Franz Haas Gmbh Srl v. Winebow Inc.

CourtCourt of Appeals for the Ninth Circuit
DecidedMarch 26, 2026
Docket25-4105
StatusUnpublished

This text of Franz Haas Gmbh Srl v. Winebow Inc. (Franz Haas Gmbh Srl v. Winebow Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Ninth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Franz Haas Gmbh Srl v. Winebow Inc., (9th Cir. 2026).

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAR 26 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

FRANZ HAAS GMBH SRL, No. 25-4105 D.C. No. Petitioner - Appellee, 2:24-cv-10146-JLS-AJR v. MEMORANDUM*

WINEBOW INC., a Delaware corporation,

Respondent - Appellant.

Appeal from the United States District Court for the Central District of California Josephine L. Staton, District Judge, Presiding

Argued and Submitted March 5, 2026 Phoenix, Arizona

Before: HAWKINS, BYBEE, and FRIEDLAND, Circuit Judges.

Winebow Inc. appeals the district court’s order confirming a foreign

arbitration award in Franz Haas GmbH srl’s favor. Under the Federal Arbitration

Act (FAA), a district court “shall confirm the award unless it finds one of the grounds

for refusal or deferral of recognition or enforcement of the award specified in the . . .

Convention.” 9 U.S.C. § 207 (emphasis added). Article V of the New York

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. Convention provides the exclusive grounds on which a court may refuse to confirm

a foreign arbitral award, and those “defenses are construed narrowly.” United

Nations Convention on the Recognition and Enforcement of Foreign Arbitral

Awards, art. V, June 10, 1958, 21 U.S.T. 2517, 330 U.N.T.S. 3 [hereinafter N.Y.

Convention]; Ministry of Def. & Support for the Armed Forces of the Islamic

Republic of Iran v. Cubic Def. Sys., 665 F.3d 1091, 1095–96 (9th Cir. 2011). But

Winebow does not invoke a defense under Article V. Instead, Winebow argues only

that confirmation was improper due to an initial minor procedural violation, which

was quickly cured and caused no prejudice, and a single, nonmaterial translation

error. We have jurisdiction under 9 U.S.C. § 16(a)(1)(D), and we affirm.

1. Winebow first argues that confirmation was barred because Franz Haas’s

original petition did not include a copy of the parties’ arbitration agreement as

required by Article IV(1)(b) of the New York Convention. The New York

Convention requires a party seeking confirmation of a foreign arbitration award to

provide “at the time of the application” the original or a duly certified copy of the

arbitration agreement and the award. N.Y. Convention, art. IV(1)(b). Although

Franz Haas’s initial petition did not attach a copy of the agreement, with leave of the

district court, Franz Haas promptly filed a corrected petition attaching a certified

copy of the agreement.

2 25-4105 There was never any doubt that the parties had agreed to arbitrate: Winebow

does not deny that the parties had an arbitration agreement; it contends only that the

initial petition failed to attach it. Cf. Al-Qarqani v. Chevron Corp., 8 F.4th 1018,

1024–26 (9th Cir. 2021). And for the brief delay before Franz Haas cured the

omission, Winebow identifies no prejudice. See Glencore Grain Rotterdam B.V. v.

Shivnath Rai Harnarain Co., 284 F.3d 1114, 1120 (9th Cir. 2002) (“The Convention

and its implementing legislation have a pro-enforcement bias.”); see also Scherk v.

Alberto-Culver Co., 417 U.S. 506, 520 n.15 (1974).

Winebow’s argument sounds in the empty formalism that U.S. courts have

long rejected. Nothing in the FAA, the New York Convention, or the Federal Rules

prohibited the district court from allowing Franz Haas to cure the omission through

an amended, operative application. A confirmation petition is treated procedurally

as a motion rather than a pleading. See 9 U.S.C. § 6 (an application to confirm is

made and heard “in the manner provided by law for the making and hearing of

motions”); Fed. R. Civ. P. 81(a)(6)(B); Voltage Pictures, LLC v. Gussi, S.A. de C.V.,

92 F.4th 815, 825–26 (9th Cir. 2024). Given the latitude under the Federal Rules

and the discretion afforded district courts in addressing motions, an amended petition

curing the defect was permissible. District courts routinely permit amendments to

pleadings when the opposing party would not suffer any prejudice. Fed. R. Civ. P.

15(a); Eminence Cap., LLC v. Aspeon, Inc., 316 F.3d 1048, 1052 (9th Cir. 2003)

3 25-4105 (“Absent prejudice, . . . there exists a presumption . . . in favor of granting leave to

amend.” (emphasis omitted)). Winebow’s contrary argument is baseless.

2. Winebow also contends that the petition failed to satisfy Article IV because

the translations of the award and arbitration agreement contained “significant flaws.”

When, as here, the arbitral award or arbitration agreement is not in the forum’s

official language, Article IV(2) requires the petitioner to “produce a translation of

[the award and arbitration agreement]” that “shall be certified by an official or sworn

translator or by a diplomatic or consular agent.” N.Y. Convention art. IV(2).

Consistent with Article IV’s requirements, Franz Haas’s amended petition included

a translation of the entire arbitration award, accompanied by a separate signed and

notarized declaration from the translator; a certified translation of the parties’

agreement to arbitrate; and an uncertified translation of the entire supply contract

containing the arbitration agreement. The translations are easily readable and readily

intelligible to any English-speaking reader.

For all its rhetoric, Winebow identifies only one concrete translation error: a

phrase rendered as the “Rules of Arbitrariness” instead of the “Rules of Arbitration.”

But this single typographical error is obvious and does not meaningfully impair the

comprehensibility of the translation. Winebow also gestures broadly to

“unexplained pages and marks in a foreign language” and insists that the award

“remains riddled with foreign language words” yet identifies only one non-English

4 25-4105 phrase: “pactum renovandi.” That phrase is a Latin term of art that the award itself

defines as “a cyclical renewal of the relationship.”

Winebow makes no attempt to identify prejudice from the alleged translation

defects, nor does it contend that it was unable to read or understand the documents.

Winebow’s insinuations that a 125-page translation is incomprehensible or that the

court would need to become fluent in Italian or Latin because of the scattered use of

a defined term of art are frivolous. Sophisticated litigants should know better than

to waste the court’s or opposing party’s resources on spurious arguments.

3. We also deny Winebow’s motion to supplement the record. “Save in

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