This document is the Reply Post-Hearing Brief on Quantum submitted by the Respondent, the Plurinational State of Bolivia, in the PCA-administered arbitration initiated by Glencore Finance (Bermuda) Ltd. The brief presents Bolivia's rebuttal to the Claimant's quantum arguments following the hearing and initial post-hearing submissions, focusing on the valuation of the expropriated assets.

Bolivia's central argument is that the Claimant's valuation is fundamentally flawed and grossly inflated because it abandons the objective "willing buyer/willing seller" standard in favor of a speculative, "seller's only" model. Regarding the Colquiri Mine, Bolivia contends that the Claimant's valuation improperly relies on an unapproved and unrealistic "Triennial Plan" for expansion. It argues that a prudent buyer would have based the valuation on the mine's historical performance, underinvestment, and proven reserves, rather than on hypothetical resources that artificially extend the mine's life in contravention of industry standards. Bolivia also challenges the Claimant's attempt to use a later, unsupported "March 2012 Investment Plan" to salvage its valuation.

For the Vinto smelter, Bolivia asserts that the Claimant's valuation is anchored to an irrelevant and unproven 2005 purchase price, failing to account for the plant's operational decline, lack of capital investment under Claimant's management, and the significantly different macroeconomic and political landscape in Bolivia by the 2007 valuation date. Concerning the Antimony Smelter, Bolivia argues it holds no commercial value and constitutes a net liability due to extensive, pre-existing environmental contamination and the associated remediation obligations that the Claimant had assumed.

Finally, the brief addresses ancillary claims. Bolivia argues that the Claimant's request for interest based on a fixed, high-risk commercial lending rate is improper. It posits that interest should be purely compensatory for the time value of money and, therefore, a risk-free rate, such as that of U.S. Treasury Bills, should apply. Bolivia also rejects the Claimant's request for a tax-exempt award, characterizing it as speculative and premature. The Respondent requests the Tribunal to dismiss the Claimant's claims for compensation or, alternatively, to adopt the valuation methodologies of its own experts and reduce any award to account for the Claimant's contributions to its losses.