There have been conflicting decisions over the years, but the topic is particularly newsworthy at the moment following French academic and arbitrator Brigitte Stern using her dissenting opinion in an ICSID award in Impregilo SpA v Argentina (ICSID Case No ARB/07/17 ??? June 21, 2011) to warn of the ???great dangers??? of allowing claimants to bypass a BIT???s jurisdictional requirements by invokin