The Court granted the petitioner's motion to remand the action to state court, finding that the four jurisdictional requirements for compelling arbitration under the New York Convention were not met. Compelling arbitration under the Convention requires that there is an agreement in writing within the meaning of the Convention, which provides for arbitration in the territory of a Convention signatory and arises out of a legal relationship, whether contractual or not, which is considered commercial; and a party to the agreement is not an American citizen, or the commercial relationship has some reasonable relation with one or more foreign states. Here, in particular, the arbitration relationship was between United States' citizens and Havens failed to demonstrate that the dispute involved property or performance abroad. The fact that the licenses which formed part of the dispute could reach beyond the borders of the United States did not make them property located abroad, nor did potential future service of the subject licenses create a reasonable relation with one or more foreign states.