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US International Arbitration

A collection of the most recent US international arbitration decisions is available here. Decisions can be quickly retrieved by using the filter tools below.

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  • Vitol, Inc., v. Copape Produtos de Petroleo LTDA, No. 22-CV-10569-JPC (S.D.N.Y. Mar. 21, 2024)
    03/21/2024

    Court granted petitioner’s motion to compel arbitration and denied respondent’s cross-motion to dismiss the action. Court found that, although respondent was not a signatory to the relevant contracts, respondent was estopped from refusing to be bound by the arbitration clauses contained therein because it directly benefited from the contracts.

  • Huzhou Chuangtai Rongyuan Investment Management Partnership v. Qin, No. 23-0747 (2d Cir. Mar. 20, 2024)
    03/20/2024

    Court of appeals affirmed district court’s confirmation of CIETAC arbitral award pursuant to the New York Convention, rejecting defendant’s argument that he was not provided adequate notice of the arbitration and was therefore unable to participate in the selection of arbitrators. Court of appeals concluded that plaintiff made sufficient efforts that were reasonably calculated to provide notice to defendant.

  • Concept Engineering LLC v. Pinterest, Inc., No. 21-CV-01465-MN (D. Del. Mar. 20, 2024)
    03/20/2024

    Court granted defendant’s motion to stay action pending arbitration finding whether a non-signatory can compel plaintiff to arbitrate is a question of arbitrability which was delegated to the arbitrator by “clear and unmistakable” evidence.

  • Allianz Risk Transfer (Bermuda) Limited, v. High Lonesome Wind Power, LLC, No. 22-CV-05133-GHW (S.D.N.Y. Mar. 19, 2024)
    03/19/2024

    Court granted defendant’s motion to compel arbitration finding the parties’ arbitration agreement unambiguously requires the arbitration of their dispute regarding the calculation of the amount due under the contract.

  • Employers’ Innovative Network, LLC v. Bridgeport Benefits, Inc., No. 18-CV-01082 (S.D.W. Va. Mar. 18, 2024)
    03/19/2024

    Court granted defendants’ joint motion to confirm and enforce arbitration award under the New York Convention, finding plaintiffs failed to prove that confirmation of the award would be contrary to public policy considering the arbitrator’s failure to disclose a potential conflict of interest. Court concluded that plaintiffs’ failure to challenge the arbitrator in Bermuda foreclosed their public policy defense and regardless, plaintiffs failed to conclusively offer proof of, or prejudice resulting from, the arbitrator’s perceived partiality.

  • Simplot India LLC v. Himalaya Food International LTD, No. 23-CV-01612-RK-TJB (D.N.J. Mar. 15, 2024)
    03/15/2024

    Court denied petitioners’ motion to confirm foreign arbitral award, holding there was no personal jurisdiction over respondent. Court found unpersuasive petitioners’ argument that a related domestic company was respondent’s alter ego; that respondent consented to general jurisdiction by registering to do business in New Jersey and accepting service by its designated agent; or that court may exercise quasi in rem jurisdiction over the related domestic company’s debts owed to respondent, because respondent lacked sufficient interest or control in the property.

  • McBurnie v. RAC Acceptance East, LLC, No. 22-16868 (9th Cir. Mar. 14, 2024)
    03/14/2024

    Court of appeals affirmed district court’s denial of motion to compel arbitration finding that defendant’s arbitration agreement was unenforceable under a California law invalidating contracts that waive the right to seek injunctive relief on behalf of the general public, and that California law was not preempted by the FAA. Court of Appeals further found that its prior decision was not abrogated by the subsequent Supreme Court decision in Viking River because that decision dealt with a different California law.

  • Metropolitan Municipality of Lima v. Rutas de Lima S.A.C., No. 20-CV-02155-ACR (D.D.C. Mar. 12, 2024)

    03/12/2024

    Court denied petition to vacate two arbitration awards and granted cross-motions to confirm them, where grounds for refusal or deferral of recognition or enforcement of the awards under the New York Convention were not met. Court noted that two independent tribunals had rejected claims of bribery related to an underlying infrastructure contract to build, improve, and maintain urban highways in Peru and declined to accept petitioner’s argument that denial of the bribery before the tribunal was fraudulent. Court also disagreed that the second arbitral tribunal committed misconduct in admitting some, but not the annexes, to a prosecutorial indictment it introduced after the close of evidence.

  • Cowin Technology Co., Ltd. v. Amazon.com Services LLC, No. 23-CV-03054-ALC (S.D.N.Y. Mar. 12, 2024)
    03/12/2024

    Court denied petition to vacate arbitral award and granted respondents’ cross-motion to confirm the award, where petitioner had not demonstrated that one of the seven exclusive grounds for refusal or deferral of recognition or enforcement of the award under Article V of the New York Convention applied.

  • In re: Application of Bonsens.org for an Order Pursuant to 28 U.S.C. § 1782 to Conduct Discovery for Use in a Foreign Proceeding, No. 23-380 (2d. Cir. Mar. 11, 2024)
    03/11/2024

    Court of appeals affirmed district court’s denial of application seeking discovery under 28 USC § 1782 from Pfizer Inc. for use in a suit applicant initiated against the French government in France. Court of appeals determined that the requested discovery was irrelevant to the jurisdictional issue on appeal in France and that the prospect of a merits review in that proceeding was too speculative to satisfy the statutory requirement that the discovery be “for use” in the French proceeding.

  • Shenzhen Gooloo E-Commerce Co., Ltd. v. Pilot, Inc., No. 23-CV-00854-PAB-SBP (D. Colo. Mar. 8, 2024)
    03/08/2024

    Court granted motion to dismiss petition to vacate arbitration award and ordered that the arbitration award be confirmed, where petitioner did not sufficiently allege that the arbitration award was in manifest disregard of the law or that the arbitrator exceeded his authority under the terms of the arbitration agreement.

  • Bufkin Enterprises, L.L.C. v. Indian Harbor Insurance Company, No. 23-30171 (5th Cir. Mar. 4, 2024)
    03/04/2024

    Court of appeals reversed district court’s denial of appellants’ motion to compel arbitration under the New York Convention. Court of appeals found that the doctrine of equitable estoppel under Louisiana law compelled arbitration because the appellee signatory to the arbitration agreement raised allegations of substantially interdependent and concerted misconduct by both non-signatory appellants and one or more of the signatory appellants to the arbitration agreement, even though the complaint later dismissed the signatory appellants as defendants.

  • Thales Avionics, Inc. v. L3 Technologies, Inc., No. 24-CV-00112-JGK-RFT (S.D.N.Y. Feb. 27, 2024)
    02/27/2024

    Court granted preliminary injunction in aid of arbitration to enjoin defendant from selling stake in parties’ joint venture, finding that plaintiff demonstrated sufficiently serious questions going to the merits of its claim, irreparable harm, and that the balance of hardships weighed decidedly in its favor.
     

  • Valentino S.p.A. v. Mrinalini, Inc., No. 23-CV-02319-MKV (S.D.N.Y. Feb. 26, 2024)
    02/26/2024

    Court granted petition to confirm arbitration award, finding that respondent failed to prove grounds under Article V of the New York Convention to refuse or defer the recognition of the award.  Court denied petitioner’s request for attorneys’ fees, finding that respondent’s actions did not warrant that exceptional award but found petitioner’s expenses would be allowed to the extent that costs are available to the prevailing party.

  • Chicken Mart, Inc. v. Independent Specialty Insurance Company, No. 23-CV-06661-EEF-JVM (E.D. La. Feb. 23, 2024)
    02/23/2024

    Court granted motion to compel arbitration and stayed litigation pending arbitration, finding that the requirements of the New York Convention were satisfied.  Court compelled arbitration between foreign and domestic defendants because plaintiff was alleging intertwined conduct on the part of all defendants.

  • Apex Hospitality Group, LLC v. Independent Specialty Insurance Company, No. 23-CV-02060-JTM-JVM (E.D. La. Feb. 23, 2024)
    02/23/2024

    Court granted motion to compel arbitration, finding that the requirements of the New York Convention were satisfied.  Court found that plaintiff was equitably estopped from objecting to arbitration against domestic defendant, a non-signatory to the arbitration agreement, because plaintiff alleged conduct that was interdependent and concerted with signatory foreign defendant.  Court also held that arbitration clauses are forum or venue selection clauses and application of equitable estoppel was thus not precluded by Louisiana law.

  • Stonex Markets LLC v. Cooperativa de Caficultores del Suroeste de Antioquia, No. 23-CV-00513-JGLC-OTW (S.D.N.Y. Feb. 21, 2024)
    02/21/2024

    No. 23-CV-00513-JGLC-OTW (S.D.N.Y. Feb. 21, 2024)
    Court accepted magistrate judge’s report and recommendation to enter a motion for default judgment to confirm arbitration award finding the recommendation to be well reasoned and grounded in fact and law.

  • Hoeg v. Samsung Electronics of America, Inc., No. 23-CV-01951 (E.D. Ill. Feb. 20, 2024)
    02/20/2024

    Court found under § 4 of the FAA, that it may grant an order to compel arbitration where a duly initiated arbitral proceeding was previously administratively closed due to the opposition’s failure to pay its fees.  To hold otherwise would lead to a “never-ending game of cat-and-mouse” where the parties continue to initiate arbitration proceedings and one-party refuses to pay.

  • Telecom Business Solutions, LLC v. Terra Towers Corp., No. 22-CV-01761-LAK (S.D.N.Y. Feb. 20, 2024)
    02/20/2024

    Court granted motion for an anti-suit injunction against defendant where a foreign litigation would frustrate the arbitration process by seeking to re-litigate issues already resolved by an arbitral tribunal and undermine the court’s confirmation of the arbitration award.

  • Cameron Parish Recreation #6 v. Indian Harbor Insurance Company, No. 23-30181 (5th Cir. Feb. 19, 2024)
    02/19/2024

    Court of Appeals vacated a discovery order and remanded to the district court to immediately grant a stay pending its decision on arbitration.  Court of appeals found discovery was improper in this case, where determining if a valid arbitration agreement existed between the parties was purely a matter of law.

  • Chemaly v. Lampert, No. 23-CV-24257-BB (S.D. Fla. Feb. 16, 2024)
    02/16/2024

    Court granted in part and denied in part motions to compel arbitration pursuant to the New York Convention and to remand to state court, finding certain claims reasonably arose out of the arbitration agreement and remanding to state court the tort claims that did not fall within the scope of the arbitration agreement and did not arise under federal law.

  • Port of Vancouver USA v. BNSF Railway Company, No. 3:23-CV-05560-DGE (W.D. Wash. Feb. 15, 2024)
    02/15/2024

    Court granted defendant’s motion to dismiss and compel arbitration under the FAA as to claims that defendant was not complying with an arbitration award against it that had been confirmed by a federal court.  Court reasoned that whether it could enforce the terms of the arbitration award was a “question of arbitrability” it could not resolve because the award was ambiguous.

  • FGI Industries, Inc. v. Tangshan Ayers Bath Equipment Co., Ltd., No. 14-CV-00188-HDV-RAO (C.D. Cal. Feb. 13, 2024)
    02/13/2024

    Court denied defendant’s motion to compel arbitration finding defendant waived that right by actively seeking to litigate the underlying merits of the case, including filing five motions to dismiss and multiple other procedural and substantive motions over the past twelve years.

  • Carriage Court Condominiums Owners Association v. Renaissance Re, No. 23-CV-05544-LMA-MBN (E.D. La. Feb. 7, 2024)
    02/07/2024

    Court granted defendants’ motion to compel arbitration finding the insurance policy included a valid arbitration agreement enforceable pursuant to the New York Convention and the FAA. Plaintiff failed to file a timely opposition.

  • Cedar Ridge, LLC v. Certain Underwriters at Lloyd’s London, No. 23-CV-07350-SSV-JVM (E.D. La. Feb. 7, 2024)
    02/07/2024

    Court granted defendants’ motion to compel arbitration and stay the proceedings finding arbitration is mandated under the plaintiff’s insurance policy and the dispute is governed by the New York Convention.  Plaintiff did not oppose the motion.

  • First United Methodist Church of Houma v. Underwriters at Lloyds of London, No. 23-CV-00610-JTM-JVM (E.D. La. Feb. 7, 2024)
    02/07/2024

    Court granted defendants’ motion to compel arbitration finding the plaintiff’s insurance policy included a valid and enforceable arbitration clause. Court rejected plaintiff’s argument that defendants had waived their right to arbitration finding that defendants did not evince a desire to resolve the dispute through litigation rather than arbitration by admitting venue and jurisdiction were proper in their answer, raising affirmative defenses but not the issue of arbitration, conducting discovery and providing initial disclosures, participating in mediation, and the passage of significant time since plaintiff filed its petition in state court.

  • Telecom Business Solution, LLC v. Terra Towers Corp., No. 23-144 (2d Cir. Feb. 6, 2024)
    02/06/2024

    Court of Appeals affirmed district court’s ruling confirming the arbitration award because the claims were rightfully governable by the binding arbitration provision in the shareholders’ agreement.  Court of Appeals found defendants failed to establish either that the arbitration panel displayed a manifest disregard for the law or that the arbitration procedure was fundamentally unfair.  Court of Appeals concluded that the panel’s “last-minute switch” from New York law to the AAA rules was not fundamentally unfair because defendants were on notice that the arbitration would be conducted in accordance with the AAA rules.

  • New Frontier Investment AG v. BitCenter, Inc., No. 23-MC-80154-PHK (N.D. Cal. Feb. 6, 2024)
    02/06/2024

    Court denied petition to partially vacate arbitration award under the provisions of the FAA and the New York Convention finding that petitioner failed to show the arbitrator manifestly disregarded Hungarian law, or that the award was completely irrational in light of the parties’ contractual agreement or violated the public policy of either the forum state—California—or the United States.

  • Devas Multimedia Private Limited v. Antrix Corp. Ltd., No. 20-36024 (9th Cir. Feb. 6, 2024)
    02/06/2024

    Court of Appeals denied petitions for rehearing en banc, finding, contrary to all other federal circuit courts, that in addition to fulfilling the Foreign Sovereign Immunities Act requirements, plaintiffs must prove “minimum contacts” to assert personal jurisdiction over a foreign state, including when enforcing an international arbitration award.

  • Voltage Pictures, LLC v. Gussi, S.A. de C.V., No. 23-55123 (9th Cir. Feb. 5, 2024)
    02/05/2024

    Court of Appeals affirmed district court’s confirmation of an arbitral award holding that (1) district court had jurisdiction under § 203 of Chapter 2 of the FAA and 28 USC § 1331; (2) district court erred in ruling that California law governed service because federal procedural law generally governs service when a party files in federal district court, however, under federal law, plaintiff sufficiently served defendant; and (3) district court did not abuse its discretion by declining to extend comity to a purported Mexican court order enjoining plaintiff from seeking to confirm the award because defendant did not certify the genuineness of document or the translation.

  • Parish of Lafourche v. Indian Harbor Insurance Company, No. 23-CV-03472-SM-MBN, Dkt. No. 33 (E.D. La. Feb. 2, 2024)
    02/02/2024

    Court denied plaintiff’s motion to remand to state court finding abstention was inappropriate, namely, because the cause of action arose under federal law under the New York Convention and FAA, and the dispute did not involve vital state interests.

  • Parish of Lafourche v. Indian Harbor Insurance Company, No. 23-CV-03472-SM-MBN, Dkt. No. 34 (E.D. La. Feb. 2, 2024)
    02/02/2024

    Court granted defendants’ motion to compel arbitration and stay proceedings finding the service-of-suit clause did not constitute a waiver of defendants’ right to compel arbitration.  Instead, the clause complemented the arbitration agreement by establishing a forum where the parties may enforce an arbitration award.

  • Dryades YMCA v. Certain Underwriters at Lloyds, London, No. 23-CV-03411-JTN-MBN (E.D. La. Jan. 31, 2024)
    01/31/2024

    Court granted defendants’ motion to compel arbitration and stay proceedings finding that Louisiana state law does not prevent the enforcement of arbitration clauses in insurance contracts as to foreign insurers.  Court found that the New York Convention superseded the Louisiana state law seeking to supersede federal laws regulating the business of insurance.

  • Conti 11. Container Schiffarts-GMBH & Co. KG M.S., MSC Flaminia v. MSC Mediterranean Shipping Company S.A., No. 22-30808 (5th Cir. Jan. 29, 2024)
    01/29/2024

    Court of appeals reversed district court’s decision to confirm a $200 million London arbitration award, finding the district court lacked personal jurisdiction over defendant.  Court of appeals agreed that when assessing personal jurisdiction to confirm an arbitration award under the New York Convention, a court should consider contacts related to the underlying dispute, not just the arbitration itself.  However, it found defendant had not waived its personal jurisdiction defense and that the sole contact with the forum, the loading of tanks in New Orleans, did not confer specific personal jurisdiction over defendant.

  • Regal Games, LLC v. SellerX Eight GMBH, No. 1:22-CV-07455-ER  (S.D.N.Y. Jan. 25, 2024)
    01/25/2024

    Court granted defendant’s motion to compel arbitration pursuant to the FAA, finding that the parties formed a valid agreement to arbitrate even when the underlying agreement did not expressly contain the words arbitration or arbitrator and where the arbitrator was a non-legal expert.  Court stayed the proceedings pending the outcome of the arbitration.

  • Bayport Financial Service (USA) Inc. v. Bayboston Managers, LLC, No. 22-CV-21306-JEM (S.D. Fla. Jan. 24, 2024)
    01/24/2024

    Magistrate judge recommended that motion to compel arbitration be granted pursuant to the New York Convention, finding that an alter ego analysis was inapplicable here and thus, one defendant’s engagement in litigation could not waive the arbitral rights of another defendant.

  • The Resource Group International Limited v. Chishti, No. 23-286 (2d Cir. Jan. 22, 2024)
    01/22/2024

    Court of Appeals vacated and remanded the district court’s order finding it relied on an erroneous view of the law in concluding that plaintiffs failed to demonstrate a likelihood of success on the merits of their claims and irreparable harm absent a preliminary injunction.  Court of Appeals found (1) district court erroneously concluded that a later-executed agreement that did not specifically mention arbitration likely did not supersede the arbitration agreement, and, as a result, failed to determine the scope of the agreement or otherwise identify which claims are arbitrable in the first instance; and (2) district court erred in concluding that being forced to arbitrate an inarbitrable claim cannot constitute irreparable harm.

  • General Mill Supplies, Inc. v. Underwriters at Lloyd’s, London, No. 2:23-CV-06464-NJB-KWR (E.D. La. Jan. 19, 2024)
    01/19/2024

    Court granted defendants’ motion to compel arbitration, finding that defendants satisfied their burden to show that plaintiff’s claims were subject to a valid arbitration agreement pursuant to the parties’ insurance policy subject to the New York Convention.  Court also found that plaintiffs failed to show that the underlying arbitration agreement was null and void, inoperative, or incapable of being performed.  Court stayed proceedings pending arbitration.

  • Siddiqui Enterprises, LLC v. Independent Specialty Insurance Company, No. 2:23-CV-04329-CJB-JVM  (E.D. La. Jan. 19, 2024)
    01/19/2024

    Court granted defendants’ motion to compel arbitration, finding the arbitration agreement was enforceable under the New York Convention because there was a written agreement to arbitrate, the agreement provided for arbitration in a New York Convention signatory nation, the agreement arose out of a commercial legal relationship, and at least one party to the agreement was not an American citizen.  Court rejected plaintiff’s argument that, pursuant to the McCarran-Ferguson Act, a local Louisiana law reverse-preempted the enforceability of the arbitration clause.

  • Watershape, Inc. v. The Association of Pool and Spa Professionals, No. 2:23-CV-00466-JCM-EJY (D. Nev. Jan. 19, 2024)
    01/19/2024

    Court granted defendants’ motion to dismiss and compel arbitration pursuant to the FAA, finding the language of the arbitration clause was broad in scope and thus plaintiff’s dispute concerning how the underlying agreement must be interpreted fell within the scope of the arbitration clause.

  • LLC SPC Stileks v. The Republic of Moldova, No. 14-CV-01921-CRC (D.D.C. Jan. 19, 2024)
    01/19/2024

    Court denied respondent’s motion for relief from judgment pursuant to Rule 60(b) of the Federal Rules of Civil Procedure without prejudice.  Although the court was inclined to agree that such relief was warranted, it held that it would be premature to grant the motion given that plaintiff may appeal the Paris Court of Appeals’ decision vacating arbitration award against respondent in favor of plaintiff’s predecessor-in-interest.

  • Equipav S.A. Pavimentação, Engenharia e Comercio Ltda. v. Bertin, No. 22-CV-04594-PGG (S.D.N.Y. Jan. 18, 2024)
    01/18/2024

    Court granted motion to confirm order of attachment as to respondent’s assets, finding that (i) there was a cause of action; (ii) it was probable that petitioner would succeed on the merits; (iii) one or more grounds for attachment pursuant to NY CPLR § 6201 existed; (iv) the amount demanded from respondent exceeded all counterclaims known to petitioner; and (v) the attachment was needed to obtain jurisdiction and also appropriate to secure payment from respondent.  Court also granted petitioner’s motion to confirm arbitration award against respondent and nonparty and denied respondent’s motion to dismiss for lack of personal jurisdiction, finding it had quasi in rem jurisdiction over respondent’s property located in its district.  Court also denied respondent’s motion for a stay, finding that the Europcar factors weighed in favor of denying a stay.

  • Causeway Partners, L.L.C. v. Indian Harbor Insurance Company, No. 23-CV-06108-SM-JVM (E.D. La. Jan. 17, 2024)
    01/17/2024

    Court granted defendant’s motion to compel arbitration and stay the proceedings, finding that the requirements of the New York Convention were satisfied.  As to domestic defendants, court found that (i) the doctrine of equitable estoppel applied to non-signatories to the arbitration provision; and (ii) Louisiana law did not prohibit the domestic defendants from enforcing the arbitration clause found in each of their contracts.  Court noted that although Louisiana law ordinarily prohibits enforcement of arbitration clauses as forum or venue selection clauses, Louisiana law grants an exception to surplus line insurance policies like that issued by defendants.

  • Zhongtie Dacheng (Zhuhai) Investment Management Co Ltd v. Yan, No. 8:22-CV-00461-KK-ADS (C.D. Cal. Jan. 12, 2024)
    01/12/2024

    Court confirmed an arbitral award pursuant to the New York Convention, holding that service was proper because respondents were mailed notice of the proceedings to their last known addresses listed on publicly available documents and their government-issued IDs. 

  • Epicenter Loss Recovery LLC v. Burford Capital Limited, No. 18-CV-03300-DJH (D. Ariz. Jan. 9, 2024)
    01/10/2024

    Court granted defendants’ motion to dismiss following the issuance of a final arbitration award from the LCIA.  Court, having previously stayed litigation pending a final award, did not maintain continued jurisdiction under the LCIA Rules or the FAA, where plaintiff challenged the validity of the award, finding the primary jurisdiction in which to challenge the award would be in the English courts.

  • In re Refinería de Cartagena S.A.S., No. 23-MC-00455-JPC (S.D.N.Y. Jan. 8, 2024) 
    01/08/2024

    Court granted 28 USC § 1782 request for leave to serve document and deposition subpoenas on defendants.  Court reasoned that the discovery requests were relevant and “for use” in foreign restructuring proceedings, and that petitioner qualified as an interested party, as the proposed restructuring plans could discharge debtors from amounts owed to petitioner under an arbitration award.  In weighing the discretionary Intel factors, court did not find the discovery requests to be overly intrusive or burdensome in light of the court ordered modifications limiting the scope of each request.

  • Patterson v. Jump Trading LLC, No. 22-CV-03600-PCP (N.D. Cal. Jan. 4, 2024)
    01/04/2024

    Court denied defendant’s motion to compel arbitration because defendant was not a party to the arbitration agreement between plaintiffs and former defendant. Court concluded that lead plaintiff’s arbitration agreement did not delegate issues of arbitrability to an arbitrator, and the arbitration agreement did not compel arbitration against non-signatory defendant. 

  • BBC Chartering Carriers GMBH & Co., KG, v. Hsin Silk Road Shipping Limited, No. 23-CV-06043-KK-MRW (C.D. Cal. Jan. 4, 2024)
    01/04/2024

    Court granted motion to confirm foreign arbitral award and motion for default judgment pursuant to the award.

  • Battle v. General Motors, LLC, No. 22-CV-10783-MAG-KGA (E.D. Mich. Jan. 4, 2024)
    01/04/2024

    Court granted defendant’s motion to compel arbitration on the grounds that the question of arbitrability as to the claims involving defendant—as a non-party to the agreement containing the arbitration provision—was properly delegated to the arbitrator.

  • Jiakeshu Technology Limited v. Amazon.com Services, LLC, No. 22-CV-10119-JGLC (S.D.N.Y. Jan. 3, 2024)
    01/03/2024

    Court denied petitioner’s petition to vacate the arbitral award and granted defendant’s motion to confirm the award, finding petitioner did not rely on any of the grounds under the New York Convention or the FAA on which courts may vacate an arbitral award, instead relying on the “severely limited” manifest disregard standard and other unrecognized bases in the Second Circuit such as “complete irrationality” and violation of “strong public policy.”

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