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  • Trustees of the New York City District Council of Carpenters Pension Fund, v. Ocean Marine Development Corp., No. 1:19-CV-06164-RA (S.D.N.Y. July 23, 2020)
    07/23/2020

    Court granted unopposed petition to confirm an arbitration award, but modified the amount of attorneys’ fees sought.  Court found that the petitioners demonstrated that there was no material issue of fact that would preclude enforcement of the award.  Court also confirmed the attorneys’ fees, but found that the rates charged for the associate were slightly higher than reasonable.

  • CEF Energia, B.V. v. Italian Republic, No. 1:19-CV-03443-K (D.D.C. July 23, 2020)
    07/23/2020

    Court granted temporary stay of petition seeking to confirm two arbitration awards in the interest of judicial economy and international comity.  The awards were rendered under the ECT by arbitration panels both based in Stockholm, Sweden.  The tribunal had ignored Italy’s argument that the panels lacked jurisdiction because of a recent CJEU ruling that intra-EU treaty arbitration are invalid to the extent they prohibit judicial review of EU law by EU courts, finding that Italy’s regulations reduced the value of petitioner’s investments. The court neglected to issue a stay pursuant to Article VI of the New York Convention because they did not determine whether they had jurisdiction and instead stayed under the courts inherent powers.

  • Levi Strauss & Co. v. Aqua Dynamics Systems, Inc., No. 3:15-CV-04718-WHO (N.D. Cal. July 20, 2020)
    07/20/2020

    Court granted petition to confirm an arbitration award and denied a petition to vacate.  Court rejected plaintiff’s argument that an arbitration award issued by JAMS should be vacated on the grounds that the panel was evidently partial because two of the three arbitrators were undisclosed shareholders in JAMS and JAMS engaged in undisclosed business with one of the parties. Court found that the business was trivial and that the parties and that the JAMS arbitration was not forced but jointly selected by both parties.

  • Teamsters Local 177 v. United Parcel Service, No. 19-3510 (3d Cir. July 16, 2020)
    07/16/2020

    Court of appeals reversed district court’s order denying petitioner’s motion to confirm an arbitration award.  Court of appeals found there was sufficient Art. III “case or controversy” to confer subject-matter jurisdiction on district court to confirm the arbitration award, since under the FAA a party’s injury was only fully remedied by the entry of a confirmation order.

  • Vantage Deepwater Company v. Petrobas America, Incorporated, No. 19-20435 (5th Cir. July 16, 2020)
    07/16/2020

    Court of appeals affirmed district court’s order confirming an arbitration award pursuant to the FAA and the Panama Convention.  Court found that, by properly deferring to arbitrators’ finding that defendants’ bribery objection was waived due to their ratification of the underlying agreement, district court correctly concluded the arbitration award did not violate public policy.  Court of appeals also determined that district court did not abuse its discretion in denying discovery from a dissenting arbitrator and the AAA.

  • Precision Castparts Corp. v. Schultz Holding GMBH & Co. KG, No. 1:20-CV-03029-LJL (S.D.N.Y. July 15, 2020)
    07/15/2020

    Court granted motion to confirm an arbitration award pursuant to the FAA and the New York Convention.  Court found the tribunal did not manifestly disregard Delaware law’s rehash doctrine in determining that petitioners’ fraud claim was not identical to but broader than the breach claim.  Court also determined that respondents failed to establish the tribunal exceeded its power under § 10(a)(4) of the FAA.

  • Levy and Brouard v. Republic of Guinea, No. 1:19-CV-02405-DLF (D.D.C. July 10, 2020)
    07/10/2020

    Court granted petitioners’ motion for default judgment recognizing and enforcing arbitration award pursuant to the ICSID Convention and 22 USC § 1650a.  Court found that the respondent was properly served under the FSIA and that copies of the tribunal’s award constituted sufficient evidence to show that petitioners were entitled to the claimed amounts as the creditor of a final ICSID award.

  • EGI-VSR, LLC v. Coderch, No. 18-12615 (11th Cir. June 25, 2020)
    06/25/2020

    Court of appeals affirmed the district court’s confirmation of an arbitration award under the Inter-American Convention on International Commercial Arbitration, but remanded with instructions to correct two errors.  Court of appeals found the district court used the incorrect date of conversion under the “breach day” rule and failed to order appellee to tender its shares on payment as required in the Shareholders’ Agreement.

  • Process and Industrial Development Limited v. Federal Republic of Nigeria, No. 18-7154 (D.C. Cir. June 19, 2020)
    06/19/2020

    Court of appeals denied district court’s order requiring that a foreign sovereign, in its response to a petition to confirm an arbitral award against it, brief the merits before resolving a colorable assertion of immunity.  Court of appeals found that the FAA imposed no such limitation and that the FSIA required a threshold immunity determination before a sovereign could be compelled to litigate merits.

  • Process of Industrial Developments Limited v. Federal Republic of Nigeria, No. 18-07154 (D.C. Cir. June 19, 2020)
    06/19/2020

    Court of appeals reversed and remanded lower court judgment ordering Nigeria to brief the merits of a petition to confirm arbitration while its foreign sovereign immunity defense was pending.  Court found that because Nigeria’s immunity defense was colorable, the lower court impermissibly ordered Nigeria to brief the merits of the dispute.

  • Tenaris S.A. v. Bolivarian Republic of Venezuela, No. 1:18-CV-01372-CRC (D.D.C. June 17, 2020)
    06/17/2020

    Court granted in part and denied in part petition to recognize and enforce an ICSID arbitration award against Venezuela.  Court found that despite petitioners’ arguments regarding discussion of post-judgment interest in the award, the applicable rate of 9% compounded semi-annually from the date of the award is set by federal law and is mandatory.  Court declined to award petitioners attorneys’ fees due to “the country’s dire political and economic situation.” 

  • Ocean World Lines, Inc. v. Transocean Shipping Transportagentur GesmbH, No. 1-19-CV-00043-AT (S.D.N.Y. June 16, 2020)
    06/16/2020

    Court granted petitioner’s petition to confirm an arbitration award, finding that no defense under the New York Convention was applicable nor was there any evidence of manifest disregard of the law.

  • Constellium Rolled Products Ravenswood, LLC v. United Steel International Union, No. 2:18-CV-01404 (S.D.W.V. June 11, 2020)
    06/11/2020

    Court denied motion to vacate an arbitration award.  Court denied petitioner’s arguments that the arbitrator manifestly disregarded the law by not applying the doctrines of res judicata and collateral estoppel because the record showed that the arbitrator considered both of these issues before rendering a decision.

  • Millner v. Bock, No. 3:20-CV-01564 (N.D. Cal. June 11, 2020)
    06/11/2020

    Court denied motion to vacate an arbitration award and confirmed the FINRA arbitration award.  Court denied respondent’s arguments that the arbitration panel improperly denied a motion to postpone a hearing and that the panel gave the parties too little time to conduct discovery according to the FINRA rules.  Court found that the panel had a reasonable basis to deny the motion to postpone because the respondent failed to identify materials it needed but did not have, and failed to meet and confer in good faith.

  • Rechnitz v. Kutner, No. 1:20-CV-01607-KAM-VMS (E.D.N.Y. June 8, 2020)
    06/08/2020

    Court granted petitioner’s motion to confirm an arbitration award related to a loan dispute, including an attachment in aid of arbitration and denied a motion to vacate.  Court found no evidence in the record to vacate the award on any of the grounds permitted under the FAA. Court also denied the respondent’s argument that the arbitrator lacked authority to resolve certain disputes because the parties only agreed to arbitrate one dispute, finding that when parties agree to arbitrate a dispute there is a presumption that they agree to arbitrate their various live disputes.

  • Denver Global Products v. Leon, No. 18-1853 (4th Cir. June 5, 2020)
    06/05/2020

    Court of appeals affirmed district court decision granting a motion to compel and confirming an arbitration award pursuant to the New York Convention. Court rejected the appellant’s arguments that an award rendered in China was invalid because there was not a valid agreement to arbitrate, or because he was “unable to present his case” in China, finding that appellant never moved the arbitration panel to delay proceedings or allow him to participate remotely.

  • Northrop Grumman Ship Systems, Inc. v. The Ministry of Defense of the Republic of Venezuela, No. 1:02-CV-00785-HSO-RHW (S.D. Miss. June 4, 2020)
    06/04/2020

    Court granted plaintiff’s request for entry of final judgment on a confirmed arbitration award, finding that plaintiff was entitled to a judgment in the full amount of the award notwithstanding amounts already paid to plaintiff on behalf of defendant.

  • Union Fenosa Gas, S.A. v. Arab Republic of Egypt, No. 1:18-CV-02395-JEB (D.D.C. June 4, 2020)
    06/04/2020

    Court granted defendant’s motion to stay and set aside entry of default and denied plaintiff’s motion for default judgment of an ICSID Award under appeal, finding inter alia that: (1) the possibility that the award will be annulled was more than wishful thinking and (2) the balance of hardships favored defendant due to the burden it would face by having to attack the validity of the award in two forums.

  • Teco Guatemala Holdings, LLC v. Republic of Guatemala, No. 1:17-CV-00102-RDM (D.D.C. June 2, 2020)
    06/02/2020

    Court granted an order for petitioner execute US property of a foreign sovereign under Section 1610(c) of the Foreign Sovereign Immunities Act, finding that a period of six months after the court entered final judgment was sufficient to satisfy the requirement under Section 1610(c) that a “reasonable period of time” pass before execution can be issued.

  • GE Energy Power Conversion France SAS Corp. v. Outokumpu Stainless USA LLC, No. 18-1048 (U.S. June 1, 2020)
    06/01/2020

    Supreme Court an Eleventh Circuit Court of Appeals decision in finding that the New York Convention does not preclude the application of domestic law permitting non-signatories to enforce an international arbitration agreement.  Consequently, Court found that a non-signatory French company could compel arbitration of an Alabama steel plant.

  • Wright v. NH Thornton Place, LLC, No. 2:19-CV-02063-DDC-GEB (D. Kan. June 1, 2020)
    06/01/2020

    Court granted defendant’s unopposed application for order confirming arbitration award finding that neither plaintiff nor the court expressed a reason to vacate the award under Section 10 of the FAA.

  • CPR Management, S.A. v. Devon Park Bioventures, L.P., No. 2:18-CV-01973-CMR (E.D. Pa. May 29, 2020)
    05/29/2020

    Court granted petitioner’s motion to confirm an arbitration award, and denied respondents’ cross motion to vacate, finding that none of the grounds for vacating an award under Section 10 of the FAA applied.  Court found that applying the FAA was appropriate where: (1) the arbitration was brought in the United States and (2) there was no conflict between the New York Convention and the domestic FAA, reasoning that Article V(1)(e) of the New York Convention allows awards to be “set aside or suspended by a competent authority of the country in which that award was made.”  Court refused to impose additional prejudgment interest finding that such interest is not a penalty and that the good or bad faith of a losing party is not of dispositive significance.

  • Kahapea v. Pennymac Loan Services, LLC, No. 1:19-MC-00028-MV (D.N.M. May 29, 2020)
    05/29/2020

    Court dismissed without prejudice petitioner’s action to confirm an arbitration award, finding that petitioner failed to fulfill the jurisdiction requirements of Section 9 of the FAA when he did not demonstrate that the arbitration agreement explicitly or implicitly intended that the parties have a judgment entered on the arbitration award.

  • IMAX Corporation v. Giencourt Investments, S.A., No. 20-10491 (11th Cir. May 28, 2020)
    05/28/2020

    Court of appeals affirmed a district court decision denying appellant’s motion to vacate arbitration awards, finding that appellant failed to carry its burden to establish any defense under the New York Convention or prove that the arbitral tribunal exceeded its powers under the FAA.

  • Teco Guatemala Holdings, LLC v. Republic of Guatemala, No. 19-7153 (D.C. Cir. May 21, 2020) 
    05/21/2020

    Court of appeals denied motion for stay of enforcement of arbitral award, finding appellant did not satisfy the stringent requirements for a stay pending appeal.

  • Ameriprise Financial Services, LLC v. George, No. 1:20-CV-00215-DDD-SKC (D. Colo. May 20, 2020) 
    05/20/2020

    Court granted motion to confirm arbitration award pursuant to the FAA and entered default judgment as defendant never moved to modify or vacate the award.

  • Bogard v. Blackstone, No. 5:20-CV-00080-XR (W.D. Tex. May 20, 2020) 
    05/20/2020

    Court granted defendant’s motion to dismiss plaintiff’s motion to confirm arbitration award.  Court found that a state official sued in her official capacity was entitled to Eleventh Amendment immunity and therefore, court did not have subject matter jurisdiction to consider plaintiff’s motion to confirm the arbitral award.

  • Micula v. Government of Romania, No. 19-7127 (D.C. Cir. May 19, 2020) 
    05/19/2020

    Court of appeals affirmed district court’s order confirming arbitration award against the Government of Romania.  Court of appeals found the district court did not improperly resolve disputes of material fact and did not abuse its discretion by denying Romania’s request for an extension of time on the day its responsive filing was due.

  • Canfornav Inc. v. TDE Group USA Inc., No. 2:19-CV-11906-BAF-DRG (E.D. Mich. May 18, 2020) 
    05/18/2020

    Court granted motion to confirm arbitration award pursuant to the New York Convention, where defendant had not responded to the motion.  Court also granted motion for summary judgment for breach of contract based on defendant’s failure to indemnify plaintiff.

  • Zhejiang Topoint Photovoltaic Co., Ltd. v. G&S Solar Installers, LLC, No. 2:19-CV-16578-KM-JBC (D.N.J. May 15, 2020)
    05/15/2020

    Court granted motion to confirm ICDR arbitration award and denied cross-motion to vacate the award, finding defendant was collaterally estopped from seeking to vacate the award because it had the opportunity to litigate the arbitrability issue and declined to do so.  Court held that the award must be confirmed pursuant to the FAA.

  • Elder v. Albertson’s, LLC, No. 3:19-CV-02464-K (N.D. Tex. Apr. 28, 2020)
    04/28/2020

    Court granted defendants’ motion to confirm an arbitration order awarding summary judgment and denied plaintiff’s motion to vacate.  Court found that plaintiff’s arguments that the arbitrator had exceeded his power by finding plaintiff’s submission to arbitration untimely were waived because they had not been raised to the arbitrator.  Court further found that the arbitrator’s order was “grounded in reason and fact.”

  • Three Brothers Trading, LLC v. Generex Biotechnology Corp., No. 1:18-CV-11585-KPF (S.D.N.Y. Apr. 24, 2020)
    04/24/2020

    Court granted respondent’s motion to vacate an arbitration award, finding that the award was not final and should be remanded when the arbitrator did not fully determine the issue of damages due to post-hearing evidentiary developments.

  • Entes Industrial Plants, Construction and Erection Contracting Co. Inc. v. The Kyrgyz Republic, No. 1:18-CV-02228-RC (D.D.C. Apr. 22, 2020)
    04/22/2020

    Court confirmed petitioner’s motion to confirm an arbitration award against a foreign sovereign that was not a party to the underlying arbitration, finding that: (1) a ministry that was a party to the arbitration was not entitled to a presumption of separateness from the foreign sovereign and (2) the ministry was acting as the foreign sovereign’s agent.

  • Machul v. State of Florida, No. 3:20-CV-00078-WHR-MJN (S.D. Ohio Apr. 8, 2020)
    04/08/2020

    Magistrate judge recommended that plaintiffs’ motion to confirm an arbitration award be denied, finding that court lacked subject matter jurisdiction under the FAA because plaintiff did not show that defendants signed an agreement to arbitrate.  Even if defendants agreed to arbitrate, court found that any confirmation of the alleged arbitral award would have to occur in the district where the award was made.

  • Texas Brine Company, L.L.C. v. American Arbitration Association, Incorporated, No. 18-31184 (5th Cir. Apr. 7, 2020)
    04/07/2020

    Court of appeals affirmed district court’s denial of remand and grant of defendants’ motion to dismiss.  Court of appeals found the non-forum defendant was permitted to remove the case to federal court even when the other defendant was a citizen of the forum state and had yet to be properly served.  It found district court was correct to dismiss plaintiff’s challenge to the AAA, considering the relief requested, purported harm, and alleged wrongdoing showed that the claims were essentially an impermissible collateral attack on the arbitration award.

  • Wells Fargo Bank National Association v. Hyflo Limited Partnership, No. 2:19-CV-02054-GMN-VCF (D. Nev. Apr. 7, 2020)
    04/07/2020

    Court granted motion to confirm arbitration award pursuant to the FAA, as defendant had not moved to vacate, modify or correct the award.

  • Catalina Holdings (Bermuda) Limited v. Muriel, No. 1:18-CV-05642 (N.D. Ill. Apr. 6, 2020) 
    04/06/2020

    Court granted plaintiff’s petition to confirm the arbitral award, holding the tribunal did not exceed its authority.  Court declined to determine whether a party may bring an action under Chapter 1 of the FAA to vacate an award issued by an arbitrator in a U.S. jurisdiction, since both the FAA and the New York Convention allow the defense that the tribunal exceeded its authority.  Court denied plaintiff’s motion for Rule 11 sanctions.

  • CBF Industria de Gusa S/A v. AMCI Holdings, Inc.., No. 1:13-CV-02581-PKC-JLC (S.D.N.Y. Apr. 6, 2020)
    04/06/2020

    Court denied defendants’ motion to partially dismiss the third amended complaint seeking to enforce an arbitration award against defendants, finding the fraudulent transfer claim was not barred by the six-year limitations period because the amendment related back to the initial compliant.

  • OJSC Ukrnafta v. Carpatsky Petroleum Corporation, No. 19-20011 (5th Cir. Apr. 6, 2020) 
    04/06/2020

    Court of appeals affirmed district court’s order affirming $147 million arbitration award against plaintiff-appellant issued by the Stockholm Chamber of Commerce.  Court of appeals held jurisdiction was proper under 9 U.S.C. § 205, and found the plaintiff-appellant’s arguments against recognition failed under the New York Convention, as the signatory had the capacity to bind defendant-appellee to the arbitration agreement, the plaintiff-appellant had waived its argument that the agreement was nonbinding by submitting to the arbitration, the award was not contrary to public policy, and manifest disregard is not a ground for nonrecognition of international arbitral awards.

  • Trina Solar US, Inc. v. Jasmin Solar PTY LTD, No. 17-572-CV (2d Cir. Apr. 2, 2020)
    04/02/2020

    Court of appeals reversed and remanded district court’s confirmation of an arbitration award and denial of a motion for limited discovery on the question of whether a party was bound by the arbitration clause at issue.  District court had found that a nonsignatory was bound to the arbitration agreement through agency theory.  The Second Circuit found that the nonsignatory could not be bound by the arbitration agreement because the contract explicitly excluded it as a party.

  • Morris v. Conifer Health Solutions LLC, No. 3:20-CV-05181-RJB (W.D. Wash. Apr. 2, 2020)
    04/02/2020

    Court granted defendants’ motion to compel arbitration of racial discrimination, harassment, and wrongful termination claims.  Court rejected plaintiff’s arguments that the arbitration agreements were substantively and procedurally unconscionable and found that a valid arbitration agreement governed the dispute.

  • Satcomm v. Paypal, No. 5:19-MC-00010-MTT (M.D. Ga. Apr. 1, 2020)
    04/01/2020

    Court denied petitioner’s motion to confirm an arbitration award, granted respondent’s motion to dismiss and vacate the arbitration award, and awarded respondent attorney’s fees as sanctions for petitioner’s pursuit to confirm a fraudulent arbitration award.  Court found that the respondent met their burden of proving that the arbitration award was procured by fraud and that the entity Satcomm was a sham entity being run by an inmate.

  • Bunge S.A. v. Pacific Gulf Shipping (Singapore) PTE Ltd., No. 3:19-CV-00419-SB (D. Or. Mar. 31, 2020)
    03/31/2020

    Court entered a default judgment to confirm an arbitration award pursuant to the New York Convention.  Court found that it had quasi in rem jurisdiction because the award had been rendered by a court of competent jurisdiction, a London arbitration tribunal, and petitioner sought property within the jurisdiction of the District of Oregon in satisfaction of the judgment.  Court noted that intangible property could support quasi in rem jurisdiction in the state of Oregon.

  • Stumbo, Inc., v. Coin Data, LLC, No. 1:19-CV-00168-GNS (W.D. Ky. Mar. 31, 2020)
    03/31/2020

    Court granted defendants’ motion to compel arbitration and dismiss an action seeking declaratory relief that the arbitration agreement is not enforceable.  Court ignored plaintiff’s argument that the court did not have jurisdiction because defendants could not prove that the amount in controversy was greater than $75,000, finding that in an action seeking declaratory judgment that the parties are not required to arbitrate, the arbitration demand determines the amount in controversy.  Court further found that the arbitration agreements in question adopted the rules of the AAA, and thus they evinced the parties intent to delegate questions of arbitrability to the arbitrator.  Finally, court found that it was immaterial under state law that the plaintiff was an assignee of the contract rather than an original party.

  • Northrop Grumman Ship Systems, Inc., v. The Ministry of Defense of the Republic of Venezuela, No. 1:02-CV-00785-HSO-RHW (S.D. Miss. Mar. 31, 2020)
    03/31/2020

    Court affirmed an arbitration award made in Brazil under Venezuelan arbitration law pursuant to the Panama Convention and the New York Convention.  Court found that it was a court with secondary jurisdiction and was therefore limited in its review to the grounds for refusal of enforcement provided in the conventions.  The court rejected the argument that the award should be vacated under Article V(1)(d) of the Panama Convention because the tribunal did not carry out the procedure in accordance with the terms of the parties agreement when it held the arbitration in Rio di Janeiro.  Court found that the tribunal applied Venezuelan arbitration law which permitted it to choose the location of the arbitration if the parties did not agree.

  • Salerno v. Credit One Bank, N.A., No. 1:15-CV-00516-LJV-LGF (W.D.N.Y. Mar. 31, 2020)
    03/31/2020

    Court denied defendant’s motion to vacate an arbitration award related to violations of the TCPA.  Court rejected defendant’s argument that the award should be vacated because the arbitrators had manifestly disregarded the law by not following recent second circuit precedent, finding that the recent precedent was distinguishable.

  • Foresight Luxembourg Solar 1 S.A.R.L, v. Kingdom of Spain, No. 1:19-CV-03171-ER (S.D.N.Y. Mar. 30, 2020)
    03/30/2020

    Court granted respondent’s motion to transfer the action seeking to confirm an arbitration award to the District Court for the District of Columbia (D.D.C.) and referred all other pending motions to that court.  The award was rendered by the Arbitration Institute of the Stockholm Chamber of Commerce pursuant to the dispute resolution provisions of the Energy Charter Treaty. Petitioner sought to confirm it under the New York Convention while respondent argued that the motion should be stayed pending set aside proceedings in Sweden.  Court reasoned that venue transfer was appropriate because the D.D.C. was designated by congress as the dedicated venue for civil cases involving foreign states, and a transfer would promote judicial economy as there were parallel actions before the D.D.C.

  • Raymond James & Associates, Inc. v. Barlow, No. 3:19-CV-00394-CWR-LRA (S.D. Miss. Mar. 27, 2020)
    03/27/2020

    Court denied motion to vacate and affirmed the award.  Court found that there was no basis for vacating the award, rejecting the argument that the arbitrators manifestly disregarded the law because they did not follow one Mississippi case that favored the respondent in the arbitration.  Court further rejected the argument that an arbitrator’s comment about a state court judge leaving the bench soon was indicative of any bias against respondent.

  • International Energy Ventures Management v. United Energy Group, No. 4:17-CV-02262-LNH (S.D. Tex. Mar. 20, 2020)
    03/20/2020

    Court granted motions to vacate two arbitral awards and to compel arbitration of claims relating to consulting services in connection with the purchase and sale of oil and gas assets in Pakistan.  Court held that the arbitrators acted outside of their authority in deciding whether plaintiff waived arbitration by taking action in the courts in connection with the dispute.  Court then decided that the plaintiff did not waive arbitration by taking steps in the courts and in turn granted plaintiff’s motion to compel arbitration.

  • First National Petroleum Corporation v. OAO Tyumenneftegaz, No. 4:19-CV-00097 (S.D. Tex. Mar. 12, 2020)
    03/19/2020

    Court granted respondent’s motion to dismiss for lack of personal jurisdiction and denied petitioner’s petition to confirm an arbitral award where responded was a Russian oil company subject to an agreement and joint venture in Russia to develop a Russian oil field.  Court found that notwithstanding respondent’s visits to Houston, the “hub of the parties’ activities” was outside of Texas.  Court further found that the New York Convention did not prevent the court from refusing to confirm an award for lack of personal jurisdiction. 

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