COUNTERCLAIM

Arbitration Case No. _______-_______, Tokyo

COUNTERCLAIM

To:The Japan Commercial Arbitration Association

Counterclaimant:
(Respondent)
E Corporation
----------------------, San Francisco
California, United States of America
Representative: Mr. B
President

Attorney for the Counterclaimant (Respondent):
Mr. G, Attorney-at-law
Law office of H
[Address], Osaka
[telephone number]
[facsimile number]
[email address]

Counterrespondent:A Co., Ltd.
(Claimant) [Address], Tokyo
Representative: Mr. B
Representative Director

I Relief or remedy sought by the counterclaims:

The counter-claimant asks that the following arbitral award be rendered:

  1. the counter-respondent (the Claimant) shall pay to the counter-claimant (the Respondent) the sum in the amount of ¥50,000,000 together with interest thereon at the rate of 6%per annum from --------------, 20---- until the date of full payment thereof; and
  2. the arbitration fee, arbitrator's remuneration and any other necessary expenses incurred during the arbitral proceedings shall be borne by the counter-respondent (the Claimant).

II Summary of the dispute and the basis for the counter-claim:
(omitted)

III Reference to the arbitration agreement that is invoked:
(omitted)

IV Manner or method of proof:

Relevant evidence shall be submitted in the future during the course of the proceedings.

--------------, 20----
(signature)

Attorney-at-law
Attorney for the Counterclaimant
(the Respondent)



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