So how can courts balance jurisdictional due process concerns with an openness to enforcing arbitration awards? The answer can be found in the proper framing of award recognition and enforcement proceedings in the first place. At a basic level, the Webuild court found there was an insufficient nexus between Webuild U.S. and SCMS's claims in the underlying arbitration. 4 But that is a puzzling framing of a recognition and enforcement proceeding. To the contrary, as the U.S. Court of Appeals for the D.C. Circuit explained mere months ago, "[c]onfirmation proceedings [under the New York Convention]. .. are not vehicles to relitigate issues in the arbitration." 5 In other words, the issues presented by confirming an award are not the same as the issues raised by the dispute that led to the award.