It has been remarked as early as 1991 that texts of international investment agreements (IIAs) differ in many important respects … however, they are also remarkably similar in structure and content – which means that tribunals may work to create a common law of investment protection, with a substantially shared understanding of its general tents. [Asian Agricultural Products Ltd v. the Republic of Sri Lanka, ICSID Case No. ARB/87/3] This substantially shared understanding may of course be jointly distributed among different states who in turn act through multiple ad-hoc tribunals. The multiplicity of tribunals naturally multiplies the number of decision-makers and creates more fragmentation.