This document is the Claimant's Memorial on the merits in an ICSID arbitration initiated against the United Mexican States under the North American Free Trade Agreement (NAFTA). The Claimant, Espíritu Santo Holdings, LP, sets forth its claims concerning the alleged destruction of its investment in a concession to modernize and operate a digital taximeter and ride-hailing system for the entire taxi fleet of Mexico City. The Claimant asserts that its Mexican subsidiary, Lusad, after a transparent public bidding process, was awarded a long-term concession by Mexico City's Secretariat of Mobility (Semovi). Following the award, the Claimant invested substantial capital over several years to develop the "L1bre System," obtaining all requisite governmental certifications and approvals. The Claimant contends that just as the system was ready for a mandatory, city-wide rollout in 2018, a newly elected Mexico City administration, for purely political reasons, first temporarily and then indefinitely suspended the Concession. This suspension, the Claimant argues, was a de facto termination that rendered its investment worthless. The Claimant further alleges that the government subsequently developed and launched its own state-run, copy-cat application, "Mi Taxi," which appropriated the core features and business model of the L1bre System. The Claimant frames these actions as breaches of Mexico's obligations under NAFTA, specifically: Article 1110 (unlawful, uncompensated expropriation), Article 1105 (failure to provide fair and equitable treatment and the minimum standard of treatment), and Article 1102 (discriminatory treatment in favor of a domestic, state-owned enterprise). The Claimant requests that the Tribunal declare Mexico in breach of its NAFTA obligations and order the payment of damages of not less than USD $2.802 billion, representing the fair market value of the investment but for the state's actions, inclusive of pre-award interest and a gross-up for taxes. The Claimant also seeks post-award interest and the full costs of the arbitration.