KMIC was subsequently incorporated and on 6 October 2003 IPOC notified the KFG companies of its intention to assign its rights and E obligations under the transfer agreement to KMIC. Unknown to the KFG companies, by a written agreement dated 1 October 2003 between IPOC and Fellowes, Fellowes agreed to purchase from IPOC 100% of its shares in KMIC conditionally upon the completion of the transfer agreement. That agreement was also governed by English law, with provision for arbitration in London under UNCITRAL Rules. IPOC then assigned its interest in BITEL under the transfer agreement to KMIC on