Arbitration analysis: The Ninth Circuit held that the arbitration exception to foreign sovereign immunity gave the federal courts subject matter jurisdiction to confirm a New York Convention award against an Indian state-owned corporation, without any additional requirement for a commercial nexus with the US. Assuming without deciding that Fifth Amendment protections applied, personal jurisdiction was reasonable. The court also held, as a matter of first impression in the circuit, that forum non conveniens is unavailable in New York Convention confirmation proceedings. The decision materially limits jurisdictional and forum-based objections to enforcement, while leaving certain constitutional questions and the effect of the subsequent Indian set-aside proceedings unresolved. Produced in partnership with Akin M. Alcitepe Partner at Rimon Law.