Investment Arbitration In Mexico: Why An Over USD 2.1 Billion Claim Failed

The arbitration in Espíritu Santo Holdings, LP and L1bre Holding, LLC v. United Mexican States concerned a digital taximeter project in Mexico City and claims exceeding USD 2.1 billion.¹ On 26 March 2026, the tribunal reportedly dismissed all claims in favour of Mexico.²

The case arose from an investment in Servicios Digitales Lusad, S. de R.L. de C.V., a Mexican company that held a 10-year concession to replace taximeters in Mexico City and operate a mobile taxi application.³ The claimants alleged that Mexico had breached the North American Free Trade Agreement (“NAFTA”), including the provisions on national treatment, the minimum standard of treatment and expropriation.⁴

The case is useful because it illustrates a point that is often decisive in investment arbitration: a commercially significant project does not become a treaty claim unless the investor can link State conduct to a specific treaty breach, causation and recoverable loss.