An arbitration award may be set aside if “procured by corruption, fraud or other undue means.” (CCP 1286.2(a)(1).) This decision holds that the opponent’s citing a statute that wasn’t effective until after the events giving rise to the arbitrated claims is not an undue means because the losing party had ample opportunity at and after the arbitration hearing to bring the inapplicability of the statute to the arbitrator’s attention. Moreover, to vacate the award, the losing party must also demonstrate a nexus between the award and the alleged undue means used to attain it. Here, the losing party couldn’t do so because the cited statute was relevant to only one of six reasons the arbitrator gave for the award. And the award is presumed to be correct and not based on the undue means unless the losing party shows otherwise–which is often difficult because an arbitrator need not give reasons for the award.