Summary

MILLETT, Circuit Judge: In 2001, China and Nigeria signed a bilateral investment treaty to encourage investment between the two countries. As part of that bargain, each country agreed to treat the other country's investors fairly and to protect their investments. The treaty also provided that the countries would arbitrate any disputes with foreign investors.

Appellant Zhongshan Fucheng Industrial Investment then invested in Nigeria, participating in a joint venture with Ogun State, a Nigerian state, to develop a free-trade zone. After years of development and millions of dollars in investments, Ogun State abruptly ended its relationship with Zhongshan, and Nigerian federal authorities ousted the company's executives from the country. Zhongshan initiated arbitration proceedings. An arbitrator found that Nigeria had breached its obligations under the bilateral investment treaty and awarded Zhongshan over $55 million in damages.

Zhongshan now seeks to enforce that arbitral award against Nigeria. The district court held that it had jurisdiction over this case, finding that the Foreign Sovereign Immunities Act's arbitration exception applied because the award is governed by an international arbitration treaty known as the New York Convention.

We affirm.