The Guest Blog

Guest blog post by Sorin MOISA MEP

This article is an attempt to on the one hand understand the root causes of the ISDS controversy and, on the other hand, to spell out a set of possible compromises over this sensitive issue. Hanging in the balance is CETA, the new generation treaty between the EU and Canada, then perhaps TTIP and the future of trans-Atlantic relations beyond trade.

ISDS stands for ‘Investor-State Dispute Settlement’ and is an international law instrument allowing an investor to sue the state hosting its investment if it believes the latter has treated it unfairly. The ISDS discussion became particularly heated when Philip Morris decided to sue the Australian government over its new rules on ‘plain tobacco packaging’ inter alia forbidding the use of all company logos or symbols that may make cigarette packets more visually attractive. The colour of packets was pre-defined to be unattractive for consumers, and ‘graphic health warnings’ must now cover 75% of the front of the packet. The sale of non compliant products was forbidden as of 1 December 2012. Philip Morris Asia, registered in Hong Kong, challenged the new Australian rules under a 1993 Bilateral Investment Treaty between Hong Kong and Australia containing an ISDS clause allowing investors to submit claims for arbitration. It argues that it has been deprived of its investment and was not accorded ‘fair and equitable treatment’. We have therefore a conflict between public (health) policy and corporate interest. Another case relevant for the debate is the Vattenfall versus Germany dispute. Vattenfall is a state owned Swedish energy company that in May 2012 sued Germany over the withdrawal of its operating licenses for two German nuclear plants. The withdrawal of licenses flows from the latest (13th) amendment of Germany’s Atomic Energy Act, in the wake of the Fukushima disaster in March 2011, phasing out nuclear energy altogether by 2022. The claim is based on the ISDS clauses of the 1994 Energy Charter Treaty, and its amount is not known. According to a Vattenfall spokesman quoted by World Nuclear News on 16 October 2014, ‘based on the confidentiality of rules that apply for the process, Vattenfall cannot give any comments regarding the size of the compensation.’ [1] Interesting remark for a state owned company suing another state, against the backdrop of the Swedish culture of transparency. Vattenfall has already sued the German government ISDS over a water quality license for a coal-fired power plant in 2009, leading, apparently, to an out-of-court settlement containing a softer environmental permit [2].

To complete the scene setter, the main institution dealing with ISDS cases is the International Centre for the Settlement of Investment Disputes (ICSID), a member of the World Bank Group, in Washington, D.C. The Centre functions under a 1966 Convention ‘on the Settlement of Investment Disputes between States and Nationals of Other States.’ The President of the World Bank is ex-officio chairman of the ICSID Administrative Council (with no vote), but the most powerful figure is the Secretary General of ICSID. The disputing parties to a case cover the costs of proceedings. Even if cases are by definition between investors and governments, the ICSID convention is international law. The basic rule in the ICSID convention is that arbitration is voluntary: the parties must give their consent for arbitration, and once given consent cannot be withdrawn (Article 25). The final award is ‘law’ and the loser must accept it and enforce it.

The EU has negotiated or is negotiating agreements that are significantly improved over older BITs, including those invoked in the two cases above. However, much of the controversy remains. My main reference for this analysis will be the published CETA text, but this is not an exhaustive or dedicated analysis of ISDS in CETA.

The root of the problem

We may start with the lesson and the message of the European elections this year: there is fundamental distrust in our societies towards political elites, including, worryingly, the political mainstream. Most people have lost confidence not only in their leaders, but also in the very menu from which they choose their leaders. If this is so for national politics, it is even more valid for Europe. European institutions are lopsided against emotion, suffocating in their hyper-rationality. It is difficult for ‘that’ to win the hearts, whereas the complexity puzzles the minds. I see the ISDS debate as an extension – for the worse- of this syndrome. If you are frustrated that you are losing control over your life to distant bureaucrats, if you believe your national leaders are overwhelmed by Brussels and/or big business, how can you possibly trust a mysterious ‘private tribunal’ appointed offshore which can arbitrate between your country and a big multinational challenging the already fragile rights that you still have, nationally, over your environment or tax money? The question contains the implicit assumption that you may not trust your government much, but you trust even less an ad-hoc institution set up abroad on which you do not have even remote, indirect control. You do not even want to look into the details or merits of arbitral tribunals and how they are going to help investment in your country, you simply do not like the idea, there is something alien, strange, unhealthy, about it, you plainly reject the principle itself. Moreover, you dislike Brussels even more for even considering doing this to you.

It would be utter blindness not to listen to these concerns and to simply dismiss them as irrational. Even if some of them were irrational according to a definition of pure economic rationality, society is a mix of emotion, anxiety, hope and reason, and democracy has to embrace and account for all that.

The building blocks of arbitration

But if you were to look into it nevertheless, what would you find that could reassure you?

The core issues on which trust depends are, I believe, the nature of arbitration, the process for setting up the arbitral tribunal, transparency of its proceedings, and the fairness of the whole arbitral process.

According to Article 24 of the Investment chapter of the CETA text, the respondent (the state being sued) ‘consents’ to all future arbitration cases by the very signature of the treaty. In contrast, Article 25 of the ICSID Convention requires consent for each separate case, when it happens. States signing ISDS treaties agree to give up that power to offer consent on a case by case basis.

How is the tribunal selected? ‘Unless the disputing parties have agreed to appoint a sole arbitrator, the Tribunal shall comprise three arbitrators. One arbitrator shall be appointed by each of the disputing parties and the third, who will be the presiding arbitrator, shall be appointed by agreement of the disputing parties.’ If the appointments do not happen in 90 days, ‘the Secretary-General of ICSID shall appoint the arbitrator or arbitrators not yet appointed.’ How? By selecting them from a list of 15 arbitrators agreed on by the two state parties signing the treaty. If the list has not been established, ‘the Secretary General of ICSID shall make the appointment at his or her discretion taking into consideration nominations made by either Party and, to the extent practicable, in consultation with the disputing parties.’ It is evident that the Secretary-General of ICSID plays a potentially key role in the setting up of the Tribunal.

On transparency: the CETA text makes reference to the UNCITRAL Transparency Rules. Those rules essentially say that everything is to be made public, except what is not to be made public. In the latter category: ‘confidential business information’ or ‘information that is protected against being made available to the public (…) under any law or rules determined by the arbitral tribunal to be applicable to the disclosure of such information’ (Art. 7.2). To be sure, ‘any determination as to whether information is confidential or protected shall be made by the arbitral tribunal after consultation with the disputing parties.’ (Art. 7.3.)

On the possibility of appeal to an arbitral decision, the CETA text is simply noting a decision to ‘consult’ on ‘whether and if so, under what conditions, an appellate mechanism could be created’. It could hardly be clearer that there is no appellate mechanism in the making.

ISDS arbitration versus national courts

The most legitimate way to assess the fairness of the whole ISDS process is to compare with the guarantees (imperfect as they may be) provided by national courts in the states with rule of law.

The following are trust-creating factors in favour of national court systems:

  • magistrates are selected according to well established patterns and traditions, including accountability mechanisms, checks and balances, criminal penalties for wrongdoings;
  • decisions can be overruled by higher courts, which is a crucial feature of rule of law systems, stemming from a wise approach to human and institutional fallibility;
  • there is unitary interpretation of the law and converging jurisprudence, based on precedent and interpretation by the highest court of the land;
  • national courts have the possibility to conduct thorough investigations, using the sovereign resources of the state;
  • courts are perennial, not constituted for each case, avoiding potential conflicts of interests at least on jurisdiction matters;
  • national courts ensure that investors operating in the same country enjoy equal treatment and the same jurisdiction; Vattenfall suing under ISDS has a different treatment than RWE or E.ON suing under German law. Naturally, local courts are more adept at balancing public and private interests then a special investor-dedicated jurisdiction and legal instrument [3].

National courts do not provide full transparency, either, as it is legitimate to protect confidential information, including business information. But they apply general rules adopted by Parliaments to balance public and private interests, so it easier to accept and check confidentiality in this context than in that of an arbitral tribunal creating its own rules.

In order to better understand the ISDS process, I have read fully a recent case published by ICSID: US nationals David Minnotte and Robert Lewis vs. Republic of Poland [4]. It is a complex, fascinating case involving a project to fractionate blood plasma in Poland in the 1990s. The arbiters ruled in favour of Poland, and decided that the claimants should pay Poland more than a million dollars in compensation. The arbiters seem to me to be impeccable professionals, as I could not detect any feeling of, let alone argument for, pro-investor bias. In the same vein, it would be unfair to use the argument that the current Secretary General of ICSID is a Canadian national [5], or that the President of the World Bank is a US national, to suggest structural bias. The critical debate on ISDS should not create itself injustice against many honest professionals. The real discussion is not about individual people, but about process and the social legitimacy and acceptability of the ISDS process.

It is in this spirit that I now turn to proposing a few possible ways out from the ISDS conundrum.

Potential ways out

Without prejudging in any way on the final position of my group, as food for thought, I suggest that one or a combination of several of the following options might offer a way out. The common thread of all my suggestions is the attempt to address the core reasons for scepticism with regard to ISDS while not falling into the other extreme of by definition killing the instrument itself.

  1. The scope of ISDS should be limited to cases of denial of justice. If, for any reason, a company does not have access to the judicial system of a country, then it should be able to invoke the jurisdiction of an arbitral tribunal. In other words, if there a void, i.e. no jurisdiction to consider a case, there is no rule of law, and arbitration should be allowed. Denial of justice is the number one example of a breach of the obligation of ‘fair and equitable treatment’ in the CETA text. It is rightly so. The other types of breaches (manifest arbitrariness, targeted discrimination, etc.) can be dealt with by domestic courts.
  2. An argument invoked by proponents of ISDS is the length of judicial proceedings in EU Member States, with some founding member states being given as example. It is reasonable for any citizen or company to expect a fairly quick resolution of their case. Therefore, we could imagine an automatic right for an investor to trigger ISDS if its case has not reached the final level of jurisdiction within say 36 months from the date of the initial claim. This would create an incentive for legislators and judiciaries, too, to speed up judicial proceedings. I disagree with The Economist suggestion that firms should first ‘exhaust domestic legal remedies before arbitration can begin’ [6]. Arbitration should not become higher than the highest court of a democratic country. Once a final ruling has been achieved, that should be just that.
  3. In meetings with stakeholders representing the business world I have repeatedly heard the argument that ISDS will be more useful for SMEs than for large multinational companies, as the latter have resources, armies of lawyers and access to governments, so they can look after themselves. Well, then, let’s make ISDS available only for SMEs, the really potentially vulnerable companies. We would have to agree on a ceiling based on turnover and/or number of employees for eligibility for ISDS. This would remove the core suspicion that ISDS is an instrument in the hands of big business against civil society: let it make the weak stronger.
  4. A possible systemic solution is the one suggested by The Economist in its 11 October article ‘A better way to arbitrate’ [7]: turning ISDS into either a state-to-state mechanism, with the choice of arbiters by the states themselves. It would be even better if there could be permanent arbitral courts, to prevent charges ad-hoc-ness and allow for jurisprudence to accumulate. In the ‘state-to-state dispute settlement’, the state of the investor would take up the claim itself and would either represent it before the other state or subrogate into its right for the purpose of the case. After all, it is rights and obligations created by the treaty between the two states that are alleged to have been breached. The award or penalty would then need to be passed on to the investor, minus the charges involved. A softer version of ‘state-to-state’ is to still allow for investor-state-dispute, but with the consent of both governments, as provided by Article 11.16 of the Australia-US FTA. This would take the automaticity out of the process and would introduce a filter, basically requiring the consent of both governments before the arbitration process would start. When consent is given by both governments, most likely good faith prevails and the public interest is safeguarded, as no government would tell anyone ‘sue me’ if it did not believe it was right. ‘State-to-state’ has the advantage of more social control and more relative legitimacy, despite the lack of confidence in national politics mentioned earlier and arguably, a state is more likely not to pursue an abusive or partisan claim against another state than a corporation. In fact, this scenario would offer an answer to a question begged by the whole ISDS debate: why would states desist from pursuing their roles in defending their nationals, including companies? Why would they privatise that function? Aren’t they making their already serious social confidence problem worse?

Last but not least, an appellate body, modelled on the WTO, should be introduced in the ISDS architecture, for appeals on issues of law, composed of more – and more senior – arbitrators than the first layer of jurisdiction. Perhaps the seven-member Standing Appellate Body of the WTO itself could be used by for ISDS appeals, since it is there already and dispute settlement is viable pillar of the multilateral trading system. Perhaps this would require a strengthening of WTO Appellate Body, and generally the move would not harm the WTO, quite the contrary.

A combination of some all or all of the above may be envisaged, too. While for cases of denial of justice all investors should be eligible for ISDS, for the other cases SMEs could have an automatic right to ISDS, while large companies would need to go through local courts or, in the other scenario, have their case taken over by their government. This might also prove an incentive for companies to ‘stay home’ rather than wonder about in fiscal paradises.

Small companies have a much harder time to get their government’s (or the European Commission’s) attention than big corporations. It is difficult for them to make their voice heard in the host countries where they may invest. And the argument that classic litigation is expensive is much more serious for them than for multinationals. In terms of public concerns, small companies are much less likely to create suspicion with the public opinion in the host country that they would try to change public policies, or in any case that they would have the lobbying power to do so. A world of ISDS for SMEs is therefore a world where small players are empowered in relation to both governments and the big players, without threatening societal choices. Last but not least, SME claims are likely to be small in financial terms, so not a threat to the public purse.

Final remarks

I believe the importance of ISDS is blown out of proportion by its supporters, some of whom may suffer from a degree of strategic blindness: it is simply not going to be the end of the world if ISDS clauses are eliminated, circumscribed, remodelled or limited in scope as suggested above. On the contrary, it is a major strategic mistake to sacrifice carefully negotiated new generation trade agreements on the altar of ISDS, if public opinion does not accept it. It is a threat to the already frail legitimacy of trade negotiations and to the further economic integration of the Atlantic world that is simply not worth pursuing. Moreover, it is not so clear that non-Western countries with which we are or will be negotiating might not want ISDS if we do not have it as standard in intra-Western trade agreements. The unfamiliarity of 28 legal systems for companies from these countries might be a strong incentive for them to want ISDS. For example, there is evidence that China had a strong preference for ISDS in the FTA negotiation with Australia [8]. We should treat ISDS on its merits, in all negotiations, rather than using it for scare mongering.

 

Tweet about this on TwitterShare on Facebook0Share on Google+0Share on LinkedIn2
Author :
Print

Comments

  1. Hello
    We admire you for taking the first step in putting up your own business. We want to assist you in bringing your dream into fruition by providing you the low-interest business loan and other credit facilities that you need to expand or pay for the start-up expenses.

    Though there are many financing companies out there that refuse to provide start-up loans and other credit facilities with the belief that they are too risky. Our company is not one of them. We understand the importance of getting a business jumpstarted and are not afraid to be of assistance.

    We offer business loans, housing loans, bank guarantee, standby Letter of Credit; Letter of credits, Medium term notes, and so many others from AAA rated banks between US$100,000 – US$1 Billion at 3% minimal interest and leasing rates. We cover all your credit facilities needs and offer low interest rates and effortless payment plans.
    Other packages include long term project partnership funding, joint ventures partnership, investment funding, invention partnership funding, contract funding and other partnership funding for those that have good business plans and ongoing projects without enough money to finance or complete it.

    Our goal is to be able to help everyone as much as possible, regardless of what your credit report has to say. We didn’t establish our company to discriminate. Email us today and discuss with us to see the great deals we have to offer. We want your business to succeed just as much as you do. Let us assist you
    During our 12 years operation in financing we didn’t receive any negative feedback from our clients.

    If you’re looking for a loan that will fund the establishment or expansion of your own business, we are here to give it to you.
    Email: creditfacilitiesconsultant@gmail.com us today regarding questions you may have and discuss with us to see the great deals we have to offer. We want your business to succeed just as much as you do. Let us assist you. We look forward to serving you.

    I am waiting for your response.

    Best regards
    Michael
    Credit Facilities Consultant

  2. Pingback: pret ecograf
  3. Pingback: guitar picks
  4. Pingback: banheiras
  5. Pingback: guitar picks
  6. Pingback: yspro.ne.jp
  7. Pingback: groupon merchant
  8. Pingback: opensky
  9. Pingback: porno
  10. Pingback: weight programs
  11. Pingback: Agustin Cutler
  12. Pingback: Joi
  13. Pingback: Clair Carrasquillo
  14. Pingback: additional hints
  15. Pingback: ecograf 4D
  16. Pingback: Leaflet printing
  17. Pingback: medora centre
  18. Pingback: bikiniluxe reviews
  19. Pingback: Shekhanzai
  20. Pingback: stained concrete
  21. Pingback: roofing
  22. Pingback: roofing
  23. Pingback: roofing
  24. Pingback: puppy playpen
  25. Pingback: roofing
  26. Pingback: foundation repair
  27. Pingback: foundation repair
  28. Pingback: foundation repair
  29. Pingback: foundation repair
  30. Pingback: Hirelay technology
  31. Pingback: video competitions
  32. Pingback: email validation
  33. Pingback: short film
  34. Pingback: luvmehair
  35. Pingback: www.qddeji.com
  36. Pingback: 6 wheel truck
  37. Pingback: Carpet cleaners
  38. Pingback: happiness
  39. Pingback: Wilfred Destefano
  40. Pingback: Brandbanglaeshop
  41. Pingback: Employment law
  42. Pingback: online slots
  43. Pingback: Lorrine
  44. Pingback: High pr links
  45. Pingback: plumbing repair
  46. Pingback: proxyweb
  47. Pingback: ejakulasi dini
  48. Pingback: ejakulasi dini
  49. Pingback: Escort
  50. Pingback: Motion Effects
  51. Pingback: medical shuttle
  52. Pingback: doll
  53. Pingback: Learn More
  54. Pingback: Full Article
  55. Pingback: dog groomer
  56. Pingback: Peppa Pig
  57. Pingback: Discover More
  58. Pingback: word pornle store
  59. Pingback: Roberto
  60. Pingback: pillow
  61. Pingback: top th9 war base
  62. Pingback: Diet
  63. Pingback: development
  64. Pingback: digital display
  65. Pingback: Logo design sydney
  66. Pingback: blues chords
  67. Pingback: digital signs
  68. Pingback: sacred 3 trainer
  69. Pingback: Pest Control Perth
  70. Pingback: funny
  71. Pingback: poker
  72. Pingback: tattoo supplies
  73. Pingback: tattoo supplies
  74. Pingback: here
  75. Pingback: baby history
  76. Pingback: Austin Sunshades
  77. Pingback: plumbers Austin tx
  78. Pingback: boss
  79. Pingback: travr
  80. Pingback: travr
  81. Pingback: inspiration
  82. Pingback: Cancer
  83. Pingback: physiq vodka
  84. Pingback: iodine lugols
  85. Pingback: VigRX Plus
  86. Pingback: fifthavenue
  87. Pingback: window tint austin
  88. Pingback: Tampa Bail Bonds
  89. Pingback: tattoo supply
  90. Pingback: Top Hip Hop Music
  91. Pingback: reviewed
  92. Pingback: The Tai Lopez Show
  93. Pingback: coola kläder
  94. Pingback: Angeline
  95. Pingback: movietube
  96. Pingback: stlpiky
  97. Pingback: italian baby names
  98. Pingback: tenerife blog
  99. Pingback: cat transport
  100. Pingback: useful reference
  101. Pingback: Probiotic
  102. Pingback: movietube
  103. Pingback: sprei murah
  104. Pingback: leaflet printing
  105. Pingback: paper crafts
  106. Pingback: pull up banners
  107. Pingback: designer ring
  108. Pingback: ads
  109. Pingback: Probiotics
  110. Pingback: security camera
  111. Pingback: surveillance
  112. Pingback: security cameras
  113. Pingback: Coto Mold
  114. Pingback: automotive mold
  115. Pingback: Miss
  116. Pingback: Gartenfahnen
  117. Pingback: dog sitter
  118. Pingback: sell house fast
  119. Pingback: we buy houses
  120. Pingback: info
  121. Pingback: Car text check
  122. Pingback: man cave
  123. Pingback: robot reviews
  124. Pingback: Buy Isagenix
  125. Pingback: ebay affiliate
  126. Pingback: Quickbooks support
  127. Pingback: desktop vaporizer
  128. Pingback: pelangsing
  129. Pingback: judi casino 338a
  130. Pingback: Banheiras
  131. Pingback: YouTube
  132. Pingback: iqoption
  133. Pingback: rastafari
  134. Pingback: ChillOut music
  135. Pingback: free porn
  136. Pingback: more
  137. Pingback: Jeremy McGilvrey
  138. Pingback: Android Apps
  139. Pingback: agen judi bola
  140. Pingback: ways to make money
  141. Pingback: BNS Gold for sale
  142. Pingback: edm mix
  143. Pingback: ageless cream
  144. Pingback: best edm 2016
  145. Pingback: Surveys for Cash
  146. Pingback: love and life
  147. Pingback: hose Reel
  148. Pingback: weight loss
  149. Pingback: ESTELLE
  150. Pingback: chargers
  151. Pingback: cars
  152. Pingback: jim corbett park
  153. Pingback: Hanna
  154. Pingback: Travel guide blog
  155. Pingback: tulsa weed control
  156. Pingback: seo singapore
  157. Pingback: ollas rena ware
  158. Pingback: bulk text message
  159. Pingback: coldstore
  160. Pingback: highend romper
  161. Pingback: identity guard
  162. Pingback: Zootopia
  163. Pingback: serviporno
  164. Pingback: Cash 4 Clothes
  165. Pingback: terrible parking
  166. Pingback: fashion bracelet
  167. Pingback: jump manual
  168. Pingback: movies
  169. Pingback: games
  170. Pingback: kitchen items
  171. Pingback: Get your ex back
  172. Pingback: Venom
  173. Pingback: new
  174. Pingback: tenerife property
  175. Pingback: dog training dvd
  176. Pingback: SME bank loan
  177. Pingback: gap cover
  178. Pingback: la rehab centers
  179. Pingback: Chocolate
  180. Pingback: jelly swim
  181. Pingback: roof vents
  182. Pingback: Dianabol Cycle
  183. Pingback: dryer vent
  184. Pingback: d?i lý son dulux
  185. Pingback: mixed martial arts
  186. Pingback: Dorthea
  187. Pingback: web design company
  188. Pingback: 12win casino
  189. Pingback: 12 win
  190. Pingback: Thai Porn
  191. Pingback: Evonne
  192. Pingback: Thai Porn
  193. Pingback: Get the facts
  194. Pingback: check here
  195. Pingback: film gratuit
  196. Pingback: read more
  197. Pingback: loren weisman
  198. Pingback: party light kmart
  199. Pingback: solar related
  200. Pingback: Crazy Bulk Coupons
  201. Pingback: cat kennels naples
  202. Pingback: body goals
  203. Pingback: cooling
  204. Pingback: mobile strike hack
  205. Pingback: bucetas gostosas
  206. Pingback: bucetas lindas
  207. Pingback: starcom mediavest
  208. Pingback: Entrepreneur
  209. Pingback: Mentorship
  210. Pingback: Brooklyn Body Shop
  211. Pingback: Brooklyn Body Shop
  212. Pingback: Internet Marketing
  213. Pingback: tech news
  214. Pingback: exercise
  215. Pingback: prevent cancer
  216. Pingback: billig tannlege
  217. Pingback: Solar Panels
  218. Pingback: tannlege
  219. Pingback: FreeRushSale
  220. Pingback: hack howrse
  221. Pingback: Nootropic
  222. Pingback: bamboo sunglasses
  223. Pingback: pattaya thai
  224. Pingback: Online Retail
  225. Pingback: beachpcrepairs.com
  226. Pingback: Health Care
  227. Pingback: Hotel shah alam
  228. Pingback: oferta gratuita
  229. Pingback: trends
  230. Pingback: solar related
  231. Pingback: wood sunglasses
  232. Pingback: Customize A Vape
  233. Pingback: Buy Isagenix Cheap
  234. Pingback: Eat Clean
  235. Pingback: Gym Shorts
  236. Pingback: dinosaur game
  237. Pingback: ps4
  238. Pingback: buy apartment
  239. Pingback: Gun Shop
  240. Pingback: Gemstone Jewelry
  241. Pingback: share video
  242. Pingback: Excel Consultants
  243. Pingback: scalper ea
  244. Pingback: Qmee review
  245. Pingback: real estate
  246. Pingback: sloveniainvest
  247. Pingback: Teleteria
  248. Pingback: Lilla
  249. Pingback: hotels in jersey
  250. Pingback: Tulsa
  251. Pingback: Word Puzzles
  252. Pingback: Tulsa
  253. Pingback: SEO
  254. Pingback: See inside
  255. Pingback: spring-cleaning
  256. Pingback: Startups Funds
  257. Pingback: dog care naples fl
  258. Pingback: seo services
  259. Pingback: personal trainer
  260. Pingback: online casinos
  261. Pingback: Taste
  262. Pingback: titwala
  263. Pingback: porno
  264. Pingback: porno
  265. Pingback: g spot dildos
  266. Pingback: na chatroom
  267. Pingback: Swimming
  268. Pingback: porno
  269. Pingback: forex accurate
  270. Pingback: regal assets
  271. Pingback: porno
  272. Pingback: Douglas Cotter
  273. Pingback: pet care naples
  274. Pingback: All Area Over Head
  275. Pingback: taoofbadass
  276. Pingback: singorama.com
  277. Pingback: Singorama 2.0
  278. Pingback: Buy Forskolin Fuel
  279. Pingback: optimind
  280. Pingback: Doug Cotter
  281. Pingback: Cerchio nel grano
  282. Pingback: plant based diet
  283. Pingback: Smart Phones
  284. Pingback: cat sitter
  285. Pingback: this resource site
  286. Pingback: Chaga Mushroom
  287. Pingback: Cool T-Shirts
  288. Pingback: neuken
  289. Pingback: Sharjah
  290. Pingback: morningquotes.info
  291. Pingback: funny jokes
  292. Pingback: us proxies list
  293. Pingback: residual income
  294. Pingback: david wygant books
  295. Pingback: david wygant books
  296. Pingback: birthday quotes
  297. Pingback: porno
  298. Pingback: Full Article
  299. Pingback: Hertfordshire
  300. Pingback: Best Shaver
  301. Pingback: read more
  302. Pingback: fast cash loans
  303. Pingback: online marketing
  304. Pingback: house samples
  305. Pingback: free samples
  306. Pingback: ADO
  307. Pingback: music
  308. Pingback: seo Norge
  309. Pingback: loss
  310. Pingback: Mia Khalifa Wiki
  311. Pingback: psychic readings
  312. Pingback: koala shirts
  313. Pingback: porno
  314. Pingback: jet porn
  315. Pingback: www.leiyao.net
  316. Pingback: www.xhcheater.net
  317. Pingback: quotes and sayings
  318. Pingback: Beckett media
  319. Pingback: hitting drills
  320. Pingback: youtube.com
  321. Pingback: Positive Quotes
  322. Pingback: Tamesha
  323. Pingback: jar
  324. Pingback: easywomen
  325. Pingback: sydney realestate
  326. Pingback: brokenwaterheater
  327. Pingback: Swimming Goggles
  328. Pingback: sturdee residences
  329. Pingback: business listing
  330. Pingback: Positive Quotes
  331. Pingback: noanchor
  332. Pingback: TED technology
  333. Pingback: adult shop online
  334. Pingback: casinos
  335. Pingback: Grammarly Review
  336. Pingback: foro escorts
  337. Pingback: mobile website
  338. Pingback: thenextweb
  339. Pingback: nike
  340. Pingback: nyc movers
  341. Pingback: Foro mu online
  342. Pingback: vocation
  343. Pingback: welcome furniture
  344. Pingback: AC Compressor
  345. Pingback: SECRET SANTA GIFT
  346. Pingback: sleep aid
  347. Pingback: whitecapsfc
  348. Pingback: edarling
  349. Pingback: JD4D
  350. Pingback: permanent makeup
  351. Pingback: junk car Austin
  352. Pingback: instagram photos
  353. Pingback: online marketing
  354. Pingback: limo austin
  355. Pingback: NBA Online Stream
  356. Pingback: kenya scholarships
  357. Pingback: SEO in Norway
  358. Pingback: SEO expert
  359. Pingback: rialudi
  360. Pingback: crear app
  361. Pingback: www.china-eng.com
  362. Pingback: Paint party ideas
  363. Pingback: kids books
  364. Pingback: songwriting tips
  365. Pingback: clear bra straps
  366. Pingback: Religion
  367. Pingback: black hat tools
  368. Pingback: Corbin Maxwell
  369. Pingback: allandale plumber
  370. Pingback: Interjero dizainas
  371. Pingback: meniscus pain
  372. Pingback: Bedside Lamps
  373. Pingback: junk car austin
  374. Pingback: trap music
  375. Pingback: EPF UAN
  376. Pingback: SEO Sweden
  377. Pingback: Click This Link
  378. Pingback: LED Strip
  379. Pingback: cinemabox app
  380. Pingback: neo2 square
  381. Pingback: sildenafil citrate
  382. Pingback: Jobs
  383. Pingback: tin nguyen blog
  384. Pingback: stresser
  385. Pingback: Free WSET Course
  386. Pingback: Gadgets
  387. Pingback: tale Red Cap
  388. Pingback: Learn More
  389. Pingback: tannlege oslo
  390. Pingback: windows and doors
  391. Pingback: eventsheros.com
  392. Pingback: home air purifier
  393. Pingback: joshua menurunkan
  394. Pingback: printing
  395. Pingback: Massage Austin
  396. Pingback: Finger Family
  397. Pingback: Peppa Pig
  398. Pingback: ucuz elektrik
  399. Pingback: pswonline
  400. Pingback: Exfoliation
  401. Pingback: OnePlus 3 price
  402. Pingback: LiveStreamRugby
  403. Pingback: club flyer
  404. Pingback: finger family
  405. Pingback: day spa Austin
  406. Pingback: Kurma
  407. Pingback: acheter des likes
  408. Pingback: Save On Energy
  409. Pingback: nursery rhymes
  410. Pingback: SEO
  411. Pingback: internet business
  412. Pingback: film streaming
  413. Pingback: dlh
  414. Pingback: fornir
  415. Pingback: fuck google
  416. Pingback: fuck google
  417. Pingback: fuck google
  418. Pingback: fuck google
  419. Pingback: fuck google
  420. Pingback: fuck google
  421. Pingback: fuck google
  422. Pingback: pornolar
  423. Pingback: play doh
  424. Pingback: fake taxi
  425. Pingback: Body care
  426. Pingback: porno izle
  427. Pingback: ?????
  428. Pingback: Peppa pig
  429. Pingback: orzech amerykanski
  430. Pingback: ?????
  431. Pingback: Ruksis780
  432. Pingback: trigger warnings
  433. Pingback: Spongebob
  434. Pingback: Ripped Body Shape
  435. Pingback: Justcause3
  436. Pingback: Email Marketing
  437. Pingback: ?????
  438. Pingback: badoo app
  439. Pingback: kids videos
  440. Pingback: Click Here
  441. Pingback: vAuto Login
  442. Pingback: ?????
  443. Pingback: ?????
  444. Pingback: cedr dlh
  445. Pingback: ?????
  446. Pingback: Online Reviews
  447. Pingback: peppa pig
  448. Pingback: jeep
  449. Pingback: ??????
  450. Pingback: Diabetes Destroyer
  451. Pingback: podlogi drewniane
  452. Pingback: viagra
  453. Pingback: 10 mais
  454. Pingback: Secret
  455. Pingback: ??????
  456. Pingback: superheroes
  457. Pingback: GTE Login
  458. Pingback: kant�wka dlh
  459. Pingback: modrzew syberyjski
  460. Pingback: http://bestcoffeemakerwithgrinderreviews.com
  461. Pingback: Villalarm
  462. Pingback: Vietnam videos
  463. Pingback: 空中网充值
  464. Pingback: ???
  465. Pingback: skirts
  466. Pingback: Find a Tax CPA
  467. Pingback: samsonite carry on
  468. Pingback: android phone
  469. Pingback: crossfit vancouver
  470. Pingback: The Lost Ways
  471. Pingback: What is glucose
  472. Pingback: crear gmail
  473. Pingback: Melvin
  474. Pingback: Mendoza Car Rental
  475. Pingback: nursery rhymes
  476. Pingback: Fitness quotes
  477. Pingback: Facebook chat bot
  478. Pingback: t shirt bestellen
  479. Pingback: plr
  480. Pingback: fragrance
  481. Pingback: Peppa pig
  482. Pingback: ?????
  483. Pingback: Collins
  484. Pingback: web design
  485. Pingback: etax 2016
  486. Pingback: Indian Coffee
  487. Pingback: consultar pis 2016
  488. Pingback: agen casino sbobet
  489. Pingback: Ziplines
  490. Pingback: spam scammer
  491. Pingback: Google
  492. Pingback: Gordie Howe Jersey
  493. Pingback: vegan youtube
  494. Pingback: seo companies
  495. Pingback: roofing
  496. Pingback: click here
  497. Pingback: XOLO phones
  498. Pingback: free notes
  499. Pingback: izmir escort
  500. Pingback: izmir escort
  501. Pingback: car truck
  502. Pingback: masha and the bear
  503. Pingback: stihl fs45 coil
  504. Pingback: escort kad?köy
  505. Pingback: 健麗,
  506. Pingback: smoke control
  507. Pingback: hairloss
  508. Pingback: family toy
  509. Pingback: fakir selim
  510. Pingback: kids animation
  511. Pingback: Trade Shows
  512. Pingback: ?????
  513. Pingback: ?????
  514. Pingback: nursery rhymes
  515. Pingback: web design
  516. Pingback: WaterJet Mosaics
  517. Pingback: Detroit Lions Blog
  518. Pingback: watch doom
  519. Pingback: Free XXX Porn
  520. Pingback: Free XXX Porn
  521. Pingback: Latest Offer
  522. Pingback: porno
  523. Pingback: Interracial Porn
  524. Pingback: MILF Porn
  525. Pingback: uab ost express
  526. Pingback: Comcast
  527. Pingback: brazzers porno
  528. Pingback: brazzers porno
  529. Pingback: J.Cole Type Beat
  530. Pingback: Top 5
  531. Pingback: Xbox One
  532. Pingback: Teen XXX Porn
  533. Pingback: Free Amateur Porn
  534. Pingback: erotic stories
  535. Pingback: Anal Porn
  536. Pingback: ?????
  537. Pingback: Fetish Porn
  538. Pingback: copiers Austin
  539. Pingback: Hardcore Porn
  540. Pingback: Gay Porn
  541. Pingback: Shemale Porn
  542. Pingback: MILF Porn
  543. Pingback: Gay Lesbian Porn
  544. Pingback: Apple
  545. Pingback: Jayden Jaymes Porn
  546. Pingback: Cam Porn
  547. Pingback: kids songs
  548. Pingback: Brazzers Porn
  549. Pingback: finger family
  550. Pingback: Sara Jay XXX
  551. Pingback: Golf Balls
  552. Pingback: Bowling Store
  553. Pingback: ??
  554. Pingback: ???
  555. Pingback: sales crm
  556. Pingback: Peppa pig
  557. Pingback: peppa pig
  558. Pingback: roofing contractor
  559. Pingback: kids animation
  560. Pingback: Valeri
  561. Pingback: Colleen
  562. Pingback: AR10 kit
  563. Pingback: metin2 pvp
  564. Pingback: free porn videos
  565. Pingback: Cialis cena
  566. Pingback: craigslist pva
  567. Pingback: phenq review
  568. Pingback: qiu qiu
  569. Pingback: Rap
  570. Pingback: forina pure
  571. Pingback: poker capsa susun
  572. Pingback: teddies on sale
  573. Pingback: Levitra opinie
  574. Pingback: fast loans
  575. Pingback: MILF Porn
  576. Pingback: Kitchen Remodel
  577. Pingback: Carl Kruse Dot Org
  578. Pingback: chipmunks
  579. Pingback: Piece Of Heaven
  580. Pingback: Elaine
  581. Pingback: Jennine
  582. Pingback: 55prints
  583. Pingback: Eda
  584. Pingback: Jodoh
  585. Pingback: porno izle
  586. Pingback: Wood
  587. Pingback: Rashguard for Men
  588. Pingback: situs poker
  589. Pingback: siktir git
  590. Pingback: Minecraft Account
  591. Pingback: Discover
  592. Pingback: Gary Chambliss
  593. Pingback: Eachine
  594. Pingback: TWITCH
  595. Pingback: Top 10
  596. Pingback: sexy shoes
  597. Pingback: sikerler
  598. Pingback: kids animation
  599. Pingback: slimming program
  600. Pingback: Qiran
  601. Pingback: Top 10
  602. Pingback: xvideos gay
  603. Pingback: Carpet cleaning
  604. Pingback: Cogniflex
  605. Pingback: free naked cams
  606. Pingback: Leather whip
  607. Pingback: Clik Here
  608. Pingback: RRB Result 2016
  609. Pingback: Crazy sex toys
  610. Pingback: health information
  611. Pingback: Craigslist VIPN
  612. Pingback: teleteria
  613. Pingback: G-Spot Toy
  614. Pingback: da xuyen sang
  615. Pingback: Dentist
  616. Pingback: mp43gpfilm
  617. Pingback: branding
  618. Pingback: Preacher2016
  619. Pingback: peppa pig
  620. Pingback: lam nhôm
  621. Pingback: movie reviews
  622. Pingback: Engineer
  623. Pingback: legit opportunity
  624. Pingback: royalty free video
  625. Pingback: CFD
  626. Pingback: lakfagot
  627. Pingback: Adam & Eve
  628. Pingback: New pop artists
  629. Pingback: peppa pig
  630. Pingback: apartment movers
  631. Pingback: Serangoon Condo
  632. Pingback: Banheira Jacuzzi
  633. Pingback: domino poker
  634. Pingback: Christian Shirts
  635. Pingback: poker online
  636. Pingback: Dark
  637. Pingback: hd1080hdkinoonline
  638. Pingback: windows and doors
  639. Pingback: hairbond moulder
  640. Pingback: kids animation
  641. Pingback: Anal beads
  642. Pingback: ch?p?nhcu?ih?c?c
  643. Pingback: Managed ITService
  644. Pingback: star wars epic
  645. Pingback: Multi Mineral
  646. Pingback: childrens books
  647. Pingback: Ship to Malaysia
  648. Pingback: Best PC builder
  649. Pingback: ODYSSEYWARE Login
  650. Pingback: 10 mais
  651. Pingback: Mat-Su
  652. Pingback: crowdcube
  653. Pingback: picccc
  654. Pingback: marketplace
  655. Pingback: Peaky Blinders
  656. Pingback: car stereo
  657. Pingback: acheter des likes
  658. Pingback: dog groomer Austin
  659. Pingback: locksmith chandler
  660. Pingback: Gadget Magazine
  661. Pingback: that dentist
  662. Pingback: protection amulets
  663. Pingback: casino online top
  664. Pingback: Dating advice
  665. Pingback: situs poker online
  666. Pingback: mickey mouse
  667. Pingback: kids animation
  668. Pingback: LED PENDANT LIGHT
  669. Pingback: tech
  670. Pingback: MMG
  671. Pingback: paytren
  672. Pingback: Diet Pills 2016
  673. Pingback: Situs poker online
  674. Pingback: Diabetes destroyer
  675. Pingback: 10 más
  676. Pingback: text correction
  677. Pingback: Bun B Style Beat
  678. Pingback: phen375 reviews
  679. Pingback: legal steroids
  680. Pingback: sex shop
  681. Pingback: watercolor
  682. Pingback: Computer disposal
  683. Pingback: best fiverr gigs
  684. Pingback: recycling computer
  685. Pingback: acrylic paint set
  686. Pingback: spam
  687. Pingback: msphack.com.pl
  688. Pingback: kispiox river
  689. Pingback: interior design
  690. Pingback: sports betting
  691. Pingback: T.I. Type Beat
  692. Pingback: grout renew
  693. Pingback: onewaytickeeet
  694. Pingback: saleforiphone
  695. Pingback: Bathroom Tile
  696. Pingback: Damion
  697. Pingback: Audrea
  698. Pingback: Z-ABC-goods
  699. Pingback: Webcam
  700. Pingback: internet marketing
  701. Pingback: 健麗
  702. Pingback: xanex
  703. Pingback: dpserie streaming
  704. Pingback: Earrings
  705. Pingback: baltic siker
  706. Pingback: baltic siker oç
  707. Pingback: baltic sikerr
  708. Pingback: fruit diet
  709. Pingback: alibaba
  710. Pingback: poke recipe
  711. Pingback: lastmeamdyou
  712. Pingback: business coaching
  713. Pingback: situs poker online
  714. Pingback: kl food
  715. Pingback: last olipik game
  716. Pingback: phuket tours
  717. Pingback: outsource staffing
  718. Pingback: loan sharks
  719. Pingback: Wedding Tips
  720. Pingback: avocat permi
  721. Pingback: hunting crossbow
  722. Pingback: malls in tampa fl
  723. Pingback: sports betting
  724. Pingback: Baccarat Online
  725. Pingback: gameplays
  726. Pingback: irving taxi cab
  727. Pingback: madjax
  728. Pingback: stresser
  729. Pingback: bulk wholesale
  730. Pingback: Studio414 Contest
  731. Pingback: Riley
  732. Pingback: home security
  733. Pingback: Opciones Binarias
  734. Pingback: nylon moulding
  735. Pingback: Read This
  736. Pingback: Prefab Homes
  737. Pingback: world news
  738. Pingback: cheap seo plans
  739. Pingback: avocat permis
  740. Pingback: MASHA AND DORA
  741. Pingback: memory workshop
  742. Pingback: multifunctional
  743. Pingback: website designing
  744. Pingback: Fitness
  745. Pingback: circle lens
  746. Pingback: zip code
  747. Pingback: KNOW MORE
  748. Pingback: traders elite scam
  749. Pingback: upratovanie
  750. Pingback: This Site
  751. Pingback: brain smart
  752. Pingback: marvel avengers
  753. Pingback: MQTT
  754. Pingback: Cory Hughes
  755. Pingback: Firework insurance
  756. Pingback: 旅行
  757. Pingback: Diabetes Destroyer
  758. Pingback: business funding
  759. Pingback: second mortgages
  760. Pingback: family travel
  761. Pingback: Doba Reviews
  762. Pingback: private lenders
  763. Pingback: elo boosting
  764. Pingback: satta matka
  765. Pingback: helppsy
  766. Pingback: teint
  767. Pingback: Network Marketing
  768. Pingback: Intel PRO/1000 MT
  769. Pingback: vegas boom
  770. Pingback: SEO
  771. Pingback: weight loss
  772. Pingback: sabit kanca 2 izle
  773. Pingback: Nursery Rhymes
  774. Pingback: Find info kizi 2
  775. Pingback: free cash
  776. Pingback: taekwondo
  777. Pingback: Masha and Dora
  778. Pingback: accounting ottawa
  779. Pingback: learn to trade
  780. Pingback: online bookmakers
  781. Pingback: drones for sale
  782. Pingback: style
  783. Pingback: Que es fertilidad
  784. Pingback: elderly care
  785. Pingback: best anime moments
  786. Pingback: Kizi all free kizi
  787. Pingback: Friv
  788. Pingback: search engine tips
  789. Pingback: poker qq
  790. Pingback: poker qq
  791. Pingback: agen domino online
  792. Pingback: Agen casino online
  793. Pingback: lampamafussil
  794. Pingback: forest wood condo
  795. Pingback: Xero Help
  796. Pingback: cloud accountants
  797. Pingback: agen casino online
  798. Pingback: this hyperlink
  799. Pingback: pokemon go cheat
  800. Pingback: SEO
  801. Pingback: apple
  802. Pingback: Caaraklinikka
  803. Pingback: tahajjud
  804. Pingback: Narcos app
  805. Pingback: qiu qiu online
  806. Pingback: lastpuob
  807. Pingback: pornovisit
  808. Pingback: situs poker
  809. Pingback: escort bayan
  810. Pingback: awesomedia
  811. Pingback: scheduled delivery
  812. Pingback: eyemuff
  813. Pingback: agen poker online
  814. Pingback: pokerkiukiu
  815. Pingback: scottie swirv
  816. Pingback: agen casino online
  817. Pingback: domino qiu qiu
  818. Pingback: facebook marketing
  819. Pingback: San Diego Purchase
  820. Pingback: canada goose
  821. Pingback: iphonereparation
  822. Pingback: viagra for sale
  823. Pingback: awesomedia
  824. Pingback: Lucky Taxi Cab
  825. Pingback: PTC
  826. Pingback: steve rahseparian
  827. Pingback: buy proxy
  828. Pingback: kinoklub
  829. Pingback: electronica
  830. Pingback: business finance
  831. Pingback: coloring books
  832. Pingback: spa pia
  833. Pingback: volarex
  834. Pingback: Mollie
  835. Pingback: use this link
  836. Pingback: Baby Girl Rompers
  837. Pingback: evden eve nakliyat
  838. Pingback: Daftar poker
  839. Pingback: dreams
  840. Pingback: Sewa Bus
  841. Pingback: sprawdzenie vin
  842. Pingback: Tulsa Web Design
  843. Pingback: Dreamlife Beats
  844. Pingback: there
  845. Pingback: kursi kantor
  846. Pingback: tattoo shop
  847. Pingback: Royal Las Vegas
  848. Pingback: slots casino
  849. Pingback: All Slot Casino
  850. Pingback: Wild Jackpots
  851. Pingback: Australia Casino
  852. Pingback: Voice
  853. Pingback: generic viagra
  854. Pingback: USB
  855. Pingback: Prostate health
  856. Pingback: Zügelfirma
  857. Pingback: zollar
  858. Pingback: porno
  859. Pingback: Billboard Top 20
  860. Pingback: guard card online
  861. Pingback: drama2016
  862. Pingback: POH
  863. Pingback: Zlog
  864. Pingback: debit card
  865. Pingback: Tulsa IT Company
  866. Pingback: Bail Bond
  867. Pingback: steven rahseparian
  868. Pingback: quotes
  869. Pingback: Australia Day 2017
  870. Pingback: additional info
  871. Pingback: click reference
  872. Pingback: toys
  873. Pingback: avery cd label
  874. Pingback: tablic online
  875. Pingback: Paya Lebar Quarter
  876. Pingback: photo booth rental
  877. Pingback: sword art online
  878. Pingback: OUE Twin Peaks
  879. Pingback: Sprinkler System
  880. Pingback: messi
  881. Pingback: free jvzoo
  882. Pingback: Fulcrum
  883. Pingback: barcelona
  884. Pingback: capsa susun
  885. Pingback: Forest woods
  886. Pingback: OUE Twin Peaks
  887. Pingback: mr. bean
  888. Pingback: Merrill Edge Login
  889. Pingback: Tienda de magia
  890. Pingback: Live Mail Login
  891. Pingback: noni saft wirkung
  892. Pingback: jpmsru
  893. Pingback: youporn
  894. Pingback: sucker for pain
  895. Pingback: travis morris dui
  896. Pingback: guillaume guersan

Comments are closed.