Acórdão do FIFA
Processo Aguilar Vargas_2023-08-31

Data
31/08/2023

Labour Disputes


Texto da decisão

REF. FPSD-9598

Decision of the
Dispute Resolution Chamber
passed on 31 August 2023
regarding an employment-related dispute concerning
the player Elias Fernando Aguilar Vargas

COMPOSITION:
Lívia SILVA KÄGI (Brazil & Switzerland), Deputy Chairwoman
Stijn BOEYKENS (Belgium), member
Calum BEATTIE (Scotland), member

CLAIMANT:
Elias Fernando Aguilar Vargas, Costa Rica
Represented by Rafael Meirelles Gomes Ávila Advocacia

RESPONDENT:
Changchun Yatai FC, China PR
Represented by Ruiz-Huerta & Crespo Abogados

pg. 2

REF. FPSD-9598

I. Facts of the case
1.

The parties to the present case are:
-

2.

The player from Costa Rica, Elias Fernando Aguilar Vargas (hereinafter: the player or
the Claimant); and
the club from China PR, Changchun Yatai FC (hereinafter: the club or the
Respondent).

On 22 September 2022, the Chinese agent, Mr Li Feng (hereinafter: the Chinese agent),
sent the following letter of proposal (hereinafter: the proposal) to the agent of the Claimant
(hereinafter: the player’s agent):
“LETTER OF PROPOSAL
SUBJECT: TRANSFER OF PLAYER
Professional football player Mr. Elias Fernando Aguilar Vargas (born in 7 of November
1991) with passport number of […]
Dear Sir,
We, Changchun Yatai FC, Chinese Super League, would like to inform you that we are
interesting in you for negotiation and employment contract for 2023 season and
future.
We appreciate your time and concern and hope to see you soon.
Best Regards,
CHANGCHUN YANTAI FOOTBALL CLUB
SPORT DIRECTOR: MR. JIANG YONG [Signature]”

3.

It is to be noted that the specimen of the proposal provided by the player in these
proceedings is allegedly signed by Mr. Jiang Yong and the player, however, it did not contain
any designated space for the player’s signature or expression of acceptance.

4.

On 13 October 2022, the Chinese agent sent the player’s agent an offer (hereinafter: the
offer). It is to be noted that the club disputes that the offer was sent to the player with the
club’s consent.

5.

The offer contained the following information (quoted verbatim):
“To: Mr. Elias Fernando Aguilar Vargas (Professional Football player, Date of Birth:
November 7, 1991)
Dear Sir,

pg. 3

REF. FPSD-9598

Greeting from Changchun Yatai FC – Chinese Football Club, we are interested to sign
a contract with professional football player Elias Fernando Aguilar Vargas, under the
following conditions.
1. Term: Two years contract options from 2023.
2. Salary: The annual salary is 1,100,000.00 euro net (one million and one hundred
thousand euros net).
3. Bonuses: win match: 3000 USD net, draw match: 1000 USD net (depends on the
player’s performance time).
4. The club provides an apartment, a car, and 4 (four) business class air tickets
between Costa Rica and China.
5. If the club is qualified to participate in the Asian Champion League during the
player’s service, the additional bonus will be 100,000.00 USD.
6. The other conditions and main details will be specified at Employment Contract,
which should be signed after the player passer the Medical Exam.
We hope that this will be a start of a good business relationship between us. Thank
you in advance and we look forward to hearing you soon […]”
6.

It is to be noted that the specimen of the offer provided by the player is allegedly signed by
“the President” and the player but it does not contain the name of “the president” and any
designated space for the player’s signature or expression of acceptance.

7.

On 26 January 2023, the Player was issued a Chinese visa.

8.

On 16 February 2023, the Chinese agent sent a letter dated 15 January 2023, informing the
player’s agent of the following:
“[…]
Changchun Yatai Football Club once sent you an Offer in interesting for 2023 season
on October 13, 2022 year. However, in view of the fact that the foreign player transfer
window of China Football association in 2023 year has not been opened yet, and the
reasons of our club’s own financial budget, we are sorry to inform you that we cannot
provide you with a work contract in the spring of 2023 season. At the same time, we
announce that the Offer previously sent to you is invalid officially.
[…]”

9.

Between 22 September 2022 and February 2023, the player’s agent and the Chinese agent
held communications via the application WeChat, in which both parties discussed, inter
alia, the following:
-

The conditions of a possible contract for the player and the club.

-

The player’s agent requested to close the pre-contract for the player.

pg. 4

REF. FPSD-9598

-

The player’s agent indicated: “I process in advance the visa for be safe” and a copy
of the player’s visa was added.

-

The proposal dated 22 September 2022 and the offer dated 13 October 2022 were
sent via this channel.

-

On 23 November 2022 the Chinese agent and the player’s agent held the following
discussions (quoted verbatim):
“Chinese agent: hi my friend, how are you? Are you in Qatar? only one thing
tell you, the Sergio in Yatai very good play and many goals. he agreed to less
salary to 1.1 M net USD. club agreed renew contract. your player need find new
team for him. and we need one good defender, free. salary about 1 M. if you
have please send to me please.
Player’s agent: I'm good ... now im in brazil ... how I gonna find new club now
impossible.. I alredy say not to incheon united fc he have before 2 years offer
made new contract ... I say no because we done the deal with Yatai ...
How now I gonna find new club for he
I stop work of he and ignore many clubs in korean one in Japan also
Chinese agent: sorry. because our coach strong want renew Sergio. very
difficult change his mind
Player’s agent: Please exchange his mind because Aguilar it's big player and
he alredy also give up many thing to go to china […]”

-

The player’s agent asked the Chinese agent various times to send over the player’s
contract.

-

The player’s agent sent a print screen of the website transfermarkt in which the
player is affiliated to the Club, however, the Chinese agent indicated that this was
not true.

-

The player’s agent insisted various times to find a solution for the player.

-

The letter dated 15 January 2023 and sent on 16 February 2023 was sent via this
channel.

10. On 25 February 2023, the Claimant sent a “legal notice” to the Respondent requesting the
latter to re-establish the Claimant’s employment relationship immediately or pay the entire

pg. 5

REF. FPSD-9598

value of the offer (EUR 2,200,000). The Claimant granted 15-day to the club to provide with
its reply and in case of no reply, the Claimant will charge the Respondent for the unilateral
and unjustified termination of the contract.
11. On 3 April 2023, the Claimant signed a new contract with the Costa Rican club Randall
Castro Bolaños, valid from 1 June 2023 until 31 December 2023 with a monthly
remuneration of CRC 1,000,000.

II. Proceedings before FIFA
12. On 14 March 2023, the Claimant filed the claim at hand before FIFA. A brief summary of
the position of the parties is detailed in continuation.
a. Position of the Claimant
13. In his claim, the player claimed having concluded with the club a valid employment
contract, indicating that “despite the fact that the contract has not been signed, the
requirements and characteristics of the employment relationship are duly proven through the
evidence that instructs this claim, that there is documentation signed by both parties and also
an unreasonable dismissal formalized by the RESPONDENT”. Therefore, in accordance with
the Claimant there was an employment relationship.
14. Despite his warning sent by the player, the Respondent did not reply to the Player following
its default notice, thus this represented a breach of the contract, and he should be entitled
to compensation in accordance with art. 17 of the Regulations on the Status and Transfer
of Players (RSTP).
15. In view of the foregoing the Claimant requested the following relief (quoted verbatim):
1. “Condemn the RESPONDENT to pay the amount of EUR 2,200,000 (TWO MILLION, TWO
HUNDRED THOUSAND EUROS), which represents the exact terms of the negotiation
agreed between the parties (Exhibit no. 3) and which were not complied with by the
RESPONDENT.
2. Condemn the RESPONDENT to pay default interest at the rate of 5% p.a. on the
amount due.
3. In case of an attempt to reach an agreement, the CLAIMANT offers EUR 2,000,000 (two
million Euros) to finalize the claim, which can be transferred to the CLAIMANTS's
account according to the “bank account registration form”. “
b. Position of the Respondent
16. On 12 April 2023, the Respondent filed its reply to the claim of the player.

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REF. FPSD-9598

17. In doing so, the Respondent argued that the letters sent on behalf of the club were sent by
the Chinese agent who acted without the authorisation of club. The Chinese agent was not
authorised by the club to negotiate with the player nor the player’s agent. The Respondent
clarified that the Chinese agent was not the president of the club, and the offer was signed
by him as the president of the club. Therefore, according to Swiss law, such offer, without
establishing whether it is contract or not, should not have any legal effect on the
Respondent and there should not be any rights/obligations accruing to the Respondent.
18. Moreover, the club manifested that it was informed of the letters sent by the Chinese
agent, when it received the claim from FIFA.
19. The Respondent further argued that it was the player’s agent that was giving all the
conditions in accordance with the communications held between the player’s agent and
the Chinese agent via the application WeChat. From those communications the
Respondent concluded that “the whole time, it was the Player’s agent giving all the conditions,
the Chinese agent never said anything about the Club’s opinion on this. secondly, it is more like
a show pulled together only by the Player’s agent. He listed all the conditions he wanted for the
Player, then he asked the Chinese agent just to copy and paste for him. This is not the usual and
normal way of negotiating a contract with the club. The whole process, the Club was not even
seen anywhere in the conversation”.
20. Additionally, in the Respondent’s view “it is the Player’s burden of proof to demonstrate that
he had the reason to believe the Club ratified such Contract Offer, given the fact that it was so
obvious and suspicious that the Chinese agent he talked to was not even the president nor the
sports director but could sign on behalf of the Club under these titles”.
21. With regards to the visa, the Respondent stated that the player got the visa without the
support Respondent and that it was managed by the player’s agent, to support this
statement the Respondent provided with the communications held between the player’s
agent and the Chinese agent via the application WeChat.
22. As to the offer, the Respondent stated that the head letter was not from the club but
downloaded online.
23. The Respondent further argued that in case the offer is effective on the club, such offer is
not a contract. In doing so, the Respondent explained the following:
-

As per the tittle, it was an offer.

-

There was an intention to conclude an official contract and referred to the wording
of the offer “[…] we are interested to sign a contract”.

-

The terms of the offer were not definite nor clear, the offer just established that it

pg. 7

REF. FPSD-9598

would be a “two years contract options from 2023”, but there was not a start/end
day.
-

The other conditions and main details would be specified in the employment
contract, which should be signed after the player pass the medical exam.

-

The player’s agent was aware that it was a pre-contract and referred to the wechat
communications.

-

The offer did not include any signature from a higher representative nor the stamp
of the club.

24. In view of the above the contract did not contain all essentialia negotti and cannot be
considered as a valid and binding document.
25. As to the damages deriving from the pre-contract, the Respondent stated that it should
bear zero compensation since it never acted in bad faith nor breached its obligation, as it
was represented unauthorized by the Chinese agent.
26. The Respondent further argued that if the offer is considered as a contract, the
compensation shall be deducted due to the player’s behaviour who did not raise any
question over the signature of both letters and did not accept any offer from other Chinese
or Korean clubs. According to the Respondent, in accordance with Swiss law, he had the
obligation to mitigate his damages. Additionally, the Respondent referred that the contract
never started, and therefore, the compensation shall be reduced.
27. The Respondent requested the following relief:
“a. To dismiss the claim lodged by the Claimant as groundless;
b. To determine that there was no employment contract between the parties.
c. The Club doesn’t need to be responsible for the unauthorized act of the agent,
therefore the Club doesn’t need to pay any compensation to the Player.
d. Award any and all costs, expenses and fees arising in connection with the present
arbitration proceedings, including but not limited to the attorney’s fees of the First
Respondent against the Appellant.
Alternatively,
1. To determine that the Contract Offer is nothing but a pre-contract.
2. The Club doesn’t need to pay any compensation to the Player, as no obligation under
such pre-contract is breached.
3. Award any and all costs, expenses and fees arising in connection with the present
arbitration proceedings, including but not limited to the attorney’s fees of the First
Respondent against the Appellant.
Alternatively,

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REF. FPSD-9598

1. Even if the Contract Offer should be considered as a Contract between the Club and
the Player, the compensation should be reduced to less than one third of the whole
contract value because of the Player’s contributory fault and the relationship never
starts.
2. Any mitigated compensation under the new contract before the decision is issued
should be reduced as well”.
c. Additional documentation and comments of the parties
28. On 3 May 2023, the FIFA general secretariat informed the parties that the submissionphase in the case at hand was closed, hence they would no longer be able to supplement
or amend their submissions or requests for relief or produce new evidence (cf. art. 23, par.
1 of the Procedural Rules Governing the Football Tribunal (hereinafter: the Procedural
Rules).
29. On 10 May 2023, the Claimant submitted additional comments with regards to the
response of the Respondent. The Claimant stated that due to the new facts alleged by the
Respondent, he should be entitled to reply as those facts, according to him are false, and
in case the Claimant would not entitle to provide with his position as to the new facts, there
would be a damage to the due process of law.
According to the Claimant, the offer was sent by Zeng Jiaogfeng, who qualified as legal
representative. Moreover, the Claimant challenged the fact that the Respondent did not
provide articles of Incorporation and the Bylaws and only relied on the information of
transfermarkt website.
Additionally, the Claimant indicated that the legal representative of the club is also
representing Mr Li Feng, the Chinese agent and that the mentioned legal representative
offered the Claimant, EUR 200,000.
Moreover, the Claimant stated that the player’s agent never acted to harm the Claimant,
who carried out numerous other deals with the Respondent and in all negotiations, it was
the Chinese agent that represented the Respondent and in some of these meetings the
Chinese agent was accompanied by the Executive Director, Mr. Zeng Jiaogfeng, however,
always saw in the Chinese agent the club manager. It was always the Chinese agent who
acted and spoke for the Respondent in all negotiations intermediated by the club.
30. On 11 May 2023, the Respondent stated that the submission phase was closed, and the
documentation provided by the Claimant shall not be admitted. Otherwise, the
Respondent should be given a chance to comment on that documentation.
31. On 15 June 2023, the FIFA general secretariat acknowledged receipt of the Claimant’ latest
submissions and confirmed that the submission-phase of the case at hand was already

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REF. FPSD-9598

closed; and it will be up to the relevant chamber of the Football Tribunal to accept or not
any unsolicited correspondence (cf. art. 23, par. 1 of the Procedural Rules).
32. On 20 June 2023, the Claimant stated that it was possible to verify a criminal scheme that
existed between the Respondent and the Chinese agent, which aimed to harm athletes so
that the Respondent can benefit in its negotiations. The Claimant informed that he
reported this to the Chinese Police Authorities, FIFA Ethics Committee and FIFA Disciplinary
Committee.
33. On 10 August 2023, the Respondent submitted an unsolicited correspondence in which it
provided additional information/comments as to the new information provided by the
player on 10 May 2023 and 20 June 2023.
34. On 21 August 2023, the FIFA general secretariat acknowledged receipt of the Respondent’
latest submissions and confirmed that the submission-phase of the case at hand was
already closed; and it will be up to the relevant chamber of the Football Tribunal to accept
or not any unsolicited correspondence (cf. art. 23, par. 1 of the Procedural Rules).
35. On 21 August 2023, the Claimant indicated that he agreed to consider the letter sent by the
Respondent and to be considered in the decision on 31 August 2023.
36. On 24 August 2023, the FIFA general secretariat recalled the parties that the submission
phase was closed and requested them to refrain from sending any further
correspondence.

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REF. FPSD-9598

III. Considerations of the Dispute Resolution Chamber
a. Competence and applicable legal framework
37. First of all, the Dispute Resolution Chamber (hereinafter also referred to as Chamber or
DRC) analysed whether it was competent to deal with the case at hand. In this respect, it
took note that the present matter was presented to FIFA on 14 March 2023 and submitted
for decision on 31 August 2023. Taking into account the wording of art. 34 of the March
2023 edition of the Procedural Rules, the aforementioned edition of the Procedural Rules
is applicable to the matter at hand.
38. Subsequently, the members of the Chamber referred to art. 2 par. 1 of the Procedural Rules
and observed that in accordance with art. 23 par. 1 in combination with art. 22 par. 1 lit. b)
of the RSTP (May 2023 edition), the Dispute Resolution Chamber is competent to deal with
the matter at stake, which concerns an employment-related dispute with an international
dimension between a player from Costa Rica and a club from China PR.
39. Subsequently, the Chamber analysed which regulations should be applicable as to the
substance of the matter. In this respect, it confirmed that, in accordance with art. 26 par. 1
and 2 of the RSTP (May 2023 edition) and considering that the present claim was lodged on
14 March 2023, the October 2022 edition of said regulations (hereinafter: the Regulations)
is applicable to the matter at hand as to the substance.
40. For the sake of completeness, the Chamber recalled that: (i) parties to the proceedings are
not authorised to supplement or amend their submissions or requests for relief or produce
new evidence once the submission phase is closed (cf. art. 23, par. 1 of the Procedural
Rules); (i) any supplementary information and/or documentation shall only be accepted if
requested by the FIFA general secretary in the course of the proceedings (cf. art. 23, par. 2
of the Procedural Rules); and (iii) submissions received outside the time lime were not
taken into account (cf. art. 11, par. 4 of the Procedural Rules. Consequently, the DRC
confirmed that the Claimant’s and Respondent’s correspondences sent after the closure of
the submission phase on 3 May 2023 were inadmissible, hence disregarded.
41. Finally, the Chamber remarked that the Respondent referred in its submissions that Swiss
law as applicable as to the substance. In this respect, the Chamber wished to recall that
when deciding a dispute before the Dispute Resolution Chamber, FIFA’s regulations prevail
over any national law that the parties might have chosen. In this regard, the Chamber
emphasised that the main objective of the FIFA regulations is to create a standard set of
rules to which all the actors within the football community are subject to and can rely on.
This objective would not be achievable if the Chamber would have to apply the national
law of a specific party on every dispute brought to it. By the same token, the Chamber
wished to point out that it is in the interest of football that the cases are based on uniform
criteria rather than on provisions of national law that may vary considerable from country

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REF. FPSD-9598

to country. Therefore, the Chamber deemed that it is not appropriate to apply the
principles of a particular national law but rather the Regulations, general principles of law
and, where existing, the Chamber’s well-established jurisprudence.
b. Burden of proof
42. The Chamber recalled the basic principle of burden of proof, as stipulated in art. 13
par. 5 of the Procedural Rules, according to which a party claiming a right on the basis of
an alleged fact shall carry the respective burden of proof. Likewise, the Chamber stressed
the wording of art. 13 par. 4 of the Procedural Rules, pursuant to which it may consider
evidence not filed by the parties, including without limitation the evidence generated by or
within the Transfer Matching System (TMS).
c. Merits of the dispute
43. The competence and the applicable regulations having been established; the Chamber
entered into the merits of the dispute. In this respect, the Chamber started by
acknowledging all the above-mentioned facts as well as the arguments and the
documentation on file. However, the Chamber emphasised that in the following
considerations it will refer only to the facts, arguments, and documentary evidence, which
it considered pertinent for the assessment of the matter at hand.
i. Main legal discussion and considerations
44. The foregoing having been established, the Chamber moved to the substance of the
matter, and took note of the fact that this is a claim of a player against a club for alleged
non-performance of a contract by the club.
45. In brief, while the player claimed that he had a valid and binding contract with the club,
consisting of the offer sent by the Chinese agent, the club stated that (i) the documents
sent by the Chinese agent such as the proposal and the offer, were sent without any
consent of the club and that the Chinese agent did not have any power to act on its behalf
regarding the negotiations of the possible employment relationship between the player
and the club; and (ii) the offer clearly indicated that it was not to be considered as a contract
and that an employment contract was never signed by the parties.
46. Thus, the Chamber acknowledged that its task was to determine the following:
a) Were the parties bound by a contractual relationship in connection with the offer
allegedly sent by the club? and
b) Was the Chinese agent acting on behalf of the club?
c) What are the consequences that follow?

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REF. FPSD-9598

Were the parties bound by a contractual relationship in connection with the offer
allegedly sent by the club?
47. The Chamber started by recalling its well-established jurisprudence which dictates that, in
order for an employment contract to be considered as valid and binding, apart from the
signature of both the employer and the employee (or the corresponding proof of consent
of both parties), it should contain the essentialia negotii of an employment contract, such
as the parties to the contract and their role, the duration of the employment relationship
and the remuneration payable by the employer to the employee.
48. From the arguments of the parties and the documentation on file, the Chamber was able
to establish that:
-

In accordance with the wording of the offer it appears to be a unilateral offer.

-

The offer was signed by the “president”, but no name was specified on it.

-

The offer explicitly mentioned that further conditions would be specified in the
contract.

-

The offer did not contain any designated space for the player’s signature or
expression of acceptance.

-

The offer did not include a specific start/end date of the contractual relationship.

-

The letter of 15 January 2023 allegedly sent by club withdrawing the offer was also
signed by the “president”, but no name was indicated.

-

There was no other evidence that the parties indeed agreed on a contract and thus
a contract never started being executed.

49. Considering the above, the Chamber concurred with the Club’s argumentation and
considered that the disputed document was not meant to be a bilateral document (i.e., an
employment contract), but solely a unilateral offer to the player.
50. The Chamber also found it noteworthy that the player did not provide any evidence capable
of demonstrating that any other document was ever concluded between the parties with a
view to confirm that the conditions described in the offer were indeed validated. In light of
these considerations, the Chamber concluded that the essential elements mentioned by
the jurisprudence were not fully included in the document at the basis of the dispute and
therefore the employment offer was not able to trigger the consequences of a labour
relationship between the parties.

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REF. FPSD-9598

51. On the basis of the foregoing, the Chamber concluded that the player could not meet his
burden of proof to demonstrate that an employment relationship was ever initiated with
the club and therefore his claim lacked any contractual basis whatsoever. Accordingly, the
Chamber found that the claim must be entirely rejected.
52. For the sake of completeness, the Chamber clarified that the abovementioned conclusion
renders moot any discussion that could arise with regards to whether the Chinese agent
was acting on behalf of the club regarding the negotiations of the possible employment
relationship between the player and the club. As such, the Chamber did not enter into such
analysis and makes no finding on it.
ii. Compliance with monetary decisions
53. Finally, taking into account the applicable Regulations, the Chamber referred to art. 24 par.
1 and 2 of the Regulations, which stipulate that, with its decision, the pertinent FIFA
deciding body shall also rule on the consequences deriving from the failure of the
concerned party to pay the relevant amounts of outstanding remuneration and/or
compensation in due time.
54. In this regard, the DRC highlighted that, against clubs, the consequence of the failure to
pay the relevant amounts in due time shall consist of a ban from registering any new
players, either nationally or internationally, up until the due amounts are paid. The overall
maximum duration of the registration ban shall be of up to three entire and consecutive
registration periods.
55. Therefore, bearing in mind the above, the DRC decided that the Respondent must pay the
full amount due (including all applicable interest) to the Claimant within 45 days of
notification of the decision, failing which, at the request of the Claimant, a ban from
registering any new players, either nationally or internationally, for the maximum duration
of three entire and consecutive registration periods shall become immediately effective on
the Respondent in accordance with art. 24 par. 2, 4, and 7 of the Regulations.
56. The Respondent shall make full payment (including all applicable interest) to the bank
account provided by the Claimant in the Bank Account Registration Form, which is attached
to the present decision.
57. The DRC recalled that the above-mentioned ban will be lifted immediately and prior to its
complete serving upon payment of the due amounts, in accordance with art. 24 par. 8 of
the Regulations.
d. Costs

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REF. FPSD-9598

58. The Chamber referred to art. 25 par. 1 of the Procedural Rules, according to which
“Procedures are free of charge where at least one of the parties is a player, coach, football agent,
or match agent”. Accordingly, the Chamber decided that no procedural costs were to be
imposed on the parties.
59. Likewise, and for the sake of completeness, the Chamber recalled the contents of art. 25
par. 8 of the Procedural Rules and decided that no procedural compensation shall be
awarded in these proceedings.
60. Lastly, the DRC concluded its deliberations by rejecting any other requests for relief made
by any of the parties.

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REF. FPSD-9598

IV. Decision of the Dispute Resolution Chamber
1.

The claim of the Claimant, Elias Fernando Aguilar Vargas, is rejected.

2.

This decision is rendered without costs.

For the Football Tribunal:

Emilio García Silvero
Chief Legal & Compliance Officer

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REF. FPSD-9598

NOTE RELATED TO THE APPEAL PROCEDURE:
According to article 57 par. 1 of the FIFA Statutes, this decision may be appealed against before
the Court of Arbitration for Sport (CAS) within 21 days of receipt of the notification of this
decision.
NOTE RELATED TO THE PUBLICATION:
FIFA may publish this decision. For reasons of confidentiality, FIFA may decide, at the request
of a party within five days of the notification of the motivated decision, to publish an
anonymised or a redacted version (cf. article 17 of the Procedural Rules Governing the Football
Tribunal).
CONTACT INFORMATION
Fédération Internationale de Football Association
FIFA-Strasse 20 P.O. Box 8044 Zurich Switzerland
www.fifa.com | legal.fifa.com | [email protected] | T: +41 (0)43 222 7777

pg. 17