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Gazprom Export must provide solution for payment of the Award
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Applying EU competition law, tribunal sees no abuse of dominant position by Gazprom Export
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Penalty clause is unconscionable, but should not be entirely set aside since Gasum agreed to it
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Gasum waived its right to challenge conscionability of obligations under take-or-pay clauses
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Russian presidential decree represents force majeure event, even though respondent is a state-owned entity
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Payment in line with Russia’s Decree No. 172 entails risk of EU sanctions breach
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While CISG Convention is applicable, it does not displace “unconscionability” doctrine under Swedish law
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Background: renegotiations of long-term gas contract are further perturbed by Russia’s new payment policy
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