Summary

This is an action pursuant to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards, June 10, 1958, 21 U.S.T. 2517, 330 U.N.T.S. 38 ("New York Convention"), codified in Chapter 2 of the Federal Arbitration Act ("FAA"), see 9 U.S.C. § 201, for recognition and confirmation of the final and binding arbitration award rendered on May 27, 2020 against India by a tribunal sitting in Geneva, Switzerland ("Tribunal") under the auspices of the Permanent Court of Arbitration ("PCA"). See Boykin Decl. Ex. 1, Deutsche Telekom AG v. The Republic of India, PCA Case No. 2014-10, Final Award (May 27, 2020) ("Award"). Petitioner seeks to enforce the Award against India's wholly-owned and controlled national airline, Air India, as the alter ego of India. In addition, Petitioner seeks declaratory relief pursuant to 28 U.S.C. § 2201 and the Federal Rule of Civil Procedure 57 to determine and resolve an immediate and actual controversy regarding the relationship between India and Air India, and in particular, for a determination that Air India is the alter ego of India.