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Amicus Curiae participation in domestic court cases is well developed in Common law countries and especially in U.S. jurisprudence. It is important to note that civil law jurisdictions do not have a tradition in using such an instrument and its introduction is mostly recent. Amicus intervention is usually not limited to any one particular kind of group and has frequently involved a range of participants, including individuals and foreign governments. Recently, this practice has been introduced in front of arbitral tribunals which have strongly advocated the participation of non-disputing parties as Amicus Curiae in such proceedings in order to ensure more transparency and public participation specifically in matters of investment arbitration.