The U.S. Court of Appeals for the Eleventh Circuit concluded that questions of arbitral venue, including those arising in international arbitration, are presumptively for the arbitrator to decide.  Bamberger Rosenheim, Ltd. V. OA Dev., Inc., 862 F.3d 1284 (11th Cir. July 17, 2017) (No. 16-16163).  Agreeing with at least four other circuits, the court held that disputes over interpretation of forum selection clauses in arbitration agreements raise presumptively arbitrable procedural questions, because such clauses determine where an arbitration is conducted, not whether there is a contractual duty to arbitrate at all.