In PSEG Global Inc. and Konya Ilgin Elektrik Üretim ve Ticaret Limited Sirketi v. Republic of Turkey, the Tribunal found that the respondent had breached its obligation to accord the investor fair and equitable treatment in connection with a planned investment in a coal-fired power plant. The claimants sought damages under three different approaches: (1) fair market value (US$ 172 million); (2) loss of profits (US$ 494 million); and (3) the amount invested in the project (US$ 48 million). The Brattle Group analyzed all three of the damages claims and, based on our testimony, the Tribunal awarded damages of only US$ 9 million.