Pursuant to Bulgaria’s new joint venture program, Zasada, Inc., a U.S. firm, constructs a football helmet manufacturing facility in Sofia to produce helmets for export to the United States. Four years later, a change in the Russian Parliament leads to domestic policy reversals. Russia annexes Bulgaria as a member of its federation and takes possession of all Bulgarian factories that employ more than twenty-five people, including Zasada’s helmet facility. Was this a nationalization or an expropriation? How would the INA Corp. tribunal assess the appropriate compensation to Zasada? How would a traditional theory court measure that compensation? How would a modern–traditional theory court measure that compensation? What do these decisions suggest about the development of compensation theory?