A precedential opinion by the U.S. Court of Appeals for the Third Circuit remanded a case to the district court to assess whether email correspondence between the two parties constituted a valid arbitration agreement under an international treaty permitting recipients of foreign awards to petition U.S. district courts for confirmation.

The appellant, Jiangsu Beier Decoration Material, a China-based flooring products manufacturer, won an arbitration award in China against appellee, Angle World, a Pennsylvania-based distributor. In 2016, the parties agreed that Angle World would serve as Jiangsu’s distribution agent in the U.S., according to the opinion.