UNITED STATES 477
477. United States District Court, Southern District of New York, 4 February 2004
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 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 questions relating to interest on the amount due under the arbitral award, including whether the enforcement court may grant interest not granted in the award, modify interest granted in the award, and grant post-award interest.
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.