We will hear argument first this morning in case 23 1201, C. Davos Morricius, Limited versus Antrix, and the consolidated case.

Mr. Street.

Mr. Chief Justice, and may it please the Court, an arbitral award against a foreign state is worth little if no courts can enforce it.

Congress added the FSIA's arbitration exception to allow U.S. courts to enforce New York Convention

Awards against foreign sovereigns.

The Ninth Circuit's holding that the FSIA requires minimum contacts is atextual and would

gut Congress's purpose.

Antrix has abandoned it, and this Court should reject it.

Antrix's new argument that the arbitration exception requires a nexus with U.S. commerce is waived and meritless.

Congress knew how to require a U.S. commercial nexus, and it did not do so in the arbitration

exception to allow enforcement of all Convention Awards. Antichs' constitutional defense also fails.

Every circuit post-Weltover has correctly held that foreign states are not persons protected

by due process. nor does the Fifth Amendment

reverse incorporate a minimum contacts requirement from the 14th. In any case, Antrix

consented to personal jurisdiction when it agreed to arbitrate under the Convention. I welcome

the Court's questions. Would you elaborate on your point that Antrix's point argument that the arbitration exception requires minimum contact without more?

Yes, Your Honor.

And I would like to first point out that Antrix conceded below. contact without more? Yes, Your Honor.

And I would like to first point out that Antrix conceded below that the arbitration exception applies.

The district court recognized that, and the circuit court recognized that at pages

four and 22 to 23.

Now they are arguing that the arbitration exception, as I understand it, by its own

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