Facts: X. initiated arbitration proceedings against Z. under a joint venture agreement ("JVA"). A partial award on liability held that X. had standing to claim under the JVA and that Z was in breach of its contractual obligations. At the subsequent hearing on the quantum of damages, Z produced a document entitled "Certificate of Incorporation", showing as date of incorporation of X. a date subsequent to the making of the JVA and the filing of the request for arbitration. Based on this document, Z. challenged the jurisdiction of the tribunal and X.'s standing. Having given the parties the opportunity to submit written argument, the tribunal rendered its final award. The tribunal held that it had jurisdiction and that X. was not a legal entity. Consequently, the tribunal declared the proceedings closed for lack of a legal person on claimant's side. "X., a division of Y, a pseudonym of Y. Inc.," challenged the award before the Swiss Supreme Court, asserting that the final award
