In principle, an investment arbitral tribunal does not have jurisdiction over a purely contractual claim.16 It follows that an investment court has jurisdiction only where the claimant`s claims arise from an ILO.17 In a recent arbitral award, a court concluded that an infringement was probably not sufficient to bring an infringement to an end. 18 In another case, the court decided that it did not have jurisdiction, given that the claimant`s claim is a mere contractual claim which is `disguised as a contractual matter` and which has already been decided by a court in a previous arbitration procedure between the same parties, 19 The question whether a contract can be regarded as a protected investment arises unlike the second court. . . .