1. Where an arbitrator and opposing counsel fail to disclose significant connections, does a party just have to show the "reasonable impression" of bias to have the award vacated as the Seventh, Eighth, Ninth, Tenth, and Eleventh Circuits have held, or must the party make a more concrete showing as required by the First, Second, Third, Fourth, Fifth, and Sixth Circuits?

2. Should the party seeking vacatur at least be permitted to conduct limited discovery into the undisclosed connections prior to the award being confirmed?

Where an arbitrator and opposing counsel fail to disclose significant connections, does a party just have to show the 'reasonable impression' of bias to have the award vacated