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The MSA called for arbitration in Florida which proceeding would be subject to Texas’ substantive law. A Florida arbitrator eventually found in favor of Timberline and High Voltage, awarding them damages and fees. The subcontractors demanded arbitration in Florida of the dispute arising over non-payment through the American Arbitration Association. Sayers eventually stopped paying its invoices, so Timberline and High Voltage stopped performing work. Sayers then paid the subcontractors within 45 days of receiving an invoice. After completing work, Timberline and High Voltage sent invoices to Sayers in Texas. Pursuant to the MSA, Timberline and High Voltage picked up work orders from Sayers at its Florida offices and then performed fieldwork in Florida on this project. The parties entered into a Master Services Agreement (MSA). Sayers Construction was hired to work on electrical utility lines in Florida. Sayers then hired Timberline Construction, Inc., a South Dakota corporation, and High Voltage, Inc., a Utah corporation, as subcontractors on the project. Timberline Construction, Inc., the United States Court of Appeals for the Fifth Circuit considered the impact of personal jurisdiction upon a court’s authority to review an arbitration award. The Court determined that the award could not be ruled upon because of the lack of personal jurisdiction as to two of the parties to the arbitration, in the process highlighting the necessity of satisfying both subject matter jurisdiction and personal jurisdiction when seeking review of an award under the Federal Arbitration Act. In its recent decision in Sayers Construction, L.L.C.