An employer’s objection that an employee failed to deliver a formally compliant certificate of earnout dispute, and therefore did not satisfy a prerequisite for initiating an arbitration, raised a procedural question that should be decided by the arbitrator, not the court.  Weiner v. Milliken Design, Inc., C.A. No. 9671-VCP, 2015 WL 401705 (Del. Ch. Jan. 30, 2015).  The court found that the employer’s objection did not rise to the level of disputing substantive arbitrability, which concerns the threshold question of whether the parties agreed to arbitrate, and which is presumptively an issue for resolution by the court.  Procedural arbitrability questions, including whether conditions precedent to an obligation to arbitrate have been met, must be decided by the arbitrator.