The Court granted the motion to compel arbitration of an insurance dispute. It first held that the four jurisdictional requirements for compelling arbitration under the New York Convention were met: there was an arbitration agreement in writing, providing for arbitration in the United States, a Convention signatory and concerning a commercial legal relationship, and at least one party was not a US citizen. The Court then rejected the plaintiff’s affirmative defense that the arbitration agreement was “inoperative” due to its choice of law provision. The plaintiff argued that the agreement’s choice for the law of New York as the proper law of the insurance conflicted with Alabama law, which provides at ALA. CODE § 27-14-22 that all insurance contracts, the application for which is taken in this state, are governed by Alabama law. Other than Alabama law, the plaintiff contended, New York law does not allow an arbitral tribunal to award exemplary, punitive, multiple, consequential, or other damages of a similar nature. The Court explained that it had previously found that § 27-14-22 does not override a parties’ contractual choice of law. Moreover, this defense was not the type of defense that the null-and-void clause has been found to encompass, which are grounded in standard breach-of-contract defenses – such as fraud, mistake, duress, and waiver – that can be applied neutrally before international tribunals.