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.

The court discusses the applicable period of limitation for seeking enforcement of an award.

Invalidity of the arbitration agreement: The court discusses other cases of invalidity of the arbitration agreement, including that there was no agreement at all or that the party was not a signatory thereto, that the incorrect arbitral institution was chosen, etc.

Public policy: The court discusses cases in which the subject matter of the award was not arbitrable in the enforcement State on public policy grounds.