AAK USA, Inc. v. Integrity Ingredients Corporation, 1:25-cv-01727

This case involves a petition to confirm an arbitration award under the Federal Arbitration Act, following a dispute over a contract for product purchases dated April 1, 2022.
Petitioner claimed respondent failed to pay for delivered products, constituting a breach of contract.
The petitioner filed a Demand for Arbitration in June 2023, including breach of contract and unjust enrichment claims.
Respondent did not respond to the arbitration demand or participate in proceedings.
The arbitrator awarded petitioner $1,203,598.89 plus 12% interest and $65,427.40 in attorney’s fees and costs on September 17, 2024.
The respondent also failed to respond to the petition to confirm the award in federal court, despite extensions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Confirm arbitration award	Award is valid and enforceable; no basis to vacate under the FAA	No response or participation	Court confirms award; finds no material fact in dispute
Standard of review for confirmation	Court review is limited—award must be confirmed unless vacated, modified, or corrected per FAA	No response	Limited review applies; award must be confirmed
Adequacy of evidentiary record	Adequate documentation submitted to arbitrator supports award	No response	Sufficient record supports confirmation
Effect of non-response	Non-response does not entitle to automatic default, but the record supports summary judgment	No response	Treats as summary judgment motion; grants confirmation

D.H. Blair & Co. v. Gottdiener, 462 F.3d 95 (2d. Cir. 2006) (motions to confirm or vacate arbitration awards are treated like summary judgment motions based on the record)
Willemijn Houdstermaatschappij, BV v. Standard Microsystems Corp., 103 F.3d 9 (2d. Cir. 1997) (arbitration awards are confirmed if there is even a barely colorable justification)
Porzig v. Dresdner, Kleinwort, Benson, N.A. LLC, 497 F.3d 133 (2d. Cir. 2007) (judicial review of arbitration awards is extremely limited)