The court discusses the application of the Convention to awards rendered by permanent arbitral bodies (as opposed to ad hoc awards).

The court discusses the first alternative requirement of Art. II(2) that the arbitral award is “signed by the parties”.

The court discusses these Articles, which require a specific, separate signature for (domestic) arbitration agreements.

The court discusses the principle that the merits of the award may not be reviewed and that the court may only carry out a limited review of the award to ascertain grounds for refusal.

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

Due process: The court discusses what are to be considered proper time limits and notice periods that fulfill the requirement that the party opposing recognition and enforcement of the arbitral award was extended due process.