UNITED STATES 366
US 366. United States District Court, Northern District of California, 1 June 2001
The court discusses the determination and relevance of the place where the award was made (in a foreign State or another contracting State.
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 overall scheme and/or pro-enforcement bias of the Convention.
The court discusses the burden of proof of the grounds for refusing enforcement under the Convention.
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.