On 30 December 2005 Green Pacific A/S, a Norwegian company, bareboat chartered the vessel Pacific Chukotka, registered in Malta, to Intertransport Company LLC, a Russian company, who sub-chartered the vessel to Emerald Reefer Lines Ltd (“ERL”), a Cayman Islands company. On 2 August 2006 ERL’s agent ordered a supply of bunkers for the vessel to be delivered in Odessa. The bunkers were to be supplied by Triton Marine Fuels Ltd (“Triton”), a Panamanian corporation and the order was sent to Triton’s agent in Canada (“Triton Canada”). Triton Canada sent a confirmation (“Bunker Confirmation”) to ERL. The Bunker Confirmation stated “This agreement shall be governed and construed in all particulars by the laws of the United States of America, and the parties hereby agree to the jurisdiction of the United States District Courts.”