The court in Sulamérica held that the starting assumption at stage two is that the governing law of the arbitration agreement is the same as the substantive law. Of course, it should be noted that in Sulamérica the court did, in fact, find the substantive law (Brazilian law) was not the law of the arbitration agreement, which called for arbitration seated in London (with the court holding that English law (the curial law) governed the arbitration agreement).