The court discusses which awards are considered non-domestic even if rendered in the State of enforcement (international element, lex mercatoria).

The court discusses whether the Convention applies to domestic arbitration and to proceedings for the setting aside of domestic awards. 

The court discusses the principle that the merits of the award may not be reviewed and that the court may only carry out a limited review of the award to ascertain grounds for refusal.

Public policy: The court discusses the meaning of (international as compared to domestic) public policy, generally defined as the basic notions of morality and justice of the enforcement State.

Public policy: The court discusses the effect of other alleged violations of public policy on the recognition and enforcement of an arbitral award, such as contradictory reasons, manifest disregard of the law (US), etc.