A collection of the most recent U.S. international arbitration decisions is available here. Decisions can be quickly retrieved by using the filter tools below.
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Song v. Que, No. 24-4129 (9th Cir. July 10, 2025)07/10/2025
Court of Appeals affirmed district court’s confirmation of foreign arbitration award, holding that appellant failed to establish a defense under Article V of the New York Convention. Court of Appeals found that appellant had entered into a valid arbitration agreement, had received sufficient notice of the arbitration proceedings, and that enforcement of the award would not violate public policy.
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Menzies Middle East and Africa SA v. Republic of Niger, No. 24-CV-00466-ABJ (D.D.C. July 3, 2025)07/03/2025
Court granted petitioner’s motion to enter default judgment and confirm ICSID arbitration award issued against Niger. Court found that it had jurisdiction over Niger pursuant to the ICSID convention and the FSIA arbitration exception, and that proper service was effected through the Head of the Ministry of Foreign Affairs of Niger. Court granted default judgement and awarded petitioner the value of arbitration award and interest.
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Molecular Dynamic, Ltd. v. Spectrum Dynamics Medical Limited, No. 24-2209 (2d Cir. July 2, 2025)07/02/2025
Court of appeals affirmed district court’s dismissal of a petition to vacate an arbitral award issued by a foreign tribunal, concluding that the court lacked subject matter jurisdiction under Chapter 2 of the FAA. Court of appeals held that a vacatur action directed at a foreign award does not fall under the New York Convention, and therefore that 9 USC § 203 does not supply subject matter jurisdiction to the district court. Court of appeals concluded that the New York Convention “specifically envisions” that vacatur proceedings be decided in the country in which or under the law of which the award was made.
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Ma v. Fang, No. 8:21-CV-00441-MCS-ADS (C.D. Cal. June 24, 2025)06/24/2025
Court denied respondent’s Rule 60(b)(5) motion for relief from a judgment confirming a foreign arbitral award, declining to consider newly proffered evidence. Noting that no authority in the award’s primary jurisdiction had annulled the decision, the court concluded that revisiting the merits would undermine international comity, contravene the New York Convention, and raise other prudential concerns.
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Metropolitan Municipality of Lima v. Rutas de Lima S.A.C., No. 1:20-CV-02155-ACR (D.D.C. June 20, 2025)06/20/2025
Court dismissed motion to stay judgment pending appeal, finding that municipality did not make a strong showing that it was likely to prevail on appeal, monetary judgements are not irreparable, and the public interest supports efficient process for recognizing and executing arbitral awards. Court also held that repeated assertions by municipality that they would not pay award made request for stay a dilatory tactic designed to delay payment.
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Olive Group FZ-LLC v. Afghanistan Civil Aviation Authority, No. 1:24-CV-02170-SLS (D.D.C. June 12, 2025).06/12/2025
Court granted petitioner’s motion for default judgment and confirmed arbitration award. Court found it had personal jurisdiction and that petitioner’s alternative service by email on respondent Afghanistan was proper, after conventional service methods through mail and diplomatic channels were unavailable.
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Yukos Capital Limited v. The Russian Federation, No. 22-CV-00798-CJN (D.D.C. June 11, 2025)06/11/2025
Court denied respondent’s motion to dismiss, motion to stay, and supplemental motion to stay. Court found it had subject matter jurisdiction pursuant to Energy Charter Treaty’s arbitration article and personal jurisdiction following petitioner’s service through diplomatic channels. Court further rejected respondent’s motion to stay, determining that pending cases cited by respondent were not relevant.
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Eurofinsa, S.A. v. The Gabonese Republic, No. 23-CV-03013-RC (D.D.C. June 11, 2025)06/11/2025
Court granted petitioner’s motion to attach assets following recognition of arbitral award. Court determined that respondent had received proper notice of a default judgment and that a reasonable period of time had elapsed since the judgment, during which respondent had made no effort to pay.
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Archirodon Construction (Overseas) Company Limited v. General Company for Ports of Iraq, No. 22-CV-01571 (D.D.C. June 10, 2025)06/10/2025
Court granted petitioner’s motion for contempt and ordered respondents to pay $15,000 per day in sanctions. Court found that respondents had not complied with post-judgment asset discovery orders and that sanctions were appropriate, as all other measures to ensure compliance were exhausted.
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CC/Devas (Mauritius) Ltd. v. Antrix Corp. Ltd., No. 23–1201 (U.S. June 5, 2025)06/05/2025
Supreme Court reversed and remanded a decision by the Ninth Circuit, which held that the district court lacked personal jurisdiction to confirm an arbitral award in a dispute involving a foreign state. Court clarified that, under the FSIA, personal jurisdiction does not require a minimum contacts analysis. Instead, the Court held that personal jurisdiction exists, if one of the exceptions to immunity enumerated in the FSIA applies and the plaintiff effectuated proper service.
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AAK USA, Inc. v. Integrity Ingredients Corporation, No. 1:25-CV-01727-JGK (S.D.N.Y. May 29, 2025)05/29/2025
Court granted petition to confirm arbitration award pursuant to 9 USC § 9, holding that there was no genuine dispute of material fact. Court found that its role in reviewing an award is limited—the award is to be confirmed even if there is a “barely colorable justification” for the decision.
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Penneco Oil Company, Inc. v. K. Petroleum, Inc., No. 25-CV-00121-WSH (W.D. Pa. May 21, 2025)05/21/2025
Court granted plaintiffs’ motion to require defendant to post a security bond during proceedings to confirm or vacate the underlying arbitration award. Court found Local Rule 67.1(B) gave it discretion to order such a bond to protect against potential asset dissipation and found no justification to disregard the local rule or evidence of prejudice to defendant.
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Happy CP Company Ltd. v. LB Accessories LLC, No. 2:24-CV-02274-TLN-JDP (E.D. Cal. May 19, 2025)05/19/2025
Magistrate judge recommended granting petitioner’s motion for default judgment to confirm a foreign arbitration award after respondents failed to appear or respond. Magistrate judge found the award enforceable under the New York Convention and FAA, recommended that petitioner’s request for attorney’s fees and costs be denied without prejudice, and recommended entering judgment in the amount of the award.
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The Republic of Nicaragua v. The Lopez-Goyne Family, No. 3:24-CV-03104-MMC (N.D. Cal. May 5, 2025)05/05/2025
Court granted petitioner’s motion for partial summary judgment on the issue of respondents’ joint and several liability for costs awarded by the arbitral tribunal. Respondents argued costs were owed severally and petitioner should seek clarification of the award using Article 50 of the ICSID Convention. Court held that the tribunal’s language directing the award of costs was consistent with an intent to impose joint and several liability and found no ambiguity requiring clarification from the arbitral tribunal.
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ICM Investment Partners II, LLC v. 360 Commercial Real Estate, LLC, No. 1:25-CV-00937-JAV (S.D.N.Y. May 1, 2025)05/01/2025
Court granted petition to confirm arbitral award, finding petitioner met its burden of showing there was no genuine issue of material fact which would preclude summary judgment on the petition, because the arbitrator’s decision provided more than “a barely colorable justification” for the outcome reached. Court also found no justification under §10(a) of the FAA for vacating the award. Court dissolved the automatic stay on execution of the judgment under Federal Rule of Civil Procedure 62(a) because petitioner established a credible fear that respondents may dissipate assets to avoid enforcement of the judgment.
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Xu v. Zhuang, No. 24-CV-08671-RGK-BFM (C.D. Cal. May 1, 2025)05/01/2025
Court granted Xu’s petition for confirmation of an arbitral award granted by the Shenzhen Court of International Arbitration under the NY Convention, finding no basis to conclude that the arbitrator made a mistake of law or fact, or that such a mistake could rise to the level of offending public policy.
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US Trinity Energy Services, L.L.C. v. Southeast Directional Drilling, L.L.C., No. 24-10833 (5th Cir. April 28, 2025)04/28/2025
Court of appeals affirmed the district court’s denial of the petition to vacate an arbitration award under 9 USC §10(a)(4) and grant of respondent’s motion to confirm the award. Court found petitioner failed to show the arbitration panel exceeded its powers and held that “manifest disregard of the law” is not a basis for vacatur under §10(a)(4).
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Zhuhai Dingfu Phase I Industrial Energy Conservation Investment Fund, LP v. Zhang, No. 8:23-CV-02059-MRA-JDE (C.D. Cal. April 25, 2025)04/25/2025
Court granted in part and denied in part respondent’s motion to amend findings and judgment and denied respondent’s motion for stay of execution of judgment as moot. Court amended the judgment to order post-judgment interest at the rate in 28 USC § 1961(a) but declined to allow discovery on the amount petitioner collected from respondent’s assets in China and declined to amend based on what respondent described as newly discovered evidence of duress.
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Madison Pacific Trust Limited v. Groza, 25-CV-00642-PKC (S.D.N.Y. Apr. 10, 2025)04/10/2025
Court granted petitioner’s application to serve respondents via alternative means under Federal Rule of Civil Procedure 4 for purposes of initiating proceedings to confirm an arbitral award. Court found that petitioner had demonstrated that respondents’ physical whereabouts were unknown and could not be ascertained with reasonable diligence, and serving respondents by email was reasonably calculated to satisfy due process requirements. Court also directed delivery of service papers to addresses listed on court filings in parallel proceedings.
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J&J Empire Express, Inc. v. FedEx Ground Package System, Inc., 1:24-CV-01200-MKV (S.D.N.Y. Apr. 9, 2025)04/09/2025
Court denied petition to vacate an arbitration award and confirmed the award, holding that petitioner had not demonstrated that the arbitrator committed manifest disregard for the law in issuing the award.
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Shanghai Liyu Optoelectronics Co., Ltd. v. Brite Lite Tribe, LLC, 9:24-CV-80690-RLR (S.D. Fla. Apr. 8, 2025)04/08/2025
Court granted a petition to confirm an arbitral award under the New York Convention based on the court’s factual findings following an evidentiary hearing that petitioner properly served respondent and legal conclusion that the underlying award dealt with matters within the scope of the arbitration.
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Webuild S.p.A. v. Argentine Republic, 1:21-CV-02464-RBW (D.D.C. Apr. 4, 2025)04/04/2025
Court granted plaintiff’s motion for judgment on the pleadings and confirmed an ICSID arbitral award, holding that it had personal jurisdiction over defendant, subject matter jurisdiction under the Foreign Sovereign Immunities Act, and the award was authentic.
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The Government of the Lao People’s Democratic Republic v. Baldwin, No. 1:22-CV-00011 (D.N. Mar. Is. April 3, 2025)04/04/2025
Court granted respondents’ motion to dismiss for lack of subject matter jurisdiction. Court accepted respondents’ argument that the Government of Laos’ petition to enforce an arbitration award against them was premature, as respondents were not parties to the underlying arbitration and a determination of whether respondents could be held liable as alter egos was inappropriate in the context of an action to confirm an arbitration award.
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Port of Vancouver USA v. BNSF Railway Co., No. 24-CV-06033-DGE (W.D. Wash. Mar. 26, 2025)03/26/2025
Court granted plaintiff’s motion to confirm an arbitration award, holding that the ambiguity grounds outlined in the FAA to vacate the award did not apply because the arbitration panel provided, upon remand, necessary clarifications to a previously judicially unenforceable award. Court also found that the panel did not exceed its authority by redetermining issues previously decided because it was responding to a court order requiring it to add specificity to its original award.
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Norman Intertrade Ltd. v. Bon-Woong Koo, No. 24-CV-02422-HSG (N.D. Cal. Mar. 24, 2025)03/24/2025
Court granted plaintiff’s petition to confirm an arbitration award, holding that the award fell under the New York Convention because it arose out of a commercial relationship between non-US parties. Court reasoned that defendants failed to meet their substantial burden to show that a defense to the enforcement of the award applied because they did not oppose the petition.
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Phillips v. Galisky, No. 24-CV-00158 (S.D.W. Va. Mar. 24, 2025)03/24/2025
Court granted a petition to confirm an arbitration award, holding that none of the grounds for vacatur under the FAA applied. Court found that the arbitrator did not exceed his powers, finding that there was no error in the arbitrator including entities not subject to the agreement in the award, rather, the award was simply unenforceable with regard to those entities.
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AKF Inc. v. Skybell Technologies Inc., No. 24-CV-02271-LTS (S.D.N.Y. Mar. 24, 2025)03/24/2025
Court granted a petition to confirm an arbitration award, holding that none of the FAA grounds for vacatur applied. Court found that the public policy exception would only apply when the enforcement of an award constituted a predatory loan, not where, as here, respondents’ claim that the underlying contract was invalid, which was for determination of the arbitrator. Court also found that the award did not exhibit a manifest disregard of law simply because respondents disagreed with the arbitrator’s interpretation and application of legal precedent.
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Leviathan Group LLC v. Delco LLC, dba Delco Products, No. 24-1547 (6th Cir. Mar. 21, 2025)03/21/2025
Court of appeals denied defendant-appellant’s motion to vacate district court’s order confirming arbitration award, holding that the arbitrator was acting within the scope of her authority. Court of appeals reasoned that where parties have bargained for an arbitrator—and not federal judges—to decide their dispute, legal or interpretive errors by arbitrators must be tolerated if the arbitrator has arguably construed the agreement. Court further found that where the arbitration agreement does not require the arbitrator to explain her decision, courts will not vacate an award for failure to provide such an explanation.
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World Media Alliance Label, Inc. v. Ello Entertainment Group, LLC, No. 23-CV-21985-FAM (S.D. Fla. Mar. 21, 2025)03/21/2025
Court denied petitioner’s renewed motion for contempt based on respondent’s failure to satisfy an arbitration award confirmed by the court. Court found that under binding Eleventh Circuit precedent, court orders confirming arbitral awards operate as final monetary judgments because they require the payment of a definite sum of money. Because monetary judgments fall outside the court’s contempt power, court held that the appropriate process to enforce the award was a writ of execution, not a finding of contempt.
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Btesh v. Btesh, No. 23-CV-23679-JB (S.D. Fla. Mar. 21, 2025)03/21/2025
Court granted respondent’s motion to dismiss petition to confirm and enforce an arbitration award under the Inter-American Convention, finding it did not have personal jurisdiction over the respondent. Court reasoned that petitioner could not plead sufficient facts to demonstrate a connection to the forum to establish specific or general personal jurisdiction, or jurisdiction pursuant to Federal Rule of Civil Procedure 4(k)(2). Moreover, Section 9 of the FAA did not provide an independent basis for personal jurisdiction.
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Spineway SA v. Strategos Group, LLC, No. 24-1584 (3d Cir. Mar. 18, 2025)03/18/2025
Court of appeals affirmed district court’s order denying petition to confirm a foreign arbitration award because the arbitrator was not selected in accordance with the parties’ agreement. Court of Appeals found that, despite a reference to the non-existent Geneva ICC in their agreement, the parties intended the ICC, not the Swiss Chambers’ Arbitration Institution (SCAI), to select the arbitrator and intended for the ICC rules to govern. Since the arbitrator was selected under SCAI rules, in contravention of the parties’ agreement, the district court properly refused to confirm the award under the New York Convention.
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Teleport Mobility, Inc v. Sywula, No. 21-CV-00874-SI (N.D. Cal. March 18, 2025)03/18/2025
Court granted plaintiff’s motion to lift the stay proceedings, denied defendant’s motion to vacate the award, and confirmed the arbitration award in part but held it did not have jurisdiction to confirm the award in full. Court held it only had jurisdiction over the portions of the award concerning issues and parties previously before the court, and that the other portions of the award would need to be confirmed by a state court judge.
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Zhongtie Dacheng (Zhuhai) Inv. Mgmt. Co. Ltd. v. Yan, No. 24-736 (9th Cir. Feb. 27, 2025)02/27/2025
Court of Appeals vacated district court judgment granting petition to enforce award against respondents under the New York Convention, explaining the “district court failed to show its work” in making the required factual findings to support confirmation of the award, including whether the agreement containing the arbitration clause was forged.
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Flintlock Construction Services, LLC v. Arch Specialty Insurance Company & Catlin Specialty Insurance Company, No. 24-791 (2d Cir. Feb. 21, 2025)02/21/2025
Court of Appeals affirmed district court’s denial of petitioner’s request to vacate arbitration award. Court of Appeals found the arbitration panel did not exceed its authority in its interpretation of the underlying agreement and that the panel’s decision was not irrational because it reflected the “plain meaning” of the underlying agreement.
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Global Voice Group SA v. Republic of Guinea, No. 22-CV-2100-JMC (D.D.C. Feb. 18, 2025)02/18/2025
Court granted defendant’s motion to set aside default judgment, finding there existed “good cause” because of the timing of the appearance of defendant’s counsel and noting the D.C. Circuit’s strong presumption against default judgments against a foreign sovereign. Court also found that it lacked subject matter jurisdiction, finding no jurisdiction existed under the FSIA arbitration exception in the absence of evidence that defendant was party to the relevant arbitration agreement or that it delegated arbitrability to the arbitration tribunal.
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Catalent Pharma Solutions, LLC v. Romark Global Pharma, LLC, No. 24-MC-00445-ADC (D.P.R. Feb. 13, 2025)02/13/2025
Court granted petitioner’s motion to confirm arbitration award pursuant to the FAA. Court found that respondent waived the right to vacate award by failing to comply with court’s order to properly oppose petitioner’s motion. Court also found that, even if respondent’s arguments for vacatur had not been waived, vacatur would not have been granted since respondent failed to show that the arbitral tribunal committed an error in rendering a final and complete award.
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Sigma Constructores, S.A. v. Republic of Guatemala, No. 22-CV-01674-TSC-MAU (D.D.C. Feb. 13, 2025)02/13/2025
Magistrate judge recommended denial of respondent’s motion to dismiss petitioner’s action to confirm three foreign arbitration awards, rejecting respondent’s argument that court lacked subject matter jurisdiction under the New York Convention and the Foreign Sovereign Immunities Act. Magistrate judge further rejected respondent’s argument that the action should be dismissed based on forum non conveniens, finding that no adequate alternative forum outside of the US existed. Lastly, magistrate judge rejected respondent’s request for dismissal under the principles of international comity, because respondent failed to cite any binding precedent supporting this assertion.
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Walgreen Co. v. PWNHealth, LLC d/b/a Everly Health Solutions, No. 24-CV-00357-RGA (D. Del. Feb. 10, 2025)02/10/2025
Court denied petitioner’s motion to vacate arbitral award under the FAA because the arbitrator neither exceeded his authority nor exhibited manifest disregard for the law. Court also denied petitioner’s alternative request to modify the award, finding that the award did not contain any evident material miscalculation, nor was it completely irrational. Court granted respondent’s cross-motion to confirm the award.
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Etrak İnşaat Taahhüt Ve Ticaret Anonim Şirketi v. State of Libya, 22-CV-864-JMC (D.D.C. Feb. 4, 2025)02/04/2025
Court granted plaintiff’s motion to confirm an arbitration award against defendant. Court found it had jurisdiction under the Foreign Sovereign Immunities Act’s arbitration exception, as well as personal jurisdiction, and determined that confirming the arbitration award would not violate public policy. Court concluded that it had no authority to stay the case under the New York Convention, where confirmation proceedings were pending in Turkey and Curaçao but no set aside proceedings were ongoing at the seat.
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McEachern v. E.R.J. Insurance Group, Inc., 23-13298 (11th Cir. Jan. 31, 2025)01/31/2025
Court affirmed the district court’s vacatur of an arbitral award, reasoning that the process for appointing arbitrators did not comply with the terms of the underlying arbitration agreement.
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Huarong Tianze (Hong Kong) Investment Partnership v. Huang, 1:24-CV-06502-ALC (Jan. 30, 2025)01/30/2025
Court entered judgment confirming a foreign arbitration award issued by CIETAC and granting monetary damages, interest, and fees.
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Safran Electronics & Defense SAS v. Exail SAS, 1:24-CV-02325-JPO (S.D.N.Y. Jan. 29, 2025)01/29/2025
Court granted respondent’s motion to dismiss a petition to vacate an arbitration award as untimely under the FAA. Court reasoned that petitioners did not properly serve respondents—despite attempting to do so by email—within the three-month period required under the FAA, and equitable tolling was not available to avoid the limitations period.
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ARDU Tech Ltd. v. DS Games, Inc., No. 1:24-CV-00901-MN (D. Del. Jan. 28, 2025)01/28/2025
Court granted petition to confirm arbitration award, finding the award met all the requirements of the New York Convention and FAA. Court further granted motion for entry of default judgment where respondent failed to appear, and plaintiff would be substantially prejudiced and unlikely to recover without a default judgment in place.
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Bluegreen Vacations Unlimited, Inc. v. T. Park Central LLC, No. 1:24-CV-08009-JMF (S.D.N.Y. Jan. 28, 2025)01/28/2025
Court dismissed petition to confirm arbitration award, finding an interim award which did not fully dispose of all the issues in the arbitration, was not a final award that the court could enforce under the FAA.
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McEnery v. McEnery, No. 4:21-CV-09614-HSG (N.D. Cal. Jan. 28, 2025)01/28/2025
Court granted defendants’ motion to confirm arbitration award and request for attorneys’ fees, and denied plaintiff’s request to vacate the award. Court found plaintiff’s argument that the arbitrator erred in its decision because it did not consider plaintiff’s additional valuation evidence was untimely, and the record reflected the arbitrator did in fact review the additional evidence.
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Glass-Inspiration GMBH Design + Engineering v. M.G. McGrath, Inc. Glass & Glazing, No. 24-CV-03315-LPM-DLM (D. Minn. Jan. 27, 2025)01/27/2025
Court granted petitioner’s motion to confirm arbitration award and denied respondent’s request to deny confirmation of the award on public policy grounds. Court reasoned that respondent’s public policy argument was forfeited, where it was not first raised in the underlying arbitration, and failed on the merits where petitioner initiated a dispute within the appropriate timeframe following respondent’s notice of dissolution. Court further awarded petitioner’s reasonable attorneys’ fees because respondent did not seek to set aside the award and failed to show a substantial justification for refusal to comply with the award.
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Li v. Lu, No. 3:24-CV-05604-DGE (W.D. Wash. Jan. 27, 2025)01/27/2025
Court granted motion for default judgment and petition to confirm a foreign arbitration award, where defendant failed to appear. Applying the Eitel factors, court found that default judgment was appropriate, entered default judgment, and confirmed the arbitration award.
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Hogan Lovells US LLP v. Islamic Emirate of Afghanistan, No. 1:24-CV-05541-AS (S.D.N.Y. Jan. 24, 2025)01/24/2025
Court granted petition to confirm arbitration award where respondents failed to respond to the petition or otherwise seek relief from the award. Treating the petition as a motion for summary judgment, court found there was no issue of material fact, the arbitrator provided more than a “barely colorable justification” for the decision, and there were no grounds to vacate the award under § 10 of the FAA. Additionally, court granted petitioner’s requested fees and costs, along with pre-judgment interest as set by the arbitrator. In awarding post-judgment interest, court found it was bound by 28 USC § 1961(a), and not by the arbitrator’s decision.
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Zhuhai Dingfu Phase I Industrial Energy Conservation Investment Fund, LP v. Zhang, No. 8:23-CV-02059-MRA-JDE (C.D. Ca. Jan. 21, 2025).01/21/2025
Court granted petitioner’s motion for recognition and enforcement of foreign arbitral award, finding that the petitioner had submitted an authentic arbitration award to the court; that notice was sufficient because a subsidiary—for whom the respondent was the controller and legal representative—participated in the arbitration proceedings and respondent appeared to be aware of this participation. Court further dismissed respondent’s defenses that he could not adequately participate in the proceedings due to COVID-19 travel restrictions, finding that respondent did not adequately prove that remote appearances or appearance through counsel were unavailable. Court also found respondent’s duress defense unpersuasive, noting the respondent did not make any effort to repudiate the contract until now.
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Charleston Immersive/Interactive Media Studio, LLC v. Aydin, No. 1:24-CV-04943-PAE (S.D.N.Y. Jan. 16, 2025)01/16/2025
Court granted defendant’s motion for a protective order, denied plaintiff’s cross-motion to compel production of certain evidence, and denied plaintiff’s motion to disqualify defendant’s counsel in an action seeking vacatur of an arbitral award. Court found that it did not have a basis to second-guess the arbitrator’s evidentiary ruling on an issue of attorney-client privilege.