The court discusses the determination and relevance of the place where the award was made (in a foreign State or another contracting State.

The court discusses the second alternative requirement of Art. II(2) that the arbitration agreement is “contained in an exchange of letters or telegrams”.

The court discusses issues relating to the manner of authentication and certification of the award and/or arbitration agreement.

The court discusses issues relating to the moment when the documents that are required for seeking recognition and enforcement must be supplied, and whether any defect can be cured later in the enforcement proceeding.

Due process: The court discusses what constitutes “proper notice” of the appointment of the arbitrators or of the arbitration proceedings.