Gallup, Inc. v. Marketing Research Solutions S.A.

At a glance

Parties

Gallup, Inc. (petitioner) v. Marketing Research Solutions S.A. (respondent)

Case no.

Civil Action No. 26-00840 (AHA), U.S. District Court for the District of Columbia

Court

United States District Court for the District of Columbia, Judge Amir H. Ali

Underlying award(s)

Arbitral award in favour of Gallup for the contract refund plus arbitration costs, payable by 8 February 2025

Forum and rules

Petition to confirm under the New York Convention and 9 U.S.C. §§ 201, 207; default judgment under Fed. R. Civ. P. 55(b)(2)

Sector

Market research and public polling

Outcome

Default judgment granted and arbitral award confirmed (6 November 2026).

Amount

USD 156,151.75, plus post-award interest at 6% a year from 9 February 2025 and post-judgment interest under 28 U.S.C. § 1961.

The dispute

In 2022, Gallup, Inc. contracted with Marketing Research Solutions S.A. to carry out public polling across Central America and paid it $150,651.75. Marketing Research Solutions did not do the work. In 2023 it admitted this and agreed to refund the full amount, but it never paid. Gallup started arbitration. With Marketing Research Solutions' express consent, the arbitrator awarded Gallup the full amount plus arbitration costs, payable by 8 February 2025. Gallup then petitioned the District Court for the District of Columbia to confirm the award under the New York Convention. Marketing Research Solutions waived service but did not appear, and the clerk entered default.

Key holdings

1. Default judgment is appropriate. Marketing Research Solutions is an essentially unresponsive party: it did not ask to set aside the default and did not suggest it had a meritorious defence. p. 4
2. None of the grounds for refusal in Article V of the New York Convention applies. The arbitration followed the terms of the parties' valid contract, and both parties took part. Marketing Research Solutions consented to the award. A contract dispute can be settled by arbitration, and confirming the award is not contrary to U.S. public policy. p. 3
3. Damages are adequately supported. The court awards $156,151.75 (the refund plus arbitration costs). Post-award interest runs from 9 February 2025 at the D.C. legal rate of 6% a year, compounded annually (D.C. Code § 28-3302(a)). p. 4
4. A judgment confirming an arbitration award is subject to 28 U.S.C. § 1961. Post-judgment interest is therefore awarded on the total judgment amount at the statutory rate. Gallup is to file a proposed judgment. pp. 4–5

Procedural history

1. 2022Gallup contracts with Marketing Research Solutions for polling in Central America and pays $150,651.75.
2. 2023Marketing Research Solutions admits it did not perform the work and agrees to refund the amount, but does not pay.
3. 8 February 2025Deadline for payment set in the arbitral award, which was rendered with the respondent's consent.
4. 2026Gallup petitions to confirm the award. The respondent waives service and does not appear. The clerk enters default, and Gallup moves for default judgment.
5. 6 November 2026Memorandum Opinion and Order: default judgment granted and award confirmed.

Tribunal, counsel and experts

Decided by

• Amir H. Ali Judge, United States District Court for the District of Columbia

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Keywords

• Gallup
• New York Convention
• confirmation of arbitral award
• recognition and enforcement
• default judgment
• Rule 55
• 9 U.S.C. § 207
• Article V
• consent award
• public polling
• market research
• post-award interest
• post-judgment interest
• 28 U.S.C. § 1961
• D.C. legal rate of interest
• Central America

Summary generated with AI from the published documents — refer to the award for the authoritative text.