The claim involved a dispute between our clients and another Iraqi party under a supply contract subject to foreign arbitration valued at over 400 Million USD. According to Article 25(1) of the Iraqi Civil Code No 40 of 1951 (the "Civil Code"), contractual obligations shall be governed by the law of the state wherein lies the domicile of the contracting parties if they have a common domicile; otherwise, the law of the state within which the contracts were concluded will be applied unless the contracting parties agree otherwise or where it would be revealed from the circumstances that another law was intended to be applied.