If it was simply a question of allowing us to deal with issues which were in the wrong place, I really wouldn't be troubling the Tribunal with this. Recognising that it is highly undesirable to argue these things out on essentially an interlocutory stage, our position is that, in relation to matters which are in the statement of claim, we will deal with them. We are proceeding on the basis that all material facts and matters on which the claimant relies in support of their claim are in the statement of claim.