Introduction

The U.S. Supreme Court recently held in Hall Street Associates, LLC v. Mattel, Inc. , 128 S. Ct. 1396 (2008) (" Hall Street "), that the grounds stated Sections 10 and 11 of the Federal Arbitration Act ("FAA") for vacating or modifying arbitral awards are exclusive, and that parties may not contractually alter or expand those grounds. While Hall Street concerned a domestic arbitral award subject to Chapter 1 of the FAA, the decision has clear implications for international arbitral awards subject to Chapters 2 (New York Convention) and 3 (Panama ...