Whether the D.C. Circuit correctly held that: (1) all 160 signatories to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (i.e., the New York Convention) waived their sovereign immunity because they "must have contemplated arbitration-enforcement actions in other signatory countries"; and (2) a petitioner enforcing an arbitral award may invoke the waiver exception without making the more specific showings required by the arbitration exception.

Whether the D.C. Circuit correctly held that: (1) all 160 signatories to the Convention on the Recognition and Enforcement of Foreign Arbitral Awards (i.e., the New York Convention) waived their sovereign immunity because they 'must have contemplated arbitration-enforcement actions in other signatory countries; and (2) a petitioner enforcing an arbitral award may invoke the waiver exception without making the more specific showings required by the arbitration exception