The court discusses which awards are considered non-domestic even if rendered in the State of enforcement (international element, lex mercatoria).

The court discusses the burden of proof of the grounds for refusing enforcement under the Convention.

Award not binding, suspended or set aside: The court discusses the difference between the exclusive jurisdiction to set aside an award (primary jurisdiction), which belongs to the courts of the country of origin of the award, and the jurisdiction of all other courts to recognize and enforce the award (secondary jurisdiction); issues relating to the determination of the “competent authority”; and whether an award that has been set aside in the country of origin can be enforced in another State under the Convention.