Presented with a motion to compel arbitration, the Court had previously found that the arbitration agreement at issue fell within the scope of the New York Convention and that it related to the dispute. In this decision, the Court denied Elko's motion for reconsideration, which based on newly discovered evidence that the person who signed the contract containing the arbitration clause on behalf of one of the defendants did not have the authority to do so. Thus, according to Elko, this non-signatory could not rely on the arbitration clause. The Court held that it need not address the factual substance of Elko's argument because the United States Supreme Court recently overturned the Eleventh Circuit precedent relied on by Elko, Outokumpu, holding that the New York Convention does not categorically prohibit non-signatories from enforcing arbitration agreements under domestic doctrines, including equitable estoppel.