Numerous federal circuit and district courts have held that, for foreign arbitral awards to be enforced in the United States there must be, in addition to subject-matter jurisdiction under Chapter 2 of the Federal Arbitration Act, personal jurisdiction over the award debtor or quasi in rem jurisdiction to the extent of the debtor's property in the jurisdiction. See Frontera Res. Azer. v. State Oil Co. of the Azer. Republic, 582 F.3d 393 (2d Cir. 2009). A Circuit Court has recently addressed whether, in considering relevant contacts with the forum in a specific personal jurisdiction analysis, courts should analyze the contacts relating to the arbitration or those concerning the transaction underlying the arbitration out of which the award arose. This is the issue we discuss in today's column.