US 499. United States Court of Appeals, Ninth Circuit, 16 August 2004
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501
The court discusses questions relating to the general approach taken by the Convention to the grounds for refusal of recognition and enforcement, including its pro-enforcement bias, as well as the system of the Convention, under which recognition and enforcement may only be denied on seven listed grounds and the petitioner has only the obligations set out in Art. IV.
Grounds are exhaustive
502
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.
No re-examination of the merits of the arbitral award
513
Ground d: Irregularity in the composition of the arbitral tribunal or arbitral procedure