In Nurhima Kiram Fornan and others v. Spain, the Tribunal dismissed the case for manifest lack of legal merit under ICSID Rule 41. The Claimants, Philippine nationals and heirs of the Sultan of Sulu, initiated arbitration against Spain under the Philippines-Spain BIT (1993). The dispute arose from Spain's alleged conduct in relation to a separate ad hoc arbitration between the Claimants and Malaysia, which concerned an 1878 agreement. That ad hoc arbitration was initially seated in Madrid with a Spanish arbitrator appointed by a Spanish court. The Claimants argued that actions by Spanish courts, including annulling the arbitrator's appointment and initiating criminal proceedings against him, breached the BIT. They contended their "investment" in Spain consisted of legal fees paid to Spanish counsel and their monetary interest in the resulting multi-billion dollar award against Malaysia. Spain objected that the Tribunal manifestly lacked jurisdiction because there was no qualifying investment in its territory. The Tribunal agreed, finding that monies spent on legal fees were expenditures, not assets, and thus not an investment. It also held that the monetary interest in the award against Malaysia, which was rendered in France after the seat was moved, lacked the necessary territorial connection to Spain to qualify as an investment under the BIT. The Tribunal concluded that the jurisdictional requirement of a qualifying investment was not met and dismissed all claims.