A number of pervasive issues abound in the task of civil procedure; one of them is personal jurisdiction. "In International Shoe, the Supreme Court held that the courts of a state may exercise personal jurisdiction over a defendant if she has such minimum contacts with the state that it would be fair to require her to return and defend a lawsuit in that state" (Glannon, 2008)
"[footnoteRef:11] Excluded by Article 2(1) from the Convention agreements are those entered into between consumers or between a consumer and a business as well as agreements that are in regards to "individual or collective contracts of employment."[footnoteRef:12] (Garnett, 2009, p
63] (1) It is detached from the procedural rules of the place of arbitration, (2) It is detached from the procedural rules of any specific national law, (3) It is detached from the substantive law of the place of arbitration, (4) It is detached from the national substantive law of any specific jurisdiction.[footnoteRef:50] (Janicijevic, 2003, p