Scenario 01

---
name: draft-notice-of-arbitration-scenario-01
task_id: arbitration-international-dispute-resolution/draft-notice-of-arbitration/scenario-01
description: Ensures a notice of arbitration identifies the parties, describes the dispute and relief sought, addresses any contractual liability cap in a neutral way, references the filing fee, and uses documented prior knowledge and settlement history as factual context where relevant.
activates_for: [planner, solver, checker]
---

# Skill: ICDR Notice of Arbitration

## 1. Subject-matter triage (only if applicable)

- Confirm this is a first-instance filing that must stand on its own as the operative arbitration notice.
- Identify the governing arbitration clause, seat, institution, and rule set before drafting any facts or remedies.
- If the source set includes multiple agreements, parties, or dispute strands, enumerate them first and map each to the governing clause before composing the notice.

## 2. Failure modes the skill is correcting

- Drafts the notice as an advocacy memo instead of a procedural pleading that cleanly initiates the case.
- Misidentifies the parties, the contractual relationship, the administering institution, or the applicable rules.
- States damages in a way that over-commits to a projection without qualifying uncertainty where the measure is forward-looking.
- Omits or handles too casually any contractual liability cap, creating avoidable credibility and pleading problems.
- Fails to reference the filing fee and concurrent submission, leaving the initiation package incomplete.
- Uses prior knowledge or settlement history either not at all or too aggressively, rather than as limited factual context tied to the dispute narrative.
- Omits the proposed number of arbitrators or states it inconsistently with the clause.
- Adds unnecessary detail from the source documents that is not needed to identify the claim and relief.

## 3. Legal frameworks / domain conventions that apply

- ICDR notice practice: identify the claimant and respondent, state the nature of the dispute, describe the relief sought, and specify the requested arbitrator structure under the applicable ICDR Rules.
- Pleading orientation: the notice should be concise, intelligible, and sufficient to commence arbitration; it need not prove the case, but it should frame the claims with enough factual precision to anchor jurisdiction and relief.
- Damages framing: present concrete, documented losses as primary support; if a forward-looking measure is used, pair it with a more certain alternative and qualify it as contingent or estimated.
- Contractual liability cap: if the governing agreement contains an aggregate cap or related limitation, acknowledge it neutrally and preserve arguments about scope, exceptions, allocation, or applicability without over-litigating it.
- Prior knowledge and settlement background: documented awareness of the risk, notice, escalation history, and settlement exchanges may be used as factual context, but should not turn the notice into a merits brief.
- Filing mechanics: reference the filing fee and confirm contemporaneous submission in the notice or cover materials consistent with the institution’s procedure.
- Authority discipline: when the notice relies on a rule or procedural proposition, tie it to the ICDR Rules, the arbitration clause, or another controlling source rather than stating conclusions bare.

## 4. Analytical scaffolds

- Start with party identification, counsel/contact details if available, and the institutional heading required by the governing clause and rules.
- State the arbitration agreement and the dispute category in one short factual paragraph.
- Describe the breach chronologically: contract, service commitment, alleged failure, notice/cure/escalation, and resulting harm.
- Use only the factual record needed to show why arbitration is being commenced; avoid argumentative surplus.
- For damages, separate:
  - documented direct losses or other concrete amounts;
  - any estimated or forward-looking component, expressly qualified as uncertain or contingent where appropriate;
  - any contractual cap issue, stated neutrally and without conceding applicability.
- Where the record shows prior knowledge of the risk, place it in the background section as support for the claim narrative and to anticipate any voluntary-risk or assumption-related response.
- Where settlement discussions occurred, mention them only to the extent needed to explain the history of the dispute, failed resolution, or timing of filing.
- State the requested relief in litigation-neutral terms: monetary relief, interest if sought, costs, fees if available, and any other contractually grounded remedy.
- Specify the proposed number of arbitrators consistently with the clause and the value/complexity of the dispute.
- Include the filing fee reference and the fact of concurrent payment or submission in a procedural paragraph or closing sentence.
- Before finalizing, verify that every factual assertion used to support the filing is anchored in the source materials and that no unsupported amount is presented as certain.

## 5. Vertical / structural / temporal relationships (only if applicable)

- If the dispute involves multiple service periods, incidents, or notice events, present them in time order so the escalation path is legible.
- If several parties appear in the source set, distinguish contracting party, service recipient, service provider, and any affiliate or guarantor roles without collapsing them into one label.
- If the contractual record includes layered provisions affecting remedies, order of precedence, or limitation of liability, identify the operative layer first and note any interaction only as needed for the notice.
- If there is a settlement sequence, preserve the chronology: breach, notice, negotiations, impasse, filing.

## 6. Output structure conventions

- Draft the operative notice as the primary deliverable; do not replace it with a summary or cover note.
- Use a conventional arbitration-notice shape:
  - caption and institution;
  - parties;
  - agreement and jurisdictional basis;
  - factual background;
  - claims/dispute summary;
  - damages and relief sought;
  - liability-cap acknowledgment, if relevant;
  - procedural requests including arbitrator count;
  - filing-fee statement;
  - signature block and service/contact details.
- Keep the tone neutral, procedural, and precise; reserve advocacy for the minimum needed to state the claim.
- Do not quote internal source materials verbatim unless a direct quotation is necessary and already provided by the record.
- Do not introduce extra parties, contracts, or authorities not supported by the source set.
- Ensure the final document is complete, self-contained, and suitable for filing as notice of arbitration under the referenced rules.