Professor Robert Bird discussed the unclear future of arbitration awards after a primary jurisdiction of injury vacates the award and refuses its enforcement. The Washington D.C. Circuit Court refused to enforce the arbitration award in Termorio due to fundamental and policy considerations. In contrast, the court in Chromalloy enforced the arbitration award in the enforcing jurisdiction. Neither of these cases is widely accepted, leaving a wide ambiguity on this topic. There remains a strong need for a coherent rule of law so that a party does not choose a jurisdiction based on its enforcement law. For example, French law gives no deference to the first jurisdiction that set the arbitration award aside. This causes vast unpredictability and defeats the purpose of arbitration: clear recovery in the event of party conflict.