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

The court discusses the meaning and effect of the referral of the resolution of disputes to arbitration, including: who can ask for referral and when, whether a party has waived its right to request arbitration, the defense that there was no contract at all; whether there was a condition precedent to the commencement of arbitration (e.g. mediation), stay of proceedings v. compelling arbitration, and national procedural specificities such as remand and removal (US), effect of class action. etc.