The court discusses whether the dispute falls within the wording of the arbitration agreement; and whether claims in tort fall within the scope of the agreement.

The court discusses the form in which the arbitration agreement is expressed: short form arbitration clause, reference to rules of institution, etc.

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

The court discusses which law – lex fori, lex contractus, law of the State where the award will be made – applies specifically to determining whether an agreement to arbitrate is “null and void etc.“, and, by extension, which law applies to determining the validity of arbitration agreements.

Public policy: The court discusses cases in which the subject matter of the award was not arbitrable in the enforcement State on public policy grounds.