Enka did not respond to Chubb Russia, communicating instead with Unipro and rejecting that it was responsible for the scope of relevant works. Despite the arbitration agreement, in May 2019 Chubb Russia commenced proceedings in the Moscow Arbitrazh Court against Enka and 10 co-defendants (the "Russian Proceedings"). In response, Enka issued an Arbitration Claim Form in the Commercial Court in London seeking a declaration that Chubb Russia was bound by the arbitration agreement in the subcontract, and an anti-suit injunction restraining Chubb Russia from continuing the Russian Proceedings. The issues to be determined by the court included: The trial judge, Baker J., declined to reach a decision on the proper law of the arbitration agreement, but indicated that it was "strongly arguable" that it should be Russian law.