The Magistrate Judge issued a recommendation in favor of granting Prosper Business's crossmotion to refer the dispute to arbitration under the New York Convention, and denied SSI's motion for a declaration that the parties' arbitration clause was invalid under Chinese law and for an order enjoining any and all further proceedings in the arbitration. SSI claimed that the arbitration clause was invalid because it failed to specify an arbitration institution. The Court held that the arbitration agreement was not "NULL and void" within the meaning of the Convention as a result, because the failure to specify an arbitral institution was not an internationally recognized defense such as duress, mistake, fraud, or waiver that could be applied neutrally on an international scale. The recommendation was adopted by the District Court on 3 September 2020.