For decades, it has been a basic principle of U.S. admiralty law that contracts for the sale of a vessel are not within the maritime jurisdiction.3 While the principle has been criticized,4 nonetheless it is still considered black letter law. In a decision issued last week, a judge of the U.S. District Court for the Southern District of New York, the Honorable Shira A. In Kalafrana, an aspect of the sales agreement concerned repairs to the vessel. A dispute over the repairs led to a arbitration and award. The New York Rule B action was based on the award. While Judge Scheindlin certainly recognized and acknowledged the traditional precedent, the Court held that more recent U.S.