[9] Phoenix Action Ltd. v. Czech Republic, ICSID case n. ARB/06/5, award, 15 April 2009, §114: “To summarize all the requirements for an investment to benefit from the international protection of ICSID, the Tribunal considers that the following six elements have to be taken into account: 1–a contribution in money or other assets; 2–a certain duration; 3–an element of risk; 4–an operation made in order to develop an economic activity in the host State; 5–assets invested in accordance with the laws of the host State; 6–assets invested bona fide.”