Following similar decisions in other circuits, this decision holds that the grounds for vacating an award under section 10 apply to international arbitration awards under the Convention on Recognition of Foreign Arbitral Awards (9 USC 201 et seq.).  9 USC 10(a)(4) allows a court to vacate an arbitration award if the arbitrators exceed their powers–which the arbitrators do only if the award exhibits a manifest disregard of law or is completely irrational.  To demonstrate manifest disregard, the party seeking to vacate the award must show that the arbitrator articulated the correct legal rule but then refused to follow it.  An award is completely irrational if it ignores controlling terms of the parties’ contract.  Here, even if FeeDX offered a better interpretation of the parties’ contract, the arbitrators’ decision based on a different, but still plausible, interpretation still drew its essence from the contract and thus was not irrational.  The arbitrators did not cite a statute FeeDX’s briefs argued was applicable, so their decision did not manifestly disregard the statute, it implicitly found the statute inapplicable which was at most an error of law.