A district court confirmed an Indian award rendered against Antrix (UNITED STATES 1011). The Ninth Circuit set that decision aside (UNITED STATES 1059), finding that the district court had failed to consider whether Antrix had minimum contacts with the United States. The Supreme Court clarified that this further requirement, established by Ninth Circuit precedent, could not apply. Personal jurisdiction over a foreign State or state agency or instrumentality, such as Antrix, under the Foreign Sovereign Immunities Act (FSIA) only required proper service and the existence of one of the FSIA immunity exceptions: arbitration exception and waiver exception.