The three defendants to the Cayman enforcement proceedings (the " MP Funds ") were private investment funds specialising in distressed investing. In 2005, the MP Funds were ultimate shareholders in an SPV that acquired Varig Logistica SA (" Varilog "), which operated a Brazilian aviation business. Varilog and its parent, Volo dB, purchased a passenger airline business through an SPV named VRG Linhas Aereas SA (" VRG "). In 2007, VRG was sold to another company, GTI SA (" GTI "). The parties to the Share Purchase and Sale Agreement (the " PSA ") were Varilog and Volo dB as sellers and GTI as purchaser. The PSA included an arbitration clause pursuant to which the parties to the PSA agreed to submit disputes to arbitration seated in São Paulo, Brazil.