1. Whether, consistent with the Fourteenth
Amendment of the United States Constitution and the
Federal Arbitration Act, a state court may extend the
claim preclusion doctrine to deprive a nonparty of its
day in court and extinguish its contractual claims based
on a prior arbitration award where the tribunal had no
jurisdiction over the nonparty, its contracts, or its claims.

2. Whether, consistent with the Fourteenth
Amendment of the United States Constitution and the
due process limitations established by this Court, a
state court may extend the claim preclusion doctrine to
deprive a nonparty of its day in court and extinguish its
contractual claims by finding an exception to nonparty
preclusion based on corporate affiliation and overlapping
rights and interests, where the nonparty's rights and
interests were not represented and its claims were not
resolved in the prior action.

Whether a state court may extend claim preclusion to deprive a nonparty of its claims based on a prior arbitration award without jurisdiction, and whether such extension violates due process