The February 2010 decision of the ICSID annulment committee in the dispute between investors Rumeli Telekom and Telsim Mobil and Kazakhstan highlights how tribunals may resolve the fundamental problem in expropriation cases of the “inherently uncertain” quantification of a business’s market value. Mark Kantor, a Washington, DC attorney and member of the Global Arbitration Review editorial board, says that, for the annulment committee, the process of calculating the amount to be awarded is one of “informed estimation” by the tribunal