152. ALTMANN incorporates here by reference paragraphs 1 through 97.

153. As described above, the AUSTRIAN GALLERY has been unjustly and unlawfully enriched at the expense of Ferdinand Bloch-Bauer and his heirs. The AUSTRIAN GALLERY obtained the Klimt paintings from Ferdinand Bloch-Bauer and his heirs through violations of international law, duress and deceit, and has wrongfully withheld the paintings from ALTMANN.

154. As a result of the AUSTRIAN GALLERY’s unjust enrichment, ALTMANN is entitled to restitution of the Klimt paintings to her, or the reasonable value thereof.