write me the memorandum in support of the claimant\’s position following by the problem below.
The problem:
The problem involves a controversy arising out of an international sale of goods. The controversy is before an arbitral tribunal pursuant to the JAMS International Arbitration Rules. The parties have agreed that the arbitration will be held in Vindobona, Danubia. Danubia has enacted the UNCITRAL Model Law on International Commercial Arbitration (Model Law). Danubia, Equatoriana, and Mediterraneo, the three states that are involved are party to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York Convention).
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