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

Multi-party disputes: The court discusses whether related court proceedings may absorb (by vis atractiva) arbitration proceedings.

The court discusses the principle that the procedure for the enforcement of awards under the Convention is governed by the lex fori, as well as procedural issues (such as the competent enforcement court) not falling under the specific cases of ¶¶ 302-307.

The court discusses the burden of proof of the grounds for refusing enforcement under the Convention.

Public policy:The court discusses the consequences of the default of a party in the arbitration on the recognition and enforcement of an arbitral award against it.