Morgan Stanley requested confirmation of the arbitration Award and moved for judgment on the pleadings, arguing that misconduct by Plaintiff's lawyer is not grounds for vacatur. The Court agrees with Morgan Stanley, and confirms the Award. Rather than punishing Morgan Stanley, which had no role in the alleged "fraud or undue means," the Court notes the limited circumstances set out in the Federal Arbitration Act ("FAA") for vacatur and concludes that allowing Plaintiff to proceed would invent an entirely new ground for vacatur not present in the FAA.