The Court of Appeals reversed the district court decision, and held that it lacked subject matter jurisdiction over an action by which the appellants asked the Court of Appeals to recognize and enforce a Zambian court judgment that confirmed an arbitral award issued in Zambia. The Court held that neither the waiver exception nor the arbitration exception to sovereign immunity under the Foreign Sovereign Immunities Act (FSIA) applied. The Court held that applying either exception here would require conflating “two distinct concepts – arbitral awards and foreign court judgments”.