The court discusses the applicability of this requirement under (domestic) US law – that parties must have expressed in the arbitration agreement their consent that judgment of the court shall be entered upon the award –in respect of Convention awards.

Award not binding, suspended or set aside: The court discusses the conditions under which an award that has merged into a court judgment in the country of origin can still be enforced as an award under the Convention, and whether a decision granting recognition under the Convention can be enforced as a foreign court judgment in a third country.