The District Court granted the insurers’ motion to refer a dispute for a Hurricane Ida insurance claim to arbitration. The Court found 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 a Convention signatory (the United States) and arising out of a commercial legal relationship. The fourth requirement – that at least one party not be a US citizen – was also met in respect of some of the insurers. Thumbs Up argued, however, that  its claims should not be subject to arbitration because the domestic insurer subscribed to a higher percentage of the policy than did the foreign insurers. The Court rejected this argument, explaining that there was equitable estoppel because the plaintiff’s claims  against the domestic insurer were intertwined with its claims against the foreign insurers.