The court discusses the principle that the procedure for the enforcement of awards under the Convention is governed by the lex fori, as well as procedural issues (such as the competent enforcement court) not falling under the specific cases of ¶¶ 302-307.

The court discusses the conditions under which a party may be estopped from raising a ground for refusal of enforcement under the Convention or has waived the right to raise it.

The court discusses the admissibility of a set off or counterclaim in enforcement proceedings under the Convention.

More-favorable right provision: The court discusses examples of domestic laws of countries where enforcement of foreign awards is more favorable.