On 15 April 2005 the claimant, a German shipbuilding company, entered into a contract (“the Construction Contract”) with the defendant, an American citizen resident in the State of Florida, for the construction by the claimant of a 20m motor yacht for an adjustable price of €48m. The Construction Contract contained a London arbitration clause and expressly provided that, save as to matters relating to title within Germany, the pre delivery mortgage and registration with the German shipbuilding register, the Construction Contract was to be governed by English law.