The District Court granted the petitioner's motion for default judgment and confirmed the arbitral award on the respondent's failure to respond to the petition for confirmation despite completion of service.

Prior to confirming the award, the Court determined that it had subject matter jurisdiction over the action as the award was a foreign arbitration award pertaining to commercial matters and was rendered in a signatory State to the New York Convention. The Court further ascertained that it had personal jurisdiction over the Republic of Guinea and that service had been properly completed by the petitioner. The Court observed that enforcing courts have little discretion in refusing or deferring enforcement of foreign arbitral award and that they may do so only if the grounds explicitly set forth in Article V of the Convention are satisfied. The respondent bears the burden of proving the application of any of the grounds for refusal to enforce an award under Article V(1) of the Convention, which was not satisfied in this case as the respondent defaulted in the proceedings. On its own review of the grounds under Articles V(1) and V(2) of the Convention, the Court concluded that none of grounds for refusal of enforcement existed in this case.