TROTT, Circuit Judge.
Glencore Grain Rotterdam B.V. ("Glencore Grain") filed an application in the district court under the Convention on the Recognition and Enforcement of Foreign Arbitral Awards ("Convention") for an order confirming its arbitration award against Shivnath Rai Harnarain Company ("Shivnath Rai"). On Shivnath Rai's motion, the district court dismissed Glencore Grain's application for lack of personal jurisdiction.
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