ABBREVIATIONS GLOSSARY OF GEOGRAPHIC NAMES Introduction Chapter One: Background to and Course of the South China Sea Arbitra- tion and the Position of the Chinese Government Chapter Two: Jurisdiction Ⅰ.The Tribunal had no jurisdiction over the Philippines' submis- sions which reflect a territorial and maritime delimitation dispute between China and the Philippines 1.1.There exists a territorial and maritime delimitation dispute between China and the Philippines in the South China Sea 1.2.The essence of the Philippines' submissions is the territo- rial and maritime delimitation issue between China and the Philippines Ⅱ.The Tribunal erroneously found that the Philippines' submissions do not relate to the territorial and maritime delimitation dispute between China and the Philippines and erroneously exercised ju- risdiction over these submissions Ⅱ.1.The Tribunal erred in characterizing the dispute reflected in the Philippines' submissions by adopting a fragmentation approach and failed to objectively and properly identify the territorial sovereignty and maritime delimitation es- sence of the Philippines' submissions Ⅱ.2.The Tribunal, on the basis of subjective assumption in- stead of fact, erroneously found that the Philippines' sub- missions do not relate to territorial sovereignty Ⅱ.3.The Tribunal misconstrued maritime delimitation, misin- terpreted Article 298 of the Convention, and erroneously determined that the Philippines' submissions do not relate to maritime delimitation Ⅱ.4.The Tribunal erred in finding that the Philippines' Submis- sions *** and 2 did not involve \"historic rifle\" and failed to consider whether \"historic rights\" constitute relevant circumstances of maritime delimitation Ⅲ.The Tribunal erred in finding that the Philippines' submissions reflected the disputes as it identified between China and the Phil- ippines concerning the interpretation or application of the Con- vention Ⅲ.1.International judicial practice in respect of determining the existence and nature of a dispute Ⅲ.2.The Tribunal erred in identifying and characterizing a dis- pute with respect to the Philippines' Submissions *** and 2 Ⅲ.3.The Tribunal's identification and characterization of dis- putes with respect to the Philippines' Submissions No.3 through 7 are not well founded in fact or law Ⅲ.4.The Tribunal failed to ascertain there exist disputes be- tween China and the Philippines concerning the interpre- tation or application of the Convention with respect to the Philippines' Submissions No.8 to 14 Ⅳ.The Tribunal erred in its decision on the choice of means made by China and the Philippines for the settlement of disputes and its effect Ⅳ.1.The Tribunal erred in finding no agreement between China and the Philippines to settle their dispute through negotiations Ⅳ.2.The Tribunal erred in determining that China and the Philip- pines had resorted to negotiation but reached no settlement Ⅳ.3.The Tribunal erred in finding that China and the Philip- pines had not excluded the compulsory dispute settlement procedures even if there existed an agreement Ⅴ.The Tribunal erred in finding that the Philippines and China had exchanged views as required by Article
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