The Court granted the motion to compel arbitration of a Hurricane Ida insurance dispute. It noted the strong presumption in favor of enforcing arbitration provisions, and found that it should compel arbitration because, prima facie, there was a valid agreement to arbitrate between the parties, and the dispute fell within the scope of that arbitration agreement. The plaintiff argued that there was no arbitration agreement in writing, as required under the New York Convention, because it had not signed the arbitration clause. The Court explained that this argument was foreclosed by Fifth Circuit precedent in Sphere Drake, where the Circuit construed Art. II of the New York Convention to require either “(1) an arbitral clause in a contract or (2) an arbitration agreement signed by the parties or contained in an exchange of letters or telegrams” – so that “an arbitral clause in a contract” need not be signed by the parties. The District Court acknowledged that the Fifth Circuit’s holding was a minority view among circuits, and that the Fifth Circuit itself suggested it may reconsider this 1994 ruling at some point. However, until the Fifth Circuit reconsidered it, Sphere Drake was binding on the District Court.