counsel <strong>of</strong> February 7,2002, numbered R.sub 7 by the Arbitral TribunalOn March 1, 2002, the Arbitral Tribunal notified the parties that the procedurehad closed.V1. FACTUAL OVERVIEW - HISTORY OF THE DISPUTE16. Before reviewing the issues that are before this Tribunal and the claimsand counterclaims that have been asserted, it is necessary to put the dispute inits context. This section contains a general overview, in an attempt to set outthe essential facts, which constitute the basis <strong>of</strong> the claims.§1. DENOMINATION OF THE RESPONDENTS17. Vision N.V., a company registered under the rules <strong>of</strong> Dutch law, is 100%owned by Vision B.V., also registered in the Netherlands. Vision B.V. is 100%owned by KPN.Vision B.V. is the holding company for KPN Kabel assets throughout Europe.In its submissions, Valvision consistently refers to "KPN" in order to refer to eitherKPN, Vision N.V. or Vision B.V. KPN is not a party to this arbitral procedureand the Arbitral Tribunal will therefore use the terms "Vision", "Vision N.V.","Vision B.V." and "KPN" where specifically appropriate, and as previouslfin ed( see above p. 5) .C. VjA02338488/0.3I/ 10 Oct 2002de-ṞE C IIV,QV COUR INTERNATIONALE D'ARBITRAGEINTERNATIONAL COURT OF ARBITRATIONaby

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