NAFTA - Chapter 11 - Investment

Cases filed against the Government of Canada

Contractual Obligation Productions, LLC, Charles Robert Underwood and Carl Paolino v. Government of Canada


Contractual Obligations Productions, LLC (a New York limited liability company), Charles Robert Underwood, and Carl Paolino (U.S. citizens residing in California and New York State respectively).


  • 1102 (National Treatment)
  • 1105 (Minimum Standard of Treatment)
  • 1106 (Performance Requirements)
  • 1110 (Expropriation)

Damages claimed

$20 million USD


Inactive. No tribunal constituted after the claim was filed.


Procedural history

The Investors served a Notice of Intent to Submit a Claim to Arbitration under NAFTA Chapter 11 on June 30, 2004 followed by a Statement of Claim on February 9, 2005. An Amended Statement of Claim was received in June 2005.

Factual overview and nature of the claim

The claimants alleged that, after investing considerable time and money in developing an American Movie Classics (AMC) production entitled "The Wrong Coast", they became ineligible to continue working on the production after AMC applied to the Canadian Audio-Visual Certification Office (CAVCO) for a tax credit. CAVCO tax credits are conditional upon Canadian citizens being involved in a production. 

Legal documents (all documents are in pdf)

The documents have been posted in the language in which they were received by the government. The Government of Canada has not modified or changed them in any way. As such they have not been translated from the original. They are provided in Acrobat (pdf) files. To view or download pdf files you need Adobe® Acrobat® Reader™ a free software that you can download from the web.

Back to "Cases Filed Against the Government of Canada"
Back to the main menu "Dispute Settlement - NAFTA Chapter 11"