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a. Whether the Claimant has fulfilled its obligations prescribed by the Definitive Agreements, as required by Article 243(2) of the Federal Law No. 5 of 1985 on the Civil Transactions Law of the United Arab Emirates as amended by Federal Law No. (1) of 1987 (the “UAE Civil Transactions Law”)?

b. Whether the Memorandum of Understanding (the “MoU”) was discharged by performance as per Article 8 (3) of the Cooperation Agreement when the parties executed the Cooperation Agreement, the Revenue Sharing Agreement and the Side Shareholder Agreement?

c. Whether the MoU was novated/superseded once the Definitive Agreements were executed?

d. Whether the Defendant is in breach of its contractual obligations as per the signed agreements, in accordance with Article 243(2) of the UAE Civil Transactions Law?

e. Whether the Claimant is entitled to refund of an amount of AED 700 from the Defendant due to the reason that the Defendant is in breach of the agreements in accordance with Article 274 of the UAE Civil Transactions Law?

f. Whether the MoU is a binding Agreement between the parties?

g. Whether as per the MoU achieving the target of AED 30 million in the first year is the main purpose of the business relationship between the parties?

h. Whether the achieving of AED 30 million is a binding obligation upon both parties?

i. Whether the MoU cast a binding obligation upon the Defendant to ensure that Claimant achieved the target of AED 30 million in the very first year?

j. If not, whether the MoU imposed any penalties of the Defendant for breaching such a binding obligation?

k. Was the MoU discharged by performance when the parties executed Definitive Agreements?

l. Whether the contractual relationship between the Defendant and the Claimant was governed by MoU?

m. Was MoU novated/superseded by the Definitive Agreements?

n. Whether the contractual relationship between the Defendant and the Claimant was governed by the Definitive Agreements?

o. If not, what was the purpose of the Definitive Agreements?

p. Whether the Claimant is in breach of the Revenue Sharing Agreement, the Side Shareholder Agreement, and the Cooperation Agreement?

q. Whether the Defendant acted as a sponsor and provided the necessary services as contemplated in the Definitive Agreements?

r. Whether the provisions of the Definitive Agreements cast a binding obligation upon the Defendant to ensure that the Claimant achieved the target of AED 30 million in the very first year?

s. In the absence of any such binding provision, whether the Claimant sought for any express undertaking from the Defendant guaranteeing the target of AED 30 million in the first year?

t. Whether the Claimant was entitled to withhold its third instalment and seek refund of all the amount paid by it if the Claimant was unable to achieve the target of AED 30 million in the very first year?

u. Whether the Claimant has conceded that it was introduced by the Defendant to new business partners, thereby contradicting its entire case?

v. Whether the Defendant’s right to receive the Annual Fee was contingent upon meeting the Target?

w. Does the non-renewal of the Agreements amount to forfeiture of the Annual Fee for the period the Agreements were in subsistence?

x. Whether the Claimant has admitted its liability to pay a sum of AED 500,000 to the Defendant vide its email dated 2 September 2019?

y. Whether the Defendant is entitled to payment of a sum of AED 500,000 from the Claimant which is the third and final tranche of the Annual Fee as per the Cooperation Agreement, the Revenue Sharing Agreement and the Side Shareholder Agreement entered into between the parties, in addition to the interest on such amounts?

z. Whether the Defendant is entitled to payment of a sum of AED 700 from the Claimant, which is 5% of the revenue generated from the Kings School project, as per the Revenue Sharing Agreement and the Cooperation Agreement, in addition to the interest on such amount?

aa. Whether the Claimant has generated any other income from other projects based on introductions made by the Defendant in the UAE that will make it liable to contribute 5% percent of its income from such projects to the Defendant?

bb. Whether the Claimant can raise new contentions in its Reply that it had not raise earlier in its Claim Form and Particulars of Claim without amending its Claim Form and Particulars of Claim?

cc. Whether the Claimant can seek a remedy regarding specific performance of the MoU without having prayed so in the Claim Form or Particulars of the Claim?