The document is a Request for Arbitration filed by Espíritu Santo Holdings, LP ("Claimant"), a Canadian entity, against the United Mexican States ("Mexico") before the International Centre for Settlement of Investment Disputes (ICSID). The claim is brought pursuant to the North American Free Trade Agreement (NAFTA). The dispute concerns Claimant's investment in a concession granted to its Mexican subsidiary, Servicios Digitales Lusad, S. de R.L. de C.V. ("Lusad"), to install and operate a proprietary digital taximeter and mobile hailing application system for all registered taxis in Mexico City. Claimant alleges that following a change in the municipal government of Mexico City, Mexico engaged in a series of unilateral, arbitrary, and politically motivated measures that destroyed its investment. Claimant's principal contentions are that Mexico, through the actions of the Mexico City government, first unlawfully suspended the installation of the system, then permanently suspended the concession, and ultimately terminated it without due process. Claimant further alleges that Mexico misappropriated Lusad's technology and business concept by developing and launching a state-run replacement application, "Mi Taxi," which offered substantially the same services. Claimant asserts that these actions constitute an unlawful indirect expropriation without compensation in breach of NAFTA Article 1110, a denial of fair and equitable treatment and full protection and security in breach of NAFTA Article 1105, and discriminatory treatment in breach of the national treatment standard under NAFTA Article 1102. As relief, Claimant requests the Tribunal to declare that Mexico has breached its NAFTA obligations, order Mexico to pay compensation for all resulting losses, estimated to be in the billions of U.S. dollars, plus interest, and award all costs of the arbitration.