Jan. 2015 CIETAC

Written Application for Arbitration (Model)

Claimant: Global (NY) International Co., Ltd., a company incorporated and existing under the laws of New York State (see P.P.1-3, the attached document of official registration at a New York authority)

Domicile (address officially registered): 2345, Fifth Avenue, New York, NY 10017, USA

Tel: (212) 1234567     Fax: (212) 1234568     Email: legalny@global.com

Person in charge: Simon Smith, Chairman of Board of Directors

Arbitral Agent: San, Zhang (see P. 4, the attached Power of Attorney) whose contact address is:

Post Code:

Tel:                 , Fax:                  Email:

Respondent: ZHAOQIAN Sunli, a citizen of People's Republic of China (see P.5, the attached Xeroxed copy of the ID Card of Citizen of the People's Republic of China)

ID Card No.:

Domicile:                                   Post Code:

Tel:                 , Fax:                  Email:

The Arbitration Agreement this Application Relies Upon: The arbitration clause—Article 15.1 of the Contract on the sales of leather clothes No. GIT05/90 signed by and between the Claimant Global (NY) International Co., Ltd. and the Respondent (see P. 6 of the attachment) reads: "…………".

Arbitral Claims:

1 The Respondent shall pay the Claimant USD165,751 as the price of the contractual commodity.

2 The Respondent shall pay the Claimant USD4,131 as the liquidated damages suffered by the Claimant.

3 The Respondent shall pay the Claimant USD3,000 to compensate the legal cost of the Claimant.

4 The Respondent shall compensate the Claimant for its traveling expenses for the present case.

5 The Respondent shall bear the arbitration fee of the present case.

The Facts and Reasons the Arbitral Claims Rely Upon:

On Sept. 9, 2013, the Claimant and the Respondent signed in Hong Kong a contract on the sales of leather clothes No. GIT05/90 (see P. 6 of the attachment), agreeing that the Claimant should sell a number of leather clothes to the Respondent. The contractual price was agreed to be USD165,751, which should be paid 180 days after the acceptance of the documents (D/A180 days).

After signing the Contract, the Claimant have the leather clothes manufactured, using the leather and the auxiliary material the Respondent examined and designated, according to the styles of clothes designated by the Respondent. The Respondent examined the goods, the leather clothes, and signed a Certificate of Conformity with the Contract (see P. 7 of the attachment). The Hebei Commodity Import and Export Inspection Bureau issued a Certificate (see P.P. 8-9 of attachment). The Goods were later timely delivered within the contractual time of delivery. After the arrival of the goods, the Respondent accepted the relevant documents inclusive of the draft and then took the goods. Within the time limit prescribed by the Contract, the Respondent did not raise nay objections regarding the quality of the goods, nor has the Respondent produced the inspection report that should be produced to accompany the objections on the quality of the goods.

The Claimant urged many times, via fax, email and etc., the Respondent make the payment for the contractual goods. The Respondent refused to honor its contractual obligations of payment and has constituted fundamental breach of contract. The Claimant sent faxes to the Respondent (see P. P. 10-15, the attachment) and called the Respondent (see P. P. 16-17, testimony of witnesses in the attachment) in order to settle the case.

But the Respondent lacked no good will.

The Application is hereby respectfully submitted to China International Economic and Trade Arbitration Commission.

Attachment:

1 P.P.1-3 of the attachment, document of official registration at a New York authority

2 P. 4 of the attachment, Power of Attorney

3 P. 5 of the attachment, the ID Card of Citizen of the People's Republic of China

4 P. 6 of the attachment, the Contract on the sales of leather clothes No. GIT05/90

5 P. 7 of the attachment, the Certificate of Conformity with the Contract, signed by the Respondent

6 P.P. 8-9 of attachment, the Certificate by The Hebei Commodity Import and Export Inspection Bureau

7 P. P. 10-15 of the attachment, the faxes to the Respondent

8 P. P. 16-17 of the attachment, testimony of witnesses

Signature and/ Seal of the Claimant or its Arbitral Agent
(Date)