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In Burlington v. Ecuador, a dispute arising out of two production-sharing contracts, the Chairman of the Administrative Council of the International Centre for Settlement of Investment Disputes (ICSID) upheld a proposal to disqualify Professor Orrego Vicuña according to Arbitration Rule 9(1), which provides that “a party proposing the disqualification of an arbitrator pursuant to Article 57 of the Convention [. . .] promptly, and in any event before the proceeding is declared closed, file its proposal with the Secretary-General, stating its reasons therefore.” The Chairman found that Professor Orrego Vicuña had not fully disclosed his previous appointments “both prior to and after” he was appointed by the party for the present case. The Chairman also found that “as the ICSID Convention and Rules do not specify a number of days within which a proposal for disqualification must be filed, the timelines of a proposal must be determined on a case by case basis.”