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

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.

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.