Unlike the New York Convention, the original model law deals specifically with interim measures because it authorizes a court to order interim measures. However, it does not concern itself with the application of such measures, but leaves it possible for national courts to provide assistance in this regard or not. The model law was updated in 2006 to address, among other things, the enforceability of intermediate arbitration measures. The amended model law authorizes courts to grant interim protections in the form of an arbitration award and in „another form,“ and provides that measures such as any other arbitration award are binding and enforceable. Except that, if in the form of an injunction, although binding for the parties such an injunction will not be acquitted by a court (and does not render a sentence). (ii) for an interim safeguard measure for one of the following issues: – In the absence of explicit provisions (such as those adopted in Hong Kong and Singapore), it is up to the national courts to decide whether an emergency arbitrator`s decision, whether in the form or arbitral award or order, is binding. Similarly, the question of whether the interim protection granted by an emergency arbitrator is enforceable in the same way as the order for reference ordered by the Material Tribunal also remains a living one. Let us take the United States as an example of the flood mark; In general, U.S. courts have adopted the same approach to emergency arbitration decisions as to interim measures adopted by the Hardware Arbitration Tribunal (see.B. Yahoo! against Microsoft Corporation, 983 F.

Supp. 2d 310 (S.D.N.Y. 2013). However, the biggest problem for users is that, in many legal systems, there have been few or too few court decisions to reliably predict how emergency arbitrators` decisions are handled. (a) the preservation, pre-trial detention or sale of goods subject to the arbitration agreement; In international trade arbitrations, the main mechanisms of application are the 1958 United Nations Convention on the Recognition and Enforcement of Foreign Arbitration Awards (the New York Convention) and applicable national arbitration laws, many of which are based on UNCITRAL`s model law on international commercial arbitration (The Model Law). The amended model law provides some useful clarification. But that doesn`t solve all the problems perfectly.

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